ML16141A372

Annual Radioactive Effluent Release Report

ML16141A372
Person / Time
Site:	Surry
Issue date:	05/02/2016
From:	Lawrence D Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
16-164
Download: ML16141A372 (185)

Text

{{#Wiki_filter:VIRGINIA ELECTRIC AND POWER COMP.ANY RICHMOND, VIRGINIA 23261 May 2, 2016 United States Nuclear Regulatory Commission Serial No. 16-164 Attention: Document Control Desk SS&LffSC RO Washington, DC 20555-0001 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Enclosed is the Surry Power Station Annual Radioactive Effluent Release Report for January 1, 2015 through December 31, 2015. The report, submitted pursuant to Surry Power Station Technical Specification 6.6.B.3, includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released during the 2015 ---

• calendar year, as outlined in Regulatory Guide 1.21, Revision 1, June 1974.

If you have any further questions, please contact Jason Eggart at 757-365-2010. Douglas . Lawrence Director Safety & Licensing Surry Power Station Attachment Commitments made in this letter: None cc: U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station

Serial No. 16-164 SPS Annual Rad Effluent Report Docket Nos.: 50-280,'50-281 ATTACHMENT 1 2015 Annual Radioactive Effluent Release Report SURRY POWER STATION UNITS 1AND2 VIRGINIA ELECTRIC AND POWER COMPANY

Surry Power Station 2015 Annual Radioactive Effluent Release Report

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SURRY POWER STATION

          . January 1, 2015 through December 31, 2015 Prepared By: _    ___,__/?_.f..___._~----1-{-~

__ -:f-_ ___ P. F. Blount Health Physicist Reviewed By: ----'°-7_0 __._A_L_~_,__ P.R. Harris __* ______ Supervisor Radiological Analysis Reviewed By: ---~,___ _____ C__/-~_:::::::::=r::::--""'-_,__ _ _ _ __ w:ATuIT{Z.~ Supervisor Health Physics Technical Services ApprovedBy: ~ *~ 1J f_,,h4

                    -UJ.W.Eg~~

Manager Radiological Protection and Chemistry

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE SURRY POWER STATION January l, 2015 through December 31, 2015 Section No. Subject 1 Executive Summary 1 2 Purpose and Scope 3 Discussion 3 4 Supplemental Information 4 Attachment 1 Effluent Release Data Attaclup.ent 2 Annual and Quarterly Doses

• Attachment 3 Revisions to Offsite Dose Calculation Manual (ODCM)

Attachment 4 Major Changes to Radioactive Liquid, Gaseous and Solid Waste Treatment Systems Attachment 5 Inoperability of Radioactive Liquid and Gaseous Effluent Monitoring Instrumentation

• Attachment 6 Unplanned Releases Attachment'? Lower Limit of Detection (LLD) for Effluent Sample Analysis Attachment 8 Industry Ground Water Protection Initiative

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

EXECUTIVE

SUMMARY

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Annual Radioactive Effluent Release Report describes the radiological effluent control program conducted at Surry Power Station during the 2015 calendar year. This document summarizes the quantities of radioactive liquid and gaseous effluents and solid waste released from Surry Power Station in accordance with Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants", Revision 1, June 1974. The report also includes an assessment of radiation doses to the maximum exposed member of the public due to the radioactive liquid and gaseous effluents. During this reporting period, there were no unplanned liquid or gaseous effluent releases as classified according to the criteria in the Offsite Dose Calculation Manual. Based on the 2015 effluent release data, IOCFR50 Appendix I dose calculations were performed in accordance with the Offsite Dose Calculation Manual. The dose calculations are as follows:

1. The total body dose due to liquid effluents was 3.43E-04 mrem, which is 5.72-03% of the 6 mrem dose limit. The critical organ doses due to liquid effluents, GI-LLI and Liver respectively, were 1.0SE-03 mrem and 2.96E-04 mrem. These doses are 5.40E-03% and 1.48E-03% of the respective 20 mrem dose limit.

     . 2. The air dose due to noble gases in gaseous effluents was 5.05E-05 mrad gamma, which is 2.53E-04% of the 20 mrad gamma dose limit, and l .33E-04 mrad beta, which is 3.33E-04% of the 40 mrad beta dose limit.

3. The critical organ dose from gaseous effluents due to I-131, I-133, H-3, and particulates with half-lives greater than 8 days is 1.0SE-01 mrem, which is 3.60E-01 % of the 30 mrem dose limit.

There were no major changes to the radioactive liquid, gaseous or solid waste treatment systems during this reporting period. There were two changes made to VPAP-2103S, Offsite Dose Calculation Manual, during this reporting period. Attachment 3 provides the changes to VPAP-2103S. In accordance with the Nuclear Energy Institute (NEI) Industry Ground Water Protection Initiative, analysis results of ground water monitoring locations not included in the Radiological Environmental Monitoring Program (REMP), will be included in this report. Ground water monitoring well sample results are provided in Attachment 8. 1

Based on the radioactivity measured and the dose calculations performed during this reporting period, the operation of Surry Power Station has resulted in negligible radiation dose consequences to the maximum exposed member of the public in unrestricted areas. Purpose and Scope includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste as outlined in Regulatory Guide 1.21, with data summarized on a quarterly or annual basis following the format of Tables 1, 2 and 3 of Appendix B, thereof. Attachment 2 of this report includes an assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site during 2015. As required by Technical Specification 6.8.B, changes to the Offsite Dose Calculation Manual (ODCM) for the time period covered by this report are included in Attachment 3. Major changes to the radioactive liquid, gaseous and solid waste treatment systems are reported in Attachment 4, as required by the ODCM, Section 6.7.2. If changes are made to these systems, the report shall include information to support the reason for the change and a summary of the 1OCFR50.59 evaluation. In lieu of reporting major changes in this report, major changes to the radioactive waste treatment systems may be submitted as part of the annual FSAR update. As required by the ODCM, Sections 6.2.2 and 6.3.2, a list and explanation for the inoperability of radioactive liquid and/or gaseous effluent monitoring instrumentation is provided in Attachment 5 of this report. Additionally, a list of unplanned releases during the reporting period is included in . provides the typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation. As required by the ODCM, Section 6.7.5, a summary of on-site radioactive spills or leaks that were communicated in accordance with the Industry Ground Water Protection Initiative reporting protocol, and sample analyses from ground water wells that are not part of the Radiological Environmental Monitoring Program are provided in Attachment 8. In 2015, no on-site radioactive spills or leaks were communicated in accordance with the Industry Ground Water Protection Initiative. 2

Discussion The basis for the calculation of the percent of technical specification for the critical organ in Table lA of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for iodine-131, iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days shall be less than or equal to 1500 mrem/yr to the critical organ at or beyond the site boundary. The critical receptor was the child for the first two quarters, the teen for the last two quarters; both via the inhalation pathway. The basis for the calculation of the percent of technical specification for the total body and skin in Table lA of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for noble gases to areas at or beyond site boundary shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin. The basis for the calculation of the percent of technical specification in: Table 2A of Attachment 1 is the ODCM, Section 6.2.1, which states that the concentration of radioactive material released in liquid effluents to unrestricted areas shall not exceed ten times the concentrations specified in 1OCFR20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.00E-04 microcuries/mL. Percent of technical specification calculations are based on the total gaseous or liquid effluents released for the respective quarter. The annual and quarterly doses, as reported in Attachment 2, were calculated according to the methodology presented in the ODCM. The beta and gamma air doses due to noble gases released from the site were calculated at the site boundary. The maximum exposed member of the public from the release of airborne iodine-131, iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days, was a child at 2.05 miles with the critical organ being the bone via the ingestion pathway. The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas was an adult, exposed by either the invertebrate or fish pathway, with the critical organ typically being the gastrointestinal-lower large intestine. The total body dose was also determined for this individual. Presented in Attachment 6 is a list of unplanned gaseous and liquid releases as required by the ODCM, Section 6.7.2. The typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation are presented in Attachment 7. These LLD values are based upon conservative conditions (i.e., minimum sample volumes and maximurri delay time prior to analysis). Actual LLD values may be lower. If a radioisotope was not detected when effluent samples were analyzed, then the activity of the radioisotope was reported as Not Detected (N/D) on Attachment 1 of this report. When all isotopes listed on Attachment 1 for a particular quarter and release mode are less than the lower limit of detection, then the totals for this period will be designated as Not Applicable (NIA). 3

Supplemental Information Section 6.6.1 of the ODCM requires the identification of the cause(s) for the unavailability of milk, or if required, leafy vegetation samples, and the identification for obtaining replacement samples. As milk was available for collection during this reporting period, leafy vegetation sampling was not required. As required by the ODCM, Section 6.6.2, evaluation of the Land Use Census is made to determine if new sample location(s) must be added to the Radiological Environmental Monitoring Program. Evaluation of the Land Use Census conducted for this reporting period identified no change in sample locations for the Radiological Environmental Monitoring Program. 4

• Attachment 1 EFFLUENT RELEASE DATA January 1, 2015 through December 31, 2015 This attachment includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste as outlined in Regulatory Guide 1.21, Appendix B.

Attachment 1 TABLE lA Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST.ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE Ci l.25E-02 6.49E-Ol 1.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec l.60E-03 8.25E-02 B. IODINE I. TOTAL I-13 1 Ci N/D N/D 2.80E+Ol

2. *AVE RELEASE RA TE FOR PERIOD µCi/sec NIA NIA C. PARTICULATE I. HALF-LIFE >8 DAYS Ci N/D 2.65E-05 2.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec NIA 3.37E-06

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

1. TOTAL RELEASE Ci 8.34E+OO l.04E+Ol 3.lOE+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec l.07E+OO l.32E+OO E. CARBON-14

1. TOTAL RELEASE Ci . l .42E-Ol 7.39E+OO

2. A VE RELEASE RA TE FOR PERIOD µCi/sec l.83E-02 9.40E-Ol PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RA TE  % l.62E-03 l.32E-02 TOTAL BODY DOSE RATE  % 2.44E-08 3.12E-05 SKIN DOSE RA TE  % 9.63E-09 l .20E-05

Attachment 1 TABLE lA Page 2of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST. ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE Ci 2.24E-Ol 4.SOE-01 l.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec 2.82E-02 6.04E-02 B. IODINE

1. TOTAL I-131 Ci N/D N/D 2.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec NIA NIA C. PARTICULATE

1. HALF-LIFE >8 DAYS Ci 4.93E-06 7.15E-06 2.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec 6.20E-07 9.00E-07

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

1. TOTAL RELEASE Ci 4.42E+OO 8.43E+OO 3.lOE+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec 5.55E-Ol 1.06E+OO E. CARBON-14

1. TOTAL RELEASE Ci 2.56E+OO 5.47E+OO

2. AVE RELEASE RATE FOR PERIOD µCi/sec 3.22E-Ol 6.96E-01 PERCENT AGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % 8.45E-04 1.65E-03 TOTAL BODY DOSE RA TE  % 1.73E-06 3.54E-06 SKIN DOSE RA TE  % 5.29E-07 l.OSE-06

Attachment 1 TABLE 1B Page3of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENTS-MIXED MODE RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND FIRST SECOND QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES .

Kr-85 Ci NID NID NID NID Kr-85m Ci NID NID NID l.30E-03 Kr-87 Ci NID NID NID NID Kr-88 Ci NID NID NID NID Xe-133 Ci 1.03E-02 NID 2.16E-03 3.69E-Ol Xe-135 Ci NID NID NID 6.21E-02 Xe-135m Ci NID NID NID NID Xe-138 Ci NID NID NID NID Xe-13 lm Ci NID NID NID N/D Xe-133m Ci NID NID NID 4.39E-03 Ar-41 Ci NID NID NID 3.45E-03 TOT AL FOR PERIOD Ci NIA NIA 2.16E-03 4.40E-01

2. IODINES 1-131 Ci NID N/D NID NID I-133 Ci NID N/D NID NID I-135 Ci NID NID NID NID TOTAL FOR PERIOD Ci NIA NIA NIA NIA

3. PARTICULATES Sr-89 Ci NID NID NID NID Sr-90 Ci NID NID NID NID Cs-134 Ci NID NID NID NID Cs-137 Ci NID 2.43E-05 NID N/D Ba-140 Ci NID NID NID NID La-140 Ci NID NID NID NID Co-58 Ci NID 2.12E-06 NID NID Co-60 Ci NID NID NID NID Mn-54 Ci NID NID NID NID Fe-59 Ci. NID NID NID NID Zn-65 Ci NID N/D NID NID Mo-99 Ci NID NID NID NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID NID NID C-14 Ci 1.17E-Ol NID 2.46E-02 5.02E+OO TOT AL FOR PERIOD Ci 1.17E-Ol 2.64E-05 2.46E-02 5.02E+OO

Attachment 1 TABLE 1B Page 4of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENTS-MIXED MODE RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D NID Kr-85m Ci N/D N/D 5.81E-04 6.44E-04 Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D NID Xe-133 Ci N/D N/D l.84E-01 4.38E-01 Xe-135 Ci N/D N/D 3.50E-02 2.83E-02 Xe-135m Ci N/D N/D N/D N/D Xe-138 Ci N/D N/D N/D N/D Xe-131m Ci N/D N/D N/D N/D Xe-133m Ci N/D NID 2.93E-03 7.66E-03 Ar-41 Ci NID NID 9.00E-04 4.16E-03 TOTAL FOR PERIOD Ci NIA NIA 2.24E-01 . 4.79E-01

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

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D NID Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci N/D N/D N/D N/D Ba-140 Ci N/D N/D N/D N/D La-140 Ci N/D N/D N/D N/D Co-58 Ci N/D N/D N/D N/D Co-60 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D N/D NID Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99 Ci N/D NID N/D N/D Ce-141 Ci N/D N/D N/D NID Ce-144 Ci NID NID N/D N/D C-14 Ci N/D N/D 2.55E+OO 5.46E+OO TOTAL FOR PERIOD Ci NIA NIA 2.55E+OO 5.46E+OO

Attachment 1 TABLElC Page 5 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND FIRST SECOND

                                              .QUARTER        QUARTER      QUARTER    QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci NID N/D N/D NID Kr-85m Ci N/D N/D N/D NID Kr-87 Ci. NID NID N/D NID Kr-88 Ci . NID N/D N/D NID Xe-133 Ci NID NID NID 2.08E-01 Xe-135 Ci NID NID NID NID Xe-135m Ci NID NID N/D NID Xe-138 Ci N/D NID NID NID Xe-13 lm Ci NID NID NID NID Xe-133m Ci NID NID NID N/D Ar-41 Ci NID 3.61E-04 NID NID TOTAL FOR PERIOD Ci NIA 3.61E-04 NIA 2.08E-01

2. IODINES I-131 Ci NID N'/D Nib NID 1-133 Ci NID NID NID N/D.

I-135 Ci NID NID N/D NID TOTAL FOR PERIOD Ci NIA NIA NIA NIA

3. PARTICULATES Sr-89 Ci NID NID NID NID Sr~9o Ci NID N/D N/D NID Cs-134 Ci N/D N/D NID N/D Cs-137 Ci NID 2.43E-05 N/D NID Ba-140 Ci NID NID NID NID La-140 Ci NID NID NID NID Co-58 Ci . NID 2.12E-06 NID NID

• Co-60 Ci NID NID NID NID Mn-54 Ci N/D NID NID . NID Fe-59 Ci N/D NID NID NID Zn-65 Ci NID NID NID NID Mo-99 Ci NID NID NID NID Ce-141 Ci N/D N/D NID NID Ce-144 Ci NID NID NID NID C-14 Ci N/D 4. l lE-03 NID 2.37E+OO TOTAL FOR PERIOD Ci NIA 4.14E-03 NA 2.37E+OO

Attachment 1 TABLElC Page 6of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 111115 TO 12/31115 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT. THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci NID N/D NID NID Kr-85m Ci N/D l.76E-06 N/D N/D Kr-87 Ci N/D l.66E-06 N/D N/D Kr-88 Ci N/D 3.14E-06 N/D NID Xe-133 Ci* NID 1.45E-05 N/D 5.66E-04 Xe-135 Ci NID 2.28E-05 N/D N/D Xe-135m Ci NID 4.26E-06 N/D NID Xe-138 Ci N/D N/D NID N/D Xe-13lm Ci N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D N/D Ar-41 Ci 2.25E-04 4.93E-04 N/D N/D TOTAL FOR PERIOD Ci 2.25E-04 5.40E-04 NIA 5.66E-04

2. IODINES I-131 Ci N/D N/D N/D N/D I-132 Ci N/D l.31E-03 N/D N/D I-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA l.3 IE-03 NIA NIA

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D NID Cs-134 Ci NID N/D N/D NID Cs-137 Ci NID N/D N/D N/D Ba-140 Ci NID NID NID N/D La-140 Ci N/D NID N/D N/D Co-58 Ci 4.93E-06 6.89E-06 N/D 2.12E-07 Co-60 Ci N/D N/D N/D 5.03E-08 Mn-54 Ci N/D NID N/D NID Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci NID N/D NID NID Mo-99 Ci NID N/D N/D NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID NID N/D C-14 Ci 2.56E-03 6.15E-03 N/D 6.45E-03 TOTAL FOR PERIOD Ci 2.56E-03 6.16E-03 NA 6.45E-03

Attachment 1 TABLE2A Page 7of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12131/15 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST. ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci 5.03E-03 7.19E-03 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCilmL 7.91E-12 l.20E-l l

3. PERCENT OF APPLICABLE LIMIT  % 2.65E-05 4.15E-05 B. TRITIUM

1. TOT AL RELEASE Ci 3.13E+02 2.87E+02 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCi/mL 4.93E-07 4.77E-07

3. PERCENT OF APPLICABLE LIMIT  % 4.93E-03 4.77E-03 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci NID NID 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCilmL NIA NIA

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

1. TOT AL RELEASE Ci N/D N/D 2.00E+Ol E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.48E+07 5.33E+07 3.00E+OO F. VOLUME OF DILUTION WATER I USED DURING PERIOD LITERS 6.36E+ 11 6.0lE+ll 3.00E+OO

Attachment I TABLE2A Page 8of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST. ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOT AL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci l.36E-02 2.37E-02 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCi/mL l.73E-11 4.36E-11

3. PERCENT OF APPLICABLE LIMIT  % 2.76E-05 9.68E-05 B. TRITIUM

1. TOTAL RELEASE Ci 3.35E+02 2.52E+02 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCi/mL 4.27E-07 4.63E-07

3. PERCENT OF APPLICABLE LIMIT  % 4.27E-03 4.63E-03 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci 4.67E-06 N/D 2.00E+Ol

2. A VE DIL. CONC .. DURING PERIOD µCi/mL 5.95E-15 NIA

3. PERCENT OF APPLICABLE LIMIT  % 2.98E-09 NIA D. GROSS ALPHA RADIOACTIVITY I. TOTAL RELEASE Ci NID NID 2.00E+Ol E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.61E+07 5.46E+07 3.00E+OO F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 7.84E+ 11 5.44E+l 1 3.00E+OO I

Attachment 1 TABLE2B

• Page 9of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 LIQUID EFFLUENTS CONTINUOUS MODE BATCHMOJ:?E SURRY POWER STATION UNITS 1&2 UNIT F~RST SECOND FIRST .SECOND QUARTER QUARTER QUARTER QUARTER Sr-89 Ci N/D N/D N/D NID Sr-90 Ci N!D N/D N/D NID Fe-55 Ci N!D N/D N/D NID Cs-134 Ci N/D NID N/D NID Cs-137 Ci 4.16E-04 3.43E-04 7.93E-06 6.26E-05 I-131 Ci N/D N/D N/D l.14E-05 Co-58 Ci N/D NID 5.29E-04 5.0lE-04 Co-60 Ci N/D N/D 3.66E-03 6.14E-03 Fe-59 Ci N/D N!D N/D NID Zn-65 Ci N/D NID NID NID Mn-54 Ci N/D NID N/D 5.26E-05 Cr-51 Ci N/D NID NID NID Zr-95 Ci N/D NID N/D N/D Nb-95 Ci N!D NID N/D NID Mo-99 Ci N/D N/D N/D NID Tc-99m Ci N/D NID N/D NID Ba-140 Ci NID NID N/D NID La-140 Ci N/D N/D N/D NID Ce-141 Ci NID NID N/D NID Ce-144 Ci N!D NID N!D NID Sb-124 Ci NID NID N/D NID Sb-125 Ci N/D NID 4.17E-04 8.35E-05 Co-57 Ci N/D NID N/D NID TOTAL FOR PERIOD Ci 4.16E-04 3.43E-04 4.61E-03 6.85E-03 Xe-133 Ci N/D N/D N/D N!D I Xe-135 Ci N/D N!D N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA NIA

Attachment 1 TABLE2B Page 10of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 LIQUID EFFLUENTS CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D NID NID Fe-55 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci l .97E-04 2.19E-04 5.18E-05 2.17E-05 1-131 Ci N/D N/D N/D N/D Co-58 Ci N/D NID 1.17E-03 2.09E-03 Co-60 Ci N/D NID 4.94E-03 l.41E-02 Fe-59 Ci N/D N/D NID N/D Zn-65 Ci NID NID N/D NID Mn-54 Ci NID NID 1.18E-05 2.07E-04 Cr-51 Ci NID NID 8.41E-04 . 7.20E-04 Zr-95 Ci NID NID NID NID Nb-95 Ci NID NID NID NID Mo-99 Ci NID NID NID NID Tc-99m Ci NID NID NID NID Ba-140 Ci NID NID N/D NID La-140 Ci NID NID NID NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID N/D *NID Sb-124 Ci NID NID l.95E-05 2.1 lE-05 Sb-125 Ci NID NID 6.36E-03 6.35E-03 Co-57 Ci NID NID NID l.97E-05 TOT AL FOR PERIOD Ci l.97E-04 2.19E-04 1.34E-02 2.35E-02 Xe-133 Ci NID NID 4.67E-06 NID Xe-135 Ci NID NID NID NID TOTAL FOR PERIOD Ci NIA NIA 4.67E-06 NIA

Attachment 1 TABLE3 Page 11 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1115 - 12/31/15 SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

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

3

a. Spent resins, filter sludges, evaporator m 2.15E+OI Note I l.OOE+Ol

                    *bottoms, etc.                                   Ci  3.41E+02                  3.00E+Ol 3

b. Dry compressible waste, contaminated m 5.36E+02 Note2 1.00E+OI equip., etc. Ci 8.59E-Ol 3.00E+Ol

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

d. Other (Waste oil) m3 8.50E-Ol Note3 l.OOE+Ol Ci l.27E-03 3.00E+Ol

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

a. Co-60  % 4.95E+Ol Ni-63  % 2.71E+Ol Fe-55  % 1.04E+Ol Co-58  % 7.68E+OO Mn-54  % l.72E+OO

b. Co-60  % 4.00E+Ol Cs-137  % 3.97E+Ol Ni-63  % l.14E+Ol Fe-55  % 4.64E+OO Co-58  % l.66E+OO

c.  %

d. Ni-63  % 8.71E+Ol Cs-137  % 7.88E+OO H-3  % l.64E+OO (based on MDA concentration)

Tc-99  % l.30E+OO (based on MDA concentration)

Attachment 1 TABLE3 Page 12of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1115 - 12/31/15 CONTINUED SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

3. Solid Waste Disposition Number of Shipments Mode of Transportation Destination 16 Truck Oak Ridge, TN (EnergySolutions) 2 Truck Erwin, TN (Energy Solutions )

Truck* Barnwell, SC (Energy Solutions) B. IRRADIATED FUEL SHIPMENT (Disposition) Number of Shipments Mode of Transportation Destination 0 NOTE 1: Some of this waste was shipped to licensed waste processors for processing and/or volume reduction. Therefore, 3 this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 9.07E+OO m . Burial volume by Erwin Resin Solutions is indeterminable due to mixing of Surry waste with other generators waste. NOTE 2: Some DAW was shipped to licensed waste processors for processing and/or volume reduction. Therefore, 3 this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 2.50E+02 m . NOTE 3: This waste was shipped to a licensed waste processor for processing and/or volume reduction. The actual 3 volume buried is indeterminable. It is conservatively assumed that 1.70E-02 m was buried this reporting period ..

Attachment 2 Page 1 of 1 ANNUAL AND QUARTERLY DOSES An assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents .released from the site for each calendar quarter for the calendar year ofthis report, along with an annual total of each effluent pathway is made pursuant to the ODCM, Section 6.7.2, requirement.

<   I LIQUID                                   GASEOUS 2015       Total Body       GI-LLI         Liver       Gamma             Beta       Bone (mrem)         (mrem)        (mrem)       (mrad)           (mrad)     (mrem) 1st Quarter    7.18E-05       1.44E-04      6.76E-05     3.62E-08        1.0SE-07    7.90E-04 2nd Quarter    8.50E-05       2.23E-04      7.63E-05     4.49E-05      . 1.28E-04    6.26E-02 3rd Quarter    6.62E-05       1.61E-04      6.03E-05     1.73E-06        2.43E-06    1.43E-02

, I 4th Quarter 1.20E-04 5.56E-04 9.16E-05 3.76E-06 4.75E-06 3.06E"'02 Annual 3.43E-04 . 1.0SE-03 2.96E-04 5.05E-05 l.33E-04 1.0SE-01 *

                                                                                                     .,

I 1 I I

Attachment 3 Page 1of1 REVISIONS TO OFFSITE DOSE CALCULATION MANUAL (ODCM) As required by Technical Specification 6.8.B, revisions to the ODCM, effective for the time period covered by this report, are included with this attachment. There were two general revision to the ODCM implemented during this reporting period. Revision 18:

• Added substep 6.6.1.b.5 addressing deviations from the Radiological Environmental Monitoring Program (REMP) sampling schedule if specimens are unattainable and requiring all deviations to be documented in the annual REMP report.
• Updated gaseous effluent dispersion and deposition factors.
• Add a garden in the SSE sector for dose assessment. This garden was idenified as a new garden location in the 2014 Land Use Census.
• Revised the description of Fish samples for the REMP to better represent the species available in the area for sampling.

Revision 19:

• Resulting from a self assessment of the REMP, the following revisions were made:

Added, as Reference 3.1.28, the Branch Technical Position,, Revision 1, November 1979 Added a footnote to Attachment 8 to clarify that a TLD station does not exist in the 4 - 5 mile range of the SE sector due to geographical limitations. This area is over the water of the James River.

• Resulting from corrective actions to Condition Report 1013104, documenting a liquid release without an operable flow rate measuring device, the following revisions were made:

Added, as Reference 3.1.29, CR1013104 On Attachment 1, revised the Action requirements for an unavailable flow rate measuring device to allow a liquid release with verification ofrelease rate at least once per 30 minutes using design capacity pump performance curves or volume released over time.

• '*
• Revised Substep 6.4.2.b to include the release of ground water wells as a contributor to the Continuous Release pathway.

                       --*--___    __:______ ._           '-.-.-.* *:__ _   -__ _;_ =-- -_-~--:_.-** I
                                                                                                                                     .. I                       I    l

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       *
       ~*Dominion"                                                                                           Administrative Procedure or Guidance and tleference DO.C1fttlentAppr9v?,/
                                                                                                                                                                       .Po..¥ I db: 7 I                                                                                                             AD-AA-101-Attachment4

• Page 1 of 1

1. Document Number.: 2. Revision: 3; Docl,!ment TYpe:

VPAP-2103.S 1-B [81 Administrative Procedure 0GARD

4. Title:

Offsite Pose Calctilatiol"l Ma,n)..1ai (Surry)

5. Requestor(s) Print Name(s) /.Locations; 6. bate  :(.'Requester Phone Heather Baer 03/30/2015 8;;798-2112.

8. Document Request

• DNew :i:8J REivisib_n [J Cancel .0 St.!pe:rsede D Te~poracy 9_. Applicable NucleaJStation(s)

Millstone D North An_na 0 Surry l8l 1o. Reason arid Bri~f Description cif Chari!le: The following changes were made in r~$porise to SAA031 ea4.

• Ad8ed .Substep 6.6.1.b.5 addressing deviations from the sainplirig s*che(j_ule ifspecimens are unattainable and requiring all deviations to be dqcumented in the . annual report For full list of changes, see Revision Sumin~ty.

11. Records Retention Requirements Affected? 12. Change Management 0 Y~s (Complet~-f\JRRS fc:ir'nl frofi:1 RM-AA-101) 181 No Attach Appropriate Pl~AA~4000 Attachm_ent(s)

13. Levefof Use:

D ' Continuous

                                    .     .            Use*
                                                        .

[)Reference Use ~ Information Use D Multiple Use Fleet Approval

14. Fleet-Approval_Required*by: (Ctieck one box only. Enter Peer-Group:Narile, if applicable)

D Peer Groll OR

• 1:8J. Fi:Jnctional Area Mana er FAM 15 .. ~rinted Approver Nam!l , 11?. Signature. 17. Date Jason W. Eg*gart 3} 3'D *,5 Site Approval

18. lrriglem~ritatiori P!'Elreqiiisites: (Items in addition to tliose listea on*oocument Traveler or Change Management Plan)

None *

• 19. lmplementatiqn Prerequisites Reviewed - Procedure Super'vi.sor SI"

21. Check Nuclear Statio"n(s) for Which Document is. bein!i Approved for Implementation.

Millstone 0 North .Anna D Sur~ 1:83

22. ~ite Apprqval (PrilitNa_nje of Ff\M) 24. :[)ate

     .,Jason* Vil. E art                                                                                                                                                  3. 3 /1";J

• 25._ Facility S~fety Reyiew- Committee Required?' -26: Fatilify. SafetY, Review Co 27. Qate

[81 No D Yes *tJ *N 2a. Site Vice Presid~mt Required? DNo [81Yes

34. Document Number.~ 35~ Revision: 37. EXpiration* Date VPAP*21-03S. 18 Ol:Ji 15 N/A .

   -Key: GARD-Guidance -and.Reference Dpcument, EDMS-:EJecfronic Document Managem_en~ System*                                                                        Form No. 72B620tocl 2014)

  'I;
  ~       Dominion Station Administrative Procedure Title: Offsite Dose Calculation Manual (Surry)

Process I Program Owner: Manager Radiological Protection and Chemistry (Surry) Procedure Number Revision Number Effective Date VPAP-2103S 18 On File Revision Summary The following changes were made in response to SAA031884.

• Added Substep 6.6.l.b.5 addressing deviations from the sampling schedule if specimens are unattainable and requiring all deviations to be documented in the annual report Additional Changes
• Updated X./Q and D/Q Factors on Attachment 7
• Added SSE Garden to Attachment 7
• Updated Ingestion, Fish and Invertebrates, d) and added Note 3 to Attachment 8 Approvals on File

DOMINION VPAP-2103S REVISION 18 PAGE20F76 TABLE OF CONTENTS Section Page 1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 10 6.0 INSTRUCTIONS 11 6.1 Sampling and Monitoring Criteria 11 6.2 Liquid Radioactive Waste Effiuents 11 i 6.2.1 Liquid Effluent Concentration Limitations 11 6.2.2 Liquid Monitoring Instrumentation 13 6.2.3 Liquid Effluent Dose Limit 16 6.2.4 Liquid Radwaste Treatment 19 6.2.5 Liquid Sampling 21 6.3 Gaseous Radioactive Waste Effiuents 21 6.3.l Gaseous Effluent Dose Rate Limitations 21 6.3.2 Gaseous Monitoring Instrumentation 24 6.3.3 Noble Gas Effluent Air Dose Limit 27 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effluent Dose Limit 28 6.3.5 Gaseous Radwaste Treatment 31 6.4 Radioactive Liquid and Gaseous Release Permits 32 6.4.1 Liquid Waste Batch Releases 32 6.4.2 Continuous Liquid Releases 32 6.4.3 Waste Gas Decay Tanlc (WGDT) Release Permit 33 6.4.4 Reactor Containment Release Permits 33 6.4.5 Miscellaneous Gaseous Release Permit 33 6.4.6 Radioactive Liquid and Gaseous Release Controls 33

DOMINION VPAP-2103S REVISION 18 PAGE3 OF76 TABLE OF CONTENTS (continued) Section Page 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 34 6.6 Radiological Environmental Monitoring 35 6.6.1 Monitoring Program 35 6.6.2 Land Use Census 38 6.6.3 lnterlaboratory Comparison Program 39 6.7 Reporting Requirements 39

6. 7 .1 Annual Radiological Environmental Operating Report 39 6.7.2 Annual Radioactive Effluent Release Report 41 6.7.3 Annual Meteorological Data 43 6.7.4 Changes to the ODCM 43 6.7.5 Industry Ground Water Protection Initiative 44 7.0 RECORDS 46 ATTACHMENTS 1 Radioactive Liquid Effiuent Monitoring Instrumentation 47 2 Radioactive Liquid Effiuent Monitoring Instrumentation 48 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 49 4 Radioactive Gaseous Waste Sampling and Analysis Program 52 5 Radioactive Gaseous Effiuent Monitoring Instrumentation 56 6 Radioactive Gaseous Effiuent Monitoring Instrumentation 58 Surveillance Requirements 7 Dispersion and Deposition Factors 60 8 Radiological Environmental Monitoring Program 61 9 Environmental Sampling Locations 64 10 Detection Capabilities for Environmental Sample Analysis 67 11 Reporting Levels for Radioactivity Concentrations in Environmental Samples 69 12 Meteorological, Liquid, and Gaseous Pathway Analysis 70

DOMINION VPAP-2103S REVISION 18 PAGE40P76 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of offsite doses due to radioactive liquid and gaseous effluents are performed to assure that:

• Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CPR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases and 2E-4 µCi/mL for dissolved or entrained noble gases
• Exposure to the maximum exposed member of the public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CPR 50, Appendix I
• Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to:

      .. Noble gases-less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin
      .. I 131 , I 133 , and H 3, and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ

• Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CPR 50, Appendix I, and
• Exposure to areal individual will not exceed 40 CPR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Radiological Environmental Monitoring Programs at Surry Power Station.

DOMINION VPAP-2103S REVISION 18 PAGES OF76

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 References 3.1.1 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Production and Utilization Facilities 3.1.3 40 CPR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3.1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 1974 3.1.6 Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CPR 50, Appendix I, Rev. 1, U.S. NRC, October 1977 3 .1. 7 Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 Surry Technical Specifications (Units 1 and 2) 3.1.9 NUREG/CR-2919, XOQDOQ, Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1982 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CPR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual

DOMINION VPAP-2103S REVISION 18 PAGE60F76 3.1.19 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.20 Surry UFSAR 3.1.21 VPAP-2802, Notifications and Reports 3.1.22 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis 3.1.23 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis 3.1.24 Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System Replacement/Surry/Unit 1&2 3.1.25 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document

3. l .26 CR0223 20 (Surry), Daily Channel Checks for 1-VG-RM-131-1 Flow Rate Measuring Device Not Performed 3.1.27 RP-AA-502, Groundwater Protection Program 3.2 Commitment Documents 3.2.1 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling 4.0 DEFINITIONS 4.1 Channel Calibration Adjustment, as necessary, of the channel output so it responds w~th the necessary range and accuracy to known values of the parameter the channel monitors. It encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test.

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

DOMINION VPAP-2103S REVISION 18 PAGE70F76 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter. The Channel Check for the MGPI sampler flow rate measuring devices, as listed on Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release rate (i.e., microcuries per second) without the presence of a sampler flow fault display. 4.3 Channel Functional Test There are two types of Channel Functional Tests. 4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions. 4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm and/or trip functions. 4.4 Critical Organ That organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded. 4.5 Dose Equivalent 1-131 That concentration of I 131 (µCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture ofl 131 , I 132, I 133 , I 134, and I 135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

DOMINION VPAP-2103S REVISION 18 PAGE 8 OF76 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent. NOTATION FREQUENCY D-Daily At least once per 24 hours W-Week:ly At least once per 7 days M-Monthly At least once per 31 days Q - Quarterly At least once per 92 days SA- Semi-annually At least once per 184 days R - Refueling At least once per 18 months I SIU - Start-up Prior to each reactor start-up II i P - Prior to release Completed prior to each release NIA- Not applicable Not applicable DR- During the release At least once during each release 4.7 Gaseous Radwaste Treatment System A system that reduces radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers and waste gas surge tanks. 4.8 General Nomenclature x = Chi: concentration at a point at a given instant (curies per cubic meter) D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) Q = Source strength (instantaneous; grams, curies)

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

I 4.9 Lower Limit of Detection (LLD) The smallest concentration of radioactive material in a sample that will yield a net count (above system background) that can be detected with 95 percent probability with only five percent probability of falsely concluding that a blank observation represents a "real" signal.

DOMINION VPAP-2103S REVISION 18 PAGE90F76 4.10 Members of the Public Any individual except when that individual is receiving an occupational dose. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine servicemen or postal workers who, as part of their formal job function, occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive materials. 4.11 Operable - Operability A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary, attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. 4.12 Purge - Purging Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required to purify the confinement. 4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., 2587 Megawatts Thermai MWt). 4.14 Site Boundary The line beyond which Dominion does not own, lease, or otherwise control the land. 4.15 Source Check For Victoreen and Eberline monitors a source check is the qualitative assessment of channel response when a channel sensor is exposed to a radioactive source or a light emitting diode, LED. For MGPI monitors a source check is the verification of proper computer response to continuous operational checks on the detector and electronics. 4.16 Special Report A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VP AP-2802, Notifications and Reports.

DOMINION VPAP-2103S REVISION 18 PAGE 10 OF76 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant. 4.18 Unrestricted Area Any area at or beyond the site boundary, access to which is neither limited nor controlled by Dominion for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, commercial, institutional or recreational purposes. 4.19 Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEPA) filters to remove iodines and particulates from a gaseous exhaust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESP) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components. 5.0 RESPONSIBILITIES 5.1 Manager Radiological Protection and Chemistry The Manager Radiological Protection and Chemistry is responsible for: 5.1.l Establishing and maintaining procedures for surveying, sampling, and monitoring radioactive effluents and the environment. 5 .1.2 Surveying, sampling, and analyzing plant effluents and environmental monitoring, and documenting these activities. 5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends. 5 .1.4 Preparing Effluent and Environmental Monitoring Program records. 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents.

DOMINION VPAP-2103S REVISION 18 PAGE 11 OF76 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 12). 6.1 Sampling and Monitoring Criteria 6.1. l Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored. 6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored. 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the status of the discharge monitored. 6.1.4 Samples shall be representative of the volume and type of discharge monitored. 6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detailed that the meaning and intent of the records are clear. 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

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

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE 120F76

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

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

                                                                   µCi/mL.            -

Volume of Waste Discharged x ~ 1

                                                                               *
                                                               .L.J ACW.1 where:
           µCi/mLi = the concentration of nuclide i in the liquid effluent discharge ACWi      =ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as µCi/mL from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/mL for dissolved or entrained noble gases

d. Bases - Liquid Effluent Concentration Limitations This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will not exceed 10 times the concentration values specified in Appendix B, Table 2, Column 2 of 10 CFR 20. The specific.ation provides operational flexibility for releasing liquid effluent in concentrations to follow the Section II.A and 11.C design objectives of Appendix I to 10 CFR Part 50. This limitation provides additional assurance that the levels ofradioactive materials in bodies of water in UNRESTRICTED AREAS will result in exposures within: (1) the Section II.A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC, and (2) restrictions authorized by 10 CFR 20.130l(e). The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its effluent concentration in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2. This specification does not affect the requirements to comply with the annual limitations of 10 CFR 20.130l(e).

DOMINION VPAP-2103S REVISION 18 PAGE 13 OF76 6.2.2 Liquid Monitoring Instrumentation

a. Radioactive Liquid Effiuent Monitoring Instrumentation I Radioactive liquid effluent monitoring instrumentation channels shown on Radioactive Liquid Effluent Monitoring Instrumentation (Attachment 1) shall be operable with their alarm/trip setpoints set to ensure that Step 6.2. l .a. limits are not exceeded.

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

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

• Promptly suspend release of radioactive liquid effluents monitored by the affected channel
• Declare the channel inoperable
• Change the setpoint to an acceptable, conservative value

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

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

1) perform the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 18 PAGE 140F76

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

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

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

1. Maximum setpoint values shall be calculated by:

s (2) where: S = the setpoint, in µCi/mL, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution C = the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station (ACW in µCi/mL) for an isotopic mixture expected in the effluent FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as: FE+ (200,000 gpm x number of circ. pumps in service)

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

s =c (3) The setpoint for Station monitors used to implement 10 CFR 20 for the site becomes the effluent concentration limit.

DOMINION VPAP-2103S REVISION 18 PAGE 15 OF76

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

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

s (4) where: Ksw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 for the Station, attributable to the service water effluent line pathway

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

s (5) where: KRw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway

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

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

DOMINION VPAP-2103S REVISION 18 PAGE 16 OF76 6.2.3 Liquid Eflluent Dose Limit

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

1. During any calendar quarter:

• Less than or equal to 1.5 mrem to the total body
• Less than or equal to 5 mrem to the critical organ

2. During any calendar year:

• Less than or equal to 3 mrem to the total body
• Less than or equal to 10 mrem to the critical organ

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

DOMINION VPAP-2103S REVISION 18 PAGE 17 OF76

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

Dose contributions shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on the equation: D = tFM'°'C*A*L.i 1 1 (6) where: Subscripts = i, refers to individual radionuclide D = the cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem t = the period for which q and F are averaged for all liquid releases, in hours M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix l lA, Surry UFSAR F = the near field average dilution factor for Ci during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in µCi/mL Ai = the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem/hr per µCi/mL (7)

DOMINION VPAP-2103S REVISION 18 PAGE 18 OF76 For example: 1.14 E+05 = 1 E+06 pCi/µCi x 1 E+03 mL/L I (8760 hr/yr), units conversion factor 21 = adult fish consumption, kg/yr, from NUREG-0133 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 Bii = the salt water bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/L BFi = the salt water bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/L DFi= the critical organ dose conversion factor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II and VCRL-50564, Rev. 1.

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

DOMINION VPAP-2103S REVISION 18 PAGE 19 OF76

e. Bases - Dose Due To Liquid Effluents This control is provided to implement the requirements of Sections II.A, ID.A, and I IV.A of Appendix I to 10 CFR Part 50. The control implements the guides set forth in Section II.A. The ACTION statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV .A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The dose calculation methodology and parameters in the ODCM implement the requirements in Section III.A that conformance with the guides of Appendix I be shown by calculation procedures, such that the actual exposure of a MEMBER OF THE PUBLIC is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

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

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 18 PAGE200F76

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body and Critical Organ Dose Calculation

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

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

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

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

Dp = (DL x P) + Da

d. Bases - Liquid Radwaste Treatment System The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This control implements the requirements of 10 CPR 50.36a, General Design Criterion 60 of Appendix A to 10 CPR Part 50 and the design objective given in Section II.D of Appendix I to 10 CPR 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 CPR Part 50 for liquid effluents.

DOMINION VPAP-2103S REVISION 18 PAGE21 OF76 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling I and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). 6.3 Gaseous Radioactive Waste Effiuents 6.3.1 Gaseous Effluent Dose Rate Limitations

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

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

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

b. Action

1. If dose rates exceed Step 6.3. l.a. limits, promptly decrease the release rate to within the above limits.

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

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

DOMINION VPAP-2103S REVISION 18 PAGE220F76

c. Calculations of Gaseous Effluent Dose Rates

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

                  ~
                  ~

[ ( K. Qivv ~Q*. ) 1 lVV

                                             + (Ki Qipv ~Q*lpV
                                                           * ) ] :-:;; 500 mrem/yr to the total body      (8)

OR

        ~[((Li+ l.IM.)Qivv
        ~                  1
                                  ~Q*.IVV ) +((Li+ l.IM.)Qipv 1
                                                                  ~Q*.lpV )] ::::;3000 mrem/yrto the skin (9) where:

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

                .     .

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

                                =   the gaseous dispersion factor, sec/m3 (See Attachment 7)

DOMINION VPAP-2103S REVISION 18 PAGE 23 OF76

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

                            . x            . x
                 ~ [P 1- Qivv -Q.IVV + P 1* Qipv-Q*lpV ] :::; 1500 mrem/yr to the critical organ L.J                                                                                  (10) where:

p. 1

                                 =   the critical organ dose factor for I 131 , I 133 , H 3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the child inhalation pathway, in mrem/yr per Curie/m3
                                 =   the release rate for ventilation vents or process vent of I 131 ,

I 133 , H3 , and all radionuclides i, in particulate form with half-lives greater than 8 days, in gaseous effluents in Curie/sec (per site) XIQ;vv, XIQ;pv = the gaseous dispersion factor, sec/m3 (See Attachment 7)

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

d. Bases - Dose Rate This specification provides reasonable assurance radioactive materials discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, either at or beyond the SITE BOUNDARY, in excess of the design objectives of Appendix I to 10 CPR Part 50.

This specification is provided to ensure that gaseous effluents from all units on the site will be appropriately controlled. It provides operational flexibility for releasing gaseous effluents to satisfy the Section II.A and II.C design objectives of Appendix I to 10 CPR Part 50. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrem/year to the whole body, less than or equal to 3000 mrem/year to the skin and the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem/year. This specification does not affect the requirements to comply with the annual limitation of 10 CPR 20.1301(a). This control applies to the release of radioactive materials in gaseous effluents from all units at the site.

DOMINION VPAP-2103S REVISION 18 PAGE240F76 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.1.a. noble gas limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.3.2.d.

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

b. Action

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

• Suspend the release of radioactive gaseous effluents monitored by the affected channel and declare the channel inoperable or
• Change the setpoint so it is acceptably conservative

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

take the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 18 PAGE 25 OF76

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

Release Point Instrument Number Process Vent 1-GW-RM-130B Condenser Air Ejector 1-SV-RM-111 2-SV-RM-211 Ventilation Vent No. 1 1-VG-RM-104 Ventilation Vent No. 2 1-VG-RM-131B Radwaste Facility Vent RRM-101

d. Setpoint Calculations

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

(11) where: D - Step 6.3. l .a. dose limits that implement Technical Specifications for the Station, mrem/yr Dpv = the noble gas site boundary dose rate from process vent gaseous effluent releases, mrem/yr Dcae = the noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr Dvv = the noble gas site boundary dose rate from summation of the Ventilation Vents 1, 2, and the Radwaste Facility vent gaseous effluent releases, mrem/yr

DOMINION VPAP-2103S REVISION 18 PAGE260F76

2. Setpoint values shall be determined by:

Rm x 2.12 E-03 (12) Fm where: m = the release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae), or Radwaste Facility (rv) Cm = the effluent concentration limit implementing Step 6.3.1.a. for the Station, µCi/mL Rm = the release rate limit for pathway m determined from methodology in Step 6.3.1.c., typically using Xe 133 as nuclide to be released, µCi/sec 2.12E-03 CFM per mL/sec Fm = the maximum flow rate for pathway m, CFM NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alarm/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases.

e. Bases - Radioactive Gaseous Effiuent Monitoring Instrumentation The radioactive gaseous effluent 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 gaseous effluent dose rate limits of Section 6.3 of the ODCM.

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

DOMINION VPAP-2103S REVISION 18 PAGE 27 OF76 6.3.3 Noble Gas Effluent Air Dose Limit

a. Requirement

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

• During any calendar quarter: ~ 5 mrads for gamma radiation and ~ 10 mrad for beta radiation
• During any calendar year: ~ 10 rnrads for gamma radiation and ~ 20 rnrad for beta radiation

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

at least once per 31 days.

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

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

The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following: For gamma radiation: (13)

DOMINION VPAP-2103S REVISION 18 PAGE28 OF76 For beta radiation: (14) Where: Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors pv, refers to the vent releases from the process vent i, refers to individual radionuclide Dg the air dose for gamma radiation, in mrad Db the air dose for beta radiation, in mrad Mi = the air dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Ni the air dose factor due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Qivv* Qipv = the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) 3.17 E-08 the inverse of the number of seconds in a year X!Qivv, XIQ;pv the gaseous dispersion factor, sec/m3(See Attachment 7) 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effiuent Dose Limit

a. Requirement

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

• During any calendar quarter: ~ 7.5 mrem to the critical organ
• During any calendar year:~ 15 mrem to the critical organ

2. Cumulative dose contributions to a member of the public from I 131 , 1133 ,

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

DOMINION VPAP-2103S REVISION 18 PAGE290F76

b. Action If the calculated dose from the release ofl 131 , 1133 , tritium, and radionuclides in particulate form, with half-lives greater than 8 days, in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that contains the:

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

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

' I limiting organ for the period being evaluated.

 !

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

DOMINION VPAP-2103S REVISION 18 PAGE300F76

1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary thatcontainI 131 , 1133 , tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

Dr= 3.17£ - 08 ~[RM ( Qivv. DIQVV + Qipv. DIQPJ +RI ( Qivv. x;Qvv + Qipv .XIQPJ l (15)

                 + RG ( Qivv . D/ Qvv + Qipv . D/ QPJ + RH3 ( Qivv . X/ Qvv + Qipv . X / QpJ]

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

                                = the dose to the critical organ of the maximum exposed member of the public in mrem ,

the release for ventilation vents or process vent of I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than 8 days in Curies 3 .17 E-08 = the inverse of the number of seconds in a year X!Qvv, X!Qpv the gaseous dispersion factor, sec/m3(See Attachment 7) DIQvv, D/Qpv = the gaseous deposition factor, m- 2 (See Attachment 7) RM = the cow-milk pathway dose factor due to I 131 , I 133 , tritium, and frOm all particulate-form radionuclides with half-lives greater than eight days, in m 2 -mrem/yr per Ci/sec RI = the inhalation pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per Ci/m3 RG the ground plane pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m 2 -mrem/yr per Ci/sec RH 3 = the tritium dose factor for milk in mrem/yr per Ci/m3

DOMINION VPAP-2103S REVISION 18 PAGE 31 OF76 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

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

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations

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

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

DOMINION VPAP-2103S REVISION 18 PAGE 320F76

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

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

Dp =(Dg x P) + Da 6.4 Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis. 6.4.1 Liquid Waste Batch Releases

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

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

• Turbine Building Sumps when RP determines that source activity requires placing pumps in manual mode
• Condensate Polishing Building Sumps and Steam Generator secondary water when RP determines the presence of contamination from primary-to-secondary leakage
• Radwaste Facility release tanks (L WMT, LDMT) 6.4.2 Continuous Liquid Releases

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

b. Examples of continuous releases include:

• Steam generator blowdown
• Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable
• Turbine building sumps and subsurface drains when pumps are in automatic mode or storm drains

DOMINION VPAP-2103S REVISION 18 PAGE 33 OF76 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until:

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

6.4.6 Radioactive Liquid and Gaseous Release Controls

                                   -

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

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

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

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

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

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

• Maximum authorized release rate
• Applicable conditions or controls pertaining to the release

DOMINION VPAP-2103S REVISION 18 PAGE 34 OF76

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

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

1. Verify the correct source is authorized for release.

2. Note maximum authorized release rate.

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

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

As appropriate, required information shall include:

• Date and time release was started
• Starting tank/sump level
• Beginning pressure
• Release flow rate
• Dilution water flow rate

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

• Date and time release was stopped
• Tank/sump ending level
• Release flow rate just prior to termination
• Ending pressure
• Volume released 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem).

DOMINION VPAP-2103S REVISION 18 PAGE35 OP76 6.5.2 Action

a. If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.1 have been exceeded.

b. If the limits in Step 6.5.1 have been exceeded, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that defines the corrective action to be taken to reduce subsequent releases and to prevent recurrence, and includes a schedule for achieving conformance with the limits. Special reports, as defined in 10 CPR 20.2203(a)(4), shall include:

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

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

3. If the estimated dose exceeds the limits in Step 6.5.1, and if the release condition that violates 40 CPR 190 has not already been corrected, the special report shall include a request for a variance in accordance with the provisions of 40 CPR 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 18 PAGE360F76

3. Samples shall be analyzed in accordance with:

• Radiological Environmental Monitoring Program (Attachment 8) requirements
• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 10)
• Guidance of the Radiological Assessment Branch Technical Position on Environmental Monitoring dated November, 1979, Revision No. 1

b. Action

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

2. If, when averaged over any calendar quarter, radioactivity exceeds the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11), prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that:

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

concentration (1) + concentration (2) + ... ;: : 1.0 (15) reporting level (1) reporting level (2)

DOMINION VPAP-2103S REVISION 18 PAGE 37 OF76

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11) are detected and are the result of plant effluents, the report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Radiological Environmental Monitoring Program (Attachment 8), identify locations for obtaining replacement samples and add them to the radiological environmental monitoring program within 30 days. The specific locations from which samples were unavailable may then be deleted from the monitoring program. Identify the cause of the unavailability of samples and identify the new locations for obtaining replacement samples in the next Annual Radioactive Effluent Release Report in accordance with VPAP-2802, Notifications and Reports.

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

DOMINION VPAP-2103S REVISION 18 PAGE 38 OF76 6.6.2 Land Use Census

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

• Nearest milk animal
• Nearest residence
• Nearest garden greater than 50 m2 (500 ft2) that produces broad leaf vegetation I

1. The land use census shall be conducted during the growing season, at least once per 12 months, using methods that will provide the best results (e.g.,

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

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

b. Action

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE390F76 6.6.3 Interlaboratory Comparison Program

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

b. Action I. Analyses shall be performed at least semi-annually as follows:

Program Cross-Check of Milk I 131 Gamma Sr89 and Sr90

                                                '       '

Water Gross Beta, Gamma, I 131 , H 3 (Tritium), Sr89 and Sr90 (blind-any combinations of above radionuclides) Air Filter Gross Beta, Gamma, Sr90

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

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

6. 7 Reporting Requirements 6.7.l Annual Radiological Environmental Operating Report Routine Radiological Environmental Operating Reports covering the operation of the units during the previous calendar year shall be submitted prior to May 1 of each year.

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

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

• A comparison (as appropriate) with preoperational studies, operational controls, and previous environmental surveillance reports
• An assessment of the observed impacts of the plant operation on the environment
• Results of land use census per Step 6.6.2

DOMINION VPAP-2103S REVISION 18 PAGE400F76

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

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

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

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

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

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

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE41 OF76 NOTE: NUREG-0543 states: "There is reasonable assurance that sites with up to four operating reactors that have releases within Appendix I design objective values are also in conformance with the EPA Uranium Fuel Cycle Standard, 40 CPR Part 190."

6. 7 .2 Annual Radioactive Eftluent Release Report

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

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

Data shall be summarized on an annual basis following the format of Regulatory Guide 1.21, Appendix B, for solid waste. [Commitment 3.2.2]

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

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

• Unplanned releases that exceeded the limits in Steps 6.2.l and 6.3.1
• Unplanned releases which require a Condition Report and involve the discharge of contents of the wrong Waste Gas Decay Tank or the wrong liquid radwaste release tank
• Unplanned releases from large leaks due to unexpected valve or pipe failures that result in a quantity of release such that a 10 CPR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CPR 50.73, Licensee Event Report System, report is required
• Unplanned releases as determined by Radiation Protection Supervision, which may or may not require a Condition Report

DOMINION VPAP-2103S REVISION 18 PAGE420F76

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

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

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

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

• An unintended spill or leak with the potential to reach groundwater, as defined in NEI 07-07, and
• The spill or leak must be greater than 100 gallons in volume or the volume cannot be quantified but is estimated to be greater than 100 gallons; or
• Any spill or leak, regardless of volume or activity deemed by the licensee to be reportable.

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

b. Dose Assessment - Station

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

Population doses shall not be included in dose assessments.

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

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

DOMINION VPAP-2103S REVISION 18 PAGE43 OF76 NOTE: The Annual Radioactive Effluent Release Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

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

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

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

6.7.3 Annual Meteorological Data

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

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

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

a. Approved by the Site Vice President before implementation.

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

Documentation shall include:

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

DOMINION VPAP-2103S REVISION 18 PAGE440F76

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

• 10 CFR 20, Subpart D
• 40CFR190
• 10 CFR 50.36a
• 10 CFR 50, Appendix I
• Technical Specifications

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

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

6.7.5 Industry Ground Water Protection Initiative

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

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

b. Communications

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

DOMINION VPAP-2103S REVISION 18 PAGE45 OF76

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

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

c. 30-Day Reports

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

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

d. Annual Reports

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

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE460F76 7.0 RECORDS 7.1 The following record(s) completed as a result of this procedure are required to be transmitted to Nuclear Document Management (NDM). The records have been identified and retention requirements established for the Nuclear Records Retention Schedule (NRRS) per RM-AA-101, Record Creation, Transmittal, and Retrieval.

7. l. l Quality Assurance Records

• Records of changes to the ODCM in accordance with Step 6.7.4
• Records of meteorological data in accordance with Step 6.7.3
• Records of sampling and analyses
• Records of radioactive materials and other effluents released to the environment
• Records of preventive maintenance, surveillances, and calibrations 7 .1.2 Non-Quality Assurance Records None 7.2 The following record(s) completed as a result of this procedure are NOT required to be transmitted to Nuclear Document Management (NDM), but are required to be retained as indicated below. The NRRS has been updated and Alternate Storage approved per RM-AA-101 for Quality Assurance Records.

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

DOMINION VPAP-2103S REVISION 18 PAGE470F76 ATTACHMENT 1 (Page 1of1) Radioactive Liquid Effluent Monitoring Instrumentation Instrument Minimum Action Operable Channels L GROSS RADIOACTIVITY MONITORS PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, RE-RRM-131 1 1

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

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW-153 1 1 ACTION 1: If the number of operable channels is less than required, effluent releases via this pathway shall be suspended.

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

DOMINION VPAP-21038 REVISION 18 PAGE48 OF76 ATTACHMENT 2 (Page 1 of 1) Radioactive Liquid Effiuent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel Channel Check Check Calibration Functional Tes1

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE49 OF76 ATTACHMENT 3 (Page 1of3) Radioactive Liquid Waste Sampling and Analysis Program Lower Limit of Liquid Release Sampling Minimum Analysis Type of Activity Detection (LLD) Type Frequency Frequency Analysis (µCi/mL), (Note 1) p p Principal Gamma 5 x 10-1 Emitters (Note 3) (Each Batch) (Each Batch) I131 1x10-6 p Dissolved and Batch Releases M Entrained Gases 1x10-5 (One Batch/M) (Gamma Emitters) (Note 2) p MComposite H3 1x10-5 (Each Batch) (Note 4) Gross Alpha 1x10-1 p Q Composite Sr89 and Sr90 5 x 10-8 (Each Batch) (Note 4) Fe55 1x10-6 Principal Gamma 5 x 10-1 Continuous WComposite Emitters (Note 6) (Note 6) (Note 6) I 131 1x10-6 Dissolved and Continuous M M Entrained Gases 1x10-5 Releases Grab Sample (Gamma Emitters) (Note 5) Continuous M Composite H3 1x10-5 (Note 6) (Note 6) Gross Alpha 1x10-1 Continuous Q Composite Sr89 and Sr90 5 x 10-8 (Note 6) (Note 6) Fe55 1x10-6

DOMINION VPAP-2103S REVISION 18 PAGE500F76 ATTACHMENT 3 (Page 2of3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 Sb LLD (8-1) E

• V
• 2.22E+06
• Y
• e-CA-~t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) A the radioactive decay constant for the particular radionuclide

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

The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement. NOTE 2: A batch release is the discharge of liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S REVISION 18 PAGE51 OF76 ATTACHMENT 3 (Page 3of3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn54 , Fe59 , Co58 , Co 60 , Zn65 , Mo99 , Cs 134 , Cs 137 , Ce 141 , and Ce 144. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and for which the method of sampling employed results in a specimen that is representative of the liquids released. NOTE 5: A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from a volume of a system that has an input flow during the continuous release. NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid effluents, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release.

DOMINION VPAP-2103S REVISION 18 PAGE520F76 ATTACHMENT 4 (Page 1of4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCi/mL), (Note 1) Prior to Release A. Waste Gas Prior to Release Principal Gamma (Each Tank) 1x10-4 Storage Tank (Each Tank) Emitters (Note 2) (Grab Sample) Principal Gamma Prior to Release Prior to Release 1x10-4 B. Containment Emitters (Note 2) (Each PURGE) Purge (Each PURGE) H3 1x10-6 (Grab Sample) C. Ventilation Weekly Principal Gamma Weekly 1x10-4 (l)Process Vent (Grab Sample) Emitters (Note 2) (2)Vent Vent #1 (3)Vent Vent #2 (Note 3) (Note 3) H3 1x10-6 (4)SRF Vent 1131 1 x 10- 12 Continuous Weekly (Note 5) (Note 4) (Charcoal Sample) 1133 1x10- 10 Continuous Weekly (Note 5) Principal Gamma 1x10- 11 All Release (Note 4) Particulate Sample Emitter (Note 2) week.ly Continuous Types as listed Composite Gross Alpha 1x10- 11 (Note 4) Particulate Sample in A, B, and C (.!uarterly Continuous Composite Sr89 and Sr90 1x10- 11 (Note 4) Particulate Continuous Noble Gas Monitor Noble Gases Gross 1x10-6 (Note 4) Beta and Gamma Principal Gamma Weekly Weekly 1x10-4 Condenser Air Emitters (Note 2) Grab Sample Ejector (Note 3) H3 1x10-6 (Note 3)

DOMINION VPAP-2103S REVISION 18 PAGE53 OF76 ATTACHMENT 4 (Page 2 of 4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCi/mL), (Note 1) Principal Gamma Prior to Release Prior to Release 1x10-4 Emitters (Grab Sample) (Each Release) H3 1x10-6 Il31 1x10- 11 Continuous Charcoal Sample (Note 4) (Note 6) I133 1x10- 10 Containment Continuous Particulate Sample Principal Gamma 1x10- 10 HogDepres- (Note 4) (Note 6) Emitter (Note 2) surization Composite Particu-Continuous 1x10-10 late Sample Gross Alpha (Note 4) (Note 6) Composite Particu-Continuous late Sample Sr89 and Sr90 1x10- 10 (Note 4) (Note 6)

DOMINION VPAP-2103S REVISION 18 PAGE540F76 ATTACHMENT 4 (Page 3 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 Sb LLD (10-1) E

• V
• 2.22E+06
• Y
• e-(A.At)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9). Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm). E = the counting efficiency (as counts per disintegration). V = the sample size (in units of mass or volume). 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie. Y = the fractional radiochemical yield (when applicable). A, = the radioactive decay constant for the particular radionuclide. At = the elapsed time between the midpoint of sample collection and time of counting. Typical values of E, V, Y and At should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP-2103S REVISION 18 PAGE 55 OF76 ATTACHMENT 4 (Page 4 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the followingradionuclides: Kr87 , Kr88 , Xe 133 , Xe 133 m, Xe 135 , Xe 135 m, andXe 138 for gaseous emissions and Mn54, Fe59 , Co 58 , Co 60 , Zn65 , Mo 99 , Cs 134, Cs 137 , Ce 141 and Ce 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and identifiable at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. NOTE 3: Sampling and analysis shall also be performed following shutdown, start-up, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, when:

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

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

NOTE 4: The ratio of the sample flow rate to the sampled stream flow rate shall be known for the period covered by each dose or dose rate calculation made in accordance with Steps 6.3.1, 6.3.3, and 6.3.4. NOTE 5: Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours for at least seven days following each shutdown, start-up, or thermal power change exceeding 15 percent of rated thermal power in one hour, and analyses shall be completed within 48 hours of changing. When samples collected for 24 hours are analyzed, the corresponding LLDs may be increased by a factor of 10. This requirement applies if:

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE560F76 ATTACHMENT 5 (Page 1of2) Radioactive Gaseous Effiuent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS

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

1-GW-RM-130B 1 1 (b) Iodine Sampler: Continuous HP Sampler, or 1-GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (c) Particulate Sampler: Continuous HP Sampler, or 1-GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor: 1-GW-Ff-100 1 3 (e) Sampler Flow Rate Measunng Device: HP Sampler Rotometer or MGPI Flow Rate Measuring 1 3 Device

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

1-SV-RM-111 1 1 2-SV-RM-211 1 1 (b) Air Ejector Flow Rate Measuring Device: Unit 1: 1-VP-FI-lA 1 3 1-VP-FI-lB 1 3 Unit 2: 2-VP-FI-lA 1 3 2-VP-FI-lB 1 3

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

SRF: RRM-101 1 1 SPS: Vent#l, 1-VG-RM-104 1 1 Vent#2, 1-VG-RM-131B 1 1 (b) Iodine Sampler: SRF: RRM-101 1 2 SPS: Vent#l, 1-VG-RM-104 (NOTE2) 1 2 Vent #2, Continuous HP Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler

DOMINION VPAP-2103S REVISION 18 PAGE 57 OF76 ATTACHMENT 5 (Page 2of2) Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS (c) Particulate Sampler: SRF: RRM-101 1 2 SPS: Vent #1, VG-RM-104 (NOTE 2) 1 2 Vent #2, HP Continuous Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor: SRF: 01-RHV-FT-156 1 3 SPS: Vent#l, 1-VS-FT-119 1 3 Vent#2, 1-VS-FT-116 1 3 (e) Sampler Flow Rate Measuring Device: SRF: RRM-101 1 3 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 3 Vent #2, HP Sampler Rotometer or 1 3 MGPI Flow Rate Measuring Device NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components. NOTE 2: Vent# 1, l-VG-RM-104, HP continuous sampler pump automatically maintains isokinetic sample flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take 15 - 20 minutes. [Commitment 3.23] ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours and these samples are analyzed for gross activity within 24 hours. When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis. [Commitment 3.2.4] ACTION2: If the number of operable channels is less than required, effluent releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours after the initiation of this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4 ). [Commitment 3.2.4] ACTION3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours.

DOMINION VPAP-2103S REVISION 18 PAGE58 OF76 ATTACHMENT 6 (Page 1of2) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL CHANNEL SOURCE CHANNEL DESCRIPTION FUNCTIONAL CHECK CHECK CALIBRATION TEST

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

Providing Alarm and Automatic Termination of Release 1-GW-RM-130B D M R Q (b) Iodine Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor 1-GW-Ff-100 D NIA R NIA (e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or D NIA SA NIA MGPI Flow Rate Measuring Device D NIA R NIA

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

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

DOMINION VPAP-2103S REVISION 18 PAGE590F76 ATTACHMENT 6 (Page 2 of2) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL CHANNEL SOURCE CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST (b) Iodine Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor SRF:O 1-RHV-Ff-156 SPS: Vent#l, 1-VS-Ff-119 Vent#2, 1-VS-Ff-116 D NIA R NIA (e) Sampler Flow Rate Measuring Device (NOTE 1) SRF: RRM-101 D NIA R NIA SPS: Vent#l, 1-VG-RM-104 D NIA R NIA Vent #2, HP Sampler Rotometer D NIA R NIA or MGPI Flow Rate Measuring D NIA SA NIA Device NOTE l:The mark numbers listed above in l(b), l(c), 3(b), 3(c), and 3(e) refer to the gaseous effluent radiation monitor or monitor skid with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor.

DOMINION VPAP-2103S REVISION 18 PAGE 60 OF76 ATTACHMENT 7 (Page 1 of 1) Dispersion and Deposition Factors Distance, Ventilation Vent Process Vent Description Sector meters XIQ D!Q XIQ D!Q N 500 l.4E-05 1.6E-08 4.2E-08 3.9E-10 NNE 532 l.8E-05 3.3E-08 l.2E-07 l.2E-09 NE 629 l.3E-05 3.0E-08 l.8E-07 l.6E-09 ENE 806 7.lE-06 1.3E-08 l.8E-07 l.8E-09 E 1210 2.7E-06 7.2E-09 2.6E-07 l.8E-09 ESE 1984 9.8E-07 3.2E-09 2.4E-07 l.7E-09 SE 1371 2.2E-06 6.8E-09 2.6E-07 2.lE-09 SSE 919 4.3E-06 9.2E-09 2.3E-07 l.2E-09 Site Boundary s 645 5.9E-06 1.lE-08 l.7E-07 l.3E-09 SSW 565 6.3E-06 1.2E-08 l.3E-07 l.4E-09 SW 548 9.7E-06 l.9E-08 l.3E-07 l.3E-09 WSW 656 8.4E-06 1.6E-08 l.4E-07 l.3E-09 w 565 l.2E-05 2.9E-08 l.2E-07 l.OE-09 WNW 565 l.4E-05 2.6E-08 8.7E-08 5.8E-10 NW 581 l.3E-05 1.7E-08 l.2E-07 8.9E-10 NNW 581 9.SE-06 1.lE-08 5.lE-08 3.lE-10 N 6534 2.4E-07 2.lE-10 6.7E-08 8.8E-11 NNE 3122 l.OE-06 1.7E-09 l.9E-07 3.7E-10 NE 7564 2.7E-07 4.2E-10 6.7E-08 l.8E-10 SE 4554 3.4E-07 8.6E-10 8.7E-08 2.7E-10 SSE 4265 3.7E-07 6.6E-10 9.SE-08 2.5E-10 s 2736 5.SE-07 9.SE-10 l.9E-07 5.7E-10 Resident SSW 2977 4.lE-07 7.4E-10 l.4E-07 4.5E-10 SW 3637 4.SE-07 7.7E-10 l.2E-07 3.4E-10 WSW 660 6.4E-06 l.3E-08 l.8E-07 l.3E-09 w 5053 3.4E-07 7.lE-10 8.lE-08 2.lE-10 WNW 7886 2.2E-07 2.9E-10 4.9E-08 9.4E-11 NW 7467 2.2E-07 2.2E-10 5.8E-08 l.3E-10 NNW 6035 2.3E-07 2.0E-10 6.2E-08 7.lE-11 SSW 7693 9.9E-08 1.4E-10 5.0E-08 l.2E-10 Milk: Cow NNW 5938 2.4E-07 2.lE-10 6.3E-08 7.lE-11 SSE 4265 3.7E-07 6.6E-10 9.5E-08 2.5E-10 s 3235 4.2E-07 7.lE-10 l.6E-07 4.3E-10 SSW 3122 3.8E-07 6.8E-10 l.3E-07 4.lE-10 Garden SW 7596 l.5E-07 2.lE-10 5.3E-08 l.2E-10 WSW 5713 2.0E-07 3.2E-10 7.SE-08 l.8E-10 w 5536 3.0E-07 6.0E-10 7.SE-08 l.8E-10 NNW 7017 l.9E-07 1.6E-10 5.3E-08 7.4E-11

DOMINION VPAP-2103S REVISION 18 PAGE61 OF76 ATTACHMENT 8 (Page 1 of 3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

1. DIRECT RADIATION About 40 Routine Monitor-ing Stations to be placed as follows:

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

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

3) The balance of the 8 dosimeters should be placed in special interest areas such as population centers, nearby residents, schools, and in 2 or 3 areas to serve as controls

2. AIRBORNE Samples from 7 locations:

a) 1 sample from close to the site boundary location of the highest IRadioiodine Canister calculated annual I 131 Analysis Weekly average ground level Continuous Radioiodines and D/Q Sampler Particulates b) 5 sample locations 6-8 operation with !Particulate Sampler km distance located in a sample collection Gross beta radioactivity concentric ring around weekly analysis following filter the Station change; c) 1 sample from a control Gamma isotopic analysis location 15-30 km of composite (by distant, providing valid location) quarterly background data

DOMINION VPAP-2103S REVISION 18 PAGE620F76 ATTACHMENT 8 (Page 2of3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

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

4. INGESTION a) Milk a) 2 samples from milking animals in the vicinity of the Station. (NOTE 1) Gamma isotopic and r131 b) 1 sample from milking Monthly animals at a control analysis monthly location (-15-30 km distant). (NOTE 2) a) 6 samples of filter feeders (clams, oysters) in the Semi-Annually b) Fish and vicinity of the Station Gamma isotopic on edible Invertebrates c) 1 sampling of crabs from Annually portions the vicinity of the Station d) 1 sampling of 2 different species in vicinity of Semi-Annually Station discharge area.

(NOTE3) NOTE 1: If milk sampling cannot be performed, use item 4.c, Food Products - d. Milk sampling cannot be performed when there are no milk sampling locations in the vicinity of the Station. NOTE2: If milk sampling from a control location cannot be performed, use item 4.c) e). Milk sampling cannot be performed when there is no milk sampling location 30 km distant. NOTE3: Commercially or recreationally important species permitted for sampling by the Virginia Marine Resources Commission include catfish, white perch, croaker, striped bass, spot, red drum, and striped mullet.

DOMINION VPAP-2103S REVISION 18 PAGE63 OF76 ATTACHMENT 8 (Page 3 of 3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

4. INGESTION (Continued) a) 1 sample com Gamma isotopic on edible b) 1 sample soybeans Annually portions c) 1 sample peanuts d) 1 sample of a broadleaf vegetation grown nearest in each of two different available offsite locations (sectors) with the c) Food Products highest annual average ground level D/Qs, if Monthly, if Gamma isotopic and I 131 milk sampling is not available, or at analysis performed. harvest e) 1 sample of a broadleaf vegetation grown 15 -

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

DOMINION VPAP-2103S REVISION 18 PAGE640F76 ATTACHMENT 9 (Page 1of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Air Charcoal and Surry Station (SS) 0.3 NNE Particulate Hog Island Reserve (HIR) 2.0 NNE Bacon's Castle (BC) 4.5 SSW Alliance (ALL) 5.1 WSW Colonial Parkway (CP) 3.8 NNW BASF (BASF) 5.1 ENE Fort Eustis (FE) 4.9 ESE Newport News (NN) 19.3 SE Control Location Environmental Control (00) Onsite

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

North North West (04) 0.2 NNW Site Boundary North (05) 0.3 N Site Boundary North North East (06) 0.3 NNE Site Boundary North East (07) 0.3 NE Site Boundary East North East (08) 0.4 ENE Site Boundary East (09) 0.3 E Site Boundary West (10) 0.1 w Site Boundary West South West (11) 0.4 WSW Site Boundary South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary South (14) 0.4 s Site Boundary South South East (15) 0.6 SSE Site Boundary South East (16) 0.9 SE Site Boundary Station Intake (18) 1.6 ESE Site Boundary Hog Island Reserve (19) 2.0 NNE Near Resident

DOMINION VPAP-2103S REVISION 18 PAGE 65 OF76 ATTACHMENT 9 (Page 2of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Environmental Bacon's Castle (20) 4.5 SSW Approx. 5 miles TLDs Route 633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles Surry (23) 7.7 WSW Population Center Route 636 and 637 (24) 4.0 w Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles Kingsmill (29) 4.6 N Approx. 5 miles Williamsburg (30) 7.8 N Population Center Kingsmill North (31) 5.5 NNE Approx. 5 miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News (38) 19.3 SE Population Center James River Bridge (39) 17.1 SE Control Benn's Church (40) 17.0 SSE Control Smithfield (41) 13.4 SSE Control Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 s Approx. 5 miles Milk Epps 4.8 SSW Colonial Parkway 3.7 NNW Williams 27.5 s Control Location

DOMINION VPAP-2103S REVISION 18 PAGE 66 OF76 ATTACHMENT 9 (Page 3of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Well Water Surry Station Onsite** Hog Island Reserve 2.0 NNE Construction Site 0.3 E Onsite*** Crops (Com, Slade's Farm 3.2 s Peanuts, Soybeans) Brock's Farm 3.8 s River Water Surry Discharge 0.4 NW (Monthly) Scotland Wharf 4.9 WNW Control Location Sediment Chickahominy River 11.2 WNW Control Location (Silt) Surry Station Discharge 1.3 NNW Clams Chickahominy River 11.2 WNW Control Location Surry Station Discharge 1.3 NNW Jamestown Island 3.9 NW Oysters Point of Shoals 6.4 SSE Mulberry Point 4.9 ESE Lawne's Creek 2.4 SE Crabs Surry Station Discharge 1.3 NNW Fish Surry Station Discharge 1.3 NNW Shoreline Hog Island Reserve 0.6 N Sediment Chickahominy River 11.2 WNW Control Location

• Onsite Location - in Lead Shield
  • Onsite sample of Well Water taken from tap-water at Surry Environmental Building
    • Onsite sample of Well Water taken from tap-water at Surry Training Center

DOMINION VPAP-2103S REVISION 18 PAGE67 OF76 ATTACHMENT 10 (Page 1of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) Analysis Water Airborne Fish Milk Food Sediment (NOTE2) (pCi/L) Particulate (pCi/kg) (pCi/L) Products (pCi/kg) or Gases (wet) (pCi/kg) (dry) (pCifm3) (wet) Gross beta 4 0.01 H-3 2,000 Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 1-131 (NOTE 3) 1 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 La-140 15 15 NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also be

• identified and reported.

NOTE 3: LLD for the ground (drinking) water samples. The LLD for the surface (non-drinking) water samples is 10 pCi/L.

DOMINION VPAP-2103S REVISION 18 PAGE 68 OF76 ATTACHMENT 10 (Page 2of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) NOTE 1: For a particular measurement system (which may include radiochemical separation): LLD (24-1) E

• V
• 2.22E+06
• Y
• e-CA-L1t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) A = the radioactive decay constant for the particular radionuclide L1t = the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, hot plant effluent samples) Typical values of E, V, Y and L1t should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP-2103S REVISION 18 PAGE690F76 ATTACHMENT 11 (Page 1of1) Reporting Levels for Radioactivity Concentrations in Environmental Samples Analysis Water Airborne Fish Milk Food Products (pCi/L) Particulate or (pCilkg, wet) (pCi/L) (pCi/kg, wet) Gases (pCifm3) H-3 20,000* Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 I-131 2* 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

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

DOMINION VPAP-2103S REVISION 18 PAGE 700F76 ATTACHMENT 12 (Page 1of7) Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEORLOGICAL ANALYSIS 1.1 Purpose The purpose of the meteorological analysis was to determine the five (5) year average XIQ and D/Q values at critical locations around the Station for ventilation vent (ground level) and process vent (niixed mode) releases. The five year average XIQ and D/Q values are used in the dose pathway analysis to determine dose and dose rate at site boundary and dose to the member of the public. 1.2 MeteorolOgical Data, Parameters, and Methodology A five (5) year average ofrepresentative onsite meteorological data for the period January 1, 2007 through December 31, 2011, is used in the gaseous effluent dose pathway calculations. i This data includes wind speed, wind direction, and differential temperature for the purpose of I. determining joint frequency distributions for those releases characterized as ground level (i.e., ,- 1 ventilation vent), and those characterized as mixed mode (i.e., process vent). I X/Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ - Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324. The open terrain adjustment factors were applied to the XIQ values as recommended in Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain correction factors are considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area. The effective release height used in mixed mode release calculations was

• based on a process vent release height of 131 ft, and plume rise due to momentum for a vent diameter of 1.5 in. with plume exit velocity of 100 ft/sec.

Ventilation vent, and vent releases other than from the process vent, are considered ground level as specified in Regulatory Guide 1.111 for release points less than the height of adjacent solid structures. Terrain elevations were obtained from Surry Power Station Units 1 and 2 Virginia Electric and Power Company Updated Final Safety Analysis Report Table 1 lA-8. XIQ and D/Q values were calculated for the nearest site boundary, residence, milk-cow, discharge bank, and vegetable garden by sector for process vent and ventilation vent releases.

DOMINION VPAP-2103S REVISION 18 PAGE 71 OF76 ATTACHMENT 12 (Page 2of7) Meteorological, Liquid, and Gaseous Pathway Analysis According to the definition for short term in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations," October, 1978, some gaseous releases may fit this category, primarily waste gas decay tank releases and containment purges. However, these releases are considered long term for dose calculations as past releases were both random in time of day and duration as evidenced by reviewing past release reports. Therefore, the use of annual average concentrations is appropriate according to NUREG-0133. 1.3 Results The XIQ and D/Q values used in the dose pathway analysis for ventilation vent releases and process vent releases can be found in Attachment 7. 2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose The purpose of the liquid pathway analysis was to determine the maximum exposed member of the public in unrestricted areas as a result of radioactive liquid effluent releases. The analysis included a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste Effluents. 2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station effluent release reports. The data for each year, along with appropriate site specific parameters and default selected parameters, were entered into the NRC computer code LADTAP as described in NUREG-1276. Liquid radioactive effluents from both units are released to the James River via the discharge canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do not exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours per year, and that bank fishing would be performed a maximum of 160 hours per year.

DOMINION VPAP-2103S REVISION 18 PAGE 720F76 ATTACHMENT 12 (Page 3 of7) Meteorological, Liquid, and Gaseous Pathway Analysis For an individual fishing in the discharge canal, no river dilution was assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e., a mixing ratio of 0.2) was assumed as appropriate according to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities and ingestion of fish and invertebrates are included in the Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year.the individual spent fishing in the canal. 2.3 Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and invertebrate pathways, are calculated for total body and various critical organs. Validation of the limiting age group and critical organ is performed by the liquid effluent dose calculation program using the data, parameters, and methodology provided in the Source Code file. 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose Gaseous effluent pathway analyses are performed to determine the location that would result in the maximum doses due to noble gases, for use in demonstrating compliance with Steps 6.3.1.a. and 6.3.3.a. The analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the release of I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than eight days for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed individual through the inhalation pathway from I 131 , I 133 , tritium, and particulates to demonstrate compliance with Step 6.3.l.a.

DOMINION VPAP-2103S REVISION 18 PAGE 73 OF76 ATTACHMENT 12 (Page 4 of7) Meteorological, Liquid, and Gaseous Pathway Analysis 3.2 Data, Parameters, and Methodology Five year average X/Q values were calculated, as described in Section 1 of this attachment. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble gases would be at these site boundary locations. The doses from both the ventilation vent and process vent release points are summed to calculate total maximum dose. 6.3.l.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and XIQ values determined for maximum noble gas doses can be used to determine the maximum dose from I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway. The maximum exposed individual for 10 CPR 50, Appendix I, compliance could be at any of the following locations: site boundary, nearest resident, nearest milk-cow, or nearest vegetable garden, using the Land Use Census data which is assessed annually. Therefore, ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous effluent dose pathway analyses. Ground plane, inhalation, cow-milk, and vegetable garden pathways are active with the exception of the infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses. The gamma and beta dose factors Kivv. Livv. Mivv, and Nivv for ground level releases and the gamma and beta dose factors Kipv, Lipv, Mipv, and Nipv for mixed mode releases are included in the Source Code file. Inhalation pathway dose factors Pivv and Pipv are calculated using the following equation: Pi= K' (BR) DFAi mrem/yr per Ci/m3 (28-1) where: K' = a constant of unit conversion, lE+ 12 pCi/Ci BR= the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev.1 DFAi = the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 18 PAGE 74 OF76 ATTACHMENT 12 (Page 5 of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R.G. 1.109, Rev. 1. It was determined that the member of the public within site boundary would be using the discharge canal bank for fishing a maximum of 160 hours per year. Active pathways are ground plane and inhalation, and all age groups are evaluated for this pathway analysis. The RMivv and RMipv dose factors, except for tritium, are calculated using the following equation: RM.1 (28-2) where: K' = a constant of unit conversion, lE+ 12 pCi/Ci Qp =cow's consumption rate, 50, in kg/day (wet weight) Uap=infant milk consumption rate, 330, in liters/yr Yp =agricultural productivity by unit area of pasture feed grass, 0.7 in kg/m2 Y s =agricultural productivity by unit area of stored feed, 2.0, in kg/m2 Fm = stable element transfer coefficients, in days/liter r =fraction of deposited activity retained on cow's feed grass, 1.0 for radioiodine, and 0.2 for particulates DFLi=critical organ ingestion dose factor for the ith radionuclide for the particular age group, in mrem/pCi Ai_ = decay constant for the ith radionuclide, in sec-1

    'Aw =decay constant for removal of activity of leaf and plant surfaces by weathering, 5. 73E-07 sec-1 (corresponding to a 14 day half-life) tf =transport time from pasture to cow, to milk, to receptor, 1.73+05, in seconds th =transport time from pasture, to harvest, to cow, to milk, to receptor, 7. 78E+06, in seconds fP =fraction of year that cow is on pasture, 1.0 (dimensionless)

DOMINION VPAP-2103S REVISION 18 PAGE 75 OF76 ATTACHMENT 12 (Page 6 of7) Meteorological, Liquid, and Gaseous Pathway Analysis fs =fraction of cow feed that is pasture grass while cow is on pasture, 0.8 (dimensionless) Parameters used above were obtained from NUREG-0133 and Regulatory Guide 1.109, Rev.l. Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation is used: K'K'"p m Qp U ap(DFLH3) [o.75(0.5/H~ (28-3) where: K '= a constant of unit conversion 1E+03 gm/kg H = absolute humidity of the atmosphere, 8.0, in gmfm3 0.75 =the fraction of total feed that is water 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined. The inhalation pathway dose factors Rlivv and Rlipv were calculated using the following equation: Rli = K' (BR) DFAi mrem/yr per Ci/m3 (28-4) where: K' = a constant of unit conversion, lE+ 12 pCi/Ci BR= breathing rate of the particular age group, m3/yr DFAi=critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 18 PAGE 76 OF76 ATTACHMENT 12 (Page 7 of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R. G. 1.109, Rev. 1. Breathing Rate Infant = 1400 m 3/yr Child = 3700 m 3/yr Teen = 8000 m 3/yr Adult = 8000 m3/yr The RG dose factors are calculated using the following equation: RG~K'K"(SF)DFG; [ 1-~';'b ] (-m_z_~m-i-;:-:-cl_y_r_) (28 - 5) where: K' = A constant of unit conversion, lE+ 12 pCi/Ci K" = A constant of unit conversion, 8760 hr/year.

                =  The decay constant for nuclide i, sec- 1.
                =  The exposure time, 4.73x108 sec (15 years), from Table E-15 of Reg Guide 1.109.
                =  The ground plane dose conversion factor for nuclide i, from Table E-6 of Reg. Guide 1.109 (mrem/hr per pCi/m2).

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

                                                               ---~-:.,,,  ____   --    ******-                                   . i:*.*.. *~-       -**

Administrative Piocedure*-or Guidance **----:**---..:*:...-::~ .* and Reference Document Approval AD-AA-101 - Attachment 4 _ Page 1 of 1

1. Document Number: 2. Revision: 3. Document Typ!i:

VPAP~2103S 19 *!81 Administrative Procedure 0GARD

4. Tiiie:

bffslte Dose Galculatibn Manual (Surry)

5. Requestor(s) Prl11t Name(s) I Locations 6. Date 7. Requestor*Phone Pete Blount I SPS 10/13/2015 8-798-2467 B. Document Request ONew !81. Revision 0 Cancel 0 Supersede ,0 Temporary I I 9.1\pplicable NtJ<:;lear Station(s)

Millstone D North Anna 0 Surry [81

10. Reas()n al]g-/:lri~fDescriptiqn.ofChange; Revision initiated to incorporaie changes from SAR60263o, Radiological Environmental Monitoririg Program and CR1013104, VPAP~2103S compensatOryactions reviel,!{_not cpmpleted fpr 1-RLW~FIT-153 failure.

,I      For full iist of change~. see Revision Surilm.ary:
 !

I 11. Records Retention Requirements Affected? 12. Change Management: D Yes (Complete NRRS-form fr6Jn R.M-AA-101) !81 N9 Attach Appropri;:ite Pl"AA-4000 Attachment(s)

13. Level of Use:

D Continuous Us.e D Reference* Use. f81 lnforniation Use D Multiple Use FleetApp~o'val . . 14; Fleet Approval Reqlil~d by: (C~e9k one box Qnly. Entef Peer ~rqup Name, if i:!PPlieable)

0 Peer Grou OR. lZJ-Funciional Area Maria er FAM 15.. Printed-Approver Nanie: :16: Slgnatllre 17. Date Jasc:m Eggart

• tDI r3i1s Site Approval

18. Implementation Prere*quisltes: (Items In addition to those listed on Document Trayelerc qr_ Change Management Plan)-

 \      None'

• 19. lmplefT!entatlon PrereqLJisltes Reviewed*- Procedure supervisor Sig NIA

30. Datp.r to?i.\ lc.l I .o

     *31. Nuclear E-Fotms Updated for Site(s)?            32. N\lclear E-Forms Updated Print Name/Signature                         33. Date

[j MP* 0 NA 0 SU 181 N!A NIA N/A

34. Document'Numb~r: 35; Revision: 36. Effective Date 37. EXplratlon Date VPAP.;21035 19 \0 l'-\ . ~ NIA Key: GARD-Guidance and Reference Document, EQMS-Electronlc. Document Management System Form No. 72Bs20(0ct 2014).

Station Administrative Procedure Title: Offsite Dose Calculation Manual (Surry) Process I Program Owner: Manager Radiological Protection and Chemistry (Surry) Procedure Number Revision Number Effective Date VPAP-2103S 19 On File Revision Summary The following changes were made in response to SAR002630, Radiological Environmental Monitoring Program.

• Added Reference 3.1.28 for Branch Technical Position
• Added footnote to Attachment 8 to clarify the omission of the TLD station in the SE sector The following changes were made in response to CR1013104, VPAP-2103S compensatory actions review not completed for 1-RLW-FIT-153 failure.
• Added Reference 3.1.29 for CR1013104
• Updated required action for instrument 3(a) on Attachment 1
• Added Action 3 on Attachment 1 Other Changes:
• Reworded 3rd bullet of Substep 6.4.2.b Approvals on File

DOMINION VPAP-2103S REVISION 19 PAGE20F76 TABLE OF CONTENTS Section Page 1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 10 6.0 INSTRUCTIONS 11 6.1 Sampling and Monitoring Criteria 11 6.2 Liquid Radioactive Waste Effiuents 11 6.2. l Liquid Effluent Concentration Limitations 11 6.2.2 *Liquid Monitoring Instrumentation J3 6.2.3 Liquid Effluent Dose Limit 16 6.2.4 Liquid Radwaste Treatment 19 6.2.5 Liquid Sampling 21 6.3 Gaseous Radioactive .Waste Effiuents 21 6.3.1 Gaseous Effluent Dose Rate Limitations 21 6.3.2 Gaseous Monitoring Instrumentation 24 6.3.3 Noble Gas Effluent Air Dose Limit 27 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effluent Dose Limit 28 6.3.5 Gaseous Radwaste Treatment 31 6.4 Radioactive Liquid and Gaseous Release Permits 32 6.4.l Liquid Waste Batch Releases 32 6.4.2 Continuous Liquid Releases 32 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 33 6.4.4 Reactor Containment Release Permits 33 6.4.5 Miscellaneous Gaseous Release Permit 33 6.4.6 Radioactive Liquid and Gaseous Release Controls 33

DOMINION VPAP-2103S REVISION 19 PAGE3 OF76 TABLE OF CONTENTS (continued) Section Page 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 34 6.6 Radiological Environmental Monitoring 35 6.6.1 Monitoring Program 35 6.6.2 Land Use Census 38 6.6.3 Interlaboratory Comparison Program 39 6.7 Reporting Requirements 39 6.7.1 Annual Radiological Environmental Operating Report 39

6. 7 .2 Annual Radioactive Effluent Release Report 41

6. 7.3 Annual Meteorological Data 43 6.7.4 Changes to the ODCM 43

6. 7.5 ~ndustry Ground Water Protection Initiative 44 7.0 RECORDS 46 ATTACHMENTS 1 Radioactive Liquid Effiuent Monitoring Instrumentation 47 2 Radioactive Liquid Effiuent Moni~oring Instrumentation 48 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 49 4 Radioactive Gaseous Waste Sampling and Analysis Program 52 5 Radioactive Gaseous Effiuent Monitoring Instrumentation 56 6 Radioactive Gaseous Effiuent Monitoring Instrumentation 58 Surveillance Requirements 7 Dispersion and Deposition Factors 60 8 Radiological Environmental Monitoring Program 61 9 Environmental Sampling Locations 64 10 Detection Capabilities for Environmental Sample Analysis 67 11 Reporting Levels for Radioactivity Concentrations in Environmental Samples 69 12 Meteorological, Liquid, and Gaseous Pathway Analysis 70

DOMINION VPAP-2103S REVISION 19 PAGE40F76 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of offsite doses due to radioactive liquid and gaseous effluents are performed to assure that:

• Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CFR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases and 2E-4 µCi/mL for dissolved or entrained noble gases
• Exposure to the maximum exposed member of the public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CFR 50, Appendix I
• Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to:

      .. Noble gases -less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin
      ** 1131 , 1133 , and H3 , and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ

• Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CFR 50, Appendix I, and
• Exposure to a real individual will not exceed 40 CFR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Radiological Environmental

                                                                          /

Monitoring Programs at Surry Power Station.

DOMINION VPAP-2103S REVISION 19 PAGE50F76

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 References 3.1.l 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Production and Utilization Facilities 3.1.3 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3.1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 1974 3.1.6 Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I, Rev. 1, U.S. NRC, October 1977 3.1.7 Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 Surry Technical Specifications (Units 1 and 2) 3.1.9 NUREG/CR-2919, XOQDOQ, Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1982 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual

DOMINION VPAP-2103S REVISION 19 PAGE60F76 3.1.19 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.20 Surry UFSAR 3.1.21 VPAP-2802, Notifications and Reports 3.1.22 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis 3.1.23 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis 3.1.24 Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System Replacement/Surry/Unit 1&2 3.1.25 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document 3.1.26 CR022320 (Surry), Daily Channel Checks for 1-VG-RM-131-1 Flow Rate Measuring Device Not Performed 3.1.27 RP-AA-502, Groundwater Protection Program 3.1.28 Branch Technical Position, Revision 1, November 1979 3.1.29 CR1013104, VPAP-2103S c9mpensatory actions review not completed for 1-RLW-FIT-153 failure 3.2 Commitment Documents 3.2.l Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling 4.0 DEFINITIONS 4.1 Channel Calibration Adjustment, as necessary, of the channel output so it responds with the necessary range and accuracy to known values of the parameter the channel monitors. It encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test. The Channel Calibration can be performed by any series of sequential, overlapping, or total channel steps so the entire channel is calibrated.

DOMINION VPAP-2103S REVISION 19 PAGE70F76 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter. The Channel Check for the MGPI sampler flow rate measuring devices, as listed on Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release rate (i.e., microcuries per second) without the presence of a sampler flow fault display. 4.3 Channel Functional Test There are two types of Channel Functional Tests. 4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions. 4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm and/or trip functions. 4.4 Critical Organ That organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded. 4.5 Dose Equivalent 1-131 That concentration of I 131 (µCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I 131 , I 132, I 133 , I 134, and I 135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

DOMINION VPAP-2103S REVISION 19 PAGE80F76 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent. NOTATION FREQUENCY D-Daily At least once per 24 hours W-Weekly At least once per 7 days M-Monthly At least once per 31 days Q - Quarterly At least once per 92 days SA - Semi-annually At least once per 184 days R - Refueling At least once per 18 months SIU - Start-up Prior to each reactor start-up P - Prior to release Completed prior to each release NIA- Not applicable Not applicable DR - During the release At least once during each release 4.7 Gaseous Radwaste Treatment System A system that reduces radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers and waste gas surge tanks. 4.8 General Nomenclature x = Chi: concentration at a point at a given instant (curies per cubic meter) D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) Q = Source strength (instantaneous; grams, curies)

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

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

DOMINION VPAP-2103S REVISION 19 PAGE90F76 4.10 Members of the Public Any individual except when that individual is receiving an occupational dose. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine' servicemen or postal workers who, as part of their formal job function,"occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive materials. 4.11 Operable - Operability A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary,. attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. 4.12 Purge - Purging Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required to purify the confinement. 4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., 2587 Megawatts Thermal MWt). 4.14 Site Boundary The line beyond which Dominion does not own, lease, or otherwise control the land. 4.15 Source Check For Victoreen and Eberline monitors a source c.heck is the qualitative assessment.of channel response when a channel sensor is exposed to a radioactive source or a light emitting diode, LED. For MGPI monitors a source check is the verification of proper computer response to continuous operational checks on the detector and electronics. 4.16 Special Report A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VP AP-2802, Notifications and Reports.

DOMINION

• VPAP-2103S REVISION 19 PAGE 100F76 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant.

4.18 Unrestricted Area Any area at or beyond the site boundary, access to which is neither limited nor controlled by Dominion for purposes of protection of individuals from exposu~e to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, commercial, institutional or recreational purposes. 4.19 Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material 1n particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEPA) filters to remove iodines and particulates from a gaseous

  * ** * :-~ e:x.haust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components.

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

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

5 .1.2 Surveying, sampling, and analyzing plant effluents and environmental monitoring, and documenting these activities. 5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends. 5.1.4 Preparing Effluent and Environmental Monitoring Program records. 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents .

...~ ... ...
        ~

DOMINION VPAP-2103S REVISION 19 PAGE 11 OF76

• 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 12).

6.1 Sampling and Monitoring Criteria 6.1.1 Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored. 6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored. 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the status of the discharge monitored. 6.1.4 Samples shall be representative of the volume and type of discharge monitored. 6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detailed that the meaning and intent of the records are clear. 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

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

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE 120F76

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

Volume of Waste Discharged+ Volume of Dilution Water> (l) 1 Ci/mL. - Volume of Waste Discharged x ~ µ 1 Li ACW-1 where:

           µCi/mLi = the concentration of nuclide i in the liquid effluent discharge ACWi      =ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as µCi/mL from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/mL for dissolved or entrained noble gases

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

DOMINION VPAP-2103S REVISION 19 PAGE 13 OF76 6.2.2 Liquid Monitoring Instrumentation

a. Radioactive Liquid Effluent Monitoring Instrumentation Radioactive liquid effluent monitoring instrumentation channels shown on Radioactive Liquid Effluent Monitoring Instrumentation (Attachment 1) shall be operable with their alarm/trip setpoints set to ensure that Step 6.2.1.a. limits are not exceeded.

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

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

• Promptly suspend release of radioactive liquid effluents monitored by the affected channel
• Declare the channel inoperable
• Change the setpoint to an acceptable, conservative value

b. Radioactive Liquid Effiuent Monitoring Instrumentation Operability Each radioactive liquid effluent monitoring instrumentation channel shall be

' :i demonstrated operable by performing.a Channel Check, Source Check, Channel Calibration, and Channel Functional Test at the frequencies shown in Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 2).

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

1) perform the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 19 PAGE 140F76

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

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

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

1. Maximum setpoint values shall be calculated by:

s (2) where: S = the setpoint, in µCi/mL, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution C = the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station (ACW in µCi/mL) for an isotopic mixture expected in the effluent FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as: FE+ (200,000 gpm x number of circ. pumps in service)

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

s =c (3) The setpoint for Station monitors used to implement 10 CFR 20 for the site becomes the effluent concentration limit.

DOMINION VPAP-2103S REVISION 19 PAGE 15 OF76

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

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

s (4) where: Ksw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 for the Station, attributable to the service water effluent line pathway

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

s (5) where:. KRw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway

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

        .e. Bases - Radioactive Liquid Effiuent Monitoring Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, a.s 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 ~ccordance with the methodology and parameters in the ODCM to ensure that the alarm/trip wiil occur prior to exceeding 10 times* the limits of 10 CPR 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 CPR Part 50.

DOMINION VPAP-2103S REVISION 19 PAGE 160F76 6.2.3 Liquid Effiuent Dose Limit

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

1. During any calendar quarter:

• Less than or equal to 1.5 mrem to the total body
• Less than *or equal to 5 mrem to the critical organ

2. During any calendar year:

• Less than or equal to 3 mrem to the total bod:y
• Less than or equal to 10 mrem to the critical organ

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

DOMINION VPAP-2103S REVISION 19 PAGE 17 OF76

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

Dose contributions shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on the equation: D = tFM'"'C*A* L.J 1 1 (6) where: Subscripts = i, refers to individual radionuclide D = the cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem t .- -* the period for which Ci and F are averaged for all liquid releases, in hours M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix 1 lA, Surry UFSAR F = the near field average dilution factor for Ci during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in µCi/mL Ai = the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem/hr per µCi/mL (7)

DOMINION VPAP-2103S REVISION 19 PAGE 18 OF76 For example: 1.14 E+05 = 1 E+06 pCi/µCi x 1 E+03 mL/L I (8760 hr/yr), units conversion factor 21 = adult fish consumption, kg/yr, from NUREG-0133 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 Bli = the salt water bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/L BFi = the salt water bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/L DFi= the critical organ dose conversion factor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II and VCRL-50564, Rev. 1.

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

DOMINION VPAP-2103S REVISION 19 PAGE 19 OF76

e. Bases - Dose Due To Liquid Effiuents This control is provided to implement the requirements of Sections II.A, Ill.A, and IV.A of Appendix I to 10 CFR Part 50. The control implements the guides set forth in Section II.A. The ACTION statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV .A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The dose calculation methodology and*parameters in the ODCM implement the requirements in Section Ill.A that conformance with the guides of Appendix I be shown by calculation procedures, such that the actual exposure of a MEMBER OF THE PUBLIC is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

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

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 19 PAGE200F76

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

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

                                       '

ino.:Perability.

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body and Critical Organ Dose Calculation

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

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

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

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

Dp = (DL x P) + Da

d. Bases - Liquid Radwaste Treatment System The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This control implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design objective given in Section 11.D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix I, 10 CFR Part 50 for liquid effluents.

DOMINION VPAP-2103S REVISION 19 PAGE21 OF76 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). _6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitations

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

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

2. The dose rate limit for I 131 , I 133 , for tritium, and for all radioactive materials in particulate f9rm with half-lives greater than 8 days shall be~ 1500 mrem/year to the critical organ.

b. Action

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE220F76

c. Calculations of Gaseous Effluent Dose Rates

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

                                  . x                . x L     [ ( K. Qivv -Q.

l lVV

                                              ) + (K 1* Qipv -Q.lpV ) ] $ 500 mrem/yr to the total body .   (8)

OR

        '1                              . ) + ( (L 1* + 1.1 M. H2ipv !Q.. ) ] $

L..J [ (<L i + 1.1 M.l H2ivv !Q.lVV l lpV

• 3000 mrem/yr to the skin (9) where:

Subscripts = vv, refers to vent releases from the building ventilation vent, including Radwaste Facility Ventilation Vent; pv, refers to the vent releases from the process vent; i, refers to individual radionuclide Kl = the total body dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/m3 L*l = the skin dose factor due to beta emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/m3 M*l = the air dose factor due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/m3 Qivv, Qipv the release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per site) 1.1 the unit conversion factor that converts air dose to skin dose, in mrem/mrad X/Qivv, X/Qipv = the gaseous dispersion factor, sec/m3(See Attach.Inent 7)

DOMINION VPAP-2103S REVISION 19 PAGE23 OF76

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

                          . x             . x
               "'[P.Qivv      -Q. + P 1-Qipv-Q* ] S 1500 mrem/yrto the critical organ               (10)

L...i 1 IVY lpV where: p. I = the critical organ dose factor for I 131 , I 133 , H 3, and all radionuclides in particulate form with half-lives greater than 8 days, for the child inhalation pathway, in mrem/yr per Curie/m3

                 .    .

Qivv,Qipv = the release rat~ for ventilation vents or process vent of I 131 , I 133 , H3 , and all radionuclides i, in particulate form with half-lives greater than 8 days, in gaseous effluents in Curie/sec (per site) X/Qiw, X/Qipv = the gaseous dispersion factor, sec/m3 (See Attachment 7)

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

d. Bases - Dose Rate This specification provides reasonable assurance radioactive materials discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, either at or beyond the SITE BOUNDARY, in excess of the design objectives of Appendix I to 10 CFR Part 50.

This specification is provided to ensure that gaseous effluents from all units on the site will be appropriately controlled. It provides operational flexibility for releasing gaseous effluents to satisfy the Section II.A and Il.C design objectives of Appendix I to 10 CFR Part 50. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrem/year to the whole body, less than or equal to 3000 mrem/year to the skin and the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem/year. This specification does not affect the requirements to comply with the annual limitation of 10 CFR 20.1301(a). This control applies to the release of radioactive materials in gaseous effluents from all units at the site.

DOMINION VPAP-2103S REVISION 19 PAGE240F76 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.l.a. noble gas limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.3.2.d.

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

b. Action

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

• Suspend the release of radioactive gaseous effluents monitored by the affected channel and declare the channel inoperable or
• Change the setpoint so it is acceptably conservative

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

take the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 19 PAGE25 OF76

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

Release Point Instrument Number Process Vent 1-GW-RM-130B Condenser Air Ejector 1-SV-RM-111 2-SV-RM-211 Ventilation Vent No. 1 1-VG-RM-104 Ventilation Vent No. 2 1-VG-RM-131B Radwaste Facility Vent RRM-101

d. Setpoint Calculations

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

(11) where: D = Step 6.3 .1.a. dose limits that implement Technical Specifications for the Station, mrem/yr Dpv = the noble gas site boundary dose rate from process vent gaseous effluent releases, mrem/yr Dcae = the noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr Dvv = the noble gas site boundary dose rate from summation of the Ventilation Vents 1, 2, and the Ra,dwaste Facility vent gaseous effluent releases, mrem/yr

DOMINION VPAP-2103S REVISION 19 PAGE260F76

2. Setpoint values shall be determined by:

Rm x 2.12 E-03 (12) Fm where: m = the release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae), or Radwaste Facility (rv) cm = the effluent concentration limit implementing Step 6.3. l .a. for the Station, µCi/mL Rm = the release rate limit for pathway m determined from methodology in Step 6.3.1.c., typically using Xe 133 as nuclide to be released, µCi/sec 2.12E"""'03 = CFM per rnL/sec Fm = the maximum flow rate for pathway m, CFM NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alarm/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases.

e. Bases - Radioactive Gaseous Effluent Monitoring Instrumentation The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of 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 gaseous effluent dose rate limits of Section 6.3 of the ODCM.

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

DOMINION VPAP-2103S REVISION 19 PAGE270F76 6.3.3 Noble Gas Effiuent Air Dose Limit

a. Requirement

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

• During any calendar quarter: :::; 5 mrads for gamma radiation and :::; 10 in.rad for beta radiation
• During any calendar year: :::; 10 mrads for gamma radiation and :::; 20 mrad for beta radiation

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

at least once per 31 days.

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

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

The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following: For gamma radiation: (13)

DOMINION VPAP-2103S REVISION 19 PAGE28 OF76 For beta radiation: (14) Where: Subscripts vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors pv, refers to the vent releases from the process vent i, refers to individual radionuclide Dg the air dose for gamma radiation, in mrad Db the air dose for beta radiation, in mrad Mi the air dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Ni the air dose factor due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Qivv* Qipv the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) 3 .17 E-08 the inverse of the number of seconds in a year X!Q;w, XIQ;pv = the gaseous dispersion factor, sec!m\See Attachment 7) 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effiuent Dose Limit

a. Requirement

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

• During any calendar quarter: :::;; 7 .5 mrem to the critical organ
• During any calendar year: :::;; 15 mrem to the critical organ

2. Cumulative dose contributions to a member of the public from I 131 , I 133 ,

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

DOMINION VPAP-2103S REVISION 19 PAGE290F76

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

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE300F76

1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary that contain I 131 , 1133 , tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

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

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

tritium, and from all particulate-form radionuclides with half-lives greater than 8 days in Curies 3.17 E-08 the inverse of the number of seconds in a year X!Qvv, X!Qpv = the gaseous dispersion factor, sec/m3 (See Attachment 7) DIQvv, D/Qpv = the gaseous deposition factor, m-2 (See Attachment 7) RM = the cow-milk pathway dose factor due to 1131 , 1133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m2 -mrern/yr per Ci/sec RI = the inhalation pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrern/yr per Ci/m3 RG = the ground plane pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m 2*mrern/yr per Ci/sec RH3 = the tritium dose factor for milk in mrern/yr per Ci/m3

DOMINION VPAP-2103S REVISION 19 PAGE31 OF76 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

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

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations

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

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

DOMINION VPAP-2103S REVISION 19 PAGE320F76

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

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

Dp = (Dg x P) + Da 6.4 Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis. 6.4.1 Liquid Waste Batch Releases  ! I

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

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

batch releases include:

• Turbine Building Sumps when RP determines that source activity requires placing pumps in manual mode
• Condensate Polishing Building Sumps and Steam Generator secondary water when RP determines the presence of contamination from primary-to-secondary leakage
• Radwaste Facility release tanks (LWMT, LDMT) 6.4.2 Continuous Liquid Releases

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

b. Examples of continuous releases include:

• Steam generator blowdown
• Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable
• Storm drains, equipped with composite sampling systems, that receive run-off from rain and turbine building sumps, subsurface drains and ground water wells when pumps are in automatic mode.

DOMINION VPAP-2103S REVISION 19 PAGE33 OF76 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until:

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

6.4.6 Radioactive Liquid and Gaseous Release Controls

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

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

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

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

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

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

• Maximum authorized release rate
• Applicable conditions or controls pertaining to the release

DOMINION VPAP-2103S REVISION 19 PAGE340F76

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

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

1. Verify the correct source is authorized for release.

2. Note maximum authorized release rate.

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

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

As appropriate, required information shall include:

• Date and time release was started
• Starting tank/sump level
• Beginning pressure
• Release flow rate
• Dilution water flow rate

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

• Date and time release was stopped
• Tank/sump ending level
• Release flow rate just prior to termination
• Ending pressure
• Volume released 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem).

DOMINION VPAP-2103S REVISION 19 PAGE35 OF76 6.5.2 Action

a. If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.1 have been exceeded.

b. If the limits in Step 6.5.1 have been exceeded, prepare and submit to the NRC, within 30 days, a special report in accordance with VP AP-2802, Notifications and Reports, that defines the corrective action to be taken to reduce subsequent releases and to prevent recurrence, and includes a schedule for achieving conformance with the limits. Special reports, as defined in 10 CFR 20.2203(a)(4), shall include:

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

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

3. If the estimated dose exceeds the limits in Step 6.5.1, and if the release condition that violates 40 CFR 190 has not already been corrected, the special report shall include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 19 PAGE360F76

3. Samples shall be analyzed in accordance with:

• Radiological Environmental Monitoring Program (Attachment 8) requirements
• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 10)
• Guidance of the Radiological Assessment Branch Technical Positio!1 on Environmental Monitoring dated November, 1979, Revision No. 1

b. Action

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

2. If, when averaged over any calendar quarter, radioactivity exceeds the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11), prepare and submit to the NRC, within 30 days, a special report in accordance with VP AP-2802, Notifications and Reports, that:

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

concentration (1) + concentration (2) + ... :;::: 1.0 (lS) reporting level (1) reporting level (2)

DOMINION VPAP-2103S REVISION 19 PAGE 37 OF76

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11) are detected and are the result of plant effluents, the report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are µnavailable from one or more of th~

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

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

DOMINION VPAP-2103S REVISION 19 PAGE38 OF76 6.6.2 Land Use Census

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

• Nearest milk animal
• Nearest residence
• Nearest garden greater than 50 m2 (500 ft2) that produces broad leaf vegetation

1. The land use census shall be conducted during the growing season, at least once per 12 months, using methods that will provide the best results (e.g.,

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

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

b. Action

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE390F76 6.6.3 Interlaboratory Comparison Program

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

b. Action

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

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

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

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

6.7 Reporting Requirements

6. 7.1 Annual Radiological Environmental Operating Report Routine Radiological Environmental Operating Reports covering the operation of the units during the previous calendar year shall be submitted prior to May 1 of each year.

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

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

• A comparison (as appropriate) with preoperational studies, operational controls, and previous environmental surveillance reports
• An assessment of the observed impacts of the plant operation on the environment
• Results of land use census per Step 6.6.2

DOMINION VPAP-2103S REVISION 19 PAGE400F76

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

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

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

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

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

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

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE41 OF76 NOTE: NUREG-0543 states: "There is reasonable assurance that sites with up to four operating reactors that have releases within Appendix I design objective values are also in conformance with the EPA Uranium Fuel Cycle Standard, 40 CPR Part 190." 6.7.2 Annual Radioactive Effluent Release Report

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

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

Data shall be summarized on an annual basis following the format of Regulatory Guide 1.21, Appendix B, for solid waste. [Commitment 3.2.2]

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

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

• Unplanned releases that exceeded the limits in Steps 6.2.l and 6.3.1
• Unplanned releases which require a Condition Report and involve the discharge of contents of the wrong Waste Gas Decay Tank or the wrong liquid radwaste release tank
• Unplanned releases from large leaks due to unexpected valve or pipe failures that result in a quantity of release such that a 10 CPR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CPR 50.73, Licensee Event Report System, report is required
• Unplanned releases as determined by Radiation Protection Supervision, which may or may not require a Condition Report

DOMINION VPAP-2103S REVISION 19 PAGE420F76

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

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

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

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

• An unintended spill or leak with the potential to reach groundwater, as defined in NEI 07-07, *and
• The spill or leak must be greater than 100 gallons in volume or the volume
• cannot be quantified but is estimated to be greater than 100 gallons; or
• Any spill or leak, regardless of volume or activity deemed by the licensee to be reportable.

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

b. Dose Assessment - Station

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

Population doses shall not be included in dose assessments.

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

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

DOMINION VPAP-2103S REVISION 19 PAGE43 OF76 NOTE: The Annual Radioactive Effluent Release Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

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

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

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

6.7.3 Annual Meteorological Data

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

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

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

a. Approved by the Site Vice President before implementation.

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

Documentation shall include:

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

DOMINION VPAP-2103S REVISION 19 PAGE440P76

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

• 10 CPR 20, Subpart D
• 40 CPR 190
• 10 CPR 50.36a
• 10 CPR 50, Appendix I
• Technical Specifications

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

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

6.7.5 Industry Ground Water Protection Initiative

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

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

b. Communications

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

DOMINION VPAP-2103S REVISION 19 PAGE45 OF76

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

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

c. 30-Day Reports

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

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

d. Annual Reports*

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

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE460F76 7.0 RECORDS 7.1 The following record(s) completed as a result ofthis procedure are required to be transmitted to Nuclear Document Management (NDM). The records have been identified and retention requirements established for the Nuclear Records Retention Schedule (NRRS) per RM-AA-101, Record Creation, Transmittal, and Retrieval.

7. l. l Quality Assurance Records

• Records of changes to the ODCM in accordance with Step 6.7.4
• Records of meteorological data in accordance with Step 6.7 .3
• Records ?f sampling and analyses
• Records of radioactive materials and other effluents released to the environment
• Records of preventive maintenance, surveillances, and calibrations 7.1.2 Non-Quality Assurance Records None 7.2 The following record(s) completed as a result of this procedure are NOT required to be transmitted to Nuclear Document Management (NDM), but are required to be retained as indicated below. The NRRS has been updated and Alternate Storage approved per RM-AA-101 for Quality Assurance Records.

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

DOMINION VPAP-2103S REVISION 19 PAGE47 OF76 ATTACHMENT 1 (Page 1of1) Radioactive Liquid Effiuent Monitoring Instrumentation Instrument Minimum Action Operable Channels

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

2. GROSS BETA OR GAMMA RADIOACTIVITY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMINATION OF RELEASE (a) Circulating Water Discharge Liries, Unit 1: 1-SW-RM-120 1

                                                                                          . 2 Unit 2: 2-SW-RM-220                                               1                   2 (b) Component Cooling Service Water Effluent Lines, 1-SW-RM-107A                                                                                '

1 2 1-SW-RM-107B 1 2 1-SW-RM-107C 1 2 1-SW-RM-107D 1 2

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW-153 1 3 ACTION 1: If the number of op*erable channels is less than required, effluent releases via this pathway shall be suspended.

ACTION 2: If the number *of operable channels is less than required, effluent releases via this pathway may continue provided that, at least once per 12 hours, grab samples are collected and analyzed for principal gamma emitters, as defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). When the effluent release via thls pathway continues, then initiate the "Loss of Radioactive Liquid Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.021, Radioactive Liquid Waste Sampling and Analysis. ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 30 minutes during the actual releases. Design capacity pump performance curves generated in place or volume released over time may be used to estimate flow.

DOMINION VPAP-2103S REVISION 19 PAGE48 OF76 ATTACHMENT 2 (Page 1 of 1) Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel Channel Check Check Calibration !Functional TesJ

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

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

NATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 D M R Q Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, l-SW-RM-107A l-SW-RM-107B D M R Q l-SW-RM-107C 1-SW-RM-107D

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

DOMINION VPAP-2103S REVISION 19 PAGE49 OF76 ATTACHMENT3 (Page 1of3) Radioactive Liquid Waste Sampling and Analysis Program Lower Limit of Liquid Release Sampling Minimum Analysis Type of Activity Detection (LLD) Type Frequency Frequency Analysis (µCi/mL), (Note 1) p p Principal Gamma 5 x 10-7 Emitters (Note 3) I (Each Batch) (Each Batch) 1131 Dissolved and 1x10-6 p Batch Releases- M Entrained Gases 1x10-5 (One Batch/M) (Gamma Emitters) (Note 2) p M Composite H3 1x10-5 (Each Batch) (Note 4) Gross Alpha 1x10-7 p Q Composite Sr89 and Sr90 5 x 10-8 (Each Batch) (Note 4) Fe55 1x10-6 Principal Gamma 5 x 10-7 Continuous WComposite Emitters (Note 6) (Note 6) (Note 6) 1131 1x10-6 Dissolved and Continuous M 1x10-5 M Entrained Gases Releases Grab Sample (Gamma Emitters) (Note 5) Continuous MComposite H3 1x10-5 (Note 6) (Note 6) Gross Alpha 1x10-7 Continuous Q Composite Sr89 and Sr90 5 x 10-8 (Note 6) (Note 6) Fe55 1x10-6

DOMINION VPAP-2103S REVISION 19 PAGE500F76 ATTACHMENT 3 (Page 2 of 3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 Sb LLD (8-1) E

• V
• 2.22E+06
• Y
• e-CA-~t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = .the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) A, the radioactive decay constant for the particular radionuclide

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

The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement. NOTE 2: A batch release is the discharge of liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S REVISION 19 PAGE51 OF76 ATTACHMENT 3 (Page 3 of3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn54, Fe59 , Co58 , Co60 , Zn65 , Mo99 , Cs 134, Cs 137 , Ce 141 , and Ce 144 . This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. I NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and for which the method of sampling employed results in a specimen that is representative of the liquids released. NOTE 5: A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from a volume of a system that has an input flow during the continuous release. NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid effluents, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release.

DOMINION VPAP-2103S REVISION 19 PAGE 520F76 ATTACHMENT 4 (Page 1of4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCjjmL), (Note 1) Prior to Release A. Waste Gas Prior to Release Principal Gamma (Each Tanlc) 1x10-4 Storage Tank (Each Tanlc) Emitters (Note 2) (Grab Sample) Principal Gamma Prior to Release Prior to Release 1x10-4 B. Containment Emitters (Note 2) (Each PURGE) Purge (Each PURGE) H3 1x10-6 (Grab Sample) C. Ventilation Weekly Principal Gamma Weekly 1x10-4 (l)Process Vent (Grab Sample) Emitters (Note 2) (2)Vent Vent #1 (3)Vent Vent #2 (Note 3) (Note 3) H3 1x10-6 (4)SRFVent I 131 1x10- 12 Continuous Weekly (Note 5) (Note 4) (Charcoal Sample) Il33 1x10- 10 Continuous Weekly (Note 5) Principal Gamma 1x10- 11 All Release (Note 4) Particulate Sample Emitter (Note 2) Weekly Continuous Types as listed Composite Gross Alpha 1x10- 11 (Note 4) Particulate Sample in A, B, and C (..!uarterly Continuous Composite Sr89 and Sr90 1x10- 11 (Note 4) Particulate Continuous Noble Gas Monitor Noble Gases Gross 1x10-6 (Note 4) Beta and Gamma Principal Gamma Weekly Weekly 1x10-4 Condenser Air Emitters (Note 2) Grab Sample Ejector (Note 3) H3 1x10-6 (Note 3)

DOMINION VPAP-2103S REVISION 19 PAGE53 OF76 ATTACHMENT 4 (Page 2 of 4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCi/mL), (Note 1) Principal Gamma Prior to Release Prior to Release 1x104 Emitters I (Grab Sample) (Each Release) H3 1x10-6 1131 1 x 10- 11 Continuous Charcoal Sample (Note 4) (Note 6) 1133 1x10- 10 Containment Continuous Particulate Sample Principal Gamma HogDepres- 1x10- 10 (Note 4) (Note 6) Emitter (Note 2) surization Composite Particu-Continuous late Sample Gross Alpha 1x10- 10 (Note 4) (Note 6) Composite Particu-

         *-*-         Continuous late Sample       Sr89 and Sr90       1x10- 10 (Note 4)

(Note 6)

DOMINION VPAP-2103S REVISION 19 PAGE540F76 ATTACHMENT 4 (Page 3 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): LLD (10-1) E

• V
• 2.22E+06
• Y
• e-CA..1.t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9). Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm). E = the counting efficiency (as counts per disintegration). V = the sample size (in units of mass or volume). 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie. Y = the fractional radiochemical yield (when applicable). A, the radioactive decay constant for the particular radionuclide.

         '1.t        =   the elapsed time between the midpoint of sample collection and time of counting.

Typical values of E, V, Y and .M should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement_.

DOMINION: VPAP-2103S REVISION 19 PAGE55 OF76 ATTACHMENT 4 (Page 4 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr87 , Kr88 , Xe 133 , Xe 133 m, Xe 135 , Xe 135 m, andXe 138 for gaseous emissions and Mn54 , Fe59 , Co58 , Co60 , Zn65 , Mo99 , Cs 134, Cs 137 , Ce 141 and Ce 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and identifiable at levels exceeding the LLD, together with the above nuclides, shall also be I identified and reported. NOTE 3: Sampling and analysis shall also be performed following shutdown, start-up, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, when:

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

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

NOTE 4: The ratio of the sample flow rate to the sampled stream flow rate shall be known for the period covered by each dose or dose rate calculation made in accordance with Steps 6.3.1, 6.3.3, and 6.3.4. NOTE 5: Samples shall be changed at least once per seven days and analyses.shall be completed within 48 hours after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours for at least seven days following each shutdown, start-up, or thermal power change exceeding 15 percent of rated thermal power in one hour, and analyses shall be completed within 48 hours of changing. When samples collected for 24 hours are analyzed, the corresponding LLDs may be increased by a factor of 10. This requirement applies if:

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE560F76 ATTACHMENT 5 (Page 1of2) Radioactive Gaseous Effiuent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS

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

1-GW-RM-130B 1 1 (b) Iodine Sampler: Continuous HP Sampler, or 1--GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (c) Particulate Sampler: Continuous HP Sampler, or 1-GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor: 1-GW-Ff-100 1 3 (e) Sampler Flow Rate Measuring Device: HP Sampler Rotometer or. MGPI Flow Rate Measuring 1 3 Device

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

1-SV-RM-111 1 1 2-SV-RM-211 1 1 (b) Air Ejector Flow Rate Measuring Device: Unit 1: 1-VP-FI-lA 1 3 1-VP-FI-lB 1 3 Unit 2: 2-VP-FI-lA 1 3 2-VP-FI-lB 1. 3

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

SRF: RRM-101 1 1 SPS: Vent#l, 1-VG-RM-104 1 1 Vent#2, l-VG-RM-131B 1 1 (b) Iodine Sampler: SRF: RRM-101 1 2 SPS: Vent #1, l-VG-RM-104 (NOTE 2) 1 2 Vent #2, Continuous HP Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler

DOMINION VPAP-2103S REVISION 19 PAGE57 OF76 ATTACHMENT 5 (Page 2of2) Radioactive Gaseous Effiuent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS (c) Particulate Sampler: SRF: RRM-101 1 2 SPS: Vent#l, VG-RM-104 (NOTE 2) 1 2 Vent #2, HP Continuous Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 I In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor: SRF: 01-RHV-FT-156 1 3 SPS: Vent#l, 1-VS-FT-119 1 3 Vent #2, 1-VS-FT-116 1 3 (e) Sampler Flow Rate Measuring Device: SRF: RRM-101 1 3 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 3 Vent #2, HP Sampler Rotometer or 1 3 MGPI Flow Rate Measuring Device NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components. NOTE 2: Vent# 1, l-VG-RM-104, HP continuous sampler pump automatically maintains isokinetic sample flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take 15 - 20 minutes. [Commitment 3.23] ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours and these samples are analyzed for gross activity within 24 hours. When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis. [Commitment 3.2.4] ACTION2: If the number of operable channels is less than required, effluent releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours after the initiation ofthis ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4). [Commitment 3.2.4] ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours.

DOMINION VPAP-2103S REVISION 19 PAGE58 OF76 ATTACHMENT 6 (Page 1of2) Radioactive Gaseous Effiuent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL CHANNEL SOURCE CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST

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

Providing Alarm and Automatic Termination of Release 1-GW-RM-130B D M R Q (b) Iodine Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor 1-GW-Ff-100 D NIA R NIA (e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or D NIA SA NIA MGPI Flow Rate Measuring Device D NIA R NIA

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

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

DOMINION VPAP-2103S REVISION 19 PAGE590F76 ATTACHMENT 6 (Page 2of2) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL SOURCE CHANNEL CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST (b) Iodine Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA I In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor SRF:Ol-RHV-FT-156 SPS: Vent #1, 1-VS-FT-119 Vent#2, 1-VS-FT-116 D NIA R NIA (e) Sampler Flow Rate Measuring Device (NOTE 1) SRF: RRM-101 D NIA R NIA SPS: Vent#l, 1-VG-RM-104 D NIA R NIA Vent #2, HP Sampler Rotomete1 D NIA R NIA or MGPI Flow Rate Measuring Device b NIA SA NIA NOTE l:The marknumbers listed above in l(b), l(c), 3(b), 3(c), and 3(e) refer to the gaseous effluent radiation monitor or monitor skid with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor. I

DOMINION VPAP-2103S REVISION 19 PAGE600F76 ATTACHMENT 7 (Page 1 of 1) Dispersion and Deposition Factors Distance, Ventilation Vent Process Vent Description Sector meters X!Q DIQ X!Q D!Q N 500 l.4E-05 J.6E-08 4.2E-08 3.9E-10 NNE 532 l.8E-05 3.3E-08 l.2E-07 l.2E-09 NE 629 l.3E-05 3.0E-08 l.8E-07 l.6E-09 ENE 806 7.lE-06 l.3E-08 l.8E-07 l.8E-09 E 1210 2.7E-06 7.2E-09 2.6E-07 l.8E-09 ESE 1984 9.8E-07 3.2E-09 2.4E-07 l.7E-09 SE 1371 2.2E-06 6.8E-09 2.6E-07 2.lE-09 SSE 919 4.3E-06 9.2E-09 2.3E-07 l.2E-09 Site Boundary s 645 5.9E-06 l.lE-08 1.7E-07 l.3E-09 SSW 565 6.3E-06 l.2E-08 l.3E-07 l.4E-09 SW 548 9.7E-06 l.9E-08 l.3E-07 l.3E-09 WSW 656 8.4E-06 1.6E-08 l.4E-07 l.3E-09 w 565 l.2E-05 2.9E-08 l.2E-07 l.OE-09 WNW 565 l.4E-05 2.6E-08 8.7E-08 5.8E-10 NW 581 l.3E-05 1.7E-08 l.2E-07 8.9E-10 NNW 581 9.SE-06 l.lE-08 5.lE-08 3.lE-10 N 6534 2.4E-07 2.lE-10 6.7E-08 8.8E-11 NNE 3122 l.OE-06 1.7E-09 l.9E-07 3.7E-10 NE 7564 2.7E-07 4.2E-10 6.7E-08 l.8E-10 SE 4554 3.4E-07 8.6E-10 8.7E-08 2.7E-10 SSE 4265 3.7E-07 6.6E-10 9.5E-08 2.5E-10 s 2736 5.SE-07 9.SE-10 l.9E-07 5.7E-10 Resident SSW 2977 . 4.lE-07 7.4E-10 l.4E-07 4.5E-10 SW 3637 4.SE-07 7.7E-10 l.2E-07

• 3.4E-10 WSW 660 6.4E-06 l.3E-08 l.8E-07 l.3E-09 w 5053 3.4E-07 7.lE-10 8.lE-08 2.lE-10 WNW 7886 2.2E-07 2.9E-10 4.9E-08 9.4E-11 NW 7467 2.2E-07 2.2E-10 5.8E-08 l.3E-10 NNW 6035 2.3E-07 2.0E-10 6.2E-08 7.lE-11 SSW 7693 9.9E-08 1.4E-10 5.0E-08 l.2E-10 Milk Cow NNW 5938 2.4E-07 2.lE-10 6.3E-08 7.lE-11 SSE 4265 3.7E-07 6.6E-10 9.5E-08 2.5E-10 s 3235 4.2E-07 7.lE~lO l.6E-07 4.3E-10 SSW 3122 3.8E-07 6.8E-10 l.3E-07 4.lE-10 Garden SW 7596 l.5E-07 2.lE-10 5.3E-08 l.2E-10 WSW 5713 2.0E-07 3.2E-10 7.5E-08 l.8E-10 w 5536 3.0E-07 6.0E-10 7.5E-08 l.8E-10 NNW 7017 l.9E-07 1.6E-10 5.3E-08 7.4E-11

DOMINION VPAP-2103S REVISION 19 PAGE 61 OF76 ATTACHMENT 8 (Page 1of3) Radiological Environmental Monitoring Program Exposure *Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

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

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

2) Outer Ring 6 to 8 km from the site with a station in Quarterly Quarterly each sector (NOTE 1)

3) The balance of the 8 dosimeters should be placed in special interest areas such as population centers, nearby residents, schools, and in 2 or 3 areas to serve as controls

2. AIRBORNE Samples from 7 locations:

a) 1 sample from close to the site boundary location of the highest calculated Radioiodine Canister annual average ground 1131 Analysis Weekly level Continuous Radioiodines and D/Q Sampler Particulates b) 5 sample locations 6-8 km operation with Particulate Sampler distance located in a sample collection Gross beta radioactivity concentric ring around the weekly analysis following filter Station change; c) 1 sample from a control Gamma isotopic analysis of location 15-30 km distant, composite (by providing valid location) quarterly background data NOTE 1: As described in the Branch Technical Position, Revision 1, November 1979, no TLD station is required in the SE sector at the 4-5 mile range due to geographical limitations.

DOMINION VPAP-2103S REVISION 19 PAGE620F76 ATTACHMENT 8 (Page 2 of 3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

3. WATERBORNE Gamma isotopic analysis a) 1 sample upstream monthly; a) Surface Monthly Sample b) 1 sample downstream Composite for tritium analysis quarterly Gamma isotopic and tritium b) Ground Sample from 1or2 sources Quarterly analysis quarterly c) Sediment from a) 1 sample upstream Gamma isotopic analysis Semi-Annually shoreline b) 1 sample downstream semi-annually a) 1 sample upstream Gamma isotopic analysis d) Silt Semi-Annually b) 1 sample downstream semi-annually

4. INGESTION a) Milk a) 2 samples from milking animals in the vicinity of the Station. (NOTE 1) Gamma isotopic and r131 b) 1 sample from milking Monthly animals at a control analysis monthly location (-15-30 km distant). (NOTE 2) a) 6 samples of filter feeders (clams, oysters) in the Semi-Annually b) Fish and vicinity of the Station Gamma isotopic on edible Invertebrates c) 1 sampling of crabs from Annually portions the vicinity of the Station d) 1 sampling of 2 different species in vicinity of Semi-Annually Station discharge area.

(NOTE3) NOTE 1: If milk sampling cannot be performed, use item 4.c, Food Products - d. Milk sampling cannot be performed when there are no milk sampling locations in the vicinity of the Station. NOTE2: If milk sampling from a control location cannot be performed, use item 4.c) e). Milk sampling cannot be performed when there is no milk sampling location 30 km distant. NOTE3: Commercially or recreationally important species permitted for sampling by the Virginia Marine Resources Commission include catfish, white perch, croaker, striped bass, spot, red drum, and striped mullet.

DOMINION VPAP-2103S REVISION 19 PAGE 63 OF76 ATTACHMENT 8 (Page 3of3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

4. INGESTION (Continued)

I a) 1 sample com b) 1 sample soybeans Annually Gamma isotopic on edible portions c) 1 sample peanuts d) 1 sample of a broadleaf vegetation grown

i. nearest in each of two different available offsite locations (sectors) with the c) Food Products highest annual average ground level D/Qs, if Monthly, if.

Gamma isotopic and 1131 milk sampling is not available, or at analysis performed. harvest e) 1 sample of a broadleaf vegetation grown 15 - 30 km distant in the available least prevalent wind directio.n, if milk sampling is not performed.

DOMINION VPAP-2103S REVISION 19 PAGE640F76 ATTACHMENT9 * (Page 1of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Air Charcoal and Surry Station (SS) 0.3 NNE Particulate Hog Island Reserve (HIR) 2.0 NNE Bacon's Castle (BC) 4.5 SSW Alliance (ALL) 5.1 WSW Colonial Parkway (CP) 3.8 NNW BASF (BASF) 5.1 ENE Fort Eustis (FE) 4.9 ESE Newport News (NN) 19.3 SE Control Location Environmental Control (00) Onsite

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

North North West (04) 0.2 NNW Site Boundary North (05) 0.3 N Site Boundary North North East (06) 0.3 NNE Site Boundary North East (07) 0.3 NE Site Boundary East North East (08) 0.4 ENE Site Boundary East (09) 0.3 E Site Boundary West (10) 0.1 w Site Boundary West South West (11) 0.4 WSW Site Boundary South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary South (14) 0.4 s Site Boundary South South East (15) 0.6 SSE Site Boundary South East (16) 0.9 SE Site Boundary Station Intake (18) L6 ESE Site Boundary Hog Island Reserve (19) 2.0 NNE Near Resident

DOMINION VPAP-2103S REVISION 19 PAGE65 OF76 ATTACHMENT 9 (Page 2of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Environmental Bacon's Castle (20) 4.5 SSW Approx. 5 miles TLDs Route 633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles I Surry Route 636 and 637 (23) (24) 7.7 4.0 WSW w Population Center Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles Kingsmill (29) 4.6 N Approx. 5 miles Williamsburg (30) 7.8 N Population Center Kingsmill North (31) 5.5 NNE Approx. 5 miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News (38) 19.3 SE Population Center James River Bridge (39) 17.1 SE Control Benn's Church (40) 17.0 SSE Control Smithfield (41) 13.4 SSE Control Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 s Approx. 5 miles Milk Epps 4.8 SSW Colonial Parkway 3.7 NNW Williams 27.5 s Control Location I

DOMINION VPAP-2103S REVISION 19 PAGE 66 OF76 ATTACHMENT 9 (Page 3 of 3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Well Water Surry Station Onsite** Hog Island Reserve 2.0 NNE Construction Site 0.3 E Onsite*** Crops (Com, Slade's Farm 3.2 s Peanuts, Soybeans) Brock's Farm 3.8 s River Water Surry Discharge 0.4 NW (Monthly) Scotland Wharf 4.9 WNW Control Location Sediment Chickahominy River 11.2 WNW Control Location (Silt) Surry Station Discharge 1.3 NNW Clams Chickahominy River 11.2 WNW Control Location Surry Station Discharge 1.3 NNW Jamestown Island 3.9 NW Oysters Point of Shoals 6.4 SSE Mulberry Point 4.9 ESE Lawne's Creek 2.4 SE Crabs Surry Station Discharge 1.3 NNW Fish Surry Station Discharge 1.3 NNW Shoreline Hog Island Reserve 0.6 N Sediment Chickahominy River 11.2 WNW Control Location

• Onsite Location - in Lead Shield
  • Onsite sample of Well Water taken from tap-water at Surry Environmental Building
    • Onsite sample of Well Water taken from tap-water at Surry Training Center

DOMINION VPAP-2103S REVISION 19 PAGE 67 OF76 ATTACHMENT 10 (Page 1of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) Analysis Water Airborne Fish Milk Food Sediment (NOTE2) (pCi/L) Particulate (pCi/kg) (pCi/L) Products (pCi/kg) or Gases (wet) (pCi/kg) (dry)

                                  .(pCifm3)                                      (wet)

Gross beta 4 0.01 I H-3 2,000 Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 I-131 (NOTE3) 1. 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 La-140 15 15 NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also be identified and reported. NOTE 3: LLD for the ground (drinking) water samples. The LLD for the surface (non-drinking) water samples is 10 pCi/L.

DOMINION VPAP-2103S REVISION 19 PAGE68 OF76 ATTACHMENT 10 (Page 2of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 ~b LLD (24-1) E

• V
• 2.22E+06
• Y
• e-(A~t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per micrdcurie Y = the fractional radiochemical yield (when applicable) A the radioactive decay constant for the particular radionuclide

         ~t          =  the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, not plant effluent samples)

Typical values of E, V, Y and ~t should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP-2103S REVISION 19 PAGE690F76 ATTACHMENT 11 (Page 1 of 1) Reporting Levels for Radioactivity Concentrations in Environmental Samples Analysis Water Airborne , Fish Milk Food Products (pCi/L) Particulate or (pCi/kg, wet) (pCi/L) (pCilkg, wet) Gases (pCifm3) H-3 20,000* Mn-54 1,000 30,000

 , Fe-59             400                              10,000 Co-58            1,000                           . 30,000 Co-60             300                              10,000 Zn-65             300                              20,000 Zr-Nb-95            400 I-131              2*             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
    *Reporting level for the ground (drinking) water samples required by Radiological Environmental Monitoring Program (Attachment 8). The reporting level for the surface (non-drinking) water samples required by Attachment 8 is 30,000 pCi/L for H-3 and 20 pCi/L for I-131.

DOMINION VPAP-2103S REVISION 19 PAGE 700F76 ATTACHMENT 12 (Page 1of7) Meteorological, Liquid, and Gaseous Pathway Analysis

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

1.2 Meteorological Data, Parameters, and Methodology A five (5) year average of representative onsite meteorological data for the period January 1, 2007 through December 31, 2011, is used in the gaseous effluent dose pathway calculations. This data includes wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases characterized as ground level (i.e., ventilation vent), and those characterized as mixed mode (i.e., process vent). X!Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ - Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324. The open terrain adjustment factors were applied to the X/Q values as recommended in Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain correction factors are considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area. The effective release height used in mixed mode release calculations was based on a process vent release height of 131 ft, and plume rise due to momentum for a vent diameter of 1.5 in. with plume exit vefocity of 100 ft/sec. Ventilation vent, and vent releases other than from the process vent, are considered ground level as specified in Regulatory Guide 1.111 for release points less than the height of adjacent solid structures. Terrain elevations were obtained from Surry Power Station Units 1 and 2 Virginia Electric and Power Company Updated Final Safety Analysis Report Table l lA-8. XIQ and D/Q values were calculated for the nearest site boundary, residence, milk-cow, discharge bank, and vegetable garden by sector for process vent and ventilatiOJ?- vent releases.

DOMINION VPAP-2103S REVISION 19 PAGE 71 OF76 ATTACHMENT 12 (Page 2 of7) Meteorological, Liquid, and Gaseous Pathway Analysis

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

However, these releases are considered long term for dose calculations as past releases were 1 both random in time of day and duration as evidenced by reviewing past release reports. Therefore, the use of annual average concentrations is appropriate according to NUREG-0133. I 1.3

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

2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose The purpose of the liquid pathway analysis was to determine the maximum exposed member of the public in unrestricted areas as a result of radioactive liquid effluent iele~ses. The analysis included a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste Effluents. 2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station effluent release reports. The data for each year, along with appropriate site specific parameters and default selected parameters, were entered into the NRC computer code LADTAP as described in NUREG-1276. Liquid radioactive effluents from both units are released to the James River via the discharge canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do n.ot exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours per year, and that bank fishing would be performed a maximum of 160 hours per year.

DOMINION VPAP-2103S REVISION 19 PAGE 720F76 ATTACHMENT 12 (Page 3of7) Meteorological, Liquid, and Gaseous Pathway Analysis For an individual fishing in the discharge canal, no river dilution was assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e., a mixing ratio of 0.2) was assumed as appropriate according to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities and ingestion of fish and invertebrates are included in the Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year the individual spent fishing in the canal. 2.3. Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and inyertebrate pathways, are calculated for total body and various critical organs. Validation of the limiting age group and critical organ is performed by the liquid effluent dose calculation program using the data, parameters, and methodology provided in the Source Code file. 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose Gaseous effluent pathway analyses are performed to determine the location that would result in the maximum doses due to noble gases, for use in demonstrating compliance with Steps 6.3.1.a. and 6.3.3.a. The analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the rel~ase of I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than eight days for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed individual through the inhalation pathway from I 131 , I 133 , tritium, and particulates to demonstrate compliance with Step 6.3.1.a.

DOMINION VPAP-2103S REVISION 19 PAGE 73 OF76 ATTACHMENT 12 (Page 4 of7) Meteorological, Liquid, and Gaseous Pathway Analysis 3.2 Data, Parameters, and Methodology Five year average XIQ values were calculated, as described in Section 1 of this attachment. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble gases would be at these site boundary locations. The doses from both the ventilation vent and process vent release points are summed to calculate total maximum dose. 6.3.l.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and X!Q values determined for maximum noble gas doses can be used to determine the maximum dose from I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway. The maximum exposed individual for 10 CFR 50, Appendix I, compliance could be at any of the following locations: site boundary, nearest resident, nearest milk-cow, or nearest vegetable

   *garden, using the Land Use Census data which is assessed annually. Therefore, ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous.

effluent dose pathway analyses. Ground plane, inhalation, cow-milk, and vegetable garden pathways are active with the exception of the infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses. The gamma and beta dcise factors Kivv. Livv. Mivv. and Nivv for ground level releases and the gamma and beta dose factors Kipv. Lipv. Mipv. and Nipv for mixed mode releases are included in the Source Code file. Inhalation pathway dose factors Pivv and Pipv are calculated using the following equation: Pi= K' (BR) DFAi mrem/yr per Ci/m3 (28-1) where: K' =a constant of unit conversion, lE+ 12 pCi/Ci BR= the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev.l DFAi = the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 19 PAGE 740F76 ATTACHMENT 12 (Page 5 of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R.G. 1.109, Rev. 1. It was determined that the member of the public within site boundary would be using the

   .discharge canal bank for fishing a maximum of 160 hours per year. Active pathways are ground plane and inhalation, and all age groups are evaluated for this pathway analysis.

The RMivv and RMipv dose factors, except for tritium, are calculated using the following equation: RM.1 K' Q F (U ap ) F . (r) (DFL.) [f f ( f f ) -1.AJ

                                                   ~ + 1- p s e 1

e-A.itr (28-2) A,. +'A m i y y 1 w p s where: K' = a constant of unit conversion, lE+ 12 pCi/Ci Qp =cow's consumption rate, 50, in kg/day (wet weight) Uap= infant milk consumption rate, 330, in liters/yr Yp =agricultural productivity by unit area of pasture feed grass, 0.7 in kg/m2 Y s =agricultural productivity by unit area of stored feed, 2.0, in kg!m2 Fm =stable element transfer coefficients, in days/liter r =fraction of deposited activity retained on cow's feed grass, 1.0 for radioiodine, and 0.2 for particulates DF'Lj=critical organ ingestion dose factor for the ith radionuclide for the particular age group, inmrem/pCi A.j = decay constant for the ith radionuclide, in sec-1 Aw =decay constant for removal of activity of leaf and plant surfaces by weathering, 5. 73E-07 sec-1 (corresponding to a 14 day half-life) tf = transp~rt time from pasture to cow, to milk, to receptor, 1.73+05, in seconds th =transport time from pasture, to harvest, to cow, to milk, to receptor, 7.78E+06, in seconds fp =fraction of year that cow is on pasture, 1.0 (dimensionless)

DOMINION VPAP-2103S REVISION 19 PAGE 75 OF76 ATTACHMENT 12 (Page 6 of7) Meteorological, Liquid, and Gaseous Pathway Analysis f8 =fraction of cow feed that is pasture grass while cow is on pasture, 0.8 (dimensionless) Parameters used above were obtained from NUREG-0133 and Regulatory Guide 1.109, Rev.1. Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation is used: K'Kp mQFUap(DFLH3) [0.75(0.5/H~ (28-3) where: K'; '= a constant of unit conversion 1E+03 gm/kg H = absolute humidity of the atmosphere, 8.0, in gmfm3 0.75 =the fraction of total feed that is water 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined. The inhalation pathway dose factors Rlivv and Rlipv were calculated using the following equation: Rli = K' (BR) DFAi mrem/yr per Ci/m3 (28-4) where: K' = aconstant of unit conversion, lE+ 12 pCi/Ci BR= breathing rate of the particular age group, m3/yr DFAi=critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 19 PAGE 76 OF76 ATTACHMENT 12 (Page 7of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R. G. 1.109, Rev. 1.

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

RG~K'K"(SF)DFG; [  !-~;'*'* ] (-m_z_~m-il_r:-:-cl_y_r_) (28 - 5) where: K' = A constant of unit conversion, IE+ 12 pCi/Ci K" = A constant of unit conversion, 8760 hr/year.

                = The decay constant for nuclide i, sec- 1.
                =  The exposure time, 4.73x108 sec (15 years), from Table E-15 of Reg Guide 1.109.
                =  The ground plane dose conversion factor for nuclide i, from Table E-6 of Reg. Guide 1.109 (mrern/hr per pCi/m2). . .        .

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

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

Attachment 5 Page 1of1 INOPERABILITY OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENT MONITORING INSTRUMENTATION The Annual Radioactive Effluent Release Report shall explain why monitoring instrumentation required by the ODCM Attachments land 5, which were determined to be inoperable, were not returned to operable status within 30 days. Two of the above referenced instrumentation were inoperable greater than 30 days during this reporting period. On 05/06/2015, the Surry Radwaste Facility (SRF) Ventilation Stack Noble Gas Monitor selector switch was determined inoperable. The selector switch provides the capability to toggle through various monitor parameters and perform selected functions. Two instruments required to monitor the SRF stack release pathway, in accordance with Attachment 5 of the ODCM, were rendered inoperable with the loss of the selector switch. The instruments lost were the noble gas activity radiation monitor and the flow rate measuring device for the stack continuous particulate and iodine sampler. Additionally, although not required by Attachment 5, the capability to source check the noble gas activity radiation monitor was rendered inoperable. Compensatory measures for the loss of the instruments were initiated in accordance with the ODCM. For the loss of the noble gas activity radiation maonitor, grab samples of the SRF stack exhaust are taken and analyzed at least once every 12 hours. No activity has been detected in any of these samples. For the loss of the sampler flow rate measuring device, an estimate of the sampler flow rate is made at least once per 4 hours and documented in the Station logs. At this time, these instruments remain inoperable with compensatory measures in place. A similar radiation monitor skid was obtained to replace the current skid, but it could not be made functional. Design Change 15-01054 has been initiated to obtain and install a new radiation monitoring system for the SRF ventillation in 2016.

Attachment 6 Page 1 of 1 UNPLANNED RELEASES There were no unplanned liquid or unplanned gaseous releases during this reporting period.

Attachment 7 Page 1 of 1 LOWER LIMIT OF DETECTION (LLD) FOR EFFLUENT SAMPLE ANALYSIS GASEOUS: Isotope Reguired LLD Typical LLD Kr-87 l.OOE-04 2.21E 4.78E-05 Kr-88 l.OOE-04 l .56E l.94E-05 Xe-133 l.OOE-04 l.28E l.48E-05 Xe-133m l.OOE-04 3.68E 4.06E-05 Xe-135 l.OOE-04 3.66E l.23E-05 Xe-135m l.OOE-04 l.35E-05 - 8.36E-05 Xe-138 l.OOE-04 2.32E 9.90E-05 I-131 l.OOE-12 4.06E 4.06E-13 I-133 l.OOE-10 4.06E-ll - 4.06E-l l Sr-89 l.OOE-11 l.23E 3.68E-12 Sr-90 1.00E-11 1. 76E-l 5 - 5.87E-13 Cs-134 l.OOE-11 l.53E 2.50E-13 Cs-137 1.00E-11 l.54E 3.38E-13 Mn-54 l.OOE-11 2.50E 2.77E-13 Fe-59 l.OOE-11 3.50E 8.38E-13 Co-58 l.OOE-11 l.72E 3.12E-13 Co-60 l.OOE-11 2.58E 4.97E-13 Zn-65 l .OOE-11 4.98E 6.99E-13 Mo-99 l.OOE-11 4.06E 4.06E-12 Ce-141 l.OOE-11 2.06E 2.98E-13 Ce-144 1.00E-11 7.89E l.34E-12 Alpha l.OOE-11 1.68E 2.21E-14 Tritium l.OOE-06 5.09E 6.61E-08 LIQUID: Sr-89 5.00E-08 2.61E-08 - . 4.30E-08 Sr-90 5.00E-08 6.15E-09 - l.69E-08 Cs-134 5.00E-07 1.94E-08 - 5.0lE-08 Cs-137 5.00E:.07 l.58E-08 - 7.85E-08 I-131 l.OOE-06 2.81E-08 - 5.52E-08 Co-58 5.00E-07 2.18E-09 - 5.99E-08 Co-60 5.00E-07 2.77E-09 - 8.82E-08. Fe-59 5.00E-07 3.25E-08 - 1.48E-07 Zn-65 5.00E-07 5.09E-09 - l.37E-07 Mn-54 5.00E-07 3.19E-09 - 6.09E-08 Mo-99 5.00E-07 2.92E-07 - 4.95E-07 Ce-141 5.00E-07 2.93E-08 9.27E-08 Ce-144 5.00E-07 l.17E-07 - 3.47E-07 Fe-55 1.00E-06 3.02E-07 - 9.94E-07 Alpha l.OOE-07 2.73E-08 - 2.76E-08 Tritium 1.00E-05 l.26E-06 - 1.63E-06 Xe-133 l.OOE-05 8.67E-08 - 2.95E-07 Xe-135 l .OOE-05 2.07E-08 - l.18E-07 Xe-133m l.OOE-05 . 2.lOE-07 - 5.66E-07 Xe-135m 1.00E-05 l.53E-06 - 2.81E-06 Xe-138 l.OOE-05 2.38E-06 - 8.78E-06 Kr-87 l.OOE-05 1.15E-07 2.53E-07 Kr-88 1.00E-05 1.59E-08 - 7.85E-07

Attachment 8 Page I of 2 INDUSTRY GROUNDWATER PROTECTION INITIATIVE The following is a summary of 2015 sample analyses of ground water monitoring wells that are not a part of the Radiological Environmental Monitoring Program (REMP). Analyses are performed by an independent laboratory. Well Sample Tritium Gamma Fe-55 Ni-63 Sr-90 TRU Designation Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter 1-PL-Piez-04 3/11/15 <1,240 ND NA NA NA NA 1-PL-Piez-05 3/11115 6,690 ND <95.4 <3.04 <1.00 NA 1-PL-Piez-06 3/11/15 2,030 ND <175 <4.95. <0.884 NA 1-PL-Piez-07 3/11/15 <1,250 ND NA NA NA NA 1-PL-Piez-27 3/11/15 <1,260 ND NA NA NA NA

        . 1-PL-Piez-33    3/11/15 <1,270       ND        NA       NA        NA        NA 1-PL-Piez-34    3/11/15 <1,250       ND        NA       NA        NA        NA 1-PL-Piez-41    3/11/15 <1,260       ND        NA       NA        NA        NA 1-PL-Piez-42    3/11/15 <1,250       ND        NA       NA        NA        NA 1-PL-Piez-29    3/12/15   7,670      ND       <141     <3.06    <0.713      NA 1-PL-Piez-05    6/8/15    7,150      ND        NA       NA        NA        NA 1-PL-Piez-06    6/8/15    1,960      ND        NA       NA        NA        NA 1-PL-Piez-09    6/8/15   <1,090      ND        NA       NA        NA        NA 1-PL-Piez-20    6/8/15   <1,090      ND        NA       NA        NA        NA 1-PL-Piez-22    6/8/15   <1,100      ND        NA       NA        NA        NA 1-PL-Piez-24    6/8/15   <1,100      ND        NA       NA        NA        NA 1-PL-Piez-25    6/8/15   <1, 110     ND        NA       NA        NA        NA 1-PL-Piez-28    6/8/15   <1,100      ND        NA       NA        NA        NA 1-PL-Piez-3 3   6/8/15   <1,090      ND        NA       NA        NA        NA 1-PL-Piez-34    6/8/15   <1,100      ND        NA       NA        NA       NA 1-PL-Piez-37    6/8/15   <1,090     ND         NA       NA        NA       NA 1-PL-Piez-39    6/8/15   <1,100      ND        NA       NA        NA       NA 1-PL-Piez-40    6/8/15   <1,100     ND         NA       NA        NA       NA 1-PL-Piez-03    619115   <l,090     ND         NA       NA        NA       NA 1-PL-Piez-04    619115   <1,100     ND         NA       NA        NA       NA 1-PL-Piez-07    6/9/15   <1,100     ND         NA       NA        NA       NA 1-PL-Piez-08    619115   <1,100     ND         NA       NA        NA       NA 1..:PL-Piez-23  619115   <1,100     ND        NA        NA        NA       NA 1-PL-Piez-2 7   619115   <1,120     ND        NA        NA        NA       NA 1-PL-Piez-29    6/9/15    9,480     ND        NA        NA        NA       NA 1-PL-Piez-35    6/9/15   <1090      ND        NA        NA        NA       NA 1-PL-Piez-36    619115   <1100      ND        NA        NA        NA       NA 1-PL-Piez-38    61911~   <1090      ND        NA        NA       NA        NA 1-PL-Piez-41    6/9/15   <1090      ND        NA        NA        NA       NA 1-PL-Piez-42    6/9/15   <1100      ND        NA        NA       NA        NA

Attachment 8 Page 2 of 2 INDUSTRY GROUND WATER PROTECTION INITIATIVE Well Sample Tritium Gamma Fe-55

• Ni-63 Sr-90 TRU I '

Designation Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter 1-PL-Piez-04 8/25115 <976 NA NA NA NA NA 1-PL-'fliez-05 8/25/15 6,260 ND NA NA NA NA 1-PL-Piez-06 8/25/15 2,340 ND NA NA NA NA 1-PL-Piez-07 8/25/15 <974 ND NA NA NA NA 1-PL-Piez-27 8/25/15 <976 ND NA NA NA NA

• l-PL-Piez.:29 8/25/15 7,640 ND NA NA NA NA 1-PL-Piez-33 8/25/15 <975 ND NA NA NA NA 1-PL-Piez-34 8/25/15 <975 ND NA NA NA NA 1-PL-Piez-41 8/25/15 <975 ND NA NA NA NA 1-PL-Piez-42 . 8/25/15 <976 NA NA NA NA NA 1-PL-Piez-04 12/9/15 <1,290 NA NA NA NA NA f-PL-Piez-05 12/9/15 7,220 ND NA NA NA NA 1-PL-Piez-06 12/9/15 2,900 ND NA .NA NA NA l-PL-Piez.,07 12/9/15 <1,290 ND NA NA NA NA 1-PL-Piez-08 12/9/15 <1,290 ND NA *NA NA NA 1-PL-Piez-24 12/9/15 <1,300 ND NA NA NA NA 1-PL-Piez-25 12/9/15 *. <1,300 NA NA NA NA NA 1-PL-Pi'ez-27 12/9/15 <1,280 NA NA *NA -NA NA 1-PL-Piez-29 12/9/15 7;470 NA NA NA NA NA l-PL-Piez.,.33 12/9/15 <1,250 ND NA NA NA NA 1-PL-Piez-34 12/9/15 <1,280 ND NA NA NA NA i-PL-Piez-40 12/9/15 . <:1,290 NA NA NA NA NA 1-PL-Piez-41 12/9/15 <1,310 NA. NA. NA NA NA 1-PL-Piez-42 12/9/15 <1,300 NA NA NA NA NA NA = Analysis not required.

ND= No non-natural gamma emitting nuclides detected when analyzed to REMP LLDs. TRU = Transuranics (Am-241, Cm-242, Cm-243/244, Pu-238 ,Pu-239/240 and Pu-241)

VIRGINIA ELECTRIC AND POWER COMP.ANY RICHMOND, VIRGINIA 23261 May 2, 2016 United States Nuclear Regulatory Commission Serial No. 16-164 Attention: Document Control Desk SS&LffSC RO Washington, DC 20555-0001 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT Enclosed is the Surry Power Station Annual Radioactive Effluent Release Report for January 1, 2015 through December 31, 2015. The report, submitted pursuant to Surry Power Station Technical Specification 6.6.B.3, includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released during the 2015 ---

• calendar year, as outlined in Regulatory Guide 1.21, Revision 1, June 1974.

If you have any further questions, please contact Jason Eggart at 757-365-2010. Douglas . Lawrence Director Safety & Licensing Surry Power Station Attachment Commitments made in this letter: None cc: U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector Surry Power Station

Serial No. 16-164 SPS Annual Rad Effluent Report Docket Nos.: 50-280,'50-281 ATTACHMENT 1 2015 Annual Radioactive Effluent Release Report SURRY POWER STATION UNITS 1AND2 VIRGINIA ELECTRIC AND POWER COMPANY

Surry Power Station 2015 Annual Radioactive Effluent Release Report

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT SURRY POWER STATION

          . January 1, 2015 through December 31, 2015 Prepared By: _    ___,__/?_.f..___._~----1-{-~

__ -:f-_ ___ P. F. Blount Health Physicist Reviewed By: ----'°-7_0 __._A_L_~_,__ P.R. Harris __* ______ Supervisor Radiological Analysis Reviewed By: ---~,___ _____ C__/-~_:::::::::=r::::--""'-_,__ _ _ _ __ w:ATuIT{Z.~ Supervisor Health Physics Technical Services ApprovedBy: ~ *~ 1J f_,,h4

                    -UJ.W.Eg~~

Manager Radiological Protection and Chemistry

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT FOR THE SURRY POWER STATION January l, 2015 through December 31, 2015 Section No. Subject 1 Executive Summary 1 2 Purpose and Scope 3 Discussion 3 4 Supplemental Information 4 Attachment 1 Effluent Release Data Attaclup.ent 2 Annual and Quarterly Doses

• Attachment 3 Revisions to Offsite Dose Calculation Manual (ODCM)

Attachment 4 Major Changes to Radioactive Liquid, Gaseous and Solid Waste Treatment Systems Attachment 5 Inoperability of Radioactive Liquid and Gaseous Effluent Monitoring Instrumentation

• Attachment 6 Unplanned Releases Attachment'? Lower Limit of Detection (LLD) for Effluent Sample Analysis Attachment 8 Industry Ground Water Protection Initiative

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

EXECUTIVE

SUMMARY

ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT The Annual Radioactive Effluent Release Report describes the radiological effluent control program conducted at Surry Power Station during the 2015 calendar year. This document summarizes the quantities of radioactive liquid and gaseous effluents and solid waste released from Surry Power Station in accordance with Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants", Revision 1, June 1974. The report also includes an assessment of radiation doses to the maximum exposed member of the public due to the radioactive liquid and gaseous effluents. During this reporting period, there were no unplanned liquid or gaseous effluent releases as classified according to the criteria in the Offsite Dose Calculation Manual. Based on the 2015 effluent release data, IOCFR50 Appendix I dose calculations were performed in accordance with the Offsite Dose Calculation Manual. The dose calculations are as follows:

1. The total body dose due to liquid effluents was 3.43E-04 mrem, which is 5.72-03% of the 6 mrem dose limit. The critical organ doses due to liquid effluents, GI-LLI and Liver respectively, were 1.0SE-03 mrem and 2.96E-04 mrem. These doses are 5.40E-03% and 1.48E-03% of the respective 20 mrem dose limit.

     . 2. The air dose due to noble gases in gaseous effluents was 5.05E-05 mrad gamma, which is 2.53E-04% of the 20 mrad gamma dose limit, and l .33E-04 mrad beta, which is 3.33E-04% of the 40 mrad beta dose limit.

3. The critical organ dose from gaseous effluents due to I-131, I-133, H-3, and particulates with half-lives greater than 8 days is 1.0SE-01 mrem, which is 3.60E-01 % of the 30 mrem dose limit.

There were no major changes to the radioactive liquid, gaseous or solid waste treatment systems during this reporting period. There were two changes made to VPAP-2103S, Offsite Dose Calculation Manual, during this reporting period. Attachment 3 provides the changes to VPAP-2103S. In accordance with the Nuclear Energy Institute (NEI) Industry Ground Water Protection Initiative, analysis results of ground water monitoring locations not included in the Radiological Environmental Monitoring Program (REMP), will be included in this report. Ground water monitoring well sample results are provided in Attachment 8. 1

Based on the radioactivity measured and the dose calculations performed during this reporting period, the operation of Surry Power Station has resulted in negligible radiation dose consequences to the maximum exposed member of the public in unrestricted areas. Purpose and Scope includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste as outlined in Regulatory Guide 1.21, with data summarized on a quarterly or annual basis following the format of Tables 1, 2 and 3 of Appendix B, thereof. Attachment 2 of this report includes an assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents released from the site during 2015. As required by Technical Specification 6.8.B, changes to the Offsite Dose Calculation Manual (ODCM) for the time period covered by this report are included in Attachment 3. Major changes to the radioactive liquid, gaseous and solid waste treatment systems are reported in Attachment 4, as required by the ODCM, Section 6.7.2. If changes are made to these systems, the report shall include information to support the reason for the change and a summary of the 1OCFR50.59 evaluation. In lieu of reporting major changes in this report, major changes to the radioactive waste treatment systems may be submitted as part of the annual FSAR update. As required by the ODCM, Sections 6.2.2 and 6.3.2, a list and explanation for the inoperability of radioactive liquid and/or gaseous effluent monitoring instrumentation is provided in Attachment 5 of this report. Additionally, a list of unplanned releases during the reporting period is included in . provides the typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation. As required by the ODCM, Section 6.7.5, a summary of on-site radioactive spills or leaks that were communicated in accordance with the Industry Ground Water Protection Initiative reporting protocol, and sample analyses from ground water wells that are not part of the Radiological Environmental Monitoring Program are provided in Attachment 8. In 2015, no on-site radioactive spills or leaks were communicated in accordance with the Industry Ground Water Protection Initiative. 2

Discussion The basis for the calculation of the percent of technical specification for the critical organ in Table lA of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for iodine-131, iodine-133, for tritium, and for all radionuclides in particulate form with half-lives greater than 8 days shall be less than or equal to 1500 mrem/yr to the critical organ at or beyond the site boundary. The critical receptor was the child for the first two quarters, the teen for the last two quarters; both via the inhalation pathway. The basis for the calculation of the percent of technical specification for the total body and skin in Table lA of Attachment 1 is the ODCM, Section 6.3.1, which requires that the dose rate for noble gases to areas at or beyond site boundary shall be less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin. The basis for the calculation of the percent of technical specification in: Table 2A of Attachment 1 is the ODCM, Section 6.2.1, which states that the concentration of radioactive material released in liquid effluents to unrestricted areas shall not exceed ten times the concentrations specified in 1OCFR20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the concentration shall be limited to 2.00E-04 microcuries/mL. Percent of technical specification calculations are based on the total gaseous or liquid effluents released for the respective quarter. The annual and quarterly doses, as reported in Attachment 2, were calculated according to the methodology presented in the ODCM. The beta and gamma air doses due to noble gases released from the site were calculated at the site boundary. The maximum exposed member of the public from the release of airborne iodine-131, iodine-133, tritium and all radionuclides in particulate form with half-lives greater than 8 days, was a child at 2.05 miles with the critical organ being the bone via the ingestion pathway. The maximum exposed member of the public from radioactive materials in liquid effluents in unrestricted areas was an adult, exposed by either the invertebrate or fish pathway, with the critical organ typically being the gastrointestinal-lower large intestine. The total body dose was also determined for this individual. Presented in Attachment 6 is a list of unplanned gaseous and liquid releases as required by the ODCM, Section 6.7.2. The typical lower limit of detection (LLD) capabilities of the radioactive effluent analysis instrumentation are presented in Attachment 7. These LLD values are based upon conservative conditions (i.e., minimum sample volumes and maximurri delay time prior to analysis). Actual LLD values may be lower. If a radioisotope was not detected when effluent samples were analyzed, then the activity of the radioisotope was reported as Not Detected (N/D) on Attachment 1 of this report. When all isotopes listed on Attachment 1 for a particular quarter and release mode are less than the lower limit of detection, then the totals for this period will be designated as Not Applicable (NIA). 3

Supplemental Information Section 6.6.1 of the ODCM requires the identification of the cause(s) for the unavailability of milk, or if required, leafy vegetation samples, and the identification for obtaining replacement samples. As milk was available for collection during this reporting period, leafy vegetation sampling was not required. As required by the ODCM, Section 6.6.2, evaluation of the Land Use Census is made to determine if new sample location(s) must be added to the Radiological Environmental Monitoring Program. Evaluation of the Land Use Census conducted for this reporting period identified no change in sample locations for the Radiological Environmental Monitoring Program. 4

• Attachment 1 EFFLUENT RELEASE DATA January 1, 2015 through December 31, 2015 This attachment includes a summary of the quantities of radioactive liquid and gaseous effluents and solid waste as outlined in Regulatory Guide 1.21, Appendix B.

Attachment 1 TABLE lA Page 1 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST.ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE Ci l.25E-02 6.49E-Ol 1.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec l.60E-03 8.25E-02 B. IODINE I. TOTAL I-13 1 Ci N/D N/D 2.80E+Ol

2. *AVE RELEASE RA TE FOR PERIOD µCi/sec NIA NIA C. PARTICULATE I. HALF-LIFE >8 DAYS Ci N/D 2.65E-05 2.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec NIA 3.37E-06

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

1. TOTAL RELEASE Ci 8.34E+OO l.04E+Ol 3.lOE+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec l.07E+OO l.32E+OO E. CARBON-14

1. TOTAL RELEASE Ci . l .42E-Ol 7.39E+OO

2. A VE RELEASE RA TE FOR PERIOD µCi/sec l.83E-02 9.40E-Ol PERCENTAGE OF T.S. LIMITS CRITICAL ORGAN DOSE RA TE  % l.62E-03 l.32E-02 TOTAL BODY DOSE RATE  % 2.44E-08 3.12E-05 SKIN DOSE RA TE  % 9.63E-09 l .20E-05

Attachment 1 TABLE lA Page 2of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENT-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST. ERROR QUARTER QUARTER A. FISSION & ACTIVATION GASES

1. TOTAL RELEASE Ci 2.24E-Ol 4.SOE-01 l.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec 2.82E-02 6.04E-02 B. IODINE

1. TOTAL I-131 Ci N/D N/D 2.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec NIA NIA C. PARTICULATE

1. HALF-LIFE >8 DAYS Ci 4.93E-06 7.15E-06 2.80E+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec 6.20E-07 9.00E-07

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

1. TOTAL RELEASE Ci 4.42E+OO 8.43E+OO 3.lOE+Ol

2. A VE RELEASE RA TE FOR PERIOD µCi/sec 5.55E-Ol 1.06E+OO E. CARBON-14

1. TOTAL RELEASE Ci 2.56E+OO 5.47E+OO

2. AVE RELEASE RATE FOR PERIOD µCi/sec 3.22E-Ol 6.96E-01 PERCENT AGE OF T.S. LIMITS CRITICAL ORGAN DOSE RATE  % 8.45E-04 1.65E-03 TOTAL BODY DOSE RA TE  % 1.73E-06 3.54E-06 SKIN DOSE RA TE  % 5.29E-07 l.OSE-06

Attachment 1 TABLE 1B Page3of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENTS-MIXED MODE RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND FIRST SECOND QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES .

Kr-85 Ci NID NID NID NID Kr-85m Ci NID NID NID l.30E-03 Kr-87 Ci NID NID NID NID Kr-88 Ci NID NID NID NID Xe-133 Ci 1.03E-02 NID 2.16E-03 3.69E-Ol Xe-135 Ci NID NID NID 6.21E-02 Xe-135m Ci NID NID NID NID Xe-138 Ci NID NID NID NID Xe-13 lm Ci NID NID NID N/D Xe-133m Ci NID NID NID 4.39E-03 Ar-41 Ci NID NID NID 3.45E-03 TOT AL FOR PERIOD Ci NIA NIA 2.16E-03 4.40E-01

2. IODINES 1-131 Ci NID N/D NID NID I-133 Ci NID N/D NID NID I-135 Ci NID NID NID NID TOTAL FOR PERIOD Ci NIA NIA NIA NIA

3. PARTICULATES Sr-89 Ci NID NID NID NID Sr-90 Ci NID NID NID NID Cs-134 Ci NID NID NID NID Cs-137 Ci NID 2.43E-05 NID N/D Ba-140 Ci NID NID NID NID La-140 Ci NID NID NID NID Co-58 Ci NID 2.12E-06 NID NID Co-60 Ci NID NID NID NID Mn-54 Ci NID NID NID NID Fe-59 Ci. NID NID NID NID Zn-65 Ci NID N/D NID NID Mo-99 Ci NID NID NID NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID NID NID C-14 Ci 1.17E-Ol NID 2.46E-02 5.02E+OO TOT AL FOR PERIOD Ci 1.17E-Ol 2.64E-05 2.46E-02 5.02E+OO

Attachment 1 TABLE 1B Page 4of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENTS-MIXED MODE RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci N/D N/D N/D NID Kr-85m Ci N/D N/D 5.81E-04 6.44E-04 Kr-87 Ci N/D N/D N/D N/D Kr-88 Ci N/D N/D N/D NID Xe-133 Ci N/D N/D l.84E-01 4.38E-01 Xe-135 Ci N/D N/D 3.50E-02 2.83E-02 Xe-135m Ci N/D N/D N/D N/D Xe-138 Ci N/D N/D N/D N/D Xe-131m Ci N/D N/D N/D N/D Xe-133m Ci N/D NID 2.93E-03 7.66E-03 Ar-41 Ci NID NID 9.00E-04 4.16E-03 TOTAL FOR PERIOD Ci NIA NIA 2.24E-01 . 4.79E-01

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

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D NID Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci N/D N/D N/D N/D Ba-140 Ci N/D N/D N/D N/D La-140 Ci N/D N/D N/D N/D Co-58 Ci N/D N/D N/D N/D Co-60 Ci N/D N/D N/D N/D Mn-54 Ci N/D N/D N/D NID Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci N/D N/D N/D N/D Mo-99 Ci N/D NID N/D N/D Ce-141 Ci N/D N/D N/D NID Ce-144 Ci NID NID N/D N/D C-14 Ci N/D N/D 2.55E+OO 5.46E+OO TOTAL FOR PERIOD Ci NIA NIA 2.55E+OO 5.46E+OO

Attachment 1 TABLElC Page 5 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND FIRST SECOND

                                              .QUARTER        QUARTER      QUARTER    QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci NID N/D N/D NID Kr-85m Ci N/D N/D N/D NID Kr-87 Ci. NID NID N/D NID Kr-88 Ci . NID N/D N/D NID Xe-133 Ci NID NID NID 2.08E-01 Xe-135 Ci NID NID NID NID Xe-135m Ci NID NID N/D NID Xe-138 Ci N/D NID NID NID Xe-13 lm Ci NID NID NID NID Xe-133m Ci NID NID NID N/D Ar-41 Ci NID 3.61E-04 NID NID TOTAL FOR PERIOD Ci NIA 3.61E-04 NIA 2.08E-01

2. IODINES I-131 Ci NID N'/D Nib NID 1-133 Ci NID NID NID N/D.

I-135 Ci NID NID N/D NID TOTAL FOR PERIOD Ci NIA NIA NIA NIA

3. PARTICULATES Sr-89 Ci NID NID NID NID Sr~9o Ci NID N/D N/D NID Cs-134 Ci N/D N/D NID N/D Cs-137 Ci NID 2.43E-05 N/D NID Ba-140 Ci NID NID NID NID La-140 Ci NID NID NID NID Co-58 Ci . NID 2.12E-06 NID NID

• Co-60 Ci NID NID NID NID Mn-54 Ci N/D NID NID . NID Fe-59 Ci N/D NID NID NID Zn-65 Ci NID NID NID NID Mo-99 Ci NID NID NID NID Ce-141 Ci N/D N/D NID NID Ce-144 Ci NID NID NID NID C-14 Ci N/D 4. l lE-03 NID 2.37E+OO TOTAL FOR PERIOD Ci NIA 4.14E-03 NA 2.37E+OO

Attachment 1 TABLElC Page 6of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 111115 TO 12/31115 GASEOUS EFFLUENTS-GROUND LEVEL RELEASES CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT. THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER

1. FISSION & ACTIVATION GASES Kr-85 Ci NID N/D NID NID Kr-85m Ci N/D l.76E-06 N/D N/D Kr-87 Ci N/D l.66E-06 N/D N/D Kr-88 Ci N/D 3.14E-06 N/D NID Xe-133 Ci* NID 1.45E-05 N/D 5.66E-04 Xe-135 Ci NID 2.28E-05 N/D N/D Xe-135m Ci NID 4.26E-06 N/D NID Xe-138 Ci N/D N/D NID N/D Xe-13lm Ci N/D N/D N/D N/D Xe-133m Ci N/D N/D N/D N/D Ar-41 Ci 2.25E-04 4.93E-04 N/D N/D TOTAL FOR PERIOD Ci 2.25E-04 5.40E-04 NIA 5.66E-04

2. IODINES I-131 Ci N/D N/D N/D N/D I-132 Ci N/D l.31E-03 N/D N/D I-135 Ci N/D N/D N/D N/D TOTAL FOR PERIOD Ci NIA l.3 IE-03 NIA NIA

3. PARTICULATES Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D N/D NID Cs-134 Ci NID N/D N/D NID Cs-137 Ci NID N/D N/D N/D Ba-140 Ci NID NID NID N/D La-140 Ci N/D NID N/D N/D Co-58 Ci 4.93E-06 6.89E-06 N/D 2.12E-07 Co-60 Ci N/D N/D N/D 5.03E-08 Mn-54 Ci N/D NID N/D NID Fe-59 Ci N/D N/D N/D N/D Zn-65 Ci NID N/D NID NID Mo-99 Ci NID N/D N/D NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID NID N/D C-14 Ci 2.56E-03 6.15E-03 N/D 6.45E-03 TOTAL FOR PERIOD Ci 2.56E-03 6.16E-03 NA 6.45E-03

Attachment 1 TABLE2A Page 7of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12131/15 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT FIRST SECOND %EST. ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOTAL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci 5.03E-03 7.19E-03 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCilmL 7.91E-12 l.20E-l l

3. PERCENT OF APPLICABLE LIMIT  % 2.65E-05 4.15E-05 B. TRITIUM

1. TOT AL RELEASE Ci 3.13E+02 2.87E+02 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCi/mL 4.93E-07 4.77E-07

3. PERCENT OF APPLICABLE LIMIT  % 4.93E-03 4.77E-03 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci NID NID 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCilmL NIA NIA

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

1. TOT AL RELEASE Ci N/D N/D 2.00E+Ol E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.48E+07 5.33E+07 3.00E+OO F. VOLUME OF DILUTION WATER I USED DURING PERIOD LITERS 6.36E+ 11 6.0lE+ll 3.00E+OO

Attachment I TABLE2A Page 8of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 LIQUID EFFLUENTS-SUMMATION OF ALL RELEASES SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH %EST. ERROR QUARTER QUARTER A. FISSION AND ACTIVATION PRODUCTS

1. TOT AL RELEASE (NOT INCLUDING TRITIUM, GASES, ALPHA) Ci l.36E-02 2.37E-02 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCi/mL l.73E-11 4.36E-11

3. PERCENT OF APPLICABLE LIMIT  % 2.76E-05 9.68E-05 B. TRITIUM

1. TOTAL RELEASE Ci 3.35E+02 2.52E+02 2.00E+Ol

2. A VE DIL. CONC. DURING PERIOD µCi/mL 4.27E-07 4.63E-07

3. PERCENT OF APPLICABLE LIMIT  % 4.27E-03 4.63E-03 C. DISSOLVED AND ENTRAINED GASES

1. TOTAL RELEASE Ci 4.67E-06 N/D 2.00E+Ol

2. A VE DIL. CONC .. DURING PERIOD µCi/mL 5.95E-15 NIA

3. PERCENT OF APPLICABLE LIMIT  % 2.98E-09 NIA D. GROSS ALPHA RADIOACTIVITY I. TOTAL RELEASE Ci NID NID 2.00E+Ol E. VOLUME OF WASTE RELEASED (PRIOR TO DILUTION) LITERS 5.61E+07 5.46E+07 3.00E+OO F. VOLUME OF DILUTION WATER USED DURING PERIOD LITERS 7.84E+ 11 5.44E+l 1 3.00E+OO I

Attachment 1 TABLE2B

• Page 9of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 LIQUID EFFLUENTS CONTINUOUS MODE BATCHMOJ:?E SURRY POWER STATION UNITS 1&2 UNIT F~RST SECOND FIRST .SECOND QUARTER QUARTER QUARTER QUARTER Sr-89 Ci N/D N/D N/D NID Sr-90 Ci N!D N/D N/D NID Fe-55 Ci N!D N/D N/D NID Cs-134 Ci N/D NID N/D NID Cs-137 Ci 4.16E-04 3.43E-04 7.93E-06 6.26E-05 I-131 Ci N/D N/D N/D l.14E-05 Co-58 Ci N/D NID 5.29E-04 5.0lE-04 Co-60 Ci N/D N/D 3.66E-03 6.14E-03 Fe-59 Ci N/D N!D N/D NID Zn-65 Ci N/D NID NID NID Mn-54 Ci N/D NID N/D 5.26E-05 Cr-51 Ci N/D NID NID NID Zr-95 Ci N/D NID N/D N/D Nb-95 Ci N!D NID N/D NID Mo-99 Ci N/D N/D N/D NID Tc-99m Ci N/D NID N/D NID Ba-140 Ci NID NID N/D NID La-140 Ci N/D N/D N/D NID Ce-141 Ci NID NID N/D NID Ce-144 Ci N!D NID N!D NID Sb-124 Ci NID NID N/D NID Sb-125 Ci N/D NID 4.17E-04 8.35E-05 Co-57 Ci N/D NID N/D NID TOTAL FOR PERIOD Ci 4.16E-04 3.43E-04 4.61E-03 6.85E-03 Xe-133 Ci N/D N/D N/D N!D I Xe-135 Ci N/D N!D N/D N/D TOTAL FOR PERIOD Ci NIA NIA NIA NIA

Attachment 1 TABLE2B Page 10of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT PERIOD: 1/1/15 TO 12/31/15 LIQUID EFFLUENTS CONTINUOUS MODE BATCH MODE SURRY POWER STATION UNITS 1&2 UNIT THIRD FOURTH THIRD FOURTH QUARTER QUARTER QUARTER QUARTER Sr-89 Ci N/D N/D N/D N/D Sr-90 Ci N/D N/D NID NID Fe-55 Ci N/D N/D N/D N/D Cs-134 Ci N/D N/D N/D N/D Cs-137 Ci l .97E-04 2.19E-04 5.18E-05 2.17E-05 1-131 Ci N/D N/D N/D N/D Co-58 Ci N/D NID 1.17E-03 2.09E-03 Co-60 Ci N/D NID 4.94E-03 l.41E-02 Fe-59 Ci N/D N/D NID N/D Zn-65 Ci NID NID N/D NID Mn-54 Ci NID NID 1.18E-05 2.07E-04 Cr-51 Ci NID NID 8.41E-04 . 7.20E-04 Zr-95 Ci NID NID NID NID Nb-95 Ci NID NID NID NID Mo-99 Ci NID NID NID NID Tc-99m Ci NID NID NID NID Ba-140 Ci NID NID N/D NID La-140 Ci NID NID NID NID Ce-141 Ci NID NID NID NID Ce-144 Ci NID NID N/D *NID Sb-124 Ci NID NID l.95E-05 2.1 lE-05 Sb-125 Ci NID NID 6.36E-03 6.35E-03 Co-57 Ci NID NID NID l.97E-05 TOT AL FOR PERIOD Ci l.97E-04 2.19E-04 1.34E-02 2.35E-02 Xe-133 Ci NID NID 4.67E-06 NID Xe-135 Ci NID NID NID NID TOTAL FOR PERIOD Ci NIA NIA 4.67E-06 NIA

Attachment 1 TABLE3 Page 11 of 12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1115 - 12/31/15 SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

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

3

a. Spent resins, filter sludges, evaporator m 2.15E+OI Note I l.OOE+Ol

                    *bottoms, etc.                                   Ci  3.41E+02                  3.00E+Ol 3

b. Dry compressible waste, contaminated m 5.36E+02 Note2 1.00E+OI equip., etc. Ci 8.59E-Ol 3.00E+Ol

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

d. Other (Waste oil) m3 8.50E-Ol Note3 l.OOE+Ol Ci l.27E-03 3.00E+Ol

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

a. Co-60  % 4.95E+Ol Ni-63  % 2.71E+Ol Fe-55  % 1.04E+Ol Co-58  % 7.68E+OO Mn-54  % l.72E+OO

b. Co-60  % 4.00E+Ol Cs-137  % 3.97E+Ol Ni-63  % l.14E+Ol Fe-55  % 4.64E+OO Co-58  % l.66E+OO

c.  %

d. Ni-63  % 8.71E+Ol Cs-137  % 7.88E+OO H-3  % l.64E+OO (based on MDA concentration)

Tc-99  % l.30E+OO (based on MDA concentration)

Attachment 1 TABLE3 Page 12of12 EFFLUENT AND WASTE DISPOSAL ANNUAL REPORT SOLID WASTE AND IRRADIATED FUEL SHIPMENTS PERIOD: 1/1115 - 12/31/15 CONTINUED SURRY POWER STATION A. SOLID WASTE SHIPPED OFFSITE FOR BURIAL OR DISPOSAL (Not irradiated fuel)

3. Solid Waste Disposition Number of Shipments Mode of Transportation Destination 16 Truck Oak Ridge, TN (EnergySolutions) 2 Truck Erwin, TN (Energy Solutions )

Truck* Barnwell, SC (Energy Solutions) B. IRRADIATED FUEL SHIPMENT (Disposition) Number of Shipments Mode of Transportation Destination 0 NOTE 1: Some of this waste was shipped to licensed waste processors for processing and/or volume reduction. Therefore, 3 this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 9.07E+OO m . Burial volume by Erwin Resin Solutions is indeterminable due to mixing of Surry waste with other generators waste. NOTE 2: Some DAW was shipped to licensed waste processors for processing and/or volume reduction. Therefore, 3 this volume is not representative of the actual volume buried. The total volume buried for this reporting period is 2.50E+02 m . NOTE 3: This waste was shipped to a licensed waste processor for processing and/or volume reduction. The actual 3 volume buried is indeterminable. It is conservatively assumed that 1.70E-02 m was buried this reporting period ..

Attachment 2 Page 1 of 1 ANNUAL AND QUARTERLY DOSES An assessment of radiation doses to the maximum exposed member of the public due to radioactive liquid and gaseous effluents .released from the site for each calendar quarter for the calendar year ofthis report, along with an annual total of each effluent pathway is made pursuant to the ODCM, Section 6.7.2, requirement.

<   I LIQUID                                   GASEOUS 2015       Total Body       GI-LLI         Liver       Gamma             Beta       Bone (mrem)         (mrem)        (mrem)       (mrad)           (mrad)     (mrem) 1st Quarter    7.18E-05       1.44E-04      6.76E-05     3.62E-08        1.0SE-07    7.90E-04 2nd Quarter    8.50E-05       2.23E-04      7.63E-05     4.49E-05      . 1.28E-04    6.26E-02 3rd Quarter    6.62E-05       1.61E-04      6.03E-05     1.73E-06        2.43E-06    1.43E-02

, I 4th Quarter 1.20E-04 5.56E-04 9.16E-05 3.76E-06 4.75E-06 3.06E"'02 Annual 3.43E-04 . 1.0SE-03 2.96E-04 5.05E-05 l.33E-04 1.0SE-01 *

                                                                                                     .,

I 1 I I

Attachment 3 Page 1of1 REVISIONS TO OFFSITE DOSE CALCULATION MANUAL (ODCM) As required by Technical Specification 6.8.B, revisions to the ODCM, effective for the time period covered by this report, are included with this attachment. There were two general revision to the ODCM implemented during this reporting period. Revision 18:

• Added substep 6.6.1.b.5 addressing deviations from the Radiological Environmental Monitoring Program (REMP) sampling schedule if specimens are unattainable and requiring all deviations to be documented in the annual REMP report.
• Updated gaseous effluent dispersion and deposition factors.
• Add a garden in the SSE sector for dose assessment. This garden was idenified as a new garden location in the 2014 Land Use Census.
• Revised the description of Fish samples for the REMP to better represent the species available in the area for sampling.

Revision 19:

• Resulting from a self assessment of the REMP, the following revisions were made:

Added, as Reference 3.1.28, the Branch Technical Position,, Revision 1, November 1979 Added a footnote to Attachment 8 to clarify that a TLD station does not exist in the 4 - 5 mile range of the SE sector due to geographical limitations. This area is over the water of the James River.

• Resulting from corrective actions to Condition Report 1013104, documenting a liquid release without an operable flow rate measuring device, the following revisions were made:

Added, as Reference 3.1.29, CR1013104 On Attachment 1, revised the Action requirements for an unavailable flow rate measuring device to allow a liquid release with verification ofrelease rate at least once per 30 minutes using design capacity pump performance curves or volume released over time.

• '*
• Revised Substep 6.4.2.b to include the release of ground water wells as a contributor to the Continuous Release pathway.

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                                                                                                                                     .. I                       I    l

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       *
       ~*Dominion"                                                                                           Administrative Procedure or Guidance and tleference DO.C1fttlentAppr9v?,/
                                                                                                                                                                       .Po..¥ I db: 7 I                                                                                                             AD-AA-101-Attachment4

• Page 1 of 1

1. Document Number.: 2. Revision: 3; Docl,!ment TYpe:

VPAP-2103.S 1-B [81 Administrative Procedure 0GARD

4. Title:

Offsite Pose Calctilatiol"l Ma,n)..1ai (Surry)

5. Requestor(s) Print Name(s) /.Locations; 6. bate  :(.'Requester Phone Heather Baer 03/30/2015 8;;798-2112.

8. Document Request

• DNew :i:8J REivisib_n [J Cancel .0 St.!pe:rsede D Te~poracy 9_. Applicable NucleaJStation(s)

Millstone D North An_na 0 Surry l8l 1o. Reason arid Bri~f Description cif Chari!le: The following changes were made in r~$porise to SAA031 ea4.

• Ad8ed .Substep 6.6.1.b.5 addressing deviations from the sainplirig s*che(j_ule ifspecimens are unattainable and requiring all deviations to be dqcumented in the . annual report For full list of changes, see Revision Sumin~ty.

11. Records Retention Requirements Affected? 12. Change Management 0 Y~s (Complet~-f\JRRS fc:ir'nl frofi:1 RM-AA-101) 181 No Attach Appropriate Pl~AA~4000 Attachm_ent(s)

13. Levefof Use:

D ' Continuous

                                    .     .            Use*
                                                        .

[)Reference Use ~ Information Use D Multiple Use Fleet Approval

14. Fleet-Approval_Required*by: (Ctieck one box only. Enter Peer-Group:Narile, if applicable)

D Peer Groll OR

• 1:8J. Fi:Jnctional Area Mana er FAM 15 .. ~rinted Approver Nam!l , 11?. Signature. 17. Date Jason W. Eg*gart 3} 3'D *,5 Site Approval

18. lrriglem~ritatiori P!'Elreqiiisites: (Items in addition to tliose listea on*oocument Traveler or Change Management Plan)

None *

• 19. lmplementatiqn Prerequisites Reviewed - Procedure Super'vi.sor SI"

21. Check Nuclear Statio"n(s) for Which Document is. bein!i Approved for Implementation.

Millstone 0 North .Anna D Sur~ 1:83

22. ~ite Apprqval (PrilitNa_nje of Ff\M) 24. :[)ate

     .,Jason* Vil. E art                                                                                                                                                  3. 3 /1";J

• 25._ Facility S~fety Reyiew- Committee Required?' -26: Fatilify. SafetY, Review Co 27. Qate

[81 No D Yes *tJ *N 2a. Site Vice Presid~mt Required? DNo [81Yes

34. Document Number.~ 35~ Revision: 37. EXpiration* Date VPAP*21-03S. 18 Ol:Ji 15 N/A .

   -Key: GARD-Guidance -and.Reference Dpcument, EDMS-:EJecfronic Document Managem_en~ System*                                                                        Form No. 72B620tocl 2014)

  'I;
  ~       Dominion Station Administrative Procedure Title: Offsite Dose Calculation Manual (Surry)

Process I Program Owner: Manager Radiological Protection and Chemistry (Surry) Procedure Number Revision Number Effective Date VPAP-2103S 18 On File Revision Summary The following changes were made in response to SAA031884.

• Added Substep 6.6.l.b.5 addressing deviations from the sampling schedule if specimens are unattainable and requiring all deviations to be documented in the annual report Additional Changes
• Updated X./Q and D/Q Factors on Attachment 7
• Added SSE Garden to Attachment 7
• Updated Ingestion, Fish and Invertebrates, d) and added Note 3 to Attachment 8 Approvals on File

DOMINION VPAP-2103S REVISION 18 PAGE20F76 TABLE OF CONTENTS Section Page 1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 10 6.0 INSTRUCTIONS 11 6.1 Sampling and Monitoring Criteria 11 6.2 Liquid Radioactive Waste Effiuents 11 i 6.2.1 Liquid Effluent Concentration Limitations 11 6.2.2 Liquid Monitoring Instrumentation 13 6.2.3 Liquid Effluent Dose Limit 16 6.2.4 Liquid Radwaste Treatment 19 6.2.5 Liquid Sampling 21 6.3 Gaseous Radioactive Waste Effiuents 21 6.3.l Gaseous Effluent Dose Rate Limitations 21 6.3.2 Gaseous Monitoring Instrumentation 24 6.3.3 Noble Gas Effluent Air Dose Limit 27 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effluent Dose Limit 28 6.3.5 Gaseous Radwaste Treatment 31 6.4 Radioactive Liquid and Gaseous Release Permits 32 6.4.1 Liquid Waste Batch Releases 32 6.4.2 Continuous Liquid Releases 32 6.4.3 Waste Gas Decay Tanlc (WGDT) Release Permit 33 6.4.4 Reactor Containment Release Permits 33 6.4.5 Miscellaneous Gaseous Release Permit 33 6.4.6 Radioactive Liquid and Gaseous Release Controls 33

DOMINION VPAP-2103S REVISION 18 PAGE3 OF76 TABLE OF CONTENTS (continued) Section Page 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 34 6.6 Radiological Environmental Monitoring 35 6.6.1 Monitoring Program 35 6.6.2 Land Use Census 38 6.6.3 lnterlaboratory Comparison Program 39 6.7 Reporting Requirements 39

6. 7 .1 Annual Radiological Environmental Operating Report 39 6.7.2 Annual Radioactive Effluent Release Report 41 6.7.3 Annual Meteorological Data 43 6.7.4 Changes to the ODCM 43 6.7.5 Industry Ground Water Protection Initiative 44 7.0 RECORDS 46 ATTACHMENTS 1 Radioactive Liquid Effiuent Monitoring Instrumentation 47 2 Radioactive Liquid Effiuent Monitoring Instrumentation 48 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 49 4 Radioactive Gaseous Waste Sampling and Analysis Program 52 5 Radioactive Gaseous Effiuent Monitoring Instrumentation 56 6 Radioactive Gaseous Effiuent Monitoring Instrumentation 58 Surveillance Requirements 7 Dispersion and Deposition Factors 60 8 Radiological Environmental Monitoring Program 61 9 Environmental Sampling Locations 64 10 Detection Capabilities for Environmental Sample Analysis 67 11 Reporting Levels for Radioactivity Concentrations in Environmental Samples 69 12 Meteorological, Liquid, and Gaseous Pathway Analysis 70

DOMINION VPAP-2103S REVISION 18 PAGE40P76 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of offsite doses due to radioactive liquid and gaseous effluents are performed to assure that:

• Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CPR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases and 2E-4 µCi/mL for dissolved or entrained noble gases
• Exposure to the maximum exposed member of the public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CPR 50, Appendix I
• Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to:

      .. Noble gases-less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin
      .. I 131 , I 133 , and H 3, and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ

• Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CPR 50, Appendix I, and
• Exposure to areal individual will not exceed 40 CPR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Radiological Environmental Monitoring Programs at Surry Power Station.

DOMINION VPAP-2103S REVISION 18 PAGES OF76

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 References 3.1.1 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Production and Utilization Facilities 3.1.3 40 CPR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3.1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 1974 3.1.6 Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CPR 50, Appendix I, Rev. 1, U.S. NRC, October 1977 3 .1. 7 Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 Surry Technical Specifications (Units 1 and 2) 3.1.9 NUREG/CR-2919, XOQDOQ, Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1982 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CPR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual

DOMINION VPAP-2103S REVISION 18 PAGE60F76 3.1.19 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.20 Surry UFSAR 3.1.21 VPAP-2802, Notifications and Reports 3.1.22 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis 3.1.23 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis 3.1.24 Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System Replacement/Surry/Unit 1&2 3.1.25 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document

3. l .26 CR0223 20 (Surry), Daily Channel Checks for 1-VG-RM-131-1 Flow Rate Measuring Device Not Performed 3.1.27 RP-AA-502, Groundwater Protection Program 3.2 Commitment Documents 3.2.1 Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling 4.0 DEFINITIONS 4.1 Channel Calibration Adjustment, as necessary, of the channel output so it responds w~th the necessary range and accuracy to known values of the parameter the channel monitors. It encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test.

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

DOMINION VPAP-2103S REVISION 18 PAGE70F76 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter. The Channel Check for the MGPI sampler flow rate measuring devices, as listed on Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release rate (i.e., microcuries per second) without the presence of a sampler flow fault display. 4.3 Channel Functional Test There are two types of Channel Functional Tests. 4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions. 4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm and/or trip functions. 4.4 Critical Organ That organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded. 4.5 Dose Equivalent 1-131 That concentration of I 131 (µCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture ofl 131 , I 132, I 133 , I 134, and I 135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

DOMINION VPAP-2103S REVISION 18 PAGE 8 OF76 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent. NOTATION FREQUENCY D-Daily At least once per 24 hours W-Week:ly At least once per 7 days M-Monthly At least once per 31 days Q - Quarterly At least once per 92 days SA- Semi-annually At least once per 184 days R - Refueling At least once per 18 months I SIU - Start-up Prior to each reactor start-up II i P - Prior to release Completed prior to each release NIA- Not applicable Not applicable DR- During the release At least once during each release 4.7 Gaseous Radwaste Treatment System A system that reduces radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers and waste gas surge tanks. 4.8 General Nomenclature x = Chi: concentration at a point at a given instant (curies per cubic meter) D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) Q = Source strength (instantaneous; grams, curies)

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

I 4.9 Lower Limit of Detection (LLD) The smallest concentration of radioactive material in a sample that will yield a net count (above system background) that can be detected with 95 percent probability with only five percent probability of falsely concluding that a blank observation represents a "real" signal.

DOMINION VPAP-2103S REVISION 18 PAGE90F76 4.10 Members of the Public Any individual except when that individual is receiving an occupational dose. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine servicemen or postal workers who, as part of their formal job function, occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive materials. 4.11 Operable - Operability A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary, attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. 4.12 Purge - Purging Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required to purify the confinement. 4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., 2587 Megawatts Thermai MWt). 4.14 Site Boundary The line beyond which Dominion does not own, lease, or otherwise control the land. 4.15 Source Check For Victoreen and Eberline monitors a source check is the qualitative assessment of channel response when a channel sensor is exposed to a radioactive source or a light emitting diode, LED. For MGPI monitors a source check is the verification of proper computer response to continuous operational checks on the detector and electronics. 4.16 Special Report A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VP AP-2802, Notifications and Reports.

DOMINION VPAP-2103S REVISION 18 PAGE 10 OF76 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant. 4.18 Unrestricted Area Any area at or beyond the site boundary, access to which is neither limited nor controlled by Dominion for purposes of protection of individuals from exposure to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, commercial, institutional or recreational purposes. 4.19 Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material in particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEPA) filters to remove iodines and particulates from a gaseous exhaust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESP) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components. 5.0 RESPONSIBILITIES 5.1 Manager Radiological Protection and Chemistry The Manager Radiological Protection and Chemistry is responsible for: 5.1.l Establishing and maintaining procedures for surveying, sampling, and monitoring radioactive effluents and the environment. 5 .1.2 Surveying, sampling, and analyzing plant effluents and environmental monitoring, and documenting these activities. 5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends. 5 .1.4 Preparing Effluent and Environmental Monitoring Program records. 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents.

DOMINION VPAP-2103S REVISION 18 PAGE 11 OF76 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 12). 6.1 Sampling and Monitoring Criteria 6.1. l Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored. 6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored. 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the status of the discharge monitored. 6.1.4 Samples shall be representative of the volume and type of discharge monitored. 6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detailed that the meaning and intent of the records are clear. 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

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

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE 120F76

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

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

                                                                   µCi/mL.            -

Volume of Waste Discharged x ~ 1

                                                                               *
                                                               .L.J ACW.1 where:
           µCi/mLi = the concentration of nuclide i in the liquid effluent discharge ACWi      =ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as µCi/mL from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/mL for dissolved or entrained noble gases

d. Bases - Liquid Effluent Concentration Limitations This control is provided to ensure that the concentration of radioactive materials released in liquid waste effluents to UNRESTRICTED AREAS will not exceed 10 times the concentration values specified in Appendix B, Table 2, Column 2 of 10 CFR 20. The specific.ation provides operational flexibility for releasing liquid effluent in concentrations to follow the Section II.A and 11.C design objectives of Appendix I to 10 CFR Part 50. This limitation provides additional assurance that the levels ofradioactive materials in bodies of water in UNRESTRICTED AREAS will result in exposures within: (1) the Section II.A design objectives of Appendix I, 10 CFR Part 50, to a MEMBER OF THE PUBLIC, and (2) restrictions authorized by 10 CFR 20.130l(e). The concentration limit for dissolved or entrained noble gases is based upon the assumption that Xe-135 is the controlling radioisotope and its effluent concentration in air (submersion) was converted to an equivalent concentration in water using the methods described in International Commission on Radiological Protection (ICRP) Publication 2. This specification does not affect the requirements to comply with the annual limitations of 10 CFR 20.130l(e).

DOMINION VPAP-2103S REVISION 18 PAGE 13 OF76 6.2.2 Liquid Monitoring Instrumentation

a. Radioactive Liquid Effiuent Monitoring Instrumentation I Radioactive liquid effluent monitoring instrumentation channels shown on Radioactive Liquid Effluent Monitoring Instrumentation (Attachment 1) shall be operable with their alarm/trip setpoints set to ensure that Step 6.2. l .a. limits are not exceeded.

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

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

• Promptly suspend release of radioactive liquid effluents monitored by the affected channel
• Declare the channel inoperable
• Change the setpoint to an acceptable, conservative value

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

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

1) perform the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 18 PAGE 140F76

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

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

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

1. Maximum setpoint values shall be calculated by:

s (2) where: S = the setpoint, in µCi/mL, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution C = the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station (ACW in µCi/mL) for an isotopic mixture expected in the effluent FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as: FE+ (200,000 gpm x number of circ. pumps in service)

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

s =c (3) The setpoint for Station monitors used to implement 10 CFR 20 for the site becomes the effluent concentration limit.

DOMINION VPAP-2103S REVISION 18 PAGE 15 OF76

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

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

s (4) where: Ksw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 for the Station, attributable to the service water effluent line pathway

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

s (5) where: KRw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway

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

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

DOMINION VPAP-2103S REVISION 18 PAGE 16 OF76 6.2.3 Liquid Eflluent Dose Limit

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

1. During any calendar quarter:

• Less than or equal to 1.5 mrem to the total body
• Less than or equal to 5 mrem to the critical organ

2. During any calendar year:

• Less than or equal to 3 mrem to the total body
• Less than or equal to 10 mrem to the critical organ

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

DOMINION VPAP-2103S REVISION 18 PAGE 17 OF76

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

Dose contributions shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on the equation: D = tFM'°'C*A*L.i 1 1 (6) where: Subscripts = i, refers to individual radionuclide D = the cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem t = the period for which q and F are averaged for all liquid releases, in hours M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix l lA, Surry UFSAR F = the near field average dilution factor for Ci during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in µCi/mL Ai = the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem/hr per µCi/mL (7)

DOMINION VPAP-2103S REVISION 18 PAGE 18 OF76 For example: 1.14 E+05 = 1 E+06 pCi/µCi x 1 E+03 mL/L I (8760 hr/yr), units conversion factor 21 = adult fish consumption, kg/yr, from NUREG-0133 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 Bii = the salt water bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/L BFi = the salt water bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/L DFi= the critical organ dose conversion factor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II and VCRL-50564, Rev. 1.

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

DOMINION VPAP-2103S REVISION 18 PAGE 19 OF76

e. Bases - Dose Due To Liquid Effluents This control is provided to implement the requirements of Sections II.A, ID.A, and I IV.A of Appendix I to 10 CFR Part 50. The control implements the guides set forth in Section II.A. The ACTION statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV .A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The dose calculation methodology and parameters in the ODCM implement the requirements in Section III.A that conformance with the guides of Appendix I be shown by calculation procedures, such that the actual exposure of a MEMBER OF THE PUBLIC is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

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

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 18 PAGE200F76

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body and Critical Organ Dose Calculation

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

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

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

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

Dp = (DL x P) + Da

d. Bases - Liquid Radwaste Treatment System The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This control implements the requirements of 10 CPR 50.36a, General Design Criterion 60 of Appendix A to 10 CPR Part 50 and the design objective given in Section II.D of Appendix I to 10 CPR 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 CPR Part 50 for liquid effluents.

DOMINION VPAP-2103S REVISION 18 PAGE21 OF76 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling I and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). 6.3 Gaseous Radioactive Waste Effiuents 6.3.1 Gaseous Effluent Dose Rate Limitations

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

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

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

b. Action

1. If dose rates exceed Step 6.3. l.a. limits, promptly decrease the release rate to within the above limits.

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

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

DOMINION VPAP-2103S REVISION 18 PAGE220F76

c. Calculations of Gaseous Effluent Dose Rates

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

                  ~
                  ~

[ ( K. Qivv ~Q*. ) 1 lVV

                                             + (Ki Qipv ~Q*lpV
                                                           * ) ] :-:;; 500 mrem/yr to the total body      (8)

OR

        ~[((Li+ l.IM.)Qivv
        ~                  1
                                  ~Q*.IVV ) +((Li+ l.IM.)Qipv 1
                                                                  ~Q*.lpV )] ::::;3000 mrem/yrto the skin (9) where:

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

                .     .

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

                                =   the gaseous dispersion factor, sec/m3 (See Attachment 7)

DOMINION VPAP-2103S REVISION 18 PAGE 23 OF76

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

                            . x            . x
                 ~ [P 1- Qivv -Q.IVV + P 1* Qipv-Q*lpV ] :::; 1500 mrem/yr to the critical organ L.J                                                                                  (10) where:

p. 1

                                 =   the critical organ dose factor for I 131 , I 133 , H 3 , and all radionuclides in particulate form with half-lives greater than 8 days, for the child inhalation pathway, in mrem/yr per Curie/m3
                                 =   the release rate for ventilation vents or process vent of I 131 ,

I 133 , H3 , and all radionuclides i, in particulate form with half-lives greater than 8 days, in gaseous effluents in Curie/sec (per site) XIQ;vv, XIQ;pv = the gaseous dispersion factor, sec/m3 (See Attachment 7)

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

d. Bases - Dose Rate This specification provides reasonable assurance radioactive materials discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, either at or beyond the SITE BOUNDARY, in excess of the design objectives of Appendix I to 10 CPR Part 50.

This specification is provided to ensure that gaseous effluents from all units on the site will be appropriately controlled. It provides operational flexibility for releasing gaseous effluents to satisfy the Section II.A and II.C design objectives of Appendix I to 10 CPR Part 50. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrem/year to the whole body, less than or equal to 3000 mrem/year to the skin and the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem/year. This specification does not affect the requirements to comply with the annual limitation of 10 CPR 20.1301(a). This control applies to the release of radioactive materials in gaseous effluents from all units at the site.

DOMINION VPAP-2103S REVISION 18 PAGE240F76 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.1.a. noble gas limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.3.2.d.

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

b. Action

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

• Suspend the release of radioactive gaseous effluents monitored by the affected channel and declare the channel inoperable or
• Change the setpoint so it is acceptably conservative

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

take the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 18 PAGE 25 OF76

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

Release Point Instrument Number Process Vent 1-GW-RM-130B Condenser Air Ejector 1-SV-RM-111 2-SV-RM-211 Ventilation Vent No. 1 1-VG-RM-104 Ventilation Vent No. 2 1-VG-RM-131B Radwaste Facility Vent RRM-101

d. Setpoint Calculations

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

(11) where: D - Step 6.3. l .a. dose limits that implement Technical Specifications for the Station, mrem/yr Dpv = the noble gas site boundary dose rate from process vent gaseous effluent releases, mrem/yr Dcae = the noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr Dvv = the noble gas site boundary dose rate from summation of the Ventilation Vents 1, 2, and the Radwaste Facility vent gaseous effluent releases, mrem/yr

DOMINION VPAP-2103S REVISION 18 PAGE260F76

2. Setpoint values shall be determined by:

Rm x 2.12 E-03 (12) Fm where: m = the release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae), or Radwaste Facility (rv) Cm = the effluent concentration limit implementing Step 6.3.1.a. for the Station, µCi/mL Rm = the release rate limit for pathway m determined from methodology in Step 6.3.1.c., typically using Xe 133 as nuclide to be released, µCi/sec 2.12E-03 CFM per mL/sec Fm = the maximum flow rate for pathway m, CFM NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alarm/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases.

e. Bases - Radioactive Gaseous Effiuent Monitoring Instrumentation The radioactive gaseous effluent 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 gaseous effluent dose rate limits of Section 6.3 of the ODCM.

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

DOMINION VPAP-2103S REVISION 18 PAGE 27 OF76 6.3.3 Noble Gas Effluent Air Dose Limit

a. Requirement

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

• During any calendar quarter: ~ 5 mrads for gamma radiation and ~ 10 mrad for beta radiation
• During any calendar year: ~ 10 rnrads for gamma radiation and ~ 20 rnrad for beta radiation

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

at least once per 31 days.

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

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

The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following: For gamma radiation: (13)

DOMINION VPAP-2103S REVISION 18 PAGE28 OF76 For beta radiation: (14) Where: Subscripts = vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors pv, refers to the vent releases from the process vent i, refers to individual radionuclide Dg the air dose for gamma radiation, in mrad Db the air dose for beta radiation, in mrad Mi = the air dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Ni the air dose factor due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Qivv* Qipv = the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) 3.17 E-08 the inverse of the number of seconds in a year X!Qivv, XIQ;pv the gaseous dispersion factor, sec/m3(See Attachment 7) 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effiuent Dose Limit

a. Requirement

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

• During any calendar quarter: ~ 7.5 mrem to the critical organ
• During any calendar year:~ 15 mrem to the critical organ

2. Cumulative dose contributions to a member of the public from I 131 , 1133 ,

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

DOMINION VPAP-2103S REVISION 18 PAGE290F76

b. Action If the calculated dose from the release ofl 131 , 1133 , tritium, and radionuclides in particulate form, with half-lives greater than 8 days, in gaseous effluents exceeds any of the above limits, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that contains the:

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

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

' I limiting organ for the period being evaluated.

 !

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

DOMINION VPAP-2103S REVISION 18 PAGE300F76

1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary thatcontainI 131 , 1133 , tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

Dr= 3.17£ - 08 ~[RM ( Qivv. DIQVV + Qipv. DIQPJ +RI ( Qivv. x;Qvv + Qipv .XIQPJ l (15)

                 + RG ( Qivv . D/ Qvv + Qipv . D/ QPJ + RH3 ( Qivv . X/ Qvv + Qipv . X / QpJ]

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

                                = the dose to the critical organ of the maximum exposed member of the public in mrem ,

the release for ventilation vents or process vent of I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than 8 days in Curies 3 .17 E-08 = the inverse of the number of seconds in a year X!Qvv, X!Qpv the gaseous dispersion factor, sec/m3(See Attachment 7) DIQvv, D/Qpv = the gaseous deposition factor, m- 2 (See Attachment 7) RM = the cow-milk pathway dose factor due to I 131 , I 133 , tritium, and frOm all particulate-form radionuclides with half-lives greater than eight days, in m 2 -mrem/yr per Ci/sec RI = the inhalation pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrem/yr per Ci/m3 RG the ground plane pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m 2 -mrem/yr per Ci/sec RH 3 = the tritium dose factor for milk in mrem/yr per Ci/m3

DOMINION VPAP-2103S REVISION 18 PAGE 31 OF76 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

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

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations

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

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

DOMINION VPAP-2103S REVISION 18 PAGE 320F76

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

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

Dp =(Dg x P) + Da 6.4 Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis. 6.4.1 Liquid Waste Batch Releases

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

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

• Turbine Building Sumps when RP determines that source activity requires placing pumps in manual mode
• Condensate Polishing Building Sumps and Steam Generator secondary water when RP determines the presence of contamination from primary-to-secondary leakage
• Radwaste Facility release tanks (L WMT, LDMT) 6.4.2 Continuous Liquid Releases

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

b. Examples of continuous releases include:

• Steam generator blowdown
• Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable
• Turbine building sumps and subsurface drains when pumps are in automatic mode or storm drains

DOMINION VPAP-2103S REVISION 18 PAGE 33 OF76 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until:

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

6.4.6 Radioactive Liquid and Gaseous Release Controls

                                   -

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

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

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

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

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

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

• Maximum authorized release rate
• Applicable conditions or controls pertaining to the release

DOMINION VPAP-2103S REVISION 18 PAGE 34 OF76

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

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

1. Verify the correct source is authorized for release.

2. Note maximum authorized release rate.

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

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

As appropriate, required information shall include:

• Date and time release was started
• Starting tank/sump level
• Beginning pressure
• Release flow rate
• Dilution water flow rate

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

• Date and time release was stopped
• Tank/sump ending level
• Release flow rate just prior to termination
• Ending pressure
• Volume released 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem).

DOMINION VPAP-2103S REVISION 18 PAGE35 OP76 6.5.2 Action

a. If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.1 have been exceeded.

b. If the limits in Step 6.5.1 have been exceeded, prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that defines the corrective action to be taken to reduce subsequent releases and to prevent recurrence, and includes a schedule for achieving conformance with the limits. Special reports, as defined in 10 CPR 20.2203(a)(4), shall include:

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

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

3. If the estimated dose exceeds the limits in Step 6.5.1, and if the release condition that violates 40 CPR 190 has not already been corrected, the special report shall include a request for a variance in accordance with the provisions of 40 CPR 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 18 PAGE360F76

3. Samples shall be analyzed in accordance with:

• Radiological Environmental Monitoring Program (Attachment 8) requirements
• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 10)
• Guidance of the Radiological Assessment Branch Technical Position on Environmental Monitoring dated November, 1979, Revision No. 1

b. Action

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

2. If, when averaged over any calendar quarter, radioactivity exceeds the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11), prepare and submit to the NRC, within 30 days, a special report in accordance with VPAP-2802, Notifications and Reports, that:

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

concentration (1) + concentration (2) + ... ;: : 1.0 (15) reporting level (1) reporting level (2)

DOMINION VPAP-2103S REVISION 18 PAGE 37 OF76

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11) are detected and are the result of plant effluents, the report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are unavailable from one or more of the sample locations required by Radiological Environmental Monitoring Program (Attachment 8), identify locations for obtaining replacement samples and add them to the radiological environmental monitoring program within 30 days. The specific locations from which samples were unavailable may then be deleted from the monitoring program. Identify the cause of the unavailability of samples and identify the new locations for obtaining replacement samples in the next Annual Radioactive Effluent Release Report in accordance with VPAP-2802, Notifications and Reports.

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

DOMINION VPAP-2103S REVISION 18 PAGE 38 OF76 6.6.2 Land Use Census

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

• Nearest milk animal
• Nearest residence
• Nearest garden greater than 50 m2 (500 ft2) that produces broad leaf vegetation I

1. The land use census shall be conducted during the growing season, at least once per 12 months, using methods that will provide the best results (e.g.,

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

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

b. Action

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE390F76 6.6.3 Interlaboratory Comparison Program

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

b. Action I. Analyses shall be performed at least semi-annually as follows:

Program Cross-Check of Milk I 131 Gamma Sr89 and Sr90

                                                '       '

Water Gross Beta, Gamma, I 131 , H 3 (Tritium), Sr89 and Sr90 (blind-any combinations of above radionuclides) Air Filter Gross Beta, Gamma, Sr90

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

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

6. 7 Reporting Requirements 6.7.l Annual Radiological Environmental Operating Report Routine Radiological Environmental Operating Reports covering the operation of the units during the previous calendar year shall be submitted prior to May 1 of each year.

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

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

• A comparison (as appropriate) with preoperational studies, operational controls, and previous environmental surveillance reports
• An assessment of the observed impacts of the plant operation on the environment
• Results of land use census per Step 6.6.2

DOMINION VPAP-2103S REVISION 18 PAGE400F76

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

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

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

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

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

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

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE41 OF76 NOTE: NUREG-0543 states: "There is reasonable assurance that sites with up to four operating reactors that have releases within Appendix I design objective values are also in conformance with the EPA Uranium Fuel Cycle Standard, 40 CPR Part 190."

6. 7 .2 Annual Radioactive Eftluent Release Report

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

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

Data shall be summarized on an annual basis following the format of Regulatory Guide 1.21, Appendix B, for solid waste. [Commitment 3.2.2]

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

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

• Unplanned releases that exceeded the limits in Steps 6.2.l and 6.3.1
• Unplanned releases which require a Condition Report and involve the discharge of contents of the wrong Waste Gas Decay Tank or the wrong liquid radwaste release tank
• Unplanned releases from large leaks due to unexpected valve or pipe failures that result in a quantity of release such that a 10 CPR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CPR 50.73, Licensee Event Report System, report is required
• Unplanned releases as determined by Radiation Protection Supervision, which may or may not require a Condition Report

DOMINION VPAP-2103S REVISION 18 PAGE420F76

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

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

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

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

• An unintended spill or leak with the potential to reach groundwater, as defined in NEI 07-07, and
• The spill or leak must be greater than 100 gallons in volume or the volume cannot be quantified but is estimated to be greater than 100 gallons; or
• Any spill or leak, regardless of volume or activity deemed by the licensee to be reportable.

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

b. Dose Assessment - Station

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

Population doses shall not be included in dose assessments.

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

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

DOMINION VPAP-2103S REVISION 18 PAGE43 OF76 NOTE: The Annual Radioactive Effluent Release Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

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

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

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

6.7.3 Annual Meteorological Data

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

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

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

a. Approved by the Site Vice President before implementation.

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

Documentation shall include:

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

DOMINION VPAP-2103S REVISION 18 PAGE440F76

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

• 10 CFR 20, Subpart D
• 40CFR190
• 10 CFR 50.36a
• 10 CFR 50, Appendix I
• Technical Specifications

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

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

6.7.5 Industry Ground Water Protection Initiative

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

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

b. Communications

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

DOMINION VPAP-2103S REVISION 18 PAGE45 OF76

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

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

c. 30-Day Reports

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

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

d. Annual Reports

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

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE460F76 7.0 RECORDS 7.1 The following record(s) completed as a result of this procedure are required to be transmitted to Nuclear Document Management (NDM). The records have been identified and retention requirements established for the Nuclear Records Retention Schedule (NRRS) per RM-AA-101, Record Creation, Transmittal, and Retrieval.

7. l. l Quality Assurance Records

• Records of changes to the ODCM in accordance with Step 6.7.4
• Records of meteorological data in accordance with Step 6.7.3
• Records of sampling and analyses
• Records of radioactive materials and other effluents released to the environment
• Records of preventive maintenance, surveillances, and calibrations 7 .1.2 Non-Quality Assurance Records None 7.2 The following record(s) completed as a result of this procedure are NOT required to be transmitted to Nuclear Document Management (NDM), but are required to be retained as indicated below. The NRRS has been updated and Alternate Storage approved per RM-AA-101 for Quality Assurance Records.

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

DOMINION VPAP-2103S REVISION 18 PAGE470F76 ATTACHMENT 1 (Page 1of1) Radioactive Liquid Effluent Monitoring Instrumentation Instrument Minimum Action Operable Channels L GROSS RADIOACTIVITY MONITORS PROVIDING ALARM AND AUTOMATIC TERMINATION OF RELEASE (a) Radwaste Facility Liquid Effluent Line, RE-RRM-131 1 1

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

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW-153 1 1 ACTION 1: If the number of operable channels is less than required, effluent releases via this pathway shall be suspended.

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

DOMINION VPAP-21038 REVISION 18 PAGE48 OF76 ATTACHMENT 2 (Page 1 of 1) Radioactive Liquid Effiuent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel Channel Check Check Calibration Functional Tes1

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE49 OF76 ATTACHMENT 3 (Page 1of3) Radioactive Liquid Waste Sampling and Analysis Program Lower Limit of Liquid Release Sampling Minimum Analysis Type of Activity Detection (LLD) Type Frequency Frequency Analysis (µCi/mL), (Note 1) p p Principal Gamma 5 x 10-1 Emitters (Note 3) (Each Batch) (Each Batch) I131 1x10-6 p Dissolved and Batch Releases M Entrained Gases 1x10-5 (One Batch/M) (Gamma Emitters) (Note 2) p MComposite H3 1x10-5 (Each Batch) (Note 4) Gross Alpha 1x10-1 p Q Composite Sr89 and Sr90 5 x 10-8 (Each Batch) (Note 4) Fe55 1x10-6 Principal Gamma 5 x 10-1 Continuous WComposite Emitters (Note 6) (Note 6) (Note 6) I 131 1x10-6 Dissolved and Continuous M M Entrained Gases 1x10-5 Releases Grab Sample (Gamma Emitters) (Note 5) Continuous M Composite H3 1x10-5 (Note 6) (Note 6) Gross Alpha 1x10-1 Continuous Q Composite Sr89 and Sr90 5 x 10-8 (Note 6) (Note 6) Fe55 1x10-6

DOMINION VPAP-2103S REVISION 18 PAGE500F76 ATTACHMENT 3 (Page 2of3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 Sb LLD (8-1) E

• V
• 2.22E+06
• Y
• e-CA-~t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) A the radioactive decay constant for the particular radionuclide

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

The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement. NOTE 2: A batch release is the discharge of liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S REVISION 18 PAGE51 OF76 ATTACHMENT 3 (Page 3of3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn54 , Fe59 , Co58 , Co 60 , Zn65 , Mo99 , Cs 134 , Cs 137 , Ce 141 , and Ce 144. This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and for which the method of sampling employed results in a specimen that is representative of the liquids released. NOTE 5: A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from a volume of a system that has an input flow during the continuous release. NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid effluents, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release.

DOMINION VPAP-2103S REVISION 18 PAGE520F76 ATTACHMENT 4 (Page 1of4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCi/mL), (Note 1) Prior to Release A. Waste Gas Prior to Release Principal Gamma (Each Tank) 1x10-4 Storage Tank (Each Tank) Emitters (Note 2) (Grab Sample) Principal Gamma Prior to Release Prior to Release 1x10-4 B. Containment Emitters (Note 2) (Each PURGE) Purge (Each PURGE) H3 1x10-6 (Grab Sample) C. Ventilation Weekly Principal Gamma Weekly 1x10-4 (l)Process Vent (Grab Sample) Emitters (Note 2) (2)Vent Vent #1 (3)Vent Vent #2 (Note 3) (Note 3) H3 1x10-6 (4)SRF Vent 1131 1 x 10- 12 Continuous Weekly (Note 5) (Note 4) (Charcoal Sample) 1133 1x10- 10 Continuous Weekly (Note 5) Principal Gamma 1x10- 11 All Release (Note 4) Particulate Sample Emitter (Note 2) week.ly Continuous Types as listed Composite Gross Alpha 1x10- 11 (Note 4) Particulate Sample in A, B, and C (.!uarterly Continuous Composite Sr89 and Sr90 1x10- 11 (Note 4) Particulate Continuous Noble Gas Monitor Noble Gases Gross 1x10-6 (Note 4) Beta and Gamma Principal Gamma Weekly Weekly 1x10-4 Condenser Air Emitters (Note 2) Grab Sample Ejector (Note 3) H3 1x10-6 (Note 3)

DOMINION VPAP-2103S REVISION 18 PAGE53 OF76 ATTACHMENT 4 (Page 2 of 4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCi/mL), (Note 1) Principal Gamma Prior to Release Prior to Release 1x10-4 Emitters (Grab Sample) (Each Release) H3 1x10-6 Il31 1x10- 11 Continuous Charcoal Sample (Note 4) (Note 6) I133 1x10- 10 Containment Continuous Particulate Sample Principal Gamma 1x10- 10 HogDepres- (Note 4) (Note 6) Emitter (Note 2) surization Composite Particu-Continuous 1x10-10 late Sample Gross Alpha (Note 4) (Note 6) Composite Particu-Continuous late Sample Sr89 and Sr90 1x10- 10 (Note 4) (Note 6)

DOMINION VPAP-2103S REVISION 18 PAGE540F76 ATTACHMENT 4 (Page 3 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 Sb LLD (10-1) E

• V
• 2.22E+06
• Y
• e-(A.At)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9). Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm). E = the counting efficiency (as counts per disintegration). V = the sample size (in units of mass or volume). 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie. Y = the fractional radiochemical yield (when applicable). A, = the radioactive decay constant for the particular radionuclide. At = the elapsed time between the midpoint of sample collection and time of counting. Typical values of E, V, Y and At should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP-2103S REVISION 18 PAGE 55 OF76 ATTACHMENT 4 (Page 4 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the followingradionuclides: Kr87 , Kr88 , Xe 133 , Xe 133 m, Xe 135 , Xe 135 m, andXe 138 for gaseous emissions and Mn54, Fe59 , Co 58 , Co 60 , Zn65 , Mo 99 , Cs 134, Cs 137 , Ce 141 and Ce 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and identifiable at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. NOTE 3: Sampling and analysis shall also be performed following shutdown, start-up, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, when:

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

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

NOTE 4: The ratio of the sample flow rate to the sampled stream flow rate shall be known for the period covered by each dose or dose rate calculation made in accordance with Steps 6.3.1, 6.3.3, and 6.3.4. NOTE 5: Samples shall be changed at least once per seven days and analyses shall be completed within 48 hours after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours for at least seven days following each shutdown, start-up, or thermal power change exceeding 15 percent of rated thermal power in one hour, and analyses shall be completed within 48 hours of changing. When samples collected for 24 hours are analyzed, the corresponding LLDs may be increased by a factor of 10. This requirement applies if:

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

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

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

DOMINION VPAP-2103S REVISION 18 PAGE560F76 ATTACHMENT 5 (Page 1of2) Radioactive Gaseous Effiuent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS

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

1-GW-RM-130B 1 1 (b) Iodine Sampler: Continuous HP Sampler, or 1-GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (c) Particulate Sampler: Continuous HP Sampler, or 1-GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor: 1-GW-Ff-100 1 3 (e) Sampler Flow Rate Measunng Device: HP Sampler Rotometer or MGPI Flow Rate Measuring 1 3 Device

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

1-SV-RM-111 1 1 2-SV-RM-211 1 1 (b) Air Ejector Flow Rate Measuring Device: Unit 1: 1-VP-FI-lA 1 3 1-VP-FI-lB 1 3 Unit 2: 2-VP-FI-lA 1 3 2-VP-FI-lB 1 3

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

SRF: RRM-101 1 1 SPS: Vent#l, 1-VG-RM-104 1 1 Vent#2, 1-VG-RM-131B 1 1 (b) Iodine Sampler: SRF: RRM-101 1 2 SPS: Vent#l, 1-VG-RM-104 (NOTE2) 1 2 Vent #2, Continuous HP Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler

DOMINION VPAP-2103S REVISION 18 PAGE 57 OF76 ATTACHMENT 5 (Page 2of2) Radioactive Gaseous Effluent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS (c) Particulate Sampler: SRF: RRM-101 1 2 SPS: Vent #1, VG-RM-104 (NOTE 2) 1 2 Vent #2, HP Continuous Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor: SRF: 01-RHV-FT-156 1 3 SPS: Vent#l, 1-VS-FT-119 1 3 Vent#2, 1-VS-FT-116 1 3 (e) Sampler Flow Rate Measuring Device: SRF: RRM-101 1 3 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 3 Vent #2, HP Sampler Rotometer or 1 3 MGPI Flow Rate Measuring Device NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components. NOTE 2: Vent# 1, l-VG-RM-104, HP continuous sampler pump automatically maintains isokinetic sample flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take 15 - 20 minutes. [Commitment 3.23] ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours and these samples are analyzed for gross activity within 24 hours. When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis. [Commitment 3.2.4] ACTION2: If the number of operable channels is less than required, effluent releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours after the initiation of this ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4 ). [Commitment 3.2.4] ACTION3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours.

DOMINION VPAP-2103S REVISION 18 PAGE58 OF76 ATTACHMENT 6 (Page 1of2) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL CHANNEL SOURCE CHANNEL DESCRIPTION FUNCTIONAL CHECK CHECK CALIBRATION TEST

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

Providing Alarm and Automatic Termination of Release 1-GW-RM-130B D M R Q (b) Iodine Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor 1-GW-Ff-100 D NIA R NIA (e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or D NIA SA NIA MGPI Flow Rate Measuring Device D NIA R NIA

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

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

DOMINION VPAP-2103S REVISION 18 PAGE590F76 ATTACHMENT 6 (Page 2 of2) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL CHANNEL SOURCE CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST (b) Iodine Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor SRF:O 1-RHV-Ff-156 SPS: Vent#l, 1-VS-Ff-119 Vent#2, 1-VS-Ff-116 D NIA R NIA (e) Sampler Flow Rate Measuring Device (NOTE 1) SRF: RRM-101 D NIA R NIA SPS: Vent#l, 1-VG-RM-104 D NIA R NIA Vent #2, HP Sampler Rotometer D NIA R NIA or MGPI Flow Rate Measuring D NIA SA NIA Device NOTE l:The mark numbers listed above in l(b), l(c), 3(b), 3(c), and 3(e) refer to the gaseous effluent radiation monitor or monitor skid with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor.

DOMINION VPAP-2103S REVISION 18 PAGE 60 OF76 ATTACHMENT 7 (Page 1 of 1) Dispersion and Deposition Factors Distance, Ventilation Vent Process Vent Description Sector meters XIQ D!Q XIQ D!Q N 500 l.4E-05 1.6E-08 4.2E-08 3.9E-10 NNE 532 l.8E-05 3.3E-08 l.2E-07 l.2E-09 NE 629 l.3E-05 3.0E-08 l.8E-07 l.6E-09 ENE 806 7.lE-06 1.3E-08 l.8E-07 l.8E-09 E 1210 2.7E-06 7.2E-09 2.6E-07 l.8E-09 ESE 1984 9.8E-07 3.2E-09 2.4E-07 l.7E-09 SE 1371 2.2E-06 6.8E-09 2.6E-07 2.lE-09 SSE 919 4.3E-06 9.2E-09 2.3E-07 l.2E-09 Site Boundary s 645 5.9E-06 1.lE-08 l.7E-07 l.3E-09 SSW 565 6.3E-06 1.2E-08 l.3E-07 l.4E-09 SW 548 9.7E-06 l.9E-08 l.3E-07 l.3E-09 WSW 656 8.4E-06 1.6E-08 l.4E-07 l.3E-09 w 565 l.2E-05 2.9E-08 l.2E-07 l.OE-09 WNW 565 l.4E-05 2.6E-08 8.7E-08 5.8E-10 NW 581 l.3E-05 1.7E-08 l.2E-07 8.9E-10 NNW 581 9.SE-06 1.lE-08 5.lE-08 3.lE-10 N 6534 2.4E-07 2.lE-10 6.7E-08 8.8E-11 NNE 3122 l.OE-06 1.7E-09 l.9E-07 3.7E-10 NE 7564 2.7E-07 4.2E-10 6.7E-08 l.8E-10 SE 4554 3.4E-07 8.6E-10 8.7E-08 2.7E-10 SSE 4265 3.7E-07 6.6E-10 9.SE-08 2.5E-10 s 2736 5.SE-07 9.SE-10 l.9E-07 5.7E-10 Resident SSW 2977 4.lE-07 7.4E-10 l.4E-07 4.5E-10 SW 3637 4.SE-07 7.7E-10 l.2E-07 3.4E-10 WSW 660 6.4E-06 l.3E-08 l.8E-07 l.3E-09 w 5053 3.4E-07 7.lE-10 8.lE-08 2.lE-10 WNW 7886 2.2E-07 2.9E-10 4.9E-08 9.4E-11 NW 7467 2.2E-07 2.2E-10 5.8E-08 l.3E-10 NNW 6035 2.3E-07 2.0E-10 6.2E-08 7.lE-11 SSW 7693 9.9E-08 1.4E-10 5.0E-08 l.2E-10 Milk: Cow NNW 5938 2.4E-07 2.lE-10 6.3E-08 7.lE-11 SSE 4265 3.7E-07 6.6E-10 9.5E-08 2.5E-10 s 3235 4.2E-07 7.lE-10 l.6E-07 4.3E-10 SSW 3122 3.8E-07 6.8E-10 l.3E-07 4.lE-10 Garden SW 7596 l.5E-07 2.lE-10 5.3E-08 l.2E-10 WSW 5713 2.0E-07 3.2E-10 7.SE-08 l.8E-10 w 5536 3.0E-07 6.0E-10 7.SE-08 l.8E-10 NNW 7017 l.9E-07 1.6E-10 5.3E-08 7.4E-11

DOMINION VPAP-2103S REVISION 18 PAGE61 OF76 ATTACHMENT 8 (Page 1 of 3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

1. DIRECT RADIATION About 40 Routine Monitor-ing Stations to be placed as follows:

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

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

3) The balance of the 8 dosimeters should be placed in special interest areas such as population centers, nearby residents, schools, and in 2 or 3 areas to serve as controls

2. AIRBORNE Samples from 7 locations:

a) 1 sample from close to the site boundary location of the highest IRadioiodine Canister calculated annual I 131 Analysis Weekly average ground level Continuous Radioiodines and D/Q Sampler Particulates b) 5 sample locations 6-8 operation with !Particulate Sampler km distance located in a sample collection Gross beta radioactivity concentric ring around weekly analysis following filter the Station change; c) 1 sample from a control Gamma isotopic analysis location 15-30 km of composite (by distant, providing valid location) quarterly background data

DOMINION VPAP-2103S REVISION 18 PAGE620F76 ATTACHMENT 8 (Page 2of3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

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

4. INGESTION a) Milk a) 2 samples from milking animals in the vicinity of the Station. (NOTE 1) Gamma isotopic and r131 b) 1 sample from milking Monthly animals at a control analysis monthly location (-15-30 km distant). (NOTE 2) a) 6 samples of filter feeders (clams, oysters) in the Semi-Annually b) Fish and vicinity of the Station Gamma isotopic on edible Invertebrates c) 1 sampling of crabs from Annually portions the vicinity of the Station d) 1 sampling of 2 different species in vicinity of Semi-Annually Station discharge area.

(NOTE3) NOTE 1: If milk sampling cannot be performed, use item 4.c, Food Products - d. Milk sampling cannot be performed when there are no milk sampling locations in the vicinity of the Station. NOTE2: If milk sampling from a control location cannot be performed, use item 4.c) e). Milk sampling cannot be performed when there is no milk sampling location 30 km distant. NOTE3: Commercially or recreationally important species permitted for sampling by the Virginia Marine Resources Commission include catfish, white perch, croaker, striped bass, spot, red drum, and striped mullet.

DOMINION VPAP-2103S REVISION 18 PAGE63 OF76 ATTACHMENT 8 (Page 3 of 3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

4. INGESTION (Continued) a) 1 sample com Gamma isotopic on edible b) 1 sample soybeans Annually portions c) 1 sample peanuts d) 1 sample of a broadleaf vegetation grown nearest in each of two different available offsite locations (sectors) with the c) Food Products highest annual average ground level D/Qs, if Monthly, if Gamma isotopic and I 131 milk sampling is not available, or at analysis performed. harvest e) 1 sample of a broadleaf vegetation grown 15 -

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

DOMINION VPAP-2103S REVISION 18 PAGE640F76 ATTACHMENT 9 (Page 1of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Air Charcoal and Surry Station (SS) 0.3 NNE Particulate Hog Island Reserve (HIR) 2.0 NNE Bacon's Castle (BC) 4.5 SSW Alliance (ALL) 5.1 WSW Colonial Parkway (CP) 3.8 NNW BASF (BASF) 5.1 ENE Fort Eustis (FE) 4.9 ESE Newport News (NN) 19.3 SE Control Location Environmental Control (00) Onsite

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

North North West (04) 0.2 NNW Site Boundary North (05) 0.3 N Site Boundary North North East (06) 0.3 NNE Site Boundary North East (07) 0.3 NE Site Boundary East North East (08) 0.4 ENE Site Boundary East (09) 0.3 E Site Boundary West (10) 0.1 w Site Boundary West South West (11) 0.4 WSW Site Boundary South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary South (14) 0.4 s Site Boundary South South East (15) 0.6 SSE Site Boundary South East (16) 0.9 SE Site Boundary Station Intake (18) 1.6 ESE Site Boundary Hog Island Reserve (19) 2.0 NNE Near Resident

DOMINION VPAP-2103S REVISION 18 PAGE 65 OF76 ATTACHMENT 9 (Page 2of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Environmental Bacon's Castle (20) 4.5 SSW Approx. 5 miles TLDs Route 633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles Surry (23) 7.7 WSW Population Center Route 636 and 637 (24) 4.0 w Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles Kingsmill (29) 4.6 N Approx. 5 miles Williamsburg (30) 7.8 N Population Center Kingsmill North (31) 5.5 NNE Approx. 5 miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News (38) 19.3 SE Population Center James River Bridge (39) 17.1 SE Control Benn's Church (40) 17.0 SSE Control Smithfield (41) 13.4 SSE Control Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 s Approx. 5 miles Milk Epps 4.8 SSW Colonial Parkway 3.7 NNW Williams 27.5 s Control Location

DOMINION VPAP-2103S REVISION 18 PAGE 66 OF76 ATTACHMENT 9 (Page 3of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Well Water Surry Station Onsite** Hog Island Reserve 2.0 NNE Construction Site 0.3 E Onsite*** Crops (Com, Slade's Farm 3.2 s Peanuts, Soybeans) Brock's Farm 3.8 s River Water Surry Discharge 0.4 NW (Monthly) Scotland Wharf 4.9 WNW Control Location Sediment Chickahominy River 11.2 WNW Control Location (Silt) Surry Station Discharge 1.3 NNW Clams Chickahominy River 11.2 WNW Control Location Surry Station Discharge 1.3 NNW Jamestown Island 3.9 NW Oysters Point of Shoals 6.4 SSE Mulberry Point 4.9 ESE Lawne's Creek 2.4 SE Crabs Surry Station Discharge 1.3 NNW Fish Surry Station Discharge 1.3 NNW Shoreline Hog Island Reserve 0.6 N Sediment Chickahominy River 11.2 WNW Control Location

• Onsite Location - in Lead Shield
  • Onsite sample of Well Water taken from tap-water at Surry Environmental Building
    • Onsite sample of Well Water taken from tap-water at Surry Training Center

DOMINION VPAP-2103S REVISION 18 PAGE67 OF76 ATTACHMENT 10 (Page 1of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) Analysis Water Airborne Fish Milk Food Sediment (NOTE2) (pCi/L) Particulate (pCi/kg) (pCi/L) Products (pCi/kg) or Gases (wet) (pCi/kg) (dry) (pCifm3) (wet) Gross beta 4 0.01 H-3 2,000 Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 1-131 (NOTE 3) 1 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 La-140 15 15 NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also be

• identified and reported.

NOTE 3: LLD for the ground (drinking) water samples. The LLD for the surface (non-drinking) water samples is 10 pCi/L.

DOMINION VPAP-2103S REVISION 18 PAGE 68 OF76 ATTACHMENT 10 (Page 2of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) NOTE 1: For a particular measurement system (which may include radiochemical separation): LLD (24-1) E

• V
• 2.22E+06
• Y
• e-CA-L1t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) A = the radioactive decay constant for the particular radionuclide L1t = the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, hot plant effluent samples) Typical values of E, V, Y and L1t should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP-2103S REVISION 18 PAGE690F76 ATTACHMENT 11 (Page 1of1) Reporting Levels for Radioactivity Concentrations in Environmental Samples Analysis Water Airborne Fish Milk Food Products (pCi/L) Particulate or (pCilkg, wet) (pCi/L) (pCi/kg, wet) Gases (pCifm3) H-3 20,000* Mn-54 1,000 30,000 Fe-59 400 10,000 Co-58 1,000 30,000 Co-60 300 10,000 Zn-65 300 20,000 Zr-Nb-95 400 I-131 2* 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

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

DOMINION VPAP-2103S REVISION 18 PAGE 700F76 ATTACHMENT 12 (Page 1of7) Meteorological, Liquid, and Gaseous Pathway Analysis 1.0 METEORLOGICAL ANALYSIS 1.1 Purpose The purpose of the meteorological analysis was to determine the five (5) year average XIQ and D/Q values at critical locations around the Station for ventilation vent (ground level) and process vent (niixed mode) releases. The five year average XIQ and D/Q values are used in the dose pathway analysis to determine dose and dose rate at site boundary and dose to the member of the public. 1.2 MeteorolOgical Data, Parameters, and Methodology A five (5) year average ofrepresentative onsite meteorological data for the period January 1, 2007 through December 31, 2011, is used in the gaseous effluent dose pathway calculations. i This data includes wind speed, wind direction, and differential temperature for the purpose of I. determining joint frequency distributions for those releases characterized as ground level (i.e., ,- 1 ventilation vent), and those characterized as mixed mode (i.e., process vent). I X/Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ - Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324. The open terrain adjustment factors were applied to the XIQ values as recommended in Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain correction factors are considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area. The effective release height used in mixed mode release calculations was

• based on a process vent release height of 131 ft, and plume rise due to momentum for a vent diameter of 1.5 in. with plume exit velocity of 100 ft/sec.

Ventilation vent, and vent releases other than from the process vent, are considered ground level as specified in Regulatory Guide 1.111 for release points less than the height of adjacent solid structures. Terrain elevations were obtained from Surry Power Station Units 1 and 2 Virginia Electric and Power Company Updated Final Safety Analysis Report Table 1 lA-8. XIQ and D/Q values were calculated for the nearest site boundary, residence, milk-cow, discharge bank, and vegetable garden by sector for process vent and ventilation vent releases.

DOMINION VPAP-2103S REVISION 18 PAGE 71 OF76 ATTACHMENT 12 (Page 2of7) Meteorological, Liquid, and Gaseous Pathway Analysis According to the definition for short term in NUREG-0133, "Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations," October, 1978, some gaseous releases may fit this category, primarily waste gas decay tank releases and containment purges. However, these releases are considered long term for dose calculations as past releases were both random in time of day and duration as evidenced by reviewing past release reports. Therefore, the use of annual average concentrations is appropriate according to NUREG-0133. 1.3 Results The XIQ and D/Q values used in the dose pathway analysis for ventilation vent releases and process vent releases can be found in Attachment 7. 2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose The purpose of the liquid pathway analysis was to determine the maximum exposed member of the public in unrestricted areas as a result of radioactive liquid effluent releases. The analysis included a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste Effluents. 2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station effluent release reports. The data for each year, along with appropriate site specific parameters and default selected parameters, were entered into the NRC computer code LADTAP as described in NUREG-1276. Liquid radioactive effluents from both units are released to the James River via the discharge canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do not exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours per year, and that bank fishing would be performed a maximum of 160 hours per year.

DOMINION VPAP-2103S REVISION 18 PAGE 720F76 ATTACHMENT 12 (Page 3 of7) Meteorological, Liquid, and Gaseous Pathway Analysis For an individual fishing in the discharge canal, no river dilution was assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e., a mixing ratio of 0.2) was assumed as appropriate according to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities and ingestion of fish and invertebrates are included in the Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year.the individual spent fishing in the canal. 2.3 Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and invertebrate pathways, are calculated for total body and various critical organs. Validation of the limiting age group and critical organ is performed by the liquid effluent dose calculation program using the data, parameters, and methodology provided in the Source Code file. 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose Gaseous effluent pathway analyses are performed to determine the location that would result in the maximum doses due to noble gases, for use in demonstrating compliance with Steps 6.3.1.a. and 6.3.3.a. The analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the release of I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than eight days for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed individual through the inhalation pathway from I 131 , I 133 , tritium, and particulates to demonstrate compliance with Step 6.3.l.a.

DOMINION VPAP-2103S REVISION 18 PAGE 73 OF76 ATTACHMENT 12 (Page 4 of7) Meteorological, Liquid, and Gaseous Pathway Analysis 3.2 Data, Parameters, and Methodology Five year average X/Q values were calculated, as described in Section 1 of this attachment. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble gases would be at these site boundary locations. The doses from both the ventilation vent and process vent release points are summed to calculate total maximum dose. 6.3.l.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and XIQ values determined for maximum noble gas doses can be used to determine the maximum dose from I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway. The maximum exposed individual for 10 CPR 50, Appendix I, compliance could be at any of the following locations: site boundary, nearest resident, nearest milk-cow, or nearest vegetable garden, using the Land Use Census data which is assessed annually. Therefore, ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous effluent dose pathway analyses. Ground plane, inhalation, cow-milk, and vegetable garden pathways are active with the exception of the infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses. The gamma and beta dose factors Kivv. Livv. Mivv, and Nivv for ground level releases and the gamma and beta dose factors Kipv, Lipv, Mipv, and Nipv for mixed mode releases are included in the Source Code file. Inhalation pathway dose factors Pivv and Pipv are calculated using the following equation: Pi= K' (BR) DFAi mrem/yr per Ci/m3 (28-1) where: K' = a constant of unit conversion, lE+ 12 pCi/Ci BR= the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev.1 DFAi = the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 18 PAGE 74 OF76 ATTACHMENT 12 (Page 5 of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R.G. 1.109, Rev. 1. It was determined that the member of the public within site boundary would be using the discharge canal bank for fishing a maximum of 160 hours per year. Active pathways are ground plane and inhalation, and all age groups are evaluated for this pathway analysis. The RMivv and RMipv dose factors, except for tritium, are calculated using the following equation: RM.1 (28-2) where: K' = a constant of unit conversion, lE+ 12 pCi/Ci Qp =cow's consumption rate, 50, in kg/day (wet weight) Uap=infant milk consumption rate, 330, in liters/yr Yp =agricultural productivity by unit area of pasture feed grass, 0.7 in kg/m2 Y s =agricultural productivity by unit area of stored feed, 2.0, in kg/m2 Fm = stable element transfer coefficients, in days/liter r =fraction of deposited activity retained on cow's feed grass, 1.0 for radioiodine, and 0.2 for particulates DFLi=critical organ ingestion dose factor for the ith radionuclide for the particular age group, in mrem/pCi Ai_ = decay constant for the ith radionuclide, in sec-1

    'Aw =decay constant for removal of activity of leaf and plant surfaces by weathering, 5. 73E-07 sec-1 (corresponding to a 14 day half-life) tf =transport time from pasture to cow, to milk, to receptor, 1.73+05, in seconds th =transport time from pasture, to harvest, to cow, to milk, to receptor, 7. 78E+06, in seconds fP =fraction of year that cow is on pasture, 1.0 (dimensionless)

DOMINION VPAP-2103S REVISION 18 PAGE 75 OF76 ATTACHMENT 12 (Page 6 of7) Meteorological, Liquid, and Gaseous Pathway Analysis fs =fraction of cow feed that is pasture grass while cow is on pasture, 0.8 (dimensionless) Parameters used above were obtained from NUREG-0133 and Regulatory Guide 1.109, Rev.l. Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation is used: K'K'"p m Qp U ap(DFLH3) [o.75(0.5/H~ (28-3) where: K '= a constant of unit conversion 1E+03 gm/kg H = absolute humidity of the atmosphere, 8.0, in gmfm3 0.75 =the fraction of total feed that is water 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined. The inhalation pathway dose factors Rlivv and Rlipv were calculated using the following equation: Rli = K' (BR) DFAi mrem/yr per Ci/m3 (28-4) where: K' = a constant of unit conversion, lE+ 12 pCi/Ci BR= breathing rate of the particular age group, m3/yr DFAi=critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 18 PAGE 76 OF76 ATTACHMENT 12 (Page 7 of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R. G. 1.109, Rev. 1. Breathing Rate Infant = 1400 m 3/yr Child = 3700 m 3/yr Teen = 8000 m 3/yr Adult = 8000 m3/yr The RG dose factors are calculated using the following equation: RG~K'K"(SF)DFG; [ 1-~';'b ] (-m_z_~m-i-;:-:-cl_y_r_) (28 - 5) where: K' = A constant of unit conversion, lE+ 12 pCi/Ci K" = A constant of unit conversion, 8760 hr/year.

                =  The decay constant for nuclide i, sec- 1.
                =  The exposure time, 4.73x108 sec (15 years), from Table E-15 of Reg Guide 1.109.
                =  The ground plane dose conversion factor for nuclide i, from Table E-6 of Reg. Guide 1.109 (mrem/hr per pCi/m2).

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

                                                               ---~-:.,,,  ____   --    ******-                                   . i:*.*.. *~-       -**

Administrative Piocedure*-or Guidance **----:**---..:*:...-::~ .* and Reference Document Approval AD-AA-101 - Attachment 4 _ Page 1 of 1

1. Document Number: 2. Revision: 3. Document Typ!i:

VPAP~2103S 19 *!81 Administrative Procedure 0GARD

4. Tiiie:

bffslte Dose Galculatibn Manual (Surry)

5. Requestor(s) Prl11t Name(s) I Locations 6. Date 7. Requestor*Phone Pete Blount I SPS 10/13/2015 8-798-2467 B. Document Request ONew !81. Revision 0 Cancel 0 Supersede ,0 Temporary I I 9.1\pplicable NtJ<:;lear Station(s)

Millstone D North Anna 0 Surry [81

10. Reas()n al]g-/:lri~fDescriptiqn.ofChange; Revision initiated to incorporaie changes from SAR60263o, Radiological Environmental Monitoririg Program and CR1013104, VPAP~2103S compensatOryactions reviel,!{_not cpmpleted fpr 1-RLW~FIT-153 failure.

,I      For full iist of change~. see Revision Surilm.ary:
 !

I 11. Records Retention Requirements Affected? 12. Change Management: D Yes (Complete NRRS-form fr6Jn R.M-AA-101) !81 N9 Attach Appropri;:ite Pl"AA-4000 Attachment(s)

13. Level of Use:

D Continuous Us.e D Reference* Use. f81 lnforniation Use D Multiple Use FleetApp~o'val . . 14; Fleet Approval Reqlil~d by: (C~e9k one box Qnly. Entef Peer ~rqup Name, if i:!PPlieable)

0 Peer Grou OR. lZJ-Funciional Area Maria er FAM 15.. Printed-Approver Nanie: :16: Slgnatllre 17. Date Jasc:m Eggart

• tDI r3i1s Site Approval

18. Implementation Prere*quisltes: (Items In addition to those listed on Document Trayelerc qr_ Change Management Plan)-

 \      None'

• 19. lmplefT!entatlon PrereqLJisltes Reviewed*- Procedure supervisor Sig NIA

30. Datp.r to?i.\ lc.l I .o

     *31. Nuclear E-Fotms Updated for Site(s)?            32. N\lclear E-Forms Updated Print Name/Signature                         33. Date

[j MP* 0 NA 0 SU 181 N!A NIA N/A

34. Document'Numb~r: 35; Revision: 36. Effective Date 37. EXplratlon Date VPAP.;21035 19 \0 l'-\ . ~ NIA Key: GARD-Guidance and Reference Document, EQMS-Electronlc. Document Management System Form No. 72Bs20(0ct 2014).

Station Administrative Procedure Title: Offsite Dose Calculation Manual (Surry) Process I Program Owner: Manager Radiological Protection and Chemistry (Surry) Procedure Number Revision Number Effective Date VPAP-2103S 19 On File Revision Summary The following changes were made in response to SAR002630, Radiological Environmental Monitoring Program.

• Added Reference 3.1.28 for Branch Technical Position
• Added footnote to Attachment 8 to clarify the omission of the TLD station in the SE sector The following changes were made in response to CR1013104, VPAP-2103S compensatory actions review not completed for 1-RLW-FIT-153 failure.
• Added Reference 3.1.29 for CR1013104
• Updated required action for instrument 3(a) on Attachment 1
• Added Action 3 on Attachment 1 Other Changes:
• Reworded 3rd bullet of Substep 6.4.2.b Approvals on File

DOMINION VPAP-2103S REVISION 19 PAGE20F76 TABLE OF CONTENTS Section Page 1.0 PURPOSE 4 2.0 SCOPE 4

3.0 REFERENCES

/COMMITMENT DOCUMENTS 5 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 10 6.0 INSTRUCTIONS 11 6.1 Sampling and Monitoring Criteria 11 6.2 Liquid Radioactive Waste Effiuents 11 6.2. l Liquid Effluent Concentration Limitations 11 6.2.2 *Liquid Monitoring Instrumentation J3 6.2.3 Liquid Effluent Dose Limit 16 6.2.4 Liquid Radwaste Treatment 19 6.2.5 Liquid Sampling 21 6.3 Gaseous Radioactive .Waste Effiuents 21 6.3.1 Gaseous Effluent Dose Rate Limitations 21 6.3.2 Gaseous Monitoring Instrumentation 24 6.3.3 Noble Gas Effluent Air Dose Limit 27 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effluent Dose Limit 28 6.3.5 Gaseous Radwaste Treatment 31 6.4 Radioactive Liquid and Gaseous Release Permits 32 6.4.l Liquid Waste Batch Releases 32 6.4.2 Continuous Liquid Releases 32 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit 33 6.4.4 Reactor Containment Release Permits 33 6.4.5 Miscellaneous Gaseous Release Permit 33 6.4.6 Radioactive Liquid and Gaseous Release Controls 33

DOMINION VPAP-2103S REVISION 19 PAGE3 OF76 TABLE OF CONTENTS (continued) Section Page 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 34 6.6 Radiological Environmental Monitoring 35 6.6.1 Monitoring Program 35 6.6.2 Land Use Census 38 6.6.3 Interlaboratory Comparison Program 39 6.7 Reporting Requirements 39 6.7.1 Annual Radiological Environmental Operating Report 39

6. 7 .2 Annual Radioactive Effluent Release Report 41

6. 7.3 Annual Meteorological Data 43 6.7.4 Changes to the ODCM 43

6. 7.5 ~ndustry Ground Water Protection Initiative 44 7.0 RECORDS 46 ATTACHMENTS 1 Radioactive Liquid Effiuent Monitoring Instrumentation 47 2 Radioactive Liquid Effiuent Moni~oring Instrumentation 48 Surveillance Requirements 3 Radioactive Liquid Waste Sampling and Analysis Program 49 4 Radioactive Gaseous Waste Sampling and Analysis Program 52 5 Radioactive Gaseous Effiuent Monitoring Instrumentation 56 6 Radioactive Gaseous Effiuent Monitoring Instrumentation 58 Surveillance Requirements 7 Dispersion and Deposition Factors 60 8 Radiological Environmental Monitoring Program 61 9 Environmental Sampling Locations 64 10 Detection Capabilities for Environmental Sample Analysis 67 11 Reporting Levels for Radioactivity Concentrations in Environmental Samples 69 12 Meteorological, Liquid, and Gaseous Pathway Analysis 70

DOMINION VPAP-2103S REVISION 19 PAGE40F76 1.0 PURPOSE The Offsite Dose Calculation Manual (ODCM) establishes requirements for the Radioactive Effluent and Radiological Environmental Monitoring Programs. Methodology and parameters are provided to calculate offsite doses resulting from radioactive gaseous and liquid effluents, to calculate gaseous and liquid effluent monitoring alarm/trip setpoints, and to conduct the Environmental Monitoring Program. Requirements are established for the Annual Radiological Environmental Operating Report and the Annual Radioactive Effluent Release Report required by Station Technical Specifications. Calculation of offsite doses due to radioactive liquid and gaseous effluents are performed to assure that:

• Concentration of radioactive liquid effluents to the unrestricted area will be limited to ten times the effluent concentration values of 10 CFR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases and 2E-4 µCi/mL for dissolved or entrained noble gases
• Exposure to the maximum exposed member of the public in the unrestricted area from radioactive liquid effluents will not result in doses greater than the liquid dose limits of 10 CFR 50, Appendix I
• Dose rate at and beyond the site boundary from radioactive gaseous effluents will be limited to:

      .. Noble gases -less than or equal to a dose rate of 500 mrem/yr to the total body and less than or equal to a dose rate of 3000 mrem/yr to the skin
      ** 1131 , 1133 , and H3 , and all radionuclides in particulate form with half-lives greater than 8 days - less than or equal to a dose rate of 1500 mrem/yr to any organ

• Exposure from radioactive gaseous effluents to the maximum exposed member of the public in the unrestricted area will not result in doses greater than the gaseous dose limits of 10 CFR 50, Appendix I, and
• Exposure to a real individual will not exceed 40 CFR 190 dose limits 2.0 SCOPE This procedure applies to the Radioactive Effluent and Radiological Environmental

                                                                          /

Monitoring Programs at Surry Power Station.

DOMINION VPAP-2103S REVISION 19 PAGE50F76

3.0 REFERENCES

/COMMITMENT DOCUMENTS 3.1 References 3.1.l 10 CFR 20, Standards for Protection Against Radiation 3.1.2 10 CFR 50, Domestic Licensing of Production and Utilization Facilities 3.1.3 40 CFR 190, Environmental Radiation Protection Standards for Nuclear Power Operations 3.1.4 TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites 3.1.5 Regulatory Guide 1.21, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants, Rev. 1, U.S. NRC, June 1974 3.1.6 Regulatory Guide 1.109, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I, Rev. 1, U.S. NRC, October 1977 3.1.7 Regulatory Guide 1.111, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Rev. 1, U.S. NRC, July 1977 3.1.8 Surry Technical Specifications (Units 1 and 2) 3.1.9 NUREG/CR-2919, XOQDOQ, Computer Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations, U.S. NRC, September 1982 3.1.10 NUREG/CR-1276, Users Manual for the LADTAP II Program, U.S. NRC, May, 1980 3.1.11 TID-4500, VCRL-50564, Rev. 1, Concentration Factors of Chemical Elements in Edible Aquatic Organisms, October, 1972 3.1.12 WASH 1258, Vol. 2, July 1973, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion "As Low As Practicable" For Radioactive Material in Light Water-Cooled Nuclear Power Reactor Effluents 3.1.13 NUREG-0597, User's Guide to GASPAR Code, U.S. NRC, June, 1980 3.1.14 Radiological Assessment Branch Technical Position on Environmental Monitoring, November, 1979, Rev. 1 3.1.15 NUREG-0133, Preparation of Radiological Effluent Technical Specifications for Nuclear Power Stations, October, 1978 3.1.16 NUREG-0543, February 1980, Methods for Demonstrating LWR Compliance With the EPA Uranium Fuel Cycle Standard (40 CFR Part 190) 3.1.17 NUREG-0472, Standard Radiological Effluent Technical Specifications for Pressurized Water Reactors, Draft, Rev. 3, March 1982 3.1.18 Environmental Measurements Laboratory, DOE HASL 300 Manual

DOMINION VPAP-2103S REVISION 19 PAGE60F76 3.1.19 NRC Generic Letter 89-01, Implementation of Programmatic Controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program 3.1.20 Surry UFSAR 3.1.21 VPAP-2802, Notifications and Reports 3.1.22 HP-3010.021, Radioactive Liquid Waste Sampling and Analysis 3.1.23 HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis 3.1.24 Design Change 01-022, Ventilation Radiation Monitoring (Kaman) System Replacement/Surry/Unit 1&2 3.1.25 NEI 07-07, Industry Ground Water Protection Initiative - Final Guidance Document 3.1.26 CR022320 (Surry), Daily Channel Checks for 1-VG-RM-131-1 Flow Rate Measuring Device Not Performed 3.1.27 RP-AA-502, Groundwater Protection Program 3.1.28 Branch Technical Position, Revision 1, November 1979 3.1.29 CR1013104, VPAP-2103S c9mpensatory actions review not completed for 1-RLW-FIT-153 failure 3.2 Commitment Documents 3.2.l Quality Assurance Audit Report Number 92-03, Observation 04NS (Item 2) 3.2.2 Deviation Report S-97-1281, Annual Radiological Effluent Release Report 3.2.3 Deviation S-2000-0235, Continuous Vent Stack Sampling 3.2.4 S-2005-0930, Response to the Verification of Back-up Effluent Accountability Sampling 4.0 DEFINITIONS 4.1 Channel Calibration Adjustment, as necessary, of the channel output so it responds with the necessary range and accuracy to known values of the parameter the channel monitors. It encompasses the entire channel, including the sensor and alarm and/or trip functions and the Channel Functional Test. The Channel Calibration can be performed by any series of sequential, overlapping, or total channel steps so the entire channel is calibrated.

DOMINION VPAP-2103S REVISION 19 PAGE70F76 4.2 Channel Check A qualitative assessment, by observation, of channel behavior during operation. This assessment includes, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter. The Channel Check for the MGPI sampler flow rate measuring devices, as listed on Attachment 6 of this procedure, is the direct observation of the MGPI radiation monitor release rate (i.e., microcuries per second) without the presence of a sampler flow fault display. 4.3 Channel Functional Test There are two types of Channel Functional Tests. 4.3.1 Analog Channel Injection of a simulated signal into a channel, as close to the sensor as practicable, to verify Operability, including alarm and/or trip functions. 4.3.2 Bistable Channel Injection of a simulated signal into a sensor to verify Operability, including alarm and/or trip functions. 4.4 Critical Organ That organ, which has been determined to be the maximum exposed organ based on an effluent pathway analysis, thereby ensuring the dose and dose rate limitations to any organ will not be exceeded. 4.5 Dose Equivalent 1-131 That concentration of I 131 (µCi/cc) that alone would produce the same thyroid dose as the quantity and isotopic mixture of I 131 , I 132, I 133 , I 134, and I 135 actually present. Thyroid dose conversion factors for this calculation are listed in Table III of TID-14844, Calculation of Distance Factors for Power and Test Reactor Sites. Thyroid dose conversion factors from NRC Regulatory Guide 1.109, Revision 1, may be used.

DOMINION VPAP-2103S REVISION 19 PAGE80F76 4.6 Frequency Notations NOTE: Frequencies are allowed a maximum extension of 25 percent. NOTATION FREQUENCY D-Daily At least once per 24 hours W-Weekly At least once per 7 days M-Monthly At least once per 31 days Q - Quarterly At least once per 92 days SA - Semi-annually At least once per 184 days R - Refueling At least once per 18 months SIU - Start-up Prior to each reactor start-up P - Prior to release Completed prior to each release NIA- Not applicable Not applicable DR - During the release At least once during each release 4.7 Gaseous Radwaste Treatment System A system that reduces radioactive gaseous effluents by collecting primary coolant system offgases from the primary system and providing delay or holdup to reduce total radioactivity prior to release to the environment. The system comprises the waste gas decay tanks, regenerative heat exchanger, waste gas charcoal filters, process vent blowers and waste gas surge tanks. 4.8 General Nomenclature x = Chi: concentration at a point at a given instant (curies per cubic meter) D = Deposition: quantity of deposited radioactive material per unit area (curies per square meter) Q = Source strength (instantaneous; grams, curies)

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

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

DOMINION VPAP-2103S REVISION 19 PAGE90F76 4.10 Members of the Public Any individual except when that individual is receiving an occupational dose. This category includes non-employees of Dominion who are permitted to use portions of the site for recreational, occupational, or other purposes not associated with Station functions. This category does not include non-employees such as vending machine' servicemen or postal workers who, as part of their formal job function,"occasionally enter an area that is controlled by Dominion to protect individuals from exposure to radiation and radioactive materials. 4.11 Operable - Operability A system, subsystem, train, component, or device is operable or has operability when it is capable of performing its specified functions and all necessary,. attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its functions are also capable of performing their related support functions. 4.12 Purge - Purging Controlled discharge of air or gas from a confinement to maintain temperature, pressure, humidity, concentration, or other operating condition, so that replacement air or gas is required to purify the confinement. 4.13 Rated Thermal Power Total reactor core heat transfer rate to reactor coolant (i.e., 2587 Megawatts Thermal MWt). 4.14 Site Boundary The line beyond which Dominion does not own, lease, or otherwise control the land. 4.15 Source Check For Victoreen and Eberline monitors a source c.heck is the qualitative assessment.of channel response when a channel sensor is exposed to a radioactive source or a light emitting diode, LED. For MGPI monitors a source check is the verification of proper computer response to continuous operational checks on the detector and electronics. 4.16 Special Report A report to NRC to comply with Subsections 6.2, 6.3, or 6.5 of this procedure. Also refer to VP AP-2802, Notifications and Reports.

DOMINION

• VPAP-2103S REVISION 19 PAGE 100F76 4.17 Thermal Power Total reactor core heat transfer rate to the reactor coolant.

4.18 Unrestricted Area Any area at or beyond the site boundary, access to which is neither limited nor controlled by Dominion for purposes of protection of individuals from exposu~e to radiation and radioactive materials, or any area within the site boundary used for residential quarters or for industrial, commercial, institutional or recreational purposes. 4.19 Ventilation Exhaust Treatment System A system that reduces gaseous radioiodine or radioactive material 1n particulate form in effluents by passing ventilation or vent exhaust gases through charcoal adsorbers and High Efficiency Particulate Air (HEPA) filters to remove iodines and particulates from a gaseous

  * ** * :-~ e:x.haust stream prior to release to the environment (such a system is not considered to have any effect on noble gas effluents). Engineered Safety Feature (ESF) atmospheric cleanup systems are not Ventilation Exhaust Treatment System components.

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

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

5 .1.2 Surveying, sampling, and analyzing plant effluents and environmental monitoring, and documenting these activities. 5.1.3 Analyzing plant effluent trends and recommending actions to correct adverse trends. 5.1.4 Preparing Effluent and Environmental Monitoring Program records. 5.2 Manager Nuclear Operations The Manager Nuclear Operations is responsible for requesting samples, analyses, and authorization to release effluents .

...~ ... ...
        ~

DOMINION VPAP-2103S REVISION 19 PAGE 11 OF76

• 6.0 INSTRUCTIONS NOTE: Meteorological, liquid, and gaseous pathway analyses are presented in Meteorological, Liquid, and Gaseous Pathway Analysis (Attachment 12).

6.1 Sampling and Monitoring Criteria 6.1.1 Surveys, sampling, and analyses shall use instruments calibrated for the type and range of radiation monitored and the type of discharge monitored. 6.1.2 Installed monitoring systems shall be calibrated for the type and range of radiation or parameter monitored. 6.1.3 A sufficient number of survey points shall be used or samples taken to adequately assess the status of the discharge monitored. 6.1.4 Samples shall be representative of the volume and type of discharge monitored. 6.1.5 Surveys, sampling, analyses, and monitoring records shall be accurately and legibly documented, and sufficiently detailed that the meaning and intent of the records are clear. 6.1.6 Surveys, analyses, and monitoring records shall be reviewed for trends, completeness, and accuracy. 6.2 Liquid Radioactive Waste Effluents 6.2.1 Liquid Effluent Concentration Limitations

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

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE 120F76

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

Volume of Waste Discharged+ Volume of Dilution Water> (l) 1 Ci/mL. - Volume of Waste Discharged x ~ µ 1 Li ACW-1 where:

           µCi/mLi = the concentration of nuclide i in the liquid effluent discharge ACWi      =ten times the effluent concentration value in unrestricted areas of nuclide i, expressed as µCi/mL from 10 CFR 20, Appendix B, Table 2, Column 2 for radionuclides other than noble gases, and 2E-4 µCi/mL for dissolved or entrained noble gases

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

DOMINION VPAP-2103S REVISION 19 PAGE 13 OF76 6.2.2 Liquid Monitoring Instrumentation

a. Radioactive Liquid Effluent Monitoring Instrumentation Radioactive liquid effluent monitoring instrumentation channels shown on Radioactive Liquid Effluent Monitoring Instrumentation (Attachment 1) shall be operable with their alarm/trip setpoints set to ensure that Step 6.2.1.a. limits are not exceeded.

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

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

• Promptly suspend release of radioactive liquid effluents monitored by the affected channel
• Declare the channel inoperable
• Change the setpoint to an acceptable, conservative value

b. Radioactive Liquid Effiuent Monitoring Instrumentation Operability Each radioactive liquid effluent monitoring instrumentation channel shall be

' :i demonstrated operable by performing.a Channel Check, Source Check, Channel Calibration, and Channel Functional Test at the frequencies shown in Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements (Attachment 2).

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

1) perform the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 19 PAGE 140F76

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

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

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

1. Maximum setpoint values shall be calculated by:

s (2) where: S = the setpoint, in µCi/mL, of the radioactivity monitor measuring the radioactivity concentration in the effluent line prior to dilution C = the effluent concentration limit for the monitor used to implement 10 CFR 20 for the Station (ACW in µCi/mL) for an isotopic mixture expected in the effluent FE = maximum design pathway effluent flow rate FD = dilution water flow rate calculated as: FE+ (200,000 gpm x number of circ. pumps in service)

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

s =c (3) The setpoint for Station monitors used to implement 10 CFR 20 for the site becomes the effluent concentration limit.

DOMINION VPAP-2103S REVISION 19 PAGE 15 OF76

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

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

s (4) where: Ksw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 for the Station, attributable to the service water effluent line pathway

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

s (5) where:. KRw = Allocation fraction of the effluent concentration limit, used to implement 10 CFR 20 attributable to the Radwaste Facility effluent line pathway

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

        .e. Bases - Radioactive Liquid Effiuent Monitoring Instrumentation The radioactive liquid effluent instrumentation is provided to monitor and control, a.s 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 ~ccordance with the methodology and parameters in the ODCM to ensure that the alarm/trip wiil occur prior to exceeding 10 times* the limits of 10 CPR 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 CPR Part 50.

DOMINION VPAP-2103S REVISION 19 PAGE 160F76 6.2.3 Liquid Effiuent Dose Limit

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

1. During any calendar quarter:

• Less than or equal to 1.5 mrem to the total body
• Less than *or equal to 5 mrem to the critical organ

2. During any calendar year:

• Less than or equal to 3 mrem to the total bod:y
• Less than or equal to 10 mrem to the critical organ

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

DOMINION VPAP-2103S REVISION 19 PAGE 17 OF76

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

Dose contributions shall be calculated for all radionuclides identified in liquid effluents released to unrestricted areas based on the equation: D = tFM'"'C*A* L.J 1 1 (6) where: Subscripts = i, refers to individual radionuclide D = the cumulative dose commitment to the total body or critical organ from the liquid effluents for the period t, in mrem t .- -* the period for which Ci and F are averaged for all liquid releases, in hours M = the mixing ratio (reciprocal of the dilution factor) at the point of exposure, dimensionless, 0.2 from Appendix 1 lA, Surry UFSAR F = the near field average dilution factor for Ci during any liquid effluent release; the ratio of the average undiluted liquid waste flow during release to the average flow from the site discharge structure to unrestricted areas Ci = the average concentration of radionuclide, i, in undiluted liquid effluent during the period t, from all liquid releases, in µCi/mL Ai = the site-related ingestion dose commitment factor to the total body or critical organ for a particular age group for each identified principal gamma and beta emitter in mrem/hr per µCi/mL (7)

DOMINION VPAP-2103S REVISION 19 PAGE 18 OF76 For example: 1.14 E+05 = 1 E+06 pCi/µCi x 1 E+03 mL/L I (8760 hr/yr), units conversion factor 21 = adult fish consumption, kg/yr, from NUREG-0133 5 = adult invertebrate consumption, kg/yr, from NUREG-0133 Bli = the salt water bioaccumulation factor for nuclide i, in invertebrates, pCi/kg per pCi/L BFi = the salt water bioaccumulation factor for nuclide i, in fish, pCi/kg per pCi/L DFi= the critical organ dose conversion factor for nuclide i, for adults, in mrem/pCi NOTE: The above parameters were obtained from R.G. 1.109, Rev. 1, LADTAP II and VCRL-50564, Rev. 1.

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

DOMINION VPAP-2103S REVISION 19 PAGE 19 OF76

e. Bases - Dose Due To Liquid Effiuents This control is provided to implement the requirements of Sections II.A, Ill.A, and IV.A of Appendix I to 10 CFR Part 50. The control implements the guides set forth in Section II.A. The ACTION statement provides the required operating flexibility and at the same time implements the guides set forth in Section IV .A of Appendix I to assure that the releases of radioactive material in liquid effluents to UNRESTRICTED AREAS will be kept "as low as is reasonably achievable." The dose calculation methodology and*parameters in the ODCM implement the requirements in Section Ill.A that conformance with the guides of Appendix I be shown by calculation procedures, such that the actual exposure of a MEMBER OF THE PUBLIC is unlikely to be substantially underestimated. The equations specified in the ODCM for calculating the doses due to the actual release rates of radioactive materials in liquid effluents are consistent with the methodology provided in Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977 and Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

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

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 19 PAGE200F76

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

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

                                       '

ino.:Perability.

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Total Body and Critical Organ Dose Calculation

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

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

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

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

Dp = (DL x P) + Da

d. Bases - Liquid Radwaste Treatment System The OPERABILITY of the Liquid Radwaste Treatment System ensures that this system will be available for use whenever liquid effluents require treatment prior to release to the environment. The requirement provides assurance that the releases of radioactive materials in liquid effluents will be kept "as low as is reasonably achievable." This control implements the requirements of 10 CFR 50.36a, General Design Criterion 60 of Appendix A to 10 CFR Part 50 and the design objective given in Section 11.D of Appendix I to 10 CFR Part 50. The specified limits governing the use of appropriate portions of the Liquid Radwaste Treatment System were specified as a suitable fraction of the dose design objectives set forth in Section II.A of Appendix I, 10 CFR Part 50 for liquid effluents.

DOMINION VPAP-2103S REVISION 19 PAGE21 OF76 6.2.5 Liquid Sampling Radioactive liquid wastes shall be sampled and analyzed according to the sampling and analysis requirements in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). _6.3 Gaseous Radioactive Waste Effluents 6.3.1 Gaseous Effluent Dose Rate Limitations

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

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

2. The dose rate limit for I 131 , I 133 , for tritium, and for all radioactive materials in particulate f9rm with half-lives greater than 8 days shall be~ 1500 mrem/year to the critical organ.

b. Action

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE220F76

c. Calculations of Gaseous Effluent Dose Rates

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

                                  . x                . x L     [ ( K. Qivv -Q.

l lVV

                                              ) + (K 1* Qipv -Q.lpV ) ] $ 500 mrem/yr to the total body .   (8)

OR

        '1                              . ) + ( (L 1* + 1.1 M. H2ipv !Q.. ) ] $

L..J [ (<L i + 1.1 M.l H2ivv !Q.lVV l lpV

• 3000 mrem/yr to the skin (9) where:

Subscripts = vv, refers to vent releases from the building ventilation vent, including Radwaste Facility Ventilation Vent; pv, refers to the vent releases from the process vent; i, refers to individual radionuclide Kl = the total body dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/m3 L*l = the skin dose factor due to beta emissions for each identified noble gas radionuclide i, in mrem/yr per Curie/m3 M*l = the air dose factor due to gamma emissions for each identified noble gas radionuclide, i, in mrad/yr per Curie/m3 Qivv, Qipv the release rate for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents in Curie/sec (per site) 1.1 the unit conversion factor that converts air dose to skin dose, in mrem/mrad X/Qivv, X/Qipv = the gaseous dispersion factor, sec/m3(See Attach.Inent 7)

DOMINION VPAP-2103S REVISION 19 PAGE23 OF76

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

                          . x             . x
               "'[P.Qivv      -Q. + P 1-Qipv-Q* ] S 1500 mrem/yrto the critical organ               (10)

L...i 1 IVY lpV where: p. I = the critical organ dose factor for I 131 , I 133 , H 3, and all radionuclides in particulate form with half-lives greater than 8 days, for the child inhalation pathway, in mrem/yr per Curie/m3

                 .    .

Qivv,Qipv = the release rat~ for ventilation vents or process vent of I 131 , I 133 , H3 , and all radionuclides i, in particulate form with half-lives greater than 8 days, in gaseous effluents in Curie/sec (per site) X/Qiw, X/Qipv = the gaseous dispersion factor, sec/m3 (See Attachment 7)

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

d. Bases - Dose Rate This specification provides reasonable assurance radioactive materials discharged in gaseous effluents will not result in the exposure of a MEMBER OF THE PUBLIC in an UNRESTRICTED AREA, either at or beyond the SITE BOUNDARY, in excess of the design objectives of Appendix I to 10 CFR Part 50.

This specification is provided to ensure that gaseous effluents from all units on the site will be appropriately controlled. It provides operational flexibility for releasing gaseous effluents to satisfy the Section II.A and Il.C design objectives of Appendix I to 10 CFR Part 50. The specified release rate limits restrict, at all times, the corresponding gamma and beta dose rates above background to a MEMBER OF THE PUBLIC at or beyond the SITE BOUNDARY to less than or equal to 500 mrem/year to the whole body, less than or equal to 3000 mrem/year to the skin and the corresponding thyroid dose rate above background to a child via the inhalation pathway to less than or equal to 1500 mrem/year. This specification does not affect the requirements to comply with the annual limitation of 10 CFR 20.1301(a). This control applies to the release of radioactive materials in gaseous effluents from all units at the site.

DOMINION VPAP-2103S REVISION 19 PAGE240F76 6.3.2 Gaseous Monitoring Instrumentation

a. Requirement

1. The radioactive gaseous effluent monitoring instrumentation channels shown in Radioactive Gaseous Effluent Monitoring Instrumentation (Attachment 5) shall be operable with alarm/trip setpoints set to ensure that Step 6.3.l.a. noble gas limits are not exceeded. Alarm/trip setpoints of these channels shall be determined and adjusted in accordance with Step 6.3.2.d.

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

b. Action

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

• Suspend the release of radioactive gaseous effluents monitored by the affected channel and declare the channel inoperable or
• Change the setpoint so it is acceptably conservative

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

take the action shown in those tables.

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

DOMINION VPAP-2103S REVISION 19 PAGE25 OF76

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

Release Point Instrument Number Process Vent 1-GW-RM-130B Condenser Air Ejector 1-SV-RM-111 2-SV-RM-211 Ventilation Vent No. 1 1-VG-RM-104 Ventilation Vent No. 2 1-VG-RM-131B Radwaste Facility Vent RRM-101

d. Setpoint Calculations

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

(11) where: D = Step 6.3 .1.a. dose limits that implement Technical Specifications for the Station, mrem/yr Dpv = the noble gas site boundary dose rate from process vent gaseous effluent releases, mrem/yr Dcae = the noble gas site boundary dose rate from condenser air ejector gaseous effluent releases, mrem/yr Dvv = the noble gas site boundary dose rate from summation of the Ventilation Vents 1, 2, and the Ra,dwaste Facility vent gaseous effluent releases, mrem/yr

DOMINION VPAP-2103S REVISION 19 PAGE260F76

2. Setpoint values shall be determined by:

Rm x 2.12 E-03 (12) Fm where: m = the release pathway, process vent (pv), ventilation vent (vv) condenser air ejector (cae), or Radwaste Facility (rv) cm = the effluent concentration limit implementing Step 6.3. l .a. for the Station, µCi/mL Rm = the release rate limit for pathway m determined from methodology in Step 6.3.1.c., typically using Xe 133 as nuclide to be released, µCi/sec 2.12E"""'03 = CFM per rnL/sec Fm = the maximum flow rate for pathway m, CFM NOTE: According to NUREG-0133, the radioactive effluent radiation monitor alarm/trip setpoints should be based on the radioactive noble gases. It is not practicable to apply instantaneous alarm/trip setpoints to integrating monitors sensitive to radioiodines, radioactive materials in particulate form, and radionuclides other than noble gases.

e. Bases - Radioactive Gaseous Effluent Monitoring Instrumentation The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of 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 gaseous effluent dose rate limits of Section 6.3 of the ODCM.

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

DOMINION VPAP-2103S REVISION 19 PAGE270F76 6.3.3 Noble Gas Effiuent Air Dose Limit

a. Requirement

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

• During any calendar quarter: :::; 5 mrads for gamma radiation and :::; 10 in.rad for beta radiation
• During any calendar year: :::; 10 mrads for gamma radiation and :::; 20 mrad for beta radiation

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

at least once per 31 days.

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

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

The air dose to areas at or beyond the site boundary due to noble gases shall be determined by the following: For gamma radiation: (13)

DOMINION VPAP-2103S REVISION 19 PAGE28 OF76 For beta radiation: (14) Where: Subscripts vv, refers to vent releases from the building ventilation vents, including the Radwaste Facility Ventilation Vent and air ejectors pv, refers to the vent releases from the process vent i, refers to individual radionuclide Dg the air dose for gamma radiation, in mrad Db the air dose for beta radiation, in mrad Mi the air dose factor due to gamma emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Ni the air dose factor due to beta emissions for each identified noble gas radionuclide i, in mrad/yr per Curie/m3 Qivv* Qipv the release for ventilation vents or process vent of noble gas radionuclide i, in gaseous effluents for 31 days, quarter, or year as appropriate in Curies (per site) 3 .17 E-08 the inverse of the number of seconds in a year X!Q;w, XIQ;pv = the gaseous dispersion factor, sec!m\See Attachment 7) 6.3.4 1-131, 133, H-3 & Radionuclides in Particulate Form Effiuent Dose Limit

a. Requirement

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

• During any calendar quarter: :::;; 7 .5 mrem to the critical organ
• During any calendar year: :::;; 15 mrem to the critical organ

2. Cumulative dose contributions to a member of the public from I 131 , I 133 ,

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

DOMINION VPAP-2103S REVISION 19 PAGE290F76

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

1. Causes for exceeding limits.

2. Corrective actions taken to reduce releases.

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE300F76

1. The dose to the maximum exposed member of the public, attributable to gaseous effluents at and beyond the site boundary that contain I 131 , 1133 , tritium, and particulate-form radionuclides with half-lives greater than 8 days, shall be determined by:

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

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

tritium, and from all particulate-form radionuclides with half-lives greater than 8 days in Curies 3.17 E-08 the inverse of the number of seconds in a year X!Qvv, X!Qpv = the gaseous dispersion factor, sec/m3 (See Attachment 7) DIQvv, D/Qpv = the gaseous deposition factor, m-2 (See Attachment 7) RM = the cow-milk pathway dose factor due to 1131 , 1133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m2 -mrern/yr per Ci/sec RI = the inhalation pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in mrern/yr per Ci/m3 RG = the ground plane pathway dose factor due to I 131 , I 133 , tritium, and from all particulate-form radionuclides with half-lives greater than eight days, in m 2*mrern/yr per Ci/sec RH3 = the tritium dose factor for milk in mrern/yr per Ci/m3

DOMINION VPAP-2103S REVISION 19 PAGE31 OF76 6.3.5 Gaseous Radwaste Treatment Historical data pertaining to the volumes and radioactive concentrations of gaseous effluents released in connection with specific Station functions, such as containment purges, shall be used to calculate projected doses, as appropriate.

a. Requirement

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

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

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

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

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

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

3. Summary description of actions taken to prevent recurrence.

c. Projected Dose Calculations

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

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

DOMINION VPAP-2103S REVISION 19 PAGE320F76

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

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

Dp = (Dg x P) + Da 6.4 Radioactive Liquid and Gaseous Release Permits RP shall maintain procedures for Liquid and Gaseous Release Permits to ensure effluent dose limits are not exceeded when making releases. As indicated on Attachment 3, Radioactive Liquid Waste Sampling and Analysis Program, prerelease assessments/permits are required for batch releases. Depending on the affected plant system, continuous releases may or may not allow for a prerelease assessment and are evaluated on a case by case basis. 6.4.1 Liquid Waste Batch Releases  ! I

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

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

batch releases include:

• Turbine Building Sumps when RP determines that source activity requires placing pumps in manual mode
• Condensate Polishing Building Sumps and Steam Generator secondary water when RP determines the presence of contamination from primary-to-secondary leakage
• Radwaste Facility release tanks (LWMT, LDMT) 6.4.2 Continuous Liquid Releases

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

b. Examples of continuous releases include:

• Steam generator blowdown
• Component Cooling Water (CCW) heat exchanger to service water leakage, if applicable
• Storm drains, equipped with composite sampling systems, that receive run-off from rain and turbine building sumps, subsurface drains and ground water wells when pumps are in automatic mode.

DOMINION VPAP-2103S REVISION 19 PAGE33 OF76 6.4.3 Waste Gas Decay Tank (WGDT) Release Permit Operations shall obtain RP authorization before initiating WGDT releases. 6.4.4 Reactor Containment Release Permits Operations shall obtain authorization from RP before initiating containment purges or containment hogging. Reactor Containment Release Permits shall be valid from start of purge/hog until:

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

6.4.6 Radioactive Liquid and Gaseous Release Controls

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

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

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

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

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

3. RP shall obtain gaseous samples.

c. RP shall perform required sample analyses.

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

• Maximum authorized release rate
• Applicable conditions or controls pertaining to the release

DOMINION VPAP-2103S REVISION 19 PAGE340F76

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

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

1. Verify the correct source is authorized for release.

2. Note maximum authorized release rate.

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

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

As appropriate, required information shall include:

• Date and time release was started
• Starting tank/sump level
• Beginning pressure
• Release flow rate
• Dilution water flow rate

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

• Date and time release was stopped
• Tank/sump ending level
• Release flow rate just prior to termination
• Ending pressure
• Volume released 6.5 Total Dose Limit to Public From Uranium Fuel Cycle Sources 6.5.1 Requirement The annual (calendar year) dose or dose commitment to a real individual due to releases of radioactivity and radiation from uranium fuel cycle sources shall not exceed 25 mrem to the total body or the critical organ (except the thyroid, which shall not exceed 75 mrem).

DOMINION VPAP-2103S REVISION 19 PAGE35 OF76 6.5.2 Action

a. If the calculated doses from release of radioactive materials in liquid or gaseous effluents exceed twice the limits in Steps 6.2.3.a., 6.3.3.a., or 6.3.4.a., calculate (including direct radiation contribution from the units and from outside storage tanks) whether limits in Step 6.5.1 have been exceeded.

b. If the limits in Step 6.5.1 have been exceeded, prepare and submit to the NRC, within 30 days, a special report in accordance with VP AP-2802, Notifications and Reports, that defines the corrective action to be taken to reduce subsequent releases and to prevent recurrence, and includes a schedule for achieving conformance with the limits. Special reports, as defined in 10 CFR 20.2203(a)(4), shall include:

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

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

3. If the estimated dose exceeds the limits in Step 6.5.1, and if the release condition that violates 40 CFR 190 has not already been corrected, the special report shall include a request for a variance in accordance with the provisions of 40 CFR 190. Submittal of the report is considered a timely request, and a variance is granted until staff action on the request is complete.

6.6 Radiological Environmental Monitoring 6.6.1 Monitoring Program

a. Requirement

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

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

DOMINION VPAP-2103S REVISION 19 PAGE360F76

3. Samples shall be analyzed in accordance with:

• Radiological Environmental Monitoring Program (Attachment 8) requirements
• Detection capabilities required by Detection Capabilities for Environmental Sample Analysis (Attachment 10)
• Guidance of the Radiological Assessment Branch Technical Positio!1 on Environmental Monitoring dated November, 1979, Revision No. 1

b. Action

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

2. If, when averaged over any calendar quarter, radioactivity exceeds the reporting levels of Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11), prepare and submit to the NRC, within 30 days, a special report in accordance with VP AP-2802, Notifications and Reports, that:

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

concentration (1) + concentration (2) + ... :;::: 1.0 (lS) reporting level (1) reporting level (2)

DOMINION VPAP-2103S REVISION 19 PAGE 37 OF76

3. When radionuclides other than those listed in Reporting Levels for Radioactivity Concentrations in Environmental Samples (Attachment 11) are detected and are the result of plant effluents, the report shall be submitted if the potential annual dose to a member of the public is equal to or greater than the calendar year limits of Steps 6.2.3, 6.3.3, and 6.3.4. The report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, report and describe the condition in the Annual Radiological Environmental Operating Report in accordance with VPAP-2802, Notifications and Reports.

4. If milk or fresh leafy vegetable samples are µnavailable from one or more of th~

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

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

DOMINION VPAP-2103S REVISION 19 PAGE38 OF76 6.6.2 Land Use Census

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

• Nearest milk animal
• Nearest residence
• Nearest garden greater than 50 m2 (500 ft2) that produces broad leaf vegetation

1. The land use census shall be conducted during the growing season, at least once per 12 months, using methods that will provide the best results (e.g.,

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

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

b. Action

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE390F76 6.6.3 Interlaboratory Comparison Program

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

b. Action

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

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

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

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

6.7 Reporting Requirements

6. 7.1 Annual Radiological Environmental Operating Report Routine Radiological Environmental Operating Reports covering the operation of the units during the previous calendar year shall be submitted prior to May 1 of each year.

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

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

• A comparison (as appropriate) with preoperational studies, operational controls, and previous environmental surveillance reports
• An assessment of the observed impacts of the plant operation on the environment
• Results of land use census per Step 6.6.2

DOMINION VPAP-2103S REVISION 19 PAGE400F76

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

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

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

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

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

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

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE41 OF76 NOTE: NUREG-0543 states: "There is reasonable assurance that sites with up to four operating reactors that have releases within Appendix I design objective values are also in conformance with the EPA Uranium Fuel Cycle Standard, 40 CPR Part 190." 6.7.2 Annual Radioactive Effluent Release Report

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

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

Data shall be summarized on an annual basis following the format of Regulatory Guide 1.21, Appendix B, for solid waste. [Commitment 3.2.2]

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

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

• Unplanned releases that exceeded the limits in Steps 6.2.l and 6.3.1
• Unplanned releases which require a Condition Report and involve the discharge of contents of the wrong Waste Gas Decay Tank or the wrong liquid radwaste release tank
• Unplanned releases from large leaks due to unexpected valve or pipe failures that result in a quantity of release such that a 10 CPR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors or 10 CPR 50.73, Licensee Event Report System, report is required
• Unplanned releases as determined by Radiation Protection Supervision, which may or may not require a Condition Report

DOMINION VPAP-2103S REVISION 19 PAGE420F76

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

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

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

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

• An unintended spill or leak with the potential to reach groundwater, as defined in NEI 07-07, *and
• The spill or leak must be greater than 100 gallons in volume or the volume
• cannot be quantified but is estimated to be greater than 100 gallons; or
• Any spill or leak, regardless of volume or activity deemed by the licensee to be reportable.

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

b. Dose Assessment - Station

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

Population doses shall not be included in dose assessments.

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

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

DOMINION VPAP-2103S REVISION 19 PAGE43 OF76 NOTE: The Annual Radioactive Effluent Release Reports for Surry Station and Surry ISFSI are separate and not submitted as a combined report.

c. Requirement - ISFSI

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

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

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

6.7.3 Annual Meteorological Data

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

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

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

a. Approved by the Site Vice President before implementation.

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

Documentation shall include:

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

DOMINION VPAP-2103S REVISION 19 PAGE440P76

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

• 10 CPR 20, Subpart D
• 40 CPR 190
• 10 CPR 50.36a
• 10 CPR 50, Appendix I
• Technical Specifications

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

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

6.7.5 Industry Ground Water Protection Initiative

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

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

b. Communications

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

DOMINION VPAP-2103S REVISION 19 PAGE45 OF76

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

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

c. 30-Day Reports

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

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

d. Annual Reports*

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

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE460F76 7.0 RECORDS 7.1 The following record(s) completed as a result ofthis procedure are required to be transmitted to Nuclear Document Management (NDM). The records have been identified and retention requirements established for the Nuclear Records Retention Schedule (NRRS) per RM-AA-101, Record Creation, Transmittal, and Retrieval.

7. l. l Quality Assurance Records

• Records of changes to the ODCM in accordance with Step 6.7.4
• Records of meteorological data in accordance with Step 6.7 .3
• Records ?f sampling and analyses
• Records of radioactive materials and other effluents released to the environment
• Records of preventive maintenance, surveillances, and calibrations 7.1.2 Non-Quality Assurance Records None 7.2 The following record(s) completed as a result of this procedure are NOT required to be transmitted to Nuclear Document Management (NDM), but are required to be retained as indicated below. The NRRS has been updated and Alternate Storage approved per RM-AA-101 for Quality Assurance Records.

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

DOMINION VPAP-2103S REVISION 19 PAGE47 OF76 ATTACHMENT 1 (Page 1of1) Radioactive Liquid Effiuent Monitoring Instrumentation Instrument Minimum Action Operable Channels

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

2. GROSS BETA OR GAMMA RADIOACTIVITY MONITORS PROVIDING ALARM BUT NOT PROVIDING AUTOMATIC TERMINATION OF RELEASE (a) Circulating Water Discharge Liries, Unit 1: 1-SW-RM-120 1

                                                                                          . 2 Unit 2: 2-SW-RM-220                                               1                   2 (b) Component Cooling Service Water Effluent Lines, 1-SW-RM-107A                                                                                '

1 2 1-SW-RM-107B 1 2 1-SW-RM-107C 1 2 1-SW-RM-107D 1 2

3. FLOW RATE MEASUREMENT DEVICES (a) Radwaste Facility Liquid Effluent Line, Instrument Loop RLW-153 1 3 ACTION 1: If the number of op*erable channels is less than required, effluent releases via this pathway shall be suspended.

ACTION 2: If the number *of operable channels is less than required, effluent releases via this pathway may continue provided that, at least once per 12 hours, grab samples are collected and analyzed for principal gamma emitters, as defined in Radioactive Liquid Waste Sampling and Analysis Program (Attachment 3). When the effluent release via thls pathway continues, then initiate the "Loss of Radioactive Liquid Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.021, Radioactive Liquid Waste Sampling and Analysis. ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 30 minutes during the actual releases. Design capacity pump performance curves generated in place or volume released over time may be used to estimate flow.

DOMINION VPAP-2103S REVISION 19 PAGE48 OF76 ATTACHMENT 2 (Page 1 of 1) Radioactive Liquid Effluent Monitoring Instrumentation Surveillance Requirements Channel Description Channel Source Channel Channel Check Check Calibration !Functional TesJ

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

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

NATION OF RELEASE (a) Circulating Water Discharge Lines, Unit 1: 1-SW-RM-120 D M R Q Unit 2: 2-SW-RM-220 (b) Component Cooling Service Water Effluent Lines, l-SW-RM-107A l-SW-RM-107B D M R Q l-SW-RM-107C 1-SW-RM-107D

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

DOMINION VPAP-2103S REVISION 19 PAGE49 OF76 ATTACHMENT3 (Page 1of3) Radioactive Liquid Waste Sampling and Analysis Program Lower Limit of Liquid Release Sampling Minimum Analysis Type of Activity Detection (LLD) Type Frequency Frequency Analysis (µCi/mL), (Note 1) p p Principal Gamma 5 x 10-7 Emitters (Note 3) I (Each Batch) (Each Batch) 1131 Dissolved and 1x10-6 p Batch Releases- M Entrained Gases 1x10-5 (One Batch/M) (Gamma Emitters) (Note 2) p M Composite H3 1x10-5 (Each Batch) (Note 4) Gross Alpha 1x10-7 p Q Composite Sr89 and Sr90 5 x 10-8 (Each Batch) (Note 4) Fe55 1x10-6 Principal Gamma 5 x 10-7 Continuous WComposite Emitters (Note 6) (Note 6) (Note 6) 1131 1x10-6 Dissolved and Continuous M 1x10-5 M Entrained Gases Releases Grab Sample (Gamma Emitters) (Note 5) Continuous MComposite H3 1x10-5 (Note 6) (Note 6) Gross Alpha 1x10-7 Continuous Q Composite Sr89 and Sr90 5 x 10-8 (Note 6) (Note 6) Fe55 1x10-6

DOMINION VPAP-2103S REVISION 19 PAGE500F76 ATTACHMENT 3 (Page 2 of 3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 Sb LLD (8-1) E

• V
• 2.22E+06
• Y
• e-CA-~t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = .the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie Y = the fractional radiochemical yield (when applicable) A, the radioactive decay constant for the particular radionuclide

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

The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement. NOTE 2: A batch release is the discharge of liquid wastes of a discrete volume. Before sampling for analyses, each batch shall be isolated, and appropriate methods will be used to obtain a representative sample for analysis.

DOMINION VPAP-2103S REVISION 19 PAGE51 OF76 ATTACHMENT 3 (Page 3 of3) Radioactive Liquid Waste Sampling and Analysis Program NOTE 3: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Mn54, Fe59 , Co58 , Co60 , Zn65 , Mo99 , Cs 134, Cs 137 , Ce 141 , and Ce 144 . This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, at levels exceeding the LLD, together with the above nuclides, shall also be identified and reported. I NOTE 4: A composite sample is one in which the quantity of liquid sampled is proportional to the quantity of liquid waste discharged and for which the method of sampling employed results in a specimen that is representative of the liquids released. NOTE 5: A continuous release is the discharge of liquid wastes of a non-discrete volume, e.g., from a volume of a system that has an input flow during the continuous release. NOTE 6: To be representative of the quantities and concentrations of radioactive materials in liquid effluents, composite sampling shall employ appropriate methods which will result in a specimen representative of the effluent release.

DOMINION VPAP-2103S REVISION 19 PAGE 520F76 ATTACHMENT 4 (Page 1of4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCjjmL), (Note 1) Prior to Release A. Waste Gas Prior to Release Principal Gamma (Each Tanlc) 1x10-4 Storage Tank (Each Tanlc) Emitters (Note 2) (Grab Sample) Principal Gamma Prior to Release Prior to Release 1x10-4 B. Containment Emitters (Note 2) (Each PURGE) Purge (Each PURGE) H3 1x10-6 (Grab Sample) C. Ventilation Weekly Principal Gamma Weekly 1x10-4 (l)Process Vent (Grab Sample) Emitters (Note 2) (2)Vent Vent #1 (3)Vent Vent #2 (Note 3) (Note 3) H3 1x10-6 (4)SRFVent I 131 1x10- 12 Continuous Weekly (Note 5) (Note 4) (Charcoal Sample) Il33 1x10- 10 Continuous Weekly (Note 5) Principal Gamma 1x10- 11 All Release (Note 4) Particulate Sample Emitter (Note 2) Weekly Continuous Types as listed Composite Gross Alpha 1x10- 11 (Note 4) Particulate Sample in A, B, and C (..!uarterly Continuous Composite Sr89 and Sr90 1x10- 11 (Note 4) Particulate Continuous Noble Gas Monitor Noble Gases Gross 1x10-6 (Note 4) Beta and Gamma Principal Gamma Weekly Weekly 1x10-4 Condenser Air Emitters (Note 2) Grab Sample Ejector (Note 3) H3 1x10-6 (Note 3)

DOMINION VPAP-2103S REVISION 19 PAGE53 OF76 ATTACHMENT 4 (Page 2 of 4) Radioactive Gaseous Waste Sampling and Analysis Program Gaseous Release Sampling Minimum Analysis Type of Activity Lower Limit of Type Frequency Frequency Analysis Detection (LLD) (µCi/mL), (Note 1) Principal Gamma Prior to Release Prior to Release 1x104 Emitters I (Grab Sample) (Each Release) H3 1x10-6 1131 1 x 10- 11 Continuous Charcoal Sample (Note 4) (Note 6) 1133 1x10- 10 Containment Continuous Particulate Sample Principal Gamma HogDepres- 1x10- 10 (Note 4) (Note 6) Emitter (Note 2) surization Composite Particu-Continuous late Sample Gross Alpha 1x10- 10 (Note 4) (Note 6) Composite Particu-

         *-*-         Continuous late Sample       Sr89 and Sr90       1x10- 10 (Note 4)

(Note 6)

DOMINION VPAP-2103S REVISION 19 PAGE540F76 ATTACHMENT 4 (Page 3 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 1: For a particular measurement system (which may include radiochemical separation): LLD (10-1) E

• V
• 2.22E+06
• Y
• e-CA..1.t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9). Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm). E = the counting efficiency (as counts per disintegration). V = the sample size (in units of mass or volume). 2.22E+06 = the number of disintegrations per minute (dpm) per microcurie. Y = the fractional radiochemical yield (when applicable). A, the radioactive decay constant for the particular radionuclide.

         '1.t        =   the elapsed time between the midpoint of sample collection and time of counting.

Typical values of E, V, Y and .M should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement_.

DOMINION: VPAP-2103S REVISION 19 PAGE55 OF76 ATTACHMENT 4 (Page 4 of 4) Radioactive Gaseous Waste Sampling and Analysis Program NOTE 2: The principal gamma emitters for which the LLD specification applies exclusively are the following radionuclides: Kr87 , Kr88 , Xe 133 , Xe 133 m, Xe 135 , Xe 135 m, andXe 138 for gaseous emissions and Mn54 , Fe59 , Co58 , Co60 , Zn65 , Mo99 , Cs 134, Cs 137 , Ce 141 and Ce 144 for particulate emissions. This list does not mean that only these nuclides are to be detected and reported. Other nuclides with half lives greater than 8 days, that are measurable and identifiable at levels exceeding the LLD, together with the above nuclides, shall also be I identified and reported. NOTE 3: Sampling and analysis shall also be performed following shutdown, start-up, and whenever a thermal power change exceeding 15 percent of the rated thermal power occurs within any one-hour period, when:

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

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

NOTE 4: The ratio of the sample flow rate to the sampled stream flow rate shall be known for the period covered by each dose or dose rate calculation made in accordance with Steps 6.3.1, 6.3.3, and 6.3.4. NOTE 5: Samples shall be changed at least once per seven days and analyses.shall be completed within 48 hours after changing (or after removal from sampler). Sampling shall also be performed at least once per 24 hours for at least seven days following each shutdown, start-up, or thermal power change exceeding 15 percent of rated thermal power in one hour, and analyses shall be completed within 48 hours of changing. When samples collected for 24 hours are analyzed, the corresponding LLDs may be increased by a factor of 10. This requirement applies if:

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

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

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

DOMINION VPAP-2103S REVISION 19 PAGE560F76 ATTACHMENT 5 (Page 1of2) Radioactive Gaseous Effiuent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS

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

1-GW-RM-130B 1 1 (b) Iodine Sampler: Continuous HP Sampler, or 1--GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (c) Particulate Sampler: Continuous HP Sampler, or 1-GW-RM-130-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor: 1-GW-Ff-100 1 3 (e) Sampler Flow Rate Measuring Device: HP Sampler Rotometer or. MGPI Flow Rate Measuring 1 3 Device

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

1-SV-RM-111 1 1 2-SV-RM-211 1 1 (b) Air Ejector Flow Rate Measuring Device: Unit 1: 1-VP-FI-lA 1 3 1-VP-FI-lB 1 3 Unit 2: 2-VP-FI-lA 1 3 2-VP-FI-lB 1. 3

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

SRF: RRM-101 1 1 SPS: Vent#l, 1-VG-RM-104 1 1 Vent#2, l-VG-RM-131B 1 1 (b) Iodine Sampler: SRF: RRM-101 1 2 SPS: Vent #1, l-VG-RM-104 (NOTE 2) 1 2 Vent #2, Continuous HP Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 In-Line Particulate I Iodine Sampler

DOMINION VPAP-2103S REVISION 19 PAGE57 OF76 ATTACHMENT 5 (Page 2of2) Radioactive Gaseous Effiuent Monitoring Instrumentation MINIMUM INSTRUMENT OPERABLE ACTION CHANNELS (c) Particulate Sampler: SRF: RRM-101 1 2 SPS: Vent#l, VG-RM-104 (NOTE 2) 1 2 Vent #2, HP Continuous Sampler, or 1-VG-RM-131-1(NOTE1) 1 2 I In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor: SRF: 01-RHV-FT-156 1 3 SPS: Vent#l, 1-VS-FT-119 1 3 Vent #2, 1-VS-FT-116 1 3 (e) Sampler Flow Rate Measuring Device: SRF: RRM-101 1 3 SPS: Vent #1, 1-VG-RM-104 (NOTE 2) 1 3 Vent #2, HP Sampler Rotometer or 1 3 MGPI Flow Rate Measuring Device NOTE 1: The mark number listed refers to the entire radiation monitor skid which includes particulate, iodine, and noble gas components. NOTE 2: Vent# 1, l-VG-RM-104, HP continuous sampler pump automatically maintains isokinetic sample flow when changes in stack flow are detected. Isokinetic sample flow adjustment can take 15 - 20 minutes. [Commitment 3.23] ACTION 1: If the number of operable channels is less than required, effluent releases via this path may continue provided that the best efforts are made to repair the channel and that grab samples are taken at least once per 12 hours and these samples are analyzed for gross activity within 24 hours. When the effluent release via this pathway continues, then initiate the "Loss of Radioactive Gaseous Effluent Monitoring Instrumentation Sampling Schedule" attachment in HP-3010.031, Radioactive Gaseous Waste Sampling and Analysis. [Commitment 3.2.4] ACTION2: If the number of operable channels is less than required, effluent releases via this pathway may continue provided that the best efforts are made to repair the channel and that the samples are continuously collected with auxiliary sampling equipment within 12 hours after the initiation ofthis ACTION statement as required in Radioactive Gaseous Waste Sampling and Analysis Program (Attachment 4). [Commitment 3.2.4] ACTION 3: If the number of operable channels is less than required, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours.

DOMINION VPAP-2103S REVISION 19 PAGE58 OF76 ATTACHMENT 6 (Page 1of2) Radioactive Gaseous Effiuent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL CHANNEL SOURCE CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST

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

Providing Alarm and Automatic Termination of Release 1-GW-RM-130B D M R Q (b) Iodine Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) Process Vent Continuous HP Sampler, or 1-GW-RM-130-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Process Vent Flow Rate Monitor 1-GW-Ff-100 D NIA R NIA (e) Sampler Flow Rate Measuring Device HP Sampler Rotometer, or D NIA SA NIA MGPI Flow Rate Measuring Device D NIA R NIA

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

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

DOMINION VPAP-2103S REVISION 19 PAGE590F76 ATTACHMENT 6 (Page 2of2) Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements CHANNEL CHANNEL SOURCE CHANNEL CHANNEL FUNCTIONAL DESCRIPTION CHECK CHECK CALIBRATION TEST (b) Iodine Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA I In-Line Particulate I Iodine Sampler (c) Particulate Sampler (NOTE 1) SRF: RRM-101 SPS: Vent#l, 1-VG-RM-104 Vent #2, Continuous HP Sampler or 1-VG-RM-131-1 w NIA NIA NIA In-Line Particulate I Iodine Sampler (d) Ventilation Vent Flow Rate Monitor SRF:Ol-RHV-FT-156 SPS: Vent #1, 1-VS-FT-119 Vent#2, 1-VS-FT-116 D NIA R NIA (e) Sampler Flow Rate Measuring Device (NOTE 1) SRF: RRM-101 D NIA R NIA SPS: Vent#l, 1-VG-RM-104 D NIA R NIA Vent #2, HP Sampler Rotomete1 D NIA R NIA or MGPI Flow Rate Measuring Device b NIA SA NIA NOTE l:The marknumbers listed above in l(b), l(c), 3(b), 3(c), and 3(e) refer to the gaseous effluent radiation monitor or monitor skid with which the iodine and particulate samplers and the flow rate measuring devices are associated. The listed mark numbers do not refer to the particulate radiation monitor. I

DOMINION VPAP-2103S REVISION 19 PAGE600F76 ATTACHMENT 7 (Page 1 of 1) Dispersion and Deposition Factors Distance, Ventilation Vent Process Vent Description Sector meters X!Q DIQ X!Q D!Q N 500 l.4E-05 J.6E-08 4.2E-08 3.9E-10 NNE 532 l.8E-05 3.3E-08 l.2E-07 l.2E-09 NE 629 l.3E-05 3.0E-08 l.8E-07 l.6E-09 ENE 806 7.lE-06 l.3E-08 l.8E-07 l.8E-09 E 1210 2.7E-06 7.2E-09 2.6E-07 l.8E-09 ESE 1984 9.8E-07 3.2E-09 2.4E-07 l.7E-09 SE 1371 2.2E-06 6.8E-09 2.6E-07 2.lE-09 SSE 919 4.3E-06 9.2E-09 2.3E-07 l.2E-09 Site Boundary s 645 5.9E-06 l.lE-08 1.7E-07 l.3E-09 SSW 565 6.3E-06 l.2E-08 l.3E-07 l.4E-09 SW 548 9.7E-06 l.9E-08 l.3E-07 l.3E-09 WSW 656 8.4E-06 1.6E-08 l.4E-07 l.3E-09 w 565 l.2E-05 2.9E-08 l.2E-07 l.OE-09 WNW 565 l.4E-05 2.6E-08 8.7E-08 5.8E-10 NW 581 l.3E-05 1.7E-08 l.2E-07 8.9E-10 NNW 581 9.SE-06 l.lE-08 5.lE-08 3.lE-10 N 6534 2.4E-07 2.lE-10 6.7E-08 8.8E-11 NNE 3122 l.OE-06 1.7E-09 l.9E-07 3.7E-10 NE 7564 2.7E-07 4.2E-10 6.7E-08 l.8E-10 SE 4554 3.4E-07 8.6E-10 8.7E-08 2.7E-10 SSE 4265 3.7E-07 6.6E-10 9.5E-08 2.5E-10 s 2736 5.SE-07 9.SE-10 l.9E-07 5.7E-10 Resident SSW 2977 . 4.lE-07 7.4E-10 l.4E-07 4.5E-10 SW 3637 4.SE-07 7.7E-10 l.2E-07

• 3.4E-10 WSW 660 6.4E-06 l.3E-08 l.8E-07 l.3E-09 w 5053 3.4E-07 7.lE-10 8.lE-08 2.lE-10 WNW 7886 2.2E-07 2.9E-10 4.9E-08 9.4E-11 NW 7467 2.2E-07 2.2E-10 5.8E-08 l.3E-10 NNW 6035 2.3E-07 2.0E-10 6.2E-08 7.lE-11 SSW 7693 9.9E-08 1.4E-10 5.0E-08 l.2E-10 Milk Cow NNW 5938 2.4E-07 2.lE-10 6.3E-08 7.lE-11 SSE 4265 3.7E-07 6.6E-10 9.5E-08 2.5E-10 s 3235 4.2E-07 7.lE~lO l.6E-07 4.3E-10 SSW 3122 3.8E-07 6.8E-10 l.3E-07 4.lE-10 Garden SW 7596 l.5E-07 2.lE-10 5.3E-08 l.2E-10 WSW 5713 2.0E-07 3.2E-10 7.5E-08 l.8E-10 w 5536 3.0E-07 6.0E-10 7.5E-08 l.8E-10 NNW 7017 l.9E-07 1.6E-10 5.3E-08 7.4E-11

DOMINION VPAP-2103S REVISION 19 PAGE 61 OF76 ATTACHMENT 8 (Page 1of3) Radiological Environmental Monitoring Program Exposure *Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

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

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

2) Outer Ring 6 to 8 km from the site with a station in Quarterly Quarterly each sector (NOTE 1)

3) The balance of the 8 dosimeters should be placed in special interest areas such as population centers, nearby residents, schools, and in 2 or 3 areas to serve as controls

2. AIRBORNE Samples from 7 locations:

a) 1 sample from close to the site boundary location of the highest calculated Radioiodine Canister annual average ground 1131 Analysis Weekly level Continuous Radioiodines and D/Q Sampler Particulates b) 5 sample locations 6-8 km operation with Particulate Sampler distance located in a sample collection Gross beta radioactivity concentric ring around the weekly analysis following filter Station change; c) 1 sample from a control Gamma isotopic analysis of location 15-30 km distant, composite (by providing valid location) quarterly background data NOTE 1: As described in the Branch Technical Position, Revision 1, November 1979, no TLD station is required in the SE sector at the 4-5 mile range due to geographical limitations.

DOMINION VPAP-2103S REVISION 19 PAGE620F76 ATTACHMENT 8 (Page 2 of 3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

3. WATERBORNE Gamma isotopic analysis a) 1 sample upstream monthly; a) Surface Monthly Sample b) 1 sample downstream Composite for tritium analysis quarterly Gamma isotopic and tritium b) Ground Sample from 1or2 sources Quarterly analysis quarterly c) Sediment from a) 1 sample upstream Gamma isotopic analysis Semi-Annually shoreline b) 1 sample downstream semi-annually a) 1 sample upstream Gamma isotopic analysis d) Silt Semi-Annually b) 1 sample downstream semi-annually

4. INGESTION a) Milk a) 2 samples from milking animals in the vicinity of the Station. (NOTE 1) Gamma isotopic and r131 b) 1 sample from milking Monthly animals at a control analysis monthly location (-15-30 km distant). (NOTE 2) a) 6 samples of filter feeders (clams, oysters) in the Semi-Annually b) Fish and vicinity of the Station Gamma isotopic on edible Invertebrates c) 1 sampling of crabs from Annually portions the vicinity of the Station d) 1 sampling of 2 different species in vicinity of Semi-Annually Station discharge area.

(NOTE3) NOTE 1: If milk sampling cannot be performed, use item 4.c, Food Products - d. Milk sampling cannot be performed when there are no milk sampling locations in the vicinity of the Station. NOTE2: If milk sampling from a control location cannot be performed, use item 4.c) e). Milk sampling cannot be performed when there is no milk sampling location 30 km distant. NOTE3: Commercially or recreationally important species permitted for sampling by the Virginia Marine Resources Commission include catfish, white perch, croaker, striped bass, spot, red drum, and striped mullet.

DOMINION VPAP-2103S REVISION 19 PAGE 63 OF76 ATTACHMENT 8 (Page 3of3) Radiological Environmental Monitoring Program Exposure Pathway Number of Sample and Collection Type and Frequency of and/or Sample Sample Location Frequency Analysis

4. INGESTION (Continued)

I a) 1 sample com b) 1 sample soybeans Annually Gamma isotopic on edible portions c) 1 sample peanuts d) 1 sample of a broadleaf vegetation grown

i. nearest in each of two different available offsite locations (sectors) with the c) Food Products highest annual average ground level D/Qs, if Monthly, if.

Gamma isotopic and 1131 milk sampling is not available, or at analysis performed. harvest e) 1 sample of a broadleaf vegetation grown 15 - 30 km distant in the available least prevalent wind directio.n, if milk sampling is not performed.

DOMINION VPAP-2103S REVISION 19 PAGE640F76 ATTACHMENT9 * (Page 1of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Air Charcoal and Surry Station (SS) 0.3 NNE Particulate Hog Island Reserve (HIR) 2.0 NNE Bacon's Castle (BC) 4.5 SSW Alliance (ALL) 5.1 WSW Colonial Parkway (CP) 3.8 NNW BASF (BASF) 5.1 ENE Fort Eustis (FE) 4.9 ESE Newport News (NN) 19.3 SE Control Location Environmental Control (00) Onsite

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

North North West (04) 0.2 NNW Site Boundary North (05) 0.3 N Site Boundary North North East (06) 0.3 NNE Site Boundary North East (07) 0.3 NE Site Boundary East North East (08) 0.4 ENE Site Boundary East (09) 0.3 E Site Boundary West (10) 0.1 w Site Boundary West South West (11) 0.4 WSW Site Boundary South West (12) 0.3 SW Site Boundary South South West (13) 0.3 SSW Site Boundary South (14) 0.4 s Site Boundary South South East (15) 0.6 SSE Site Boundary South East (16) 0.9 SE Site Boundary Station Intake (18) L6 ESE Site Boundary Hog Island Reserve (19) 2.0 NNE Near Resident

DOMINION VPAP-2103S REVISION 19 PAGE65 OF76 ATTACHMENT 9 (Page 2of3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Environmental Bacon's Castle (20) 4.5 SSW Approx. 5 miles TLDs Route 633 (21) 4.9 SW Approx. 5 miles Alliance (22) 5.1 WSW Approx. 5 miles I Surry Route 636 and 637 (23) (24) 7.7 4.0 WSW w Population Center Approx. 5 miles Scotland Wharf (25) 5.0 WNW Approx. 5 miles Jamestown (26) 6.3 NW Approx. 5 miles Colonial Parkway (27) 3.8 NNW Approx. 5 miles Route 617 and 618 (28) 4.9 NNW Approx. 5 miles Kingsmill (29) 4.6 N Approx. 5 miles Williamsburg (30) 7.8 N Population Center Kingsmill North (31) 5.5 NNE Approx. 5 miles Budweiser (32) 5.8 NNE Population Center Water Plant (33) 5.0 NE Approx. 5 miles BASF (34) 5.1 ENE Approx. 5 miles Lee Hall (35) 7.1 ENE Population Center Goose Island (36) 5.1 E Approx. 5 miles Fort Eustis (37) 4.9 ESE Approx. 5 miles Newport News (38) 19.3 SE Population Center James River Bridge (39) 17.1 SE Control Benn's Church (40) 17.0 SSE Control Smithfield (41) 13.4 SSE Control Rushmere (42) 5.3 SSE Approx. 5 miles Route 628 (43) 5.1 s Approx. 5 miles Milk Epps 4.8 SSW Colonial Parkway 3.7 NNW Williams 27.5 s Control Location I

DOMINION VPAP-2103S REVISION 19 PAGE 66 OF76 ATTACHMENT 9 (Page 3 of 3) Environmental Sampling Locations SAMPLE LOCATION DISTANCE DIRECTION REMARKS MEDIA (MILES) Well Water Surry Station Onsite** Hog Island Reserve 2.0 NNE Construction Site 0.3 E Onsite*** Crops (Com, Slade's Farm 3.2 s Peanuts, Soybeans) Brock's Farm 3.8 s River Water Surry Discharge 0.4 NW (Monthly) Scotland Wharf 4.9 WNW Control Location Sediment Chickahominy River 11.2 WNW Control Location (Silt) Surry Station Discharge 1.3 NNW Clams Chickahominy River 11.2 WNW Control Location Surry Station Discharge 1.3 NNW Jamestown Island 3.9 NW Oysters Point of Shoals 6.4 SSE Mulberry Point 4.9 ESE Lawne's Creek 2.4 SE Crabs Surry Station Discharge 1.3 NNW Fish Surry Station Discharge 1.3 NNW Shoreline Hog Island Reserve 0.6 N Sediment Chickahominy River 11.2 WNW Control Location

• Onsite Location - in Lead Shield
  • Onsite sample of Well Water taken from tap-water at Surry Environmental Building
    • Onsite sample of Well Water taken from tap-water at Surry Training Center

DOMINION VPAP-2103S REVISION 19 PAGE 67 OF76 ATTACHMENT 10 (Page 1of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) Analysis Water Airborne Fish Milk Food Sediment (NOTE2) (pCi/L) Particulate (pCi/kg) (pCi/L) Products (pCi/kg) or Gases (wet) (pCi/kg) (dry)

                                  .(pCifm3)                                      (wet)

Gross beta 4 0.01 I H-3 2,000 Mn-54 15 130 Fe-59 30 260 Co-58, 60 15 130 Zn-65 30 260 Zr-95 30 Nb-95 15 I-131 (NOTE3) 1. 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-140 60 60 La-140 15 15 NOTE 1: Required detection capabilities for thermoluminescent dosimeters used for environmental measurements are given in Regulatory Guide 4.13. NOTE 2: This list does not mean that only these nuclides are to be detected and reported. Other peaks that are measurable and identifiable, together with the above nuclides, shall also be identified and reported. NOTE 3: LLD for the ground (drinking) water samples. The LLD for the surface (non-drinking) water samples is 10 pCi/L.

DOMINION VPAP-2103S REVISION 19 PAGE68 OF76 ATTACHMENT 10 (Page 2of2) Detection Capabilities for Environmental Sample Analysis LOWER LIMIT OF DETECTION (LLD) NOTE 1: For a particular measurement system (which may include radiochemical separation): 4.66 ~b LLD (24-1) E

• V
• 2.22E+06
• Y
• e-(A~t)

Where: LLD = the "a priori" (before the fact) Lower Limit of Detection as defined above (as microcuries per unit mass or volume) (See Subsection 4.9) Sb = the standard deviation of the background counting rate or of the counting rate of a blank sample as appropriate (as counts per minute, cpm) E = the counting efficiency (as counts per disintegration) V = the sample size (in units of mass or volume) 2.22E+06 = the number of disintegrations per minute (dpm) per micrdcurie Y = the fractional radiochemical yield (when applicable) A the radioactive decay constant for the particular radionuclide

         ~t          =  the elapsed time between sample collection (or end of the sample collection period) and time of counting (for environmental samples, not plant effluent samples)

Typical values of E, V, Y and ~t should be used in the calculation. The LLD is an "a priori" (before the fact) limit representing the capability of a measurement system and not a "posteriori" (after the fact) limit for a particular measurement.

DOMINION VPAP-2103S REVISION 19 PAGE690F76 ATTACHMENT 11 (Page 1 of 1) Reporting Levels for Radioactivity Concentrations in Environmental Samples Analysis Water Airborne , Fish Milk Food Products (pCi/L) Particulate or (pCi/kg, wet) (pCi/L) (pCilkg, wet) Gases (pCifm3) H-3 20,000* Mn-54 1,000 30,000

 , Fe-59             400                              10,000 Co-58            1,000                           . 30,000 Co-60             300                              10,000 Zn-65             300                              20,000 Zr-Nb-95            400 I-131              2*             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
    *Reporting level for the ground (drinking) water samples required by Radiological Environmental Monitoring Program (Attachment 8). The reporting level for the surface (non-drinking) water samples required by Attachment 8 is 30,000 pCi/L for H-3 and 20 pCi/L for I-131.

DOMINION VPAP-2103S REVISION 19 PAGE 700F76 ATTACHMENT 12 (Page 1of7) Meteorological, Liquid, and Gaseous Pathway Analysis

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

1.2 Meteorological Data, Parameters, and Methodology A five (5) year average of representative onsite meteorological data for the period January 1, 2007 through December 31, 2011, is used in the gaseous effluent dose pathway calculations. This data includes wind speed, wind direction, and differential temperature for the purpose of determining joint frequency distributions for those releases characterized as ground level (i.e., ventilation vent), and those characterized as mixed mode (i.e., process vent). X!Qs and D/Qs were calculated using the PC version of NRC computer code "XOQDOQ - Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations", Version 2.0, provided in NUREG-0324. The open terrain adjustment factors were applied to the X/Q values as recommended in Regulatory Guide 1.111. The site region is characterized as flat terrain such that open terrain correction factors are considered appropriate. The ground level ventilation vent release calculations included a building wake correction based on a 1516 m2 containment minimum cross-sectional area. The effective release height used in mixed mode release calculations was based on a process vent release height of 131 ft, and plume rise due to momentum for a vent diameter of 1.5 in. with plume exit vefocity of 100 ft/sec. Ventilation vent, and vent releases other than from the process vent, are considered ground level as specified in Regulatory Guide 1.111 for release points less than the height of adjacent solid structures. Terrain elevations were obtained from Surry Power Station Units 1 and 2 Virginia Electric and Power Company Updated Final Safety Analysis Report Table l lA-8. XIQ and D/Q values were calculated for the nearest site boundary, residence, milk-cow, discharge bank, and vegetable garden by sector for process vent and ventilatiOJ?- vent releases.

DOMINION VPAP-2103S REVISION 19 PAGE 71 OF76 ATTACHMENT 12 (Page 2 of7) Meteorological, Liquid, and Gaseous Pathway Analysis

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

However, these releases are considered long term for dose calculations as past releases were 1 both random in time of day and duration as evidenced by reviewing past release reports. Therefore, the use of annual average concentrations is appropriate according to NUREG-0133. I 1.3

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

2.0 LIQUID PATHWAY ANALYSIS 2.1 Purpose The purpose of the liquid pathway analysis was to determine the maximum exposed member of the public in unrestricted areas as a result of radioactive liquid effluent iele~ses. The analysis included a determination of most restrictive liquid pathway, most restrictive age group, and critical organ. This analysis is required for Subsection 6.2, Liquid Radioactive Waste Effluents. 2.2 Data, Parameters, and Methodology Radioactive liquid effluent release data for the years 1976, 1977, 1978, 1979, 1980, and 1981 were compiled from the Surry Power Station effluent release reports. The data for each year, along with appropriate site specific parameters and default selected parameters, were entered into the NRC computer code LADTAP as described in NUREG-1276. Liquid radioactive effluents from both units are released to the James River via the discharge canal. Possible pathways of exposure for release from the Station include ingestion of fish and invertebrates and shoreline activities. The irrigated food pathway and potable water pathway do n.ot exist at this location. Access to the discharge canal by the general public is gained two ways: bank fishing, controlled by the Station and limited to Dominion employees or guests of employees, and by boat as far upstream as the inshore end of the discharge canal groin. It has been estimated that boat sport fishing would be performed a maximum of 800 hours per year, and that bank fishing would be performed a maximum of 160 hours per year.

DOMINION VPAP-2103S REVISION 19 PAGE 720F76 ATTACHMENT 12 (Page 3of7) Meteorological, Liquid, and Gaseous Pathway Analysis For an individual fishing in the discharge canal, no river dilution was assumed for the fish pathway. For an individual located beyond the discharge canal groins, a river dilution factor of 5 (i.e., a mixing ratio of 0.2) was assumed as appropriate according to Regulatory Guide 1.109, Rev. 1, and the fish, invertebrate, and shoreline pathways were considered to exist. Dose factors, bioaccumulation factors, shore width factors and usage terms for shoreline activities and ingestion of fish and invertebrates are included in the Source Code file. Dose to an individual fishing on the discharge bank was determined by multiplying the annual dose calculated with LADTAP by the fractional year the individual spent fishing in the canal. 2.3. Results For the years 1976, 1977, 1979, 1980, and 1981, the invertebrate pathway resulted in the largest dose. In 1978 the fish pathway resulted in the largest dose. The maximum exposed member of the public was determined to utilize the James River. The critical age group was the adult and the critical organ was either the thyroid or GI-LLI. The ingestion dose factors, which include the fish and inyertebrate pathways, are calculated for total body and various critical organs. Validation of the limiting age group and critical organ is performed by the liquid effluent dose calculation program using the data, parameters, and methodology provided in the Source Code file. 3.0 GASEOUS PATHWAY ANALYSIS 3.1 Purpose Gaseous effluent pathway analyses are performed to determine the location that would result in the maximum doses due to noble gases, for use in demonstrating compliance with Steps 6.3.1.a. and 6.3.3.a. The analyses includes a determination of the location, pathway, and critical organ, of the maximum exposed member of the public, as a result of the rel~ase of I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than eight days for use in demonstrating compliance with Step 6.3.4.a. In addition, the analyses includes a determination of the critical organ, maximum age group, and sector location of an exposed individual through the inhalation pathway from I 131 , I 133 , tritium, and particulates to demonstrate compliance with Step 6.3.1.a.

DOMINION VPAP-2103S REVISION 19 PAGE 73 OF76 ATTACHMENT 12 (Page 4 of7) Meteorological, Liquid, and Gaseous Pathway Analysis 3.2 Data, Parameters, and Methodology Five year average XIQ values were calculated, as described in Section 1 of this attachment. The maximum doses to total body and skin, and air doses for gamma and beta radiation due to noble gases would be at these site boundary locations. The doses from both the ventilation vent and process vent release points are summed to calculate total maximum dose. 6.3.l.a.2 dose limits apply specifically to the inhalation pathway. Therefore, the locations and X!Q values determined for maximum noble gas doses can be used to determine the maximum dose from I 131 , I 133 , tritium, and for all radionuclides in particulate form with half-lives greater than 8 days for the inhalation pathway. The maximum exposed individual for 10 CFR 50, Appendix I, compliance could be at any of the following locations: site boundary, nearest resident, nearest milk-cow, or nearest vegetable

   *garden, using the Land Use Census data which is assessed annually. Therefore, ventilation vent and process vent X/Q and D/Q values for these selected receptors are included in the gaseous.

effluent dose pathway analyses. Ground plane, inhalation, cow-milk, and vegetable garden pathways are active with the exception of the infant age group, which is not active for the vegetable garden pathway. Otherwise, all age groups are evaluated at these locations. The data, parameters, and methodology of R. G. 1.109, Rev. 1, and NUREG-0133 are used in the gaseous effluent dose pathway analyses. The gamma and beta dcise factors Kivv. Livv. Mivv. and Nivv for ground level releases and the gamma and beta dose factors Kipv. Lipv. Mipv. and Nipv for mixed mode releases are included in the Source Code file. Inhalation pathway dose factors Pivv and Pipv are calculated using the following equation: Pi= K' (BR) DFAi mrem/yr per Ci/m3 (28-1) where: K' =a constant of unit conversion, lE+ 12 pCi/Ci BR= the breathing rate of the particular age group, m 3/yr, from Table E-5, Regulatory Guide 1.109, Rev.l DFAi = the critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 19 PAGE 740F76 ATTACHMENT 12 (Page 5 of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R.G. 1.109, Rev. 1. It was determined that the member of the public within site boundary would be using the

   .discharge canal bank for fishing a maximum of 160 hours per year. Active pathways are ground plane and inhalation, and all age groups are evaluated for this pathway analysis.

The RMivv and RMipv dose factors, except for tritium, are calculated using the following equation: RM.1 K' Q F (U ap ) F . (r) (DFL.) [f f ( f f ) -1.AJ

                                                   ~ + 1- p s e 1

e-A.itr (28-2) A,. +'A m i y y 1 w p s where: K' = a constant of unit conversion, lE+ 12 pCi/Ci Qp =cow's consumption rate, 50, in kg/day (wet weight) Uap= infant milk consumption rate, 330, in liters/yr Yp =agricultural productivity by unit area of pasture feed grass, 0.7 in kg/m2 Y s =agricultural productivity by unit area of stored feed, 2.0, in kg!m2 Fm =stable element transfer coefficients, in days/liter r =fraction of deposited activity retained on cow's feed grass, 1.0 for radioiodine, and 0.2 for particulates DF'Lj=critical organ ingestion dose factor for the ith radionuclide for the particular age group, inmrem/pCi A.j = decay constant for the ith radionuclide, in sec-1 Aw =decay constant for removal of activity of leaf and plant surfaces by weathering, 5. 73E-07 sec-1 (corresponding to a 14 day half-life) tf = transp~rt time from pasture to cow, to milk, to receptor, 1.73+05, in seconds th =transport time from pasture, to harvest, to cow, to milk, to receptor, 7.78E+06, in seconds fp =fraction of year that cow is on pasture, 1.0 (dimensionless)

DOMINION VPAP-2103S REVISION 19 PAGE 75 OF76 ATTACHMENT 12 (Page 6 of7) Meteorological, Liquid, and Gaseous Pathway Analysis f8 =fraction of cow feed that is pasture grass while cow is on pasture, 0.8 (dimensionless) Parameters used above were obtained from NUREG-0133 and Regulatory Guide 1.109, Rev.1. Since the concentration of tritium in milk is based on the airborne concentration rather than the deposition, the following equation is used: K'Kp mQFUap(DFLH3) [0.75(0.5/H~ (28-3) where: K'; '= a constant of unit conversion 1E+03 gm/kg H = absolute humidity of the atmosphere, 8.0, in gmfm3 0.75 =the fraction of total feed that is water 0.5 = the ratio of the specific activity of the feed grass to the atmospheric water Other parameters have been previously defined. The inhalation pathway dose factors Rlivv and Rlipv were calculated using the following equation: Rli = K' (BR) DFAi mrem/yr per Ci/m3 (28-4) where: K' = aconstant of unit conversion, lE+ 12 pCi/Ci BR= breathing rate of the particular age group, m3/yr DFAi=critical organ inhalation dose factor for particular age group for the ith radionuclide, in mrem/pCi

DOMINION VPAP-2103S REVISION 19 PAGE 76 OF76 ATTACHMENT 12 (Page 7of7) Meteorological, Liquid, and Gaseous Pathway Analysis Parameters used above were obtained from NUREG-0133 and R. G. 1.109, Rev. 1.

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

RG~K'K"(SF)DFG; [  !-~;'*'* ] (-m_z_~m-il_r:-:-cl_y_r_) (28 - 5) where: K' = A constant of unit conversion, IE+ 12 pCi/Ci K" = A constant of unit conversion, 8760 hr/year.

                = The decay constant for nuclide i, sec- 1.
                =  The exposure time, 4.73x108 sec (15 years), from Table E-15 of Reg Guide 1.109.
                =  The ground plane dose conversion factor for nuclide i, from Table E-6 of Reg. Guide 1.109 (mrern/hr per pCi/m2). . .        .

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

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

Attachment 5 Page 1of1 INOPERABILITY OF RADIOACTIVE LIQUID AND GASEOUS EFFLUENT MONITORING INSTRUMENTATION The Annual Radioactive Effluent Release Report shall explain why monitoring instrumentation required by the ODCM Attachments land 5, which were determined to be inoperable, were not returned to operable status within 30 days. Two of the above referenced instrumentation were inoperable greater than 30 days during this reporting period. On 05/06/2015, the Surry Radwaste Facility (SRF) Ventilation Stack Noble Gas Monitor selector switch was determined inoperable. The selector switch provides the capability to toggle through various monitor parameters and perform selected functions. Two instruments required to monitor the SRF stack release pathway, in accordance with Attachment 5 of the ODCM, were rendered inoperable with the loss of the selector switch. The instruments lost were the noble gas activity radiation monitor and the flow rate measuring device for the stack continuous particulate and iodine sampler. Additionally, although not required by Attachment 5, the capability to source check the noble gas activity radiation monitor was rendered inoperable. Compensatory measures for the loss of the instruments were initiated in accordance with the ODCM. For the loss of the noble gas activity radiation maonitor, grab samples of the SRF stack exhaust are taken and analyzed at least once every 12 hours. No activity has been detected in any of these samples. For the loss of the sampler flow rate measuring device, an estimate of the sampler flow rate is made at least once per 4 hours and documented in the Station logs. At this time, these instruments remain inoperable with compensatory measures in place. A similar radiation monitor skid was obtained to replace the current skid, but it could not be made functional. Design Change 15-01054 has been initiated to obtain and install a new radiation monitoring system for the SRF ventillation in 2016.

Attachment 6 Page 1 of 1 UNPLANNED RELEASES There were no unplanned liquid or unplanned gaseous releases during this reporting period.

Attachment 7 Page 1 of 1 LOWER LIMIT OF DETECTION (LLD) FOR EFFLUENT SAMPLE ANALYSIS GASEOUS: Isotope Reguired LLD Typical LLD Kr-87 l.OOE-04 2.21E 4.78E-05 Kr-88 l.OOE-04 l .56E l.94E-05 Xe-133 l.OOE-04 l.28E l.48E-05 Xe-133m l.OOE-04 3.68E 4.06E-05 Xe-135 l.OOE-04 3.66E l.23E-05 Xe-135m l.OOE-04 l.35E-05 - 8.36E-05 Xe-138 l.OOE-04 2.32E 9.90E-05 I-131 l.OOE-12 4.06E 4.06E-13 I-133 l.OOE-10 4.06E-ll - 4.06E-l l Sr-89 l.OOE-11 l.23E 3.68E-12 Sr-90 1.00E-11 1. 76E-l 5 - 5.87E-13 Cs-134 l.OOE-11 l.53E 2.50E-13 Cs-137 1.00E-11 l.54E 3.38E-13 Mn-54 l.OOE-11 2.50E 2.77E-13 Fe-59 l.OOE-11 3.50E 8.38E-13 Co-58 l.OOE-11 l.72E 3.12E-13 Co-60 l.OOE-11 2.58E 4.97E-13 Zn-65 l .OOE-11 4.98E 6.99E-13 Mo-99 l.OOE-11 4.06E 4.06E-12 Ce-141 l.OOE-11 2.06E 2.98E-13 Ce-144 1.00E-11 7.89E l.34E-12 Alpha l.OOE-11 1.68E 2.21E-14 Tritium l.OOE-06 5.09E 6.61E-08 LIQUID: Sr-89 5.00E-08 2.61E-08 - . 4.30E-08 Sr-90 5.00E-08 6.15E-09 - l.69E-08 Cs-134 5.00E-07 1.94E-08 - 5.0lE-08 Cs-137 5.00E:.07 l.58E-08 - 7.85E-08 I-131 l.OOE-06 2.81E-08 - 5.52E-08 Co-58 5.00E-07 2.18E-09 - 5.99E-08 Co-60 5.00E-07 2.77E-09 - 8.82E-08. Fe-59 5.00E-07 3.25E-08 - 1.48E-07 Zn-65 5.00E-07 5.09E-09 - l.37E-07 Mn-54 5.00E-07 3.19E-09 - 6.09E-08 Mo-99 5.00E-07 2.92E-07 - 4.95E-07 Ce-141 5.00E-07 2.93E-08 9.27E-08 Ce-144 5.00E-07 l.17E-07 - 3.47E-07 Fe-55 1.00E-06 3.02E-07 - 9.94E-07 Alpha l.OOE-07 2.73E-08 - 2.76E-08 Tritium 1.00E-05 l.26E-06 - 1.63E-06 Xe-133 l.OOE-05 8.67E-08 - 2.95E-07 Xe-135 l .OOE-05 2.07E-08 - l.18E-07 Xe-133m l.OOE-05 . 2.lOE-07 - 5.66E-07 Xe-135m 1.00E-05 l.53E-06 - 2.81E-06 Xe-138 l.OOE-05 2.38E-06 - 8.78E-06 Kr-87 l.OOE-05 1.15E-07 2.53E-07 Kr-88 1.00E-05 1.59E-08 - 7.85E-07

Attachment 8 Page I of 2 INDUSTRY GROUNDWATER PROTECTION INITIATIVE The following is a summary of 2015 sample analyses of ground water monitoring wells that are not a part of the Radiological Environmental Monitoring Program (REMP). Analyses are performed by an independent laboratory. Well Sample Tritium Gamma Fe-55 Ni-63 Sr-90 TRU Designation Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter 1-PL-Piez-04 3/11/15 <1,240 ND NA NA NA NA 1-PL-Piez-05 3/11115 6,690 ND <95.4 <3.04 <1.00 NA 1-PL-Piez-06 3/11/15 2,030 ND <175 <4.95. <0.884 NA 1-PL-Piez-07 3/11/15 <1,250 ND NA NA NA NA 1-PL-Piez-27 3/11/15 <1,260 ND NA NA NA NA

        . 1-PL-Piez-33    3/11/15 <1,270       ND        NA       NA        NA        NA 1-PL-Piez-34    3/11/15 <1,250       ND        NA       NA        NA        NA 1-PL-Piez-41    3/11/15 <1,260       ND        NA       NA        NA        NA 1-PL-Piez-42    3/11/15 <1,250       ND        NA       NA        NA        NA 1-PL-Piez-29    3/12/15   7,670      ND       <141     <3.06    <0.713      NA 1-PL-Piez-05    6/8/15    7,150      ND        NA       NA        NA        NA 1-PL-Piez-06    6/8/15    1,960      ND        NA       NA        NA        NA 1-PL-Piez-09    6/8/15   <1,090      ND        NA       NA        NA        NA 1-PL-Piez-20    6/8/15   <1,090      ND        NA       NA        NA        NA 1-PL-Piez-22    6/8/15   <1,100      ND        NA       NA        NA        NA 1-PL-Piez-24    6/8/15   <1,100      ND        NA       NA        NA        NA 1-PL-Piez-25    6/8/15   <1, 110     ND        NA       NA        NA        NA 1-PL-Piez-28    6/8/15   <1,100      ND        NA       NA        NA        NA 1-PL-Piez-3 3   6/8/15   <1,090      ND        NA       NA        NA        NA 1-PL-Piez-34    6/8/15   <1,100      ND        NA       NA        NA       NA 1-PL-Piez-37    6/8/15   <1,090     ND         NA       NA        NA       NA 1-PL-Piez-39    6/8/15   <1,100      ND        NA       NA        NA       NA 1-PL-Piez-40    6/8/15   <1,100     ND         NA       NA        NA       NA 1-PL-Piez-03    619115   <l,090     ND         NA       NA        NA       NA 1-PL-Piez-04    619115   <1,100     ND         NA       NA        NA       NA 1-PL-Piez-07    6/9/15   <1,100     ND         NA       NA        NA       NA 1-PL-Piez-08    619115   <1,100     ND         NA       NA        NA       NA 1..:PL-Piez-23  619115   <1,100     ND        NA        NA        NA       NA 1-PL-Piez-2 7   619115   <1,120     ND        NA        NA        NA       NA 1-PL-Piez-29    6/9/15    9,480     ND        NA        NA        NA       NA 1-PL-Piez-35    6/9/15   <1090      ND        NA        NA        NA       NA 1-PL-Piez-36    619115   <1100      ND        NA        NA        NA       NA 1-PL-Piez-38    61911~   <1090      ND        NA        NA       NA        NA 1-PL-Piez-41    6/9/15   <1090      ND        NA        NA        NA       NA 1-PL-Piez-42    6/9/15   <1100      ND        NA        NA       NA        NA

Attachment 8 Page 2 of 2 INDUSTRY GROUND WATER PROTECTION INITIATIVE Well Sample Tritium Gamma Fe-55

• Ni-63 Sr-90 TRU I '

Designation Date pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter pCi/Liter 1-PL-Piez-04 8/25115 <976 NA NA NA NA NA 1-PL-'fliez-05 8/25/15 6,260 ND NA NA NA NA 1-PL-Piez-06 8/25/15 2,340 ND NA NA NA NA 1-PL-Piez-07 8/25/15 <974 ND NA NA NA NA 1-PL-Piez-27 8/25/15 <976 ND NA NA NA NA

• l-PL-Piez.:29 8/25/15 7,640 ND NA NA NA NA 1-PL-Piez-33 8/25/15 <975 ND NA NA NA NA 1-PL-Piez-34 8/25/15 <975 ND NA NA NA NA 1-PL-Piez-41 8/25/15 <975 ND NA NA NA NA 1-PL-Piez-42 . 8/25/15 <976 NA NA NA NA NA 1-PL-Piez-04 12/9/15 <1,290 NA NA NA NA NA f-PL-Piez-05 12/9/15 7,220 ND NA NA NA NA 1-PL-Piez-06 12/9/15 2,900 ND NA .NA NA NA l-PL-Piez.,07 12/9/15 <1,290 ND NA NA NA NA 1-PL-Piez-08 12/9/15 <1,290 ND NA *NA NA NA 1-PL-Piez-24 12/9/15 <1,300 ND NA NA NA NA 1-PL-Piez-25 12/9/15 *. <1,300 NA NA NA NA NA 1-PL-Pi'ez-27 12/9/15 <1,280 NA NA *NA -NA NA 1-PL-Piez-29 12/9/15 7;470 NA NA NA NA NA l-PL-Piez.,.33 12/9/15 <1,250 ND NA NA NA NA 1-PL-Piez-34 12/9/15 <1,280 ND NA NA NA NA i-PL-Piez-40 12/9/15 . <:1,290 NA NA NA NA NA 1-PL-Piez-41 12/9/15 <1,310 NA. NA. NA NA NA 1-PL-Piez-42 12/9/15 <1,300 NA NA NA NA NA NA = Analysis not required.

ND= No non-natural gamma emitting nuclides detected when analyzed to REMP LLDs. TRU = Transuranics (Am-241, Cm-242, Cm-243/244, Pu-238 ,Pu-239/240 and Pu-241)}}