Text

Procedure, AP 078-004, Revision 21, Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program).
	ML18121A137
Person / Time
Site:	Wolf Creek
Issue date:	04/25/2018
From:	; Wolf Creek
To:	; Office of Nuclear Reactor Regulation
References
	RA 18-0046 AP 078-004, Rev 21
	Download: ML18121A137 (38)
	v • d • e

Enclosure II to 2017 Annual Radioactive Effluent Release Report-Report 41 Wolf Creek Nuclear Operating Corporation Procedure, AP 078-004, Revision 21, "Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program)"

. FCREEK ' NUCLEAR OPERATING CORPORATION AP 07B-004 OFFSITE DOSE CALCULATION MANUAL (RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM) Responsible Manager Manager Regulatory Affairs Revision Number 21 Use Category Information Administrative Controls Procedure Yes Management Oversight Evolution No Program Number 07B Revision:

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SECTION 1. 0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 PURPOSE SCOPE TABLE OF CONTENTS TITLE REFERENCES AND COMMITMENTS DEFINITIONS RESPONSIBILITIES PROCEDURE RECORDS FORMS AP Page 1 07B-004 of 36 PAGE ----z---2 2 3 3 5 6 6 ATTACHMENT A OFFSITE DOSE CALCULATION MANUAL (REMP) 7 ATTACHMENT B SPECIAL SCOPE QUALITY ASSURANCE FOR THE REMP 34 Revision:

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Page 2 of 36 1.0 PURPOSE 1.1 This procedure contains the Offsite Dose Calculation Manual (ODCM) Radiological Environmental Monitoring Program (REMP) requirements.

1.2 This procedure also contains the Special Scope Quality Program for the REMP to assure the quality of the results of measurements of radioactive materials in the environment.

2.0 SCOPE 2.1 Technical Specifications 5.5.1 and 5.6.2 shall be implemented by this procedure.

2.2 Procedure AP 07B-003, OFFSITE DOSE CALCULATION MANUAL has been split into two procedures.

Requirements for the REMP are now contained in this procedure.

2.3 ATTACHMENT B, SPECIAL SCOPE QUALITY ASSURANCE FOR THE REMP, ensures the environmental monitoring requirements of Technical Specification 5.4.1.c are met. 2.4 The requirements of the Special Scope Quality Program do not apply to hardware.

2.5 For NEI 07-07 [Final] Industry Ground Water Protection Initiative

-Final Guidance Document "Communication Protocol" for offsite waters, see AI 07B-004, REPORTING REQUIREMENTS OF THE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM. 2.6 For NEI 07-07 [Final] Industry Ground Water Protection Initiative

-Final Guidance Document "Communication Protocol" for onsite waters, see AI 07-007, ONSITE GROUNDWATER PROTECTION PROGRAM MONITORING.

2.7 For NEI 07-07 [Final] Industry Ground Water Protection Initiative

-Final Guidance Document "Communication Protocol" for leaks/spills, see AP 14B-003, SPILL AND RELEASE REPORTING.

3.0 REFERENCES

AND COMMITMENTS 3.1 References 3 .1.1 3 .1. 2 3 .1. 3 AP 07B-003, OFFSITE DOSE CALCULATION MANUAL Radiological Assessment Branch Technical Position on Environmental Monitoring; Revision 1, November 1979 PIR 1998-0112, Revising the ODCM with an OTSC Revision:

21 Information Use 3 .1. 4 3 .1. 5 3 .1. 6 3 .1. 7 3 .1. 8 3 .1. 9 3 .1. 10 3.1.11 3. 1. 12 3 .1. 13 3.1.14 3.1.15 3.1.16 3.1.17 3.1.18 OFFSITE DOSE CALCULATION MANUAL AP 07B-004 (RADIOLOGICAL ENVIRONMENTAL M/'"'\l\TT

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Technical Specification 5.5.1 Technical Specification 5.6.2 Page 3 of 36 PIR 1998-3887, Wind Direction Frequency Rankings Regulatory Guide 4.15 -Quality Assurance for Radiological Monitoring Programs (Normal Operations)

-Effluent Streams and the Environment, February 1979 Technical Specification 5.4.1.c AP 24C-008, SUPPLIER AUDIT PROGRAM PIR 2001-1604, REMP Quality Program Requirements PIR 2001-1640, REMP Air Sample Control Location PIR 2002-0975, Changes to the ODCM 07-00558, NEI 07-07 [Final] Industry Ground Water Protection Initiative

-Final Guidance Document 11/14 Condition Report 2008-000574 REMP Harris Air Sample Station Equipment Malfunction WCGS Letter Number RA 08-0109 REMP: Acceptability of new Air Sample Location 53 dated 12-04-2008 Condition Report 2008-004274 Review of Engineering Evaluation SA-07-001 for the REMP AP 20A-003, QA AUDIT REQUIREMENTS, FREQUENCIES, AND SCHEDULING Technical Specification 5.6.3 3.2 Commitments 3.2.1 None 4.0 DEFINITIONS 4.1 None 5.0 RESPONSIBILITIES 5.1 Manager Regulatory Affairs 5 .1.1 Ensures that a quality program has been developed for Revision:

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DDn~DnM\ Page 4 of 36 radiological environmental monitoring.

Ensures that the Offsite Dose Calculation Manual (Radiological Environmental Monitoring Program) has been established, implemented and is maintained in accordance with Technical Specification 5.5.1. 5.2 Manager Quality 5.3 5.2.1 Ensures that internal and external audits are performed and documented.

Supervisor Regulatory Support 5.3.1 5.3.2 5.3.3 5.3.4 5.3.5 5.3.6 Implements and maintains the radiological environmental monitoring program. Ensures procedures are developed and maintained which describe sample collection, sample preparation and sample shipping.

Ensures procedures are developed and maintained which describe equipment maintenance and calibration.

Ensures procedures are developed and maintained which describe data review and reporting requirements.

Ensures personnel have received the required training prior to performing REMP-related activities.

Ensures that problems are identified and are properly addressed for resolution in the corrective action program. 5.4 Environmental Management Personnel

5. 4 .1 5.4.2 Ensure the REMP is established, implemented, and maintained.

Ensure that Condition Reports are generated in accordance with AP 28A-100, CONDITION REPORTS, for identified problems.

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ccn~cnM\ AP 07B-004 Page 5 of 36 6.1 Revisions to This Procedure NOTE To com.ply with Technical Specification 5.5.1, revisions to this procedure are not permitted via APF 15C-004-04, ON THE SPOT CHANGE form (3.1.3). 6 .1.1 6 .1. 2 Revisions to this procedure are to be submitted through the Manager Regulatory Affairs via APF 15C-004-01, DOCUMENT REVISION REQUEST (ORR). Changes to ATTACHMENT A shall include: 1. Sufficient information to support the change(s) together with the appropriate analyses or evaluations justifying the change(s) and (3.1.4) NOTE Changes to the REMP will have no impact upon the level of radioactive effluent control nor will impact the accuracy or reliability of effluent dose or setpoint calculations.

6 .1. 3 6 .1. 4 2. A determination that the change(s) maintain the levels of radioactive effluent control required by 10 CFR 20.1302, 40 CFR 190, 10 CFR 50.36a, and 10 CFR 50, Appendix I, and accuracy or reliability setpoint calculations.

not adversely impact the of effluent, dose, or (3 .1. 4) The changes shall become effective after the approval of the Plant Manager. (3.1.4) IF Figure 5.2 or Figure 5.3 are revised, THEN Emergency Planning should be notified so that the Radiological Emergency Response Plan may be revised accordingly.

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ccn~PnM\ Page 6 of 36 6.2 ODCM Submittal To NRC NOTE To comply with Technical Specification 5.5.1, a copy of this procedure must be submitted to the NRC with the Radioactive Effluent Release Report. 6.2.1 6.2.2 7.0 RECORDS Changes to the ODCM shall be submitted to the NRC in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Radioactive Effluent Release Report for the period of the report in which any change in the ODCM 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 (i.e., month and year) the change was implemented.

(3.1.4) The Radioactive Effluent Release Report covering the operation of the unit during the previous year shall be submitted to the NRC prior to May 1. (3.1.18) 11/14 7.1 The following is a lifetime QA Record: 7 . 1 . 1 8.0 FORMS 8.1 None AP 07B-004, OFFSITE DOSE CALCULATION MANUAL (RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM) -END -

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ATTACHMENT A (Page 1 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) AP Page 7 Wolf Creek Generating Station 07B-004 of 36 Offsite Dose Calculation Manual Radiological Environmental Monitoring Program Revision:

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ccn~cnM\ ATTACHMENT A (Page 2 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE OF CONTENTS Title INTRODUCTION 2.0 LIQUID EFFLUENTS (CONTAINED IN AP 07B-003) 3.0 GASEOUS EFFLUENTS (CONTAINED IN AP 07B-003) 4.0 TOTAL DOSE (CONTAINED IN AP 07B-003) AP Page 8 5.0 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 5. 1 Monitoring Program 5.2 Land Use Census 5.3 Interlaboratory Comparison Program 5.4 Reporting Requirements 6.0 BASES Sections 2.0 through 4.0 (Contained in AP 07B-003) 07B-004 of 36 4 4 5 5 6 Section 5.0 Radiological Environmental Monitoring 24 Program Section 5.1 Monitoring Program 24 Section 5.2 Land Use Census 25 Section 5.3 Interlaboratory Comparison Program 25 7.0 REPORTS 7.1 Annual Radiological Environmental Operating Report 26 7.2 Radioactive Effluent Release Report (Contained in APPENDIX A: APPENDIX B: AP 07B-003) Dose Conversion Factor Tables (Contained in AP 07B-003) Meteorological Model (Contained in AP 07B-003)

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ATTACHMENT A (Page 3 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) LIST OF TABLES AP 07B-004 Page 9 of 36 Table Title Page 5-1 5-2 5-3 5-4 Figure 5.1 5.2 5.3 5.4 5.5 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM SAMPLING LOCATION IDENTIFIERS, DISTANCES (MILES) AND DIRECTIONS DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES LIST OF FIGURES Title AIRBORNE PATHWAY SAMPLING LOCATIONS DIRECT RADIATION PATHWAY SAMPLING LOCATIONS WATERBORNE PATHWAY SAMPLING LOCATIONS INGESTION PATHWAY SAMPLING LOCATIONS DISTANT SAMPLING LOCATIONS 7 13 15 18 19 20 21 22 23 Revision:

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ccn~cnM\ ATTACHMENT A (Page 4 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) 1.0 Introduction AP 07B-004 Page 10 of 36 This attachment contains the ODCM for the Radiological Environmental Monitoring Program which was previously contained in AP 07B-003. This program is provided to monitor the radiation and radionuclides in the environs of the plant. The program provides (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways.

This program conforms to the guidance of Appendix I to 10 CFR Part 50 and includes the following:

1. Monitoring, sampling, analysis, and reporting of radiation an radionuclides in the environment.

2. A Land Use Census to ensure that changes in the use of areas at and beyond the site boundary are identified and the modifications to the monitoring program are made if required by the results of this census, and 3. Participation in an Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.

This attachment also provides a description of the information that should be included in the Annual Radiological Environmental Operating Report. 2.0 Liquid Effluents (Contained in AP 07B-003) 3.0 Gaseous Effluents (Contained in AP 07B-003) 4.0 Total Dose (Contained in AP 07B-003) 5.0 Radiological Environmental Monitoring Program This section describes the Radiological Environmental Monitoring Program for Wolf Creek Generating Station. 5.1 Monitoring Program Table 5-1 provides a schedule which describes the pathways, specific locations, sample collection frequencies, and analyses to be performed to implement the Radiological Environmental Monitoring Program.

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DDn~DnM\ Page 11 of 36 ATTACHMENT A (Page 5 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) Figures 5.1 through 5.5 contain maps depicting sampling locations in relation to the WCGS site. Table 5-2 lists distances and directions to these locations from the WCGS site. Table 5-3 lists required detection capabilities for the analyses performed.

5.2 Land Use Census 5.3 A Land Use Census shall be conducted annually during the growing season to identify the nearest (1) milk animal, (2) residence, and (3) garden of greater than 500 square feet producing broadleaf vegetation in each of the 16 meteorological sections within five miles of the WCGS site. (Broadleaf vegetation sampling of available vegetation may be performed at the site boundary in each of two different direction sectors with the highest predicted D/Qs in lieu of the garden census. Specifications for broadleaf vegetation sampling in Table 5-1 shall be followed, including analysis of control samples.)

Methods shall be used in conducting the census that provide the best results, such as door-to-door surveys, telephone surveys, mailed surveys, drive-by surveys, consulting the U.S.D.A. office in Burlington, consulting with Coffey County Emergency Management, inspection of aerial photographs of the area, or reviewing leasing records for area farms and residences.

If a location(s) is identified which yields a calculated dose or dose commitment (via the same exposure pathway) 20% greater than at a location from which samples are currently being obtained, and the cooperator agrees, the new location(s) shall be added to the Radiological Environmental Monitoring Program. The indicator sampling location(s) having the lowest calculated dose or dose commitment may then be deleted from the monitoring program. The results of the Land Use Census shall be included in the Annual Radiological Environmental Operating Report described in Section 7.1. Interlaboratory Comparison Program The analysis laboratory contracted to analyze samples from the Radiological Environmental Monitoring Program participates in a Laboratory Intercomparison Program. A summary of intercomparison results shall be included in the Annual Radiological Environmental Operating Report described in Section 7.1.

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oon~onM\ Page 12 of 36 5.4 ATTACHMENT A (Page 6 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) Reporting Requirements 5.4.1 Annual Radiological Environmental Operating Report To meet the requirements of Wolf Creek Technical Specification 5.6.2, the Annual Radiological Environmental Operating Report covering the operation of the unit during the previous calendar year shall be submitted to the NRC before May 1 of each year. The content of this report is described in Section 7.1. 5.4.2 Special Reports A special report shall be prepared and submitted to the NRC within 30 days if levels of radioactivity as a result of plant effluents detected in an environmental medium at a specified location exceed the reporting levels of Table 5-4 when averaged over any calendar quarter. The special report shall identify the cause(s) for exceeding the limit(s) and define 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 Wolf Creek Technical Specification 5.5.4. When one or more of the radionuclides in Table 5-4 is detected in the sampling medium, this report shall be submitted if: Concentration (1) + Reporting Level (1) Concentration (2) + .. ~1.0 Reporting Level (2) When radionuclides other than those in Table 5-4 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose* to a member of the public from all radionuclides is equal to or greater than the calendar year limits of Technical Specification 5.5.4. (*The methodology and parameters used to estimate the potential annual dose to a member of the public shall be indicated in this report.)

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ATTACHMENT A (Page 7 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-1 AP 07B-004 Page 13 of 36 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway/ Sample TyPe 1. AIRBORNE Radioiodine and Particulates

2. DIRECT RADIATION ( 4) Number of Samples and Sample Locations (1) FIGURES 5.1 & 5.5 Samples from six locations Samples from locations near the site boundary in three sectors having the highest calculated annual average D/Q and one supplemental location (Locations 2, 18, 37, or 49 on Figure 5.1); Sample from the vicinity of a community having the highest calculated annual average D/Q (Location 32 on Figure 5.1, New Strawn); Sample from a control location 9.5 to 18.5 miles distant in a low ranked D/Q sector (Location 53 on Figure 5.5). (11) FIGURES 5.2 AND 5.5 39 routine monitoring stations with two or more dosimeters measuring dose continuously, placed as follows: An inner ring of stations, one in each meteorological sector 0-3 mile range from the site (Locations 1, 7, 9, 11-13, 18, 26, 27, 29, 30, 37, 38, 46, & 49 on Figure5.2).

Sample Collection Frequency Continuous sampler operation with sample collection weekly, or more frequently if required, by dust loading Quarterly Type and Frequency of Analysis Analyze radioiodine canister weekly for I-131 Analyze particulate filter weekly for gross beta activity (2); perform quarterly gamma isotopic analysis (3) composite (by location).

Gamma dose quarterly 11/14 11/14 Revision:

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ATTACHMENT A (Page 8 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-1 (Continued)

AP 07B-004 Page 14 of 36 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway/ Sample TyPe DIRECT RADIATION (4) (CONTINUED)

3. WATERBORNE Surface Ground Number of Samples and Sample Locations (1) An outer ring of stations, one in each meteorological sector in the 3 to 5 mile range from the site (Locations 4, 5, 15-17, 19, 22-25, 32, 34-36, 50 & 51 on Figure 5.2). Four sectors [A, B, G & J] contain an additional station (Locations 2, 8, 14 & 20) The balance of the stations to be placed in special interest areas such as population centers (Locations 23, 32 & 52), nearby residences (many locations are near a residence), schools (Locations 23 & 52), Wilson Cadman Wildlife Education Area (44), CCL Public Fishing Area (46) and in two areas to serve as control stations 10-20 miles distant from the site (Locations 39 and 53 on Figure 5. 5) (11) FIGURE 5.3 One sample upstream (5) (Location JRR on Figure 5.3) and one sample stream (Location SP on Figure 5.3) Samples from one or two sources only if likely to be affected Indicator samples at locations hydrologically down-gradient of the site (Locations C-10, C-49, F-1, G-2, J-1 and J-2 on Figure 5.3); control sample at a location hydrologically upgradient of the site (Location B-12 on Figure 5. 3) (6) Sample Collection Frequency Monthly grab sample Quarterly grab sample Type and Frequency of Analysis Monthly gamma isotopic analysis (3) and composite for tritium analysis quarterly.

Quarterly gamma isotopic analysis (3) and tritium analysis.

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ATTACHMENT A (Page 9 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-1 (Continued)

AP 07B-004 Page 15 of 36 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway/ Sample TyPe 3. WATERBORNE (CONT.) Drinking Shoreline Sediment 4. INGESTION Milk Fish Number of Samples and Sample Locations (1) Sample of municipal water supply at an indicator location downstream of the Neosho River-Wolf Creek confluence (Location IO-OW on Figure 5.5); control sample from location upstream of the Neosho River-Wolf Creek confluence (Location BW-15 on Figure 5. 3) One sample from the vicinity of Coffey County Lake discharge cove (Location DC on Figure 5.3); control sample from John Redmond Reservoir (Location JRR on Figure 5. 3). FIGURES 5.4 AND 5.5 Samples from milking animals at three indicator locations within 5 miles of the site having the highest dose potential (currently there are no locations producing milk for human consumption within 5 miles of the site); one sample from a control location greater than 10 miles from the site if indicator locations are sampled. (11) Indicator samples of 1 to 3 recreationally important species from Coffey County Lake (Figure 5.4); control samples of similar species from John Redmond Reservoir Spillway (indicated on Figure 5.4). Sample Collection Frequency Monthly composite (7) Semiannually Semimonthly April to November; monthly December-March (9) Semiannually Type and Frequency of Analysis Monthly gamma isotopic analysis (3) and gross beta analysis of composite sample. Quarterly tritium analysis of composites (8). 11/14 Semiannual gamma isotopic analysis (3) Gamma isotopic analysis (3) and I-131 analysis of each sample. Gamma isotopic analysis (3) on edible portions Revision:

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ATTACHMENT A (Page 10 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-1 (Continued)

AP 07B-004 Page 16 of 36 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM Exposure Pathway/ Sample Type 4. INGESTION (CONT.) Food Products Food Products Number of Samples and Sample Locations (1) Samples of available broadleaf vegetation from two indicator locations (using the criteria from the "Land Use Census" section) with highest calculated annual average D/Q (Locations A-3 and Q-6 and alternate Locations B-1, H-2, N-1 and R-2 on Figure 5.4); sample of similar broadleaf vegetation from a control location 9.5 to 18.5 miles distant in a low ranked D/Q sector (Location D-2 on Figure 5 . 5) . ( 11) Sample of crops irrigated with water from the Neosho River downstream of the Neosho River-Wolf Creek confluence (locations will vary from year to year, e.g., Location NR-Dl & NR-D2 on Figure 5.5). Sample Collection Frequency Monthly when available (9) At time of harvest (10) Type and Frequency of Analysis Gamma isotopic analysis (3) on edible portions.

Gamma isotopic analysis (3) on edible portions Revision:

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oon~onM\ ATTACHMENT A (Page 11 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-1 (Continued)

TABLE NOTATIONS AP 07B-004 Page 17 of 36 (1) Deviations are permitted from the required sampling schedule if specimens are unobtainable due to hazardous conditions, seasonal unavailability, malfunction of automatic sampling equipment, and other legitimate reasons. If specimens are unobtainable due to sampling equipment malfunction, every effort shall be made to complete corrective action prior to the end of the next sampling period. All deviations from the sampling schedule shall be documented in the Annual Radiological Environmental Operating Report described in Section 7.1. It is recognized that, at times, it may not be possible or practicable to continue to obtain samples of the media of choice at the most desired location or time. In these instances, suitable specific alternative media and locations may be chosen for the particular pathway in question and appropriate substitutions made. (2) Airborne particulate sample filters shall be analyzed for gross beta radioactivity 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or more, preferably after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , after sampling to allow for Rn-220 and Rn-222 daughter decay. If gross beta activity in air particulate samples is greater than 10 times the yearly mean of control samples, gamma isotopic analysis shall be performed on the individual samples. (3) Gamma isotopic analysis means the identification and quantification of gamma-emitting radionuclides that may be attributable to the effluents from the facility.

(4) One or more instruments, such as a pressurized ion chamber, for measuring and recording dose rate continuously may be used in place of, or in addition to, integrating dosimeters.

Film badges shall not be used as dosimeters for measuring direct radiation.

The 40 stations are not an absolute number. The number of direct radiation monitoring stations may be reduced according to geographical limitations, e.g., some sectors are over water so that the number of dosimeters may be reduced accordingly.

Sector J is an example. The frequency or analysis or readout for the dosimeter system depends upon the characteristics of the specific system used and is selected to obtain optimum dose information with minimal fading. 11/14 Revision:

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DDn~DnM\ ATTACHMENT A (Page 12 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-1 (Continued)

TABLE NOTATIONS AP 07B-004 Page 18 of 36 (5) The "upstream" sample is taken at a distance beyond significant influence of the discharge.

(6) Ground water samples shall be taken when this source is tapped for drinking or irrigation purposes in areas where the hydraulic gradient or recharge properties are suitable for contamination.

(7) A composite sample is one in which the quantity (aliquot) of liquid sampled is consistent over the sampling period and in which the method of sampling employed results in a specimen that is representative of the liquid concentrate.

In this program, composite sample aliquots shall be collected at time intervals that are very short (e.g., every two hours) relative to the compositing period (e.g., monthly) in order to assure obtaining a representative sample. (8) If the dose calculated for consumption of water (using ODCM methodology and parameters) exceeds one millirem per year, composite sampling at the indicator location shall be performed every two weeks and I-131 analysis shall be performed on the composite samples. (9) Milk and broadleaf vegetation samples are often temporarily, but not permanently, unavailable at the scheduled sample collection times. Alternate sampling locations may therefore be listed in the Table and used at these times to provide continued monitoring of these pathways.

If samples are considered permanently unavailable at a location, another location will be selected (if available) as described in Note (1). (10) If harvest occurs more than once a year, sampling shall be performed during each discrete harvest. If harvest occurs continuously, sampling shall be monthly. Attention shall be paid to including samples of tuberous and root food products.

(11) The purpose of this sample is to obtain background information.

If it is not practical to establish control locations in accordance with the distance and wind direction criteria, other sites that provide valid background data may be substituted.

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oon~onM\ ATTACHMENT A (Page 13 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-2 AP 07B-004 Page 19 of 36 SAMPLING LOCATION IDENTIFIERS, DISTANCES (miles) AND DIRECTIONS Sample Type Location Distance Direction Sector Identifier from Reactor Air Particulates 2 2.7 N A and Radioiodine 18 3.0 SSE H 32 3.1 WNW p 37 2.0 NNW R 49 0. 8 NNE B 53 10.8 ENE D Dosimeters 1 1. 4 N A 2 2.7 N A 4 4.0 NNE B 5 4.1 NE C 7 2.1 NE C 8 1. 7 NNE B 9 2.0 ENE D 11 1. 7 E E 12 1. 9 ESE F 13 1. 6 SE G 14 2.5 SE G 15 4.6 ESE F 16 4.3 E E 17 3.7 SE G 18 3.0 SSE H 19 3.9 SSE H 20 3.3 s J 22 3.9 SSW K 23 4.3 SW L 24 4 .1 WSW M 25 3.4 w N 26 2.4 WSW M 27 2.2 SW L 29 2.7 SSW K 30 2.5 w N 32 3.1 WNW p 34 4.4 NW Q 35 4.6 NNW R 36 4.2 N A 37 2.0 NNW R 38 1. 2 NW Q 39 13 .1 N A 44 3.0 NNW R 46 1. 6 WNW p Revision:

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ocn~cnM\ ATTACHMENT A (Page 14 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-2 (Cont.) AP 07B-004 Page 20 of 36 SAMPLING LOCATION IDENTIFIERS, DISTANCES (miles) AND DIRECTIONS Sample Type Location Distance Direction Sector Identifier from Reactor Dosimeters 49 0.8 NNE B 50 3.6 ENE D 51 4. 3 s J 52 3.6 SW L 53 10.8 ENE D Surface Water JRR 3.7 w N SP 3.2 SSE H Ground Water B-12 1. 9 NNE B C-10 2.7 w N C-49 2. 8 SW L F-1 2.5 ESE F G-2 3.6 SE G J-1 3.8 s J J-2 4.3 s J Drinking Water BW-15 3.9 SW L IO-DW 26 .1 SSE H Shoreline DC 0. 8 WNW p Sediment JRR 3.6 w N Fish CCL 0.6 E to NNW E to R JRR 3.7 w N Food/Garden A-3 2.6 N A B-1 0. 8 NNE B D-2 14.8 ENE D H-2 3.0 SSE H N-1 2.4 w N Q-6 2.4 NW Q R-2 2.0 NNW R Crops NR-Dl 8. 9 s J NR-D2 11. 5 s J I Revision:

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ccn~cnM\ Page 21 of 36 ATTACHMENT A (Page 15 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-3 DETECTION CAPABILITIES FOR ENVIRONMENTAL SAMPLE ANALYSIS (1) Lower Limit of Detection (LLD) (2) AIRBORNE FOOD PARTICULATE FISH PRODUCTS SEDIMENT ANALYSIS WATER OR GASES (pCi/kg, MILK (pCi/kg, (pCi/kg, (pCi/1) (pCi/m 3) wet) (pCi/1) wet) dry) Gross 4* 0.01 Beta H-3 2,000** Mn-54 15 130 Co-58 15 130 Fe-59 30 2 60 Co-60 15 130 Zn-65 30 2 60 Zr-Nb-95 15 I-131 1*** 0.07 1 60 Cs-134 15 0.05 130 15 60 150 Cs-137 18 0.06 150 18 80 180 Ba-La-140 15 15

LLD for drinking water samples. ** LLD for drinking water and ground water samples. For surface water samples, a value of 3,000 pCi/1 may be used. ***LLD for drinking water and ground water samples. For surface water samples, a value of 15 pCi/1 may be used.

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ocn~cnM\ Page 22 of 36 ATTACHMENT A (Page 16 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-3 (Continued)

TABLE NOTATIONS (1) This list does not mean that only these nuclides are to be considered.

Other peaks that are identifiable, together with those of the above nuclides, shall also be analyzed and reported in the Annual Radiological Environmental Operating Report described in Section 7.1. (2) The LLD is defined, as the smallest concentration of radioactive material in a sample that will yield a net count, above system background, that will be detected with 95% probability with only 5% probability of falsely concluding that a blank observation represents a "real" signal. For a particular measurement system, which may include radiochemical separation:

Where: LLD E V 2.22 y ~t LLD 4.66 Sb E* V* 2.22 *Y* exp (-A~t) the "a priori" lower limit of detection (picoCuries per unit mass or volume), the standard deviation of the background counting rate or of th counting rate of a blank sample as appropriate (counts per minute), the counting efficiency (counts per disintegration), the sample size (units of mass or volume), the number of disintegrations per minute per picoCurie, the fractional radiochemical yield, when applicable, the radioactive decay constant for the particular radionuclide (sec-1), and the elapsed time between sample collection, or end of the sampl collection period, and time of counting (sec). Typical values of E, V, Y, and ~t should be used in the calculation.

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ATTACHMENT A (Page 17 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-3 (Continued)

TABLE NOTATIONS AP 07B-004 Page 23 of 36 It should be recognized that the LLD is defined as an~ priori (before the fact) limit representing the capability of a measurement system and not as an~ posteriori (after the fact) limit for a particular measurement.

Analyses shall be performed in such a manner that the stated LLDs will be achieved under routine conditions.

Occasionally background fluctuations, unavoidable small *sample sizes, the presence of interfering nuclides, or other uncontrollable circumstances may render these LLDs unachievable.

In such cases, the contributing factors shall be identified and described in the Annual Radiological Environmental Operating Report described in Section 7.1.

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DD/"'\r::'.D71M\

Page 24 of 36 ATTACHMENT A (Page 18 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) TABLE 5-4 REPORTING LEVELS FOR RADIOACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES ANALYSIS WATER (pCi/1) AIRBORNE PARTICULATE OR GASES (pCi/m 3) FISH (pCi/kg, wet) MILK (pCi/1) FOOD PRODUCTS (pCi/kg, wet) H-3 Mn-54 Co-58 Fe-59 Co-60 Zn-65 20,000* 1,000 1,000 400 300 300 Zr-Nb-95 400 I-131 Cs-134 Cs-137 Ba-La-140 2** 30 50 200 0.9 10 20 30,000 30,000 10,000 10,000 20,000 1,000 2,000

For drinking water and ground water samples. value. For surface water samples, a value of ** For drinking water and ground water samples. a value of 20 pCi/1 may be used. 3 60 70 300 100 1,000 2,000 This is 40 CFR Part 141 30,000 pCi/1 may be used. For surface water samples, IF ground water or surface water results exceed the Reporting Levels, THEN proceed to AI 07B-004, REPORTING REQUIREMENTS OF THE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM for specific details regarding NEI 07-07 [Final] Industry Ground Water Protection Initiative

-Final Guidance Documen "Communication Protocol" requirements.

(3.1.13) 11/14 Revision:

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Page N r" l ATTACHMENT A (Page 19 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) FIGURE 5.1 "A ,\ < Q C AIRBORNE PATHWAY SAMPLING LOCATIONS

= AIRBORNE PARTICULATE AND RADIOIODINE 25 of 36 D Revision:

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Page 26 of 36 ATTACHMENT A (Page 20 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) FIGURE 5.2 Q DIRECT RADIATION PATHWAY SAMPLING LOCATIONS e = DOSIMETER LOCATIONS

/

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Page N ATTACHMENT A (Page 21 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) FIGURE 5.3 Q C WATERBORNE PATHWAY SAMPLING LOCATIONS e = DRINKING WATER * = GROUND WATER A = SURFACE WATER * = SHORELINE SEDIMENT 27 of 36 D E Revision:

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OFFSITE DOSE CALCULATION MANUAL (RADIOLOGICAL ENVIRONMENTAL MnhlT~nDThl~

DDn~DnM\ ATTACHMENT A (Page 22 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) FIGURE 5.4 Q AP 07B-004 Page 28 of 36 C / T INGESTION PATHWAY SAMPLING LOCATIONS = FISH (JRR) * = BROADLEAF VEGETATION = FISH (CCL)

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ccn~DnM\ ATTACHMENT A (Page 23 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) FIGURE 5.5 A * = Dosimeter AP 07B-004 Page 29 of 36 E

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ccn~cnM\ Page 30 of 36 6.0 Bases ATTACHMENT A (Page 24 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) The bases contained on the succeeding pages summarize the general requirements of Section 5.0 of the ODCM (REMP) Section 2.0 Liquid Effluents (Contained in AP 07B-003) Section 3.0 Gaseous Effluents (Contained in AP 07B-003) Section 4.0 Total Dose (Contained in AP 07B-003) Section 5.0 Radiological Environmental Monitoring Program Section 5.1 Monitoring Program The Radiological Environmental Monitoring Program provides representative measurements of radiation and of radioactive materials in those exposure pathways and for those radionuclides that lead to the highest potential radiation exposures of MEMBERS OF THE PUBLIC resulting from the station operation.

This monitoring program implementsSection IV.B.2 of Appendix I to 10 CFR Part 50 and thereby supplements the Radiological Effluent Monitoring Program by verifying that the measurable concentrations of radioactive materials and levels of radiation are not higher than expected on the basis of the effluent measurements and the modeling of the environmental exposure pathways.

Guidance for this monitoring program is provided by the Radiological Assessment Branch Technical Position on Environmental Monitoring, Revision 1, November 1979. The required detection capabilities for environmental sample analyses are tabulated in terms of the lower limits of detection (LLDs). The LLDs are considered optimum for routine environmental measurements in industrial laboratories.

It should be recognized that the LLD is defined as an~ priori (before the fact) limit representing the capability of a measurement system and not as an~ posteriori (after the fact) limit for a particular measurement.

Detailed discussion of the LLD, and other detection limits, can be found in HASL Procedures Manual, HASL-300 (revised annually), Currie, L.A., "Limits for Qualitative Detection and Quantitative Determination-Application to Radiochemistry," Anal. Chem. 40, 586-93 (1968), and Hartwell, J.K., "Detection Limits for Radioanalytical Counting Techniques," Atlantic Richfield Hanford Company Report ARH-SA-215 (June 1975).

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oon~onM\ ATTACHMENT A (Page 25 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) Section 5.2 Land Use Census AP 07B-004 Page 31 of 36 This section is provided to ensure that changes in the use of areas at and beyond the SITE BOUNDARY are identified and that modifications to the Radiological Environmental Monitoring Program given in the ODCM are made if required by the results of this census. Information that will provide the best results, such as door-to-door survey, aerial survey, or consulting with local agricultural authorities, shall be used. This census satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. Restricting the census to gardens of greater than 50 m2 provides assurance that significant exposure pathways via leafy vegetables will be identified and monitored since a garden of this size is the minimum required to produce the quantity (26 kg/year) of leafy vegetables assume in Regulatory Guide 1.109 for consumption by a child. To determine this minimum garden size, the following assumptions were made: (1) 20% of the garden was used for growing broadleaf vegetation (i.e., similar to lettuce and cabbage), and (2) a vegetation yield of 2 kg/m2. Section 5.3 Interlaboratory Comparison Program The requirement for participation in an approved Interlaboratory Comparison Program is provided to ensure that independent checks on the precision and accuracy of the measurements of radioactive material in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring in order to demonstrate that the results are valid for the purposes of Section IV.B.2 of Appendix I to 10 CFR Part 50.

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DDn~DnM\ ATTACHMENT A (Page 26 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) AP 07B-004 Page 32 of 36 7.1 Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2) Sections IV.B.2, IV.B.3 and IV.C of Appendix I to 10 CFR Part 50 (3.1.5), including a comparison with preoperational studies, with operational controls and with previous environmental surveillance reports, and an assessment of the observed impacts of the plant operation on the environment.

The report shall also include the results of the Land Use Census described in Section 5.2. The Annual Radiological Environmental Operating Report shall include the results of analysis of all radiological environmental samples and of all environmental radiation measurements taken during the period pursuant to the locations specified in Table 5-1 as well as summarized and tabulated results of these analyses and measurements in the format of the table in the Radiological Assessment Branch Technical Position, Revision 1, November 1979. In the event that some individual results are not available for inclusion with the report, the report shall be submitted noting and explaining the reasons for the missing results. The missing data shall be submitted as soon as possible in a supplementary report. The report shall also include the following:

a summary description of the Radiological Environmental Monitoring Program; legible maps covering all sampling locations keyed to a table giving distances and directions from the centerline of the reactor; the results of licensee participation in the Interlaboratory Comparison Program and the corrective actions being taken if the specified program is not being performed as required by Section 5.3; reasons for not conducting the Radiological Environmental Program as required by Section 5.1 with plans for preventing a recurrence and discussion of all deviations from the sampling schedule of Table 5-1; discussion of environmental sample measurements that exceed the reporting levels of Table 5-4 but are not the result of plant effluents, and discussions of all analyses in which the LLD required by Table 5-3 was not achieved.

7.2 Radioactive Effluent Release Report (Contained in AP 07B-003)

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ccn~cnM\ ATTACHMENT A (Page 27 of 27) OFFSITE DOSE CALCULATION MANUAL (REMP) AP 07B-004 Page 33 of 36 APPENDIX A Dose Conversion Factor Tables (Contained in AP 07B-003) APPENDIX B Meteorological Model (Contained in AP 07B-003) -END -

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oon~onM\ ATTACHMENT B (Page 1 of 3) AP 07B-004 Page 34 of 36 SPECIAL SCOPE QUALITY ASSURANCE FOR THE REMP B.l QUALITY REQUIREMENTS B.1.1 B.1.2 B.1.3 B.1.4 Review and Reporting of Data 1. Data from sample analysis are reviewed in accordance with approved procedures.

Organization

1. Section 5 of this procedure identifies the organizational structure, management positions and responsibilities.

Personnel Qualifications

1. Personnel responsible for collection and preparation of radiological environmental monitoring samples shall be qualified in accordance with approved procedures.

2. Personnel responsible for calibration of air sampler flow meters shall be qualified in accordance with approved procedures.

Procurement Document Control 1. Purchase orders for contracted services shall: a. Include quality requirements

b. Specify technical requirements

c. Identify documentation requirements

d. Detail records requirements

e. Extend applicable procurement document requirements to lower tier suppliers; and f. Specifying special requirements such as reporting program deficiencies, documentation requirements and applicable acceptance criteria.

2. Purchase orders for contracted laboratory services shall require participation in an interlaboratory comparison program.

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ccn~cnM\ ATTACHMENT B (Page 2 of 3) AP 07B-004 Page 35 of 36 SPECIAL SCOPE QUALITY ASSURANCE FOR THE REMP B.1.5 Instructions, Procedures and Drawings B.1.6 B.1.7 B.1.8 1. This criterion applies to: a. Surveillances, test and calibrations, b. Environmental sampling, and c. Data processing and evaluation

2. Activities shall be accomplished using procedures, instructions and drawings approved prior to use. 3. Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.

Control of Purchased Services 1. Controls shall be established to ensure that purchased services conform to procurement document requirements.

2. Controls shall include evaluation and selection of suppliers and surveillance or audit of supplied services.

Control of Measuring and Test Equipment

1. Measures shall be established to assure that tools, gages, instruments, and other measuring and testing devices used.in activities affecting quality are properly controlled, calibrated and adjusted at specified periods to maintain accuracy within necessary limits. Inspection, Test and Operating Status for Purchased Calibration Services 1. These inspections and tests shall be completed in accordance with approved procedures.

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ccn~cnM\ ATTACHMENT B (Page 3 of 3) AP 07B-004 Page 36 of 36 SPECIAL SCOPE QUALITY ASSURANCE FOR THE REMP B.1.9 Quality Assurance Records B.1.10 1. All documentation shall be legible, reproducible and or microfilmable quality. 2. Documented records shall be maintained to show objective evidence of quality. 3. Quality records shall not be destroyed or disposed of without written authorization.

4. For the vendor laboratory, data sheets and finished records shall be retained by the contactor for a period of five years. Audits 1. Audits shall be performed in accordance with AP 20A-003, QA AUDIT REQUIREMENTS, FREQUENCIES, AND SCHEDULING, to verify compliance to requirements and to verify the effectiveness of the implemented activities affecting quality. 2. Vendor audits in accordance with AP 24C-008, SUPPLIER AUDIT PROGRAM, shall be performed a minimum of once every 3 years unless commitments require more frequent audits. -END -