Text

2024 Annual Radioactive Effluent Release Report
	ML25120A082
Person / Time
Site:	FitzPatrick
Issue date:	04/30/2025
From:	Mark Hawes; Constellation Energy Generation
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	JAFP-25-0026
	Download: ML25120A082 (1)
	v • d • e

Constellation,.

JAFP-25-0026 April 30, 2025 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Mark R. Hawes Regulatory Assurance James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50-333

Subject:

2024 Annual Radioactive Effluent Release Report

Dear Sir or Madam:

This letter transmits the James A. FitzPatrick Nuclear Power Plant's (JAF) Annual Radioactive Effluent Release Report for the period of January 1, 2024 through December 31, 2024. The enclosure is submitted in accordance with 10 CFR 50.36a and the Reporting Requirements of Technical Specifications Section 5.6.3 and Technical Requirements Manual Appendix H, Offsite Dose Calculation Manual (ODCM), Part 1 Section 6.2, Radioactive Effluent Release Report.

This report (Enclosure 1) includes, as an Addendum, an Assessment of the Radiation Doses to the Public due to the radioactive liquid and gaseous effluents released during the 2024 calendar year. The format used for the effluent data is outlined in Appendix B of Regulatory Guide 1.21, Revision 1. Distribution is in accordance with Regulatory Guide 10.1, Revision 4.

There are no new regulatory commitments contained in this letter. If you have any questions concerning the enclosed report, please contact Mr. Ryan Conger, Chemistry Manager, at (315) 349-6640.

Sincerely,

~1~ #"-

Mark R. Hawes Regulatory Assurance MRH/RC/gg

Enclosure:

2024 cc: next page Annual Radioactive Effluent Release Report, January 1, 2024 - December 31,

JAFP-25-0026 Page 2 of 2 cc:

NRC Regional Administrator, Region I NRC Resident Inspector NRC Project Manager Supervisor, Town of Scriba Route 8, Box 382 Oswego, NY 13126

JAFP-25-0026 Enclosure Annual Radioactive Effluent Release Report January 1, 2024 - December 31, 2024 (47 Pages)

= Constellation James A FitzPatrick 2024 Annual Radioactive Effluent Release Report Docket No: 50-333 License No: DPR-59

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 1 of 35 Company: Constellation I Plant: James A FitzPatrick NPP TABLE OF CONTENTS 1.0 LIST OF ACRONYMS AND DEFINITIONS................................................................................ 3 2.0 EXECUTIVE

SUMMARY

............................................................................................................ 5 2.1 Comparison to Regulatory Limits.................................................................................... 6

3.0 INTRODUCTION

........................................................................................................................ 8 3.1 About Nuclear Power...................................................................................................... 8 3.2 About Radiation Dose................................................................................................... 10 3.3 About Dose Calculation................................................................................................ 12 4.0 DOSE ASSESSMENT FOR PLANT OPERATIONS................................................................. 14 4.1 Regulatory Limits.......................................................................................................... 14 4.2 Regulatory Limits for Gaseous Effluent Doses.............................................................. 14 4.3 Regulatory Limits for Liquid Effluent Doses................................................................... 15 4.4 40 CFR 190 Regulatory Dose Limits for a Member of the Public.................................. 16 5.0 SUPPLEMENTAL INFORMATION........................................................................................... 17 5.1 Gaseous Batch Releases............................................................................................. 17 5.2 Liquid Batch Releases.................................................................................................. 17 5.3 Abnormal Releases...................................................................................................... 17 5.4 Land Use Census Changes.......................................................................................... 18 5.5 Meteorological Data...................................................................................................... 18 5.6 Effluent Radiation Monitors Out of Service Greater Than 30 Days................................ 18 5.7 Offsite Dose Calculation Manual (ODCM) Changes...................................................... 19 5.8 Process Control Program (PCP) Changes.................................................................... 19 5.9 Radioactive Waste Treatment System Changes........................................................... 19 5.1 O Other Supplemental Information................................................................................... 19 6.0 NEI 07-07 ONSITE RADIOLOGICAL GROUNDWATER MONITORING PROGRAM............... 21 6.1 Voluntary Notification.................................................................................................... 23 7.0 BIBLIOGRAPHY...................................................................................................................... 24 TABLES Table 1, James A FitzPatrick Unit 1 Dose Summary.............................................................................. 6 Table 2, Total Annual Offsite-Dose Comparison to 40 CFR 190 Limits for JAF...................................... 7 Table 3, Groundwater Protection Program Monitoring Well Sample Schedule..................................... 21 Table 4, Groundwater Protection Program Monitoring Well Tritium Results......................................... 23 Table 5, Gaseous Effluents Summation of All Releases JAF Unit 1.................................................... 25 Table 6, Gaseous Effluents - Ground Level Release Batch Mode JAF Unit 1..................................... 26 Table 7, Gaseous Effluents - Ground Level Release Continuous Mode JAF Unit 1............................. 27 Table 8, Gaseous Effluents - Elevated Level Release Batch Mode JAF Unit 1................................... 28 Table 9, Gaseous Effluents - Elevated Level Release Continuous Mode JAF Unit 1........................... 29 Table 10, Liquid Effluents - Summation of All Releases JAF Unit 1.................................................... 30 Table 11, Batch Mode Liquid Effluents Canal JAF Unit 1..................................................................... 31 Table 12, Batch Mode Liquid Effluents Non-Canal JAF Unit 1............................................................. 32

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 2 of 35 Company: Constellation I Plant: James A FitzPatrick NPP Table 13, Continuous Mode Liquid Effluents Canal JAF Unit 1............................................................ 33 Table 14, Continuous Mode Liquid Effluents Non-Canal JAF Unit 1..................................................... 34 FIGURES Figure 1, Pressurized Water Reactor (PWR) [1]..................................................................................... 8 Figure 2, Boiling Water Reactor (BWR) [2]............................................................................................. 9 Figure 3, Sources of Radiation Exposure (NCRP Report No. 160) [3].................................................. 10 Figure 4, Potential exposure pathways to Members of the Public due to Plant Operations [6]............. 12 ATTACHMENTS, ARERR Release Summary Tables (RG-1.21 Tables)................................................... 25, Solid Waste Information................................................................................................ 35

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 3 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 1.0 LIST OF ACRONYMS AND DEFINITIONS

1.

Alpha Particle (a): A charged particle emitted from the nucleus of an atom having a mass and charge equal in magnitude of a helium nucleus.

2.

BWR: Boiling Water Reactor

3.

Composite Sample: A series of single collected portions (aliquots) analyzed as one sample. The aliquots making up the sample are collected at time intervals that are very short compared to the composite period.

4.

Control: A sampling station in a location not likely to be affected by plant effluents due to its distance and/or direction from the Plant.

5.

Counting Error: An estimate of the two-sigma uncertainty associated with the sample results based on total counts accumulated.

6.

Curie (Ci): A measure of radioactivity; equal to 3.7 x 1010 disintegrations per second, or 2.22 x 1012 disintegrations per minute.

7.

Direct Radiation Monitoring: The measurement of radiation dose at various distances from the plant is assessed using thermoluminescent dosimeters (TLDs), optically stimulated luminescent dosimeters (OSLDs), and/or pressurized ionization chambers.

8.

Grab Sample: A single discrete sample drawn at one point in time.

9.

Indicator: A sampling location that is potentially affected by plant effluents due to its proximity and/or direction from the plant.

10.

Ingestion Pathway: The ingestion pathway includes milk, fish, drinking water and garden produce. Also sampled (under special circumstances) are other media such as vegetation or animal products when additional information about particular radionuclides is needed.

11.

ISFSI: Independent Spent Fuel Storage Installation

12.

LLD: Lower Limit of Detection. An a priori measure of the detection capability of a radiochemistry measurement based on instrument setup, calibration, background, decay time, and sample volume. An LLD is expressed as an activity concentration. The MDA is used for reporting results. LLD are specified by a regulator, such as the NRC and are typically listed in the ODCM.

13.

MDA: Minimum Detectable Activity. For radiochemistry instruments, the MDA is the a posteriori minimum concentration that a counting system detects. The smallest concentration or activity of radioactive material in a sample that will yield a net count above instrument background and that is detected with 95%

probability, with only 5% probability of falsely concluding that a blank observation represents a true signal.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 4 of 35 Company: Constellation I Plant: James A FitzPatrick NPP

14.

MDC: Minimum Detectable Concentration. Essentially synonymous with MDA for the purposes of radiological monitoring.

15.

Mean: The sum of all of the values in a distribution divided by the number of values in the distribution, synonymous with average.

16.

Microcurie (µCi): 3.7 x 104 disintegrations per second, or 2.22 x106 disintegrations per minute.

17.

millirem (mrem): 1/1000 rem; a unit of radiation dose equivalent in tissue.

18.

Milliroentgen (mR): 1/1000 Roentgen; a unit of exposure to X-or gamma radiation.

19.

N/A: Not Applicable

20.

NEI: Nuclear Energy Institute

21.

NRC: Nuclear Regulatory Commission

22.

ODCM: Offsite Dose Calculation Manual

23.

OSLO: Optically Stimulated Luminescence Dosimeter

24.

Protected Area: A 10 CFR 73 security term is an area encompassed by physical barriers and to which access is controlled for security purposes. The fenced area immediately surrounding the plant and around ISFSI are commonly classified by the licensee as "Protected areas." Access to the protected area requires a security badge or escort.

25.

PWR: Pressurized Water Reactor

26.

REC: Radiological Effluent Control

27.

REMP: Radiological Environmental Monitoring Program

28.

Restricted Area: A 10 CFRR 20 defined term where access to which is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

29.

TEDE: Total Effective Dose Equivalent (TEDE) means the sum of the effective dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures).

30.

TLD: Thermoluminescent Dosimeter

31.

TRM: Technical Requirements Manual

32.

TS: Technical Specification

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 5 of 35 Company: Constellation I Plant: James A FitzPatrick NPP

33.

Unrestricted Area: An area, access to which is neither limited nor controlled by the licensee.

2.0 EXECUTIVE

SUMMARY

James A FitzPatrick (JAF) Radiological Effluent Control (REC) Program was established to limit the quantities of radioactive material that may be released based on calculated radiation doses or dose rates. Dose to Members of the Public due to radioactive materials released from the plant is limited by Technical Specifications, 10 CFR 20, and by 40 CFR 190. Operational doses to the public during 2024 were calculated to be within the limits required by regulation and compared to other sources of radiation dose and pose no health hazard. These doses are summarized and compared to the regulatory limits in Section 2.1 Comparison to Regulatory Limits below.

The Annual Radioactive Effluent Release Report (ARERR) is published per REC requirements and provides data related to plant operation, including: quantities of radioactive materials released in liquid and gaseous effluents; radiation doses to members of the public; solid radioactive waste shipped offsite for processing or direct disposal; and other information as required by site licensing documents.

In 2024, the gaseous effluent dose assessments for locations from the Land Use Census showed that the critical receptor for James A FitzPatrick is Child, due to Carbon-14. The maximum Annual Organ Dose calculated for this receptor was 3.157E-2 mRem, to the bone.

The maximum dose calculated to any organ due to radioactive liquid effluents was 4.029E-6 mRem, for Child Total Body.

Solid radioactive waste shipped offsite for processing or direct disposal included 4.34E+1 Curies and 8.68E+2 m3, shipped in 42 shipments.

In addition to monitoring radioactive effluents, JAF and Nine Mile Point (NMP)

Nuclear Power Plant share a Radiological Environmental Monitoring Program (REMP) that monitors for levels of radiation and radioactive materials in the local environment. Data from the REMP is published in the Annual Radiological Environmental Operating Report (AREOR).

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 6 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 2.1 Comparison to Regulatory Limits During 2024 all solid, liquid, and gaseous radioactive effluents from James A FitzPatrick were well below regulatory limits, as summarized in Table 1 and Table 2.

Table 1, James A FitzPatrick Unit 1 Dose Summary1 Quarter 1 Quarter 2 Quarter 3 Quarter 4 Annual Liquid Effluent Limit 1.5 mrem 1.5 mrem 1.5 mrem 1.5 mrem 3mrem Dose Limit, Total Body Dose 1.810E-6 7.034E-7 5.489E-7 9.672E-7 4.029E-6 Total Body

% of Limit 1.207E-4 4.689E-5 3.659E-5 6.448E-5 1.343E-4 Liquid Effluent Limit 5mrem 5mrem 5mrem 5mrem 10 mrem Dose Limit, Max Organ Dose 1.810E-6 7.034E-7 5.489E-7 9.672E-7 4.029E-6 Any Organ

% of Limit 3.620E-5 1.407E-5 1.098E-5 1.934E-5 4.029E-5 Gaseous Effluent Limit 5 mrad 5 mrad 5 mrad 5 mrad 10 mrad Dose Limit, Gamma Air Dose 1.692E-4 1.866E-4 1.633E-4 1.027E-4 6.219E-4 Gamma Air (Noble Gas)

% of Limit 3.384E-3 3.733E-3 3.267E-3 2.054E-3 6.219E-3 Gaseous Effluent Limit 10 mrad 10 mrad 10 mrad 10 mrad 20 mrad Dose Limit, Beta Air Dose 1.745E-5 1.702E-5 1.516E-5 1.049E-5 6.011 E-5 Beta Air (Noble Gas)

% of Limit 1.745E-4 1.702E-4 1.516E-4 1.049E-4 3.006E-4 Gaseous Effluent Limit 7.5 mrem 7.5 mrem 7.5 mrem 7.5 mrem 15 mrem Organ Dose Limit Max Organ Dose 4.468E-4 5.184E-4 2.163E-3 1.703E-4 3.299E-3 (Iodine, Tritium, Particulates with

> 8-day half-life)

% of Limit 5.957E-3 6.912E-3 2.884E-2 2.270E-3 2.199E-2 1 Table 1 demonstrates compliance with 10 CFR Part 50, App. I Limits.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 7 of 35 Company: Constellation I Plant: James A FitzPatrick NPP Table 2, Total Annual Offsite-Dose Comparison to 40 CFR 190 Limits for JAF2 Whole Body Thyroid Max Other Organ Liquid Effluents 4.03E-06 4.03E-06 4.03E-06 Gaseous Effluents, excluding C-1.62E-3 3.98E-3 1.63E-3 143 Carbon-14 6.31 E-3 3.16E-2 3.16E-2 Direct Radiation 0.00E+0 0.00E+0 0.00E+0 Total Site Dose 7.93E-3 3.56E-2 3.32E-2 Total w/Other Nearby Facility4 7.42E-2 2.02E-1 2.51 E-1 Limit 25 mrem 75 mrem 25 mrem

% of Limit 2.97E-1 2.70E-1 1.01E+0 2 Table 2 is a summation of Units to show compliance with 40 CFR Part 190 Limits.

3 Gaseous dose values in Table 2 include organ dose from Noble Gas, Iodine, Tritium, and particulates.

4 Other fuel cycle sources within 5 miles of the site are considered in this analysis.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 8 of 35 Company: Constellation I Plant: James A FitzPatrick NPP

3.0 INTRODUCTION

3.1 About Nuclear Power Commercial nuclear power plants are generally classified as either Boiling Water Reactors (BWRs) or Pressurized Water Reactors (PWRs), based on their design. A BWR includes a single coolant system where water used as reactor coolant boils as it passes through the core and the steam generated is used to turn the turbine generator for power production. A PWR, in contrast, includes two separate water systems: radioactive reactor coolant and a secondary system. Reactor coolant is maintained under high pressure, preventing boiling. The high-pressure coolant is passed through a heat exchanger called a steam generator where the secondary system water is boiled, and the steam is used to turn the turbine generator for power production.

Containment Stnlctirc Figure 1, Pressurized Water Reactor (PWR) [1]

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 9 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 3.1 (Continued)

Containment Structure Figure 2, Boiling Water Reactor (BWR) [2]

Electricity is generated by a nuclear power plant similarly to the way that electricity is generated at other conventional types of power plants, such as those powered by coal or natural gas. Water is boiled to generate steam; the steam turns a turbine that is attached to a generator and the steam is condensed back into water to be returned to the boiler. What makes nuclear power different from these other types of power plants is that the heat is generated by fission and decay reactions occurring within and around the core containing fissionable uranium (U-235).

Nuclear fission occurs when certain nuclides (primarily U-233, U-235, or Pu-239) absorb a neutron and break into several smaller nuclides (called fission products) as well as producing some additional neutrons.

Fission results in production of radioactive materials including gases and solids that must be contained to prevent release or treated prior to release. These effluents are generally treated by filtration and/or hold-up prior to release. Releases are generally monitored by sampling and by continuously indicating radiation monitors. The effluent release data is used to calculate doses in order to ensure that dose to the public due to plant operation remains within required limits.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 10 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 3.2 About Radiation Dose Ionizing radiation, including alpha, beta, and gamma radiation from radioactive decay, has enough energy to break chemical bonds in tissues and result in damage to tissue or genetic material. The amount of ionization that will be generated by a given exposure to ionizing radiation is quantified as dose. Radiation dose is generally reported in units of millirem (mrem) in the US.

Computed tomography (medical)

(24%)

Terrestrial (background)

(3%)

Nuclear medicine (medical)

(12%)

Space (background)

(5%)

lnterventional fluoroscopy (medical)

(7%)

Radon & thoron (background)

(37%)

Industrial

(<0.1%)

Occupational

(<0.1%)

Consumer (2%)

Conventional radiography/fluoroscopy (medical)

(5%)

Figure 3, Sources of Radiation Exposure (NCRP Report No. 160) [3]

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 11 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 3.2 (Continued)

The National Council on Radiation Protection (NCRP) has evaluated the population dose for the US and determined that the average individual is exposed to approximately 620 mrem per year [3]. There are many sources for radiation dose, ranging from natural background sources to medical procedures, air travel, and industrial processes. Approximately half (31 O mrem) of the average exposure is due to natural sources of radiation including exposure to radon, cosmic radiation, and internal radiation and terrestrial due to naturally occurring radionuclides. The remaining 310 mrem of exposure is due to man-made sources of exposure, with the most significant contributors being medical (48% of total mrem per year) due to radiation used in various types of medical scans and treatments. Of the remaining 2%

of dose, most is due to consumer activities such as air travel, smoking cigarettes, and building materials. A small fraction of this 2% is due to industrial activities including generation of nuclear power.

Readers that are curious about common sources and effects of radiation dose that they may encounter can find excellent sources of information from the Health Physics Society, including the Radiation Fact Sheets [4], and from the US Nuclear Regulatory Commission website [5].

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 12 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 3.3 About Dose Calculation Concentrations of radioactive material in the environment resulting from plant operations are very small and it is not possible to determine doses directly using measured activities of environmental samples. To overcome this, dose calculations based on measured activities of effluent streams are used to model the dose impact for Members of the Public due to plant operation and effluents. There are several mechanisms that can result in dose to Members of the Public, including: Ingestion of radionuclides in food or water; Inhalation of radionuclides in air; Immersion in a plume of noble gases; and Direct Radiation from the ground, the plant or from an elevated plume.

0 u** :Behavior of raclionuc;lides Figure 4, Potential exposure pathways to Members of the Public due to Plant Operations [6]

Each plant has an Offsite Dose Calculation Manual (ODCM) that specifies the methodology used to obtain the doses in the Dose Assessment section of this report.

The dose assessment methodology in the ODCM is based on NRC Regulatory Guide 1.109 [7] and NUREG-0133 [8]. Doses are calculated by determining what the nuclide concentration will be in air, water, on the ground, or in food products based on plant effluent releases. Release points are continuously monitored to quantify what concentrations of nuclides are being released. For gaseous releases meteorological data is used to determine how much of the released activity will be present at a given location outside of the plant either deposited onto the ground or in gaseous form.

Intake patterns and nuclide bio-concentration factors are used to determine how much activity will be transferred into animal milk or meat. Finally, human ingestion factors and dose factors are used to determine how much activity will be consumed and how much dose the consumer will receive. Inhalation dose is calculated by determining the concentration of nuclides and how much air is breathed by the individual.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 13 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 3.3 (Continued)

For liquid releases, dilution and mixing factors are used to model the environmental concentrations in water. Drinking water pathways are modeled by determining the concentration of nuclides in the water at the point where the drinking water is sourced (e.g., taken from wells, rivers, or lakes). Fish and invertebrate pathways are determined by using concentration at the release point, bioaccumulation factors for the fish or invertebrate and an estimate of the quantity of fish consumed.

Each year a Land Use Census is performed to determine what potential dose pathways currently exist within a five-mile radius around the plant, the area most affected by plant operations. The Annual Land Use Census identifies the locations of vegetable gardens, nearest residences, milk animals and meat animals. The data from the census is used to determine who is the likely to be most exposed to radiation dose as a result of plant operation.

There is significant uncertainty in dose calculation results, due to modeling dispersion of material released and bioaccumulation factors, as well as assumptions associated with consumption and land-use patterns. Even with these sources of uncertainty, the calculations do provide a reasonable estimate of the order of magnitude of the exposure. Conservative assumptions are made in the calculation inputs such as the number of various foods and water consumed, the amount of air inhaled, and the amount of direct radiation exposure from the ground or plume, such that the actual dose received are likely lower than the calculated dose. Even with the built-in conservatism, doses calculated for the maximum exposed individual due to plant operation are a very small fraction of the annual dose that is received due to other sources. The calculated doses due to plant effluents, along with REMP results, serve to provide assurance that radioactive effluents releases are not exceeding safety standards for the environment or people living near the plant.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 14 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 4.0 4.1 DOSE ASSESSMENT FOR PLANT OPERATIONS Regulatory Limits Regulatory limits are detailed in station licensing documents such as the plant Technical Specifications and the Offsite Dose Calculation Manual (ODCM) and Regulatory Guide 1.109, "Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents from the Purpose of Evaluating Compliance with 1 OCFR Part 50, Appendix I," Revision 1, Regulatory Guide 1.113, "Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," Revision 1, and Regulatory Guide 1.111, "Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Cooled Reactors," Revision 1. These documents contain the limits to which JAF must adhere. JAF drives to maintain the philosophy to keep dose "as low as is reasonably achievable" (ALARA) and actions are taken to reduce the amount of radiation released to the environment. Liquid and gaseous release data show that the dose from JAF is well below the ODCM limits. The instantaneous concentration of liquid radioactive material released shall be limited to ten times the concentration specified in 10 CFR 20, Appendix B, Table 2, Column 2, for radionuclides other than dissolved or entrained noble gases. For dissolved or entrained noble gases, the total concentration released shall be limited to 2.0 x 10-4 microcuries/ml.

The annual whole body, skin and organ dose was computed using the 2024 source term using the dose calculation methodology provided in the ODCM. The calculated doses due to gaseous effluents are used to demonstrate compliance with offsite dose limits are presented in Table 1, James A FitzPatrick Unit 1 Dose Summary and Table 2, Total Annual Offsite-Dose Comparison to 40 CFR 190 Limits for JAF.

4.2 Regulatory Limits for Gaseous Effluent Doses

1.

Fission and activation gases:

a.

Noble gases 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 the following:

1)

Less than or equal to 500 mrem/year to the total body

2)

Less than or equal to 3000 mrem/year to the skin

b.

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

1)

Quarterly a)

Less than or equal to 5 mrads gamma b)

Less than or equal to 10 mrads beta

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 15 of 35 Company: Constellation I Plant: James A FitzPatrick NPP

2)

Yearly a)

Less than or equal to 10 mrads gamma b)

Less than or equal to 20 mrads beta 4.2 (Continued) 4.3

2.

Iodine, tritium, and all radionuclides in particulate form with half-lives greater than 8 days.

a.

The dose rate for iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from the site to areas at and beyond the site boundary shall be limited to the following:

1)

Less than or equal to 1500 mrem/yr to any organ

b.

The dose to a MEMBER OF THE PUBLIC from iodine-131, iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 DAYS in gaseous effluents released, from each reactor unit, to areas at and beyond the site boundary shall be limited to the following:

1)

Quarterly a)

Less than or equal to 7.5 mrem to any organ

2)

Yearly a)

Less than or equal to 15 mrem to any organ Regulatory Limits for Liquid Effluent Doses

1.

The dose or dose commitment to a MEMBER OF THE PUBLIC from radioactive materials in liquid effluents released, from each reactor unit, to unrestricted areas shall be limited to the following:

a.

Quarterly

1)

Less than or equal to 1. 5 mrem total body

2)

Less than or equal to 5 mrem critical organ

b.

Yearly

1)

Less than or equal to 3 mrem total body

2)

Less than or equal to 10 mrem critical organ

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 16 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 4.4 40 CFR 190 Regulatory Dose Limits for a Member of the Public

1.

Total Dose (40 CFR 190)

a.

The annual (calendar year) dose or dose commitment to any MEMBER OF THE PUBLIC in the unrestricted area due to releases of radioactivity and to radiation from uranium fuel cycle sources shall be limited to the following:

1)

Less than or equal to 25 mrem, Total Body or any Organ except Thyroid.

2)

Less than or equal to 75 mrem, Thyroid.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 17 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 5.0 SUPPLEMENTAL INFORMATION 5.1 Gaseous Batch Releases 5.1.1 JAF Unit 1 Number of batch releases 43 Total time period for batch releases 5.108E+4 minutes Maximum time period for a batch release 1.004E+4 minutes Average time period for a batch release 1.188E+3 minutes Minimum time period for a batch release 2.000E+1 minutes 5.2 Liquid Batch Releases 5.2.1 JAF Unit 1 Number of batch releases 6

Total time period for batch releases 2.285E+3 minutes Maximum time period for a batch release 1.471 E+3 minutes Average time period for a batch release 3.808E+2 minutes Minimum time period for a batch release 7.000E+0 minutes 5.3 Abnormal Releases 5.3.1 Gaseous Abnormal Releases Number of releases 8

Total activity released 6.103E-9 Ci Abnormal releases were during the Refuel Outage near a rolled-up door in the Turbine Building. Sample equipment was positioned to continuously collect a representative sample for the duration of the door being opened.

5.3.2 Liquid Abnormal Releases Number of releases 0

Total activity released 0 Ci There were no abnormal liquid releases.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 18 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 5.4 5.5 5.6 Land Use Census Changes In accordance with the James A FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Section 6.2.3, a listing of new locations for dose calculation and/or environmental monitoring identified by the lad use census shall be included in the Annual Radioactive Effluent Report.

During the reporting period, no changes in Dose Calculation Receptor Locations and/or the Environmental Monitoring were required based on the results of the land use census.

Meteorological Data The James A FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Sections 6.2 and 6.2.2 states in part:

The Annual Radioactive Effluent Release Report submitted prior to May 1 of each year may include an annual summary of meteorological data collected over the previous year. Meteorological data is not included. The licensee shall retain it on file and provide it to the U.S. Nuclear Regulatory Commission upon Request.

Effluent Radiation Monitors Out of Service Greater Than 30 Days In accordance with the James A FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Sections 2.1.3.2.B and 3.1.3.1.A, corrective actions should be taken to return the operability of Effluent Monitoring Instrumentation within 30 days, otherwise report why the inoperability was not corrected.

No Effluent Radiation Monitors were out of service consecutively for the time listed in the ODCM or Technical Specification (30 Days).

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 19 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 5.7 Offsite Dose Calculation Manual (ODCM) Changes 5.8 5.9 In accordance with the James A FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluents Controls Section 6.2.3, any change made to the PCP or the ODCM during the reporting period shall be included in the Annual Radioactive Effluent Release Report.

During the reporting period, no changes were made to the Offsite Dose Calculation Manual (ODCM).

Process Control Program (PCP) Changes In accordance with the James A FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1 Radiological Effluent Controls Section 6.2.3, changes made to the Process Control Program (PCP) during the reporting period shall be included in the Annual Radioactive Effluent Release Report.

No changes were made to the PCP.

Radioactive Waste Treatment System Changes In accordance with the James A FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Sections 6.2.10 and 7.0, Major Modifications to Radioactive Waste Treatment Systems (liquid, gaseous, and solid) shall be reported in the Annual Radioactive Effluent Release Report for the period in which the modification is completed and made operational.

There were no major modifications to any liquid, gaseous, or solid radioactive waste treatment systems.

5.10 Other Supplemental Information 5.10.1 Outside Tanks In accordance with the James A FitzPatrick Nuclear Power Plant Offsite Dose Calculation Manual (ODCM), Part 1, Radiological Effluent Controls Section 6.2.9, the report shall contain the events leading to the conditions which resulted in exceeding the radioactivity limits for the specified outdoor radioactivity radwaste tanks specified in the Technical Requirements Manual. TRM 3.7.E.

The radioactivity limits for the specified outdoor radioactive radwaste tanks were not exceeded.

5.10.2 Independent Spent Fuel Storage Installation {ISFSI) Monitoring Program Information concerning the ISFSI Monitoring Program and annual dose can be found in the appropriate reporting year JAF/NMP Annual Radiological Environmental Operating Report, which is published on the NRC's website.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 20 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 5.10.3 Carbon-14 Carbon-14 (C-14) is a naturally occurring radionuclide with a 5,730-year half-life.

Nuclear weapons testing in the 1950s and 1960s significantly increased the amount of C-14 in the atmosphere. Nuclear power plants also produce C-14, but the amount is infinitesimal compared to what has been distributed in the environment due to weapons testing and what is produced by natural cosmic ray interactions.

In accordance with Regulatory Guide 1.21, "Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste," the NRC recommended re-evaluating "principal radionuclides" and reporting C-14 as appropriate. Carbon-14 production and release estimates were calculated using active core coolant mass, average neutron flux by energy and reactor coolant nitrogen concentrations to determine Carbon-14 generation based upon an effective full power year. The estimated generation for James A FitzPatrick during 2024 was 10.0 Curies.

Public dose estimates were performed using methodology from the ODCM which is based on Regulatory Guide 1.109 methodology. C-14 dose is included in dose calculation results in Table 2.

5.10.4 Errata/Corrections to Previous ARERRs No errata or corrections for previous reporting periods are submitted by this report. In addition, no errata or corrections were submitted for previous reporting periods by a separate correspondence during this reporting period. A summary for previous Annual Radioactive Effluent Release Reports, including Corrections and Errata, can be found on the NRC's website: https://www.nrc.gov/reactors/operating/ops-experience/tritium/plant-specific-reports/fitz.html

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 21 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 6.0 NEI 07-07 ONSITE RADIOLOGICAL GROUNDWATER MONITORING PROGRAM James A FitzPatrick has developed a Groundwater Protection Initiative (GPI) program in accordance with NEI 07-07, Industry Ground Water Protection Initiative-Final Guidance Document [9]. The purpose of the GPI is to ensure timely detection and an effective response to situations involving inadvertent radiological releases to groundwater in order to prevent migration of licensed radioactive material off-site and to quantify impacts on decommissioning. FitzPatrick Nuclear Power Plant has a total of 22 wells, (seven Background designated wells, two Mid-Field designated wells, two Perimeter designated wells, and eleven Source designated wells), and one Reactor Building Perimeter Drain Sump (RBPDS) (sampled as a Source designated sample point), that are sampled as part of the Radiological Groundwater Protection Program (RGPP). The RBPDS has historically been sampled weekly for tritium by site Chemistry per the ODCM and these results are also used for RGPP monitoring.

During 2024, JAF collected and analyzed groundwater samples in accordance with the requirements of EN-JF-408-4160.

This section is included in this report to communicate results of NEI 07-07 Radiological Groundwater Monitoring Program. Monitoring wells installed as part of GPI program are sampled and analyzed as summarized in Table 3, Groundwater Protection Program Monitoring Well Sample Schedule. In addition to reporting results from NEI 07-07 monitoring wells, voluntary communications to offsite governmental agencies for onsite leaks or spills per NEI 07-07 Objective 2.2, are also reported as part of this report. It is important to note, samples and results taken in support of NEI 07-07 groundwater monitoring program are not part of the Radiological Environmental Monitoring Program (REMP) but should be reported as part of ARERR.

Table 3, Groundwater Protection Program Monitoring Well Sample Schedule Well Name Tritium Gamma HTD Gross Alpha Strontium MW-1A MW-2A MW-3A MW-4A MW-48 MW-6 MW-7 Every 2 years Every 5 years Every 2 years Quarterly (Sampled in (Sampled last in (Sampled in Annually MW-13 2024) 2021)*

2024)

MW-14 MW-15 MW-16 RBPDS (Reactor Building Perimeter Drain Sump)

Annual Radioactive Effluent Release Report l YEAR: 2024 l Page 22 of 35 Company: Constellation I Plant: James A FitzPatrick NPP MW-2B Semi-Every 2 years MW-3B Annually (Sampled in Not Required Not Required Not Required 2024)

MW-1B MW-5 MW-8 MW-9 Every 2 years MW-10A Annually (Sampled in Not Required Not Required Not Required MW-10B 2024)

MW-19 MW-20 MW-21

RBPDS sample was collected and analyzed in 2024, once included in the RGPP, and will be collected on the same sampling frequency as the other samples going forward.

Radiological Groundwater Monitoring Program tritium results are summarized in Table 4, Groundwater Protection Program Monitoring Well Tritium Results.

Gamma-radionuclide analysis was most recently performed during the 2nd quarter 2024 RGPP sampling round. Gamma radionuclides were not detected at concentrations exceeding their respective LLDs in 2024.

The most recent hard-to-detects (Fe-55 and Ni-63) analyses were performed on samples collected from Source designated wells was in 2021. Hard-to-detects (Fe-55 and Ni-63) were not detected in the samples collected in 2021. The 3rd quarter 2024 sample collected from the RBPDS was analyzed for hard-to-detects (Fe-55 and Ni-63). Fe-55 and Ni-63 were not detected in the 3rd quarter RBPDS sample.

Gross-alpha analysis was most recently performed during the 1st quarter 2024 RGPP sampling round for the eleven Source designated monitoring wells, and 3rd quarter 2024 for the sample collected from the RBPDS. Gross-alpha (dissolved and suspended fractions) was not detected at concentrations greater than the established Alert Level in the samples collected in 2024.

Sr-89 and Sr-90 analysis was performed on samples collected from Source designated wells and RBPDS during the 3rd quarter 2024 RGPP sampling round. No detections of Sr-89 and Sr-90 were reported in the samples collected during the 3rd quarter 2024 RGPP sampling round.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 23 of 35 Company: Constellation I Plant: James A FitzPatrick NPP Table 4, Groundwater Protection Program Monitoring Well Tritium Results Number of Number of Average Maximum Well Name Positive Analyses Concentration 5 Concentration Detections (pCi/L)

(pCi/L)

MW-1A 0

5

<LLD

<LLD MW-1B 0

2

<LLD

<LLD MW-2A 2

5 246 282 MW-2B 1

3 211 211 MW-3A 3

4 285 324 MW-3B 1

2 197 197 MW-4A 2

4 292 299 MW-4B 0

4

<LLD

<LLD MW-5 1

1 275 275 MW-6 3

4 238 308 MW-7 1

4 220 220 MW-8 1

1 239 239 MW-9 0

1

<LLD

<LLD MW-10A 0

1

<LLD

<LLD MW-10B 0

1

<LLD

<LLD MW-13 2

5 262 265 MW-14 0

4

<LLD

<LLD MW-15 0

4

<LLD

<LLD MW-16 2

4 215 236 MW-19 0

1

<LLD

<LLD MW-20 0

1

<LLD

<LLD MW-21 0

1

<LLD

<LLD RBPDS 46 53 1718 3496 6.1 Voluntary Notification During 2024, James A FitzPatrick did not make any voluntary NEI 07-07 notifications to State/Local officials, NRC, and to other stakeholders required by site procedures.

5 Results <MDC should not be included in the average concentration calculation.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 24 of 35 Company: Constellation I Plant: James A FitzPatrick NPP 7.0 BIBLIOGRAPHY

[1] Nuclear Regulatory Commission, 30 June 2015. [Online]. Available: http://www.nrc.gov/reading-rm/basic-ref/students/animated-pwr.html. [Accessed October 2020].

[2] Nuclear Regulatory Commission, 25 June 2015. [Online]. Available: http://www.nrc.gov/reading-rm/basic-ref/students/animated-bwr.html. [Accessed October 2020].

[3] "NCRP Report No. 160 - Ionizing Radiation Exposure of the Population of the United States,"

National Council on Radiation Protection and Measurements, Bethesda, MD, 2009.

[4] Health Physics Society, [Online]. Available: http://hps.org/hpspublications/radiationfactsheets.html.

[Accessed 2020].

[5] "NRC Resource Page," [Online]. Available: http://www.nrc.gov/about-nrc/radiation.html. [Accessed 10 November 2020].

[6] "Japan Atomic Energy Agency," 06 November 2020. [Online]. Available:

https://www.jaea.go.jp/english/04/ntokai/houkan/houkan_02.html.

[7] "Regulatory Guide 1.109 - Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Demonstrating Compliance with 10 CFR Part 50, Appendix I," Nuclear Regulatory Commission, Ocotober, 1977.

[8] "NUREG-0133 - Preparation of Effluent Technical Specifications for Nuclear Power Plants,"

Nuclear Regulatory Commission, 1987.

[9] "NEI 07 Industry Ground Water Protection Initiative -

Final Guidance Document, Rev. 1,"

Nuclear Energy Institute, Washington, D.C., 2019.

[10] "10 CFR 50 - Domestic Licensing of Production and Utilization Facilities," US Nuclear Regulatory Commission, Washington, DC.

[11] "40 CFR 190 - Environmental Radiation Protection Standards for Nuclear Power Operation," US Environmental Protection Agency, Washington, DC.

[12] "10 CFR 20- Standards for Protection Against Radiation," US Nuclear Regulatory Commission, Washington, DC.

[13] "40 CFR 141 - National Primary Drinking Water Regulations," US Environmental Protection Agency, Washington, DC..

[14] "NUREG-0324 - XOQDOQ, Program for the Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations," Nuclear Regulatory Commission, September, 1977.

[15] "NUREG-1301 - Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors," Nuclear Regulatory Commission, April 1991.

[16] "NUREG-1302-Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors," Nuclear Regulatory Commission, April 1991.

[17] "Regulatory Guide 4.13 - Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Applications, Revision 2," Nuclear Regulatory Commision, June, 2019.

[18] "Regulatory Guide 4.15 - Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination) -- Effluent Streams and the Environment,"

Nuclear Regulatory Commission, July, 2007.

Annual Radioactive Effluent Release Report I YEAR: 2024 I Page 25 of 35 Company: Constellation I Plant: James A FitzPatrick NPP, ARERR Release Summary Tables (RG-1.21 Tables)

- The following Tables utilize double asterisk to indicate concentrations lower than the limit of detection 1.0 GASEOUS EFFLUENTS Table 5, Gaseous Effluents Summation of All Releases JAF Unit 1 6 A

Fission & Activation Gases Units Quarter 1 Quarter 2 Quarter 3 Quarter 4 Est. Total Error%

1.

Total Release Ci 5.738E+0 5.923E+0 5.815E+0 3.171E+0 S2.50E+1

2.