ML11256A057

Documents to Support Review of the South Texas Project License Renewal Application, List of Transmitted Documents Including Copy of Each Document, Enclosure to NOC-AE-11002720

ML11256A057
Person / Time
Site:	South Texas
Issue date:	08/31/2011
From:	Harrison A W South Texas
To:	Office of Nuclear Reactor Regulation
References
TAC ME4938, TAC ME5122, G25, NOC-AE-11002720, STI: 32917986
Download: ML11256A057 (528)

Text

{{#Wiki_filter:Enclosure NOC-AE-1 1002720 Page 1 of 3 List of transmitted documents including copy of each document Terrestrial Ecology TER-1 Department of Army letter with enclosed map of wetland delineation [STPLR-422] TER-2 STPNOC Site Environmental Compliance, Rev.13, OPGP03-ZO-0025, April 2011[STPLR-26] TER-3 Austin Energy T-Line ROW Management Summary, January 1, 2010 [STPLR-446] TER-4 Austin Energy Tree Pruning and T-line Clearance Specs, November 7, 2005,[STPLR-448] TER-5 Pesticides and herbicides associated with operational maintenance of the transmission lines [STPLR-410] Aquatic Ecology AQ-1 McAden, D. C., G. N. Greene, and W. B. Baker 1984. Colorado River Entrainment and Impingement Monitoring Program, Phase Two Studies -July 1983-June 1984 (Report# 1). Prepared for South Texas Project by Ecology Division, Environmental Protection Department, Houston Lighting & Power Company. October.AQ-2 McAden, D. C., G. N. Greene, and W. B. Baker 1985. Colorado River Entrainment and Impingement Monitoring Program, Phase Two Studies -July -December 1984 (Report # 2). Prepared for South Texas Project by Ecology Division. Environmental Protection Department. Houston lighting & Power Company. April.AQ-3 Citation and documentation is needed for the following sentence that was included in the ER, Section 5.2: Based upon best professional judgment (BPJ) the TCEQ Water Quality Division has determined that the CWIS reflects BTA for AEI through use of a closed-cycle recirculating system.AQ-4 "Essential Cooling Pond Fish Population Study." Prepared for STP Nuclear Operating Company by ENSR International, Houston, Texas, May 2002.AQ-5 Texas Commission on Environmental Quality (TCEQ). 2007. Letter from Mr. Kelly Holligan, TCEQ, to Mr. R. A. Gangluff, STPNOC, dated June 27,2007, "Cooling Water Intake Structures Phase II Rules; South Texas Project Electric Generating Station; TPDES Permit No. WQOOO 1908000." This letter (or other documentation) should state that the Main Cooling Reservoir (MCR) is not waters of the State.AQ-6 "South Texas Project, Units 1 and 2, Environmental Report," Docket Nos. 50-498 and 50-499, July 1, 1974, and Subsequent Amendments. (Transmittal of this report is planned for submittal within 30 days of this letter) Enclosure NOC-AE-1 1002720 Page 2 of 3 AQ-7 Baker W. B., Green G. N. 1989, 1987-1988 Special Ecological Studies for the South Texas Project, Matagorda County, Texas. Final report March 1989. Houston, TX: Houston Lighting & Power Company. 34 p. [in Terrestrial Ecology section of STP NRC Environmental Audit Binder]AQ-8 Ducks Unlimited and HPLC. 1996. Wetland Development Agreement for the Texas Prairie Wetland Project, Gulf Coast Joint Venture, between Ducks Unlimited, Inc., and Houston Lighting & Power Co. October 23, 1996. 12 p. [in Terrestrial Ecology section of STP NRC Environmental Audit Binder]AQ-9 ENSR Corporation. 2008. Ecological Survey Report-Habitat Assessment, Units 3 and 4 Licensing Project. Prepared for STP Nuclear Operating Company. Wadsworth, TX: ENSR. 34 p. [In Aquatic Ecology section of STP NRC Environmental Audit Binder]Water Resource WR-1 US Army Corps of Engineers (USACE) Permit No.10570 (Maintenance dredging of barge slip) (dated November 4, 2005).WR-2 USACE Permit No. SWG-1992-02707 (Maintenance dredging of intake) (dated July 21, 2009). [STPLR-472] WR-3 Current TCEQ-issued TPDES permit (TPDES Permit No. WQ0001908000 issued July 21, 2005). [STPLR-05] WR-4 TPDES permit renewal application (June 2009 and May 24,2007, letters)WR-5 TCEQ ID No. 1610103/1610051 (Operation of public potable water system(s)) WR-6 TCEQ Amendment to Certificate of Adjudication 14-5437A (Water rights for diversion and impoundment of Colorado River water). [STPLR-471] WR-7. Water Conservation Plan, STP Nuclear Operating Company, South Texas Project Electric Generating Station, Certificate of Adjudication 14-5437A, May 1, 2009, Revision 2 WR-8 OPOP02-LM-0001. Rev. 41 dated 2/1/2011. Reservoir Makeup Pumping Facility.WR-9 Current groundwater operating permit issued by the Coastal Plains Groundwater Conservation District. [STPLR-468] WR-10 Conceptual Site Model for Units 1 and 2, Groundwater Protection Initiative, South Texas Project, Electric Generating Station, Wadsworth, Texas, Prepared by MACTEC Engineering and Consulting, Inc., Prepared for STP Nuclear Operating Company, Revision 1, May 20, 2009. [STPLR-375] 1 1 This report contains pages marked "NOT FOR PUBLIC DISCLOSURE." Since the issuance of the report, it is no longer necessary to withhold these pages from public disclosure. Appendix E only includes condition report documentation for Condition Report 06-1056. Enclosure NOC-AE-1 1002720 Page 3 of 3 WR-1 1 A summary of historic and current (past 5 years) total dissolved solids (TDS) data for groundwater produced by STP production wells from the Deep Chicot Aquifer.WR-12 TPDES Discharge Monitoring Reports (covering past 3 years).WR-13 Annual groundwater use reports (covering past 5 years). [In Surface and Groundwater Tab of STP NRC Environmental Audit Binder; e.g., STPLR-13 (2006), etc.]WR-14 Annual surface water withdrawal reports for the Colorado River (covering past 5 years). [In Surface and Groundwater Tab of STP NRC Environmental Audit Binder;e.g., STPLR-14 (2006), STPLR-39 (2007), etc.]WR-15 Data on tritium concentrations in groundwater and surface water observed since the MACTEC report (i.e., materials provided following the protected area tour) as follows: i. Spreadsheet of groundwater monitoring results (no title) for well #s 807-837;dates 2/15/2005-11/9/2010, 3 pages.ii. "Tritium Results in PA Piezometer and New Monitoring Wells" (2005-2011), graph iii. "Historical Comparison of Tritium Activity in Surface and Relief Well Water 1988-2011." Graph with attached spreadsheet, "Tritium in Owner-Controlled Groundwater.xls" (2005-2011), 2 pages.iv. "Historical Comparison of Tritium Activity in Ground Water 1988-2011," 1 page covering wells 255-271.v. "Historical Comparison of Tritium Activity in Ground Water 1988-2010," includes 2011 data covering well #s 258, 270, 259, 235, 251.vi. "Tritium Activity in Shallow Ground Water West of the Main Cooling Reservoir 2006-2011," 1 page covering well #s 271, 270, 258, 259.vii. Spreadsheet with no title of annual frequency of piezometer well and windmills data, covering well #s 206-269, dates 2008-2011, 1 page.viii. Spreadsheet with no title including "quarterly frequency," "old monitoring test wells," "piezometer wells," and "new monitoring wells," covering well #s 235, 251, 205, 258, 259, 266,270, and 271; dates 2005-2011 WR-16 STP Well Location Map (contained in the Field Log Book) TER-1. Department of Army letter with enclosed map of wetland delineation [STPLR-422] STI 32475214 U7-C-ACE-STP-090002 DEPARTMENT OF THE ARMY GALVESTON DISTRICT, CORPS OF ENGINEERS P. O. BOX 1229 GALVESTON TX 77553-1229 May 14, 2009 Compliance Section

SUBJECT:

SWG-2007-786; South Texas Project Nuclear Operating Company, Units 3 & 4, Preliminary Jurisdictional Determination, Wadsworth, Montgomery County, Texas Mr. Russell Kiesling South Texas Project Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483

Dear Mr. Kiesling:

This letter is in response to your April 11, 2008 request for a jurisdictional determination on the proposed project site for the construction of Units 3 & 4. The 1406.5-acre project site is located on Farm-to-Market 521, approximately 8 miles west of Wadsworth, Matagorda County, Texas.Based on the review of the information associated with this request, we determined that the revised delineation map dated May 13, 2009 (enclosed) is a reasonable depiction of the approximate locations of the aquatic resources with the tract. Computation ofjurisdiction made on the basis of this preliminary jurisdictional determination will treat all waters, including wetlands, on the 1406.5-acre tract as jurisdictional water of the United States. As such all aquatic resources, including 17.6 acres of wetlands and 24,639 linear feet of non-wetland waters are subject to Section 404 of the Clean Water Act and will require a Department of the Army permit prior to the discharge of any dredged and/or fill material into these aquatic resources. Wetlands were identified on the tract using the 1987 Corps of Engineers Wetland Delineation Manual which requires that under normal conditions wetlands exhibit wetland hydrology, hydric soils, and hydrophytic vegetation. This determination has been conducted to identify the limits of the Corps' Clean Water Act jurisdiction for the particular site identified in this request. This determination may not be valid for the wetland conservation provisions of the Food Security Act of 1985, as amended. If you or your tenant are USDA program participants, or anticipate participation in USDA programs, you should request a certified wetland determination from the local office of the Natural Resources Conservation Service prior to starting work. This preliminary jurisdictional determination is valid for 5 years from the date of this letter, unless new information warrants a revision prior to the expiration date. An approved jurisdictional determination can be requested at any time. If you have any questions concerning this matter, please reference file number SWG-2007-786 and contact Mr. Nicholas Laskowski at the letterhead address or by telephone at 409-766-6381. Sincerely, Ke yy JaynsýýChief, Compliance Section Enclosures Cc: U.S. Regulatory Commission c/o Jessie Muir M/S T6-D32 11555 Rockville Pike Rockville, MD 20852 e V K~ca~ MII.gWd.-Waters (24,639.1 Linear Feet)EJ Wetlands (17.6 Acres)-]- Project Review Area (1406.5 Acres)=reliminary Jurisdictional Determination South Texas Project Units 3 & 4 Matagorda County, TX W#1 C f SWG-2007-786 May 13, 2009 0 750 1,500 3.000 P"4Cbo, NADI 193 SU"PUMJt.,. Cen". FIPS 4203 FW4 8anck'ou 3 Imagoy P-n. Vwo.1420 TER-2. STPNOC Site Environmental Compliance, Rev. 13, OPGP03-ZO-0025, April 2011 [STPLR- 26] S1 PLQ--c~SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION D0527 STI 32862984 OPGP03-ZO-0025 Rev. 13 Page 1 of 50 Site Environmental Compliance _Non-Quality Non Safety-Related Usage: Available Effective Date: 04/29/11 T Simmons S. Dannhardt R. Hotstream Chemistry PREPARER TECHNICAL USER COGNIZANT DEPT.Table of Contents Pane 1.0 Purpose and Scope .......................................................................................................................... 3 2 .0 D efi n ition s ....................................................................................................................................... 3 3 .0 R esp on sib ilities ............................................................................................................................... 6 4 .0 P rocedu re ............................................................... ....................................................................... 10 4.1 W ildlife Protection and Control ....................................................................................... 10 4.2 Plant Effluent Permit Requirements .................................................................................. 11 4.3 Plant Air Emissions Requirements ................................................................................... 12 4.4 Plant Solid W aste Requirements ....................................................................................... 15 4.5 Plant Drainage Requirements ........................................................................................... 17 4.6 Hazardous and Nonhazardous W aste Accumulation and Disposal .................................. 18 4.7 Oil/Chemical Product Storage ........................................................................................ 20 4.8 Spill Response, Cleanup, and Reporting ........................................................................... 21 4.9 Monitoring and Reporting Requirements ......................................................................... 22 4.10 Land Management .......................................................................................................... 23 4.11 Corrective Action M easures ............................................................................................ 24 4.12 Environmental Compliance Screening ........................................................................... 24 5 .0 R eferen ces ..................................................................................................................................... 2 5 6.0 Support Documents ....................................................................................................................... 27 Form 1, Hazardous W aste Storage Area W eekly Inspection Checklist .................................. 28 Form 2, Monthly Ground W ater Usage Report ......................................................................... 29 Form 3, W astewater Treatment System Sludge Removal Log ................................................ 30 Form 4, Blast Grit Usage Tracking ........................................................................................... 31 Form 5, Surface Coat Facility Operations Tracking ................................................................. 32 Form 6, Degreaser Unit Operations Tracking ........................................................................... 34 Form 7, Storm W ater Sampling ................................................................................................ 35 Form 8, Storm W ater Pollutant Source Monthly Checklist ..................................................... 36 Form 9, Storm W ater Periodic Inspection Checklist ............................................................... 37 rl777777 OPGP03-ZO-0025 Rev. 13 Page 2 of 50 I Site Environmental Compliance l Addendum 1, Examples of Potentially Incompatible Waste/Materials ..................................... 38 Addendum 2, Nonradiological Plant Effluent Standards and Limitations .................................. 41 Addendum 3, Auxiliary Boiler Emission Standards and Limitations ........................................ 44 Addendum 4, Environmental Compliance Screening Questions ............................................... 45 Addendum 5, Unanticipated Discovery of Cultural Resources .............................................. 48 OPGP03-ZO-0025 Rev. 13 I Page 3 of 50 Site Environmental Compliance

1.0 Purpose

and Scope 1.1 This procedure provides guidelines necessary for site compliance with applicable non-radiological environmental laws, regulations, procedures, and commitments at the South Texas Project Electric Generating Station (STPEGS).1.2 This procedure defines those deviations, deficiencies, discrepancies, and items requiring remedial action for correction that constitute an environmental violation. 1.3 This procedure describes the minimum actions which may be taken for notification or prevention of an environmental violation, or subsequent corrective actions if appropriate. 1.4 Each section of this procedure may be performed independently.

2.0 Definitions

2.1 BYPASS

The intentional diversion of waste streams from any portion of a treatment facility (e.g., overflows or discharging a system to other than its designated outfall).2.2 ENVIRONMENTAL PROGRAM COORDINATOR: The individual(s) in the Environmental Division responsible for the environmental program at the STPEGS.2.3 ENVIRONMENTAL PROTECTION AGENCY (EPA): The federal agency responsible for assuring the protection of the environment by abating and controlling pollution on a systematic basis.2.4 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL) (EPP): Plan established to provide for protection of nonradiological environmental values during operation of the South Texas Project Electric Generating Station (STPEGS). This plan is described in Appendix B to the Unit 1 Operating License NPF-76 and Unit 2 Operating License NPF-80, Environmental Protection Plan (Nonradiological).

2.5 ENVIRONMENTAL

VIOLATION: Any deviation, deficiency or discrepancy with established site environmental procedures OR any applicable federal, state, or local laws or regulations.

2.6 HAZARDOUS

MATERIAL: Any substance so designated by the EPA under 40CFR1 16 pursuant to Section 311 of the Clean Water Act; also, any substance used as product defined as hazardous by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) OR, for the purposes of transportation, which contains any constituent or combination thereof as listed in 49CFR172. OPGP03-ZO-0025 j Rev. 13 Page4of 50 Site Environmental Compliance

2.7 HAZARDOUS

WASTE: Any waste material defined as hazardous by the CERCLA OR which contains any constituent or combination thereof as listed in 49CFR172 with the exception of radioactive waste; ALSO, any waste material exhibiting any of the characteristics identified in Subpart C of 40CFR261, OR any waste material listed in Subpart D of 40CFR261, OR any waste material which is ignitable, corrosive, reactive, or toxic to the extent that it may pose a threat to human health, safety, or the environment.

2.8 MIXED

WASTE: Waste that contains both hazardous waste, as defined in this procedure, and source, special nuclear, or byproduct material subject to the Atomic Energy Act of 1954, as amended.2.9 NON-ENGINEERED BERM: A berm which is NOT part of the normal plant design.2.10 NONRADIOACTIVE WASTE MANAGEMENT COORDINATOR: The individual(s) in the Environmental Division that is responsible for coordinating nonradioactive waste disposal activities at the STPEGS.2.11 PRODUCT: New, unused material (excluding articles as defined in 29CFR1910.1200) which could, if released, adversely affect personnel, equipment, the public, and/or the environment. 2.12 RESOURCE CONSERVATION AND RECOVERY ACT OF 1976 (RCRA): The Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act, as amended which authorizes the EPA to regulate current and future waste management and disposal practices. 2.13 SITE: STPEGS as a whole.2.14 SOLID WASTE: Any discarded or waste material as defined in 30TAC335.1 and 40CFR261.2. 2.15 STORAGE: To place or leave in a location for longer than seventy-two (72) hours.2.16 TEXAS COMMISSION on ENVIRONMENTAL QUALITY (TCEQ): The state agency responsible for safeguarding the public and environment by setting and enforcing standards and emission limits for the abatement and control of air pollution and the administration of state water rights, water quality program including potable water, conduct of the state's coastal oil and hazardous spill prevention and control program, state programs involving underground water and water wells, and administration of the national flood insurance program. The TCEQ also oversees all aspects of industrial and municipal hazardous waste, radioactive waste, nonhazardous industrial solid waste, and sewage sludge disposal activities in Texas. (In 1993, the Texas Air Control Board merged with the Texas Water Commission to form the Texas Natural Resources Conservation Commission (TNRCC) which was renamed to the TCEQ in 2003.Portions of the Texas Department of Health (now known as the DSHS) were previously consolidated with the Texas Water Commission in 1992.) OPGP03-ZO-0025 I Rev. 13 Page 5of 50 Site Envir onmental Compliance 2.17 TEXAS DEPARTMENT OF STATE HEALTH SERVICES (DSHS): The state agency responsible for regulating those systems, facilities, and conditions, which, if improperly handled, could have a detrimental impact upon human health. These regulated factors include, but are not limited to asbestos abatement, working conditions, and food quality.2.18 TEXAS HISTORICAL COMMISSION (THC): The state agency responsible for identification of important historic sites and for historic preservation of Texas'architectural, archeological and cultural landmarks. 2.19 TEXAS POLLUTANT DISCHARGE ELIMINATION SYSTEM (TPDES): A program for issuing, enforcing and terminating permits and requirements of applicable sections of the Clean Water Act, as amended. TPDES permits specify the types and amounts of pollutants that may be discharged from wastewater treatment facilities. 2.20 UPSET: An exceptional incident (e.g., unusual amount of flow through a system or an unusual or abnormal input into a system) in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee. An upset does NOT include noncompliance to the extent caused by operational error, improperly designed treatment facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or improper operation. 2.21 WASTE: Any discarded or abandoned material, material used in a manner constituting disposal defined in 40CFR261, OR material intended for disposal (excluding articles as defined in 29CFR1910.1200). OPGP03-ZO-0025 Rev. 13 Page 6 of 50 Site Environmental Compliance

3.0 Responsibilities

3.1 PLANT

MANAGER: The plant manager is responsible for: 3.1.1 Implementing procedures, programs, and guidelines necessary to ensure Site environmental compliance;

3.1.2 Implementing

procedures, programs, or guidelines necessary to ensure Site compliance with Administrative Policy No. STP-415.3.2 DESIGN ENGINEERING DEPARTMENT: The Design Engineering Department is responsible for: -3.2.1 Monitoring and inspection of the Main Cooling Reservoir (MCR) and appurtenant structures and areas excluding electrical/mechanical facilities;

3.2.2 Generation

of records documenting the aforementioned monitoring activities;

3.2.3 Providing

technical assistance as necessary.

3.3 PERSONAL

SAFETY GROUP: The Personal Safety Group is responsible for the implementation of all site environmental programs involving compliance with SARA Title III, Sections 311 and 312.3.4 NUCLEAR LICENSING DEPARTMENT: The Nuclear Licensing Department is responsible for establishing and maintaining mechanisms necessary to ensure STPEGS's responsibilities relative to the reporting of information to the USNRC pursuant to lOCFR50 and any other such legally based requirements (including the annual submittal of the Annual Environmental Operating Report) and the preparation, internal review, and transmittal of written communications to the USNRC.3.5 PLANT ENGINEERING DEPARTMENT: The Plant Engineering Department is responsible for: 3.5.1 Providing system engineers for the Oily Waste Treatment System, Nonradiological Chemical Waste Treatment System, Sanitary Waste Treatment Systems, Potable Water Systems and other systems with associated environmental regulations;

3.5.2 Notifying

appropriate personnel and agencies of open burning activities associated with fire training exercises;

3.5.3 Providing

technical assistance as necessary. OPGP03-ZO-0025 Rev. 13 Page 7 of 50 Site Environmental Compliance

3.6 PLANT

OPERATIONS DEPARTMENT: The Plant Operations Department is responsible for: 3.6.1 Compliant operations of the Oily Waste Treatment System, the Nonradiological Chemical Waste Treatment System, Water Wells Nos. 5, 6, and 7, the Auxiliary Boiler and temporary boiler (if applicable), diesel-driven equipment operated by the Plant Operations Department, the Reservoir Makeup Pumping Facility, the Spillway/Blowdown and other systems or equipment under Plant Operations control with associated environmental regulations as applicable;

3.6.2 Generation

of applicable documentation including logs, records, and reports concerning operations of the aforementioned systems and equipment;

3.6.3 Providing

spill response resources as necessary to conduct and support Plant Operations spill response activities;

3.6.4 Providing

operational support and assistance as necessary.

3.7 FACILITIES

MANAGEMENT DIVISION: The Facilities Management Division is responsible for: 3.7.1 Maintenance and repair of potable water pumping station 8, main potable water pumping station and distribution system outside the Protected Area;3.7.2 Sanitary wastewater collection system outside the Protected Area;3.7.3 Maintenance of the West and Training Sanitary Waste Treatment Systems.3.7.4 Pest control, herbicide application, and municipal trash disposal;3.7.5 Ensuring the site drainage system is free of obstructions and blockages;

3.7.6 Providing

labor support for spill response and cleanup activities;

3.7.7 Construction

of temporary berms;3.7.8 Site dewatering activities;

3.7.9 Transportation

of waste materials to the Hazardous Waste Storage Area;3.7.10 General labor requirements; 3.7.11 Maintenance, repair and operation of facility/building HVAC and cooling water systems exclusive of those under the specific control of Plant Maintenance; 3.7.12 Pest, vermin and animal control. OPGP03-ZO-0025 j Rev. 13 Page 8 of 50 Site Environmental Compliance

3.8 MAINTENANCE

DEPARTMENT: The Maintenance Department is responsible for: 3.8.1 Maintenance and repair of the potable water distribution system and the sanitary wastewater collection system inside the Protected Area;3.8.2 Calibration of instrumentation required by site wastewater discharge permits;3.8.3 Maintenance and repair of Water Wells Nos. 5, 6, & 7 and distribution system.3.9 CHEMISTRY DIVISION: The Chemistry Division is responsible for: 3.9.1 Performing analyses required by permit or contract or arranging for offsite analysis as necessary or as otherwise coordinated with the Environmental Division. This includes, but may not be limited to, collection of wastewater outfall discharge samples; potable water samples for backshift, weekend and holiday support; and miscellaneous sampling activities necessary to support spill response, cleanup or remediation activities;

3.9.2 Implementing

the station's Expendable Material Program;3.9.3 Providing technical guidance for chemistry control of facility building cooling water systems.3.9.4 Providing chemical analysis support and assistance as necessary. 3.10 HEALTH PHYSICS DIVISION: The Health Physics Division is responsible for: 3.10.1 Implementation of the station's Radiological Environmental Monitoring Program;3.10.2 Implementation of site programs involving compliance with applicable laws, regulations and permits associated with mixed waste management; 3.10.3 Providing support resources as necessary for the Spill Response and Spill Cleanup Teams to address radiological spills or spills located in radiologically controlled areas;3.10.4 Coordination of the station's Radiological Ground Water Protection Program. OPGP03-ZO-0025 I Rev. 13 Page 9 of 50 Site Environmental Compliance 3.11 ENVIRONMENTAL DIVISION: The Environmental Division is responsible for: 3.11.1 Performing analyses required by permit or contract or arranging for offsite analysis as necessary; 3.11.2 Providing technical assistance and consultation services as necessary concerning nonradiological site environmental matters;3.11.3 Implementation of the Source Reduction and Waste Minimization Plan (nonradiological) for the STPEGS;3.11.4 Implementation of site environmental programs involving compliance with applicable laws, regulations, and permits associated with non-radioactive solid and hazardous waste and sludge disposal, water quality and usage, air quality, potable water, and the EPP;3.11.5 Implementation of site environmental programs involving ecological protection and control, landfill operations and compliance, compliance with Texas Parks and Wildlife permits and requirements, monitoring for compliance with U. S.Army Corps of Engineers'permits and requirements, spoil area monitoring and compliance; 3.11.6 Monitoring river flow rates as necessary for reservoir pumping;3.11.7 Maintenance of the Hazardous Waste Storage Area;3.11.8 Compliant operation of the Sanitary Waste Treatment Systems and Potable Water Systems;3.11.9 Coordination of environmental compliance assessments; 3.11.10 Acquisition of local, state, and federal environmental permits and approvals. 3.12 The Houston Lighting and Power Co. Manager, Environmental Department, was responsible for preparation of the Units 1 and 2 Environmental Report, environmental-related portions of the Units 1 and 2 safety analysis report and acquisition of local, state and federal permits and approvals. These responsibilities were subsequently assumed by the Environmental Division for the STP Nuclear Operating Company.3.13 SITE PERSONNEL: Site personnel are responsible for adhering to requirements set forth in this procedure or as further specified by Site Management. OPGP03-ZO-0025 Rev. 13 Page 10 of 50 Site Environmental Compliance

4.0 Procedure

4.1 Wildlife Protection and Control 4.1.1 No site personnel other than the licensed Animal Controller available to the Site OR those individuals designated by the Facilities Management Division SHALL handle any traps or trapped animals.4.1.2 No site personnel other than the contracted Pest Controller OR those individuals designated by the Facilities Management Division SHALL handle or remove any bait station.4.1.3 No site personnel other than the licensed Animal Controller available to the Site OR those individuals designated by the Facilities Management Division SHALL touch, feed, capture, kill, remove, or take any action that may cause harm to any animal found on site.4.1.4 Fish kills, dead or injured alligators, and unusual numbers of wildlife mortalities should be reported to the Environmental Division. OPGP03-ZO-0025 Rev. 13 Page I Iof 50 Site Environmental Compliance

4.2 Plant

Effluent Permit Requirements NOTE Limitations delineated in this section are necessary to ensure compliance with applicable TCEQ permit requirements. Site specific administrative controls MAY be more stringent.

4.2.1 Bypasses

and upsets as defined in Section 2.0 of this procedure should be immediately reported to the Environmental Program Coordinator (EPC) or his/her alternate. 4.2.2 Upon the approval of the EPC or the Environmental Manager a bypass may be allowed if necessary for essential maintenance IF the bypass does NOT cause effluent limitations to be exceeded AND also meets the criteria in Step 4.2.3 below.4.2.3 Bypasses are prohibited unless: 4.2.3.1 The bypass was unavoidable to prevent loss of life, personal injury, or severe property damage, OR 4.2.3.2 There were no feasible alternatives, e.g., use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime AND a notice of an anticipated bypass has been filed with AND approved by the appropriate regulatory agency, OR 4.2.3.3 The bypass is authorized under a program of preventive or corrective maintenance as approved by the TCEQ.4.2.4 Reasonable steps necessary SHALL be taken to minimize or prevent any bypass or upset.NOTE Effluent standards and limitations referred to in Step 4.2.5 are outlined in Addendum 2.4.2.5 Exceedence of or noncompliance with applicable effluent standards and limitations or conditions as stated in TCEQ Permit No. 01908 SHALL constitute an environmental violation. OPGP03-ZO-0025 Rev. 13 Page 12 of 50 Site Environmental Compliance

4.3 Plant

Air Emissions Requirements NOTE Limitations delineated in this section are necessary to ensure compliance with applicable TCEQ permit requirements. Site specific administrative controls MAY be more stringent.

4.3.1 Permit

exceedences, upsets and items of non-compliance as defined in this procedure should be promptly reported to the EPC or his/her alternate. NOTE Emission standards and limitations referred to in Step 4.3.2 are outlined in Addendum 3.4.3.2 Exceedence of or noncompliance with applicable terms, conditions or emission standards and limitations as stated in TCEQ Permit No. 7410 or Federal Operating Permit 0801 SHALL constitute an environmental non-compliance. 4.3.3 As a minimum, records of reportable and nonreportable exceedences or noncompliance's in accordance with Step 4.3.2 above SHALL contain the following information: 4.3.3.1 date and time of the occurrence; 4.3.3.2 the processes and equipment involved;4.3.3.3 description and cause;4.3.3.4 duration or anticipated duration;4.3.3.5 steps taken to correct and minimize the emission;4.3.3.6 steps taken to prevent recurrence.

4.3.4 Refrigerant

management and use SHALL be in accordance with OPGPG03-ZA-05 11, Refrigerant Management Program. I OPGP03-ZO-0025 I Rev. 13 j Page 13 of 50 Site Environmental Compliance 4.3.5 The following activities relevant to lead-containing material require evaluation by Environmental personnel to determine environmental permitting requirements, if any: 4.3.5.1 Lead melting or reclamation activities; 4.3.5.2 Brazing, soldering or welding equipment that emit _> 0.6 tons per year (1,200 lbs/year) of lead;4.3.5.3 Application of coatings that contain > 0.1% by weight of lead with spray equipment; or, 4.3.5.4 Activities where the emission of lead to the environment is anticipated.

4.3.6 Abrasive

blasting of potable water storage tanks SHALL be conducted in accordance with and controlled by applicable requirements in Federal Operating Permit 0801 and 30 T.A.C. §111.4.3.7 Open burning activities including, but not limited to, fire training SHALL be conducted in accordance with applicable requirements in Federal Operating Permit 0801 and 30 T.A.C. §111.4.3.8 Blast Yard Operations 4.3.8.1 Blast Yard operations SHALL be consistent with the terms and conditions of TACB Permit Exemption No. X-4014.4.3.8.2 Environmental shall be notified of any change to the Blast Yard facility or equipment impacting compliance with Permit Exemption No. X-4014.4.3.8.3 The organization responsible for operation of the Blast Yard facility SHALL record monthly operating hours and amount/type of blast grit used. This information SHALL be transmitted to Environmental using Form 4, Blast Grit Usage Tracking, or in a format that allows completion of Form 4. OPGP03-ZO-0025 Rev. 13 Page 14 of 50 Site Environmental Compliance

4.3.9 Surface

Coat Facility Operations 4.3.9.1 Surface Coat Facility operations SHALL comply with applicable requirements in the June 1996 version of 30 T.A.C. § 106.433 (previously Standard Exemption 75).4.3.9.2 The organization responsible for operation of the Surface Coat Facility SHALL prepare a monthly report that contains the following. This data SHALL be transmitted to Environmental using Form 5, Surface Coat Facility Operations Tracking, or in a format that allows completion of Form 5: a. Daily data of coatings and solvent use;b. Actual hours of operation each day;c. Volatile organic emissions from each operation in pounds per hour, pounds per day and pounds per week;d. Examples of the method of data reduction including units, conversion factors, assumptions and bases for assumptions. 4.3.10 Degreasing Units 4.3.10.1 Degreasing unit operations (e.g. parts washers) SHALL comply with applicable requirements in the June 1996 version of 30 T.A.C.§ 106.454 (previously Standard Exemption 107).4.3.10.2 The organization responsible for operation of degreasing units SHALL maintain a monthly tracking of solvent product used and total solvent makeup (gross usage minus waste disposal) for each unit operated. This data SHALL be transmitted to Environmental using Form 6, Degreaser Unit Operations Tracking, or in a format that allows completion of Form 6. OPGP03-ZO-0025 Rev. 13 Page 15 of 50 Site Environmental Compliance

4.4 Plant

Solid Waste Requirements

4.4.1 Waste

management methods SHALL comply with TCEQ Registration No. 30651.4.4.2 The generation of hazardous/nonhazardous wastes SHALL be minimized in accordance with the recommendations in Administrative Policy No. STP-415, the Source Reduction and Waste Minimization Plan for the STPEGS, and OPGP03-ZI-0008, Control of Expendable Materials. 4.4.3 To ensure compliance with TCEQ Registration No. 3065 1, the following requirements concerning waste management methods SHALL apply: 4.4.3.1 Only inert construction debris and non-combustible waste as listed below may be disposed of in the on-site landfill.NOTE Concrete waste containing re-bar or other contaminants is not permitted in the onsite landfill. The station-preferred disposition of concrete and related material is to recycle when possible.a. Concrete waste (e.g., blocks, test cylinders, mortar/grout, etc.)b. Plastic c. Rubber hose (no tires)d. PVC pipe e. ' Glass f. Wire 4.4.3.2 Waste that cannot be land filled on-site SHALL be packaged in accordance with OPGP03-ZH-0003, Packaging of Nonradioactive Waste Materials for Disposal, and shipped off-site for disposal or recycling in accordance with OPCP 1O-ZH-0002, Packaging and Shipment of Nonradioactive Waste Materials. 4.4.4 The type of material that may be stored in stock piles north of Building 20 are as follows: 4.4.4.1 Clean road construction material 4.4.4.2 Clean backfill material 4.4.4.3 Asphalt/backfill material destined for recycle or reuse 4.4.4.4 Concrete/backfill material destined for recycle or reuse OPGP03-ZO-0025 IRev. 13 Page 16 of 50 Site Environmental Compliance 4.4.5 The type of material that may be placed on the area west of Building 20 is as follows: 4.4.5.1 Clean fill material 4.4.5.2 Material removed from ditch clearing activities 4.4.6 The types of items that can be disposed of in trash containers or dumpsters from office, cafeteria, or food service operations are as follows: 4.4.6.1 Paper 4.4.6.2 Cardboard 4.4.6.3 Wood (treated/untreated) 4.4.6.4 Food wastes 4.4.6.5 Plastic 4.4.6.6 Polystyrene NOTE Outside the Protected Area, scrap metal shall be stored in the scrap metal yard west of Warehouse E.Scrap metal components that cannot fit (e.g. due to size or irregular shape) in the scrap metal dumpsters provided must be cut to fit or special arrangements must be made through the Nuclear Purchasing and Materials Management Department to have the material hauled directly.4.4.7 The type of items that can be placed in scrap metal dumpsters are items made of metal with the exceptions of: 4.4.7.1 Compressed gas cylinders 4.4.7.2 Aerosol cans 4.4.7.3 Any equipment that still contains oil or any other hazardous/nonhazardous material (e.g., transformers, oil filters, etc.). OPGP03-ZO-0025 Rev. 13 Page 17 of 50 Site Environmental Compliance

4.5 Plant

Drainage Requirements

4.5.1 Plant

drainage and dewatering activities SHALL comply with the requirements delineated in the applicable TCEQ discharge permit and the Storm Water Pollution Prevention Plan (SWPPP) for the STPEGS.4.5.2 Only the following plant water systems may be diverted if necessary into the storm drain/plant drainage system: 4.5.2.1 Well water 4.5.2.2 Fresh water 4.5.2.3 Potable water 4.5.2.4 Service water 4.5.2.5 Fire water 4.5.3 No process water (e.g., demineralized, flush, blowdown, chemical cleaning, or hydro) SHALL be diverted to the storm drain/plant drainage system without prior approval by the EPC or the Environmental Manager.4.5.4 At least once per calendar year, a compliance evaluation will be conducted in accordance with the SWPPP.4.5.5 Monitoring will be conducted quarterly and recorded on Form 7, Storm Water Sampling.4.5.6 A monthly inspection of pollutant sources will be conducted and recorded on Form 8, Storm Water Pollutant Source Monthly Checklist. 4.5.7 A quarterly inspection of pollutant sources and best management practices contained in the SWPPP will be conducted and recorded on Form 9, Storm Water Periodic Inspection Checklist. OPGP03-ZO-0025 Rev. 13 Page 18 of 50 Site Environmental Compliance

4.6 Hazardous

and Nonhazardous Waste Accumulation and Disposal NOTE Total containment of temporary mobile tanks may be waived at the discretion of Environmental Personnel as long as reasonable measures (e.g., drip pans under hose connections, operational practices, etc.) to prevent leakage or spillage are implemented.

4.6.1 Accumulation

of bulk quantities of waste (any quantity greater than one (1)gallon of chemicals, solvents, and hazardous material OR any quantity greater than thirty (30) gallons of oil or lubricants) which have a potential for direct discharge to the environment (i.e., any waste being accumulated without engineered containment) SHALL be within a bermed area.4.6.2 Berms should be sized to contain the entire contents of the largest container plus 10 percent for precipitation. Accumulated precipitation in bermed areas must be removed in a timely manner as necessary to prevent overflow of the berm and not exceed the volume required to accommodate the largest container inside the berm. Covered berms need only be sized to contain the entire contents of the largest container. 4.6.3 Non-engineered bermed areas must have a sign specifying the organization responsible for that area.4.6.4 Containers of waste SHALL be labeled with a permanent marker prior to filling with the type of waste contained. (paint, solvent, etc.) Containers SHALL be transferred to the Hazardous Waste Storage Area (HWSA) in accordance with OPGP03-ZH-0003, Packaging of Nonradioactive Waste Materials for Disposal.4.6.5 Containers accumulated within a bermed area SHALL be properly labeled identifying the contents of the container in accordance with OPGP03-ZH-0003, Packaging of Nonradioactive Waste Materials for Disposal.4.6.6 Containers which hold waste within a berm SHALL be closed at all times except when adding or removing waste.4.6.7 When possible, product and waste stored within the same area SHALL be separated. (See Addendum 1 and Steps 4.7.7 through 4.7.9 for proper storage guidelines)

4.6.8 Disposal

of expendable and hazardous or nonhazardous materials SHALL be in accordance with OPGP03-ZH-0003, Packaging of Nonradioactive Waste Materials for Disposal. OPGP03-ZO-0025 Rev. 13 Page 19 of 50 Site Environmental Compliance

4.6.9 Records

SHALL be kept for all sludge removed from any wastewater treatment system. Records SHALL be maintained on a monthly basis using Form 3, Wastewater Treatment System Sludge Removal Log, and include the following: 4.6.9.1 Volume of waste and date(s) generated from treatment process.4.6.9.2 Volume of waste disposed of on-site OR shipped off-site.4.6.9.3 Date(s) of disposal.4.6.9.4 Identity of transporter. 4.6.9.5 Location of disposal site.4.6.9.6 Method of final disposal. OPGP03-ZO-0025 I Rev. 13 j Page 20 of 50 Site Environmental Compliance 4.7 Oil/Chemical Product Storage NOTE In addition to the requirements listed below, procurement and storage of oil, chemicals, solvents, or hazardous material must comply with the requirements of: " OPGP03-ZF-0019, Control of Transient Fire Loads and Use of Combustible and Flammable Liquids and Gases,* OPGP03-ZI-0012, Hazardous Communication Program," OPGPO3-ZI-0015, Industrial Compressed Air and Gases,* OPGP03-ZG-0001, Control of Materials and Products by the User Group," OPGP03-ZM-0004, Lubrication Program, and" OPGP03-ZI-0008, Control of Expendable Materials.

4.7.1 Storage

of bulk quantities (any quantity greater than one (1) gallon of chemicals, solvents, and hazardous material OR any quantity greater than thirty (30) gallons of oil or lubricants) which have a potential for direct discharge to the environment (i.e., any material stored without engineered containment) SHALL be within a bermed area.4.7.1.1 4.7.1.2 Berms should be sized to contain the entire contents of the largest container plus 10 percent for precipitation. Covered berms need only be sized to contain the entire contents of the largest container. Alternative containment systems (e.g., skid pans or drip pans) may be used for product being stored temporarily. NOTE Loading or off-loading of product containers does NOT require a containment system although proper precautions should be taken to prevent any possible spills or discharge of product to the environment. Total containment of temporary mobile tanks may be waived at the discretion of Environmental Personnel. 4.7.1.3 Alternative containment systems (e.g., drip pans for hose connections) SHALL be employed for truck loading or off-loading activities.

4.7.2 Product

containers SHALL be labeled to identify the contents contained (paint, solvent, etc.). OPGP03-ZO-0025 Rev. 13 I Page 21 of 50 Site Environmental Compliance

4.7.3 Accumulated

precipitation in bermed areas must be removed in a timely manner as necessary to prevent overflow of the berm and not exceed the volume required to accommodate the largest container inside the berm.4.7.3.1 Accumulated precipitation NOT routed to an appropriate treatment system shall be visually inspected for surface sheens or other indications of oil contamination prior to discharge. 4.7.3.2 Accumulated precipitation with indication of oil contamination SHALL be routed to an appropriate treatment system.4.7.3.3 Accumulated precipitation removed from bulk oil storage facilities that is NOT routed to an appropriate treatment system SHALL be documented.

4.7.4 Containers

within the berm SHALL be closed during storage except when it is necessary to remove material.4.7.5 Non-engineered bermed areas must have a sign specifying the organization responsible for that area.4.7.6 WHEN possible, THEN product and waste stored within the same area SHALL be separated. (See Addendum 1 in addition to Steps 4.7.7 through 4.7.9 for proper storage guidelines.)

4.7.7 Corrosive

material SHALL NOT be stored next to flammable liquids, flammable solids, oxidizing materials, or organic peroxides.

4.7.8 Cyanides

or cyanide mixtures SHALL NOT be stored with acids or corrosive liquids.4.7.9 Poisonous gases SHALL NOT be stored with flammable liquids or flammable gases.4.8 Spill Response, Cleanup, and Reporting 4.8.1 Spill response, cleanup, and reporting SHALL be done in accordance with OPGP03-ZH-0006, Nonradioactive Spill Response, Cleanup and Reporting and the Integrated Spill Contingency Plan for STPEGS. OPGP03-ZO-0025 Rev. 13 Page 22 of 50 Site Environmental Compliance

4.9 Monitoring

and Reporting Requirements

4.9.1 STPEGS

personnel SHALL conduct the activities describe below in accordance with applicable site procedures and policies.4.9.1.1 Monitor ongoing site activities for compliance with environmental regulatory requirements:

a. Hazardous Waste Storage Area Weekly Inspection Checklist (Form 1).b. Monthly Groundwater Usage Report (Form 2)c. Wastewater Treatment System Sludge Removal Log (Form 3)4.9.1.2 Conduct on-site sampling and analysis or arrange for offsite analysis of effluent streams, potable water system, groundwater wells, Main Cooling Reservoir, and waste streams associated with the solid waste management requirements.

NOTE Step 4.9.1.3 is applicable only to activities covered by Unit 1 Operating License No. NPF-76 and Unit 2 Operating License No. NPF-80.4.9.1.3 Submit copies to the USNRC of permit/license acquisitions and reports submitted in behalf of the STPEGS to other government agencies (federal, state, etc.)4.9.1.4 Prepare and submit the Annual Environmental Operating Report (AEOR) as required by Section 5.4.1 of Appendix B to Unit 1 Operating License No. NPF-76 and Unit 2 Operating License No NPF-80, Environmental Protection Plan (Nonradiological). OPGP03-ZO-0025 Rev. 13 Page 23 of 50 Site Environmental Compliance 4.10 Land Management 4.10.1 The following activities SHALL have a nonradiological environmental evaluation in accordance with OPGPO3-ZA-00 17, Nonradiological Environmental Evaluations: 4.10.1.1 Any cleaning, clearing, or draining activities in the spillway channel other than mowing or actions that DO NOT disturb the root zone of the existing vegetation (SPR 941677).4.10.1.2 Any activity that would disturb the Low Land Habitat.4.10.1.3 Any clearing, grubbing, or grading other than routine mowing that would result in the disturbance of one or more acres of land.4.10.2 Prior to disturbing the ground in an area on site outside the existing Unit 1 and Unit 2 facilities, a review SHALL be performed to determine if the area might contain archaeological items of cultural significance. 4.10.2.1 Review the Final Environmental Statement -Operating License (FES-OL), and supplements, Final Environmental Statement -Construction Phase (FES-CP), Environmental Report to the NRC and supplements, and/or Appendix B to Technical Specifications to obtain information pertaining to the archeological significance of the location where ground will be disturbed. 4.10.2.2 IF the document review indicates the NRC has previously evaluated the location where ground will be disturbed as not significant, THEN no further action is needed. OTHERWISE, contact the State Historic Preservation Officer for guidance on how to proceed prior to initiating ground disturbance. 4.10.3 IF during ground disturbance an unanticipated discovery of archaeological items of cultural significance is made, THEN refer to Addendum 5, Unanticipated Discovery of Cultural Resources, for further guidance. OPGP03-ZO-0025 Rev. 13 Page 24 of 50 Site Environmental Compliance 4.11 Corrective Action Measures 4.11.1 Deviations, deficiencies, discrepancies, items requiring remedial action, or other environmental violations noted by the EPC or alternate SHALL be subject to corrective measures in accordance with OPGP03-ZX-0002, Condition Reporting Process, or other applicable documentation. 4.12 Environmental Compliance Screening 4.12.1 Changes to procedures, programs, or the facility which may affect compliance with the Environmental Protection Program (EPP) or applicable operating permits SHALL be reviewed per OPGPO3-ZA-00 17, Nonradiological Environmental Evaluations. Addendum 4, Environmental Compliance Screening Questions, may be used to determine if a proposed change requires a Nonradiological Environmental Evaluation. OPGP03-ZO-0025 Rev. 13 Page 25 of 50 Site Environmental Compliance

5.0 References

5.1 Appendix

B, Environmental Protection Plan (Nonradiological) to Unit 1 Operating License NPF-76 and Unit 2 Operating License NPF-80 5.2 OPCP1O-ZH-0002, Packaging and Shipment of Nonradioactive Waste Materials 5.3 0PGP03-ZA-0017, Nonradiological Environmental Evaluations 5.4 0PGP03-ZA-051 1, Refrigerant Management Program 5.5 0PGP03-ZH-0003, Packaging of Nonradioactive Waste Materials for Disposal 5.6 0PGP03-ZH-0006, Nonradioactive Spill Response, Cleanup, and Reporting 5.7 0PGP03-ZI-0008, Control of Expendable Materials 5.8 0PGP03-ZG-0001, Control of Materials and Products By User Groups 5.9 0PGP03-ZX-0002, Condition Reporting Process 5.10 OPGPO3-ZI-0015, Industrial Compressed Air and Gases 5.11 OPGPO3-ZG-000 1, Control of Materials and Products by the User Group 5.12 OPGP03-ZM-0004, Lubrication Program 5.13 OPGP03-ZI-0012, Hazard Communication Program 5.14 OPGPO3-ZF-0019, Control of Transient Fire Loads and Use of Combustible and Flammable Liquids and Gases 5.15 29 CFR 1910.1200 5.16 40 CFR 116, 261, 262, 268 5.17 49CFR 171,172 5.18 Texas Commission on Environmental Quality Permit No. 7410 5.19 Texas Commission on Environmental Quality Permit No. 01908 5.20 Texas Commission on Environmental Quality Registration No. 30651 5.21 Federal Operating Permit 0801 5.22 Facility Notice of Registration No. 30651 5.23 Integrated Spill Contingency Plan for STPEGS, October 2004 5.24 Storm Water Pollution Prevention Plan 5.25 ST-YS-EY-6120, July 8, 1986 5.26 ST-HS-HS-5650, September 1, 1986 5.27 Administrative Policy No. STP-415 OPGP03-ZO-0025 I Rev. 13 Page 26 of 50 Site Environmental Compliance 5.28 SPR-94-1677 5.29 Condition Report No. 97-8205 5.30 30TAC335.1 5.31 SARA Title III, Section 311 and 312 5.32 1O CFR 50 5.33 30TACI11 5.34 30TAC1O6.433 5.35 30TAC1O6.454 5.36 TACB Permit Exemption NO. X-4014 OPGP03-ZO-0025 I Rev. 13 Page 27 of 50 Site Environmental Compliance

6.0 Support

Documents 6.1 Form 1, Hazardous Waste Storage Area Weekly Inspection Checklist 6.2 Form 2, Monthly Groundwater Usage Report 6.3 Form 3, Wastewater Treatment System Sludge Removal Log 6.4 Form 4, Blast Grit Usage Tracking 6.5 Form 5, Surface Coat Facility Operations Tracking 6.6 Form 6, Degreaser Unit Operations Tracking 6.7 Form 7, Storm Water Sampling 6.8 Form 8, Storm Water Pollutant Source Monthly Checklist 6.9 Form 9, Storm Water Periodic Inspection Checklist 6.10 Addendum 1, Examples of Potentially Incompatible Waste/Materials 6.11 Addendum 2, Nonradiological Plant Effluent Standards and Limitations 6.12 Addendum 3, Auxiliary Boiler Emission Standards and Limitations 6.13 Addendum 4, Environmental Compliance Screening Questions 6.14 Addendum 5, Unanticipated Discovery of Cultural Resources Z0919 0PGP03-ZO-0025 Rev. 13 Page 28 of 50 Site Environmental Compliance Form 1 Hazardous Waste Storage Area Weekly Inspection Page 1 of 1 Checklist (Sample)Satisfactory Comments & Corrective Actions Housekeeping Yes/No Condition of drums/containers (look for Yes/No deteriorated or leaking containers) Drums Properly Sealed Yes/No Drums Properly Labeled Yes/No Adequate Aisle Space Between Drums Yes/No Incompatible Wastes Separated Yes/No Condition of bulk waste containers (look for Yes/No deteriorated or leaking containers) Bulk Waste Containers Properly Labeled Yes/No"Authorized Personnel" Signs Posted Yes/No Security Fence & Gate Secure Yes/No Safety Equipment Available (Fire Yes/No Extinguisher, Eye Wash Station, etc.)Berm Integrity and Condition Yes/No Accumulation Date of the Oldest Hazardous Waste Container: Inspection Performed by: Date: This form, when completed, SHALL be retained for the life of the plant Z0920 OPGPO3-ZO-0025 I Rev. 13 Page 29 of 50 Z Site Environmental Compliance Form 2 IMonthly Ground Water Usage Report (Sample) IPagelI ofl I MONTHLY REPORT FOR Month/Year: Ending Beginning WELL Monthly NO. Date Time Meter Reading Date Time Meter Reading Usage (Gal) Remarks*Read Read (Gal) Read Read (Gal)5 6 7 8 NTF-FW Total (Gal)_*Remarks should include the dates and meter readings associated with equipment (wells and meters) taken out of or returned to service.Prepared by: Date: Date: Reviewed by: This form, when completed, SHALL be retained for the life of the plant. Z0919 I. OPGP03-ZO-0025 Rev. 13 Page 30 of 50 Site Environmental Compliance Form 3 Wastewater Treatment System Sludge Removal Log (Sample) Page 1 of I MONTHLY REPORT FOR Month/Year: Date Treatment Volume Disposal Disposal Disposal Facility Transporter Disposal Method___e System Removed Date Volume I 1- 4 4- 4 + 4 1- 4 4- 4 + 4 4 .9- 4 + 4 .9 4 9- 4 + 4 4 I. $ 4- 4 + 4 4 4. 4 4- 4 4 4 4 4- 4 4- 4 + 4 4 4- 4 4- 4 + 4 4 4- 4 4- 4 4 4 4 Prepared by: Reviewed by: Date: Date: This form, when completed, SHALL be retained for the life of the plant. Z0919 Site Environmental Compliance Form 4 Blast Grit Usage Tracking (Sample) Page 1 of 1 Month/Year: Date Operating Abrasive Type* Amt. Used (tons)I Hours I I i i 4 I I 4. 4 I 4. 4 I 4. 4 4+ 4 4 1~ I I 4. 4 4+ 4 4+ 4. 4 Totals:*Abrasive type = Coal Slag, Silica Sand or Other (Specify)This facility is currently exempted under Permit Exemption No. X-4014 Prepared by: Date: This form, when complete, SHALL be retained for five years. Z0919 O PGP03-ZO-0025 Rev. 13 IPage 32°ofs°0 Site Environmental Compliance I Form 5 Surface Coat Facility Operations Tracking (Sample) IPagel1 of 2I Day Hour VOC Emitted Usage Total Operating Date 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 (ibslday) (gatday) Hours (hrsJday)Sunday Product No.Quantity (gallons)VOC (iblgal)EMISSIONS (Ib/'hr)EMISSIONS (ibI5-hr)Monday Product No.Quantity (gallons)VOC (Iblgal)EMISSIONS (Ib/hr)EMISSIONS (Ib/5-hr)Tuesday Product No.Quantity (gallons)VOC (Ib/gal)EMISSIONS (Ib/hr)EMISSIONS (Ib/5-hr)Wednesday Product No.Quantity (gallons)VOC (Iblgal)EMISSIONS (Ib/hr)EMISSIONS (lb/5-hr)This form, when complete, SHALL be retained for five years. OPGP03-ZO-0025 1 Rev. 13 Page 33 of 50 Site Environmental Compliance Form 5 Surface Coat Facility Operations Tracking (Sample) Page 2 of 2_Day Hour VOC Emitted Usage Total Operating Date 7:00 8:00 9:00 10:00 11:00 12:00 13:00 14:00 15:00 16:00 17:00 18:00 (lbs/day) (gal/day) Hours (hrs/day)Thursday Product No.Quantity (gallons)VOC (lb/gal)EMISSIONS (lb/hr)EMISSIONS (lb/5-hr)Friday Product No.Quantity (gallons)VOC (lb/gal)EMISSIONS (lb/hr)EMISSIONS (IblS-tr)Saturday Product No.Quantity (gallons)VOC (lb/gal)EMISSIONS (lb/hr)EMISSIONS (IblS-hr)VOC Emitted (lbs/wk) =Operating Hours (hswk) =Prepared by: Date: Z0919 OPGP03-ZO-0025 I Rev. 13 Page 34 of 50 Site Environmental Compliance Form 6 Degreaser Unit Operations Tracking (Sample) Page 1 of 1 Degreaser Unit Location: Month/Year Solvent Solvent Added [(-) [Solvent Drained Net Usage Type (gal) (gal) (gal)4 p 4 4 4 4 4 i 4 i 4 4 4 4 4 4 TotaII1 gal Prepared by: Date: This form, when complete, SHALL be retained for five years. Z0919 OPGP03-ZO-0025 Rev. 13 Page 35 of 50 Site Environmental Compliance Form 7 Storm Water Sampling (Sample) Page I of I Form7 Strm aterSamping(Samle) age 1 o OUTFALL: GENERAL DATE OF OBSERVATION: WEATHER CONDITIONS: TEMPERATURE: RAINFALL STARTED AT: RAINFALL ENDED AT: DURATION OF STORM EVENT (MINUTES): TOTAL RAINFALL (INCHES): FIRST FLOW THROUGH OUTFALL OBSERVED AT: VOL. DISCH. DURING EVENT (GAL.): DATE OF PREVIOUS RAINFALL: PREVIOUS RAINFALL AMOUNT (IN): GRAB SAMPLES SAMPLE DATE/TIME: (MUST BE W/IN 30 MIN. OF FIRST OBSERV ED FLOW THROUGH OUTFALL, NO MORE THAN AN HOUR)VISUAL COLOR: FLOATING SOLIDS: ODOR: FOAM: CLARITY: OIL SHEEN: OTHER OBVIOUS INDICATORS OF STORM WATER POLLUTION: ANALYTICAL IRON COLLECTED: YES NO if no, why_TSS COLLECTED (if applicable): YES NO if no, why SAMPLER SIGNATURE: This form, when complete, SHALL be retained for five years. Z0919 OPGP03-ZO-0025 Rev. 13 Page 36 of 50 Site Environmental Compliance Form 8 Storm Water Pollutant Source Monthly Checklist Page 1 of 1 (Sample)Month: Performed by: Potential Storm Water Pollutant Source Remarks Gasoline Storage Tank (fuel island)Diesel Storage Tank (fuel island)Diesel Storage Tank (NTF)Diesel Storage Tank (NSC)Diesel Storage Tank (EOF)Fueling Station Environmental Yard WSWTS/ Sodium Hypochlorite Tank TSWTS/Sodium Hypochlorite Tank NSC Potable Water Hypochlorite Tank Main Potable Water Hypochlorite Tank Car Wash Kerosene and Diesel Fuel Tanks Bld 20 Admin Parking Lot Firing Range Parking Lot Drum Storage (Bld 20)Sandblast Area Equipment Laydown Material Stockpiles Landfill (Inactive) Land Farm (Inactive) Fertilizer/Herbicide Notes:

• Switchyard walk-downs are performed by Transmission and Distribution personnel." Warehouse Building 19 checked by Warehouse personnel." CW and EW chemical injection systems checked by Chemistry personnel." Remainder of Facilities on Plant Operation watch stations.This form, when complete, SHALL be retained for five years.

Z0919 OPGP03-ZO-0025 Rev. 13 Page 37 gof 50 Site Environmental Compliance F Form 9 Storm Water Periodic Inspection Checklist (Sample) [ Page I of I Inspections are to be conducted on a quarterly basis. Refer to the Storm Water Pollution Prevention Plan (SWPPP) potential pollutant list for individual sources/locations. Should revisions or additions to the SWPPP be required based on the findings of the inspection, a summary description of these proposed changes should be documented in a summary attached to the inspection checklist. The summary must include the time frame required to implement the proposed changes.Area Good Housekeeping Measures Fueling Area(s)Chemical (Un)Loading Areas Liquid Storage Tanks Laydown Yard(s)Vehicle Maintenance Activities Material Storage Area(s)Bulk Storage Area(s)Pipeline(s)/Pumps for Fuel Oil/Chemicals Landfill Inspections Active Landfill Area: Stabilization/Erosion Storm Water Collection System Land Application Area: Stabilization/Erosion Storm Water Collection System Integrated Contingency Plan Erosion Control Measures Maintenance Program for Structural Controls Best Management Practices Employee Training Inspector: Satisfactory? Comments -if No, Other or NA Yes No Yes_ No_Yes No Yes No Yes No Yes No Yes_ No Yes_ No Yes No Yes_ No_Yes No Yes_ No Yes_ No Yes_ No Yes No Yes_ No Yes_ No Date: This form, when complete, SHALL be retained for five years. SOPGP03-ZO-0025 Rev. 13 Page 38 of 50 I .. .Site Environmental Compliance .I Addendum 1 Examples of Potentially Incompatible Waste/Materials Page 1 of 3 Many hazardous wastes, when mixed with other waste or materials at a hazardous waste facility, can produce effects which are harmful to human health and the environment, such as (1) heat or pressure, (2) fire or explosion, (3) violent reaction, (4) toxic dusts, mists, fumes, or gases, or (5) flammable fumes or gases.Below are examples of potentially incompatible wastes, waste components, and materials, along with the harmful consequences which result from mixing materials in one group with materials in another group. It is possible for potentially incompatible wastes to be mixed in a way that precludes a reaction (e.g., adding acid to water rather than water to acid) or that neutralizes them (e.g., a strong acid mixed with a strong base), or that controls substances produced (e.g., by generating flammable gases in a closed tank equipped so that ignition cannot occur, and burning the gases in an incinerator). In the lists below, the mixing of a Group A material with a Group B material may have the potential consequence as noted.GROUP 1-A Acetylene sludge Alkaline caustic liquids Alkaline cleaner Alkaline corrosive liquids Alkaline corrosive battery fluid Caustic wastewater Lime sludge and other corrosive alkalines Lime wastewater Lime and water GROUP 1-B Acid sludge Acid and water Battery acid Chemical cleaners Electrolyte, acid Etching acid liquid or solvent Pickling liquor and other corrosive acid Spent acid Spent mixed acid Spent caustic Spent sulfuric acid Potential Consequences: Heat generation; Violent reaction O 0PGP03-ZO-0025 Rev. 13 Page 39 of 50 Site Environmental Compliance

Addendum Examples of Potentially Incompatible Waste/MateriaI Page 2 of 3 Addenum 1Exampes o Potntialy Inompaible asteMateial ae2o GROUP 2-A Aluminum Beryllium Calcium Lithium GROUP 2-B Any waste in Group 1-A or 1-B Magnesium Potassium Sodium Zinc powder Other reactive metals and metal hydrides Potential Consequences

Fire or explosion; Generation of flammable hydrogen gas.GROUP 3-A Alcohols Water GROUP 3-B Any concentrated waste in Groups 1-A or 1-B Calcium Lithium Metal hydrides Potassium S0 2 C1 2 , SOC1 2 , PC1 3 , CH 3 SiC1 3 Other water-reactive waste Potential Consequences: Fire, explosion, or heat generation; Generation of flammable or toxic gases.GROUP 4-A Alcohols Aldehydes Halogenated hydrocarbons Nitrated hydrocarbons Unsaturated hydrocarbons Other reactive organic compounds and solvents GROUP 4-B Concentrated Group 1-A or 1-B waste Group 2-A wastes Potential Consequences: Fire, explosion, or violent reaction. [OPGP03-ZO-0025 Rev. 13 Page 40 of 50 Site Environmental Compliance E Addendum 1 Examples of Potentially Incompatible Waste/Materials Page 3 of I GROUP 5-A Spent cyanide and sulfide solutions GROUP 5-B Group 1-B wastes Potential Consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas.GROUP 6-A Chlorates Chlorine Chlorites Chromic acid Hypochlorites Nitrates Nitric acid, fuming Perchlorates Permanganates Peroxides Other strong oxidizers GROUP 6-B Acetic acid and other organic acids Concentrated mineral acids Group 2-A wastes Group 4-A wastes Other flammable and combustible wastes Potential consequences: Fire, explosion, or violent reaction.Source: "Law, Regulation, and Guidelines for Handling of Hazardous Waste." California Department of Health, February 1975. IOPGP03-ZO-0025 I Rev. 13 J Page 41 of 50 Site Environmental Compliance Addendum 2 Nonradiological Plant Effluent Standards and Limitations Page 1 of 3 To ensure permit compliance, the following outfall limitations and requirements SHALL be maintained: Cooling Pond Discharge -Outfall 001 NOTE Discharges via this outfall must also comply with state water quality standards.

1. Daily maximum flow SHALL NOT exceed 200 MGD.2. Daily average flow SHALL NOT exceed 144 MGD.3. Daily average temperature SHALL NOT exceed 35°C (95 0 F).4. Daily maximum temperature SHALL NOT exceed 36.1 0 C (97 0 F).5. pH SHALL be maintained between 6.0 and 9.0 standard units.6. There SHALL be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.7. Total residual chlorine SHALL be maintained below detectable levels.8. Biomonitoring SHALL NOT exhibit chronic toxicity as defined in TCEQ Permit No. 01908.Neutralization Basin -Outfall 101 1. The daily maximum total suspended solids SHALL NOT exceed 100 mg/l.2. The daily average for total suspended solids SHALL NOT exceed 30 mg/l.3. The daily maximum for oil and grease SHALL NOT exceed 20 mg/l.4. The daily average for oil and grease SHALL NOT exceed 15 mg/l.5. There SHALL be no discharge of visible foam or floating solids in other than trace amounts and no discharge of visible oil.

Site Environmental Compliance E Addendumn 2 Nonradiological Plant Effluent Standards and Limitations Page 2 of 3 Oily Waste Treatment System -Outfall 201 1. The daily maximum for total suspended solids SHALL NOT exceed 100 mg/l.2. The daily average for total suspended solids SHALL NOT exceed 30 mg/l.3. The daily maximum for oil and grease SHALL NOT exceed 20 mg/l.4. The daily average for oil and grease SHALL NOT exceed 15 mg/l.5. There SHALL be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.West Sanitary Waste Treatment System -Outfall 401 1. The daily maximum Biochemical Oxygen Demand (5-day) SHALL NOT exceed 45 mg/l.2. The daily average Biochemical Oxygen Demand (5-day) SHALL NOT exceed 20 mg/l.3. The daily maximum for total suspended solids SHALL NOT exceed 45 mg/l.4. The daily average for total suspended solids SHALL NOT exceed 20 mg/i.5. There SHALL be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.Metal Cleaning Waste -Outfall 501 1. The daily maximum for total iron SHALL NOT exceed 1 mg/I.2. The daily average for total iron SHALL NOT exceed 1 mg/l.3. The daily maximum for total copper SHALL NOT exceed 1 mg/l.4. The daily average for total copper SHALL NOT exceed 0.5 mg/l.5. There SHALL be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil. O 0PGP03-ZO-0025 Rev. 13 Page 43 of 50 Site Environmental Compliance Addendum 2 Nonradiological Plant Effluent Standards and Limitations Page 3 of 3 Training Sanitary Waste Treatment System -Outfall 601 1. The daily maximum Biochemical Oxygen Demand (5-day) SHALL NOT exceed 45 mg/l.2. The daily average Biochemical Oxygen Demand (5-day) SHALL NOT exceed 20 mg/l.3. The daily maximum for total suspended solids SHALL NOT exceed 45 mg/l.4. The daily maximum for total suspended solids SHALL NOT exceed 20 mg/l.5. There SHALL be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil. [OPGP03-ZO-0025 R Rev. 13 Page 44 of 50 Site Environmental Compliance I Addendum 3 Auxiliary Boiler Emission Standards and Limitations Page 1 of 1 To ensure permit compliance the following emission limitations and requirements SHALL be maintained for the Auxiliary Boiler: 1. The following maximum allowable emission rates SHALL be maintained:

a. 0.3 lb/mm BTU and 55 lb/hr oxides of nitrogen b. 0.24 lb/mm BTU and 44.4 lb/hr sulfur dioxide c. 0.1 lb/mm BTU and 18.3 lb/hr particulates

d. 15.24 lb/hr carbon monoxide e. 1.01 lb/hr volatile organic compounds 2. Emission opacity SHALL NOT exceed 15 percent averaged over a six minute period.3. The emission point (Auxiliary Boiler) SHALL be fired only with No. 2 fuel oil with a sulfur content no greater than 0.30 percent by weight.4. During load operation greater than 30 percent, feedback control from the oxygen monitor SHALL continuously maintain Low Excess Air (LEA) air/fuel ratio parameters in the combustion mixture.In lieu of the use of feedback control from the oxygen monitor, the boiler may be manually operated within a range of between 2.5 and 10 percent excess oxygen in the flue gas.

Site Environmental Compliance Addendum 4 Environmental Compliance Screening Questions Page 1 of 3 This addendum provides guidance on the types of changes to the facility that require a Nonradiological Environmental Evaluation per 0PGP03-ZA-0017, Nonradiological Environmental Evaluations. A Nonradiological Environmental Evaluation is required if all or a portion of a plant design change (including installation, construction, modification, or operation and maintenance of the change) alters, adds, deletes or impacts any of the following subordinate issues.1. Change to the Environmental Protection Plan (EPP) or change that could potentially constitute an unreviewed environmental question as defined in Appendix B to the Operating License?Note that implementation of changes in the EPP shall not commence prior to NRC approval of the proposed changes in the form of a license amendment. Such changes include, but are not limited to:-Impact to previously undisturbed area(s) of the site-A matter that may result in an increase in any adverse environmental impact previously evaluated in the Final Environmental Statement -Operating License, environmental impact appraisals or in any decisions of the Atomic Safety and Licensing Board [or successor organization] -A matter not previously reviewed and evaluated in the Final Environmental Statement -Operating License, environmental appraisal or decision of the Atomic Safety and Licensing Board [or successor organization] -A change in effluents or power level-Change increases potential to result in significant environmental impact that could be causally related to plant operation (Examples: fish kills; increase in nuisance organisms or conditions; unanticipated or emergency discharge of waste water or chemical substances; or impact to any onsite species protected by the Endangered Species Act)-Modification to station structures, systems or components that could potentially affect the continued protection of the environment

2. Change could impact the site's ability to comply with conditions of applicable wastewater discharge permit(s)?

Such changes include, but are not limited to:-Potential to alter the nature or increase the quantity of pollutants discharged in plant effluents-Structural changes to Main Cooling Reservoir, Reservoir Makeup Pumping Facilities or blowdown facilities or monitoring capabilities -Re-location or change to designated discharge points-Potential to alter effluent flow rates, concentrations or temperatures -Structural changes to wastewater treatment systems or monitoring capabilities qll Site Environmental Compliance OPGP03-ZO-0025 IRev. 13 Page 46 of 50]Addendum 4 Environmental Compliance Screening Questions I Page 2 of 3 3. Change could materially affect the site's potential for discharges of oils or chemicals? Such changes include, but are not limited to:-Commissioning or decommissioning of tanks or bulk containers -Replacement, reconstruction or movement of tanks or bulk containers -Reconstruction, replacement or installation of piping systems-Construction or demolition that might alter secondary containment structures -Potential increase in site's oil or chemical storage inventory 4. Change could impact the site's ability to comply with conditions of applicable storm water discharge permit?Such changes include, but are not limited to:-Modifications, including deletions or additions, to structural controls that prevent pollutants from entering storm water collection conveyances such as storm drains, ditches and sloughs.-Modifications that include any clearing or grading that would result in the disturbance of one or more acre of land-Modifications that impact existing drainage flows 5. Change could affect the site's water conservation capabilities? Such changes include, but are not limited to:-Modifications, including deletions or additions, to procedures or components used for leak-detection, water-loss accounting, water transmission or delivery-Process modifications to improve water-use efficiency -Increase in production or consumption of non-potable water including well water 6. Change could impact site's waste generation, minimization or disposal practices? Such changes include, but are not limited to:-Potential to generate mixed hazardous and radioactive waste-Potential to generate a new or additional non-radioactive waste type-Potential to significantly increase generation of existing non-radioactive waste type-Change, addition or deletion of onsite waste processing practices 7. Change or addition to existing potable water systems including water wells?Such changes include, but are not limited to:-Changes or additions to the systems' production, treatment, storage or distribution facilities -Changes or additions to existing systems that result in an increase in production, treatment, or storage capacity-Changes involving disinfection application points, disinfectants used or disinfection processes OPGP03-ZO-0025 Rev. 13 Page 47 of 50 Site Environmental Compliance Addendum 4 Environmental Compliance Screening Questions Page 3 of 3 8. Change could impact the site's ability to comply with conditions of applicable air quality permit(s) or alter non-radioactive air emissions? Examples of air emission sources include, but are not limited to, tanks, diesel/electrical generators, boilers, heaters, degreasers, painting/coatings activities, abrasive blasting activities, cooling towers, outdoor burning, refrigerant use, building demolition or renovation activity, etc. Such changes include, but are not limited to:-Installation, construction, operation or maintenance of new air emission sources-Modification of existing air emission sources--A physical change or change in method of operation of an existing air emission source including changes in fuel, increase in hours of operation, increase in production rate, etc.-Installation, operation, cessation, removal/addition or replacement of pollution control or monitoring technology associated with an air emission source-Addition or alteration of an existing source of carbon monoxide, oxides of nitrogen, volatile organic compounds, sulfur oxides, particulate matter, lead or ozone depleting chemicals-Potential increase in air emissions or air emission points-Potential asbestos removal or disturbance

9. Change could impact site's ability to comply with various water rights permits, contractual agreements or other compliance documents that authorize the site to divert and impound water from the Colorado River?Such changes include, but are not limited to:-Structural modifications to the Reservoir Makeup Pumping Facility-Potential to increase water use or change the design flow rate-Impact to water use monitoring capability

-Installation, construction, operation or maintenance of structures in or adjacent to navigable waterways e.g. boat ramps, riprap, wharfs, piers, etc.-Potential for discharge or deposit of dredged or fill materials into navigable waters or onsite-Impacts the use by the public of navigable waters-Alterations to the reservoir spillway or embankments

10. Change could impact site's current land management practices or regulatory obligations?

Such changes include, but are not limited to:-Potentially result in net loss of existing wetlands-Change in designated area for onsite placement of waste material e.g. dredge, Class Ill waste, beneficial land application of sludge-Potentially impact natural resources and wildlife habitat-Potentially impact designated set aside areas such as the lowland habitat-Change in land use of previously un-impacted areas OPGP03-ZO-0025 Rev. 13 Page 48 of 50 Site Environmental Compliance Addendum 5 Unanticipated Discovery of Cultural Resources Page 1 of 3 Introduction Pursuant to the regulatory requirements of Section 106 of the National Historic Preservation Act (NHPA)and its implementing regulation 36 CFR Part 800 (as amended August 5, 2004) an Area of Potential Effect (APE) associated with construction and operations activities (existing and proposed) at the South Texas Project site has been surveyed and a determination of no adverse effect to historic properties was asserted and concurred with by the Texas Historical Commission (THC) on 01/19/2007. The following Unanticipated Discovery Plan (UDP) outlines procedures to follow in the case of a post review discovery in accordance with 36 CFR Part 800.13.Discovered cultural resource materials could include human skeletal remains, artifacts, sites, or any other cultural resources eligible, or potentially eligible, for listing in the National Register of Historic Places (NRHP). All cultural resource discoveries are considered confidential and to protect their integrity, the press will not be contacted under any circumstance. This plan is intended to provide guidance to STPNOC and their contractors so they can:* Comply with any applicable Federal and State laws and regulations, particularly 36 CFR 800 (as amended August 5, 2004) that implements section 106 of the National Historic Preservation Act of 1966, and* Describe to regulatory and review agencies the procedures agents will follow to prepare for and deal with unanticipated discoveries, and* Provide direction and guidance to project personnel for the proper procedures to be followed should an unanticipated discovery occur.Discovery of Cultural Resources Should construction or maintenance activities cause disturbance to underground cultural/archaeological resources the following section establishes provisions for the professional archaeological treatment of cultural materials discovered. Provisions of the Cultural / Archaeological Resource Procedures are as follows: A. If any STPNOC employee, contractor or subcontractor believes that they have uncovered any cultural resource during construction or maintenance activities, all work adjacent to the discovery shall cease.The STPNOC Supervisor responsible for the ongoing work will notify the STPNOC Environmental Manager immediately. A cultural resource discovery could be prehistoric or historic and consist of, but not be limited to:* anthropogenic soil horizons, occupational surfaces, middens, etc., 0 areas of charcoal or charcoal -stained soil and stones,* stone tools or waste flakes (i.e. an arrowhead, or stone chips),* bones, burned rocks, or other food related materials in association with stone tools or flakes,* or a cluster of tin cans or bottles, logging or agricultural equipment older than 50 years. O PGP03-ZO-0025 IRev. 13 Page 49 of 50 Site Environmental Compliance Addendum 5 Unanticipated Discovery of Cultural Resources Page 2 of 3 B. In order to protect the integrity of a discovery the STPNOC Supervisor will take appropriate steps to protect the discovery site by ceasing all work in an area of stoppage adequate to provide for the total security, protection, and integrity of the resource. Vehicles, equipment, and unauthorized personnel will not be permitted to traverse the discovery site. Work in the immediate area will not resume until treatment of the discovery has been completed following provisions for treating archaeological cultural material contained in this addendum.C. The STPNOC Environmental Manager, arrange for the site to be evaluated by a qualified cultural resources management specialist. If the cultural resources find is determined to be significant; the cultural resource specialist/archaeologist or consulting archaeologist will immediately contact the THC to seek consultation regarding the National Register eligibility of any further discovery. Construction will be halted within the immediate area of the discovery and the scene will be protected until consultation to determine the appropriate course of action has been conducted. The STPNOC Supervisor may direct construction away from cultural resources to work in other areas prior to contacting the concerned parties.D. Where cultural resources are encountered during construction, but additional project effects to the resources are not anticipated, project construction may continue while documentation and assessment of the cultural resources proceed. The total area of work stoppage will be adequate to provide for the security, protection, and integrity of the discovery. Construction may continue at the discovery location only after the process outlined in this addendum is followed and STPNOC and THC are satisfied the caveats of Section 106 of the National Historic Preservation Act have been met.E. Routine documentation of newly discovered cultural material should not impact construction schedules. Where complex or extensive cultural remains are encountered, the STPNOC Environmental Manager and archaeological personnel will determine the appropriate level of documentation and treatment of the resource through consultation with THC.F. STPNOC will ensure the proper documentation and assessment of any discovered cultural resources in cooperation with a contracted consultant and THC. All prehistoric and historic cultural material discovered will be recorded by a professional archaeologist using standard techniques. Where warranted in the opinion of the qualified cultural resources professional, site overviews, features, and artifacts will be photographed; stratigraphic profiles and soil/sediment descriptions will be prepared for subsurface exposures. Discovery locations will be documented on scaled site plans and site location maps.G. All prehistoric and historic artifacts collected from the surface and from probes and excavation units will be analyzed, catalogued, and temporarily curated. Ultimate disposition of cultural materials will be determined in consultation with the THC.H. Within 90 days of concluding fieldwork, a technical report describing any and all monitoring and resultant archaeological excavations will be provided to the STPNOC Environmental Manager. The STPNOC Environmental Manager will forward the report to the THC.I. If assessment activity exposes human remains (burials, isolated teeth, or bones) all defined procedures outlined in the following section will be followed. OPGP03-ZO-0025 Rev. 13 Page 50 of 50 Site Environmental Compliance Addendum 5 Unanticipated Discovery of Cultural Resources Page 3 of 3 Special Procedures for the Discovery of Human Skeletal Material Any human skeletal remains regardless of ethnic origin, which may be discovered during this project will at all times be treated with dignity and respect.A. During all project operations if any STPNOC employee or any of the contractors or subcontractors believes that they have made an unanticipated discovery of human skeletal remains, all work adjacent to the discovery shall cease. The area of work stoppage will be adequate to provide for the total security, protection, and integrity of the human skeletal remains. No persons other than the proper law enforcement personnel, STPNOC Cultural Resource Consultant(s), and the THC will be authorized direct access to the discovery location after the area is secured. If the remains are determined to be of Native American ancestry thorough consultation with the THC, tribal access will only be allowed to the designated representative(s) of the affected tribes'. Coordination for tribal member access must go through the designated tribal representative. The strict control of a burial location is mandated to insure the safety and integrity of the burial feature and remains.B. Representatives of STPNOC are responsible for taking appropriate steps to protect the discovery.. The immediate area will be secured to a distance adequate to provide for the total security, protection, and integrity of the resource. Vehicles, equipment, and unauthorized personnel will not be permitted to traverse or enter the discovery site.C. STPNOC will immediately call the Matagorda County Sheriff's Office and will ensure that an individual competent and qualified to identify human skeletal remains is present. If possible, the ethnic origin, or ancestry, of the discovered human remains will be determined through consultation with the THC, County Coroner and the THC-determined affected tribe. The local law enforcement official may arrange for a representative of the county coroner's office to assist the STPNOC Cultural Resource Staff in the examination of the discovery and together will determine whether it should be treated as a crime scene or as a human burial of Native American ancestry.D. If disinterment of Native American human remains becomes necessary, the consulting parties, which will include STPNOC, THC, and the affected tribe(s), will jointly determine the final custodian of the human skeletal remains for reinterment. E. STPNOC and/or the FHWA will make a good faith effort at accommodating requests from the affected tribe(s) to be present after they are notified of discoveries, and prior to the implementation of mitigation measures related to the human remains. TER-3. Austin Energy T-Line ROW Management Summary, January 1, 2010[STPLR-446] 743 [Page I of I

Dearing,

Krista From: Schattenberg, Carl [Carl.Schattenberg@austinenergy.com] Sent: Thursday, January 07, 2010 1.18 PM To:

Dearing,

Krista; mmsimons@STPEGS.COM Cc: Weise, Doug; Sloan, David; Henning, Ray

Subject:

Land Use Information for NRC Audit Binder Attachments: IEEE516.PDF; Original TreeSpec 97 05 Update with 11-15-05 revisions.doc Friends, I received a request to forward to you information regarding Austin Energy (AE) Transmission ROW vegetation management on AE circuit 3123 and 3124 from the STNP Corridor at Danevang to Holman substation near La Grange. I hope the following information meets your needs." Austin Energy (AE) last performed ROW vegetation management in 2006 with extensive ROW dearing of brush and trees in the 100 foot ROW." Austin Energy is scheduled to perform vegetation maintenance on our four-year cycle, scheduled maintenance this year, 2010 We are scheduled to begin field work on this ROW sometime in March, 2010* AE has completed our property ownership research and we are beginning our field patrols of the ROW to assess vegetation conditions. Preliminary findings are that the ROW vegetation conditions are still very good, with good clearances and access." AE has an aggressive and thorough vegetation management program utilizing herbicide applications, tree removals and mowing to control vegetation to prevent outages and maintain facility access." AE Forestry Transmission Program is managed according to AE Tree Pruning and Line Clearance Specifications (attached). The methods of ROW maintenance that more direct our practices on this ROW are outlined on page 4, item B of these specifications. This is paraphrased as "any vegetation in the AE right-of-way that has the potential to grow into the clearance zone (20 feet minimum clearance near poles or structures and 25 feet at mid-span) of the transmission conductors, should be targeted for removal... As right of way conditions allow, the right of way may be kept clear of woody vegetation by mowing or other appropriate methods." (specifically herbicide applications)." AE's specifies removal of trees that have the potential of growing into the clearance zone surrounding the conductors, which is a minimum of 20 to 25 feet; and in most cases much more clearance distance is achieved; which allows for four to five years of above-average tree growth.These distances are in addition to the 9.4 feet minimum distance for 345kV from the IEEE 516 2003 Clearances (table attached)." AE Transmission Construction and Maintenance personnel patrol this transmission ROW twice a year and report any vegetation concerns to AE Transmission Forestry Section for immediate attention for vegetation maintenance. Please let me know if this is the appropriate information you need. If you require any additional supporting information, please don't hesitate to contact me via e-mail with the specifics needed, or call me at one of the phone numbers given below.Thank you, Carl Schattenberg Utility Forester Austin Energy (512) 322-6931 (Office)(512) 801-4997 (Cell)1/7/20 10 TER-4. Austin Energy Tree Pruning and T-line Clearance Specs, November 7, 2005, [STPLR-448] /4-- STPL_- 446 AUSTIN ENERGY TREE PRUNING AND LINE CLEARANCE SPECIFICATIONS INTRODUCTION These Tree Pruning Specifications and Requirements, together with the American National Standards Institute ANSI A300, "Standard for Tree Care Operations" (as approved May 22, 2001, or subsequent revision), shall govern all pruning and/or removal of any plant or tree growth interfering with the safe operation of any City of Austin Energy (AE) facility. Where any discrepancy or contradiction exists between this contract document and the ANSI standard, the requirements of the contract document shall prevail.The primary goal for the line clearance tree pruning program is to maintain a safe and reliable electrical transmission and distribution system. These specifications and requirements prescribe arboricultural standards to ensure consistent tree pruning practices, and efficient, economical line clearance maintenance. They shall provide a basis for determining whether tree pruning is necessary or appropriate, and shall dictate the arboricultural methods to be adhered to in the performance of the work activity described in this document.The AE is obliged and committed to compliance with the terms and conditions of City of Austin General Development Permit No. GP-05-0000.AEU, and any subsequent extension or renewal. The Vendor shall be familiar with these terms and conditions, and will ensure that no violations occur as a result of the Vendor's actions.All tree work shall conform to approved principles and techniques of modern arboriculture. Proper line clearance tree pruning shall direct tree growth away from electrical conductors and facilities, extend pruning cycles, and reduce the overall amount of future pruning work required. The AE shall determine the appropriate distances between all plant or tree growth and electrical facilities. Because of the difficulty in developing line clearance tree pruning policies which would cover all circumstances, the AE reserves the right to assess, on a case-by-case basis, any special situations where the strict application of these specifications and requirements might be impractical or inappropriate. I. PRUNING SPECIFICATIONS The following specifications shall apply to all tree pruning unless otherwise specified herein. For the purpose of this line clearance tree pruning contract, a tree shall be considered to be a self-supporting woody perennial plant, having a trunk diameter of no less than two inches (2") at maturity, measured at four and one-half (4-1/2) feet (Qiameter at Breast Height, or DBH), with one (1) or more branches developing from the stem or trunk. Plants containing multiple trunks or stems, each of which exceeds two inches (2") in diameter (DBH), will be considered to be one (1) tree when those stems originate from a common root crown, or are less than six inches (6") apart.A) The most important technique in pruning a tree is the collar cut. This term refers to the final pruning cut to remove a limb just outside the raised portion (branch collar) of the branch junction with the trunk or another limb. A proper collar cut will minimize the exposed surface area of the cut surface.All limb or branch removals shall be performed using the collar cut method.B) When removing a lateral branch at its point of origin on the trunk or parent limb, the final cut shall be made in branch tissue close to the trunk or parent limb, without cutting into the branch bark ridge or collar, or leaving a stub. (ANSI A300 Standard 5.3.2 and 5.3.3).C) When removing a dead branch, the final cut shall be made just outside the collar of live tissue. If the collar has grown out along the branch stub, only the dead stub shall be removed. The live collar shall be left intact and uninjured. (ANSI A300 Standard, 5.3.5).D) No stub and/or flush cuts shall be left on the trunk or supporting branch unless specifically requested by the property owner and specifically approved by the AE, prior to the removal of branch or limb.11/07/05 1 Specifications and Guidelines Original TreeSpec 97 05 Update.doc AUSTIN ENERGY TREE PRUNING AND LINE CLEARANCE SPECIFICATIONS E) Old stubs from prior stub cuts that have re-sprouted and re-grown into the electrical conductor clear area shall be removed to the branch collar of the stubbed-off limb, or may be pruned to a lateral limb, behind the stub, large enough to assume the terminal role, consistent with these pruning specifications and requirements. F) The three-cut method should be used in order to prevent ripping or peeling of the bark on the trunk or parent stem from which the limb is removed.G) When a leader, dominate or co-dominate stem is to be removed, it shall be removed back to a lateral limb or branch no less than one-third (1/3) of the diameter of the portion being removed.H) When removal of an entire lateral limb back to the branch collar on the parent stem would remove excessive branch tissue and foliage, and is not necessary to obtain the required line clearance, the leader of a lateral limb may be pruned to a lateral limb large enough to assume the terminal role. In making a thinning cut in this instance, the final cut shall be beyond the branch bark ridge of the crotch.I) All final lateral pruning shall be concluded at a branch collar on the supporting branches or trunks growing away from the electrical facility, so that the growth of the tree is directed away from electrical facilities (directional pruning).J) Directional pruning is used to redirect side growth away from the electrical facilities. Limbs growing towards the facilities are removed to appropriate limbs or trunk to train the tree away from the electrical facilities. K) Drop crotch pruning is used to reduce the height of a tree by removing dominant or co-dominant stems in the center of the crown of the tree and direct growth away from the electric lines overhead.This method of line clearance pruning is most often used when the conductors are involved with the center of the tree crown. Limbs should be cut at the branch bark ridge, consistent with proper arboricultural techniques, as detailed in B) above.L) All tree pruning wounds and other wounds caused by AE operations on oak trees shall be treated promptly with a thin but complete covering of an approved non-phytotoxic tree wound dressing.Wounds on oaks shall be treated before moving to another part of the tree, and prior to descending the tree. All oak stumps shall be painted with a tree wound dressing, as required on all oak wounds.No other tree species shall be painted unless specifically requested by the property owner, or directed by the AE. (ANSI A300 Standard, 5.4.1).M) Rips and peels are not acceptable and shall be avoided, but if they occur, tree wound dressing may be applied, as a cosmetic treatment only. Tree wound dressing may be applied as a cosmetic treatment on large wounds.N) To help prevent the spread of various types of tree diseases, all cutting tools (hand and powered)shall be surface disinfected with a seventy percent (70%) or higher solution of alcohol and water.Other disinfectants, such as Lysol and 50% chlorine bleach (sodium hypochlorite) and water solution may be substituted. Disinfectants shall be applied prior to commencing any pruning on the job site, and immediately after pruning oaks suspected to be infected with oak wilt in a designated diseased area.11/07/05 2 Specifications and Guidelines Original TreeSpec 97 05 Update.doc AUSTIN ENERGY TREE PRUNING AND LINE CLEARANCE SPECIFICATIONS II. LINE CLEARANCE Line clearance distances attained during tree pruning operations shall vary depending on the power line voltage and the type of trees encountered. Higher voltage power lines require greater clearances. Fast growing trees shall be pruned to provide more clearance from electrical facilities than slow growing trees.The tree pruning operation shall provide clearance as appropriate for the line voltage and average growth rate of the affected trees, with the overall objective of achieving a minimum four (4) to five (5) year pruning cycle.Line clearing shall begin only after careful consideration of the position occupied by the electric facility relative to the adjacent trees, and the growth rate of the affected trees.The clearances specified shall be consistently achieved. Special efforts shall be undertaken for reasonable resolution of any property owner objections or disputes.DISTRIBUTION FACILITIES If the pruning required to obtain adequate clearance from an electric facility (i.e., leaning pole, low pole height, sagging wire) would significantly affect the shape of the tree, the Vendor shall consult with the AE Inspector to determine if the electric facilities can be adjusted to reduce the pruning required.Telephone or TV Cable facilities shall not be considered in determining line clearances. A) Primary conductors 600 volts to 12,500 volts -Minimum clearance shall be 6 to 8 feet, depending on the tree species. Additional line clearance may be required to allow for the annual growth of the vegetation to maintain a 4 -5 year right-of-way maintenance cycle. The Vendor shall remove all overhang above the top of the pole or primary conductor, or as directed by the AE.B) Secondary conductors less than 600 volts -Minimum clearance shall be 4 to 6 feet, depending upon tree species. Additional line clearance may be required to allow for the annual growth of the vegetation to maintain a 4 -5 year right-of-way maintenance cycle.C) Service drops and streetlight conductors -2 to 3 feet, depending upon tree species. Service drops and street light conductors will only be pruned when Vendor crews are working in the area and limbs are applying pressure to the facilities. The cost effectiveness of re-routing the wires will be considered before any line clearance work is completed. Tree removals will not be done on these wire types.D) Poles, Guy Wires, Down Guys, Transformers, and Other Electric Facilities -The Vendor shall free guy wires and down guys of weight, strain or altered position caused by contact with tree limbs or branches. Guy wires, down guys and poles shall be free of vines. The AE, at its sole discretion, shall determine whether to cut and/or remove all vines or plant growth obstructing or limiting accesses, at the base of, or on the affected electric facility.E) Street lights and night watchmen lights will not be part of the Utility Forestry Section line clearance program. Any trees that need to be maintained for illumination purposed are solely the responsibility of the owner or PARD.F) New Construction -The customer requesting service will be asked to be responsible for clearing all trees in the ground easement to meet the requirements of the AE. All required tree removal permits will be the responsibility of the customer and will be completed by the customer. The AE's Vendor will be responsible for pruning all trees to establish necessary aerial clearance to provide safe and reliable electric service.11/07/05 3 Specifications and Guidelines Original TreeSpec 97 05 Update.doc AUSTIN ENERGY TREE PRUNING AND LINE CLEARANCE SPECIFICATIONS TRANSMISSION FACILITIES -69,000 volts to 345,000 volts Wherever possible, the following transmission specifications shall be obtained by the Contractor. The Vendor shall inform AE personnel where these clearances can not be obtained.A) Trees and other vegetation will be pruned or removed to allow for a minimum of 20 feet of clearance near all transmission conductors, poles or structures and a minimum of 25 feet at mid-span, to allow for sag and sway. Additional line clearance may be required to allow for the annual growth of the vegetation to maintain a 4 -5 year right-of-way maintenance cycle. The AE, at its sole discretion, shall determine whether to cut and/or remove plant growth obstructing access at the base of the transmission facility.B) In rural or undeveloped areas, as right of way conditions allow, any vegetation in the AE right-of-way that has the potential to grow into the clearance zone (20 feet minimum clearance near poles or structures and 25 feet at mid-span) of the transmission conductors, should be targeted for removal.Any vegetation in the AE right-of-way, or beneath the transmission conductors, that has the potential to obstruct right of way access, or access to the transmission structure should be targeted for removal. This includes trees growing beneath conductors and structures, vegetation blocking AE access gates and any vines on facilities. As right of way conditions allow, the right of way may be kept clear of woody vegetation by mowing or other appropriate methods.C) The Contractor shall remove all overhang above the top of the transmission conductors and structures. D) A corridor will be maintained free of any woody plants to provide access by AE to the transmission facilities to repair and maintain the transmission grid.E) Any hazardous tree within the right-of-way that poses a hazard to any transmission facility, at the sole discretion of the AE, should be pruned or removed to mitigate the hazard. Any vegetation outside of the AE right-of-way that presents a hazard to the transmission facilities will be pruned back or removed to the limits of the right-of-way. F) Poles, Guy Wires, Down Guys, and Other Transmission Facilities -The Vendor shall clear tree limbs or branches a minimum of 4 -6 feet from guy wires and down guys. The Contractor shall cut and/or treat all vines growing on all transmission facilities. The AE, at its sole discretion, shall determine whether to cut and/or remove plant growth obstructing access at the base of the transmission facility.F) In designated Balcones Canyonlands Preserve (BCP) bird habitat areas, proposed line clearance work must be submitted for the BCP review process for approval. Access corridors shall not exceed 20 feet in width, unless to allow for clearance of truck booms. In accordance with the review process, line clearing is limited to the removal of fast growing species directly below transmission conductors and pruning to provide at least 20 feet of clearance from conductors. Line clearance activity, other than emergency response, is prohibited in these habitat areas between March 1 and September 1.G) In any other area determined to be endangered species habitat by the US Fish & Wildlife Service, any proposed line clearance work must be submitted for review prior to initiating work. Work scheduling, and certain clearing methods may be restricted by the US Fish & Wildlife Service.TREE REMOVALS Tree removals are an unavoidable component of a utility forestry program. Problem trees and other vegetation often need to be removed from near electrical facilities to correct a hazardous situation, improve service reliability, and to provide access to the electrical facilities. When considering a tree removal, the AE personnel or Vendor needs to consider the condition and specie of the tree, its placement and the priority of the tree removal. Every reasonable effort should be made to communicate 11/07/05 4 Specifications and Guidelines Original TreeSpec 97 05 Update.doc AUSTIN ENERGY TREE PRUNING AND LINE CLEARANCE SPECIFICATIONS with the customer to obtain informed consent prior to removal of these problem trees from near the electrical facilities. TREE REMOVAL CANDIDATES A) Dead, dying, diseased, or unstable trees (danger trees) which presents a danger to utility facilities or where a tree is destabilizing utility structures. B) A tree that is totally involved with the utility facility and can not be effectively pruned to provide adequate clearance from electrical facilities and the continued health of the tree. Such trees located near schools, or other public areas where a person could easily climb and contact the electrical facilities present a serious safety concern.C) Fast-growing trees that may interfere with the electrical facilities, present a safety concern and/or hinder service reliability before the next tree maintenance cycle.D) Trees with dominant terminal leaders (pines, etc.) that can not be directionally pruned away from the electrical facilities E) Immature trees that can be economically removed from near the electrical facilities to prevent future reliability concern TREE REMOVAL CONDITIONS A) With the informed consent of the property owner or customer, removal of trees should be limited to the area within the distribution easement or up to ten feet either side of distribution conductors and within transmission rights of way, unless a dangerous situation exists.B) A tree removal should be cost effective to the AE. A tree removal should be limited to twice the time it would take to prune the tree. Exceptions would include trees near the main line circuits and danger trees, C) Low-growing trees, which have a mature height of less than 25 feet, should not be removed unless directed by the AE for access and clearance around electrical facilities. D) Stumps shall be cut as close to the ground as possible. All oak tree stumps shall be painted with a tree wound dressing, as required on all oak wounds. With customer consent, the stump will be treated with an EPA -approved herbicide to prevent re-sprouting. E) All proposed removals of trees 8" in diameter at breast height (DBH), or larger, must be reported by AE or Vendor field personnel to the Utility Forester for review and submittal to the City Environmental contacts at least two days prior to removal. Any proposed removals of treesl9" DBH, or larger, must be have a signed permit approved prior to pruning 33% or more of the canopy, or prior to removal of the tree, as required by the City Protected Tree Ordinance. INDIVIDUAL REQUESTS FOR ASSISTANCE-TICKETS The AE receives numerous requests from customers to prune trees on their property near the electrical facilities. The Utility Forestry Section is responsible for evaluating and taking appropriate actions on these requests. The following shall apply to individual requests for pruning trees near to AE facilities. General Specifications Each request shall be evaluated individually, and may require a site visit by AE or Vendor personnel. 11/07/05 5 Specifications and Guidelines Original TreeSpec 97 05 Update.doc AUSTIN ENERGY TREE PRUNING AND LINE CLEARANCE SPECIFICATIONS A) If is determined that the customer request should be granted on an expedited basis, at the direction of Owner, the Vendor shall schedule and perform the work as soon as possible.B) The customer may be directed, at the option of the AE, to request a temporary disconnection of their service drop to allow safe tree pruning or removal by the customer, without the services of the Vendor.C) The Vendor will be required to provide the AE with information on work order status for customer request jobs on a weekly basis.TOPPING FOR REMOVAL Property owners will often request AE assistance with tree removals near the electrical facilities. The Inspector or Vendor will evaluate the removal and determine if its removal by the property owner would constitute a threat to the electrical facilities. In cases where a threat is perceived, the Inspector or Vendor will work with the property owner to remove any parts of the tree that are in danger of contacting the electrical facilities. It is the property owner's responsibility to remove the rest of the tree. Listed below are the AE procedures. A) At the request of a property owner, with notification and approval of appropriate City Environmental authorities, the AE will direct the Vendor to remove only those branches which could come into contact with the electrical facilities for the property owner to safely complete the tree removal.B) If necessary, AE facilities shall be temporarily removed or de-energized by the AE to permit safe removal of the tree by the property owner.C) For removal of trees sixty inches (60") or more in circumference, or nineteen inches (19") or more in diameter (DBH), measured four and one-half (4-1/2) feet from ground level, the property owner is required, under City ordinance, to obtain an approved tree removal permit from the City Arborist's office. The Vendor shall not commence work prior to verification of the required permit.DISPOSAL OF PRUNED MATERIAL Wood chips are usually disposed of at the specified locations agreed to by the Owner and Vendor. An agreement between the City Parks Department and Austin Energy will allow the Vendor to dispose of chips at designated park locations. The following shall apply to cleanup, removal and disposal of pruned material.A) The Vendor shall remove and dispose of only those trees, plants or portions of trees pruned by the Vendor. When possible, removal and cleanup shall be completed daily by the Vendor before leaving the job site. No cut limbs, woody debris, trash or other debris will be left on the premises without prior consent of the property owner and responsible AE personnel. No woody debris, trash or other debris will be left in roads or drainage ditches.B) Removal and disposal of portions of any tree pruned by the property owner, or portions of any tree not affecting the electrical facilities, are the responsibilities of the property owner.C) The Vendor shall promptly clean up and remove all debris produced by AE personnel performing routine or emergency tree pruning when instructed by appropriate AE personnel. D) The Vendor should make every effort to find alternate dump sites for chips or woods, with property owner approval, near the work location if at all possible. Any alternate disposal sites must meet any environmental restrictions for the particular area and must not be left in roads, ditches or adversely affect drainage or access.11/07/05 6 Specifications and Guidelines Original TreeSpec 97 05 Update.doc & 'AUSTIN ENERGY TREE PRUNING AND LINE CLEARANCE SPECIFICATIONS E) Oak wood from Spanish, Blackjack or red oak trees suspected of being infected with oak wilt disease shall not be left on site and shall be disposed of at the appropriate location.F) Any woody debris generated by the crews that can not be disposed of near the work site shall be transported to a temporary dumpsite provided by the Vendor. Logs and chips must be separated at the site or at the temporary dumpsite for transportation to the appropriate dumpsite.G) Any non-woody debris (paper, plastic, cans, metal, etc.) shall be disposed of separately from the woody debris.11/07/05 Original TreeSpec 97 05 Update.doc 7 Specifications and Guidelines TER-5. Pesticides and herbicides associated with operational maintenance of the transmission lines [STPLR-410] Denton Environmental Inc.Prescription for Circuit Code & Name: 39A WAP-STP,64C WAP-Hfllje,72C WAP-Hillje Prescribed by: David Denton Date of Prescription: 07/18/08 JEstimated Start Date 10/01/08 JEstimated Completion Date 12/08/08 Proactive I X ICapitol I Mileage: 103.9 Row Width Varies Tower Numbers WA Parish I to Hillje Type of work to be completed on Circuit Trimming IYes [ Mowing I Yes Herbicide (High Vol.& Low Vol Basals ) 1 Access Mowing T Yes Reclaiming of Right of Way Yes Visible Damage to Structures? No If yes, explain N/A Photo's taken? None Types of Vegetation: All types Ground Conditions: Currently dry Sub-Contractor Information Will Sub Contractor be used on Circuit? No jHas Sub -Contractor been approved by Centerpoint? NA Comments: Com Name of Sub Contractor ..Estimated dollar amount for Sub-Contractor on Circuit: $0.00 Ty e of Equipment and Crew Hours (not man hours)Manual 295 Jarraff I145 I Herbicide 1 170 1 Tractor 1 0 1 Boom Sprayer 0 Bucket 0 I BTC 159 Supervisor 200 SUB -CONTRACTOR EQUIPMENT (Type of Fxipment GEO-BOY. Total Hours) 0 Estimated dollar amount for Circuit + Sub Contractor $100,0.00 Foreseen Problems: Should be no problems with Circuit.Comments / Special Instructions: All reclaiming of ROW, Herbicide, 10' Access Path, Jarraff side trimming, Removals.PRESCRIPTION: WA Parish to 19068 Clear structures & spakil spray towers only; ckt cleard with 02B 19068 to 19099 Side trim S side;spray basils;mow access, clean towers.There is aout 8 cross fences to clear as well. Some areas complete ROW Mowing 19099 to 19121 Side trim S side;spray basils;mow access, clean towers.19122 to 19125 Lots of small basils to spray before mowing ROW, side trimming; Herbicide; Mow access.19126 to 19128 Clean fences 19128 to 00745 Side trim, mow access, spray basils, herbicide, mow access. This area will be mowed with Supp mowing in July 00745 to 00731 Side trim N & S side of ROW, mow access & brances, herbicide, clean towers. This area gets mowed with Supp mowing.00731 to 00730 Clean both sides of river by hand -four fences.00730 to 00710 Grass farm; just clean towers and herbicide 00708 to Small trees to remove, side trim, clean towers, herbicide; Mow branches and access 00701 to New Gulf Clean ditches & fences; side trim, clean towers, mow access, herbicide (cow pasture) Denton Environmental Inc.Prescription for Circuit Code & Name: 39A WAP-STP,64C WAP-Hillje,72C WAP-Hillje 00691 to 1 00671 Clean ditches & fences; side trim, mow access, spray basils (cow pasture)00671 to 00651 Corn fields; Just clean towers and spray 00651 00646 00637 00635 28535'28541 28542 28560 28560 28571 28576 28576 28581 28581 28588 28590 28603 to 00647 Clean fences (5), spray basils, clean towers, mow access to 00641 Barley fields; Just clean towers and spray.to 00635 Soy bean fields to 00625 Clean towers to end of CP ownership, mow and light side trimming.to 28541 Side trim (light), clean towers, pick up branches, Rancher very picky, mow access, spray herbicide. to 28542 Clean river edges and spray.to 28555 Spray basils, mow entire ROW, clean towers, side trim.to Clean ditch and fences, spray.to 28569 Spray basils, clean fences, mow access, clean towers.to 28574 Crossing Milo field, just clean towers.to Clean ditch on both sides of road; spray.to 28581 Rice field; clean towers.to Clean ditch and spray.to 28588 Corn fields; Just clean towers and spray to 28589 Side trim, folier spray, mow entire ROW, clean towers.to 28600 Clean ditch, mow entire ROW, spray herbicide, clean fence to Hillje Corn fields; will have to clear towers, fences, and spray. AQ-1. McAden, D. C., G. N. Greene, and W. B. Baker 1984. Colorado River Entrainment and Impingement Monitoring Program, Phase Two Studies-July 1983-June 1984 (Report # 1). Prepared for South Texas Project by Ecology Division, Environmental Protection Department, Houston Lighting & Power Company. October. a-,/'rl...1"\SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION REPORT #1 COLORADO RIVER ENTRAINMENT AND IMPINGEMENT MONITORING PROGRAM PHASE TWO STUDIES -JULY, 1983 -JUNE, 1984 OCTOBER, 1984 REPORT #1 COLORADO RIVER ENTRAINMENT AND IMPINGEMENT MONITORING PROGRAM PHASE TWO STUDIES -JULY, 1983-JUNE, 1984 PREPARED FOR SOUTH TEXAS PROJECT SUBMITTED BY ECOLOGY DIVISION, ENVIRONMENTAL PROTECTION DEPARTMENT HOUSTON LIGHTING & POWER COMPANY OCTOBER 1984 PREPARED BY: DAVID C. McADEN, GEORGE N. GREENE, WILLIAM B. BAKER, JR. TABLE OF CONTENTS PAGE LIST OF TABLES ............... ............................ .i..INTRODUCTION ............... ............................. .I.METHODS ...................... ............................... 2 SAMPLING SCHEDULE AND STATIONS .......... .................. 2 FIELD AND LABORATORY PROGRAMS ....... .................. 2 Impingement ............. ......................... 2 Entrainment ............ ......................... 3 Colorado River ............ ..................... 4 Siltation Basin ............. .............. .... 7 RESULTS AND DISCUSSION ............... ........................ 8 HYDROLOGY AND WATER QUALITY ....... ....................... 8 MACROZOOPLANKTON AND ICHTHYOPLANKTON ........ ............... 9 MACROINVERTEBRATES AND FISH ........... ................... .13 LIST OF TABLES TABLE 1 TEMPORAL VARIATIONS IN TEMPERATURE, TURBIDITY, pH AND DISSOLVED OXYGEN AT MID-CHANNEL OF THE COLORADO RIVER (JULY-SEPTEMBER, 1983)PAGE...15 2 TEMPORAL AND SPATIAL VARIATIONS IN CONDUCTIVITY (MILLIMHOS/CM) AT MID-CHANNEL OF THE COLORADO RIVER (JULY-SEPTEMBER, 1983)16 3 TEMPORAL AND SPATIAL VARIATIONS IN SALINITY (PPT) AT MID-CHANNEL OF THE COLORADO RIVER (JULY-SEPTEMBER, 1983) ..... .......... 4 TEMPORAL VARIATIONS IN SURFACE WATER QUALITY PARAMETERS IN THE RMPF SILTATION BASIN (AUGUST-SEPTEMBER, 1983) .........5 TEMPORAL VARIATIONS IN TEMPERATURE, CONDUCTIVITY, SALINITY, DISSOLVED OXYGEN AND pH AT THE STP REVOLVING SCREENS (JULY-SEPTEMBER, 1983) ........... ..................... 6 AVERAGE COLORADO RIVER FLOW (CFS) ON DATES OF SAMPLE COLLECTION, JULY-SEPTEMBER, 1983 ...... ..... ....................... 7 RESERVOIR MAKEUP PUMPING FACILITY (RMPF) DAILY PUMPAGE, IN CUBIC METERS, JULY-SEPTEMBER, 1983 ..... ................ 8 MACROZOOPLANKTON AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET, JULY-SEPTEMBER, 1983 .......... 9 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 14-15 JULY 1983 ....10 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 27-28 JULY 1983 ....11 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 9-10 AUGUST 1983 ....12 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 15-16 SEPTEMBER 1983 13 LIST OF FISH TAXA COLLECTED IN O.5-M PLANKTON NET SAMPLES FROM THE COLORADO RIVER (C.R.) AND THE SILTATION BASIN (S.B.), JULY-SEPTEMBER, 1983 .............................. 14 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 14-15 JULY 1983 ....15 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 27-28 JULY 1983 ..* ...17* ...18* ...19* ...20...21* ...22.... 25....27* .29....32....33 S. .. 34 i LIST OF TABLES TABLE 16 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 9-10 AUGUST 1983 ....17 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 15-16 SEPTEMBER 1983 18 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON AND ICHTHYOPLANKTON COLLECTED IN THE SILTATION BASIN BY O.5-M PLANKTON NET ON 9-10 AUGUST 1983 ... ......................19 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON AND ICHTHYOPLANKTON COLLECTED IN THE SILTATION BASIN BY O.5-M PLANKTON NET ON 15-16 SEPTEMBER 1983 ........... ...................... 20 MACROINVERTEBRATE AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY TRAWL, SEINE AND REVOLVING SCREENS, JULY-SEPTEMBER 1983 21 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY TRAWL ON 14-15 JULY 1983 ........ ... .................... PAGE... .35....36 S.. ..38... .39 41 22 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY TRAWL ON 27-28 JULY 1983 ........... ........................ ..42 23 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY TRAWL ON 9-10 AUGUST 1983 ............ ....................... ..44 24 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY TRAWL ON 15-16 SEPTEMBER 1983 ........... ..................... ..45 25 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 14-15 JULY 1983 ........... ........................ ..46 26 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 27-28 JULY 1983 ............ ........................ ..47 27 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 9-10 AUGUST 1983 ............ ....................... ..48 28 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 15-16 SEPTEMBER 1983 ........... ..................... ..49 ii LIST OF TABLES TABLE PAGE 29 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 13-14 JULY 1983 .............. ..................... 50 30 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 21-22 JULY 1983 .............. ..................... 50 31 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 27-28 JULY 1983 .............. ..................... 51 32 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 9-10 AUGUST 1983 ........... ..................... 51 33 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 15-16 SEPTEMBER 1983 ........ ................... .52 iii INTRODUCTION Section 6.1.3.2 and Appendix E of the Final Environmental Statement requires Phase Two of the aquatic ecology studies to begin within one week of the start of reservoir fill pumping. The objective of Phase Two studies is to determine the number and type of aquatic organisms which are (a) impinged on the revolving screens and (b) entrained by the reservoir fill pumps during the filling of the main cooling reservoir. Phase One studies, conducted in 1975-76, resulted in predictions of impingement and entrainment losses and Phase Two is designed to confirm the accuracy of those predictions. Sampling methods remain the same as in Phase One. Phase One samples were collected at four locations in the Colorado River, designated as Stations 1,2,3 and 5.Phase Two samples are to be collected only at Station 2, i.e., in the Colorado River adjacent to the Reservoir Makeup Pumping Facility (RMPF) and in the Siltation Basin, the body of water located between the RMPF revolving screen structure and the pump structure. On 11 July 1983, cooling reservoir filling operations began at the South Texas Project in Matagorda County, Texas. This report presents data collected during July, August and September 1983. After the third week of September, no further reservoir filling occurred in 1983 or through the first six months of 1984. The data presented in the following report therefore constitute the information collected during the period July, 1983, through June, 1984.1 METHODS SAMPLING SCHEDULE AND STATIONS The aquatic ecology study is divided into two distinct types of studies, impingement and entrainment, requiring different gear types and methodologies. The impingement study is conducted on the revolving screen structure, which extends 423.5 ft along the west bank of the Colorado River at River Mile 14.6.The entrainment study is conducted at two locations:

1) in the Colorado River adjacent to and slightly downstream of the screen structure, and 2) in the siltation basin between the pump structure and the submerged weir.FIELD AND LABORATORY PROGRAMS Impingement Impingement samples are collected within one week of the start of each pumping period and weekly thereafter as long as pumping continues.

Each week, three samples are collected over a 24-hr period. Prior to the start of each revolving screen sample, 2 of the 24 screens are selected at random and run for 15 min to clean them of accumulated debris. The two screens are then sampled for a 30-min period by placing a tight-fitting dip net with 1/4-in mesh at the lower end of the screenwash trough and filtering all the organisms washed off the screens. While the sample is being collected, hydrology and water quality parameters are recorded from the siltation basin behind the screen structure. Surface and bottom readings of water temperature (°C), conductivity (millimhos/cm) and dissolved oxygen (ppm) and a surface reading of pH are recorded as are the number and size of RMPF pumps operating at the 2 time of sample collection. The Colorado River flow (cfs) is also noted on the field data sheets.After the two screens have been sampled for 30 min, the collecting net is checked for fish, shrimp and crabs. Those found are placed in a plastic sample jar, preserved with 10% buffered formalin and taken to the laboratory for identification and enumeration. In the laboratory, each sample is rinsed, sorted by species and the total weight by species and individual lengths (standard length for fish, total for shrimp) or widths (carapace width for crabs) are recorded. If over 50 individuals of the same species occur in a sample, a subsample of 50 is measured. The remainder are counted and the weight of the total is recorded.Entrainment Entrainment sampling commences within one week of the start of each cooling reservoir filling period and is conducted at least every other week as long as pumping continues. A set of samples is collected every 6 hrs over a 24-hr period. During the months of March-May and August-December, sampling is done weekly when the salinity at the -8.5 ft level in the Colorado River exceeds 3 ppt. Salinity probes have been mounted on a piling in the river near the RMPF at that depth and are connected to a continuous chart recorder to provide a record of salinity fluctuations. The recorder is checked daily and, if the 3 ppt level is exceeded, the appropriate personnel are notified to initiate sampling. During the initial months of pumping in 1983, instrumentation and procedural problems resulted in the total loss of 3 continuous salinity data. However, salinity data was collected in conjuction with biological sampling and is discussed later in this report.Colorado River Prior to the start of collection of each set of biological samples, surface and bottom readings of conductivity (which was later converted to salinity), water temperature and dissolved oxygen were taken at mid-channel of the Colorado River near the northern end of the RMPF screen structure. Additional conductivity readings were made at 5-ft intervals between the surface and bottom. The primary instrument used to measure these parameters was a Hydrolab Model 8002 with 8100 series probe assembly. A Yellow Springs Instrument Co. Model 51A temperature and dissolved oxygen meter and an American Optical Co. hand-held refractometer were used as a backup to the primary system. Surface pH was measured with a portable Altex Model 531153 pH meter and water transparency was determined using a 200-mm diameter Secchi disc.A 0.5-m diameter, 3:1 (length:mouth diameter) plankton net with 0.5-mm square mesh was used to collect plankton samples at mid-channel of the Colorado River. Samples were collected at the surface, mid-depth (10 ft) and near the bottom. The plankton net was attached to a sled to keep the net about 4 inches above the bottom during towing for the bottom sample. A General Oceanics Model 2030 digital flowmeter mounted in the center of the net mouth was used to calculate the volume of water filtered during each tow. The flowmeter reading was recorded prior to and at the conclusion of each plankton 4 tow. Each mid-channel sample was collected by lowering the net to the appropriate depth with the boat in a stationary position. All tows were made in the direction of river flow, i.e. north to south. Each tow started approximately 50 yds upstream of the RMPF and continued to a point approximately 50 yds downstream of the RMPF. Bottom tows were made at a slower forward speed than either the mid-depth or surface tows to insure that the net sled remained on the bottom. A wire-angle indicator and graduated towline were used to verify the depth from which the mid-depth sample was collected. This was maintained at about 10 ft as the depth of the channel is approximately 20 ft. The surface sample was taken by towing the net with the upper edge of the net mouth a few inches below the water's surface. At the end of each tow, the boat was held stationary in the river while the net was quickly brought to the surface. This was done in an effort to minimize contamination of the sample due to the net being towed upward through the water column above the level being sampled. At the end of each tow the net was rinsed from the outside to wash the sample contents into the cod end bucket. The sample was then placed in a plastic jar, labeled and preserved with 5% formalin. Rose Bengal was added to each sample several days before sample workup to facilitate visual separation of the organisms from trash and detritus.A 0.5-m diameter, 3:1 (length:mouth diameter) plankton net with 0.5-mm square mesh equipped with a General Oceanics model 2030 digital flowmeter and a cable depressor was used to collect oblique-tow plankton samples near the west shoreline of the Colorado River. Before each sample was collected, the flowmeter reading was recorded. After lowering the net to the bottom at the 5 north end of the RMPF screen structure, the net was towed downstream while the towline and attached plankton net was slowly reeled in. When the net reached the surface, the boat was stopped, the net raised and the flowmeter reading recorded. After rinsing the net down from the outside, the sample was placed in a plastic jar, labeled and preserved with 5% buffered formalin. Rose Bengal was added to each sample as described above.A 20-ft (headrope length) otter trawl, with 1 1/4-in stretched mesh in the upper end and 3/8-in stretched mesh in the cod end, was towed on the bottom parallel to shore at mid-channel of the Colorado River to determine the species composition and abundance of the nekton (fish and macroinvertebrates). Tows were of 5 min duration and were made in the direction of water flow.Each trawl tow began approximately 50 yds upstream of the RMPF. Each sample was emptied into a large tub and inspected for larger specimens of fish and invertebrates. These were identitied, weighed, measured and returned to the river. The remainder of the sample was preserved in 10% formalin and taken to the laboratory for analysis.Shallow shoreline populations of fish and invertebrates in the vicinity of the RMPF were sampled by use of a two-man bag seine. A 20-ft long x 6-ft high x 6-ft deep seine, with 1/2-in stretched mesh in the body and 1/4-in ace webbing in the bag, was pulled for a distance of approximately 75 ft along the west shore line downstream of the RMPF. The seine collections were made by pulling the seine in the upstream direction (south to north) as the current helps in holding the bag of the seine open. Specimens taken by seining were handled as described above for trawl samples.6 Siltation Basin The method originally chosen to sample organisms from the siltation basin was to pump water to the top of the RMPF pump structure deck where it would be filtered through an ichthyoplankton net. During the first two collecting trips, on 14-15 July and 27-28 July 1983, repeated attempts were made to collect samples by this method. However, the pump could not overcome the head involved. Therefore, no siltation basin samples were collected on those dates. On the third trip, surface plankton samples were collected by hand-towing a 0.5-m (mouth diameter) ichthyoplankton net, having 0.5-mm square mesh, parallel to the front wall of the pump structure. Hand-towing the net at a deeper level in the water was not attempted because of the danger of the net being pulled into the mouth of one of the operating pumps. Towing the net by boat in the siltation basin was not possible because of the small size of the basin and the presence of several submerged obstructions. 7 RESULTS AND DISCUSSION HYDROLOGY AND WATER QUALITY Water temperature, pH, turbidity (Secchi disc) and dissolved oxygen at the Colorado River station are given in Table 1. Tables 2 & 3 show the conductivity measurements and the derived salinity values. Water temperature, salinity, dissolved oxygen and pH in the RMPF siltation basin are given in Table 4. Water temperature, conductivity, salinity, dissolved oxygen and pH at the RMPF revolving screens are given in Table 5.On 14-15 July a wedge of salt water was present in the Colorado River extending up to about 10 to 15 ft below the surface. The wedge was 2.3 to 3.0 C warmer than the overlying fresh water and was low in dissolved oxygen (maximum of 0.9 ppm).On 27-28 July no salt wedge was present (0.9 ppt at bottom) and fresh oxygenated water extended to the bottom. A salt wedge was re-established on 9-10 August and 15-16 September extending up to 10 to 15 ft from the surface and even up to 5 ft on 9 August. The bottom oxygen was again very low on these two days (0.1 to 0.5 ppm).In the RMPF siltation basin the water quality of the surface water was similar to that of the surface water in the river on the same dates.At the revolving screens the water quality was similar to that of the river at comparable depths on the same dates.8 River flow during the sampling periods is shown in Table 6 and the daily volume of water pumped into the cooling reservoir during July -September, 1983 is shown in Table 7.MACROZOOPLANKTON AND ICHTHYOPLANKTON Samples collected by 0.5-m plankton net in the Colorado River yielded 49 taxa of invertebrates and 10 taxa of vertebrates, (Table 8). The dominant invertebrate forms were cladocerans, or water fleas, which are all freshwater organisms; copepods, both freshwater and estuarine-marine in origin; and Malacostraca, consisting of estuarine mysid shrimp, freshwater and estuarine amphipods, estuarine-marine penaeids (commercial shrimp), freshwater and estuarine carideans (grass and river shrimp) and various species of crabs.The fish were represented by as many as 10 taxa, but they were rarely a major component of any single sample. On some occasions, however, the bay anchovy did occur in large numbers.Tables 9-12 show the temporal and spatial variations in density of invertebrates collected from the Colorado River on each of the four sampling trips. The largest total numbers of organisms were collected in mid-depth, bottom and oblique tows and also innight collections. Higher densities appear to be closely related to the presence of a salt wedge at the -10 ft level and deeper, as occurred on 9-10 August and 15-16 September (See Table 3). A salt wedge also occurred on 14-15 July, but no bottom samples were collected on that trip because the bottom plankton net was lost during the first tow of the day.9 The most ubiquitous species, as well as the most abundant, was the zoea larval stage of the xanthid mud crab, Rhithropanopeus harrisii. The second most abundant forms were the zoeal and postlarval stages of the ghost shrimp, Callianassa spp. The postlarval stage of the brown shrimp, Penaeus aztecus, and the'white shrimp, P. setiferus, and the megalops and juvenile stages of the blue crab, Callinectes sapidus, were collected only sporadically and never in very high densities. It is possible that some of the crab megalops represented the non-commercial pygmy blue crab, C. similis, which is impossible to differentiate from C. sapidus at this stage of development. A list of the common and scientific names of the egg, larval and juvenile stages of the fish taxa collected from both the Colorado River and the siltation basin is found in Table 13.Tables 14-17 show the changes in abundance which were observed, both temporally and spatially, in the Colorado River ichthyoplankton during the study period. The most notable trends seen in this limited amount of data are: (a) the relatively small numbers of ichthyoplankters from the surface and oblique tows compared to the large numbers from the mid-depth and bottom tows and (b) the greater numbers of larval and juvenile fish in samples col-lected at night, regardless of depth. The bay anchovy was the most abundant species, due primarily to its peak in abundance on 27-28 July. One possible explanation for the anchovy's apparent high level of abundance is due to the low salinity observed from surface to bottom on those dates (see Table 3).The bay anchovy is an estuarine species preferring salinities in excess of 10 ppt, and the fact they were caught in such large numbers during a period of 10 high freshwater flow and salinities less than 1 ppt indicates they were under stress. This made them more susceptible to capture by a plankton net than they would be under normal conditions, when they are probably just as abundant, especially in the salt wedge (mid-depth to the bottom). The only other taxa collected regularly were two species of gobies and one category called Gobiidae larvae. The darter goby, Gobionellus boleosoma, and the naked goby, Gobiosoma bosci, are both estuarine, mid-depth to bottom dwelling species which are common over mud substrates in all Texas estuaries. The larvae of the two genera are indistinguishable below about 5 mm, thus resulting in the unidentified Gobiidae larvae category.Because ichthyoplankton were taken in such small numbers in the samples collected in the siltation basin, they are included with the invertebrates on the tables showing temporal changes in abundance of organisms at this location (Tables 18 and 19). Penaeus setiferus (white shrimp) postlarvae peaked in abundance during the night on both collecting dates, but were otherwise found only in low densities. Macrobrachium ohione, one of the river shrimps, and Rhithropanopeus harrisii, a xanthid mud crab, were the most abundant species in the basin. M. ohione were much more abundant in the basin than they were in the Colorado River on the same dates (see Tables 11 and 12). This is easily explained by the fact that river shrimp zoeae and juveniles, the life stages collected in these samples, prefer shoreline areas with protective vegetation cover to open river channel habitat. The front wall of the RMPF pump structure, along which the plankton net was towed, afforded a semblance of shoreline habitat by accumulating floating pieces of wood, dead grasses and other types of vegetative material. Further evidence for the shoreline nature 11 of the siltation basin sampling location is the occurrence of Gambusia affinis, a shallow shoreline species of fish known as the mosquitofish, on both the 9-10 August and 15-16 September collecting dates. The megalops and juvenile life stages of the blue crab, Callinectes sapidus, were the only other taxa occurring in fairly high densities, and this was only on 9-10 August when they also peaked in abundance in river samples. Notable by its absence from the siltation basin were Callianassa spp. zoeae, which were very abundant in the river. They are, however, primarily a mid-depth and bottom dwelling group and the sampling technique used was not adequate for detecting their presence.12 MACROINVERTEBRATES AND FISH Trawl and seine samples yielded eight macroinvertebrate species, five shrimp, two crabs and a crayfish (Table 20 and Tables 21-28). The grass shrimp, Palaemonetes paludosus, the river shrimp, Macrobrachium ohione, and the crayfish, Procambarus blandingi acutus, are freshwater animals whereas the three penaeid shrimp and the two crabs are estuarine and marine. The blue crab, Callinectes sapidus, however, is tolerant ot fresh water and is known to migrate far upstream in rivers.The river shrimp was the most common invertebrate (818) closely followed by the white shrimp, Peneaus setiferus (760). The majority of the river shrimp were caught in trawls on 27-28 July while the majority of the white shrimp were caught in seines on 15-16 September. Twenty-nine species of fish were collected in trawl and seine samples. Of these, four species are freshwater and 25 are estuarine or marine. The greatest number of species of fish (16) as well as the greatest number of individuals (3697) were recorded from the trawls taken on 27-28 July.However, because the majority (97.7%) of the fish caught that day were bay anchovies, Anchoa mitchilli, the diversity for that day is low. Except for the large number of anchovies on this one day, the catches in the trawls and seines were similar in number of species and total number of individuals taken.13 Impingement samples yielded 6 macroinvertebrate taxa, 2 of which were found only in the impingement samples (Tables 29-33). Palaemonid shrimp dominated the species list (4 of 6 taxa), but the majority of individuals were blue crabs. With few exceptions the individuals were small, less than 30 mm in length (or width in the case of crabs).Three species of fish were collected in the impingement samples, each represented by one individual. The green sunfish, Lepomis cyanellus, was the only freshwater fish and the only fish species caught by impingement that was not caught by trawl or seine.14 TABLE 1 TEMPORAL VARIATIONS IN TEMPERATURE, TURBIDITY, pH AND DISSOLVED OXYGEN AT MID-CHANNEL OF THE COLORADO RIVER (JULY-SEPTEMBER, 1983)01 Sampling Dates 14 July 14 July 14 July 15 July 27 July 27 July 28 July 28 July Time (CST)1100 1720 2300 0845 1300 1920 0120 0720 1155 1800 2330 0600 Temperature (°C)Surface Bottom 9 9 9 10 27.2 26.6 26.6 26.1 32.5 32.8 31.8 31.6 30.9 29.9 29.8 29.4 29.6 30.5 29.8 29.2 29.5 29.6 29.3 29.0 31.3 31.5 31.5 31.4 29.8 29.8 29.9 29.9 29.4 29.3 29.2 29.1 pH Surface 7.4 7.4 8.0 7.7 8.4 8.4 8.4 8.4 8.0 8.0 7.9 7.9 Secchi disk Turbidity (inches)16.5 13.0 12.5 11.0 14.0 17.0 18.5 19.0 25.5 24.5 25.5 26.0 6.1 6.5 6.4 7.2 10.5 10.9 9.6 9.4 7.6 7.9 7.1 6.1 8.1 10.2 9.6 7.3 0.6 0.4 0.4 0.9 5.9 7.2 5.7 6.4 0.1 0.1 0.1 0.1 0.1 0.5 0.5 0.5 Dissolved 0 (ppm)Surface Bottom Bottom Depth (ft)21 22 21 21 19 19 17 16 18 19 20 17 August August August August 15 15 15 16 September September September September 1200 1745 2330 0600 8.0 8.2 8.2 8.2 16.5 16.5 20.0 19.5 18 17 19 18 TABLE 2 TEMPORAL AND SPATIAL VARIATIONS IN CONDUCTIVITY (MILLIMHOS/CM) AT MID-CHANNEL OF THE COLORADO RIVER (JULY-SEPTEMBER, 1983)DEPTH (ft.)Sampling Dates 14 14 14 15 27 27 28 28 9 9 9 10 15 15 15 16 July July July July July July July July August August August August September September September September Time (CST)1100 1720 2300 0845 1300 1920 0120 0720 1155 1800 2330 0600 1200 1745 2330 0600 S 2.6 2.4 1.9 0.8 0.5 0.5 0.6 0.6 4.9 4.6 4.9 4.1 1.4 1.5 2.9 2.0 2.9 2.5 2.0 1.0 0.6 0.5 0.6 0.6 8.1 11.7 15.6 6.3 5.2 4.8 3.3 3.5 5 10 15 20 B (Depth)9.8 6.2 5.7 1.2 0.6 0.6 0.6 0.6 32.3 32.0 33.2 25.5 17.5 16.0 7.6 11.5 23.2 20.0 16.5 12.0 28.7 22.0 24.9 20.3 28.6 26.0 25.5 22.5 1.0 0.6 0.6 1.5 1.4 0.9 1.9 1.7 (21')(22')(21')(21')(19')(19')(17')(16')(18')(19')(20')(17')(18')(17')(19')(18')36.9 36.9 36.4 35.8 26.0 25.6 25.4 24.1 36.8 37.7 37.5 36.8 36.5 27.9 26.6 26.2 25.5 16 TABLE 3 TEMPORAL AND SPATIAL VARIATIONS IN SALINITY (PPT)AT MID-CHANNEL OF THE COLORADO RIVER (JULY-SEPTEMBER, 1983)DEPTH ( ft. )Sampling Dates 14 14 14 15 27 27 28 28 9 9 9 10 15 15 15 16 July July July July July July July July August August August August Time (CST)1100 1720 2300 0845 1300 1920 0120 0720 1155 1800 2330 0600 S 1.4 1.3 1.0 0.4 0.3 0.3 0.3 0.3 2.6 2.5 2.6 2.1 5 1.5 1.3 1.0 0.5 0.3 0.3 0.3 0.3 4.5 6.7 9.1 3.4 10 5.5 3.4 3.1 0.6 0.3 0.3 0.3 0.3 20.1 19.9 20.7 15.5 10.3 9.4 4.1 6.5 15 14.1 12.0 9.7 6.8 20 17.7 13.3 15.1 12.1 B (Depth)17.6 (21')15.9 (22')15.5 (21')13.6 (21')0.5 0.3 0.3 0.7 0.7 0.4 0.9 0.8 23.3 23.3 23.0 22.6 15.9 15.6 15.5 14.6-23.8-23.7 23.2 23.2-23.0-17.1-16.3-16.0-15.6 (19')(19')(17')(16')(18')(19')(20')(17')(18')(17')(19')(18')September September September September 1200 1745 2330 0600 0.7 0.7 1.5 1.0 2.8 2.6 1.7 1.8 17 TABLE 4 TEMPORAL VARIATIONS IN SURFACE WATER QUALITY PARAMETERS IN THE RMPF SILTATION BASIN (AUGUST-SEPTEMBER, 1983)Sampling Dates Time (CST)9 9 9 10 15 15 15 16 August August August August 1100 1640 2230 0450 1100 1705 2250 0545 Temperature (00)31.5 30.0 29.6 29.4 Salinity (PPT)2.8 2.7 3.2 2.4 Dissolved Oxygen (PPM)7.4 7.8 7.2 6.3 7.9 8.1 8.0 7.8 7.9 8.0 8.1 7.8 pH September September September September 29.4 30.3 30.1 29.4 1.2 1.0 1.6 1.4 7.5 9.2 8.1 7.8 18 TABLE 5 TEMPORAL VARIATIONS IN TEMPERATURE, CONDUCTIVITY, SALINITY, DISSOLVED OXYGEN AND pH AT THE STP REVOLVING SCREENS (JULY -SEPTEMBER, 1983)Sampling Dates Time (CST)Temperature (*C)Surface Bottom Conductivity (millimhos/cm) Surface Bottom Salinity (ppt)Surface Bottom Dissolved Oxygen (ppm)Surface Bottom (0 13 13 14 21 21 22 27 28 28 9 9 10 15 15 16 July July July July July July July July July August August August September September September 1329 2100 0511 1315 2110 0505 1400 2230 0626 1300 2100 0500 1414 2205 0615 27.5.27.2 26.6 29.6 29.4 29.5 32.9 31.9 31.6 30.7 29.7 29.4 30.1 30.2 29.3 27.5 27.4 26.8 29.4 29.8 29.8 32.1 32.5 32.0 30.3 30.2 29.6 29.4 30.2 29.8 4.6 5.0 3.5 0.4 0.4 0.4 0.6 0.6 0.6 5.0 6.2 4.4 1.6 2.4 2.3 6.0 5.9 3.9 0.4 0.4 0.4 0.6 0.6 0.7 13.8 12.2 5.8 4.0 6.0 5.2 2.5 2.7 1.7 0.2 0.2 0.2 0.3 0.3 0.3 2.7 3.4 2.3 0.8 1.2 1.1 3.3 3.3 2.1 0.2 0.2 0.2 0.3 0.3 0.4 8M0 7.0 3.2 2.3 3.3 2.8 6.5 6.1 6.1 6.2 6.6 6.6 8.9 11.0 9.2 8.0 7.5 7.0 8.1 8.4 7.6 5.2 6.8 6.1 5.4 6.1 6.2 8.7 10.8 8.9 6.3 7.1 5.8 6.7 7.0 6.3 pH Sur-face 7.4 7.5 7.4 7.9 7.9 8.0 7.8 8.6 8.1 7.9 8.0 7.9 8.2 8.2 8.0 Bottom Depth 4 3 3 4 7 8 8 7 9 9 6 5 7 7 9 TABLE 6 AVERAGE COLORADO RIVER FLOW (CFS) ON DATES OF SAMPLE COLLECTION, JULY-SEPTEMBER, 1983 DATE RIVER FLOW 13 14 15 21 22 27 28 9 10 15 16 July July July July July July July August August September September 492 1023 3149 2139 1676 713 825 637 2076 913 736*Derived by taking arithmetic mean of 3 daily flow values recorded at the beginning of each shift 20 TABLE 7 RESERVOIR MAKEUP PUMPING FACILITY (RMPF)DAILY PUMPAGE, IN CUBIC METERS, JULY-SEPTEMBER, 1983 DATE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 JULY 85,617.24 0 0 0 0 0 0 0 0 0 88,676.32 84,988.15 100,591.93 319,846.55 396,607.26 691,376.75 1,027,505.50 1,027,505.50 975,229.77 1,027,505.50 1,027,505.50 1,070,332.62 1,174,304.34 897,309.58 477,130.14 365,412.04 271,110.97 475,674.61 434,512.71 191,056.82 21,401.23 12,231,201.03 AUGUST 94,388.08 85,617.24 64,030.99 293,005.59 200,283.40 278,758.67 160,540.03 146,120.41 311,409.41 873,071.30 1,674,340.57 1,761,499.68 1,761,499.68 1,761,499.68 1,761,499.68 1,466,409.47 530,590.03 0 316,528.44 580,509.77 357,764.34 79,018.01 0 0 0 0 0 0 0 0 0 14,558,384.47 SEPTEMBER 0 0 0 0 0 0 0 36,696.63 176,871.57 327,185.88 464,314.07 667,841.57 733,969.51 733,969.51 733,969.51 554,569.27 354,705.26 305,784.65 131,552.78 9,744.65 0 0 0 0 0 0 0 0 0 0 0 5,231,174.86 Totals 21 TABLE 8 MACROZOOPLANKTON AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY 0.5-M PLANKTON NET, JULY -SEPTEMBER 1983 14-15 JULY Mid-TAXA Surface Depth Bottom* Oblique 27-28 JULY Mid-Surface Depth Bottom Oblique 9- 1 0 AUGUST 15- 16 S E P T EMB E R Mid- Mid-Surface Depth Bottom Oblique Surface Depth Bottom Oblique OIIDARIA Jellyfish medussae x x X X X X X AEELIDA (01igochaeta) Dero furcata ANNELIDA (Polychaota) Nereid reproductive form x x HOLLUSCA P) Pelecypoda juvenile x x x x x X CHAIETOWATHM Sagitta sp.x x x X X X CLADOCERA Leydigia acanthacercoldes Noina brachiata Moinodaphnia macleayii Simocephalus exspfnosus S. serrulatus S. vetulus OSTRACDA Unidentifled Ostracoda CPEPODA Copepoda nauplii Acartia 1 iljeborgei A. tonsa x X x x x x x x x'C x'C'C'C'C'C C 'C ' TABLE 8 (Cont'd)14-15 JULY 27-28 JULY Mid- Mid-TAXA Surface Depth Bottom* Oblique Surface Depth Bottom Oblique 9-10 AUGUST Mid-Surface Depth Bottom Oblique 15-16 SEPTEMBER Mid-Surface Depth Bottom Oblique COPEPOA (Cont'd)Diaptomus app.Cylopolda copepodida Cyclops vernalis Halicyclops spp.Hemicyclops spp.Macrocyclops albidus M. ater M. fuscus MesocYclops edex Oithona spp.Harpactacoida copepodida Unidentified Caligolda x X X X X X X X X X X X X X X X X BIANOHURA Argulus app. X x x X X X X X X X CIRRIPEDIA Barnacle nauplii Barnacle cypris HALACOSTRACA Mysidopsis app. juveniles M. almyra Corophium louisfanum Hyaletia azteca Penaeus aztecus postlarvae P. setiferus postlarvae Macrobrachium spp. zoeae M. ohione Palaemonetes spp. zoeae P. pugio X x X X X X X X X X X x X X X X X X X X x X X X X X X x X'C'C'C X 'X X X x x X X X'C C'C ' TABLE 8 (Cont'd)14-15 JULY Mid-TAXA Surface Depth Bottom* Oblique 27-28 JULY Mid-Surface Depth Bottom Oblique 9 -10 AUGUST 15 -16 S E P T EMB ER Mid- Mid-Surface Depth Bottom Oblique Surface Depth Bottom Oblique NALACOSTRACA (Cont'd)Callianassa spp. zoeae Callianassa spp. postlarvae C. jamaicense Petrolflthes armatus zoeae Callinectes spp. megalopa C. sapidus juveniles Rhithropanopeus harrilis zoeae R. harrisil megalopa Pinnixa spp. zoeae PISCES 4U i i Unidentified fish eggs Unidentified fish larvae Anchoa mitchilli Syngnathus sp. juvenile Caranx hippos Goblonellus boleosoma Goblonellus hastatus Goblosoma bosci Goblosoma robustum Unidentified Goblidae x X X X X X -X X X IC I IC IC I X X X IC IC I C IC IC I IC I x IC IC IC I C IC IC I IC X IC X X X X IC IC X IC IC X X X X IC x IC X C IC C IC X IC IC IC IC X x X IC IC I IC I IC IC IC x X IC I IC IC IC I*No bottom samples collected on this date due to loss of net on submerged debris TABLE 9 NLfBER (PER 100 M) OF MACROZX)pLANKrON COLLECTED IN THE COLOPMMO RIVER BY 0.5-4M PLANKTON NET ON 14-15 JULY 1983 SURFACE TIME (CST): 1100 1720 2300 CB45 Jellyfish medussae MID- DEPTH 1100 1720 2300 (B45 72.2 142.2 36.7 79.9 BOTTOM*1100 1720 2300 0845 OBL IQUE 1100 1720 2300 OB45 91.1 176.1 63.3 192.7 01 Dero furcata Nereid reproductive form Sagitta sp.Leydigia acanthacercoides Moina brachilata Moinodaphnia imcleacyi Sinmoephalus exspinosus S. serrulatus S. vetulus Ostracoda (unidentified) Acartia tonsa DiaplmUs spp.Macrocyclops albidks M. ater M. fuscus Argulus spp.2.3 9.8 4.2 10.1 9.8 3.0 2.0 2.0 2.1 2.1 6.9 6.1 2.1 20.7 6.2 42.2 3.0 19.5 4.2 11.4 10.1 2.1 2.1 21.1 2.0 2.3 19.6 10.1 TABLE 9 (Cont'd)Barnacle nauplii SURFACE MID- DEPTH TIME (CST): 1100 1720 2300 0045 1100 1720 2300 0045 13.7 50.9 BOTTOM* OBLIQUE 1100 1720 2300 0845 1100 1720 2300 0B45 9.8 M&ysidopsis spp. juveniles Coromphium louisianun Hyalella azteca Penaeus setiferus postlarvae ecrdbrachium spp. zoeae M. ohione Callianassa spp. zoeae Callianassa slpo. postlarvae Callinectes sapids juveniles Rhithrrpanopeus harrisil zoeae 2.1 2.1 13.8 2.1 2.1 6.2 2.1 2.3 12.3 21.1 21.1 21.1 21.1 3.0 3.9 2.1 101.9 200.0 73.7 39.0 2.1 19.6 42.2 10.1 64.4 4.6 3.0 177.5 72.2 259.5 18.4 48.9 105.5 30.4* No sanples taken at the bottom on this date due to loss of net on stmerged debris TABLE 10 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY 0.5-M PLANKTON NET ON 27-28 JULY 1983 SURFACE TIME (CST): 1300 1920 0120 0720 TAXA Moina brachiata Ostracoda (unidentified) Copepoda nauplii Acartia tonsa Diaptomus spp.Cyclopoida copepodida Cycloos vernalis Mesocyclops edax Harpactacoida copepodida Argulus spp.Mysidopsis spp. juveniles M. almyra Corophium louisianum Macrobrachium spp. zoeae M. ohione Palaemonetes spp. zoeae P. puglo MID- DEPTH 1300 1920 0120 0720 2.2 3.2 BOTTOM 1300 1920 0120 0720 OBL IQUE 1300 1920 0120 0720 10.3 2.8 2.0 2.0 10.1 16.8 42.7 23.5 2.2 2.0 10.1 3.0 2.2 2.8 3.0 2.2 2.0 6.4 42.7 71.1 10.3 8.1 9.9 10.0 5.5 2.2 2.0 9.6 20.4 4.0 3.2 9.0 6.1 3.2 2.2 2.2 10.1 3.2 22.8 14.2 11.7 11.7 11.7 26.9 2.2 13.4 10.1 140.9 102.6 4.4 2.8 2.0 12.8 16.8 22.8 50.3 20.9 TABLE 10 (Cont'd)TAXA TIME Callianassa spp. zoeae Callinectes sapidus juveniles Rhithropanopeus harrisii zoeae R. harrisli megalopa (CST): 1300 S U R F 1920 47.9 ACE 0120 4.4 0720 MID- D 1300 1920 463.6 EPTH 0120 0720 66.5 25.5 BOTTOM 1300 1920 0120 0720 50.3 1252.9 554.8 23.4 0 B L I Q U E 1300 1920 0120 0720 164.3 71.8 6.6 12.1 28.5 19.9 19.7 140.8 57.9 179.2 98.8 194.7 184.6 205.0 455.2 233.9 93.9 61.5 171.5 2.2 2.0 33.6 28.5 TABLE 11 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY 0.5-M PLANKTON NET ON 9-10 AUGUST 1983 SURFACE TIME (CST): 1155 1800 2330 0600 TAXA Jellyfish medussae Pelecypoda juveniles Sagitta spp.Ostracoda (unidentified) Acartia tonsa Argulus spp.Barnacle nauplii Barnacle cypris MID-DEPTH 1155 1800 2330 0600 2.5 2.6 BOTTOM 1155 1800 2330 0600 10.2 13.8 3.1 3.2 13.8 3.1 9.5 1155 21.3 OBL I QUE 1800 2330 0600 11.8 11.9 2.8 44.4 2.6 2.5 2.9 3.0 7.7 2.6 23.0 10.2 5.9 19.8 11.5 5.9 23.0 17.8 2.7 249.3 20.7 3.2 Mysidopsis spp. juveniles M. almyra Penaeus setiferus postlarvae Macrobrachium spp. zoeae M. ohione Callianassa spp. zoeae Callianassa spp. postlarvae C. jamaicense Callinectes spp. megalopa C. sapidus juveniles Rhithropanopeus harrisii zoeae 2.8 17.9 3.0 64.2 2.6 54.3 2.6 12.8 10.2 2.8 85.6 16.3 13.8 2.7 175.2 120.2 30.6 12.4 262.5 34.5 53.3 17.9 3.0 2.9 7.4 19.7 14.8 2458.1 3.1 6.2 9.3 183.4 2680.9 119.1 23.0 11.5 942.5 3493.2 14.2 21.0 92.4 847.8 1960.2 1153.6 4831.2 71.5 130.9 TABLE 12 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 15-16 SEPTEMBER 1983 SURFACE TIME (CST): 1200 1745 2330 0600 MID -DEPTH BOTTOM OBL I QUE TAXA Jellyfish medussae Nereid reproductive form Pelecypoda juveniles Sagitta spp.Simocephalus exspinosus Acartia lilljeborgei A. tonsa"a3 C Halicyclops spp.Hemicyclops spp.Oithona spp.Harpactacoida copepodida Caligoida (unidentified) 1200 1745 15.2 8.8 15.2 8.8 15.2 2330 0600 1200 1745 12.1 32.8 2330 5.5 0600 3.9 1.9 1.9 13.2 1200 1745 23.9 8.9 47.9 95.7 2330 0600 4.7 2.3 1.5 8.2 16.5 3.9 18.1 13.7 11.0 7.8 5.3 13.7 2.6 1.9 17.7 12.7 7.5 1.5 12.1 3.9 8.9 15.9 16.5 8.2 2.5 15.5 2.9 10.9 4.7 15.9 5.3 5.3 5.3 Argulus spp.Barnacle nauplii Barnacle cypris 10.9 3.8 7.0 22.8 3.8 2.3 1.5 5.5 5.5 8.9 Mysidopsis spp. juveniles M. almyra 2.5 15.1 8.2 22.0 3.9 TABLE MID -0 12 (Cont'd)EPTH TAXA TIME (C Corophium louisianum Penaeus aztecus postlarvae P. setiferus postlarvae Macrobrachium spp. zoeae M. ohione Palaemonetes spp. zoeae Callianassa spp. zoeae o Callianassa spp. postlarvae C. jamaicense Petrolisthes armatus zoeae Callinectes sapidus juveniles Rhithropanopeus harrisii zoeae R. harrisii megalopa Pinnixa spp. zoeae SURFACE;ST): 1200 1745 2330 0600 B OTTOM OBLIQUE 1200 1745 2330 1.9 0600 1200 1745 2330 0600 1200 3.9 1745 2330 0600 1.9 8.2 5.4 35.7 8.2 11.0 5.6 2.2 22.1 2.2 11.3 3.8 99.0 26.3 2.5 5.6 5.5 6.0 2.3 61.9 3.0 5.5 84.6 7.8 38.5 46.6 5.5 7.8 8.9.10.6 5.3 15.9 5.3 167.5 10.6 23.9 10.6 6.6 2.5 1.9 7.5 2.3 7.6 5.5 20.1 20.3 32.6 358.0 10311.5 9091.4 2.7 7.7 10953.6 2994.7 3077.5 1623.9 291.2 889.3 4701.7 17248.8 2343.3 604.4 7.5 15.9 2.7 TABLE 13 LIST OF FISH TAXA COLLECTED IN O.5-M PLANKTON NET SAMPLES FROM THE COLORADO RIVER (C.R.) AND THE SILTATION BASIN (S.B.), JULY -SEPTEMBER, 1983 COMMON NAME Bay anchovy Mosquitofish Pipefish (juvenile) Crevalle jack Gobies (larvae)Darter goby Sharptail goby Naked goby Code goby Unidentified fish eggs Unidentified larvae SCIENTIFIC NAME Anchoa mitchilli Gambusia affinis Syngnathus sp..Caranx hippos Fam. Gobiidae Gobionellus boleosoma G. hastatus Gobiosoma bosci G. robustum LOCATION OF COLLECTION C.R., S.B.S.B.C.R.C.R.C.R.C.R.C.R.C.R.C.R.C.R.C.R.32 TABLE 14 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY 0.5-M PLANKTON NET ON 14-15 JULY 1983 TAXA Anchoa mitchilli Caranx hippos Gobiidae (unidentified) Gobiosoma bosci Fish eggs Unidentified larvae SURFACE TIME (CST): 1100 1720 2300 0845 MID- DEPTH 1100 1720 2300 0845 B 0 T T 0 M*1100 1720 2300 0845 OBLIQUE 1100 1720 2300 0845 21.1 21.1 3.9 2.1 2.1 8.2 5.7 2.9 3.0 10.1 9.2 4.1*No bottom samples collected on this date due to loss of net on submerged debris TABLE 15 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 27-28 JULY 1983 TAXA Anchoa mitchilli Syngnathus sp.Gobionellus boleosoma Gobiosoma bosci G. robustum Unidentified larvae SURFACE TIME (CST): 1300 1920 0120 0720 167.5 238.8 MID- DEPTH 1300 1920 0120 0720 5.5 201.6 373.0 BOTTOM 1300 1920 0120 0720 3.0 597.4 269.0 OBLIQUE 1300 1920 0120 0720 188.0 492.3 3.0 23.5 4.5 4.0 10.3 2.0 2.8 TABLE 16 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY 0.5-M PLANKTON NET ON 9-10 AUGUST 1983 TAXA Anchoa mitchilli Gobionellus boleosoma G. hastatus Gobiosoma bosci SURFACE TIME (CST): 1155 1800 2330 0600 6.0 MID- DEPTH 1155 1800 2330 0600 2.5 BOTTOM 1155 1800 2330 0600 OBL I QUE 1155 1800 2330 0600 9.9 7.4 4.9 3.1 15.5 TABLE 17 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY 0.5-M PLANKTON NET ON 15-16 SEPTEMBER 1983 TAXA SURFACE M I D- D E PT H BOTTOM 0 B.L I QU E TIME (CST): 1200 1745 2330 0600 1200 1745 2330 0600 1200 1745 2330 0600 1200 1745 2330 0600 Anchoa mitchilli 7.5 2.7 5.3 Syngnathus sp. 2.6 Gobiidae (unidentified) 6.6 16.9 4.7 1.5 5.3 Goblonellus boleosoma 33.9 33.0 42.5 G. hastatus 8.2 Gobiosoma bosci 2.5 5.6 Unidentified larvae 5.3 TABLE 18 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON AND ICHTHYOPLANKTON COLLECTED IN THE SILTATION BASIN BY O.5-M PLANKTON NET ON 9-10 AUGUST 1983 TAXA 1100 Neanthes succinea Pelecypoda juveniles Argulus spp.Penaeus setiferus postlarvae Macrobrachium ohione Rhithropanopeus harrisii zoeae Callinectes spp. megalopa C. sapidus juveniles Anchoa mitchilli Gambusia affinis TIME (CST 1640 2230 10.3 10.3 12.4 12.4 0450)323.1 48.5 40.4 149.1 12.4 20.5 30.8 51.3 209.8 116.6 93.2 23.3 46.6 16.2 51.3 23.3 37 TABLE 19 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON AND ICHTHYOPLANKTON COLLECTED IN THE SILTATION BASIN BY 0.5-M PLANKTON NET ON 15-16 SEPTEMBER 1983 TAXA TIME 1705 (CST)2250 1100*Polychaeta larvae Pelecypoda juveniles Halicyclops spp.Oithona spp.Penaeus setiferus postlarvae Macrobrachium ohione Palaemonetes paludosus Rhithropanopeus harrisii zoeae Callinectes sapidus juveniles Gambusia affinis 0545 14.1 28.3 42.4 14.1 14.1 14.1 466.8 15.5 283.2 14.9 14.9 685.5 309.1 14.1 14.9*No organisms in sample 38 TABLE 20 MACROINVERTEBRATE AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY TRAWL, SEINE AND REVOLVING SCREENS, JULY -SEPTEMBER 1983 TAXA TRAWL SEINE REVOLVING SCREENS Penaeus aztecus X Penaeus setiferus X X X Trachypeneus constrictus X Palaemonidae sp. X Palaemonetes kadiakensis X Palaemonetes paludosus X X X Macrobrachium ohione X X X Callinectes sapidus X X X Rhithropanopeus harrisii X Procambarus blandingi acutus X Lepisosteus oculatus X X Brevoortia patronus X X Dorosoma cepedianum X Anchoa mitchilli X X Ictalurus furcatus X Arius felis X Bagre marinus X Gambusia affinis X Poecilia latipinna X Menidia beryllina X X Lepomis cyanellus X 39 TABLE 20 (cont'd)TAXA TRAWL Caranx hippos Eucinostomus argenteus Eucinostomus lefroyi Archosargus probatocephalus Lagodon rhomboides Bairdiella chrysoura Cynoscion arenarius Leiostomus xanthurus Micropogonias undulatus Mugil cephalus Dormitator maculatus Evorthodus lyricus Gobiosoma bosci Gobionellus boleosoma Gobionellus shufeldti Gobioides broussonetti Citharichthys spilopterus Paralichthys lethostigma Achirus lineatus SEINE REVOLVING SCREENS X x X x X x X x x X x X X X X X X X x x x X x X X 40 TABLE 21 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY TRAWL ON 14 -15 JULY 1983 TIME (CST): 1100 1 7 2 0 a 2300a 0 8 4 5 b TAXA Anchoa mitchillt Arius felis Cynoscion arenarius Micropogonias undulatus No. Wt. L.4 2.2 33.2 26 1376.0 141.7 5 9.9 43.4 26 130.2 58.1 No. Wt. L. No. Wt. L.No. Wt. L.aNo trawls completed because of snags bTrawl completed, no organisms caught TABLE 22 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED BY TRAWL ON 27 -28 JULY 1983 TIME (CST)TAXA Penaeus setiferus Palaemonetes paludosus Macrobrachium ohione Callinectes sapidus Rhlthropanopeus harrisii Lepisosteus oculatus Brevoortia patronus Dorosoma cepedianum Anchoa mitchilli Ictalurus furcatus Arius fells Bagre marinus Bairdiella chrysoura Cynoscion arenarius Micropogonias undulatus Gobiosoma bosci Gobionellus boleosoma 1300 No. Wt. L.14 23.9 58.1 IN THE COLORADO RIVER 0720 No. Wt. L.1920 No. Wt. L.6 7.5 49.8 0120 No. Wt. L.3 1.3 1 0.1 34.7 25 1 33.3 0.1 52.4 13.8 478 163.0 47 95.4 53 98 69.0 43.4-20 11.8 93 18.3 107.7-196 168.2 12.1 26 60.8 1 2 850.5 12.4 13.1 505.0 67.0 29.0 207.5 1 0.2 1 1105.6 530.0 1 1 4.3 57.0 2.8 56.0 1 7.1 75.0 245 77.9 8 1261.6 1561 196.6 2 81.4 21.1 9.6 1000 1 115.3 47.3 20.9 146.0 806 192.6 26.4 2 142.2 157.5 1 5.2 68.0 1 141.7 195.0 1 113.4 155.0 2 16.5 76.0 1 10.5 84.0 5 13.8 46.8 9 2 38.2 175.3 56.6 129.0 4 2 24.3 151.8 58.7 129.0 2 0.4 20.5 2 0.9 30.0 2 143.3 125.0 3 0.7 23.0 4 1.2 25.7 0.2 24.0 TIME (CST)TAXA Gobioides broussonetti Citharichthys spilopterus Paralichthys lethostigma Achirus lineatus 1300 No. Wt. L.7 5.0 34.4 TABLE 22 (cont'd)1920 0120 No. Wt. L. No. Wt. L.0720 No. Wt. L.1 0.1 25.0 1 0.1 13.0 2 183.1 165.0 1 0.3 21.0 1 1.9 51.0 1 0.1 13.0 6 5.4 38.5 2 236.0 903.9 1 0.1 18.0 TABLE 23 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY TRAWL ON 9 -10 AUGUST 1983 TIME (CST): 1155a 1800 2300 0600 TAXA Ictalurus furcatus Arius fells Bagre marinus No. Wt. L.No. Wt. L.1 93.4 178.0 1 165.4 214.0 1 14.2 96.0 No. Wt. L.2 247.3 197.0 No. Wt. L.1 65.5 1 7.9 152.0 77.0 aNo organisms caught TABLE 24 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED BY TRAWL ON 15 -16 SEPTEMBER 1983 TIME (CST)1200 No. Wt. L.1745 No. wt. L.2330 No. Wt. L.IN THE COLORADO RIVER 0600 No. wt. L.16 18.2 47.3 TAXA Penaeus setiferus Trachypeneus constrictus Anchoa mitchilli ictalurus furcatus Arius fells.Bagre marinus Lagodon rhomboides Cynosclon arenarlus Lelostomus xanthurus Micropogonias undulatus 1 5.3 95.0 50 34.4 43.9 1 0.1 23.0 1 35.9 125.0 2 35.7 82.5 3 266.6 170.3 1 22.4 108.0 1 0.1 13.0 1 10.8 73.0 1 0.1 19.0 1 260.0 248.0 2 45.4 109.5 5 52.1 79.0 1 18.6 90.0 2 184.6 143.5 1 111.7 192.0 4 318.7 157.0 11 3 169.5 80.0 79.8 103.0 5 4 79.1 82.6 88.7 102.2 TABLE 25 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH BY SEINE ON 14 -15 JULY 1983 (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER TIME (CST): 1100 No. Wt. L.1720 No. Wt. L.2300 No. Wt. L.TAXA Penaeus aztecus Penaeus setiferus Macrobrachium ohione Callinectes sapidus Procambarus blandingi acutus Lepisosteus oculatus C Brevoortia patronus Anchoa mitchilli Poecilla latipinna Menidia beryl1ina Caranx hippos Eucinostomus lefroyi Cynoscion arenarius Mugil cephalus Dormitator maculatus Gobionellus boleosoma Gobionellus shufeldti Citharichthys spilopterus Paralichthys lethostigma 1 4.3 0845 No. Wt. L.8 8.0 47.0 1 0.7 18.0 7 5.3 44.1 2 0.8 16.5 19 11.7 38.6 24 17.5 39.1 4 3.8 2 119.2 69.5 10 1 1.4 2.8 11.3 2 2 1757.7 1.5 475.0 33.5 2 992.2 423.5 2 1.6 35.0 12 27.7 2 0.3 44.2 24.5 1 1 1.4 32.0 1.4 45.0 1 0.4 31.0 10 7.1 27.2 2 1.6 28.5 1 36 0.2 0.6 79.0 18.0 32.0 39.5 19 15.2 30.3 1 0.2 18.0 1 0.7 30.0 2 0.8 27.5 2 1.0 30.0 2 1048.9 288.0 3 4 3.2 22.2 37.3 55.0 2 7 1.3 206.5 1 2.3 44.0 5 1.8 25.8 1 1.4 42.0 14 8.1 30.9 30.5 78.1 1 0.3 27.0 TABLE 26 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mim) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 27 -28 JULY 1983 TIME (CST)TAXA Palaemonetes paludosus Macrobrachium ohlone Callinectes sapidus Brevoortla patronus Anchoa mitchilli 4 Gambusia affinis Poecilia latipinna Archosargus probatocephalus Evorthodus lyricus Gobionellus boleosoma Goblonellus shufeldti Citharlchthys sptlopterus 1300 No. Wt. L.1920 No. Wt. L.0120a 0720a No. Wt. L. No. Wt. L.1 0.3 42 44 27.9 31.6 38 23.4 12.6 3 2.2 38.0 13.5 7 4.2 28.9 64 1 13.8 0.4 25.6 23.0 1 0.7 29.0 1 2 10 1 69.5 2.0 115.0 34.0 2.8 24.9 1.7 44.0 3 1.0 24.3 22 12.4 31.8 13 5.8 27.7 aNo collection due to silt clogging net TABLE 27 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 9 -10 AUGUST 1983 TIME (CST): 1155 1800a 2300a 06008 TAXA Penaeus setiferus Macrobrachium ohione Ca1linectes sapidus Anchoa mitchilli Cynoscion arenarius S Mugil cephalus 00 , Goblonellus bolesoma Citharichthys spilopterus No. Wt. L.27 24.4 43.9 No. Wt. L. No. Wt. L.No. Wt. L.1 1.2 7 0.7 4 0.4 2 0.6 1 16 5 11.0 20.8 23.0 47.0 24.6 36.6 3.0 4.7 4.4 aNo collection due to silt clogging net TABLE 28 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED BY SEINE ON 15 -16 SEPTEMBER 1983 IN THE COLORADO RIVER 0600 No. Wt. L.TIME (CST)TAXA 1200 No. Wt. L.88 65.1 47.6 1745 No. Wt. L.2330 No. Wt. L.Penaeus setiferus Palaemonetes paludosus Macrobrachium ohione Callinectes sapidus Brevoortia patronus ko Menidia beryllina Caranx hippos Eucinostomus argenteus Cynoscion arenarius Lelostomus xanthurus Mugil cephalus Gobionellus boleosoma Citharlchthys spilopterus 222 55.7 32.0 221 40.7 1 0.1 27.2 36 37.0 50.6 5 2.9 6 11.5 43.5 2 1.7 40.0 5 1.8 15.0 2 1.3 37.5 1 2.4 45.0 1 27.1 98.0 3 26.2 69.0 6 2.4 28.2 8 7.2 34.4 1 0.1 13.0 3 1.5 36.7 1 1.9 44.0 1 1.5 51.0 6 56.5 74.2 2 4.4 51.5 1 0.4 25.0 10 933.5 107.1 TABLE 29 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 13 -14 JULY 1983 TIME (CST): 1329 2100 0511 TAXA Palaemonetes paludosus Macrobrachium ohione Callinectes sapidus Caranx hippos No. Wt. L.No. Wt. L.No. Wt. L.1 0.1 21 1.7 42 3.2 10 1.4 12.4 1 0.6 27.0 3 1.3 19.0 9.2 TABLE 30 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 21 -22 JULY 1983 TIME (CST): 1315 2110 0505 TAXA Palaemonetes paludosus Macrobrachium ohione Callinectes sapidus Menidia beryllina Lepomis cyanellus No. Wt. L.No. Wt. L.No. Wt. L.2 0.4 2 0.6 -5 1.2 1 3 0.1 -1.3 17.0 3.2 0.4 0.4 1 0.1 10.0 17.0 1 1 0.6 37.0 1.2 32.0 TABLE 31 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 27 -28 JULY 1983 TIME (CST): 1400 No. Wt. L.2230 No. Wt. L.0626 No. Wt. L.TAXA Palaemonetes kadiakensis Palaemonetes paludosus Palaemonidae sp.Macrobrachium ohione Callinectes sapidus 1 0.3 2 0.4 2 0.6 -2 0.3 2 4 0.6 -16.7 23.5 1 3 0.1 -0.8 14.7 3 0.4 13.0 TABLE 32 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 9 -10 AUGUST 1983 TIME (CST): 1300 2100 0500 TAXA Penaeus setiferus Palaemonetes kadiakensis Palaemonetes paludosus Macrobrachium ohione Callinectes sapidus No. Wt. L.No. Wt. L.No. Wt. L.3 2.9 47.0 1 0.1 1 0.2 1 0.1 1 11 0.1 -1.2 11.6 2 0.6 -4 35.6 55.7 29 18.6 12.5 TABLE 33 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 15 -16 SEPTEMBER 1983 TIME (CST): TAXA 1414 No. Wt. L.1 0.1 25.0 2205 No. Wt. L.2 0.4 28.0 0615 No. Wt. L.10 3.8 35.7 Penaeus setiferus Macrobrachium ohione Callinectes sapidus 1 0.2 2 0.6 18.0 2 0.3 11.5 Page 1 of 1 Nagle, Joseph From: Hoppes, David Sent: Thursday, August 18, 2011 8:26 AM To: Dunn, Roland Cc: Gore, Duane; LeValley, John; Nagle, Joseph

Subject:

First cut at manpower loading for PIP # 081270- Spent Fuel management Project Last Thursday (Aug 11) there was a Pre-PRT review of the DRAFT for PIP #081270. The PIP was presented to PRT on Wednesday (Aug 17).At the Pre-PRT meeting we recognized some changes to the first DRAFT manpower loadings. Some but not all of these were incorporated into the PIP that was presented to PRT.Today I met with Joe Nagle and further changes were identified. Two changes were to re-assign "Fuel Movers- Craft labor" and "Vendor Install the SFP Racks" from cost center 932 to the Refueling Team cost center.With these changes, the following NFAD activities are identified in the latest working version of PIP #081270:* NFAD and DED are jointly identified for Design work support (to the vendor) for Installing the SFP Rack Modules 12 and 16. This activity is assigned 556 hours for Ul in 2012 and 444 hour for U2 in 2012." NFAD is the responsible group for the Criticality Analysis work to be done by a vendor to be selected. The funding is $100,000 in 2012 and $25,000 in 2013; this should be corrected to$250,000 in 2013." NFAD is the responsible group for the NRC's review of the Criticality Analysis. The funding is$200,000 in 2014 and $200,000 in 2015.* NFAD is the responsible group for the Poison Insert design work to be done by a vendor to be selected. The funding is $1,000,000 in 2015 which is identified as "Contingency"; and $1,000,000 in 2016.These PIP funding amounts are consistent with NFAD's inputs to date.NFAD needs to consider additional NFAD manpower support that will be required for the on-going spent fuel management work, and which budgets (PIP, baseline, or other) will be used.8/18/2011 AQ-2. McAden, D. C., G. N. Greene, and W. B. Baker 1985. Colorado River Entrainment and Impingement Monitoring Program, Phase Two Studies -July -December 1984 (Report # 2). Prepared for South Texas Project by Ecology Division, Environmental Protection Department, Houston Lighting & Power Company. April. Aý-oL REPORT #2 COLORADO RIVER ENTRAINMENT AND IMPINGEMENT MONITORING PROGRAM PHASE TWO STUDIES -JULY-DECEMBER, 1984 PREPARED FOR SOUTH TEXAS PROJECT SUBMITTED BY ECOLOGY DIVISION, ENVIRONMENTAL PROTECTION DEPARTMENT HOUSTON LIGHTING & POWER COMPANY APRIL 1985 PREPARED BY: DAVID C. McADEN, GEORGE N. GREENE, WILLIAM B. BAKER, JR. TABLE OF CONTENTS PAGE LIST OF TABLES ................... ......................... i INTRODUCTION .................... .......................... 1 METHODS ..................... ............................ 1 RESULTS AND DISCUSSION .......... ..... ..................... 1 HYDROLOGY AND WATER QUALITY ............. ................ 1 MACROZOOPLANKTON AND ICHTHYOPLANKTON ........ ............ 2 MACROINVERTEBRATES AND FISH ......................... 4 REFERENCES CITED .......... ....... ...................... 6 LIST OF TABLES TABLE PAGE 1 TEMPORAL VARIATIONS IN TEMPERATURE, TURBIDITY AND DISSOLVED OXYGEN AT MID-CHANNEL OF THE COLORADO RIVER, SEPTEMBER 1984 .... ...... 7 2 TEMPORAL AND SPATIAL VARIATIONS IN CONDUCTIVITY (MILLIMHOS/CM) AT MID-CHANNEL OF THE COLORADO RIVER, SEPTEMBER 1984 ..... ......... 8 3 TEMPORAL AND SPATIAL VARIATIONS IN SALINITY (PPT) AT MID-CHANNEL OF THE COLORADO RIVER, SEPTEMBER 1984 .......... ................. 9 4 TEMPORAL VARIATIONS IN SURFACE WATER QUALITY PARAMETERS IN THE RMPF SILTATION BASIN, SEPTEMBER 1984 ....... ................. ..10 5 TEMPORAL VARIATIONS IN TEMPERATURE, CONDUCTIVITY, SALINITY AND DISSOLVED OXYGEN AT THE STP REVOLVING SCREENS, SEPTEMBER 1984 ..... 11 6 AVERAGE COLORADO RIVER FLOW (CFS) ON DATES OF SAMPLE COLLECTION, SEPTEMBER 1984 ................. ........................... ..12 7 RESERVOIR MAKEUP PUMPING FACILITY (RMPF) DAILY PUMPAGE (M 3), JULY-DECEMBER 1984 .............. .................... ...... ..13 8 MACROZOOPLANKTON AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTONINET, SEPTEMBER 1984 ...... ................. ..15 9 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 5-6 SEPTEMBER 1984 .... ...... 17 10 LIST OF FISH TAXA COLLECTED IN O.5-M PLANKTON'.NET SAMPLES FROM THE COLORADO RIVER (C.R.) AND THE SILTATION BASIN (S.B.), 5-6 SEPTEMBER 1984 .............. .......................... ..19 11 -NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON'.NET ON 5-6 SEPTEMBER 1984 .... ...... 20 12 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON AND ICHTHYOPLANKTON COLLECTED IN THE SILTATION BASIN BY O.5-M PLANKTON NET ON 6 SEPTEMBER 1984 ................. ........................... 21 13 MACROINVERTEBRATE AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY TRAWL, SEINE AND REVOLVING SCREENS, 5-6 SEPTEMBER 1984 ..... ... 22 14 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 5-6 SEPTEMBER 1984 ........ .............. ......... 24 15 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 5-6 SEPTEMBER 1984 ...................................... 26 i INTRODUCTION Section 6.1.3.2 and Appendix E of the Final Environmental Statement require Phase Two of the aquatic ecology studies to begin within one week of the start of reservoir fill pumping. The initial report (McAden et al. 1984)covered the period July 1983 -June 1984. This report presents data from the sampling period July -December 1984. Due to limited pumping during this period, only one set of samples was collected. METHODS All stations, schedules and methods employed were the same as those described in the initial report (McAden et al. 1984). A malfunction of the pH meter precluded pH measurements during sampling.RESULTS AND DISCUSSION HYDROLOGY AND WATER QUALITY Water temperature, turbidity and dissolved oxygen data from the Colorado River station are shown in Table 1. Conductivity values are given in Table 2, and salinity values are given in Table 3. Water temperature, salinity and dissolved oxygen data from the Reservoir Makeup Pumping Facility (RMPF)siltation basin are given in Table 4. Water temperature, salinity and dissolved oxygen data from the RMPF revolving screens are given in Table 5.1 On 5-6 September a salt wedge was present in the Colorado River, extending to within 5-10 ft of the surface. The wedge was up to 3.0 C warmer than the low salinity surface water and contained low dissolved oxygen levels (maximum 0.8 ppm at the bottom).Surface water quality in the RMPF siltation basin was similar to that of the surface water in the river. Bottom water quality measurements were not made in the siltation basin.Surface water quality at the revolving screens was similar to the surface water quality in the river. However, bottom salinity at the screens was lower (as much as 6.3 ppt) than salinities at comparable river depths.River flow during the sampling period is shown in Table 6 and the daily volume of water pumped into the reservoir during July-December 1984 is shown in Table 7.MACROZOOPLANKTON AND ICHTHYOPLANKTON Samples collected by 0.5-m plankton net yielded 29 taxa of invertebrates and 7 taxa of vertebrates (Table 8). The most abundant invertebrates were jellyfish (medusae), copepods (especially Acartia tonsa and Oithona spp.), barnacle nauplii, the zoeae of the brackish water shrimps Palaemonetes spp.and Callianassa spp. and the zoeae of the brackish water crab Rhithropanopeus harrisii. All of the vertebrate taxa consisted of larval and juvenile stages of both freshwater and estuarine fishes. A single sunfish larva (Family Centrarchidae) constituted the freshwater component of the ichthyoplankton samples, whereas the bay anchovy and at least two species of gobies dominated the estuarine taxa.2 Table 9 shows the variations in macrozooplankton abundance over the 24-hr sample period on 5-6 September 1984 in the Colorado River. The largest total numbers of organisms were taken in samples collected at mid-depth and in the oblique tows. Considerably smaller numbers of taxa, as well as numbers within taxa, were collected at the surface and near the bottom. The reasons for these spatial differences in abundance can be seen in the hydrological and water quality measurements made at the times of sample collection (Tables 1-3). There was a layer of very low salinity water at the surface, which contained a paucity of both taxa and numbers of individuals within taxa.The reason for the relative scarcity of zooplankton near the bottom of the river is the critically low dissolved oxygen levels near the river bottom (Table 1).By far the most commonly found and most abundant of the river zooplankton taxa was the xanthid mud crab, Rhithropanopeus harrisii. Other abundant forms were jellyfish medusae and the zoeal stages of the ghost shrimp, Callianassa spp. Relatively low numbers of the commercial white shrimp, Penaeus setiferus, and the megalops stage of the blue crab, Callinectes spp., were taken, although Callinectes spp. megalops did occur at a high density in the 0300-hr oblique sample. It is possible that this taxon consisted of both the commercial blue crab, C. sapidus, and the noncommercial pygmy blue crab, C.similis.A list of the common and scientific names of the larval and juvenile stages of fish taxa collected from both the Colorado River and the siltation basin is found in Table 10.3 Table 11 shows the temporal and spatial variations in ichthyoplankton abundance in the Colorado River. The data are too limited to draw any meaningful conclusions, except to note the total absence of ichthyoplankton near the bottom. This is understandable given the low dissolved oxygen levels noted in the earlier discussion of macrozooplankton abundance. Table 12 depicts the changes in abundance of macrozooplankton and ichthyoplankton over the sampling period. As in the river samples, the zoeal stage of the xanthid mud crab, Rhithropanopeus harrisii, was the most abundant taxon, but unlike the river samples, highest densities occurred during the hours of daylight. The reasons for this are unclear, because siltation basin samples were collected at the surface and zooplankton abundance in surface samples is typically lowest in the daytime. Another commonly occurring, albeit in low densities, taxon was the parasitic fish louse, Argulus spp. 'No penaeid shrimp or blue crab larvae were taken from the siltation basin, and only one ichthyoplankter, an unidentified yolksac larva.MACROINVERTEBRATES AND FISH Representatives of 27 species were captured in seine and revolving screen samples during the study (Table 13), but no organisms were captured in the trawl samples. Critically low dissolved oxygen levels at the bottom of the river (Table 1) appear to be the limiting factor.4 Six (6) species of macroinvertebrates, including 5 species of shrimp and 1 crab, were taken in seine samples (Table 14). Macrobrachium ohione, a small river shrimp, was the only freshwater representative, while the estuarine/ marine white shrimp, Penaeus setiferus, was the most abundant invertebrate (643 caught).Twenty species of vertebrates, all of which were fish, were caught in the seine samples (Table 14). Of these, only the spotted gar, Lepisosteus occulatus, is freshwater, with the remainder being estuarine and marine. The fish most commonly caught was the bay anchovy, Anchoa mitchilli (170).Impingement samples (Table 15) yielded 4 macroinvertebrate species, one of which was the pink shrimp, Penaeus duorarum, found only in the impingement samples. The total catch was 15 individuals. In general, the animals were small, 5-64 mm in length.5 REFERENCES CITED McAden, D.C., G.M. Greene and W.B. Baker, Jr. 1984. Report #1. Colorado River Entrainment and Impingement Monitoring Program, Phase Two Studies -July, 1983-June, 1984. Ecology Division, Environmental Protection Department, Houston Lighting & Power Company.USNRC. 1975. Final Environmental Statement. South Texas Project Units 1 and 2. Houston Lighting & Power Company, City Public Service Board of San Antonio, Central Power and Light Company, City of Austin. Docket Nos. 50-498 and 50-499. Prepared by Office of.Nuclear Reactor Regulation, United StatesNuclear Regulatory Commission. 6 TABLE 1 TEMPORAL VARIATIONS IN TEMPERATURE, TURBIDITY, AND DISSOLVED OXYGEN AT MID-CHANNEL OF THE COLORADO RIVER, SEPTEMBER 1984 Sampling Dates 5 September 6 September 6 September 6 September Time (CST)2045 0300 0855 1450 Temperature (°C)Surface Bottom 27.7 29.6 26.5 29.5 26.2 29.5 29.2 29.6 pH Surface*Secchi disk Turbidity (inches)17.0 20.5 21.0 20.0 Dissolved 0 (ppm)Surface Bottom 7.8 0.1 7.4 0.1 8.2 0.1 9.1 0.8 Bottom Depth (ft)17.0 20.0 19.5 18.0*pH meter not working TABLE 2 TEMPORAL AND SPATIAL VARIATIONS IN CONDUCTIVITY (MILLIMHOS/CM) AT MID-CHANNEL OF THE COLORADO RIVER, SEPTEMBER 1984 DEPTH (ft.)Sampl ing Dates 5 September 6 September 6 September 6 September Time (CST)2045 0300 0855 1450 S 4.3 4.3 4.9 4.5 5 31.8 22.1 23.6 25.0 10 44.3 42.6 40.8 42.3 15 45.2 44.0 44.8 44.6 20 45.5 B (Depth)45.5 (17.0)45.5 (20.0)45.4 (19.5)44.9 (18.0)8 TABLE 3 TEMPORAL AND SPATIAL VARIATIONS IN SALINITY (PPT)AT MID-CHANNEL OF THE COLORADO RIVER, SEPTEMBER 1984 DEPTH (ft.)Sampl ing Dates 5 September 6 September 6 September 6 September Time (CST)2045 0300 0855 1450 S 2.4 2.4 2.8 2.5 5 20.0 13.5 14.5 15.4 10 28.8 27.7 26.3 27.4 15 29.5 28.6 29.2 29.1 20 B (Depth)-29.8 (17.0)29.8 29.8 (20.0)-29.7 (19.5)-29.3 (18.0)9 TABLE 4 TEMPORAL VARIATIONS IN SURFACE WATER QUALITY PARAMETERS IN THE RMPF SILTATION BASIN (SEPTEMBER 1984)9 Sampl ing Dates 6 Sept.6 Sept.6 Sept.6 Sept.Time (CST)0020 0500 1030 1615 Temperature (0 c)26.8 25.9 27.1 29.2 Salinity (PPT)2.8 2.5 3.5 3.5 Dissolved Oxygen (PPM)8.6 6.9 8.1 9.1 pH** pH meter not working 10 TABLE 5 TEMPORAL VARIATIONS IN TEMPERATURE, CONDUCTIVITY, SALINITY, AND DISSOLVED OXYGEN AT THE STP REVOLVING SCREENS, SEPTEMBER 1984 Sampling Dates Time (CST)Temperature (1C)Surface Bottom Conductivity (millimhos/cm) Surface Bottom Salinity (ppt)Surface Bottom Dissolved Oxygen (ppm)Surface Bottom pH* Bottc Sur- Depth face (ftt.5 September 6 September 6 September 1910 0300 1104 28.3 26.4 27.4 29.0 27.2 28.3 5.7 25.4 5.2 12.4 7.5 22.4 3.2 15.7 3.0 7.2 7.8 7.8 6.2 1.3 7.4 2.8 6 5 5 4.2 13.7* pH meter not working TABLE 6 AVERAGE COLORADO RIVER FLOW (CFS) ON DATES OF SAMPLE COLLECTION, SEPTEMBER 1984 DATE 5 September 6 September*Derived by taking arithmetic mean of 3 daily flow values recorded at the beginning of each shift RIVER FLOW 663 721 12 TABLE 7 RESERVOIR MAKEUP PUMPING FACILITY (RMPF)DAILY PUMPAGE (M 3), JULY-DECEMBER 1984 DATE-a CA)1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 JULY 618,317 745,407 300,178 262,975 122,316 AUGUST 687,444 498,332 330,252 226,549 35,661 SEPTEMBER OCTOBER NOVEMBER 39,757 268,477 376,127 403,647 401 ,340 440,344 7,697 314,278 494,298 39,103 DECEMBER 9,399 68,892 119,825 49,563 25,448 81$524 130,815 636,709 403,647 158,582 109,833 TABLE 7 (Cont'd)DATE JULY AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER 22 23 24 25 26 27 28 29 65,414 15,604 2,751 30 31 79,439 557,245 Totals 2,792,849 3,217,824 2,850,482 253,884 2,751 9,399 TABLE 8 MACROZOOPLANKTON AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET, 5-6 SEPTEMBER 1984 Mid-TAXA Surface Depth Bottom Oblique CNIDARIA Jellyfish medusae X X X X ANNELIDA (Polychaeta) Polychaete larvae X X X X MOLLUSCA Pelecypoda juvenile X X X Gastropoda juvenile X X CHAETOGNATHA Sagitta sp. X X CLADOCERA Daphnia sp. X X Moina brachiata X X Moinodaphnia macleayii X X COPEPODA Copepoda nauplii X A. tonsa X X X Diaptomus spp. X Eucalanus sp. X Cylopoida copepodida X Halicyclops spp. X X Oithona spp. X X X Unidentified Caligoida X 15 TABLE 8 (Cont'd)Mid-TAXA Surface Depth Bottom Oblique BRANCHIURA Argulus spp. X CIRRIPEDIA Barnacle nauplii X X X Barnacle cypris X MALACOSTRACA Mysidopsis spp. juveniles X X X P. setiferus postlarvae X Hippolyte sp. zoeae X Palaemonetes spp. zoeae X X X X Callianassa spp. zoeae X X X Callianassa spp. postlarvae X X Callinectes spp. megalopa X X X Rhithropanopeus harrisii zoeae X X X X R. harrisii megalopa X X Sesarma sp. zoeae X PISCES Unidentified fish larvae X Anchoa mitchilli X Unidentified Centrarchidae X Cynoscion arenarius X Gobionellus spp. larvae X G. hastatus X X Gobiosoma bosci X 16 TABLE 9 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON COLLECTED IN THE COLORADO RIVER BY O.5-M PLANKTON NET ON 5-6 SEPTEMBER 1984 TAXA Jellyfish medusae Polychaete larvae Gastropod juveniles Pelecypod juveniles Sagitta spp.Daphnia spp.Moina brachiata Moinodaphnia macleayi iCopepod nauplii Acartia tonsa Eucalanus sp.Diaptomus spp.Halicyclops sp.Oithona spp.Cyclopoida copepodida Caligoida (unidentified) Argulus spp.SURFACE TIME (CST): 2045 0300 0855 1450 2.7 3.3 MID- DEPTH 2045 0300 0855 1450 178.8 192.6 41.3 25.2 4.6 41.3 2.3 3.2 9.0 BOTTOM 2045 0300 0855 1450 7.3 10.9 9.0 10.7 7.3 2.2 2.1 7.3 2.2 OBLIQUE 2045 0300 0855 1450 64.7 452.1 25.9 10.8 18.9 12.1 6.5 21.6 21.6 64.8 10.8 12.1 4.7 11.0 2.7 10.0 6.5 1.6 10.8 11.5 249.9 3.6 9.7 10.8 3.2 3.6 2.2 21.6 9.4 4.0 4.7 2.1 2.1 6.9 39.0 2.3 10.8 1.6 9.0 4.4 9.4 5.5 3.3 10.8 TABLE 9 (Cont'd)SURFACE TIME (CST): 2045 0300 0855 1450 TAXA Barnacle nauplii Barnacle cypris MID- DEPTH 2045 0300 0855 1450 300.4 41.4 BOTTOM 2045 0300 0855 1450 6.6 OBL I QUE 2045 0300 0855 1450 21.6 12.1 9.2 Mysidopsis spp. juveniles Penaeus setiferus postlarvae Hippolyte sp. zoeae Palaemonetes spp. zoeae Callianassa spp. zoeae Callianassa spp. postlarvae Callinectes spp. megalops co Rhithropanopeus harrisil zoeae R. harrisii megalopa Sesarma sp. zoeae 4.6 6.5 1.8 2.2 10.8 12.1 6.7 1.6 5.5 10.0 13.5 2.1 4.9 2.1 811.7 309.3 70.2 2.1 3.7 11.0 10.9 2.2 45.3 64.7 4.7 4.0 13.0 172.6 51.9 48.4 1.6 2.2 6.7 8.2 13.4 108.1 16.9 22.9 3.2 1.8 6.2 181.1 174.9 90.0 13.0 2.2 537.5 151.0 1661.3 34.4 22.0 13.1 4004.7 189.7 2.1 4.6 10.8 TABLE 10 LIST OF FISH TAXA COLLECTED IN 0.5-M PLANKTON NET SAMPLES FROM THE COLORADO RIVER (C.R.) AND THE SILTATION BASIN (S.B.), 5-6 SEPTEMBER 1984 COMMON NAME Bay anchovy Unidentified sunfish Sand seatrout Unidentified goby Sharptail goby Naked goby Unidentified larvae SCIENTIFIC NAME Anchoa mitchilli Fam. Centrarchidae Cynoscion arenarius Gobionellus spp.G. hastatus Gobiosoma bosci LOCATION. OF COLLECTION C.R.C.R.C.R.C. R.C.R.C.R.C.R., S.B.19 TABLE 11 NUMBER (PER 100 M 3) OF ICHTHYOPLANKTON COLLECTED IN THE COLORADO RIVER BY 0.5-M PLANKTON NET ON 5-6 SEPTEMBER 1984 SURFACE MID- DEPTH BOTTOM TIME (CST): 2045 0300 0855 1450 2045 0300 0855 1450 2045 0300 0855 1450 2045 TAXA Anchoa mitchilli Centrarchidae larvae OBLIQUE 0300 0855 1450 e 8.2 3.3 2.7 Cynoscion arenarlus Gobionellus sp. larvae G. hastatus Gobiosoma bosci Unidentified larvae 2.3 2.3 4.6 6.5 2.1 2.3 3.3 5.6 0 TABLE 12 NUMBER (PER 100 M 3) OF MACROZOOPLANKTON AND ICHTHYOPLANKTON COLLECTED IN THE SILTATION BASIN BY O.5-M PLANKTON NET ON 6 SEPTEMBER 1984 TAXA T I M E (C S T)0020 0500 1030 1615 Sagitta spp. 12.9 Daphnia spp. 25.7 Acartia tonsa 38.6 Harpactacoid copepodida 38.6 Argulus spp. 12.9 12.9 12.9 Callianassa spp. zoeae 51.4 Rhithropanopeus harrisii zoeae 51.4 77.1 552.7 115.7 Unidentified fish larvae 12.9 21 TABLE 13 MACROINVERTEBRATE AND FISH TAXA COLLECTED IN THE COLORADO RIVER BY TRAWL, SEINE AND REVOLVING SCREENS, 5-6 SEPTEMBER 1984 TAXA TRAWL SEINE REVOLVING SCREENS Penaeus aztecus X P. setiferus X X Penaeus duorarum X Trachypeneus constrictus X Palaemonetes pugio X Macrobrachium ohione X X Callinectes sapidus X X Lepisosteus occulatus X Elops saurus X Alosa chrysochloris X Brevoortia patronus X Anchoa hepsetus X A. mitchilli X Fundulus grandis X Poecilia latipinna X Menidia beryllina X Hemicaranx amblyrhynchus X Oligoplites saurus X Eucinostomus argenteus X Lagodon rhomboides X Cynoscion arenarius X 22 TABLE 13 (Cont'd)TAXA TRAWL SEINE REVOLVING SCREENS Leiostomus xanthurus X Mugil cephalus X Evorthodus lyricus X Gobionellus boleosoma X Citharichthys spilopterus X Paralichthys lethostigma X 23 TABLE 14 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES AND FISH COLLECTED IN THE COLORADO RIVER BY SEINE ON 5-6 SEPTEMBER 1984 2045 0300 0855 145(No. Wt. L. No. Wt. L. No. Wt. L. No. Wt.TIME (CST): TAXA Penaeus aztecus P. setiferus Trachypeneus constrictus Palaemonetes pugio Macrobrachium ohione Callinectes sapidus Lepisosteus occulatus Elops saurus Alosa chrysochloris Brevoortia patronus Anchoa hepsetus A. mitchilli Fundulus grandis Poecilia latipinna Menidia beryllina Hemicaranx amblyrhynchus 0 L.3 189 0.5 61.9 29.0 30.1 2 1.5 42.5 68 54.3 44.7 259 579.5 61.3 127 218.0 59.4 1 0.8 46.0 36 13.8 -3 0.3 10.3 23 1 3 11.1 0.7 0.9 6 2.0 41.0 13.7 1 1.1 1 595.0 27.0 465.0 2 79.9 65.5 1 230.3 254.0 1 0.9 8 15.0 37.0 45.0 16 53.7 51.2 1 0.9 6 2.5 32.2 161 74.2 43.0 34.4 3 1.1 32.3 2 7.9 52.5 1 1 2.9 0.6 44.0 39.0 2 1.7 43.5 5 7.2 36.6 TABLE 14 (Cont'd)0300 No. Wt. L.TIME (CST): 2045 No. Wt. L.0855 No. Wt. L.1450 No. Wt. L.TAXA Oligoplites saurus Eucinostomus argenteus Lagodon rhomboides Cynoscion arenarius Leiostomus xanthurus Mugil cephalus Evorthodus lyricus Un, Gobionellus boleosoma Citharichthys spilopterus Paralichthys lethostigma 1 0.2 2 1.6 24.0 33.5 4 7 1 5 1.5 69.9 1.7 25.2 24.2 67.7 45.0 57.8 1 0.1 20.0 2 1.2 30.5 1 4.1 55.0 1 5.6 70.0 1 1 15.5 80.0 3.9 63.0 4 40.5 72.0 5 47.1 71.0 2 9.2 56.5 2 11.2 63.0 1 4.1 60.0 1 0.4 28.0 10 1 1 5.7 1.4 935.5 32.2 48.0 350.0 TABLE 15 TOTAL NUMBER, TOTAL WEIGHT (g) AND MEAN LENGTH (mm) OF MACROINVERTEBRATES IMPINGED ON 2 INTAKE SCREENS IN 30 MINUTES ON 5-6 SEPTEMBER 1984 TIME (CST): TAXA Penaeus setiferus P. duorarum Macrobrachium ohione Callinectes sapidus 1910 No. Wt. L.1 2.2 63.0 1 2.4 58.0 2 0.2 12.0 0300 No. Wt. L.1 1.8 64.0 1104 No. Wt. L.3 1.5 39.7 3 1.4 28.0 3 2.9 22.0 1 0.1 5.0 AQ-3. Citation and documentation is needed for the following sentence that was included in the ER, Section 5.2: Based upon best professional judgment (BPJ) the TCEQ Water Quality Division has determined that the CWIS reflects BTA for AEI through use of a closed-cycle recirculating system. Kathleen Hartnett White, Chairman Larry R. Soward, Commissioner H. S. Buddy Garcia, Commissioner Glenn Shankle, Executive Director TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas by Reducing and Preventing Pollution June 27, 2007 Mr. R.A. Gangluff, Manager, Chemistry Environmental and Health Physics STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 Re: Cooling Water Intake Structures Phase II Rules; South Texas Project Electric Generating Station;TPDES Permit No. WQ0001908000.

Dear Mr. Gangluff:

I received your letter dated May 24, 2007, requesting that the Main Cooling Reservoir (MCR) be designated as a closed-cycle recirculating system and as not water in the state.The Texas Commission on Environmental Quality (TCEQ) does not have an official method of"designating" a facility's operation as a closed-cycle recirculating system. However, we have reviewed the information you submitted and based on our best professional judgement, we consider your facility to be a closed-cycle recirculating system. As mentioned in your letter, the federal rule governing the 316(b)Phase II cooling water intakes is currently in the process of being suspended. For the time being, implementation of the 316(b) requirements will be based on best professional judgement (BPJ) and subject to EPA Region VI review.We also concur that the Main Cooling Reservoir (MCR) at your facility does not meet the definition of water in the state.If you have any questions, please contact me at (512) 239-2369.Sincerely, Kelly Holligan, Leader Industrial Team Water Quality Division KH/jp P.O. Box 13087 0 Austin, Texas 78711-3087 0 512-239-1000 0 Internet address: www.tceq.state.tx.us pti iI I I ()? I CCC r dflY~ -ing soy-Imsud ink Nuclear Operating Company South T&s P/edct Extrinc Gcnetin SiaUon PO. Bar 289 Wadsworth, Tems 748.?May 24, 2007 NOC-TX-07016176 PE'N: W02 STI No. 32165797 Mr. Kelly Holligan Team Leader, Industrial Wastewater Permits Texas Commission on Envirornmental Quality P.O. Box 13087 Austin, TX 78711-3087 Re: Cooling Water Intake Structures Phase It Rules South Texas Project Electric Generating Station TPDES Permit No. 01908

Dear Mr. Holligan:

Thank you for meeting with my staff on May 15, 2007 to discuss the South Texas Project Electric Generating Station (STPEGS) cooling reservoir and other wastewater discharge pennit issues. Based on our discussion, STP Nuclear Operating Company (STPNOC) is submitting the following information regarding the Main Cooling Reservoir (MCR) and the applicability of the regulations for cooling water intake structures. We are confident that the South Texas Project Station (STP) complies with the regulation by employing a closed-cycle recirculating cooling system as defined in 40 CFR §125.93. Pursuant to 40 CFR §125.94(a)(1)(i), cooling water flow for this facility is commensurate with a closed-cycle recirculating cooling system, as demonstrated below. Additional technical information is included in letters dated March 7, 2005 and August 18, 2005 previously submitted to the Texas Commission on Environmental Quality (TCEQ).STP is located on 12,220-acres in Matagorda County, approximately 15 miles southwest of Bay City along the west bank of the Colorado River. The facility consists of two electric-generating units, which share a closed-cycle recirculating cooling reservoir. Water from the MCR is passed through the cooling loops of both units then returned to the MCR for heat dissipation before cycling back through the cooling systems.The MCR is a perched, off-channel, on-site industrial cooling impoundment of approximately 7,000 acres, impounding over 202,600 acre-feet of cooling water at its maximum operating level.Dikes are installed in the MCR that channel the water flow to maximize circulation time for heat dissipation before the water is recirculated back to the generating units. Blowdown from the MCR to the Colorado River has not occurred since March 1997. Should blowdown be required it would occur through an underground pipe that discharges back into the Colorado River. This point is designated as Outfall 001 in the TPDES Permit No. 01908. The MCR is also equipped with a gated spillway for emergency use. The MCR is not a "water of the U.S." as defined at 40 CFR § 122.2. The MCR is not considered a "water of the State" based on internal and external outfall designations in the permit. The MCR is on private property and exists solely for Mr. Kelly Holligan May 24, 2007 Page 2 industrial cooling. It is not a publicly managed water body and has no recreational uses. The general public has never had access to the MCR nor is any planned in the foreseeable future.The only sources of new water to the MCR are direct rainfall and make-up water diverted periodically from the Colorado River, primarily at high river flows. Water from tile Colorado River is pumped approximately I mile via a 108 inch pipe to the MCR. To protect inflows during low river flow conditions, the water right for STP includes a special provision to limit diversion from the Colorado River to 55% of the flow over 300 cubic feet per second, to protect inflows during low river flow conditions. Currently, the intake consists of trash racks, rotating screens with 3/8 inch mesh and 4 pumps. In addition, the reservoir makeup pumping facility has the following design: " The traveling water screens are flush with the river shoreline;" The maximum approach velocity to the traveling water screens is 0.5 feet per second;" Fish passageways were constructed in the wing walls between the traveling screens to facilitate fish migration parallel to the screen surfaces; and" A sluice and discharge line was installed for the purpose of returning all impinged organisms directly to the river, downstream of the intake structure, immediately after being backwashed from the screens.The pumps are operated intermittently based on reservoir level, river flow, and the operability of the makeup pumping facility. A cooling reservoir evaporates less water per unit of heat dissipated than a cooling tower, thus dissolved solids build up more slowly over time. This is complemented by the designed seepage from the MCR, which maintains the structural integrity of the reservoir embankment. Rainfall further dilutes the dissolved solids in the MCR. These factors minimize the blowdown and make-up required to maintain MCR water quality. As a result, intake water flow for cooling purposes at STP reflects best technology available (closed-cycle recirculating systems) for minimizing adverse environmental impact.As was discussed in the May 15, 2007 meeting, several provisions of the Phase II rule are in the process of being suspended by the U.S. Environmental Protection Agency and the Regional Administrators have been authorized to review the applicability of the rule on a case by case basis using Best Professional Judgment. Based on that authorization and the informrition provided, STPNOC is requesting that TCEQ designate the MCR as a closed-cycle recirculating system. We are also requesting concurrence that the MCR does not meet the definition of a"water of the State". If you have any questions or require additional information, please contact Ms. S. L. Dannbardt at (361) 972-8328.Sincerely, R. A. Gangluff Manager, Chemistry Environmental and Health Physics Mr. Kelly Holligan May 24, 2007 Page 3 cc: Mr. Earl Lott Special Assistant, Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Ms. Susan Jablonski Special Assistant/Radioactive Waste Specialist Office of Pennitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Mr. Kelly Holligan May 24, 2007 Page 4 bcc: Correspondence, N2002 AQ-4. "Essential Cooling Pond Fish Population Study." Prepared for STP Nuclear Operating Company by ENSR International, Houston, Texas, May 2002. ,qQ-4 EK1RL South Texas Project Electric Generating Station Wadsworth, Texas Essential Cooling Pond Fish Population Study Prepared For: STP Nuclear Operating Company P.O. Box 270 Wadsworth, TX 77483 Prepared by: ENSR 3000 Richmond Ave, Suite 400 Houston, TX 77098 May 2002 Document Number 05727-008-400 The following personnel have prepared and/or reviewed this report for accuracy, content and quality of presentation. Kurtis K. Schlicht Project Manager Report Author Frank G. Schlicht Ph.D.Senior Technical Specialist 4444- iýd7Aj2 Rocky Stevens, RE.Senior Reviewer-2 ,oo 2__Date CONTENTS 1.0 INTRO DUCTION .................................................................................................................................... 1 1.1 M ATERIALS AND M ETHO DS ................................................................................................ 1 1.2 HYDROLOG ICAL DATA ....................................................................................................... 2 1.3 NEKTO N ....................................................................................................................................... 2 1.4 DATA ANALYSIS ......................................................................................................................... 3 2.0 RESULTS ............................................................................................................................................... 5 2.1 SAM PLE LOCATIO NS ................................................................................... .............................. 5 2.2 HYDROLOGICAL DATA ................................................... 5 2.3 NEKTO N ....................................................................................................................................... 6 2.3.1 Trawls ................................................................................................................................ 6 2.3.2 G ill Nets ............................................................................................................................. 7 2.3.3 Hoop Nets ......................................................................................................................... 7 3.0 DISCUSSIO N ......................................................................................................................................... 8 3.1 RESULTS ..................................................................................................................................... 8 3.2 MANAG EM ENT RECO M M ENDATIO NS ............................................................................. 12 4.0 LITERATURE CITED ................................................................................................ I ......................... 17 UDt~t-ttAJ!~ I rtuwrsn ropuietion ~woy May, *~uIJ~U05727-8)I STPEG~/t-isn P'opu ataion Study May, 2U002 LIST OF TABLES TABLE 1 Latitude and longitude coordinates for gill net, hoop net, and trawl samples collected in the 47 acre Essential Cooling Pond, (STPEGS), March 27-28, 2002 ............................................................... 19 TABLE 2 Hydrological data (water temperature, dissolved oxygen, salinity, and pH)Collected during the Fish Population Study on the Essential Cooling Pond, (STPEGS), March 27-28, 2002 ........................................................... 20 TABLE 3 Total number of fish caught in each section and quadrant in the Essential Cooling Pond, (STPEGS), March 27-28, 2002 ............................... 21 TABLE 4 Catch rates for species caught in each section and quadrant in the Essential Cooling Pond, (STPEGS), March 27-28,2002 .................................... 22 TABLE 5 Mean sizes and range of sizes for the two species, sheepshead minnow and sailfin molly caught in the Essential Cooling Pond, (STPEGS), M arch 27-28, 2002 .................................................................................... 23 05727-800/STPEGS/FiFh Population Study May, 2002 LIST OF FIGURES FIGURE 1 The four sampling Quadrants (Q1, Q2, Q3, and Q4) established in the 47 acre Essential Cooling Pond (STPEGS), March 27-28, 2002 ................... 25 FIGURE 2 Location of gill net, hoop net, and trawl samples collected in the 47 acre Essential Cooling Pond (STPEGS), March 27-28, 2002 ............... 26 FIGURE 3 Cumulative length frequency of sheepshead minnow, Cyprinidon variegatus, captured in the Essential Cooling Pond, (STPEGS), March 27-28, 2002 ......................................................... 27 FIGURE 4 Cumulative length frequency of sailfin molly, Poecilia latipinna, captured in the Essential Cooling Pond, (STPEGS), March 27-28, 2002 ......................................................... 28 LIST OF APPENDICES APPENDIX A Water Quality Data: Graph of pH ranges in the Essential Cooling Pond, (STPEGS), from November 1999 until the present ...................... 31 APPENDIX B Essential Cooling Pond Fish Population Study, January 2002 ....................... 33-36 r~tj~,risn 'optMauon ~1uuy U05["72JI8=S P'OpUtaTionl SlhJy May, 2UU2 iii EMIL.EXECUTIVE

SUMMARY

Fish composition, size ranges, relative abundance, and estimates of total abundance were investigated in the South Texas Project Electric Generating Station 47-acre Essential Cooling Pond (ECP) through the use of three types of sampling gear (trawl, gill net, and hoop net). Of the three gear types used to sample the ECP, only the trawl was productive in catching fish. A total of 5,589 fish representing two species, sheepshead minnow (Cyprinodon variegatus) and sailfin molly (Poecilia latipinna), were caught during the study. Sheepshead minnows and sailfin mollies are both common species in Texas and are indigenous to coastal streams, rivers, and estuaries. Mean sizes for both species ranged from 27 to 62 mm total length (TL) (1 inch to 2.5 inches)and were evenly distributed across all sample sections. Sheepshead minnows were most abundant in quadrant Q2A and sailfin mollies were more abundant in Q4A near the intake structure. Relative abundance for both species was evenly distributed across quadrants Q2 and 03. The total number of fish caught in quadrant Q1, near the discharge, was significantly lower than the total number of fish caught in quadrants Q2, Q3, and Q4. Total abundance estimates derived from the total number of fish caught, total amount of trawling effort and total area covered, indicate that a population of 535,000 fish comprised of both species exists in the ECP. This estimate is an extrapolation from the data collected and is based on assumptions about the existing populations and the sample gear used. Therefore, interpretation of such data may result in an over estimate of total abundance. It is, however, our belief that fish populations in the ECP are not overabundant. Fish congregating at or near the intake structures may be attributed to the availability of food, structure or cover, and protection from environmental stresses. Under normal operating and environment conditions, both species would be expected to avoid the higher water velocities found immediately adjacent to the intake structure. Excessive impingement and entrainment of organisms is a factor more of how the pumps are operated rather than the total number of fish present in the ECP. Prevention of fish congregating in the intake structures may be achieved by maintaining a constant flow rate at the intake screens and in the pump wells and/or by changing the chemical composition of the water in the pump wells. If pumps must be shut down, adding 05727-800/STPEGS/Fish Population Study May, 2002 iv EM~.chemicals such as rotenone, chlorine or other chemicals in the pump wells may create water conditions unsuitable for fish and prevent them from congregating in the area.Based on the data we collected during this study and discussion with site personnel who observed the size/species distribution associated with the Essential Cooling Water Pump 1C strainer clogging, the existing population in the ECP is not expected to cause a recurrence of this condition as long as precautionary measures are taken to preclude fish from utilizing the screen/pump well areas during pump shut down and start up. Management recommendations for monitoring and control of the existing population are discussed in the body of the report.05727-800/STPEGS/Fish Population Study May, 2002 V

1.0 INTRODUCTION

This document presents a summarized report for the Fish Population Study performed on the 47 acre Essential Cooling Pond (ECP) at the South Texas Project Electric Generating Station (STPEGS), Wadsworth, Texas. The objective of this study was to determine baseline characteristics of the fish population (Nekton Population) in the 47 acre ECP and to provide management recommendations for monitoring and controlling said fish population. Section 1 presents the materials and methods arranged categorically. Section 2 discusses the data collected. Section 3 presents a discussion of the results and provides management recommendations.

1.1 MATERIALS

AND METHODS The fish population study was conducted in accordance with techniques described in FISHERIES TECHNIQUES by Nielson and Johnson (1983), published by the American Fisheries Society.The ECP was divided into four quadrants (Q1, Q2, Q3, Q4) based on linear shoreline measurements of approximately 1000 feet (Figure 1). Each quadrant was divided into two approximately equal sections and labeled as section A or B for each quadrant starting in a clockwise direction from the discharge structure around to the intake structure. A total of eight sections were identified in the ECP. A GARMIN 48 handheld GPS unit was used to verify sample quadrants and sections. Latitude and longitude coordinates were recorded for all samples collected. Per the request of site management (Pre-Job Brief) no gill nets or hoop nets were set within 1000 feet of the intake structure. Gill net and hoop net sets designated for Q4 were set on or immediately adjacent to the 1000-foot line in Q3 (Figure 2). Hydrological and nekton sampling methodology are detailed below.'4WC,-VIJOOI rLaorIbi, rupuiaiiui, ctuuy 1 7- -ý i" /p al tUJIL UI 1

1.2 HYDROLOGICAL

DATA A YSI Model 58 temperature/oxygen meter was used to measure water temperature (00) and dissolved oxygen (mg/I). These parameters were measured at the start and end of each sampling day. Both parameters were measured at mid-water depth. Water depths were reported by site personnel to be approximately 9 feet to 12 feet at the pump intake structure. South Texas Project's Nuclear Operating Company Chemistry/Environmental personnel provided additional water quality data. These data included pH and conductivity. Conductivity was converted to salinity [parts per thousand (ppt)] using a conversion nomogram. Hydrological data collected during this study were used only as base-line reference points for current conditions in the ECP.1.3 NEKTON The following gear types were used to establish sample size (numbers) and species (kinds) of fish present in the ECP. These gear types are routinely used by fisheries biologists for conducting total fish population assessments. Trawl samples were collected in the ECP using a 6.1 m (20 ft) otter trawl measured along the head-rope from shackle to shackle. A trawl door measuring 1.2 m long and 0.6 m tall (48 inch x 21 inch) was attached to each wing of the net. Each door was shackled to a 30.4-m (100 ft) long bridal and then attached to the stern of the towing vessel. The trawl was comprised of 3.8-cm (1 3/8-inch) stretched-nylon mesh and the cod end of the trawl was covered by a 6.3-mm (1/4 inch)nylon mesh sock. Trawl samples were towed for ten minutes behind a 16-foot center-console boat powered by a 40 hp motor. In the initial work scope, tow speed was set at 3.0 knots for all samples; however, trawls were towed at approximately

2.0 knots

in an effort to minimize net avoidance caused by engine prop wash. A total of eight trawl samples were collected (2 per each Quadrant). All finfish species were measured for total length (TL) to the nearest mm. If more than 50 individuals of a species occurred in sample, a random subsample of 50 was measured and the remaining individuals were counted to obtain a total number for each species.UD~ CI'tAJO~Q I rcuors~,I r~JIJut4utJ,, oiuuy 2 tviay ctnJc 057 7- -F -O rEl/isl rpuI~u oln i u iy 2 Maey =w Gill net samples were collected in the ECP using four (4) experimental gill nets constructed of monofilament mesh. Each net was 91.4-m (300 ft) long, 2-m (6 ft) deep and was comprised of four separate 22.9-m (75-foot) sections of 1.3-, 2.5-, 5.1-, and 7.6-cm (1/2-,1- , 2-, and 3-inch)stretched mesh connected in ascending mesh sizes. Two 15-lb concrete blocks were used to anchor each gill net to the bottom and one 15-lb block was used to anchor each gill net on the shore. Gill nets were set in randomly selected sections within each quadrant. Quadrant 4 gill net was set on or immediately adjacent to the 1000-foot boundary line separating Quadrant 3 and Quadrant 4 (the net was essentially set in Quadrant 3) per the Pre-Job Brief requirement that no nets be set within 1000 ft of the intake structure. Gill nets were set starting shortly before sunset (6:18 pm) and were retrieved within 2 hours after sunrise (6:38 am) on the following morning. No fish were captured in any of the gill net sets. Had fish been captured in the gill nets, they would have been sorted according to each section of mesh, identified by species, and measured for TL to the nearest millimeter. Four hoop net samples were set in the ECP using hoop nets constructed of fiberglass rings and cotton netting material. Each net measured 3.6-m (12-ft) in length, had an opening hoop diameter of 0.91--m (3-ft), and was covered by 5.1-cm (2-inch) stretched cotton mesh netting dipped in nylon coating.Hoop nets were set in a randomly selected section within each quadrant. Quadrant 4 hoop net was set on or immediately adjacent to the 1000-foot boundary line separating Quadrant 3 and Quadrant 4 (the net was essentially set in Quadrant 3) per the Pre-Job Brief requirement that no nets be set within 1000-foot of the intake structure. Each net was baited with a fish attractant (one can of dog food, recommended by local commercial fishermen). Hoop nets were set with the opening facing down current, anchored by two 15-lb concrete blocks and marked with buoys for easy retrieval. No fish were captured in any of the hoop net sets. Had fish been captured in the hoop nets, they would have been sorted by species and measured for TL to the nearest millimeter. 1.4 DATA ANALYSIS Data analysis was conducted for eight trawl samples and included the following parameters: total number of fish for each species captured, calculation of average size and range of sizes for each species, cumulative length frequencies for each species, and an estimate of relative abundance for each species.U572/-0t-UU/: IH'tU6:/F-ISn Population Study 3 Relative abundance was calculated by dividing the total number of each species captured by the amount of effort (time) the gear was used. This value represents catch-per-unit-effort (CPUE). CPUE is directly proportional to the total abundance of fish in the stock and can be used to make further statistical analyses such as comparing catch rates from quadrant to quadrant or from year to year.Additional statistical analyses were performed in order to test for homogeneity between sample variances (t-Test: Two-Sample Assuming Equal Variances) and to test for variability among sample means (ANOVA) (Alder and Roessler, 1977; Ott and Mendenhall, 1993).n QJQTDCr_'QIC;ýk 0;ý-I.C- C-A, M _F0 4 ay

2.0 RESULTS

The results of our study are presented below.2.1 SAMPLE LOCATIONS Sample locations for gill nets, hoop nets, and trawls are shown in Figure 2. Latitude and longitude coordinates for each sample site are presented in Table 1. A total of 16 samples were collected during this study. Hydrological and nekton data are presented below.2.2 HYDROLOGICAL DATA Hydrological data (water temperature, dissolved oxygen, salinity, and pH) are presented in Table 2.Water temperature during the study was 20.5 'C at the start of the study and 20.4 °C at the completion of the study.Dissolved oxygen (DO) readings during the study period ranged from 7.8 mg/I to 9.8 mg/I. DO readings were the highest in Quadrant 1 and the lowest in Quadrant 4. DO readings decreased incrementally from quadrant to quadrant as the sample stations moved further away from the discharge structure. This is to be expected, based on the turbulence near the discharge serving as an aerator. Dissolved oxygen readings were higher on day 1 than day 2 for all sample stations. Lowest dissolved oxygen readings were recorded on the second day of the study during the retrieval of the gill nets and hoop nets. A reading of 7.8 mg/I was recorded at Q4. Quadrant 1 dissolved oxygen readings on day 2 dropped down to 8.0 mg/l.STPEGS' Project Manager provided additional water quality data. Their data during the study period indicated the pH to range from 8.87 to 8.89 and conductivity to be 1114 qS/cm to 1131.qS/cm. Conversion of conductivity readings to salinity parts per thousand (ppt) indicated that salinity was <2.0 ppt. Additional water quality data provided by STPEGS's Chemistry/Environmental personnel indicated that pH in the ECP has fluctuated between 8.3 and 9.5 since November 1999 (Appendix A).UOICt~tAJOIOI rcuoIrIbII rupumirurr otuuy 5 gv~y ~uue U5727-ýSII Ipu atiUI on U y 5 M~ay 2002,

2.3 NEKTON

A total of 5,589 fish representing 2 species was caught during this study (Table 3). Species collected during sampling were Cyprinodon variegatus, (Sheepshead minnow) and Poecilia latipinna, (Sailfin molly). The trawl was the only gear type to capture fish. A discussion of each sampling gear is detailed below.2.3.1 Trawls A total of eight (8) trawl samples-were collected on the 47 acre ECP. Trawl samples were collected from eight different sections (Q1A, Q1 B, Q2A, Q2B, Q3A, Q3B, Q4A, and Q4B) of the ECP (Figure 2). Each section was trawled for 10 minutes at a tow speed of 2 knots. However, trawl sample Q4A was trawled for 8 minutes due to a twist in the trawl door that occurred during sampling. No attempt was made to redo the sample due to the proximity to the intake structure (within 1000 ft) and because the area was already covered during the initial trawl sample collection. Trawling twice in the same sample area during the same sample period could result in even fewer fish being caught. CPUE was adjusted according to different trawl times. A two-sample t-statistic was run to test for difference in sample population means between Q4A and Q4B. T-statistic results indicated there was no significant (95% level) difference between the two sample population means; further indicating there was no bias introduced by the shortened trawl time.Total catch (by number and catch rate) for each section is presented in Table 3. Section Q2A had the largest number of fish captured of all sections sampled. Section Q1 B had the fewest number of fish captured. ANOVA test results across all eight samples indicated that there was no significant (95% level) difference between sample means, thus indicating that all eight trawl samples were homogeneous. Total fish caught by quadrant indicates a significantly lower number of fish were caught in Q1 as compared to the other three quadrants. However, the total number of fish caught in Q2, Q3, and Q4 were not significantly different from one another.UO~~t-LflJN~I rtu~,rwfI ropuwtivri otutiy 6 May ~UU~-opu t~onl ou y 6 may 2002=: Catch rates for each section and quadrant are listed in Table 4. Catch rates by species indicates that sheepshead minnows were most prevalent in section Q2A and least abundant in Q1B. Sailfin mollies were most prevalent in section Q4A and least abundant in sections QIA, Q1 B, and Q3A. Species relative abundance was most evenly distributed across Q2 and Q3.The abundance of sailfin mollies in Q4 can be attributed to a number of different components; however, the availability of food and habitat (structure) as it relates to the intake structure are most likely the key components. Mean sizes for both species were the same across all sample sections (Table 5). The widest range was for sailfin mollies, which ranged from 27 to 62 mm TL (1 inch to 2.5 inches). The abundance of sailfin mollies was most prevalent in the 40 to 55 mm TL (1.5 to 2.25 inches) size class. Cumulative length frequencies for both species are presented in Figures 3 and 4.2.3.2 Gill Nets Four experimental gill nets were set in the ECP; one net per quadrant in randomly selected sections of each quadrant. No fish were captured in any of the gill net samples. Gill net fishing times (effort) are listed in Table 6. Average fishing time for gill nets was 13.24 hours.2.3.3 Hoop Nets Four hoop nets were set in the ECP; one net per quadrant in randomly selected sections of each quadrant. No fish were captured in any of the hoop net samples. Hoop net fishing times (effort)are listed in Table 6. Average fishing time for hoop nets was 14.01 hours.u~LeI-LAJ~ I rtu~irisn rupui~uun ~iuuy 7 IVIdY CUUC 05727-00/1 IE~is opulatton Sludy 7 Maliy 2LqJ EKr RNITA.3.0 DISCUSSION Discussions of the results for our study and management recommendations are detailed below.3.1 RESULTS Hydrological data were collected during this study for the purpose of establishing baseline water quality parameters in the ECP. No statistical correlation between fish abundance and water quality was performed using these data. Any inferences concerning possible correlation would be speculative at best and would require more data.Trawling was the only successful method of capturing fish in the ECP. Trawl samples collected in each of the four quadrants contained fish. Although only two species were captured, the total number and catch rate for each species indicates these fish are prevalent in all areas of the ECP. Quadrant 1 was the only quadrant sampled which had a significant difference in total number of fish. This fact can most likely be attributed to the amount of water being discharged by the plant into quadrant 1 of the ECP. Despite the fact that most fish species are attracted to water currents, flow rates from the discharge structure into Quadrant 1 are judged to be high enough to discourage most fish from residing in this area, specifically smaller fish such as those collected in our samples. In fact, it may be great enough to flush them from the area or limit their presence to the perimeter of the pond. A similar difference in distribution could be expected directly in front of the intake structure. However, it would be impossible to discern where exactly the fish in our study were caught because trawling methods used covered both shoreline and open water areas. Furthermore, trawl samples were not collected immediately in front of the intake structure for safety reasons.Data from the four gill net and four hoop net samples indicate the absence of larger fish species in the ECP. Although it is possible the sampling gears may have been selective for species and sizes, it is highly unlikely that all eight samples would have resulted in zero catches if fish of any size over 3 inches were present in the ECP. Furthermore, the lack of species diversity collected during trawl samples indicates no other species were present in the pond. Trawling is typically selective for the size of the individual captured, but not selective for species.-~a -C.JUC 0512 -0viyo I s PoL/InFpulaionl~ oudy 8 May 2002 EKR.The lack of species diversity has been further validated by data collected by STPEGS site personnel. Their preliminary data indicated that only sheepshead minnows and sailfin mollies were the species present (Appendix B). Their data were collected using baited minnow traps at or near the intake structure and the discharge structure. Comparative analysis of catch rates between gears is very difficult. Although no direct correlation between STPEGS data and the data we collected was conducted, the use of minnow traps to collect data as it pertains to relative abundance, size distribution, and species composition could prove valuable assuming proper sampling techniques are followed. These would include standardizing sample stations, sample times (soak time), placement depths, and baiting techniques to name a few.Data analysis of the eight trawl samples indicated the fish populations sampled were homogeneous. Mean sizes of fish captured in all four quadrants were similar for both species.Data analysis of sample size and catch rates indicate that Q1 was significantly different from Q2, Q3, and Q4. This significant difference can most likely be attributed to the velocity water in QI. Total abundance of fish was determined based on total number of fish caught and estimates of area covered during trawl samples.In an effort to estimate the total number of fish in the ECP, we made several basic assumptions, the validity of which we cannot verify based on a single set of samples. We have taken a "worst case" approach, which could overestimate the actual population size.We have assumed that there is a uniform distribution of fish throughout the ECP, both in depth and in width. We have also assumed that our trawling effort covered 5% of the total water volume and caught all fish that encountered the gear. Therefore, we collected 5% of the total population during our sampling effort. Based on these assumptions and extrapolation of the data, there is a population of 535,000 fish in the ECP, comprised of both species. However, we know that the fish are not uniformly distributed (Q1 was statistically different than Q2, Q3, Q4 in our data) and the size of the area sampled was not precisely 5% of the total area.Consequently, the actual population size could be less than this. As both species are more commonly found in shallow water or shoreline areas rather than open- or deep-water areas, it is highly probable that fish collected in the trawls were captured only from the shoreline zones. If s opua on u 9 ,vay this is true, the total population would be expected to be less than what we estimated, as the estimate is based on the total volume, not just the shallow shoreline area. Having determined that this is likely the case, we do not feel that either species is overpopulated. Congregation of these species at or near the intake structure may be attributed to the availability of food, structure or cover, and protection from environmental stresses such as extensive cold spells. During normal environmental conditions, fish in the ECP should tend to seek out natural habitats or niches. The occurrence of fish in the intake wells during cold weather conditions is a natural response. Fish will seek protected waters that provide relief from existing environmental conditions. The intake structure could provide such habitat. This could be particularly true when pumps are shutdown, creating a calm water refuge in the screen/pump wells. If this in fact happens, one would expect an increase in impingement when pumps are turned back on.Under normal operating and environmental conditions, both species would be expected to avoid the higher water velocities found immediately adjacent to the intake structure. Therefore, we believe that excessive impingement could occur only when pumps are shut down for an extended time period and fish either seek shelter within the intake structure pump wells, or utilize it as new habitat due to additional food availability and/or cover. Preventing fish from congregating in the intake structures may be achieved by maintaining a constant flow rate through the screens and/or by changing the chemical composition of the water around the pumps. This may be accomplished by dispersing chemicals, such as rotenone, chlorine, or other chemicals, directly into the water in the pump wells prior to restarting of pumps.The species captured from the ECP, Cyprinodon variegatus (sheepshead minnow) and Poecilia latipinna (sailfin molly) are common to brackish waters of the Texas Gulf Coast and both species are found in the many rivers and streams that enter the Texas bays. Make-up water for the ECP was from the main cooling reservoir, which originally came from the adjacent Colorado River. Both species are common in this river system (Texas Parks and Wildlife, personal communication). Although the possible sources of these fish were not evaluated in this study, ENSR is of the opinion that fish were introduced during the initial filling of the ECP. This means of introduction 05127-0=6/ I Ftt;:gw-Sn' Hopulation Zjtucly 10 may 2002 is highly probable if surface water was used to fill the pond. In the case of the sheepshead minnow, eggs could have also been carried in on the feet, legs, and plumage of various wading and aquatic birds as their eggs are semi-adhesive and are capable of adhering to these surfaces. This mechanism of introduction is not deemed possible with sailfin mollies.Of the two species captured, sheepshead minnows were more prevalent by a ratio of 50:1.Mean sizes of both species caught in the ECP were within normal length ranges and the majority of fish were either subadult or adults. Maximum length for sheepshead minnows was 55 mm TL (2.25 inches) and the maximum length for sailfin mollies was 62 mm TL (2.6 inches).No fish less than 20 mm TL were caught. The lack of juvenile fish in the samples is most likely a result of mesh size used on the trawl. A smaller mesh size would need to be used to capture the juvenile fish.Sheepshead minnows are a very hardy species. They are tolerable of a wide range of water quality conditions and are commonly found in marine, brackish, and freshwater habitats. They prefer shallow water habitats and are most common along sandy or silty shorelines. Sheepshead minnows can reach a maximum size of 3 inches and have an average life span of about three years. They are very prolific breeders reaching sexual maturity by the time they are one year old. They are egg layers and will spawn multiple times during the spring and summer months allowing them to populate an area in a very short period of time. They will lay approximately 20-25 eggs per spawn and their eggs are semi-adhesive. Sheepshead minnows are detritivores and prefer to feed over substrates of silt and detritus. They are known to burrow into soft substrate during adverse conditions, such as large temperature fluctuations and extreme tidal changes; which enables them to survive these situations. Sailfin mollies are primarily a brackish water species. They are known to be very adaptable in the wild and are commonly found in freshwater rivers and streams as well as saltwater environments. They feed mostly on algae and other plant matter that is available. Sailfin mollies are surface dwelling and swim freely in open areas, and they are particular to waters that are high in calcium (hard water) and more alkaline waters ranging in pH from 7.5 to 8.5.Sailfin mollies are typically 4 to 6 inches in length and have an average life span of 3 years.Po ulation StuA, Ma 2002 F 1"1 ENsR They are live bearers, giving birth to 20 to 80 fully developed young in each brood. The female sailfin molly will give birth once every six to eight weeks during the breeding season (April to September). They can produce young year round; however, they normally do not give birth when water temperatures are below 21.1°C.Beneficial aspects of these fish species in the ECP were not evaluated during our study.However, both species are known to feed on algae as well as other plant matter such as detritus and therefore could have a positive impact on the ECP. Furthermore, the ability of these fish to maintain healthy populations in the ECP is a good indication that the present ecosystem is providing necessary food, habitat, and water quality. It should be noted however, that current turbidity levels in the ECP are too high to allow establishment of large quantities of algae throughout the entire pond. Most of the algae should be isolated along the shoreline where available sunlight can penetrate the water and allow algae to grow. It is our opinion that if algae levels were to get to problematic levels in the ECP, it would require a larger population than the current population of fish to alleviate the problem.3.2 MANAGEMENT RECOMMENDATIONS Management of undesirable fish populations is achieved by using three basic methods: chemical, biological, and mechanical. Chemical and biological means are favored over mechanical controls for most species of fishes (Kohler and Hubert, 1993). Before determining what management approach will be most effective, several factors should be considered and evaluated. These include cost, size of the water body, water temperature and quality, target species, environmental concerns, and location of the water body (Kohler and Hubert, 1993).The use of chemical methods to control undesirable fish populations has become a very popular tool for fisheries managers. Most chemicals are easily applied, require a short time to get results, and very inexpensive when compared to other methods. Chemical methods are typically used to treat an entire system where the goal is the removal of all fish. Chemicals can also be used to partially treat particular sections, or spawning sites of selected fishes in an effort U~727-COWi I PL(~S/HSfl I~opuIation ~tudy 12 May ~UO2 05727-008/Zi 1 PE(35/I-I$1 Population 12 may z200 EN, .to remove a major portion of the population. This approach usually requires the introduction of a predatory species to forage on the remaining residual population. Chemicals used as fish toxicants must meet the needs* of the fishery managers. The toxicant should be specific for the targeted species, easy and safe to apply, degrade to a harmless constituent, must be effective over a broad range of water quality conditions, and be registered for use in the aquatic environment (Lennon et al. 1970).There are four approved and registered toxicants in the United States, two of which are registered for "general" use and will be discussed; rotenone and Antimycin. Fisheries managers commonly use both of these toxicants. Rotenone is the most common fish toxicant used by fisheries managers. Rotenone works by shutting down the oxygen transfer system in fish, which eventually causes suffocation. The chemical is safe and effective when applied properly and has almost no adverse affect on birds or mammals. Rotenone comes in liquid and powder formulations and can be dispersed by various methods. Liquid forms are easier to handle; however, they work best in shallower lakes and ponds. Rotenone is usually applied in the summer or fall when the water temperatures are above 20'C. There are several factors that affect the toxicity of rotenone; water temperature, light, dissolved oxygen, turbidity, and alkalinity. Some species of fish can tolerate low levels of oxygen and are therefore less susceptible to the effects of rotenone.Antimycin is an antibiotic and is the only other chemical registered as a "general" fish toxicant (Kohler and Hubert 1993). It is available only in a liquid form and is not as effective in deeper lakes. Antimycin is commonly referred to as Fintrol; however, it is not a common product found on the market. Antimycin is most effective in lakes, ponds, and streams that are comprised of a soft-water chemistry. n.10ý 0 1 -i stuý, M -02 op vsuau 13j ay IKRI Biological methods used to control undesirable fish species include the use of predation by other species of fish, birds, mammals, etc. It also includes the use of pathogens and biomanipulation to achieve the desired ecological balance. The use of biological methods usually requires adding one or more biological mechanism(s) into the natural system. Adding new species or managing for a particular species to control an undesirable species can have adverse effects on the overall management goals. Before choosing this approach, fisheries managers must evaluate whether the predator-prey combination will be effective as a control agent. Biological control methods are less expensive than chemical methods; however, the desired result is not attained as rapidly as with chemical methods, but often it is a more permanent method.Mechanical methods used to control undesirable fish species include water level manipulation, traps, barriers, commercial fishing, and electricity. Other methods include seines, trawls, gill nets, and cast nets. All of these gears are labor intensive and require multiple applications over an extended period of time to have an overall impact on the fishery.Complete eradication of undesirable fish species is seldom possible. However, control of existing species can be achieved by using methods that are applied at a time and location when the undesirable species is most vulnerable. The use of an integrated management approach may prove to be more effective than any one single approach.Based on the fish species present and the present population structure, management of these species may be best achieved by utilizing a combination of management approaches. Some possible approaches could include the following:

• Complete removal of both species through the use of chemicals such as Rotenone;* Management of species using both mechanical and chemical methods such as trawls, seining, and traps, followed by supplemental Rotenone applications;
• Management of species using mechanical methods described and supplemented by stocking of predator species; and* Management of species using only mechanical methods.U3,C-~AOOrcurisi rpuiwuiiowuyIV~Y CUC 1 5U 7-00/-JIoI Po'pulation Study 14 auy -'u All things considered, total removal of all fish from the Essential Cooling Pond may not be possible and or desirable due to beneficial aspects such as algae control. Using chemicals can be quite costly and will most likely not kill all the fish in the pond. Remaining individuals would be able to repopulate the pond in time. Furthermore, a massive kill could require a considerable amount of manpower and there is the possibility that dead fish would clog the screens at the intake structure.

Managing the species using multiple methods may prove most beneficial. First, capture of the fish using trawls or other gear will provide continuing data on the productivity of the fish population. Second, the cost associated with sampling will not be as high. Third, sampling could take place during times of the year when fish populations are the highest and pose the greatest threat to the pumps. For example, changes in numbers or species distribution detected in minnow traps could be used to implement control methodology. Fourth, supplementing the sampling with heavy dosages of rotenone in specific areas of the lake during peak spawning periods and before or during the coldest winter months could help manage the populations. An additional approach includes managing the pond by having a commercial fisherman harvest the two fish species.Both species are popular on the tropical fish market and/or are used by commercial laboratories for toxicity testing.The use of biological methods does work in some well managed lakes and ponds. However, the use of a biological control in the ECP would require continued management of stocked predator species and could eventually become a management problem in and of itself in the future.Given the dynamics of the ECP and the species present, managing the fish population will require an established monitoring and control plan based on the recommendations above. Periodic monitoring of the fish population in the pond should be used to determine if any control methodology is required based on plant operational considerations. For example, quarterly sampling using minnow traps with a standardized sampling program would provide size and species distribution information that could serve as a basis for initiating additional actions.Jug C, tJv0,c, r~~orICI H FUWUHGIIUI H CtUU~Uol~ ~ ~~ op a, lliFVInU Ituy 15 ay S:~R In an effort to prevent impingement after extended periods when a pump may be shut down, it is recommended that chemicals could be applied to the screen/pump wells prior to shut down to exclude or eliminate fish. Additionally, the placement of stop logs in the intake structure should help to preclude fish from utilizing the screen/pump wells during the down periods.-7-~n~t ,~ -jQ.r11. o- -i Q ..1.1 16t ivay II1IcR.4.0 LITERATURE CITED Alder, H. L. and E. B. Roessler. 1977. Introduction to Probability and Statistics. W.H. Freeman and Company. QA273.A43. Kohler, C. C. and W. A. Hubert, editors. 1993. Inland Fisheries Management in North America.American Fisheries Society, Bethesda, Maryland.Nielsen, L. A. and D. L. Johnson, editors. 1983. Fisheries Techniques. American Fisheries Society, Bethesda, Maryland.Ott, L. and W. Mendenhall. 1995. Understanding Statistics. International Thompson Publishing. QA276, 12087.Va, Ct ~'.AJCO S rCtorbE I ruj~u~tiui oiutjy *17 MU~ C'AIC--l~-Ul {}I -IlOi-ir S pu .tU onI w 17 nay,,,', ENTAB.TABLES 05727-O08ISTPEGSIFish Population Study 18 May 2002 Table 1. Latitude and longitude coordinates recorded for gill nets, hoop in the Essential Cooling Pond (STPEGS), March 27-28, 2002.nets, and trawl samples collected Area: 01 Trawl Data 02 B 03 04 A B B Latitude Longitude 28* 47' 46.9" 96* 02' 30.2" 28* 47' 40.6" 96* 02' 31.7" 28* 47' 49.7" 96* 02' 39.3" 96* 02' 39.8" Major Area: Station: 01 I Hoop Nets 02 B I 03 04 A B A A B A B Latitude 28*47'54.0 928*4753.3 .28*4742.9 28*47'45.0 Longitude 96*02'43.5 96*02"33.6 96*02'30.4 96*02'38.8 Gill Nets Major Area: Q1 02I I Q4 Station: A B A B A B A B Latiiuae Longitude Ie 75.96*02'38.4 94/",39.5 96*02'33.5 96"02'31.5 2 47 49.96*02'39.0 TABLE 2. Hydrological data (water temperature, dissolved oxygen, salinity, and pH) collected from the Essential Cooling Pond (STPEGS), March 27-28, 2002.Hydrological Data D.O. (mg/I)Start End Temperature (C)Start End pH*Start End Salinity** Start End 0 Trawls Gill Nets Hoop Nets 9.8 8.6 20.6 20.5 8.87 <2 8.4 7.8 20.7 20.4 8.87 <2 8.6 8.0 20.6 20.5 8.87 <2* pH readings were provided by STPEGS site personnel. Readings are presented in Appendix A.** Salinity readings were converted from conductivity readings provided by STPEGS site personnel. TABLE 3. Total number of fish caught in each sample section and quadrant in the Essential Cooling Pond (STPEGS), March 27-28, 2002.Total Number of Fish Caught Major Area: Station: 01 02 A 03 04 I-A B B A B A B Total Sheepshead Minnow 91 39 1862 85 1200 716 947 540 5480 Sailfin Molly 3 3 27 3 12 11 30 20 109 Total 94 42 1889 88 1212 727 977 560 5589 TABLE 4. Catch rates* (CPUE) for species caught in each sample section and quadrant in the Essential Cooling Pond (STPEGS), March 27-28, 2002.Sheepshead Minnow-Catch Rates (CPUE)Major Area: Station: Q1 02 Q3 04 A B A B A B A**B TOTAL N)N)Sheepshead Minnow 535.3 229.4 10952.9 500.0 7058.8 4211.8I7284.6 3176.5 4243.7 Sailfin Molly 17.6 17.6 158.8 17.6 70.6 64.7 230.8 117.6 86.9* Catch rates are calculated as number per hour for each trawl.** Sample time for this trawl was only eight minutes. CPUE was calculated for an eight minute time and not a ten minute time. TABLE 5. Mean size and range of size for species caught in each sample section and quadrant in the Essential Cooling Pond (STPEGS), March 27-28, 2002.Mean Size and Size Range mm Total Length (TL)Major Area: Station: 01 02 03 04 B A B A B A B A Ranqe*Sheepshead Minnow 37 39 39 38 39 40 39 40 28-55 Sailfin Molly 38 48 42 44 46 47 46 49 24-62* Range was determined across all sample sections. ERNR.FIGURES 05727-008/STPEGSIFish Population Study 24 May 2002 SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION ESSENTIAL COOLING POND 500 0 000 FEET Figure 1. Four sampling Quadrants (Q1, Q2, Q3, Q4) established in the Essential Cooling Pond (STPEGS) March 27-28, 2002.25 SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION ESSENTIAL COOLING POND LEGEND Trawl Samples Hoop nets Gill nets 500 0 000 FEET Flow Direction Figure 2. Locations of gill net, hoop net, and trawl samples collected in the Essential Cooling Pond (STPEGS) March 27-28, 2002 26 South Texas Project Electric Generating Station Fish Population Study 250 191 200-U.0.z z 150-100-88 79 50-0-16 8 7 0 25 0 30 35 40 45 50 55 60 Length (mm TL)Figure 3. Cumulative length frequency of sheepshead minnows caught in the Essential Cooling Pond, (STPEGS), March 27-28, 2002. South Texas Project Electric Fish Population Generating Station Study 40-35-35 (I)00 I-E=z 30 25 20 15 10 22 19 16 7 4 5-0-3 2 25 30 35 40 45 50 55 60 65 Length (mm TL)Figure 4. Cumulative length frequency of saifin mollies caught in the Essential Cooling Pond (STPEGS), March 27-28, 2002. ENM.R APPENDICES uagc,-UIJco rcuor,~.,rujju.auu.i oLuuy May2002 27 oputuuu ontuuy 29 May 2002 ENM~.APPENDIX A Hydrological Data: Graph of pH ranges in the Essential Cooling Pond, (STPEGS), from November 1999 until the present.05727-O8/STPEGS/Fish Population Study 30 May 2002 ECW Pond pH from 1999 to Present 10 9.5.9-.-E I-.8-7.5 -i i i i 1 1 1 1 1 Nov-99 Jan-00 Mar-00 May-00 Jul-00 Sep-00 Nov-00 Jan-01 Mar-01 May-01 Jul-01 Sep-01 Nov-01 Jan-02 Mar-02 May-02 Jul-02-Ul- U ECW TRN COMM PH pH Units 11cR.APPENDIX B Essential Cooling Pond Fish Population Study, January 2002.05727-008/STPEGS/Fish Population Study 32 May 2002 05727-00a(STPEGS/Fish Population Study 32 May 2002 Essential Cooling Pond Fish Population Study January-February 2002 The Essential Cooling Pond is a 47 acre pond. Depth is approximately 9 feet to 12 feet at the pump intake structure. The conductivity is approximately 1100 uS and the pH is approximately 9.0.1/7/02 @ 1700 -Set minnow trap in the Essential Cooling Pond (ECP) at Sample Point No. 1 to observe population activity overnight. Minnow trap used was 23 cm diameter by 41 cm long, mesh size 0.5 cm. Trap was baited with can tuna with holes punched in the can. Trap was placed approximately 6 feet from the edge at a depth of 1 foot.1/8/02 @0830 -Minnow trap removed with 40 minnows captured. The largest minnow was a male sailfin molly approximately 5.5 cm (2 1/8" long). Only 1 of these was observed. Most of the population observed appeared to be female and juvenile sailfin mollys. A few of what appeared to be sheepshead minnows were also captured.Average temperature of the ECP overnight -560 F.1/8/02 @0840 -Set minnow trap at Sample Point No. 1 to observe population activity during the day.1/8/02 @1610 -Minnow trap was removed with no minnows captured. There was still some tuna in the can. Additional holes were punched in the can and the trap was returned to Sample Point No. 1 to observe population activity overnight. A walk down of the area around the discharge structure was conducted and no minnows were observed in the shallow water.1/9/02 @0900 -Minnow trap was removed with 37 minnows captured. Most of the population observed appeared to be female and juvenile sailfin mollys. The largest minnow was approximately 1 '"long. A few of what appeared to be sheepshead minnows were also captured.1/9/02 @0910 -A new can of tuna was placed in the trap and it was returned to Sample Point I to observe population activity during the day.1/9/02 @ 1620 -Minnow trap was removed with no minnows captured. Minnow trap was returned to Sample Point 1.1/9/02 @ 1630 -Minnow trap was baited with can cat food and placed at Sample Point 2 to observe population activity overnight on the intake side near ECW 2A. Windy conditions were noted with quite a bit of wave action.1/10/02 @08 10 -Minnow trap was removed from Sample Point No.1 with 28 minnows captured. Most of the population observed appeared to be small female and juvenile sailfin mollys. The largest minnow captured was approximately 2" long male sailfin molly. A few of what appeared to be sheepshead minnows were also captured. The trap was removed.33 1/10/02 @ 0815 -Minnow trap was removed from Sample Point No. 2 with 214 minnows captured. Most of these were small female and juvenile sailfin mollys. Five (5) small and two (2) large males were also captured. In addition ten (10) sheepshead minnows were captured.When the trap was removed the conditions of the ECP were calm with very little wave action in the intake area. The trap was returned to Sample Point 2 to observe population activity during the day.1/10/02 @ 1620 -Minnow trap was removed from Sample Point No. 2 with 22 minnows captured. All were very small sailfin mollys. Largest was only 1". Average size was 3/4". The wave action had increased from this morning. Most of the afternoon was cloudy. The trap was returned to Sample Point 2 to observe population activity over the weekend.1/14/02 @ 0820 -Minnow trap was removed from Sample Point No. 2 with approximately 400-500 minnows captured. Most were juvenile and female sailfin mollys. There were 5 large males and several small males captured. The largest male was approximately 2 1/2". Several large females were also observed. A few sheepshead minnows were also captured. Note that the trap was left out from Thursday afternoon until Monday morning. The bait had been used twice before.1/14/02 @ 1630 -Reset minnow traps with new cat food bait at Sample Points 1 and 2 at a depth of approximately 2 feet. Noted a small school of larger fish approximately 75-100 feet from shore. They appeared to be 5-6" in length.1/15/02 @ 1000 -Minnow trap was removed from Sample Point No. 1 with 30 minnows captured. Most were female and juvenile sailfin mollys. The largest was a female that measured approximately 2 "'. Two small males were also captured as well as two sheepshead minnows.The trap at Sample Point 2 was unable to be collected due to wave action.1/15/02 @1630 -Minnow trap was removed from Sample Point No. 2 with 35 minnows captured. Most were female and juvenile sailfin mollys. All were about the same size of approximately 1-1 1/2". Ten sheepshead minnows were also captured. The trap was in approximately 2' of water for 24 hours. The wind was causing significant wave action.1/16/02 @0900 -Minnow trap was removed from Sample Point No.2. The minnows captured yesterday were left in the trap overnight due to the wave action. An additional 10 more minnows were captured by 0900. A couple of larger sheepshead minnows were observed. Two small male sailfin mollys were also captured. It is believed that the wave action limited the activity overnight. Also observed was a layer of black organic matter that appeared to be larvae (fish, mosquito, midge, etc.) in the north intake area.1/16/02 @ 1630 -Placed minnow trap at Sample Point No. 3 on the intake side in approximately 1 foot of water with cat food as bait.1/17/02 @ 1600 -Minnow trap was removed with approximately 150-200 minnows captured.Most were female and juvenile sailfin mollies. One large and several small males were captured.34 Some small sheepshead minnows were also captured. The temperature was warm (75°F.) with a southeast wind.1/21/02 @0940 -Minnow trap was removed with approximately 100 minnows captured. Most were female and juvenile sailfin mollies. Six large males were captured. A few sheepshead minnows were also collected. The trap had been out all weekend. At collection time, there was heavy fog. The minnow trap was removed by

• and *. New bait was placed in the trap and it was returned to Sample Point No. 3.1/21/02 @ 1540 -Minnow trap was removed with no minnows captured.

Weather conditions were sunny and warm (-65'F.). Trap was returned to the water to observe overnight activity.1/22/02 @ 1600 -Minnow trap had blown ashore during windy conditions. No minnows were captured. The trap was returned to Sample Point No. 3.1/23/02 @ 1545 -Minnow trap was removed with 6 minnows captured. All were juvenile and female sailfin mollies. The trap was removed from this location.2/11/02 @ 1630 -Minnow traps were baited with cat food and placed at Sample Points 1 and 2.2/12/02 @ 0930 -Minnow traps were removed. No minnows were captured at Sample Point 1.A total of 34 minnows were captured at Sample Point 2. All were small juvenile or female mollies, except for 1 sheepshead minnow. Minnow traps were returned to Sample Point 1 and 2.2/13/02 @ 1530 -Minnow traps were removed. Three minnows were captured at Sample Point 1. All were small juvenile or female mollies. A total of 103 minnows were captured at Sample Point 2. Most were small juvenile or female mollies, except for one young male. A few small sheepshead minnows were also noted. A strong east wind was noted. Minnow traps were returned to Sample Point 1 and 2. Minnows captured were released in the PADD.2/14/02 @ 1545 -Minnow traps were removed. Thirteen minnows were captured at Sample Point 1. Most were small female and juvenile mollies. One small male was observed.Approximately 300 minnows were captured at Sample Point 2. Most were female and juvenile mollies. Some small males were observed. There was a strong southeast wind. The minnows were released in to the Main Cooling Reservoir. The traps were removed.3/26/02 @ 1615 -Minnow traps were baited with cat food and placed at Sample Points I and 2.3/27/02 @ 0900 -Approximately 306 minnows were captured at Sample Point 2. Most were small female and juvenile mollies. Six small males were observed. Five large females were observed. Approximately 25% were sheepshead minnows. Three of these were large.Approximately 69 minnows were captured at Sample Point 1. Most were small female and juvenile mollies. Two large male mollies were captured. Eight sheepshead minnows were also captured. Traps were but back in the water at 1600 on 3/27/02.35 3/27/02 @ 1215- ENSR here to perform ECP fish population assessment. Eight trawls were performed. Gill and hoop nets were set out overnight. 3/28/02 @0700 -ENSR retrieved gill and hoop nets. No fish were captured in any of the nets.3/28/02 @ 1000 -Approximately 67 minnows were captured at Sample Point 2. Most were juvenile and small female mollies. Some large sheepshead minnows were also captured. 110 minnows were captured at Sample Point 1. Most were small female and juvenile mollies. Some sheepshead minnows were also captured. The traps were removed.** Names were removed per the request of STPEGS Nuclear Operating Chemical/Environmental personnel. 36 AQ-5. Texas Commission on Environmental Quality (TCEQ). 2007. Letter from Mr. Kelly Holligan, TCEQ, to Mr. R. A. Gangluff, STPNOC, dated June 27, 2007, "Cooling Water Intake Structures Phase II Rules; South Texas Project Electric Generating Station; TPDES Gangluff, STPNOC, dated June 27, 2007, "Cooling Water Intake Structures Phase II Rules; South Texas Project Electric Generating Station; TPDES Permit No. WQOOO 1908000."- This letter (or other documentation) should state that the Main Cooling Reservoir (MCR) is not waters of the State. £14-6STP k&Cý2I Kathleen Hartnett White, Chairman Larry R. Soward, Commissioner H. S. Buddy Garcia, Commissioner Glenn Shankle, Executive Director TEXAS COMMISSION ON ENVIRONMENTAL QUALITY Protecting Texas by Reducing and Preventing Pollution June 27, 2007 Mr. R.A. Gangluff, Manager, Chemistry Environmental and Health Physics STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 Re: Cooling Water Intake Structures Phase II Rules; South Texas Project Electric Generating Station;TPDES Permit No. WQ0001908000.

Dear Mr. Gangluff:

I received your letter dated May 24, 2007, requesting that the Main Cooling Reservoir (MCR) be designated as a closed-cycle recirculating system and as not water in the state.The Texas Commission on Environmental Quality (TCEQ) does not have an official method of"designating" a facility's operation as a closed-cycle recirculating system. However, we have reviewed the information you submitted and based on our best professional judgement, we consider your facility to be a closed-cycle recirculating system. As mentioned in your letter, the federal rule governing the 316(b)Phase I1 cooling water intakes is currently in the process of being suspended. For the time being, implementation of the 316(b) requirements will be based on best professional judgement (BPJ) and subject to EPA Region VI review.We also concur that the Main Cooling Reservoir (MCR) at your facility does not meet the definition of water in the state.If you have any questions, please contact me at (512) 239-2369.Sincerely, Kelly Ilolligan, Leader Industrial Team Water Quality Division KH!jp P.O. Box 13087

• Austin, Texas 78711-3087
• 512-239-1000 I lnternet address: www.tceq.state.tx.us AQ-7 Baker W. B., Green G. N. 1989, 1987-1988 Special Ecological Studies for the South Texas Project, Matagorda County, Texas. Final report March 1989. Houston, TX: Houston Lighting & Power Company. 3 4 p. [In Terrestrial Ecology section of STP NRC Environmental Audit Binder]

.1987 -1988 SPECIAL ECOLOGICAL STUDIES FOR THE SOUTH TEXAS PROJECT MATAGORDA COUNTY, TEXAS FINAL REPORT by William B. Baker, Jr.and George N. Greene (Houston Lighting & Power Company Environmental Department Water and Ecological Resources Division P.O. Box 1700 Houston, Texas 77251 March 1989 TABLE OF CONTENTS Page LIST OF FIGURES ................ .................... iii LIST OF TABLES ................ .................. iv LIST OF APPENDIX TABLES ............... ................ v INTRODUCTION .................... ..................... 1 STUDY AREA ..................... ...................... 1 METHODS ....................... ........................ 3 Alligator Survey ................. .................. 3 White-tailed Deer Survey ........... .............. 3 Waterfowl Survey ................. ................. 5 Bald Eagle Survey ................ ................. 5 RESULTS AND DISCUSSION ............... ................. 8 Alligator Survey ................. .................. 8 White-tailed Deer Survey ........... .............. 8 Waterfowl Survey ......... .................. .. 14 Bald Eagle Survey .......... .................. 17 SUMM1ARY .................. ........................ 21 LITERATURE CITED ............. .................... 22 APPENDIX TABLES .............. .................... 24 ii LIST OF FIGURES 0 Figure Page 1 Location of the South Texas Project Site .... ...... 2 2 American Alligator transect lines on the STP site ................ ................... 4 3 White-tailed deer observation points and transect line on the east side of the STP cooling reservoir ..... ....... ............. 6 4 Number of known active bald eagle nests in TPWD survey area C, 1988 (from Mabie 1988) ........ 20 0 iii 0 LIST OF TABLES Table Page 1 Maximum number of alligators observed per transect on the STP site, 1982-1988 ..... ................ 9 2 Number of alligators seen on survey transects at STP, 17-19 May 1988. ............ ............... 10 3 Mean number of alligators observed per km of transect on the STP site, 1978-1988 ... ......... ..11 4 Daily counts of alligators seen in the STP reservoir during waterfowl surveys, 1983-1987 .... 12 5 Daily counts of white-tailed deer at STP, 1987 .... 13 6 Maximum number of white-tailed deer observed in daily counts at STP, 1982-1987 ..... ............ .. 15 7 Minimum waterfowl population estimates on the STP cooling reservoir during October, November and December, 1981-1987 ........ ............... 16 8 Minimum waterfowl (other than ducks and geese)population estimates on the STP cooling reservoir during October, November and December, 1983-1987 .......... ................. 18 9 Texas Parks and Wildlife Department midwinter duck and goose inventory along the Upper Texas Coast, 1982-83 thru 1987-88 ...... ............. .. 19 iv LIST OF APPENDIX TABLES Appendix Table Page I Daily counts of white-tailed deer along the STP makeup right-of-way surveys, 1987. .....25 II Daily counts of white-tailed deer along the STP blowdown canal, 1987 .... ........... .. 26 III Daily counts of white-tailed deer adjacent to the woodland area at STP, 1987 ............ ...27 IV Daily counts of white-tailed deer seen during waterfowl surveys at the STP reservoir 1987 .. .28 C.V 0Q INTRODUCTION This report describes the special ecological studies designed to monitor the impacts of plant operations at the South Texas Project (STP) site on selected wildlife populations. On August 21, 1987, Unit .received an operating license and initiated fuel loading, marking the beginning of operational phase monitoring. The operational studies involve a continuation of procedures established during construction phase monitoring, which covered the period 1978-1987. Species selected for monitoring were considered to be indicators of general environmental quality. Both American alligators (Alligator mississippiensis) and bald eagles (Haliaeetus leucocephalus) were originally chosen because of their endangered and threatened species status. Since the study was initiated the status of the American alligator in Texas has been changed from endangered to threatened by similarity of appearance (Federal Register 1983). Other species selected for monitoring were white-tailed deer (Odocoileus virginianus) and waterfowl (family Anatidae) because of their recreational and economic importance to the region. Selected resident waterfowl and shorebirds were also monitored for changes in populations. Presented in this report are the results of field investigations conducted on and near the STP site between September 1987 and May 1988. These data are summarized and compared with data obtained in earlier years (1978-1987). The results of studies conducted in previous years were reported by Springer (1980), Leavens et al. (1981), Davis (1952, 1983), Davis and Wilkinson (1984), Greene et al. (1985), Baker et al. (1986), Greene et al. (1987), and Baker and Greene (1988).STUDY AREA The STP site is located in southern Matagorda County, approximately 16 km south of Bay City, on the west bank of the Colorado River (Figure 1). Over half of the 5000 ha site is occupied by a cooling reservoir which presently has an average depth of about 3.5 m.Vegetationally, the study area is part of the Gulf Praries and Marshes region (Gould 1975). Five basic wildlife habitats have been identified on the site: (1) the disturbed construction area, (2) the cooling reservoir, (3) the woodlands between the reservoir and the Colorado River, (4) drainage and irrigation canals, and (5) Kelly Lake.1 I ý'OKLAHOMA I 68ýww M0,00 Art 0 tRa~EIC OrtF -&-0 -1 tW GULF O0F MEXICO FIGURE 1. Location of the South Texas Project site METHODS Alligator Survey Alligators at the STP site were surveyed along previously established transects. Figure 2 shows transect locations and lengths. Transects 1 and 5 (Kelly Lake and Relocated Little Robbins Slough) were surveyed on 3 consecutive nights. Transect 10 was surveyed on three consecutive days. The night surveys were conducted no earlier than 1 hour after sunset and no later than 30 minutes before sunrise. All surveys were conducted on 17-19 May 1988 during the dark phase of the moon (new moon).Surveys have been conducted during the dark phase of the moon since the monitoring study began to ensure high count accuracy and to standardize the procedures (Chabreck 1966). Surveys were conducted in May, the peak of the breeding season, when alligators of both sexes travel a great deal and are more conspicuous than at other times of the year (Joanen and McNease 1975, Nichols et al. 1976).Transect 1 was surveyed by canoe, the other two by truck. A 400,000 candlepower spotlight was used to locate the alligators at night. Their eyes reflect a characteristic amber glow that can be easily recognized and detected from several hundred yards (Chabreck 1966). With a light shining in their eyes, most alligators will remain stationary long enough to be approached within range for reliable size estimation. The alligators were easily approachable by truck during the day as well. In transects 1 and 5 the alligators were assigned to size classes by estimating the distance from their eyes to the tip of their snout. The total body length was estimated using the formula: x = -0.5113 + 1.1456y where x is total length in feet and y is snout length in inches.This formula was derived by linear regression from data reported for coastal Louisiana alligators (Chabreck 1966). Alligators greater than 1.8 m (6 ft) in length were considered adults (Nichols et al. 1976). On transect 10 (the Entire Dike), length estimates were made from observations of the entire animal when visible or from snout length when the entire animal was not visible. The highest count for each survey period was used as the minimum population estimate for that period.White-tailed Deer Survey White-tailed deer surveys were conducted on five consecutive days during the week of September 27-October 2, and during the first full week of November and December.3

• ICHRE:*NTK cr" ESSENTIAL "1 SITE COOLING RBOUNDARY i -- ,,,.PONDI S RNSC 10 4 .2 .. km........~KELLY.................

TRANSE COOLING RESERVOIR EIP FIUR 2 llgao trnsc loain"nth.Tie ..... .... .. ... .. ..* .... S~rLN*ENnING POINTS FIGURE 2. Alligator transect locations on the STP site. Deer were observed from two fixed observation points and a driving transect between these two points. The two fixed points were located on the dike adjacent to the makeup right-of-way and the blowdown canal (Figure 3). Observers watched the fixed survey areas for 30 minutes starting at sunrise and 30 minutes prior to sunset. Observation times for a site were rotated on alternate days, e.g., if the blowdown canal was surveyed in the morning on the first day, it would be surveyed in the evening on the second day. The driving transect was along the western edge of the woodlands adjacent to the reservoir. It was surveyed in the morning and evening of each day by driving along the dike after each fixed survey, stopping to count and identify deer as necessary. A 22X spotting scope was used to help classify deer according to age and sex. Incidental deer observations were also recorded while conducting waterfowl surveys.Waterfowl Surveys Ducks, geese and other waterfowl are most abundant on the STP cooling reservoir during the fall and winter months.Population estimates were made on five consecutive days during the week of September 27-October 2, and the first full week of November and December. Observations began after the dawn deer survey and ended before the dusk deer survey. Species were identified with the aid of a 22X spotting scope. The highest daily count of each species in each month was used as the minimum population estimate of that species.Additional data were obtained from the annual aerial surveys of duck and goose populations wintering in Texas, which were coordinated by the U.S. Fish and Wildlife Service (USFWS) and conducted by the Texas Parks & Wildlife Department (TPWD). For survey purposes, Texas is currently divided into five waterfowl zones by TPWD: Northeast Texas, Northwest Texas, North-central Texas, Lower Coast and Upper Coast. Matagorda County is in the Upper Coast zone. Total goose estimates were derived from combined totals of Texas Coastal Goose Inventory Zones 1-3. Duck totals were derived by combining totals in Texas Mid-winter Waterfowl Inventory Zones A,B,C, and D.Bald Eagle Survey All large raptors are carefully observed during waterfowl surveys to see if they are bald eagles. In addition, reports of bald eagle sightings in the vicinity of the STP site were solicited from specified site personnel. 5 F.'.o SITE BOUNDARY I N t'COOLING RESERVOIR RESERVOIR DIKE* *OBSERVATION POINTS........ ! TRANSECT LINE White-tailed deer observation points and transect line on the east side of the STP cooling reservoir. 40 6 An extensive aerial search for bald eagle nests in eastern and coastal Texas was conducted by TPWD personnel in January, February and early March of 1988. Nests found to be active were examined again in March and later to determine the number of young produced (Mabie 1988). When new eagle nests were located, TPWD biologists contacted landowners to acquire nest history data.7 RESULTS AND DISCUSSION Alligator Survey The maximum number of alligators observed on transects at the STP site in 1988 was 53 (Table 1). The highest mean density of alligators seen was 7.0 alligators/km on the Kelly Lake transect (Table 2). This represents a reduction in the density of alligators from the 1987 census, which was apparent in all 3 observation transects (Table 3). The total number of alligators on the site continues to decline, but should begin to stabilize now that the plant is operational, although seasonal variations in population level will probably remain.Results of the Entire Dike survey in the Spring of 1988 showed a total of 23 alligators. This represents a reduction of 27 animals from the 1987 Fall survey, 7 from the 1987 Spring survey, and 58 from the 1986 Spring survey (Table 4). This decline was predicted to occur as reservoir fill operations inundated nesting habitat in the Main Cooling Reservoir (MCR)(Baker and Greene 1988). Now that the water level is at operational design levels the population of alligators in the MCR should remain relatively constant, being dominated by adult males. Based on total length estimates, the 1988 Spring survey of the MCR showed a 98% adult population present.Results of the Kelly Lake transect indicate a maximum number of 27 alligators. This is slightly lower than the Spring 1987 survey of 32. The 1988 density in Kelly Lake was 7.0 alligators/km which is well above densities recorded from 1978-1985, but slightly below the density of 8.3 alligators/km recorded in 1987. The 1988 Kelly Lake population consisted of 69% adults and 31% juveniles. Kelly Lake remains as the prime alligator nesting habitat site at the STP.The Relocated Little Robbins Slough transect had a maximum count of 3 alligators in the Spring 1988 survey, down about 50%from 1986 and 1987. This decline can probably be attributed to a major construction project which involved dredging the entire transect channel and resurfacing it with a layer of sand, mat material, and irregular shaped stone. The renovation of the Slough was completed in early 1988, just prior to the survey.Subsequent to these activities, the alligator population in the Little Robbins Slough should stabilize. All alligators observed on this transect in 1988 Spring survey were juveniles. White-tailed Deer Survey In 1987 the greatest number of deer observed per day was 29, which occurred in the October survey (Table 5). The November 8 0 TABLE 1. Maximum number of alligators observed per transect on the STP site, 1982-1988 TRANSECT LENGTH 1982 1983 1984 1985 1986 1986 1987 1988 NUMBER & NAME (km) Night Day 01 Kelly Lake 3.5 3 8 9 17 8 32 27 03 South Drainage 5.1 7 3 3 6 Canal 04 Blowdown Canal 1.6 1 0 1 05 Relocated Little 6.8 1 2 4 1 6 5 7 3 Robbins Slough 07 East Dike 3.0 6 4 2 Cooling Reservoir 08 South Dike 5.4 8 2 Cooling Reservoir 09 "Y" Dike 8.3 14 Cooling Reservoir 10 Entire Dike 41.2 81 30 23 Cooling Reservoir TOTAL 9 22 22 32 23 94 69 53 a TABLE 2. Number of alligators seen on survey transects at STP, 17-19 May 1988 b,c TRANSECT TRANSECT REPLICATE NO. NO./KM MEAN BODY NO. ADULTS: NO. AND NAME LENGTH (km) SEEN LENGTH (m) NO. JUVENILES 01 3.5 1 25 7.1 Kelly Lake 2 22 6.3 (night) 3 27 7.1 1.4 20:44 MEAN 7.0 05 6.8 1 2 0.3 Relocated Little 2 3 0.4 Robbins Slough 3 2 0.3 0.5 0:7 (night) MEAN 0.3 10 41.2 1 19 0.5 Entire Dike 2 23 0.6 (day) 3 22 0.5 3.0 57:1 MEAN 0.5 a Location shown in Figure 1 b Alligators greater than 1.8 m were designated adults c Includes only individuals for which length estimates were made I-i S a TABLE 3. Mean number of alligators observed per km of transect on the STP site, 1978-1988 TRANSECT NO. Length 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1982 AND NAME (km) Day Night 01 Kelly Lake 3.5 0.9 0.6 0.6 0.7 0.8 0.9 2.1 1.6 2.0 4.1 8.3 7.C 03 South Drainage Canal 5.1 2.0 1.5 3.1 0.5 1.4 0.6 0.6 0.9 ... ...04 Blowdown Canal 1.6 0.9 0.6 --- 0.4 0.6 0.0 0.2 ---......05 Relocated Little 6.8 0.2 0.2 0.0 0.3 0.3 0.1 0.4 0.2 0.6 0.6 0.9 0.3 Robbins Slough 07 East Dike 3.0 --- --- 0.7 1.0 2.4 1.7 0.8 0.3 Cooling Reservoir 08 South Dike 5.4 --- --- --- 0.8 0.4 1.0 0.2 ---Cooling Reservoir 09 sty li Dike 8 .3 ---. --- .--. -.- ... ... ...- 1 .4 ----Cooling Reservoir 10 Entire Dike 41.2 --- --- --- --- --- --- --- --- 1.8 --- 0.7 0.E Cooling Reservoir a Mean number of alligators observed divided by the total transect length. TABLE 4. Daily counts of alligators seen in the STP reservoir during waterfowl surveys, 1983-1987 MONTH DATE 1983 1984 1985 1986 1987 1 September October November December 28 29 30 1 2 3 4 5 6 7 8 9 10 2 3 4 5 6 7 8 9 10 11 2 3 4 5 6 7 8 9 10 11 12 21 23 22 19 14 10 32 35 8 18 20 10 10 13 12 12 9 14 14 14 6 0 0 3 2 9 17 20 27 36 32 37 33 35 45 54 39 52 38 28 50 38 46 38 38 26 36 10 22 26 36 31 21 27 14 (.6 5 57 25 31 20 9 35 42 30 37 13 2 2 4 15 29 12 28 10 MONTHLY MAXIMUM October November December 23 35 42 20 14 6 36 50 57 54 36 37 45 36 29 12 a TABLE 5. Daily counts of white-tailed deer at STP, 1987 DATE TIME OF DAY BUCKS DOES YEARLINGS UNKNOWN TOTAL September 27 28 28 29 29 30 30 October 1 1 2 November 1 2 2 3 3 4 4 5 5 6 December 6 7 7 8 8 9 9 10 10 11 PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM 4 2 3 2 8 3 6 3 3 3 1 1 1 8 3 11 5 4 3 15 12 12 9 1 2 1 2 2 6 2 7 1 2 6 10 5 2 1 9 3 No Observation -8 2 8 4 17 8 9 7 29 17 27 13 9 13 6 4 13 13 4 7 4 9 11 17 4 18 7 25 Fog 3 5 3 1 2 1 1 2 1 4 4 2 6 2 6 3 11 5 3 1 10 4 5 2 14 7 No Observation -Fog 9 3 9 3 14 12 b MONTHLY MAXIMUM October November December 8 3 4 15 10 14 7 3 7 30 16 25 a Includes deer seen on waterfowl survey. They were added to AM totals because they were observed in AM.b Monthly maximum is the total of the largest number of Bucks, Does, and Yearlings seen. Before the largest numbers were chosen, Unknowns were apportioned to Bucks, Does and Yearlings in the percentage in which they occur in the population. 13 survey showed a significant drop in deer totals in the Woodlands Al drive transect and the Blowdown transect (Table 6). This decline was probably due to intense construction activities on the upper half of the Blowdown transect and the associated traffic moving along the Woodlands drive transect. Worker shift changes closely coincided with the morning and evening drive transect schedules. This trend continued on the drive transect in December, but counts increased on the Blowdown transect as heavy equipment work declined. Following these construction activities, deer totals should return to levels observed in the three previous annual surveys.Approximately 63% of the deer sighted in all survey areas were adult does (Appendix Tables I-IV). Bucks comprised approximately 17%, yearlings 19%, and unknowns 1% of the population. These figures compare favorably to previous STP deer surveys. Downing et al. (1977) pointed out the inherent bias and the unequal observability between sex and age classes of white-tailed deer, so it is doubtful that these data represent the true proportion of sex and age classes.Only 2 deer were observed during the waterfowl survey at the Main Cooling Reservoir (Appendix Table IV). Both were does, observed during the October survey.Waterfowl Survey The total number of ducks observed in the 1987 maintained Ae the population decline that began in 1985. Species diversity also continued to decline with only 16 duck species observed in the three month survey of the Main Cooling Reservoir (Table 7). In the 1987 survey 84 ducks were observed in October, 1,768 in November, and 665 in December (Table 7). The most abundant duck in October was the Black-bellied whistling duck. In November and December the most abundant duck was the Lesser scaup. It should be noted that other wetland habitats on site such as Kelly Lake and the Little Robbins Slough, along with numerous drainages, continue to have high species diversity. The highest number of total geese was recorded in December.Snow geese were the most abundant species with 1,656 individuals observed, followed by Canadian geese at 309, and the White-fronted goose at 130. Goose counts were significantly lower in 1987 than in any of the 5 previous years.As mentioned previously (Baker and Greene 1988), reservoir fill operations have inundated the temporary marshes and isolated islands within the Main Cooling Reservoir, and have created a deep, open-water habitat. This change in habitat due to reservoir filling is the main reason for the decline in species diversity and total numbers of waterfowl on the MCR. As predicted (STP ER-OL 1985), the dominant duck species on the MCR are now diving ducks (e.g. Lesser scaup and Ring-necked ducks)(Table 7).0 14 TABLE 6. Maximum number of white-tailed 1982-1987 deer observed in daily counts at STP, SURVEY AREA 1982 1983 1984 1985 1986 1987 MAKEUP RIGHT-OF WAY October 4 2 7 7 6 13 November 4 4 5 12 5 9 December 0 0 7 12 12 11 BLOWDOWN CANAL October 15 3 9 19 30 15 November 5 15 38 23 25 8 December 8 21 28 11 18 25 WOODLANDS, EAST OF RESERVOIR October 13 5 10 15 20 14 November 6 9 23 11 12 7 December 0 12 26 25 32 8 a SOUTH DIKE, COOLING RESERVOIR October 13 November 10 December 7 a Not surveyed after 1982, as the area was under water.H TABLE 7. Minimum waterfowl population estimates on the STP cooling reservoir during October, November and December, 1981-1987 OCTOBER NOVEMBER DECEMBER 1981 1982 1983 1984 1985 1986 1987 1981 1982 1983 1984 1985 1986 1987 1981 1982 1983 1984 1985 1986 1987 SPECIES Canad White Snow Unide a goose. 0 5 0 1 16 0 c-fronted goose 72 0 0 2 0 0 goose 0 1 0 0 1 0 entified geese 0 0 12 0 0 0 TOTAL GEESE 72 6 12 3 17 0 0 0 0 0 0 23 400 130 27 113 51 3 57 250 18 28 423 31 1 135 400 751 190 57 19 9.0 0 58 0 0 0 215 1050 957 245 593 101 13'0 17 98 406 1082 589 103 876 1705 9381 19676 1895 157 46 2097 1855 3245 1543 1990 79 350 11998 6037 6669 7153 9712 1656 0 0 0 0 0 1250 0 499 14971 9597 19295 28372 14847 1892Black-bellied whistling duck Fulvous whistling duck Mallard Mottled duck Gadwall Northern pintail Green-winged teal Blue-winged teal Cinnamon teal American wigeon Northern shoveler Wood duck Redhead Ring-necked duck Canvasback Lesser scaup Bufflehead Common goldeneye Ruddy duck Hooded merganser Redbreasted merganser Unidentified ducks Unidentified teal 0 47 205 316 741 0 22 23 98 41 0 2 0 8 0 160 833 130 322 96 0 0 0 36 8 300 904 0 22 2 400 74 8 1060 69 950 1517 529 19378 9252 1 0 0 0 0 11 540 0 294 269 25 0 1 22 0 0 0 0 0 12 0 0 0 1 0 0 0 0 2 0 0 0 0 0 0 0 5 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 2 3 0 0 0 0 0 0 0 0 0 0 0 0 112 185 13 0 0 0 0 300 66 40 9 0 237 157 815 88 318 0 0 0 1 8 100 0 11 0 6 0 0 26 0 2 0 0 22 0 0 0 17 0 0 0 4 0 0 0 0 0 0 4 0 0 0 27 0 0 0 17 0 0 0 0 0 0 0 0 0 0 0 0 0 43 70 32 26 69 4 5 147 925 141 278 317 58 67 15 151 78 2890 543 90 27 153 2638 13 697 15 11 18 615 3296 151 2376 709 38 5 32 43 322 8396 377 223 84 0 5 0 2,0 0 0 43 154 457 3423 1958 251 48 31 69 12 55 47 133 18 0 9 3 3 0 0 12 0 7 36 12 7 0 11 250 96 43 679 242 134 4 175 11 110 453 543 20 9 1 57 223 207 148 155 1416 2 3 1 3 0 0 0 0 0 0 0 0 0 0 2 25 81 582 189 49 13 3 1 8 0 0 0 0 0 0 0 1 0 0 4 0 545 112 66 62 90 18 0 0 0 0 0 11 0 36 248 87 45 16 170 19 110 404 159 163 86 113 22 3 209 301 1337 84 14 4 72 267 61 299 60 85 2 826 3576 230 1353 169 191 9 3 7 31 775 72 102 6 0 1 1 12 0 2 0 5 390 1304 2225 373 2 10 25 128 123 229 52 32 0 0 9 0 1 9 0 0 0 6 1 8 4 0 0 128 150 1 60 52 250 176 2 151 1041 1118 725 1 0 30 3 11 22 190 33 384 2 0 0 1 3 0 0 0 0 1 2 0 1 0 12 12 62 109 64 5 3 2 7 0 15 2 4 0 0 0 2 0 0 2 0 0 525 53 101 71 82 30 0 0 3 0 0 40 0 0 7 0 0 0 TOTAL DUCKS 1847 3944 1008 21746 10806 120 84 1512 8123 1929 20655 6308 1867 1768 1262 6330 3629 8716 2120 1449 665 84 1727 9173 2886 20900 6901 1968 3128 1761 21301 13226 28011 30492 16269 2557 TOTALS 1919 3950 1020 21749 10823 120 a Population estimates consist of the highest of five consecutive daily counts in each month, b See American Ornithologist's Union (1983) for scientific names.9 S In addition to ducks and geese, 23 other waterfowl species were included in the monthly surveys at the STP reservoir (Table 8). The Cormorant spp. was the most abundant species (287 seen in December), followed by the Anhinga (169 in October) and the Great blue heron (111 in October).In general, species which require shallow water habitat, aquatic vegetation, and woody vegetation have declined in abundance since 1984 (Table 8). Examples of this are the Common gallinule, Purple gallinule, American coot and Pied-billed grebe.Waterfowl species which thrive in open water and non-vegetated shorelines have maintained or increased their population numbers since 1983. Examples are the Great blue heron and Cormorant spp.This shift in populations can be attributed to the rise of the water level within the reservoir. This trend will probably stabilize now that operational levels have been reached.Biologists from the Texas Parks and Wildlife Department annually survey set transects to assess the duck and goose populations in Texas. The goose survey was conducted during the period December 14-17, 1987, and the duck survey during the period January 11-13, 1988 (Lobpries 1988).Total geese for the 1987-88 survey was 700,300 (Table 9).This represents the lowest total in the six year period reported.The decline is in all three species of geese. The Snow goose and White-fronted goose totals represent an all time low in the survey of 584,200 and 65,000 respectively. Only in the 1982-83 survey was the Canada goose total lower than the 51,100 reported in the 1987-88 survey.Total ducks for the 1987-88 survey was 1,644,200 (Table 9).This total is significantly higher than the 1986-87 total of 972,400, and is the highest total recorded in the last six years of the survey. Northern pintails and Green-winged teal were at peak levels, accounting for almost 80% of the total duck survey.Bald Eagle Survey A reliable source reported the sighting of one mature bald eagle on the STP site near the blowdown canal (Fig. 2) in April 1988. This was the only observation of a bald eagle on the site in 1988.During January, February and March 1988, the Texas Parks and Wildlife Department conducted its annual bald eagle nest survey (Mabie 1988). Of 20 active nests in Texas, 16 were found in area C, the counties surrounding the STP site (Figure 4). Ten of the 16 active nests fledged 15 young. This figure compares favorably with 1987, when 18 young were fledged (Mabie 1987), and is slightly less than the 1986 total of 22 (Mabie 1986).17 a TABLE 8. Minimum waterfowl (other than ducks and geese) population estimates on the STP cooling reservoir during October, November and December, 1983-1987 b SPECIES OCTOBER NOVEMBER DECEMBER 1983 1984 1985 1986 1987 1983 1984 1985 1986 1987 1983 1984 1985 1986 1987 Pied-bill grebe Eared grebe Horned grebe Western grebe White pelican Cormorant spp.Anhinga Great blue heron Green heron Little blue heron 0 Great egret Snowy egret Louisiana heron Black-crowned night heron Yellow-crowned night heron American bittern White-faced ibis White ibis Roseate spoonbill Sandhill crane Purple gallinule Common gallinule American coot 356 11 0 0 0 6 179 122 1 28 60 17 45 6 184 0 1 0 0 40 187 98 1 9 62 19 61 6 158 0 0 0 0 57 116 95 0 15 36 8 18 2 75 0 0 0 0 83 97 107 3 160 16 10 14 13 5 0 0 0 0 90 169 i11 0 3 2 9 9 2 539 0 3 0 1 30 305 106 0 12 48 27 71 1 181 1 16 1 0 100 183 93 0 4 64 14 13 7 380 0 7 0 0 339 88 88 3 6 23 40 29 3 11 1 4 1 172 72 85 0 1 5 1i 7 0 3 0 0 0 0 154 12 103 0 2 3 10 3 0 387 109 2 0 19 85 178 89 0 4 46 13 16 14 266 30 38 1 0 306 122 85 0 5 38 11 6 28 70 11 29 0 34 24 76 66 0 2 13 23 4 3 13 0 2 0 13 425 23 103 0 2 0 5 1 9 2 0 0 0 17 287 2 100 0 1 1 14 2 0 24 0 1 0 0 1 1 1 0 0 0 0 3 0 0 2 62 14 6 3 455 2089 0 8 13 6 3 467 6818 2 38 2 1 0 380 727 0 13 45 2 0 0 0 211 0 22 0 2 0 2 0 75 0 5 8 12 0 63 14274 0 235 17 4 0 7 3589.2 1 78 12 0 3 9 3529 0 27 1 0 0 0 527 0 1 0 2 0 0 0 67 0 5 30 6 0 16 6429 0 10 0 9 0 2 24926 0 40 5 7 0 2 2034 0 75 0 2 30 0 0 115 0 19 2 0 10 0 0 15 6429 24926 2034 uS 15 a Population estimates consist of five consecutive daily counts in each month.b See American Ornithologists' Union (1983) for scientific names.I~ i 0 I-, a TABLE 9. Texas Parks and Wildlife Department midwinter duck and goose inventory along the Upper Texas Coast, 1982-83 thru 1987-88 b SPECIES 1982-83 1983-84 1984-85 1985-86 1986-87 1987-88 Canada goose 31,400 93,300 62,600 110,300 64,150 51,100 Snow goose 765,800 778,400 895,600 746,200 771,000 584,200 White-fronted goose 96,600 128,000 138,900 89,000 161,850 65,000 TOTAL GEESE 893,800 999,700 1,097,100 945,500 997,100 700,300 Mottled Duck 38,200 50,500 32,100 42,100 33,150 27,100 Mallard 29,200 52,000 17,300 40,000 19,800 64,500 Northern pintail 199,600 446,600 438,400 230,600 300,350 596,600 Gadwall 124,700 145,700 110,200 78,600 93,200 65,300 American wigeon 31,400 40,800 8,900 13,900 11,200 12,500 Green-winged teal 172,000 213,500 239,300 200,400 363,400 708,000 Blue-winged teal 1,200 2,000 12,300 3,900 2,450 2,600 Northern shoveler 70,400 44,900 45,700 63,200 63,850 99,200 Wood duck 900 0 2,600 0 250 300 Whistling duck 3,300 _0 0 3,900 0 0 Lesser scaup 11,300 12,400 49,100 27,800 18,550 34,300 Redhead 25,400 1,200 2,300 900 40,700 4,700 Canvasback 80,100 53,200 6,000 25,200 7,750 11,600 Ring-necked duck 1,400 33,000 5,800 8,800 4,600 12,600 Ruddy duck 5,500 19,.900 9,600 5,300 11,800 2,700 Bufflehead 300 100 1,200 700 450 1,400 Common goldeneye 0 100 100 100 900 800 Unidentified ducks 32,400 15,700 2,300 2,000 0 0 TOTAL DUCKS 827,300 1,131,600 983,200 751,900 972,400 1,644,200 TOTAL WATERFOWL 1,721,100 2,131,600 2,080,300 1,697,400 1,969,500 2,344,500 a D.S. Lobpries, TPWD; unpublished data.b See American Ornithologists' Union (1983)for scientific names. AREA C FORT SEND BAOIA GOLIAD 'BEE RIEFUGIO SA ARICI NUECES , A FIGURE 4. Number of known active bald eagle nests in TPWD survey area C, 1987 (Mabie, 1987).20

SUMMARY

Population levels of alligators, white-tailed deer, waterfowl and bald eagles were monitored on the STP site to detect any changes that might be attributed to operational activities. Field studies were conducted between late September 1987 and May 1988.The alligator population on the STP site continues to decline. Only 53 alligators were counted in 1988, compared to 69 in 1987, and 94 in 1986.It appears that the main cause for the decline is the elimination of suitable habitat within the main cooling reservoir. The population should begin to stabilize now that water has reached operational levels in the main cooling reservoir. A maximum of 29 deer were seen in 1987. The deer population was relatively stable during the previous 3 survey periods, but construction activities on the Blowdown transect during the 1987 survey resulted in a slight population decline. When construction activity is completed the deer population should stabilize at previous levels. Adult does accounted for 63% of the deer population, bucks 17%, yearlings 19% and unknown 1%.In the 1987 survey, 84 ducks were observed in October, 1,768 in November, and 665 in December. The most abundant duck in October was the Black-bellied whistling duck. In November and December the most abundant duck was the Lesser scaup. Total numbers of ducks and species diversity have declined since their peak in 1984.Geese were most abundant in the month of December. Snow geese were the most abundant species with 1,656 individuals observed. Goose counts on the site were at their lowest levels since 1981, which corresponds to TPWD counts in Texas Coastal Zones.Of the 23 species of waterfowl other than ducks and geese, the Cormorant spp. was the most abundant species (287 seen in December), followed by the Anhinga (169 in October) and the Great blue heron (111 in October).Reservoir fill operations in late summer and early fall of 1985 inundated prime waterfowl habitat. This appears to be the major factor for the recent decline in waterfowl population numbers and species diversity. As the lake level has risen, there has been a decline in the numbers of dabbling ducks (e.g. Galdwall, Northern pintail and American wigeon) and an increase in the number of diving ducks (e.g. Lesser scaup and Ring-necked ducks). Populations should begin to stabilize now that the reservoir water level is at the operation design level.One bald eagle was observed on the STP site in 1987. In counties surrounding the STP site, the Texas Parks and Wildlife Department recorded 16 active nests. The total number of fledgling eagles was 15, which was slightly lower than the 18 fledged in 1987.21 LITERATURE CITED American Ornithologists' Union. 1983. Check-list of North American birds, 6th edition. A.O.U., New York. 691 pp.Baker, W. B. Jr., D. C. McAden and G. N. Greene. 1986. Special Ecological Studies for the South Texas Project, Matagotda County, Texas (1984-1985). Houston Lighting & Power Co., Environmental Protection Dept., Ecology Div., Houston, TX. 29 pp.and G. N. Greene. 1988. Special Ecological Studies for the South Texas Project, Matagorda County, Texas (1987-1988). Houston Lighting and Power Co., Environmental Dept., Water and Ecological Resources Div., Houston, TX. 28 pp.Chabreck, R.H. 1966. Methods of determining the size and composition of alligator populations in Louisiana. Proc. Southeastern Assoc. Game and Fish Commissioners Conf. 20:105-112. Davis, C.E. 1982. Special ecological studies for the South Texas Project: Matagorda County, Texas. Report submitted to Houston Lighting & Power Co.by LGL Ecological Research Associates, Inc., Bryan, TX. 22 pp.1983. Special ecological studies for the South Texas Project: Matagorda County, Texas 1981-1982. Report submitted to Houston Lighting &Power Co. by LGL Ecological Research Associates, Inc., Bryan, TX. 28 pp.and D.L. Wilkinson. 1984. Special ecological studies for the South Texas Project, Matagorda County, Texas (1982-1983). Report submitted to Houston Lighting & Power Co. by LGL Ecological Research Associates, Inc., Bryan, TX. 29 pp.Downing, R.L., E.D. Michael and R.J. Poux, Jr. 1977. Accuracy of sex and age ratio counts of white-tailed deer. J. Wildl. Manage. 41(4):709-714. Environmental Report -Operating License Stage, South Texas Project Units l&2, May 1985, Vol. 2, Appendix G, G-10.Federal Register. 1983. Endangered and threatened wildlife and plants; final rule to change the status of the American alligator in the State of Texas.48(198):46332-46336. Gould, F.W. 1975. Texas plants: a checklist and ecological summary. Texas Agric. Exp. Stn. MP-585/Rev. 121 pp.Greene, G.N., D.C. McAden and W.B. Baker, Jr. 1985. Special ecological studies for the South Texas Project, Matagorda County, Texas (1983-1984). Houston Lighting & Power Co., Environmental Protection Dept., Ecology Div., Houston, TX. 28 pp.22 , and 1987. Special ecological studies for the South Texas Project, Matagorda County, Texas (1985-1986). Houston Lighting & Power Co., Environmental Dept., Water and Ecological Resources Div., Houston, TX. 29 pp.Joanen, T. and L. McNease. 1975. Notes on the reproductive biology and captive propagation of the American alligator. Proc. Southeastern Assoc.Game and Fish Commissioners Conf. 29:407-414. Leavens, W.R., C.E. Davis and M.D. Springer. 1981. Special ecological studies for the South Texas Project: Matagorda County, Texas 1981-1982. Report submitted to Houston Lighting & Power Co. by LGL Ecological Research Associates, Inc., Bryan, TX. 26 pp.Lobpries,D.S. 1988. TPWD, unpublished data.Mabie, D.W.No. 30, Austin, No. 30, Austin, No. 30, Austin, 1986.Federal TX. 10 1987.Federal TX. 11 1988.Federal TX. 11 Nongame wildlife investigations: bald eagle survey. Job Aid Proj. No. W-103-R-16. Texas Parks and Wildl. Dept., pP.Nongame wildlife investigations: bald eagle survey. Job Aid Proj. No. W-103-R-17. Texas Parks and Wildl. Dept., pp.Nongame wildlife investigations: bald eagle survey. Job Aid Proj. No. W-103-R-18. Texas Parks and Wildl. Dept., pp.Nichols, J.D., L. Viehman, R.H. Chabreck and B. Fenderson. 1976. Simulation of a commercially harvested alligator population in Louisiana. La. Agric.Exp. Stn. Bull. No. 691. 59 pp.Springer, M.D. 1980.Matagorda County, by LGL Ecological Special ecological studies for the South Texas Project, Texas. Report submitted to Houston Lighting & Power Co.Research Associates, Inc., Bryan, TX. 23 pp.23 APPENDIX TABLES C.24 APPENDIX TABLE I.Daily counts of white-tailed deer along STP makeup right-of-way, 1987 the DATE TIME OF DAY BUCKS DOES YEARLINGS UNKNOWN TOTAL September 27 28 29 30 October 1 November 2 3 4 5 6 December 6 7 8 9 10 PM AM PM AM PM PM AM PM AM AM PM AM PM AM PM 3 1 5 8 3 3 5 3 2 7 2 3 2 6 6 5 5 8 3 7 1 1 2 13 1 2 2 1 3 3 9 3 4 1 1 2 3 4 2 2 4 11 10 7 8 25 APPENDIX TABLE II. Daily counts of white-tailed deer along STP blowdown canal, 1987 the (1.DATE TIME OF DAY BUCKS DOES YEARLINGS UNKNOWN TOTAL September 28 29 30 October 1 2 November 1 2 3 4 5 December 7 8 9 10 11 PM AM PM AM AM PM AM PM AM PM PM AM PM AM AM 3 2 5 3 2 2 4 6 4 8 3 9 1 2 1 1 9 7 15 4 13 2 6 5 1 No Observation -2 1 4 8 6 3 Fog 8 3 14 4 1 7 12 4 25 12 No Observation -9 3 Fog 0 26 APPENDIX TABLE III. Daily counts of white-tailed deer adjacent to the woodland area at the STP, 1987 DATE TIME OF DAY BUCKS DOES YEARLINGS UNKNOWN TOTAL September 27 28 28 29 29 30 30 October 1 1 2 November 1 2 2 3 3 4 4 5 5 6 December 6 7 7 8 8 9 9 10 10 11 PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM PM AM 1 3 3 1 5 1 1 3 7 7 7 1 2 1 2 4 1 6 1 8 1 2 6 14 14 0 1 1 1 1 2.1 4 4 2 4 2 No Observation -Fog 1 2 1 3 1 5 5 3 1 7 4 1 4 0 5 0 5 0 8 0 0 6 0 1 1 4 4 3 1 4 No Observation -Fog 4 1 1 27 APPENDIX TABLE IV. Daily counts of white-tailed deer seen during 0 waterfowl surveys at the STP reservoir, 1987 DATE BUCKS DOES YEARLINGS TOTAL September 28 29 30 October 1 2 2 2 November 2 3 4 5 6 December 7 8 9 11 28 AQ-8. Ducks Unlimited and HPLC. 1996. Wetland Development Agreement for the Texas Prairie Wetland Project, Gulf Coast Joint Venture, between Ducks Unlimited, Inc., and Houston Lighting & Power Co. October 23, 1996. 12 p. [In Terrestrial Ecology section of STP NRC Environmental Audit Binder] WETLAND DEVELOPMENT AGREEMENT TEXAS PRAIRIE WETILAND PROJECT GULF COAST JOINT VENTURE This Agreement is made this 23 day of October , 1996 between Ducks Unlimited, Inc., a not for profit corporation organized under the laws of the District of Columbia with its address at 101 Business Park Drive, Suite D, Jackson, Mississippi 39213 (hereinafter "DU") and Houston Lighting and Power Company, acting as Project Manager of the South Texas Project Electric Generating Station on behalf of all Participants therein under the South Texas Project Participation Agreement executed as of July 1, 1973, as amended.an individual with its address at P.O. Box 1700, Houston, Texas 77251, Phone: (713)945-8,213 (hereinafter "Cooperator"). WHEREAS, DU is a member and representative of the Gulf Coast Joint Venture;WHEREAS, as part of its purpose, the Gulf Coast Joint Venture seeks to develop private lands for wildlife management, pursuant to the Texas Prairie Wetlands Project , by encouraging the management of harvested croplands, waterfowl food plots, moist soil areas, forested wetlands and other natural wetland, by their owners, to provide habitat for waterfowl and other migratory birds and other wildlife;WHEREAS, Cooperator owns certain land, described in Exhibit A of this Agreement, and wishes to develop a portion of that land for wildlife management purposes listed above pursuant to the Texas Prairie Wetlands Project.NOW, THEREFORE, in consideration of the mutual premises listed herein the parties agree as follows:

1. Cooperator agrees to undertake those wildlife development activities listed in Exhibit B of this Agreement (hereinafter "Improvements")

on his property at the location specified therein (hereinafter "site") within 2 months of the date of this Agreement.

2. DU agrees to provide the materials detailed in Exhibit B having a value equal to N/A Dollars ($ N/A .3. Upon completion of the Improvements, DU agrees to reimburse to the Cooperator an amount equal to fifteen thousand Dollars ($15,000.00) or one hundred percent (100%) of the cost of the Improvements, whichev-er is less. Only those costs, or the portion thereof, for the Improvements listed in Exhibit B will be subject to reimbursement.

The amount of reimbursement due the cooperator shall be reduced by the amount of the value of materials supplied by DU pursuant to paragraph two (2) of this agreement. Completion of the Improvements shall be deemed to have occurred when the construction of the Improvements has been completed and DU has inspected and accepted such construction as being in compliance with the Improvements listed in Exhibit B.4. Cooperator shall be solely responsible for the :Site and improvements. Nothing in this Agreement shall give DU any jurisdiction or responsibility for the Site and Improvements, other than the right of inspection from time to time to assure compliance with this Agreement. Cooperator shall be solely responsible for all liability arising from the Site and Improvements. DU and the partners of the Gulf Coast Joint Venture shall not be responsible for any liability arising from the Site and Improvements.

5. Cooperator shall comply with terms of the management plan listed in Exhibit C of this Agreement (hereinafter"Management Plan") and the special. provisions listed in Exhibit D of this Agreement (hereinafter "Special Provisions")

.6. Cooperator shall be responsible for all maintenance of the Site and Improvements.

7. The Cooperator is responsible for obtaining and shall obtain all necessary and required permits for the construction and maintenance of the Improvements.

2

8. During the term of this Agreement, Cooperator shall permit DU or its representatives the right of access to the Site for inspection purposes.

DU's employees, officers, agents, representatives, invites, permittees, shall enter upon Cooperator's property at their own risk and Cooperator in no way warrants the condition of the property subject to this Agreement. Cooperator assumes no responsibility or liability whatsoever by reason of granting this permit to DU, and DU assumes the risk of personal employee injury (including death) and property damage when upon Cooperator's property, including for any latent or patent defects in the property.9. The Cooperator warrants and guarantees that it is the owner of the Site and has all required authority to enter into this Agreement and comply with its terms.10. This Agreement shall be effective on the date listed above and shall remain in effect until 15 years from that date.11. Cooperator shall be in breach of this Agreement if Cooperator: A. does not maintain the Improvements in compliance with the Management Plan;B. does not comply with the Special Provisions; C. sells or transfers the Site and does not assign this Agreement to the new owners; or D. breaches any other term of this Agreement. If Cooperator is in breach of this Agreement, DU may, upon thirty (30) days prior written notice to Cooperator, terminate this Agreement unless Cooperator within such notice period remedies the breach. If the Agreement is terminated due to a Cooperator's breach of the Agreement, Cooperator agrees to reimburse DU an amount equal to 100 percent divided by the length of this Agreement times each year remaining in this Agreement (for a 10 year agreement with 5 years remaining: 100/10 X 5=50% of the amount specified in item three (3) of this agreement).

12. DU may, upon at least sixty (60) days prior written notice to Cooperator, assign this Agreement to the Texas Parks and Wildlife Department if DU ceases to be a partner of the Texas Prairie Wetlands Project.

13. Notices under this Agreement shall be in writing and shall 0 deemed to be given when mailed by certified mail return receipt requested or hand delivered to the address of the party to whom the notice is intended at the address listed above or at such other address as that party may specify from time to time.(0 A Agreed and accepted: COOPERATOR DATE (Signature)

Social Security or Taxpayer ID #: .... Lo BY: TITLE:A /ý,ýTHE TEXAS PRAIRIE S PROJECT IS JOINTLY FUNDED AND DELIVERED BY: DUC tNL ITED, INC.; U.S. FISH & WILDLIFE SERVICE, TEXASP & WILDLIFE DEPARTMENT, AND USDA NATURAL RESOURCES CONSERVATION SERVICE 5 EXHIBIT A PROPERTY DESCRIPTION LEGAL DESCRIPTION: attach a state county map highlighting property boundaries and nearest town; using ASCS field map (preferred) or quadrangle map highlight project area to be flooded and show location of water control structures to be installed and/or levee to be constructed. Quadrangle Map Name: Blessing SE, Tex.Project location: (at center of property)Latitude: Longitude: County and state where project is located:Matagorda Co. / Texas Legal

Description:

Approximately 12,228.184 acres of land located in the John Raney Survey, Abstract 80, C.H. Vander-veer Survey, Abstract 95, Abram Sheppard Survey, Abstract 383, Fred S. Robbins Survey, Abstract 523, and the William Selkirk Survey, Abstract 87, all in Matagorda County, Texas.GENERAL DIRECTIONS TO PROPERTY (proximity to nearest town, major roads, etc suitable for locating the property)From Bay City, Texas take State Highway 60 south. Travel approximately 9 miles, then take F.M. 521 west, just south of Wadsworth, Texas. Continue on F.M. 521 approximately 8 miles to South Texas Nuclear Power Plant. Project sites are located south of F.M. 521.6 EXHIBIT B IMPROVEMENTS The Cooperator (landowner) agrees to provide project land of approximately 110 acres and to perform and/or provide the construction related wildlife habitat developments listed in this Exhibit.The Cooperator shall provide and/or perform the following improvement related wildlife habitat development activities: Unit 1: Construct/Repair 2,670' (1,273 yds 3) levee with 4'crown and 4:1 side slopes from station 29+30 -56+00.Purchase and install one 18"x30' aluminum pipe equipped with 18"x3' aluminum flash-board riser and tongue &groove flash-boards. Cost / Value = $3,606.80 1,273 yds 3 @ $1/yds 3 = $1,273.00 site preparation/clear vegetation = $1,361.10 (1) 18"1x30' aluminum pipe @ $13.53/L.F. $405.90 (1) 18"x3' aluminum flash-board riser = $283.30 (1) set tongue & groove flash-boards with pins = $58.50 installation 5hrs./structure @ $45/hr. = $225.00 Unit 2: Construct/Repair 2,083' (2,085 yds 3) levee with 4'crown and 4:1 side slopes from station 39+68 -60+51.Purchase and install one 21"x30' aluminum pipe equipped with 21"x4' aluminum flash-board riser and tongue &groove flash-boards..Cost / Value = $4,623.60 2,085 yds 3 @ $1/yds3 = $2,085.00 site preparation/clear vegetation = $1,361.10 (1) 21"x30' aluminum pipe @ $15.76/L.F. = $472.80 (1) 21"x4' aluminum flash-board riser $389.70 (1) set tongue groove flash-boards with pins = $90.00 installation 5hrs./structure @ $45/hr. = $225.00 Unit 3: Construct/Repair 4,846' (4,231 yds 3) levee with 4'crown and 4:1 side slopes from station 17+54 -66+00.Purchase and install one 21"x30' aluminum pipe equipped with 21"x4' aluminum flash-board riser and tongue &groove flash-boards. Cost / Value = $6,769.60 7 4,231 yds3 @ $1/yds' = $4,231.00 site preparation/clear vegetation = $1,361.10 (1) 21"x30' aluminum pipe @ $15.76/L.F. = $472.80 (1) 21"x4' aluminum flash-board riser $389.70 C.(1) set tongue & groove flash-boards with pins = $90.00 installation 5hrs./structure @ $45/hr. = $225.00 Pursuant to Paragraph 2 of this agreement, the following materials will be supplied by DU: N/A 8 EXHIBIT B cont.The project includes the following habitat types/acres: Unit 1: MSPL / 18 Unit 4: /Unit 2: MSPL / 46 Unit 5: /Unit 3: MSPL / 46 Unit 6: /The total value of improvements listed in Exhibit B = $15,000.00 9 EXHIBIT C MANAGEMENT PLAN To help ensure that waterfowl receive the maximum benefits from the project, disturbance in and around project sites should be kept to a minimum during the winter season. It is recommended that hunting of each management unit be restricted to no more than three (3) mornings per week.The Cooperator shall provide and/or perform the following improvement related wildlife habitat development activities: Units 1, 2, & 3 collectively comprise 110 acres of farmland that has been taken out of agricultural production. The units will be developed and managed to provide seasonal/semi-permanent wetland habitat for wintering migratory waterfowl, and other wetland dependent wildlife.The units will be managed for the production of native moist soil vegetation, with a water depth averaging from 6"-18". Flooding of the impoundments should begin with the installation of some flash boards by August 15 or as soon as moist soil plants have become well established. All flashboards should be installed up to the designed maximum water level by November 1. The Cooperator agrees to "guarantee" 55 acres of surface water (by pumping or purchase from irrigation canal) if runoff conditions have not provided same by November 1 of each year.The impoundments should remain flooded until at least March 1 each year to provide habitat for waterfowl during the spring migration. A slow annual drawdown (over a 2-4 week period) at this time will allow revegetation of valuable seed producing annual moist soil plants. If inundation of the impoundments does not interfere with spring/summer land use operations, annual drawdown could be postponed as late as June 1. Late season drawdowns should be staggered and rotated annually for all units between the months of May and June. This type of late season drawdown will provide valuable brooding habitat for nesting mottled ducks and whistling ducks, encourage plant/habitat diversity, and reduce mowing expenses.In some years (every 3-4), it may be necessary to lightly disc, shred, or burn the impoundment if undesirable plants (eg. sena bean, and cattail) become dominant. This soil disturbance will set back plant succession and encourage the production of more desirable waterfowl foods. All flashboards should be installed after these moist soil plants have germinated and become firmly established (typically by November 1).10 If vegetation within the project site is overly dense, it may be necessary to create several open areas by shredding, rolling, or lightly discing the vegetation. This will provide open water areas to allow waterfowl access into the impoundments. However, if waterfowl will be hunted on the sites it is advised to consult current federal "baiting" regulations for compliance before the habitat is mechanically manipulated. Undesirable woody vegetation and rank wetland plants such as cattails should be controlled throughout the site. Mowing of woody vegetation on levees and within the impoundments should prevent more difficult control problems with larger trees and shrubs in the future.Impoundments with newly constructed levees should not be filled to capacity immediately following completion. The-slopes of these levees need to settle and vegetate to resist shoreline erosion. At no time should impoundments be held above design capacity which provides at least 12" of freeboard to the tops of levees.The Project Initiator and/or other Texas Prairie Wetland Project representatives shall periodically provide technical assistance for the beneficial management of the wetland habitat developed under this agreement. The Project Initiator is Ed Ritter (Texas Project Biologist for Ducks Unlimited Inc.) in Rosenberg, Texas;Phone: (713)341-7968. Ii

PRAIRIE WETLAND PROJECT GULF COAST JOINT VENTURE in N 'SOUTH TEXAS PROJECT Siphon Kv Uf -18A rs--- ---Siphon .iho 46 Untc46rres." "N------------.--

L'- , Nu l I ti-AQ-9. ENSR Corporation. 2008. Ecological Survey Report-Habitat Assessment, Units 3 and 4 Licensing Project. Prepared for STP Nuclear Operating Company. Wadsworth, TX: ENSR. 34 p. [In Aquatic Ecology section of STP NRC Environmental Audit Binder] 4q- ýEcological Survey Report -Habitat Assessment Unit 3 and 4 Licensing Project South Texas Project Electric Generating Station, Wadsworth, Texas ENSR Corporation June 2008 ENSR AECOM I Prepared for: STP Nuclear Operating Company Wadsworth, Texas Ecological Survey Report -Habitat Assessment Unit 3 and 4 Licensing Project South Texas Project Electric Generating Station, Wadsworth, Texas Prepared By Kurtis K. Schlicht Reviewed By Robert D. Carpenter ENSR Corporation June 2008 ENSR AECOM L Contents 1.0 Intro d u ctio n ............................................................................................................................................... 1-1 1.1 P roject and S ite D escription ........................................................................................................... 1-1 2.0 M ethod s ..................................................................................................................................................... 2-1 3 .0 R esu lts ....................................................................................................................................................... 3-1 3 .1 H a b ita t D e scriptio n s ........................................................................................................................ 3 -1 3 .2 B ird D a ta .......................................................................................................................................... 3 -3 3 .3 H a b ita t U s e ...................................................................................................................................... 3 -4 4.0 Summary and Conclusions .................................................................................................................... 4-1 5.0 R eferences ................................................................................................................................................ 5-1 5 .1 R efe rence D ocum ents .................................................................................................................... 5-1 List of Tables Table 1 Habitat/Land use assemblages at STP Nuclear Operating Company's South Texas Electric Generating Station, Matagorda County, Texas.Table 2 Summary of bird species by habitat type associated with the Mad Island Christmas Bird Counts at the STP Nuclear Operating Company's South Texas Project Electric Generating Station, 1993-2007. Table 3 Summary of relative important species and their associated habitats at the STP Nuclear Operating Company's South Texas Project Electric Generating Station.List of Figures Figure 1 Project Location Map.Figure 2 STP Nuclear Operating Company site plan layout.Figure 3 Habitat and Land Use Map.Figure 4 Total number of species documented annually in the STP Christmas Bird Count Surveys 1993-2007. Figure 5 Total number of birds documented in the STP Christmas Bird Count Surveys 1993-2007. Figure 6 Percent composition of bird species comprising >1% in the STP Christmas Bird Count, 1993-2007. Figure 7 Total number of waterfowl documented in the STP Christmas Bird Count Surveys 1993-2007. Figure 8 Percent composition of waterfowl species comprising > 1% in the STP Christmas Bird Count Surveys 1993-2007. Habitat Report Document June 2008

1.0 Introduction

This report summarizes the results of ENSR's habitat assessment completed for STP Nuclear Operating Company's (STPNOC) proposed Unit 3 and 4 Combined Operating License (COL) application. The proposed Project is located at the South Texas Project Electric Generating Station (STPEGS) in Matagorda County, Texas, Figure 1. The scope of work included conducting an analysis of current and historic mapping and biological data using Geographic Information System (GIS) data sets and data collected during onsite wetland delineations surveys, threatened and endangered species surveys, and routine site visits. In addition to the habitat assessment, this report provides a summary of bird species and relative important species (RIS)associated with the documented habitats within the STPEGS property. Data in this report will be used to supplement information in the Environmental Report for the COL application.

1.1 Project

and Site Description STPNOC is currently proposing to license, construct, and operate two additional generating units (Units 3 and 4) at its STPEGS facility located on FM 521 approximately 8 miles west of Wadsworth, Texas. The STPEGS property currently consists of approximately 12,220 acres of land located adjacent to the Colorado River, Figure 1. The geographical and ecological region associated with the facility is referred to as the coastal plains, which historically was comprised of tall grass prairies, open grasslands, and bottomland habitat areas near creeks and rivers. The current setting and habitat of the region consists almost entirely of agricultural farmland, pastureland, and bottomlands. The plant property is currently occupied by approximately 7,346 acres of existing plant facilities which include an approximate 7,000-acre Main Cooling Reservoir (MCR), 300 acres for the existing Units 1 and 2 and associated buildings and warehouses, and 46 acres for the Essential Cooling Pond. The remaining property (approximately 4,874 acres) is comprised of undeveloped lands that include bottomland habitat, leased agriculture/pastureland, managed wetlands, scrub shrub and mix habitats.A detailed description of habitat areas is provided in Section 3 of this report.The proposed construction of Units 3 and 4 will require the additional use of approximately 244 acres of land.Figure 2 provides an overview of the proposed project layout for each of the following components. The current project scope includes the following construction and operating activities for Units 3 and 4:* Construction and operation of Units 3 and 4;* Construction of a new switchyard;

• Clearing and maintenance of additional storage and materials laydown yards;* Clearing and maintenance of a new heavy haul road;* Construction of a radioactive waste storage building;* Relocation and construction of the existing drainage ditch;* Construction of a concrete batch plant;* Clearing and maintenance of materials spoil area;* Construction of a new Cooling Water Intake Structure (CWIS) and discharge system; and* Clearing and maintenance of additional contractor and craft parking areas for the construction of Units 3 and 4.Habitat Report Document 1-1 June 2008

2.0 Methods

The following section describes methods implemented by ENSR's biologists for completing the habitat assessment and summarization of bird species and relatively important species (RIS) at STPEGS. Data in this report were compiled using available GIS data, data collected during onsite wetland delineations, threatened and endangered species surveys, Christmas Bird Counts, and routine site visits from 2006 through 2008. GIS data sets were compiled using available data from the following sources: " U.S. Geological Survey (USGS) 7.5-minute Topographic Quadrangle Maps;* U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI) Maps;" Aerial Photographs (1974 and 2004);* Natural Resources Conservation Service (NRCS) Soil Surveys for Matagorda County, Texas; and* Texas General Land Office (GLO) Land Use Classification Data.GIS data were then incorporated into ArcGIS programs to create a geo-referenced base map for the property, Acreages were calculated by assigning GIS polygons to each of the different habitats by interpreting changes in vegetation and land use. These calculations are considered approximations or estimates of the acreage based on aerial coverage of each polygon. Identified features in the GIS data set were then field verified during routine site visits to document actual habitat types.Field surveys were conducted in conjunction with the wetland delineations and threatened and endangered species surveys which occurred in December 2006, February 2007, and April 2008. Pedestrian surveys were performed by walking transects spaced 200 ft apart in areas where vegetative cover had distinct changes and 500 feet apart in areas where vegetation remained similar. Data from these surveys were compiled into individual reports and submitted to the Habitat Assessment Branch of the Texas Parks and Wildlife Department (TPWD) in March 2007 and then to the TPWD Resource Protection and U.S. Fish and Wildlife Service in December of 2007 (ENSR 2007). Habitats documented during these surveys were used to develop a habitat map for the STPNOC property, Figure 3. Upon completion of the habitat map, areas were further surveyed by ENSR, NRG biologists, and a biologist from the Natural Resource Conservation Service (NRCS)to verify vegetative communities within the construction areas of the project.Data from the STP Section of the Audubon Society Mad Island Christmas Bird Counts, 1993-2007, were used for the bird evaluation. Data were summarized on an annual basis to determine yearly trends in species richness and relative abundance. Bird counts at the STPEGS facility were collected from multiple locations associated with each of the different habitats. Documented species were grouped based on their known habitat assemblages and then categorized according to those habitats documented at STPEGS to identify key areas associated with the project.A qualitative assessment of wildlife species at the STPEGS facility was completed by documenting wildlife species during multiple field activities conducted from 2006 to 2007(ENSR 2007). Emphasis was placed on documenting relative important species and their known habitats. Relative important species include those species that belong to any of the following groups:* Those species listed as state or federal threatened and endangered species;* Species proposed for listing as a threatened and endangered or is a candidate for listing;* Commercially or recreationally valuable species;" Species that are critical to the structure and function of local terrestrial ecosystems; and Habitat Report Document 2-1 June 2008

• Species that may serve as biological indicators to monitor the effects of the proposed facilities on the terrestrial environment.

During the initial licensing phase for Units 1 and 2 (1974-1987) species considered as "important" included the whitetail deer, American alligator, bald eagle, and all waterfowl. Habitat Report Document/-4 June 2008

3.0 Results

The results of the habitat assessment for the proposed Unit 3 and 4 licensing project are presented in the following sections. Descriptions of habitat types and vegetation communities are discussed. Table 1 provides a summary of the habitat types, vegetation communities, and acreages for each identified community within the STPEGS facility and provides an overview of the habitats that will potentially be impacted by the project.3.1 Habitat Descriptions Fourteen habitats types were documented within the STPEGS property. Figure 3 illustrates the locations of each of the identified habitats and provides a summary of the potential habitat impacts. The documented habitat types include: 1. Main Cooling Reservoir (MCR);2. Bottomland;

3. Scrub Shrub;4. Maintained and disturbed areas;5. Forested communities;

6. Forested/mixed pastureland/leased land;7. Mixed grass communities;

8. Wetlands;9. Existing facilities;

10. Unit 1 & 2 construction spoil area;11. Essential Cooling Pond (ECP);12. Reservoir levee system;13. Dredge materials disposal area; and 14. Leased agricultural land.Main Cooling Reservoir and Essential Cooling Pond The MCR is an approximately 7,000-acre reservoir originally designed to provide closed cycle cooling for four generating units. Make-up water for the reservoir is pumped from the Reservoir Make-up Pumping Facility (RMPF) approximately 1 mile from the Colorado River to the MCR. The MCR is a perched system constructed of earthen levees covered by grasses on the outside slopes and sandcrete on the inside slopes. There are a series of levees inside the MCR which lengthen the flow path, providing extended circulation and cooling of the water. The MCR is designed to handle a capacity of 49 ft MSL; however, it is currently maintained at a water level .of 47 ft MSL. Water depth in the MCR averages 25 ft with the exception of a few deep holes that reach 35 ft. These deep holes are associated with soil borrow areas used in the construction of the levees. Salinity in the reservoir remains constant at approximately 1.6 ppt. Fishery studies conducted on the MCR indicate that both freshwater species and saltwater species are present (ENSR MS). There is little to no natural habitat within the MCR and any areas considered habitat are confined to the steep levee shorelines and the areas associated with the cooling water intake structure.

Habitat Report Document 3-1 June 2008 The Essential Cooling Pond (ECP) is a 46-acre perched pond designed to supply water to cool crucial plant components. The pond is constructed of earthen levees covered by grasses on the outside slopes and sandcrete on the inside slopes providing a hard substrate surface. The ECP is considered openwater habitat and contains no natural structure. A fish study completed in 2002 indicated that the ECP supports a significant population of sheepshead minnows, mosquito fish, and sailfin mollies. No large aquatic organisms such as sunfishes or catfishes were documented. The MCR and ECP consist of both external and internal levees that are constructed of earthen materials cover by sandcrete on the inside slopes and grasses on the outside slopes. The internal levees for both areas are covered entirely by sandcrete materials. The footprint of all the levees combined comprises approximately 759 acres. The grasses on the outside of the levees consist primarily of angleton bluestem, King Ranch bluestem, dallisgrass, Bermuda grass, and perennial rye grass. These are mowed on a routine basis and provide limited habitat to wildlife. The shoreline around the MCR and ECP provides roosting and nesting habitat for a variety of colonial shore birds.Bottomland and Forested Habitats Approximately 1,176 acres of bottomland forest habitat exists along the eastern boundary of the STPEGS property. This habitat borders the Colorado River and is comprised of a mixture of trees, shrubs, and grasses.The dominant tree species include sugarberry/hackberry, pecan, cottonwood, water oak, live oak, American elm, willow, and Chinese tallow. Shrub species include yaupon, Chinese privet, McCartney Rose, and American beautyberry. Grasses include woodoats, carpet grass, crab grass, broomsedge, and Bermuda grass. Vines include greenbriar, poison ivy, and southern dewberry.Three important components of the STPEGS facility are located within the bottomland area. These include the RMPF, the dredge materials disposal area, and the spillway/blowdown area. The RMPF is located in the northern portion of the bottomland area and occupies approximately 6 acres. The dredge materials disposal area is a 133 acre area located just south of the RMPF. The area is used for the placement of dredged materials from the RMPF and barge slip. The spillway/blowdown area consists of an approximate 1 mile long, man-made canal that is designed to provide emergency release of water from the MCR to the river.Additional forested communities are located on the east side of the property north of the heavy haul road and on the southeast section of the property between the MCR spillway and the Colorado River. The area north of the heavy haul road includes 53 acres of forested habitat that includes live oak, sugarberry/hackberry, and yaupon. This area surrounds Kelly Lake and extends north to FM 521. Just east of this section is approximately 91 acres of forested/mixed pastureland habitat that is currently leased for cattle grazing. Trees in this area are comprised predominantly of sugarberry/hackberry with a few live oaks mixed throughout. Grasses in this area include Bermuda grass, carpet grass, crabgrass, smut grass, dallisgrass, and paspalum spp. The forested area near the spillway is a component of the bottomland habitat and contains similar species as described in the bottomland habitat.Scrub Shrub Scrub shrub habitats dominate the western and northern portions of the property totaling 976 acres. The scrub shrub communities are comprised mostly of sea myrtle, goldenrod, ragweed, aster, southern dewberry, peppervine, sumpweed, and in some areas McCartney rose. Very few grass species are included in this habitat primarily due to the dense coverage of the shrub vegetation. Grasses that are present include broomsedge, bushy bluestem, paspalum spp., and bristle grass.Mixed Grasses Approximately 486 acres of the STPEGS property are comprised of predominantly mixed grass communities. These areas are located along the southern boundary of the MCR, north of the essential cooling pond (ECP), and two areas within the bottomland habitat. Grasses in all three areas are comprised predominately of angleton bluestem, King Ranch bluestem, bristle grass, brownseed paspalum, vasey grass, smut grass, and Bermuda grass. Part of the area north of the ECP includes several small disturbed areas with vegetation that includes goldenrod, aster, ragweed, and sumpweed.Habitat Report Document 3-2 June 2008 Wetlands Wetland habitats located within the STPEGS property include Kelly Lake (34 acres), the managed wetlands area (110 acres), and delineated wetlands (11 acres). Kelly Lake is located on the northeast portion of the property and consists of open water areas surrounded by fringing wetland plants including cattails and arrowhead. The managed wetland area is located on the northern portion of the property along FM 521. This area was developed in a partnership between STPNOC and Ducks Unlimited and various other agencies to provide prairie wetland habitat for waterfowl and coastal wading birds. Delineated wetlands include 20 small wetlands located in various locations around the property. Sixteen of the wetlands are less than 0.5 acres in size while the other four wetlands range from 0.63 acres up to 3.78 acres in size. None of the identified wetlands are associated with or have a significant nexus to waters of the U.S. Dominant wetland vegetation associated with these wetlands includes: spikerush, cattail, water hyssop, knotgrass, bushy bluestem, sea myrtle, and rattlebox. Existing Facilities Approximately 300 acres of the STPEGS property is associated with the existing plant facilities for Units 1 and 2. These facilities include the generating units, warehouses, storage yards, switchyard, intake structure, Nuclear Support Center (NSC) building and parking areas. Most of these areas are comprised of paved and crushed rock surface areas that have some mixed grasses growing sporadically throughout the area. An additional component of the existing facilities includes the 41 acre Unit 1 and 2 construction spoil area located on the west side of the property. This area was used during the initial construction phase for stockpiling soils.The area is not currently being used and has established vegetative cover that includes grasses such as angleton bluestem, bushy bluestem, dallisgrass, and broomsedge. Other species present in the construction spoil area include sea myrtle, sugarberry/hackberry, peppervine, and southern dewberry.Maintained and Disturbed Areas Maintained and disturbed habitats are associated with portions of the STPEGS that were used initially in the construction of Units I and 2. These areas consist of approximately 468 acres of land that are routinely mowed and the vegetation layers are kept less than 6 inches in height. Species include a dallisgrass, brownseed paspalum, carpet grass, Bermuda grass, crabgrass, King Ranch bluestem, plantain, muhly grass, poa, broomsedge, bushy bluestem, angleton bluestem, sumpweed, and clover.Leased Agricultural Land Approximately 536 acres of the STPEGS property is leased out for agricultural purposes. These lands are located north and west of FM 521 and are routinely used for growing cotton and soybean. Periodically the lands are changed from agricultural use over to cattle grazing. Habitat within these areas will vary during the year due to the type of crop and frequency of growth and planting. The areas will provide vegetative cover during growing season and open field habitat during the non-growing seasons.3.2 Bird Data The annual Audubon Society Christmas Bird Count (CBC) is a volunteer effort conducted to take a census of birds across the western hemisphere. The Mad Island CBC is a single day event occurring between mid-December and early January, over a 15 mile area that includes Mad Island Marsh Preserve and also includes the STPEGS facility. CBC data for STP has been collected over a 15 year period from 1993 through 2007.Species richness during this time period has remained relatively stable averaging 122 species and ranging from a low of 60 species in 1993 and a high of 142 in 2006, Figure 4. The low in 1993 was followed by an increase to a 112 species in 1994 then followed by stable trend for the remainder of the survey years. Total number of birds surveyed varies significantly from year to year, Figure 5. The lowest total of birds counted was 1,274 in 1993 and the highest number of total birds was 8,630,645 in 2003. Number of individuals per species also varies significantly from year to year and ranges from 0 to as many as 700,000 for species such as the red-winged black bird and the brown-headed cowbird. Red-winged black birds and the brown-headed cowbirds comprise 47% and 46% of the overall total birds counted for the entire period, Figure 6. These two species also account for the greatest variation in total number of birds for each of the years counted. For Habitat Report Document 3-3 June 2008 example, 0 brown-headed cowbirds were counted in 1999, 2000, and 2001, twelve were counted in 2002, and W then a significant increase was documented in 2003, when a total count of 4,300,000 was recorded. A similar trend occurred for the red-winged blackbird, where low counts were recorded in 2000 at 1,950 birds, increasing to a high of 4,300,270 birds in 2003.A total of 28 waterfowl species have been documented annually during the Mad Island CBC. Annual counts for waterfowl are highly variable with numbers ranging from a low of 442 birds in 1998 to a high of 19,906 in 2004, Figure 7. Snow geese demonstrated the greatest variability from year to for all the species documented. The Snow goose, Cackling goose, and the Greater White-fronted goose represent the dominant species for all years counted, Figure 8.3.3 Habitat Use Relatively important species and birds species documented during the CBC were grouped based on their known habitat associations and observations of these species on the STPEGS property. Five habitat groups were designated including openwater, woodland, grasslands, shoreline, and scrub shrub. Table 2 provides a summary of those species found in each of the groups. Many species will be included in more than one group due to the overlap in habitat use. Openwater species include waterfowl such as ducks, geese, pelicans, and cormorants. Woodland species include those that commonly occur in habitats associated with forest communities such as the woodpeckers, flycatchers, vireos, bluejays, and wrens. Grasslands birds include those species that commonly occur in open grassland areas such as the bobwhite quail, dove, vultures, and many of the hawk species. Shoreline birds include species such as plovers, sandpipers, killdeer, stilts, terns, and egrets. Scrub shrub birds include the groove-billed ani and the pyrrhuloxia. Other common species listed from some of the other groups and associated with the scrub shrub include: the sparrows, wrens, dove, grackle, and cowbirds. The largest numbers of species are associated with woodlands and openwater habitats.Relative important species evaluated during this assessment included those species previously identified during the initial licensing phase as well as those species considered to be commercially or recreationally important. Table 3 provides a summary of these species and their associated habitats. Species considered relative important species based on their threatened and endangered or listed status were addressed as part of the threatened and endangered species review and included in a separate report (ENSR 2007).0 Habitat Report Document 3-4 June 2008

4.0 Summary

and Conclusions This document provides the results of ENSR's desktop review and field investigation for the proposed STPNOC licensing project located in Matagorda County, Texas. A total of fourteen habitat types comprising approximately 12,220 acres of land were identified and verified within the STPEGS property. The largest component of habitat consists of the 7,000-acre Main Cooling Reservoir which provides aquatic habitat for a variety of freshwater and saltwater species, as well as nesting and feeding habitat for waterfowl and shore birds. The 1,176 acres of bottomlands provides the most diverse habitat located within the plant property.This area supports a variety of wildlife including whitetail deer, wild hogs, squirrels, raccoons, song birds, and migratory birds. The scrub shrub habitat, maintained and disturbed areas, and the construction spoil area are considered low quality habitats. Vegetative communities present in each of these areas are comprised mostly of weeds or invasive species that have characteristically low food and habitat values due to their lack of seeds and fruits and thick spatial coverage. Approximately 34 acres of the MCR (including the levee system) and 87.5 acres of the scrub shrub habitat will be impacted, Figure 3.The forested communities, forested/mixed pastureland, and mixed grass lands provide a moderate to high quality habitat. These areas provide suitable food and cover essential for sustaining wildlife populations. The forested and forested/mixed pastureland areas will not be impacted by the proposed project; however, approximately 7 acres of the mixed grass communities will be impacted.Wetland communities within the STPEGS property are considered low to high quality habitats. The managed prairie wetlands and the Kelly Lake wetland are considered high quality wetlands based on the diversity of plant species present and the quantity of bird species and other wildlife that utilize the areas. The remaining wetlands are considered to be low quality wetlands based on the lack of plant species diversity, location of wetlands within the overall habitat setting, and lack of extensive wetland functions. In addition, these wetlands do not appear to support any aquatic life. One small palustrine wetland totaling 0.17 acres located near where Unit 3 will be located will be impacted by the project. The remaining 19 wetlands will not be impacted.The Essential Cooling Pond provides low aquatic habitat value, There is no natural habitat cover in the pond and aquatic life is limited to a few species of small fish including sheepshead minnows, mosquitofish, and sailfin mollies. However, the hard substrate surrounding the pond does provide good roosting habitat for shoreline birds. No impacts to the ECP are proposed.Habitats within the existing facilities and the maintained and disturbed areas are considered low quality based on the limited food and cover. Additionally, the daily operational activities and continued disturbances within these areas limits the amount of wildlife that are present. Some of the abandoned parking or storage areas covered with gravel do provide nesting habitats for bird species such as the killdeer and roosting habitats for other shore birds. Approximately 42 acres of the existing facilities and 73 acres of the maintained and disturbed areas will be impacted during construction of Units 3 and 4.The leased agricultural lands provide a low quality habitat based on the overall use of the land. These lands are routinely altered, and depending on the type of crop, may only provide a resting area or temporary cover for wildlife. No impacts from construction or operation of Units 3 and 4 will occur to the leased agricultural lands.Bird data from the Mad Island Christmas Bird Counts indicate that more than 140 species of birds totaling as many as 8.6 million individuals are documented in a given year at the STPEGS facility. These birds are associated primarily with five different habitats including openwater, woodlands, shoreline, scrub shrub, and grasslands. The largest numbers of birds are associated with woodlands and openwater habitats. There will be no impacts to the woodland habitat and a 29 acre impact to the openwater habitat. The impact to the openwater habitat will be associated with the construction and operation of the new Cooling Water Intake Habitat Report Document 4-1 June 2008 Structure for Unit 3 and 4 that will also include an approximate 5 acre loss of shoreline habitat. The remaining impacts will be temporary disturbances associated with noise and moving equipment. Relatively important species and their associated habitats will have minimal to no impacts associated with the construction or operation of Units 3 and 4. Of the seven habitats being impacted only the scrub shrub, MCR, and mixed grass communities support any of the RIS. Impacts to RIS will be through habitat loss and not from direct impacts. It is anticipated that displacement of these species into other areas of the STPEGS facility, as well as to adjacent properties, will occur resulting in minimal impacts to RIS.STPNOC is proposing to license, construct, and operate two new electric generating units (Units 3 and 4) at the STPEGS facility. Construction of Units 3 and 4 and the associated plant features will impact seven of the fourteen identified types of habitats totaling approximately 244 acres. These habitats include existing facilities, maintained and disturbed areas, scrub shrub habitats, mixed grass communities, the MCR, wetlands, and the reservoir levee system (Other). All seven habitats are considered to be of low to moderate quality based on their value as a food source for wildlife, their dense vegetative cover prohibiting adequate space for wildlife movement, and vegetative cover only providing suitable nesting habitat for a small variety of bird species.Based on these facts, impacts to wildlife are anticipated to be small.Habitat Report Document 4-2 June 2008

5.0 References

5.1 Reference

Documents Conant, R. and J.T. Collins. A Field Guide to Reptiles and Amphibians of Eastern and Central North America.Third Edition, Expanded.ENSR. 2007. Ecological Survey Report -Threatened and Endangered Species, Unit 3 and 4 Licensing Project.ENSR. 2008. Preliminary Wetland Delineation Report Unit 3 and 4 Licensing Project.Gould, Frank. W. 2002. Common Texas Grasses, An Illustrated Guide. Texas A&M University Press.Griggs, Jack. 1997. American Bird Conservancy's field guide to all the birds of North America: a revolutionary system based on feeding behaviors and field-recognizable features. Library of Congress Cataloging-in-Publication Data. First Edition.Hatch, S. L. and J. Pluhar. 1999. Texas Range Plants. Texas A&M University Press College Station.Little, E.L. 2000. National Audubon Society Field Guide to North American Trees Eastern Region.Simpson, B.J. 1999. A Field Guide to Texas Trees. Gulf Publishing Field Guide Series.Stutzenbaker, Charles. D. 1999. Aquatic and Wetland Plants of the Western Gulf Coast. Texas Parks and Wildlife Press.Texas Parks and Wildlife Department. 2006. Annotated County List of Endangered, Threatened, and Rare Species, Matagorda County, Texas.Tveten, J. and G. Tveten. 1993. Wildflowers of Houston & Southeast Texas. University of Texas Press, Austin.United States Department of Agriculture (USDA) NRCS. 1981. Soil Survey of Matagorda County, TX.United States Fish and Wildlife Service (USFWS). 2005. List of Threatened and Endangered Species, Brazoria County, Texas, 2005. http://ifw2es.fws.gov/endangeredspecies/lists/ListSpecies.cfm United States Fish and Wildlife Service. 1987 & 1996. National List of Plant Species that Occur in Wetlands-Region 6-South Plains.United States Geological Survey (USGS) 7.5-Minute Topographic Quadrangle Maps. Juliff, TX 1974;Rosharon, TX 1974; Angleton, TX 1979; Danbury, TX 1974; and Oyster Creek, TX 1974.Habitat Report Document June 2008 Tables Habitat Report Document June 2008 Table 1. -Habitat/Land Use Assemblages STP Nuclear Operating Company's Generatina Station.South Texas Project Electric Habitat Habitat Description* Acreage Area Of Percentage of Comment (Approximate) Impact (Acres) Impact**Bottomland Forest communities comprised The bottomland area of sugarberry/hackberry, was set aside during the cottonwood, pecan, Chinese initial licensing of STP to Tallow, yaupon, greenbriar, 1,176 0 0 preserve overall habitat.American beautyberry, No impacts anticipated. Chasmanthium spp., Carex spp.Units 1 & 2 Area covered mostly by Construction Spoil Area Construction Spoil grasses -Angleton bluestem, was used for spoil Area King Ranch bluestem, storage during the vaseygrass, and Johnson 41 0 0 original construction of grass. Other vegetation Units 1 & 2. No longer includes baccharis, southern used.dewberry and peppervine. Essential Cooling Open freshwater pond. The ECP provides Pond (ECP) Concrete lined pond with no cooling water for crucial aquatic vegetation. 46 0 0 components for Units 1 and 2. No impacts anticipated. Existing Facilities -Most of these areas are Units 3&4 will be located Buildings, Units 1&2, significantly disturbed and/or in an area already Switchyard, NSC, maintained. Small areas of disturbed by previous Warehouses, old vegetation exist in isolated construction. Some laydown yards areas. These include a variety additional modifications of grass species -Paspalum 300 42 14.0 will be made to the spp., Angleton bluestem, King existing infrastructure for Ranch bluestem, Bermuda new laydown, grass as well as weeds warehouses, parking including ragweed, sow thistle, etc.goldenrod, and clovers.1-I Table 1. -Habitat/Land Use Assemblages STP Nuclear Operating Company's Generating Station.South Texas Project Electric Habitat Habitat Description* Acreage Area Of Percentage of Comment (Approximate) Impact (Acres) Impact**Forested Communities This area is comprised of live Area is adjacent to the oak, pecan, and mixed stands existing Kelly Lake.of sugarberry/hackberyy. Area may be subject to Scrub species includes mostly temporary noise and yaupon and privet. 53 0 0 dust from heavy equipment. No significant construction or operational impacts are anticipated. Forested/Mixed This area is comprised of open Area is adjacent to the Pastureland (leased grassland areas intermixed existing heavy haul lands) with forested communities. road. Area may be Grasses include: Paspalum subject to temporary spp., Bermuda grass, St. noise and dust from Augustine, rattail smutgrass, 91 0 0 heavy equipment. No broomsedge, bushy bluestem, significant construction and Angleton bluestem. or operational impacts Forested species include are anticipated. sugarberry/hackberry, live oak, and yaupon.Leased Agricultural Land is currently used for No plans to expand lands cattle pasture and various these areas. No agricultural practices. 536 0 0 impacts anticipated. Main Cooling Open water habitat. Average The shoreline inside the Reservoir (MCR) depth is 25 ft. Water is mostly reservoir provides fresh to brackish (salinity nesting and feeding averages 1.6 ppt). No aquatic habitat for a variety of vegetation present. 7,000 29 0.4 shore birds species.Water level in the MCR is designed for 49 ft MSL but is currently at 47 ft MSL. Table 1. -Habitat/Land Use Assemblages STP Nuclear Operating Company's South Texas Project Electric Generating Station.Habitat Habitat Description* Acreage Area Of Percentage of Comment (Approximate) Impact (Acres) Impact*'Maintained and Most of these areas are Portions of these areas Disturbed Areas significantly disturbed and/or will be impacted by the maintained. Vegetation is construction of the new comprised of grasses and units, east laydown weeds -Paspalum spp., area, and crew and Angleton bluestem, King 468 74 16.0 contractor parking Ranch bluestem, broomsedge, areas.bushy bluestem, Poa, burclover, geranium, sow thistle, southern dewberry, ragweed spp.Mixed Grass Areas are comprised of a Areas are periodically Communities variety of vegetation mowed. The area south dominated by grasses -of the MCR will not be Paspalum spp., Angleton impacted. Areas north bluestem, King Ranch 486 1.0 of the ECP will be used bluestem, broomsedge, and for a new spoil area.bushy bluestem. Other species include goldenrod, sumpweed, aster spp., and wild sunflower. Scrub Shrub Area is comprised of mostly Portions of area will be Communities Baccharis dominated shrub impacted by relocation habitat. Southern dewberry of the stormwater ditch, and peppervine comprise a construction of heavy significant amount of cover haul road, switch yard, below the shrub overstory. 976 87 9.0 and west laydown area.Additional species include golden rod, sump weed, and ragweed. Few grasses are present -broomsedge, bushy bluestem and Paspalum spp.1-3 Table 1. -Habitat/Land Use Assemblages STP Nuclear Operating Company's South Texas Project Electric Generating Station.Habitat Habitat Description* Acreage Area Of Percentage of Comment (Approximate) Impact (Acres) Impact**Wetlands Wetland communities are 155 Total No construction or broken down by 3 different Acreage operational impacts will areas -* Kelly occur to Kelly Lake or* Kelly Lake Lake -Managed Wetlands.(Stream/Pond 34; Approximately 0.17 dominated by

• Managed acres of impact will cattails);

Wetlands 0.17 0.1 occur to a wetland near" Managed Wetlands -110; where Units 3&4 will be (prairie wetlands), ° Other- constructed. and 11* Other (small isolated wetlands with mixed grasses, rushes and sedges).Other -Reservoir Levees are comprised of Small area of impact levee systems (MCR earthen materials covered by associated with the and ECP). grasses on outside and construction of the new sandcrete on the inside. 759 5 0.6 CWIS which will be built on the central dike adjacent to the existing CWIS.Area is located in the Area is only utilized bottomland habitat along the when maintenance Colorado River. Vegetation is dredging of the River Dredge Materials comprised of mixed grasses Make-up Pumping Dredge Atea (bushy bluestem and 133 0 0 Facility and/or barge slip Disposal Area broomsedge), rattlebox, and takes place. STP has a stands of cattail. USACE dredge maintenance permit for these activities. TOTALS 12,220 244 (2.0)...*Habitat descriptions are derived from on-site pedestrian surveys.** Percent Impacts are based on potential impacts for each habitat/land use type.***Value represents total percentage impact for entire property. Values representing individual percentage impacts in the table are not cumulative. 1-4 Table 2. Summary of Bird Species by Habitat Type Associated with the Christmas Bird Counts at the STP Nuclear Operating Company's South Texas Project Electric Generating Station.Habitat Type Species Waterfowl Black-bellied Whistling-Duck Greater White-fronted Goose Snow Goose Ross' Goose Cackling Goose Canada Goose Wood Duck Gadwall Am. Wigeon Mallard Mottled Duck Blue-winged Teal Cinnamon Teal N. Shoveler N. Pintail Green-winged Teal Canvasback Redhead Ring-necked Duck Greater Scaup Lesser Scaup Surf Scoter Buffiehead Common Goldeneye Hooded Merganser Com. Merganser Red-breaster Merganser Ruddy Duck Common Loon Least Grebe Pied-billed Grebe Horned Grebe Eared Grebe Am. White Pelican Brown Pelican Neotropic Cormorant Double-crested Cormorant Anhinga Com. Moorhen Am. Coot 2-1 Table 2. Continued. Habitat Type Species Woodland Golden-fronted Woodpecker Red-bellied Woodpecker Yellow-bellied Sapsucker Ladder-backed Woodpecker Downy Woodpecker Hairy Woodpecker N. (Yel.-sh.) Flicker Pileated Woodpecker Am. Woodcock Least Flycatcher Traill's Flycatcher Empidonax, sp.E. Phoebe Vermilion Flycatcher Ash-throated Flycatcher Brown-crested Flycatcher Couch's Kingbird Thick-billed Kingbird W. Kingbird Loggerhead Shrike White-eyed Vireo Blue-headed Vireo Red-eyed Vireo Blue Jay Am. Crow Horned Lark Tree Swallow N. Rough-winged Swallow Cave Swallow Barn Swallow Carolina Chickadee Tufted Titmouse Red-breasted Nuthatch Brown Creeper Carolina Wren House Wren Winter Wren Sedge Wren Marsh Wren Golden-crowned Kinglet Ruby-crowned Kinglet Blue-gray Gnatcatcher E. Bluebird Hermit Thrush 2-2 Table 2. Continued. Habitat Type Woodland Species Wood Thrush Am. Robin N. Mockingbird Brown Thrasher*Eur. Starling Am. Pipit Sprague's Pipit Cedar Waxwing Tennessee Warbler Orange-crowned Warbler N. parula Nashville Warbler Yellow-r. (Myrtle) Warbler Yellow-throated Warbler Pine Warbler Palm Warbler Black-and-White Warbler Ovenbird Com. Yellowthroat Wilson's Warbler Yellow-breasted Chat Summer Tanager Western Tanager Spotted Towhee Eastern Towhee Chipping Sparrow Field Sparrow Vesper Sparrow Lark Sparrow Savannah Sparrow Grasshopper Sparrow Le Conte's Sparrow Fox Sparrow Song Sparrow Lincoln's Sparrow Swamp Sparrow White-throated Sparrow White-crowned Sparrow Harris' Sparrow Dark-eyed Junco N. Cardinal Pyrrhuloxia Indigo Bunting Painted Bunting Red-winaed Blackbird 2-3 Table 2. Continued. Habitat Type Species Woodland E. Meadowlark Yellow-headed Blackbird Brewer's Blackbird Com. Grackle Boat-tailed Grackle Great-tailed Grackle Bronzed Cowbird Brown-headed Cowbird Bullock's Oriole Baltimore Oriole Am. Goldfinch House Sparrow Grassland N. Bobwhite Rock Dove Eur. Collared Dove White-winged Dove Mourning Dove Inca Dove Com. Ground Dove Black Vulture Turkey Vulture Osprey0 White-tailed Kite Bald Eagle N. Harrier Sharp-shinned Hawk Cooper's Hawk Harris's Hawk Red-shouldered Hawk White-tailed Hawk Red-tailed Hawk Ferruginous Hawk Crested Caracara Am. Kestrel Merlin Peregrine Falcon 2-4 Table 2. Continued. Habitat Type Species Shoreline Black-bellied Plover Semipalmated Plover Piping Plover Killdeer Black-necked Stilt Greater Yellowlegs Lesser Yellowlegs Willet Spotted Sandpiper Ruddy Turnstone Sanderling W. Sandpiper Least Sandpiper Dunlin Stilt Sandpiper Short-billed Dowitcher Long-billed Dowitcher Laughing Gull Franklin's Gull Bonaparte's Gull Ring-billed Gull Herring Gull Gull-billed Tern Caspian Tern Royal Tern Com. Tern Forster's Tern Am. Bittern Least Bittern Great Blue Heron Great Egret Snowy Egret Little Blue Heron Tricolored Heron Reddish Egret Cattle Egret Green Heron Black-crowned Night-Heron Yellow-crowned Night-Heron White Ibis White-faced Ibis Roseate Spoonbill 2-5 Table 2. Continued. Habitat Type Species Shoreline Long-billed Curlew Wilson's Snipe King Rail Virginia Rail Sora Sandhill Crane Scrub Shrub* Groove-billed Ani Pyrrhuloxia

• Most species associated with the grasslands and many of the woodland species will be common to the scrub shrub habitat. Areas are determined based on known habitat use and observation during bird counts.0 2-6 Table 3. Summary of Relative Important Species and their associated habitats at STP Nuclear Operating Company's South Texas Project Electric Generating Station.Wildlife Species Habitat Observed Mostly associated with the scrub shrub Observed on many Whitetail deer and woodland habitats.

Common in the occasions. Species is common throughout the open grassland areas.prety property.Observed infrequently over facility property and over the MCR. Two Bald eagle Mostly associated with woodland habitats. active nests were documented on the lower Colorado River more than 1 mile from the site.Observed frequently in Mostly associated with large wetlands, on-site wetlands (Kelly Americandrainages, ponds, rivers, and lakes. Lake) and drainages. Few numbers observed in the MCR.Bobwhite quail Mostly grassland habitats but common in Observed infrequently. scrub shrub habitat.Observed on many Mostly grassland habitats but common in occasions. Species is Morning Dove scrub shrub habitat. common throughout the property.Mostly associated with open water Observed frequently on Waterfowl habitats such as the MCR, ECP, and lower the MCR and ECP.Colorado River. Common to the area as part of migratory flyway.Rabbits (swamp Mostly associated with grassland and Observed infrequently rabbit, Eastern scrub shrub habitat. during current field cottontail) activities. Squirrels (Eastern None observed during gray squirrel, Eastern Mostly associated with woodland habitats. any of the current field fox squirrel) activities. 3-1 Figures June 2008 Habitat Report Document Project Location Map STPNOC South Texas Project Electric Generating Station Unit 3 and 4 Licensing Project ENSR AECOM Matagorda County, Texas Figure 1 Image Source: Delorme Scale:1:500,000 (1" =7.9 miles)ImageProject

1. 10720-008 oi Site Layout Features Vast Laydown Areas , and Craft Parking areas pol Area IRoad i Waste Storage Buildin iatch Plant/ I~-'-a P. 5oY8dýr3(12.220,,)

STP Nuclear Operating Company Habitat Assessment Matagorda County, Texas 0 00 1: .0o3oo a i.000 2.ooo 3 Qoq-STPNOC ENSR I AECOM Figure 2 June 2008_____________________________________________ .1 ________________________ J I'- Lg.T--l nd m A- Leas AgrIcurfJ Land (536 an)II Bo1la'.nd Hnata (1178. ) Man Cot. RasaR.o- (70O0 N)Urit 1 & 2 Conatn Spol Ail- (41 an) M MaintainedandOlstbe A-,a (4MB 1)0,1091d Mat-aW DrIpod 00.. (133 M) Mixed G-a1s C --,ttn s (4WS an)ExIosing Fa..is (300 .a) 511rb Shrxb Com-1il1, (975ac)Fo-Wla Cotnmu,10e a53 a) Wet.ands (00 .n)FoottaýlM-,od PastlWixndqa.' d ,f da(91 n) S.t Prpery Bondry (12,220a)Matagorda County, Texas 0 201, 41000 0170 STPNOC ENSR l O(Fgure 3 June 2008 160 140 120 ---100 80 E z 60 40_20 --0 --- 1 F -- 7 --- -F Year Figure 4. Total number of species documented annually in the STP Christmas Bird Count Surveys 1993 -2007.STP Nuclear Operating Company Christmas Bird Count Data 0 10000000 9000000 8 -45 .8000000 ... ........ .7000000 .-.. ....6000000 ......:3 E 4000000 .3 000000 3000000 1554998 -1256261 2000000 --- ---- -8155819 1000000 *374601 405352 1 1267 17990 9791 18652 11905 48462 66764 64855 0 Year Figure 5. Total number of birds documented in the STP Christmas Bird Count Surveys 1993- 2007.STP Nuclear Operating Company Christmas Bird Count Data I Brewer's Blackbird 2%F-/Com. Grackle 2%Great-tailed Grackle 2%Brown-headed Cowbird 46%Red-winged Blackbird 48%Figure 6. Percent composition of bird species comprising >1% in the STP Christmas Bird Count, 1993-2007. STP Nuclear Operating Company Christmas Bird Count Data 25000 2 0 0 0 0 -----...... -..15000 --.0 E Z 10000 .... ... .. ..5000 ___0 Year Figure 7. Total number of waterfowl documented in the STP Christmas Bird Count Surveys 1993 -2007.STP Nuclear Operating Company Christmas Bird Count Data Lesser Scaup i=.lU Blue-winged Teal 1%Mottled Duck 1%Snow Goose 63%/i/,/ G~/Green-winged Teal 2%adwall 2% N. Shoveler-3%N. Pintail 6%Greater White-fronted Goose 8%Cackling Goose 12%Figure 8. Percent composition of waterfowl species comprising > 1% in the STP Christmas Bird Count Surveys 1993 -2007.STP Nuclear Operating Company Christmas Bird Count Data WR-1. US Army Corps of Engineers (USACE) Permit No. 10570 (Maintenance dredging of barge slip) (dated November 4, 2005). DEPARTMENT OF THE ARMY GALVESTON DISTRICT, CORPS OF ENGINEERS P. 0. BOX 1229 GALVESTON TX 77553-1229 November 4, 2004 REPLY TO ATTENTION OF: Evaluation Section

SUBJECT:

Permit No. 10570(06); Extension of Time STP Nuclear Operating Company Attn: Ms. S. L. Dannhardt P.O. Box 289 Wadsworth, Texas 77483-0289

Dear Ms. Dannhardt:

Your letter, dated June 24, 2004, requesting to amend Department of the Army Permit 10570 to extend the time to maintenance dredge is approved pursuant to Section 10 of the Rivers and Harbors Act of 1899. Permit No. 10570 was issued on July 20, 1975 and authorized you to dredge a basin and discharge channel, place riprap and construct a wharf, intake pumping station and spillway. Amendment (01) was issued on April 16, 1976 to revise sheet 2 of 7 of the original permit plans. Amendment (02) was issued on August 12, 1976 to revise sheets 3 and 4 of the original permit plans. ,Amendment (03) was issued on October 19, 1978 to extend time to dredge a basin and discharge channel, place riprap and construct a wharf, intake pumping station and spillway to December 31, 1983. Amendment (04) was issued on May 24, 1984 to extend time to maintenance dredge barge slips to December 31, 1994. Amendment (05) was issued to extend time to maintenance dredge until December 31, 2004. The permit site is located in the Colorado River, in the vicinity of River Mile 14.6, approximately 5 miles northwest from Matagorda, in Matagorda County, Texas.All work is to be performed in accordance with the enclosed permitted plans in 3 sheets and the original permit conditions, which remain in full force and effect, with the exception of the time limit for completion. This authorization expires on December 31, 2014. Please note the enclosed Notification of Administrative Appeal Options regarding this authorization. This authorization is based on a approved jurisdictional determination. In addition to the original permit conditions, the following special condition is added to your authorization:

e. The permittee understands and agrees that if future operations by the United States require the removal, relocation or other alteration of the structure or work herein authorized, or if, in the opinion of the Secretary of the Army or his authorized representative, said structure or work' shall cause unreasonable obstruction to the free navigation of the navigable waters, the permittee will be required, upon due notice from the Corps of Engineers to remove, relocate or alter the structural work or obstructions caused thereby, without expense to the United States. No claim shall be made against the United States on account of any such removal or alteration. Please notify the District Engineer, in writing, upon completion of the authorized work. A pre-addressed postcard has been enclosed for this purpose.FOR THE DISTRICT ENGINEER: Janet Thomas Botello Leader, Central Evaluation Unit Enclosures Copies Furnished:

Eighth Coast Guard District, New Orleans, LA U.S. Fish and Wildlife Service, Houston, TX Texas General Land Office, Austin, TX Texas General Land Office, La Porte, TX Northern Area Office, Galveston, TX PERMITTED PLANS 0 2000 4000 FEET SCALE NOTE: MAP BASE IS 71/2' USGS OUADRANGLE SHEErS.GRID BASED ON "TEXAS COORDINATE SYSTEM;OUTH CENTRAL ZONE." ELEVATION ANIO CONTOURS SHOWN ARE IN FEET. DATUM IS MEAN SEA LEVEL.RE FERENCE ELEVATIONS: tMEANJ SEA LEVLL: EL.O-O0 MEAN LOW TIDE: EL. (-)-1.43 ME4,tI LOW WATER: EL. 0.10 ,AT SITE)WEAN HIGH WIATER: EL.1.12 (1,T SIi7)SOUTH TEXAS PROJECT LOCATION MAP Matagorda County, TX STP Nuclear Operating Co.Permit No. 105706a&)Sheet 1 of 3 CENTERLINE -. OF DtTCH-7AHWT-1ED PLANS-N-II I DROP INLET 81 OUTFALL I WITH RIPRA\L..,." I/SOUTH TEXAS PROJEC MAKEUP PUMP STATIQI 81 BARGE SLIP ON THE COLD1AOO RIVER AT RIVER WILE 14.-MATAGORDA COUNTY, To" (As APPUr CATION 1-f STP Nuclear Operating Co.Permit No. 10570ol)Sheet 2 of 3 0 100 20.0 300 7FT'3CALF- "PER-PA1T TED LN EXIS ING GRADE DREGE ........"\0 j/ / " 7 7 f ELEV(-I _ )10 CROSS SECTION BARGE SLIP 1530. -0 ._ tna, -a" S'\JDREDGE Ta ELEV (-) F , 50IQ FEET s C-- Crr 10f 1,,i NOTE: ELEVATION5 3HOWN ARE IN FEET. OATUM S1 IN MEAN SEA LEVEL.SOUTH TEXAS PROJECT CROSS SECTION PUMP STATION& BARGE SLIP M COUNTY, TrXaS Ag' UCLLTl Ut Q STP Nuclear Operating Co.Permit No. 10570 tot Sheet 3 of 3 WR-2. USACE Permit No. SWG- 1992-02707 (Maintenance dredging of intake)(dated July 21, 2009). [STPLR-472] DEPARTMENT OF THE ARMY bcc: Correspondence, N2002 GALVESTON DISTRICT, CORPS OF ENGINEERS TNP. O. BOX 1229 GALVESTON TX 77553-1229 FD-NOC-09020059 July 21, 2009 STI: 32508999 REPLYo PFN: W02 ATTENlnON OF.Evaluation Section

SUBJECT:

Permit No. SWG- 1992-02707; Extension of Time S.L. Dannhardt STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483

Dear Ms. Dannhardt:

Your July 1, 2009, letter to amend Permit No. 14848(04) for an Extension of Time is approved pursuant to Section 10 of the Rivers and Harbors Act of 1899 and Section 404 of the Clean Water Act. Permit No. 14848 was issued on March 17, 1981, and authorized maintenance dredging of an intake pumping station and the use of Dredged Material Placement Area 3B.Amendment (01), issued on December 26, 1985, authorized a 3-year Extension of Time to continue maintenance dredging. Amendment (02), issued March 7, 1989, authorized an Extension of Time to maintenance dredge until December 31, 1999. Amendment (03), issued January 26, 1993, authorized an extension of the dredging area 25 feet waterward into the Colorado River. Amendment (04), issued June 9, 1999, authorized an Extension of Time to maintenance dredge until December 31, 2009. The permit site is located at River Mile 14.6 on the Colorado River, approximately 5 miles north of Matagorda, in Matagorda County, Texas.All work is to be performed in accordance with the enclosed plans in 5 sheets and the original permit conditions, which remain in full force and effect, with the exception of the time limit for completion. This authorization expires on December 31, 2019. The following special conditions remain in full force and effect: a. Prior to performance of hydraulic dredging, the applicant will obtain a 401 Water Quality Certification from the Texas Commission on Environmental Quality for the effluent or return water from authorized dredged material placement areas. The applicant will submit a copy of the certification to the Corps of Engineers prior to performing hydraulic dredging.b. The permittee must coordinate in writing the use of government-owned dredged material placement areas with the Corps of Engineers Galveston District's Northern Area Office, the Navigation Branch and the Operations Division, at least 60 days prior to conducting any and all work in or affecting the disposal area(s) to assure that the work will not conflict with U. S.Government dredging or disposal area management activities. c. The permittee understands and agrees that, if future operations by the United States require the removal, relocation, or other alteration, of the structure or work herein authorized, or if, in the opinion of the Secretary of the Army or his authorized representative, said structure or work shall cause unreasonable obstruction to the free navigation of the navigable waters, the permittee will be required, upon due notice from the Corps of Engineers, to remove, relocate, or alter the structural work or obstructions caused thereby, without expense to the United States. No claim shall be made against the United States on account of any such removal or alteration. Please refer to SWG41992-02707 in all future correspondence regarding this project. Please also notify the District Commander, in writing, upon completion of the authorized work. A pre-addressed postcard has been enclosed for this purpose.FOR THE DISTRICT COMMANDER: lanet Thomas Botello Leader, Central Evaluation Unit Enclosures Copies Furnished: Eighth Coast Guard District, New Orleans, LA Texas General Land Office, Austin, TX Texas General Land Office, La Porte, TX Houston/Galveston Resident Office, Galveston, TX STP Nuclear Operating Co, Figure 2: South Texas Project Site PERMITTED PLANS STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 SWG-1 992-02707 P. 1 of 5 PERMITTED PLANS Cuj a N. -COLORADOJ -* -. RIVER PL40T AREA 1 STPIROPFERTY.- LIhMITS N3' 0.1 ________'1 ii -~i~\* '-~~~L-. .MAlKE2UP Sump* 7* i- STATION C O IGMAKEUP p..* .PIPELINES RE E VOIR~ C I [" SPILLWAY a. BLOWVDOWN-LCWIDOWN DPISCHARGE CHA NEL DISCHARGE ,- --LOwOOWN PIPLIN I 0 1 2000 4000 FEET SCALE Kl6 NOTE: MAP BASE IS 71/2' USGS OUADRANIGLE GRID BASED ON "TEXAS COORDINATE SYST~tA,'SOUTH CENTRAL ZONE." ELEVATION AND COnrjOURS SHOWN ARE Itn FEET. DATUM IS MEAN SEA LEVEL.REFERENICE ELE-VATIONS: MiEA1 SEA LEVLL: EL. 0.00 MEAN LOW TIDE: EL. (--).43 MEAN LOW WATER: EL.O-tO !AT SIrTE)SOUTH TEXAS PROJECT LOCATION MAP STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 SWG-1992-02707 P. 2 of 5 CENTERLINE I-PERMITTED PLANS DROP INLET OUTFALL P WITH RIPRAP I: ,/1 k SOUTH TEXAS PROJE(-MAKEUP PUMP STATIO: 8. BARGE SLIP ON THE COLORAo0 RIVER AT RIVER MILE 14.0 UATAGOROA COUNTY, TEXAS APf UCAT I1 U" STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 SWG-1 992-02707 P. 3 of 5 0 0oo 20o 300 T SCALE I W0-- -ij-.~~ 0,_ _ weI tw p f r- f 0 7.7. ........---.--. PWPA1TDLJNSRMFOVRVE CD-4 -0C G) M L--n0f Note: I.. Elevations shown in feet 2. Spoil depth varies PERMIrflz[D pLANS-N 0 1 CrC-1 4 0L~0 04 Hr;I X-D00 0)CO 0 CD W)South Texas Project Cross Section of RMPF WR-3. Current TCEQ-issued TPDES permit (TPDES Permit No.WQ0001908000 issued July 21, 2005). [STPLR-05] TPDES PERMIT NO. W00001908000 [For TCEQ office use only -EPA I.D. No. TX00649471] TEXAS COMMISSION ON ENVIRONMENTAL QUALITY This is a renewal of TPDES Permit No.P. 0. Box 13087 W00001908000, issued onNovember 2, Austin, Texas 78711-3087 2000.PERMIT TO DISCHARGE WASTES under provisions of Section 402 of the Clean Water Act and Chapter 26 of the Texas Water Code STP Nuclear Operating Company whose mailing address is P. 0. Box 289 Wadsworth, Texas 77483-0289 is authorized to treat and discharge wastes from the South Texas Project Electric Generating Station (SIC 4911)located on Farm-to-Market Road 521, approximately 10 miles north of Matagorda Bay and 12 miles south-southwest of the City of Bay City, Matagorda County, Texas to Colorado River Tidal in Segment No. 1401 of the Colorado River Basin only according to effluent limitations, monitoring requirements and other conditions set forth in this permit, as well as the rules of the Texas Commission on Environmental Quality (TCEQ), the laws of the State of Texas, and other orders of the TCEQ. The issuance of this permit does not grant to the permittee the right to use private or public property for conveyance of wastewater along the discharge route described in this permit. This includes, but is not limited to, property belonging to any individual, partnership, corporation or other entity. Neither does this permit authorize any invasion of personal rights nor any violation of federal, state, or local laws or regulations. It is the responsibility of the permittee to acquire property rights as may be necessary to use the discharge route.This permit shall expire at midnight on December 1, 2009.ISSUED DATE: JUL 2.12005 For the Commission STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 DEFINITIONS AND STANDARD PERMIT CONDITIONS As required by Title 30 Texas Administrative Code (TAG) Chapter 305, certain regulations appear as standard conditions in waste discharge permits. 30 TAC §§ 305.121 -305.129 (relating to Permit Characteristics and Conditions) as promulgated under the Texas Water Code §§ 5.103 and 5.105, and the Texas Health and Safety Code §§ 361.017 and 361.024(a), establish the characteristics and standards for waste discharge permits, including sewage sludge, and those sections of40 Code of Federal Regulations (CFR) Part 122 adopted by reference by the Commission. The following text includes these conditions and incorporates them into this permit. All definitions in Section 26.001 of the Texas Water Code and 30 TAC Chapter 305 shall apply to this permit and are incorporated by reference. Some specific definitions of words or phrases used in this permit are as follows: 1. Flow Measurements

a. Annual average flow- the arithmetic average of all daily flow determinations taken within the preceding 12 consecutive calendar months. The annual average flow determination shall consist of daily flow volume determinations made by a totalizing meter, charted on a chart recorder and limited to major domestic wastewater discharge facilities with a I million gallons per day or greater permitted flow.b. Daily average flow -the arithmetic average of-all determinations of the daily flow within a period of one calendar month. The daily average flow determination shall consist of determinations made on at least four separate days. If instantaneous measurements are used to determine the daily flow, the determination shall be the arithmetic average of all instantaneous measurements taken during that month. Daily average flow determination for intermittent discharges shall consist of a minimum of three flow determinations on days of discharge.

c. Daily maximum flow -the highest total flow for any 24-hour period in a calendar month.d. Instantaneous flow -the measured flow during the minimum time required to interpret the flow measuring device.e. 2-hour peak flow (domestic wastewater treatment plants) -the maximum flow sustained for a two-hour period during the period of daily discharge.

The average of multiple measurements of instantaneous maximum flow within a two-hour period may be used to calculate the 2-hour peak flow.f. Maximum 2-hour peak flow (domestic wastewater treatment plants) -the highest 2-hour peak flow for any 24-hour period in a calender month.2. Concentration Measurements

a. Daily average concentration

-the arithmetic average of all effluent samples, composite or grab as required by this permit, within a period of one calendar month, consisting of at least four separate representative measurements.

i. For domestic wastewater treatment plants -When four samples are not available in a calendar month, the arithmetic average (weighted by flow) of all values in the previous four consecutive month period consisting of at least four measurements shall be utilized as the daily average concentration.

ii. For all other wastewater treatment plants -When four samples are not available in a calender month, the arithmetic average (weighted by flow) of all values taken during the month shall be utilized as the daily average concentration.

b. 7-day average concentration

-the arithmetic average of all effluent samples, composite or grab as required by this permit, within a period of one calendar week, Sunday through Saturday.c. Daily maximum concentration -the maximum concentration measured on a single day, by the sample type specified in the permit, within a period of one calender month.d. Daily discharge -the discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations expressed in terms of mass, the"daily discharge" is calculated as the total mass of the pollutant discharged over the sampling day. For pollutants with limitations expressed in other units of measurement, the "daily discharge" is calculated as the average measurement of the pollutant over the sampling day.The "daily discharge" determination of concentration made using a composite sample shall be the concentration of the composite sample. When grab samples are used, the "daily discharge" determination of concentration shall be the arithmetic average (weighted by flow value) of all samples collected during that day.e. Fecal coliform bacteria concentration -the number of colonies of fecal coliform bacteria per 100 milliliters effluent.The daily average fecal coliform bacteria concentration is a geometric mean of the values for the effluent samples collected in a calendar month. The geometric mean shall be determined by calculating the nth root of the product of all measurements made in a calender month, where n equals the number of measurements made; or, computed as the Page 2 Outfall Number 001 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

1. During the period beginning upon date of issuance and lasting through date of expiration, the permittee is authorized to discharge

(*5) recirculated cooling water, cooling reservoir blowdown, previously monitored effluents, storm water, and makeup water from Colorado River subject to the following effluent limitations: The daily average flow of effluent shall not exceed 144 million gallons per day (MGD). The daily maximum flow shall not exceed 200 MGD.Effluent Characteristics Discharge Limitations Flow (MGD)Colorado River Flow (MGD) (*5)Temperature (*F)Total Residual Chlorine (*3)Daily Average mg/I (Report)N/A (95 -F) (*2)N/A Daily Maximum mg/l Single Grab mg/I (Report)(Report)(97 -F) (*2)0.05 N/A N/A N/A N/A Continuous (* 1)1/day (* 1)Continuous (* 1)1/week (* 1)Record Estimate In-Situ Grab (*4)Minimum Self-Monitoring Requirements Report Daily Average and Daily Maximum Measurement Frequency Sample Type (*I)(*2)(*3)(*4)(*5)When discharge occurs from Outfall 001.See "Other Requirements," provision No. 9.See "Other Requirements," provision No. 5.Samples shall be representative of periods of chlorination. See "Other Requirements," provision No. 4.2. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 1/day, by grab sample.3. There shall be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.4. Effluent monitoring samples shall be taken at the following location: At Outfall 001, which is at a point in the blowdown line prior to entering the Colorado River.Page 2 of TPDES Permit No. WQ000 1908000 STP Nuclear Operating Company EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Outfall Number 101 I, During the period beginning upon date of issuance and lasting through date of expiration, the permittee is authorized to discharge low volume waste sources (* 1) commingled with previously monitored effluent (PME) from the metal cleaning waste system discharge subject to the following effluent limitations: Volume: Flow variable.Effluent Characteristics ' Daily Avera, mg/I Discharge Limitations ge Daily Maximum rmg/I Single Grab mg/I Minimum Self-Monitoring Requirements Report Daily Average and Daily Maximum Measurement Frequency Sample Type Flow (MGD)Total Suspended Solids Oil and Grease (Report)30 15 (Report)100 20 N/A 100 20 1/day 1/week I/week Estimate Grab (*2)Grab (*2)(* 1) See "Other Requirements," provision 10.(*2) If more than one source is associated with this particular waste category, grab samples from each source shall be analyzed and the analytical values combined on a flow weighted basis with the calculated values used to determine the "Daily Average" for the month. The highest analytical value of all grab samples for the monthly reporting period shall be reported as the "Daily Maximum." 2. There shall be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.3. Effluent monitoring samples shall be taken at the following location: At Outfall 101, where low volume waste sources (*1) commingled with previously monitored effluents (PME) are discharged from the neutralization basins prior to mixing with any other waste stream.Page 2a of TPDES Permit No. WQOOO 1908000 STP Nuclear Operating Company EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Outfall Number 201 1. During the period beginning upon date of issuance and lasting through date of expiration, the permit-tee is authorized to discharge low volume waste sources (* 1) from the oily waste treatment system and storm water subject to the following effluent limitations: Volume: Flow variable.Effluent Characteristics Daily Average mg/1 Discharge Limitations Daily Maximum mg/I Single :Grab mg/1 Minimum Self-Monitoring Requirements Re port Daily Average and Daily Maximum Measurement Frequency Sample Type Flow (MGD)Total Suspended Solids Oil and Grease (Report)30 15 (Report)100 20 N/A 100 20 1/day'1/week 1/week Estimate Grab (*2)Grab (*2)(* 1) See "Other Requirements," provision 10.(*2) If more than one source is associated with this particular waste category, grab samples from each source shall be analyzed and the analytical values combined on a flow weighted basis with the calculated values used to determine the "Daily Average" for the month. The highest analytical value of all grab samples for the monthly reporting period shall be reported as the "Daily Maximum." 2. There shall be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.3. Effluent monitoring samples shall be taken at the following location: Outfall 201, where low volume waste sources are discharged from the oily waste treatment system prior to mixing with any other waste stream.Page 2b of TPDES Permit No. WQ0001908000 STP Nuclear Operating Company EFFLUENT LMouiATIONS AND MONITORING REQUIREMENTS Outfall Number 401 1. During the period beginning upon date of issuance and lasting through date of expiration, the permittee is a 'uthorized to discharge treated sanitary sewage commingled with car wash water and air conditioning condensate subject to the following effluent limitations: Volume: Continuous and flow variable.Effluent Characteristics Daily Average mg/l Discharge Limitations Daily Maximum mg/1 Single Grab mg/i Minimum Self-Monitoring Requirements Report Daily Average and Daily Maximum Measurement Frequency Sample Type Flow (MGD)Biochemical Oxygen Demand (5-day)Total Suspended Solids (Report)20 20 (Report)N/A 1/day 1/week l/week Estimate Grab Grab 45 45 45 45 2. The effluent shall contain a minimum chlorine residual of 1.0 mg/l after a detention time of at least 20 minutes (based on peak flow), and shall be monitored 1/week, by grab sample.3. There shall be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.4. Effluent monitoring samples shall be taken at the following location: At Outfall 401, at discharge from the sewage treatment plant (West Sanitary Waste Treatment System) prior to mixing with any other waste stream.Page 2c of TPDES Permit No. WQO0O 1908000 STP Nuclear Operating Company EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Outfall Number 501 " 1.

• During the period beginning upon date of issuance and lasting through date of expiration, the permittee is authorized to discharge metal cleaning waste (*1)subject to the following effluent limitations

(*3): Volume: Intermittent and flow variable.Effluent Characteristics Daily Average mg/1I Discharge Limitations Daily Maximum mg/I Single Grab mg/I" Minimum Self-Monitoring Requirements Report Daily Average and Daily Maximum Measurement Frequency Sample Type Flow (MGD)Iron, Total Copper, Total (Report)1.0 0.5 (Report)1.0 1.0 N/A 1.0 1.0 1/day (*2)lweek (*2)1/week (*2)Estimate Grab Grab (* 1) See "Other Requirements," provision No. 7.(*2) When discharge occurs.2. There shall be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.3. Effluent monitoring samples shall be taken at the following location: At Outfall 501, where metal cleaning wastes are discharged prior to mixing with any other waste stream.Page 2d of TPDES Permit No. WQ00 1908000 STP Nuclear Operating Company Outfall Number 601 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

1. During the period beginning upon date of issuance and lasting through date of expiration, the permittee is authorized to discharge treated sanitary sewage commingled with air conditioning condensate and HVAC cooling tower blowdown subject to the following effluent limitations:

Volume: Continuous and flow variable.Effluent Characteristics Daily Average mg/l Discharge Limitations Daily Maximum mg/1 Single Grab mg/1 Minimum Self-Monitoring Requirements Report Daily Average and Daily Maximum.Measurement Frequency Sample Type Flow (MGD)Biochemical Oxygen Demand (5-day)Total Suspended Solids (Report)20 20 (Report)N/A 1/day Estimate 45 45 45 45 lweek 1/week Grab Grab 2. The effluent shall contain a minimum chlorine residual of 1.0 mg/I after a detention time of at least 20 minutes (based on peak flow), and shall be monitored 1/week, by grab sample.3. There shall be no discharge of floating solids or visible foam in other than trace amounts and no discharge of visible oil.4. Effluent monitoring samples shall be taken at the following location: At Outfall 601, at discharge from the sewage treatment plant (Training Sanitary Waste Treatment Facility) prior to mixing with any other waste stream.Page 2e of TPDES Permit No. WQ0001908000 STP Nuclear Operating Company STP Nuclear Operating Company TPDES Pennit No. WQOOO 1908000 DEFINITIONS AND STANDARD PERMIT CONDITIONS As required by Title 30 Texas Adminstrative Code (TAC) Chapter 305, certain regulations appear as standard conditions in waste discharge permits. 30 TAC §§ 305.121 -305.129 (relating to Permit Characteristics and Conditions) as promulgated under the Texas Water Code §§ 5.103 and 5.105, and the Texas Health and Safety Code §§ 361.017 and 361.024(a), establish the characteristics and standards for waste discharge permits, including sewage sludge, and those sections of40 Code of Federal Regulations (CFR) Part 122 adopted by reference by the Commission. The following text includes these conditions and incorporates them into this permit. All definitions in Section 26.001 of the Texas Water Code and 30 TAC Chapter 305 shall apply to this permit and are incorporated by reference. Some specific definitions of words or phrases used in this permit are as follows: 1. Flow Measurements

a. Annual average flow -the arithmetic average of all daily flow determinations taken within the preceding 12 consecutive calendar months. The annual average flow determination shall consist of daily flow volume determinations made by a totalizing meter, charted on a chart recorder and limited to major domestic wastewater discharge facilities with a I million gallons per day or greater permitted flow.b. Daily average- flow ý the arithmetic average of-all-determinations of-the-daily flow within a-period of-one-calendar

-month. The daily average flow determination shall consist of determinations made on at least four separate days. If instantaneous measurements are used to determine the daily flow, the determination shall be the arithmetic average of all instantaneous measurements taken during that month. Daily average flow determination for intermittent discharges shall consist of a minimum of three flow determinations on days of discharge.

c. Daily maximum flow -the highest total flow for any 24-hour period in a calendar month.d. Instantaneous flow -the measured flow during the minimum time required to interpret the flow measuring device.e. 2-hour peak flow (domestic wastewater treatment plants) -the maximum flow sustained for a two-hour period during the period of daily discharge.

The average of multiple measurements of instantaneous maximum flow within a two-hour period may be used to calculate the 2-hour peak flow.f. Maximum 2-hour peak flow (domestic wastewater treatment plants) -the highest 2-hour peak flow for any 24-hour period in a calender month-2. Concentration Measurements

a. Daily average concentration

-the arithmetic average of all effluent samples, composite or grab as required by this permit, within a period of one calendar month, consisting of at least four separate representative measurements.

i. For domestic wastewater treatment plants -When four samples are not available in a calendar month, the arithmetic average (weighted by flow) of all values in the previous four consecutive month period consisting of at least four measurements shall be utilized as the daily average concentration.

ii. For all other wastewater treatment plants -When four samples are not available in a calender month, the arithmetic average (weighted by flow) of all values taken during the month shall be utilized as the daily average concentration.

b. 7-day average concentration

-the arithmetic average of all effluent samples, composite or grab as required by this permit, within a period of one calendar week, Sunday through Saturday.c. Daily maximum concentration -the maximum concentration measured on a single day, by the sample type specified in the permit, within a period of one calender month.d. Daily discharge -the discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for purposes of sampling. For pollutants with limitations expressed in terms of mass, the"daily discharge" is calculated as the total mass of the pollutant discharged over the sampling day. For pollutants with limitations expressed in other units of measurement, the "daily discharge" is calculated as the average measurement of the pollutant over the sampling day.The "daily discharge" determination of concentration made using a composite sample shall be the concentration of the composite sample. When grab samples are used, the "daily discharge" determination of concentration shall be the arithmetic average (weighted by flow'value) of all samples collected during that day.e. Fecal coliform bacteria concentration -the number of colonies of fecal coliform bacteria per 100 milliliters effluent.The daily average fecal coliform bacteria concentration is a geometric mean of the values for the effluent samples collected in a calendar month. The geometric mean shall be determined by calculating the nth root of the product of all measurements made in a calender month, where n equals the number of measurements made; or, computed as the Page 2 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 antilogarithm of the arithmetic mean of the logarithms of all measurements made in a calender month. For any measurement of fecal coliform bacteria equaling zero, a substituted value of one shall be made for input into either computation method. The 7-day average for fecal coliform bacteria is the geometric mean of the values for all effluent samples collected during a calender week.f. Daily average loading (lbs/day) -the arithmetic average of all daily discharge loading calculations during a period of one calender month. These calculations must be made for each-day of the month that a parameter is analyzed. The daily discharge, in terms of mass (lbs/day), is calculated as ( Flow, MGD x Concentration, mg/I x 8.34).g. Daily maximum loading (lbs/day) -the highest daily discharge, in terms of mass (lbs/day), within a period of one calender month.3. Sample Type a. Composite sample -For domestic wastewater, a composite sample is a sample made up of a minimum of three effluent portions collected in a continuous 24-hour period or during the period of daily discharge if less than 24 hours, and combined in volumes proportional to flow, and collected at the intervals required by 30 TAC § 319.9 (a). For industrial wastewater, a composite sample is a sample made up of a minimum of three effluent portions collected in a continuous hour-period-or-during-the-period of daily-discharge-if-less-than-24-hours,- and combined-in-volumesproportional to flow, and collected at the intervals required by 30 TAC § 319.9 (b).b. Grab sample -an individual sample collected in less than 15 minutes.4. Treatment Facility (facility) -wastewater facilities used in the conveyance, storage, treatment, recycling, reclamation and/or disposal of domestic sewage, industrial wastes, agricultural wastes, recreational wastes, or other wastes including sludge handling or disposal facilities under the jurisdiction of the Commission.

5. The term "sewage sludge" is defined as solid, semi-solid, or liquid residue generated during the treatment of domestic sewage in 30 TAC Chapter 312. This includes the solids which have not been classified as hazardous waste separated from wastewater by unit processes.

6. Bypass -the intentional diversion of a waste stream from any portion of a treatment facility.MONITORING AND REPORTING REQUIREMENTS

1. Self-Reporting Monitoring results shall be provided at the intervals specified in the permit. Unless otherwise specified in this permit or otherwise ordered by the Commission, the permittee shall conduct effluent sampling and reporting in accordance with 30 TAC §§ 319.4 -319.12. Unless otherwise specified, a monthly effluent report shall be submitted each month, to the Enforcement Division (MC 224), by the 20th day of the following month for each discharge which is described by this permit whether or not a discharge is made for that month. Monitoring results must be reported on an approved self-report form, that is signed and certified as required by Monitoring and Reporting Requirements No. 10.As provided by state law, the permittee is subject to administrative, civil and criminal penalties, as applicable, for negligently or knowingly violating the Clean Water Act, the Texas Water Code, Chapters 26, 27, and 28, and Texas Health and Safety Code, Chapter 361, including but not limited to knowingly making any false statement, representation, or certification on any report, record, or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or noncompliance, or falsifying, tampering with or knowingly rendering inaccurate any monitoring device or method required by this permit or violating any other requirement imposed by state or federal regulations.

2. Test Procedures Unless otherwise specified in this permit, test procedures for the analysis of pollutants shall comply with procedures specified in 30 TAC §§319.11 -319.12. Measurements, tests and calculations shall be accurately accomplished in a representative manner.3. Records of Results a. Monitoring samples and measurements shall be taken at times and in a manner so as to be representative of the monitored activity.b. Except for records of monitoring information required by this permit related to the permittee's sewage sludge use and disposal activities, which shall be retained for a period of at least five years (or longer as required by 40 CFR Part 503), monitoring and reporting records, including strip charts and records of calibration and maintenance, copies of all records required by this permit, records of all data used to complete the application for this permit, and the certification Page 3 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 required by 40 CFR § 264.73(b)(9) shall be retained at the facility site, or shall be readily available for review by a TCEQ representative for a period of three years from the date of the record or sample, measurement, report, application or certification.

This period shall be extended at the request of the Executive Director.c. Records of monitoring activities shall include the following:

i. date, time and place of sample or measurement; ii. identity of individual who collected the sample or made the measurement.

iii. date and time of analysis;iv. identity of the individual and laboratory who performed the analysis;v. the technique or method of analysis; and vi. the results of the analysis or measurement and quality assurance/quality control records.The period during which records are required to be kept shall be automatically extended to the date of the final disposition of any administrative or judicial enforcement action that maybe instituted against the permittee.

4. Additional Monitoring by Perrnittee if the permitteenmonitors any-pollutant at the location(s) designated herein more frequently-than required-by-this permit using approved analytical methods as specified above, all results of such monitoring shall be included in the calculation and reporting of the values submitted on the approved self-report form. Increased frequency of sampling shall be indicated on the self-report form.5. Calibration of Instruments All automatic flow measuring or recording devices and all totalizing meters for measuring flows shall be accurately calibrated by a trained person at plant start-up and as often thereafter as necessary to ensure accuracy, but not less often than annually unless authorized by the Executive Director for a longer period. Such person shall verify in writing that the device is operating properly and giving accurate results. Copies of the verification shall be retained at the facility site and/or shall be readily available for review by a TCEQ representative for a period of three years.6. Compliance Schedule Reports Reports of compliance or noncompliance with, or any progress reports on, interim and final requirements contained in any compliance schedule of the permit shall be submitted no later than 14 days following each schedule date to the Regional Office and the Enforcement Division (MC 224).7. Noncompliance Notification

a. In accordance with 30 TAC § 305.125(9) any noncompliance which may endanger human health or safety, or the environment shall be reported by the permittee to the TCEQ. Report of such information shall be provided orally or by facsimile transmission (FAX) to the Regional Office within 24 hours of becoming aware of the noncompliance.

A written submission of such information shall also be provided by the permittee to the Regional Office and the Enforcement Division (MC 224) within five working days of becoming aware of the noncompliance. The written submission shall contain a description of the noncompliance and its cause; the potential danger to human health or safety, or the environment; the period of noncompliance, including exact dates and times; if the noncompliance has not been corrected, the time it is expected to continue; and steps taken or planned to reduce, eliminate, and prevent recurrence of the noncompliance, and to mitigate its adverse effects.b. The following violations shall be reported under Monitoring and Reporting Requirement 7.a.: i. Unauthorized discharges as defined in Permit Condition 2(g).ii. Any unanticipated bypass which exceeds any effluent limitation in the permit.iii. Violation of a permitted maximum daily discharge limitation for pollutants listed specifically in the Other Requirements section of an Industrial TPDES permit.c. In addition to the above, any effluent violation which deviates from the permitted effluent limitation by more than 40%shall be reported by the permittee in writing to the Regional Office and the Enforcement Division (MC 224) within 5 working days of becoming aware of the noncompliance.

d. Any noncompliance other than that specified in this section, or any required information not submitted or submitted incorrectly, shall be reported to the Enforcement Division (MC 224) as promptly as possible.

For effluent limitation violations, noncompliances shall be reported on the approved self-report form.8. In accordance with the procedures described in 30 TAC §§ 35.301 -35.303 (relating to Water Quality Emergency and Temporary Orders) if the permittee knows in advance of the need for a bypass, it shall submit prior notice by applying for such authorization. Page 4 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 9. Changes in Discharges of Toxic Substances All existing manufacturing, commercial, mining, and silvicultural permittees shall notify the Regional Office, orally or by facsimile transmission within 24 hours, and both the Regional Office and the Enforcement Division (MC 224) in writing within five (5) working days, after becoming aware of or having reason to believe: a. That any activity has occurred or will occur which would result in the discharge, on a routine or frequent basis, of any toxic pollutant listed at 40 CFR Part 122, Appendix D, Tables II and III (excluding Total Phenols) which is not limited in the permit, if that discharge will exceed the highest of the following "notification levels": i. One hundred micrograms per liter (100 [tg/L);ii. Two hundred micrograms per liter (200 ýLg/L) for acrolein and acrylonitrile; five hundred micrograms per liter (500 pLg/L) for 2,4-dinitrophenol and for 2-methyl-4,6-dinitrophenol; and one milligram per liter (1 mg/L) for antimony;iii. Five (5) times the maximum concentration value reported for that pollutant in the permit application; or iv. The level established by the TCEQ.b. That any activity has occurred or will occur which would result in any discharge, on a nonroutine or infrequent basis, of a toxic pollutant which is not limited in the permit,--if that-discharge will-exceed the -highest of the following"notification levels": i. Five hundred micrograms per liter (500 ýigfL);ii. One milligram per liter (1 mg/L) for antimony;iii. Ten (10) times the maximum concentration value reported for that pollutant in the permit application; or iv. The level established by the TCEQ.10. Signatories to Reports All reports and other information requested by the Executive Director shall be signed by the person and in the manner required by 30 TAC § 305.128 (relating to Signatories to Reports).11. All Publicly Owned Treatment Works (POTWs) must provide adequate notice to the Executive Director of the following:

a. Any new introduction of pollutants into the POTW from an indirect discharger which would be subject to section 301 or 306 of the CWA if it were directly discharging those pollutants;

b. Any substantial change in the volume or character of pollutants being introduced into that POTW by a source introducing pollutants into the POTW at the time of issuance of the permit; and c. For the purpose of this paragraph, adequate notice shall include information on: i. The quality and quantity of effluent introduced into the POTW; and ii. Any anticipated impact of the change on the quantity or quality of effluent to be discharged from the POTW.PERMIT CONDITIONS

1. General a. When the permittee becomes aware that it failed to submit any relevant facts in a permit application, or submitted incorrect information in an application or in any report to the Executive Director, it shall promptly submit such facts or information.

b. This permit is granted on the basis of the information supplied and representations made by the permittee during action on an application, and relying upon the accuracy and completeness of that information and those representations.

After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked, in whole or in part, in accordance with 30 TAC Chapter 305, Subchaptei D, during its term for good cause including, but not limited to, the following:

i. Violation of any terms or conditions of this permit;ii. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; or iii. A change in any condition that requires either a temporary or permanent reduction or elimination of the authorized discharge.

c. The permittee shall furnish to the Executive Director, upon request and within a reasonable time, any information to determine whether cause exists for amending, revoking, suspending or terminating the permit. The permittee shall also furnish to the Executive Director, upon request, copies of records required to be kept by the permit.Page 5 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 2. Compliance

a. Acceptance of the permit by the person to whom it is issued constitutes acknowledgment and agreement that such person will comply with all the terms and conditions embodied in the permit, and the rules and other orders of the Commission.

b. The permittee has a duty to comply with all conditions of the permit. Failure to comply with any permit condition constitutes a violation of the permit and the Texas Water Code or the Texas Health and Safety Code, and is grounds for enforcement action, for permit amendment, revocation or suspension, or for denial of a permit renewal application or an application for a permit for another facility.c. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit.d. The permittee shall take all reasonable steps to minimize or prevent any discharge or sludge use or disposal or other permit violation which has a reasonable likelihood of adversely affecting human health or the environment.

e. Authorization from the Commission is required before beginning any change in the permitted facility or activity that may result-in noncompliance with any-permit--requirements.

f. A permit may be amended, suspended and reissued, or revoked for cause in accordance with 30 TAC §§ 305.62 and 305.66 and Texas Water Code Section 7.302. The filing of a request by the permittee for a permit amendment, suspension and reissuance, or termination, or a notification ofplanned changes or anticipated noncompliance, does not stay any permit condition.

g. There shall be no unauthorized discharge of wastewater or any other waste. For the purpose of this permit, an unauthorized discharge is considered to be any discharge of wastewater into or adjacent to water in the state at any location not permitted as an outfall or otherwise defined in the Other Requirements section of this permit.h. In accordance with 30 TAC § 305.535(a), the permittee may allow any bypass to occur from a TPDES permitted facility which does not cause permitted effluent limitations to be exceeded or an unauthorized discharge to occur, but only if the bypass is also for essential maintenance to assure efficient operation.

i. The permittee is subjectto administrative, civil, and criminal penalties, as applicable, underTexas Water Code §§7.051-7.075 (relating to Administrative Penalties), 7.101 -7.111. (relating to Civil Penalties), and 7.141 -7.202 (relating to Criminal Offenses and Penalties) for violations including, but not limited to, negligently or knowingly violating the federal Clean Water Act, §§ 301, 302, 306, 307, 308, 318, or 405, or any condition or limitation implementing any sections in a permit issued under the CWA § 402, or any requirement imposed in a pretreatment program approved under the CWA §§ 402 (a)(3) or 402 (b)(8).3. Inspections and Entry a. Inspection and entry shall be allowed as prescribed in the Texas Water Code Chapters 26,27, and 28, and Texas Health and Safety Code Chapter 361.b. The members of the Commission and employees and agents of the Commission are entitled to enter any public or private property at any reasonable time for the purpose of inspecting and investigating conditions relating to the quality of water in the state or thecompliance with any rule, regulation, permit or other order of the Commission.

Members, employees, or agents of the Commission and Commission contractors are entitled to enter public or private property at any reasonable time to investigate or monitor or, if the responsible party is not responsive or there is an immediate danger to public health or the environment, to remove or remediate a condition related to the quality of water in the state. Members, employees, Commission contractors, or agents acting under this authority who enter private property shall observe the establishment's rules and regulations concerning safety, internal security, and fire protection, and if the property has management in residence, shall notify management or the person then in charge of his presence and shall exhibit proper credentials. If any member, employee, Commission contractor, or agent is refused the right to enter in or on public or private property under this authority, the Executive Director may invoke the remedies authorized in Texas Water Code Section 7.002. The statement above, that Commission entry shall occur in accordance with an establishment's rules and regulations concerning safety, internal security, and fire protection, is not grounds for denial or restriction of entry to any part of the facility, but merely describes the Commission's duty to observe appropriate rules and regulations during an inspection.

4. Permit Amendment and/or Renewal a. The permittee shall give notice to the Executive Director as soon as possible of any planned physical alterations or additions to the permitted facility if such alterations or additions would require a permit amendment or result in a violation of permit requirements.

Notice shall also be required under this paragraph when: Page 6 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 i. The alteration or addition to a permitted facility may meet one of the criteria for determining whether a facility is a new source in accordance with 30 TAC § 305.534 (relating to New Sources and New Dischargers); or ii. The alteration or addition could significantly change the nature or increase the quantity of pollutants discharged. This notification applies to pollutants which are subject neither to effluent limitations in the permit, nor to notification requirements in Monitoring and Reporting Requirements No. 9;iii. The alteration or addition results in a significant change in the pennittee's sludge use or disposal practices, and such alteration, addition, or change may justify the application of permit conditions that are different from or absent in the existing permit, including notification of additional use or disposal sites not reported during the permit application process or not reported pursuant to an approved land application plan.b. Prior to any facility modifications, additions, or expansions that will increase the plant capacity beyond the permitted flow, the permittee must apply for and obtain proper authorization from the Commission before commencing construction.

c. The permittee must apply for an amendment or renewal prior to expiration of the existing permit in order to continue a permittedactivity after the expiration date of the permit. If an application-issubmitted-prior-to the expiration date of the permit, the existing permit shall remain in effect until the application is approved, denied, or returned.

If the application is returned or denied, authorization to continue such activity shall terminate upon the effective date ofi-he action. If an application is not submitted prior to the expiration date of the permit, the permit shall expire and authorization to continue such activity shall terminate.

d. Prior to accepting or generating wastes which are not described in the permit application or which would result in a significant change in the quantity or quality of the existing discharge, the permittee must report the proposed changes to the Commission.

The permittee must apply for a permit amendment reflecting any necessary changes in permit conditions, including effluent limitations for pollutants not identified and limited by this permit.e. In accordance with the Texas Water Code § 26.029(b), after a public hearing, notice of which shall be given to the permittee, the Commission may require the permittee, from time to time, for good cause, in accordance with applicable laws, to conform to new or additional conditions. f If any toxic effluent standard or prohibition (including any schedule of compliance specified in such effluent standard or prohibition) is promulgated under Section 307(a) of the Clean Water Act for a toxic pollutant which is present in the discharge and that standard or prohibition is more stringent than any limitation on the pollutant in this permit, this permit shall be modified or revoked and reissued to confornnto the toxic effluent standard or prohibition. The permittee shall comply with effluent standards or prohibitions established under Section 307(a) of the Clean Water Act for toxic pollutants within the time provided in the regulations that established those standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement.

5. Permit Transfer a. Prior to any transfer of this permit, Commission approval must be obtained.

The Commission shall be notified in writing of any change in control or ownership of facilities authorized by this permit. Such notification should be sent to the Water Quality Applications Team (MC 161) of the Registration, Review, and Reporting Division.b. A permit may be transferred only according to the provisions of 30 TAC § 305.64 (relating to Transfer of Permits) and 30 TAC § 50.133 (relating to Executive Director Action on Application or WQMP update).6. Relationship to Hazardous Waste Activities This permit does not authorize any activity of hazardous waste storage, processing, or disposal which requires a permit or other authorization pursuant to the Texas Health and Safety Code.7. Relationship to Water Rights Disposal of treated effluent by any means other than discharge directly to water in the state must be specifically authorized in this permit and may require a permit pursuant to Chapter 11 of the Texas Water Code.8. Property Rights A permit does not convey any property rights of any sort, or any exclusive privilege.

9. Permit Enforceability The conditions of this permit are severable, and if any provision of this permit, or the application of any provision of this Page 7 STP Nuclear Operating Company TPDES Permit No. WQ0001908000 permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby.10. Relationship to Permit Application The application pursuant to which the permit has been issued is incorporated herein; provided, however, that in the event of a conflict between the provisions of this permit and the application, the provisions of the permit shall control.11. Notice of Bankruptcy.

a. Each permittee shall notify the executive director, in writing, immediately following the filing of a voluntary or involuntary petition for bankruptcy under any chapter of Title 11 (Bankruptcy) of the United States Code (11 USC)by or against: i. the permittee; ii. an entity,(as that term is defined in 11 USC, § 1 01(15)) controlling the permittee or listing the permit or permittee as property of the estate; or iii. an affiliate (as that term is defined in 11 USC, § 101 (2)) of the permittee.

b. This notification must indicate: i. the name of the permittee; ii. the permit number(s);

iii. the bankruptcy court in which the petition for bankruptcy was filed; and iv. the date of filing of the petition.OPERATIONAL REQUIREMENTS

1. The permittee shall at all times ensure that the facility and all of its systems of collection, treatment, and disposal are properly operated and maintained.

This includes, but is not limited to, the regular, periodic examination of wastewater solids within the treatment plant by the operator in order to maintain an appropriate quantity and quality of solids inventory as described in the various operator training manuals and according to accepted industry standards for process control.Process control, maintenance, and operations records shall be retained at the facility site, or shall be readily available for review by a TCEQ representative, for a period of three years.2. Upon request by the Executive Director, the permittee shall take appropriate samples and provide proper analysis in order to demonstrate compliance with Commission rules. Unless otherwise specified in this permit or otherwise ordered by the Commission, the permittee shall comply with all applicable provisions of 30 TAC Chapter 312 concerning sewage sludge use and disposal and 30 TAC §§ 319.21 -319.29 concerning the discharge of certain hazardous metals.3. Domestic wastewater treatment facilities shall comply with the following provisions:

a. The permittee shall notify the Municipal Permits Team, Wastewater Permitting Section (MC 148) of the Water Quality Division, in writing, of any facility expansion at least 90 days prior to conducting such activity.b. The permittee shall submit a closure plan for review and approval to the Agriculture and Sludge Team, Wastewater Permitting Section (MC 148) of the Water Quality Division, for any closure activity at least 90 days prior to conducting such activity.

Closure is the act ofpermanently taking a waste management unit or treatment facility out of service and includes the permanent removal from service of any pit, tank, pond, lagoon, surface impoundment and/or other treatment unit regulated by this permit.4. The permittee is responsible for installing prior to plant start-up, and subsequently maintaining, adequate safeguards to prevent the discharge of untreated or inadequately treated wastes during electrical power failures by means of alternate power sources, standby generators, and/or retention of inadequately treated wastewater.

5. Unless otherwise specified, the permittee shall provide a readily accessible sampling point and, where applicable, an effluent flow measuring device or other acceptable means by which effluent flow may be determined.

6. The permittee shall remit an annual water quality fee to the Commission as required by 30 TAC Chapter 21. Failure to pay the fee may result in revocation of this permit under Texas Water Code § 7.302(b)(6).

7. Documentation For all written notifications to the Commission required of the permittee by this permit, the permittee shall keep and make available a copy of each such notification under the same conditions as self-monitoring data are required to be kept and made available.

Except for information required for TPDES permit applications, effluent data, including effluent data in permits; draft permits and permit applications, and other information specified as not confidential in 30 TAC § 1.5(d), any Page 8 -STP Nuclear -Operating Company TPDES Permit No. WQOOO 1908000 information submitted pursuant to this permit may be claimed as confidential by the submitter. Any such claim must be asserted in the manner prescribed in the application form or by stamping the words "confidential business information" on each page containing such information. If no claim is made at the time of submission, information may be made available to the public without further notice. If the Commission or Executive Director agrees with the designation of confidentiality, the TCEQ will not provide the information for public inspection unless required by the Texas Attorney General or a court pursuant to an open records request. If the Executive Director does not agree with the designation of confidentiality, the person submitting the information will be notified.8. Facilities which generate domestic wastewater shall comply with the following provisions; domestic wastewater treatment facilities at permitted industrial sites are excluded.a. Whenever flow measurements for any domestic sewage treatment facility reach 75 percent of the permitted daily average or annual average flow for three consecutive months, the permittee must initiate engineering and financial planning for expansion and/or upgrading of the domestic wastewater treatment and/or collection facilities. Whenever the flow reaches 90 percent of the permitted daily average or annual average flow for three consecutive months, the permittee shall obtain necessary authorization from the Commission to commence construction of the necessary additional treatment and/or collection facilities. In the case of a domestic wastewater treatment facility which reaches 75 percent of the permitted daily average or annual average flow for three consecutive months, and the planned population to be served or the quantity of waste produced is not expected to exceed the design limitations of the---..treatinent-facility,-the-permittee-shall-submit-an-engineering-report supporting this-claim-to-the-Executive-Direttorof the Commission. If in the judgement of the Executive Director the population to be served will not cause permit noncompliance, then the requirement of this section may be waived. To be effective, any waiver must be in writing and signed by the Director of the Enforcement Division (MC 149) of the Commission, and such waiver of these requirements will be reviewed upon expiration of the existing permit; however, any such waiver shall not be interpreted as condoning or excusing any violation of any permit parameter.

b. The plans and specifications for domestic sewage collection and treatment works associated with any domestic permit must be approved by the Commission, and failure to secure approval before commencing construction of such works or making a discharge is a violation of this permit and each day is an additional violation until approval has been secured.c. Permits for domestic wastewater treatment plants are granted subject to the policy of the Commission to encourage the -development of area-wide waste collection, treatment and disposal systems. The Commission reserves the right to amend any domestic wastewater pernit in accordance with applicable procedural requirements to require the system covered by this permit to be integrated into an area-wide system, should such be developed; to require the delivery of the wastes authorized to be collected in, treated by or discharged from said system, to such area-wide system; or to amend this permit in any other particular to effectuate the Commission's policy. Such amendments may be made when the changes required are advisable for water quality control purposes and are feasible on the basis of waste treatment technology, engineering, financial, and related considerations existing at the time the changes are required, exclusive of the loss of investment in or revenues from any then existing or proposed waste collection, treatment or disposal system.9. Domestic wastewater treatmentplants shall be operated and maintainedby sewage plant operators holding a valid certificate of competency at the required level as defined in 30 TAC Chapter 30.10. For Publicly Owned Treatment Works (POTWs), the 30-day average (or monthly average) percent removal for BOD and TSS shall not be less than 85 percent, unless otherwise authorized by this permit.11. Facilities which generate industrial solid waste as defined in 30 TAC § 335.1 shall comply with these provisions:

a. Any solid waste, as defined in 30 TAC § 335.1 (including but not limited to such wastes as garbage, refuse, sludge from a waste treatment, water supply treatment plant or air pollution control facility, discarded materials, discarded materials to be recycled, whether the waste is solid, liquid, or semisolid), generated by the permittee during the management and treatment of wastewater, must be managed in accordance with all applicable provisions of 30 TAC Chapter 335, relating to Industrial Solid Waste Management.

b. Industrial wastewater that is being collected, accumulated, stored, or processed before discharge through any final discharge outfall, specified by this permit, is considered to be industrial solid waste until the wastewater passes through the actual point source discharge and must be managed in accordance with all applicable provisions of 30 TAC Chapter 335.c. The permittee shall provide written notification, pursuant to the requirements of 30 TAC § 335.8(b)(1), to the Corrective Action Section (MC 127) of the Remediation Division informing the Commission of any closure activity involving an Industrial Solid Waste Management Unit, at least 90 days prior to conducting such an activity.Page 9 STP Nuclear 0 1 g Company.peratin TPDES Permit No. WQOOO 1908000 d. Construction of any industrial solid waste management.unit requires the prior written notification of the proposed activity to the Registration and Reporting Section (MC 129) of the Registration, Review, and Reporting Division.

No person shall dispose of industrial solid waste, including sludge or other solids from wastewater treatment processes, prior to fulfilling the deed recordation requirements of 30 TAC § 335.5.e. The term "industrial solid waste management unit" means a landfill, surface impoundment, waste-pile, industrial furnace, incinerator, cement kiln, injection well, container, drum, salt dome waste containment cavern, or any other structure vessel, appurtenance, or other improvement on land used to manage industrial solid waste.f. The permittee shall keep management records for all sludge (or other waste) removed from any wastewater treatment process. These records shall fulfill all applicable requirements of 30 TAC Chapter 335 and must include the following, as it pertains to wastewater treatment and discharge:

i. Volume of waste and date(s) generated from treatment process;ii. Volume of waste disposed of on-site or shipped off-site;Wi. Date(s) of disposal;iv. Identity of hauler or transporter;

v. Location of disposal site; and vi. Method of final disposal.The abo records shall be on a monthly basis. The records shall be retained at the facility site, or shall be readily available for review by authorized representatives of the TCEQ for at least five years.12. For industrial facilities to which the requirements of 30 TAC Chapter 335 do not apply, sludge and solid wastes, including tank cleaning and contaminated solids for disposal, shall be disposed of in.accordance with Chapter 361 of the Texas Health and Safety Code.TCEQ Revision 05/2004 Page 10 STP Nuclear 0perating Company TPDES Permit No. WQ0001908000 OTHER REQUIREMENTS I. The Executive Director has reviewed this action for consistency with the goals and policies of the Texas Coastal Management Program (CMP) in accordance with the regulations of the Coastal Coordination Council (CCC) and has determined that the action is consistent with the applicable CMP goals and policies.2. Violations of daily maximum limitations for the following pollutants shall be reported orally or by facsimile to TCEQ Region 12, within 24 hours from the time the permittee becomes aware of the violation followed by a written report within five working days to TCEQ Region 12 Office and the Enforcement Division (MC 224): POLLUTANT MAL (mal1)Copper, Total 0.010 Iron, Total -...--Test methods utilized shall be sensitive enough to demonstrate compliance with the permit effluent limitations.

Permit compliance/noncompliance determinations will be based on the effluent limitations contained in this permit with consideration given to the MAL for the parameters specified above.When an analysis of an-effluent sample for any of the parameters listed above indicates no detectable levels above the MAL and the test method detection level is as sensitive as the specified MAL, a value of zero (0)shall be used for that measurement when determining calculations and reporting requirements for the self-reporting form. This applies to determinations of daily maximum concentration, calculations of loading and daily averages, and other reportable results.When a reported value is zero (0) based on this MAL provision, the permittee shall submit the following statement with the self-reporting form either as a separate attachment to the form or as a statement in the comments section of the form."The reported value(s) of zero (0) for [list parameter(s)] on the self-reporting form for the term of this permit is based on the following conditions:

1) the analytical method used had a method detection level as sensitive as the MAL specified in the permit, and 2) the analytical results contained no-detectable levels above the specified MAL." When an analysis of an effluent sample for a parameter indicates no detectable levels and the test method detection level is not as sensitive as the MAL specified in the permit, or an MAL is not specified in the permit for that parameter, the level of detection achieved shall be used for that measurement when determining calculations and reporting requirements for.the self-reporting form. A zero (0) may not be used.3. The discharges from sources such as reservoir relief wells, reservoir spillway gate leakage, condenser box drainage, ground water monitoring wells, and process monitoring instrumentation are authorized.

These sources may discharge to the Colorado River, to the West Branch of the Colorado River, to Little Robbins Slough and the East Fork of Little Robbins Slough.4. For Outfall 001, the discharge from the cooling pond shall not exceed 12.5% of the flow of the Colorado River at the discharge point and there shall be no discharge from Outfall 001 when the receiving water flow adjacent to the plant is less than 800 cubic feet per second.5. Total Residual Chlorine: The term "total residual chlorine" (or total residual oxidants for intake water with bromides) means the value obtained using the amperometric method for total residual chlorine described in 40 CFR Part 136. The permittee may use the DPD spectrophotometric method (EPA Method 330.5) upon written notification of the Executive Director, provided that EPA has modified the existing effluent limitation guidelines (40 CFR Part 423) or has provided the permittee with demonstration that this new method is appropriate for use by steam electric power generating facilities. Total residual chlorine may not be discharged from any single generating unit for more than two hours per day unless the discharger demonstrates to the permitting authority that discharge for more than two hours is required for macroinvertebrate control.Simultaneous multi-unit chlorination is permitted. Page 11 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 6. There shall be no discharge of polychlorinated biphenyl transformer fluid.7. The term "metal cleaning waste" means any wastewater resulting from cleaning (with or without chemical compounds) any metal process equipment including, but not limited to, boiler tube cleaning, boiler fireside cleaning, and air preheater cleaning.8. The term "chemical metal cleaning waste" means any wastewater resulting from the cleaning of any metal process equipment with chemical compounds, including, but not limited to, boiler tube cleaning.9. For the purposes of this permit, daily temperature discharge is defined as the flow weighted average temperature (FWAT) and shall be computed and recorded on a daily basis. FWAT shall be computed at equal time intervals not greater than two hours. The method of calculating FWAT is as follows: Y.(INSTANTANEOUS FLOW X INSTANTANEOUS TEMPERATURE) _(LNSTANTANEOUS FLOW)"Daily average temperature" shall be the arithmetic average of al!_WATsealculatedduring the calender.rioiurli. ",Dailyj maximum temperature" shall be the highest FWAT calculated during the calender month.10. The term "low volume waste sources" means, taken collectively as if from one source, wastewaters from all sources except those for which specific limitations are otherwise established. Low volume waste sources include but are not limited to: wet scrubber air pollution controt systems, ion exchange wate treatment systems, water treatment evaporator blowdown, laboratory and sampling streams, boiler blowdown, floor drains, cooling tower basin cleaning wastes and blowdown from recirculating house service water systems. Sanitary and air conditioning wastes are not included.11. This provision supersedes and replaces Provision 1, Paragraph 1 of Monitoring and Reporting Requirements found on Page 4 of this permit.Monitoring results shall be provided at the intervals specified in the permit. Unless otherwise specified in this permit or otherwise .ordered by the Commission, the permittee shall conduct effluent sampling and reporting in accordance with 30 TAC §§319.4 -319.12. Unless otherwise specified, a monthly effluent report shall be submitted each month, to the location(s) specified on the reporting form or the instruction sheet, by the 25th day of-the following month for each discharge which is described by this permit whether or not a discharge is made for that month. Monitoring results must be reported on the approved TPDES self-reporting form, Discharge Monitoring Report (DMR) Form EPA No. 3320-1, signed and certified as required by Monitoring and Reporting Requirements No. 10.12. The mixing zone is defined as a volume within a radius of 60 feet extending over the receiving waters from the point where discharge from each jet port enters the Colorado River.. Chronic toxic criteria apply at the edge of the mixing zone.13. Daily average concentration shall mean the arithmetic average (weighted by flow) of all effluent samples, composition or grab as required by this permit within a period of one calender month, consisting of at least four separate representative measurements. When four samples are not available in a calender month, the arithmetic average (weighted by flow) of the four most recent measurements or arithmetic average (weighted by flow) of all values taken during the month shall be utilized as the daily average concentration. The provision supersedes and replaces Provision 2(a), Daily Average Concentration, as defined on page 3 of this permit.14. The permittee shall comply with the Cooling Water Intake regulations found in Title 40 Code of Federal Regulations Part 125, Subpart J. These regulations include, but are not limited to the following provisions:

a. the permittee shall submit four copies of the Proposal for Information Collection to the Industrial Team (MC-148) of the Water Quality Division prior to the start of information collection activities, and b. the permittee shall submit four copies of the completed Comprehensive Demonstration Study (if required by 40 CFR Part 125, Subpart J) to the Industrial Team (MC-148) of the Water Quality Division no later than January 7, 2008.Page 12

.STP Nuclear Operating Company TPDES Permit No. WQOO0 1908000 The permittee shall meet all other applicable requirements of this regulation.

15. Wastewater discharged via Outfall 001 shall be sampled and analyzed for those parameters listed on Attachment I (Tables 1, 2, and 3) of this permit for a minimum of four (4) separate sampling events which are a minimum of one (1) week apart. Attachment 1 (Tables 1, 2 and 3) shall be completed with the analytical results for each outfall and sent to the TCEQ, Wastewater Permiting Section (MC-148), Industrial Team.Analytical testing for Outfall 001 shall be conducted with first available discharge events following permit issuance.

Based on a technical review of the submitted analytical results, an amendment may be initiated by TCEQ staff to include additional effluent limitations and/or monitoring requirements. Page 13 STP Nuclear Operating Company TPDES Permit No. WQ0001908000 ATTACHMENT 1 TARIr 1w Outfall No.: [IC []G Effluent Concentration m( )Pollutants Samip. 1 Samp. 2 Samp. 3 Samp. 4 Average BOD (5-day)CBOD (5-day)Chemical Oxygen Demand Total Organic Carbon Ammonia Nitrogen Total Suspended Solids Nitrate Nitrogen Total Organic Nitrogen Total-Phosphorus-Oil and Grease Total Residual Chlorine Total Dissolved Solids Sulfate Chloride Fluoride Fecal Coliform Temperature (OF)pH (Standard Units; min/max)Effluent Concentration (tg/1) MAL (Itgfi)Total Aluminum 30 Total Antimony 30 Total Arsenic 10 Total Barium 10 Total Beryllium 5 Total Cadmium I Total Chromium 10 Trivalent Chromium N/A Hexavalent Chromium 10 Total Copper 10 Cyanide 20 Total Lead 5 Total Mercury 0.2 Total Nickel 10 Total Selenium 10 Total Silver 2.0 Total Thallium 10 Total Zinc 5 Page 14 STP Nuclear Operating Company TPDES Permit No. WQ0001908000 ATTACHMENT I TALE 2: Outfall No.: D]C OIG Effluent Concentration (gfl) (*I Pollutants Samp. 1 Samp. 2 Samp. 3 Samp. 4 Average. MAL Benzene 10 Benzidine 50 Benzo(a)anthracene 10 Benzo(a)pwrene 10 Carbon Tetrachloride 10 Chlorobenzene 10 Chloroform ._10.Chrysene 10-C reso ls -------.. .-Dibromochloromethane 10 1,2-Dibromoethane __2 1,4-Dichlorobenzene 1 10 1,2-Dichloroethane 10 1 ,1-Dichloroethylene 10 Fluoride 500 Hexachlorobenzene 10 Hexachlorobutadiene 10 Hexachloroethane 20 Methyl Ethyl Ketone ....._50 Nitrobenzene 10 n-Nitrosodiethylamine 20 n-Nitroso-di-n-Butylamine 20 PCB's, Total (*3) 1 Pentachlorobenzene 20 Pentachlorophenol 50 Phenanthrene 10 Pyridine 20 1,2,4,5-Tetrachlorobenzene 20 Tetrachloroethylene 10 Trichloroethylene _10 11,,1 -Trichloroethane 10 2,4,5-Trichlorophenol 50 TTHM (Total Trihalomethanes) 10 Vinyl Chloride 10 (*1) Indicate units if different from jig/I.(*2) MAL's for Cresols: p-Chloro-m-Cresol 10 [ig/1; 4,6-Dinitro-o-Cresol 50 lIg/l; p-Cresol 10 [ig/l (*3) Total of PCB-1242, PCB-1254, PCB-1221, PCB-1232, PCB-1248, PCB-1260, PCB-1016.Page 15 STP Nuclear Operating Company TPDES Permit No. WQ0001908000 ATTACHMENT 1 TARIE -I-Outfall No.: -0C EIG Believed Believed Effluent Concentration (mU/l) -Pollutants Present Absent Average Maximum No. of Samples Bromide Color (PCU)Nitrate-Nitrite(as N)Sulfide(as S)Sulfite(as $03)Surfactants _Total Antimony.Total Beryllium-T6tallBoro -" Total Cobalt Total Iron Total Magnesium Total Molybdenum Total Manganese Total Thallium Total Tin Total Titanium -.Page 16 _STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 CHRONIC BIOMONITORING REOUTIREMENTS: MARINE The provisions of this Section apply to Outfall 001 for whole effluent toxicity testing (biomonitoring).

1. Scope, Frequency and Methodology

a. The permittee shall test the effluent for toxicity in accordance with the provisions below. Such testing will determine if an appropriately dilute effluent sample adversely affects the survival, reproduction, or growth of the test organisms.

b. The permittee shall conduct all toxicity tests utilizing the test organisms, procedures, and quality assurance requirements specified below and in accordance with "Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Marine and Estuarine Organisms, Third Edition" (EPA-821 -R-02-014), or the most recent update thereof: 1) Chronic static renewal 7-day survival and growth test using the mysid shrimp (Mysidopsis bahia) (Method 1007.0 or the most recent update thereof).

A minimum of eight replicates with five organisms per replicate shall be used in the control and in each dilution. This test shall be condiimtd onc-per quarter.2) Chronic static renewal 7-day larval survival and growth test using the inland silverside (Menidia beryllina) (Method 1006.0 or the most recent update thereof). A minimum of five replicates with eight organisms per replicate shall be used in the control and in each dilution.This test shall be conducted once per quarter.The permittee must perform and report a valid test for each test species during the prescribed reporting period. An invalid test must be repeated during the same reporting period. An invalid test isherein defined as any test failing to satisfy the test acceptability criteria, including Percent Minimum Significant Difference (PMSD) boundary requirements, procedures, and quality assurance requirements specified in the test methods and permit. All test results, valid or invalid, must be submitted as described below.c. The permittee shall use five effluent dilution concentrations and a control in each toxicity test. These additional effluent concentrations are 5%, 7%, 10%, 13%, and 17% effluent. The critical dilution, defined as 13% effluent, is the effluent concentration representative of the proportion of effluent in the receiving water during critical low flow or critical mixing conditions.

d. This permit may be amended to require a Whole Effluent Toxicity (WET) limit, Chemical-Specific (CS) limits, a Best Management Practice (BMP), additional toxicity testing, and/or other appropriate actions to address toxicity.

The permittee may be required to conduct additional biomonitoring tests and/or a Toxicity Reduction Evaluation (TRE) if biomonitoring data indicate multiple numbers of unconfirmed toxicity events.e. Testing Frequency Reduction 1) If none of the first four consecutive quarterly tests demonstrates significant lethal or sub-lethal effects, the permittee may submit this information in writing and, upon approval from the Water Quality Standards Team, reduce the testing frequency to once per six months for the invertebrate test species and once per year for the vertebrate test species.2) If one or more of the first four consecutive quarterly tests demonstrates significant sub-lethal effects, the permittee shall continue quarterly testing for that species until four consecutive quarterly tests demonstrate no significant sub-lethal effects. At that time, the permittee may apply for the appropriate testing frequency reduction for that species.3) If one or more of the first four consecutive quarterly tests demonstrates significant lethal effects, the permittee shall continue quarterly testing for that species until the permit is reissued.If a testing frequency reduction had been previously granted and a subsequent test demonstrates significant lethal effects, the permittee will resume a quarterly testing frequency for that species until the permit is reissued.Page 17 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 2. Required Toxicity Testing Conditions

a. Test Acceptance

-The permittee shall repeat any toxicity test, including the control and all effluent dilutions, which fails to meet any of the following criteria: 1) a control mean survival of 80% or greater;2) a control mean dry weight of surviving mysid shrimp of 0.20 mg or greater;3) a control mean dry weight for surviving unpreserved inland silverside of 0.50 mg or greater and (0.43 mg or greater for surviving preserved inland silverside.

4) a control Coefficient of Variation percent (CV%) between replicates of 40 or less in the in the growth and survival tests.5) a critical dilution CV% of 40 or less in the growth and survival endpoints for either growth and survival test. However, if statistically significant lethal or nonlethal effects are exhibited at the critical dilution,_a CV% _greater than_40 shall not'inalidatethe-test.....

6) a PMSD range of 11 -37 for mysid shrimp growth;7) a PMSD range of 11 -28 for inland silverside growth.b. Statistical Interpretation

1) For the mysid shrimp and the inland silverside larval survival and growth tests, the statistical analyses used to determine if there is a significant difference between the control and an effluent dilution shall be in accordance with the methods described in the "Short-Term Methods for-Estimating the Chronic Toxicity of Effluents and Receiving Waters to Marine and Estuarine Organisms, Third Edition" (EPA-821-R-02-014), or the most recent update thereof.2) The permittee is responsible for reviewing test concentration-response relationships to ensure that calculated test-results are interpreted and reported correctly.

The EPA manual, "Method Guidance and Recommendation for Whole Effluent Toxicity (WET) Testing (40 CFR Part 136)" (EPA 821-13-00-004) provides guidance on determining the validity of test results.3) If significant lethality is demonstrated (that is, there is a statistically significant difference in survival at the critical dilution when compared to the control), the conditions of test acceptability are met, and the survival of the test organisms are equal to or greater than 80% in the critical dilution and all dilutions below that, then the permittee shall report a survival No Observed Effect Concentration (NOEC) of not less than the critical dilution for the reporting requirements.

4) The NOEC is defined as the greatest effluent dilution at which no significant effect is demonstrated.

The Lowest Observed Effect Concentration (LOEC) is defined as the lowest effluent dilution at which a significant effect is demonstrated. A significant effect is herein defined as a statistically significant difference at the 95% confidence level between the survival, reproduction, or growth of the test organism(s) in a specified effluent dilution compared to the survival, reproduction, or growth of the test organism(s) in the control (0% effluent).

5) The use of NOECs and LOECs assumes either a monotonic (continuous) concentration-response relationship or a threshold model of the concentration-response relationship.

For any test result that demonstrates a non-monotonic (non-continuous) response, the NOEC should be determined based on the guidance manual referenced in Item 3 above and a full report will be submitted to the Water Quality Standards Team 6) Pursuant to the responsibility assigned to the permittee in Part 2.b.2), test results that demonstrate a non-monotonic (non-continuous) concentration-response relationship may be submitted, prior to the due date, for technical review. The above-referenced guidance manual will be used when making a determination of test acceptability Page 18 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 7) The Water Quality Standards Team will review test results (i.e., Table I and Table 2 forms) for consistency with established TCEQ rules, procedures, and permit requirements.

c. Dilution Water 1) Dilution water used in the toxicity tests shall be the receiving water collected as close as possible to the discharge point, but unaffected by the discharge.

2) Where the receiving water proves unsatisfactory as a result ofpre-existing instream toxicity (i.e.fails to fulfill the test acceptance criteria of item 2.a.), the permittee may substitute synthetic dilution water for the receiving water in all subsequent tests provided the unacceptable receiving water test met the following stipulations:

a) a synthetic lab water control was performed (in addition to the receiving water control)which fulfilled the test acceptance requirements of item 2.a;b) the test indicating receiving water toxicity was carried out to completion (i.e., 7 days);-------.c) thepermittee-submitted all-test results-indicating-receivvmg-water-toxxicity-with-thereports-- and information required in Part 3.Upon approval, the permittee may substitute other appropriate dilution water with chemical and physical characteristics similar-to that of the receiving water.d. Samples and Composites

1) The permittee shall collect a minimum of three flow-weighted 24-hour composite samples from Outfall 001. The second and.third 24-hour composite samples will be used for the renewal of the dilution concentrations for each toxicity test. A 24-hour composite sample consists of a minimum of 12 effluent portions collected at equal time intervals representative of a 24-hour operating day and combined proportionally to flow, or a sample continuously collected proportionally to flow over a 24-hour operating day.2) The permittee shall collect the 24-hour composite samples such that the samples are representative of any periodic episode of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent basis.3) The permittee shall initiate the toxicity tests within 36 hours after collection of the last portion of the first 24-hour composite sample. The holding time for any subsequent 24-hour composite sample shall not exceed 72 hours. Samples shall be maintained at a temperature of 0-6 degrees Centigrade during collection, shipping, and storage.4) If flow from the outfall being tested ceases during the collection of effluent samples, the requirements for the minimum number of effluent samples, the minimum number of effluent portions, and the sample holding time, are waived during that sampling period. However, the permittee must have collected an effluent composite sample volume sufficient to complete the required toxicity tests with daily renewal of the effluent.

When possible, the effluent samples used for the toxicity tests shall be collected on separate days if the discharge occurs over multiple days. The effluent composite sample collection duration and the static renewal protocol associated with the abbreviated sample collection must be documented in the full report required in Part 3 of this Section.3. Reporting All reports, tables, plans, summaries, and related correspondence required in any Part of this Section shall be submitted to the attention of the Water Quality Standards Team (MC 150) of the Water Quality Division.All DMRs, including DMRs with biomonitoring data, should be sent to the Water Quality Compliance Monitoring Team of the Enforcement Division (MC 224).a. The permittee shall prepare a full report of the results of all tests conducted pursuant to this permit in accordance with the Report Preparation Section of "Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Marine and Estuarine Organisms, Third Edition" (EPA-Page 19 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 821-R-02-014), or the most recent update thereof, for every valid and invalid toxicity test initiated whether carried to completion or not. All full reports shall be retained for 3 years at the plant site and shall be available for inspection by TCEQ personnel.

b. A full report must be submitted with the first valid biomonitoring test results for each test species and with the first test results any time the permittee subsequently employs a different test laboratory.

Full reports need not be submitted for subsequent testing unless specifically requested. The permittee shall routinely report the results of each biomonitoring test on the Table 1 forms provided with this permit.All Table 1 reports must include the information specified in the Table I form attached to this permit.1) Annual biomonitoring test results are due on or before January 20th for biomonitoring conducted during the previous 12 month period.2) Semiannual biomonitoring test results are due on or before July 20th and January 20th for biomonitoring conducted during the previous 6 month period.3) Quarterly biomonitoring test results are due on or before April 20th, July 20th, October 20th, and January 20th, for biomonitoring conducted during the previous calendar quarter.4) Monthly biomonitoring test results are due on or before the 20th day of the month following sampling.c. Enter the following codes on the DMR for the appropriate parameters for valid tests only: 1) For the mysid shrimp, Parameter TLP3E, enter a "1" if the NOEC for survival is less than the critical dilution; otherwise, enter a "0." 2) For the mysid shrimp, Parameter TOP3E, report the NOEC for survival.3) For the mysid shrimp, Parameter TXP3E, report the LOEC for survival.4) For the mysid shrimp, Parameter TWP3E, enter a "I" if the NOEC for growth is less than the critical dilution; otherwise, enter a "0." 5) For the mysid shrimp, Parameter TPP3E, report the NOEC for growth.6) For the mysid shrimp, Parameter TYP3E, report the LOEC for growth.7) For the inland silverside, Parameter TLP6B,enter a " 1" if the NOEC for survival is less than the critical dilution; otherwise, enter a "0." 8) For the inland silverside, Parameter TOP6B, report the NOEC for survival.9) For the inland silverside, Parameter TXP6B, report the LOEC for survival.10) For the inland silverside, Parameter TWP6B,enter a " 1" if the NOEC for growth is less than the critical dilution; otherwise, enter a "0." 11) For the inland silverside, Parameter TPP6B, report the NOEC for growth.12) For the inland silverside, Parameter TYP6B, report the LOEC for growth d. Enter the following codes on the DMIR for retests only: 1) For retest number 1, Parameter 22415, enter a "I" if the NOEC for survival is less than the critical dilution; otherwise, enter a "0." 2) For retest number 2, Parameter 22416, enter a "1" if the NOEC for survival is less than the critical dilution; otherwise, enter a "0." Page 20 STP Nuclear Operating Company TPDES Permit No. WQ0001908000

4. Persistent Toxicity The requirements of this Part apply only when a test demonstrates a significant effect at the critical dilution.A significant effect is defined as a statistically significant difference, at the 95% confidence level, between a specified endpoint (survival, growth, or reproduction) of the test organism in a specified effluent dilution when compared to the specified endpoint of the test organism in the control. Significant lethality is defined as a statistically significant difference in survival at the critical dilution when compared to the survival of the test organism in the control. Significant sublethality is defined as a statistically significant difference in growth/reproduction at the critical dilution when compared to the growth/reproduction of the test organism in the control.a. The permittee shall conduct a total of 2 additional tests (retests) for any species that demonstrates a significant effect (lethal or sublethal) at the critical dilution.

The two retests shall be conducted monthly during the next two consecutive months. The permittee shall not substitute either of the two retests in lieu of routine toxicity testing. All reports shall be submitted within 20 days of test completion. Test completion is defined as the last day of the test. The retests shall also be reported on the DMRs as specified in Part 3.d.-b.-- --fhf- t-ets-.arge--e-rf-rned~due-to-a-demonstration-of.significant-lethality and-one-orboth-ofthe-two-retests specified in item 4.a. demonstrates significant lethality, the permittee shall initiate the TRE requirements as specified in Part 5. The provisions of item 4.a. are suspended upon completion of the two retests and submittal of the TRE Action Plan and Schedule defined in Part 5.If neither test demonstrates significant lethality and the permittee is testing under the reduced testing frequency provision of Part I.e., the permittee shall return to a quarterly testing frequency. for that species.c. If the two retests are performed due to a demonstration of significant sublethality, and one or. both of the two retests specified in item 4.a. demonstrates significant lethality, the permittee shall again perform two retests as stipulated in item 4.a.d. If the- two retests are performed due to a demonstration of significant sublethality, and both retests pass, the permittee shall continue testing at the quarterly frequency until such time that the permittee. can invoke the reduced testing frequency provision specified in Part L.e.e. Regardless of whether retesting for lethal or sublethalIeffects, or a combination of the two, no more than one retest per month is required for a species.5. Toxicity Reduction Evaluation

a. Within 45 days of the last test day of the retest that demonstrates significant lethality, the permittee shall submit a General Outline for initiating a TRE. The outline shall include, but not be limited to, a description of project personnel, a schedule for obtaining consultants (if needed), a discussion of influent and/or effluent data available for review, a sampling and analytical schedule, and a proposed TRE initiation date.b. Within 90 days of the last test day of the retest that demonstrates significant lethality, the permittee shall submit a TRE Action Plan and Schedule for conducting a TRE. The plan shall specify the approach and methodology to be used in performing the TRE. A Toxicity Reduction Evaluation is a step-wise investigation combining toxicity testing with physical and chemical analysis to determine actions necessary to eliminate or reduce effluent toxicity to a level not effecting significant lethality at the critical dilution.

The TRE Action Plan shall lead to the successful elimination of significant lethal effects at the critical dilution for both test species defined in item I.b. As a minimum, the TRE Action Plan shall include the following: I) Specific Activities -The TRE Action Plan shall specify the approach the permittee intends to utilize in conducting the TRE, including toxicity characterizations, identifications, confirmations, source evaluations, treatability studies, and/or alternative approaches. When conducting characterization analyses, the permittee shall perform multiple characterizations and follow the procedures specified in the document entitled, "Toxicity Identification Evaluation: Characterization of Chronically Toxic Effluent, Phase I" (EPA/600/6-91/005F), or alternate procedures. The permittee shall perform multiple identifications and follow the methods Page 21 STP Nuclear Operating Company TPDES Permit No. WQOO0 1908000 specified in the documents entitled, "Methods for Aquatic Toxicity Identification Evaluations, Phase II Toxicity Identification Procedures for Samples Exhibiting Acute and Chronic Toxicity" (EPA/600/R-92/080) and "Methods for Aquatic Toxicity Identification Evaluations, Phase Ill Toxicity Confirmation Procedures for Samples Exhibiting Acute and Chronic Toxicity" (EPA/600/R-92/08 1). All characterization, identification, and confirmation tests shall be conducted in an orderly and logical progression;

2) Sampling Plan -The TRE Action Plan should describe sampling locations, methods, holding times, chain of custody, and preservation techniques.

The effluent sample volume collected for all tests shall be adequate to perform the toxicity characterization/ identification! confirmation procedures, and chemical-specific analyses when the toxicity tests show significant lethality. Where the permittee has identified or suspects specific pollutant(s) and/or source(s) of effluent toxicity, the permittee shall conduct, concurrent with toxicity testing, chemical-specific analyses for the identified and/or suspected pollutant(s) and/or source(s) of effluent toxicity;3) Quality Assurance Plan -The TRE Action Plan should address record keeping and data evaluation, calibration and standardization, baseline tests, system blanks, controls, duplicates,--..----. spikes,-tox-icity-_persistenceein-:the:samplesrandomization; referencetoxicatt -cntrol ha-tsas well as.mechanisms to detect artifactual toxicity; and 4) Project Organization -The TRE Action Plan should describe the project staff, project manager, consulting engineering services (where applicable), consulting analytical and toxicological services, etc.c. Within 30 days of submittal of the TRE Action Plan and Schedule, the permittee shall implement the TRE with due diligence.

d. 'Te permittee shall submit quarterly TRE Activities Reports concerning the progress of the TRE. The quarterly reports are due on or before April 20th, July 20th, October 20th, and January 20th. The report shall detail information regarding the TRE activities including:

1) results and interpretation of any chemical-specific analyses for the identified and/or suspected pollutant(s) performed during the quarter;2) results and interpretation of any characterization, identification, and confirmation tests performed during the quarter;3) any data and/or substantiating documentation which identifies the pollutant(s) and/or source(s)of effluent toxicity;4) results of any studies/evaluations concerning the treatability of the facility's effluent toxicity;5) any data which identifies effluent toxicity control mechanisms that will reduce effluent toxicity to the level necessary to meet no significant lethality at the critical dilution; and 6) any changes to the initial TRE Plan and Schedule that are believed necessary as a result of the TRE findings.Copies of the TRE Activities Report shall also be submitted to the U.S. EPA Region 6 office.e. During the TRE, the permittee shall perform, at a minimum, quarterly testing using the more sensitive species; testing for the less sensitive species shall continiue at the frequency specified in Part 1 .b.f. If the effluent ceases to effect significant lethality (herein as defined below) the permittee may end the TRE. A "cessation of lethality" is defined as no significant lethality for a period of 12 consecutive months with at least monthly testing. At the end of the 12 months, the permittee shall submit a statement of intent to cease the TRE and may then resume the testing frequency specified in Part 1 .b.The permittee may only apply the "cessation of lethality" provision once.This provision accommodate situations where operational errors and upsets, spills, or sampling errors triggered the TRE, in contrast to a situation where a single toxicant or group of toxicants cause Page 22 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 lethality.

This provision does not apply as a result of corrective actions taken by the permittee."Corrective actions" are herein defined as proactive efforts which eliminate or reduce effluent toxicity.These include, but are not limited to, source reduction or elimination, improved housekeeping, changes in chemical usage, and modifications of influent streams and/or effluent treatment. The permittee may only apply this cessation of lethality provision once. If the effluent again demonstrates significant lethality to the same species, the permit will be amended to add a WET limit with a compliance period, if appropriate. However, prior to the effective date of the WET limit, the permittee may apply for a permit amendment removing and replacing the WET limit with an alternate toxicity control measure by identifying and confirming the toxicant and/or an appropriate control measure.g. The permittee shall complete the TRE and submit a Final Report on the TRE Activities no later than 28 months from the last test day of the retest that confirmed significant lethal effects at the critical dilution. The permittee may petition the Executive Director (in writing) for an extension of the 28-month limit. However, to warrant an extension the permittee must have demonstrated due diligence in their pursuit of the TIE/TRE and must prove that circumstances beyond their control stalled the TIE/TRE. The report shall provide information pertaining to the specific control mechanism(s) on-oeduct-i.n-9f effluent-toxicity-to-no-significant-lethality-at the critical dilution. The report will also provide a specific corrective action schedule for implementing the selected control mechanism(s). A copy of the TRE Final Report shall also be submitted to the U.S. EPA Region 6 office.h. Based upon the results of the TRE and proposed corrective actions, this permit may be amended to modify the biomonitoring requirements, where necessary, to require a compliance schedule for implementation of corrective actions, to specify a WET limit, to specify a BMP, and/or to specify CS limits.Page 23 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 TABLE I (SWEET 1 OF 4)MYSID SHRIMP SURVIVAL AND GROWTH Dates and Times Composites Collected Date Time No. 1 FROM: No. 2 FROM: No. 3 FROM: Date Time TO: TO: TO: Test initiated: anm/pm __date Dilution water used:.Receiving water___ Synthetic Dilution water MYSID SHRIMP SURVIVAL-Pei&&n PctSiram Mexecent:I ': -...* coefficient of variation = standard deviation x 100/mean DATA TABLE FOR GROWTH OF MYSID SHRIMP Ate-- -:w ":. i -b"s'Re'nl.. icateB. .. M at eihtinx-iiigansn i.ae.!?ie,. f.' -. :...- ' .: .. ..% : .:i ..:' ,'A B. .C: D .: 3*.,: ." ..Page 24 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 TABLE 1 (SHEET 2 OF 4)MYSID SHRIMP SURVIVAL AND GROWTH DATA TABLE FOR GROWTH OF MYSID SHRIMP (Continued).Repliate .M. ders1.7%..-, G-MeanDyWih ' -:.: -.- ... "__?"-__ ___.__Acceptable Range 11-37* coefficient of variation = standard deviation x 100/mean 1. Dunnett's Procedure or Steel's Many-One Rank Test or Wilcoxon Rank Sum Test (with Bonferroni adjustment) or t-test (with Bonferroni adjustment)- as appropriate: Is the mean survival at 7 days significantly less (p1=0.05) than the control survival for the % effluent corresponding to lethality? CRITICAL DILUTION (13%): -YES NO 2. Dunnett's Procedure or Steel's Many-One Rank Test or Wilcoxon Rank Sum Test (with Bonferroni adjustment) or t-test (with Bonferroni adjustment) as appropriate: Is the mean dry weight (growth) at 7 days significantly less (p=0.05) than the control's dry weight (growth) for the % effluent corresponding to non-lethal effects?CRITICAL DILUTION (13%): YES NO 3. Enter percent effluent corresponding to each NOEC/LOEC below: a.) NOEC survival = % effluent b.) LOEC survival = % effluent c.) NOEC growth = % effluent d.) LOEC growth = % effluent Page 25 STP Nuclear Operating Company TPDES Permit No. WQOOO1908000 TABLE 1 (SHEET 3 OF 4)INLAND SILVERSIDE LARVAL SURVIVAL AND GROWTH TEST Date Time Date Time Dates and Times No. I FROM: TO: Composites Collected No. 2 FROM: TO: No. 3 FROM: TO: Test initiated: anm/pm date Dilution water used: _ Receiving water __ Synthetic Dilution water* coefficient of variation = standard deviation x 100/mean Page 26 STP Nuclear Operating Company TPDES Permit No. WQ0001908000 TABLE 1 (SHEET 4 OF 4)INLAND SILVERSIDE LARVAL SURVIVAL AND GROWTH TEST INLAND SILVERSIDE GROWTH Av~tge ry-Wigh inMean--Percent Anwogam nr ict hmers _____I)~Effluent 1 D- B () CV% ._5%/'13A'Al Acceptable Range 11 -28*coefficient of variation =standard deviation x 100/mean Weights are for: preserved larvae, or unpreserved larvae 1. Dunnett's Procedure or Steel's Many-One Rank Test or Wilcoxon Rank Sum Test (with Bonferroni adjustment) or t-test (with Bonferroni adjustment) as appropriate: Is the mean survival at 7 days significantly less (p=0.0 5) than the control survival for the % effluent corresponding to lethality? CRITICAL DIDLUTION (13%): YES NO 2. Dunnett's Procedure or Steel's Many-One Rank Test or Wilcoxon Rank Sum Test (with Bonferroni adjustment) or t-test (with Bonferroni adjustment) as appropriate: Is the mean dry weight (growth) at 7 days significantly less (p=0.05) than the control's dry weight (growth) for the % effluent corresponding to non-lethal effects?CRITICAL DILUTION (13%): _ _YES _ _NO 3. Enter percent effluent corresponding to each NOEC/LOEC below: a.) NOEC survival = _ ___% effluent b.) LOEC survival = _ ___% effluent c.) NOEC growth = _ ___% effluent d.) LOEC growth = % effluent Page 27 STP Nuclear Operating Company TPDES Permit No. WQ0001908000 24-HOUR ACUTE BIOMONITOR]NG REOUIREMENTS: MARINE The provisions of this Section apply individually and separately to Outfall 001 for whole effluent toxicity testing (biomonitoring). No samples or portions of samples from one outfall may be composited with samples or portions of samples from another outfall.I Scope, Frequency and Methodology

a. The permittee shall test the effluent for lethality in accordance with the provisions in this Section.Such testing will determine compliance with the Surface Water Quality Standard, 30 TAC§307.6(e)(2)(B), of greater than 50% survival of the appropriate test organisms in 100% effluent for a 24-hour period.b. The toxicity tests specified shall be conducted once per six months. The permittee shall conduct the following toxicity tests utilizing the test organisms, procedures, and quality assurance requirements specified in this section of the permit and in accordan e-with"Methods-for-Measuring--the-Acute-

..... Effl-rits and Receiving to Freshwater and Marine Organisms, Fifth Edition" (EPA-82 1 -R-02-012), or the most recent update thereof: 1) Acute 24-hour static toxicity test using the mysid shrimp (Mysidopsis bahia). A minimum of five replicates with eight organisms per replicate shall be used in the control and in each dilution.2) Acute 24-hour static toxicity test using the inland silverside (Menidia beryllina). A minimum of five replicates with eight organisms per replicate shall be used in the control and in each dilution.The permittee must perform and report a valid test for each test species during the prescribed reporting period. An invalid test must be repeated during the same reporting period. An invalid test is herein defined as any test failing to satisfy the test acceptability criteria, procedures, and quality assurance requirements specified in the test methods and permit. All test results, valid or invalid, must be submitted as described below.c. In addition to an appropriate control, a 100% effluent concentration shall be used in the toxicity tests.Except as discussed in item 2.b., the control and/or dilution water shall consist of a standard, synthetic, moderately hard, reconstituted water.d. This permit may be amended to require a Whole Effluent Toxicity (WET) limit, a Best Management Practice (BMP), a Chemical-Specific (CS) limit, additional toxicity testing, and/or other appropriate actions to address toxicity. The permittee may be required to conduct additional biomonitoring tests and/or a Toxicity Reduction Evaluation (TRE) if biomonitoring data indicate multiple numbers of unconfirmed toxicity events.e. If the biomonitoring dilution series specified in the Chronic biomonitoring requirements includes a 100% effluent concentration, those results may fulfill the requirements of this Section. The results of any test with a 100% effluent concentration performed in the proper time interval may be substituted in lieu of performing a separate 24-hour acute test. Compliance will be evaluated as specified in item a. The greater than 50% survival in 100% effluent for a 24-hour period standard applies to all tests utilizing a 100% effluent dilution, regardless of whether the results are submitted to comply with the minimum testing frequency defined in item b.2. Required Toxicity Testing Conditions

a. Test Acceptance

-The permittee shall repeat any toxicity test, including the control, if the control fails to meet a mean survival equal to or greater than 90%.b. Dilution Water -In accordance with item I .c., the control and/or dilution water shall normally consist of a standard, synthetic, reconstituted seawater. If the permittee is utilizing the results of a 48-Hour Acute test or a Chronic test to satisfy the requirements in item L .e., the pernuttee may use the receiving Page 28 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 water or dilution water that meets the requirements of item 2.a. as the control and dilution water.c. Samples and Composites

1) The permittee shall collect one flow-weighted 24-hour composite sample from Outfall 001. X 24-hour composite sample consists of a minimum of 12 effluent portions collected at equal time intervals representative of a 24-hour operating day and combined proportional to flow, or a sample continuously collected proportional to flow over a 24-hour operating day.2) The permittee shall collect the 24-hour composite samples such that the samples are representative of any periodic episode of chlorination, biocide usage, or other potentially toxic substance discharged on an intermittent basis.3) The permittee shall initiate the toxicity tests within 36 hours after collection of the last portion of the 24-hour composite sample. Samples shall be maintained at a temperature of 0-6 degrees Centigrade during collection, shipping, and storage.4) If the Outfall ceases discharging during the collection of the effluent composite sample, the requirements for the minimum number of effluent portions are waived. However, the permittee must have collected a composite sample volume sufficient for completion of the required test.The abbreviated sample collection, duration, and methodology must be documented in the full report required in Part 3 of this Section.3. Reporting All reports, tables, plans, summaries, and related correspondence required in any Part of this Section shall be submitted to the attention of the Water Quality Standards Team (MC 150) of the Water Quality Division.All DMRs, including DMRs with biomonitoring data, should be sent to the Water Quality Compliance Monitoring Team of the Enforcement Division (MC 224).a. The permittee shall prepare a full report of the results of all tests conducted pursuant to this permit in accordance with the Report Preparation Section of "Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, Fifth Edition" (EPA-821 -R-02-012), or the most recent update thereof, for every valid and invalid toxicity test initiated.

All full reports shall be retained for three years at the plant site and shall be available for inspection by TCEQ personnel.

b. A full report must be submitted with the first valid biomonitoring test results for each test species and with the first test results any time the permittee subsequently employs a different test laboratory.

Full reports need not be submitted for subsequent testing unless specifically requested. The permittee shall routinely report the results of each biomonitoring test on the Table 2 forms provided with this permit.All Table 2 reports must include the information specified in the Table 2 form attached to this permit.1) Semiannual biomonitoring test results are due on or before January 20th and July 20th for biomonitoring conducted during the previous 6 month period.2) Quarterly biomonitoring test results are due on or before January 20th, April 20th, July 20th, and October 20th, for biomonitoring conducted during the previous calendar quarter.c. Enter the following codes on the DMR for the appropriate parameters for valid tests only: 1) For the mysid shrimp, Parameter TIE3E, enter a "0" if the mean survival at 24-hours is greater than 50% in the 100% effluent dilution; if the mean survival is less than or equal to 50%, enter a "1." 2) For the inland silverside, Parameter TIE6B, enter a "0" if the mean survival at 24-hours is greater than 50% in the 100% effluent dilution; if the mean survival is less than or equal to 50%, enter a "1." Page 29 STP Nuclear Operating Company TPDES Permit No. WQO0O 1908000 d. Enter the following codes on the DMR for retests only: 1) For retest number 1, Parameter 22415, enter a "0" if the mean survival at 24-hours is greater than 50% in the 100% effluent dilution; if the mean survival is less than or equal to 50%, enter a " 2) For retest number 2, Parameter 22416, enter a "0" if the mean survival at 24-hours is greater than 50% in the 100% effluent dilution; if the mean survival is less than or equal to 50%, enter a " 4. Persistent Mortality The requirements of this Part apply when a toxicity test demonstrates significant lethality, here defined as a mean mortality of 50% or greater to organisms exposed to the 100% effluent concentration after 24-hours.a. The permittee shall c -nduct~tw--oadditional-tests(retests)-for-each-species-thatdemonstrates-signifi-cat lethality. The two retests shall be conducted once per week for two weeks. Five effluent dilution concentrations in addition to an appropriate control shall be used in the retests. These additional effluent concentrations shall be 6%, 13%, 25%, 50% and 100% effluent. The first retest shall be conducted within 15 days of the laboratory determination of significant lethality. Ail test results shall be submitted within 20 days of test completion of the second retest. Test completion is defined as the 24th hour. The retests shall also be reported on the DMRs as specified in Part 3.d.b. Ifone or both of the two retests specified in item 4.a. demonstrates significant lethality, the permittee shall initiate the TRE requirements as specified in Part 5 of this Section.5. Toxicity Reduction Evaluation

a. Within 45 days of the retest that demonstrates significant lethality, the permittee shall submit a General Outline for initiating a TRE. The outline shall include, but not be limited to, a description of project personnel, a schedule for obtaining consultants (if needed), a discussion of influent and/or effluent data available for review, a sampling and analytical schedule, and a proposed TRE initiation date.b. Within 90 days of the retest that demonstrates significant lethality, the permittee shall submit a TRE Action Plan and Schedule for conducting a TRE. The plan shall specify the approach and methodology to be used in performing the TRE. A Toxicity Reduction Evaluation is a step-wise investigation combining toxicity testing with physical and chemical analysis to determine actions necessary to eliminate or reduce effluent toxicity to a level not effecting significant lethality at the critical dilution.

The TRE Action Plan shall lead to the successful elimination of significant lethality for both test species defined in item 1 .b. As a minimum, the TRE Action Plan shall include the following:

1) Specific Activities

-The TRE Action Plan shall specify the approach the permittee intends to utilize in conducting the TRE, including toxicity characterizations, identifications, confirmations, source evaluations, treatability studies, and/or alternative approaches. When conducting characterization analyses, the permittee shall perform multiple characterizations and follow the procedures specified in the document entitled, "Methods for Aquatic Toxicity Identification Evaluations: Phase I Toxicity Characterization Procedures" (EPA/600/6-91/003), or alternate procedures. The permittee shall perform multiple identifications and follow the methods specified in the documents entitled, "Methods for Aquatic Toxicity Identification Evaluations, Phase II Toxicity Identification Procedures for Samples Exhibiting Acute and Chronic Toxicity" (EPA/600/R-92/080) and "Methods for Aquatic Toxicity Identification Evaluations, Phase mI Toxicity Confirmation Procedures for Samples Exhibiting Acute and Chronic Toxicity" (EPA/600/R-92/081). All characterization, identification, and confirmation tests shall be conducted in an orderly and logical progression;

2) Sampling Plan -The TRE Action Plan should describe sampling locations, methods, holding times, chain of custody, and preservation techniques.

The effluent sample volume collected for all tests shall be adequate to perform the toxicity characterization/ identification/ confirmation Page 30 STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 procedures, and chemical-specific analyses when the toxicity. tests show significant lethality. Where the permittee has identified or suspects specific pollutant(s) and/or source(s) of effluent toxicity, the permittee shall conduct, concurrent with toxicity testing, chemical-specific analyses for the identified and/or suspected pollutant(s) and/or source(s) of effluent toxicity;3) Quality Assurance Plan -The TRE Action Plan should address record keeping and data evaluation, calibration and standardization, baseline tests, system blanks, controls, duplicates, spikes, toxicity persistence in the samples, randomization, reference toxicant control charts, as well as mechanisms to detect artifactual toxicity; and 4) Project Organization -The TRE Action Plan should describe the project staff, project manager, consulting engineering services (where applicable), consulting analytical and toxicological services, etc.c. Within 30 days of submittal of the TRE Action Plan and Schedule, the permittee shall implement the TRE with due diligence.

d. The permittee shall submit quarterly TRE Activities Reports concerning the progress of the TRE. The quarterly TRE Activities Reports are due on or before April 20th, July 20th, October 20th, and January 20th. The report shall detail information regarding the TRE activities including:

1) results and interpretation of any chemical-specific analyses for the identified and/or suspected pollutant(s) performed during the quarter;2) results and interpretation of any characterization, identification, and confirmation tests performed during the quarter;3) any data and/or substantiating documentation which identifies the pollutant(s) and/or source(s)of effluent toxicity;4) results of any studies/evaluations concerning the treatability of the facility's effluent toxicity;5) any data which identifies effluent toxicity control mechanisms that will reduce effluent toxicity to the level necessary to eliminate significant lethality; and 6) any changes to the initial TRE Plan and Schedule that are believed necessary as a result of the TRE findings.Copies of the TRE Activities Report shall also be submitted to the U.S. EPA Region 6 office.e. During the TRE, the permittee shall perform, at a minimum, quarterly testing using the more sensitive species; testing for the less sensitive species shall continue at the frequency specified in Part I .b.f. If the effluent ceases to effect significant lethality (herein as defined below) the permittee may end the TRE. A "cessation of lethality" is defined as no significant lethality for a period of 12 consecutive weeks with at least weekly testing. At the end of the 12 weeks, the permittee shall submit a statement of intent to cease the TRE and may then resume the testing frequency specified in Part I.b. The permittee may only apply the "cessation of lethality" provision once.This provision accommodate situations where operational errors and upsets, spills, or sampling errors triggered the TRE, in contrast to a situation where a single toxicant or group of toxicants cause lethality.

This provision does not apply as a result of corrective actions taken by the permittee."Corrective actions" are herein defined as proactive efforts which eliminate or reduce effluent toxicity.These include, but are not limited to, source reduction or elimination, improved housekeeping, changes in chemical usage, and modifications of influent streams and/or effluent treatment. The permittee may only apply this cessation of lethality provision once. If the effluent again demonstrates significant lethality to the same species, the permit will be amended to add a WET limit with a compliance period, if appropriate. However, prior to the effective date of the WET limit, the Page 31 I-STP Nuclear Operating Company TPDES Permit No. WQ0001908000 pennittee may apply for a permit amendment removing and replacing the WET limit with an alternate toxicity control measure by identifying and confirming the toxicant and/or an appropriate control measure.g. The pennittee shall complete the TRE and submit a Final Report on the TRE Activities no later than 18 months from the last test day of the retest that demonstrates significant lethality. The permittee may petition the Executive Director (in writing) for an extension of the 18-month limit. However, to warrant an extension the permittee must have demonstrated due diligence in their pursuit of the TIE/FRE and must prove that circumstances beyond their control stalled the TIE/TRE. The report shall specify the control mechanism(s) that will, when implemented, reduce effluent toxicity as specified in item 5.g. The report will also specify a corrective action schedule for implementing the selected control mechanism(s). A copy of the TRE Final Report shall also be submitted to the U.S.EPA Region 6 office.h. Within 3 years of the last day of the test confirming toxicity, the permittee shall comply with 30 TAC 307.6.(e)(2)(B), which requires greater than 50% survival of the test organism.in-100%_effluent-at-the- --. end-of-24h-ours-The -permittee -may-p-iyfiiiithe Executive Director(in writing) for an extension of the 3-year limit. However, to warrant an extension the permittee must have demonstrated due diligence in their pursuit of the TIE/TRE and must prove that circumstances beyond their control stalled the TIE/TRE.The requirement to comply with 30 TAC 307.6.(e)(2)(B) may be exempted upon proof that toxicity is caused by an excess, imbalance, or deficiency of dissolved salts. This exemption excludes instances where individually toxic components (e.g. metals) form a salt compound. Following the exemption, the permit may be amended to include an ion-adjustment protocol, hlternate species testing, or single species testing.Based upon the results of the TRE and proposed. corrective actions, this permit may be amended to modify the biomonitoring requirements where necessary, to require. a compliance schedule for implementation of corrective actions, to specify a WET limit, to specify a BMP, and/or to specify a CS limit.Page 32 A !, -STP Nuclear Operating Company TPDES Permit No. WQOOO 1908000 TABLE 2 (SHEET 1 OF 2)MYSID SHRIMP SURVIVAL GENERAL INFORMATION PERCENT SURVIVAL I.Enter percent effluent corresponding to the LC50 below: 24 hour LC50 = % effluent 95% confidence limits: Method of LC50 calculation: Page 33 ~. A STP Nuclear Operating Company TPDES Permit No. WQ000 1908000 TABLE 2 (SHEET 2 OF 2)INLAND SILVERSIDE SURVIVAL GENERAL INFORMATION I It Kimiie- an13pi a e~~n- .... .... ..*te u ....... "C. ....... ..I I I PERCENT SURVIVAL Time Rep Percent effuent(A) .0V/...... .6% 13% 25% 50% 100%A "___ _" __ "_ _-_ _._"_ _ .._ _ _ VMEAN _ _ _ _ _ ___ _1.Enter percent effluent corresponding to the LC50 below: 24-hour LC50 = % effluent 95% confidence limits: Method of LC50 calculation: Page 34 WR-4. TPDES permit renewal application (June 2009 and May 24, 2007, letters) Nuclear Operating Company South Te$,s Pmfrd Electric GcncratinS Slatlon P.O Ba' 28-' W&ds5ýrth, Tn;7s 77483, May 24, 2007 NOC-TX-07016176 PFN: W02 STI No. 32165797 Mr. Kelly Holligan Team Leader, Industrial Wastewater Permits Texas Commission on Enviromnental Quality P.O. Box 13087 Austin, TX 78711-3087 Re: Cooling Water Intake Structures Phase II Rules South Texas Project Electric Generating Station TPDES Permit No. 01908

Dear Mr. Holligan:

Thank you for meeting with my staff on May 15, 2007 to discuss the South Texas Project Electric Generating Station (STPEGS) cooling reservoir and other wastewater discharge permit issues. Based on our discussion, STP Nuclear Operating Company (STPNOC) is submitting the following information regarding the Main Cooling Reservoir (MCR) and the applicability of the regulations for cooling water intake structures. We are confident that the South Texas Project Station (STP) complies with the regulation by employing a closed-cycle recirculating cooling system as defined in 40 CFR § 125.93. Pursuant to 40 CFR §125.94(a)(1)(i), cooling water flow for this facility is commensurate with a closed-cycle recirculating cooling system, as demonstrated below. Additional technical information is included in letters dated March 7, 2005 and August 18, 2005 previously submitted to the Texas Commission on Environmental Quality (TCEQ).STP is located on 12,220-acres in Matagorda County, approximately 15 miles southwest of Bay City along the west bank of the Colorado River. The facility consists of two electric-generating units, which share a closed-cycle recirculating cooling reservoir. Water from the MCR is passed through the cooling loops of both units then returned to the MCR for heat dissipation before cycling back through the cooling systems.The MCR is a perched, off-channel, on-site industrial cooling impoundment of approximately 7,000 acres, impounding over 202,600 acre-feet of cooling water at its maximum operating level.Dikes are installed in the MCR that channel the water flow to maximize circulation time for heat dissipation before the water is recirculated back to the generating units. Blowdown from the MCR to the Colorado River has not occurred since March 1997. Should blowdown be required it would occur through an underground pipe that discharges back into the Colorado River. This point is designated as Outfall 001 in the TPDES Permit No. 01908. The MCR is also equipped with a gated spillway for emergency use. The MCR is not a "water of the U.S." as defined at 40 CFR § 122.2. The MCR is not considered a "water of the State" based on internal and external outfall designations in the permit. The MCR is on private property and exists solely for Mr. Kelly Holligan May 24, 2007 Page 2 industrial cooling. It is not a publicly managed water body and has no recreational uses. The general public has never had access to the NMICR nor is any planned in the foreseeable future.The only sources of new water to the MCR are direct rainfall and make-up water diverted periodically from the Colorado River, primarily at high river flows. Water from the Colorado River is pumped approximately I mile via a 108 inch pipe to the MCR. To protect inflows during low river flow conditions, the water right for STP includes a special provision to limit diversion from the Colorado River to 55% of the flow over 300 cubic feet per second, to protect inflows during low river flow conditions. Currently, the intake consists of irash racks, rotating screens with 3/8 inch mesh and 4 pumps. In addition, the reservoir makeup pumping facility has the following design: " The traveling water screens are flush with the river shoreline;

• The maximum approach velocity to the traveling water screens is 0.5 feet per second;" Fish passageways were constructed in the wing walls between the traveling screens to facilitate fish migration parallel to the screen surfaces; and* A sluice and discharge line was installed for the purpose of returning all impinged organisms directly to the river, downstream of the intake structure, immediately after being backwashed from the screens.The pumps are operated intermittently based on reservoir level, river flow, and the operability of the makeup pumping facility.

A cooling reservoir evaporates less water per unit of heat dissipated than a cooling tower, thus dissolved solids build up more slowly over time. This is complemented by the designed seepage from the MCR, which maintains the structural integrity of the reservoir embankment. Rainfall further dilutes the dissolved solids in the MCR. These factors minimize the blowdown and make-up required to maintain MCR water quality. As a result, intake water flow for cooling purposes at STP reflects best technology available (closed-cycle recirculating systems) for minimizing adverse environmental impact.As was discussed in the May 15, 2007 meeting, several provisions of the Phase 11 rule are in the process of being suspended by the U.S. Environmental Protection Agency and the Regional Administrators have been authorized to review the applicability of the rule on a case by case basis using Best Professional Judgment. Based on that authorization and the information provided, STPNOC is requesting that TCEQ designate the MCR as a closed-cycle recirculating system. We are also requesting concurrence that the MCR does not meet the definition of a"water of the State". If you have any questions or require additional information, please contact Ms. S. L. Dannhardt at (361) 972-8328.Sincerely, R. A. Gangluff Manager, Chemistry Environmental and Health Physics Mr. Kelly Flolligan May 24, 2007 Page 3 cc: Mr. Earl Lott Special Assistant, Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Ms. Susan Jablonski Special Assistant/Radioactive Waste Specialist Office of Pennitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087.Austin, TX 78711-3087 Mr. Kelly Holligan May 24, 2007 Page 4 bcc: Correspondence, N2002 Nuclear Operating Company South k12S /'rqt Ek/bic Gen,'atig o S .O Bar 28.9 Ts 77483 -A, A June 2, 2009 NOC-AE-09002433 STI: 32479342 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 TPDES Permit Renewal Application 01908 Please find attached a copy of the Renewal Application for the South Texas Project TPDES Permit No. 01908.Appendix B of the South Texas Project Operating License requires the NRC be provided a copy of the application for renewal of the TPDES Permit at the same time the application is submitted to the permitting agency.There are no commitments in this letter.If you should have any questions on this matter, please contact me at (361) 972-8328.S. L. Dannhardt Manager, Environmental MK

Attachment:

TPDES Permit Renewal Application for TPDES Permit No. 01908 ffL~c/,c-~ NOC-AE-09002433 Page 2 cc: (paper copy)(electronic copy)Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 East Lamar Blvd, Suite 400 Arlington, Texas 76011-4125 Mohan C. Thadani Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North (MS 7 DI)11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 A. H. Gutterman, Esquire Morgan, Lewis & Bockius LLP Mohan C. Thadani U. S. Nuclear Regulatory Commission Kevin Howell Catherine Callaway Jim von Suskil NRG South Texas LP Ed Alarcon J. J. Nesrsta R. K. Temple Kevin Polio City Public Service Jon C. Wood Cox Smith Matthews C. Mele City of Austin Richard A. Ratliff Texas Department of State Health Services Alice Rogers Texas Department of State Health Services STP Nuclear Operating Company South Texas Project Electric Generating Station.TPDES Application 2009 Permit 01908) Administrative Report a STP Nuclear Operating Company South Texas Project Electric Generating Station TPDES Application 2009 Permit 01908 Application Contents Copy of application fee check Administrative Report 1.0 SPIF SPIF Maps Blessing SE Palacios NE South Texas Project (aerial photo)Technical Report 1.0 Worksheet

1.0 Overall

Flow Diagram Flow Diagram -Outfall 001 Flow Diagram -Outfall 101 Flow Diagram -Outfall 201 Flow Diagram -Outfall 501 Flow Diagram -Outfall 401 Flow Diagram -Outfall 601 Worksheet

2.0 Laboratories

Providing Analyses Worksheet

5.0 Worksheet

11.0 Correspondence letters (2) related to closed-cycle system Water Well Report Treatment Chemicals and MSDSs Site Drawings South Texas Project (aerial photo)Plot Plan Integrated Spill Contingency Plan Site Map USGS Maps Blessing SE Palacios NE Wadsworth Matagorda 110916BO7' i:03LLO0267O

6301L46434?

509o, 0 TEXAS COMMISSION ON ENVIRONMENTAL QUALITY INDUSTRIAL WASTEWATER PERMIT APPLICATION SUBMISSION CHECKLIST -SUBMIT THIS WITH THE APPLICATION DO NOT SUBMIT THE INSTRUCTIONS WITH THE APPLICATION INDICATE IF THE FOLLOWING ARE INCLUDED IN THE APPLICATION. ADDITIONAL BLANK SPACES PROVIDED FOR REFERENCING APPLICANT'S ATTACHMENTS TO THE APPLICATION. WORKSHEET Y N WORKSHEET Y N ADMINISTRATIVE REPORT 1.0 V -WORKSHEET

7.0 ADMINISTRATIVE

REPORT 1.1 1 WORKSHEET 8.0 , SPIF 1 WORKSHEET 9.0 1 TECHNICAL REPORT 1.0 / WORKSHEET 10.0 1 WORKSHEET 1.0 / ORIGINAL USGS MAP 1 WORKSHEET 2.0 / AFFECTED LANDOWNER MAP /WORKSHEET 3.0 1 LANDOWNER DISK OR LABELS WORKSHEET 3.1 COPY OF APPLICATION FEE CHECK WORKSHEET 3.2 1 ALL FEES OWED TCEQ ARE PAID /WORKSHEET 3.3 ,* FLOW DIAGRAM /WORKSHEET 4.0 1 SITE DRAWING WORKSHEET 4.1 1 ORIGINAL PHOTOGRAPHS 't WORKSHEET 5.0 / SOLIDS MANAGEMENT PLAN " WORKSHEET 6.0 / WATER BALANCE /Note: Worksheet 11.0 Cooling Water Intake Structures is also included.Please indicate by a check mark the amount submitted for the application fee: Major Minor EPA Classification New Amend. Renewal Amend./Mod. Minor facility not subject to categorical standards promulgated by the EPA (40 CFR $350 $350 $315 $150 Part 400-47 1)Minor facility subject to categorical standards promulgated by the EPA (40 CFR Part 400- -$1,250 $1,250 $1,215 _ $150 471) 1 1 Major facility N/A* $2,050 I $2,015 $450* All facilities are designated as minors until formerly classified as a major by EPA.A COPY OF THE CHECK MUST BE SUBMITTED AS PART OF THE APPLICATION For Commission Use Only: Segment Number County Expiration Date Region Proposed/Current Permit Number Page 1 ADMINISTRATIVE REPORT 1.0- INDUSTRIAL THE FOLLOWING IS REQUIRED FOR ALL APPLICATIONS, RENEWAL. NEW AND AMENDMENT. The instructions MUST BE FOLLOWED while completing the application. Failure to do so will result in significant delays in the processing of the application. Type of application: (check all that apply)New TPDES New TLAP Major amendment to existing permit Minor modification to permit* Renewal of existing permit I Minor amendment to permit Storm water only discharges If applying for an amendment/modification to a permit, briefly describe the reason for the proposed amendment.

1) Remove Item 14 from the Other Requirements of the permit because it refers to regulations for cooling water intake structures that do not apply to the closed-cycle recirculating system at the facility.2) Remove Item 15 from the Other Requirements of the permit because wastewater characterization data are provided with this application.

3) Add storm water to Outfalls 101,401, 501, and 601.4) Add uncontaminated groundwater to Outfall 001.5) Allow DPD method for total residual chlorine In Item 5 in the Other Requirements of the permit.I. APPLICANT INFORMATION (instructions, Page 14)a. Facility owner*: STP Nuclear Operating Company* Owene of the facility n'ust apply for tdie panit Charter Number (issued by the Texas Secretary of State): 1459553-01 Mailing address for use on the permit and permit correspondence:

Street No. Street Name: Street Type: P.O. Box: 289 City: Wadsworth State: TX ZIP Code: 7 7 4 8 3 Telephone Number: (361)972-8328 Tax Identification Number issued by the State Comptroller: 1-76-0517597-9 Check one: I The TCEQ has issued this Customer Reference Number to the owner. CN: 601658669 The owner has not yet received a Customer Reference Number. A completed Core Data Form (TCEQ-10400) listing the owner as a customer and this facility as the regulated entity is attached to this application.

b. Co-Permittee information (complete only if the operator must be a co-permittee)

Facility operator, n/a Charter Number (issued by the Texas Secretary of State): Mailing address for use on the permit and permit correspondence: Street No. .Street Name: Street Type: P.O. Box: City: State: ZIP Code: Telephone Number: Date of Birth: Tax Identification Number issued by the State Comptroller: Check one: __ The TCEQ has issued this Customer Reference Number to the owner. CN: The owner has not yet received a Customer Reference Number. A completed Core Data Form (TCEQ-10400) listing the owner as a customer and this facility as the regulated entity is attached to this* application. Administrative Report, TCEO-10411 (Revised 312009) Page 2 Provide a brief description as to the need for a co-permittee. n/a c. Individual information (complete only if the facility owner or co-permittee is an individual) Name: rkla Check one: -Male __ Female State Identification Number: Date of Birth: Assumed business or professional name:_Home Address: Street No. Street Name: Street Type: P.O. Box: City: State: ZIP Code: Telephone Number_Business name: Check one: The TCEO has issued this Customer Reference Number to this person. CN: This person has not yet received a Customer Reference Number. A completed Core Data Form (TCEQ-10400) listing this person as a customer and this facility as the regulated entity is attached to this application.

2. CONTACT INFORMATION (Instructions, Pages 15)Name: S.L. Dannhardt Company: STP Nuclear Operating Company Telephone number: (361) 972-8328 Fax number: (361) 972-7760 E-Mail: sldannhardt@STPEGS.COM Street No. Street name: Street type: P.O. Box: 2 8 9 City:Wadsworth State: TX ZIP code: 7 7 4 8 3 Check one or more: _/ Administrative contact / Technical contact Name: n/a Company: Telephone number: Fax number: E-Mail: Street No. Street name: __Street type: P.O. Box: City. State: ZIP code: Check one or more: _ Administrative contact Technical contact 3. NOTICE INFORMATION (Instructions, Page 15)a. Individual publishing the notices Name: S.L. Dannhardt Telephone number: (361) 972-8328 Company: STP Nuclear Operating Company Fax number: (361) 972-7760 Street No: Street name: Street type: P.O. Box: 289 City:Wadsworth State: TX ZIP code: 7 7 4 8 3 0 Industrial Administrative Report, TCEQ-1 0411 (Revised 3/2009)Page 3

b. Method of receiving Notice of Receipt and Intent to Obtain a Water Quality Permit Package and Instructions

• (Check one)v/ E-mail: E-mail address: sldannhardt@STPEGS.COM Fax: Fax number: Overnight/Priority mail: (self addressed, prepaid envelope required)Regular Mail: Street No- Street name: Street type: P.O. Box: City: State: ZIP code: __c. Contact in the notice Name: S.L. Dannhardt Telephone number: (361) 972-8328 Company: STP Nuclear Operating Company Fax number: (361) 972-7760 Street No. Street name: Street type:_P.O. Box: 2 8 9 City: Wadsworth State: TX ZIP code: 77483 d. Public place information (If the facility and/or outfall is located in more than one county, a public viewing place for each county must be provided.)

Location of public building: Matagorda County Courthouse Public building name: Matagorda County Courthouse Street No. 1700 Street name: 7th Street type: Street City: Bay City County: Matagorda State: TX ZIP Code: 7 7 4 1 4 e. Bilingual Notice Requirements: FOR NEW PERMIT APPLICATIONS, MAJOR AMENDMENT AND RENEWAL APPLICATIONS (Not applicable for minor amendment or minor modification applications.) Please call the bilingual/ESL coordinator for the nearest elementary and middle schools and obtain the following information to determine if an alternative language notice is required: 1. Is a bilingual education program required by the Texas Education Code at the nearest elementary or middle school to the facility or proposed facility?____ Yes / No (If No, alternative language notice publication is not required; skip to item 4.FACILITY INFORMATION.)

2. Are the students who attend either the elementary school or the middle school enrolled in a bilingual education program at that school?Yes No 3. Do the students at these schools attend a bilingual education program at another location?Yes No 4. Would the school be required to provide a bilingual education program but the school has waived out of this requirement under 19 TAC Section 89.1205(g)?

Yes No Industrial Administrative Report, TCEQ-10411 (Revised 3/2009)Page 4

5. If the answer is yes to either 2, 3, or 4, public notice in an alternative language is required.Which language is required by the bilingual program?Name of language: (Complete instructions on publishing the alternative language notice will be available in your full public notice package. This section of the application is only used to determine if alternative language notice will be needed.)4. FACILITY INFORMATION (Instructions, Page 16)a. Statc/TPDES Permit No. 0 1 9 0 8 Expiration date: December 1, 2009 EPA ID. No.TX0064947 Expiration date: n/a Check one: / The TCEQ has issued this Regulated Entity Reference Number for this facility.

RN: 102395654-No Regulatory Entity Reference Number has been received for this facility. One or more completed Core Data Forms (TCEQ-10400) listing this facility as the regulated entity is attached to this pplication.

b. Plant Name: South Texas Project Electric Generating Station County in which the facility is located: Matagorda County in which the outfall is located: Matagorda ZIP code in which the facility is located: 77483 c. Owner of treatment plant: STP Nuclear Operating Company* (see note below)Street No. Street name: P.O. Box 289 Street type: City: Wadsworth State: TX ZIP code:'7 7 4 8 3 d. Owner of land where treatment plant is/will be: STP Nuclear Operating Company*(If noL the sarne as the facility owner, there must be a loag r-trm lease agreement in effect for at least six years. In some case. a lease may ot usffice -see instmsctions.)

Street No. Street name: P.O. Box 289 Street type: City:Wadsworth State: TX ZIP code: 77483 e. Ownership of effluent disposal site: n/a (Ift not the samne as the ficility owner, there must be a long teem lease agreement in effect for at least six years.)Street No. Street name: Street type: City: State: ZIP code: f. Owner of sewage sludge disposal site: n/a (Required only ifauthneization is being sought is the permit for sludge disposal on propesty owwed/cantrollcd by the applicant.) Street No. Street name: __ Street type: City State: ZIP code: 5. LOCATION INFORMATION (Instructions, Pages 17-18)a. Is the location of the facility used in the existing permit correct: *" Yes __ No Provide an address for the facility, if available (address must be validated through the US Postal Service or your local police (911 service) as a valid address. If the location description is not accurate or this is a new permit application, please provide an accurate description. Industrial Administrative Report, TCEO-10411 (Revised 312009) Page S*As Agent for the South Texas Project Owners, which are NRG Energy, Inc., Austin Energy, and CPS Energy. 0 If no, or a new permit application, please give an accurate description: n/a b. Is the point of discharge and discharge route in the existing permit correct: / Yes No If no, or a new or amendment permit application, please give an accurate description: it/a c. If a TLAP, is the location of the effluent disposal in the existing permit accurate: -Yes No If no, or a new or amendment permit application, please give an accurate description: n/a d. lf a TLAP, provide the flow of effluent from the treatment facility to the effluent disposal site.rVa e. For TLAP applications, please identify the nearest watercourse to the disposal site to which rainfall runoff might flow if not contained: n/a f. Is the location of the sewage sludge disposal site in the existing permit accurate: If no, or a new permit application, please give an accurate description: __Yes __ No n/a g. Provide anoriginal USGS Map with all required information. Indicate by a check mark that the information SeeoUSGS maps (4): Blessing SE, Palaclos NE, Wadsworth, Matagorda; is provided, and Water Well Report./ Applicant's property boundary / Treatment plant boundaries / Point of discharge and highlighted discharge route Effluent disposal site boundaries All ponds Sewage sludge disposal site/ 1 mile radius and 3 miles downstream information V New and future construction 0 Industrial Administrative Report, TCEQ-10411 (Revised 312009)Page 6

h. Is'the facility located in Bexar, Comal, Hays, Kinney, Medina, Travis, Uvalde, or Williamson County?Yes V No If yes, additional information concerning protection of the Edwards Aquifer may be required.i. Identify the name and distance to the nearest city from the facility:

Wadsworth, 8 miles j. Is/will the treated wastewater discharge to a city, county, or state highway right-of-way, or a flood control district drainage ditch? __ Yes 1 No If yes, indicate by a check mark if Authorization granted _ Authorization pending For new and amendment permit applications, provide copies of letters that show proof of contact and upon receipt, the approval letter. Addtlonal USGS maps attached.k. Is the facility located on or does the treatcd cffluent cross Indian Land? -Yes V_ No 6. MISCELLANEOUS INFORMATION (Instructions, Page 19)a. Provide two names of individuals that can be contacted during the permit term.Name: S.L. Dannhardt Telephone number: (361) 972-8328 Company: STP Nuclear Operating Company Fax number: (361) 972-7760 Street No. Street name: _Street type: P.O. Box: 28 9 City: Wadsworth State: TX ZIP code: 77483 Name: R. A. Gangluff Telephone number: (361) 972-7879 Company: STP Nuclear Operating Company Fax number: (361) 972-8273 Street No. Street name: Street type: P.O. Box: 289 City: Wadsworth State: TX ZIP code: 77483 b. List each person formerly employed by the TCEQ who represented your company and was paid for service regarding the application. n/a c. For all applications involving an average daily discharge of 5 million gallons per day or more, provide the names of all counties located within 100 statute miles downstream of the point(s) of discharge. Matagorda Industrial Administrative Report, TCEQ.1041 I (Revised 312009) Page 7 Industrial Administrative Report TCIEQ-110411 (Revised 312009)Page7

d. Please provide the address for receiving self-reporting/DMVR forms: Company: STP Nuclear Operating Company Department:

Environmental Name: S.L. Dannhardt Street No. Street Name: Street Type: P.O. Box: 2 8 9 City: Wadsworth State: TX ZIP code: 77483 Please provide thc address for receiving Annual Billing Invoices: Company: STP Nuclear Operating Company Department: Environmental Name: S.L. Dannhardt Street No. Street Name: Street Type: P.O. Box: 2 8 9 City: Wadsworth State: TX ZIP code: 77483 e. Do you owe fees to the TCEQ?Yes V No Confirmed with TCEQ database, 4-24-09.If yes, please provide the amount past due, the type of fee, and an identifying number.WA Do you owe any penalties to the TCEQ?Yes / No Confirmed with TCEQ database, 4-24-09.If yes, please provide the amount past due, the type of penalty, and an identifying number.WA industrial Adiministrative Report, TCEQ-1 0411 (Revised 312009)Pae Page 8

7. SIGNATURE PACE (Instructions, Page 20)Chemistry, Environmental and Health 1 , R. A. Gangluff Physics Manager Typed or printed name Title certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted.

Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware there are significant penalties for submitting false information, including the possibility of fine and imprisonment for known violations. I futther certify that I am authorized under 30 Texas Administrative Code § 305.44 to sign this document and can provide documentation in proof of such authorization upon request.Signature:_ Date:__5___/0____5P_ Subscribed and Sworn to before me by the said R.A" ' , ('- on this a. " day of t-ufct. 200$day o ,.ithe ,20ýZ [4SEAL]Notary Public 4a. rn ..... 4,\ LIS J. MILLS--l Notary Publc, State of Taxu" County, Texas M1 \" .H eMy b aen, 1.P-" JULY 27, 2011 NOTE: If co-permittees are necessary, both entities must submit separate Signature Pages.Industrial Administrative Report, TCEQ-10411 (Revised 3/12M0)Page 9 TCEQ USE ONLY: Application type: Renewal __Major Amendment Minor Amendment New County: -Admin Complete Date: Agency Receiving SP1F: Texas Historical Commission U.S. Fish and Wildlife Texas Parks and Wildlife Army Corps of Engineers 8. SUPPLEMENTAL PERMIT INFORMATION FORM (SPIF) (Instructions, Page 20)This form applies to TPDES permit applications only. The SPIF must be completed as a separate document.The TCEQ will mail a copy of the SPIF to each agency as required by the TCEQ agreement with EPA. If any of the items are not completely addressed and/or further information is needed, you will be contacted to provide the information before the permit is issued. Each item must be completely addressed. DO NOT REFER TO A RESPONSE OF ANY ITEM IN THE PERMIT APPLICATION FORM. Each attachment must be provided with this form, separately from the administrative report of the application. The application will not be declared administratively complete without this form being completed in its entirety including all attachments The following applies to all applications:

1. Permittee:

STP Nuclear Operating Company 2. Permit No. 01908 (NPDES Permit No./EPA ID No.) TX0064947 3- Address of the project (location description that includes street/highway, city/vicinity, county: Located on Farm-to-Market Road 521, approximately 10 miles north of Matagorda Bay and 12 miles south-southwest of the City of Bay City, Matagorda County, Texas.4. Provide the name, address, telephone and fax number of an individual that can be contacted to answer specific questions about the property: Name: S.L. Dannhardt Telephone number: (361) 972-8328 Company: STP Nuclear Operating Compny Fax number: (361) 972-7760 Street No.: Street name: P.O. 289 Street type: City: Wadsworth State: TX ZIP code: 77483-0289

5. List the county in which the facility is located: Matagorda 6. If the property is publicly owned and the owner is different that the permittee/applicant, please identify the owner of the property:

STP Nuclear Operating Company*7. Identify the name of the water body (receiving waters) or TCEQ segment number that will receive the discharge: Colorado River Tidal in Segment No. 1401 of the Colorado River Basin Industrial Administrative Reporlt TCEQ-10411 (Revised 312009) Page 10 As Agent for the South Texas Project Owners, which are NRG Energy, Inc., Austin Energy, and CPS Energy.

8. Please provide a separate 7.5 minute USGS quadrangle map with the project boundaries plotted and a general location map showing the project area. (This map is required in addition to the map in the administrative report)See USGS maps (Blessing SE, Palacios NE) and aerial photo (South Texas Project).9. Please provide original photographs of any structures 50 years or older on the property.There are no structures 50 years or older.10. Does your project involve any of the following?

If yes, circle the appropriate letter.Yes.a. Proposed access roads, utility lines, construction easements b. Visual effects that could damage or detract from a historic property's integrity c. Vibration effects during construction, or as a result of project design I D) Additional phases of development that are planned for the future e. Sealing caves, fractures, sinkholes, other karst features V ODisturbance of vegetation or wetlands (vegetation only)11. List proposed construction impact (surface acres to be impacted, depth of excavation, sealing of caves or other karst features): The South Texas Project site has a total of 12,220 acres. Approximately 244 acres will be Impacted by the construction and operation of Units 3 and 4. Excavation for Units 3 and 4 will be to a depth of approximately 85 feet. Isolation of the shallow aquifer will be accomplished with a slurry wail during construction. Wetlands and jurisdictional drainage ditches will be protected. There are no caves or karst features onsite.12. Describe existing disturbances, vegetation & land use The area surrounding the South Texas Project is characterized by coastal plain with farmland and pasture predominating. Sixty-five of the 12,220 acres are occupied by the two current power plants. Plant facilities Include a 7,000-acre cooling reservoir and a 47-acre essential cooling pond. Many smaller bodies of water onsite Include wetlands, Kelly Lake, and natural and engineered drainage ditches. Much of the land east of the reservoir is leased for cattle grazing. Approximately 1,700 acres remain in a more natural state as a lowland habitat. A 110-acre wetland habitat was established northeast of the power plants.The following applies only to applications for New TPDES permits and Major Amendments to TPDES Permits 13. List construction dates of any buildings or structures on the property: n/a 14. Provide a brief histroy of the property, and namc of the architect/builder, if known: n/a Industrial Administrative Report, TCEQ-10411 (Revised 3120091 Page 11 S South Texas Project F of Mexico Wetata-or&h Technical Report TECHNICAL REPORT 1.0- INDUSTRIAL THE FOLLOWING IS REQUIRED FOR ALL APPLICATIONS, RENEWAL, NEW, AND AMENDMENT 1. FACILITY/SITE INFORMATION (instructions, page 24)a. Describe the type of activity and general nature of your business.south Texas Project (STP) Electric Generating Station Is a nuclear fueled, steam-electric generating facility. Electricity Is generated from steam driven turbines.b. SIC Code(s) 4911 NAICS Code(s) 221113 , c. Describe the wastewater generating processes. Main Cooling Reservoir-Outfall 001 Outfall 001 is Me discharge point for the 7,100-acre main cooling reservoir. This resetvo r Is part of the main recirculating cooling water loop used to remove heat from the steam-electric generating units. There has not been a discharge from Outfall 001 since March 1997 other than minor permitted leakage tihough the closed spillway gates and relief wells. If a discharge were to occur, blowdown from the main cooling reservoir would make up the largest percentage of wastewater. A discharge from Outfall 001 would flow to the Colorado River (Colorado River Tidal in Segment 1401 of the Colorado River Basin).All internal outfalls (Outfall 101, 201, 401, and 601) discharge to the main cooling reservoir. Outfall 501 would also discharge to the reservoir via Outfall 101. but has not discharged since 1992.Low Volume Wastewater (Outfalla 101 and 201)Low volume wasutwator results from water treatment operations, boiler blowdown. HVAC bbowdown, floor drains and SPCC sources and their associated oily watet treatment system discharges, and other miscellaneous Sources. Boiler blowdown Is from one auxiliary steam boiler, released to reduce impurities In the water that can cause corrosion and boiler tube fallure. Service water Is denineralzed and regeneration of the demineralzer resin beds produces an acidic and caustic wastewater that is treated at the neutralization basins along with boiler blowdown. The floor drain system captures condensate and water from production and maintenance areas that may contain oil or grease, which Is then transported to the oily waste tr"atment system where the oil is separated from the water. The first flush of storm water from production and storage area is also treated In the oily waste system. Other non-process storm water flow is directed through designated storm water outrfaIl.Treated Domestic Wastewater (Out lsts 401 and 601)Domestic wastewater Is treated onsite in two package treatment systems consisting of aeration, clarificaion, and disinfection. Car wash water, air conditioning condensate, HVAC cooling tower blowdown, and storm water are commingled with the domestic wastewater puior to treatment. Metal Cleaning Waste (Outfalla 501)Metal cleaning waste has not been discharged since 1992- Cleaning of metal using chemical or non-chemical liquids produces a waste that would be discharged through Outfall 501 to the neutralization basins (Outfall 1t1). Storm water may also be discharged through Outfall 501.d. ' Provide a list of raw materials, major intermediates, and products handled at your facility.Raw Materials Intermediate Products Final Products nuclear fuel (7440-61-1) steam electricity ___________________ .1 Technical Report 1.0, TCEFQ-1 0055 (Revised 9/2006)Page 1

e. Indicate by a check mark that an attached facility map with the following information was provided with the application:

_ _ lProduction areas, maintenance areas, materials handling areas, and waste disposal areas.I The location of each unit of the wastewater treatment plant including the location of wastewater collection sumps and impoundments. See South Texas. Project (aerial photo), USGS maps (4), Plot Plan, Integrated Spill

Attachment:

cnntingenc-y Plan Map f. Is this a new permit application for an existing facility? __ Yes V No If yes, provide background discussion below., i n/a g. Is the treatment facility/disposal site located above the 100-year frequency flood level?g. Is the treatment facility/disposal site located above the I100-year frequency flood level?V Yes No List source(s) used to determine 100-year freouencv flood olain: IFIRM 485489037C, March 18, 1985.If no, provide the elevation of the 100-year frequency flood plain and describe what protective measures are in use or planned to be used to prevent flooding of the treatment facility/disposal area.m/a h. For new or amendment permit applications, will there be discharge of fill material into a water in the state for construction of the proposed outfall structure? Yes __ No n/a If no, proceed to Item No. 2. If yes, has the applicant applied for a U.S. Corps of Engineers 404 Dredge and Fill permit? _ Yes _ No If yes, provide the permit number. n/a If no, provide the approximate date you anticipate submitting your application to the Corps. n/a Technical Repoil 1.0, TCEQ-10055 (Revised 912006)Page 2

2. TREATMENT SYSTEM (Instructions, page 25)a. List any physical, chemical, and/or biological treatment process that you use for the treatment of wastewater at your facility.

Include a description of each treatment process starting with initial treatment and finishing with the discharge point.See table on page 3a.b. 0' Indicate by a check mark that an attached flow schematic with a water balance was provided with the application showing each treatment unit and all sources ofwastewater flow into the treatment plant and to each outfall/point of disposal.

Attachment:

See flow diagrams In Worksheet

1.3. IMPOUNDMENTS

(Instrctions, pages 25-27)Do you use or plan to use any wastewater lagoons, ponds, or impoundments? I Yes -No If yes, complete item 3(a) for existing impoundments and items 3(a)-3(f) for new or proposed impoundments. If no, proceed to Item No. 4.a. Provide the following information in the table provided: Designation: Indicate the appropriate use designation for each pond [Treatment (T), Disposal (D), Containment (C), or Evaporation (E)]Discharge Point: If a discharge occurs from the impoundments, designate the outfall associated with the impoundment. Liner Information: If the impoundments are lined to comply with specifications outlined for 1) a compacted clay liner (C), 2) an in-situ clay liner (i), or 3) a synthetic/plastic/rubber liner (S), indicate the liner type with the appropriate letter designation (see instructions for further detail on liner specifications). If not, provide a reference to the attachment that provides a description of the alternate liner and any additional technical information necessary for an evaluation. Dimensions: Provide the dimensions(s), freeboard, surface area, and storage volume capacity ofthe impoundments. For impoundments with irregular shapes, submit surface area (instead of length and width), the average depth, and the maximum depth below natural ground level.Technical Report 1.0, TCEQ-10055 (Revised 9/2006)Page 3 Wastewater Treatment System Treatment System Outfall Unit Dimensions Treatment Processes Main Cooling Reservoir 001 7,000 acre pond (irregular) Heat Dissipation Reuse/Recycle Low Volume Waste 2-Neutralization Basins Neutralization" Metal Cleaning Wastes. 101 (300.000 gallons each) Mixing*Neutralization Basin 68' x 42' x 16' Sedimentation Gross Oil Separator (API) Equalization Flotation 13,000 gaxlons Skimming*Low Volume Waste 242 x 8' x ' Sedimentation Oily Waste Treatment System 201 Tricellerator (DAF) 3,800 gallons Dissolved air flotation 9' dia x 8' Coagulation* Effluent Tank 850 gallons Multi-media Filtration 5' dia x 6'2-Aeration Basins Screening 63' x 12' x 11'6" Activated Sludge 2 Clarifiers 16' dia x 11'6" Sedimentation West Sanitary Waste Treatment Primary Chlorine Contact System401 Chamber Disinfection**** 6"x 12'x 11'6" Secondary Chlorine Contact Chamber Disinfection-* 4'dia x 4'3" Organic Basin Equalization Approx. 1.000.000 gallons Mixing*100'x 80'x 17'6" Aeration'Metal Cleaning Waste- Inorganic Basin Coagulation* Approx. 50,000 gallons Chemical Precipitation' 25' x 25' x 13S3" Sedimentation Treatment Tanks (possible future Not determined at this use) time.2-Aeration Basins Screening 54'6" x 12' x 13'3" Activated Sludge Training Sanitary Waste Treatment 601 1 -Clarifier System*- 20 ' 1 dier x Sedimentation Chlorine Contact Chamber Disinfection-* Note: Chlorine may be used intermittently to control algae growth in treatment units.Treatment process may be used based on influent characteristics. Outfall 501 is routed to Outfall 101. There have been no discharges from Outfall 501 since December 1992.*.. The West Plant is currently rated at 110,000 gallons per day (gpd) and the Training Plant at 66,000 gpd.Sanitary wastewater will increase beginning with the construction of two new electric generating units (3 and 4)and an increase in construction personnel. The physical locations of the treatment systems and Outfalls 401 and 601 may change; however, the outfall descriptions in the permit would remain the same (i.e., monitoring at the discharge from the sewage treatment plant)..... Disinfection may include sodium hypochlorite or calcium hypochlorite. I Technical Report 1.0 Page 3a Impoundment Information Table Pond# 1 Pond# 2 1 Pond# 3 Pond# 4 Pond# 5 Designation Organic Basin Inorganic Basin Neutralization Main Cooling Evaporation Pond (T) (D)(C)or (E) T T IT IT C Discharge Point Outfall Number 501 501 101001 none Liner Information Liner Type (C) (1) or (S) r1nftecU coicrnao [re~iftord concrns J rewnorced C~crete goo0 nd ceocete [nn Alt. Liner Attachment Reference n/a nfa n/a n/a n/a Dimensions Length (feet) 100 ft 25 ft 136 fl n/a fl 150 ft Width (feet) 80 ft 25 ft 42 fl n/a ft 70 ft Depth from Water Surface 17.5 ft 13.3 ft 16 ft 25 fl 4 ft Depth from Nat. Ground Level 0 avg 0.max 0 avg 0_max D0avg 0_hax 0 avg __0 max 0avg 0 max Freeboard (feet) >2 ft >2 ft >2 ft >2.5 ft >2 ft Surface Area (acres) 0.18 acres 0.01 acres 0.13 acres 7,000 acres 0.24 acres Storage Capacity (gallons) 1.000,000 gal. 50,000 gal. 600,000 gal. 6.6e10 gal. 314.160 gal.Pond# 6 Pond Ni _ Pond # __ Pond#- I_ Pond #__Essential Cooling Designation Po nnd (T) (D) (C) or (E) C Discharge Point Outfall Number None Liner Information Liner Type (C) (1) or (S) @oi s ct.Alt. Liner Attachment Reference n/a Dimensions Length (feet) 2,000 ft ft ft ft fi Width (feet) 1.000 ft. fi _ _ _f fl Depth from Water Surface 8 ft f _ ft ft ft Depth from Nat. Ground Level 0.avg 0.max _avg max avg max avg max ___avg ..max Freeboard (feet) >2 ft _ ft ft ft ft Surface Area (acres) 47 acres acres acres acres acres Storage Capacity (gallons) 1.3e8 gal. __ gal. __ gal. __ gal. __ gal.Technical Report 1.0, TCEQ-10055 (Revised 912006)Page 4 n/a THE FOLLOWING ITEMS ARE REQUIRED ONLY FOR NEW OR PROPOSED IMPOUNDMENTS.

b. Indicate by a check mark if any of the following data was provided with the application:

(1) Synthetic/plastic/rubber liner data (2) In-situ clay liner data

Attachment:

c. Are there any leak detection systems orground watermonitoring wells in place or planned? Yes -No_ If yes, indicate by a check mark that a separate attachment was provided with the leak detection system information for each pond and/or ground water monitoring well data.

Attachment:

d. Is the bottom of the pond above the seasonal high water table in the most shallow water bearing zone?Yes No___ If no, indicate by a check mark that additional information was provided describing the depth of the seasonal high water table in the most shallow water bearing zone in relation to the depth of the bottom of the new or proposed impoundment and how this may or may not impact groundwater.

e. Indicate by a check mark that the following information was provided:_ A USGS quadrangle map or a color copy of original quality and scale which accurately locates and identifies water supply wells and/or monitor wells within /2 mile radius of the impoundments.

-__ Copies of State Water Well Reports (driller's logs, completion data), and data on depths to ground water for water supply wells including a description of how the depths to ground water were obtained.For TLAP permit applications: _ Indicate by a check mark that the new or proposed impoundment(s) and the land application disposal area are located in the same general area and the information for this item is provided in Worksheet 3.0 (item 8).f. __ Indicate by a check mark if any data was provided with the application pertaining to the ground water, soils, geology, etc. used to assess the potential for migration of wastes from the impoundments and/or the potential for contamination of ground water or surface water.4. OUTFALL/DISPOSAL METHOD INFORMATION (instructions, pages 27-28)Complete the following tables to describe the location and wastewater discharge or disposal operations for each outfall for discharge operations and for each point of disposal for TLAP operations. For TLAP permit applications: Indicate the disposal method and each individual irrigation area (1), evaporation pond (E), or subsurface drainage system (S) by providing the appropriate letter designation for the disposal method followed by a numerical designation for each disposal area (e.g. evaporation pond, application area) in the space provided for "Outfalr' designation (e.g. "El" for evaporation pond 1, "12" for irrigation area No. 2, etc.).0 -.... ,_ n. 4 fl-=. ,,nd ,oe mn.. n,.,nn, Pape 5 I echnical Repos a 1.0, CE I DOM tne Sed 9 -,-- OUTFALL: 001 Latitude

• Longitude
• Location Description 28 144 T58 96 101 : 0 At a point in the blowdown line prior to entering the Colorado River Permitted Flow (MCD) Proposed Flow (MGD)Dly Avg Dly Max Dly Avg Dly Max Discharge Duration 144 120D 144 200 (hrs./day)
  • (days/mo.) (mo./year)

__ Pumped ! Gravity Measurement Device: estimate %If Intermittent Seasonal Continuous Contributing Wastestreams: Volume (MCD) % of Total Flow recirculated cooling water n/a** n/a**cooling reservoir blowdown previously monitored effluents storm water makeup water from Colorado River uncontaminated groundwater

• At spillway.

At blowdown at the river: N2844'46!, W9500'O2.-There has been no discharge from the outfall since March 4, 1997.OUTFALL: 101 Latitude

• Longitude Location Description 8 47 35 9 Where low volume waste sources commingled with previously 28 47 35 I monitored effluents (PME) are discharged from the neutralization basins prior to mixing with any other waste Permitted Flow (MGD) Proposed Flow (MCD) stream Dly Avg Dly Max Dly Avg Diy Max Discharge Duration n/a Inia nia n/a n/a (hrs./day) n/a (days/mo.)

!!a (mo./year) 4' Pumped -Gravity Measurement Device: totalizer .Intermittent Seasonal Continuous Contributing Wastestreams: Volume (MGD) % of Total Flow low volume waste sources commingled with 0.31" 100%previously monitored effluent (PME) from the metal cleaning waste system discharge storm water*At discharge into the MCR**Total outfall flow, average Jul 05 -Feb 09 Technical Report 1.0, TCEQ-10055 (Revised 9/2006)Page 6 ft OUTFALL: 201 Latitude

• Longitude*

Location Description 28 17 15 96 103 107 Where low volume waste sources are discharged from the oily waste treatment system prior to mixing with any Permitted Flow (MGD) Proposed Flow (MGD) other waste stream Dly Avg Dly Max Dly Avg Dly Max Discharge Duration n/a n/a rda n/a n/a (hrs./day) n/a (days/mo.) rIa (mo./year) / Pumped ;_" Gravity Measurement Device: tOtalizer v_ Intermittent Seasonal Continuous Contributing Wastestreams: Volume (MGD) % of Total Flow low volume waste sources from the oily waste 0.030"* 100%treatment system storm water*At discharge into the MCR"Total outfall flow, average Jul 05 -Feb 09 OUTFALL: 401 Latitude

• Longitude*

Location Description 27 At discharge from the sewage treatment plant (West Sanitary Waste Treatment System) prior to mixing with Permitted Flow (MGD) Proposed Flow (MGD) any other waste stream.Dly Avg Dly Max Dly Avg Dly Max Discharge Duration n/a n/a //a n/a (hrs./day) IVa (days/mo.) n/a (mo./year) Pumped _ Gravity Measurement Device: ultrasonic 1 Intermittent Seasonal Continuous Contributing Wastestreams: Volume (MGD) % of Total Flow treated sanitary sewage commingled with 0.028" 100%car wash water and air conditioning condensate storm water*At the discharge Into the MCR**Total outfall flow, average Jul 05 -Feb 09 Technical Report 1.0, TCEQ-10055 (Revised 912006)Page 7 OUTFALL: _01 Latitude* Longitude Location Description 28 147 19 9 0 5 Where metal cleaning wastes are discharged prior to , mixing with any other waste stream Permitted Flow (MGD) Proposed Flow (MCD)Dly Avg Dly Max Dly Avg Dly Max Discharge Duration n/a nra naa n/a (rs/day) rVa (days/mo.) n/a (mo./year) Pumped __ Gravity Measurement Device: estimate j_ Intermittent Seasonal Continuous Contributing Wastestreams: Volume (MGD) % of Total Flow metal cleaning waste n/a** n/a*storm water*Prior to mixing with Outfall 101**There has been no discharge from this outfall since December 1992.OUTFALL: 601 Latitude

• Longitude*

Location Description 28 147 115 96 102 110 At discharge from the sewage treatment plant (Training Sanitary Waste Treatment Facility) prior to mixing with Permitted Flow (MGD) Proposed Flow (MCD) any other waste stream Dly Avg Dly Max Dly Avg Dly Max Discharge Duration n/a n/a n/a n/a n/a (hrs./day) nia (days/mo.) n/a (mo./year) I/ Pumped -Gravity Measurement Device: ultrasonic 1_ Intermittent Seasonal ____Continuous Contributing Wastestreams: Volume (MGD) % of Total Flow treated sanitary sewage commingled with 0.026* 100%air conditioning condensate and HVAC cooling tower blowdown storm water*At discharge into the MCR**Total outfall flow, average Jul 05 -Feb 09 Technical Report 1.0, TCEC-10055 (Revised 9/2006)Page 7a

5. BLOWDOWN AND ONCE-THROUGH COOLING WATER DISCHARGES (Instructions, page 28)a. Does your facility use any cooling towers or boilers that discharge blowdown or other wastestreams to the outfall(s)?

V Yes __ No b. Does your facility discharge once-through cooling water to the outfall(s)? _ Yes *" No c. If yes to either item a or b, indicate with a check mark that the appropriate MSDS with the following information for each chemical additive was submitted with the application. Note: Not all of the Items below are included In the MSDSs./ Manufacturers Product Identification Number." Product use. (e.g., biocide, fungicide, corrosion inhibitor, etc.)_ Chemical Composition including Chemical Abstracts System (CAS) number for each ingredient. Classify product as non-persistent, persistent, or bioaccumulative. Product or active ingredient half-life.

• Frequency of product use (e.g., 2 hr/day once every two weeks).* Product toxicity data specific to fish and aquatic invertebrate organisms.

/ Concentration of whole product in wastestream (if above item is for whole product)* Concentration of active ingredient in wastestream (if above item is for active ingredient) Please provide a summary ofthis information in addition to the submittal ofthe MSDS for each specific wastestream and the associated chemical additives and specify which outfalls are affected.

Attachment:

See "Treatment Chemicals and MSDSs." d. Cooling Towers and Boilers Number of Units Daily Avg. Blowdown Daily Max Blowdown Cooling Towers 1 cooling towers Daily Avg: 7 , 2 0 0 gallons/day Daily Max:17,280 gallons/day Boilers 1 boilers Daily Avg:

• gallons/day Daily Max:*__ gallons/day
• 4022 gpd for approximately 5 days per year.6. STORM WATER MANAGEMENT (Instructions, pages 28-29)Are there any existing or proposed outfalls which discharge storm water runoff commingled with other wastestreams?

/ Yes -No. If yes, provide the following information. If no, proceed to Item No. 7.a. Provide a brief narrative description of the industrial processes and activities that occur outdoors or in some manner that may result in exposure of the materials to precipitation or runoff in areas where runoff is generated. Some storm water drainage from production and non-production areas is discharged through permitted outfalls. Some storm water drainage from production and non-production areas is discharged under a TPDES Storm Water General Permit. For production areas, at least the first flush of storm water runoff from SPCC sources and production equipment areas is collected and treated by the Oily Waste Treatment Systems (Outfall 201). Oil storage procedures are detailed In the facility's Integrated Spill Contingency Plan. Large storage tanks are located within secondary containment. Chemical storage tanks are located within secondary containment or curbed areas for spill control.Outdoor storage of equipment is limited to items that will not significantly affect storm water quality.Potential storm water contamination sources and best management practices for storm water runoff are addressed In the facility's Industrial Storm Water Pollution Prevention Plan.Technical Report 1.0. TCEO-1 0055 (RoviSed 9I2O06~ Page 8 Technical Report 1.0, TCEQ-1 0055 (Revised 912006)Page 8

7. DOMESTIC SEWAGE, SEWAGE SLUDGE, AND/OR SEPTAGE MANAGEMENT AND DISPOSAL (Instructions, page 29)a. Please check the appropriate method(s) ofdomestic sewage and domestic sewage sludge treatment/disposal and complete Attachment F if directed.Domestic sewage is not generated on-site. PROCEED TO ITEM NO. 8.Both domestic and industrial treatment sludge ARE commingled prior to use or disposal.

PROCEED TO ITEM NO. 8.1 Industrial wastewater and domestic sewage are treated separately and the respective sludge IS NOT commingled prior to sludge use or disposal. COMPLETE WORKSHEET 5.0 OF THIS APPLICATION. If your facility is a POTW, COMPLETE WORKSHEET 5.0 OF THIS APPLICATION. Facility is connected to a wastewater treatment plant permitted to receive domestic sewage, or the domestic sewage is transported off-site to a permitted facility for treatment and/ordisposal. COM PLETE ITEM NO.7.B.Domestic sewage is disposed of by an on-site septic tank. COMPLETE ITEM 7.B.Other. Please provide a detailed description below.rn/a b. Provide the name and TCEQ, NPDES, and/or TPDES Permit No- of the waste disposal facility which receives the domestic sewage/septage. If hauled by motorized vehicle, provide the name and TCEQ Registration No- of the hauler.Plant/Hauler Name Permit/Registration No.n/a 8. IMPROVEMENTS OR COMPLIANCE/ENFORCEMENT REQUIREMENTS (Instructions, page 29)Is the permittee currently required to meet any implementation schedule for compliance or enforcement? Yes I No If yes, provide a brief summary of the requirements and a status update.n/aI Technical Repott 1.0, TCEQ-10055 (Ravtsed 8/2006) Page 9 Technical Report 1.0, TCECI-10055 (Revt3ed 912006)Page 9

9. TOXICITY TESTING (Instructions, page 30)Have any biological tests for acute or chronic toxicity been made on any of your discharges or on a receiving water in relation to your discharge within the last three (3) years?Yes &No If yes, identify the tests and describe their purposes below. Please attach a copy of all tests performed that have not been previously sent to the TCEQ and/or EPA.The current TPOES permit contains routine blomonitoring requirements for discharges from Outfall 001. However, because there have been no discharges from Outfall 001 since 1997, biomonltoring has not been required.10. OFF-SITE/THIRD PARTY WASTES (Instructions, page 30)Do you receive wastes from off-site sources for treatment in your facility, disposal on-site via land application, and/or discharge via a permitted outfall? -Yes v/ No If no, proceed to Item No. 11. If yes, proceed as directed.a. Indicate with a check mark that a detailed attachment with the following information was provided with the application:

Attachment:

n/a List of wastes received Identified sources of wastes received Characterization of wastes received Name and addresses of generators Volumes of each waste received Description of the relationship of waste Info. on compatibility with on-site wastes source(s) with your facility's activities.

b. Is wastewater from a TCEQ, NPDES, and/or TPDES permitted facility commingled with your wastewater after your fimal treatment and prior to discharge via your final outfall/point of disposal?

-Yes V No If yes, provide the name, address, and TCEQ, NPDES, and/or TPDES permit number of the contributing facility and a copy of any agreements and/or contracts relating to this activity.c. Is your facility a Publicly Owned Treatment Works (POTW) that accepts process wastewater from any Significant Industrial User (SIU) and has or is required to have an approved pretreatment program under the NPDES/TPDES program? _ Yes ./ No If yes, complete Worksheet 6.0 of this application.

11. RADIOACTIVE MATERIALS (Instructions, page 30)Are radioactive materials mined, used, stored, or processed at this facility?

/' Yes No If yes, Provide a list of the materials and the results of one analysis of your effluent in picocuries per liter (pCi/L)for all radioactive parameters which may be present.Radioactive Materials Cone. (pCi/L)nuclear fuel (CAS no. 7440-61-1) 13,200 (tritium)Technical Report 1.0, TCEQ-1 0055 (Revised 9/2006)Page 10 THE FOLLOWING ITEMS ARE ONLY REQUIRED FOR EXISTING PERMITTED FACILITIES.

12. MAJOR AMENDMENT REQUESTS (Instructions, pages 30-31)Are you requesting a major amendment of an existing permit? _ Yes V_ No If yes, list each specific request and provide discussion on the scope of any requested permit changes.n/a If necessary, provide supplemental information or additional data that will support the request.13. MINOR MODIFICATION REQUESTS (Instructions, page 31)Are you requesting any minor modifications to the permit? -Yes '/ No Note: see the instructions for an exclusive list of changes considered as minor modifications.

If yes, list and discuss the requested changes.n/a 14. MINOR AMENDMENT REQUESTS (Instructions, page 31)Are you requesting any minor amendments to the permit? V Yes -No If yes, list and discuss the requested changes.1) Remove Item 14 from the Other Requirements of the permit because it refers to regulations for cooling water intake structures that do not apply to the closed-cycle recirculating system at the facility.2) Remove Item 15 from the Other Requirements of the permit because wastewater characterization data are provided with this application.

3) Add storm water to Ouffalls 101,401, 501, and 601. Storm water was listed In the 2004 TPDES renewal application for Outfalls 101, 401, and 601, but was not specifically described in permit. Storm water is a very small component of water that may discharge through Outfall 501 (there have been no discharges since December 1992). Storm water is already listed in the final Outfall 001.4) Add uncontaminated groundwater to Outfall 001. Groundwater from excavation during construction of new electric generating Units 3 and 4 will be routed to the Main Cooling Reservoir.

5) Allow analysis of total residual chlorine by DPD spectrophotometric method (EPA Method 330.5) In htem 5 In the Other Requirements of the permiL Technical Report 1.0, TCEQ-1 0055 (Revised 912006)Page I11 WORKSHEETS TO THE INDUSTRIAL WASTEWATER PERMIT APPLICATION TECHNICAL REPORT Please review the worksheet requirements in the instructions and indicate by checking either yes or no which worksheets are required, completed, and submitted with the technical report. Worksheets that are not applicable do not need to be submitted with the technical report.WORKSHEET COMPLETED AND SUBMITTED WITH THE TECHNICAL REPORT: YES NO 1.0: EPA EFFLUENT CATEGORICAL GUIDELINES

/2.0: POLLUTANT ANALYSES REQUIREMENTS /3.0: LAND DISPOSAL OF EFFLUENT 10 3.1: SURFACE LAND DISPOSAL OF EFFLUENT /3.2: SUBSURFACE LAND DISPOSAL OF EFFLUENT I 3.3: SUBSURFACE AREA DRIP DISPERSAL SYSTEM LAND DISPOSAL OF EFFLUENT 4.0: RECEIVING WATERS V/4.1: STREAM PHYSICAL CHARACTERISTICS WORKSHEET I 5.0: SEWAGE SLUDGE MANAGEMENT AND DISPOSAL 6.0: INDUSTRIAL WASTE CONTRIBUTION /7.0: STORM WATER RUNOFF 8.0: AQUACULTURE _" 9.0: CLASS V INJECTION WELL I 10.0: QUARRIES IN THE JOHN GRAVES SCENIC RIVERWAY /Note: Worksheet 11.0 Cooling Water Intake Structures is also included.Technical Report 1.0, TCEQ-1 0055 (Revised 912006)Page 12 WORKSHEET 1.0 -EPA EFFLUENT CATEGORICAL GUIDELINES REQUIRED FOR ALL APPLICATIONS FOR TPDES PERMITS FOR DISCHARGES OF WASTEWATERS SUBJECT TO EPA EFFLUENT LIMITATION GUIDELINES.

1. CATEGORICAL INDUSTRIES (Instructions, pages 34-35)Is your facility subject to any of thc 40 CFR effluent guidelines outlined in Table I? V Yes _ No If yes, provide the appropriate information in the table below. If no, this worksheet is not required.Industry CFR Steam Electric Power GeneratIng 423 2.a.PRODUCTION/PROCESS DATA (Instructions, page 35)Production data: Provide the appropriate data for effluent guidelines with production based effluent limitations.

Subcategory Actual Quantity/Day Design Quantity/Day Units n/a_ __ I-_ _ I __ I _b. Organ ic Chemicals, Plastics, and Synthetic Fibers Manufacturing Data (40 CFR Part 414): Provide each appropriate subpart and the percent of total production. Also provide the appropriate data for metal bearing wastestreams as required in 40 CFR Part 414, Appendices A and B.Subcategory % of total Appendix A and B production Metal Process n/a Worksheet 1.0, TCEQ-10055 (Revised 912006)Page I1-I

c. Refineries (40 CFR Part 419): Provide the applicable subcategory and a brief'justification for each.n/a 3. PROCESS/NON-PROCESS WASTEWATER FLOWS: Provide a breakdown of process wastewater flow(s) and non-process wastewater flow(s) as directed. (Instructions, page 35)See flow diagrams (7) following Worksheet 1: 1) Overall Flow Diagram 2) Flow Diagram -Outfall 001 3) Flow Diagram -Ouffall 101 4) Flow Diagram -Outfall 201 5) Flow Diagram -Outfall 401 6) Flow Diagram -Outfall 501 7) Flow Diagram -Outfall 601 With respect to effluent guidelines at 40 CFR 423, the facility does not generate the following types of wastewater:

coal pile runoff, fly/bottom ash transport water, and once-through cooling water.4. NEW SOURCE DETERMINATION: Provide a list of wastewater generating processes subject to effluent guidelines and the appropriate information. (Instructions, page 35)Process EPA Guideline Date Process/Construction Commenced Part Subpart Steam electric power generation 423 n/a Units 1, 2 1975 Units 3,4 2009 or 2010 (projected date)NRC Combined License --2012 (projected) Warksheet 1.0, TCEO-10055 (Revised 9/2006)Page 1-2 Evaporation Steam Electric from cooling reservoir & impoundments Plant Use//I Surface Water from the Colorado River* Y I Groundwater South Texas Project Electric:Generating Station Outfall 001O To Colorado River Storm Water Overall Water Row Diagram Notes: No discharge from this outfall since March 4, 1997 Somth U=5 Ped EIý GeMM"b S5*W TPflE9PeoNwO I9s My 2W5Q 0D 0 0 Low Volume Wastewater including wastewater from the following operations and sources:*demineraiizer regenerant wastewater;-condenser polishing regenerant wastewater;-boiler blowdown;-boiler drainage;-laboratory, instrument, and sampling sources;-well water filler backwash;-water softener regenerate;-floor drains in chemical storage containment areas;-rinse water from triple rinsing empty chemical drums;-fuel handling building HVAC blowdown; and-miscellaneous low volume wastewater. recirculation line.-........................................ V 4 t NEUTRALIZATION BASINS Neutralization* Mixing'Sedimentation s sludge to landfill I Oulfoll 101 I 0.3) MGD (Ju105- Fab 09 average)to Main Cooling Reservoir Metal Cleaning Waste Effluent (Outfall 501")Storm Water Notes: Flow Diagram -Outfall 101 5. T... Pm"O 11101010-U5o2 TPDES Porta DNG 0 Trealment may be used based on Influent quality Outfall 501 has not discharged since December 1992.U.t 2009'

0.9 sludge

to incineration and/or landfill..--" filter media to landfill Noles: Treatment process may be used based on Influeni characteristics Flow Dia gram -DOWtal 201&m "- PPMi~d Ue.kM G-b...bna n Ypoes P-ydN. eio Ma 5 May 9 I I I-, I I I Sludge to landfill .--TER ---r-1 ---Outfall 401 0.028 MGD (Jul 05 -Feb 09 Average)To Main Cooling Reservoir To Outfall 101 Flow Diagram -Outfail 501 Notes: Treatment process may be used based an influent charecledstlcs I n~A~ .. P. nus~*.nG.,..ene ~Mop 2 0 S------- -------DIGESTER Aerobic Digestion I Outfall 601 0.026 MGD (Jul 05 I I Tp To Main Cooling Reservoir Sludge to landfill WORKSHEET 2.0 -POLLUTANT ANALYSES REQUIREMENTS REQUIRED FOR APPLICATIONS SUBMITTED FOR A TPDES PERMIT. NOT REQUIRED FOR APPLICATIONS FOR A PERMIT TO DISPOSE OF ALL WASTEWATER BY LAND DISPOSAL OR FOR DISCHARGES SOLELY OF STORM WATER RUNOFF. (General Requirements: Instructions, Pages 36-37)1. TABLE 1: Complete table required for all external outfalls. (Instructions, Page 37)I Sfflue. nt Connrntra 'nn Irnartl Pollutants Samp. 1 Samp. 2 Samp. 3 Samp. 4 Average BOD (5-day) <2 <2 <2 <2 <2 CBOD (5-day) <2 <2 <2 <2 <2 Chemical Oxygen Demand 44.4 43 49.4 41.5 44.6 Total Organic Carbon 12.2 13.6 16.2 15.4 114.4 Dissolved Oxygen -----Ammonia Nitrogen <1 <1 <1 <1 <1 Total Suspended Solids 12.4 11.2 30.8 18 18.1 Nitrate Nitrogen <0.5 6.93 6.96 <0.5 3.6 Total Organic Nitrogen 0.75 0.210 4.76 3.5 2.3 Total Phosphorus <0.05 <0.05 0.0745 <0.05 0.037 Oil and Grease <5 <5 <5 <5 <5 Total Residual Chlorine 0.00 0.00 0.00 0.00 0.00 Total Dissolved Solids 2140 2270 2440 2430 2320 Sulfate 179 180 181 199 185 Chloride 971 960 1020 1040 998 Fluoride 0.990 0.991 0.953 1.02 0.988 Fecal Coliform <1 5 <1 <1 <1 (.eomeg Temperature(F) 65.7 -65.5 65.5 64.0 65.2 in)pH (Standard Units; min/max)8.66 8.77 8.75 8.80 8.74 Effluent Concentration (;tg/I) MAL (ILg/I)Total Aluminum 220 159 431 240 262 30 Total Antimony <5 <5 5.98 <5 3.37 60 Total Arsenic 11.1 10.1 15.3 10.6 11.8 10 Total Barium 392 440 442 418 423 10 Total Beryllium <4 <4 <4 <4 <4 5 Total Cadmium <5 <5 <5 <5 <5 I Total Chromium 5.66 <5 <5 <5 <5 10 Trivalent Chromium <10 <5 <5 <5 <5 N/A Hexavalent Chromium <10 <10 <1 0 <10 <10 10 Total Copper <5 <5 <5 <5 <5 10 Cyanide (total) <5 <5 <5 <5 <5 20 Total Lead <5 <5 <5 <5 <5 5 Total Mercury <0.2 <0.2 <0.2 <0.2 <0.2 0.2 Total Nickel 8.64 <5 <5 <5 4.04 10 Total Selenium 13.4 5.28 7.76 12.6 9.76 10 Total Silver <5 <5 <5 <5 <5 2.0 Total Thallium <5 <5 <5 <5 <5 10 Total Zinc <10 <10 <10 <10 <10 5*Because there have been no discharges from Outfall 001 since 1997, samples were taken from the Main Cooling Reservoir for effluent characterization, as allowed per the application instructions (pg. 1j7).Worksheet 2.0, TCEQ-10055 (Revised 912006) rage 2-1

2. TABLE 2: Complete table required for all external outfalls which discharge process wastewater.

Partial table required for all external outfalls with nonprocess wastewater discharges. Storm water runoff discharges commingled with other wastestreams shall complete the table as instructed (Instructions, Page 37).Outfall No.: 001 EJCIOG Effluent Concentration (ig/l) (*])Pollutants Samp. 1 Samp. 2 Samp. 3 Samp. 4 Avera2e MAL (ttg/I)Benzene <5 <5 <5 <5 <5 I0 Benzidine <20 <20 <20 <20 <20 1;0 Benzo(a'anthracene <5 <5 <5 <5 <S 0 Bertzo(a)pvrene <5 <5 <5 <5 <5 10 Carbon Tetrachloride <5 <5 <5 <5 <5 10 Chlorobenzene <5 <5 <5 <5 <5 I0 Chloroform <5 <5 <5 <5 <5 10 Chrvsene <5 <5 <5 <5 <5 10 Cresols <5 <5 <5 <5 <5 Dibromochloromethane <5 <5 <5 <5 <5 10 1.2-Dibromoethane <2 <2 <2 <2 <2 2 1,4-Dichlorobenzene <5 <5 <5 <5 <5 1 1 1.2-Dichloroethane <5 <5 <5 <5 <5 10 I.l-Dichloroethvlene <5 <5 <5 <5 <5 !0 Fluoride (mg/L) 0.990 0.991 0.953 1.02 0.988 Soo H<exachlorobenzene <5 <5 <5 <5 <5 I(Hexachlorobutadiene <5 <5 <5 <5 <5 U)Hexachloroethane <5 <5 <5 <5 <5 20 Methyl Ethyl Ketone <20 <20 <20 <20 <20 50 Nitrobenzene <5 <5 <5 <5 <5 IQ n-Nitrosodiethylamine <5 <5 <5 <5 <5 20 n-Nitroso-di-n-Butvlamine <5 <5 <5 <5 <5 20 PCB's. Total (*3) <1 <1 <1 <1 <1 I Pentachlorobenzene <5 <5 <5 <5 <5 ?0 Pentachlorophenal <25 <25 <25 <25 <25 so Phenanthrene <5 <5 <5 <5 <5 10 Pyridine <5 <5 <5 <5 <5 20 1.2.4.5-Tetrachlorobenzene <10 <10 <10 <10 <10 20 Tetrachloroethylene <5 <5 <5 <5 <5 I0 Trichloroethvlene <5 <5 <5 <5 <5 10 1 Jl-Trichloroethane <5 <5 <5 <5 <5 l0 2,4.5-Trichlorophenol <10 <10 <10 <10 <10 so"rHM (Total Trihalomethanes) <5 <5 <5 <5 <5 1 0 Vinyl Chloride <10 <10 <10 <10 <10 10 (*1) Indicate units if different from ptg/l.(*2) MAL's for Cresols: p-Chloro-m-Cresol 10 tg/l; 4,6-Dinitro-o-Cresol 50 Vg/l; p-Cresol 10 gg/l (*3) Total of PCB-1242, PCB-1254, PCB-1221, PCB-1232, PCB-1248, PCB-1260, PCB-1016.Wocksheet 2.0. TCEO-10055 (Revised 912006)Page 2-2

3. TABLE 3: Partial table (only those pollutants which are required by the conditions specified) required for each external outfall. Not required for internal outfflls. (Instructions, Page 38)a. TRIBUTYLTIN:

Is your facility or will your proposed facility be an industrial/commercial facilities which directly disposes of wastewater from the types of operations listed below or a domestic facilities which receive wastewater from the types of industrial/commercial operations listed below? _ Yes v/ No If yes, indicate with a check mark all ofthe following criteria which apply and provide the appropriate testing results in the table below._ Manufacturers and formulators of tributyltin or related compounds. Painting of ships, boats and marine structures. ___ Ship and boat building and repairing. Ship and boat cleaning, salvage, wrecking and scaling.___ Operation and maintenance of marine cargo handling facilities and marinas_ Facilities engaged in wood preserving ___ Any other industrial/commercial facility for which tributyltin is known to be present, or for which there is any reason to believe that tributyltin may be present in the effluent.b. ENTEROCOCCI Does your facility or will your proposed facility discharge directly into saltwater receiving waters?/' Yes No If yes, provide the appropriate testing results in the table below.TABLE 3 Outfall No.: Z -']C G Effluent Concentration (ItP/)Pollutants SamD. 1 SamD. 2 Samn. 3 Samo. 4 Averane MAL (uP/1)Tributyltin n/a n/a n/a n/a n/a 0.010 Enterococci ..... N/A*Outfall 001 discharges to Segment No. 1401 Colorado River Tidal. For bacteriologic analyses, fecal coliform was analyzed (see Table 1) to be consistent with TPDES permit requirements (Other Requirements, Item 15).0 0 Worksheet 2.0, TCEO-10055 (Revised 912006)Page 2-3

4. TABLE 4: Complete table required for all external outfalls which discharge process wastewater and other wastewaters, which may contain pesticides or herbicides, from a facility which manufactures or formulates pesticides or herbicides.

Not required for internal outfalls. (Instructions, Page 38)Does your facility manufacture or formulate pesticides or herbicides? If yes, provide the appropriate testing results.TABLE 4 Yes / No Outfall No.: EIC CG Effluent Concentration (ja/1) (*I) MAL Pollutants Samp. I Samp. 2 Samp. 3 Samp. 4 Ave. (pg/l)Beta-hexachlorocyclohexane 0.05 Carbaryl 5 Chlordane 0.15 Chlorpyrifos .... 0.05 2,4-D 10 Danitol ---4,4'-DDD 0.1 4,4-DDE 0.1 4,4'-DDT 0.1 Demeton 0.2 Diazinon 0.5 Dicofol 20 Dieldrin 0.1 Diuron 0.09 Endosulfan I (alpha) 0.1 Endosulfan 1I (beta) 0.1 Endosulfan Sulfate 0.1 Endrin 0.1 Gamma -Hexachlorocyclohexane (Lindane) .._0.05 Guthion 0.10 Heptachlor 0.05 Heptachlor Epoxide 1.0 Hexachlorophene 10 Malathion 0.10 Methoxychlor

2.0 Mirex

0.2 Parathion _0.1 Toxaphene 5 2.4,5-TP (Silvex)_ 2* Indicate units if different from mg!L.0 Worksheet 2.0, TCEQ-10055 (Re-Ased 912006)Page 2-4

5. TABLE 5: Complete table required for all external outfalls.

Not required for internal outfalls.(Instructions, Page 38)TABLE 5 Outfall No.: 001" IC WIJG Believed Believed Effluent Concentration (ma/1)Pollutants Present Absent Average Maximum No. of Samples Bromide x 7.03 7.11 4 Color(PCU) x 102 151 4 Nitrate-Nitrite(as N) x <0.5 <0.5 4 Sulfide(as S) X 0.034 0.0601 4 Sulfite(as SO,) x ...Surfactants x 0.122 0.158 4 Total Antimony x 0.00337 0.00598 4 Total Beryllium x <0.004 <0.004 4 Total Boron x 1.26 1.36 4 Total Cobalt x <0.005 <0.005 4 Total Iron X 0.130 0.223 4 Total Magnesium x 83.0 87.6 4 Total Molybdenum x 0.0360 0.117 4 Total Manganese x 0.0235 0.0304 4 Total Thallium x <0.005 <0.005 4 Total Tin X <0.05 <0.05 4 Total Titanium "_ x <0.02 <0.02 4*Because there have been no discharges from Outfall 001 since 1997, samples were taken from the Main Cooling Reservoir for effluent characterization, as allowed per the application instructions (pg. 37).-EPA 200.7 used for titanium analysis.*Initial test results for suffites ranged from 24-52 mg/L, but are believed to be false positives due to matrix interference. These samples were collected from the Main Cooling Reservoir. It is an open air Impoundment where oxygen in the water would readily oxidize sulfite to sulfate. Dissolved oxygen was measured in the recirculating loop from the reservoir following the sulfite analyses and found to be over 5 mg/L, indicating that no sulfite could be present.Worksheet 2.0. TCE3-1 0055 (Revised 912006)Page 2-5

6. TABLE 6: Indicate with a check mark any of the industrial categories applicable to your facility.

If testing is required, indicate with a check mark in the box provided that the testing results for the appropriate parameters in Table B-7 are provided with the application. (Instructions, Page 39)N/A (C/MNS Testino Rnllirdt VVr H88 _ Adhesives and Sealants___ Aluminum Forming_ Auto and Other Laundries Battery Manufacturing _ Coal Mining_ Coil Coating Copper Forming__ Electric and Electronic Components ___ Electroplating ___ Explosives Manufacturing ___ Foundries Gum and Wood Chemicals Subparts A,B,C,E Subparts D,F Inorganic Chemicals_ Iron and Steel Manufacturing _ Leather Tanning/Finishing _ Mechanical Products Manufacturing Nonferrous Metals Mfg._ Ore Mining(Subpart B)Organic Chemicals, Plastics, and Synthetic Fibers_ Paint and Ink Formulation ___ Pesticides _ Petroleum Refining_ Pharmaceutical Preparations Photographic Equipment and Supplies_ Plastic and Synthetic Materials Manufacturing _ Plastic Processing-Porcelain Enameling_ Printing and Publishing _ Pulp and Paperboard Mills Subparts A Subparts B,C,D,R__Subparts F,G H,I,K,L,M,N,O,P Subparts E,Q,S,T-Subparts J,U Rubber Processing Soap and Detergent Manufacturing V Steam Electric Power Plants__Textile Mills (Not Subpart C)_ Timber Products Processing Volatile Yes "i Yes "]Yes Li Yes E" No Yes --Yes ID Yes EL Yesi--No Yes --Yes E-Yes EL Yes--I YesF--Yes[-Yes LI Yes '-No Yes EL Yes F-'Yes El Yes !]Yes "'Yes -'Yes EL Yes--No Ycsfl YesLi Yes -'Yes ID Yes E]Yes 1--Yes W]Yes Li Yes Li Acid Yes E]Yes[[]Yes EL No No Yes [-Yes ['-Yes --Yes Yes fl Yes E Yes --Yes EI-Yes --Yes E1-Yes E--Yes F-1 Yes 1--Yes F--Yes El Yes []Yes Li No Yes[--Yes Li Yes No No Yesf-Yes--Yes-Yes Li Yesl-Yes Li Yes[-" Yes fl Yes '7 Yes[-]Yes 1"-Base/Neutral Yes E" Yes []Yes EL Yes EL No Yes Fi Yes E-" Yes D-Yes 1-" Yes Yes HL No Yes "'Yes LI Yes -]Yes'--Yes FL Yes [--No Yes EL Yes Yes Li No Yes --Yes ID Yes EL No No Yes EL Pesticides No No Yes-]No No No No Yes E No No No No No No No No No Yes F-E No Yes[-No Yes EL No No No Yesv-i No No Yes EL* EL Yesf-]* F-1 * --*E L Yes --]Yes -"

• F-" Yes M No Yes Ei No No No Yes EL No Yes["l Yes D-* Test if "believed present" Worksheet 2.0, TCEQ-10055 (Revised 912006)Page 2-6

7. TABLE 7: Please complete as directed and only for those parameters specified in Table 6. Required for all external outfalls which contain process wastewater.

Not required for internal outfalls.Testing may be required for types of industry not specified in Table 6 for specific parameters if believed present (Instructions, Page 39).TABLE 7 Outfall No.: 001" LC 12) Effluent Concentration (awl) *Polutants Average Maximum No. of Samples MAL (go)VOLATILE COMPOUNDS Acrolein <50 <50 4 Acrylonitrile <10 <10 4 50 Benzene <5 <5 4 t0 Bromoform <5 <5 4 10 Carbon Tetrachloride <5 <5 4 10 Chlorobenzene <5 <5 4 10 Chlorodibromomethane <5 <5 4 to Chloroethane <10 <10 4 50 2-Chloroethylvinl Ether <10 <10 4 10 Chloroform <5 <5 4 10 Dichlorobromomethane <5 <5 4 10 1,l-Dichlomethane <5 <5 4 10 1,2,-Dichloroethane <5 <5 4 10 1,l-Dichloroethylene <5 <5 4 10 1,2-Dichloropropane <5 <5 4 10 1.3-Dichloropropylene <5 <5 4 10 Ethylbenzene <5 <5 4 10 Methyl Bromide <10 <10 4 50 Methyl Chloride <10 <10 4 50 Methylene Chloride <5 <5 4 20 1,1,2,2-Tewrachlorocthane <5 <5 4 10 Tetrachloroethylene <5 <5 4 10 Toluene <5 <5 4 10 1,2-Trans-Dichlorocthylene <5 <5 4 10 1, 1, 1 -Trichloroethane <5 <5 4 10 1, 1,2-Trichloroethane <5 <5 4 10 Trichloroethylene <5 <5 4 10 Vinyl Chloride <10 <10 4 10*Because there have been no discharges from Outfall 001 since 1997, samples were taken from the Main Cooling Reservoir for effluent characterization, as allowed per the application instructions (pg.37).Worksheet 2.0, TCEQ-10055 (Revised 912006)Page 2-7 Effluent Concentration (ag/) S f Pollutants Average Maximum No.of Samples MAL (Ag/i)ACID COMPOUNDS 2-Chlorophenol <5 <5 4 10 2,4-Diehlorophenol <5 <5 4 10 2.4-Dimethvlphenol <5 <5 4 10 4.6-Dinitro-o-Cresol <25 <25 4 50 2.4-Dinitroohenol <25 <25 4 50 2-Nitrophenol <5 <5 4 20 4-Nitroohenol <25 <25 4 50 P-Chloro-m-Cresol <5 <5 4 10 Pentachlorophenol <25 <:25 4 50 Phenol <5 <5 4 10 2.4.6-Trichlorophenol <5 <5 14 10 BASE/NEUTRAL COMPOUNDS Acenaphthene <5 <5 4 10 Acenaphthvlene <5 <5 4 10 Anthracene <5 <5 4 10 Benzidine <:2o <20 4 50 Benzo(a)Anthracene <5 <5 4 10 Benzo(a)Pvrene <5 <5 4 10 3.4-Benzofluoranthene <5 <5 4 10 Benzo(ghi)Pervlene <5 <5 4 20 Benzo(k')Fluoranthene <5 <5 4 10 B is(2-Chloroethoxv) Methane <:5 <5 4 10 Bis(2-Chloroethvl) Ether <5 <5 4 10 Bis(2-Chloroisopropvi)Ether <5 <5 4 10 Bis(2-Ethylhexvl)Phthalate <5 <5 4 10 4-Bromophenyl Phenyv.Ether <5 <5 4 10 Butvlbenzvl Phthalate <5 <5 4 10 2-chloronaohthalene <5 <5 4 10 4-chlorophenvi phenyl ether <5 <5 10 Chrvsene <5 <5 4 10 Dibenzo(ah)Anthracene <5 <5 4 20 1.2-Dichlorobenzene <5 <5 4 10 1.3-Dichlorobenzene <5 <5 4 10 1.4-Dichlorobenzene <5 <5 4 10 3.3-Dichlorobenzidine <10 <10 4 50 Diethvl Phthalate <5 <5 4 I0 Dimethyl Phthalate <5 <5 4 10 Di-n-Butyl Phthalate, <5 <5 4 10 2.4-Dinitrotoluene <5 <5 4 10 Worksheet 2.0, TCEQ-10055 (Revised 9W2006)Page 2-8 Effluent Concentration (6iIM) *Pollutants Average Maximum No. of Samples MAL (pg/I)BASE/NEUTRAL COMPOUNDS (conm)2,6-Dinitrotoluene <5 <5 4 10 Di-n-Octyl Phthalate .<5 <5 4 10 1,2-Diphenyl Hydrazine (as Azobenzene) <5 <5 4 20 Fluoranthene <5 <5 4 10 Fluorene <5 <5 4 10 Hexachlorobenzene <5 <5 4 10 Hexachlorobutadiene <5 <5 4 10 Hexachlorocyclopentadiene <5 <5 4 10 Hexachloroethane <5 <5 4 20 Indeno(I,2,3-cd)pyrene <5 <5 4 20 Isophorone <5 <5 4 10 Naphthalene <5 <5 4 10 Nitrobenzene <5 <5 4 10 N-Nitrosodimethylamine <5 <5 4 50 N-Nitrosodi-n-Propylamine <5 <5 4 20 N-Nitrosodiphenylaminc <5 <5 4 20 Phenanthrene <5 <5 4 10 Pyrene <5 <5 4 10 1,2,4-Trichlorobenzene. <5 1<5 4 10 PESTICIDES Aldrin n/a 0.05 aIpha-BHC n/a 0.05 beta-BHC n/a 0.05 gamma-BHC n/a 0.05 delta-BHC n/a 0.05 Chlordane n/a 0.15 4,4,-DDT n/a 0.1 4,4,-DDE n/a 0.1 4,4,-DDE n/a 0.1 Dicldrin n/a 0.1 alpha-Endosulfan ........ n/a 0.1 beta-Endosulfan n/a O.I Endosulfan Sulfate n/a 0.1 Endrin n/a 0.1 Endrin Aldehyde n/a 0.1 Heptachlor n/a 0.05 Worksheat 2.0, TCEQ-iOO55 (Revised W2006)Page 2-9 Effluent Concentration (PP/A)Pollutants Average Maximum No. of Samples FMAL (F gl)PESTICIDES (cont.) _Heptachlor Epoxide n/a PCB-1254 <1 <1 4 1.0 PCB-1221 <1 <1 4 1.0 PCB- 1242 < _ _ <1 4 PCB-1232 <i <1 4 1.0 PCB- 1248 <1 _ <1 4 1.0 PCB-1260 <l <1 4 1.0 PCB-1016 <1 <1 4 1.0 Toxaphene I _n/a 5.0 Indicate units if different from Rg/!Worksheet 2.0, TCEQ-1 0055 (Revised 912006)Page 2-10

8. TABLE 8 (DIOXINSIFURAN COMPOUNDS):

Please complete as directed. Not required for internal outfalls.(Instructions, Pages 39-40)a. Are any of the following compounds manufactured and/or used in a process at the facility?_ Yes / No If yes, indicate with a check mark the compound(s) which apply and provide a brief description of the conditions of its/their presence at the facility.-2,4,5-trichlorophenoxy acetic acid (2,4,5-T) CAS #93-76-5 2-(2,4,5-trichlorophenoxy) propanoic acid (Silvex, 2,4,5-TP) CAS #93-72-1__2-(2,4,5-trichlorophenoxy) ethyl 2,2-dichloropropionate (Erbon) CAS #136-25-4_____ 0,0-dimethyl 0-(2,4,5-rrichlorophenyl) phosphorothioate (Ronnel) CAS #299-84-3____ 2,4,5-trichlorophenol (TCP) CAS #95-954_ Hexachlorophene (HCP) CAS #70-30-4 b. Do you know or have any reason to believe that 2,3,7,8 Tetrachlorodibenzo-P-Dioxin (TCDD) or any congeners of TCDD may be present in your effluent? __ Yes V No If yes, provide a brief description of the conditions for its presence.nla c. If your responded yes to either item a or b, complete Table 8 as instructed. TABLE 8 Outfall E3C fl]G Wastewater Sludge Equivalent Concentration Equivalents Concentration Equivalents Compound Factors (ppq) (ppq) (ppt) (ppt) MAL (ppq)2,3,7,8-TCDD 1 10.0 I,2,3,7,R-PeCDD 0.5 50.0 2,3,7,8-HxCDDs 0.1 50.0 2,3,7,8-TCDF 0.1 10.0 1,2,3,7,8-PeCDF 0.05 50.0 2,3,4,7,8-PeCDF 0.5 50.0 2,3,7,8-HxCDFs 0.1 50.0 Total Worksheet 2.0. TCEO-10055 (Revised 912006)Page 2-11

9. TABLE 9 (HAZARDOUS SUBSTANCES):

Proceed complete as directed. Not required for internal outfalls.(Instructions, Pages 41)a. Are there any pollutants listed in the instructions (page 41) believed present in the discharge? Yes / No b. Are there pollutants listed in Item No. I.d. on Page No. 1 of this technical report which are believed present in the discharge and have not been analytically quantified elsewhere in this application? __- Yes / No If your responded yes to either item, complete Table 9 as instructed. TABLE 9 Pollutant & CAS Number Average Maximum No. of Analytical (jIg/i) (Wig/I) Samples Method n/a 0 Worksheet 2.0, TCEQ-10055 (Revised 912006)Page 2-12 STP Nuclear Operating Company TPDES 01908 Application May-09 Laboratories Providing Analyses Parameters Laboratory Field analyses (temperature, pH, total STP Nuclear Operating Company residual chlorine) (permittee) SPL Inc.All others 8880 Interchange Drive Houston, TX 77054 (713) 660-0901 0 Worksheet 2.0 Page 2-13 WORKSHEET 4.0 -RECEIVING WATERS THE FOLLOWING IS REQUIRED FOR ALL TPDES PERMIT APPLICATIONS !. DOMESTIC DRINKING WATER SUPPLY (Instructions, Page 54)Is there a surface water intake for domestic drinking water supply located within 5 (five) miles downstream from the point/proposed point of discharge? __ Yes V No If yes, identify owner of the drinking water supply, the distance and direction to the intake, and locate and identify the intake on the USGS map. Indicate by a check mark that the requested information is provided: 2. DISCHARGE INTO TIDALLY INFLUENCED WATERS (Instructions, Page 54)a. Width of the receiving water at the outfall? -300 feet b. Are there oyster reefs in the vicinity of the discharge? __ Yes V No If yes, indicate approximate distance and direction from outfall(s): n/a c. Are there any sea grasses within the vicinity of the point of discharge? __ Yes V/ No If yes, provide the distance and direction to the grasses: n/a 3. CLASSIFIED SEGMENT (Instructions, Page 54)Is the discharge directly into (or within 300 feet of) a classified segment? v' Yes __ No (See note* below.)'From Outfall 001, the discharge flows through a pipe -1 mile directly to the Colorado River.If yes, stop here. It is not necessary to complete items 4 and 5 and it is not necessary to complete Worksheet 2.1.If no, complete items 4 and 5.4. DESCRIPTION OF IMMEDIATE RECEIVING WATERS (Instructions, Page 55)Name of the immediate receiving waters: n/a a. Check the appropriate description of the receiving waters Man-made Channel or Ditch Stream or creek Lake or Pond Surface area acres. Average depth of the entire water body __ feet Average depth of water body within a 500-foot radius or the discharge point __ feet___ Freshwater Swamp or Marsh___ Tidal Stream, Bayou, or Marsh___ Open Bay Other: If a man-made channel, ditch or stream was checked above, provide the following:

b. Check one of the following that best characterizes the area upstream of the discharge.

For new discharges, characterize the area downstream of the discharge (check one)._ Intermittent (dry for at least one week during most years)___ Intermittent with Perennial Pools (enduring pools containing sufficient habitat to maintain significant aquatic life uses)___ Perennial (normally flowing)Worksheet 4.0, TCEQ-10055 (Revised 912006)Page 4-1 Check the method used to characterize the area upstream (or downstream for new dischargers): USGS flow records,__ personal observation, _ historical observation by adjacent landowner(s), _ others, specify: c. List the name(s) of all perennial streams that join the receiving water within three miles downstream of the.discharge point: n/a d. Do the receiving water characteristics change within three miles downstream of the discharge? (e.g., natural or man-made dams, ponds, reservoirs, etc.) _ Yes __ No If yes, discuss how: e. Provide general observations of the water body during normal dry weather conditions: n/a Date and time ofobservation: _l/a Was water body influenced by storm water runoff during observations? Yes No 5. GENERAL CHARACTERISTICS OF WATER BODY (Instructions, Page 55)a. Is the receiving water upstream of the discharges or proposed discharge site influenced by (check as appropriate): oil field activities urban runoff_ agricultural runoff___ upstream discharge septic tanks__ Others, specify below b. Uses of water body, observed or evidences of (check as appropriate): __ livestock watering contact recreation non contact recreation __ fishing__ domestic water supply __ industrial water supply others- snecifv below__ irrigation withdrawal __ navigation __ picnic park activities

c. Check one of the following to best describe the aesthetics of the receiving water and the surrounding area: Wilderness:

outstanding natural beauty; usually wooded or unpastured area: water clarity exceptional Natural Arc : trees and/or native vegetation common; some development evident (from fields, pastures,dwellings); water clarity discolored Common Setting: not offensive, developed but uncluttered; water may be colored or turbid Offensive: stream does not enhance aesthetics; cluttered; highly developed; dumping areas; water discolored Waitsheot 4.0, TCEQ-10055 (Revised 91200)a Page 4-2 WORKSHEET 5.0 -SEWAGE SLUDGE MANAGEMENT AND DISPOSAL THE FOLLOWING IS REQUIRED FOR ALL TPDES PERMIT APPLICATIONS THAT MEET THE CONDITIONS AS OUTLINED IN TECHNICAL REPORT 1.0, ITEM NO. 7.1. SEWAGE SLUDGE SOLIDS MANAGEMENT PLAN (Instructions, Page 58)a. Is this a new permit application or an amendment permit application? -Yes v' No b. Does the facility discharge in the Lake Houston watershed? _ Yes V' No If yes to either item a or b, _ indicate by a check mark that a solids management plan was provided with the application.

2. SEWAGE SLUDGE MANAGEMENT AND DISPOSAL (Instructions, Pages 58-59)a. Please check the current sludge disposal method(s).

More than one method can be checked.V Permitted landfill Marketing and distribution by the permiittee-Registered land application site Composted by the permittee Surface disposal site (sludge monofill)Transported to another WWTP (written statement or contractual agreement required)Beneficial land application as authorized in the existing permit b. Disposal site name, TCEQ Permit/Registration Number and County where disposal site is located: Blue Ridge Landfill, Fort Bend County, permit no. 1505 c. Method of Transportation (truck, train, pipe, other) and hauler Registration Number: truck, Aqua Zyme Services, registration no. 21480 Transported in: liquid semi-liquid _ semi-solid 9' solid state Land application for: Reclamation Soil Conditioning

d. Ifthe existing permit contains authorization for sludge land application, composting, marketing and distribution of sludge, and/or sludge lagoons and authorization to renew the activity is being sought in the application, the appropriate sections of the Sludge Technical Report must be provided.3. PERMIT AUTHORIZATION FOR SEWAGE SLUDGE DISPOSAL (Instructions, Page 59)Are you requesting new authorization to beneficially land apply sewage sludge at this site or a site under your direct control? Yes %/ No Are you requesting new authorization to market and distribute sewage sludge at this facility or a facility under your direct control? Yes V No Are you requesting new authorization to compost sewage sludge? __ Yes V No Are you requesting new authorization to surface dispose sewage sludge at this site or site under your direct control?Yes V No Are you requesting new authorization to incinerate sewage sludge at this site or site under your direct control?Yes %/ No If yes to any of the above items, provide the information required in the SLUDGE TECHNICAL REPORT.New authorization for beneficial land application, incineration, and sludge lagoons in the TPDES or TLAP permits requires a mawor amendment to the permit. New authorization for composting may require a major amendment to the permit. See the instructions for an explanation whether a major amendment is required or if authorization for composting can be added through the renewal process.Worksheet 5.0, TCEQ-10055 (Revised 912006) Page 5-1 WORKSHEET 11.0 -COOLING WATER INTAKE STRUCTURES REQUIRED FOR ALL INDIVIDUAL TPDES PERMIT APPLICATIONS FOR: " MANUFACTURING FACILITIES CONSTRUCTED ON OR AFTER JANUARY 17, 2002* ALL POWER GENERATING FACILITIES 40 CFR Part 125, Subparts I and J regulate the cooling water intake structure(s) certain at power generation and manufacturing facilities.

40 CFR Part 125, Subparts I and J should be thoroughly reviewed prior to completing any portion of this worksheet.

1. Phase I Facilities

a. Applicability Please answer the following:

Facility Yes No N/A i. Is this facility def'ied as a new facility? /ii. Is this a point source that uses/proposes to use a cooling water intake structure to withdraw cooling water from waters of the /United States?iii. Does the facility have at least one cooling water intake structure that uses >25% of the water it withdraws for cooling purposes /(average monthly basis)?iv. Does the facility have a design intake flow _>2 MGD? " If yes to all of the questions, 316(b) Phase I is applicable to this facility and you will need to continue to Item 1.b. If no or N/A to any of the questions, stop here.b. Compliance Alternative Please indicate the compliance alternative selected for this facility.Corn plance Alternative Selected i. Track I, facilities withdrawing a 10 MGD ii. Track I, facilities withdrawing _ 2 MGD and <1 0 MGD iii. Track II c. Application Requirements The 316(b) Phase I Compliance Report has been submitted with this permit application as

Attachment:

n/a Please complete the table provided, indicating with an "x" that the information has been submitted.

• "ew facility means any building, structure, facility, or installation that meets the definition of a "new source" or "new discharger" in 40 CFR 122.2 and 122.29(bXl

), (2), and (4) and is a greenfleld or stand-alone facility; commences construction after January 17, 2002; and uses either a newly constructed cooling water Intake structure, or an existing cooling water intake structure whose design capacity is increased to accommodate the intake of additional cooling water. New facilities Include only "greenfield" and "stand-alone" facilities. A greenfield facility is a facility that Is constructed at a site at which no other source Is located, or that totally replaces the process or production equipment at an existing facility (see 40 CFR 122.29(b)(1)(1) and (i1)). A stand-alone facility is a new, separate facility that is constructed on property where an existing facility is located and whose processes are substantially independent of the'existing facility at the same site ( see 40 CFR 122.29(b){1)(iii)). New facility does not include new units that are added to a facility for purposes of the same general industrial operation (for example, a new peaking unit at an electrical generating station).0 Worksheet 11.0, TCEQ-100S5 (Revised 0912006)Page 1 1- 1 316(b) Phase I Compliance Demonstration Requirements 'The Design and Construction Technology Plan is required ONLY where: there are threatened and endangered or otherwise protected federal, state, or tribal species, or critical habitat for these species, within the hydraulic zone of influence of the cooling water intake structure; OR based on information submitted by any fishery management agency(ies) or relevant information, there are migratory and/or sport or commercial species of impingement concern that pass through the hydraulic zone of influence of the cooling water intake structure; OR it is determined, based on information submitted by any fishery management agency(ies) or other relevant information, that the proposed facility, after meeting the technology-based performance requirements in 40 CFR §125.84(b)(1), (2), and (3) would still contribute unacceptable stress to the protected species, critical habitat of those species, or these species of concern.Worksheet 11.0, TCEQ-10055 (Revised 0912006)Page 11-2

2. Phase [I Facilities

a. Applicability Please answer the following:

Yes No N/A i. Does this facility, as its primary activity, generate/transmit or generate/sell for transmission electric power?ii. Was the facility constructed prior to January 17, 2002? /iii. Is this a point source that uses/proposes to use a cooling water intake structure to withdraw cooling water from waters of the /United States?iv. Does the facility have at least one cooling water intake structure that uses >25%.of water withdrawn used exclusively for cooling /purposes (monthly average basis)?v. Does the facility have a design intake flow of>50 MGD? I/If yes to al_ of the questions, 316(b) Phase 11 is applicable to this facility and you will need to continue to Item L.b. If no or N/A to anv of the questions, stop here.b. Compliance Alternative Please indicate the compliance alternative selected for this facility.Compliance Alternative Selected (1) (i) Flow reduced commensurate with a closed-cycle recirculating system.(ii) Maximum through-screen design intake velocity reduced to 0.5 fl/sec.(2) Existing design/construction technologies, operational measures, and/or restoration measures meet the performance standards specified at 40 CFR§ 125.94(b) and/or the restoration requirements in 40 CFR § 125.94(c). (3) New in combination with existing design/construction technologies, operational measures, and/or restoration measures meet the performance standards specified at 40 CFR § 125.94(b) and/or the restoration requirements in 40 CFR § 125.94(c). (4) Approved design and construction technology in accordance with 40 CFR-_§ 125.99(a) or (b).(5) Site-Specific Determination of Best Technology Available (i) Costs significantly gr~e.ater than those considered by EPA (cost/cost)(ii)[ Cost significantly greater than benefits (cost/benefit)

c. Application Requirements The 316(b) Phase II Compliance Report has been submitted with this permit application as

Attachment:

See the attachled etterm lollowing this page: 1) Letter from STP Nuclear Operating Company to Mr. Kelly Holligan, Texas Commission on Environmental OualilTy (TCEO). May 24. 2007.2) e from Mr. Kelly Holligan. TCEO to STP Nuclear Operating Company, June 27, 2007.Please complete the table provided, indicating with an "x" that the information has been submitted. 316(b) Phase II Compliance Demonstration Requirements 0 Worksheet 11.0, TCEQ-10055 (Revised 09/2006)Page 11 -3 0 rr T1 46 CFR_~l2Z.2i Cnmnr~ha~n~iv~ DenIfln~tratlom1 Study ICI)S~Compliance Option i)(ii), 2 3 40CFR§122.21(r) Com rehensive Demonstration Study (CDS)*0 U D.I-U 42 42 0 42 U, U, I-U 91 0 Uý0.S 0 0 In.101 Technology &conmpliance assessment information 0 0-4U4 Information to support site-specific determination of best technology available for minimizing adverse environmental impact 0:: 0 U,U'0>~.f.0 C's c's 0 I-.Q L=rn/'0 0 tC 0 I ...-II 4 4 _ _ __'This compliance alternative demonstrates compliance with impingement perlormance standards only. Where entrainment performance standards are applicable, please also select a separate compliance alternative for entrainment and submit all applicable data, 2 The PIC is submitted ONLY where a FINAL PIG has not been previously submitted to the TCEQ."'l'he Restoration Plan is submitted ONLY where the facility proposes restoration measures.4 Thc Verification Monitoring Plan is submitted ONLY where the facility proposes design and construction technologies and/or operational measures.Workshee 11.0, TCEQ-10055 (Reviscd 09)2006)Page 11-4 Nuclear Operating Company Souh R d ckcw c .rL- t Szauan P0 .ar 2*2 b Traw 77483 .May 24, 2007 NOC-TX-07016176 PFN: W02 STI No. 32165797 Mr. Kelly Holligan Team Leader, Industrial Wastewater Permits Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Re- Cooling Water Intake Structures Phase II Rules South Texas Project Electric Generating Station TPDES Permit No. 01908

Dear Mr. Holligan:

Thank you for meeting with my staff on May 15, 2007 to discuss the South Texas Project Electric Generating Station (STPEGS) cooling reservoir and other wastewater discharge permit issues. Based on our discussion, STP Nuclear Operating Company (STPNOC) is submitting the following information regarding the Main Cooling Reservoir (MCR) and the applicability of the regulations for cooling water intake structures. We are confident that the South Texas Project Station (STP) complies with the regulation by employing a closed-cycle recirculating cooling system as defined in 40 CFR §125.93. Pursuant to 40 CFR §125.94(a)(1)(i), cooling water flow for this facility is commensurate with a closed-cycle recirculating cooling system, as demonstrated below. Additional technical information is included in letters dated March 7, 2005 and August 18, 2005 previously submitted to the Texas Commission on Environmental Quality (TCEQ).STP is located on 12,220-acres in Matagorda County, approximately 15 miles southwest of Bay City along the west bank of the Colorado River. The facility consists of two electric-generating units, which share a closed-cycle recirculating cooling reservoir. Water from the MCR is passed through the cooling loops of both units then returned to the MCR for heat dissipation before cycling back through the cooling systems.The MCR is a perched, off-channel, on-site industrial cooling impoundment of approximately 7,000 acres, impounding over 202,600 acre-feet of cooling water at'its maximum operating level.Dikes are installed in the MCR that channel the water flow to maximize circulation time for heat dissipation before the water is recirculated back to the generating units. Blowdown from the MCR to the Colorado River has not occurred since March 1997. Should blowdown be required it would occur through an underground pipe that discharges back into the Colorado River. This point is designated as Outfall 001 in the TPDES Permit No. 01908. The MCR is also equipped with a gated spillway for emergency use. The MCR is not a "water of the U.S." as defined at 40 CFR § 122.2. The MCR is not considered a "water of the State" based on internal and external outfall designations in the permit. The MCR is on private property and exists solely for Mr. Kelly Holligan May 24, 2007 Page 2 industrial cooling. It is not a publicly managed water body and has no recreational uses. The general public has never had access to the MCR nor is any planned in the foreseeable future.The only sources of new water to the MCR are direct rainfall and make-up water diverted periodically from the Colorado River, primarily at high river flows. Water from the Colorado River is pumped approximately I mile via a 1 0 inch pipe to the MCR. To protect inflows during low river flow conditions, the water right for STP includes a special provision to limit diversion from the Colorado River to 55% of the flow over 300 cubic feet per second, to protect inflows during low river flow conditions. Currently, the intake consists of trash racks, rotating screens with 3/8 inch mesh and 4 pumps. In addition, the reservoir makeup pumping facility has the following design: " The traveling water screens are flush with the river shoreline;

• The maximum approach velocity to the traveling water screens is 0.5 feet per second;* Fish passageways were constructed in the wing walls between the traveling screens to facilitate fish migration parallel to the screen surfaces; and" A sluice and discharge line was installed for the purpose of returning all impinged organisms directly to the river, downstream of the intake structure, immediately after being backwashed from the screens.The pumps are operated intermittently based on reservoir level, river flow, and the operability of the makeup pumping facility.

A cooling reservoir evaporates less water per unit of heat dissipated than a cooling tower, thus dissolved solids build up more slowly over time. This is complemented by the designed seepage from the MCR, which maintains the structural integrity of the reservoir embankment. Rainfall further dilutes the dissolved solids in the MCR. These factors minimize the blowdown and make-up required to maintain MCR water quality. As a result, intake water flow for cooling purposes at STP reflects best technology available (closed-cycle recirculating systems) for minimizing adverse environmental impact.As was discussed in the May 15, 2007 meeting, several provisions of the Phase II rule are in the process of being suspended by the U.S. Environmental Protection Agency and the Regional Administrators have been authorized to review the applicability of the rule on a case by case basis using Best Professional Judgment. Based on that authorization and the information provided, STPNOC is requesting that TCEQ designate the MCR as a closed-cycle recirculating system. We are also requesting concurrence that the MCR does not meet the definition of a"water of the State". If you have any questions or require additional information, please contact Ms. S. L. Dannhardt at (361) 972-8328.Sincerely, R A. Gangluff Manager, Chemistry Environmental and Health Physics Mr. Kelly Holligan May 24, 2007 Page 3 cc: Mr. Earl Lott Special Assistant, Office of Perm;it-ing, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Ms. Susan Jablonski Special Assistant/Radioactive Waste Specialist Office of Permitting, Remediation & Registration Texas Commission on Environmental Quality P.O. Box 13087 Austin, TX 78711-3087 Kathleen Hartnett White, Chairman /Larry R. Soward, Commissioner _ , .H. S. Buddy Garcia, Commissonrter ,.Glenn Shankle, Executive Director TEXAS COMMISSION ON. ENVIRONMENTAL QUALITY Protecting 7eras by Reducing and Preventing Pollution June 27, 2007 Mr. R.A. Gangluff, Manager, Chemistry Environmental and Health Physics STP Nuclear Operating Company P.O. Box 289 Wadsworth, Texas 77483 Re: Cooling Water Intake Structures Phase !I Rules; South Texas Project Electric Generating Station;TPDES Permit No. WQOOO 1908000.

Dear Mr. Gangluff:

I received your letter dated May 24, 2007, requesting that the Main Cooling Reservoir (MCR) be designated as a closed-cycle recirculating system and as not water in the state.The Texas Commission on Environmental Quality (TCEQ) does not have an official method of"designating" a facility's operation as a closed-cycle recirculating system. However, we have reviewed the information you submitted and based on our best professional judgement, we consider your facility to be a closed-cycle recirculating system. As mentioned in your letter, the federal rule governing the 316(b)Phase II cooling water intakes is currently in the process of being suspended. For the time being, implementation of the 316(b) requirements will be based on best professional judgement (BPJ) and subject to EPA Region VI review.We also concur that the Main Cooling Reservoir (MCR) at your facility does not meet the definition of water in the state.If you have any questions, please contact me at (512) 239-2369.Sincerely, Kelly Holligan, Leader Industrial Team Water Quality Division KH/jp P.O. Box 13087

• Austin, Texas 78711-3087
• 512-239-1000 a Internet address: www.tceq.state.tx.us Attachments TMV ps BANIZ(S Water Well Report ENVIRONMENTAL DATA A DMVSION OF THE BANKS GROUP Map of Wells within I Mile(s)9W 9 4 I U, I I, SAO ° One inch = 0.39 miles o : Sc'moot E State 9Centary ]Lc. Aes,, One-Mile Radius Around Outfall N SL-ftedACCESS HwY m WOWpn Sp.ao Pnon,-t , Rairoa duo,,atua Oom 001 Blowdown at Riv Secondary Hwhvy Churcht WMt. Roads Trat I u-- txrsoehold Banks Environmental Data[ Hogta arse -MirVy 1601 Rio Grande Suite 500 Austin, Texas 787017 Tower Custod, t PH 512-478-0059 FAX 512-478-1433

rtTM B( Water Well Report jjENVIRONMENTAL DATA A DIVISION OF THE BANKS GROUP DETAILS.p-~ i~) 0wnero Wl Ty ofel Dpthj :Cmp~iet 'od~Lttd~Dil~L-" 1 101055 .... Gen Miller Domestic 720 87/2006 -95.99694 28ý74499-2 80-24-302, Southeem Minerals Corp. blank ., -96.0075 28.74499 View. U>3 80-i6-9 Two River Cattle Co. Domestic 130 11/21/2001 -96.00105 28.7547' View 3 8-816 9 .T-_VoRivwerCatt6 -Co 130. 11/21/2001 _ 096;O101 28.75478 View 3 80-16-9 Two River Cattle Co. Domestic 130 11/2112001 -96.00113 28.75478 Vie.w 81-17-1 Jane Cox,-, Domestic .140 ,,8115/1999 ,-95.99007 2.7 35 j 5 G1610019A. EXOTIC ISLE SUBDIV Public Supply 548 -96.00111 28.75916 WATER SYSTEM.5 80-16-903 Exotic Isle Subd PUBLIC 548 -96.00138 28.75944', .SUPPLY 5 8950 Exotic'Isle Home Owners Public Supply 330 3/20/2002 -96.00138 28.75972 Association A S 1601 Rio Grande Suite 500 Austin, Texas 78701 PH 512.478.0059 FAX 512.478.1433 E-mail banks@banksinfo.com 0 CROSS REFERENCE SHEET No"e or Subject Cg-O,,;D Dote Located Well Data TA 80-24-302 Regoading Elecyric Log SEE Iftme or subject GW- SC ELECTRIC LOG FILE Q-665 B-152(62-1) 0 Send ofigins: ompy ty cr.nled reawun rat.pl raquired rel INRCC, MC 177. P.O. Box 1307, A.tin, TX 78711431W. 4 VTTENTMIN OWNER: Carddentieliy Texas WaiterWell Drillers ANvoutry Counell rkge fOiI on on rena State Texas me177 For olfO*Ter'rc~yfjork)P.O. Box 1WO87 waG Qwi°er copy+ (p"k) 'WELL REPORT AiusinTl78711-39S 512.239-0530 iNMie) (Strele or RFDI (City) (Sl.re) (Zip)2) ADDRE W , ,, GRI D /t__t (Strdeet, W.D Or oDler) (Gil) (SiAXc) VZi3).3) TYPE9FWDRK(Chocl):

4) PAOPOSEDUSE.(Check):

fl Monitor 0 Enviionmrtntal, Sollo.'t i' 5)0Wel 0 DeeWlng f IndmrTal [] Irrnlgat'cn Injection [- PtfllcStpply Q) De-walerIng L-) lOSte4S E: Ractir.ioning Li fluqggg If'PubtikSupplywel. were plans subtrrledtoiheTNRCC? .'- Yga -No 8) WELL LO: OLA4NETER OF HOLE 7) DRILLING MEhODJo0hoek): [] Driven Da ta.e;p/) () From. M) To) 50 AirRawry Sfl'iRotary C. Bored r -17 surface a -', CabteTo'"l L Prom (ft.) To (iL) IDteeplpion and color of formiton materiel 0) Borehole (Cheek): 0 Open Mi-e D Stflght Wall go -A~c r] Underreerred 52 Gravel Fadrod [j1 Other -II Gravel Pa:ckd pive n-.erv, .. Irotm h. to .... it 747j- to .Sffy# ____ CASING. BLANK PIPE, AND WELL SCIIEEN DATA:____________________ --NW Stea", Piesteb. etc. Sewtn (ft I Gage Did. or Per'., Slled. etc. Casing O-) S creentflg,1cor -ersI Ftc n Ta Screen j--4 A-U.m 9) CBMEN11NGDATA WMA~ ? _ ft Io t (I.o _ ftNo.CfsCUSed M~tiitdttft, It .-aIt. No.c'sackauxowl__ __Cenvanteam -own Merthod olwerifloaatrnc!sbai dialiince. 5 ..A...s.IL.6L.......(Use reverse as/ie or wao Cent, copy. r necaesa."y)

13) TYPE PUMP: R r+/-L"j Turbtrie rja VS.i -eible C. Cyirdar rI-nrerr...... ....... ,--:. :- .:L;;iW)evtUo pumpb t.wls, cytd0F. let, rc., __- ft.19) SURFACE COMPLETION

-, o oc.lloc Surface S 3, I'l.d eRule 3 3 8.ii 2 2002[3 Spec:fled Steel Sleeve InjPed !RuLt 331. A )p/pproved Malrnative Ptcur Used[R.k M18.71V 14) WELL TESTS: Typ.cSl: Pumpg C) Baler ld Eeeinerr n ....< I 15) wATER QUALITY: Dut you kcowtngy penerter. n y m trata wric' cariined undesttabte coratiuerl ?j Yes &'No U ys, slmb, "REPORT OF ULMDESIRABLE WATER'TypeW o ,ler? -_ Depth Was a ctr'talerrinaysis ma:7 I j Yt* Li Ný11) WATER LEYVEL-r Static level _ _' It+. boowlarlduface Catre -Artesian he.w_ ___ gp.m. DGae ' " 12) PACKERS: Type DqW.I ilby ý,,rcify tral this WDll was mied cy ame (:r under my supoer/Icnn) tlhao a,, and wat:o the s .ttc herein are ;ra- to vie be fI rrttt kno.eRdge and I..ajncersand O,'Iaira: ean mpt uc tp~ivlof ltcraL 1ra l~crae~iligsbi~rcturralIc to: wpletL'e and cbpttt/. .-COMPANYNM E P1 >116 M WELL DRILLER'S LICENSE INOD.ADDRESS ADIS w&7 2bW __.. ............. (CITY).... ....................... (imto)... .. .. ..... .f cered Well , (ric"gJtPued Drile Trainea)-Plea-a attach olacule trog. lgcnenaitl and other prtlInent Inlormallon, if availa ble.DI N eR,-01 E9 (00 v. 05 9)Wnlre .T-hRCC Ye&;cw- DRILLER Pik -WELL OWNERý4 el 5-2 VO I .I .<-)- -.... S.dolvei~ co4 kat CDbyC04*l'ld ratirlO raoelge ratireimed Mai, MtBCC, MC 117, P.O. Box 13057, Austin, TX 78711-3067. n4D l kfTIENTIONOflt CoState of Texa Texas Waere Wall 01111crv Adv¶;oq C~utoil Ortdvftp NAm.7 on on teveme side.Saeo ea MC. 177 o~Wfl twr ~WELL REPORT Auztln.TiXh787-3087

1) OWNERT-00 if MEW 7'&ft 4tLe~ ADDRIESS 20/ _A? L~ bK / 1 7 )r 2) AEM Name) (Stre,0oeRfO) (CR~Y) (State) (ZIP)________________

-#X0 GRD)Stresl RFDt~ orhetwa (CMly (ivle) PPlp, 3) TYPEJ WOflK(Ch90k4:

Zf ý1 -Dwarfning 0 c ple t c'r-9 C2 pkwggrg 4) PMOPOSEDUSE(Cheok)

0 Mor&hor .1 Environentoral SoilBoring y'esomesic rtj tndusLial

I Iftrigtion 0 Ilactoz. 0l Pubilolcupply

[3 Do-wwoe1rg C1 Todwut If PubloSuplywell. war* plAns st ed to If,*T.NRCC7 D Yes C No 7) DRILUNG METHOD(.kc): C D.-.%o Al ROWY MAZVI Rotary OMrl"am.eyr r3 CableTool J0,l1d 0 __ _ _ _From Ill.) To (ft.) Descrption and color of formaiontelitaifrei B) *onrhoje Cotpletuofl CIeCk): rj Ot ýW# o* ca.2l~ight Wall If Gratvel P.!:kcd G*Vo l~IcrW l fr __________ '1. 0 _______ -I-CASING. BLANK PIPE, AND WELL SCREEN DATA;010.('A)NJew of.%feel, Nlas~. etc.p'ea., Vzotd. Inc.sevem ig.. if coflm7o!ch Sallingilt4 Gape Casing Screen 4- + ~- I A + -~---4--.---~- 4 Not IV' Vt:-~/ 1/(....... ______,__1 _ //Z i-]9) GEMENT'INODATA. e330.44V CnRe*Tvr.Ie 1-n -____ No _____ft. l~~~csed/Diefwote t3 saoti,- sysfan field Ones or otltor cowacnlreted contanrrl.'uon _i,.M-eirmo olver.fcailar. of above elsteý,e_ ___________(bee rewsre wda ttf r/cO Ownre~ copy. If necessay)131 TYPEPWAMP! lj Turthce E: Jet t /Sjljtuble C: Cyiroler M olther DeprhI Uto pum bowls, G hyrear. jet, eCC- _____ ft.10) SUJRFACE COMPLETION O o;aifliadSurlacc Slab h1001000 (RUl23Z3.44.'21(A'. L] Pilleus5A~apfe'Usoc jRrvht330.44(3](t:)]

14) WELL TESTS: Tirosfalif 0 PnMC 0 5Pc11" V/416d ) Est vrff5_____ ppw~w-th ____ldnsvdoewrvafter

-tva.15) WATEFIQUALflYý. Oldyou hrvcrwlfnit, enarafe any~ Strata which Contained undesirable cons:ituarre7 1I1 yes PI". lfy.e,xubýiEPORTOFU'~r-SifPAFOEWATFnfl Was a rCfo-X 3rsla"11 Made? 12, I'C5 0 No 11) WATEAIelEVFLJ. StatizlevelL.L..... -f. level~wLn suae Ayfes'art tkw_________ SPn Daote-D3r1e ....12) PACKERS: Iype Ihearey u'Mrfy Iflal U06 well was drild4oIb rro (v! w.Cm mry suparvr..on) and (ivu each and all of ft., 1cvroter.5 haroin ure I've to trko bestcf my unOvetr~e otd belief. I un&rser~md llba- lflrs~re fo .rpl ihnle~1thru 15 wili rmsRl In thre Ir~g() hr.i.1 ieumed fccmr 'ciAted rew.sibilfaI. COPANY NAMiE 8A1k~i~% 11 VAtE~t W O/C6 L' WELL DRILLER'S LICENSE NO. (~P ' __o S RF)(~rty) tstwo)9`1v~)L/ / \.~ (Signed)____ ______________(W. er -d) Patrofe~ar Pica". artamh etearic lee. ehandcal t aryeia and other pertinene t inormation, it hwailsbIe.-

• INRCC ~i 5 9 (Re. 00.21 90) LVytife-TIJRCC Viv-D~!Ll.~R

~rrk- VJ~tL OWUER ~ ~"-INnCC-01-9 (Rev- 06-21-96)0 Xnk -WEL L 0IW4EF?Ytrh;ow-Dr?!L1.rR L4 . Sewa or.M.Il co'py koer h. roLlm recempl rewuswsed m:t tNRCC, BC 177, P.O. Box 1307, Autdn.TX 78711I-30 4 bTTENTioN OWNER: CalnftoaMy ofe Texas Waler Wail Driller Advieory Cuncil movar &VON onaqms. State of Texas C 177' 4 WP.O. Box 1108?bfl7 Genoa o,, 0WELL REPORT Augtlnf,,71,711-,OS 512.,MB-30-D

1) owr"Ii'oý A'//ERC Csrt4C o 1 ADDRESS /?op/ffM r, Ilv 4 t 1 /(Name) (S:r811 or RFDO (City) (State) (Zip)C2 _ _ _ _ __ _ _ _ _ _ _ _ GRID. 0-6146-(Sliest, RFD o, cther) (City) tSla!;) (zip)3) TY!3.OFWORK(Chteck):

4)

Q Mort ,1 Entoe.'ntrnSoilflorgt'Mr omreak 6)"'NeWdJ n DcepitnIng Q] IndtustAl n Iriga.ort 9 In4eclion Q PubficE.ply De-weotung 9] TeO&Wr fo Rec-dwoning 93 Pluggln; ItPu.ltlcp_1TywelLweieplans submtedlotheTNRCCt 9J Yea 9 No 8) WELL LOt: DM~ROFMOL.

7) DRILLING MET;$0hect)

): ru- Dtion DataDrata 9Dl. D, FFP7. D Altrctry -, Muofotary 9 Bored Stre -- E AjrHeoeunre 9 CaoleTool 9Jstted X Fom (ft) To (ft.) Deacripllon bad CaOW of tormeatton mtalleal ) Borehole Completion (Check): 9 Hnle El &13iit Wel[3 lithderrmsmd Q GmvlPadred 9 te 01 "-"30 --'f ,'o! cvegvm, __ _ ___............ CASING, BLANK PIPE. AND WELL SCREEN DATA: New S:ee, PFute* eta. Setnrv ('L) Cage_,( or Pe t,-, aosetinn.- ras~g 4 .7( ,.) Usel Sceenr.g. iP V a oo " mn at Frcm -Sreen -4 lt k Lit-]0-IL 9) CEM!NTING DATA )tHui#338"4(1)j Cerreedttn ~ t to 0 ItNo. at sacks used /It___ to 11,I No. ofsacks used ____Methcd used #214 ________oorneredaty p0Ot 4rca14sN (use turere of WtN e0tof ct0,y. it ncessnr.vt

13) TYPE PUMP: 7'C] Turbho 9 Jet IlSýtrcrsoo Cyaltr C- Ottper-1-4* Q~ PAnll ra~rrte 10) SURFACE COMPLETION

[I Specified Surnate Slar In Il Adedf le! Sreeve trP-0 AjtooratlvPro talld (Rule 33M.V A,12 0 toted (tt'JO33Ba.WA) jAIOUNi ejure Used MuleI ddf.71Ij .14) WELL rESTS: Typets: -Pump E Pur Baiter Etibrreled V]lC: __ answeR _ fl.oweowata.er _ heo.11) WATER LEVEL'St'an level l it. belowe lat stics Aftos'antlow-_________gpm.' Dole li) WATEI OUALITY: .Did nat knhvrnyly pehstale any streat wleir rJr:iained urders-able consftiuent3 v.tfycs,suIntI'REPORTOFUIIOES;RAELEWflrTEFQ Ty.. ot welter?'l Dpthyol Wa" a nwm'cat gnawys made? El Yes El kt 12) PACKERS: Type Depth I hereby C "oeily hr ItN& well wAS drt n by me ({.r under myl .superviln) wo IN: ano all 0! thto slaltCOflet herein .re tre tn the tr." M.1t myr inwI -.ge eand bel,,9 I unCerstand (that lalure ovoltfl.lete (terra I trir 15 will mnub t.r ftt'o'j e L 9bing r .mcd Icr o on~d aid res',bftL ... .,....COMPANY NAmE F 4/d l v- S e c 4 Lý L LDRILLER'S LbCENSEI NO.7__ADDRES ta T (Signe._)) .. (Cy)...IP)................(sew) ... W :: (UceWsna WiN ,r) (Ryisrte'ed tluer'r a'!lhe)PFloas attach electlic 0011, Chemical asalyvis, and other ilformatiot. it onvolabte. ROO9 e o- 0 ig _ TNRC,.-ow DRLE P.,,WLLOW E Whife"- TNRCC Yoffow- DRILLEA Pink- I'VELL OWNER Send cgriag copy by -rAllied reium rece pl re.e- In; TDLR. P.O. Box 12167. Austin. TX 78711 C ATTENTION OWNER: Co6otdittlWy SP0rtw jol ke no re'.s e of Veil C wows opy "Pink)State of Texas: WELL REPORT Texas Deparltmtnt of Licensing &Regulation P.O. Box 12167 Au ltn, TX 78711 612463-7MSV

1) OWNER k#1 3 hq !!JADRSSý W 2) ADDRESS WLLA T /i r. Log -ta.____Caily T Lat.rA~rA M (Oilv) (S.. ) .t) GridsJ 3) TYPE OF WORK (Cliack):

(41 PROPOSEDUSEICheck): (DWmbi [] Ernirannna.-IaISoiilorlng U.Dcrnohie 6 Well [ Deepaning C:, wuiltdl 5 w] Ifaion Q Injecliun 5 PubI;Supply 5 D"-emlerirrg 5 E5 Rlecnecfonfg 0 Pluiggling 11 Pu~ic S -ppa .wllwar pans auutOillv i tor IhThRC? M Vie 5l No 6) WELL LOG: DIAMETER OF HOLE 71) DRILINO METHOD (Check): Driven Dalte 01f : Drn.f(imft Tor) ... -Air Rolary 2 lf.d. Rotary[] Bared started 1it11 19 F At Ham man Cable Tootl Jelled Completed Oe IFroma(ft.) To (I'L.) DeirIprIOn ead color of formation materlal.8) Borehole CaMploon (Check;: 5- Open, M4ow 5 Sfragf Wan C] Urder:uoma 5 iv Piikcd C] Gio' _______If Gravol Pockied girve- reitrvv! Irh. om __ 0. to i______ t.CASING. BLANK PIPE, AND WELL SCREEN DATA: t) CEMENTING DATA* 8m.1 8{I .Mn,.ou.ckausm.d__ .._a ruse tide oft Wl, coPjY', ffnf oJy -- .m m S13) ] Wcll plu.. .'d uitrn 46 late...v£strgi9_iM, v-llL..S_ i,', W;h I S.'a"It. ,r,ed: Fro (ft)T ml, r-,=. III I "to F.I, _-7, 77;:":.+.: ": 14) TYPIEpUW; ....:..E] T"s"ie r Sub[os3 Cd x r!h to &X,"p bowls, cyl;fidt", jea, etc.,. L ., '---18) WELLTESVS: Typelosi: 5 Puraf E Ea~efr j_-'Seed 5Estroo.Meld: JL'- .... gp f. drowow after hr..16 .WATER QUALITY: Did yor knavigy perelrmioany eoiaiiinedur~denrrmble coistilUlanas? E Yes , V'yes. subrnk'RrEPORT OF UNOESRASLE WATE " Type M~wierttj r Op'far_____ Wasa LI Yes....L Na .Cerneledhb'tovsulh syslom Ieli bnseolia c,,oeneltodccolawinslion _13, 1¶0l SURFACE COMPLETION 5 Ptens~dpier'Jed 5Approved AhteiiliveProcedure l'sel 11 WATER L'rJEL: Ellic lee4l -112 ,. bv'zw rI.d curlfua.A _ _w _ pm.Dae _____-' -tae________

12) PACKERS: TType Deplh fi.k b..... .. .. ...I cerify Ihl I drilled tl.a w-11 (or the wavll v$ d.iled rodur mycditm:l sr.F.,vision lnditheaich-ai d all ofl Ire hluldrraots ter-fa a'. tIre and Corred. I underlaond 1"l feilora t0 Conipmple items 1 111r1 16 will in thh Ing(s)- borg fI' alid rasauimn Itl..COMPANY NAME WErm L L.. -... .: 6 .iýAi .5"7.4 ( -I o.,- .-ADDRESS ts O1-T Y '_I!!4 7cc8 IS~ancd / g .1fl$X11 fs5)VIiP)(Licormod WallDrlf)er)

.-- " -Please attach electric l"g. helhrn l e n3lytnly,'alnd.other peririnenl ibn:o if.vallable. T"OtR FORM COVA.VWD N2W)0 Wite -TDLP .yeb7,. -DRILLER Fin0.. VELL OWNER~g5AI'flh7 BPNI(S Water Well Report ENVIRONMENTAL DATA A DMnSON OF THE BANKS GROUP Map of Wells within 1 Miels)0* s-e Pa. ccnt One inch = 0.39 miles 0 Well ScWI ZI" state* , ,Cerne, Bidn O.nac One-Mile Radius Centered Around N Pnnnary oo K,,,-,Ar Edil Rio. Internal Outfalls S,/ andanr¥ Higih-y Ch.rch Wat Bodies Id' Tai -t-,#mhotd Banks Environmental Data[H HoSwt* Le W.ary 1601 Rio Grande Suite 500 Austin, Texas 78701Amr~t = To~er gM Custodial Fa fit PH 512-478-0059 FAX 512-478-1433 BANI Water Well Report...on USGS Topo ENVIRONMENTAL DATA Map.o. Wlswh.... n .DIVISION OF THE BANKS4GROUP wi M Mile(s)0O 0-~4-suti.*A3 'E r-A-j'~'r"~V One inch = 0.39 miles G weo ..One-Mile Radius Centered Around N Enslng Ro?, d Internal Outfalls Co-myuny U'/? P.oOM Banks Environmental Data 1601 Rio Grande Suite 500 Austin. Texas 78701 TM SBWater Well Report ENVIRONMENTAL DATA.A DIVON IHE BANKS GROUP DETAILS M~ap State ID Owe ofWel Type of Well Derth Completioni Longitude Lattu~dei DriIlaets Log Dr d Dates V 1 80-_16-801 H. A. Norris_ STOCK 130 -96ý..0:222 28.78833 View_I 2 G1610103B NSC NTF POTABLE, Public Supply 0 ' -96.03888 28.78916 S3 80-16-B Spaw Glass Domestic 660 2/21/1985 -96.03729 28.79428 V'9w 1601 Rio Grande Suite 500 Austin, Texas 78701 PH 512.478.0059 FAX 512.478.1433 E-mail banks@banksinfo.com W I.... Well 2,, , , -, --, .--.. ---_-_----'rrJ~jcvnpaa- -tI -io --- i---r --~ -t -c -~ ----0 2, re r V e il F : .: gA -A t t y _ --J. .........-- -------- ------j ~A.

• 0,'e'.o. 1/i. ;/'.

fS _ _ _./ .). : ..s..._ -.se ,---------- -.en r -- --..;_ L _ , ...I..:,, Stage.- _ B,;4/ Diao. -_ !, U UA ------.. I "_~_ L -__r ------ ---- ---.. ....r .... ... .... _... .. ýj_ *d.d.. ..M ..!- ..1' -0, F -- -. _!14_ .......-------,- --,--, 10*Lii i .........------ --------------.J .. ._. J ._ f ........ .... r.... --- -, r ------2. T.:.vattot .. -r n 7f-_j -.-_ -----.. ..-. ... ..-L ., ,. JS. 2v. -°-: -.. ...... °- '_ý -to 0 -.--n. -ft"'.p S.l .t .4 t.a .... Fr. ... /r--. -- --- -l --l ------_----------- 1 ------------------------ --7 P. ...... .t ..,.../3- .-. ...... ......6. .: ".t~ .m: 07.r.~ H 1 :ui ll~rt ii]. Lnd.rnmaW, O"tj) Ho__t U-6__,", ..Wrk, m, tone, odor. .01 ... U .) -_- -_- -------_-_- ---............ ..... ....... ............--.v. _ ::t ;~ o ftl.*a -----yp IL. data .b , _a __In., ........... p f L , Aý ,-A M ----- --54 -IAr..&. 6 .......... ...--. .- -.. .- ...........----------- l-- --t ~f440 _t tdd t-------------------------------

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ft.-- -- -- -- ------- ----- ----- ------- -- -a...-- -- -- ---I---I---- -I-- -- --- -- -- -- -t **- ' rjj--- ----- --- --- --- --- --- ---- --- --- --- --- --- ---- --- --- --- --le. -(SI-to) 801-0-f2' GTJ 2 0FI'W1CAL WATER ANAL!~IS BEORr I~typevrit.e (Bick rl!bIoz) or Frlnt Plaid1Jy (soft ptmttL or bLack ink)Do itot = 'Oak,- point pan tsiies State Detyrtagnt of Hen1tt. rAbortfloridc 1.100 Want~ k9L?. Etreet Austin 5, VMLS Send report toi County JVW9W--Oround Va$er DIVlabon state Wei;~ :10. -J -P.0. 3ozx 12386 -_____ Well No.________

Auntin, Tnkcas 78711 Da.te Col~ccted A bec. VC, Loato it:i/A)77aA ,omi~ 0.2 0V. ~~r we jyv' g.- Foot IQ) 2 O6 t.jJv" Source (tnpe of .n.J,) 0yd*4aea' OVOYMd r wipf.3Ate Dri1lled 4-1 -I S 9 2 -Depth 1310 rt. u~r' 7~aegypmpa7 Prodolng 'rL'r-Vt~a 1*4- IJQ Water level U?, wt M Per )9"~4 ~ t"ledis arter puiin me hl 11.1 P t -~erjortie 7 5- o Point 3f ca~ct~or. D~jsrMrAlp PI, Joe ApVpemrame OIL~tor-MAe.clo -ui1 -cirC Ume VVft~R Ma'a nit LOMAZ'1S =J OnLy CHBUCAL AK-1alsI w11?t&L.borutozr' U.. ? 1) ý4 74 ts SJte eelve___________ Zeat Reported --]wM HaSnezjua*2 it~-.Lv iik7-7 4-Ol~orn ________ SAR _____3 ___(other)________ D~tutfd Condkt-fanee (micrO~omhe.cm?) ~3"'items wIlA te anibmLeta if ehecwel.Tvtoq. Tron. req~uiresaeDpaimte eavTle.Sulfate 5.3 ~orlde 6, -7 ,1as-dSo~lde (.um) 00 0 TotsL AlkA&Unity @a C oO TIttal Y(erdrmvd9 ac C acaj Ata~aeto.Checke.L U~U 'he b~cauhenu'te repr~otedt In ti.~a &"3cyzniet; converted by ==0p~atlo'n (mu:.tiplying by 0.491T) to on -uva~er'.aff.o~t of cartornote, and thet carbonate figurei da oel in the rýtation of thlb sum. 4 AMA; Thmeen 7071 State ufj Texas WATERI WELL REPORT A1TTENTION OWNER; Confiderndxgtr iPn.*U 1 NaA2 T H a an.Looc ...0 7.e SM--~ dY9kA~nV~..-a' 2)LOCATUO -Mk~ 1 (atea F!(~t,- ,!'e hP_____________

d. __________

i _________________ -n L~ni dtowpl 0 ecordpa.1 Ir ng L3 Pla.6ir blab ,r and Idnl n The t ArnOwr -Na.fur UC40________ 0.16tato ilhll~~~~rM aill l(Iama. It'llaaa Ia~o~31 ~ ~ ~ ~ ~ ~ ~ Z" H;n, Wa n aaNbameI hela. (en.a~dwkn(el e)eaeraaelnar Iwn;a.cQ-91 6 -gik.0 -,a1admp 23 TmmmOPYORdlnerkl .11 PRPS cUOd.nýl 11i U"J RLANI( P t7HO(1iCWELL enI DAA 14q.1I ~ a~er ~ tO Ordeb.ID )aapy ~ -tfoevC)Hr.,OieiOao D~renl~wnm O~ke~y Etrp: e ~eL,~ N-lar. oAtnr Ze. oI Oau Jha____A ipl ,O) LOO; LotETC OFer Miffe e) BORCHOI. F- S.-C Ow la. Fa~?A n~n! ~ ae.ii ~ en~t ~ dan~aao lit.a Sr.a 4(, l~pa.e lOr ____ .N63fr 9.l~ CEMVTN DATAt.0~~~ne~a.l ewe_____b). 5 -_ --I f VAR nDaa~reele l,30, ~ ~ icaA~co ~CL~lEOt Stad k'b CV1 01 Canton (t_-IýAll At WATER LEVEL;AU G3JIfl...... Il To- c~WP_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __SO_ _ 9i .r Dre ) J b a n i I n v e n flF~~~~~11 OFOyn._______________ I~~~~~~aa~0"- eO aJ ~ tI ~ ) ~* ne):~r ena r~~.: m.la _______233 ~ ~ ~ nP MArfLArv L ___________________ 0k vj4.a~rlIU --nfab a .ý atat ae Sh ?ntaa. r Mtaabn 11 -..TSO aaim Dyine AI?Y, Ifym~~~ea~hl2.bb4'12btOF~12 UM tifIeWA k4C0V)N ') Pnt EDaaSjaTd 'e;aýIto. Dinab....... ........6Ona 0l rytal i_______ noYmi t : r-____ Puap w 0l,. an.1t , ardW din, ...I .i--if, a- cbuwta am.InaeeIoe U DYES L 0 F1 ADDRESS~hzI P~aae. ettch on~n e1 haicInlea.nd a.-ar PVfoChIraC.It n I).En BAK Water Well Report T M ENVIRONMENTAL DATA A DIVISION Of THE BANXS GROUP DISCLAIMER 0 Water Well Report Research Mapping "A The Banks Environmental Data Water Well ReportT" is prepared from existing state water well databases and additional file data/records research conducted at Texas' regulatory authorities. Submission of driller's log records upon completion of a drilled water well became mandatory in 1985. The state of Texas has processed these records into several different filing systems within two state regulatory authorities. The water well files, records and map locations are maintained by the Texas Commission on Environmental Quality (TCEQ) and the Texas Water Development Board (TWDB). Actual water well site locations of this report are geocoded and geoplotted directly from the drilling records, drilling schedules, and driller's logs and maps submitted by the water well driller and maintained at these two primary water well regulatory authorities. Below is a description of the filing systems utilized for well drilling records.Texas Water Development Board (TWDB)The Texas Water Development Board maintains two datasets of located water well records: TWDB Groundwater Data-These well files are water well site locations that have been verified with a field inventory inspection by TWDB personnel. The wells are assigned a State Identification Number unique to that well (ex. 65-03-401) and plotted on county base maps, U.S.G.S. 7.5 minute topographical quadrangle maps, as well as in-house and on line geographic information systems. Records may also include analytical data attached with each drilling record.TWDB Submitted Drillers Reports- A Database created from the online Texas Well Report Submission and Retrieval System (A cooperative TDLR. TWDB system) that registered water-well drillers use to submit their required reports. Reports that drillers submit by mail are geoplotted/geocoded by a TWDB staff member. These wells are assigned a unique tracking number by the Texas Well Report Submission and Retrieval System. This system was introduced in February 2001 as an option for drillers to use, and will be mandatory in the future.Texas Commission on Environmental Quality The Texas Commission on Environmental Quality (TCEQ) maintains two datasets of water well records.Water Utility Database*(WUD) -This database contains a collection of data from Texas Water Districts, Public Drinking Water Systems and Water and Sewer Utilities who submit information to the TCEQ. These wells are assigned unique numbers with correlate to the Public Water System they act as a source for (example- $2200199A, G2200322A). The WUD does not contain Drillers Reports or analytical data. This data was provided to Banks in digital format.TCEQ Central Records-Several different types of Driller's Reports are filed with TCEQ Central Records according to the State Grid Number.Plotted water well files are water well site locations that have been determined from map information submitted on water well logs and subsequently plotted on TWDB county highway base maps. The accuracy and location of these wells is relative to the information provided on the drillers report. TWDB assigned letters to the correlating grid number to identify these wells (example 59-1A). In some instances, a single well number can represent more than one well location. This type of mapping and filing procedure ceased in June 1986.Partially numbered water wells -Well Reports that were provided a State Identification Number by the TWDB which establishes the well location somewhere within a 2.5 minute quadrant of a 7.5 minute quadrangle map. This method was the standard procedure from 1986 through 1991. From 1991 to the 2001, Texas Well Reports contain a grid location box, where drillers are provided a place to mark an X where within the 2.5 minute quadrant is located. These locations have not been verified by the state.Unnumbered water well files are water well site locations that have been processed since June 1990. These well records are filed solely on their county location and are not provided a State Identifiation Number nor are they mapped.Disclaimer Banks Environmental Data has performed a thorough and diligent search of all wells recorded with the Texas Water Development Board and the Texas Commission on Environmental Quality. All mapped locations are based on information obtained from the TWDB and the TCEQ. Although Banks performs quality assurance and quality control on all research projects, we recognize that any inaccuracies of the records and mapped well locations could possibly be traced to the appropriate regulatory authority or the water well driller. Many water well schedules may have never been submitted to the regulatory authority by the water well driller and, thus. may explain the possible unaccountability of private drilled wells. It is uncertain if the above listing provides 100% of the existing well locations within the area of review. Therefore, Banks Environmental Data cannot gaurantee the accuracy of the data or well location(s) of those maps and records maintained by Texas' regulatory authorities. 1601 Rio Grande Suite 500 Austin, Texas 78701 PH 512.478.0059 FAX 512.478.1433 E-mail banks@banksinfo.com THU.,F Il ~ ll ~Irl* £V. & 7;V , J flH MATERIAL SAFETY DATA SHEET ALTI VIA Sodium Hypochlorite Solution 10-15%ALTIVIA 24 Hour Emergency Phone Number: 713-636-3189 Transportation Emergencies CHEMTREC: 800-424-9300 SECTION 1: PRODUCT AND COMPANY IDENIFICATION PRODUCT NAME: Sodium Hypochloito Solution 10-16%CHEMICAL NAME/ FAMILY: Sodium Hypochlorite TRADE NAMESI SYNONYMS: Bleach; hypochlorous acid, sodium salt, Soda bleach; sodium oxychloride PRODUCT USE: Bleaching agent, chemical intermnediate, disinfectant. MOLECULAR FORMULA: NaOCI MANUFACTURER; ALTIVIA, 1100 Louisiana, Suite 3160, Houston, TX 77002 SECTION 2: COMPOSMONw INFORMATION ON INGREDIENTS CHEMICAL NAME CAS NUMBER % RANGE Sodium Hypochlorite 7651-52-9 9-5 -16.5 Sodium Hydroxide 131D-73-2 0-1%Water 7732-18-5 Balance Donates chwmk:ll subet 10 r trfnr4s ol Section 313 of "I III Of Mhe 1986 Sipedurx Amonfrwrls wad ResJuttWwliOn Act (SARA) and 40 CFR P&At 372.SECTION 3: HAZARDS IDENTIFICATION EMERGENCY OVERVIEW Dangarl Corrosive. May cause skin and eye irritation or chemical burns to broken skin. Causes eye damage.Harmful if swallowed. Sirong oxidizer. Does not burn. Decomposes when heated, during a fire or upon contact with acids releasing corrosive chlorine gas. During a lire corrosive hydrogen chloride gas may be generated, POTENTIAL HEALTH EFFECTS EYE Liquid or mist contact can produce severe eye Irritation and bums. Prolonged exposures may cause eye damage and blindness. SKIN Can cause Wirilalion and burns. Liquid contact can cause blistering and erczma- Prolonged exposure may cause dermalilis. Prepared-12/2812005 i/B Cotrol Number: A 2002 0 0 0 0 STP Nuclear Operating Company TPDES 01908 Treatment Chemicals Frequecy ofToxicity Product Name Manufacturer Use Components Listed in MSDS CAS Fruency Data In Product Concentration MSDS 3 times per dayfor 20 0.15 -0.6 ppm total Aquachlor Altivia biocide sodium hydroxide 1310-73-2 minutes to no 0e15-0.6 chlotote unit coaingresidual chlorine unit's cooling water sodium nitrite 7632-00,0 as needed to 0.25 oz per gallon of 1359 Plus Nalco corrosion inhibitor sodium metaborate 7775-19-1 maintain no closed cooling system sodium hydroxide 8012-01-9 concentration water i9H Nalco oxygen scavenger hydrazine 302-01-2 continuous yes 0.5 ppm to feedwater 9226 Nalco corrosion Inhibitor monoethanolamine 141-43-5 continuous no 1 ppm as product to feedwater 9353 Nalco scale Inhlbtoradispersant We n/a continuous yes 0.25 ppm feedrate as n ntimues per dayfor 20 0.15- 0.6 ppm total ACTI-BROM 1318 Nalco biocide sodium bromide 7647-15-6 minutes to yes residual chlorine unit's cooling watgr didecyl-dimethyl ammonium chloride 7173-51-5 4 ppm as product (2,5 ppm H-130M Nalco biocide (molluscicide) 2/yr yes as active) to auxiliary ethanol 64-W7-5 cooling system for 8 hours twice per year B-2206 Varichem blocide bromochloro-5,5-dimethylhydantoin n/a continuous no 1 -1.5 ppm B-2207 Varichem biocide gluteraldehyde 111-30-8 batch treat as no 20 ppm needed SC-2312 Varichem scale and corrosion inhibitor-none listed n/a continuous no 80 -120 ppm as needed to SC-2316 Varichem scale and corrosion Inhibitor none listed n/a maintain no 100 ppm concentration I 5/27/09 May.111. 11111 Y;IYiRvi (IV. W'7 1 r I , J A MATERIAL SAFETY DATA SHEET- Sodium Hypochlorite 10-15%INGESTION Orel or gastrointestinal ir"lteion. Corrosion of mucous membranes, perforation of esophagus and stomachJ may foflow.INHALATION Irritation of the respiratory system. Mist or fumes may cause bronchial irritation, coughing, difficult breathing, nausea and pulmonary edema.SIGNS AND SYMPTOMS OF EXPOSURE Iraltion or burns to the eyes and skin. Inhalation may cause coughing, choking, Irritation and pulmonary edema.Sodium hypochlorle solutions are corrosive following ingestion and may cause irritation, bums and vomiting.MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE None known.EFFECTS FOLLOWING REPEATED EXPOSURE Prolonged contact wilth sodium hypochlorile may cause dermatitis, permanent eye damage Including blindness. SECTION 4: FIRST AID MEASURES EYES Hold eye open and rinse slovly and gently for 15-20 minutes. Remove contact lenses, 0 present, after the first 5 minutes. then continue rinsing eye. Get medical attent on for irritation or any other symptom.SKIN Take off contaminated clothing and shoes. Rfnse skin Immediately with plenty ot water for 15-20 minutes. Get medical attention for irritation or burns. Wash clothing and thoroughly clean shoes before reuse.INGESTION Gel immediate medical altenltlon. Have person drink a glass of water Immediately If able to swallow. 12o not Induce vomtrficn unless directed to do so by medical personnel Do not give anything by mouth to an unconscious person.INHALATION Remove person frmm exposure to fresh ai. I1 person is not breathing, call 911 or an ambulance, and then give artilicial respiration (CPR). If intividual Is breathing, but with diticully, got immediate medical atlention. NOTES TO PHYSICIAN The absence of visible signs or symptons of bums does not relably exclude the presence of actual tissue damage.See Section 11 for Toxicological Information. SSECTIONS5: FIRE FIGHTING MEASURES FLAMMABLE PROPERTIES FLASH POINT AUTO IGNITION TEMPERATURE Not combustible (Coes not bum) Not Established FLAMMABLE LIMITS IN AIR (% BY VOLUME)Not EXTINGUISHING MEDIA Water, water mist, foam, carbon dioxide, dry powder.Prepared: 12/2W20O5 2/8 Control Number; A 2002 May. LV. y :e ynm I.... I,, #A MATERIAL SAFETY DATA SHEET -Sodium Hypochlorite 10-15%-4',1IVL=, HAZARDOUS COMBUSTION PRODUCTS Thermal decomposition may release to*ic gases such as chlorine and hydrogen chloride gas.FIRE FIGHTING INSTRUCTIONS Use extinguishing agents suitable for the surrounding tire and not contraindicated for use with sodium hypochiodte. Sodium Hypochlortl releases oxygen when heated, which may Increase the severity of an existing fire. Use water spray to cool flre exposed surfaces and to protect personnel Avoid ihalation of material of combustion by-products. Firelighters should weer lull protective clothing and NMOSH approved positive pressure self-contained breathing apparatus. I SECTION 6: ACCIDENTAL RELEASE MEASUJRES WATER SPILL Prevent additional discharge of material, if possible t do so without hazard.LAND SPILL Prevent additional discharge of material, It. possible to do so without hazard. For small spills Implement cleanup procedures; for lazge spills implement cleanup procedures and, If in pulc area. advise authorities. GENERAL PROCEDURES No smoking In spill aweas. Isolate spill area and deny entry to unnecessary or unprotected personnel. Remove am1 sources of Ignition, such as flames, hot glowing surfaces or electric arcs. Stop source of spill as soon as possible and notify appropriate personnel. Cleanup personnel must wear proper protective equipment (reter to Section 8).Decontaminate all clothing. Notify all downtrearn water users of possible conamination. Create a dlike or trench to contain all liquid material. Liquid material may be removed with a vacuumn buck. Spill materials may also be absorbed using clay, soil or nonflammable commercial absorbents. Do, not place spill materials back in their original container. Contairerize and label ea spill materials properly.RELEASE NOTES Notify the National Response Center (B00/414/88O2) of unconlained to the envreonment In excess of the Reportable Quantity (R0). See Section IS.Regulatory Information. Recycle or dispose of recovered maleral in accordance with all federal, state, and local, regulations. For all transportation accidents, call CHEMTREC at 8001424-9300. 1 SECTION 7: HANDLING AND STORAGE HANDLING Do not get In eyes, or on skin. or clothing. Do not taste or swallow. Avoid breathing mists or fumes. Do not handle with bare hands.Carefully monitor handling, use and storage to avoid spills and leaks. Follow protective controls set forth In Section 8 when handling this product. Do not eat. drink, or smoke in work area. Wash hands prior to eating, drinking, or using restroom.STORAGE STORAGE CONDITIONS Store in closed, property labeled tanks or conlainers. Keep away from heat, &Ec0 sunlight and sources of ignion.Do not remove or deface labels or tags. Store in a cool, Well ventilated place away from Incompatible materials. Do Prepared: 12I2812005 3/8 Control Number. A 2002 A MATERIAL SAFETY DATA SHEET- Sodium Hypochforite 10.15%not pressurze, cut, heal, or weld cortainers. Do riot drop, rol or skid drums. Keep drums upright. Do not rouse empty containers without commercial cleaning or reCondilionlttg. STORAGE TEMPERATURE Do not store above 35C (95'F).INCOMPATIBLE MATERIALS FOR STORAGE OR TRANSPORT Acids, ammonia compounds, oxidizing materials, peroxides, reducing agents and most metals.FSECTION 8: EXPOSURE CONTROLS PERSONAL PROTECTION ENGINEERING CONTROLS VENTILATION Use dosed systems when possible. Local exhaust ventilation is recommended I vapors, mists or aerosols are generated. PERSONAL PROTECTIVE EQUIPMENT (PPE)EYE AND FACE PROTECTION Wear chemical goggles. A face shield showld be wrn In addition to goggles where splashing or spraying is possible.SKIN PROTECTION Wear chemical iesIstant ulothing. Neoprene gloves, boots and apron or sticker suit.RESPIRATORY PROTECTION A NIOSH approved respirator with N95 (dust, fume, mitt) fifters may be permissible under co-lain circumstances where airborne concentrations are expected to exceeded exposure limits, or when symptoms have been obseived that are indicative of overexposure. When decomposition products exist, acid gas cartridges are also required.A half face place air-purifying respiratory may be used In concentranons up to 1OX the acceptable exposure level and a full face piece akr-purifying respiralm may be used in concentrations up to 5OX the acceptable exposure level.Suppled air should be used when the level Is expected to be above 5OX the acceptable level, or when there is a potential for uncontrolled release.A respiratory protection program that meats. 29 CFR 1910.134 rust be followed whenever workplace conditions warrant use of a respirator. CENERAL Safety shower and eye wash Station must be provided In the lmmedtate work area. Protective equipment and clothing should be selected, used, and mahntained according to appltable standards and regulations-For further informatdon. conMact the clhing or equipment manufaclurer. EXPOSURE GUIDEUNES Component Date: Sodium Hypochlorite AIHA (STEL 15 minutes). 2mg/n'Component Data: Sodium Hydroxide OSHA (TWA) -2mg/ý 'Sodium Hydroxide ACGIN Celling -2mglm'Prepared; 418 Control Number: A 2002 Nall. LV. Uim 7; 3v~m A MATERIAL SAFETY DATA SKEET- Sodium Hypochlorite 10-15%... ~ ~ ~ 9% InE iJE AUAWF Ufl ru-.w I[ UN-I "VII W: r rl I ON CHEMICAL FORMULA MOLECULAR WEIGHT APPEARANCE ODOR pH @ 250C VAPOR PRESSURE VOLATILES, % BY VOLUME BOILING POINT FREEZING POINT SOLUBILITY IN WATER EVAPORATION RATE SPECIFIC GRAVITY DENSITY VISCOSITY NaDOl 74.4 Clear colorless to pale yellow luid Characteristic bleach odor 11.5-13.5 Not Established Not Established 1 109C (230n-.126C (10 0 F)Complete Not Established 1.1.3-127 @ 21 C (70"F)9.42-10.58 @ 210C (70 0 F)Not Established I SECTION 10: STABILITY AND REACTIV7TY CHEMICAL STABILITY, Stable under normal use conditlons. May decompose upon heating and exposure to sunight.CONDMONS TO AVOID Avoid heeL, flames, spamks and other sources of ignition. Avoid direct sunfight, acidic condcdions, the presence ot mealas "nd other impurities. INCOMPATiBIuTY WITH OTHER MATERIALS Acids, ammonia compounds, oxiding materials, peroxides, reducing agents and most metals.HAZARDOUS DECOMPOSITION PRODUCTS Thermal decomoposllIon may release toxic gases such as chlorine and hydrogen chloride gas.HAZARDOUS POLYMERIZATION Will not occur.I SECTION 11: TOXICOLOGICAL INFORMATION ANIMAL TOXICOLOGY The toxicity and cofoslvity of this material is a lunction of concentration and pH. This material is irrilating and may be corrosive to all tissue.EYES Very dilute solutions have caused no irritation. More concentrated solutions have caused corrosive lnjujy, which did rnot heal withIn 21 days.SKIN LD 5 a (Dermal, Rabbit): > 10.000 11)rn 3 (undiluted) ACUTE ORAL EFFECTS LC 5 (Oral. Female Mouse): -7,540 mgAg; died as 5.B mnlfg (50% soluton)Prepared* 12128/2005 5/8 Control Number: A 20102 MY. LU. LVU7 7;.)Vhffl P% MATERIAL SAFETY DATA SHEET -Sodium Hypochlorite 10-15%-l rVIA LCa (Oral, Rat). 8.910 mglk9 (undiluted) ACUTE INHALATION EFFECTS No available data.EFFECTS FOLLOWING PROLONGED OR REPEATED EXPOSURE Dermatws, CARCINOGENICITY This product (or any component at a concentratiOn ot 0.1% or greates) is not listed by NTP, IARC, OSHA EPA, or any other authority as a carcinogen. MUTAGENICITY No available data.REPRODUCTIVE/DEVELOPMENTAL TOXICITY No available date.I SECTION 12: ECOLOGICAL INFORMATION

GENERAL COMMENT

This material is believed to be a moderate order of toxicity based on analogous material.ENVIROMENTAL FATE This material Is inorganic and not subjecl to biodogradation. This material is believed not to persist in the environment. Thi matetial maybe harmM to aquatic organisms in low concentmaions. SECTION 13: DISPOSAL CONSIDERATIONS SPILL RESIDUES Processing, use or contamination ot this product may change the waste management options. All disposals of this material must be done in accordance with Federal, state and local regulalions. Waste characterization and compiance with disposal regulations are the responsibilities of the waste generator. It this. product becomes a waste it may be subject to disposal regulations: U.S. EPA 40 CFR 262. Hazardous Waste Numberls): D002.I SECTION 14: TRANSPORT INFORMATION THIS MATERIAL IS A HAZARDOUS AS DEFINED BY 49 CFR 172.01 BY THE U.S DEPARTMENT OF TRANSPORTATION. DOT IDENTIFICATION NO.: UN 1791 DOT SeIPPING DESCRIPTION (49 CFR 172.101): Hypochlorite solutions, Corrosive, 8 PACKAGING GROUP: UI PLACARD REQUIRED: Corrosive $, UN 1791 LABEL REQUIRED-Corrosive

8. Label as required by EPA and by OSHA Hazard Communication Standard, and any applicable state and local regulations-EMERGENCY RESPONSE GUIDE NUMBER; t54 Prepared:

12/28I2005 6/8 Control Number: A 2002 I may. iv. iuuy i; )ummg~1-rd , It.. W-r !I A I .V A~MATERIAL SAFETY DATA SHEET -Sodium Hypochlorite 10-15%I SECTION 15: REGULATORY INFORMATION U S FEDERAL REGULATIONS CERCLA REPORTABLE QUANTITY (RO)Ingredient CAS NO. RG Sodium Hypochlorite 7681-52-9 100 lbs Sorium Hydroxide 1310-73-2 1000 lbs TSCA (TOXIC SUBSTANCES CONTROL ACM All components 01 mlis product are Ulsted on the TSCA Inyentory or ate exempt from TSCA Inhentoiy requirements. SUPERFUND AMENDMENTS AND REAUTHORWZATION ACT (SARA) TITLE III SARA SECTION 302 (EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 302.4);Not Approa ble SARA SECTION 311/312 HAZARD CATEGORIES (40 CFR 370.2): Fire Hazard Yes Reactivity Hazard No Release ot Pressure No Acute Health Hazard Yes Chronic Health Hazard No SARA SECTION 313 (40 CFR 372.65): Components Identified with an asterisk (*) in Section 2 are subject to the reporting requirements of Seclion 313 of Tidle III of The 1985 Superfund Amendments and Reauthorization Act (SARA) and 40 CFR Part 372.OSHA PROCESS SAFETY (29 CFR 1910.119): Not regulated. OTHER U.S. REGUALATIONS Federal Insecticide, Fugicide and Rodentloide Act (FIFRA): Registored pesticide (40 CFR 152-10)INTERNATIONAL REGULATIONS CANADA CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA)DSU NDSL: This prnxuct, or its compOnents, are listed on or are exempt from the Canedian Domestic Substance List (DSL).I SECTION 16: OTHER INFORMATION LZPA RAINGS HELT FL~AMAIITY 0 HMIS CODES HEALTH 3 FLAMMABILITY 0 REACTIVITY 1 PROTECTION C RATING NOTES Hazardous Melerials tdeniticatlon: 4 .Severe, 3 = Serious. 2 -Moderate. I -Slight, 0 -Minimal.Prepared; 1212W2005 7/8 Controt Number: A 2002 1111dy. IV. IVV7 7 -j I rwn 0 A~ MATERIAL SAFETY DATA SKEET -Sodium Hypochlorite 10-15%o Emergen-ev Informaion; For- Any Other Infformalign Contact: Call toll free 24 hours a day: 713-t6a6-3189 ALTI VIA, Technical Marketing, 1100 Louisiana, Suite 3160, H-ouston. TX 77002..Phone: 713-658-90W0 8 AMA -5 PM CST, Monday through Friday Revisions 12/2812005: Revised to conform to ANSI Standard Z00.1-199191 replaces MSI)S A21102-05010. Ciactaknem of Warranty: Tho inloiinton provided hin 1hi M&tWisi Safety Data Shedt has boon Obt23b~d hmsou'cSOU bdaliod 1o be reSgba. ALTIVIA prvvidal no warrantimesaiher expresed or bnplWe and asswnaa no respaombi~ti to? fth acurcy or ovwnWrienss of fti data cantahted heitin. This infonalion E5 ofl..ud for yota intarmiation, cqkiona, and Iniuefaf.ainn. YOU timid safttgy youreanl thal vow have all Wunen daita fotevarlt to your parlicusr use. ALUMA kniows of no modkoeat onditior., other than thesenoted on this malarial saftazy dale 5heet, whichi are genrerally recognized Is5 bahie a~afflvetd by exposure bD fth~ product.a Prepared; 12./Z/2005 8/8 Control Number A 2002 0 P4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 11. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: NALCO 1359 PLUS APPLICATION: CORROSION INHIBITOR COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 3/3 FLAMMABILITY: 0/0 INSTABILITY: 0/0 OTHER: 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme 12. 1 COMPOSrIION/INFORMATION ON INGREDIENTS Our hazard evaluation has identified the following chemical substance(s) as hazardous. Consult Section 15 for the nature of the hazard(s). Hazardous Substance(s) Sodium Nitrite Sodium Metaborate CAS NO 7632-00-0 7775-19-1% (wlw)10.0- 30.0 5.0- 10.0 13. I HAZARDS IDENTIFICATION I"EMERGENCY OVERVIEW** DANGER Toxic if swallowed. Irritating to eyes and skin. Contains sodium nitrite. Substances in the product can lead to the formation of methemoglobin. Unborn children are particularly sensitive to methemoglobinemia. Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. After contact with skin, wash immediately with plenty of water.Wear suitable protective clothing.Not flammable or combustible. May evolve oxides of nitrogen (NOx) under fire conditions. If product is allowed to dry, the sodium nitrite is an oxidizing agent and can initiate the combustion of other materials. PRIMARY ROUTES OF EXPOSURE: Eye, Skin.HUMAN HEALTH HAZARDS- ACUTE: EYE CONTACT: Irritating, and may injure eye tissue if not removed promptly.S Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 1110 MATERIAL SAFETY DATA SHEET AW PRODUCT NALCO NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC SKIN CONTACT: Can cause mild irritation. INGESTION: Not a likely route of exposure. Large exposures may be fatal. Ingestion of sodium nitrite can cause methemoglobinemia which can lead to cyanosis and possible death. Pregnant women and their fetuses are particularly sensitive to the effects of methemoglobinemia. INHALATION: Not a likely route of exposure. Aerosols or product mist may irritate the upper respiratory tract.SYMPTOMS OF EXPOSURE: Acute : A review of available data does not identify any symptoms from exposure not previously mentioned. Chronic: A review of available data does not identify any symptoms from exposure not previously mentioned. AGGRAVATION OF EXISTING CONDITIONS: Sodium Nitrite. Pregnant women are particularly sensitive to methemoglobinemia. HUMAN HEALTH HAZARDS -CHRONIC: Repeated ingestion of small amounts of sodium nitrite causes drops in blood pressure, rapid pulse, headaches and visual disturbances. It may also react with organic amines in the body to form carcinogenic nitrosamines.

14. 1 FIRST AID MEASURES EYE CONTACT: Immediately flush eye with water for at least 15 minutes while holding eyelids open. If irritation persists, repeat flushing.

Get medical attention. SKIN CONTACT: Immediately flush with plenty of water for at least 15 minutes. If symptoms persist, call a physician. INGESTION: Do not induce vomiting without medical advice. If conscious, washout mouth and give water to drink. Get immediate medical attention. INHALATION: Remove to fresh air, treat symptomatically. If symptoms develop, seek medical advice.NOTE TO PHYSICIAN: Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition. Measures against circulatory shock, respiratory depression and convulsions may be needed.5. 1 FIRE FIGHTING MEASURES FLASH POINT: None Nalco Company 1601 W. Diehl Road- Naperville, Illinois 60563-1198-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 2/10 0 MATERIAL SAFETY DATA SHEET NALCO PRODUCT NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC EXTINGUISHING MEDIA: Not expected to bum. Use extinguishing media appropriate for surrounding fire.FIRE AND EXPLOSION HAZARD: Not flammable or combustible. May evolve oxides of. nitrogen (NOx) under fire conditions. If product is allowed to dry, the sodium nitrite is an oxidizing agent and can initiate the combustion of other materials. SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING: In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit.16. 1 ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS: Restrict access to area as appropriate until clean-up operations are complete. Ensure clean-up is conducted by trained personnel only. Ventilate spill area if possible. Do not touch spilled material. Stop or reduce any leaks if it is safe to do so. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Notify appropriate government, occupational health and safety and environmental authorities. METHODS FOR CLEANING UP: SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Wash site of spillage thoroughly with water. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). ENVIRONMENTAL PRECAUTIONS: Do not contaminate surface water.17. 1 HANDLING AND STORAGE HANDLING: Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Do not breathe vapors/gases/dust. Keep the containers closed when not in use. Have emergency equipment (for fires, spills, leaks, etc.) readily available. Ensure all containers are labeled.STORAGE CONDITIONS: Store the containers tightly closed. Store in suitable labeled containers. Store separately from acids. Store separately from reducing agents.S8. EXPOSURE CONTROLSIPERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS: This product does not contain any substance that has an established exposure limit.ENGINEERING MEASURES: General ventilation is recommended. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 3/10 AWNALCO MATERIAL SAFETY DATA SHEET PRODUCT-NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC RESPIRATORY PROTECTION: Respiratory protection is not normally needed.HAND PROTECTION: When handling this product, the use of chemical gauntlets is recommended., The choice of work glove depends on work conditions and what chemicals are handled, but we have positive experience under light handling conditions using gloves made from, Neoprene, PVC or nitrile, Gloves should be replaced immediately if signs of degradation are observed., Breakthrough time not determined as preparation, consult PPE manufacturers. SKIN PROTECTION: When handling this product, the use of overalls, a chemical resistant apron and rubber boots is recommended. A full slicker suit is recommended if gross exposure is possible.EYE PROTECTION: Wear chemical splash goggles.HYGIENE RECOMMENDATIONS: Use good work and personal hygiene practices to avoid exposure. Keep an eye wash fountain available. Keep a safety shower available. If clothing is contaminated, remove clothing and thoroughly wash the affected area.Launder contaminated clothing before reuse. Always wash thoroughly after handling chemicals. When handling this product never eat, drink or smoke..HUMAN EXPOSURE CHARACTERIZATION: Based on our recommended product application and personal protective equipment, the potential human exposure is: Moderate 1 9. 1 PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Light yellow ODOR SPECIFIC GRAVITY 1.305 @ 72 'F / 22.2 'C DENSITY 10.84 lb/gal SOLUBILITY IN WATER Complete pH (100 %) >= 11.4 VISCOSITY Max 7 cps @ 73 'F / 22.8 'C FREEZING POINT < -50 'F / -45.5 °C VAPOR PRESSURE Same as water Note: These physical properties are typical values for this product and are subject to change.[10. S STABILITY AND REACTIVITY STABILITY: .Stable under normal conditions. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 4/10 MATERIAL SAFETY DATA SHEET I PRODUCT NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC HAZARDOUS POLYMERIZATION: Hazardous polymerization will not occur.CONDITIONS TO AVOID: Freezing temperatures. Do not allow product to evaporate to dryness. Dried product residue can act as an oxidizer.MATERIALS TO AVOID: Contact with reducing agents (e.g. hydrazine. sulfites, sulfide, aluminum or magnesium dust) may generate heat, fires, explosions and toxic vapors. Do not mix with amines. Sodium nitrite can react with certain amines to produce N-nitrosamines, many of which are cancer-causing agents to laboratory animals. Contact with strong acids (e.g.sulfuric, phosphoric, nitric, hydrochloric, chromic, sulfonic) may generate heat, splattering or boiling and toxic vapors.HAZARDOUS DECOMPOSITION PRODUCTS: Under fire conditions: Oxides of nitrogen 111. I TOXICOLOGICAL INFORMATION No toxicity studies have been conducted on this product.SENSITIZATION: This product is not expected to be a sensitizer. CARCINOGENICITY: None of the substances in this product are listed as carcinogens by the International Agency for Research on Cancer (IARC), the National Toxicology Program (NTP) or the American Conference of Governmental Industrial Hygienists (ACGIH).HUMAN HAZARD CHARACTERIZATION: Based on our hazard characterization, the potential human hazard is: High 12. 1 ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS: No toxicity studies have been conducted on this product.MOBILITY: The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM , provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air Water Soil/Sediment <5% 30-50% 50-70%Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198

• (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 5/10

)4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC The portion in water is expected to be soluble or dispersible. ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: Moderate Based on our recommended product application and the product's characteristics, the potential environmental exposure is: High If released into the environment, see CERCLAISUPERFUND in Section 15.13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the criteria of a hazardous waste.Hazardous Waste: D002 Hazardous wastes must be transported by a licensed hazardous waste transporter and disposed of or treated in a properly licensed hazardous waste treatment, storage, disposal or recycling facility. Consult local, state, and federal regulations for specific requirements.

• 114. ]_TRANSPORT INFORMATION v The information in this section is for reference only and should not take the place of a shipping paper (bill of lading)specific to an order. Please note that the proper Shipping Name I Hazard Class may vary by packaging, properties.

and mode of transportation. Typical Proper Shipping Names for this product are as follows.LAND TRANSPORT: Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Hazard Class -Secondary: Packing Group: Flash Point: DOT Reportable Quantity (per package): DOT RQ Component: AIR TRANSPORT (ICAO/IATA): Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Hazard Class -Secondary: CORROSIVE LIQUID, TOXIC, N.O.S SODIUM NITRITE UN 2922 8 6.1 III None 430 lbs SODIUM NITRITE CORROSIVE LIQUID, TOXIC, N.O.S SODIUM NITRITE UN 2922 8 6.1 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 6/10 P4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 0 Packing Group: IATA Cargo Packing Instructions: IATA Cargo Aircraft Limit: MARINE TRANSPORT (IMDG/IMO): III 820 60 L (Max net quantity per package)CORROSIVE LIQUID, TOXIC, N.O.S SODIUM NITRITE UN 2922 8 6.1 III Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Hazard Class -Secondary: Packing Group: 15. 1 REGULATORY INFORMATION NATIONAL REGULATIONS, USA: OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200: Based on our hazard evaluation, the following substance(s) in this product is/are hazardous and the reason(s) is/are shown below.Sodium Nitrite : Target Organ Effect -Kidney, Target Organ Effect -Nervous system, Target Organ Effect -Blood Sodium Metaborate

Irritant CERCLAISUPERFUND, 40 CFR 117,302: This product contains the following Reportable Quantity (RQ) Substance.

Also listed is the RO for the product.RQ Substance Sodium Nitrite R43Q 430 Ibs SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE III) -SECTIONS 302, 311, 312, AND 313: SECTION 302 -EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355): This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance. SECTIONS 311 AND 312 -MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370): Our hazard evaluation has found this product to be hazardous. The product should be reported under the following indicated EPA hazard categories: X X Immediate (Acute) Health Hazard Delayed (Chronic) Health Hazard Fire Hazard Sudden Release of Pressure Hazard Reactive Hazard Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals. The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10,000 pounds for all other hazardous chemicals. Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198

-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 7/10 WMATERIAL SAFETY DATA SHEET ANALCO PRODUCT NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC SECTION 313 -LIST OF TOXIC CHEMICALS (40 CFR 372): I This product contains the following substance(s), (with CAS # and % range) which appear(s) on the List of Toxic Chemicals H;azardous Substance(s) CAS NO ' % WwI)Sodium Nitrite 7632-00-0 10.0 -30.0 TOXIC SUBSTANCES CONTROL ACT (TSCA): The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710)FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 116.4/ formerly Sec. 311 : This product contains the following substances listed in the regulation: Substance (s) Citations* Sodium Nitrite Sec. 311" Sodium Hydroxide CLEAN AIR ACT, Sec. 112 (40 CFR 61, Hazardous Air Pollutants), Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances): None of the substances are specifically listed in the regulation. CALIFORNIA PROPOSITION 65: This product does not contain substances which require warning under California Proposition 65.MICHIGAN CRITICAL MATERIALS: None of the substances are specifically listed in the regulation. STATE RIGHT TO KNOW LAWS: The following substances are disclosed for compliance with State Right to Know Laws: Sodium Nitrite 7632-00-0 NATIONAL REGULATIONS, CANADA: WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS): This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR.WHMIS CLASSIFICATION: D2A -Materials Causing Other Toxic Effects -Very Toxic Material, D2B -Materials Causing Other Toxic Effects -Toxic Material CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA): The substances in this preparation are listed on the Domestic Substances List (DSL), are exempt, or have been reported in accordance with the New Substances Notification Regulations. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 8/10 A4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS).EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories. JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Ministry of International Trade & industry List (MITI).KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL)PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippine Inventory of Chemicals & Chemical Substances (PICCS).16. OTHER INFORMATION Due to our commitment to Product Stewardship, we have evaluated the human and environmental hazards and exposures of this product. Based on our recommended use of this product, we have characterized the product's general risk. This information should provide assistance for your own risk management practices. We have evaluated our product's risk as follows:* The human risk is: Moderate"The environmental risk is: Moderate Any use inconsistent with our recommendations may affect the risk characterization. Our sales representative will assist you to determine if yourproduct application is consistent with our recommendations. Together we can implement an appropriate risk management process.This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the recommended safety precautions and should have access to this information. For any other uses, exposures should be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information. REFERENCES Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 9110 N NALCO MATERIAL SAFETY DATA SHEET PRODUC-T NALCO 1359 PLUS EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer.Integrated Risk Information System, U.S. Environmental Protection Agency, Washington. D.C. (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service.Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Ariel Insight# (An integrated guide to industrial chemicals covered under major regulatory and advisory programs), North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Anel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS# CD-ROM Version), Micromedex. Inc., Englewood, CO.Prepared By: Product Safety Department Date issued : 03/12/2008 Version Number: 2.0 0 Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198
• (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 10/10 A4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC I1. 1 CHEMICAL PRODUCT AND COMPANY IDENTIFICATION i PRODUCT NAME: APPLICATION:

NALCO 19H OXYGEN SCAVENGER COMPANY IDENTIFICATION: EMERGENCY TELEPHONE NUMBER(S): Nalco Company 1601 W. Diehi Road Naperville, Illinois 60563-1198 (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 2/2 FLAMMABILITY: 1 / I INSTABILITY: 0/0 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme OTHER: 1 2. 1 COMPOSITIONIINFORMATION ON INGREDIENTS I Our hazard evaluation has Identified the following chemical substance(s) as hazardous. Consult Section 15 for the nature of the hazard(s). Hazardous Substance(s) GAS NO 302-01-2% (wlw)30.0- 60.0 0 Hydrazine 13. 1 HAZARDS IDENTIFICATION I**EMERGENCY OVERVIEW" DANGER This product contains hydrazine which is a suspect carcinogen. Extreme health hazard. May be absorbed through the skin. Risk of serious damage to eyes. Irritating to skin. May cause skin sensitization reaction in certain individuals. Harmful by inhalation, in contact with skin and if swallowed. This material or some of its substance(s) has been shown to cause cancer in laboratory animals. Toxic to aquatic organisms. Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Keep container tightly closed and in a well-ventilated place. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. After contact with skin, wash immediately with plenty of water.Wear a face shield. Wear chemical resistant apron, chemical splash goggles, impervious gloves and boots.May evolve oxides of nitrogen (NOx) under fire conditions. May evolve toxic gases or fumes under fire conditions. PRIMARY ROUTES OF EXPOSURE: Eye, Skin, Inhalation HUMAN HEALTH HAZARDS- ACUTE: EYE CONTACT: Severely irritating. If not removed promptly, will injure eye tissue and may result in permanent eye damage.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies, of an MSDS visit www.nalco.com and request access 1/11 0 AWNALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC SKIN CONTACT: Can cause moderate to severe irritation. May cause sensitization by skin contact. Can be absorbed through the skin.INGESTION: Not a likely route of exposure. There may be irritation to the gastro-intestinal tract with nausea and vomiting.INHALATION

Vapors extremely irritating to eyes and respiratory tract. Can cause pulmonary edema. May cause liver and kidney disorder and/or damage.SYMPTOMS OF EXPOSURE: Acute : A review of available data does not identify any symptoms from exposure not previously mentioned.

Chronic: A review of available data does not identify any symptoms from exposure not previously mentioned. AGGRAVATION OF EXISTING CONDITIONS: Skin contact may aggravate an existing dermatitis condition. HUMAN HEALTH HAZARDS -CHRONIC: Oral administration of hydrazine has produced lung and liver tumors in mice and rats and mammary tumors in mice..Inhalation of hydrazine has produced nasal tumors in rats.14. FIRST AID MEASURES EYE CONTACT: Immediately flush eye with water for at least 15 minutes while holding eyelids open. Get immediate medical attention. SKIN CONTACT: Remove contaminated clothing. Wash off affected area immediately with plenty of water. Get immediate medical attention. Contaminated clothing, shoes, and leather goods must be discarded or cleaned before re-use.INGESTION: Induce vomiting if the patient is fully conscious. If conscious, washout mouth and give water to drink. Get immediate medical attention. INHALATION: Remove to fresh air, treat symptomatically. Get medical attention. NOTE TO PHYSICIAN: Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition. 0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 2/11

• 04NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 0 5. FIRE FIGHTING MEASURES FLASH POINT: > 230 OF I > 110 "C (PMCC)EXTINGUISHING MEDIA: Not expected to bum. Use extinguishing media appropriate for surrounding fire.FIRE AND EXPLOSION HAZARD: May evolve oxides of nitrogen (NOx) under fire conditions.

May evolve toxic gases or fumes under fire conditions. SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING: In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit.16. 1 ACCIDENTAL RELEASE MEASURES I PERSONAL PRECAUTIONS: Restrict access to area as appropriate until cdean-up operations are complete. Ensure clean-up is conducted by trained personnel only. Ventilate spill area if possible. Do not touch spilled material. Stop or reduce any leaks if it is safe to do so. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Notify appropriate government, occupational health and safety and environmental authorities. METHODS FOR CLEANING UP: SMALL SPILLS: LARGE SPILLS: Dike to prevent further movement. Reclaim into recovery or salvage drums.Wash site of spillage thoroughly with water. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). ENVIRONMENTAL PRECAUTIONS: Do not contaminate surface water.17. 1 HANDLING AND STORAGEI HANDLING: Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Avoid generating aerosols and mists. Keep the containers closed when not in use. Have emergency equipment (for fires, spills, leaks, etc.) readily available. STORAGE CONDITIONS: Store the containers tightly closed. Store separately from oxidizers. Store in suitable labeled containers. SUITABLE CONSTRUCTION MATERIAL: Polypropylene, Polyethylene, Stainless Steel 304, Stainless Steel 316L, Compatibility with Plastic Materials can vary;, we therefore recommend that compatibility is tested prior to use.UNSUITABLE CONSTRUCTION MATERIAL: Copper, Brass, Aluminum 0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 3111 PA NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 18. 1 EXPOSURE CONTROLS/PERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS: Exposure guidelines have not been established for this product. Available exposure limits for the substance(s) are shown below.ACGIH/TLV: Substance(s) Hydrazine OSHA/PEL: Substance(s) Hydrazine TWA: 0.01 ppm , 0.013 mglm3 (Skin)TWA: 0.1 ppm, 0.1 mglm3 (Skin)ENGINEERING MEASURES: General ventilation is recommended. Use local exhaust ventilation if necessary to control airborne mist and vapor.RESPIRATORY PROTECTION: Where concentrations in air may exceed the limits given in this section, the use of a half face filter mask or air supplied breathing apparatus is recommended. A suitable filter material depends on the amount and type of O chemicals being handled. Consider the use of filter type: Ammonia / amine cartridge. with a Particulate pre-filter. In event of emergency or planned entry into unknown concentrations a positive pressure, full-facepiece SCBA should be used. If respiratory protection is required, institute a complete respiratory protection program including selection, fit testing, training, maintenance and inspection. HAND PROTECTION: Impervious gloves SKIN PROTECTION: Wear chemical resistant apron, chemical splash goggles, impervious gloves and boots. A full slicker suit is recommended if gross exposure is possible.EYE PROTECTION: Wear a face shield with chemical splash goggles.HYGIENE RECOMMENDATIONS: Eye wash station and safety shower are necessary. If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse.19. 1 PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Colorless ODOR Ammoniacal 0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 4(11 )4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 0 SPECIFIC GRAVITY 1.03 @ 60 °F / 15.6 -C DENSITY 8.56 lb/gal SOLUBILITY IN WATER Complete pH (100 %) 12.5 pH (1 %) 10.1 -10.7 VISCOSITY 2.0 cps @ 60 °F / 15.6 °C FREEZING POINT -85 OF -65 OC BOILING POINT 228 OF 1 108.9 °C VAPOR PRESSURE 22 mm Hg @ 77 °F 125 °C Note: These physical properties are typical values for this product and are subject to change.10. 1 STABILITY AND REACTIVITY STABILITY: Stable under normal conditions. HAZARDOUS POLYMERIZATION: Hazardous polymerization will not occur.CONDITIONS TO AVOID: Heat MATERIALS TO AVOID: Contact with strong oxidizers (e.g. chlorine, peroxides, chrornates, nitric acid, perchlorate, concentrated oxygen, permanganate) may generate heat, fires, explosions and/or toxic vapors.HAZARDOUS DECOMPOSITION PRODUCTS: Under fire conditions: Oxides of nitrogen 11. TOXICOLOGICAL INFORMATION The following results are for the product.ACUTE ORAL TOXICITY: Species LD50 Test Descriptor Rat 185 mg/kg Product ACUTE DERMAL TOXICITY: Species LD50 Test Descriptor Rabbit 420 mg/kg Product ACUTE INHALATION TOXICITY: Species LC50 Test Descriptor Rat 2.1 mg/I (4 hrs) Product Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 5/11 0 SNALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC SENSITIZATION: May cause sensitization by skin contact. Repeated or prolonged contact may cause sensitization in some individuals. CARCINOGENICITY: This product contains hydrazine. The International Agency for Research on Cancer(IARC) has evaluated hydrazine, and found it to be a possible human carcinogen (Group 2B) based on sufficient animal data and inadequate human data.MUTAGENICITY: An ingredient in this product has shown positive results in a screening test for mutagenicity. HUMAN HAZARD CHARACTERIZATION: Based on our hazard characterization, the potential human hazard is: High 12. 1 ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS: The following results are for the product.ACUTE FISH RESULTS 'Species .Exposure LC50 Test Descriptor Bluegill Sunfish 96 hrs 4.2 mg/I Product Rainbow Trout 96 hrs 4.3 mg/I Product Gold Orfe 96 hrs 0.75 mg/1 Product ACUTE INVERTEBRATE RESULTS: Species .Exposure LC50 EC50 Test Descriptor Daphnia magna 48 hrs 0.46 mg/l Product Daphnia magna 48 hrs 0.81 mq/I Product MOBILITY: The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air Water Soil/Sediment <5% 30 -50% 50 -70%The portion in water is expected to be soluble or dispersible. BIOACCUMULATION POTENTIAL This preparation or material is not expected to bioaccumulate. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1 198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 6/11 ANALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 0 ENVIRONMENTAL HAZARD AND. EXPOSURE CHARACTERIZATION ENVIRONMENTAL HAZARD AND. EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: High If released into the environment, see CERCLA/SUPERFUND in Section 15.113. 1 DISPOSAL CONSIDERATIONS I If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the criteria of a hazardous waste.Hazardous Waste: D002, U133 Hazardous wastes must be transported by a licensed hazardous waste transporter and disposed of or treated in a property licensed hazardous waste treatment, storage, disposal or recycling facility. Consult local, state, and federal regulations for specific requirements. 114. 1 TRANSPORT INFORMATION I The information in this section is for reference only and should not take the place of a shipping paper (bill of lading)specific to an order. Please note that the proper Shipping Name ( Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows.LAND TRANSPORT: Proper Shipping Name: Technical Name(s): UNIID No: Hazard Class -Primary: Packing Group: HYDRAZINE, AQUEOUS SOLUTION UN 3293 6.1 IlI Flash Point:> 110 °C / > 230 °F DOT Reportable Quantity (per package): DOT RQ Component: 2 lbs HYDRAZINE AIR TRANSPORT (ICAO/IATA): Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Packing Group: IATA Cargo Packing Instructions: IATA Cargo Aircraft Limit: MARINE TRANSPORT (IMDG/IMO): HYDRAZINE, AQUEOUS SOLUTION UN 3293 6.1 III 618 220 L (Max net quantity per package)Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 7/11@1 MATERIAL SAFETY DATA SHEET ANALCO PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMIREC I i Proper Shipping Name: HYDRAZINE, AQUEOUS SOLUTION Technical Name(s): Hydrazine UN/ID No: UN 3293 Hazard Class -Primary: 6.1 Packing Group: Il 15. REGULATORY INFORMATION NATIONAL REGULATIONS. USA: OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200: Based on our hazard evaluation, the following substance(s) in this product is/are hazardous and the reason(s) is/are shown below.Hydrazine: Cancer suspect agent (refer to Section 3), Corrosive, Dermal Sensitizer CERCLNISUPERFUND, 40 CFR 117, 302: This product contains the following Reportable Quantity (RQ) Substance. Also listed is the RQ for the product.RQ Substance RQ Hydrazine 2 lbs SARNSUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE Ill) -SECTIONS 302, 311, 312, AND 313: SECTION 302 -EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355): This product contains the following substance(s) which is listed in Appendix A and B as an Extremely Hazardous Substance. Listed below are the statutory Threshold Planning Quantity (TPQ) for the substance(s) and the Reportable Quantity (RQ) of the product. If a reportable quantity of product is released, it requires notification to your State Emergency Response Commission. You may also be required to notify the National Response Center -See CERCLNISUPERFUND, above.Extremely Hazardous Substance TPQ RQ Hydrazine 1,000 lbs 2 lbs SECTIONS 311 AND 312 -MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370): Our hazard evaluation has found this product to be hazardous. The product should be reported under the following indicated EPA hazard categories: X Immediate (Acute) Health Hazard X Delayed (Chronic) Health Hazard Fire Hazard Sudden Release of Pressure Hazard Reactive Hazard Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals. The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10,000 pounds for all other hazardous chemicals. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 8/11 MATERIAL SAFETY DATA SHEET ANALCO PRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER4S)(800) 424-9300 (24 Hours) CHEMTREC SECTION 313 -LIST OF TOXIC CHEMICALS.(40 CFR 372): This product contains the following substance(s), (with CAS # and % range) which appear(s) on the List of Toxic Chemicals Hazardous Substance(s) CAS NO % (wtw)Hydrazine 302-01-2 30.0 -60.0 TOXIC SUBSTANCES CONTROL ACT (TSCA): The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710)FOOD AND DRUG ADMINISTRATION (FDA) Federal Food, Drug and Cosmetic Act: When use situations necessitate compliance with FDA regulations, this product is acceptable under: 21 CFR 173.310 Boiler Water Additives The following limitations apply: Maximum dosaae Limitation ZERO PPM as product in the steam NSF NON-FOOD COMPOUNDS REGISTRATION PROGRAM (former USDA List of Proprietary Substances & Non-Food Compounds): NSF Registration number for this product is: 062465 This product is acceptable for use in meat, poultry, and other food processing areas as a Boiler Treatment Product (G6), for treating boiler and steam lines where the steam produced may contact edible products. Acceptable usage W shall be in accordance with the dosage limitations specified on the product label.FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.151 formerly Sec. 307, 40 CFR 116.4 1 formerly Sec. 311 : None of the substances are specifically listed in the regulation. CLEAN AIR ACT, Sec. 112 (40 CFR 61, Hazardous Air Pollutants), Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances): This product contains the following substances listed in the regulation: Sbtanes Citations*Hydrazine Sec. 112 CALIFORNIA PROPOSITION 65: This product contains the following substances which require warning under California Proposition 65.Substance(s) Concentration EFFECTS e Hydrazine <= 60 % Causes Cancer MICHIGAN CRITICAL MATERIALS: This product contains the following substances listed in the regulation: Hydrazine Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198

-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 9/111 .NALCO MATERIAL SAFETY DATA SHEET PRODUC NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC STATE RIGHT TO KNOW LAWS : The following substances are disclosed for compliance with State Right to Know Laws: Hydrazine 302-01-2 NATIONAL REGULATIONS, CANADA: WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS): This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR.WHMIS CLASSIFICATION: D2B -Materials Causing Other Toxic Effects -Toxic Material CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA): The substances in this preparation are listed on the Domestic Substances List (DSL), are exempt, or have been reported in accordance with the New Substances Notification Regulations. INTERNATIONAL CHEMICAL CONTROL LAWS AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS).EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories. JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Ministry of International Trade & industry List (MITI).KOREA All substances in this product comply with the.Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL)THE PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippine Inventory of Chemicals & Chemical Substances (PICCS).116. 1 OTHER INFORMATION This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the recommended safety precautions and should have access to this information. For any other uses, exposures should be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information. REFERENCES Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 10/11 P 4NALCO MATERIAL SAFETY DATA SHEET SPRODUCT NALCO 19H EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Ariel Insight# CD-ROM Version), Adel Research Corp., Bethesda, MD.Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer.Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service.Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Ariel Insight# (An integrated guide to industrial chemicals covered under major regulatory and advisory programs), North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Prepared By: Product Safety Department Date issued: 10/03/2006 Version Number: 1.12 Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198
• (630)305-1000 For additional copies of an MSDS visit www.nalco.corn and request access 11/11 P NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 11. 1 CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: NALCO 9226 APPLICATION:

CORROSION INHIBITOR COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (BOO) 424-9300 (24 Hours) CHEMTREC NFPA 704MWHMIS RATING HEALTH: 313 FLAMMABILITY: 1 1 1 INSTABILITY: 0/0 OTHER: 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme 12. 1 COMPOSITIONIINFORMATION ON INGREDIENTS Our hazard evaluation has identified the following chemical substance(s) as hazardous. Consult Section 15 for the nature of the hazard(s). Hazardous Substance(s) CAS NO 141-43-5% (w/w)60.0 -100.0 Monoethanolamine

13. 1 HAZARDS IDENTIFICATION I**EMERGENCY OVERVIEW-DANGER Corrosive.

May cause tissue damage. Harmful if absorbed through skin. Large quantities may cause kidney and liver damage. Vapors may have a strong offensive odor which may cause sensory response including headache, nausea and vomiting.Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Keep container tightly dosed and in a well-ventilated place. In case of contact with eyes, rinse immediately with plenty of water and seek medical advice. After contact with skin, wash immediately with plenty of water.Wear a face shield. Wear chemical resistant apron, chemical splash goggles, impervious gloves and boots.May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) under fire conditions. PRIMARY ROUTES OF EXPOSURE: Eye, Skin, Inhalation S Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 1/10 P NALCO HUMAN HEALTH HAZARDS -ACUTE: MATERIAL SAFETY DATA SHEET'PRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC EYE CONTACT : Corrosive. Will cause eye bums and permanent tissue damage. Exposure to low vapor concentrations can result in foggy or blurred vision, objects appearing bluish and appearance of a halo around lights. These symptoms are temporary. SKIN CONTACT: May cause severe irritation or tissue damage depending on the length of exposure and the type of first aid administered. Harmful if absorbed through skin.INGESTION: Not a likely route of exposure. Corrosive; causes chemical bums to the mouth, throat and stomach.INHALATION: irritating, in high concentrations, to the eyes, nose, throat and lungs. Vapors may have a strong offensive odor which may cause sensory response including headache, nausea and vomiting.SYMPTOMS OF EXPOSURE: Acute : A review of available data does not identify any symptoms from exposure not previously mentioned. Chronic: A review of available data does not identify any symptoms from exposure not previously mentioned. AGGRAVATION OF EXISTING CONDITIONS: A review of available data does not identify any worsening of existing conditions.

14. FIRST AID MEASURES EYE CONTACT: PROMPT ACTION IS ESSENTIAL IN CASE OF CONTACT. Immediately flush eye with water for at least 15 minutes while holding eyelids open. Get immediate medical attention.

SKIN CONTACT: Immediately flush with plenty of water for at least 15 minutes. For a large splash, flood body under a shower.Remove contaminated clothing. Wash off affected area immediately with plenty of water. Get immediate medical attention. Contaminated clothing, shoes, and leather goods must be discarded or cleaned before re-use.INGESTION: DO NOT INDUCE VOMITING. If conscious, washout mouth and give water to drink. Get immediate medical'attention. INHALATION: Remove to fresh air, treat symptomatically. Get medical attention. NOTE TO PHYSICIAN: Probable mucosal damage may contraindicate the use of gastric lavage. Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 2/10 p4 NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC s5. I FIRE FIGHTING MEASURES FLASH POINT: 208 'F / 97.8 'C EXTINGUISHING MEDIA: This product would not be expected to bum unless all the water is boiled away. The remaining organics may be ignitable. Use extinguishing media appropriate for surrounding fire. Keep containers cool by spraying with water.FIRE AND EXPLOSION HAZARD: May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) under fire conditions. SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING: In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit.16. 1 ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS: Restrict access to area as appropriate until dean-up operations are complete. Ensure clean-up is conducted by trained personnel only. Ventilate spill area if possible. Do not touch spilled material. Stop or reduce any leaks if it is safe to do so. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Notify appropriate government, occupational health and safety and environmental authorities. .METHODS FOR CLEANING UP: SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Wash site of spillage thoroughly with water. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). ENVIRONMENTAL PRECAUTIONS: Do not contaminate surface water.17. 1 HANDLING AND STORAGEI HANDLING: Do not get in eyes, on skin, on clothing. Do not take internally. Do not breathe vapors/gases/dust. Use with adequate ventilation. Avoid generating aerosols and mists. Keep away from acids and oxidizing agents. Keep the containers closed when not in use. Have emergency equipment (for fires, spills, leaks, etc.) readily available. STORAGE CONDITIONS: Store the containers tightly closed. Store separately from acids. Store separately from oxidizers. Amine and sulphite products should not be stored within close proximity or resulting vapors may form visible airborne particles.

18. 1 EXPOSURE CONTROLS/PERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS: Exposure guidelines have not been established for this product. Available exposure limits for the substance(s) are shown below.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 3/10 A NALCO MATERIAL SAFETY DATA SHEET[PR ODUCT NALCO 9226.1 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC ACGIH/TLV:

Substance(s) Monoethanolamine OSHA/PEL: Substance(s) Monoethanolamine TWA: 3 ppm, 7.5 mg/m3 STEL: 6 ppm, 15 mg/m3 TWA: 3 ppm , 8 mg/m3 STEL: 6 ppm, 15 mg/m3 ENGINEERING MEASURES: General ventilation is recommended. Use local exhaust ventilation if necessary to control airborne mist and vapor.RESPIRATORY PROTECTION: If significant mists, vapors or aerosols are generated an approved respirator is recommended. An organic vapor cartridge with dust/mist prefilter or supplied air may be used. In event of emergency or planned entry into unknown concentrations a positive pressure, full-facepiece SCBA should be used. If respiratory protection is required, institute a complete respiratory protection program including selection, fit testing, training, maintenance and inspection. HAND PROTECTION: Butyl gloves. Most glove materials are of low chemical resistance. Replace gloves regularly. SKIN PROTECTION: Wear chemical resistant apron, chemical splash goggles, impervious gloves and boots. A full slicker suit is recommended if gross exposure is possible.EYE PROTECTION: Wear a face shield with chemical splash goggles.HYGIENE RECOMMENDATIONS: Eye wash station and safety shower are necessary. If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse.HUMAN EXPOSURE CHARACTERIZATION: Based on our recommended product application and personal protective equipment, the potential human exposure is: Low 19. 1 PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Colorless ODOR Amine SPECIFIC GRAVITY 1 @ 77 °F / 25 -C Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198 (630)305-1000 4110 fNALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC DENSITY 8.31 lb/gal SOLUBILITY IN WATER Complete pH 0 13.8 VISCOSITY 42 SUS @ 100 °F /37.8 °C POUR POINT -30 'F 1-34.3 °C BOILING POINT 266 "F 130 °C Note: These physical properties are typical values for this product and are subject to change.110. 1 STABILITY AND REACTIVITY STABILITY:

Stable under normal conditions. HAZARDOUS POLYMERIZATION: Hazardous polymerization will not occur.CONDITIONS TO AVOID: None known MATERIALS TO AVOID:.Contact with strong acids (e.g. sulfuric, phosphoric, nitric, hydrochloric, chromic, sulfonic) may generate heat, splattering or boiling and toxic vapors. Contact with strong oxidizers (e.g. chlorine, peroxides, chromates, nitric acid, perchlorate, concentrated oxygen, permanganate) may generate heat, fires, explosions and/or toxic vapors. Avoid contact with S02 or acidic bisulfite products, which may react to form visible airborne amine salt particles. Certain amines in contact with nitrous acid, organic or inorganic nitrites or atmospheres with high nitrous oxide concentrations may produce N-nitrosamines, many of which are cancer-causing agents to laboratory animals.HAZARDOUS DECOMPOSITION PRODUCTS: Under fire conditions: Oxides of carbon, Oxides of nitrogen I11. I TOXICOLOGICAL INFORMATION I No toxicity studies have been conducted on this product.SENSITIZATION: This product is not expected to be a sensitizer. CARCINOGENICITY: None of the substances in this product are listed as carcinogens by the International Agency for Research on Cancer (IARC), the National Toxicology Program (NTP) or the American Conference of Governmental Industrial Hygienists (ACGIH).HUMAN HAZARD CHARACTERIZATION:. Based on our hazard characterization, the potential human hazard is: High NalcoCompany 1601 W. Diehl Road

• Naperville, Illinois 60563-1198 (630)305-1000 5/10 P4'NALCO MATERIAL SAFETY DATA SHEET SPRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 112. 1 ECOLOGICAL INFORMATION.

ECOTOXICOLOGICAL EFFECTS: No toxicity studies have been conducted on this product.ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: Moderate Based on our recommended product application and the product's characteristics, the potential environmental exposure is: Low If released into the environment, see CERCLA/SUPERFUND in Section 15.13. DISPOSAL CONSIDERATIONS If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the criteria of a hazardous waste.Hazardous Waste: D002 Hazardous wastes must be transported by a licensed hazardous waste transporter and disposed of or treated in a properly licensed hazardous waste treatment, storage, disposal or recycling facility. Consult local, state, and federal regulations for specific requirements. 114. 1 TRANSPORT INFORMATION The information in this section is for reference only and should not take the place of a shipping paper (bill of lading)specific to an order. Please note that the proper Shipping Name / Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows.LAND TRANSPORT: 0 Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Packing Group: ETHANOLAMINE SOLUTION UN 2491 8 III Flash Point: 97.8 °C /208 OF AIR TRANSPORT (ICAO/IATA): Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Packing Group: ETHANOLAMINE SOLUTION UN 2491 8 III 0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 6/10 PNALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(500) 424-9300 (24 Hours) CHEMTREC IATA Cargo Packing Instructions: 820 IATA Cargo Aircraft Limit: 60 L (Max net quantity per package)MARINE TRANSPORT (IMDG/IMO): Proper Shipping Name: ETHANOLAMINE SOLUTION TechnicalName(s)

UN/ID No: UN 2491 Hazard Class -Primary: 8 Packing Group: III 15. REGULATORY INFORMATION NATIONAL REGULATIONS, USA: OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200:

Based on our hazard evaluation, the following substance(s) in this product islare hazardous and the reason(s) is/are shown below.Monoethanolamine: Corrosive, Combustible. CERCLA/SUPERFUND, 40 CFR 117, 302: Notification of spills of this product is not required.SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE III) -SECTIONS 302,311, 312. AND 313: SECTION 302 -EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355): This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance. SECTIONS 311 AND 312 -MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370): Our hazard evaluation has found this product to be hazardous. The product should be reported under the following indicated EPA hazard categories: X Immediate (Acute) Health Hazard Delayed (Chronic) Health Hazard Fire Hazard Sudden Release of Pressure Hazard Reactive Hazard Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals. The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10,000 pounds for all other hazardous chemicals. SECTION 313 -LIST OF TOXIC CHEMICALS (40 CFR 372): This product does not contain substances on the List of Toxic Chemicals. TOXIC SUBSTANCES CONTROL ACT (TSCA): The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710)Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 7/10 MATERIAL SAFETY DATA SHEET~NALCO EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC This product has been certified as KOSHER/PAREVE for year-round use INCLUDING THE PASSOVER SEASON by the CHICAGO RABBINICAL COUNCIL.FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 116.4 / formerly Sec. 311: None of the substances are specifically listed in the regulation. CLEAN AIR ACT, Sec. 111 (40 CFR 60, Volatile Organic Compounds), Sec. 112 (40 CFR 61, Hazardous Air Pollutants), Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances): This product contains the following substances listed in the regulation: Substance(s) Citations 0 Monoethanolamine Sec. 111 CALIFORNIA PROPOSITION 65: This product does not contain substances which require warning under California Proposition 65.MICHIGAN CRITICAL MATERIALS: None of the substances are specifically listed in the regulation. STATE RIGHT TO KNOW LAWS: The following substances are disclosed for compliance with State Right to Know Laws: Monoethanolamine 141-43-5 NATIONAL REGULATIONS, CANADA: WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS): This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR.WHMIS CLASSIFICATION: E -Corrosive Material CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA): The substances in this preparation are listed on the Domestic Substances List (DSL), are exempt, or have been reported in accordance with the New Substances Notification Regulations. INTERNATIONAL CHEMICAL CONTROL LAWS AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS) and are listed on the Australian Inventory of Chemical Substances (AICS).EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 8/10 NNALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC I 0 JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Ministry of International Trade & industry List (MITI).KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL)THE PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippine Inventory of Chemicals & Chemical Substances (PICCS).116. 1 OTHER INFORMATION Due to our commitment to Product Stewardship, we have evaluated the human and environmental hazards and exposures of this product. Based on our recommended use of this product, we have characterized the product's general risk. This information should provide assistance for your own risk management practices. We have evaluated our product's risk as follows:* The human risk is: Low" The environmental risk is: Low Any use inconsistent with our recommendations may affect the risk characterization. Our sales representative will assist you to determine if your product application is consistent with our recommendations. Together we can implement an appropriate risk management process.This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the recommended safety precautions and should have access to this information. For any other uses, exposures should be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information. REFERENCES Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer.Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 (630)305-1000 9110 A NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9226 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service.Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (AMel Insight# CD-ROM Version). Ariel Research Corp., Bethesda, MD.Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Ariel Insight# (An integrated guide to industrial chemicals covered under major regulatory and advisory programs), North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Prepared By: Product Safety Department Date issued: 02/22/2004 Version Number: 1.4 Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198 (630)305-1000 10/10 P4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 1. [ CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: NALCO 9353 APPLICATION:

SCALE INHIBITOR/DISPERSANT COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 0/1 FLAMMABILITY: 1 /1 INSTABILITY: 0/0 OTHER: 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme 12. 1 COMPOSITION/INFORMATION ON INGREDIENTS Based on our hazard evaluation, none of the substances in this product are hazardous. I 3. I HAZARDS IDENTIFICATION A W"EMERGENCY OVERVIEW** CAUTION May cause irritation with prolonged contact.Do not get in eyes, on skin, on clothing. Do not take internally. Wear suitable protective clothing. Keep container tightly closed. Flush affected area with water. Protect product from freezing.May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) and sulfur (SOx)under fire conditions. PRIMARY ROUTES OF EXPOSURE : Eye, Skin HUMAN HEALTH HAZARDS -ACUTE: EYE CONTACT: May cause irritation with prolonged contact.SKIN CONTACT: May cause irritation with prolonged contact.INGESTION: Not a likely route of exposure. No adverse effects expected.INHALATION: Not a likely route of exposure. No adverse effects expected.0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198

• (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 1/9 MATERIAL SAFETY DATA SHEET NALCO PRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC SYMPTOMS OF EXPOSURE: Acute: A review of available data does not identify any symptoms from exposure not previously mentioned.

Chronic : A review of available data does not identify any symptoms from exposure not previously mentioned. AGGRAVATION OF EXISTING CONDITIONS: A review of available data does not identify any worsening of existing conditions. HUMAN HEALTH HAZARDS -CHRONIC: No adverse effects expected other than those mentioned above.14. 1 FIRST AID MEASURES EYE CONTACT: Flush affected area with water. If symptoms develop, seek medical advice.SKIN CONTACT: Flush affected area with water. If symptoms develop, seek medical advice.INGESTION: Do not induce vomiting without medical advice. If conscious, washout mouth and give water to drink. If symptoms develop, seek medical advice.INHALATION: Remove to fresh air, treat symptomatically. If symptoms develop, seek medical advice.NOTE TO PHYSICIAN: Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition.

15. 1 FIRE FIGHTING MEASURES FLASH POINT: > 212 OF/> 100 °C ( PMCC)EXTINGUISHING MEDIA: This product would not be expected to bum unless all the water is boiled away. The remaining organics may be ignitable.

Use extinguishing media appropriate for surrounding fire.FIRE AND EXPLOSION HAZARD: May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) and sulfur (SOx)under fire conditions. SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING: In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit.S Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 2/9 4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 16. 1 ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS: Restrict access to area as appropriate until clean-up operations are complete. Stop or reduce any leaks if it is safe to do so. Do not touch spilled material. Ventilate spill area if possible. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). METHODS FOR CLEANING UP: SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). ENVIRONMENTAL PRECAUTIONS: Do not contaminate surface water.1 HANDLING AND STORAGE HANDLING: Avoid eye and skin contact. Do not take internally. Ensure all containers are labelled. Keep the containers closed when not in use.STORAGE CONDITIONS: Protect product from freezing. Store in suitable labelled containers. Store the containers tightly closed.SUITABLE CONSTRUCTION MATERIAL: Compatibility with Plastic Materials can vary; we therefore recommend that compatibility is tested prior to use.8. EXPOSURE CONTROLS/PERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS: This product does not contain any substance that has an established exposure limit.ENGINEERING MEASURES: General ventilation is recommended. RESPIRATORY PROTECTION: Respiratory protection is not normally needed. Respiratory protection is not normally needed.HAND PROTECTION: Neoprene gloves, Nitrile gloves, Butyl gloves, PVC gloves SKIN PROTECTION: Wear standard protective clothing.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 3/9 NNALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC EYE PROTECTION: Wear chemical splash goggles. When handling this product, the use of splash chemical goggles is recommended. The applicable European standard can be found in EN 166.HYGIENE RECOMMENDATIONS: Keep an eye wash fountain available. Keep a safety shower available. If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse.HUMAN EXPOSURE CHARACTERIZATION: Based on our recommended product application and personal protective equipment, the potential human exposure is: Moderate 19. 1 PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Colorless Opaque ODOR None SPECIFIC GRAVITY 1.23 -1.29 @ 77 -F / 25 -C DENSITY 10.5 lb/gal SOLUBILITY IN WATER Complete pH (100 %) 3 VISCOSITY 275 cps VOC CONTENT 0.0 % Calculated Note: These physical properties are typical values for this product and are subject to change.110. 1 STABILITY AND REACTIVITY STA1I3LITY: Stable under normal conditions. HAZARDOUS POLYMERIZATION: Hazardous polymerization will not occur.CONDITIONS TO AVOID: Freezing temperatures. MATERIALS TO AVOID: Contact with strong oxidizers (e.g. chlorine, peroxides, chromates, nitric acid, perchlorate, concentrated oxygen, permanganate) may generate heat, fires, explosions and/or toxic vapors. Contact with strong alkalies (e.g. ammonia and its solutions, carbonates, sodium hydroxide (caustic), potassium hydroxide, calcium hydroxide (lime), cyanide, sulfide, hypochlorites, chlorites) may generate heat, splattering or boiling and toxic vapors.HAZARDOUS DECOMPOSITION PRODUCTS -Under fire conditions: Oxides of carbon, Oxides of nitrogen, Oxides of sulfur Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198

-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 4/9 4 NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 11. TOXICOLOGICAL INFORMATION No toxicity studies have been conducted on this product.SENSITIZATION

This product is not expected to be a sensitizer.

CARCINOGENICITY: None of the substances in this product are listed as carcinogens by the International Agency for Research on Cancer (IARC), the National Toxicology Program (NTP) or the American Conference of Governmental Industrial Hygienists (ACGIH).HUMAN HAZARD CHARACTERIZATION: Based on our hazard characterization, the potential human hazard is: Low 12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS: The following results are for the product.ACUTE FISH RESULTS: Species Exposure LC50 Test Descriptor Fathead Minnow 96 hrs 700 moI Product ACUTE INVERTEBRATE RESULTS: Species Exposure LC5O EC50 Test Descriptor Ceriodaphnia dubia 48 hrs 375 mg/I Product MOBILITY: The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM, provided by the US EPA. The model assumes a steady state condition between the total input and output. The level III model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air Water Soil/Sediment <5% 10-30% 70-90%The portion in water is expected to be soluble or dispersible. BIOACCUMULATION POTENTIAL This preparation or material is not expected to bioaccumulate. Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198

-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 5/9 A4NALCO MATERIAL SAFETY DATA SHEET PRODUCTi NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 0 ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: Low Based on our recommended product application and the product's characteristics, the potential environmental exposure is: High If released into the environment, see CERCLA/SUPERFUND in Section 15.S13. 1 DISPOSAL CONSIDERATIONS If this product becomes a waste, it is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261, since it does not have the characteristics of Subpart C, nor is it listed under Subpart D.As a non-hazardous waste, it is not subject to federal regulation. Consult state or local regulation for any additional handling, treatment or disposal requirements. For disposal, contact a property licensed waste treatment, storage, disposal or recycling facility.I 14. I TRANSPORT INFORMATION I The information in this section is for reference only and should not take the place of a shipping paper (bill of lading)specific to an order. Please note that the proper Shipping Name I Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows.LAND TRANSPORT: Proper Shipping Name: AIR TRANSPORT (ICAO/IATA): Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION PRODUCT IS NOT REGULATED DURING TRANSPORTATION PRODUCT IS NOT REGULATED DURING TRANSPORTATION MARINE TRANSPORT (IMDG/IMO): Proper Shipping Name: 15. 1REGULATORY INFORMATION NATIONAL REGULATIONS, USA: OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200: Based on our hazard evaluation, none of the substances in this product are hazardous. CERCLA/SUPERFUND, 40 CFR 117,302: Notification of spills of this product is not required.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 6/9 AWNALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE III) -SECTIONS 302, 311, 312, AND 313: SECTION 302 -EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355): This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance. SECTIONS 311 AND 312 -MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370): Our hazard evaluation has found that this product is not hazardous under 29 CFR 1910.1200. Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals. The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10,000 pounds for all other hazardous chemicals. SECTION 313 -LIST OF TOXIC CHEMICALS (40 CFR 372): This product does not contain substances on the List of Toxic Chemicals. TOXIC SUBSTANCES CONTROL ACT (TSCA): The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710)FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 116.4 /formerly Sec. 311 : None of the substances are specifically listed in the regulation. CLEAN AIR ACT, Sec. 111 (40 CFR 60, Volatile Organic Compounds), Sec. 112 (40 CFR 61, Hazardous Air Pollutants). Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances): None of the substances are specifically listed in the regulation. CALIFORNIA PROPOSITION 65: This product does not contain substances which require warning under California Proposition 65.MICHIGAN CRITICAL MATERIALS: None of the substances are specifically listed in the regulation. STATE RIGHT TO KNOW LAWS: None of the substances are specifically listed in the regulation. NATIONAL REGULATIONS, CANADA: WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS): This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR.WHMIS CLASSIFICATION: Not considered a WHMIS controlled product.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 7/9 MATERIAL SAFETY DATA SHEET P04NALCOPRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S) 0 (800) 424-9300 (24 Hours) CHEMTREC CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA): The substances in this preparation are listed on the Domestic Substances List (DSL), are exempt, or have been reported in accordance with the New Substances Notification Regulations. INTERNATIONAL CHEMICAL CONTROL LAWS AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS).CHINA All substances in this product comply with the Chemical Control Law and are listed on the Inventory of Existing Chemical Substances China (IECSC).EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories. JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Ministry of International Trade & industry List (MITI).KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL)THE PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippine Inventory of Chemicals & Chemical Substances (PICCS).16. 1 OTHER INFORMATION Due to our commitment to Product Stewardship, we have evaluated the human and environmental hazards and exposures of this product. Based on our recommended use of this product, we have characterized the product's general risk. This information should provide assistance for your own risk management practices. We have evaluated our product's risk as follows: " The human risk is: Low" The environmental risk is: Low Any use inconsistent with our recommendations may affect the risk characterization. Our sales representative will assist you to determine if your product application is consistent with our recommendations. Together we can implement an appropriate risk management process.0 Nalco Company 1601 W. Diehl Road

• Naperville, Illinois 60563-1198

-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 8/9 )4NALCO MATERIAL SAFETY DATA SHEET PRODUCT NALCO 9353 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the recommended safety precautions and should have access to this information. For any other uses, exposures should be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information. REFERENCES Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Mel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood. CO.IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer.Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service.Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Adel Insight# (An integrated guide to industrial chemicals covered under major regulatory and advisory programs), North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Prepared By: Product Safety Department Date issued : 11/03/2005 Version Number: 1.6 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 9/9 MATERIAL SAFETY DATA SHEET"NALCO PRODUCT ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S) 0 (800) 424-9300 (24 Hours) CHEMTREC S1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: ACTI-BROMO 1318 APPLICATION: BIOCIDE COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 424-9300 (24 Hours) CHEMTREC NFPA 704MlHMIS RATING HEALTH: 1/1 FLAMMABILITY: 0 /0 INSTABILITY: 0/0 OTHER: 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme 12. 1 COMPOSITIONIINFORMATION ON INGREDIENTS Our hazard evaluation has identified the following chemical substance(s) as hazardous. Consult Section 15 for the nature of the hazard(s). Hazardous Substance(s) CAS NO % (w/w)Sodium Bromide 7647-15-6 30.0 -60.0 13. 1 HAZARDS IDENTIFICATION-EMERGENCY OVERVIEW-CAUTION Causes moderate eye irritation. Avoid contact with eyes, skin and clothing. Wash with soap and water after handling. Remove contaminated clothing and wash before reuse.May evolve hydrogen bromide and bromine under fire conditions. PRIMARY ROUTES OF EXPOSURE: Eye, Skin HUMAN HEALTH HAZARDS -ACUTE: EYE CONTACT: Can cause mild to moderate irritation. SKIN CONTACT: May cause irritation with prolonged contact.INGESTION: Not a likely route of exposure. No adverse effects expected.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 1/11 fNALCO MATERIAL SAFETY DATA SHEET PRODUCT ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC INHALATION: Not a likely route of exposure. Aerosols or product mist may irritate the upper respiratory tract.SYMPTOMS OF EXPOSURE: Acute : A review of available data does not identify any symptoms from exposure not previously mentioned. Chronic: A review of available data does not identify any symptoms from exposure not previously mentioned. AGGRAVATION OF EXISTING CONDITIONS: A review of available data does not identify any worsening of existing conditions. HUMAN HEALTH HAZARDS -CHRONIC: No adverse effects expected other than those mentioned above.14. -FIRST AID MEASURES IF ON SKIN OR CLOTHING: Take off contaminated clothing. Rinse skin immediately with plenty of water for 15-20 minutes. Call a poison control center or doctor for treatment advice.IF IN EYES: Hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing eye. Call a poison control center or doctor for treatment advice.IF SWALLOWED: Call poison control center or doctor immediately for treatment advice. Have person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by the poison control center or doctor. Do not give anything by mouth to an unconscious person.IF INHALED: Remove victim to fresh air. If not breathing, give artificial respiration, preferably, mouth-to-mouth. Get medical attention.A

15. 1 FIRE FIGHTING MEASURES FLASH POINT: None EXTINGUISHING MEDIA: Not expected to bum. Keep containers cool by spraying with water. Use extinguishing media appropriate for surrounding fire.FIRE AND EXPLOSION HAZARD: May evolve hydrogen bromide and bromine under fire conditions.

SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING: In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 2/11 MATERIAL SAFETY DATA SHEET)4NALCO PRODUCT ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 16. ____ I ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS: Restrict access to area as appropriate until clean-up operations are complete. Ensure clean-up is conducted by trained personnel only. Ventilate spill area if possible. Do not touch spilled material. Stop or reduce any leaks if it is safe to do so. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Notify appropriate government, occupational health and safety and environmental authorities. METHODS FOR CLEANING UP: SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Wash site of spillage thoroughly with water. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations). ENVIRONMENTAL PRECAUTIONS: This pesticide is toxic to fish and aquatic organisms. Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans or other waters, unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA.17. 1 HANDLING AND STORAGE HANDLING: Avoid eye and skin contact. Do not take internally. Do not get in eyes, on skin, on clothing. Have emergency equipment (for fires, spills, leaks, etc.) readily available. Ensure all containers are labelled. Keep the containers closed when not in use. Use with adequate ventilation. STORAGE CONDITIONS: Store the containers tightly closed. Store in suitable labelled containers.

8. EXPOSURE CONTROLSIPERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS: This product does not contain any substance that has an established exposure limit.ENGINEERING MEASURES: General ventilation is recommended.

RESPIRATORY PROTECTION: Respiratory protection is not-normally needed.HAND PROTECTION: Neoprene gloves, Nitrile gloves, Butyl gloves, PVC gloves Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198

• (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 3/11 fNALCO MATERIAL SAFETY DATA SHEET EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC SKIN PROTECTION:

Wear standard protective clothing.EYE PROTECTION: Wear chemical splash goggles.HYGIENE RECOMMENDATIONS: If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse. Keep an eye wash fountain available. Keep a safety shower available. HUMAN EXPOSURE CHARACTERIZATION: Based on our recommended product application and personal protective equipment, the potential human exposure is: Moderate 19. 1 PHYSICAL AND CHEMICAL PROPERTIES PHYSICAL STATE Liquid APPEARANCE Colorless ODOR None SPECIFIC GRAVITY 1.45 @ 77 °F /25 -C DENSITY 12.1 lb/gal SOLUBILITY IN WATER Complete pH (100 %) 7.9 VISCOSITY 5 cps FREEZING POINT 7 OF / -14 °C BOILING POINT 218 OF (103.5 °C VAPOR PRESSURE 5.6 mm Hg @ 68 °F /20 °C VOC CONTENT 0.00 %Note: These physical properties are typical values for this product and are subject to change.110. 1 STABILITY AND REACTIVITY STABILITY: Stable under normal conditions. HAZARDOUS POLYMERIZATION: Hazardous polymerization will not occur.CONDITIONS TO AVOID: Freezing temperatures. MATERIALS TO AVOID: Contact with strong oxidizers (e.g. chlorine, peroxides, chromates, nitric acid, perchlorate, concentrated oxygen, permanganate) may generate heat, fires, explosions and/or toxic vapors.0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 4/11 P4NALCO MATERIAL SAFETY DATA SHEET PRODUCT ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC HAZARDOUS DECOMPOSITION PRODUCTS: Under fire conditions: None known 111. 1 TOXICOLOGICAL INFORMATION I ACUTE ORAL TOXICITY: Species LD50 Rat > 5,000 mglkg Rating: Non-Hazardous ACUTE DERMAL TOXICITY: Species LD50 Rabbit > 2,000 mg/kg Rating : Non-Hazardous PRIMARY SKIN IRRITATION: Draize Score 0.0 /8.0 Rating: Essentially non-irritating PRIMARY EYE IRRITATION: Draie Score 16.0 1110.0 Rating : Mildly irritating Test Descriptor Similar Product Test Descriptor Similar Product Test Descriptor Similar Product Test Descriptor Similar Product SENSITIZATION: This product is not expected to be a sensitizer. CARCINOGENICITY: None of the substances in this product are listed as carcinogens by the International Agency for Research on Cancer (IARC), the National Toxicology Program (NTP) or the American Conference of Governmental Industrial Hygienists (ACGIH).HUMAN HAZARD CHARACTERIZATION: Based on our hazard characterization, the potential human hazard is: Low 12. ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS: The following results are for the product and a similar product. The following results are for the active components. The following results are for the hypobromous acid (as Br2) generated from sodium bromide and hypochlorite. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 5/11 ) NALCO MATERIAL SAFETY DATA SHEET APRODUCT ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC ACUTE FISH RESULTS: Species Exposure LC50 Test Descriptor Fathead Minnow 96 hrs > 5,000 mg/I Product Rainbow Trout 96 hrs > 1,000 mg/I Similar Product Bluegill Sunfish 96 hrs > 1,000 mg/I Similar Product Fathead Minnow 96 hrs 0.097 mg/I HOBr (Generated from NaBr)Rainbow Trout 96 hrs 0.23 mg/I HOBr (Generated from NaBr)Bluegill Sunfish 96 hrs 0.52 mg/I HOBr (Generated from NaBr)Sheepshead Minnow 96 hrs 0.19 mg/i HOBr (Generated from NaBr)ACUTE INVERTEBRATE RESULTS: Species Exposure LC50 EC50 Test Descriptor Daphnia magna 48 hrs 7,900 mg/i Active Substance ( Sodium Bromide)Ceriodaphnia dubia 48 hrs > 5,000 mg/I Product Daphnia magna 48 hrs 0.038 mg/I HOBr (Generated from NaBr)American Oyster 96 hrs 0.54 mg/I HOBr (Generated from NaBr)Mysid Shrimp (Mysidopsis 96 hrs 0.17 mg/i HOBr (Generated from NaBr)bahia) I I ADDITIONAL ECOLOGICAL DATA: AOX information: Product contains no organic halogens.PERSISTENCY AND DEGRADATION: Biological Oxygen Demand (BOD): environment. This material is an oxidizing biocide and is not expected to persist in the Greater than 95% of this product consists of inorganic substances for which a biodegradation value is not applicable. MOBILITY: The environmental fate was estimated using a level III fugacity model embedded in the EPI (estimation program interface) Suite TM , provided by the US EPA. The model assumes a steady state condition between the total input and output. The level Ill model does not require equilibrium between the defined media. The information provided is intended to give the user a general estimate of the environmental fate of this product under the defined conditions of the models. If released into the environment this material is expected to distribute to the air, water and soil/sediment in the approximate respective percentages; Air Water Soil/Sediment <5% 30 -50% 50 -70%The portion in water is expected to be soluble or dispersible. BIOACCUMULATION POTENTIAL This preparation or material is not expected to bioaccumulate. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305.1000 For additional copies of an MSDS visit www.nalco.com and request access 6/11 AWNALCO MATERIAL SAFETY DATA SHEET ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: Low Based on our recommended product application and the product's characteristics, the potential environmental exposure is: Moderate If released into the environment, see CERCLA/SUPERFUND in Section 15.113. 1 DISPOSAL CONSIDERATIONS I If this product becomes a waste, it is not a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261, since it does not have the characteristics of Subpart C, nor is it listed underSubpart D.As a non-hazardous waste, it is not subject to federal regulation. Consult state or local regulation for any additional handling, treatment or disposal requirements. For disposal, contact a properly licensed waste treatment, storage, disposal or recycling facility.DO NOT REUSE EMPTY CONTAINER. Triple rinse the container (or equivalent). Then offer for recycling or reconditioning, or puncture and dispose of in a sanitary landfill, or incinerate. Bum only if allowed by state and local authorities. If burned, stay out of smoke.114. -FTRANSPORT INFORMATION The information in this section is for reference only and should not take the place of a shipping paper (bill of lading)specific to an order. Please note that the proper Shipping Name I Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows.LAND TRANSPORT: 0 Proper Shipping Name: AIR TRANSPORT (ICAO/IATA): Proper Shipping Name: PRODUCT IS NOT REGULATED DURING TRANSPORTATION PRODUCT IS NOT REGULATED DURING TRANSPORTATION PRODUCT IS NOT REGULATED DURING TRANSPORTATION MARINE TRANSPORT (IMDG/IMO): Proper Shipping Name: 115. 1 REGULATORY INFORMATION NATIONAL REGULATIONS, USA: OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200: Based on our hazard evaluation, the following substance(s) in this product is/are hazardous and the reason(s) is/are shown below.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 7/11 0 MATERIAL SAFETY DATA SHEET AW PRODUCT~NALCO ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC Sodium Bromide : Eye irritant CERCLAISUPERFUND, 40 CFR 117, 302: Notification of spills of this product is not required.SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE Ill) -SECTIONS 302,311, 312, AND 313: SECTION 302 -EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355): This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance. SECTIONS 311 AND 312 -MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370): Our hazard evaluation has found this product to be hazardous. The product should be reported under the following indicated EPA hazard categories: X Immediate (Acute) Health Hazard Delayed (Chronic) Health Hazard Fire Hazard Sudden Release of Pressure Hazard Reactive Hazard.Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals. The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10.000 pounds for all other hazardous chemicals. SECTION 313 -LIST OF TOXIC CHEMICALS (40 CFR 372): This product does not contain substances on the List of Toxic Chemicals. TOXIC SUBSTANCES CONTROL ACT (TSCA): This product is exempted under TSCA and regulated under FIFRA. The inerts are on the Inventory List.FOOD AND DRUG ADMINISTRATION (FDA) Federal Food, Drug and Cosmetic Act: When use situations necessitate compliance with FDA regulations, this product is acceptable under: 21 CFR 176.170 Components of paper and paperboard in contact with aqueous and fatty foods and 21 CFR 176.180 Components of paper and paperboard in contact with dry foods., 21 CFR 176.300 Slimicides, The following limitations apply: This product may be used to treat pulp and papermill water systems in situations requiring FDA sanction provided the bromide concentration in the water is kept below 22 ppm. The product must be used in conjunction with an oxidant such as bleach or gaseous chlorine. Follow instructions for use in pulp and papermill on the product label.FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA): EPA Reg. No. 5185-467-1706 In all cases follow instructions on the product label.This product has been certified as KOSHER/PAREVE for year-round use INCLUDING THE PASSOVER SEASON by the CHICAGO RABBINICAL COUNCIL.0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 8/11 NALC OPRMATERIAL SAFETY DATA SHEET ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S) 0 (800) 424-9300 (24 Hours) CIEMTREC FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 116.4 / formerly Sec. 311:.None of the substances are specifically listed in the regulation. CLEAN AIR ACT, Sec. 112 (40 CFR 61, Hazardous Air Pollutants), Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances): None of the substances are specifically listed in the regulation. CALIFORNIA PROPOSITION 65: This product does not contain substances which require warning under California Proposition 65.MICHIGAN CRITICAL MATERIALS: None of the substances are specifically listed in the regulation. STATE RIGHT TO KNOW LAWS: This product is a registered biocide and is exempt from State Right to Know Labelling Laws.NATIONAL REGULATIONS, CANADA: WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS): This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR) and the MSDS contains all the information required by the CPR.WHMIS CLASSIFICATION: Pesticide controlled products are not regulated under WHMIS.CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA): The substances in this preparation are listed on the Domestic Substances List (DSL), are exempt, or have been reported in accordance with the New Substances Notification Regulations. INTERNATIONAL CHEMICAL CONTROL LAWS AUSTRALIA All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS).EUROPE The substances in this preparation have been reviewed for compliance with the EINECS or ELINCS inventories. JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Ministry of International Trade & industry List (MITI).KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL)0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 9/11 )VNALCO 0 MATERIAL SAFETY DATA SHEET PRODUCT ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC THE PHILIPPINES AJl substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippine Inventory of Chemicals & Chemical Substances (PICCS).116. 1 OTHER INFORMATION Due to our commitment to Product Stewardship, we have evaluated the human and environmental hazards and exposures of this product. Based on our recommended use of this product, we have characterized the product's general risk. This information should provide assistance for your own risk management practices. We have evaluated our product's risk as follows:* The human risk is: Low* The environmental risk is: Low Any use inconsistent with our recommendations may affect the risk characterization. Our sales representative will assist you to determine if your product application is consistent with our recommendations. Together we can implement an appropriate risk management process.This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the.recommended safety precautions and should have access to this information. For any other uses, exposures should be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information. REFERENCES Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Ariel Insight# CD-ROM Version), Ariel Research Corp., Bethesda, MD.Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer.Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service.Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (Ariel Insight# CD-ROM Version), Mel Research Corp., Bethesda, MD.Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.S Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198

• (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 10/11 PNALCO MATERIAL SAFETY DATA SHEET PRODUCT ACTI-BROM 1318 EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC Ariel Insight# (An integrated guide to industrial chemicals covered under major regulatory and advisory programs), North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel Insight# CD-ROM Version), Ardel Research Corp., Bethesda, MD.The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS# CD-ROM Version), Micromedex, Inc., Englewood, CO.Prepared By: Product Safety Department Date issued: 05/08/2006 Version Number: 1.17 0.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198

-(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 11/11 P4NALCO SAFETY DATA SHEET PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 11. 1 CHEMICAL PRODUCT AND COMPANY IDENTIFICATION PRODUCT NAME: H-130M APPLICATION: BIOCIDE COMPANY IDENTIFICATION: Nalco Company 1601 W. Diehl Road Naperville, Illinois 60563-1198 EMERGENCY TELEPHONE NUMBER(S): (800) 424-9300 (24 Hours) CHEMTREC NFPA 704M/HMIS RATING HEALTH: 3/3 FLAMMABILITY: 2/2 INSTABILITY: 0/0 OTHER: 0 = Insignificant 1 = Slight 2 = Moderate 3 = High 4 = Extreme = Chronic Health Hazard 12. 1 COMPOSITIONIINFORMATION ON INGREDIENTS Our hazard evaluation has identified the following chemical substance(s) as hazardous. Consult Section 15 for the nature of the hazard(s). Hazardous Substance(s) Didecyl-Dimethyl-Ammonium chloride Ethanol CAS NO 7173-51-5 64-17-5% (w/w)30.0- 60.0 5.0- 10.0 I 3. I HAZARDS IDENTIFICATION I"EMERGENCY OVERVIEW" DANGER Combustible. CORROSIVE. Causes severe eye and skin damage. Harmful or fatal if swallowed. Do not get in eyes, on skin, or on clothing. Wears goggles or face shield and rubber gloves when handling. Avoid contamination of food.Remove contaminated clothing and wash before reuse.Keep away from heat. Keep away from sources of ignition -No smoking. Use with adequate ventilation. Keep container tightly closed and in a well-ventilated place.Wear chemical resistant apron, chemical splash goggles, impervious gloves and boots.Combustible Liquid; may form combustible mixtures at or above the flash point. Empty product containers may contain product residue. Do not pressurize, cut, heat, weld, or expose containers to flame or other sources of ignition.May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) under fire conditions. May evolve HCI under fire conditions. May evolve ammonia under fire conditions. PRIMARY ROUTES OF EXPOSURE: Eye, Skin 0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 1/10 SAFETY DATA SHEET)PNALCO PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC HUMAN HEALTH HAZARDS- ACUTE: EYE CONTACT: Corrosive. Will cause eye bums and permanent tissue damage.SKIN CONTACT: May cause severe irritation or tissue damage depending on the length of exposure and the type of first aid administered. Harmful if absorbed through skin.INGESTION: Corrosive, causes bums to gastro-intestinal tract. Nausea, vomiting and stomach pain may occur. In severe cases blood may be vomited. May be fatal if swallowed. INHALATION: Irritating, in high concentrations, to the eyes, nose, throat and lungs. Inhalation of vapors may cause headache, nausea, and vomiting. Can cause central nervous system depression. Large exposures may be fatal.SYMPTOMS OF EXPOSURE: Acute: A review of available data does not identify any symptoms from exposure not previously mentioned. Chronic : A review of available data does not identify any symptoms from exposure not previously mentioned. AGGRAVATION OF EXISTING CONDITIONS: Skin contact may aggravate an existing dermatitis condition.

14. 1 FIRST AID MEASURES IF IN EYES: Hold eyelids open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing. Call poison control center or doctor for treatment advice.IF ON SKIN: Take off contaminated clothing.

Rinse skin immediately with plenty of water for 15-20 minutes. Call a poison control center or doctor for treatment advice.IF SWALLOWED: Call a Poison Control center or doctor for treatment advice. Have person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by the poison control center or doctor. Do not give anything by mouth to an unconscious person.IF INHALED: Move person to fresh air. if person is not breathing, call 911 or ambulance, then give artificial respiration, preferable mouth-to-mouth, if possible. Call a poison control center or doctor for treatment advice., Take container, label or product name and Pest Control Product registration number with you when seeking medical attention. NOTE TO PHYSICIAN: Probable mucosal damage may contraindicate the use of gastric lavage. Based on the individual reactions of the patient, the physician's judgement should be used to control symptoms and clinical condition. 0 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198

• (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 2/10

)4NALCO SAFETY DATA SHEET PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 1 5. 1 FIRE FIGHTING MEASURES FLASH POINT: 109 'F /43 -C ( SETAFLASH) EXTINGUISHING MEDIA: Foam, Carbon dioxide, Dry powder, Other extinguishing agent suitable for Class B fires, For large fires, use water spray or fog, thoroughly drenching the burning material.Water mist may be used to cool closed containers. FIRE AND EXPLOSION HAZARD: Combustible Liquid; may form combustible mixtures at or above the flash point. Empty product containers may contain product residue. Do not pressurize, cut, heat, weld, or expose containers to flame or other sources of ignition. May evolve oxides of carbon (COx) under fire conditions. May evolve oxides of nitrogen (NOx) under fire conditions. May evolve HCI under fire conditions. May evolve ammonia under fire conditions. SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING: In case of fire, wear a full face positive-pressure self contained breathing apparatus and protective suit.16. 1 ACCIDENTAL RELEASE MEASURES PERSONAL PRECAUTIONS: .Restrict access to area as appropriate until clean-up operations are complete. Use personal protective equipment recommended in Section 8 (Exposure Controls/Personal Protection). Stop or reduce any leaks if it is safe to do so.Ventilate spill area if possible. Do not touch spilled material. Ensure clean-up is conducted by trained personnel only.Notify appropriate government, occupational health and safety and environmental authorities. Have emergency equipment (for fires, spills, leaks, etc.) readily available. Remove sources of ignition.METHODS FOR CLEANING UP: SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Wash site of spillage thoroughly with water. Contact an approved waste hauler for disposal of contaminated recovered material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations), ENVIRONMENTAL PRECAUTIONS: This product is toxic to fish and other water organisms. Do not discharge directly into lakes, ponds, streams, waterways or public water supplies.17. 1 HANDLING AND STORAGE HANDLING: Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Avoid release of vapors or mists into workplace air. Keep the containers closed when not in use. Do not use in locations where vapor is likely to travel to welding flames or arcs or to other hot surfaces. Vapors are much heavier than air, this can result in uneven distribution. Have emergency equipment (for fires, spills, leaks, etc.) readily available. Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 3/10 SAFETY DATA SHEET A41' PROUCT NALCO H-130M EMERGENCY TELEPHONE NUMBER(S) 0 (B00) 424-9300 (24 Hours) CHEMTREC STORAGE CONDITIONS: Store away from heat and sources of ignition. Connections must be grounded to avoid electrical charges. Store the containers tightly closed. Store separately from oxidizers. Store in suitable labeled containers.

18. 1 EXPOSURE CONTROLSIPERSONAL PROTECTION OCCUPATIONAL EXPOSURE LIMITS: Exposure guidelines have not been established for this product. Available exposure limits for the substance(s) are shown below.ACGIHJTLV:

Substance(s) Ethanol TWA: 1,000 ppm, 1,880 mg/m3 OSHA/PEL: Substance(s) Ethanol TWA: 1,000 ppm, 1,900 mglm3 ENGINEERING MEASURES: Use general ventilation with local exhaust ventilation. RESPIRATORY PROTECTION: If significant mists, vapors or aerosols are generated an approved respirator is recommended. A suitable filter material depends on the amount and type of chemicals being handled. Consider the use of filter type: Organic vapor cartridge. with a Particulate pre-filter. In event of emergency or planned entry into unknown concentrations a positive pressure, full-facepiece SCBA should be used. If respiratory protection is required, institute a complete respiratory protection program including selection, fit testing, training, maintenance and inspection. HAND PROTECTION: When handling this product, the use of chemical gauntlets is recommended., The choice of work glove depends on work conditions and what chemicals are handled. Please contact the PPE manufacturer for advice on what type of glove material may be suitable., Gloves should be replaced immediately if signs of degradation are observed.SKIN PROTECTION: Wear impervious apron and boots. A full slicker suit is recommended if gross exposure is possible.EYE PROTECTION: Wear chemical splash goggles.HYGIENE RECOMMENDATIONS: Use good work and personal hygiene practices to avoid exposure. Keep an eye wash fountain available. Keep a safety shower available. If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing before reuse. Always wash thoroughly after handling chemicals. When handling this product never eat, drink or smoke.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 4/10 AWNALCO SAFETY DATA SHEET PRODUCT H-1 30MI EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC I 9. I PHYSICAL AND CHEMICAL PROPERTIES I PHYSICAL STATE APPEARANCE ODOR Liquid Light yellow Alcoholic SPECIFIC GRAVITY DENSITY SOLUBILITY IN WATER pH (1 %)VISCOSITY FREEZING POINT VOC CONTENT 0.93 @ 77 -F/25 -C 7.7 lb/gal Complete 7.0 -8.0<100cps @ 77°FI25°C 12 0 F/-11.11 0 C 10%Note: These physical properties are typical values for this product and are subject to change.110. 1 STABILITY AND REACTIVITY STABILITY: Stable under normal conditions. HAZARDOUS POLYMERIZATION: Hazardous polymerization will not occur.CONDITIONS TO AVOID: Heat and sources of ignition including static discharges. Extremes of temperature MATERIALS TO AVOID: Contact with strong oxidizers (e.g. chlorine, peroxides, chromates, nitric acid, perchlorate, concentrated oxygen.permanganate) may generate heat, fires, explosions and/or toxic vapors. Contact with reducing agents (e.g.hydrazine, sulfites, sulfide, aluminum or magnesium dust) may generate heat, fires, explosions and toxic vapors.HAZARDOUS DECOMPOSITION PRODUCTS: Under fire conditions: Oxides of carbon, Oxides of nitrogen, HCI, ammonia 11. 1 TOXICOLOGICAL INFORMATION The following results are for the product.ACUTE DERMAL TOXICITY: Species LD50 Rabbit > 4 g/kg Test Descriptor Product SENSITIZATION: This product is not expected to be a sensitizer. Nalco Company 1601 W. Diehl Road ' Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 5/10 AWNALCO SAFETY DATA SHEET PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC CARCINOGENICITY: None of the substances in this product are listed as carcinogens by the International Agency for Research on Cancer (IARC), the National Toxicology Program (NTP) or the American Conference of Governmental Industrial Hygienists (ACGIH).HUMAN HAZARD CHARACTERIZATION: Based on our hazard characterization, the potential human hazard is: High 12. 1 ECOLOGICAL INFORMATION ECOTOXICOLOGICAL EFFECTS: The following results are for the product.ACUTE FISH RESULTS: Species Exposure LC50 Test Descriptor Rainbow Trout 96 hrs 2.2 mo Bluegill Sunfish 96 hrs 0.92 mg/I ACUTE INVERTEBRATE RESULTS: Species I Exposure LC50 EC50 Test Descriptor Daphnia magna 48 hrs 0.19 mg/A Mysid Shrimp (Mysidopsis 96 hrs 0.14 mg/I bahia) I ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION Based on our hazard characterization, the potential environmental hazard is: High If released into the environment, see CERCLA/SUPERFUND in Section 15.13- 1 DISPOSAL CONSIDERATIONS If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the criteria of a hazardous waste.Hazardous Waste: DOO Pesticide wastes are acutely hazardous. Improper disposal of excess pesticide, spray mixture, or rinsate is a violation of Federal law. If these wastes cannot be disposed of by use according to label instructions, contact your State Pesticide or Environmental Control Agency, or the Hazardous Waste Representative at the nearest EPA Regional Office for guidance.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 ° (630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 6/10 t NALCO SAFETY DATA SHEET PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC 114. 1 TRANSPORT INFORMATION !The information in this section is for reference only and should not take the place of a shipping paper (bill of lading)specific to an order. Please note that the proper Shipping Name I Hazard Class may vary by packaging, properties, and mode of transportation. Typical Proper Shipping Names for this product are as follows.LAND TRANSPORT: Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Hazard Class -Secondary: Packing Group: CORROSIVE LIQUID, FLAMMABLE, N.O.S.DIDECYLDIMETHYLAMMONIUM CHLORIDE, ETHANOL UN 2920 8 3 II Flash Point: 43 °C / 109 °F AIR TRANSPORT (ICAO/IATA): Proper'Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Hazard Class -Secondary: Packing Group: IATA Cargo Packing Instructions: IATA Cargo Aircraft Limit: MARINE TRANSPORT (IMDG/IMO): CORROSIVE LIQUID, FLAMMABLE, N.O.S.DIDECYLDIMETHYLAMMONIUM CHLORIDE, ETHANOL ULN 2920 8 3 II 812 30 L (Max net quantity per package)CORROSIVE LIQUID, FLAMMABLE, N.O.S.DIDECYLDIMETHYLAMMONIUM CHLORIDE, ETHANOL UN 2920 8 3 II Proper Shipping Name: Technical Name(s): UN/ID No: Hazard Class -Primary: Hazard Class -Secondary: Packing Group: 115. I REGULATORY INFORMATION ý I This section contains additional information that may have relevance to regulatory compliance. The information in this section is for reference only. It is not exhaustive, and should not be relied upon to take the place of an individualized compliance or hazard assessment. Nalco accepts no liability for the use of this information. NATIONAL REGULATIONS, USA: OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200: Based on our hazard evaluation, the following substance(s) in this product is/are hazardous and the reason(s) is/are shown below.Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 7/10 SAFETY DATA SHEET ANALCO P H-130M EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC Didecyl-Dimethyl-Ammonium chloride: Corrosive Ethanol: Flammable CERCLA/SUPERFUND, 40 CFR 117, 302: Notification of spills of this product is not required.SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE Il1) -SECTIONS 302, 311, 312, AND 313: SECTION 302 -EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355): This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance. SECTIONS 311 AND 312 -MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370): Our hazard evaluation has found this product to be hazardous. The product should be reported under the following indicated EPA hazard categories: X Immediate (Acute) Health Hazard Delayed (Chronic) Health Hazard X Fire Hazard Sudden Release of Pressure Hazard Reactive Hazard Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals. The current thresholds are:'500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely hazardous substances and 10,000 pounds for all other hazardous chemicals. SECTION 313 -LIST OF TOXIC CHEMICALS (40 CFR 372): This product does not contain substances on the List of Toxic Chemicals. TOXIC SUBSTANCES CONTROL ACT (TSCA): This product is exempted under TSCA and regulated under FIFRA. The inerts are on the Inventory List.FEDERAL INSECTICIDE, FUNGICIDE AND RODENTICIDE ACT (FIFRA): EPA Reg. No. 6836-203-1706 In all cases follow instructions on the product label.FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.15 / formerly Sec. 307,40 CFR 116.4l formerly Sec. 311 : Substances listed under this regulation are not intentionally added or expected to be present in this product.CLEAN AIR ACT, Sec. 112 (40 CFR 61, Hazardous Air Pollutants), Sec. 602 (40 CFR 82, Class I and II Ozone Depleting Substances): Substances listed under this regulation are not intentionally added or expected to be present in this product.CALIFORNIA PROPOSITION 65: Substances listed under California Proposition 65 are not intentionally added or expected to be present in this product.0 For additional copies of an MSDS visit www.nalco.com and request access 8/10 AWNALCO SAFETY DATA SHEET PRODUCT H-130M EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC MICHIGAN CRITICAL MATERIALS: Substances listed under this regulation are not intentionally added or expected to be present in this product.STATE RIGHT TO KNOW LAWS: This product is a registered biocide and is exempt from State Right to Know Labelling Laws.NATIONAL REGULATIONS, CANADA: WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM (WHMIS): This product has been classified in accordance with the hazard criteria of the Controlled Products Regulations (CPR)and the MSDS contains all the information required by the CPR.WHMIS CLASSIFICATION: Pesticide controlled products are not regulated under WHM IS.CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA): Substances regulated under the Pest Control Products Act are exempt from CEPA New Substance Notification requirements. AUSTRALIA.All substances in this product comply with the National Industrial Chemicals Notification & Assessment Scheme (NICNAS).CHINA All substances in this product comply with the Provisions on the Environmental Administration of New Chemical Substances and are listed on the Inventory of Existing Chemical Substances China (IECSC).EUROPE The substance(s) in this preparation are included in or exempted from the EINECS or ELINCS inventories JAPAN All substances in this product comply with the Law Regulating the Manufacture and Importation Of Chemical Substances and are listed on the Existing and New Chemical Substances list (ENCS).KOREA All substances in this product comply with the Toxic Chemical Control Law (TCCL) and are listed on the Existing Chemicals List (ECL)PHILIPPINES All substances in this product comply with the Republic Act 6969 (RA 6969) and are listed on the Philippines Inventory of Chemicals & Chemical Substances (PICCS).16. OTHER INFORMATION This product material safety data sheet provides health and safety information. The product is to be used in applications consistent with our product literature. Individuals handling this product should be informed of the.recommended safety precautions and should have access to this information. For any other uses, exposures should Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 9110 SAFETY DATA SHEET AW NALCOPRODUCT EMERGENCY TELEPHONE NUMBER(S)(800) 424-9300 (24 Hours) CHEMTREC be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace operations. Please consult your local sales representative for any further information. REFERENCES Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American Conference of Governmental Industrial Hygienists, OH., (Ariel Insight CD-ROM Version), Ariel Research Corp., Bethesda, MD.Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPS CD-ROM Version), Micromedex, Inc., Englewood, CO.IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health Organization, International Agency for Research on Cancer.Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPS CD-ROM Version), Micromedex, Inc., Englewood, CO.Annual Report on Carcinogens. National Toxicology Program, U.S. Department of Health and Human Services, Public Health Service.Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration (OSHA), (Ariel Insight CD-ROM Version), Ariel Research Corp., Bethesda, MD.Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati, OH, (TOMES CPS CD-ROM Version), Micromedex, Inc., Englewood, CO.Ariel Insight (An integrated guide to industrial chemicals covered under major regulatory and advisory programs), North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel Insight CD-ROM Version), Ariel Research Corp., Bethesda, MD.The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPS CD-ROM Version), Micromedex, Inc., Englewood, CO.Prepared By: Product Safety Department Date issued: 04120/2009 Version Number: 1.6 Nalco Company 1601 W. Diehl Road -Naperville, Illinois 60563-1198 -(630)305-1000 For additional copies of an MSDS visit www.nalco.com and request access 10/10 Material Safety Data Sheet May be used to comply with OSHA'S Hazard Communication Standard 29 sCFR 1910, 1200. Standard Must be consulted for SneCifiC reauirements. U.S, Department of Labor Occupational Safety and Health Administration (Non-Mandatory Form)Form Approved OMB No. 1218-0072 consulted .. ......r i ............. 0EN`TIY(A on andL) INota: Blank spaces ame not penmitld. I any kem is nct Ww isabn B-2206 Bromide Tablets aval , b e space mu ie moft t Wica that Section I mautacnre'w "no VariChem International, Inc. Ern nTaleplne Nuwrbei 1-800-424-9300 Address (Nunber, Street. City, State, and Zip Code ) .Tlephono Number fo I'oMi"' 1-979-245-7278 P.O. Box 528/ Hwy 35 West IDaisUpdated May6, 2009 Van Vleck, TX 77482 signatureat Preparer (optiona,) Section II -Hazardous Ingredients I Identity Information Hazardous CvnwponeM (I5pecd Cramcal klertty. Carmon Narme( s) OSH-A PEL ACGIH TLV Other Units % (Optional) Bromochloro-5.5-dimethy4hydantoin A biocide used to control bacteria, algae, yeast and fungi in industrial water systems.D.O.T.= Oxidizing Solid. N.O.S..5.1 .UN 1479,PGII(Contains Halogen)Section III -Physical I Chemical Characteristics lorng Panl NA Specific Gravity (H20 -1) 1.8-2.0 Vapor Pressre (-r HI) 25 n PNtt I25*CC N/A Vapor Denity (Aký,) N/A Evaporati Rate (Butyl)Acate 1)Soluklty In Water 25C:Benzefe:2.5 gil0Og Aptearance and Odor White to Off Whfe. Tablet Faint halogen odor Section IV -Fire and Explosion Hazard Data Flasht PokE (Me~tod Used) NONE 77mmbl Limits NO LEL WA ULNI~t A Extiiguiushh Medla DRY POWDER, CARBON DIOXIDE. OR WATER SPRAY Special Fire F19Wn Procedwas USE WATER SPRAY TO COOL CONTAINERS EXP)OSED TO FIRE. DO NOT BREATHE FUM&S.Contain Run Off.Unusual Fire and Efp;bsk;n Hazanls OXIDIZING MATERIALS. WHEN HEATED TO DECOMPOSITION, MAY RELEASE POISONOUS AND CorrohSe fumes, of bromide, ri&gen oxi:le. and hydrogen chloride. Strong zxivng agent.Forms explosive mixtures with combustible, organic or other easily oxidizable materials.(Reproduce Locally) OSHA 174. Sept. 19a5 Section V -Reactivity Data Stabilit LftIICondlfonsloAvvdW TEMPERATURES ABOVE 1Rn'Bc.2O*F X IStable under normal conditions of storage,shipment and/or use.Incoe'0tbflty (Malimis to Avoid) OXIDIZING AGENTS. COMBUSTIBLE ORGANIC MATERIALS. BASES Hazazdmoi DecormPl5tion or Byproducts ROGEN BROMIDE. BROMINE GAS, AND HYDROGEN CHLORIDE HaZIMayOcur ICaoInma to AvWd Section VI -Health Hazard Data Route(s) d Erdy Eyes? Inhrlhon? x Skn Ingerton?Health Hamds (AAutO and Chmrpr) INHALATION LCSO -0.53MG/I A HOUR(RAT) ORAL LD0-I 500 MUACO (RAT)OIERMAL LE50 Car-gewiiy-NO NIP? NO LARC MonogrAoti NO OSHA Regulated? YES Not known to be carcinogenic. Not included in NTP 8th Annual Report on Carcinogens.Not classified by LARC Slats ian SryparisY* r E~xpowu SEVERE EYE IRRIrATION. SKIN CONTACT CAUSES BURNS. SEVERE IRRITANT TO UPPER RESPIRATORY Tract, nose. throat and lungs. Can cause shortness or breath, headache and nausea.Emergeny and irs? Aid Pmceds* yes HOtLD THE EYELIDS APART,FLUSH IMMEDIATELY WITH LARGE AMOUNTS OF WATER FOR AT LEAST 15 MINULTES. SKIN: REMOVE CONrAMINATED CLOTHING & WASH AFFECTED SKIN WITH MILD SOAP & WATER AT LEAST 15 MINUTES.4 I If swallowed.wash mouth thoroughly with water and drink 2 glasses of water.(Never give an unconclous person anything to drink)Dust Inhalation or Brething Fumes:Remove person to fresh aire, keep quiet and warm.IN ALL CASES SEEK MEDICAL ATTENTION IMMEDIATELY! Section VII -Precautions for Safe Handling and Use Steps Io Be Tuken In 5"a Maleinwl ii Releand or Spiled EVACUATE THE SPILL AREA. KEEP DUST TO A MINIMUM .TRANSFER SPILLED Material to suitable containers for recovery of disposal. Ventilate area and wash spill sites after material pickup Is complete CAUTION: Keep spills and cleaning runoff out of municipal sewers &open bodyof waters.Waste Disposa Method DISPOSE OF IN APPROVED LANDFILL SITE OR AN APPROVED INCINERATOR. CRUSH AND BURY EMPTY CON-tainels. Avoid access to streams,lakes or ponds.Observe all federalstate and local environmental regulations. Preca*iom to a6 Taken i, Handing aid Sorig MA.TERIAl IS POSSIBLE SKIN SENSITIZEr. AVOID SKIN CONTACT. PVC GLOVES SHOULD BE Worn when using this substance. They should.be replaced.immediately if there is any chemical on them.Dow Pmca,,sti UPON REMOVAL OF GLOVES, CLOTHING OR SHOES. WASH THOROUGHLY WITH SOAP AND WATER.Section VIII -Control Measures respiratory Protattian (Spe, fy Type) WEAR MSHAINIOSH APPROVED FULL-FACEPIECE AIR PURIFYING RESPIRATOR. EQUIP WITH CHEMICAL CARTRIDGXE FOR PROTECTION AGAINST HALOGEN GASES AND DUST/MIST. Veribjlation Local Exhaust: USE (ESPECIALLY UNDER DUJST CONDITIONS) Spca Pn01ect.ve Gks WEAR CHEMICALLY RESISTANT GLOVES Eye Protectior: USE SAFETY GLASSES (ANSI28.7.IOR APPROVED EOUIVALENT) WEAR CHEMICAL SAFETY GOGGLES IF AIRBORNE PARTICLES ARE PRESENT.0 PrIedIVe Cldnoug Equipment USE CHEMICAL RESISTANT BODY COVERING CLOTHES TO AVOID PROLONGFED SKIN CONTACT Woro-iMienk Prmcte SAFE'Y SHOWER AND EYE BATH SHOULD BE PROVIDED.I IDO NOT EATDRINK OR SMOKE UNTIL SHOWERING AND CHANGING CLOTHES I I Material Safety Data Sheet May be used to comply with OSHA'S Hazard Communication Standard 29 sCFR 1910, 1200. Standard Must be consulted for specific requirements. B-2207 Microbiocide Section I U.S. Department of Labor Occupational Safety and Health Administration (Non-Mandatory Form)Form Approved OMB No. 1218-0072 Nm:Blnk spaces am~ not pamifntad. lf mwluhm is notap pkcabl. or no .ini mn Is lavabbse. the space mur m b6naded to kIdicata that.Section II -Hazardous Ingredients I Identity Information -=Plftus CPonMnM (Speaoh ChýSC kWn5t. COMMon NSme(5)) OSHA PEL ACGIH TLV Other Lontt % (OPOa)Gluteratdehyda (CAS# 111-30-8) 25%DOT: Corrosive Liquid, N.O.S.; 8; UN 3265; PGII; (Contains Gluteraldehyde) HMIS: H-2, F-2, R-0 Section III -Physical I Chemical Characteristics AWC Oand O Transparent Colorless, Odor is sharp-medicinal. Section IV -Fire and Explosion Hazard Data Flash Powd Aewdusa) None I oFfobint LIMmls N/A ILF" N/A JuEL N/A* m Dry Chemical, Carbon Dioxide, or Alcohol type Foam.s3PS P~e RFhl'xi du- Not Available ursusw Fft ow Expiosm Hm None Known))~e6Dth L~iB~y LspA,~s~apLisa (RepnW-= L-ecay)OSHA 174. Sept. 1985 Section V -Reactivity Data Stao U strene CIins to Avod Inci ubItyt goAvoid Sftrn Alkalies and evaporation of water, strong acids.Kazzrdoua Dec I p iuo or Bypoducts Huandun may O~u ... C:xotios to Avoid Po~nrizzto X Temperatures above 100OC Section Vl -Health Hazard Data R W &(s) d n In h c= n? Y sS kin ? Y e sin e ston ? e Hefh H"Az Aa c,=k)DANGER: Corrosive, causes irreversible eye damage, Causes skin bums. Harmful if inhaled, may be fatal if swallowed, Aspiration may cause lung damage.CaWdnoSey. NnP None 'AR"-ýna None OS"A 0 edeUnknown s0- an.d syptair e Fum May cause skin sensitization. May cause asthma. Repeated skin contact may cause a cumulative dermatitis. =- bft Wers Skin allergies and pre-existing asthmatic conditions. Emrwnencry I' wId IA , I Inhalation: Remove to fresh air, obtain medical attention. Eyes: Immediately flush eyes with water and obtain medical attention of ophthalmologist. Skin: Wash with soap and water. Swallowing: DO NOT Induce vomiting., Do Not give anything to drink. Obtain medical attention without delay.Section Vil -Precautions for Safe Handling and Use Smps tBe ~atRelw a orSpfi Very low levels can be biodegraded in a waste water system (5ppm).Flush small spills can be flushed with large quantities of water. Collect large spills on absorbent and dispose of according to Federal, State, and Local regulations. W"aO"P"'Me=x Atomize into hot incinerator fire or mix with suitable solvent and Incinerate. Dispose in accordance with appropriate Federal. State, and Local regulations. Pmf6 Be Taken i HadI and Storing Wear protective clothing (Nitnle NBR) monogoggles and Butyl gloves.Work in well ventilated area.Oth.w~W'o Wash all equipment and protective clothing If contacted. Section VIII -Control:Measures R= ra n contained breathing apparatus MSHAINIOSH air purifying respirator. Vetw honf 1 Locaj Exwi aSsI r6` 1 (0-"en Room Ventilation OK oza Proecie Gw Butyl I Proetn Monogoggles Oher Pro1a cmkv Equ-prm Nitrile (NBR) Chemical Apron, Eye bath, Safety Shower, Rubber Boots.wmMu-ni Prmdces Good housekeeping acceptable industrial engineering practices. 0 Material Safety Data Sheet May be used to comply with OSHA'S Hazard Communication Standard 29 sCFR 1910, 1200. Standard Must be consulted for specific requirements. -=.)TV tAV 14d On Laft WM LWQt SC-2312 Scale & Corrosion Inhibitor Section I U.S. Department of Labor Occupational Safety and Health Administration (Non-Mandatory Form)Form Approved OMB No. 1218-0072 BN:olbtk apaCaaa not parmded. I aIty Item is not applicabl, or no ibmallon i avaieable. Ue space Trust be marked to Irtclcate fatt Section II -Hazardous Ingredients I Identity Information HaNzMrim CMone;;,Mrm (,Spant CJoanical Ger~r. conw Na Peri)) OSHA PEL ACGIH TLV Otrer urrm. % (Optlona') Recmrrmood None This product contains no hazardous components under current OSHA definitions. DOT: Not Regulated 0*" This product does not contain any SARA Section 313 listed Chemicals Section III -Physical I Chemical CharacteristicsPoi' 212OF Spscic Gravity (H20 =1)Vapor Prosaure (rnm HI.) 16.6 M-n Poin Vapor DOmi (Aikl) 0.6 Evaipolren Rate (51t4 Acetrts a 1)1.032 N/A N/A Solubeiy In Water Complete Appearance ar o=,r Dark brown liquid with no distinct odor.Section IV -Fire and Explosion Hazard Data" Above 200OF (PMCC) % TL NIDA UEL N/DA Extiushia Moda Water spray Spaeca FkehtN P,_, , Do not enter any enclosed fire space without proper protective equipment. URnusW Fire and Exploslon Hazards None (Repraud-LoalyýOSHA 174, Sept. 1985 Section V -Reactivity Data s___y uab_'" Co_ _lioj AvoMd X INone~ eioAv) Strong acids, strong oxidizing agents.iziwo necoanWaio o r- , Incomplete combustion may result in oxides of Phosphorus, Sulfur, & Nitrogen.iazoous OCan:itins to Avoid Poiymatiation NI O0, 1 I X None Section VI -Health Hazard Data R.;*e.() of EDuy. Inhalation? Yes Sk? Yes Ingesfion7 Yes HeaiUHamf (A=Ac w Cn") This material may cause minor irritation upon contact with the eyes.cannowi. N- No L Monographs No OSRA R te? No saS- "rd s This material may cause minor irritation upon contact with the eyes. This material is not expected to present a skin contact hazard.Madica Con~tioms Awwvated by E.xmum None E-9*nq Aw,, =- Eyes: Flush with water for 15 min. Seek medical attention if irritation persist.Skin: Wash with soap & water. Ingestion: Seek medical attention. Section VII -Precautions for Safe Handling and Use Stgo t Ta i.m Mael iwd or s1a Eliminate all open flames in the vicinity of the spill or released vapor. Contain by diking with a Non-Combustible absorbent and dispose of in a DOT approved container. wa-m 'wt' 'od Flush with water. Absorb large spills with an absorbent, and dispose of in a DOT approved l I container. Pnxeaian to B. Taken P Hancig and Stnn Keep outof reach of Children. Avoid splashing in your eyes.00hW PmcauiW I None Section VIII -Control Measures ReapI-yP' in(Sflec TvPe) Not normally required.Ventiwlat I. Eau31 Sufficient iuwmrk r'urm None SpeaI None 00hW None Goggles, Safety Glasses I Pcfrv, Ob= Rubber Gloves IEye PtaFetion o""en 'c'neCr Not normally required.Eyewash should be available and ready for use.I I Material Safety Data Sheet May be used to comply with OSHA'S Hazard Communication Standard 29 sCFR 1910, 1200. Standard Must be consulted for specific requirements. U.S. Department of Labor Occupational Safety and Health Administration (Non-Mandatory Form)Form Approved OMB No. 1218-0072 I D rT f M, U B M Lt a b o a M L i s t) N o t e : E ll a n k s p a me a r e n o p v --lt e O If n y sm is o t Pa k ~ bl e o cr n o r = n is SC-2316 Scale & Corrosion Inhibitor ,a=. mu ont Section I Ma`caro"'"Nam" VariChem International, Inc. eTphone Number 1-800-424-9300 Addmsr (Number. Stree. City. State, and Zip Code) iNumber for I 1-979-245-7278 P.O. Box 528 / Hwy 35 West Dam P Jeae January 1,2006 Van Vleck, TX 77412 s"uo Preparer (oplional) Section II -Hazardous Ingredients / Identity Information Hawroous Conpwaft l(Soaoc Chenwi blentityr Conrer Namnes)) OSHA PEL ACGIH TLV Oter Limris % (Ophionai) Reconmrrvded None This product contains no hazardous components under current OSHA definitions. DOT: Not Requlated HMIS: H-1. F-0. R-0 This product does not contain any SARA Section 313 listed Chemicals Section III -Physical I Chemical Characteristics Boilig Pce 212oF SpectlcGravity(H20-1) 1.01 Vapor Pressure (mm ) 16.6 " ' NIA Vapor Deanay (Ak i) 0.6 vaporation Rate 4uM Aetato -1) NIA solI% "I w'.Val Complete A"--- ' o"' Light to Dark brown liquid with no distinct odor.Section IV -Fire and Explosion Hazard Data FkhPoint jMetnod Usd) Abv 0O PC)FmttLimits LeL N/DA juLNIDA Eaish Ik&,di Water spray Special Fr-e Fhtrocur Do not enter any enclosed fire space without proper protective equipment. Unumia For and Explosoio Hazards None (Ftepmouce L.cay) OSHA 174. 500t, I YM I ii Section V -Reactivity Data US Cer, r= to Awod rta" IX INone ira~1toy M Av Strong acids, strong oxidizing agents." """ op' Incomplete combustion may result in oxides of Phosphorus, Sulfur, & Nitrogen. to Aydd ra ý O~x X INone Section VI -Health Hazard Datadf Ern. Yes swn? Yes Mg=stn? Yes Hea=m Hads (e a CI~r~r) This material may cause minor Irritation upon contact with the eyes.4 I CtoQckfnt: No ARC M rrapm No OSH Re NoSw¶P syTon' Eosa This material may cause minor irritation upon contact with the eyes. This material is not expected to present a skin contact hazard.A OZExoosu .None Emincy xWd F d ow Eyes: Flush with water for 15 min. Seek medical attention if irritation persist.Skin: Wash with soap & water. Ingestion: Seek medical attention. Section VII -Precautions for Safe Handling and Use Sups to Be T,*.m tf C= Mmaw i Eliminate all open flames in the vicinity of the spill or released vapor. Contain by diking with a Non-Combustible absorbent and dispose of in a DOT approved container. w"v ..eM.. Flush with water. Absorb large spills with an absorbent, and dispose of in a DOT approved container. Precauorm to Be Taluan U= am sto~rr Keep out of reach of Children. Avoid splashing in your eyes.Keep container dosed when not in use.00W Pr~autio 4 None Section Viii -Control Measures R--P9ed' f (SpedryTYPO) Not normally required.Venlimnm Locat J1St Sufficient mem"'cw (Gen0ral` None Sp-l" None 09tW None RubberGloves " Goggles, Safety Glasses otw P,,1U cuhU1Eq*npmer. Not normally required.Woulclpran Wash hands after use. An eyewash should be available and ready for use. South Texas Project UNITED STATES / "'YBLESSING SE QUADRANGLE DEPAKITIENT OF THE INTIERIOR 7Pe ow ZSACGORD O GEOLCQC 'V 7.5 Ain 'V-WAV A--W U Z' ' V.. ..-----A7;.......... , ---A A -L ~..GV 0'V~mAAA.,~.U AALAFAA " ~ Tr ,-illw 0 -A ou.AAL Os-u lA*~TCA~a.RG.L.Vtt. .........GAL~ L V~AAALAA~A~VA~AALAAGAALAL LESSNOSE-WA., U Z'S~" GAAL71 3AL .q Lj 7 AAVALAL ALLLALA UAA A A -t'VAAAAA UAA -A'VAA~ AAALAVA A AAAAA SAG-AL 4/3 -r 7T~DES. c~t~C6 0b 0 MA TA G0RDA AB A Y'* ~ A, PtOOAdby lb. 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