ML23103A448
| ML23103A448 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/13/2023 |
| From: | Morgan J South Texas |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NOC-AE-23003952 | |
| Download: ML23103A448 (1) | |
Text
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Nuclear Operating Company South Texas Project Electric Generating Station P.O Box 289 Wadsworth. Texas 77483 ------------VVV'v-April 13, 2023 NOC-AE-23003952 10 CFR 50.36b STI: 35454866 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. 50-498; 50-499 South Texas Project Electric Generating Station 2022 Annual Environmental Operating Report Pursuant to the South Texas Project Environmental Protection Plan (Non-radiological) and Technical Specification 6.9.1 .3, the STP Nuclear Operating Company provides the attached South Texas Project Electric Generating Station 2022 Annual Environmental Operating Report.
There are no commitments in this letter.
If there are any questions about this report, please contact Zachary Dibbern at (361) 972-4336 or me at (361) 972-4045.
~ ah~
Manager, Health Physics
Attachment:
South Texas Project Electric Generating Station 2022 Annual Environmental Operating Report cc:
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 76011-4511
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION 2022 ANNUAL ENVIRONMENTAL OPERATING REPORT 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
TABLE OF C O N T E N T S CHAPTER ONE CHAPTER TWO FIGURES Figure 2-1: Plant Water Systems. . . . 2-4 EXECUTIVE SITE AND AREA Figure 4-1: 2022 Non-radioactive
SUMMARY
. . . . . . . . . . . . . 1-1 DESCRIPTION. . . . . . . . . . . 2-1 Waste Management . . . . . . . . . 4-9 Figure 4-2: 2022 Non-radioactive Waste Generation . . . . . . . . . 4-9 Figure 4-3: Hazardous Waste Shipped Historical Comparison . . . . . 4-9 Figure 6-1: Radiological Environmental Monitoring Program Designated Sample Location Map. . . . . . . . . . . 6-3 Figure 6-2: Radiological Environmental Monitoring Program Onsite Sample Location Map . . . . . . . . . . . 6-4 CHAPTER THREE CHAPTER FOUR Figure 6-3: Radiological Environmental Monitoring Program Zone Location Map . 6-5 NON-RADIOLOGICAL NON-RADIOLOGICAL Figure 6-4: Historical Comparison of ENVIRONMENTAL ENVIRONMENTAL Average Quarterly Beta Activity from Indicator and Control Air Samples . . . . 6-6 INTRODUCTION AND INTRODUCTION AND
SUMMARY
. . . . . . . . . . . . . 4-1 Figure 6-5: Environmental
SUMMARY
. . . . . . . . . . . . . 3-1 Dosimeter Comparisons . . . . . . . 6-7 Environmental Conditions . . . . . . . . . .4-2 Figure 6-6: Historical Comparison Aquatic and Ecological Monitoring. . . . .4-2 of Cobalt-60 in Main Cooling Reservoir Sediment. . . . . . . . . 6-7 Water Quality Management . . . . . . . . .4-3 Figure 6-7: Calculated Cumulative Curies of Air Quality Management . . . . . . . . . . .4-7 Cobalt-60 in the Main Cooling Reservoir . 6-7 Non-radioactive Waste Management . . . 4-8 Figure 6-8: Historical Comparison of Chemical Control and Management. . . 4-10 Tritium Added to and Remaining in Environmental Protection Plan Status. . 4-11 the Main Cooling Reservoir. . . . . . 6-9 Figure 6-9: Historical Comparison of Tritium Activity in Reservoir Relief Wells. . 6-9 Figure 6-10: Historical Comparison of Tritium Activity in Surface Water . . . . 6-11 Figure 6-11: Historical Comparison of Tritium CHAPTER FIVE CHAPTER SIX Activity in Shallow Aquifer Ground Water . 6-11 Figure 6-12: Tritium Activity in Shallow Ground RADIOLOGICAL RADIOLOGICAL Water West of the Main Cooling Reservoir. 6-13 ENVIRONMENTAL ENVIRONMENTAL Figure 6-13: STP Protected Area Ground INTRODUCTION AND OPERATING Water Monitoring Wells Results . . . . 6-15
SUMMARY
. . . . . . . . . . . . . 5-1 REPORT . . . . . . . . . . . . . . 6-1 Figure 6-14: STP Protected Area Ground Water Monitoring Wells. . . . 6-15 Program Description . . . . . . . . . . . . . 6-2 Figure 6-15: 2022 Radiological Laboratory Airborne Pathway . . . . . . . . . . . . . . 6-6 Quality Assurance Program Performance . 6-17 Direct Exposure Pathway. . . . . . . . . . 6-6 Figure 6-16: Duplicate & Split Agreement of Environmental Samples in 2022 . . . 6-17 Sediment Samples. . . . . . . . . . . . . . 6-8 Waterborne Pathway. . . . . . . . . . . . 6-10 NEI Groundwater Protection Initiative. . 6-15 TABLES Land Use Census. . . . . . . . . . . . . . . 6-16 Table 1: Radiological Environmental Monitoring Program . . . . . . 6-19 to 6-21 Quality Assurance . . . . . . . . . . . . . . 6-18 Table 2: Sample Media and Program Deviations . . . . . . . . . . . . . 6-18 Location Descriptions. . . . . 6-23 to 6-27 Radiological Environmental Monitoring Table 3: 2022 Radiological Program Analysis Summary . . . . . . . .6-29 Environmental Monitoring Program Analysis Summary . . . . . . 6-30 to 6-38 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION 2022 ANNUAL ENVIRONMENTAL OPERATING REPORT The 2022 Annual Environmental Operating Report for the South Texas Project Electric Generating Station combines in one report the requirements for the Annual Environmental Operating Report (Non-radiological) found in Appendix B to the renewed Facility Operating License No. NPF-76 and No. NPF-80 and the requirements for the Annual Radiological Environmental Operating Report found in Part A of the stations Offsite Dose Calculation Manual.
Authored by: Authored by:
Laura Stoicescu, CHP Kenneth M. Cunningham Consulting Health Physicist, Health Physics Division Environmental Supervisor, Regulatory Affairs Technical Review: Approved by:
Edmond Hardcastle Jr. Jonah Morgan Staff Environmental Radiological Manager, Health Physics Division Services Specialist Health Physics Division Completed in accordance with Technical Specifications for United States Nuclear Regulatory Commission l Renewed License No. NPF-76 and No. NPF-80 l April 2023 Photo courtesy of Christie Dement 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT IN TRO l OV ERV IEW
STP l A N N UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT MESSAGE FROM THE PRESIDENT AND CEO For over thirty years, STP has produced safe, carbon-free, clean-air energy at our site in beautiful Matagorda County with great respect and admiration for the land, water and air we all share.
Matagorda County prides itself on the beauty and variety of the ecosystems and wildlife that thrive here. It harbors a unique convergence of those ecosystems, including secluded, extensive forests, waterways, riparian wetlands, an expansive prairie and 40 miles of beautiful, wild coastline. Its uniqueness as prime habitat for wildlife is evidenced by it being consistently named as the county with the greatest variety of migratory birds than in any other county in the United States. STP is committed to caring for the natural resources with which we have been entrusted. We want Matagorda County residents to know that STPs dedication to protecting the environment will not diminish, and it is our great privilege to operate on this land that we all call home. Transparency in our environmental operations is a key element to maintaining our trust and good relationship with our community. This report exemplifies our dedication to maintaining this open communication.
Thank you for allowing us to continue to be your trusted neighbor. We look forward to serving this community and being a steward of our environment for many years to come.
Tim Powell President and CEO STP Nuclear Operating Company 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT MES SAGE l F ROM THE PRESIDEN T AN D C EO
EXECUTIVE
SUMMARY
1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
CHAPT ER O N E The South Texas Project Electric This report describes the environmental Generating Station (South Texas monitoring programs, non-radiological Project) continues to operate with no and radiological, conducted at adverse effect on the population or the South Texas Project during the environment. The dose equivalent 2022. Included in this report are for people living in the area remains the Environmental Protection Plan at less than one millirem per year.
Status, the results of the Radiological Environmental programs at the site monitor known and predictable Environmental Monitoring Program, and relationships between the operation the Land Use Census.
of the South Texas Project and the Photo courtesy of Gary Parkey Non-radiological environmental surrounding area. These monitoring monitoring is performed each Texas Project continued to provide programs verify that the operation of year as part of the stations overall high-quality habitat areas for a variety the South Texas Project has no impact Environmental Protection Plan which of flora and fauna and continued to offsite and is well below state and federal regulations and guidelines. is intended to provide for protection have no indications of negative non-These programs are verified by the of non-radiological environmental radiological impacts to State of Texas through collection and parameters during station operations. local environmental conditions.
analysis of samples and placement of Non-radiological monitoring The environment within a 15-mile the States monitoring dosimeters and encompasses, as a minimum, water radius of the South Texas Project is other onsite and offsite inspections.
quality, air quality, waste generation routinely monitored for radiation and and minimization, and local aquatic radioactivity. Sampling locations are and terrestrial ecological conditions. In selected using weather, land use, and 2022, non-radiological monitoring by water use information. Two types of the station confirmed that the South sampling locations are used. The first Texas Projects efforts to respect and type, Control Stations, are located in protect local environmental conditions areas that are beyond the measurable were successful. The operation of South influence of the South Texas Project Photo courtesy of Gary Parkey 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER 0NE l EX EC UTIV E S UMMARY 1-2
or any other nuclear facility. The sample small changes in the environment.
results from these stations are used to The United States Nuclear Regulatory explain radiation from sources other Commission also has a required than the South Texas Project. Indicator reporting level. Licensed nuclear Stations are the second type of station. facilities must prepare a special report The samples from these stations and increase their sampling if any measure any radiation contributed to measured radiation level is equal to the environment that could be caused or greater than this reporting level.
by the South Texas Project. Indicator No sample from the South Texas Stations are located in areas close to Project has ever reached or exceeded the South Texas Project where any this reporting level. Measurements plant releases would be detected. performed are divided into four categories, or pathways, based upon Prior to initial operation of the South how the results may affect the public.
Texas Project, samples were collected Airborne, waterborne, ingestion, and and analyzed to determine the amount direct radiation are the four pathways of radioactivity present in the area.
that are sampled. Each pathway is These results are used as a pre-described on page 1-4.
operational baseline. Results from the Indicator Stations are compared The South Texas Project continues to both current control sample results to operate with no adverse effect on and the pre-operational baseline the population or the environment.
values to determine if changes in The dose equivalent for people living radioactivity levels are attributable to in the area is maintained at less than station operations or other causes such one millirem per year. Environmental as previous nuclear weapons testing programs at the site monitor known programs and natural variations. and predictable relationships between the operation of the South Texas Radioactivity levels in the South Texas Project and the surrounding area.
Projects environment frequently These monitoring programs verify fall below the minimum detection that the operation of the South Texas Photos courtesy of 1. Greg McMullin, 2. & 3. Drew Richards capabilities of state-of-the-art scientific Project has no impact offsite and is well instruments. Samples with radiation within state and federal regulations and levels that cannot be detected are guidelines. These programs are verified below the Lower Limits of Detection.
by United States Nuclear Regulatory The United States Nuclear Regulatory Commission inspections and the Commission requires that equipment State of Texas through collection and used for radiological monitoring must analysis of samples and state radiation be able to detect specified minimum monitoring dosimeters.
limits for certain types of samples. This ensures that radiation measurements are sufficiently sensitive to detect 1-3 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
Each of the * The airborne pathway is sampled reporting limits and within United States Environmental in areas around the South Texas Protection Agency drinking water standards.
four pathways Project by measuring the levels Previously detected plant-related nuclides, such as
of radioactive iodine and particulate radioactivity cobalt-60 and cesium-137, were detected in the reservoir on air filters. The 2022 airborne results were similar sediment at designated sample locations at very low to pre-operational levels detecting only naturally concentrations. Additional samples had detectable occurring radioactive material unrelated to the cesium-137 which is normally present in the environment operation of the South Texas Project. and is consistent with pre-operational concentrations.
- The waterborne pathway includes samples taken Onsite sediment samples continue to occasionally indicate from surface water, groundwater, and drinking traces of plant-related nuclides such as cobalt-60. Offsite water. Also included in this pathway are sediment sediment samples continue to show no radioactivity from samples taken from the Main Cooling Reservoir and the South Texas Project. In summary, the station produced the Colorado River. Tritium was the only man-made no detectable waterborne effects offsite.
nuclide consistently detected in water samples * The ingestion pathway includes broadleaf vegetation, and was measured in the shallow aquifer, the Main agricultural products, and food products. Naturally Cooling Reservoir, ditches, and sloughs consistent occurring nuclides were detected at average with the South Texas Project Main Cooling Reservoir environmental levels in the samples. The data indicated operating design. The levels of Tritium found were there were no man-made nuclides detected in these types near or lower than the concentration of Tritium in the of samples.
Main Cooling Reservoir. Additional onsite wells have
- The direct exposure pathway measures environmental been sampled to map Tritium migration. The average radiation doses using thermoluminescent dosimeters.
Tritium level in the Main Cooling Reservoir remained These results are consistent with the readings from stable throughout 2022. Tritium levels remain well previous years and pre-operational measurements below United States Nuclear Regulatory Commission indicating no effect from South Texas Project operations.
Photo courtesy of Christie Dement 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER 0NE l EXEC UTIV E S UMMARY 1- 4
SITE AND AREA DESCRIPTION 2-1 STP l A N N UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT
CHAPT ER T W O The South Texas Project is located on The South Texas Project has two 12,220 acres in Matagorda County, Westinghouse pressurized water Texas, approximately 15 miles reactors. The rated core thermal power southwest of Bay City along the west of each unit is 3,853 megawatts-bank of the Colorado River. The South thermal (MWt). Each unit was originally Texas Project is owned by NRG South designed for a net electrical power Texas LP, City of Austin, and City output of 1,250 megawatts-electric Public Service Board of San Antonio (MWe). Unit 1 received a low-power as tenants in common. Houston testing license on August 21, 1987, Lighting & Power Company was the original project manager of the South achieved initial criticality on March 8, Texas Project and was responsible 1988, and was declared commercially for the engineering, design, licensing, operational on August 25, 1988. Unit 2 construction, startup, and initial received a low-power testing license commercial operation of the two-unit on December 16, 1988, achieved initial facility. In 1997, the STP Nuclear criticality on March 12, 1989, and was Operating Company assumed declared commercially operational on operational control of the South June 19, 1989. On September 28, 2017, Texas Project and responsibility the United States Nuclear Regulatory for implementation of associated Commission approved the South environmental programs.
Texas Projects request to extend the operating licenses an additional twenty years through 2047 and 2048.
The combined units currently produce enough electricity to serve more than two million homes and businesses throughout Texas. With approximately 1,000 baseline employees, the STP Nuclear Operating Company is the largest employer and source of revenue for Matagorda County. Nuclear energy Photos courtesy of Greg McMullin continues to provide long-term long-term energy future, nuclear energy cost stability and promote energy will continue to play an important role independence. It is our nations largest as a safe and reliable supply of clean source of carbon-free energy. As we baseload electricity.
work collectively to secure our states HOW THE SOUTH TEXAS PROJECT WORKS Fossil-fueled and nuclear-powered fissioning or splitting of uranium atoms into assemblies that make up the core steam generating plants operate on the inside the reactor produces the heat. of the reactor. The use of uranium same principle. Fuel is used to produce allows us to conserve natural gas, oil, The fuel for a nuclear reactor is heat to convert water into high-pressure and coal and to avoid the associated uranium. It is formed into cylindrical steam. The steam is directed through production of greenhouse gases.
ceramic pellets, each about the size of a turbine to turn a generator. In a The fission process and generation the end of your little finger. One pellet fossil fuel plant, either coal, lignite, oil, of usable heat begins in a nuclear has the energy potential of about a or natural gas is burned in a boiler to reactor when control rods in the core ton of coal. Millions of these pellets are produce the heat. In a nuclear plant, are withdrawn. In pressurized water stacked in fuel rods that are arranged the reactor replaces the boiler and the reactors, like those at the South Texas 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER T WO l SITE AND AREA DES C RIPTION 2-2
Project, the fuel rods heat water structures, two more concrete walls circulating in sealed, stainless-steel provide another 11 feet of radiation piping that passes through large heat shielding. The reactor vessel itself has exchangers called steam generators. steel walls six inches thick, and the The water in the reactor is under pressure fuel pellets inside it are sheathed in to prevent boiling. This is why the South hardened metal tubes.
Texas Projects Units 1 and 2 reactors Nuclear energy has one of the lowest are called pressurized water reactors.
impacts on the environment. It is the This hot, pressurized water heats a most eco-efficient energy source separate supply of water in the steam because it produces the most electricity generators to produce steam that is in relation to its minimal environmental directed through the blades of a turbine impact. 1Nuclear power plants generate generator to produce electricity. The approximately 50 percent of the steam is then fed to a condenser where carbon-free electricity generated in the a separate supply of cooling water from United States. Additional information the Main Cooling Reservoir condenses on nuclear energy and the environment it back into water that is then pumped can be found on the website back to the steam generator for reuse. maintained by the Nuclear Energy A diagram of the plant water systems is Institute at www.nei.org.
shown in Figure 2-1. 1 Nuclear Energy Institute. Nuclear Energy In addition to its safety systems, the Fast Facts; October 2022. As viewed at www.nei.org/resources/fact-sheets/
South Texas Project has many built-in nuclear-fast-facts.
physical barriers designed to prevent the release of radioactive materials in the unlikely event of an accident. The most visible ones are the 200-foot tall, domed containment buildings with steel reinforced concrete walls four feet thick. Inside each of these massive Photos courtesy of 1. & 2. Greg McMullin, 3. Drew Richards THE PLANT SITE Sixty-five of the total 12,220 acres at and depressions. Much of the land surrounding the South Texas Project the South Texas Project are occupied east of the cooling reservoir is leased is characterized by coastal plain with by the two current power plants. for cattle grazing. Approximately 1,700 farmland and pasture predominating.
Plant facilities include a 7,000-acre acres remain in a more natural state as Local relief of the area is characterized main cooling reservoir and a 47-acre a lowland habitat. A 110-acre wetland by flat land, approximately 23 feet essential cooling pond. Many smaller habitat area was established in 1996 above sea level.
bodies of water onsite include wetlands, on previously unused land located Kelly Lake, drainage ditches, sloughs, northeast of the power plants. The area 2-3 ST P l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
THE AREA Matagorda Countys economy is based of migratory birds. The local estuary The climate of the region is subtropical primarily on ranching, farming, oil and environments provide the necessary maritime, with continental influence. It natural gas production and refinement, habitat for a variety of fish types to is characterized by short, mild winters petrochemical production, electricity complete their life cycles. The area also and long, hot, and humid summers.
generation, and commercial fishing affords opportunity for recreational Rainfall normally ranges from about and fisheries. The area within 10 hunting and fishing. two inches per month in February miles of the site is generally rural and peaking to about four to five inches per The South Texas Project is home to characterized as farmland, which is month in May, June, September, and many species of animals. Inhabitants primarily pastureland used for livestock October. The prevailing wind direction include American alligators, a variety ranching. Although the surrounding is from the south-southeast, shifting of birds, and several hundred deer. In area is heavily cultivated, significant to north-northeast for short intervals winter, literally hundreds of thousands amounts of woodlands, thicket, brush, during the winter months.
of waterfowl, principally migratory fields, marsh, and open water exist geese as well as white pelicans, have to support wildlife. The area lies in found that the plants 7,000-acre the southern region of the central cooling reservoir provides a good flyway and is host to an abundance resting place during their migrations.
PLANT WATER SYSTEMS Figure. 2-1 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER T WO l SITE AND AREA DES C RIPTION 2- 4
NON-RADIOLOGICAL ENVIRONMENTAL INTRODUCTION AND
SUMMARY
3-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
CHAPT ER T H R E E Non-radiological environmental The South Texas Project is committed conditions and performance at to the production of electricity in a safe, the South Texas Project during reliable, and economical manner using 2022 remained satisfactory and nuclear energy. The stations programs, demonstrated that the South Texas policies, and business plan objectives Project continued to operate in an also incorporate a commitment environmentally responsible manner to environmental protection and during the year. The South Texas management. The stations commitment Project achieved and maintained to sound environmental management in high standards of environmental performance and compliance 2022 is illustrated below.
throughout 2022. Everyone at the South Texas Project has a responsibility to protect the environment. Commitment to environmental safety is an integral component of the South Texas Project operating policy and core values. This responsibility reaches further than mere compliance with laws and regulations to encompass the integration of sound environmental practices into our daily operational and business decisions. The people at the South Texas Project understand the need to balance economic, operational, and environmental issues for the benefit of the station and the public.
We recognize our responsibility to hold ourselves to the highest principles of environmental stewardship.
Photos courtesy of 1. & 3. Greg McMullin, 2. Christie Dement The stations commitment to sound environmental management in 2022
- Satisfactory performance * Continued support of community * Continued emphasis on waste classification2 by the Texas activities such as the annual minimization and source Commission on Environmental Matagorda County Household reduction allowing the station Quality based on the stations Hazardous Waste Collection Day to maintain its classification as environmental compliance and hosting Science, Technology, a small quantity generator of record in all areas considered, Engineering and Mathematics industrial waste.
including water quality, waste (STEM) teachers for a summer management, and air quality workshop.
compliance.
Per Compliance History Report for CN601658669, RN102395654, Rating Year 2022; as prepared by the Texas Commission on Environmental 2
Quality.
1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER THREE l NON-R ADIOLO GICAL ENVIRONM ENTAL INTRODUCT ION AN D S UMMARY 3 -2
NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 4 -1 STP l A N N UA L E N VIR O NME NTAL O PE RATING RE PO RT
CHAPT ER F O U R E N V I R O N M E N TA L C O N D I T I O N S This section of the report describes the The Texas Commission on South Texas Projects non-radiological Environmental Quality rated the environmental program performance South Texas Project as a satisfactory and environmental conditions for performer in 2022 based on the 2022. The STP Nuclear Operating stations environmental compliance Company employees closely monitor record. Facilities, such as the South environmental conditions at the Texas Project, can be classified by the South Texas Project. NRG Energy, state as a high performer, satisfactory Inc. provides support and technical performer, or unsatisfactory performer assistance to the South Texas Project.
based on that facilitys compliance history. The states classification of the South Texas Project as a satisfactory performer was based on the stations environmental performance over the last five-year period.
During the period of this report, the station continued to promote green initiatives including the recycling of paper, plastics, and aluminum by site employees. The station also continued to support various bird counts and surveys in 2022 sponsored by federal and state agencies and volunteer organizations such as the annual National Audubon Society Christmas Bird Count and the United States Fish and Wildlife Services Colonial Waterbird Survey.
AQUATIC AND ECOLOGICAL MONITORING Photos courtesy of 1. Gary Parkey, 2. & 3. Greg McMullin The location of the South Texas Project falls within the Texas Land Resource 1996 on previously unused land located Area designation as coastal prairie northeast of the power plants. The and can be divided into two broad remaining area of the site offers diverse ecological areas bottomland and habitats for mammals and several upland areasbased on topography, types of birds. The South Texas Project soils, and vegetation. The bottomland regularly monitors the sites environs lowland habitat is a swampy, marshy for changing conditions. Ecological area that provides an important habitat conditions onsite in 2022 remained for birds and other wildlife and occupies generally unchanged and stable.
approximately 1,700 acres of the site near the Colorado River. An upland spoil The South Texas Project is located containment area, originally constructed on the state-sponsored Great Texas in 1972 by the United States Army Corps Coastal Birding Trail that spans of Engineers, is included in this area. In the entire Texas Gulf Coast from addition, a 110-acre wetland habitat area Brownsville to the Louisiana border.
that attracts a variety of bird groups Matagorda County, in which the South and other wildlife was established in Texas Project is located, consistently 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER FOUR l NON-R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 4-2
ranks at or near the top of the National regulations. These regulations govern Audubon Societys Annual Christmas virtually every aspect of business Bird Count for the number of species operations at the South Texas Project.
identified. Many bird species have been Water usage, wastewater treatment observed visiting the wetland habitat onsite and certain maintenance and and elsewhere onsite. These include repair activities are regulated under the bald eagle, white-faced ibis, and the Safe Drinking Water Act, the brown pelican. Additional migratory Federal Clean Water Act, and the Texas and resident bird species such as a Water Quality Act. Collectively, these variety of ducks, geese, turkey, and Acts provide for the safeguarding of pelicans (both brown and white) public drinking water supplies and have been observed during informal maintaining the integrity of state and surveys of the sites diverse natural federal waters. Regulating agencies and man-made habitats. Intensive that administer these requirements bird nesting continues throughout the include the United States Army lowland habitat, particularly in a heron Corps of Engineers, the United States rookery around the perimeter of Kelly Environmental Protection Agency, the Lake and on the internal dikes of the Texas Commission on Environmental Main Cooling Reservoir at the South Quality, the Texas General Land Office Texas Project. The South Texas Project the Lower Colorado River Authority, continues to provide vital habitat for and the Coastal Plains Groundwater more than an estimated 125 species of Conservation District.
wintering and resident birds.
The South Texas Project uses both The South Texas Project continues to surface water and groundwater for monitor important wildlife species to station purposes. Consistent with the detect population changes. Informal stations environmental principles observations continue to indicate that encouraging efficient water usage and the site provides high-quality habitat conservation, surface and groundwater in which a wide range of animals thrive. usage are carefully managed to The site continues to attract extensive conserve this important resource.
Photos courtesy of 1. & 3. Greg McMullin, 2. Kelly Callais wildlife populations, offering a refuge Groundwater is pumped from deep for resident species as well as seasonal aquifer wells to provide onsite drinking migrants. The lowland habitat located water for station personnel, to replenish between the Colorado River and the the Essential Cooling Pond, and for east bank of the Main Cooling Reservoir other industrial purposes onsite. Water offers a significant source of water year- from the Main Cooling Reservoir and round. These natural resource areas, the Essential Cooling Pond is used in concert with numerous additional as cooling water for plant operations.
wetland and grassland areas, offer the Water from the Colorado River key ingredients necessary to sustain replenishes the Main Cooling Reservoir the extensive wildlife population at the via intermittent diversion periods.
South Texas Project. Surface water diverted to the Main WATER QUALITY MANAGEMENT Cooling Reservoir from the Colorado Water is an essential component in River accounted for approximately electricity production, and electric 90% of the water used at the South utilities must comply with extensive Texas Project in 2022. Information federal, state, and local water regarding water use in Texas can be found on the website maintained by 4 -3 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
the Texas Water Development Board feet of water. Various water rights 1,080 acre-feet of the water used by at www.twdb.texas.gov. permits, contractual agreements, and the station was withdrawn from onsite compliance documents authorize groundwater sources in 2022.
Most of the water used by the South the South Texas Project to maintain Texas Project is needed to condense Existing federal and state water quality these reservoirs, impound water steam and provide cooling for plant standards are implemented and enforced diverted from the Colorado River, generating systems. The majority of through the Texas Pollutant Discharge and to circulate, divert, and use water this water is drawn from and returned Elimination System (TPDES) permit from the reservoirs for industrial to the stations Main Cooling Reservoir. program to restore and maintain the purposes to operate the plant. These The Main Cooling Reservoir is a 7,000- states waters. Under this permit program, authorizations also limit the amount acre, above grade, off-channel reservoir the South Texas Project monitors, and rate of diversion from the capable of impounding 202,600 records, and reports the types and Colorado River to protect downstream acre-feet of water at its maximum quantities of pollutants from wastewater environmental flow requirements for level. Water is diverted intermittently discharges to ensure that the South bays and estuaries. The South Texas from the adjacent Colorado River to Texas Project meets the stringent levels Project diverted 9,555 acre-feet in replenish the Main Cooling Reservoir. set in the permit. The TPDES permit was 2022 from the Colorado River for Main In addition, the Essential Cooling renewed in 2020. A monthly monitoring Cooling Reservoir fill operations while Pond, a 47-acre, below grade, off- report is submitted to the Texas preserving adequate freshwater flow channel reservoir that supplies water Commission on Environmental Quality conditions for downstream bay and to cool crucial plant components, is for wastewater discharges. Reports estuarine ecosystems. Approximately capable of impounding 388 acre- identifying groundwater use, surface Photo courtesy of Christie Dement 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER FOUR l NON-R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 4- 4
water use, and water conservation are United States Environmental Protection potential for the discharge of pollutants submitted annually to the Texas Water Agency or the Texas Commission on from the station. The stations Multi-Development Board. Reports of surface Environmental Quality. Wastewater Sector General Permit for storm water water diversion and consumptive use discharges met state and federal discharges was renewed in 2021.
are submitted to the Texas Commission water quality standards during the Following a severe drought in 1996, the on Environmental Quality and the Lower year, while conserving and maximizing Texas Legislature recognized the need Colorado River Authority. An annual efficient water usage at the South Texas to address a wide range of state water groundwater use report is also submitted Project. In addition to the wastewater resource management issues. In 1997, to the Coastal Plains Groundwater discharge permit program, the Federal the Texas Senate drafted legislation Conservation District in accordance with Clean Water Act, as amended, requires known as Senate Bill 1 to address these groundwater district requirements. permits for storm water discharges issues and to develop a comprehensive associated with industrial activity. The Wastewater generated at the state water policy. The legislation South Texas Projects Storm Water South Texas Project is processed required the Texas Water Development Pollution Prevention Plan ensures that and discharged to the onsite Main Board to create a statewide water plan potential pollution sources at the site Cooling Reservoir to be re-used by that emphasizes regional planning.
are evaluated and that appropriate the station as cooling water for plant Sixteen planning regions were created, measures are selected and implemented systems. No water was discharged each tasked to prepare a plan for the to prevent or control the discharge of from the Main Cooling Reservoir orderly development, management, pollutants in storm water runoff. This in 2022 other than from the relief and conservation of water resources.
plan is a document that is revised wells that are part of the reservoir The South Texas Project was chosen whenever there is a change in design, embankment stabilization system. No to represent the interests of electric construction, operation, or maintenance aquatic monitoring was required to be generating utilities for water-planning that has a significant effect on the conducted at the site in 2022 by the Region K, encompassing the lower Photo courtesy of Kelly Callais 4 -5 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
Colorado River Basin. A state water years. Station personnel continue to plan is prepared by the Texas Water monitor onsite groundwater usage Development Board every five years according to the requirements of based on the regional water plans. District rules. Additional information The regional water plans are revised regarding the Coastal Plains each planning cycle based on updated Groundwater Conservation District population and water demand projections, can be found on its website at www.
water supply analyses, and water coastalplainsgcd.com. In 2007, in management strategies for a water further recognition of the importance planning horizon out to the year 2070. of water conservation to meet future In November of 2020, the water plan demands in the state, Senate Bill 3, adopted by the Region K water planning enacted by the Texas Legislature, group was submitted to the Texas Water created a stakeholder-driven process Development Board and was approved in for the development of environmental 2021. The South Texas Project continues flows. Environmental flows are the to actively participate in the Lower amount of water necessary for a Colorado Regional Water Planning Group river, estuary, or other freshwater to identify strategies to meet future system to maintain its health and water supply demand projections for productivity. The law established a the region and to update the existing process to develop environmental plan accordingly. Additional information flow regime recommendations for regarding regional water planning in Texas each major river basin in Texas. The can be found on the website maintained process tasked a team of stakeholders by the Texas Water Development Board from each area of the state, working at www.twdb.texas.gov. with a science team, to develop a set of recommendations to the Texas Senate Bill 1 also required groundwater Commission on Environmental Quality conservation districts to develop and to perform ongoing periodic groundwater management plans reviews of the recommendations. The with estimates on the availability of South Texas Project participated as a groundwater in the district, details member of the stakeholder committee Photos courtesy of Greg McMullin of how the district would manage that included the Colorado River and groundwater, and management goals Matagorda Bay. The environmental for the district. The water planning and flow standards set flow levels at various management provisions were further points in rivers and streams to protect clarified in 2001 with the enactment of water in the rivers and estuaries along Senate Bill 2. Accordingly, the Coastal the coast. The existing South Texas Plains Groundwater Conservation Project right to divert surface water was District, encompassing Matagorda not impacted by this legislation.
County, was confirmed by local election Additional information regarding in late 2001. The purpose of the environmental flows can be found at district is to manage and protect the www.tceq.texas.gov/permitting/water_
groundwater resources of the district.
rights/wr_technical-resources/eflows.
The South Texas Project groundwater wells are registered with the Coastal In February 2020, the Texas Plains Groundwater Conservation Commission on Environmental Quality District. Operating permits for the approved a revised Lower Colorado groundwater wells will be renewed in River Authority Water Management January 2023, as required every three Plan. The Lower Colorado River 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER FOUR l NON-R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 4- 6
Authority Water Management Plan on the efficient use and conservation determines how water is allocated of water resources.
from the Highland Lakes (specifically AIR QUALITY MANAGEMENT Lakes Travis and Buchanan) to meet Air emission sources at the South the needs of water users, including Texas Project fall under the scope of the South Texas Project, during water air pollution regulations promulgated supply shortages. The process started under the Texas Clean Air Act, the in 2019 when the Lower Colorado Federal Clean Air Act and numerous River Authority submitted an updated associated amendments. The purpose Water Management Plan to the Texas of these regulations is to protect air Commission on Environmental Quality resources from pollution by controlling for approval. The South Texas Project or abating air pollution and harmful participated in the development of emissions. Although nuclear generation the revision for presentation to and of electricity is a form of zero-emission approval by the Texas Commission on clean energy, the South Texas Project Environmental Quality. Stakeholders uses small amounts of fossil fuel for included representatives from cities, backup and emergency equipment.
industry, lake area businesses and Regulated emission sources at the residents, environmental interests, South Texas Project include fossil-fueled and agriculture. Additional information emergency generators and fire pumps, on the Lower Colorado River Authority fire-fighting training, and other minor Water Management Plan can be found maintenance equipment and activities.
at www.lcra.org.
The station is registered under Texas In 1999, the South Texas Project Commission on Environmental Quality implemented a station Water Permit By Rule Registration No.
Conservation Plan in accordance 154767. This permit by rule registration with state water use regulations. The grants the station the authority to purpose of the Water Conservation Plan operate identified emission sources in is to identify and establish principles, accordance with applicable permit and practices, and standards to effectively regulatory requirements.
Photos courtesy of 1. & 2. Greg McMullin, 3. Drew Richards conserve and efficiently use available ground and surface water supplies and In 2022, the South Texas Project had meet historical and projected average no reportable air emissions events and industrial water demand. Annual no violations.
implementation reports are submitted Unlike conventional electrical to the Texas Water Development generating stations, nuclear power Board and the plan is updated every plants do not burn fossil fuel to five years. The station re-submitted produce electricity. Therefore, the a revised plan to the Texas Water South Texas Project produces virtually Development Board in 2019. Managers no greenhouse gases or other air and staff at the South Texas Project pollutants that are the typical by-understand the water resources of the products of industrial power production state are a critical natural resource processes. The use of emissions-requiring careful management and free nuclear power is a significant conservation to preserve water quality contributor to the preservation of our and availability. Accordingly, the station communitys clean air resources.
continues to support efforts focusing 4 -7 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
NON-RADIOACTIVE WASTE regulates the collection, handling, the site. Hazardous waste and Class MANAGEMENT storage, and disposal of solid wastes, I non-hazardous waste handling and Solid waste management procedures including hazardous wastes. The disposal activities are summarized for hazardous and non-hazardous transportation of waste materials and documented in a waste summary wastes generated at the South Texas is regulated by the United States report for the South Texas Project Project ensure that wastes are properly Department of Transportation. that is submitted annually to the dispositioned in accordance with Texas Commission on Environmental applicable federal, state, and local The South Texas Project is classified as Quality. The South Texas Project environmental and health regulations. a small quantity generator of industrial five-year Source Reduction and Waste By regulatory definition, solid waste solid wastes. Texas Commission on Minimization plan for hazardous includes solid, semi-solid, liquid, and Environmental Quality regulations waste was last updated and the gaseous waste material. The Texas require industrial solid wastes associated executive summary was Commission on Environmental Quality, generated at the South Texas Project to submitted to the Texas Commission on which administers the Texas Solid Waste be identified to the Commission. These Environmental Quality in 2019.
Disposal Act and the federal Resource are listed in the Texas Commission Conservation and Recovery Act program, on Environmental Quality Notice Hazardous waste accumulation at the is the primary agency regulating of Registration for the South Texas South Texas Project in 2022 was limited non-radioactive wastes generated at Project. The registration is revised to a maximum holding period of 180 days.
the South Texas Project. The Texas whenever there is a change in waste The Resource Conservation and Recovery Commission on Environmental Quality management practices change at Act and Texas Solid Waste Disposal Act Photo courtesy of Paul Huff 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER FOUR l NON-R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 4- 8
Figure 4-1 Figure 4-2 Figure 4-3 4 -9 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
also requires the use of proper storage source reduction efforts by employees and shipping containers, labels, manifests, have allowed the South Texas Project reports, personnel training, a spill control to remain classified as a small-quantity plan, and an accident contingency waste generator since 2004. (Reference plan. South Texas Project personnel Figures 4-2 and 4-3).
routinely inspect areas throughout the CHEMICAL CONTROL AND site to ensure wastes are not stored or MANAGEMENT accumulated inappropriately. The stations Integrated Spill Contingency South Texas Project policies and Plan for the South Texas Project, regulations encourage the recycling, last updated and re-certified in 2019, recovery, or reuse of waste, when consolidates multiple federal and state possible, to reduce the amount of requirements into one plan. The plan waste generated or disposed of in is implemented through standard site landfills. Approximately 67 percent of operating procedures and guidelines.
the industrial non-radioactive waste The South Texas Project uses standard generated in 2022 at the South Texas operating procedures, policies, and Project was recycled or processed for programs to minimize the generation of reuse (Reference Figure 4-1). Used waste materials, control chemical use, oil, diesel fuels, electro-hydraulic and prevent spills. The South Texas fluid, and used oil filters were sent to Project also evaluates chemicals and a recycling vendor for reprocessing. products prior to their approval for Empty polyethylene drums are use at the station. Site procedures that returned, when possible, to the original implement the stations Integrated Spill manufacturer for reuse. In addition, the Contingency Plan and the stations station supports recycling programs Chemical Control Program address the for cardboard, paper, aluminum, printer evaluation, storage, use, labeling, spill cartridges and plastic. Approximately control, and disposal requirements 16 tons of scrap metal were removed of chemicals. These guidelines also from the station for recycle in 2022. assist in reducing waste generation, The South Texas Project continues to ensuring proper packaging for disposal, and mitigating the consequences of Photos courtesy of 1. & 3. Gary Parkey, 2. Drew Richards explore new areas where recycling may be expanded or initiated. inadvertent spillage.
Non-radioactive solid waste that The South Texas Project emphasizes cannot be shipped for recycling is awareness training for spill prevention shipped for disposal. and maintains readiness to respond should a spill occur. Spill response Municipal type trash is transported to an team members receive annual offsite landfill. Hazardous waste accounts refresher training in hazardous material for only a small portion of the waste incident response. The South Texas generated at the South Texas Project. Project did not have any reportable Minimization and reduction of hazardous liquid spills in 2022.
waste generation where feasible remains an important goal. Changes in the amount of hazardous waste shipped each year generally reflect differences in operation and maintenance activities.
Successful waste minimization and 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER FOUR l NON-R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 4-1 0
E N V I R O N M E N TA L P R OT E C T I O N P L A N S TAT U S The South Texas Projects Events that require notifications to Environmental Protection Plan was federal, state, or local agencies are issued in March of 1989 to protect non- reported in accordance with the radiological environmental monitoring applicable reporting requirements.
parameters during operation of the The United States Nuclear Regulatory nuclear plants. This report reviews Commission is provided with a copy Environmental Protection Plan non- of any such reports at the time they are compliances, if any, identified in 2022 submitted to the cognizant agency. If a and the associated corrective actions non-routine event occurs and a report taken to prevent recurrence. Potential is not required by another agency, non-conformities are promptly then a 30-day report to the United addressed to maintain operations in States Nuclear Regulatory Commission compliance with plan requirements. is required by the Environmental Protection Plan. No such 30-day or Plant personnel use a condition other non-routine event report was reporting process to document these required in 2022.
conditions and track corrective actions to completion. Internal assessments, Photos courtesy of 1. Drew Richards, 2. Gary Parkey reviews and inspections are also used to ensure compliance.
Photo courtesy of Drew Richards 4 -1 1 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
Non-routine report reviews This annual report also reviews non-routine reports submitted by plant personnel and any activities that involved a potentially significant unreviewed environmental question. A proposed change, test or experiment is considered to present an unreviewed environmental question if it concerns:
- A matter that may result in a significant increase in any * A matter not previously reviewed and evaluated in adverse environmental impact previously evaluated in the the documents specified in (1) above, that may have a Final Environmental Statement related to the Operation significant adverse environmental impact.
of South Texas Project, Units 1 and 2 (Docket Nos. 50-498 and 50- 499), environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board.
- A significant change in effluents or power level.
No unreviewed environmental questions were identified in 2022.
Photo courtesy of Greg McMullin 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER FOUR l NON-R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 4-1 2
RADIOLOGICAL ENVIRONMENTAL INTRODUCTION &
SUMMARY
5 -1 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
CHAPT ER F I V E The Radiological Environmental Only Tritium and naturally occurring Monitoring Program is designed radioactive material were identified in the to evaluate the radiological impact offsite environmental samples in 2022.
of the South Texas Project on the Samples of fish and meat collected and environment by collecting and analyzed showed no South Texas Project analyzing samples for low levels related nuclides were present. Water of radioactivity. Measurements of samples from the onsite drinking water samples from the different pathways supply from the deep aquifer and from indicate that there continues to be offsite sampling stations on the Colorado no adverse effect offsite from the operation of the South Texas Project. River show only natural background radioactivity. The station also monitors for radioactivity in onsite sediment from the Main Cooling Reservoir and ditches.
Measurements of direct radiation onsite and offsite indicated no federal dose limits were exceeded.
Tritium is a radioactive isotope of hydrogen that is produced in the reactor and cannot be removed from effluents released to the Main Cooling Reservoir because it is part of the water molecule.
Due to the design of the Main Cooling Reservoir, the presence of Tritium in various sloughs and ditches onsite and the shallow aquifer is expected. Tritium has been detected in these types of samples and the concentrations remain below the United States Environmental Protection Agency drinking water limits.
Photos courtesy of 1. & 2. Gary Parkey, 3. Greg McMullin A sampling program was developed to monitor the Tritium in the immediate area around the plant for long term trending. Wells are sampled either semi-annually, annually, or once every five years, depending on location and the amount of Tritium present. The Tritium concentration remained below the United States Environmental Protection Agency drinking water limits in 2022 and within the design basis of the South Texas Project.
Analyses of the data collected from the implementation of the Radiological Environmental Monitoring Program indicates that the operation of the South Texas Project has no adverse radiological impact.
1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER FIVE l R ADIOLO GICAL ENVIRONM ENTAL INTRODUCTION & S UMMARY 5 -2
RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
CHAPT ER S I X PROGRAM DESCRIPTION The South Texas Project initiated Analyses of the environmental a comprehensive pre-operational pathways require that samples be taken Radiological Environmental from water, air, and land environments.
Monitoring Program in July 1985. These samples are obtained to evaluate That program terminated on March 7, potential radiation exposure to people.
1988, when the operational program Sample types are based on established was implemented. The data from the pathways and experience gained at pre-operational monitoring program other nuclear facilities. Sample locations form the baseline against which were determined after considering operational changes are measured.
site meteorology, site hydrology, local demography, and land use. Sampling locations are further evaluated and modified according to field and analysis experience. Table 1 at the end of this section lists the required sampling locations and frequency of collection.
Additional discretionary samples were also collected.
Sampling locations consist of Indicator Stations and Control Stations. Indicator Stations are locations on or off the site that may be influenced by plant discharges during plant operation.
Control Stations are located beyond the measurable influence of the South Texas Project. Although most samples analyzed are accompanied by a control sample, it should be noted that this practice is not always possible or meaningful with all sample types.
Photos courtesy of: 1 . Greg McMullin, 2. & 3. Drew Richards Fluctuations in the concentration of radionuclides and direct radiation locations and media types that may be exposure at Indicator Stations are used for additional information. Figure evaluated in relation to historical 6-3 illustrates zones that may be used data and against the Control Stations. to complement permanent, numbered Indicator Stations are compared with sample stations.
characteristics identified during the Environmental samples from areas pre-operational program to monitor for surrounding the South Texas Project radiological effects from plant operation.
continue to indicate no radiological Two sample identification methods are effects from plant operation. Measured used in the program. Figures 6-1 and values from offsite indicator sample 6-2 are maps that identify permanent stations continue to trend with the sample stations. Descriptions of Control Stations. Measurements from sample stations shown on Figures 6-1 onsite indicator samples continued to and 6-2 are found in Table 2. Table 2 fluctuate within normal historical ranges.
also includes supplemental sampling 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -2
RA D IO LO GI CA L EN V I RON M E N TA L MO N I TO RI N G P RO GRAM D E S I G N AT E D S A M P L E LO C AT I O N M A P (Offsite locations are numbered)
Figure 6-1 6-3 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
RA D IO LO GI CA L E N V I RON M E N TAL MO N I TO RI N G P RO GRAM O N S I T E S A M P L E LO C AT I O N M A P Figure 6-2 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6-4
RA D IO LO GI CA L E N V I RON M E N TAL MO N I TO RI N G P RO GRAM Z O N E LO C AT I O N M A P The zone station is determined in the following manner:
- The first character of the station number Z to identify it as a zone station.
- The second character is the direction coordinate No. 1-8.
- The third character is the distance from the site No. 1-6.
Figure 6-3 6-5 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
A I R B O R N E PAT H WAY Average quarterly air particulate sample are located near the site boundary beta radiation activity from three downwind from the plant, based on onsite Indicator Stations and a single the prevailing wind direction. The beta control station have been compared activity measured in the air particulate historically from 2001 through 2022 samples is from naturally occurring (see Figure 6-4). The average of the radioactive material. Gamma radiation onsite indicators trends closely with the analyses are performed on quarterly offsite control values. The comparison composites of the weekly air particulate illustrates that plant operations are samples to determine if any activity is not having an impact on air particulate from the South Texas Project. The gamma activity even at the Sensitive Indicator analyses revealed no radioactivity from Photo courtesy of Gary Parkey Stations (#1, #15, and #16). These stations the South Texas Project.
D I R E C T E X P O S U R E PAT H WAY Direct gamma exposure is The South Texas Project started using #
1 respectively. The Indicator Stations monitored in the environment with a vendor for offsite processing of the are the remainder of the required thermoluminescent dosimeters thermoluminescent dosimeters for monitoring stations.
(TLDs) located at 40 locations around environmental measurement of direct The values plotted are the averages for the site. The natural direct gamma radiation during the third and fourth all the stations according to type. The exposure varies according to location quarter of 2014. The Control Stations, average of the Control Stations is higher because of differences in the natural Stations #23 and #37, are greater than than the other stations because Station radioactive materials in the soil, soil 10 miles from the site in the minimal #
23 is in an area that has slightly higher moisture content, and other factors. wind direction. The prevailing wind natural background radiation. The trends Figure 6-5 compares the amount of direction was into the northwest sector.
of Figure 6-5 show that South Texas direct gamma exposure measured at The Sensitive Indicator Stations are Project is not contributing to the direct the plant since the first quarter of 2001 one-mile NW, NNW, and N from the radiation in the offsite environment.
from three different types of stations. plants on FM 521 at Stations #15, #16 and Figure 6-4 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6-6
Figure 6-5 Figure 6-6 Figure 6-7 6-7 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
SEDIMENT SAMPLES The cobalt-60 inventory in the reservoir was 43.5 pCi/kg at station #215, which has decreased since 1992 because is considerably less than the reportable of radioactive decay and installed levels. Figure 6-6 and Figure 6-7 show equipment to reduce radioactive the results from the plant-produced effluents. Although the total activity cobalt-60 from the Main Cooling of cobalt-60 has decreased over time, Reservoir. Cobalt-60 was not identified an inventory of cobalt-60 is still in in any other sediment sample in 2022.
the reservoir as seen occasionally Cesium-137 was measured in three at Stations #215 and #216. In 2022, out of six bottom sediment samples cobalt-60 was identified in zero out of from Stations #215 and #216 in the Main seven Main Cooling Reservoir sediment Cooling Reservoir in 2022. The highest samples taken, all results were less measurement was 62.5 pCi/kg at Station than the reporting levels. Figure 6-7 #
215. There was no cesium-137 detected demonstrates the calculated decline at station 216. Cesium-137 is often found in the total amount of cobalt-60 in environmental media including soil in the reservoir. Bottom sediment and sediment as residual radioactive samples are taken from the Main material resulting from aboveground Cooling Reservoir each year. A study nuclear weapons testing conducted in was performed in 2010 to locate the 1950s and 1960s. Soil and sediment Photos courtesy of Greg McMullin the distribution and concentrations samples taken in 1986 and 1987 prior at Station #215 in 2022 were slightly of cobalt-60 and cesium-137 in the to operation of the South Texas Project higher than previously detected due Main Cooling Reservoir. Although no contained cesium-137 from weapons to sampling non-homogeneous media.
cobalt-60 was detected from 2007 testing. The average pre-operational Results remained considerably less than through 2010 at Stations #215 and #216, cesium-137 concentration was 118 pCi/ reportable levels. The measured values the concentration of cobalt-60 is not kg in soil and sediment samples, and the at Station #215 and #216 are consistent uniformly distributed in the reservoir highest sample concentration was 383 with pre-operational concentrations sediment and some cobalt-60 remains.
pCi/kg. Cesium-137 activities measured reduced by 30 years of radioactive decay The highest cobalt-60 measurement Photo courtesy of Drew Richards 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -8
Figure 6-8 Figure 6-9 6 -9 STP l A NN UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT
WAT E R B O R N E PAT H WAY Tritium has been detected in the In 2022, Tritium levels remained shallow aquifer on the south side consistent with historical values in of the Main Cooling Reservoir since the relief wells as shown in Figure 6-9.
1999. Models used when licensing the Sampling of Main Cooling Reservoir site predicted Tritium in the shallow relief well #701 has been discontinued aquifer. These models were validated due to no water flow at that location.
with additional studies in 2013. A site Another existing Main Cooling Reservoir conceptual model, developed in 2008 relief well #707, is now used as a and updated in 2014, validated the representative substitute for sampling the original predictions of the site hydrology relief well water from the Main Cooling study. A revision was completed in 2018 Reservoir. Station #707 is just west of the to include Independent Spent Fuel discontinued relief well #701 on the south Storage Installation Project construction. side of the Main Cooling Reservoir. Due to different flow rates of water through Tritium is a radioactive isotope of the relief wells, the base concentration hydrogen and is produced in the is slightly higher at relief well #707 reactors during plant operation.
compared to #701. The highest 2022 Wastewater is treated to remove sample from relief well #707 indicated impurities before release, but Tritium approximately 6,972 pCi/kg, which is less cannot be removed because it is than required reporting levels.
chemically part of the water molecule.
Some of the Tritium is released into The Tritium concentrations in eight the atmosphere and the remainder surface water sample locations from is released into the Main Cooling 2001 through 2022 are shown in Reservoir. The Tritium escapes from the Figure 6-10. The specific sample point Main Cooling Reservoir by evaporation, locations can be found in Table 2.
movement into the shallow aquifer, Tritium levels in the onsite sloughs and and by percolation from the relief ditches vary with the concentration wells which are a part of the reservoir in the reservoir and the amount of embankments stabilization system. rainfall received. The average Tritium Photos courtesy of 1. Greg McMullin, 2. Gary Parkey,
- 3. Drew Richards Figure 6-8 shows the amount of Tritium concentration in the relief well, sloughs, released to the Main Cooling Reservoir and ditches are less than the reservoir each year and the amount present because the water is diluted as it during the last quarter of each year. migrates through the reservoir relief well system. In 2022, seven out of twelve The concentration of Tritium in the surface water sample locations tested Main Cooling Reservoir was relatively positive for Tritium. All test results were stable in 2022. The amount of Tritium below the United States Environmental measured in the Main Cooling Reservoir Protection Agency drinking water was consistent with the amount usually limit of 20,000 pCi/kg. Rainwater was released to the reservoir. The amount collected and analyzed during 2022 of rainfall and reservoir makeup from to determine if the Tritium from the the Colorado River influences the reservoir precipitated in the local area.
concentration of Tritium in the Main Tritium was not measured in any of the Cooling Reservoir and the shallow aquifer rainwater samples offsite.
surrounding it. Tritium enters the sloughs and ditches of the site as runoff from the Tritium was identified in the shallow relief wells that surround the reservoir. (i.e., ten to thirty feet deep) aquifer test 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -1 0
Figure 6-10 Figure 6-11 6-1 1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
wells at Station #235 approximately pCi/kg. In 2022, a maximum value of seventy-five yards south of the reservoir 565 pCi/ kg was identified for onsite test embankment base during 1999. Starting wells. Tritium levels continued to remain in 2000, samples were collected from below the United States Environmental the shallow aquifer well at Station #251 Protection Agency drinking water limit south of the Main Cooling Reservoir. (20,000 pCi/kg).
The Tritium results from these two Tritium has not been detected in the shallow aquifer wells are shown in deep aquifer that is the source of Figure 6-11. In 2022, the concentration drinking water for the local communities of Tritium at Station #235 was consistent and homes. These measurements follow with values over the past ten years.
the hydrological model described in the Shallow aquifer Tritium concentrations original license basis and the updated have remained near the concentrations site conceptual model discussed earlier found in the relief wells. Wells at Stations in this section.
258 and #259 on the west side of the A windmill-powered well, Station site boundary have been sampled since #
267, was 310 pCi/kg, in 2022 which 2006. Wells at Stations #270 and #271 is just above detection. This onsite were installed during the last quarter ground water sample station is the of 2008. The sample results are shown most distant location from the Main in Figure 6-12. The well at Station #271, Photos courtesy of 1. Greg McMullin, 2. Pedro Garcia Cooling Reservoir that Tritium has located adjacent to site property on a been detected. This well is not used for county road easement directly west of human consumption.
the Main Cooling Reservoir, indicated its highest concentration for 2022 at 920 The drinking water onsite is pumped Photo courtesy of Drew Richards 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -1 2
from deep aquifer wells and is collected pasture grass, sediment samples, monthly and composited quarterly rainwater, shallow aquifer well, water to verify Tritium is not present. The from various ditches and sloughs onsite, South Texas Project does not use direct radiation, and air samples near water from the reservoir, shallow communities or other areas of interest.
aquifers, or other surface water for The results of these analyses indicate drinking. If the water with the highest that plant operation has no health Tritium concentration that leaves impact offsite and is well within state the site was used for drinking, the and federal regulations and guidelines.
maximum dose to an individual would 3 NCRP (2006). National Council on be less than one millirem in a year. Radiation Protection and Measurements, This dose is insignificant compared Ionizing Radiation Exposure of the to the approximately 620 millirem the Population of the United States, (Bethesda, public receives a year from natural Maryland), NCRP Report No. 160.
radioactivity in the environment and the radiation received from medical procedures.3 Other samples are collected and analyzed in addition to those required Photos courtesy of 1. Kelly Callais , 2. Greg McMullin by our licensing documents or internal procedures. These samples are collected to give additional assurance that the public and the environment are protected from any adverse effects from the plant. These samples include Figure 6-12 Photo courtesy of Gary Parkey 6 -1 3 ST P l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -1 4 N E I G R O U N D WAT E R P R OT E C T I O N I N I T I AT I V E In 2007, the Nuclear Energy Institute include additional samples collected since sampling began in 2006. Their (NEI) established a standard for near the plants. Some of the positive locations are shown in Figure 6-14.
monitoring and reporting radioactive results of this broadened monitoring Two wells sampled annually (Stations isotopes in groundwater entitled NEI program reflect Tritium associated with #
807 and #808) are adjacent to where a Groundwater Protection Initiative, the Main Cooling Reservoir.
pipe was damaged and repaired several NEI 07-07. The station implemented Wells near the plants are sampled years ago. The Tritium concentration at the recommendations of this industry semi-annually, annually, or once these two wells continued to decrease standard and has broadened the every five years depending on the as expected in 2022. Station #809 groundwater monitoring program to concentration of Tritium anticipated Tritium concentrations were related and the location of to the previously referenced pipe and STP Protected Area Ground Water Monitoring Results the wells. Wells with subsequent repair. All the wells sampled high concentrations in 2022 that had detectable Tritium are are sampled more influenced by groundwater originating frequent over a in the Main Cooling Reservoir. Their five-year period concentrations remain in the range of which follow groundwater Tritium concentrations STP procedure associated with the Main Cooling requirements. Figure Reservoir. All the 2022 measurements 6-13 contains the of Tritium in groundwater are a 2022 results for small fraction of the United States wells that were Environmental Protection Agency sampled along with drinking water limit (20,000 pCi/kg).
the historical highs Note: All measurements are reported in pCi/kg for increased accuracy During 2012, steam traps for the and are equivalent to pCi/L for reporting purposes. measured prior to auxiliary steam system that could Figure 6-13 2022 for each station potentially contain trace amounts of STP Protected Area Ground Water Monitoring Wells Figure 6-14 6- 1 5 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
Tritium were modified to re-direct the well casing used for sampling the condensed steam or liquid water to the upper aquifer. The modifications were Main Cooling Reservoir. Information completed in 2015 with continued regarding the steam traps and subsequent improvements into 2016.
response was documented in the In 2022, there was one occurrence where stations condition reporting process.
condensed steam or water contacted This evaluation identified no new the ground onsite. This occurrence did effluent release pathways and no impact not result in impact to the public or the to the drinking water or the health and environment. No discharge occurred safety of the public. offsite or to groundwater that may be used as a source of drinking water.
By the end of 2014, the majority of the Where applicable, the water was quickly protected area wells had undergone a recovered, recaptured, and clean up modification to enhance the protection completed with no impact to groundwater.
of the structural integrity of the water LAND USE CENSUS The Annual Land Use Census is generating units in each of 16 sectors.
performed to determine if any changes The results of the survey indicated no have occurred in the location of changes for 2022. The eleven sectors residents and the use of the land within that have residents within five miles and Photos courtesy of 1. Gary Parkey, 2. Cheryl Bentley five miles of the South Texas Project. the distance to the nearest residence in The information is used to determine each sector are listed below.
whether any changes are needed in the Radiological Environmental Monitoring Program. The census is performed by contacting local government agencies that provide the information.
In addition, a survey is performed to verify the nearest residents within five miles of the South Texas Project Land Use Census items of interest
- No commercial dairies operate plant located in the area north * Broadleaf vegetation sampling within Matagorda County. of Robbins Slough Road and east is performed at the site
- There were no identified of South Citrus Grove Road. The boundary in the three most animals producing milk for water supply for the ponds is not leeward sectors and at a human consumption located affected by the operations of the control location in lieu of a within five miles of STP. South Texas Project. garden census. The broadleaf
- Colorado River water from below vegetation samples collected
- A commercial olive tree orchard the Bay City Dam has not been also satisfy the collection is located approximately 4.9 used to irrigate crops. requirement when milk miles WSW of the plant.
samples are not available.
- One commercial fish farm * There were no identified continues to operate. It is commercial vegetable farms located approximately four located within the five-mile zone.
to five miles southwest of the 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -1 6
Figure 6-15 Figure 6-16 6 -1 7 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
QUALITY ASSURANCE Quality assurance encompasses duplicates and splits out of a total of planned and systematic actions 1369 samples analyzed for 2022.
to ensure that an item or facility The interlaboratory measurement will perform satisfactorily. Reviews, assurance program provides samples surveillances, and audits have that are similar in matrix and size to determined that the programs, those measured by the Radiological procedures, and personnel are Environmental Monitoring Program.
performing at a satisfactory level.
This program assures that equipment Quality audits and independent calibrations and sample preparation technical reviews help to determine methods accurately measure areas that need attention. These areas radioactive material in samples. Figure are addressed in accordance with the 6-15 summarizes the results of the stations Condition Reporting Process. interlaboratory comparison programs.
The measurement capabilities of Duplicate sampling of the environment the Radiological Laboratory are allows the South Texas Project to demonstrated by participating in estimate the repeatability of the an interlaboratory measurement sample collection, preparation, and assurance program as well as analysis process. Splitting samples performing duplicate and split sample allows estimation of the precision and analyses. Approximately 21.4 percent bias trends of the method of analysis of the analyses performed are quality without the added variables introduced control samples. These consist by sampling. Generally, two samples of interlaboratory measurement split from the same original sample assurance program samples, duplicate material should agree better than two samples, and split samples. All separate samples collected in the same analyses include National Institute of area and time. The 2022 variances Standards and Technology samples, for duplicates and splits are shown in blanks, intercomparison testing, Figure 6-16.
Photos courtesy of 1. Kelly Callais , 2. Gary Parkey,
- 3. Drew Richards P R O G R A M D E V I AT I O N S In addition to measurement accuracy, During 2022 samples not collected or conditions, since this sample is outside radiochemical measurements must unacceptable for analysis: the growing season it was not required meet sensitivity requirements at by the ODCM.
Eight out of 265 Offsite Dose Calculation the Lower Level of Detection for Manual (ODCM) required air sample There were two instances where TLD environmental samples. Deviations from was not collected due to loss of power results used for measuring direct the sampling program or sensitivity from Station #1, #15, #16, and #39. radiation were questionable. One was requirements must be acknowledged hit by the mower and the second had and explained in this report. The loss Twenty-seven air samples not required questionable results when compared of a small fraction of the total samples by the ODCM were not continuously to the duplicate TLD used at the collected in 2022 did not impact the collected for the full-time interval because same location.
ability to demonstrate that the South of power or equipment failures from Texas Project continues to operate with station #35, and #6, and #6 duplicate.
no negative effect on the population or One broadleaf vegetation sample was the environment. not collected in January due to weather 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -1 8
TA B L E 1 R A D I O LO G I C A L E N V I R O N M E N TA L M O N I TO R I N G P R O G R A M MCR-STP Main Cooling Reservoir STP- South Texas Project 6- 19 STP l A N N UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT
TA B L E 1 R A D I O L O G I C A L E N V I R O N M E N TA L M O N I T O R I N G P R O G R A M ( C O N T. )
MCR-STP Main Cooling Reservoir STP- South Texas Project Photo courtesy of Greg McMullin 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -2 0
TA B L E 1 R A D I O L O G I C A L E N V I R O N M E N TA L M O N I T O R I N G P R O G R A M ( C O N T. )
Photo courtesy of Gary Parkey Photo courtesy of Charles Townsend 6-21 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -2 2 TA B L E 2 S A M P L E M E D I A A N D LO C AT I O N D E S C R I P T I O N S 6-2 3 STP l A N N UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT
TA B L E 2 S A M P L E M E D I A A N D L O C AT I O N D E S C R I P T I O N S ( C O N T. )
This station may be used to obtain the required aquatic samples in the vicinity of STP that may be influenced by plant operations.
MCR-STP Main Cooling Reservoir STP-South Texas Project Media codes typed in bold satisfy collection requirement described in Table 1.
Station codes typed in bold identify offsite locations.
- Control Station 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -24
TA B L E 2 S A M P L E M E D I A A N D L O C AT I O N D E S C R I P T I O N S ( C O N T. )
This station may be used to obtain the required aquatic samples in the vicinity of STP that may be influenced by plant operations.
MCR-STP Main Cooling Reservoir STP-South Texas Project Media codes typed in bold satisfy collection requirement described in Table 1.
Station codes typed in bold identify offsite locations.
TA B L E 2 S A M P L E M E D I A A N D L O C AT I O N D E S C R I P T I O N S ( C O N T. )
This station may be used to obtain the required aquatic samples in the vicinity of STP that may be influenced by plant operations.
MCR-STP Main Cooling Reservoir STP-South Texas Project Media codes typed in bold satisfy collection requirement described in Table 1.
Station codes typed in bold identify offsite locations.
- Control Station 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -26
TA B L E 2 S A M P L E M E D I A A N D L O C AT I O N D E S C R I P T I O N S ( C O N T. )
Station codes typed in bold identify offsite locations.
Photo courtesy of Clarence Holley Photo courtesy of Bethani Wittig 6-2 7 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -2 8 RAD IO LO GI CAL E N V I RO N ME N TA L M O NI TO RI N G P RO GRAM A N ALYS I S S U M M ARY A summary of all required samples is For each of these groups of data, given in Table 3. The table has been the following is calculated:
formatted to resemble a United States
- The mean positive values Nuclear Regulatory Commission *The number of positive industry standard. Modifications have measurements/the total number been made for the sole purpose of of analyses reading ease. Only positive values are * The lowest and highest values given in this table. for the analysis Media type is printed at the top The data placed in Table 3 are from the left of each table, and the units of samples required by the sites Offsite Dose measurement are printed at the top Calculation Manual as described in Table 1.
right. The first column lists the type Additional thermoluminescent dosimeters of radioactivity or specific radionuclide were utilized each quarter for quality for which each sample was analyzed. control purposes. The minimum samples The second column gives the total required by Table 1 were supplemented number of analyses performed and in 2022 by numerous direct radiation the total number of non-routine measurements, additional surface water analyses for each indicated nuclide. A samples, ground water samples, additional non-routine measurement is a sample pasture grass, additional rainwater whose measured activity is greater than samples, additional relief well water the reporting levels for Radioactivity samples, and additional sediment samples.
Concentrations in Environmental Fish and crustacean samples vary in Samples. The LOWER LIMIT OF number according to availability, but DETECTION column lists the normal exceeded the minimum number required measurement sensitivities achieved. by Table 1, as well as other meat samples.
The sensitivities were better than Also, numerous air station samples were required by the United States Nuclear collected from weekly air sample stations, Regulatory Commission. in addition to the minimum number of samples required by Table 1 to strengthen A set of statistical parameters is listed the Radiological Environmental for each radionuclide in the remaining Monitoring Program.
columns. The parameters contain information from the indicator locations, The minimum required Radiological the location having the highest annual Environmental Monitoring Program mean, and information from the Control is presented in Table 1. The table is Stations. Some sample types do not organized by exposure pathway. Specific have Control Stations. When this is the requirements such as location, sampling Photos courtesy of 1. & 2. Gary Parkey, 3. Kelly Callais, case, no samples is listed in the control method, collection frequency, and
- 4. Drew Richards location column. analyses are given for each pathway.
6-29 STP l A N N UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT
Photo courtesy of Greg McMullin 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER S IX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -3 0
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Surface Water Units: PicoCuries per Kilogram ANALYSIS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION WTI11 HIGHES T ANNUAL MEAN CONTROL LOCATIONS TYPE /NONROUTINE UMITOF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE INFORMATION RANGE RANGE Hydrogen-3 12/ 0 2.5E+02 I.I E+04 ( 4 / 8) 3 miles SSE I.I E+04 ( 4 / 4) --- ( 0 / 4)
( 9.3E+03 - l .4E+04 ) (#2 16) ( 9.3E+03 - l.4E+04)
Iodine- 13 1 48/ 0 4.2E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Cesium-134 48/ 0 2.0E+OO --- ( 0 I 32) --- --- --- ( 0 / 16)
Cesium- 137 48/ 0 2. IE+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Manganese-54 48/ 0 2.IE+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Iron-59 48/ 0 4.9E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Cobalt-58 48/ 0 2.2E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Cobalt-60 48/ 0 2.3E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Zinc-65 48/ 0 5.0E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Zirconium-95 48/ 0 3.9E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Niobium-95 48/ 0 2.2E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Lanthanum-1 40 48/ 0 4.7E+OO --- ( 0 I 32) --- --- --- ( 0 I 16)
Barium-1 40 t Number of positive measurements I total measurements at specified locations.
TABLE 3 2022 RADIOLOGICAL ENVIRONMENT AL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Ground Water (On site test well) Units: PicoCuries per Kilogram ANALYSIS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION WTI11 HIGHEST ANNUAL MEAN CONTROL LOCATIONS TYPE /NONROUT INE UM ITOF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE INFORMAT ION RANGE RANGE Hydrogen-3 27/ 0 2.8E+02 4.2E+03 ( 16 / 27) 4.0 miles SSE 5.3E+03 ( 7 / 7) no samples
( 2.0E+03 - 5.6E+03 ) (#25 1) ( 5. IE+03 - 5.6E+03)
Iodine-131 27/ 0 2.7E+OO --- ( 0 I 27) --- --- no samples Cesium- 134 27/ 0 2.8E+OO --- ( 0 I 27) --- --- no samples Cesium- 137 27/ 0 2.8E+OO --- ( 0 I 27) --- --- no samples Manganese-54 27/ 0 2.6E+OO --- ( 0 I 27) --- --- no samples Iron-59 27/ 0 5.SE+OO --- ( 0 I 27) --- --- no samples Cobalt-58 27/ 0 2 .6E+OO --- ( 0 I 27) --- --- no samples Cobalt-60 27/ 0 3.0E+OO --- ( 0 I 27) --- --- no samples Zinc-65 27/ 0 8.SE+OO --- ( 0 I 27) --- --- no samples Zirconi um-95 27/ 0 4.SE+OO --- ( 0 I 27) --- --- no samples Niobi um-95 27/ 0 3. IE+OO --- ( 0 I 27) --- --- no samples Lanthanum-1 40 27/ 0 3.8E+OO --- ( 0 I 27) --- --- no samples Barium- 140 t Number ol pos111ve measurements / total measurements at spec1fied locat10ns.
6-31 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Drinking Water Units: PicoCuries per Kilogram ANALYS IS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION wrrn I-IIGI-IEST ANNUAL MEAN CONTROL LOCATIONS TY PE /NONROUTINE LIMJTO F MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE INFORMATION RANGE RANGE Gross Beta 24J 0 1.4E+00 2 .2E+00 ( 10 J 12) 14 milesNNE 3.7E+00( 12 J 12) 3.7E+00( 12 J 12)
( L7E+00 - 2.8E+00) (#228) ( 3 0E+o0 - 4.8E+00) ( 3 0E+00 - 4.8E+00 )
Hydrogen-3 8J 0 2.SE+02 --- ( 0 J 4 ) --- --- --- ( 0 J 4) lodine-13 1 24JO 3.3E+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Cesium-1 34 24J 0 3.I E+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Cesium-137 24JO 3.l E+00 --- ( 0 J 12) --- --- --- ( 0 J 12)
Manganese-54 24J 0 3 0E+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Iron-59 24J 0 6.4E+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Cobalt-58 24JO 3.0E+00 --- ( 0 J 12) --- --- --- ( 0 J 12)
Cobalt-60 24J 0 3.4E+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Zinc-65 24J 0 9.3E+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Zirconium-95 24JO S.2E+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Niobium-95 24J 0 3.SE+00 --- ( 0 J 12) --- --- --- ( OJ 12)
Lanthannm- 140 24J 0 4.SE+00 --- ( 0 J 12) --- --- --- ( 0 J 12)
Barium-1 40 t Number of positive measurements J total measurements at specified locations.
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSTS
SUMMARY
Medium: Rain Water Units: PicoCuries per Kilogram ANALYS IS TOTAL ANALYS ES LOW ER INDICATOR LOCATIONS LOCATION WITH HIGHEST ANNUAL M EAN CONTROL LOCATIONS TYPE /NONROUTINE LIMIT OF MEAN t LOCATION MEAN t M EAN t MEASUREMENTS DETECTION RANGE INFORMATION RANGE RANGE Hydrogen-3 4JO 2.SE+02 --- ( OJ 4) --- --- no samples lodine-131 4J 0 2.8E+00 --- ( OJ 4) --- --- no samples Cesium-1 34 4J 0 2.8E+00 --- ( OJ 4) --- --- no samples Cesium-1 37 4JO 3.IE+00 --- ( OJ 4) --- --- no samples Manganese-54 4J 0 2.7E+00 --- ( OJ 4) --- --- no samples lron -59 4J 0 6. IE+00 --- ( OJ 4) --- --- no samples Cobalt-58 4JO 2.8E+00 --- ( OJ 4) --- --- no samples Cobalt-60 4J 0 3.2E+00 --- ( OJ 4) --- --- no samples Zinc-65 4JO 7.3E+00 --- ( OJ 4) --- --- no samples Zirconium-95 4J 0 4.8E+00 --- ( OJ 4) --- --- no samples Niobium-95 4J 0 2.7E+00 --- ( OJ 4) --- --- no samples Lanthanum-1 40 4JO 3.8E+00 --- ( OJ 4) --- --- no samples Barium-1 40 t Number of pos1t1ve measurements J total measurements at specified locat10ns.
1-1 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -32
6-3 3 STP l A NN UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Sediment-Shoreline Units: PicoCuries per Kilogram dry weight ANALYSIS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION WIII-I I-IIGI-IES I ANNUAL MEAN CONTROL LOCAIIONS
'IYPE /NONROUT!NE LIMITOF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE lNFORMA TION RANGE RANGE Cesium- 134 4/ 0 2-3E+OI --- ( Of 2) --- --- --- ( Of 2)
Cesium- 137 4/ 0 2-3E+OI --- ( 0 / 2) --- --- --- ( 0 / 2)
Mangancsc-54 4/ 0 2-3E+Ol --- ( 0 / 2) --- --- --- ( 0 / 2)
Iron-59 4/ 0 5-3E+OI --- ( Of 2) --- --- --- ( Of 2)
Cobalt-58 4/ 0 2.2E+OI --- ( 0 / 2) --- --- --- ( 0 / 2)
Cobalt-60 4/ 0 24E+OI --- ( Of 2) --- --- --- ( Of 2)
Zinc-65 4/ 0 7-2E+O l --- ( 0 / 2) --- --- --- ( 0 / 2)
Zirconium-95 4/ 0 4.IE+Ol --- ( 0 / 2) --- --- --- ( 0 / 2)
Niobium-95 4/ 0 2.6E+OI --- ( Of 2) --- --- --- ( Of 2)
Lanthanum-140 4/ 0 4.0E+OI --- ( 0 / 2) --- --- --- ( 0 / 2)
Bari um-140 t Number of positive measurements I total measurements at specified locations_
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Sediment-Bottom Units: PicoCuries per Kilogram dry weight ANALYS IS TOTAL ANALYSES LOWER lNDJCATOR LOCATIONS LOCATJON WITI-1 I-IIGI-IEST ANNUAL MEAN CONrROL LOCATIONS TYPE /NONROUTINE LIMIT OF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE INFORMATION RANG E RANGE Cesium-134 6/ 0 2.6E+OI --- ( 0 I 6) --- --- no samples Cesium-1 37 6/ 0 2. IE+OI 44E+OI ( 3 / 6) I mile SW 44E+OI ( 3 / 3) no samples
( 2.8E+Ol 3E+Ol ) (#2 15) ( 2.8E+OI - 6.3£+01 )
Manganese-54 6/ 0 24E+O l --- ( 0 I 6) --- --- no samples lron-59 6/ 0 6,2£+0 1 --- ( 0 / 6) --- --- no samples Cobalt-58 6/ 0 2-3E+OI --- ( Of 6) --- --- no samples Cobalt-60 6/ 0 2.6E+Ol 4.2E+O l ( 2 / 6) I mile SW 4_2E+Ol ( 2 / 3) no samples
( 4.0E+Ol - 44E+Ol ) (#215) ( 4.0E+OI - 44E+Ol )
Zinc-65 6/ 0 7,9£+0 1 --- ( 0 I 6) --- --- no samples Zirconium-95 610 4.6E+OI --- ( Of 6) --- --- no samples Niobium-95 6/ 0 2.9E+OI --- ( 0 / 6) --- --- no samples Lanthanum-1 40 6/ 0 6.8E+Ol --- ( 0 / 6) --- --- no samples Bari um-140 t Number of postl:Jve measurements / total measurements at specified locattons_
1-1 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -3 4
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: B a n ana Leaves U n its : PicoCuries p e r Kilogram w et w e igh t ANALYSIS TOTAL ANALYSES LOWER INDICATOR LOCATION S LOCATION WTI1-I I-IIGI-IEST ANNUAL MEAN CONTROL LOCATIONS TYP E /NONROUTINE LIMITOF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE INFORMATION RANGE RANGE Iodine- 131 11/ 0 I .4E+01 --- ( 0 / 7) --- --- --- ( 0 / 4)
Cesium-1 34 l l/ 0 l.6E+Ol --- ( 0 / 7) --- --- --- ( 0/ 4)
Cesium-1 37 11/0 l.5E+Ol --- ( 0 / 7) --- --- --- ( 0 / 4)
Manganese-54 11/ 0 1.5E+Ol --- ( 0 / 7) --- --- --- ( 0 / 4) lron-59 Il l 0 3.4E+Ol --- ( 0 / 7) --- --- --- ( 0 / 4)
Cobalt-58 11 / 0 l.5E+OI --- ( Of 7) --- --- --- ( Of 4)
Cobalt-60 Il l 0 l.SE+O l --- ( 0 / 7) --- --- --- ( 0 / 4)
Zinc-65 11/0 4.7E+Ol --- ( 0 / 7) --- --- --- ( 0 / 4)
Zirconium-95 11 / 0 2.5E+OI --- ( 0 / 7) --- --- --- ( 0 / 4)
N iobium-95 Il l 0 l.6E+O l --- ( 0 / 7) --- --- --- ( 0 / 4)
Lanthanum-1 40 11/0 2.IE+Ol --- ( 0 / 7) --- --- --- ( 0 / 4)
Barium-1 40 t Number of positive measurements / total measurements at specified locations.
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Cana Leaves U n it s : PicoCu ries p er Kilogram we t weight ANALYSIS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION Will i IIIGI-IEST ANNUAL MEAN CONTROL LOCATIONS TYPE /NONROlJTINE LIM ITOF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE IN FORMATION RANGE RANGE Iodine-131 21/ 0 l.3E+0 1 --- ( 0 I 15) --- --- --- ( 0 / 6)
Cesium-1 34 2 1/ 0 l.5E+O l --- ( 0 I 15) --- --- --- ( 0 / 6)
Ccsium-1 37 21/ 0 l.5E+O l --- ( 0 I 15) --- --- --- ( 0 / 6)
Manganese-54 21/ 0 l.5E+O l --- ( 0 I 15) --- --- --- ( 0 / 6)
Iron-59 21/ 0 3.4E+Ol --- ( 0 I 15) --- --- --- ( 0 / 6)
Cobalt-58 21/ 0 l.5E+O l --- ( 0 I 15) --- --- --- ( 0 / 6)
Cobalt-60 21/ 0 1.SE+Ol --- ( 0 I 15) --- --- --- ( 0 / 6)
Zinc-65 2 1/ 0 4.6E+OI --- ( 0 I 15) --- --- --- ( 0 / 6)
Zirconium-95 21/ 0 2.5E+O l --- ( 0 I 15) --- --- --- ( 0 / 6)
Niobium-95 2 1/ 0 l.6E+O l --- ( 0 I 15) --- --- --- ( 0 / 6)
Lanthanum-1 40 21/ 0 2.0E+Ol --- ( 0 I 15) --- --- --- ( 0 / 6)
Barium-1 40 t Number of positive measurements / total measurements at specified locations.
6-3 5 STP l A NN UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Mediwn: Collard G reen s U n its : PicoCuries p e r K ilogram wet weig ht ANALYSIS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION wrrn HIGHEST ANNUAL MEAN CONTROL LOCATIONS TYPE /N ONROUTINE LIMIT OF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE !NFORMATION RANGE RANGE Iodine-131 4/ 0 1.2E+O\ --- ( 0 / 4) --- --- no samples Cesium-1 34 4/ 0 1.3E+O I --- ( 0/ 4) --- --- no samples Ccsium-1 37 4/ 0 l.4E+Ol --- ( 0 / 4) --- --- no samples Manganese-54 4/ 0 l.3E+O\ --- ( 0 / 4) --- --- no samples lron-59 4/ 0 3.0E+Ol --- ( 0 / 4) --- --- no samples Cobalt-58 4/ 0 l.3E+O I --- ( 0 1 4) --- --- no samples Cobalt-60 4/ 0 l.6E+Ol --- ( 0 / 4) --- --- 110 samples Zinc-65 4/ 0 4. l E+Ol --- ( 0 / 4) --- --- no samples Zirconium-95 4/ 0 2.2E+O I --- ( 0 1 4) --- --- no samples N iobium-95 4/ 0 1.5E+O l --- ( 0/ 4) --- --- 110 samples Lanthanum-1 40 4/ 0 l.8E+Ol --- ( 0 / 4) --- --- no samples Barium-1 40 t Number of positive measurements I tota l measurements at specified locations.
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Mediwn: F ish - P iscivoro u s U nits: PicoCuries p e r Kilogram we t weig ht ANALYS IS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION WJTH HI GHEST ANNUAL MEAN CONTROL LOCATIONS TYPE /NONROUTINE LIMIT OF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE INFORMATION RANGE RANGE Cesium-1 34 5/ 0 3.2E+Ol --- ( 0/ 4) --- --- --- ( 0/ I)
Cesium-1 37 5/ 0 3.2E+Ol --- ( 0 / 4) --- --- --- ( 0 / I )
Manganese-54 5/ 0 3.3E+OI --- ( 0 / 4) --- --- --- ( 0 / 1)
Iron-59 5/ 0 7.3E+Ol --- ( 0/ 4) --- --- --- ( 0/ I)
Cobalt-58 5/ 0 3.2E+Ol --- ( 0 / 4) --- --- --- ( 0 / I )
Cobalt-60 5/ 0 4.lE+Ol --- ( 0 / 4) --- --- --- ( 0 / 1 )
Zinc-65 5/ 0 8.IE+OI --- ( 0 / 4) --- --- --- ( 0/ I)
Zirconium-95 5/ 0 5.9E+Ol --- ( 0 / 4) --- --- --- ( 0 / 1)
Niobium-95 5/ 0 3.3E+Ol --- ( 0 / 4) --- --- --- ( 0 / 1 )
Lanthanum- 140 5/ 0 5.9E+Ol --- ( 0 / 4) --- --- --- ( 0 / I )
Barium-140 t Number of pos1llve measurements / total measurements at specified locat10ns.
1-1 STP l A NN UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -3 6
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Fish - Crustacean & Insect Feeders Units: PicoCuries per Ki logram wet weight ANALYS IS TOTAL ANALYSES LOWER IN DICATOR LOCATIONS LOCATION WITH HIGHEST ANNUAL MEAN CONTROL LOCATIONS TYPE /NONROUTINE LIMIT OF M EAN t LOCATION ME AN t M EAN j" MEASUREMENTS DETECTION RANGE INFORMATION RANGE RANGE Cesium- 134 3/ 0 3.3E+() l --- ( 0 / 2) --- --- --- ( 0/ I)
Cesium-1 37 3/ 0 3.4E+()l --- ( Of 2) --- --- --- ( Of I )
Manganese-54 3/ 0 3.3E+() I --- ( 0 / 2) --- --- --- ( 0 / I)
Iron-59 3/ 0 7.2E+() l --- ( 0 / 2) --- --- --- ( 0/ I)
Coba lt-58 3/ 0 3.2E+() J --- ( 0 / 2) --- --- --- ( 0/ I)
Cobalt-60 3/ 0 4.0E-t-()1 --- ( 0 / 2) --- --- --- ( 0 / I )
Zinc-65 3/ 0 8.0E-t-()1 --- ( Of 2) --- --- --- ( Of I )
Zirconium-95 3/ 0 5.7E+() J --- ( Of 2) --- --- --- ( Of I)
N iobium-95 3/ 0 3.3E+() l --- ( Of 2) --- --- --- ( Of I)
Lanthanum-140 3f 0 5.3E+()l --- ( Of 2) --- --- --- ( Of I )
Barium-140 t Number o r positive measurements f total measurements at specified locations.
TABLE 3 2022 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS
SUMMARY
Medium: Crustacean Shrimp Units: PicoCuries per Kilogram wet weight ANALYSIS TOTAL ANALYSES LOWER INDICATOR LOCATIONS LOCATION WITI-I HIGHES T ANNUAL MEAN CONTROL LOCATION S TYPE /NONROUTINE LIMIT OF MEAN t LOCATION MEAN t MEAN t MEASUREMENTS DETECTION RANGE INFORMATION RANGE RANGE Cesium-1 34 3f 0 3.9E+() I --- ( 0 I 3) --- --- no samples Cesium- 137 3f 0 3.7E+() J --- ( 0 / 3) --- --- no samples Manganese-54 3/ 0 3.7E+()l --- ( 0 / 3) --- --- no samples Iron-59 3/ 0 8. IE-t-() 1 --- ( 0 / 3) --- --- no samples Cobalt-58 3/ 0 3.7E+() l --- ( 0 / 3) --- --- no samples Cobalt-60 3/ 0 4.4E+() l --- ( 0 / 3) --- --- no samples Zinc-65 3/ 0 9.5E+() l --- ( 0 / 3) --- --- no samples Zirconium-95 3/ 0 6.6E+Ol --- ( 0 / 3) --- --- no samples N iobium-95 3/ 0 3.8E+O l --- ( 0 / 3) --- --- no samples Lanthanum- 140 3f 0 5.5E+Ol --- ( 0 / 3) --- --- no samples Barium- 140 t Number of pos11Ive measurements / tota l measurements at specified locations.
6-3 7 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
Photo courtesy of Dana Buckley Photo courtesy of Pedro Garcia 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT CHA PTER SIX l R ADIOLO GICAL ENVIRONM ENTAL OPERATIN G REPORT 6 -3 8
STP l A NN UA L E N V I RO N ME N TA L O P E RAT I N G RE P O RT Photo courtesy of Gary Parkey 1-1 STP l A N N UA L E N V I RO N ME N TAL O P E RAT I N G RE P O RT
Maps provided by Janice Hopes Cover photo by Gary Parkey Other photos courtesy of: Charles Townsend, Cheryl Bentley, Christie Dement, Clarence Holley, Dana Buckley, Drew Richards, Gary Parkey, Greg McMullin, Kelly Callais , Paul Huff, Pedro Garcia, Robert Nies and Bethani Wittig Graphics by Diane Davis Design Coordination 1-1 STP l and ANN support byV Corporate UA L E N Communications I RO N ME N TAL O P E RAT I N G RE P O RT