ST-HL-AE-2636, Annual Environ Operating Rept for 1987

Annual Environ Operating Rept for 1987

ML20151W883
Person / Time
Site:	South Texas
Issue date:	12/31/1987
From:	Scott W, Travis P, Vaughn G HOUSTON LIGHTING & POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
ST-HL-AE-2636, NUDOCS 8805030530
Download: ML20151W883 (53)

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d ANNUAL ENVIRONMENTAL CPERATING REPORT FOR 1987

'0 SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION Prepared by:

J, William F. Scott, II and Peggy Lofton Travis 4

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O TABLE OF CONTENTS I. . Introduction and Summary 1

II. Fog Monitoring Program 1 III. Aquatic Monitoring Program 1 IV. Plant Operations 1 V. Environmental Monitoring 3 VI. Environmental Protection Plan Noncompliances 6 VII. Unreviewed Environmental Questions 9 VIII. Nonroutine Reports 9 IX. References 9 X. Attachments 12 Attachment A - United States Environmental Protection Agency Administrative Order Docket No. VI-87-278 NPDES Permit No. TX0064947, August 31, 1987 Attachment B - Answer to Findings of Violation and Administritive Order of August 31, 1987 Attachment C - 1987 Annual Waste Summary Attachment D - 1987 Groundwater Monitoring Program Analytical Results Attachment E - Wastewater Permit Exceedance Notifications for August 21, 1987 through December 31, 1987 A

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I. Introduction and Summary The South Texas Project Electric Generating Station (STPEGS) is located on 12,300 acres in Matagorda County, Texas, approximately 15 miles southwest of Bay City along the west bank of the Colorado River. STPEGS consists of two 1250-MWe units, a 7,000 acre cooling reservoir, a cooling pond, attendant pumping and discharge facilities and approximately 305 miles of transmission line corridors or.<inating from the STPEGS site.

STPEGS is jointly owned by Houston Lighting & Power Company (HL&P),

Central Power & Light Company, the City of Austin, and the City of San Antonio. HL&P has been designated as Project Manager for the owners and is responsible for implementation of all environmental programs.

The following report fulfills requirements established in Sections 3.1 and 5.4.1 of the South Texas Project Units 1 and 2; Appendix B to Facility Operating License No. NPF-76 South Texas Project Units 1 and 2 (Environmental Protection Plan (Nonradiological)), March 1988. The time period for this report begins with the issuance of the low-level operating license on August 21, 1987, and terminates as of December 31, 1987, as required by Section 5.4.1 of Appendix B of the aforementioned license. Environmental monitoring for STPEGS for this time period was conducted by plant and corporate (HL&P) personnel in accordance with federal and state regulations and applicable plant procedures. The following report offers a compendium of plant environmental activities and notable events for the specified time period. With the exceptions noted in Sections V and VI of this report, STPEGS was in compliance with all nonradiological, environmental-related federal, state, and local laws and regulations, license-related documents and commitments, and plant procedures.

! II. Fog Monitoring Program The fog monitoring program as described in Section 6.2.4.2 of Amendment 10 to the Environmental Report began in May 1987 and will continue for one year. The second phase will begin following startup of Unit 2 and l will continue for one year. A report on the results of the program will t

be submitted in a timely manner following completion of the monitoring.

III. Aquatic Monitoring Program No aquatic monitoring was required by the U.S. Environmental Drotection

( Agency or the state of Texas under the authority of the Clean Water Act for this time period.

IV. Plant Operations Any plant design, plant operation, test or experiment which may involve a change in the Environmental Protection Plan (EPP) or which could have a significant environmental impact is required to undergo a nonradiological environmental evaluation as per OPGP03-ZA-0003 (License Compliance Review) and OPGP03-ZA-0017 (Non-Radiological Environmental Evaluations) to identify and to minimize or prevent any adverse environmental impact, in the nonradiological area, resulting from operational activities, j Reviews of applicable plant designs, operations, tests and experiments are discussed below.

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t- l An operations procedure for the Construction Potable Water System OTCP11-PW-0001-(Construction Potable Water System Operation) was approved in Nonradiological Environmental Evaluation 87-71. This procedure called for the handling of a hazardous material used for potable water treatment and actions to be taken in case of a spill were included in the procedure.

Nonradiological Environmental Evaluation 87-74 approved a temporary plant procedure ITGP03-CS-0001 (Filling the Spray Additive Tanks) for addition of sodium hydroxide solution to the Containment Spray Additive Tanks.

Precautionary statements and procedural steps included were adequate to ensure no adverse environmental conditions would occur. This procedure is no longer in effect.

A testing procedure, (OTEP03-FP-0005 (Proteus Computer Room Halon Concentration Test)),

entailing the release of Halon 1301 (bromotrifluoromethane) to verify that all Halon System alarms and interlocks in the Proteus Computer Room (215), Battery Room (215A), and Battery Charger Room (2152) operate properly and to verify an acceptable concentration of Halon 1301 can be discharged was evaluated. The material to be discharged was determined to be non-hazardous in relation to U.S. Environmental Protection Agency (EPA) regulations and had no associated Department of Transportation (DOT) or Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) related reportable quantity (RQ) value and therefore posed no adverse effect to the environment in Nonradiological Environmental Evaluation 87-78.

A temporary modification was approved to provide service water for cooling the Saltwater / Freshwater Heat Exchangers in Unit 1 and to install temporary drain lines to the plant drainage system on the Open-Loop Cooling l Water Headers. The water to be drained was determined to be chemically untreated water and posed no adverse impact to the environment in Nonradiological Environmental Evaluation 87-81.

This modification has since been discontinued.

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Nonradiological Environmental Evaluation 87-82 approved a temporary modification to connect the discharge lines of_ temporary sump pumps in the Equalization Basin to circumvent the permanent Equalization Basin Discharge Pump 1A and to provide a path for high volumes of water to prevent overworking of the permanent pumps.

This modification posed no adverse environmental impact. These temporary pumps have since been removed and this system returned'to normal operations.

Operations of the Construction Sanitary Waste Treatment System (CSWTS) were approved in OTCP11-ST-0002 (Construction Sanitary Waste Treatment System Operations). These operations required the termination of effluent discharge if limits delineated in Texas Vater Commission (TWC) Permit No. 01908 and U.S. EPA Permit No.

TXD0064947 are exceeded and were therefore approved in Nonradiological Environmental Evaluation 87-87.

The plant operations and tests discussed in this section were determined to be in compliance with applicable environmental federal, state, and local laws and regulations, STPEGS license-related documents, and site environmental procedures and commitments.

V. Environmental Monitoring Site environmental inspections were conducted by plant personnel on a weekly basis, as'a minimum, per Site procedure OPCP10-ZH-0004 (Site Environmental Monitoring). With the minor exceptions noted below and those exceptions discussed in Section VI of this report, compliance with applicable environmental laws and regulations and Site-specific environmental documents were confirmed. Final Environmental Statement-Construction Phase (FES-CP) and Final Environmental Statement-Operation License Stage (FES-OL) compliance was documented on the FES Commitment Checklist per the aforementioned procedure. The following non-reportable incidents were noted for the time period of this report:

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DATE DESCRIPTION CORRECTIVE ACTION 09-19-87 Minor sulfuric acid spill at Contained and neutralized.

Portable Makeup Domineralizer System 09-19-87 Small oil spill at Unit 1 Contained and cleaned up Lube Oil pit with sorbent material.

9-24-87 Small overflow of hydrogen None. pH was 8.55.

peroxide / demineralized water Majority contained in berm.

at Unit 2 Auxiliary Feedwater Storage Tank.

10-02-87 Approximately 65 to 75 gallons Neutralized.

of sodium carbonate solution spilled in area around the Oily Waste Surge Tank.

10-17-87 Approximately 100 gallons Contained and removed with of oil was released to an aorbent materials.

onsite ditch. Contaminated soil removed for disposal.

10-21-87 Overflowed the Unit 1 Overflow halted. No adverse Secondary Makeup Water effects noted upon monitoring.

Storage Tank to the storm drain.

10-21-87 Break in discharge line Contained and neutralized.

from Unit 1 Condensate Polisher (CP) Sump to Neutralization Basin. Low pH 11guld on ground.

12-01-87 Less than 1 gallons of oil Contained on site and removed spilled to storm drain at with sorbent materials.

Unit 2 Diesel Generator Building.

12-01-87 Leak on discharge line from Contained on site, Unit 1 CP Total Dissolved neutralized, and pumped Solids Tanks to Neutrali- back to Unit 1 CP Sump.

zation Basin during an attempted transfer. Approx-imately 50 gallons of low pH water entered a nearby storm drain.

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t Biweekly inspectiona of the Main Cooling Recorvoir (HCR) embanspent vere conducted by Harza Engineering Company. Inspection findings aro documented by Harza via transmittal ir a biweekly inspection report to Houston Lighting and Power. A summary of significant findings is discussed below.

Dewatering and inspection of the Spillway and Blowdown Structure area stilling basin was completed during the tilaa frame of this report.

The basin was then returned to its natural pool elevation. Remedial work began during the time frame of this report and was in progreac as of December 31, 1987 on Little Robbins Slout h, the Plant Area Drainage Ditch, and the Spillway Discharge Channel. The MCP level during this time period varied between 33.40 cnd 35.15 feet.

Monitoring for Sito compliance with applicable federal and state environmental permits (Texas Air Control Board (TACB) Permit No. R-7410, TACB Permit No. C-7410, EPA Permit No. PSD-TX-209, TWC Permit No. 01908, and EPA Permit No. TX0064947) was conducted by plant personnel in accordance with Site procedures Site Instruction 3.10 (Environmental Protection Control Program) and OPCP10-ZH-0004 (Site Er.vironmental Monitoring). With thosa exceptions noted earlier in this section and in Section VI ct this report, STPEGS was in compliance wit h applicable federal and state environmental regulations including the aforementioned permits.

A review of pertinent records and documentation for the aforementioned TACB permits was conducted by plant personnel for the time period of this report in January of 1988. Result s were documented and transmitted to the cognizant plant operating organization. On December 11, 1987, a temporary boiler was delivered to the Site and mounted on skids adjacent to the existing auxilicty boilers to support Unit i start-up activities.

Proper notification was made to the TACB.

Compliance with T'J C Fermit No. 01908 and EPA Permit No. TX0064947 is documented via Solf Reporting Data Sheets as per OPCP10-ZH-0004 (Site Environmental Monitoring). This information is then transmitted to the TWC. Groundwater monitoring was conducted in accordance with TWC Permit No. 01908 and results for 1987 are attached to this report. (Attachment D)

The Lower Colorado River Authority (LCRA) commenced monthly inspections of wastewater treatment facility compliance with TWC permit limits in September of 1987. Inspection findings are documented by the LCRA via monthly inspection reports to Houston Lighting & Power. No items of noncompliance have been documented in relation to these inspections.

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5 Solid waste activities during the time period of this report included the shipment of 9500 gallons of waste oil for recycle, 498 drums of non-hazardous waste for disposal, 113 drums of hazardous waste for disposal, and 11,658 gallons of hazardous waste via tank trucks for disposal. The Annual Waste Summary submitted to the TWC by STPEGS documenting waste handling and disposal activities for 1987 has heen attached to this report. (Attachment C) In addition to the aforementioned waste shipments, activities of the onsite Class III landfill were monitored by plant personnel for regulatory and procedural compliance on a weekly basis.

VI. Environmental Protection Plan Noncompliances On August 31, 1987, the U.S. Environmentel Protection Agency issued Administrative Order Docket No. VI-87-278 NPDES Permit No. TX0064947 (South Texas Project) against the South Texas Project . Electric Generating Station for alleged permit exceedances in late 1986 and early 1987. A copy of the EPA Findings of Violation and Administrative Order (Attachment A) and the reply (Attachment B), which includes a detailed discussion of the alleged violations, by Houston Lighting & Power Company has been attached to this report.

For the time frame of this report, nine environmental permit violations were incurred.by STPEGS. (Attachment E) All of these violations Involved exceeding effluent limits established in TWC Permit No. 01908 and EPA Permit No. TX0064947. Below is a detailed review of the deficiencies that occurred during the time frame of this report in 1987 and descriptions of corrective actions taken to prevent the recurrence of the deficiencies indicated.

1. Outfall 101 (Neutralization Basin)

During this time period two violations occurred at che Neutralization Basin for Outfall 101. One occurrence involved an overflow and bypass of the Neutralization Basin and the other involved a bypass of Outfall 101. On October 8, 1987, the Neutralization Basin overflowed approximately 2500 gallons to the plant drainage system resulting in a bypass of Outfall 101 treatment facilities. The overflow occurred due to inattention of the operator in monitoring basin levels. The situation was aggravated by a past failure of the basin high level alarm. Once the overflow was discovered, influent to the system was stopped and basin overflow was halted. Repairs were made to the high level alarm and the operator was re-instructed in the necessity of adequately monitoring basin j levels. An inspection of the drainage system and samples taken after the overflow indicated no adverse environmental impact occurred.

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On October 22, 1987, during transfer ~of reverse osmosis reject wastewater f rom the equalization basin to the neutralization basin, approximately 500-600 gallons of wastewater overflowed to the plant drainage system. One of two transfer. pumps was out of service for repairs and the other pump failed due to an electrical malfunction.

With both pumps out of service, the equalization basin overflowed. Input'to the basin was halted and the faulty pump was immediately repaired and returned to service. An inspection of the drainage system after this ove-flow indicated no adverse environmental impact occurred to the receiving stream as a result of-this release.

2. Outfall 201 (Oily Waste Treatment System)

Five violations were attributable to Outfall 201 at the Oily Waste Treatment System. On

. September 6, 1987, two violations were incurred on Outfall 201. On this date the chemical injection portion of the Oily Waste Treatment System was experiencing mechanical problems resulting in a high oil and grease level above specified limits. The equipment failure related to this occurrence was repaired and the system resumed compliant operations. No adverse impacts to the receiving stream were noted as a result of this discharge. ' Subsequent to the high oil and grease levels on this date and other samples for this period exceeding or being near the permitted daily average, the daily average for oil and grease on Outfall 201 for the month of September was exceeded.

Also during this month the Total Suspended l Solids (TSS) daily permitted average was

!. exceeded due to samples for this period exceeding or being near the permitted daily I

average.

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On October 4, 1987, during the cleaning of the Unit 2 Secondary Makeup Water Storage' Tank, plant personnel inadvertently allowed high'pH wastewater to enter the Oily Waste-Treatment System which does not have pH adjustment capabilities. Approximately 130 gallons were discharged to the plant reservoir before the error was discovered and the discharge halted. The pH was then manually adjusted and the system returned to compliant operations. Procedural controls implementing a batch mode of processing have since been instituted to prevent similar future occurrences. No adverse environmental impact was experienced.

During the month of October, the permitted TSS daily average was exceeded due to samples for this period exceeding or being near the permitted daily average value.

3. Outfall 401 (West Sanitary Waste Treatment System)

Two violations were attributable to Outfall 401. On October 6, 1987, the West Sanitary Waste Treatment System experienced a high TSS level associated with excessive sludge carryover from the clarifier. Plant personnel decreased clarifier sludge levels by increasing the sludge return rate from the clarifier to the aeration basin and tha system resumed compliant operation. This exceedance of the maximum permitted daily TSS limit resulted in the permitted TSS daily average value being oxceeded. No further violations occurred on this system.

No other items of noncompliance were noted for the time period of this report.

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VII. Unreviewed Environmental Questions As defined in Appendix B to Facility Operating License No. NPF-71, South Texas Project Units 1 and 2, Houston Lighting & Power Company, et al.,

Docket Nos. 50-498 and 50-499, Environmental Protection Plan (Nonradiological), March, 1988, an unreviewed environmental question consists of "...(1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated in the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Boards or (2) a significant change in effluents or power levels or (3) a matter, not previously reviewed and evaluated in the documents specified in (1) of (this] Subsection, which may have a significant adverse environmental impact." Any plant design, operation, test, or experiment which may involve an unreviewed environmental question must have a nonradiological environmental evaluation performed as per Site procedure OPGP03-ZA-0017 (Non-Radiological Environmental Evaluations) and OPGP03-ZA-0003 (License Compliance Review) to determine whether such an unreviewed question is involved. Any such question would require prior Nuclear Regulatory Commission (NRC) approval.

Documents determined to require prior NRC approval must be submitted to the NRC for approval in accordance with Interdepartmental Procedure 1.19Q (Change Notices for Licensed Documents). No such unreviewed environmental questions were presented in 1987.

VIII. Nonroutine Reports No nonroutine reports other than those discussed in Section VI of this report were submitted.

l IX. References A. STPEGS Plant Procedures

1. OPGP03-ZA-0003 (License Compliance Review)

2. OPGP03-ZA-0017 (Non-radiological Environmental Evaluations) l

3. OTCPil-PW-0001 (Construction Potable Water System Operation)

4. OTEP03-FP-0005 (Proteus Computer Room Halon Concentration Test)

5. OTCPil-ST-0002 (Construction Sanitary Vaste Treatment System Operations)

6. Site Instruction 3.10 (Environmental Protection Control Program)

I 7. OPCP10-ZH-0004 (Site Environmental Monitoring) l 8. Interdepartmental Procedure 1.19Q (Change Notices for Licensed l Documents)

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B. Houston Lighting & Power Company Office Memoranda and Correspondence 1, ST-P2-HL-200, Environmental Activity Report, September 14, 1987

2. ST-P2-HL-213, Environmental Activity Report, October 13, 1987 3 '. ST-P2-HL-230, Environmental Activity Report, November 10, 1987

4. ST-P2-HL-249, Environmental Activity Report, December 2, 1987

5. ST-P2-HL-260, Environmental Activity Report, .anuary 25, 1988

6. ST-P2-HL-205, Texas Water Commission Monthly Effluent Reports, September 21, 1987

7. ST-P2-HL-216 Texas Water Commission Monthly Effluent Reports, October 21, 1987

8. ST-P2-HL-233, Texas Water Commission Monthly Effluent Reports, November 20, 1987.

9. ST-P2-HL-248, Texas Water Commission Monthly Effluent Reports, December 18,'1987.

10. ST-P2-HL-257, Texas Water Commission Monthly Effluent Reports, January 20, 1988

11. ST-P2-P2-151, Auxiliary Boiler Environmental Records, January 18, 1988.

12. ST-HL-TX-633, J. R. Smith to Herb Williams, December 14, 1987.

13. ST-P2-HL-294, 1987 Groundwater Monitoring Program Analytical Results, March 29, 1988

14. ST-HL-TX-639, 1987 Annual Vaste Summary, January 21, 1988 l 15. T. E. Undervood to W. H. Kinsey, 1987 Environmental Violations, January 18, 1988 C. Lower Colorado River Authority Transmittals l

l 1. Dennis Haverlah to Bill Scott, October 19, 1987 t

2. Dennis Haverlah to Bill Scott, November 9, 1987 l 3. Dennis Haverlah to Bill Scott, December 8, 1987

! 4. Dennis Haverlah to Bill Scott, January 8, 1988 I

l D. United States Environmental Protection Agency Administrative Order Docket No. VI-87-278 NPDES Permit No. TX0064947, August 31, 1987.

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E. Robin Morse to Terry Lane, Answer to Findings of Violation and Administrative Order of August 31, 1987, September 29, 1987.

F. Houton Lighting & Power Company Wastewater Permit Exceedance.

Notifications

1. ST-HL-FD-240, ST-HL-TX-618, September 15, 1987

2. ST-HL-FD-244, ST-HL-TX-620, October 7, 1987

3. ST-HL-FD-246, ST-HL-TX-623, October 13, 1987

4. ST-HL-FD-245, ST-HL-TX-622, October 12, 1987

5. ST-HL-FD-248, ST-HL-TX-624, October 23, 1987 G. Harza Engineering Company Weekly InspGction Reports

1. Report No. MCR-85-WIR-068 for period ending August 29, 1987

2. Report No. MCR-85-WIR-069 for peric3 cnding September 12, 1987

3. Report No. MCR-85-WIR-070 for period ending September 26, 1987

4. Report No. MCR-85-WIR-071 for period ending October 10, 1987

5. Report No, MCR-85-WIR-072 for period ending October 24, 1987

6. Report No MCR-85-WIR-073 for period ending November 7, 1987

7. Report No. MCR-85-WIR-074 for perioc ending November 21, 1987

8. Report No. MCR-85-WIR-075 for period ending December 5, 1987

9. Report No. MCR-85-WIR-076 for period ending December 19, 1987

10. Report No MCR-85-WIR-077 for period ending January 2, 1989 4

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I X. Attachments l

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f Attachment A United States Environmental-Protection Agency Administrative Order-Docket

' No. VI-87-278 NPDES Permit No. TX0064947

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1 CERTIFIED MAIL: RETURN RECEIPT REQUESTED (P 483 657 114)

Mr. W. F. McGuire, Manager Environmental Protection Department H uston Lighting and Power Company P.O. Box 1700 Houston, Texas 77001 Re: AJninistrative Order Docket No. VI-87-278 NPDES Permit No. TX0064947

Dear Mr. McGuire:

Violation of an NPDES pemit requires the Environmental Protectit-AcWy to take appropriate enforcement action to assure compliance. Pursuant to -Me Clean Water Act (33 U.S.C.1251 et seq.). the enclosed Administrative

& W is hereby served on you and Houston Lighting and Power Company-South

'ms Station for the violations described therein.

Ccopliance with the provisions of this Order is expected within th e eximum tir.a periods established by each part of the Order. Your coa; va-n 3r, and prcapt attention will be appreciated. In response herete, 6 ease reference Docket No. VI-87-278 and your NPDES permit number and ser:! corre-mndence to the attention of Ms. Terry Lane (6W.EA).

It is the policy of the Environmental Protection Agency to achieve tall -

co pliance with the NPDES Permit Program as rapidly as possible. This office is prepared to help you in any way it can. If you have any questions. please contact Ms. Sharon Parish, EPA. Dallas. Texas at (214) 655-2186.

Sincerely yours, Myron .Knud:on,fP.

Director-Water Management Division (6W)

Enclosure P

cc: Mr. Rex McDonnell

~ Texas' Water Comission' P.O. Box 13087, Capitol Station Austin, T.exas.-78711

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UNITf:) $TATi9 EWIRONMENTAt PW W ~ ION AGENCY REGICn (,

IN THE MATTER OF 5 DOCKET NO. VI-87-278 4

HOUSTON LIGHTING AND POWER COMPANY  %

PROCEEDINGS UNDER SECTION 309(a)(3), 6 CLEAN WATER ACT, 6

[33 U.S.C. 1313(a)(3)], 4 ADMINISTRATIVE ORDER in RE: NPDES PERMIT NO TX0064947 6 The following FINDIG3 are made and ORDER issued pursuant to the authority vested in the Administrator of the Environmental Protection Agency by the above referenced statute (hereinafter the Act) and duly delegated to the Regional Administrator, Region 6, and duly redelegated to the undersign Director, Water Management Divisien, Region 6.

I.

Houston Lighting and Pcwer Ccepany-South Texas Station (hereinafter the Permittee) is a company doing business in the State of Texas, and located in Bay City, Texas, the mailing address for which is P.O. Rox 1700, Houston, Texas 77001.

II.

Pursuant to the authority of Section 402(a)(1) of the Act [33 U.S.C.1342 (a)(1)), Region 6 issued National Pollutant Discharge Elimination System (NPDES) Permit No. TX0064947 to the Permittee on October 18, 1985, with an effective date of November 19, 1985. The permit authorizes the discharge of specified qualities and quantities of effluent to the Colorado River.

The permit also requires the submission of Discharge Monitoring Reports and

! Noncompliance Reports.

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III.

PERMIT FINDINGS Part 1.A of the Permit places certain limitations on the quantity and quality of effluent discharged by the Permittee. The relevant limitations folicw:

Outfall 201 - Low Volume Wastewater (Oily Waste Treatment System)

Effluent Characteris'ics Discharge Limitatic_n_s daily avg. daily max.

Total Suspended Solids (TSS) 30 mg/l 100 mg/l Oil and Grease (0&G) 15 mg/l 20 mg/l Outfall 301 - Treated Sanitary Sewage (East Side Facility)

Effluent Charact_ eristics Discharge Limitatiens daily avg. daily max.

Biochenical Oxygen Demand (8005 ) 20 mg/l 45 mg/l Total Suspended Solids (TSS) 20 mg/l 45 mg/l Outfall 401 - Treated Sanitary Sewage (West Side Facility)

Effluent Characte_ristics Discharge tim _itations daily avg. daily max. ,

Total Suspended Solids (TSS) 20 mg/l 45 mg/l Out_ fall 601 - Treated Sanitary Sewage (Training Area Facility)

Effluent Characteristics Discharge Limitations daily avg. daily max.

Biochemical Oxygen Demand (B005) 20 mg/l 45 mg/l Total Suspended Solids (TSS) 20 mg/l 45 mg/l

_0_utfall 00_2 - Sewage Treatment Plant Discharge Effluent Characteristics Discharge Limitations daily aYg. daily max.

Biochemical Oxygen Demand (B005 ) 20 mg/l 45 mg/l Total Suspended Solids (TSS) 20 mg/l 45 mg/l i

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Docket No. VI-87-278 Page 3 '

IV.

FINDINGS OF V101.ATION Based on information provided by the Environmental Protection Agency and the Pemittee, the Pemittee has violated Part I.A. of the permit.

Violations of Part I.A. of the NPDES permit - Recent violations include the following:

, Outfall Date Parameter No. Ex. Violations daily avg. daily max.

201 5/87 TSS 1 231.41 mg/l 270 mg/l 08G 1 69.52 mg/l 61 mg/l i 4/87 OAG 1 40 ng/l 301 5/87 2 63.25 mg/l 188 mg/l B005 TSS 1 49.67 mg/l 176 mg/l 4/87 B005 1 49.51 mg/l 150 mg/l TSS 1 35.62 mg/l 80 mg/l 11/86 TSS 1 53 ng/l 10/86 8005 2 31.19 mg/l 50 mg/l 401 4/87 TSS 1 27.5 mg/l 53 mg/l 2/87 TSS 0 21.16 mg/l 601 5/87 B005 0 28.17 mg/l 4/87 TSS 1 43.57 mg/l 74 mg/l 3/87 B005 1 29.1 mg/l 180 mg/l TSS 2 35.4 mg/l 113 mg/l ,

1/87 B005 1 92.62 mg/l 187 mg/l TSS 1 75 mg/l 147 mg/l 12/86 TSS 1 44.67 mg/l 76 mg/l 10/86 8005 0 28 mg/l 8/86 TSS 0 21.75 mg/l 7/86 B005 1 90 mg/l TSS 2 92.2 mg/l 321 mg/l 002 5/87 B005 1 21.84 mg/l 54 mg/l TSS 1 29.74 mg/l 96 mg/l 10/86 8005 1 34.92 mg/l 55 mg/l V.

Issuance of this ORDER does not preclude the pursuit of additional enforce-ment action for the violations cited herein, including administrative penalties authorized by the Water Quality Act of 1987

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~ OP. DER Based on the foregoing FINDINGS OF VIOLATION and pursuant to the authority

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vested .in, the Administrator under Section 309(a)(3)' of the Act [33 U.S.C.

'.1319'(a)'(3)),4nd duly delegated to th'e' Regional Administrator, Region 6, and duly redelegated to the undersigned Director, Water Management Division, Region 6, it is ORDERED:

A. That the Pennittee, within thirty (30) days of the effective date of this ORDER, shall take whatever corrective action is necessary to eliminate and prevent recurrence of the effluent violations cited in the FINDINGS OF VIOLATION. In addition, the Permittee shall, within thirty (30) db .

sut .it a report detailing the specific actions taken and why such fons are su'ficient to prevent recurrence of the effluent violations.

B. In the event the Pemittee believes that complete correctics of the

,cevionly cited rencomplying discharges is not physically posM'c wi'* .

thirty (30) days, the Permittee shall submit, within thirty (30) days, a

_ co prehensive plan for. the expeditious elimination and prevention or su:h ncncomplying discharges. Such plan shall provide for specific corrective ,

~

actiens to be taken and shall include a critical path schedule for the achievement of compliance within the shortest time possible.

The effective date of this ORDER shall be the dat'e it is received by the Pemittee.

l DATE0: ' Ti.is nst day of Auaust 19.87 .

1 t

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Myron.0. Knuds6h, P.E.

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' Director 1 WaterManagementDivision(6W)

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Attachment B Answer to Findings of Violation and Administrative Order of August 31, 1987 September 29, 1987 l

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)- tu P h BAKER & BOTTS Ot=t o CFF8CCs ONC SMCLL PLAZ A WACMih 0 ?ON. O C TELEPaONC '7f 312291234 OALLAS TCLCConstm '7 31229 73o Austf N . H O U STON, TEXAS 77002 499S ttLCs re 2779 H-18,490 September 29, 1987 Ms. Terry Lane (6W-EA)

U.S. Environmental Protection Agency - Region VI Allied Bank Tower at Fountain Place 1445 Ross Avenue Dallas, TX 75202 VIA MESSENGER RE: Administrative Order Docket No. VI-87-278 NPDES Permit No. TX0064947 (South Texas Project)

Dear Ms. Lane:

Enclosed for filing is respondent Houston Lighting

& Power Company's Answer to Findings of Violation and Admin-istrative Order of August 31, 1987. Should Region VI wish to discuss this respcnse, please contact the undersigned and we will be happy to do so.

Very truly yours, BAKER & BOTTS CalGiN/A 5'2C gy, BY 10K i facag;, ;!;

Robin Morse Attorneys for Houston Lighting

& Power Company REM:175 Encl.

cc: Ms. Sharon Parish (w/ Encl.)

U.S. Environmental Protection Agency - Region VI Allied Bank Tower at Fountain Place 1445 Ross Avenue Dallas, TX 75202 (VIA MESSENGER)

Water Quality Enforcement Section (w/ Encl.)

Texas Water Commission P. O. Box 13087, Capitol Station Austin, TX 78711 002REMFP/118E01 .

J

bAxcn 6'soTTs ems. Terry Lane Page 2 September 29, 1987 bec: Mr. W. F. McGuire _(w/ Encl.)

Environmental Protection Department Energy Development Complex.

Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001 Mr. Ed_Feith (w/ Encl.)

Environmental Protection Department Energy Development Complex Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001 Mr. Steve Davies (w/ Encl.)

Environmental' Protection Department Energy Development Complex Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001

%[ Mr. Tom Underwood (w/ Encl.)

Nuclear Plant Operations Chemical Operations & Analysis Division Houston Lighting & Power Company P. O. Box 510 Wadsworth, TX 77483 e

\'

m

t i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 6 IN THE MATTER OF S

5 DOCKET NO. VI-87-278 HOUSTON LIGHTING AND POWER COMPANY 5 5

5 PROCEEDINGS UNDER SECTION S 309 (a) (3) , CLEAN WATER ACT,

[33 U.S.C. 1319 (a) (3) ) , 5 ANSWER TO FINDINGS OF in RE: NPDES PERMIT NO.

5 VIOLATION AND ADMINIS-TX0064947 5 5 TRATIVE 31, 1987 ORDER OF AUGUST I.

Houston Lighting & Power Company (the "company")

received the captioned Administrative Order on September 2 1987, ,

which is the effective date of such order.The Order concerns operations at the South Texas Project for which eth company is part owner and project manager.

4 II.

The Administrative Order involves a series of al -

leged permit exceedences in late 1986 and early 1987 , pri-marily involving domestic sewage discharges from the svariou South Texas Project sewage treatment plants .

All of the alleged violations were reported by the Company to EPA prior to the issuance of the order, and corrective actio n, based on investigative engineering, has also been taken as de- ,

scribed in greater detail below.

It should be recognized that the South Texas Project, a two-unit nuclear power fa-cility, is in a complicated state of start-up preparation of

+

V one unit and continuing construction of the other. As such, the facility is experiencing a certain amount of operational fine tuning and continues to be subject to shifting hydraulic load conditions due to the movement of large numbers of per-sonnel.

With the improvements discussed below, the Company believes that the unexpected problems encountered over the course of the last year have been resolved'and should not be repeated.

III.

The Company hereby responds on an outfall-by-outfall basis to the alleged violations as follows:

Outfall 201 (Oily Waste Treatment System)

Outfall 201 represents a 15,000 gpd floor drainage treatment facility which discharges to the plant's cooling pond.

Treatment system upsets were observed due to the han-dling of new or increased waste stream flows associated with Unit 1 start-up preparations. Most of the reported exceedences resulted from temporary hydraulic overloads when an excessive amount of treated condensate water was drained into the Oily Waste Treatment System. A routing modification consistent with permit conditions has been implemented which allows condensate water to be directed to the neutralization basin (Outfall 101), which prevides additional hydraulic capacity as well as allowing t~r Ji adjustment prior to discharge to the cooling reservoir.

002REMFM/118E01

4; i

It was also determined that a secondary factor contributing to the observed elevated TSS and Oil & Grease results may have been insufficient chemical feed to the Tri-cellerator, and system adjustments were made to increase feed rates.

The foregoing improvements to the Oily Waste Treat-ment System have resolved the difficulty with temporary flow e

upsets and have resulted in compliant discharges.

Outfall 301 (East Sanitarv Waste Treatment System)

The East Sanitary Waste Treatment System is a 15,000 gpd sewage treatment facility which discharges to the c00 ling pond.

Most of the reported exceedences at this facility can be attributed to hydraulic overload resulting from the neces-sary relocation of plant personnel to support Unit 1 start-up activities. To address this situation, a piping modification has been made'that allows the excess flow to this treatment unit to be diverted to both the West Sanitary Waste Treatment System (Outfall 401) and the Construction Sanitary Waste Treatment System (Outfall 002). This allows operators to maintain flow to the East Sanitary Waste Treatment System at or below design capacity by balancing the influent flows to various treatment systems. The reallocation of system flows has been successful in achieving improved system performance.

The reported exceedence in April, 1987 resulted from an isolated upset condition when high levels of 002REMFM/118E01

filamentous floc developed in the unit's aeration chambers.

1 This condition was believed to have been causad by an increase l in ambient temperatures. Since then, plant personnel have been careful to maintain operating conditions (closely monitoring dissolved oxygen and solids levels) so as to prevent recurrence l

of this problem.

Outfall 401 (West Sanitarv Waste Treatment Systemi The West Sani tary Waste Treatment System is a 60,000 gpd sewage treatment facility which discharges to the cooling pond. It is believed that the reported exceedences at Outfall 401 were caused by high solids levels in the aeration basins of the treatment system, which probably resulted in reduced capacity in the system as well as solids carryover. Opera-tional steps have been taken to ensure that solids in the aeration chambers are kept at optimum levels, and no recent exceedences have been observed.

Outfall System) 601 (Trainina Facility Sanitary Waste Treatment Outfall 601 cewage treatment facility is a 15,000 gpd capacity unit which discharges to the cooling pond. The exceedences reported at this outfall in 1987 were generally determined to have resulted from the hydraulic overload of the system's as-built capacity, capacity expansion to the ultimate licensed capacity of 15,000 gpd was completed in April, 1987, and this treatment system has operated within 002REMFM/118E01

1 e =

t permit parameters since May, 1987 following start-up of the full-sized system.

It is also believed that some of the earlier exceed-ences at this outfall were aggravated by the presence of excessive sand in the training facility's well water which accumulated in plumbing fixtures and which did not allow them to seat properly, resulting in excessive flows. This earlier problem was corrected by improved well conditions and by a general cleaning of the plumbing fixtures at the training facility.

Ougfall002 (Construction Sanitary Waste Treatment Svster)

Outfall 002 represents a 60,000 gpd sewage treat-ment facility which discharges to a tidal segment of the lower Colorado River. After investigation, the marginally excessive BOD 5 levels reported (54 mg/l and 55 mg/l versus 45 mg/l permit' limit) were felt to be due to isolated upset conditions or spurious lab results because monitoring of the system during the period of exceedence indicated that the system was operating properly. Process tests have been per-formed to monitor and reduce the solids levels in the aeration basins of the system (high sludge levels having been identified as the probable cause of the reported TSS exceedence).

Complicnce with all permit parameters at this outfall have requited. An earlier difficulty with the unit's chlorina-tion system (which was enanged from a gaseous to a 002REMFM/118E01 l

__ __ _ _ 1

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t hypochlorination system'.-in April, 1987 due to~NRC' safety requirements)'has also been eliminated following-an initial-adjustment period in which control problems were rectified.

IV.

Based on outfall monitoring results, it is be-lieved that the foregoing improvements have effectively cor-rected the described wastewater treatment s'ystem problems.

Recent monitoring over the last three months confirms excellent performance by plant wastewater systems. With tha assistance of Bechtel, Inc. (its consultants) and sanitary treatment system manufacturers' representatives, the company will con-tinue to use its best efforts to operate the South Texas Project wastewater treatment systems in compliance with permit requirements, making additional adjustments and engineered improvements during construction and start-up operations, if necessary to maintain compliant conditions.

Respectfully submitted, BAKER & BOTTS

• CR13i.yJ.S' c g DATE: September 23, 1987 BY EC E U E I.'.C.M:- iE ROBERT E. MORSE, III 3000 One Shell Plaza Houston, TX 77002 (713) 229-1492 4-Attorneys for Houston Lighting

& Power Company 002REMFM/118E01

4 Attachment C 1987 Annual Waste Summary

bec: W. F. McGuira

• J. T. Vastermtist S

• STP-RMS .

a cW. F. Scott e LigM (+v/ attachment RCRA File 22) liouston Lighting & Power January 21, 1988 ST HL-TX-639 SFN: W13 Mr. Ed Hatton Waste Management Reports Unit Texas Water Commission P. O. Box 13087 Capitol Station Austin, Texas 78711

SUBJECT:

1987 ANNUAL WASTE

SUMMARY

South Texas Project Electric Generating Station TWC Registration No. 30651

Dear Mr. Hatton:

Enclosed is the 1987 Annual Waste Summary for the above referenced facility. If you have any questions concerning this report, please cal; Mr. J . A. Jones at 713/922-2211.

Sincerely, R. W. Lawhn, Manager Environmental Assessment & Waste Mgmt.

Environmental & Research Department JAJ/ sis:B14 Enclosure A Subsidiary of Houston Industries Incorporated

5 GEncretor's TWC R gistration nuzbar 30651 TEXAS WATER COMMISSION ^ A l SHIPPING CONTROL UNIT EPA ID Number TXD020810503 HAZARDOUS AND SOLID WASTE DIVISION, P. O. BOX 13087 CAPITOL STATION i8711 G1 AUSTIN, TEXAS 6

mo yr ANNUAL WASTE

SUMMARY

12 1987 DWO500 8 10 GENERATORS' NAME : Houston Lighting & Power Company: SOUTH TEXAS PROJECT BUSINESS ADDRESS : P. O. Box 1700 Houston, Texas Zip 77001 Phone : (713) 922-2205-Part 1:

1 2 3 4 5 Q 7 8 Facility Texas Com- Hand-Waste Quantity Quantity ponent ling .N Code Generated

• Handled

• Number Codes Comments '

12-17 18-26 27 28-36 37 38-42 43-45 46-92 108320 495 G 440 G 03 S01 108320 495 G 165 G 01429 T06 110450 51750 G 43750 G 32479 T47 WASTE OIL RECYCLE 110450 51750 G 8000 G 04 SO2 110910 0G 330 G 03 S01 170750 1050 P 1050 P 03 S01 181490 207 P 207 P 67822 T34 SILVER RECOVERY 183230 0G 0G 03 S01 900040 0G OG 03 S01 900070 0 G 0 G 03 S01 901760 585 G 585 G 67822 T34 SILVER RECOVERY 910100 13143 G 13088 G 01429 T06 910100 13143 G 55 G 03 S01 910110 0G 0G 03 S01 910650 9845 G 9570 G 01429 T06 910650 9845 G 275 G 03 S01 913650 0G 0G 03 S01 950840 27029.5 P 1484.5 P 03 SO1 950840 27029.5 P 25545 P 01429 T07 952879 0G 0G 03 S01 979740 0G 0G 03 sol 981490 15 P 15 P 67822 T34 SILVER RECOVERY a Enter one letter: G= gallons, L= liters, P= pounds, T= tons, Y= cubic yards, K= kilograms, M= metric tons, N= cubic meter Part II A. Cost estimate - Facility Closure 93 B. Cost estimate - Facility Post-Closure 102 I certify under penalty of law that I have personally examined and am familiar with the information and submikteSonthisandallattacheddocuments immed ately responsible for obtaining the infor a hat ion,based gn my@,i I b lleve quiry of those individua so is htthesubmittedinforma true, and complete A0d)-- Prepared

.D M -.n------------

$ccurate, Signature of Authorized Agent W-- ------------- J 4 8.

by Date

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h Attachment D 1987 Groundwater Monitoring Program Analytical Results i L

~

,, . Houston Lighting & Power Company  ;

OFFICE MEMORANDUM .

1 To V. F. McGuire March 29, 1988- ,

ST-P2-HL-294 ggr-from 11. H. Kinsey PFN: WO2.01 Subicct 1987 Groundwater Monitoring' Program Analytical Results SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION Attached are the 1987 analytical results for the South Texas Project Groundwater Monitoring Program. Attachments 2-8 graphically show conductivity for each sample point, since the beginning of the monitoring program. Sample point locations are shown in Attachment 1.

Please contact T. E. Underwood at site extension 8750 or R. A.

Gangluff at 7879 if you have any questions concerning this report.

CFTEU/WMG/rgb w

Attachments cc: J. R. Lovell J. J. Nesrsta R. A. Gangluff W. F. Jocher V. F. Scott RMS ODCC

4 e

CEMICAL ANALYSIS RESULTS FCR SECOND Half 1987 SOUTHTEIASPROJECT CPO *0 WATER MONITORING PROGRAN WELL 61 WELL 82 WELL 43 WELL 64 FISEE 0lR 41 RESEWO!k 42 Re.SE W0'.R 83 CATE 11/4/67  !!/4/87 11/4/67  !!/4/87 11/8187~  !!/4/87 11/4/87 TIME 1140  !!00 1000 0900 l'.40 1430 1420 pH 7.23 7,04 7.46 7.18 t.53 8.31 6.61 C&OXTP11TY (uMHD/CM) 1046 3420 943 liS 2910 2900 29th TOTPs. P!!N.SS (Pff.) 252 671 180 .,4 0 255 245 293 TOT DIES $11DS (Fft). 604 1950 500 572 1790 1700 1620 PJ.ALINITY (PM) 350 370 20 360 130 1A0 130 CH.0 RIM (Pn) 107 753 7.", 257 890 893 659 S!Ll(A (FFt0 2'." 27,6 25.4 25,1  !.Ah 1,57  !.11

... = = . . - .... ... .. ........ ......... .- ... ...... - ...- .........-

5t'LF;i! (FFM) 22 67 60 0 103 103 100 S0DIL? 4FM) 127 '60 1C2 178 255 222 352 POT 655iM M r.)  ;.. 6,5 ~,1 2.1 13,? e ,5 *,'

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CALC!LH (PF11) 65 140 36 65 24 20 35

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MONE3!tt (PPM) 20 75 22 ~4 46 45 45 WELL DE TH TO WATER FEtM CKAND LEVEL (FT) 12 9 4 7 N/A N/A VA

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l REMP!WS:

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00t!CA ANALYSIS RESIA.TS FOR FIRST HALF 1987 SOUTH TEIAS PROJECT GR0tND WATER HONIT(RING PROCPAf WELL 41 WELL 62 VELL 43 WELL 64 RESERVOIR 81 RESERVOIR 42 RESERV0IR 83 DATE 4/13/87 4/13/87 4/13/87 4/13/87 4/13/87 4/13/87 4/13/87 TIME 1456 9954 1958 1227 1242 1252 1305 pl 7,41 7,61 7.38 6,98 8.58 8.45 8,45 CONDUCTIVITY (uPH)/Cm 1110 3431 1211 1968 2673 2674 2674 TOTAL WP.DNESS (PPM) 274 667 259 466 328 3dl 314 TOT DIES SOLIDS (FW 757 2266 736  !!72 1688 1665 1672 ALVAINIT) (Fm 328 382 Zo4 393 129 135 135 CHLORIDE (PPn) 102 755 165 296 651 656 617 SILICA ( m ) 22 23 26 25 1,4 0.9 1,9 SVlFATE (F N 42 126 65 59 93 200 67

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s Attachment E Vastewater Permit Exceedance Notifications August 21, 1987 through December 31, 1987

Houston Lighting & Power Company l l'.O. Ilox 1700 Houston. 'Ibxas 77001 (713) 22H211 WASTEWATER PERMIT EXCEEDENCE NOTIFICATION OArE: CORRESPONDENCE NO :

October 23, 1987 ST-HL-FD-248, ST-HL-TX-624,SFN:U2

• Mr. Myron O. Knudson, P.E. Mr. Larry R. Soward Water Management Division (6W) Executive Director U.S, Environmental Protection Agency Texas Water Commission Region VI P.O. Box 13087 1445 Ross Avenue Capitol Station Da:tas Texas Austin, Texas 78711 75202 2733 TWC PERM:T NQ:

NPOES PERMlT NO: TX0064947 01908 FAQUTY NAME: South Texas Project EXCEEDENCE TYPE: y MAXIMUM MINIMUM CNERFLCW OTbER OUTFALL NQ 1 DESNN; EXCEEDENCE DATE-10/22/87 101, Neutralization Basin SAMPLE RESULT.

PARAMETER g PERMIT UMIT.

g CAUSE C

• EXCEECENCEJACTION TAKENCURRENT STATb3-During transfer of reverse osmosis reject wastewater from the cqualization basin to the neutralization basin, approxi=ately 500-600 gallons of wastewater overflowed to the plant drainage system. One of two transfer pumps was out of service for repair.n and the other punp failed due to an' electrical malfunction. With both pump: out of service, the equalization basin overflowed. Personnel in the area iCimtified the overflow condition and.the operator halted the input of the reverse osmosis reject water to the equalization basin, thereby stopping the overflow. The faulty pump was immediately repaired and reCurned to corvice. An inspection of the drainage system after this overflow indicates no adverse environmental impacts occurred to the receiving stream as a result of this release.

Analytical results:

Volume (gals.) pH bec: J. H. Goldberg C. E. Vaughn 500-600 7.4 D. R. Betterton W. H. Kinsey S. M. Dev W. F. McCuire M. A. McBurnett IHR/pm/E_STP3, pl S*

f R. D. Martin (NRC)

D. Carpenter (NRC)

STP/RMS (1)

File: STP 170

., /3 f SJG AT PHONENO:

RESPONSIBLE OFFtOAL:(Name/ Tale)

E.A. FEITH, DIVISION MANAGER p (713) 922G5 ENVIRONMENTAL & RESEARCH DEPARTMENT L, R /( ' ,

"R

Houston Lighting & Power Company P.O. Box 1700 Houston. Thras 77001 (713) 228 9211 i

l DATE WASTEWATER October 13, 1987 PERMIT EXCEEDENCE NOTIFICAT COAAESPONOENCE NO:

• ST-HL-FD-246, Mr. Myron O. Knudson, P.E.

Water Management Division (6W) Mr. Larry R. Soward ST-HL-TX-623.SFM:W.2 U.S. Environmental Protection Agency Executive Director Region VI Texas Water Commission 1445 Ross Avenue P.O. Box 13087 Dallas Texas Capitol Station 75202-2733 Austin, Texas 78711 Neces PEnun No:

TX0064947 NC eEEMU NW FACRJn NWE: 01908 South Texas Project EXCEEDENCE WPC y

LMXIMUM -

MfN3 AIM -

QCEE ENCE ME CNT.RFLCNV -

CTHER 10/06/87 * * " " " "

NEW 401, Sewage Treatment (West Side)

TSS "E*"'""

4S mg/l ""

CAUSE CF EXCEECENCEACnON TAKEN/CURAENT STATUS: 60 mg/l The high TSS from the clarifier.

increasing the sludge basin. level wasrateassociated return from the clarifier witht excessive ysludge ca The sewage treatment rystem has resumed compliant o the aeration IHR/pm/E_STP1, P1 operation.

{ bcc: J. H. Goldberg C. E. Vaughn D. R. Betterton W. F. McGuire W. H. Kinsey S. M. Dew S. S. Davies R. D.

D.

Martin (NRC)

Carpenter (NRC)

STP/RMS (1)

File (170) i nt seousaE OmCue <N.m rram

.- 0 '

E.A. FEITH. DIVISION MANAGER PHONE NO:

ENVIRONVENTAL & RESEARCH DEPARTMENT () , , pt _

(713) 022 2205

- - - - - - ~ - ~ -

Hcuston Lighting & Power Company P.O. Box 1700 Houston. 'Ibxas 77001 (713) 228-9211 WASTEWATER PERMIT EXCEEDENCE NOTIFICATION QATE: CORAESPONDENCE NO:

j October 13, 1987 ST-HL-FD-246, ST-HL-TX-623.SFN:W.2

• Mr. Myron O. Knudson, P.E. Mr. Larry R. Soward Water Management Division (GW) Executive Director U.S. Environmental Protection Agency Texas Water Commission Region VI P.O. Box 13087 1445 Ross Avenue Capitol Station Da!!as Texas Austin, Texas 78711 .'

75202-2733 NeoEs PERuT NO:

TX0064947 mCPERMR NC 01908 r4oury NAuE:

South Texas Project EXCEEDENCE TYPE: y uxauvu unuuu o vytCw OTwa EXCEEDENCE DATE: " " " " ' ' * "

10/06/87 401, Sewage Treatment (West Side)

METER PERM 4 UMR NE REM TSS 4g mg/1 60 mg/1 CAUSE OF EXCCEDENCEACDON TAKEtVCURRENT STATUS:

The high TSS level was associated with excessive sludge carryover from the clarifier. Plant personnel decreased clarifier sludge levels by increasing the sludge return rate from the clarifier to the aeration basin. The sewage treatment system has resumed compliant operation.

IHR/pm/E_STP1, P1 bec: J. H. Goldberg C. E. Vaughn D. R. Betterton W. F. McGuire W. H. Kinsey S. M. Dew S. S. Davies R. D. Martin (NRC)

D. Carpenter (NRC)

STP/RMS (1)

File (170)

)

p - A RESPONSJBLE OFFIC2AL:(Na ne/Tafe) -

l PHONE NO:

E.A. FEITH, DIVriiON MANAGER -

l (713) 922 2205 j ENVIRONMENTAL & RESEARCH DEPARTMENT .,pt rsnm

bec: J. H. Coldbstg D. R. Letterton Houston Lighting & Pcwer Company u. H. xins y S. M. Dew P.O. Box 1700 llouston, 'Ibxas 77001 (713) 228 9'211

u. F. McGuire R. D. Martin (NRC WASTEWATER PERMIT EXCEEDENCE NOTIFIC. , j^1*"t*; (NRC oArE. CoaREseONouCE No: STP/RMS (1)

October 7, 1987 ST HL FD-244 ST HL.TX-620. S F.. File : STP (170)

• Mr. Myron O. Knudson, P.E. Mr. Larry R. Soward Water Management Division (6W) Executive Director U.S. Environmental Protection Agency Texas Water Commission Region VI P.O. Box 13087 1445 Ross Avenue Capitol Station Da!!as Texas Austin, Texas 78711 75202 2733 NPOcS PERMIT NO: TX0064947 Twc PERU T No: 01908 FACILF. .' NAME: South Texas Projeet l EXCEEDENCE TYPE: y M,4X1 MUM MINIMUM _ -- OVERFLOW CTNER EXCEEDENCE CMTE: ouTFALL NQ & DESCRIPDON:

10/04/87 PARAMETER I PERMIT UMft 'AMPL5 RESULT.

g j CAUSE OF EXCEEDENCEJACDON TAKEMCURRENT STATut l

l

. During the cleaning of a system component, plant personnel inadvertently allowed

...gh pH wastewater to enter the oily wastewater treatment system. This system does not have pH adjustment capabilities. Approximately 130 gallons cf the high pH wastewater ware discharged to the plant reservoir. Once the error was discovered, the discharge was halted until the pH could be manually adjusted to withia permit limits. Process monitoring indicates that the system has been returned to compliant operation. No adverse impact is anticipated as the result of this discharge.

IHR/pm/E_STP i

RESPONSIBLE OFebCLAL' (Nune/TWe) SIGt' U PHONE NC :

~

E.A. FEITH, DIV;SION MANAGER f/ (713) 922 2205 ENVIRONMENTAL & RESEARCH DEPARTMENT , __

Housten Lighting & P;wer Company P.O. Box 1700 Houston, 'Ihzas 77001 (713) 228-9211 WASTEWATER PERMIT EXCEEDENCE NOTIFICATION Dn.rE: CORRESPONoENCE NO:

September 15, 1987 ST-HL-FD-240. ST-ML-TY-61g_ syn tn

• Mr. Myron O. Knudson, P.E. Mr. Larry R. Soward Water Management Division (6W) Executive Director U.S. Environmental Protection Agency Texas Water Commission Region V1 P.O. Box 13087 1445 Ross Avenue Capitol Station Dallas Texas Austin, Texas 78711 75202-2733 NeoEs PERurt NO: " "E""" "";

TX0064947 019og FA UW NAME:

South Texas Project EXCEEDENCE WPE: y MAXIMUM MINIMUM CNTAFLOW OTHER accEocNes e " " " ' "

09/06/87 201, Oily Waste Treatment System

"^^^" " " Oil and Grease PERMU UMR: "E*

• 20 mg/l 24 mg/l CMJSE OF EXCEEDENCEACnON TAKEN.C)RRENT STATUS:

The high oil and grease level was due to mechanical problems with te chemical injection portion of the treatment system. Corrective cction to the chemical feed-system has been completed and the treatment cystem has resumed compliant operation. No adverse impacts to the receiving stream are anticipated as a result of this discharge.

IHR/pm/E_STP3, pl bcc: J. H. Goldberg G. E. Vaughn D. R. Betterton W. H. Kinsey S. M. Dew

.W. F. McGuire S. S. Davies R. D. Martin (NRC)

D. Carpenter (NRC) l STP/RMS (2) i File (170) l l

l 1 - I RES,0~~ er%w r roe Na:

g' E.A. FE1TH, DMSION MANAGER g/r p,r

_j (713) 922-2205 ENVlftONMENTAL & RESEARCH DEPARTMENT

/ /(( )_

s

o .

Hcustcn Lighting & Pcwer C mpany P.O. Box 1700 Houston, 'lhxas 77001 (713) 228-9211 l

WASTEWATER PERMIT EXCEEDENCE NOTIFICATION I

conaEsPonoENcs No:

cwE.

October 12, 1987 ST-HL-FD-245, ST-HL-TX-622. SFN: W2

• Mr. Myron O. Knudson, P.E. Mr. Larry R. Soward Water Management Division (6W) Executive Director U.S. Environmental Protection Agency Texas Water Commission Region VI P.O. Box 13087 1445 Ross Avenue Capitol Station Dallas Texas Austin, Texas 78711 75202 2733 Nms PEnu T Na: TX0064947 E PERMIT NO: 01908 FAOLTTY NAME: South Texas Project EXCEEDENCE TYPE: X max 1 MUM MLN! MUM CNERFLOW OTHER EXCEEDENCE DATE lO/ Q g/ g 7 OUTFAR NQ & DESCR1" 101, Neutralization Basin PERMff UMff. SWPLE AESULT.

PARAMETEH NA pg CAUSE OF EXCEEDENCEACnON TAKEN/ CURRENT STATUS:

An estimated 2500 gallons of low volume wastewater overflowed the neutralization basin and entered the plant storm drainage system. The overflow occurred while the basin was receiving low volume wastewater and the'high level alarm malfunctioned. Once the overflow was dis-covered, influent to the system was stopped and the basin overflow was halted. Temporary containment was placed around the storm drain to halt the offsite releases. Repairs have been made to the high level alarm and the level of water in the basin returned to a proper level. An inspection of the drainage system and samples taken after the overflow indicates no adverse environmental impacts occurred.

Analytical results of overflow:

Volume (gals) pH 2,500 8.35 bec: J. H. Goldberg G. E. Vaughn IHR/jcc/E-1.IHR D. R. Betterton W. H. Kinsey S. M. Dew E. A. Feith S. S. Davies R.

D. D. Martin (HRC)

Carpenter (NRC)

STP/RMS (1)

File: (170)

I n A l n RESPONSIBLE OFFICLAL:(Nam =Tdje) SG 'u % PHONE NOu f '

E.A. FEITH DIVISION MANAGER I (713) 922 2205 ENVIRONMENTAL & RESEARCH DEPARTMENT 7()( ,

n-

'P EDC Mallroom TEL No. Apr 08.88 13j03 P.02

, ~

-h a -

l S 8 170

'e Light -

omnany W P.O.n.ist700 lloussuu. To.n 7 7001 (711) '22H.r211 I lionstnn f.igliting & l'ower

/ October 26, 1987 ST ML-FD 250 ST-HL TX-6D SFN: W2 Mr. Myron O. Knudson, P.E. Mr. Larry R. Soward Vater Management Division (6V) Executive Director U. S. Environmental Protection Agency Texas Vater Commission Region VI P. O. Box 13087 1445 Ross Avenuo Capito?. Station Dallas, Texas 75202 2733 Austin, Texas 78711 1

SUBJ ECT: SOUTH TEXAS FROJECT EPA PERMIT tio. TX0064947 TWC PERMIT No. 01908 Houston Lighting & Power Company previously submitted a vastewater pern.c exceedence notificat'.on dated October 12, 1987 (attached), The ext:eecence notification reported that the overflow occurred while the basin was receiving However Plant low volu=e vastevater and the htsh ~1evel alarm malfunctioned.

personnel have since discoveted that the overflow was due to inattention by the operator in properly conitoring basin levels while filling with lov volume vastewater. The situation was aggravated due to a prior failure of the basin high level alarm.

Please add this addit'.onal information to your files. Ghould you have any questions or require additional information concernin5 this correction, please i contact Mr. Irving Rade at (713) 922-2213.

1 Sin.erely.

Edward A. Feith, P.E.

Hanager, Water and Ecological Resources Division s

IHR/g*.n/L2 1 9563 GM 60 7' d*L

- .,. a o... P7 P..A,36

~ , - o.. .d W60 Y

o v

The Light company P.O. Box 1700 llouston, 'lixas 77001 (713) 228 9211 llouston Lighting & Power April 26, 1988 ST-HL-AE-2636 File No.: G2 10CFR50.36b U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 South Texas Project Electric Generating Station Unit 1 Docket No. STN 50-498 Annual Environmental Operating Report Pursuant to the South Texas Project Electric Generating Station (STPEGS)

Unit 1 Operating License NPF-76 Appendix B, Environmental Protection Plan (Non radiological), attached is the Annual Environmental Operating Report for 1987.

If you should have any questions on this matter, please contact Mr. C.A. Ayala at (512) 972-8628.

/

G. E. Vaughn Vice President Nuclear Plant Operations GEV/CAA/nl

Attachment:

Annual Environmental Operating Report for 1987

^ " ' "'E "" "" "" " "

NL.88.111.02

o llouston 1 ighting & l'ower Comp.my ST-HL-AE-2636 File No.: G2 Page 2 CCI Regional Administrator, Region IV Rufus S. Scott Nuclear Regulatory Commission Associated General Counsel 611 Ryan Plaza Drive, Suite 1000 Houston Lighting & Power Company Arlington, TX 76011 P. O. Box 1700 Houston, TX 77001 N. Prasad Kadatabi, Proj ect Manager U. S. Nuclear Regulatory Commission INPO 1 White Flint North Records Center 11555 Rockville Pike 1100 Circle 75 Parkway Rockville, MD 20859 Atlanta, Ga. 30339-3064 Dan R. Carpenter Dr. Joseph M. Hendrie Senior Resident Inspector / Operations 50 Be11 port Lane c/o U. S. Nuclear Regulatory Commission Bellport, NY 11713 P. O. Box 910 Bay City, TX 77414 Don L. Garrison Resident Inspector / Construction c/o U. S. Nuclear Regulatory Commission P. O. Box 910 Bay City, TX 77414 J. R. Newman, Esquire Newman & Holtzinger, P.C.

1615 L Street, N.W.

Washington, DC 20036 R. L. Range /R. P. Verret Central Power & Light Company P. O. Box 2121 Corpus Christi, TX 78403 R. John Miner (2 copies)

Chief Operating Officer l City of Austin Electric Utility i

721 Barton Springs Road Austin, TX 78704 R. J. Costello/M. T. Hardt l City Public Service Board P. O. Box 1771 San Antonio, TX 78296 l

Revised 03/18/88 NL.DIST

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