View source for NOC-AE-04001719, 2003 Annual Environmental and Annual Radiological Environmental Operating Reports

{{Adams
| number = ML041280247
| issue date = 04/29/2004
| title = 2003 Annual Environmental and Annual Radiological Environmental Operating Reports
| author name = Bullard W
| author affiliation = South Texas Project Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000498, 05000499
| license number = NPF-076, NPF-080
| contact person = 
| case reference number = NOC-AE-04001719, STI: 31739784
| document type = Annual Operating Report, Environmental Monitoring Report, Letter type:NOC
| page count = 49
}}

=Text=
{{#Wiki_filter:Nuclear Operating Company South Teas JI'h EkdicP Gncnatfn9 Statko        ldsmhdh, Tx- 7748'                               P..0.
289 April 29, 2004 NOC-AE-04001719 10CFR50.36b STI: 31739784 U. S. Nuclear Regulatory Commission; Attention: Document Control Desk One White Flint North 11555 Rockville Pike
-Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 2003 Annual Environmental and Annual Radiological Environmental Operating Reports Pursuant to the South Texas Project (STP) Unit 1 Operating License NPF-76, Unit 2 Operating License NPF-80 Appendix B, Environmental Protection Plan (Nonradiological), and Technical Specification 6.9.1.3, attached are the 2003 Annual Environmental and Annual Radiological Enviromnental Operating Reports.
If you have any questions, please contact J. D. Sherwood at (361) 972-8766 or me at (361) 972-7130.
W. T. Bullard Manager, Health Physics MKJ

==Attachment:==
2003 Annual Environmental and Annual Radiological Environmental Operating Reports.
O:WP\NL\NRC-AP\RREP-2003\04001719

NOC-AE-0400 1719 Page 2 cc:
(paper copy)                           (electronic copy)
Bruce S. Mallett                     -'A. H. Gutterman, Esquire Regional Administrator, Region IV      Morgan, Lewis & Bockius LLP U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400        L. D. Blaylock Arlington, Texas 76011-8064           -City Public Service U. S. Nuclear Regulatory Commission    Michael K. Jaffe Attention: Document Control Desk       U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike                   R. L. Balcom Rockville, MD 20852                    Texas Genco, LP Richard A. Ratliff                     A. Ramirez Bureau of Radiation Control            City of Austin Texas Department of Health 1100 West 49th Street                  C. A. Johnson Austin, TX 78756-3189                  AEP Texas Central Company Jeffrey Cruz                           Jon C. Wood U. S. Nuclear Regulatory Commission    Matthews & Branscomb P. 0. Box 289, Mail Code: MN1 16 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704 O:WP\NL\NRC-AP\RREP-2003\0400 17 19

L F   Ali-]

                       .000 .            a .L                             2...            -.      I
      . 0 m..                                   .                                               0
* 0=&#xb6;
                                    *                        ..                    -    '00' 1
                                                        -            -         0000 k -                                                          0
* 0                                 .00400 00                                              0    0000000 00 '?                              -
      -            -   a-.             -                          ___
0.&#x17d;--%j--______        -                __  -   --  -. a-.
: 0.                                            -_                   0
- - -                *   -*----                   -      -                  _____             0

Completed inAccordance with Tech                   Spec ifidcations -
5,     ,~Ui   ,;       Al-tUted States   Nfclddr Repulatory Commission                                   g bMV;~oLU           rio-i Lense Nos.' .
                                             - ZuIP..6 &NF8 z
A.          1;20*'               f`
Au~hoed~~b    ~n JU4_u~eiodmr i1              M    Lf    X     fl    lI               I t  J        o                    1.rl.            .jj%-    -
t
                                                          &VE             iitnje                 'y                     I
        .         1 ~z;      -tSouthu~exas.P'roject Elbctric Generatiffg Station_                                       r a-.i               -.          A
: r. .#%c   &    .3            W-              ~s.Ctr        .4~$        ~     t~4*t    ~    ~       r 4~~~ A*4         ~    r

I Table of Contents A Executive Summary ...................................................                                                  1-1 Site and Area Description ...................................................                                         2-1 Non-Radiological Environmental Introduction and Summary ........................................ 3-1 Non-Radiological Environmental Operating Report ...................................................                   4-1 Environmental Conditions
* Aquatic and Ecological Monitoring ...................................................                         4-1
* Water Quality Management ...................................................                                  4-2
* Air Quality Management ....................................................                                   4-4....
* Non-Radioactive Waste Management ...................................................                          4-4
* Chemical Control and Management ......................                      ............................. 4-5 Environmental Protection Plan Status ................................................... 4-6 Radiological Environmental Introduction and Summary ............................................... 5-1 Radiological Environmental Operating Report ...................................................                       6-1
* Program Description ....................................................                                      66-1
* Analysis of Results and Trends ...................................................                             6-1
* Land Use Census ...................................................                                            6-9
* Quality Assurance ...................................................                                          6-8
* Program Deviation ...................................................                                        6-10 List of Tables Table 1: Radiological Environmental Monitoring Program ..............                         .............. 6-11 Table 2: Sample Media and Location Descriptions ......................................... 6-13 Table 3: 2003 Radiological Environmental Monitoring Program Analysis Summary ...................................................                      6-18 STP      rNclear OperatingCompany

                                  -2003 EnvironmentalReport List of Figures                                                                                           Page Figure 4-1:  2003 Nonradioactive Waste Manag'e'ment ................................. 4-5 Figure 4-2:  2003 Nonradioactive Waste Generation .................................... 4-6 Figure 4-3:  Hazardous Waste Generation Historical Comparison ....................................                            4-6 Figure 6-1:  Radiological Environmental Monitoring Program Designated Sample Location Map (Off Site) ................ 6-2 Figure 2: Radiological Environmental Monitoring Program Designated Sample Location Map (On Site) ................ 6-3 Figure 6-3:  Radiological EnVirohnmental Monitoring Program Zone Location Map ....................................                        6-4 Figure 6-4:  Historical Comparison ofAverage Quarterly Beta Activity.............................................................. 6-5 Figure 6-5:  Environmental Dosimeter Comparisons .................................... 6-6 Figure 6-6:  Historical Comparison of Cobalt-58 and Cobalt-60 In Main Cooling Reservoir Sediment ....................................               6-7 Figure 6-7:  Calculated Cumulative Curies of Cobalt-60 In the Main Cooling Reservoir .................................                       6-7 Figure 6-8:  Historical Comparison of Tritium Added to And Remaining in the Main Cooling Reservoir .........................                 6-8 Figure 6-9:  Historical Compapsonhof Tritium Activity In Surface Water                   ................................. 6-8 Figure 6-10: 2003 Radiological Laboratory Quality; Assurance Program Performance .................................                                6-10 STP Xrclear Operating Comripany ii

I I L
il     i mmkm"AXA

II Executive Summary                                d                                                  - o I T        his report describes the environmental moni-Indicator stations are the second type of stations. The samples frequently fall below the min-imum detection capabilities of toring programs, radio-  from these stations measure            the state-of-the-art scientific logical and non-radio-   any radiation contributed to           instruments. Samples with ra-logical, conducted at the South    the environment by the project.        diation levels that cannot be Texas Project during 2003. In-     Indicator stations are located         detected are below the Lower cluded in this report are the      in areas close to the South Texas      Limits of Detection. The United Environmental Protection Plan      Project where any plant releases       States Nuclear Regulatory Com-Status, the results of the Radio-  would be at the highest concen-        mission requires that equipment logical Environmental Monitoring   tration.                               used for radiological monitoring Program and the Land Use Census.        Prior to initial operation of     must be able to detect specified Radiation and radioactivity   the South Texas Project, samples       minimum limits for certain types in the environment are constantly  were collected and analyzed            of samples. This ensures that monitored within a 15-mile radius  to determine the amount of ra-         radiation measurements are suf-of the South Texas Project.        dioactivity present in the area.       ficiently sensitive to detect small Sampling locations are selected    These results are used as a "pre-      changes in the environment.
using weather, land use and        operational baseline." Results         The United States Nuclear Reg-water use information. Two         from the indicator stations are        ulatory Commission also has types of sampling locations are    compared to both current control       a required "reporting level."
used. The first type, control      sample results and the pre-operational Licensed nuclear facilities must stations, are located in areas     baseline values to determine           prepare a special report and that are beyond measurable in-     if changes in radioactivity levels     increase their sampling if any fluence of the South Texas Project are attributable to station opera-     measured radiation level is equal or any other nuclear facility. tions or other causes such as          to or greater than this reporting The sample results from these      previous nuclear weapons testing       level. No sample from the South stations are used to explain       programs and natural variations.       Texas Project has ever reached radiation from sources other           Radioactivity levels in the        or exceeded a reporting level.
than the South Texas Project.      South Texas Project's environment STPeVNuclear OperatingCompany 1 -1

CZ-Executive                Summary Measurements made are divided into four categories or pathways based upon how the results may affect the public. Airborne, waterborne, ingestion and direct radiation are the four pathways that are sampled. Each pathway is described below.
* The airborne pathway is sampled in areas around the South Texas Project by measuring radioactivity of iodine and particulate air filters. The 2003 airborne results were similar to preoperational levels with only naturally occurring radioactive material unrelated to the operation of the South Texas Project detected.
o   The waterborne pathway includes samples taken from surface water, ground water and drinking water. Also included in this'path are sediment samples taken from the Main Cooling Reservoir and the Colorado River. Tritium was the only man-made isotope consistently detected in water samples and was measured in the shallow aquifer, the Main Cooling Reservoir and other bodies of water onsite. The average tritium level decreased in the Main Cooling Reservoir over the past year and remained below United States Nuclear Regulatory Commission reporting limits and within United States En-vironmental Protection Agency drinking water standards. Sediment samples from the Main Cooling Reservoir continue to show traces of plant-related isotopes. The amount of plant-related isotopes found in reservoir bottom sediment samples has decreased since 1992 because less Cobalt-60 has been added to the reservoir by plant effluents than has undergone radioactive decay. Offsite sediment samples continue to show no radioactivity from the South Texas Project. This indicates that the station produces no detectable effect offsite from this pathway.
o   The ingestion pathway includes broadleaf vegetation, agricultural products and food products. Naturally occurring isotopes were detected at average environmental levels in the samples.
o   The direct exposure pathway measures environmental radiation doses using thermo-luminescent dosimeters. These results are consistent with the readings from previous years and continue to show no effect from plant operations.
The South Texas Project continues to operate without a negative effect on the population or the environment. The exposure for people living in the area is maintained at less than one millirem per year. Environmental programs at the site monitor known and predictable relationships between the operation of the South Texas Project and the surrounding area.
These monitoring programs verify that the operation of the South Texas Project has no detectable impact offsite and is well within state and federal regulations and guidelines.
These programs are verified by the state of Texas through collection and analysis of samples and placement of the state's thermoluminescent dosimeters.
STP Nuclear OperatingCompany 1 -2

Site Area Description Thhe         South Texas Project is located on 12,220 acres in Matagorda County, Texas, approximately 15 miles southwest of Bay              Fossil-fueled and nuclear-powered City along the west bank of       steam generating plants operate on the Colorado River. The South Texas       the same principle. Fuel is used Project is jointly owned by Texas         to produce heat to convert water Genco, LP, AEP Texas Central Company,     into high-pressure steam. The steam the City of Austin and the City of        is directed through a turbine to turn San Antonio. Until late 1997, the         a generator. In a fossil fuel plant, Houston Lighting & Power Company          burning coal, lignite, oil or natural        steel piping that passes through large was the designated Project Manager        gas in a boiler produces the heat.           heat exchangers called steam generators.
for the owners. In November of 1997,      In a nuclear plant, the reactor replaces     The water in the reactor is pressurized the STP Nuclear Operating Company         the boiler and the "fissioning" or           to prevent boiling. This is why the assumed operational control of the        splitting of uranium atoms inside            South Texas Project's reactors are South Texas Project and responsibility    the reactor produces the heat.               called "pressurized water reactors."
for implementation of all environmental        The fuel for a nuclear reactor               This hot, pressurized water heats programs.                                 is uranium. It is formed into cylindrical    a separate supply of water in the The South Texas Project has two      ceramic pellets, each about the size         steam generators to produce steam 1,250 megawatt-electric Westinghouse     of the end of your little finger. One        that is directed through the blades pressurized water reactors. Unit I        pellet has the energy potential of           of a turbine generator to produce received a low-power testing license      about a ton of coal. Millions of             electricity. The steam is then fed on August 21, 1987, obtained initial      these pellets are stacked in fuel rods       to a condenser where a separate supply criticality on March 8, 1988, and         that are arranged into assemblies            of cooling water from the reservoir was declared commercially operational     that make up the core of the reactor.        turns it back into water that is then on August 25, 1988. Unit 2 received       The use of uranium allows us to conserve     pumped back to the steam generator a low-power testing license on December   natural gas, oil and coal and to avoid       for reuse. A diagram of the plant 16, 1988, obtained initial criticality   the associated production of greenhouse      water systems is shown below. In on March 12, 1989, and was declared       gases.                                       addition to its safety systems, the commercially operational on June               A reactor starts operating when         South Texas Project has many built-19, 1989. Both units together produce     control rods in the core are withdrawn       in physical barriers that would prevent enough electricity to serve over a        and fission begins. The fuel rods            the release of radioactive materials million homes.                            heat water circulating in sealed, stainless  in the unlikely event of an accident.
SECONDARY LOOP
                                                                          ~~1 TURBINE.V                                    GENERATOR IA lL-CIRCULATING P   PUMP CONTAINMENT PRIMARY LOOP                              WALL                    COOLING LOOP STP Nuclear Operating Company 2 -1

                                               -2               003 En vironmnental Report are beginning to be developed in the area with the main crop being catfish.
Although the surrounding area is heavily cultivated, significant amounts of woodlands, thicket, brush, fields, marsh and open water exist to support wildlife. The area lies in the southern region of the central flyway and is host to an abundance of migratory birds. The local estuary environments provide the necessary habitat for a variety of fish types to complete their life cycles. The area also affords opportunity for recrea-tional hunting and fishing.
The South Texas Project is home to many species of animals. Inhabitants include American alligators, ospreys, bald eagles and several hundred deer.
In winter, literally hundreds of thousands of waterfowl, principally migratory The most visible ones are the 200-         wetlands, Kelly Lake, drainage ditches,     geese as well as white pelicans and foot-tall, domed containment buildings     sloughs and depressions. Much of            the common tern, have found that with steel-reinforced walls four feet      the land east of the cooling reservoir      the plant's 7,000-acre cooling reservoir thick. Inside each of these massive        is leased for cattle grazing. Approximately provides a good resting place during structures, two more concrete walls        1,700 acres remain in a more natural        their migrations. The station also provide another 11 feet of shielding.      state as a lowland habitat. A 110-          established a man-made wetland habitat The reactor vessel itself has steel        acre wetland habitat area was establish-    in 1996 that attracts an increasing walls six inches thick, and the fuel       ed in 1996 on previously unused             diversity of migratory fowl and other pellets inside it are sheathed in hardened land located northeast of the power         wildlife. Since 1997, the 15-mile-metal tubes.                               plants. The area surrounding the            wide area that includes the South South Texas Project is characterized        Texas Project has had the highest Nuclear power plants produce approximately 20 percent of the nation's   by coastal plain with farmland and          number of bird species nationwide electricity while saving the equivalent    pasture pre-dominating. Local relief        in the National Audubon Society's of approximately 164 million metric        of the area is characterized by flat        annual Christmas Bird Count.
tons of carbon, as well as 2.4 million     land, approximately 23 feet above                 The climate ofthe region is subtropical tons of nitrogen oxide emissions           sea level                                   maritime, with continental influence.
and 5.1 million tons of sulfur dioxide,                                                It is characterized by short, mild from entering the earth's atmosphere                           ire I.     ~---             winters and long, hot and humid annually. Between 1973 and 2001,                                                       summers. Rainfall is usually abundant nuclear generation in the United                                                       throughout the year with an annual The economic base for this area States prevented the emission of                                                       average of approximately forty-two primarily is agricultural related. Most     inches. The prevailing wind direction approximately 2.97 billion tons of         of the land near the site is used for carbon, 35.6 million tons of nitrogen                                                  is from the south-southeast, shifting the production of five major agricultural oxide and 70.3 million tons of sulfur                                                  to north-northeast for short intervals products: beef, rice, grain sorghum, during the winter months.
dioxide.                                   soybeans and cotton. In addition
                                                                                                                      -      - i-;W;  1 to the agriculture industry, there
  ,Zp,
                              "            is commercial fishing in the lower Colorado River, East and West Mata-            Ad--     T  -   -
* Sixty-five of the entire 12,220     gorda Bays,'Intracoastal Waterway acres at the South Texas Project are       and the Gulf of Mexico. Currently occupied by the two power plants.          shrimp, oysters, crab and fin fishes Plant facilities include a 7,000-acre      such as catfish and striped bass are main cooling reservoir and a 47-           the predominant commercial fish in acre essential cooling pond. Many          the county. The Aquaculture farms smaller bodies of water onsite include STP Nuclear Operating Company 2 -2

,,T,(,
4-

I I Non-RadiologicalEnvironmental-                                          Itrrozductionl and Sunmary he South Tex-   The station's commitment to sound environmental management is illustrated as Project is  by the following environmental successes in 2003:
committed to the production      o Continued classification as a high performer by the of electricity in a safe,          Texas Commission on Environmental Quality based on reliable, and economi-             the station's above-average environmental compliance cal manner using nuc-              record in all areas considered, including water quality, lear energy. The station's         waste management and air quality compliance programs, policies and           o Station involvement in community efforts to increase business plan objectives           public safety awareness, collect hazardous and non-also incorporate a com-            hazardous waste for proper disposal and responsibly mitment to environmen-             manage regional water resources Continued reductions tal excellence and sound           in non-radiological waste generation at the station.
environmental man-agement. The dedica-        Everyone has a responsibility to protect the environment. Commitment tion of station personnel   to environmental responsibility is an integral component of the South who develop, imple-         Texas Project operating policy. This responsibility reaches further ment and monitor site       than mere compliance with laws and regulations to encompass the environmental protec-       integration of sound environmental practices into our daily operational tion programs and com-      and business decisions. The people at the South Texas Project understand pliance exemplify this      the need to balance economic, operational and environmental issues commitment.                 for the benefit of the station and the public. The South Texas Project understands that we must hold ourselves to the highest principles of responsibility for our environmental and station activities.
STP Nuclear Operating Company 3 -1

                     ;Baxter,  w v"A vl, n-l W:,4
        !Je Mt R

Non-RadiologicalEnvironmental Operating Report hissection of the-report        ri
                                                    -..          -ties-.and other organizations: with
               , ,i',,describesthe South Texas t'a common' goal to prtect the state P,]roject',snon-radiological~' air,'wateran'd aiand resources-s a" Te             e           ment pam                         partner in'the CLEAN TEXAS program,'
* perform'    ance
                          .1.>.-: i---K.
and environ          -the'South
                                                                       -;t*-. Texas Prject is committed rS^~,->                        h 1Q 5insSS
   'nme tal conditions    f          rom January.
meeting 1 .to                     cstablished env1rVnmentalI
  'ltrough December 1 2003                         Theimprovement goals, maint
    .STPNuc 1er Op erati ng Company improving internal programs and conung
  'environmenta1 staffcloselyzmonitors communlityenvironmental outreach environmental conditions and per                             programs.anrid projects. In .2003 formiance'at the South Texas Proj ect                       SouthTexkasProjectvolunteers participated
    -Reliaiit Resources, lInc -'1provides in the atagorda-County Communiity-
    .support'.and technical hassistance. SafetyAwareness dayand the Matagord.
to the'South Texas'Project.'-In;2003,' .c.County Househoid Ha'zado'us'ate&sect;
  .the Texas Commission on Environ$;&sect;Co11letin
  - mental Quality condu~icted a wastewater             "-,   ",-The       Tekas Commission on Environ-disc argepermitcompliance ,in- .'.>mental-Quiaiity.-classified the Soiuthn i-peCtl n at the stati on No 'di s -Texas                              Projc in 2003 as a high performer crepancies were foiund.-X- z                            '  based onfthe station s above-average 4In 2002,the South Texas Projectj               Menvironmental compliance record applieddfor recog'nition as a-partner iFaciitiessuch as the So'uth.Texas in the CLEAN TEXAS program ad7 "IProject are clssified y the state
   -ministered by the Texas Commission '.>as a high performer, average performer on Environmental -Quality.-- -The :,-- orpoorperformer based on that facility s
  .:tate 'sub seq-uentlygranted approval , compliancehistory.The state's classification
   .of the station's application..: CLEANT--6f the-South- TexasiProject as'a hight
  .TEXAS i a voluntaryenvirohnmental.'P-perforier.was u                                                        based on the station's l adershipuprogram compris e of 1.environmental peformance overthe indinstriesononprofit groups, coun->e-lastfV earpdi16dj' Photo by: Gwenna Kelton AQUATIC AND ECOLOGICAL MONITORING he location of the South remaining area of the site offers diverse Department ofAgriculture Conservation
             ' Texas Project falls within habitats for mammals and several 'Award in 1999 for habitat preservation.
the Texas Land Resource types of birds. -- The South Texas This habitat area immediately attracted Area designation as coastal Project-environmental staff regularly a variety of bird species-and other prairie and can be divided monitor the site's environs for changing wildlife and has continued to support
 *intotwo broad ecological areas based conditions:-.Ecological conditions an increasing diversity of plants and on topography, soils and vegetation. -onsite in 2003-remained generally animals. An observation trail adjacent The bottomland area is a swampy, unchanged'and satisfactory.                                                   to the wetland habitat allows easy marshy area that occupies approx-                                    In 1996,;the SouthfTexasProject access and viewing by visitors.
imately 1,700 acres of the site near and Houston Industries Incorporated                                           The South Texas Project is located the Colorado River. This area provides initiated a joint effort with Ducks on the state-sponsored Great Texas an important habitat for birds and Unlimited, Texas Parks and Wildlife, Coastal Birding Trail that spans the other wildlife. A spoil impoundment 'the United'States Fish and Wildlife entire Texas Gulf Coast from Brownsville constructed in 1972 by the United Service, and theUnited States De- *to the Louisiana border. Several States Army Corps of Engineers is partment of Agriculture Natural Re- bird species listed on the state and included in this area. In addition, sources Conservation Service to es- federal threatened or endangered species a 110-acre wetland habitat area that tablish a '10-acre-wetland habitat lists have been observed at the wetland attracts a variety of bird groups and for migratory waterfowl at the station. habitat and elsewhere onsite. These other wildlife' was established'in The wetland pr6ject received the include the bald eagle, peregrine 1996 on previously unused land located Ducks Unlimited Habitat'Conservation falcon, wood stork, white-faced ibis, northeast of the power plants. 'The Award in:1996 and a United States wood ibis and white-tailed hawk.
STP Nuclear Operating Company 4-1

                                                   -2OO3'Environmental                                                                                       Report Additional migratory and resident Water Quality Management bird species such as a variety of                                                                                    Cooling Reservoir .The Main Cooling J!Water is an essential ducks, geese, turkey and pheasant        in! electricity               ~production, and -'all 2'Reservoir is a 7,000-acre above g have been observed during informal         eltric ;utilities must complywith off-channel reseryoir capableo ht surveys of the site's diverse natural            .
kte~sive   t._}A federal,^ '' _-i.
                                                                        .- ,,         ;'n state    4 andA' --lo
                                                                                                       'ii '-'
Jocals        tpounding 202,600           '
acre-feet of Vwater.=t.' <'i*'e:
and man-made habitats.                   water'regulations. Theseregulations Sati-ts maximum'level. Reservoir The South Texas Project continues govern virtually every aspect of9bu- 'makeup water is withdrawn inter-to provide vital habitat for more than 125 different species of wintering ines' Te~, ,,.,,,,op'rations 2w r'2#"i '-! '.'4 atthe
                                                                              ..... "' Sodth''"'' m"TT-xas
                                                                                                       ''       ' Ji :1 sJ; S..,:          ? ..        i th   ehdjacent'Colorado 1 -    -.
Project Water usage and-wastev'ati                                                     tInIaRiver ldditiontheEssential and-resident birds, including the        treatment onsite are regulated iindet ;Cooling:Po'id;aia-46.9.7adre,-eldoT common tern and white pelicans.          th Safe Drinkin'g.Water Actjthe                                             grade'off-channelr servo                           su In 1998, a small number of black         Federal'Clean WaterAct and the Texas plies water~to cool'ruciM lanit com-skimmers and least terns established          u.,.ae            H                                                                                           f <;<XSi.--i;<b..-+
Water Quality, ActCollectively'                                             ponents:'is -cabi                    ofimponding nests on a remote parking lot at         these acts provide for the safeguardig-388 acre-feet f ae Various 'water the station. Special precautions         of6:public' drinking iwater supplies rights permits, contractual agreements were taken to protect the nesting a ndmaintaining         -- ;,A>
the--integrity of state and conpliance locuments autho." ^;vg<.
area and a small, but growing population        q                      1-'-j,?t\,-i.''S,,
Urizethe'South'exas Project to main'T 2-and federal waters :!-The South Texas of both species has continued to            roject uses both surface water and                                       tam these reservoirs; impound water return each year to the site. Intensive     groundwater for st-atio purpose
                                                           -                                                         dm s                    qn ivert? .r-ithedado Riv er bird nesting continues throughout            roundwater provides onsite drinkingocand to irculatedivert and use water the lowland habitat; particularly-       water for station personnel, replenishes                                    from :the res ervoiirsfor- industrial in a heron'rookery around the periimeter theiEssential Cooling Pond, and is .- purposes to operate the plant <.These' of Kelly Lake. U. S. Fish and Wildlife     sed for other industrial purposes                                          permits dlso'limit the rate of diversionP Service biologists estimate that disite 'Surface water,,from the Main'. Sfrom the 'Colorado t Rive'r. -- l;,;a;xJ over half of Texas' breeding adult                                                                                           Existiii federal and                      water 1 Cooling R-servoir and the Essental Gull-billed Tern population nest            ooing    fothCooaoPond is used            River~.,s:-6lng replnish               Dcar                        r~iiatiofSyte (PDS nqualityiitnd on the internal dikes of the Main            v        9for- plant activities.Watr and enforced through the Texas Pollutant Cooling Reservoir. The U. S. Fish and Wildlife Service considers nesting   the-Main Cooling;'Reservoir via                                              permit program torestore andini of Gull-billed Terns in Texas uncommon. ntermittent pumping petiods.; S tam                                                       s                   a s      In ,1,99 The South Texas Project continues               SlMost'~of 'thr.-water'used. byhe 'the                                  State.fof Y6,a'.assumedjauth1 to monitor important wildlife species               Sot        iTxs ,,Piodjectsis nqee~'ded~-o'~rity 't-oadmrinister &i'~ip-rnnt to detect population changes. Informal ondense steamifandeerovide cooling                                         the. fedefal NationaJPollutaIt'Di observations by station and Reliant       forlplant generating 'sysfen~i&. The ;.charge Eliiniiiatin Systeni(NPDES)
Resources, Inc. personnel continue           ii'ajbrity of thiswater is drawnfrom'--.. program. :Accordingly,'federal an'd to indicate that the site provides           iiid~returned toihthestton's 'Maim-                                     state requiren'ents'were'coisolidated high-quality habitat in which a wide range of animals live. The site continues to attract extensive wildlife populations, offering a refuge for resident species as well as seasonal migrants. The lowland habitat located between the Colorado River and the east bank of the Main Cooling Reservoir offers a significant sourceof water year-round. These natural resource areas, in concert with numerous additional wetland and grassland areas, offer the key ingredients necessary to sustain the extensive wildlife pop-ulation at the South Texas Project.                                                                                     '4.'
STP Nuclear Operating Company 4 -2

IR Non-RadiologicalEnvironmentalw prail                                                                            Rpr of Intent for transfer from the Gener-al Permit to the Multi-Sector General Permit with the United States Environ-mental Protection Agency in 1998.
The Texas Natural Resource Conservation Commission issued a TPDES Multi-Sector General Permit in August of 2001. The station filed a Notice of Intent in November of 2001 to obtain coverage under the state permit and the station's Storm Water Pollution Prevention Plan was modified accord-ingly to reflect these changes. This plan is a working document that is revised whenever there is a change in design, construction, operation or maintenance that has a significant effect on the potential for the discharge of pollutants from the station.
In order to regulate storm water pollution resulting from construction activities, the Texas Commission in November of 2000 into one waste-      charge permits or otherwise. Wastewater     on Environmental Quality further water discharge permit for the station   discharges met state and federal water      requires authorization of storm water under the TPDES permit program.          quality standards demonstrating a           discharges from construction activities Under this permit program, the South      100 per-cent compliance record for         that entail the disturbance of one Texas Project monitors, records and      the year while conserving and maximizing    or more acres of land. Accordingly, reports the types and quantities of      efficient water usage at the station.       a separate Storm Water Pollution pollutants from wastewater discharges    No discrepancies were noted in the          Prevention plan was developed for to ensure that we meet or exceed         wastewater discharge permit compliance      the construction of a three-lane vehicle the stringent levels set in the permit. inspection conducted by the Texas           pull offarea with an additional overflow A monthly monitoring report is submitt-  Commission on Environmental Quality         parking area along the main plant ed to the Texas Commission on Environ-   at the station in 2003.                     access road that commenced in November mental Quality for wastewater dis-            In addition to the wastewater          of 2003.
charges. Reports identifying ground      discharge permit program, the Federal            Following a severe drought in and surface water use are also submitted Clean WaterAct, as amended in 1987,          1996, the Texas Legislature recognized annually to the Texas Commission         requires permits for storm water dis-       the need to address a wide range on Environmental Quality and Texas       charges associated with industrial          of state water resource management Water Development Board.                 activity. The South Texas Project           issues. In 1997, the Texas Senate Wastewater generated at the South   Storm Water Pollution Prevention            drafted legislation known as Senate Texas Project is processed and dis-      Plan, implemented in October of 1993,       Bill I to address these issues and charged to the onsite Main Cooling       ensures that potential pollution sources    to develop a comprehensive state Reservoir to be re-used by the station   at the site are evaluated, and that         water policy. Towards this end, this as cooling water for plant systems.      appropriate measures are selected           legislation required that the Texas No water was released from the re-       and implemented to prevent or control       Water Development Board create a servoir in 2003. The station con-        the discharge of pollutants in storm        statewide water plan that emphasiz-tinued its outstanding wastewater        water runoff. In September of 1998,         es regional planning. Sixteen plan-discharge compliance performance         the United States Environmental Pro-        ning regions were created, each task-record in 2003. Station conditions       tection Agency modified the storm           ed to prepare a regional plan for did not require site aquatic monitoring  water permit program to require facilities, the orderly development, manage-studies be conducted in 2003 nor         such as the South Texas Project, permitted  ment and conservation of water re-were any additional studies required     under the baseline general permit           sources. The South Texas Project by the United States Environmental       to obtain permit coverage under a           was chosen to represent the electric Protection Agency or the State of        multisector general storm water permit. generating utility interest for the Texas either by way of station dis-      Accordingly, the station filed a Notice     water-planning region that encom-STP Nuclear Operating Company 4 -3

2003 EnvironmentalReport Air Quality-Management passes the lower Colorado River Basin.      amounts of fossil fuel for backup           of firefighting training sessions is Plans subsequently submitted by each        and emergency equipment. Air emission       provided to the Matagorda County planning region were incorporated           sources at the South Texas Project          Environmental Services and the Texas into a State Water Plan in the year         fall under the scope of air pollution       Commission on Environmental Quality.
2001. However, water resource plann-        regulations promulgated under the           On five occasions, onsite fire extinguisher ing is a continuous process and the         Texas Clean Air Act, the Federal Clean      training was conducted for short periods Regional and State water plans must         Air Act and numerous associated amend-      on days not identified in the associated be updated every five years. The            ments that protect air resources from       open burn notifications. These permit South Texas Project continues to            pollution by controlling or abating         condition deviations were subsequently' actively participate in the Lower           air pollution an'd emissions. 'The          reported to the Texas Commission Colorado Regional Water Planning            major regulated air emission sources        on Environmental Quality.
Group to update the existing-plan           at the South Texas. Prject include               Title V Federal Operating by 2006. Additional information             one fossil-fueled boiler and various                         Permit regarding regional water planning           emergency diesel generators.                     In 1990, amendments to the Federal in Texas can be found on the website             The South Texas Project has one        Clean Air Act mandated a new per-maintained by the Texas Water Develop-      oil-fired auxiliary steam boiler available  mitting program to clearly define ment Board at http://www.twdb.state.-       to furnish steam for deaerator startup,     applicable air quality requirements tx.us/or at regionk.org.                    turbine gland'seals and radioactive         for affected facilities such as the The South Texas Project understands    liquid waste processing when steam          South Texas Project. This program that the water resources of the state       is not available from the nuclear           is commonly known as the Title V are a critical natural resource requiring   steam supply system. On two occasions       Operating Permit Program and is ad-careful management and conservation         in March of 2003 during operation           ministered by the state. The Texas to preserve water quality and availability. of the station's auxiliary boiler, flue     Natural Resource Conservation Com-Accordingly, the station continues          gas excess oxygen levels intermittently     mission (now known as the Texas to explore and support efforts focusing     fluctuated above the permit established     Commission on Environmental Quality) on the efficient use of water resources     range for manual operations. The            issued a Federal Operating Permit and reduction of water waste.               excess flue gas oxygen range establish-     in January of 2000 for the South Air Quality Management               ed in the permit is a control parameter     Texas Project granting authority to Air emission sources at the South           for operation of the auxiliary boiler.      operate identified emission units Texas Project fall under the scope          The condition-was corrected and no          at the station in accordance with of air pollution regulations promulgated    emission limits were exceeded. Correc-      applicable permit and regulatory under the Texas Clean Air Act and           tive actions were taken to prevent          requirements. The Texas Commission the Federal Clean Air Act and the           occurrence. These permit condition          on Environmental Quality revised numerous associated amendments.             deviations were subsequently reported       the permit in July of 2003 to add The purpose of these regulations            to the Texas Commission on Environmen-      applicable requirements regarding is to protect air resources from pollution  tal Quality. In addition to the auxiliary   minor new source review authoriza-by controlling or abating air pollution     steam boiler, a number of fossil-fuel-      tions. In accordance with the South and emissions. Regulated emission           ed diesel generators are located onsite. Texas Project's Federal Operating sources at the South Texas Project          These diesels are designed to pro-          Permit's reporting requirements, those include a fossil-fuel boiler, emergency     vide emergency power to various             deviations from permit conditions diesel generators, fire-fighting train-     plant systems-or buildings in the           discussed previously were reported ing and other minor maintenance             event of a loss of power. This equip-       to the Texas Commission on Environ-equipment and activities.                   ment is not normally needed for daily       mental Quality.
Fossil-Fueled Emission Sources             operations and the station does not                Non-Radioactive Waste Unlike conventional electrical         use it to produce electricity for distribu-              Management generating stations, nuclear power          tion. Routine maintenance runs are               Solid waste management procedures plants do not burn petroleum fuel.          conducted to ensure availability if         for hazardous.and non-hazardous Therefore, the South Texas Project          needed and for equipment mainte-            wastes generated at the South Texas produces virtually no greenhouse            nance.                        -             Project ensure that wastes are properly gases or other air pollutants that                 Fire-Fighting Activities             dispositioned in accordance with are the typical by-products of industrial        The South Texas Project conducts       applicable federal, state~and local production processes. The use of            onsite training of selected employees       environmental and health regulations.
emissions-free' nuclear power is a          on proper fire-fighting techniques.         By regulatory definition, solid waste significant contributor to the preservation Most onsite instruction consists of         includes solid, semi-solid, liquid of our community's clean air resources. training on the proper use of a fire        and gaseous waste material. The The South Texas Project uses small          extinguisher. Advance notification          Texas Commission on Environmental STP Nuclear Operating Company 4 -4

Non-RadiologicalEnvironmental                                                              .
Operating Report tion of several tons of paper each 2003 Nonradioactive Waste Management                                         year. In 2003, the station collected South Texas Project                                         approximately 36 tons of paper for recycling. Every ton of paper recycled saves approximately 17 trees, el-Recycle                                        iminates approximately three cubic 76.0%                                         yards of landfill material and saves enough energy to power the average home for six months. The station continues to explore new areas where recycling may be expanded or initiated.
Non-radioactive solid waste that cannot be shipped for recycling is shipped for disposal. Municipal-type trash is transported to the county Incineration &               Landfill 19.2%                          landfill transfer station for appro-Fuel Blending 4.8%                                                    priate disposition. Construction-related non-combustible, inert debris, if generated, is placed in the onsite Figure 4-1                                        landfill. Waste minimization and Quality, which administers the Texas         at the South Texas Project in 2003        source reduction efforts by employees Solid Waste Disposal Act and also            was limited to a maximum holding          allowed the South Texas Project to the federal Resource Conservation            period of 90 days. The Resource           achieve approximately an 8 1 percent and Recovery Act program, is the             Conservation and Recovery Act and         reduction in normal hazardous waste primary agency regulating non-radioac-       Texas Solid Waste Disposal Act also       generated at the site during 2003.
tive wastes generated at the South           require the use of proper storage         The volume of hazardous waste gen-Texas Project. The Texas Commission          and shipping containers, labels, mani-    erated at the station was sufficiently on Environmental Quality also regulates      fests, reports, personnel training,       low in 2003 to allow the station the collection, handling, storage and        a spill control plan and an accident      to re-classify as a small-quantity disposal of solid wastes, including          contingency plan. Plant personnel         generator early in 2004. Hazardous hazardous wastes. The transportation         routinely inspect areas throughout        waste accounts for only a small portion of waste materials is regulated by           the site to ensure wastes are not stored  of the waste generated at the South the United States Department of Trans-       or accumulated inappropriately.           Texas Project; however, minimization portation.                                        Station policies and regulations     and reduction of hazardous waste The South Texas Project was register-   encourage the recycling, recovery         generated where feasible remains ed with the Texas Commission on              or reuse of waste when possible to        an important goal at the station.
Environmental Quality as a large             reduce the amount of waste generated      (Reference Figures 4-2 and 4-3 )
quantity generator of industrial solid       or disposed of in landfills. Approxi-wastes in 2003, including hazardous          mately 76 percent of the industrial wastes. Texas Commission on Environ-         non-radioactive waste generated at mental Quality regulations require           the South Texas Project was recycled that indust-rial solid wastes generated      or processed for re-use in 2003. (Ref-at the South Texas Project be identified     erence Figure 4-1) The South Texas to the Commission and these are              Project ships waste oil, grease, electro-listed in the Texas Commission on            hydraulic fluid, adhesives, liquid Environmental Quality Notice of Regis-       paint and solvent for fuel blending tration for the South Texas Project.         and thermal energy recovery. Used The registration is revised whenever         oil, diesel fuels and antifreeze solu-there is a change in waste management        tions are sent to a recycling vendor practices at the site. Waste handling        for reprocessing. Lead-acid batteries and disposal activities are summarized       are returned, when possible, to the and documented in a waste summary            original manufacturer for recycling report for the South Texas Project           or are shipped to a registered battery that is submitted annually to the            recycler, thereby reducing the volume Texas Commission on Environmental            of hazardous waste that might other-Quality.                                     wise be generated. A site paper re-Hazardous waste accumulation            cycling program results in the collec-STP Nuclear Operating Company 4 -5

                                                      '%   2003 EnvironmentalReport Chemical Control Management The South Texas Project uses                          2003 Nonradioactive Waste Generation standard operating procedures, policies                                   South Texas Project and programs to minimize the generation of waste materials, control chemical Non-Hazardous usage and prevent spills.                                             Waste The South Texas Project also evaluat-                            96.2%     -
es chemicals and products proposed for use, which could come in contact with plant components. Site procedur-es address the evaluation, storage, use, spill control, and disposal require-ments of chemicals. These guidelines assist in reducing wastes, ensure proper                                                                           Universal Waste packaging for disposal and mitigate                                                                                     0.6%
the consequences of inadvertent spillage.
Hazardous Waste       Used Batteries The South Texas Project empha-                                                 0.2%                3.0%
sizes awareness training for spill prevention and maintains station                                                       Figure 4-2 readiness to respond should a spill occur. Spill response team members                         Hazardous Waste Generation Historical receive annual refresher training in                            Comparison South Texas Project hazardous material incident response.
No significant or consequential spills occurred in 2003.
25 20 1015 Environmental Protection Plan Status                              lo5 The South Texas Project's Environ-                  0 1997    1998      1999       2000      2001      2002    2003 mental Protection Plan was issued in March of 1989 to provide for the                                O Hazardous Waste from Cleanup of an Onsite Spill protection of non-radiological environ-
* Hazardous Waste mental values during operation of the South Texas Project. This report                                                 Figue 4-3 reviews Environmental Protection           unreviewed environmental questions                   No unreviewed environmental Plan non-compliances identified by         if it concerns:                                  questions were identified in 2003.
the plant in 2003 and the associated            I) A matter that may result in              Events that require reports to federal, corrective actions taken to prevent                a significant increase in any            state or local agencies other than their recurrence. Potential nonconfor-             adverse environmental impact             the Nuclear Regulatory Commission mities are promptly addressed, as                  previously evaluated in the              such as the Title V Operating Permit identified, to maintain operations                 Final Environmental Statement            program deviations discussed earlier in an environmentally acceptable                   related to the Operation of              in this report are reported in accord-manner. The station uses its Correc-               South Texas Project, Units               ance with the applicable reporting tive Action Program to document                     I and 2 (Docket Nos. 50-498             requirements. The Nuclear Regula-these conditions and track corrective              and 50-499), environmental               tory Commission is provided with actions to completion. Internal assess-            impact appraisals, or in any             a copy of any such report at the ments, reviews and inspections are                 decisions of the Atomic Safety           time it is submitted to the cognizant also used to document plant compliance.            and Licensing Board; or,                 agency. If a non-routine event occurs This report also reviews non-              2) A significant change in eff-             and a report is not required by another routine reports submitted by plant                 luents or power level; or,               agency, then a 30-day report to the personnel and any activities that               3) A matter not previously reviewed         Nuclear Regulatory Commission is involved a potentially significant                 and evaluated in the documents           required by the Environmental Protec-unreviewed environmental question.                 specified in (1) above, that             tion Plan. No such 30-day or other A proposed change, test or experi-                 may have a significant adverse           non-routine report of this type was ment is considered to present an                   environmental impact.                    required in 2003.
STP Nuclear Operating Company

U RadiologicalEnvironmentalI-ntroduction and Summary here were two items of interest identifie'd by this program during 2003. A short Tdescription of them follows.
O Cobalt-60 levels in reservoir bottom sediment samples vary but remain within the expected range. The amount-of Cobalt-60 in the Main Cooling Reservoir has decreased because of additional equipment installed to reduce radioactive effluents.
* Low level tritium was monitored in shallow aquifer ground water samples.
The shallow. well was located within approximately seventy-five yards of the Main Cooling Reservoir dike base. The positive values, measured since 1999, increased during the year, as anticipated; but remained less' than in the Main Cooling Reservoir.                                    -
Operation of the South Texas Project continues to have no detectable radiological impact offsite. Samples analyzed from the off-site sampling stations continue to show no radiological contribution from' plant operation. The radiological doses received by.the general public from plant operations were less than one millirem which is insignificant when comparedito the 360 millirems average annual radiation exposure to people in the United States from natural and medical sources.
STP Nuclear Operating Company 5 -1

71- " 1 Radiologica tEnvironmentalIOperatingReport Program: Des~cription he South Texas Project initiat-. the minimum sampling locations and                                   be noted that this practice is not
       *        -ed a comprehensive preopera- frequency oficollection.                                                 always possible or meaningful with tional Radiological Environ- Sampling locations consist of indicator                                  all sample types. Fluctuations in fl        mental Monitoring Program and control stations. Indicator stations                                    the concentration of radionuclides S         in July 1985. That program are locations'on or off the site that                                      and direct radiation exposure at in-terminated on March 7, 1988, when may be infliuenc'ed by plant discharges                                             dicator stations are evaluated in relation the operational program was implement-. during plant operation. Control stations                                      to historical data and against the ed. The pre-operational monitoring are located beyond the measurable                                                  control stations. Indicator stations program data forms the baseline against influencexof thie-South Texas Project                                         are compared with characteristics which operational changes are measured. or'any other nuclear facility. Although                                       identified during the pre-operational Critical pathway analysis requires most samples analyzed are accompani-                                               program to monitor for radiological that samples be taken from water, ed by a control sample, it should                                                   effects from plant operation. Several air, and land environ-                                                                                                                        sample'identification ments. These samples                                                                                                                        lmethods are used to are obtained to evaluate -                                                                                                                   'implement the pro-potential radiation                                                                                                                           gram. Figures 6-1 exposure. -Sample                                                                                                                             and 6-2 are maps that types are based on                                                                                                                            identify permanent established pathways                                                                                                                          sample stations. Des-and experience gain-                          _                                                                                                cripions of sample ed at other nuclear                                                                                                                            stations shown onFigure facilities. Sample                                                                                                                             6-1 and 6-2 are found locations were deter-                                                                                                                          in Table 2. Table 2 mined after consider-                                                                                                                          also includes addicc ing site meteorology,                                                                                                                          tional sampling loc-Colorado Riverhydro-                                                                                                                          ations and media types logylocaldemography                                                                                                                            that may be used for andlanduse. Sampling                                                                                                                           additional informa-locations are furthere                                                                                                                         tion. Figure 6-3 illu-evaluated and modifi-                                                                                                                          strates the zones used ed according to field                                                                                                                          when collection loca--
and analysis exper-                                                                                                                           tions are not perma-ience. Table i lists                                                                                                                           nent sample stations.
flflybbUITVULbUUL ni                                             iiUU
           ;. nvironmental saiples-from .comparisonillustratesthatplantoperationiV                                      scent dosirneters located at 43 sites
          -i.-areas surrounding th Sotth
* arenothavinganimpactonairparticulate& The'natural direct gamma nlatlo Texas roject5iniiet6mhlcate                             activity even at the Sensitie Indicato            varesaccording to location because no1significant radiobogicaleffectsjStations                                      (#1s,#1'5,-   and#16).The-se ,ofdiffer6ncesinthenaturalradioactive o'into'rto.-Anaiyticais,,''t'at'ic'ns' are'elo'c-at'e'd:'nea'r thse pla~nCtifa~ilin1~t-osu
   'valti&frd'offsite indicator sample ->.and are Ilocated
                                             .:.r 1;4sam        *,~    -                 t d' downwindI fe fromfthe
                                                                                                                  . l.  :            R.
the
                                                                                                                        -content anda~hyge5-f,D
:vetaifoncover.
                                                                                                                                          -. =.;-.i        .. ..-;tidw;cov.
                                                                                                                                                                     *t        .
siatonsd        ontinue to trend!wlth jtheD                     %:Fplani        e    on`t epgura6-5;                                icoiparesi        _th etamount
   ,control stations. ,Ons iti indicator Fdirectidh>nThe betahativity-measured                                         .of directgamma 'adiaiion measure
               's-?iitinueidto          ;w'c're' 'o dsaipl                              in'thKeairjparticulate sapples isfrm                t the plant in6ethe o'urt 'quarteri edcres'e iifinmeasu'red         v    liiesttleir              natuAl         taaioivehaterialSs                     6ff 8 'fothre&'ifferennt'typesire              pes expadtedrra                                                       ad i o ac                                                                -J exp cte a ra te s                -prfh.                                    inTh-e' 9otions:                      rta          We         t                  Control  -hStation's]
Av--eeragerquarterybeta activityprform gamma analysis on quarterly aregreater than                                                           miles fr               e from three onsite indicator stations composites of the airparticulate samples -',,site and are in the idrection 'of the anda singlecontroilstation foraair t'odeterm'in if'an a6ctivity is from leastprevailingwinds (Stations 23 particulate samples have been compared "the South                       S        Texas Proj ect The gamma and #37),The Sensitive In historically from 1988 through 2003' -analysis                   1             revealedthat    it was all natural -Stations are in the 'directions that (see'Figur'e 6-4)'Te average of radioactivity                                                                       the wnd blows most often'andlare the onsite indicatorstre'nds-closely                                    Directga7          radiatiois monitore       on mi e fromerplants                               onw with th offsite control vhiue'sThe                                in the environmentiby thermolumineii- Fam               mto' 'Market Road 521 (Stations j-,;,b.^.i~eoro
                                    ;    v..           .?!                 i .--ti STPNuclear:OperatingCompany 6 -1

                         '2003           EnvironmentalReport Designated Sample Locations
* L <*
I       I
   ,i   .
      '44.
-b    _,X~
A*
Figure 6-1 STP Nuclear Operating Company 6 -2

Radiological Environmental d)erating Report Designated Sample Locations (On Site Sample Locations)
Figure 6-2 STP Nuclear Operating Company 6 -3

a2003 EnvironmentalReport Zone Location Map N
The zone station number is determined in the following manner:
* The first character of the station number is 'Z' to identify it as a zone station.
* The second character is the direction coordinate numbers 1-8.
* The third character is the distance from site numbers 1-6.
Figure 6-3 STP Nuclear Operating Company 6 -4

RadiologicalEnvironmental OperatingReport Analysis of Results   and Trends (Continued from page 6-1)
Historical Comparison of Average Quarterly Beta Activity from Indicator and Control Air Samples 1988 - 2003 0.03500 0.03000      ......----
t 0.02500-      1 : 050              _      ______     A AA           AA t  0.02000 -                                A m 0.01500 U3 0.01000 0.00500   --    ~         L-_                                             _   -
ro 0.00000 1988               1991           1994            1997           2000          2003
                                -Station    #001, #015 & #016 Average of Onsite Indicators
                                -Station    #037 Offsite Control Figure 6-4 STP Nuclear Operating Company 6 -5

                                                =>->2003EnvironmentalReport Environmental Dosimeter Comparisons 22
                 -Average    of Indicator Stations              Average of Control Stations              Sensitive Indicator Stations 20 18 16 o   14
  ~12                           Unit #1 Criticality   - 03/08/88                   Unit #2 Criticality - 03/12/89 10 1985 1986 1987   1988    1989    1990   1991 1992   1993  1994   1995   1996    1997 1998  1999   2000    2001   2002    2003 Results by Quarter Figure 6-5 STP Nuclear Operating Company 6 -6

RadiologicalEnvironmental aperauingReport Historical Comparison of Cobalt-58 & Cobalt-60 in Main Cooling Reservoir Sediment 1986 - 2003 1800
                                                                                                                            -     Station #215:
1600                                                                                                                  Cobalt-58 Plant Discharge 1400                                                                                                                  Station #215:
Cobalt-60 Plant a                                                                                                                           Discharge
      '     1200                                                                ___
en               s           ......                                      hThe             Cobalt-58 activity inthe reservoir has decreased to
        *c'
        -    800   -_____b_                                                                                                 below  levels that can be detected. Statistical variations typical of material in a a      600                                                                                                          particulate form are seen in 1996 & 1997 Cobalt-60 values. The inventory of 400                                                                    -                                    Cobalt-60 has decreased since 1992 due to radioactive decay and reduced liquid effluents.
200          -----------
0 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 Figure 6-6 Calculated Cumulative Curies of Cobalt-60 in the Main Cooling Reservoir 3t60 ASSUMPTIONS:
: 1. Radioactive decay is the only mechanism for removal from the Main Cooling Reservoir.
: 2. The initial time for calculating the remaining radioactivity is July I of the year released.
Figure 6-7 STP Nuclear Operating Company 6 -7

i            2003 EnvironmentalReport Historical Comparison of Tritium Added to and Remaining in the Main Cooling Reservoir 1989 - 2003 4000 3500 3000 2500 C   1500 1000 500 0
1989       1990   1991     1"92     1993 1994        1995   196     1997        198    199    2000       2001    2002   2003 UTritium Released to the Main Cooling Reservoir   *Tritium Measured in the Main Cooling Reservoir Figure 6-8 Historical Comparison of Tritium Activity in Surface Water 1988 - 2003 30000 E     25000 0
20000 EW
:19&
15000 I-10000 5000-1908   1989   199  1991    9W2   1993   1994 1995 I96    W97   999   1999   2099  2001 2902   2003 r           E River Sam.ple Upstream of Plant (Offsite) #Q02
* River Sample Downstream of Plant (Offsite) #QO I
* West Branch of River (Onsite) #213                                   *Little Robbins Slough (Onsite) #212
* East Branch of Little Robbins Slough (Onsite) #211                   I Ditch NE of Main Cooling Reservoir (Onsite) #229 llMain Cooling Reservoir Blowdown (Onsite) #237
* Main Coolina Reservoir (Onsite) #216 Figure 6-9 STP Nuclear Operating Company 6 -8

RadiologicalEnvironmmental 3p7 tratigReport T      The Annual Land Use Census is performed to determine if any changes have occurred changes are needed in the Radiological Environmental Monitoring Program.
The census is performed by contacting to verify the nearest residents within five miles of the South Texas Project generating units in each of 16 sectors.
in the location of residents          area residents and local government            The nine sectors that have residents and the use of the land within five             agencies that provide the information.         within five miles and the distance miles of the South Texas Project                The results of the survey indicated            to the nearest residence in each sector generating units. The information               that no changes were required.                 are listed below.
is used to determine whether any                In addition, a survey is performed Nearest Residentsn Sector                 Distance                                    Location                                         '
a r miles) apE p r>  -                                _ _ _ _ _ _ __;-_      _ _ _ _ _ _ _ _ _ _-   _ _ _ _ _ _
ESE-                   3.561i SE W                   3-.
5                       ~--SelkirkIsland                     e SWrk                -~ 45                                         --CitruGrve~
WSW                    25           :                          -.              -=     --
_W                      45                                          F4i095.
V1NW44          ~       _4.0                                        AsbyBucke -Road NW                      4     .Mondrik                                            R6Sid=Z NWSW--;'                                                            Ru R          1ls`Ranch (FM 1468)         -    -
The following items of interest were noted du-ring the census 1   A 110 -acre wetland prairie project.            the second is five miles southwest         inter-laboratory measurement assurance continues to provide a habitat                  of the 'plant. The water supply            programs. These programs provide for migratory birds and waterfowl.              for the ponds is not affected by           samples that are similar in matrix The habitat is located northeast                the operation of the STP power             and size to those measured for the of the power plants and is easily               plants.                                    Radiological Environmental Monitoring accessible to the public.                             Quality Assurance                    Program.
Figure 6-10 summarizes the
* Colorado River water from below                   Quality assurance encompasses             results of these intercomparison pro-the Bay City Dam has not been               planned and systematic actions to              grams. Analyses consisted of radiochem-used to irrigate crops.         .    --
ensure that an item or facility will           ical measurements and'measurement perform satisfactorily. Reviews, surveil-      of direct radiation through the use
* No commercial dairy operates in             lance and'iudits' have determined              of thermoluminescent dosimeters.
Matagorda County and there is               that the prograams, procedures and             In addition, approximately twenty no agricultural milk source within          personnel perform satisfactorily.              percent of the analyses made are the five-mile Zone.'                             Quality; audits and independent           quality control samples that consist technical reviews help to determine            of duplicate, split and blind samples.
* There were no identified commercial         areas that'need attention and re-                        Radiochemical measurements vegetable farms located within              evaluation. Areas that need attention          must meet sensitivity requirements the five-mile Zone.                         are addressed-in accordance with               at the lower level of detection for the station's Corrective Action Program.       environmental samples. These stringent 1   Two commercial fish farms continue               The measurement capabilities              requirements were met in all samples to operate. One-is two miles west           of the Radiological-Laboratory are             presented in this report.
of the plant near FM 521 and                demonstrated by participating in STP Nuclear Operating Company 6 -9

                                         --     2003 EnvironmentalReport 2003 Radiological Laboratory Quality Assurance Program Performance 0-5% Difference 5-10% Difference 10-15% Difference 83 Total Analyses Figure 6-10 Program Deviations Deviations from the sampling pro-gram must be acknowledged and ex-plained in this report. During 2003 the following samples were not collect-ed or were unacceptable for analysis:
* Three out of thirty-six required broadleaf vegetation samples were not collected due to seasonal unavailability in February.
* Fourteen out of two hundred and sixty air samples were not con-tinuously collected for the full time interval due to equipment and power failures. However, all but two air particulate and one air iodine samples met the LLD requirements and the results are included in Table 3.
STP Nuclear Operating Company 6 -10

I RadiologicalEnvironmentaliwraingReport The minimum Radiological Environmental Monitoring Program is presented in Table 1. The table is organized by exposure pathway. Specific requirements like location, sampling method, collection frequency, and analyses are given for each pathway.
Table 1 Radiological Environmental Monitoring Program EXPOSURE: DIRECT RADIATION                                                                                          40 TOTAL SAMPLING STATIONS Sample Media, Number, Approximate Location and Distance of               Routine Sampling       Sampling and          Analysis        Minimum Sample Stations from Containment.                                              Mode               Collection            Type          Analysis Frequency                          Frequency Exposure Media: TLD.
16- Located in all 16 meteorological sectors, 0.2* to 4 miles.            Continuously            Quarterly       Gamma dose         Quarterly 16- Located in all 16 meteorological sectors, 2 to 7 miles.
6- Located in special interest areas (e.g. school, population centers), within 14 miles.
2- Control stations located in areas of minimal wind direction (WSW,ENE), 10-16 miles.
The inner ring of stations in the southern sectors are located within 1 mile because of the main cooling reservoir EXPOSURE: AIRBORNE                                                                                                    5 TOTAL SAMPLING STATIONS Sample Media, Number, Approximate Location, and Distance of              Routine Sampling          Nominal            Analysis        Minimum Sample Stations from Containment.                                              Mode               Collection            Type          Analysis Frequency                          Frequency Charcoal and Particulate Filters 3- Located at the exclusion zone, N, NNW, NW Sectors, 1 mile.               Continuous           Weekly or          Radioiodine       Weekly sampler               more              Canister:
1- Located in Bay City, 14 miles.                                           operations         frequently if           1-131 1- Control Station, located in a minimal wind direction (WSW),                                 required by        Particulate 10 miles.                                                                                   dust loading         SamDler:
Gross Beta      Following Activity   filter change Gamnma-          Quarterly Isotopic of composite (by location)
EXPOSURE: WATERBORNE                                                                                                  9 TOTAL SAMPLING STATIONS Sample Media, Number And Approximate Location of Sample                  Routine Sampling          Nominal             Analysis       Minimum Stations                                                                       Mode               Collection            Type          Analysis Frequency                          Frequency Surface I-  Located In MCR at the MCR blowdown structure.                        Composite sample          Monthly           Gamma-           Monthly Over a 1 month                               Isotopic
       .1- Located above the site on the Colorado River not Influenced           period (grab if by plant discharge (control).                                             not available)                               Tritium      Quarterly
        .- Located downstream from blow down entrance Into the                                                                            Composite Colorado River.
Ground 1- Located at well down gradient In the shallow aquifer.                       Grab               Quarterly         Gamma-           Quarterly Isotopic &
Tritium STP Nuclear Operating Company 6 -11

02003 EnvironmentalReport Table I Radiological Environmental Monitoring Program EXPOSURE: WATERBORNE              (CONTINUED)
Sample Media, Number And Approximate Location of Sample                     Routine Sampling          Nominal             Analysis           Minimum Stations            -                                                              Mode             Collection               Type            Analysis
                                                                      ;:    :-                       Frequency                               Frequency Drinkina Water 1- Located on site.                                                                Grab               Monthly          Gross Beta             Monthly
                                                                                                                        &   Gamma-1- Located at a control station.                                                                                           Isotopic Tritium           Quarterly Sediment                                                                                                                                   Composites 1- Located above the site on the Colorado River, not Influenced                   'Grab           Semi-annually           Gamma-         Semi-annually by plant discharge.                                                                                                        Isotopic 1- Located downstream from blowdown entrance Into the Colorado River.
1- Located In MCR.
* No municipal water systems are affected by STP. This sample taken from deep aquifer supplying drinking water to employees while at work.
EXPOSURE: INGESTION                                                                                                      7 TOTAL SAMPLING STATIONS Sample Media, Number And Approximate Location of Sample              K      Routine Sampling          Nominal             Analysis           Minimum Stations                                                                           Mode              Collection              Type            Analysis
                                                                                     -               Frequency                               Frequency Milk Grab          Semi-monthly            Gamma-          Semi-monthly
* when animals             Isotopic      when animals are on             and 1-131            are on
                                                                                       .              pasture;                                pasture; monthly at                              monthly at Broadleaf Veaetation                                                          -                   other times.                            other times.
2- Located at the exclusion zone, N, NW, or NNW sectors.                           Grab                                  Gamma-1- Located In a minimal wind direction.                                                           Monthly durng           Isotopic         As collected growing season           and 1-131 (When available)
Limited source of sample In vicinity of the South Texas Project. (Attempts will be made to obtain samples when available.)
 -  Three different kinds of broadleaf vegetation are to be collected over the growing season, not each collection period EXPOSURE: INGESTION (continued).
Sample Media, Number And Approximate Location of Sample                     Routine Sampling          Nominal             Analysis           Minimum Stations                                                                           Mode              Collection              Type             Analysis Frequency                               Frequency Fish and Invertebrates (edible portions) 1- Representing commercially or recreational Important species                    Grab          Sample semi-             Gamma-           As collected In vicinity of STP that maybe Influenced by plant operation.                                     annually            Isoopicon Is      c
                                                                                           -  .                               edible J- Same or analogous species In area not Influenced by STP.                                                                portions
   - Same or analogous species In the MCR.                                i Agricultural Products                                                              Grab              At time of           Gamma-           As collected
* havestIsotopic
                                                                                                        -harvest          Analysis In Domestic Meat                                                                                                          edible portion 1- Represents domestic stock fed on crops grown exclusively                        Grab                                   Gamma-           As collected within 10 miles of the plant.                                                                         Annually              Isotopic
* No sample stations have been Identified In the vicinity of the site. Presently no agricultural land is Irrigated by water Into which liquid plant wastes will be discharged. Agricultural products will be considered If these conditions change.
S TP Nuclear Operating Company 6 -12

RadiologicalEnvironmental OperalingReport Table 2 Sample Media and Location Description AI      AIRBORNE RADIOIODINE                                       -L5 CABBAGE AP -AIRBORNE PARTICULATE                                             L6      COLL RDGREENS-Bf1RESIDENT DABBLER DUCK--                                          M        BEEF MEAT.;
B2 RESIDENT DIVER'DUCK                                              M2 POULTRY MEAT, B3 MIGRATORY-DABBLER-DUC.                                           M3, WILD SWINE 1B4 MIGRATORY DIVER DUCK                                           M4' DOMESTIC SWINE
       'B5      GOOSE                                                      M5 EGGS B6'- DOVE                                                           M6 GAME DEER B. .QUAIL                                                           M7 ALLIGA
       -B8 PIGEON,'. t                      r        i  '                  M8 RABBIT,,
CC CRUSTACEAN CROY                                                        'OYSTER'..
CS CRUSTACEAN SHRIMP..'                                       -              -SOSOIL DR fDIRECT RADIATION;,                                               S1       SEDIMENT - SHORELINE-F1'- l FISH
                          -. PISCIVOROUS 5 - .   .'9   ' .~ --
                                                              --            S2       SEDIMENT.-BOTTOMa=-a
                                                                                       - .=  ., ~- -
FISH- CRUSTACEAN & iNSECT-                                                               -   -;
F2                                                                           PASTUREGRS
           -   FEEDERS               -                 4-----
F3 FISH "PLANTIVORES & DETRITUS.                                   W DR             N    WTER   - .'-
FEEDERS .--
LI      BANANA LEAVES                                             WGGROUND WAR L2      CANA LEAVES                                                WS SURFACE.WATER .-
L4 TURNIP    l~~I GREENS G E N                             L ;-t0. WW
                                                                         -f--  ;;4~,,nRELIEF WELL-WATER
                                                                           ;. .-<->f=<;AI:
6 -13                                            STP Nuclear Operating Company

_6-2OO0 3. En vironnme ntal1 R ep ort Table 2 Sample Media and Location Description MEDIA CODE          STATION      i,.VECTOR:                              LOCATION DESCRIPTION
                       -  CODE        (Apprximate)
DR AlAPVB VP SO             001     ~1miieN                         FM21 R002                         imileNNE                   FM 52 1 DR~                         003,-         imileNE-                  FMS21, DR.004                   4A !ril'N~~                     FM 521 DR005                               mieE 1                   STPVisitor Center onFM 521 DR Al AP SO                 06         3.5 fiiilesESE        -Site      near, Reservoir Makeup PumigFclt DR                          00         1SilsE                       MCR Dike DR                          008        0.5iijeSE                    MCRIDik DR                 ~        009_,.  ~~0.25inile S ~kMCR Dk DR                  ~       010     MO.25 i1e&SSW                  -MCR:Dike~
DR                          011         0.5         16~eSW         `MCR Dike.
R02                     1.5 mile WSWj              ;MCR~Dike.,z,,
R           '1       u-.mileW                       F   521 014:-l4 A1.5mfile WNW                  -FM52l1-6,.e---
DR AlAP.VBSO VP           *'-015           Miie                       M 521,_
DAlIAP VBSOV                            -ilfilile NNW"            FM 521 DR-07                      6.5 mie                    Bucky-M16 DRAIP             .018                            16.5ieNNEc        CelaniesePlant-FM[3057.
DR           K                19        5.5 milesNE &#x17d;~              FM2668 DR                          020        -5 miesEE                    FM2668&FM2078~'_,,-__
DR021                           5ieE.            ~FM 521&FM2668 DR'-022,7                                    mslesE0_2             quistar Chemiical Plant DR                 23
* 1          ei1s     >Itreto             fN 521 and FM 24 oFM MCR-STP Main Cooling Reservoir STP-South Texas Project Media codes typed in bold satisfy collection requirements described in Table 1.
  *Control     Station STP Nuclear Operating Company 6 -14

Radio logical Environmental                                                                     tiraug Report ITable 2 Sample Media and Location Description MEDIA CODE                  STATION          VETRLCIODSRPIN
____________CODE                     (Apiomae DR                              .024            4 Miles SSE~ MCR Dike DR                                  054mieS                           MCRI~ike~
DR                                  026         4fmiles SSW_.-        MCR Dike DR     .~.027,                                 2.5Mifle SW~:i         MCR Dike DR:02                                          5 Miles .WSW           FM 1095 & lisRa DR S0                               02            .5mileks W -I FM 1095 DR00                           6iles WNW--            Tres Palacios Oas FM 285-3 DR                                -,031      .5miesNWZ                  ison reek oad-DR                      ~032            -    ;3.5 rnilesNNW           FM 1468 DR AlAPSO                           03         14 miles NNE           Microwave Tower at end of Kilowatt Road in BayC DR                                   34        7.5mles ENE            Wadsworth Water Suppl Pum Station>
DR AI AP SO               ->035                8.5 mil es SSE         Magrd DR                                  036        9    ie      S<         olge Port DR Al AP VB VP SO                   037*       10 miles WS            Palacios CP&L Substation-DR                                  038~    _10.5 ml, NW~             CP&L Substation on TX71narBesg DROT P                39          9 mfles NW    rTX        35 under High Voltage Power lines near DR040                                `4.5 miles SW,          Citrus   rv                      .
DR                                  041        2.0 miiiis-ESE         MCR Dike                 -
DR042                                   85mlsNW           .- FM 459 at Tidhve      nermnedite School DR                   ..              43         4.5 mifes SE          Sie bonarit blowdownf outlet Ws                                  209         2 Miles ESE           Kelly Lake WD                    10               n Site.         Appovddrikn water supplyfo            T WSS12113.5                             miles S-        Sie, EBranch Little Robbins Slouigh MCR-STP Main Cooling Reservoir STP-South Texas Project Media codes typed in bold satisfy collection requi~rements described in Table 1.
* Control Station 6-15                                    STP Nuclear Operating Company

                                                          -2003Enviro'nmental Report Table 2 Sample Media and.LoCation Description MEDIA CODE          STATION                iECTOR                              LOCATION DESCRIPTION CODE       -       (Appoiae Ws Si                      212                   _4 mile'S~           Little Robbins Slough WSS                     213'                  4mniuies EE;         West BranchColdrado River FI (12,or 3) CC:       ~     24                 2.5 -miles SE         MCR at Makeup Water Discharge S2 ,                        250                        ieS            MCR a-t Circulating Water Dischare WS S2               ~      216`             -3.milesSSE               MCR at blowdown structure-F(19 2,or 3) CC CS QY    222                   >0mls                WtMagoda              a Wetban of Colorado Rver dwtreamoST WS S(l or 2)22                                  5-6mieS arss frmchainel marke #22 WD                 228*          : 14 miles NNE_              LieTulle Park public water supply 1 Drainage ditch north of the reservoir thatlempties into:
WsSi                       229                :2 3 miles ESE           Colorado River upstream of the reservoir makeup,~-
___     ____   ___   ___    pumping facility S~i                                                   Colorado River at point where drainage ditch (#229)
     ~
or 2                  230                 35Smiles ESE           emteinot SCI 2WS     23           Y 4mileSE            -        Colorado River where MCR blowdown discharge or,                                             -~channel     emptiies into it.
WG235                                 `3 8mile S:I Well B-3 directly south fromn MCR B8          236                       N/ASTP                 Protected Area.
WS'___                      237                3.7 miles SSE           Blowdown discharge channel from MCR 5(1 or 2) WS242                            `>10milesN-                Colorado River where it intersects Highway 35 WS              *                      ~          -~Colorado      River upstream of Bay City Dam at the, 24              ne       ~      Lower Colorado River Authority pumping station-Ws                         -247                   <1mile E~            Essential Cooling Pond F(1,2, or 3)                249*                                       dNA ontrol sample purchased from a local retailer SO                          250            -0.75     mile NWiz         Sewag sludge land farmigae (1,2,or 3) CC 2300                                 :~5:i    __STP          Main Cooling Reservoir, WW701                                   >4ilesi-z-            MCR ReliefWell#4            ---
WS          QO                        N/AJ~~IQuarterly composite of station #227 and/or altermate WS          Q02N/A~~                                   Quarterly composite of station #243'and/or altermate:
MCR-STP Main Cooling Reservoir STP-South Texas Project Media codes typed in bold satisfy collection requirements described in Table 1.
* Control Station STP Nuclear Operating Company 6 -16

I I RadiologicalEnvironmental 3 7raung                                                                   i                     Report 2003 Radiological Environmental Monitoring Program Analysis Summary An analysis summary for all of the required samples is given in Table 3. The table has been formatted to resemble a United States Nuclear Regulatory Commission industry standard. Modifications have been made for the sole purpose of reading ease. Only positive values are given in this table.
Media types are printed at the top left of each table, and the units of measurement are printed at the top right. The first column lists the type of radioactivity or specific radionuclide for which each sample was analyzed. The second column gives the total number of analyses performed and the total number of non-routine analyses for each indicated nuclide. (A non-routine measurement is a sample whose measured activity is greater than the reporting levels for Radioactivity Concentrations in Environmental Samples.)
The "LOWER LIMIT OF DETECTION" column lists the normal measurement sensitivities achieved which were more sensitive than specified by the Nuclear Regulatory Commission.
A set of statistical parameters is listed for each radionuclide in the remaining columns. The parameters contain information from the indicator locations, the location having the highest annual mean, and information from the control stations. Some sample types do not have control stations. When this is the case, "no samples" is listed in the control location column. For each of these groups of data, the following is calculated:
m The mean value of positive real values.
I    The number of positive real measurements / the total number of analyses.
* The lowest and highest values for the analysis.
The data placed in the table are from the samples listed in Table 1. Additional thermoluminescent dosimeters were utilized each quarter for quality purposes. The minimum number of other analyses required by Table 1 were supplemented in 2003 by four surface water samples, two groundwater samples, one drinking water sample, four rainwater samples and one shoreline sediment sample. Fish, vegetation, and wildlife samples vary in number according to availability but normally exceeded the minimum number required by Table 1.
TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Direct Radiation                                                                                Units: Milliroentgen/Standard Quarter ANALYSIS        TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS          LOCATION WITH HIGHEST ANNUAL MEAN          CONTROL LOCATIONS TYPE         /NONROUTINE           LIMIT OF                MEAN (f)             LOCATION              MEAN (f)        l           MEAN (f)'
MEASUREMENTS         DETECTION                  RANGE             INFORMATION              RANGE                       RANGE Gamma                174/0                _           1.4E+01 ( 165/ 165)          I mile W          1.8E+01 (5/5)              1.6E+0I ( 9/ 9) l(.2E+01 - 2.OE+- IO)         (#013)       (1.7E+01 -2.0E1+01)        (1.4E+01- 1.8E+01)
      *  (0 Number of positive measurements / total measurements at specified locations.
TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Airborne Radioiodine                                                                               Units: Picocuries per Cubic Meter ANALYSIS       TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS          LOCATION WITH HIGHEST ANNUAL MEAN           CONTROL LOCATIONS TYPE          /NONROUTINE          LIMIT OF                MEAN (0*             LOCATION              MEAN (f)-                   MEAN (0' MEASUREMENTS        DETECTION                  RANGE             INFORMATION              RANGE                       RANGE Iodine-131                 259/0            8.5E-03              -- ( 0/207)                                                            -- ( 0/ 52)
      *  (f) Number ofpositive measurements / total measurements at specified locations.
STP Nuclear Operating Company 6 -17

_-2003 EnvironmentalReport TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Airborne Particulate                                            -                                           Units: Picocuries per Cubic Meter ANALYSIS         TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS              -   LOCATION WITH HIGHEST ANNUAL MEAN          CONTROL LOCATIONS TYPE           INONROUTINE,         LIMIT OF                MEAN (f)*                    LOCATION             MEAN (f)*                     MEAN (f)'
MEASUREMENTS         DETECTION                   RANGE                    INFORMATION             RANGE                         RANGE GrossBeta                   258/0            1.5E-03         2.3E-02(206/206)                   14 milesNNE      2.4E-02( 52/ 52)           2.3E-02( 52/ 52) 7.4E 6.1E-02)     -             (#033)        (7.4E 5.7E-02)        (7.5E 6.4E-02)
Cesium-134                   20/0            3.4E-03             -     ( Of16)                          _                                              ( 0/
Of 4)
Cesium-137                   20/0            3.0E-04             -    (   0/ 16)                                                                     (    Of 0/     4)
Manganese-54                 20/0            3.3E-04             -       0/16)                                                                   -   (    Of 4) 0/
Iron-59                      20/0            I.SE-04             _-    ( 0/l6)                          _                                       -(        0/ f- 4)
Cobalt-58                    20/0            4.8E-04                . ( 01 16)                   :                                                   (    O 0/     4)
Cobalt-60                    20/ 0           3.4E-04                   ( 0/16)
Of            -                                                        -(        01 4)
Zinc-65                      20/0            7.7E-04             _. ( 0/16)                            _                   _                       _ ( 0/ O      4)
Zirconium-95                 20/0            9.2E-04               _ ( 0/16)                                                                              0 f-( 4)
Niobium-95                   20/0            8.4E-04             -(      0/116)                                                                       ( 0/O f- 4)
Lanthanum-140                20/0            4.4E-03             --    ( 0/16)                                                                         ( 0/
O f- 4)
Barium-140                                                                  '   --
(f) Number of positive measurements / total measurements at specified locations.
TABLE 3
            - 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Surface Water                                                                                                  Units: PicoCuries per Kilogram ANALYSIS        TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS            -     LOCATION WITH HIGHEST ANNUAL MEAN           CONTROL LOCATIONS TYPE           INONROUTINE          LIMIT OF                 MEAN (f)*                    LOCATION             MEAN (f)-                     MEAN (f)*
MEASUREMENTS        DETECTION                    RANGE                   INFORMATION              RANGE                         RANGE Hydrogen-3                    12/0           1.7E+02           9.9E03( 4/ 8)                     3milesSSE          9.9E03( 4/ 4)                -         0 O( 4)
(8.1 E03 - 1.1 E04)                   (#216)         (8.1E03 - 1.1E04)
Iodine-131                   40/0            4.5E+00             -(       0/ 27)                       _-                                       -(        0/     13)
Cesium-134                   40/0            1.7E+00                      0/27):
O-(                .-                                                       ( 0/13)
Cesium-137                   40/0            1.6E+00             -     ( 0/27)                        -                   -                     -     ( 0/13)
Manganese-54                 40/0            1.5E+00             -     ( 0/27)                                                                  -(        0O f 13)
Iron-59                      40/0            4.9E+00             -     ( 0/27)                                                                        ( 0O f 13)
Cobalt-58                    40/ 0           1.6E+00                   ( 0/27)                                            -_                    -     ( 0/13)
Cobalt-60                    40/0            1.6E+00                  (0 1 27)               .                                                  -(0/13) O f Zinc-65          '           40/0            3.3E+00            '-(       0/27) i              -           -                                    -(         013)
Zirconium-95       -         40/0            2.9E+00             -     ( 0/27)-                       --                                        -(         0/ 13)
Niobium-95                   40/0            1.9E+00                     '-(
0127) -           ,                                                    - (       0/13)
Lanthanum-140                40/0            3.8E+00             -        0 27)
O(                                                                    -     ( 0 f- 13)
Barium-140                 ____maumn        totalmeasurementsatspecifiedlocations.'mr
    * (f) Number of positive measurements / total measurements at specified locations.
STP Nuclear Operating Company 6 -18

II RadiologicallEnvironmental OfPeratingReport TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Drinking Water                                                                                            Units: PicoCuries per Kilogram ANALYSIS         TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS           LOCATION WITH HIGHEST ANNUAL MEAN            CONTROL LOCATIONS TYPE            INONROUTINE          LIMIT OF                MEAN (O-              LOCATION               MEAN (f).                   MEAN (f)'
MEASUREMENTS        DETECTION                  RANGE              INFORMATION                RANGE                      RANGE GrossBeta                    2510           2.0E+00           3.4E00( 91 13)             14milesNNE          3.4E00( 121 12)           3.4E00( 12/ 12)
(2.5EOO - 4.6E00)              (#228)           (2.4E00 - 4.4E00)         (2.4E00 - 4.4E00)
Hydrogen-3                    8/0           2.6E+02              -(     0/ 4)                 _                     _                      _ ( 01 4)
Iodine-131                   25/0           3.3E+00                _ ( 0/13)                  _                     _                         ( 0/ 12)
Cesium-134                   25/0           2.OE+00                _ ( 0/   13)               _                     _                         ( 0/12)
Cesium-137                   25/0            I.8E+00               _ ( 0/13)                  _                     _                         ( 0/ 12)
Manganese-54                 25/0            1.8E+00               _ ( 0/ 13)                 _                     _                         ( 0/ 12)
Iron-59                      25/0            5.OE+00               _ ( 0/   13)               _                      _                     _  ( 0/ 12)
Cobalt-58                    25/0            1.8E+00               _ ( 0/   13)               _                      _                     _  ( 0/ 12)
Cobalt-60                    2510            1.9E+00               _ ( 0/13)                  ---                                             ( 0  12)
Zinc-65                      25/0           3.8E+00                _ ( 01   13)               _                      _                     _  ( 0  12)
Zirconium-95                 25/0            3.2E+00               _ ( 0/   13)               ---                                          -(   0  12)
Niobium-95                   25/0            2.IE+00               _ ( 0/ 13)                                        _                        ( 0/ 12)
Lanthanum-140                25/0            3.2E+00               _ ( 0/   13)               _                      _                        ( 0/ 12)
Barium-140 (f) Number of positive measurements / total measurements at specified locations.
TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Sediment-Shoreline                                                                           Units: Picocuries per Kilogram dry weight ANALYSIS         TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS           LOCATION WITHI HIGHEST ANNUAL MEAN           CONTROL LOCATIONS TYPE           /NONROUTINE          LIMITOF                 MEAN (fI              LOCATION               MEAN (f)                    MEAN (f)-
MEASUREMENTS        DETECTION                  RANGE             INFORMATION                RANGE                       RANGE Cesium-134                    5/0           2.0E+01              -   (  0/  3)                                      -_                          0/  2)
Cesium-137                    510            1.2E+01          2.0E01( I/ 3)               6 miles SE          2.OEO1( I/ 3)                   ( 01 2)
(2.OEO I - 2.OEO )             (#227)          (2.OEO I - 2.OEO I Manganese-54                  510            1.6E+01             -(     0/ 3)                 _                      _                     _  ( 0/  2)
Iron-59                       510            7.9E+0I             _   (  0/ 3)                  _                                           _  ( 0/ 2)
Cobalt-58                     510            I.9E+0I             _   ( 0/    3)               _                       _                    _  ( 01 2)
Cobalt-60                     510            I.9E+0I             _-  ( 0/    3)               _                                               ( 0/ 2)
Zinc-65                       5/0           4.OE+01              -(     0/  3)                _                       _                       ( 0/  2)
Zirconium-95                  5/0            4.IE+01             -(     0/  3)                _                       _                       ( 01 2)
Niobium-95                    5/0            4.OE+01              _  ( 0/   3)                _.                      _                       ( 0/  2)
Lanthanun-140                 5/0            1.8E+02             -(     0/  3)                _                       _                       ( 0/  2)
Barium-140 (f) Number o0positive measurements I total measurements at specifed Iocations.
STP Nuclear Operating Company 6 -19

                                                            -w2003Environmental[Report TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Rain Water             _                                               -                                         Units: PicoCuries per Kilogram ANALYSIS         TOTALANALYSES            LOWER        INDICATOR LOCATIONS                     LOCATION WITH HIGHEST ANNUAL MEAN          CONTROL LOCATIONS TYPE            INONROUTINE          LIMIT OF               MEAN (1)*                         LOCATION           MEAN (f)-                 MEAN (ft' MEASUREMENTS         DETECTION                 RANGE                        INFORMATION             RANGE                      RANGE Hydrogen-3                    310            2.5E+02             --   ( O/ 3)                     .            _                                   no samples Iodine-131                    410            4.5E+00                _ ( 01 4)         .                .                                           no samples Cesium-134                    410             I.9E+00            -(       01 4)                .                                                   no samples Ccsium-137                    410             1.8E+00            -    ( 0t 4)          ,            .                       -                      nosamples Manganese-54                 4/0             1.7E+00                  (-(-01 4)                        -       _                                   nosamples Iron-59                      410             4.7E+00             -(       01 4)                               -                                    nosamples Cobalt-58                    410             1.8E+00             -(       01 4)                             ;                                      no samples Cobalt-60                    4/0             1.8E+00             -        0 4)
O(                                                                       no samples Zinc-65                      4/0             3.6E+00             -(       0    4)     .                                                            no samples Zirconium-95                 4/0             3.3E+00             -(       01 4)                                             -                      no samples Niobium-95                   4/0             2.OE+00             -(       01 4)                     .         -                                    no samples Lanthanum-140                4/0             3.7E+00             -(       01 4)                  .                                                 nosamples Barium-140                                                                   :    i        :
(f) Number of positive measurements I total measurements at specified locations.
TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Ground Water (On site test well)                                                                                 Units: PicoCuries per Kilogram ANALYSIS         TOTAL ANALYSES           LOWER        INDICATOR LOCATIONS                     LOCAnON WITH HIGHEST ANNUAL MEAN           CONTROL LOCATIONS TYPE           INONROUTINE          LIMITOF                 MEAN (f) ,                        LOCATION           MEAN (f)*                 MEAN (f)
MEASUREMENTS          DETECTION                 RANGE                   -INFORMATION                 RANGE                      RANGE Hydrogen-3                   6/0             2.6E+02           1.2E03 ( 6/ 6)-                        3.8 miles S     12E03( 6/ 6)                 no samples
(.0E02 - l.8E03)                              (#235)    (8.0E02 -1.8E03)
Iodine-131                   6/0             4.1E+00             -(       01 6)                               -                                    nosamples Cesium-134                   6/0             1.9E+00             -(       0l 6)                          .      _                                  nosamples Cesium-137                    6/0             1.7E+O0            -(       0/-6)       -                        _                                   no samples Manganese-54                  610            1.7E+00             -(       0/ 6)                   :      .                                         no samples Iron-59                       610            4.9E+00             -(       01 6)                   .      .                                         no samples Cobalt-58       -             6/0            1.7E+00             -        0 O(   6)                              _                                   no samples Cobalt-60                     6/0            1.7E+00             -        O(
0 6)                                -                                    no samples Zinc-65                      6/0             3.5E+00             -(       0l 6)                               -                                    no samples Zirconium-95                  6/0            3.1E+00             -   ( 0/,6))%                     '  -                                            no samples Niobium-95                    6/0            2.OE+00              _ ( 0/ 6)           ._                                                           no samples Lanthanum-140         -      6/0             3.5E+00               _ ( 01 6)        -                    .      _                                  no samples Barium-140            _                   __
(f) Number of positive measurements / total measurements at specified locations.
STP Nuclear Operating Company 6 -20

I I RadiologicalEnvironmental-OperautigReport TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Mediumn: Sediment-Bottom                         _                                                     Units: Picocuries per Kilogram dry weight ANALYSIS         TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS             LOCATION WIMh HIGHEST ANNUAL MEAN           CONTROL LOCATIONS TYPE            /NONROUTINE         LIMIT OF                 MEAN (1)*                LOCATION              MEAN (f)-                 MEAN (f)
MEASUREMENTS        DETECTION                   RANGE              INFORMATION                RANGE                      RANGE Cesium-134                     2/ 0         2.9E+01              -     ( 0/      2)                                    _                     no samples Cesium- 13 7                   210          2.9E+0I1           4.0E01 ( I/ 2)                I mile SW         4.0E01( I / 2)               no samples (4.0E01 - 4.0E01)                (#215)         (4.OEOI- 4.OEO I Manganese-54                   2V0          2.2E+01               _ ( 0/ 2)                      _.                                         no samples Iron-59                        2V0           8.IE+01              _    ( 0/      2)              _.                                         no samples Cobalt-58                      2/0          2.4E+OlI.                  ( 0/      2)              __                                          nosamples Cobalt-60                      2/0           I.9E+01           2.5E01 ( 2/          2)       1 mile SW         2.5E01 ( 2/     2)            no samples (2.2E01- 2.9E01 )                (#215)         (2.2E01 - 2.9E01 )
Zinc-65                        2/0          4.9E1+0 1            _     ( 01 2)                     _                   _                     no samples Zirconium-95                   2/0           5.1E+01             __ ( 0/         2)                                                          no samples Niobiuma-95                    2/0           4.4E+01             -(        0/    2)              _                     _.                    nosamples Lanthanum-140                  2/0           1.3E+02             -(        0/    2)                                    _                     no samples Barium -140                 _   _ ___
(f) Number of positive measurements I total measurements at specified locations.
TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Banana Leaves                                                                                 Units: Picocuries per Kilogram wet weight ANALYSIS         TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS             LOCATION WITH HIGHEST ANNUAL MEAN           CONTROL LOCATIONS TYPE           /NONROUTINE          LIMITOF                 MEAN (f                  LOCATION              MEAN (0-                  MEAN (f)
MEASUREMENTS        DETECTION                   RANGE               INFORMATION                RANGE                     RANGE Iodine-131                   220             1.2E+01              _    ( 0/ 15)                   _                     _                 _. ( 0/ 7)
Cesium-134                   22/0            1.6E+00             -     (      /I15)                                                       --   ( 0/    7)
Cesium-137                   22/0            1.3E+00                   ( 0/ 15)                  ._                                       _
                                                                                                                                                 -(      0/   7)
Manganese-54                 22/0            1.5E+00                   ( 01 15)                  ._                     _                 _-(     01 7)
Iron-59                      22/0            76E+00              _     ( 01 15)                  ._                                       _    (  0/   7)
Cobalt-58                    22/0            1.8E+00             -     ( 0/15)                   __                                       _    (  0/ 7)
Cobalt-60                     22V0           2.5E+00               _ j     0115)                   _                                      _    (  0/   7)
Zinc-65                       22/0           4.7E+00                  ( 0/       15)             ._                     _                 _.(     0/   7)
Zirronium-95                  22V0           3.2E4+00            __ (      0/15)                                       -(                         0/   7)
Niobium-95                   2210            2.3E+00             __ ( 0/I1)                                                               _-- ( 0/     7)
Lanthanum. 140                22V0           4.4E+00             __ ( 0115)                        _                   _.                 _- ( 0/      7)
Barium-140
           * (f) Number of positive measurements / total measurements at specified locations.
STP Nuclear Operating Company 6 -21

a2003 EnvironmentalReport TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Cana Leaves            _                  _      _-___                               ._Units:                              Picocuries per Kilogram wet weight ANALYSIS       TOTAL ANALYSES             LOWER          INDICATOR LOCATIONS                            LOCATION WITH HIGHEST ANNUAL MEAN              CONTROL LOCATIONS TYPE          tNONROUTINE             LIMITOF                   MEAN (f)*                              LOCATION               MEAN (0,                       MEAN (f' MEASUREMENTS          DETECTION                       RANGE                            INFORMATION                RANGE                             RANGE Iodine-131                   9/0               9.5E+00                  _    (0,6),                  -   , ,.           --        .        -.                      -      ( 0/ 3)
Cesium-134                   9/0               2.8E+00               *_ ( 0t6)                 ,            ,                              -                     __ ( o/ 3)
Cesium-137                   9/0               2.3E+00               -(0t            6)                _                                   -                     __(         0/ 3)
Manganese-54                 9/0               2.6E+O0               -       (   0/6),                                                      _                       - (      0/ 3)
Iron-59                      9/0               1.2E+0I               -(0/.6)                                          -                     _       .            -(          0/3)
Cobalt-58                    9/0               2.9E+-0               -(          0t 6)                                -                   -                      -(          0tf. 3)
Cobalt-60                    9/0              4.5E+00                -(          0/ 6)
* _                                    (   0/ 3)
Zinc-65                     9/0                8.0E+00               -(0/            6)                               _                   -                          (0/ Of       3)
Zirconium-95                9/0               4.9E+00                -(         0/   6)                   -                   -                                 -        (   0/ 3)
Niobium-95                  9/0               3.4E4-00                      ( 0/ 6) ,,                  .                                                       -     (      0/ 3)
Lanthanum-140               9/0               4.6E+00                _      (   0/ 6) ,                       ,,                          -                     _            0/ 3)
Barium-140                                                                                                    ;             .
    * (f Number of positive measurements   /  total measurements at specified locations.
                                                                               -  ~.TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Collard Greens _                            ._,_._-,___-___Units:Picocuries                                                          per Kilogram wet weight ANALYSIS        OTAL ANALYSE'            LOWER         INDICATOR LOCATIONS LOCATION WITH HIGHEST ANNUAL MEAN                                           CONTROL LOCATIONS TYPE         /NONROUTINE            LIMIT OF                   MEAN (f) -,                            LOCATION                MEAN (f)                     MEAN (f)'
IMEASUREMENTS         DETECTION                        RANGE            -              INFORMATION                  RANGE                          RANGE Iodine-131                  3/0               I.4E+0I               --     (j0/ 2)                                   --                  __                       _    (     0/   1)
Cesium-134                  3/0               92E-01                 -.-( ,0/        2)                                 --               ---                    -(           0/ 1)
Cesium-137                  310               7.7E-01               ---        (   &deg;2)                                                                                       Of 1)_17 Manganesc-54                3/0               8.8E-01               _. (.0! 2)                     -        ,        --                                                      0/ 1)
Of(
Iron-59                     3/0              4.9E+00                 _(0/            2)            -               -*                    _--(
                                                                                                                                         -                                   0/1)
Cobalt-58                   3/0              I.IE+00            --       ( 0/2)               ,.          ,.                             -                     -- (0/             1)
Cobalt-60                   3/0              1.5E+00                      (,0/       2)            -.               -                                              _-(0&deg;          1)
Zinc-65                     3/0              2.7E+00           _         (0/        2)                               ---                 --                    --          0./   _1)
Zirconium-95                3/0              2.0E+O0               __ ( 0/12)                          ;         -        -     .                                      (    0/ 1)
Niobium-95                  3/0              1.6E+00                  -   (    01 2)             _                      -               --        ,                    (    0/ 1)
Lanthanum-140               3/0              3.7E+00               --- (0           2)                 ,            _                                          _ ( 0/ 1)
Barium-140                      _                                                       ,               .,                                        .   .
   *  (f) Number of positive measurements / total measurements at specified locations.
STP Nuclear Operating Company 6 -22

IN RadiologicalEnvironmental                                                                                    3erating Report TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS SUIMIARY Medium: Piscivorous - Fishh                                                                      Units: Picocuries er Kilogram wet weight ANALYSIS        TOTALANALYSES           LOWER         INDICATOR LOCATIONS          LOCATION WITH HIGHESTANNUAL MEAN        CONTROL LOCATIONS TYPE           'NONROUTINE           LIMIT OF               MEAN (0-              LOCATION            MEAN (f)-                 MEAN (t)-
MEASUREMENTS         DETECTION                  RANGE             INFORMATION            RANGE                      RANGE Cesium-134                   610            2.4E+01             __     ( 01 4)               _                                      _     ( 01   2)
Cesium-137                   6/0            2.3E+01               _ ( 0/ 4)                 --                                            ( 0/ 2)
Manganese-54                 6/0            2.3E+01             --    ( 0/ 4)                                    _                  _     ( 0/ 2)
Iron-59                       6/0           8.0E+01                  (   0/ 4)               _                                      --  (   0/2)
Cobalt-58                    610            25E+01                  (    0  4)               _                                      _     ( 0/2)
Cobalt-60                    610            2.7E+0I             -(       0  4)               _                                      _     ( 0/   2)
Zinc-65                      6/0            5.3E+01             -(       0/ 4)               _                                      -(      01 2)
Zirconium-95                 6/0            4.6E+01             __     ( 0/ 4)                                   _                  -(      01 2)
Niobium-95                   6/ 0           3.2E+01             __     ( 0/ 4)               _                   _                  _     ( 0/ 2)
Lanthanum-140                6/0           8.3E+01                    ( 0/ 4)                                                      _     ( 0/ 2)
Barium-140
         *  (f Number of positive measurements / total measurements at specified locations.
TABLE 3 2003 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM ANALYSIS 

==SUMMARY==

Medium: Crustacean Shrimp                                                                        Units: Picocuries r Kilogram wet weight ANALYSIS        TOTAL ANALYSES          LOWER         INDICATOR LOCATIONS          LOCATION WITH HIGHEST ANNUAL MEAN       CONTROL LOCATIONS TYPE          /NONROUTINE           LIMITOF                MEAN (f)              LOCATION            MEAN (f                   MEANtO MEASUREMENTS         DETECTION                  RANGE             INFORMATION            RANGE                      RANGE Cesium-134                    7/0           3.1E+01                 (    0/ 4)               _                                            ( 0/3)
Cesium-137                    7/0           2.8E+01               _ ( 0/    4)               _                                      _     ( 0/   3)
Manganese-54                 7/0           2.7E+01             -(       01 4)               _                   _                  _     ( 0/   3)
Iron-59                      7/0            8.3E+01             -(       0/ 4)               _                                      _     ( 0/ 3)
Cobalt-58                    7/0            2.7E+01             -(       0/ 4)               _                                      _     ( 0/   3)
Cobalt-60                    710           3.0E+01               _ ( 0/    4)               _                                      _     ( 0/ 3)
Zinc-65                       7/0           6.0E+01               _    ( 01 4)               _                   _                  _     ( 01 3)
Zirconium-95                  7/0           5.0E+01               _ (    0/ 4)                                                      _     ( 0/ 3)
Niobium-95                   7/0            3.2E+0I               _ ( 0!    4)                                                      _     ( 01 3)
Lanthanum-140                 7/0           5.9E+01             -(       0/ 4)               _                                      _     ( 0/   3)
Barium-140
          * (f) Number of positive measurements / total measurements at specified locations.
STP Nuclear Operating Company 6 -23

11 -}}