ML15132A362

South Texas Project, Units 1 and 2 - 2014 Annual Environmental Operating Report

ML15132A362
Person / Time
Site:	South Texas
Issue date:	04/26/2015
From:	Aguilera R A South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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ML15132A360	List: ML15132A361 ML15132A362 NOC-AE-15003245, 2014 Radiological Environmental Operating Report, Chapter 6
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NOC-AE-15003245, STI: 34103206
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AttachmentSouth Texas ProjectUnits 1 and 22014 Annual Environmental and Annual Radiological Environmental Operating Reports Sm Baad 4ap The 2014 Annual Environmental Operating Report for the South Texas ProjectElectric Generating Station combines in one report the requirements for theAnnual Environmental Operating Report (Non-radiological) found in Appendix B toFacility Operating License Nos. NPF-76 and NPF-80 and the requirements for theAnnual Radiological Environmental Operating Report found in Part A of thestation's Offsite Dose Calculation Manual.Graphics and artwork performed by Barbara CarnleyCover photo by: Gary ParkeyMaps provided by Janice HopesPhotography performed by: Cheryl Bentley, Gene Fisseler, Edmond Hardcastle,Janice Hopes, Frank Jacobus, Jodie Jankauskas, Nancy Kubecka, ChelseaMaxey, Connie Milliff Bud Nosbisch, Gary Parkey, Aubrey Passafuma, RobynSavage, Tammy Stevens and Cheryl Yeamans( nPa. r F 03)STP Nuclear Operating Company Completed in accordance withTechnical Specifications forUnited States Nuclear Regulatory CommissionLicense Nos.NPF-76 and NPF-80April 2015Authored by: l,,'a '--5 rLau'ra StoicescuStaff Health PhysicistHealth Physics DivisionandJ.D.Environmental SupervisorRegulatory AffairsTechnical Review:_______-_-'-Ken K. Kawabata, CHPPlant Health PhysicistHealth Physics DivisionApproved by: R~gdrManagerHealth Physics Division2014Annual EnvironmentalOperating ReportSOUTH TEXAS PROJECT ELECTRIC GENERATING STATION Table of ContentsExecutive Sum mary .................................................................................................. 1-2Site and Area Description .......................................................................................... 2-2NonRadiological Environmental Introduction and Summary .................................... 3-2NonRadiological Environmental Operating Report ................................................... 4-2Environmental Conditions .............................................................................. 4-2Aquatic and Ecological M onitoring ...................................................... 4-3W ater Quality M anagement ................................................................ 4-4Air Quality M anagement ..................................................................... 4-9NonRadioactive W aste M anagement .................................................. 4-11Chemical Control and M anagement .................................................... 4-14Environmental Protection Plan Status ............................................................ 4-15Radiological Environmental Introduction and Sum mary ........................................... 5-2Radiological Environmental Operating Report .......................................................... 6-2Program Description ....................................................................................... 6-2Analysis of Results and Trends ............................................................. 6-6NEI Groundwater Protection Initiative ........................................................... 6-14Land Use Census ............................................................................................ 6-16Quality Assurance .......................................................................................... 6-17Program Deviations ........................................................................................ 6-172014 Radiological Environmental Monitoring Program Analysis Summary... 6-29List of FiguresFigure 2-1: Plant W ater Systems Diagram .................................................. 2-4Figure 4-1: 2014 Nonradioactive W aste M anagement ............................... 4-13Figure 4-2: 2014 Nonradioactive W aste Generation .................................. 4-13Figure 4-3: Hazardous W aste Shipped Historical Comparison .................... 4-14STP Nuclear Operating Company 2014 Environmental ReportFigure 6-1:Figure 6-2:Figure 6-3:Figure 6-4:Figure 6-5:Figure 6-6:Figure 6-7:Figure 6-8:Figure 6-9:Figure 6-10:Figure 6-11:Figure 6-12:Figure 6-13:Figure 6-14:Figure 6-15:Figure 6-16:List of TablesRadiological Environmental Monitoring Program DesignatedSam ple Location M ap ...................................................................... 6-3Radiological Environmental Monitoring Program OnsiteSam ple Location M ap ..................................................................... 6-4Radiological Environmental Monitoring Program ZoneLocatio n M ap ................................................................................... 6-5Historical Comparison of Average Quarterly Beta Activityfrom Indicator and Control Air Samples .......................................... 6-6Environmental Dosimeter Comparisons .......................................... 6-7Historical Comparison of Cobalt-60 in Main Cooling ReservoirSed im e nt ......................................................................................... 6-9Calculated Cumulative Curies of Cobalt-60 in the MainCooling Reservoir ............................................................................. 6-9Historical Comparison of Tritium Added to and Remaining inthe M ain Cooling Reservoir ............................................................. 6-10Historical Comparison of Tritium Activity in ReservoirRe lief W ells ..................................................................................... 6-10Historical Comparison of Tritium Activity in Surface Water ............ 6-12Historical Comparison of Tritium Activity in Shallow AquiferG round W ater .................................................................................. 6-12Tritium Activity in Shallow Ground Water West of the MainCooling Reservoir ............................................................................. 6-13STP Protected Area Ground Water Monitoring Wells Results ......... 6-14STP Protected Area Ground Water Monitoring Wells ..................... 6-152014 Radiological Laboratory Quality AssuranceProgram Perform ance ..................................................................... 6-18Duplicate & Split Agreement of Environmental Samples in 2014 ... 6-18Radiological Environmental Monitoring Program ........................... 6-19Sample Media and Location Descriptions ....................................... 6-222014 Radiological Environmental Monitoring ProgramA nalysis Sum m ary ........................................................................... 6-30Table 1:Table 2:Table 3:STP Nuclear Operating Company Photo By: Bud NosbischSTP Nuclear Operating Company EXECUTVE SUM AR..... ..

Executive SummaryThe South Texas Project continues to operate with no adverse effect on the population or theenvironment. The exposure for people living in the area remains at less than one millirem peryear. Environmental programs at the site monitor known and predictable relationships betweenthe operation of the South Texas Project and the surrounding area. These monitoring programsverify that the operation of the South Texas Project has no impact offsite and is well within stateand federal regulations and guidelines. These programs are verified by the State of Texas throughcollection and analysis of samples and placement of the State's monitoring dosimeters and otheronsite and offsite inspections.This report describes the environmental monitoring programs, radiological and nonradiological,conducted at the South Texas Project during 2014. Included in this report are the EnvironmentalProtection Plan Status, the results of the Radiological Environmental Monitoring Program, and theLand Use Census.Nonradiological environmental monitoring is performed each year as part of the station's overallEnvironmental Protection Plan which is intended to provide for protection of nonradiologicalenvironmental values during station operations. Nonradiological monitoring encompasses, asa minimum, water quality, air quality, waste generation and minimization, and local aquatic andterrestrial ecological conditions. In 2014, nonradiological monitoring by the station confirmed that theSouth Texas Project's efforts to respect and protect local environmental conditions were successful.The South Texas Project continued to be rated by the Texas Commission on Environmental Qualityas a high performer in the area of environmental compliance, continued to provide high-qualityhabitat areas for a variety of flora and fauna, and continued to have no indications of negative non-radiological impacts to local environmental conditions.The environment within a 15-mile radius of the South Texas Project is routinely monitored forradiation and radioactivity. Sampling locations are selected using weather, land use, and water useinformation. Two types of sampling locations are used. The first type, control stations, are locatedin areas that are beyond the measurable influence of the South Texas Project or any other nuclearfacility. The sample results from these stations are used to explain radiation from sources other thanthe South Texas Project. Indicator stations are the second type of stations. The samples from thesestations measure any radiation contributed to the environment that could be caused by the SouthTexas Project. Indicator stations are located in areas close to the South Texas Project where any plantreleases would be detected.Prior to initial operation of the South Texas Project, samples were collected and analyzed to determinethe amount of radioactivity present in the area. These results are used as a "preoperational baseline."Results from the indicator stations are compared to both current control sample results and thepreoperational baseline values to determine if changes in radioactivity levels are attributable tostation operations or other causes such as previous nuclear weapons testing programs and naturalvariations.Radioactivity levels in the South Texas Project's environment frequently fall below the minimumdetection capabilities of state-of-the-art scientific instruments. Samples with radiation levels thatcannot be detected are below the Lower Limits of Detection. The United States Nuclear RegulatoryCommission requires that equipment used for radiological monitoring must be able to detect1-2STP Nuclear Operating Company 2014 Environmental Reportspecified minimum limits for certain types of samples. This ensures that radiation measurementsare sufficiently sensitive to detect small changes in the environment. The United States NuclearRegulatory Commission also has a required reporting level. Licensed nuclear facilities must preparea special report and increase their sampling if any measured radiation level is equal to or greaterthan this reporting level. No sample from the South Texas Project has ever reached or exceeded thisreporting level.Measurements performed are divided into four categories, or pathways, based upon how the resultsmay affect the public. Airborne, waterborne, ingestion, and direct radiation are the four pathwaysthat are sampled. Each pathway is described below." The airborne pathway is sampled in areas around the South Texas Project by measuring the levelsof radioactive iodine and particulate radioactivity on air filters. The 2014 airborne results weresimilar to preoperational levels detecting only naturally occurring radioactive material unrelatedto the operation of the South Texas Project." The waterborne pathway includes samples taken from surface water, ground water, and drinkingwater. Also included in this pathway are sediment samples taken from the Main CoolingReservoir and the Colorado River. Tritium was the only man-made nuclide consistently detectedin water samples and was measured in the shallow aquifer, the Main Cooling Reservoir, ditches,and sloughs consistent with the South Texas Project Main Cooling Reservoir operating design.The levels of tritium found were near or lower than the concentration of the Main CoolingReservoir. Additional onsite wells have been sampled to map tritium migration. The averagetritium level in the Main Cooling Reservoir remained stable throughout 2014. Tritium levelsremain well below United States Nuclear Regulatory Commission reporting limits and withinUnited States Environmental Protection Agency drinking water standards. Previously detectedplant-related nuclides, cobalt-60 and cesium-137, were also detected in the reservoir sedimentthis year at the designated sample locations. Several samples had detectable cesium-137 which ispresent in the environment and was detected at preoperational concentrations. Onsite sedimentsamples continue to occasionally indicate traces of plant-related nuclides such as cobalt-60.Offsite sediment samples continue to show no radioactivity from the South Texas Project. Insummary, the station produces no detectable waterborne effects offsite." The ingestion pathway includes broadleaf vegetation, agricultural products, and food products.Naturally occurring nuclides were detected at average environmental levels in the samples. Thedata indicated there were no man-made nuclides detected in these types of samples." The direct exposure pathway measures environmental radiation doses using thermoluminescentdosimeters. These results are consistent with the readings from previous years and continue toshow no effect from plant operations.The South Texas Project continues to operate with no negative effect on the population or theenvironment. The dose for people living in the area is maintained at less than one millirem peryear. Environmental programs at the site monitor known and predictable relationships betweenthe operation of the South Texas Project and the surrounding area. These monitoring programsverify that the operation of the South Texas Project has no impact offsite and is well within state andfederal regulations and guidelines. These programs are verified by United States Nuclear RegulatoryCommission inspections, STP Nuclear Operating Company sponsored quality assurance audits, and theState of Texas through collection and analysis of samples and State radiation monitoring dosimeters.STP Nuclear Operating Company1-3 Photo By: Robyn Savage1-4 STP Nuclear Operating Company a

Site and Area DescriptionThe South Texas Project is located on 12,220 acres in Matagorda County, Texas,approximately 15 miles southwest of Bay City along the west bank of the Colorado River.The South Texas Project Electric Generating Station is owned by NRG South Texas LP, Cityof Austin, and City Public Service Board of San Antonio as tenants in common. HoustonLighting & Power Company was the original project manager of the South Texas Projectand was responsible for the engineering, design, licensing, construction, startup, andinitial commercial operation of the two-unit facility. In 1997, the STP Nuclear OperatingCompany assumed operational control of the South Texas Project and responsibility forimplementation of associated environmental programs.The South Texas Project has two Westinghouse pressurized water reactors. The rated corethermal power of each unit is 3,853 megawatts-thermal (MWt). Each unit was originallydesigned for a net electrical power output of 1,250 megawatts-electric (MWe). Unit 1received a low-power testing license on August 21, 1987, achieved initial criticality onMarch 8, 1988, and was declared commercially operational on August 25, 1988. Unit 2received a low-power testing license on December 16, 1988, achieved initial criticalityon March 12, 1989, and was declared commercially operational on June 19, 1989. Thecombined units currently produce enough electricity to serve more than two million homesand businesses throughout Texas. With nearly 1,200 baseline employees, the STP NuclearOperating Company is the largest employer and source of revenue for Matagorda County.The South Texas Project initiated activitiesin 2008 to pursue renewal of the operatinglicenses for Units I and 2 from the United StatesNuclear Regulatory Commission. The licenserenewal application was submitted to theUnited States Nuclear Regulatory Commissionin October of 2010 to request authorizationto operate the South Texas Project, Units 1and 2, for an additional 20 years beyond theperiod specified in the current licenses. TheNuclear Regulatory Commission issued the finalSupplemental Environmental Impact Statementfor the license renewal in November of 2013.The final Supplemental Environmental ImpactStatement was prepared in compliance withthe National Environmental Policy Act. Theprocess for preparation of the final supplementalimpact statement included consultation withother applicable regulating agencies, reviewof information provided by the South TexasProject, the Nuclear Regulatory Commission'sown independent environmental review andconsideration of public comments receivedduring the process. Photo By: Cheryl Bentley2-2STP Nuclear Operating Company 2014 Environmental ReportIn September of 2007, a Combined Construction and Operating License Application (COLA)was filed with the United States Nuclear Regulatory Commission to build and operatetwo additional units, Units 3 and 4, at the South Texas Project. The Nuclear RegulatoryCommission issued the Final Environmental Impact Statement for Units 3 and 4 in Februaryof 2011. The Final Environmental Impact Statement was prepared in compliance withthe National Environmental Policy Act. The process for preparation of the final impactstatement included consultation with other applicable regulating agencies, review ofinformation provided by the South Texas Project, the Nuclear Regulatory Commission's ownindependent environmental review and consideration of public comments received duringthe process. Efforts continue to secure licensing for the two new units.Nuclear energy continues to provide long-term cost stability and promote energyindependence. It is our nation's largest source of carbon-free energy. As we workcollectively to secure our state's long-term energy future, nuclear energy will continue toplay an important role as a safe and reliable supply of clean baseload electricity.HOW THE SOUTH TEXAS PROJECT WORKSFossil-fueled and nuclear-powered steam generating plants operate on the same principle.Fuel is used to produce heat to convert water into high-pressure steam. The steam isdirected through a turbine to turn a generator. In a fossil fuel plant, either coal, lignite,oil or natural gas is burned in a boiler to produce the heat. In a nuclear plant, the reactorreplaces the boiler and the "fissioning" or splitting of uranium atoms inside the reactorproduces the heat.The fuel for a nuclear reactor is uranium. It is formed into cylindrical ceramic pellets,each about the size of the end of your little finger. One pellet has the energy potential ofabout a ton of coal. Millions of these pellets are stacked in fuel rods that are arranged intoassemblies that make up the core of the reactor. The use of uranium allows us to conservenatural gas, oil and coal and to avoid the associated production of greenhouse gases.The fission process and generation of usable heat begins in a nuclear reactor when controlrods in the core are withdrawn. In pressurized water reactors, like those at the South TexasProject, the fuel rods heat water circulating in sealed, stainless steel piping that passesthrough large heat exchangers called steam generators. The water in the reactor is underpressure to prevent boiling. This is why the South Texas Project's Units 1 and 2 reactors arecalled "pressurized water reactors."This hot, pressurized water heats a separate supply of water in the steam generatorsto produce steam that is directed through the blades of a turbine generator to produceelectricity. The steam is then fed to a condenser where a separate supply of coolingwater from the reservoir turns it back into water that is then pumped back to the steamgenerator for reuse. A diagram of the plant water systems is shown in Figure 2-1.STP Nuclear Operating Company2-3 Site and Area DescriptionPLANT WATER SYSTEMSPRESSURIZER SECONDARY LOOPGENERATORREACTORCIRCULATINGPUMPCOOLING I CONDENSATEPUMP PUMPI t RESERVOIR (7000 ACRE LAKE)PRIMARY LOOP CONTAINMENTWALL COOLING LOOPFigure 2-1In addition to its safety systems, the South Texas Project has many built-in physical barriersthat would prevent the release of radioactive materials in the unlikely event of an accident.The most visible ones are the 200-foot-tall, domed containment buildings with steel-reinforced concrete walls four feet thick. Inside each of these massive structures, two moreconcrete walls provide another 11 feet of shielding. The reactor vessel itself has steel wallssix inches thick, and the fuel pellets inside it are sheathed in hardened metal tubes.Nuclear energy has one of the lowest impacts on the environment. It is the mosteco-fficient energy source because it produces the most electricity in relation to its minimalenvironmental impact. In 2013, the most recent year for which data is available, nucleargeneration in the United States prevented 588.54 million metric tons of carbon dioxide,0.97 million short tons of sulfur dioxide, and 0.48 million short tons of nitrogen oxide fromentering the Earth's atmosphere.1 In 2013, nuclear power plants generated approximately63 percent of all clean-air electricity in the United States.2 Additional information onnuclear energy and the environment can be found on the website maintained by theNuclear Energy Institute at http://www.nei.org.I Nuclear Energy Institute. Emissions Avoided by the U.S. Nuclear Industry. http://www.nei.org/Knowledge-Center/Nuclear-Statistics/Environment-Emissions-Prevented/Emissions-Avoided-by-the-US-Nuclear-Industry. April2014.2 Nuclear Energy Institute. Environment: Emissions Prevented. http://www.nei.org/Knowledge-Center/Nuclear-Statistics/Environment-Emissions-Prevented. Sources of Emission-Free Electricity Infographic (2013). Viewed onMarch 9, 2015.2-4STP Nuclear Operating Company 2014 Environmental ReportPhoto By: Edmond HardcastleTHE PLANT SITESixty-five of the entire 12,220 acres at the South Texas Project are occupied by the twocurrent power plants. Plant facilities include a 7,000-acre main cooling reservoir and a47-acre essential cooling pond. Many smaller bodies of water onsite include wetlands,Kelly Lake, drainage ditches, sloughs, and depressions. Much of the land east of the coolingreservoir is leased for cattle grazing. Approximately 1,700 acres remain in a more naturalstate as a lowland habitat. A 110-acre wetland habitat area was established in 1996 onpreviously unused land located northeast of the power plants. The area surroundingthe South Texas Project is characterized by coastal plain with farmland and pasturepredominating. Local relief of the area is characterized by flat land, approximately 23 feetabove sea level.THE AREAMatagorda County's economy is based primarily on ranching, farming, oil and naturalgas production and refinement, petrochemical production, electricity generation, andcommercial fishing and fisheries. The area within 10 miles of the site is generally ruraland characterized as farmland, which is primarily pastureland used for livestock ranching.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 thesouthern region of the central flyway and is host to an abundance of migratory birds. Thelocal estuary environments provide the necessary habitat for a variety of fish types tocomplete their life cycles. The area also affords opportunity for recreational hunting andfishing.STP Nuclear Operating Company2-5 Site and Area DescriptionThe South Texas Project is home to many species of animals. Inhabitants include Americanalligators, a variety of birds, and several hundred deer. In winter, literally hundreds ofthousands of waterfowl, principally migratory geese as well as white pelicans and thecommon tern, have found that the plant's 7,000-acre cooling reservoir provides a goodresting place during their migrations.The climate of the region is subtropical maritime, with continental influence. It ischaracterized by short, mild winters and long, hot and humid summers. Although droughtconditions continued in Texas throughout 2014, rainfall normally ranges from about twoinches per month in February peaking to about four to five inches per month in May, June,September and October. The prevailing wind direction is from the south-southeast, shiftingto north-northeast for short intervals during the winter months.Photo courtesy of: Jodie Jankauskas2-6STP Nuclear Operating Company

Nonradiological Environmental Introduction and SummaryNonradiological environmental conditions and performance at the South Texas Projectduring 2014 remained satisfactory and demonstrated that the South Texas Projectcontinued to operate in an environmentally responsible manner during the year. The SouthTexas Project achieved and maintained high standards of environmental performance andcompliance throughout 2014.The South Texas Project is committed to the production of electricity in a safe, reliable,and economical manner using nuclear energy. The station's programs, policies, andbusiness plan objectives also incorporate a commitment to environmental protectionand management. The station's commitment to sound environmental management isillustrated by the following successes in 2014.* Continued classification as a high performer3 by the Texas Commission onEnvironmental Quality based on the station's environmental compliance recordin all areas considered, including water quality, waste management, and airquality compliance;Photo By: Gene Fisseler3Per Compliance History Report for CN601658669, RN102395654, Rating Year 2014; as prepared by the Texas Com-mission on Environmental Quality on March 10, 2015.3-2STP Nuclear Operating Company 2014 Environmental Report* No reportable spills or leaks; and,*" Reduction to the lowest amount over the past five years in the generation andshipment of hazardous waste at the station.Everyone has a responsibility to protect the environment. Commitment to environmentalsafety is an integral component of the South Texas Project operating policy and core values.This responsibility reaches further than mere compliance with laws and regulations toencompass the integration of sound environmental practices into our daily operationaland business decisions. The people at the South Texas Project understand the need tobalance economic, operational and environmental issues for the benefit of the station andthe public. We recognize our responsibility to hold ourselves to the highest principles ofenvironmental stewardship for station activities.rnoro uene risseterSTP Nuclear Operating Company3-3 Photo By: Bud Nosbisch3-4 STP Nuclear Operating Company S NADIOLIAL ENIRNMNALOPEATN RPORT="mom, Nonradiological Environmental Operating ReportENVIRONMENTAL CONDITIONSThis section of the report describes the South Texas Project's nonradiological environmentalprogram performance and environmental conditions from January 1 through December 31,2014. The STP Nuclear Operating Company closely monitors environmental conditions andperformance at the South Texas Project. NRG Energy, Inc. provides support and technicalassistance to the South Texas Project. The Texas Commission on Environmental Qualityconducted one onsite air quality permit compliance inspection and one onsite wastewaterquality permit compliance inspection in 2014.The Texas Commission on Environmental Quality rated the South Texas Project as a highperformer in 2014 based on the station's environmental compliance record. Facilities, such asthe South Texas Project, are classified by the state as a high performer, satisfactory performer,or unsatisfactory performer based on that facility's compliance history. The state's classificationof the South Texas Project as a high performer was based on the station's environmentalperformance over the last five year period.The South Texas Project, alongwith other local industries andorganizations, co-sponsoredand participated in the annualMatagorda County HouseholdHazardous Waste Collection Dayin the fall of 2014, and stationemployees also participatedin other community areaenvironmental projects such asthe county's Matagorda CountyBeach Cleanup. During theperiod of this report, the stationcontinued to promote "green"initiatives including encouragingcarpooling among employeesand the recycling of plastics andaluminum by site employees.The station also continued tosupport various bird counts andsurveys in 2014 sponsored byfederal and state agencies andvolunteer organizations such asthe annual National AudubonSociety Christmas Bird Count, theGreat Texas Birding Classic, andthe United States Fish and WildlifeService Colonial Waterbird Survey. Photo By. Gary Parkey4-2STP Nuclear Operating Company 2014 Environmental ReportAQUATIC AND ECOLOGICAL MONITORINGThe location of the South Texas Project falls within the Texas Land Resource Area designationas coastal prairie and can be divided into two broad ecological areas based on topography,soils, and vegetation. The bottomland lowland habitat is a swampy, marshy area that providesan important habitat for birds and other wildlife and occupies approximately 1,700 acres ofthe site near the Colorado River. A spoil impoundment originally constructed in 1972 by theUnited States Army Corps of Engineers is included in this area. In addition, a 110-acre wetlandhabitat area that attracts a variety of bird groups and other wildlife was established in 1996 onpreviously unused land located northeast of the power plants. In 2012, the Matagorda Countychapter of Ducks Unlimited awarded the station the John Runnels Good Steward Award formaintenance of the wetland habitat area. The remaining area of the site offers diverse habitatsfor mammals and several types of birds. The South Texas Project regularly monitors the site'senvirons for changing conditions. Ecological conditions onsite in 2014 remained generallyunchanged and satisfactory.The South Texas Project is located on the state-sponsored Great Texas Coastal Birding Trail thatspans the entire Texas Gulf Coast from Brownsville to the Louisiana border. Matagorda County,which includes the South Texas Project, consistently ranks at or near the top of the NationalAudubon Society's annual Christmas Bird Count for the number of species identified. Severalbird species have been observed visiting the wetland habitat and elsewhere onsite. Theseinclude the bald eagle, white-faced ibis, and brown pelican. Additional migratory and residentPhoto By: Gary ParkeySTP Nuclear Operating Company4-3 Nonradiological Environmental Operating Reportbird species such as a variety of ducks, geese, turkey and pelicans (both brown and white) havebeen observed during informal surveys of the site's diverse natural and man-made habitats.Intensive bird nesting continues throughout the lowland habitat, particularly in a heron rookeryaround the perimeter of Kelly Lake. U. S. Fish and Wildlife Service biologists estimate thatapproximately one-third of Texas' breeding adult Gull-billed Tern population, considered to be indecline, nest on the internal dikes of the Main Cooling Reservoir at the South Texas Project. TheSouth Texas Project continues to provide vital habitat for more than an estimated 125 differentspecies of wintering and resident birds.The South Texas Project continues to monitor important wildlife species to detect populationchanges. Informal observations by station and NRG Energy, Inc. personnel continue to indicatethat the site provides high-quality habitat in which a wide range of animals live. The sitecontinues to attract extensive wildlife populations, offering a refuge for resident species aswell as seasonal migrants. The lowland habitat located between the Colorado River and theeast bank of the Main Cooling Reservoir offers a significant source of water year-round. Thesenatural resource areas, in concert with numerous additional wetland and grassland areas, offerthe key ingredients necessary to sustain the extensive wildlife population at the South TexasProject.WATER QUALITY MANAGEMENTWater is an essential component in electricity production, and all electric utilities must complywith extensive federal, state and local water regulations. These regulations govern virtuallyevery aspect of business operations at the South Texas Project. Water usage, wastewatertreatment onsite and certain maintenance and repair activities are regulated under the SafeDrinking Water Act, the Federal Clean Water Act, and the Texas Water Quality Act. Collectively,these acts provide for the safeguarding of public drinking water supplies and maintaining theintegrity of state and federal waters. Regulating agencies that administer these requirementsinclude the United States Army Corps of Engineers, the United States Environmental ProtectionAgency, the Texas Commission on Environmental Quality, the Texas General Land Office and theLower Colorado River Authority.The South Texas Project uses both surface water and groundwater for station purposes.Groundwater is pumped from deep aquifer wells to provide onsite drinking water for stationpersonnel, to replenish the Essential Cooling Pond, and for other industrial purposes onsite.Consistent with the station's environmental principles encouraging efficient water usage andconservation, groundwater usage is carefully managed to conserve this important resource.Water from the Main Cooling Reservoir and the Essential Cooling Pond is used as cooling waterfor plant activities. Water from the Colorado River replenishes the Main Cooling Reservoir viaintermittent pumping periods. Surface water diverted to the Main Cooling Reservoir from theColorado River accounted for almost 97 percent of the water used at the South Texas Project in2014. Information regarding water use in Texas can be found on the website maintained by theTexas Water Development Board at http://www.twdb.state.tx.us/.4-4STP Nuclear Operating Company 2014 Environmental ReportMost of the water used by the South Texas Project is needed to condense steam and providecooling for plant generating systems. The majority of this water is drawn from and returned tothe station's Main Cooling Reservoir. The Main Cooling Reservoir is a 7,000-acre, above grade,off-channel reservoir capable of impounding 202,600 acre-feet of water at its maximum level.Water is diverted intermittently from the adjacent Colorado River to replenish the Main CoolingReservoir. In addition, the Essential Cooling Pond, a 47-acre, below grade, off-channel reservoirthat supplies water to cool crucial plant components, is capable of impounding 388 acre-feetof water. Various water rights permits, contractual agreements, and compliance documentsauthorize the South Texas Project to maintain these reservoirs, impound water diverted fromthe Colorado River, and to circulate, divert, and use water from the reservoirs for industrialpurposes to operate the plant. These permits also limit the rate of diversion from the ColoradoRiver. Although widespread drought conditions during the year continued to limit the amountof water available for diversion from the river, the South Texas Project diverted 35,994 acre-feetin 2014 from the Colorado River for Main Cooling Reservoir fill operations, mainly in the secondquarter of the year, while preserving adequate freshwater flow conditions for downstream bayand estuarine ecosystems. Approximately 3 percent, or 1,057 acre-feet, of the water used bythe station was withdrawn from onsite groundwater sources in 2014.Existing federal and state water quality standards are implemented and enforced through theTexas Pollutant Discharge Elimination System (TPDES) permit program to restore and maintainthe state's waters. Under this permit program, the South Texas Project monitors, records,and reports the types and quantities of pollutants from wastewater discharges to ensurePhoto By: Jodie JankauskasSTP Nuclear Operating Company4-5 Nonradiological Environmental Operating Reportthat we meet or exceed the stringent levels set in the permit. A monthly monitoring reportis submitted to the Texas Commission on Environmental Quality for wastewater discharges.Reports identifying groundwater use, surface water use and water conservation are submittedannually to the Texas Water Development Board. Reports of diversion and consumptive useare submitted to the Texas Commission on Environmental Quality and the Lower ColoradoRiver Authority. An annual groundwater use report is also submitted to the Coastal PlainsGroundwater Conservation District.Wastewater generated at the South Texas Project is processed and discharged to the onsiteMain Cooling Reservoir to be re-used by the station as cooling water for plant systems. Nowater was discharged from the reservoir in 2014. Station conditions neither required siteaquatic monitoring studies be conducted in 2014, nor were any additional studies required bythe United States Environmental Protection Agency or the State of Texas either by way of stationdischarge permits or otherwise. The Texas Commission on Environmental Quality conductedone onsite wastewater quality permit compliance inspection in 2014. One area of concernwas identified regarding a sampling technique that was immediately corrected in the field andno further actions were required. Wastewater discharges met state and federal water qualitystandards during the year, while conserving and maximizing efficient water usage at the station.In addition to the wastewater discharge permit program, the Federal Clean Water Act, asamended, requires permits for storm water discharges associated with industrial activity. TheSouth Texas Project Storm Water Pollution Prevention Plan ensures that potential pollutionsources at the site are evaluated and that appropriate measures are selected and implementedto prevent or control the discharge of pollutants in storm water runoff. This plan is a workingdocument that is revised whenever there is a change in design, construction, operation, ormaintenance that has a significant effect on the potential for the discharge of pollutants fromthe station.Following a severe drought in 1996, the Texas Legislature recognized the need to address a widerange of state water resource management issues. In 1997, the Texas Senate drafted legislationknown as Senate Bill 1 to address these issues and to develop a comprehensive state waterpolicy. Towards this end, this legislation required that the Texas Water Development Boardcreate a statewide water plan that emphasizes regional planning. Sixteen planning regions werecreated, each tasked to prepare a regional plan for the orderly development, management, andconservation of water resources. The South Texas Project was chosen to represent the electricgenerating utility interest for the water-planning region, Region K, encompassing the lowerColorado River Basin. A state water plan is prepared by the Texas Water Development Boardbased on the regional water plans that are developed every five years by the regional waterplanning groups. The fourth cycle of regional and state water planning commenced in 2011 andwill extend through 2016. The regional water plans will be revised based on updated populationand water demand projections, water supply analyses, and water management strategies fora water planning horizon out to the year 2070. The South Texas Project continues to activelyparticipate in the Lower Colorado Regional Water Planning Group to identify strategies to meetfuture water supply demand projections for the region and update the existing plan accordingly.Additional information regarding regional water planning in Texas can be found on the website4-6STP Nuclear Operating Company 2014 Environmental Reportmaintained by the TexasWater DevelopmentBoard at http://www.twdb.state.tx.us/.Senate Bill 1 alsorequired groundwaterconservation districts todevelop groundwatermanagement planswith estimates onthe availability ofgroundwater in thedistrict, details of howthe district wouldmanage groundwater,and management goalsfor the district. Thewater planning andmanagement provisionswere further clarifiedin 2001 with theenactment of SenateBill 2. Accordingly, Photo By.: Cheryl Yeamansthe Coastal Plains Groundwater Conservation District, encompassing Matagorda County, wasconfirmed by local election in late 2001. The purpose of the District is to "...manage andprotect the groundwater resources of the District." The South Texas Project groundwaterwells are registered with the Coastal Plains Groundwater Conservation District. The station'sgroundwater wells' operating permits were renewed in 2014 as required every three years.Station personnel continue to monitor onsite groundwater usage according to the requirementsof the District's rules. Additional information regarding the Coastal Plains GroundwaterConservation District can be found on their website at http://www.coastalplainsgcd.com/.In 2007, in further recognition of the importance of water conservation to meet future demandsin the state, Senate Bill 3, enacted by the Texas Legislature, created a stakeholder-driven processfor the development of environmental flows. Environmental flows are the amount of waternecessary for a river, estuary, or other freshwater system to maintain its health and productivity.The law established a process to develop environmental flow regime recommendations foreach major river basin in Texas. The process tasked a team of stakeholders for each area of thestate, working with a science team, to develop a set of recommendations to submit to the TexasCommission on Environmental Quality. The South Texas Project participates as a member of thestakeholder committee that includes the Colorado River and Matagorda Bay. In August of 2011,the stakeholder committee recommendations for the Colorado River Basin were submittedto the Texas Commission on Environmental Quality. The commission, after considering theserecommendations along with public input, adopted formal environmental flow standards thatQ-TD KIIh ,nl ~ fin;Prn~ 4-7I 'UI.-.IV01 VVJIGI "Vi '..IJI IIIJaI y Nonradiological Environmental Operating Reportmust be maintained. The environmental flow standards set flow levels at various points in riversand streams to protect water in the rivers and estuaries along the coast. As a follow up to theinitial flow recommendations, the stakeholder committee submitted a Draft Work Plan to theTexas Commission on Environmental Quality in June of 2012. The Draft Work Plan addressedadditional efforts needed for research and data development to support a planned reviewof the environmental flow standards in 2021. In 2013, the stakeholder committee evaluatedand recommended additional environmental studies for the Matagorda Bay and Estuariesand subsequently submitted this recommendation to the Texas Water Development Boardfor approval and funding. Accordingly, additional field studies were initiated and conductedin 2014. The existing South Texas Project surface water diversion right is not impacted by thislegislation. Additional information regarding environmental flows can be found at http://www.tceq.texas.gov/permitting/wate rsu pply/water-rights/eflows/.In January 2010, the Texas Commission on Environmental Quality approved a revised LowerColorado River Authority Water Management Plan. The Water Management Plan determineshow water is allocated from the Highland Lakes (specifically, Lakes Travis and Buchanan) to meetthe needs of water users, including the South Texas Project, during water supply shortages.As part of the of January 2010 approval of the revised Water Management Plan, the TexasCommission on Environmental Quality directed the Lower Colorado River Authority to filean application to revise the Water Management Plan no later than July of 2013. To assistwith this update, the Lower Colorado River Authority assembled an advisory committee torepresent the diverse interests that rely on the Highlands Lakes water supply. The advisorycommittee included representatives from cities, industry, lake area business and residents,the environment and agriculture. The advisory committee started in July 2010 and completedits recommendations in late 2011. The South Texas Project represented industrial firm watercustomers on the advisory committee. The Lower Colorado River Authority Board of Directorsapproved the revised plan in 2012 and forwarded it to the Texas Commission on EnvironmentalQuality for final approval. The Texas Commission on Environmental Quality subsequentlydetermined that it was necessary to update the plan to include more recent drought data.The Lower Colorado River Authority filed an amended application incorporating the updateddata with stakeholder input in 2014. The plan remains under technical review by the TexasCommission on Environmental Quality. Additional information on the Water Management Plancan be found at http://www.lcra.org.In 1999, the South Texas Project developed, submitted and implemented an initial stationWater Conservation Plan in accordance with state water use regulations. The purpose of thestation's Water Conservation Plan is to identify and establish principles, practices, and standardsto effectively conserve and efficiently use available water supplies and provide historical andprojected average industrial water demand. Annual implementation reports are submitted tothe Texas Water Development Board. Plans are required to be updated every five years. Thestation reviewed, updated and re-submitted a revised plan to the Texas Water DevelopmentBoard in 2014. The South Texas Project personnel understand that the water resources of thestate are a critical natural resource requiring careful management and conservation to preservewater quality and availability. Accordingly, the station continues to explore and support effortsfocusing on the efficient use of water resources and reduction of water waste.4-8STP Nuclear Operating Company 2014 Environmental ReportAIR QUALITY MANAGEMENTAir emission sources at the South Texas Project fall under the scope of air pollution regulationspromulgated under the Texas Clean Air Act and the Federal Clean Air Act and the numerousassociated amendments. The purpose of these regulations is to protect air resources frompollution by controlling or abating air pollution and emissions. The South Texas Project usessmall amounts of fossil fuel for backup and emergency equipment. Regulated emission sourcesat the South Texas Project include a fossil-fuel boiler, diesel-powered emergency generators andfire pumps, fire-fighting training, and other minor maintenance equipment and activities. Thestation submits a report of air emissions annually to the Texas Commission on EnvironmentalQuality.The South Texas Project has one fossil fuel-fired auxiliary steam boiler available to furnish steamfor plant use when steam is not available from the nuclear steam supply system. In addition tothe auxiliary steam boiler, a number of fossil-fueled diesel generators are located onsite. Thesediesels are designed to provide emergency power to various plant systems or buildings in theevent of a loss of power. This equipment is not normally needed for daily operations and thestation does not use it to produce electricity for distribution. Routine maintenance runs areconducted to ensure availability if needed and for equipment maintenance.Photo By: Janice HopesSTP Nuclear Operating Company4-9 Nonradiological Environmental Operating ReportThe Federal Clean Air Act mandates a permitting program to clearly define applicable air qualityrequirements for affected facilities such as the South Texas Project. This program is commonlyknown as the Title V Federal Operating Permit Program and is administered by the state. Thestation's Federal Operating Permit grants authority to operate identified emission sources atthe station in accordance with applicable permit and regulatory requirements. The stationnotified the Texas Commission on Environmental Quality of changes related to replacement oftwo tanks at the station's Fuel Island in 2014. The new applicable requirements associated withthe changes will be incorporated into the permit in the next renewal. The Texas Commission onEnvironmental Quality conducted one onsite inspection in 2014 for compliance with applicablerequirements for air quality as identified in the station's Federal Operating Permit. No findingsor violations were identified.Unlike conventional electrical generating stations, nuclear power plants do not burn fossilfuel for production of electricity. Therefore, the South Texas Project produces virtuallyno greenhouse gases or other air pollutants that are the typical by-products of industrialproduction processes. The use of emissions-free nuclear power is a significant contributor tothe preservation of our community's clean air resources.Photo By: Edmond Hardcastle4-10STP Nuclear Operating Company 2014 Environmental ReportNONRADIOACTIVE WASTE MANAGEMENTSolid waste management procedures for hazardous and non-hazardous wastes generated at theSouth Texas Project ensure that wastes are properly dispositioned in accordance with applicablefederal, state, and local environmental and health regulations. By regulatory definition, solidwaste includes solid, semi-solid, liquid, and gaseous waste material. The Texas Commissionon Environmental Quality, which administers the Texas Solid Waste Disposal Act and also thefederal Resource Conservation and Recovery Act program, is the primary agency regulatingnonradioactive wastes generated at the South Texas Project. The Texas Commission onEnvironmental Quality regulates the collection, handling, storage, and disposal of solid wastes,including hazardous wastes. The transportation of waste materials is regulated by the UnitedStates Department of Transportation.The South Texas Project is classified as a small quantity generator of industrial solid wastes.Texas Commission on Environmental Quality regulations require that industrial solid wastesgenerated at the South Texas Project be identified to the Commission. These are listed in theTexas Commission on Environmental Quality Notice of Registration for the South Texas Project.The registration is revised whenever there is a change in waste management practices at thesite. Hazardous waste and Class I non-hazardous waste handling and disposal activities aresummarized and documented in a waste summary report for the South Texas Project that issubmitted annually to the Texas Commission on Environmental Quality. The station's five yearSource Reduction and Waste Minimization plan for hazardous waste was updated and theassociated executive summary submitted to the Texas Commission on Environmental Qualityin 2014.Hazardous waste accumulation at the South TexasProject in 2014 was limited to a maximum holdingperiod of 180 days. The Resource Conservation andRecovery Act and Texas Solid Waste Disposal Actalso requires the use of proper storage and shippingcontainers, labels, manifests, reports, personneltraining, a spill control plan, and an accidentcontingency plan. Plant personnel routinely inspectareas throughout the site to ensure wastes are notstored or accumulated inappropriately.Station policies and regulations encourage therecycling, recovery, or reuse of waste when possibleto reduce the amount of waste generated or disposedof in landfills. Approximately 89 percent of theindustrial nonradioactive waste generated in 2014 atthe South Texas Project was recycled or processed forreuse. (Reference Figure 4-1) Used oil, diesel fuels,electro-hydraulic fluid and used oil filters are sent to arecycling vendor for reprocessing. Empty polyethylene Photo By: Connie MilliffSTP Nuclear Operating Company4-11 Nonradiological Environmental Operating Reportdrums are returned, when possible, to the original manufacturer for reuse. Non-hazardousblast grit and construction debris were also shipped for recycle in 2014. This includedapproximately 15,665 tons of concrete for recycle. In addition, the station supports recyclingprograms for cardboard, paper, aluminum, printer cartridges and plastic. Approximately 127tons of scrap metal, in addition to tin and steel recovered from building demolitions, wereremoved from the station for recycle in 2014. The station continues to explore new areas whererecycling may be expanded or initiated.Nonradioactive solid waste that cannot be shipped for recycling is shipped for disposal.Municipal-type trash is transported to an offsite landfill. Hazardous waste accounts for onlya small portion of the waste generated at the South Texas Project; however, minimizationand reduction of hazardous waste generation where feasible remains an important goal atthe station. Changes in the amount of hazardous waste shipped each year generally reflectdifferences in operation and maintenance activities that result in the generation of hazardouswaste. Successful waste minimization and source reduction efforts by employees haveallowed the South Texas Project to remain classified as a small-quantity generator since 2004.(Reference Figures 4-2 and 4-3)DON- BINs veo docurments that am no longer neededExamprne-Bank Statements* Insurance Forms.Credit Card StatementsInoeTax Records*MdclRecordsInvestment InformationUmitof6 boxes (I S202.50) per housltaL.PLmoaper products onlylt4-12STP Nuclear Operating Company 2014 Environmental Report2014 Nonradioactive Waste ManagementSouth Texas ProjectRecycle88.99%Incineration &/Fuel Blending0.15%"-ýLandfill10.86%Figure 4-12014 Nonradioactive Waste GenerationSouth Texas ProjectNon-HazardousWaste99.885%Hazardous Waste/0.004%VUniversal Waste0.041%Used Batteries0.070%Figure 4-2STP Nuclear Operating Company4-13 Nonradiological Environmental Operating ReportHazardous Waste ShippedHistorical ComparisonSouth Texas Project430212010 2011 2012 2013 2014YearFigure 4-3CHEMICAL CONTROL AND MANAGEMENTThe station's Integrated Spill Contingency Plan for the South Texas Project Electric GeneratingStation, updated and recertified in 2014, consolidates multiple federal and state requirementsinto one plan. The plan is implemented through standard site operating procedures andguidelines. The South Texas Project uses standard operating procedures, policies, and programsto minimize the generation of waste materials, control chemical use, and prevent spills. TheSouth Texas Project also evaluates chemicals and products proposed for use at the station. Siteprocedures that implement the station's Integrated Spill Contingency Plan and the station'sChemical Control Program address the evaluation, storage, use, labeling, spill control, anddisposal requirements of chemicals. These guidelines also assist in reducing waste generation,ensuring proper packaging for disposal and mitigating the consequences of inadvertent spillage.The South Texas Project emphasizes awareness training for spill prevention and maintainsstation readiness to respond should a spill occur. Spill response team members receive annualrefresher training in hazardous material incident response. No reportable, significant, orconsequential spills occurred in 2014.4-14STP Nuclear Operating Company 2014 Environmental ReportENVIRONMENTAL PROTECTION PLAN STATUSThe South Texas Project's Environmental Protection Plan was issued in March of 1989 toprotect nonradiological environmental values during operation of the South Texas Project.This report reviews Environmental Protection Plan non-compliances, if any, identified bythe plant in 2014 and the associated corrective actions taken to prevent their recurrence.Potential nonconformities are promptly addressed, as identified, to maintain operations inan environmentally acceptable manner. The station uses its Corrective Action Program todocument these conditions and track corrective actions to completion. Internal assessments,reviews and inspections are also used to document compliance.This report also reviews non-routine reports submitted by plant personnel and any activitiesthat involved a potentially significant unreviewed environmental question. A proposedchange, test or experiment is considered to present an unreviewed environmental question if itconcerns:1) A matter that may result in a significant increase in any adverse environmental impactpreviously evaluated in the Final Environmental Statement related to the Operationof South Texas Project, Units 1 and 2 (Docket Nos. 50-498 and 50-499), environmentalimpact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or,2) A significant change in effluents or powerlevel; or,3) A matter not previously reviewed andevaluated in the documents specified in (1)above, that may have a significant adverseenvironmental impact.No unreviewed environmental questions wereidentified in 2014.Events that require reports to federal, state or localagencies, other than the United States NuclearRegulatory Commission, are reported in accordancewith the applicable reporting requirements. TheUnited States Nuclear Regulatory Commission isprovided with a copy of any such report at the timeit is submitted to the cognizant agency. If a non-routine event occurs and a report is not required byanother agency, then a 30-day report to the UnitedStates Nuclear Regulatory Commission is required bythe Environmental Protection Plan. No such 30-dayor other non-routine report was required in 2014. D U... I....,.oto By: ene se etSTP Nuclear Operating Company4-15

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Radiological Environmental Introduction and SummaryThe Radiological Environmental Monitoring Program is designed to evaluate the radiologicalimpact of the South Texas Project on the environment by collecting and analyzing samples forlow levels of radioactivity. Measurements of samples from the different pathways indicate thatthere is no adverse effect offsite from the operation of the South Texas Project.Only tritium and naturally occurring radioactive material were identified in the offsiteenvironmental samples in 2014. Samples of fish and meat collected and analyzed show noplant-related nuclides were present. Water samples from the onsite drinking water supply fromthe deep aquifer and from offsite sampling stations on the Colorado River show only naturalbackground radioactivity. The station also continues to monitor for radioactivity in onsitesediment of the Main Cooling Reservoir and ditches. Measurements of direct radiation onsiteand offsite indicated no dose limits were exceeded.Tritium is a radioactive isotope of hydrogen that is produced in the reactor and cannot beremoved from effluents released to the Main Cooling Reservoir because it is a part of the watermolecule. Due to the design of the Main Cooling Reservoir, the presence of tritium in varioussloughs and ditches onsite and the shallow aquifer was expected. Tritium has been detected inthese types of samples and the concentrations remain below the United States EnvironmentalProtection Agency drinking water limits.Photo By: Edmond Hardcastle and Aubrey Passafuma5-2STP Nuclear Operating Company 2014 Environmental ReportIn 2005, several nuclear plants discovered tritium in groundwater on site at levels exceeding theUnited States Environmental Protection Agency drinking water limits, mainly near undergroundprocess or effluent pipes. To determine if this were the case at the South Texas Project, testwells near underground process and effluent pipes were sampled and analyzed for tritium.Although some results were positive, all results were below the United States EnvironmentalProtection Agency drinking water limits.A sampling program was developed to monitor the tritium in the immediate area aroundthe nuclear plants for long term trending. Wells are sampled semi-annually, annually, andonce every five years, depending on location and the amount of tritium present. The tritiumconcentration remained below the United States Environmental Protection Agency drinkingwater limits in 2014 and within the design basis of the South Texas Project.Analyses of the data collected from the implementation of the Radiological EnvironmentalMonitoring Program indicates that the operation of the South Texas Project has no adverseoffsite radiological impact.Photo By: Gary ParkeySTP Nuclear Operating Company5-3 Photo By: Edmond Hardcastle and Aubrey Passafuma5-4 STP Nuclear Operating Company