ML061770136

State of Vermont Public Service Board, 2003, Prefiled Testimony of Sonja A. Schuyler on Behalf of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. Feb. 21, 2003

ML061770136
Person / Time
Site:	Vermont Yankee
Issue date:	02/21/2003
From:	Brown V, Franklin G Eggleston & Cramer, Ltd
To:	Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee, Office of Nuclear Reactor Regulation
References
%dam200611
Download: ML061770136 (149)

Text

STATE OF VERMONT PUBLIC SERVICE BOARD Docket No.

Petition of Entergy Nuclear Vermont Yankee,. LLC ))

and Entergy Nuclear Operations, Inc., pursuant to 30 V.S.A. §248, for a Certificate of Public Good )

to modify certain generation facilities )

PETITION AND PREFILED TESTIMONY ON BEHALF OF ENTERGY NUCLEAR VERMONT YANKEE, LLC AND ENTERGY NUCLEAR OPERATIONS, INC.*

February 21, 2003 Volume 2 of 2 A

EGGLESTON & CRAMER, LTD.

Victoria L Brown P.O. Box 1489 150 South Champlain Street Burlington, VT 05402-1489 (802) 864-0880 Caw)

STATE OF VERMONT PUBLIC SERVICE BOARD Docket No.

Petition of Entergy Nuclear Vermont Yankee, LLC )

and Entergy Nuclear Operations, Inc. pursuant to )

30 V.S.A. §248, for a Certificate of Public Good )

to modify certain generation facilities )

PREFILED TESTIMONY OF SONJA A. SCHUYLER ON BEHALF-OF ENTERGY NUCLEAR VERMONT YANKEE, LLC AND ENTERGY NUCLEAR OPERATIONS. INC.

February 21, 2003 Summar: Ms. Schuyler's testimony addresses the impacts of the proposed uprate on the environmental criteria contained in 30 V.S.A. 248(bX5), j&, the impact on esthetics, historic sites, air and water purity, the natural environment and the public health and safety, taking into consideration criteria in 10 V.S.A. § 1424a and § 6086(a) I through 8 and 9 (K). Her testimony also addresses §248 (bX8) -

impact on outstanding resource waters - as well as compliance with Executive Order 80-52 regarding Agricultural Resources.

STATE OF VERMONT PUBLIC SERVICE BOARD Docket No.

Petition of Entergy Nuclear Vermont Yankee, LLC )

and Entergy Nuclear Operations, Inc., pursuant to )

30 V.S.A. §248, for a Certificate of Public Good )

to modify certain generation facilities )

PRE-FILED TESTIMONY OF SONJA A. SCHUYLER

1. INTRODUCTION ................................................................................................................ 2 II. 248 (BX5): THE ACT 250 CRITERIA [10 V.S.A. §6086(AXI) THROUGH 8 AND 9(K)

AND §1424a(d)] ................................................................................................................... 6 A. Criterion 1 Air and Water Pollution ............................................................................ 6

1. Air Pollution .................................................................................................................. 6

2. Water Pollution ........................................................................................................... 10

a. Criterion I (A) Headwaters .................................................................................. 10

b. Criterion 1 (B) Waste Disposal ............................................................................ 10 (1) Wastewater ........................................................................................................... 11 (2) Solid Waste ...................................................................................................... 15 (3) Radioactive Waste ............................................................................................ 17 (4) Hazardous Waste .................................................................................................. 17

c. Criterion I(C) Water Conservation ..................................................................... 19

d. Criterion I(D) Floodways and § 1424a(dX3) ..................................................... 21

e. Criterion I(E) Streams [10 V.S.A. §1424 a(d)(l)] ............................................. 21

f. Criterion i(F) Shorelines [10 V.S.A. §1424 a(dX8X12)] ....................................... 23

g. Criterion I(Q) Wetlands .................................................................................... 23 B. Criterion 2 Sufficient water available ....................................................................... 24 C. Criterion 3 Burden on existing water supply [10 V.S.A. §1424 a(d)(12)] ................. 25 D. Criterion 4 Soil Erosion and nmoff characteristics of site ........................................ 26 E. Criterion 5 Highway congestion and traffic safety .................................................. 26 F. Criterion 6 Educational Services .............................................................................. 28 G. Criterion 7 Municipal Services ................................................................................. 29 H. Criterion 8 Scenic or natural beauty, aesthetics, historic sites, or rare and irreplaceable natural areas [10 V.S.A. §1424 a(d)(7)(X9XlOXI 1)] ............ ...... ........... 29 I. Criterion 8 (A) Necessary wildlife habitat and endangered species [10 V.S... §1424 a(dX4X5X6)] .................................................................................................................... 33 J. Criterion 9(K) Impact on Public Investments [10 V.S.A. §1424 a(d)(12)] ... ......... 34 1I. 248 (BX8) EFFECT ON OUTSTANDING RESOURCE WATERS [10 V.S.A. §1424 a(d)(13)] ........................................................................................................................... 34 IV. EXECUTIVE ORDER 80-52: AGRICULTURAL RESOURCES ............................... 35 A

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 2 of 35 STATE OF VERMONT PUBLIC SERVICE BOARD Docket No.

Petition of Entergy Nuclear Vermont Yankee, LLC) and Entergy Nuclear Operations, Inc., pursuant to )

30 V.S.A. §248, for a Certificate of Public Good )

I to modify certain generation facilities )

2 I. INTRODUCTION 3 Q1. Please state your name and business address.

4 Response: My name is Sonja A. Schuyler and my business address is The Johnson 5 Company, Inc., 100 State Street, Suite 600, Montpelier, VT 05602.

6 Q2. What is your occupation?

7 Response: I am a Senior Scientist at The Johnson Company, Inc., an environmental 8 science and engineering consulting firm in Montpelier, Vermont In this capacity, I have 9 prepared pre-filed testimony for Section 248 Certificate of Public Good filings. I have also 10 prepared Act 250 Land Use Permit applications. A copy of my resume is attached as Exhibit 11 EN-SAS-I.

12 Q3. Have you previously testified before the Vermont Public Service Board or 13 other state or federal agencies?

14 Response: Yes. I have testified before the Vermont Public Service Board in Docket 15 5330, Application of 24 Electric Utilities for a Certificate of Public Good authorizing execution a6 and performance of a firm power and energy contract with Hydro Quebec, and in the dockets for

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 3 of 35

.1 several independent power purchase contracts with Vermont Power Exchange in the 1980s. I 2 have also testified before the Vermont Environmental Board and Vermont Water Resources 3 Board on the appeal of an Act 250 Permit Amendment and NPDES permit for the UniFirst 4 facility in Williamstown, Vermont, and in Act 250 Land Use Permit Hearings before District 5 Environmental Commissions in Vermont.

6 Q4. What is the purpose ofyour testimony?

7 Response: The purpose of my testimony is to address the requirements related to 8 environmental impacts for a Certificate of Public Good ("CPG") under Title 30 Section 248, 9 (bX5). Entergy Nuclear VY seeks a CPG to implement a "power uprate" at the Vermont Yankee 10 Nuclear Power Station (the "VY Station") at Vernon, Vermont. Specifically I will address §248 11 suberiteria (bX5) - impact on esthetics, historic sites, air and water purity, the natural 12 environment and the public health and safety, taking into consideration criteria in 10 V.S.A. § 13 1424a and § 6086(a) 1 through 8 and 9 (K). My testimony will also address §248 (bX8) -

14 impact on outstanding resource waters, as well as compliance of the project with Executive Order 15 8052 regarding Agricultural Resources.

16 QS. Please summarize your understanding of the VY Station and the uprate 17 project.

18 Response: The VY Station is located in Vernon, Vermont, on the Connecticut River 19 0.75 miles upstream of the Vernon Dam, and is shown on the Site Location Map (Exhibit EN-(Q 20 SAS-2). The surface water intake and cooling water and stormwater discharge points for the VY A

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 4 of 35 I Station are located on the impoundment of the Connecticut River upstream of Vernon Dam 2 known as Vernon Pool. Vernon Pool is a 25-mile long impoundment that extends from Vernon 3 Darn north to the foot of the Bellows Falls Dam in Bellows Falls, Vermont. At full-pond 4 elevation of 22.13 ft, Vernon Pool encompasses a 2,550-acre area.

5 Entergy Nuclear VY proposes a power uprate that will result in an approximate 20%

6 increase in electrical generating capacity at the Vermont Yankee plant. This process can increase 7 the power output at the plant by up to I10 MW from current net generation of approximately 510 8 MW. Power uprate increases the output of the plant through the increase in reactor core power 9 and the resulting increase in the amount of steam that passes to the turbine/generator. The 10 modifications to the VY Station necessary to implement the uprate involve the replacement or 11 upgrade of selected plant equipment with new equipment capable of handling the increased 12 power output. The existing cooling towers will also be modified to increase their cooling 13 capability. Importantly, from an environmental impact perspective, none of the proposed 14 modifications will significantly affect the physical layout of the plant, nor will any permanent 15 structures be built outside of existing building footprints, although a temporary office space 16 addition will be required for the project. The only outside work in connection with the uprate 17 was the replacement of the main transformer in the transformer area west of the turbine building.

18 (See the Site Plan, Exhibit EN-SAS-3.) The power uprate project is more completely described 19 in the testimony of Mr. Thayer.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 5 of 35 1 The power uprate will not require any increase in the size of the diesel generators used for 2 emergency electrical power for the facility, or any modifications to water intake or discharge 3 structures on the bank of the Connecticut River. The power uprate will increase the thermal 4 output of the VY Station reactor which may slightly increase the temperature of cooling water 5 discharged to the Connecticut River and may require more frequent operation of the plant cooling 6 towers.

7 Independent of this application to the Board, Entergy Nuclear VY is seeking an 8 amendment to the plant's National Pollutant Discharge Elimination System ("NPDES") permit to 9 allow the discharge of more heat to the Connecticut River. As I explain below, achieving the 10 power uprate is not contingent on receiving this permit amendment 11 Q6. How does the NPDES permit for the Entergy Nuclear VY station relate to 12 these proceedings?

13 Response: The VY Station operates subject to and with the benefit of an NPDES 14 permit (#VT0000264, VT DEC Permit No. 3-1199) to discharge to waters of the United States.

15 The permit was issued by the State of Vermont, Agency of Natural Resources, under authority 16 delegated to it by the United States Environmental Protection Agency (U.S.EPA), under §402 of 17 the federal Clean Water Act, and Vermont law, 10 V.S.A.§ 1259 and §1263. A copy of this 18 permit is attached as Exhibit EN-SAS-4. Operation of the facility in compliance with this permit 19 as now issued or as subsequently amended creates a rebuttable presumption in this proceeding J

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY Febkiaiy 21, 2003 Page 6 of 35 1 that the power uprate will not have an adverse impact on water quality in the Connecticut River 2 as judged by the Act 250 criteria.

3 II. 248 ('B)(5): THE ACT 250 CRITERIA 110 V.S.A. 46086(A)(1) THROUGH 8 AND 4 9(K) AND §1424a(d)l 5 Q7. Will this project have an undue adverse effect on esthetics, historic sites, air 6 and water purity, the natural environment and the public health and safety?

7 Response: No. This project will not have an undue adverse effect as judged by the 8 criteria specified in 10 V.S.A. Sec. 1424 a(d) and Sec. 6086(aXl) through (8) and (9)(K). My 9 testimony below will address each criterion. The testimony has been organized to address the 10 Act 250 criteria in order. Where the analysis of those criteria also overlap with the criteria under 11 10 V.S.A. Sec. 1424 a(d), I will discuss them together and note the relevant criterion in 12 parentheses after the question.

13 A. Criterion 1 Air and Water Pollution 14 L Air Pollution 15 Q8. Is the VY Station considered a Source for the purpose of the Vermont Air 16 Pollution Control Regulations?

17 Response: Yes. The VY Station is a Registered Source as defined by 5-801 of the 18 Vermont Air Pollution Control Regulations, which means that it emits or has the potential to 19 emit air contaminants that, in total, amount to more than five (5) tons per year. As discussed

~0 below, VY Station is also an Indirect Source as defined by 5-101 of the Regulations, but it does I

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY Februay 21, 2003 Page 7 of 35 1 not require a New Source Construction and Operating Permit or an Indirect Source Permit.

2 Q9. Will this project result in undue air pollution?

3 Response: No. The VY Station is in full compliance with Vermont Air Pollution 4 Control regulations as reported in its annual renewal of Air Source Registration that

-5 demonstrates that VY Station's air emissions are less than 10 tons per year. Entergy Nuclear VY 6 makes the required reports and payment of fees for the annual renewal of its Air Source 7 Registration. The 2002 Air Pollutant Emissions Inventory Report is presented in Exhibit EN-8 SAS-5. The proposed changes will not affect the facility's status as a Registered Source. No 9 changes are proposed for the power uprate that would significantly increase its air emissions, so 10 no undue air pollution, as judged by Vermont's Air Pollution Control Regulations, will occur.

11 Q10. Does the VY Station hold an Air Source Construction and Operating Permit?

12 Response: No. The total of allowable air contaminant emissions from the VY Station 13 is less than 10 tons peryear so it is not subject to the permit requirement under Subchapter X, 14 Operating Permits, of the Vermont Air Pollution Control Regulations. The reported emissions 15 come from fuel burning in furnaces and emergency generators. The threshold for treatment as a 16 Major Stationary Source which would require a permit for construction or modification is 17 allowable emissions of one or more criteria air contaminant greater than 50 tons per year, well

18. above the less than 10 tons produced by Entergy Nuclear VY. Thus, the VY Station is not 19 required to obtain a New Source Construction permit. The proposed power uprate will not result 0 in a physical modification or operational change that would cause the quantity of allowable

Prefiled Testimony of Sonja A. Scbuyler Entergy Nuclear VY February 21, 2003.

Page 8 of 35 1 emissions from the VY Station to increase. Accordingly, a New Source Construction or 2 Operating Permit would not be required.

3 Q1I. Is the VY Station an Indirect Source as defimed by Section 5-101 of the 4 Vermont Air Pollution Control Regulations?

5 Response: Yes. The VY Station is a facility "...that leads to associated mobile source 6 activity as a result of which any air contaminant is or may be emitted." The VY Station 7 employees travel to and from the facility daily by car, deliveries of supplies and materials are 8 made by truck, and solid waste is removed by truck.

Q12. Would the power uprate be a modification to an Indirect Source that would 10 require Entergy Nuclear VY to obtain an air permit?

11 Response: No. The parking area at the site has 433 spaces which is fewer than the 12 1,000 spaces that would make the VY Station subject to permit requirements. The power uprate 13 will not increase the number of permanent employees at the facility;, and therefore, will not 14 require the addition ofparking spaces that would make the project subject to permit 15 requirements. (Vermont Environmental Protection Regulations Section 5-503 (a)).

16 Arrangements for temporary parking during the uprate construction are discussed in Q59 below 17 under the traffic criterion.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 9 of 35 1 Q13. Are there any process emissions or noxious odors which will result from this, 2 project, and, if so, how will they be controlled?

3 Response: Entergy Nuclear VY does not produce typical greenhouse gases as part of 4 the electricity production process. There are no noxious odors produced as part of the electricity 5 generating process.

6 The operations and maintenance activities required after the uprate will be essentially the 7 same as at present, so no increases in emissions or noxious odors are anticipated from them. The 8 current reportable emissions from plant operations are presented in Exhibit EN-SAS-5.

9 Q14. Are there any sources of noise which will result from this project?

10 Response: No. As presented in Mr. Yasi's testimony, Entergy Nuclear VY had a 11 noise analysis of the proposed changes to the cooling towers performed that showed that the 12 change in sound levels from cooling tower operation after the upgrade compared to current 13 operation should not be noticeable.

14 Q15. How will dust be controlled during construction of this project?

15 Response: The only outside construction required for the power uprate will be the 16 installation of the temporary office space. Since mobile units are planned, outside construcfion 17 will be minimal, so dust control will not be required. Parking areas are existing paved or gravel 18 surfaces, so parking will not be a source of dust.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 10 of 35 1 2. Water Pollution.

2 a. Criterion 1 (A) Headwaters 3 Q16. Does the project site qualify as a headwaters area as defined in 10 V.S.A. See.

4 6086(aXl)(A)?

5 Response: No. The site is located on the Connecticut River in Vernon, Vermont, at 6 an elevation of 260 feeL (See Site Location Map EN-SAS-2). The facility is in the developed 7 area of the Town of Vernon and the site itself has been extensively developed for the nuclear 8 power plant. At this point the watershed is not characterized by steep slopes, or shallow soils.

9 The drainage area is greater than 20 square miles, and the elevation is less than 1,500 feet. It is 10 not in the watershed for a surface water designated public water supply, and is not in a significant S1I aquifer recharge area.

12 b. Criterion 1 (B) Waste Disposal 13 Q17. Will the project meet any applicable Department of Environmental 14 Conservation Department regulations regarding the disposal of wastes?

15 Response: Yes. As detailed in the following testimony, the power uprate project will 16 meet the applicable regulations regarding the disposal of wastes. The VY Station holds several 17 permits and certifications for disposal of wastes that the State of Vermont uses to protect 18 groundwater and surface water resources and public health. Some aspects of the project may 19 change waste volumes that must be managed. The potential impact ofthese changes on the

'70 facility's permits and certifications is discussed below.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 11 of 35 1 Q18. Are there any aquifer protection areas on the Entergy Nuclear VY property 2 in Vernon, Vermont? [10 V.S.A. §1424a(d)(2)]

3 Response: No. There are no aquifer protection areas on the property (See Site Plan, 4 Exhibit EN-SAS-3). Therefore, waste disposal will not affect aquifer recharge areas.

5 (1) Wastewater 6 Q19. What are the sources of wastewater discharge from the VY Station?

7 Response: There are four sources of wastewater discharge from the VY Station.

8 Wastewater that is discharged to the Connecticut River consists of three waste streams: 1) the 9 main condenser cooling water discharge; 2) the service water system discharge; and 3) 10 stormwater discharge. The fourth source is domestic sewerage from the facility that is 11 discharged to septic systems.

12 Q20. What is the existing water quality and current water quality classification of 13 the Connecticut River at Vernon, Vermont? [10 V.S.A. §1424a(dX1)]

14 Response: The water quality classification for the Connecticut River in this segment 15 is Class B. (Vermont Water Quality Standards, Section 4-13). The Connecticut River meets the 16 criteria for Class B waters in this reach.

17 Q21. How will the project affect surface water quality?

18 Response: The project will not have an undue adverse effect on surface water quality 19 because the facility will be operated in full compliance with the requirements of its existing C20 NPDES permit (Exhibit EN-SAS-4), or any subsequent amendment to that permit. In order for

Prefiled Testimony of Sonja A. Scbuyler Entergy Nuclear VY February 21,2003 Page 12 of 35 I the Vermont Agency of Natural Resources to issue an NPDES permit, it must find "that the 2 discharge: (1) will not significantly alter the aquatic biota in the receiving waters, (2) will not 3 pose more than a negligible risk to public health, (3) will be consistent with existing and 4 potential beneficial uses of the waters, and (4) will not cause a violation of water quality 5 standards." [10 V.S.A. § 1259(e)]

6 Q22. How would you characterize cooling water discharge from the VY station?

7 Response: The VY Station produces non-contact cooling water as a by-product firom 8 the generation of electricity. Non-contact means that the water discharged to the Connecticut 9 River is never in direct contact with the reactor or any radioactive water. The VY Station 10 withdraws water from the Connecticut River to condense the steam used to drive the turbine 11 generator. Heat produced during the cooling of steam in the main condenser is discharged as 12 heated water. The discharge of heated water is governed by the NPDES permit Biocides are 13 added to the circulating water to prevent fouling of the condenser tubes. The biocide application 14 is also governed by the NPDES permit.

15 Q23. How would you characterize service water discharge from the VY station?

16 Response: The service water system is used to cool internal plant equipment other 17 than the main condenser and for other maintenance work that does not require potable water.

18 River water is used to backwash the intake screens, strainers, and water treatment sand filter, and 19 this backwash is discharged to the river. Boiler blowdown from the heating boilers is discharged C 0 with the service water, but the heating boiler water comes from on-site wells. These discharges

Prefiled Testimony of Sonja A. Schuyler February 21, 2003 Page 13 of 35 1 are subject to the NPDES pennit. No appreciable change to the service water discharge volume 2 is anticipated as a result of the power uprate.

3 Q24. How would you characterize stormwater discharge from the VY station?

4 Response: The developed area of the VY Station is served by a storm sewer system 5 that discharges to the Connecticut River and is permitted by the NPDES permit The north storm 6 drain system and the southeast storm drain system have separate discharge points. The south 7 storm drain system discharges through the discharge structure that also handles the cooling water 8 and service water dicharges. These discharge points are shown on the Site Plan, Exhibit EN-9 SAS-2.

10 Q25. Does the project require amendment of the NPDES permit for changes to the II stormwater discharge system?

12 Response: No. However, I am aware that an NPDES permit amendment application 13 is pending that solely addresses modifications to the stormwater management system, and thus is 14 unrelated to the power uprate project.

15 Q26. Does the project require a Construction Site Runoff General Permit?

16 Response: No. The area disturbed during the exterior project construction will be 17 less than one acre and will consist of minor work required to install the temporary office space.

18 The threshold for coverage under the Construction Site Runoff General Permit is now two acres 19 of disturbance, but a change to a one-acre threshold is pending. In either case, application for 20 coverage under the General Permit will not be required for this project.

Profiled Testimony of Sonja A. Scbuyler Entergy Nuclear VY Febnrary 21, 2003 Page 14 of 35 1 Q27. How would you characterize wastewater discharge to the septic systems?

2 Response: Sanitary wastewater and laboratory wastewater from the facility are 3 discharged to on-site septic systems. There are six septic systems: Main (North) System; 4 Construction Office Building (COB) (South) System; New Office Building System; New 5 Warehouse System; Governor Hunt House System; and Gatehouse #1 System. The on-site 6 systems are covered by Vermont Indirect Discharge Permit ID-9-0036-lA (Exhibit EN-SAS-6),

7 which permits a discharge of up to 26,297 gallons per day (gpd) of wastewater during 8 maintenance outages. This total capacity is sufficient to accommodate the temporary increase in 9 workers required during plant shutdowns; however, the use of some of the individual systems 10 may need to be regulated during the power uprate construction period so that the individual 11 systems arc not over taxed. (The maximum water usage rate anticipated is presented in a 12 Memorandum from Southern Vermont Engineering Associates, Exhibit EN-SAS-7). The 13 septage from these septic systems is a solid waste that is managed on-site, as discussed below.

14 Q28. Will a temporary Pollution or Discharge permit be required by this project?

15 Response: No. No construction will occur in or adjacent to surface waters "...that 16 may result in unavoidable short term non-compliance with the turbidity or aquatic biota, wildlife, 17 and aquatic habitat criteria." (Vermont Water Quality Standards, Section 2-03, B. 1.) Therefore, 18 a temporary pollution or discharge permit will not be required.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY Febnrary 21, 2003 Page 15 of 35 1 (2) Solid Waste 2 Q29. How is septage from the on-site wastewater treatment system handled?

3 Response: The solids from the septic system are managed by land application on-site 4 according to the conditions in the Indirect Discharge permit referenced above; the Vermont Solid 5 Waste Management Facility Certification #F9906-A1 (Exhibit EN-SAS-8); and VY NRC Offsite 6 Dose Calculation Manual, Appendix L (Exhibit EN-SAS-9). Two areas have been approved for 7 land application, the North Field and the South Field. (See the Sludge and Silt Disposal Areas, 8 Exhibit EN-SAS-10). An extensive monitoring program is in place for the land application 9 areas.

109 Q30. What other wastes are managed by land application on-site and would the 11 quantity of waste increase?

12 Response: Silt from the cooling towers accumulates in a basin under the west cooling 13 tower. The basin is cleaned out once per operating cycle, and the silt is spread on the same fields 14 that are used for the septic systems. The source of the silt is suspended solids in the cooling 15 water taken from the river and solids from the cooling towers that wash into the basin. The 16 amount of silt deposited in the basin may increase ifmore river water passes through the cooling 17 towers.

Profiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21,2003 Page 16 of35 1 Q31. Does the VY Station have the capacity to continue.land application of septage 2 and cooling tower silt?

3 Response: Yes. The facility has been operating using only the 1.9-acre south field for 4 land application of all of the VY Station's septage, cooling tower silt and other waste soils. This 5 field is certified to receive 55,100 gallons of solids per year. The 7.4-acre north field, is certified 6 for 214,600 gallons per year. (See the Sludge and Silt Disposal Areas, Exhibit EN-SAS-10, and 7 the Solid Waste Management Facility Certification, Exhibit EN-SAS-8). The septage volumes 8 per refueling cycle would remain essentially the same because no increase in the work force is 9 expected except for the short duration of the uprate construction. As discussed in the testimony i 10 and exhibits of Mr. Yasi, the amount of the cooling tower silt could increase after power uprate U,,

11 from approximately 16,000 gallons per yearto approximately 47,000 gallons per year if the plant 12 operates under the existing NPDES permit. The cooling tower silt volume would intreaseo 13 approximately 56,000 gallons if the NPDES permit amendment is granted for the summer period 14 only. If the winter limits are also amended, the cooling tower silt volume would only increase to 15 23,400 gallons because the cooling towers would not need to operate in the winter. VY station 16 also has NRC approval to land spread up to 28.3 m3 (7,477 gallons) per year of soils from 17 miscellaneous construction and maintenance activities (See Exhibit EN-SAS-9). In any case, 18 sufficient capacity for land application of waste is available.

Prefiled Testimony of Sonja A. Scbuyler Entergy Nuclear VY February 21, 2003 Page 17 of 35 I Q32. What methods will be used for the disposal of stumps and.construction 2 debris?

3 Response: No stumps will be generated by the uprate. The construction debris from 4 the cooling tower upgrade will be taken to the Brattleboro transfer station and disposed of at a 5 licensed solid waste landfill.

6 (3) Radioactive Waste 7 Q33. Will the power uprate result in an increase in radioactive waste generation?

8 Response: Yes. An increase in low level and high level radioactive waste generation 9 will result from the power uprate. The quantification of this increase and the management of (10 these wastes are discussed in Mr. Thayer's testimony.

11 (4) Hazardous Waste 12 Q34. Will hazardous waste generation increase significantly as a result of the 13 power uprate?

14 Response: No. Hazardous waste generation will not increase significantly due to the 15 power uprate. Typical components of the hazardous waste stream are paints and solvents used 16 for facility maintenance. The Vermont Yankee facility maintains registration as a Large Quantity 17 Generator under the Vermont Hazardous Waste Management Regulations, Section 7-308, and the 18 VY Station status as a Large Quantity Generator will be maintained.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 18 of 35 1 Q35." How does Entergy Nuclear VY dispose of hazardous waste?

2 Response: Hazardous waste may be stored temporarily on-site up to 90 days, as 3 permitted by Vermont Hazardous Waste Regulations. Entergy Nuclear VY contracts with a 4 licensed hazardous waste disposal firm, such as Clean Harbors, Inc., to have the wastes disposed 5 of at a certified hazardous waste disposal facility.

6 Q36. Will any asbestos or lead-based paint waste be generated during the power 7 uprate construction?

8 Response: Yes. Asbestos removal will be required during the power uprate. The 9 asbestos covered stator bars in the Main Generator will be removed and replaced. Four asbestos-4 90 insulated feedwater heaters that are painted with lead-based paint will be replaced during the 11 power uprate project. These heaters will be encapsulated and removed. All asbestos and lead 12 abatement will be completed by certified asbestos and lead-based paint abatement contractors.

13 All asbestos containing wastes will be disposed of at a landfill licensed for asbestos waste. The 14 estimated quantity of asbestos to be removed is 600 cubic feet. (See Exhibit EN-SAS-11).

15 Q37. A new main transformer was installed during re-fueling outage (RFO) 23. Is 16 the existing spill containment system design capable of containing a release of dielectric 17 fluid from the main transformer?

18 Response: Yes. The spill containment system was modified to accommodate the 19 increased volume of dielectric fluid in the new transformer. The Spill Prevention Control and

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 19 of 35 I Countermeasure (SPCC) Plan for the facility has been revised to include the new main 2 transformer. The revised SPCC Plan is presented in Exhibit EN-SAS-12.

3 c. Criterion I(C) Water Conservation 4 Q38. How is water used at the VY Station?

5 Response: As noted above, water is used to produce steam, to condense steam, and to 6 cool process equipment during the generation of electricity. It is also used in the heating systems 7 for some buildings, and to provide potable water and domestic wastewater disposal for plant 8 employees. Water sources for the VY Station are the Connecticut River and on-site groundwater 9 wells.

109 Q39. Will more water be consumed as a result of the power uprate and, if so, what 11 steps could be taken to minimize the increase? 110 V.S.A. 1424 a(d)(14)]

12 Response: Use of the cooling towers results in evaporative loss of water taken from 13 the Connecticut River. If the facility operates under the thermal discharge conditions of its 14 existing NPDES permit (Exhibit EN-SAS-4), the evaporative water loss due to cooling tower 15 operation is expected to increase slightly after uprate. If an NPDES permit amendment is granted 16 to change the thermal discharge conditions as requested, the potential increase in evaporative loss 17 would be reduced. Mr. Yasi's testimony and studies compare the potential evaporative losses 18 from power uprate for plant operation under the conditions of the existing NPDES permit and 19 under the conditions requested in the NPDES permit amendment application.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 20 of 35 I The worst case for evaporative loss under either set of permit conditions would occur if 2 the weather conditions for the highest evaporation rate coincided with river' flow at 1250 cfs, the 3 minimum flow requirement for the Vernon Dam. In that case, the loss would be less than 1.5%

4 of stream flow. The Vermont Water Quality Standards require that all uses of water be supported 5 by the streamflow, and they use a streamflow protection guideline of no more than 5 percent 6 diminished flow at the 7Q10 2 stream flow rate (Vermont Water Quality Standards Section 3-01, 7 B. 1.). Thus, the additional evaporative loss due to power uprate would not be significant based 8 on this guideline. If the requested amendment to the NPDES permit is granted, the evaporative 9 losses after power uprate will be less than if the plant operates under the existing NPDES permit 0 because the cooling towers would operate less.

11 Q40. Would the use of groundwater increase as a result of the power uprate?

12 Response: No. The normal use of water from groundwater wells will not increase as 13 a result of the power uprate. During the 2004 planned outage period of about one month, when 14 more workers will be on-site, there will be an increase in groundwater use. (See Memorandum 15 from Southern Vermont Engineering Associates, Exhibit EN-SAS-7). The amount of well water 16 used for make-up water for the reactor witer system will not increase after the power uprate. The 17 reactor water system is a closed system with no discharge of cooling water, so the system is as 18 conservative of water use as is possible.

2 7Q10 (Seven day low flow, ten year return period) means a drought flow equal to the lowest mean flow for seven 4 consecutive days, adjusted to nullify any effects ofartificial flow regulation, that has a 10( chance of occuring in any given year.

Profiled Testimony of Sonja A. Schuyler Entetry Nuclear VY February2l, 2003 Page 21 of 35 1 d. Criterion 1UD) Floodwavs and 4 1424a(d)(3) 2 Q41. Is this project located near a stream or watercourse?

3 Response: Yes. The VY Station is located on the Connecticut River on the west side 4 of the impoundment formed by the Vernon Dam (see Exhibit EN-SAS-2, Site Location Map).

5 Q42. Are any changes to the facility proposed to take place within the floodway or 6 floodway fringe?

7 Response: No changes will take place to facilities in the floodway or floodway fringe 8 (See Exhibit EN-SAS-13).

9 Q43. Has the project been designed so that it will not divert the flow of 190 floodwaters thereby endangering the health, safety and welfare of the public or of riparian 11 owners during flooding?

12 Response: Yes. Entergy Nuclear VY has proposed no changes that would divert the 13 flow of floodwaters.

14 e. Criterion 1E) Streams 110 VS.A. §1424 a(dX1)]

15 Q44. Please describe any streams or waterways in the vicinity of the project.

16 Response: The VY Station is located on the Connecticut River, and a small unnamed 17 stream crosses the Entergy Nuclear VY property to the north of the VY Station. (See the Site 18 Location Map, Exhibit EN-SAS-2).

Prefiled Testimony ofSonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 22 of 35 1 Q45. Will any construction affect the unnamed stream or the Connecticut River?

2 Response: No. No construction will be required adjacent to the unnamed stream or 3 the Connecticut River for the power uprate.

4 Q46. Will the project maintain the existing condition of the Connecticut River, so 5 as to provide full support of uses consistent with its water quality classification?

6 Response: Yes. Under the existing NPDES permit, Entergy Nuclear VY conducts 7 continuous monitoring of river temperature and flow upstream and downstream of the facility, 8 water quality sampling, and ecological studies ofmacroinvertebrates, larval fish, and fish in the 9 river. The purpose of this monitoring is to assure that the discharges from the VY Station 4 10 authorized by the NPDES permit do not have an adverse impact on the fish and other wildlife 11 communities in the river, and that the biological integrity of the aquatic community in the river is 12 maintaned.

13 The annual monitoring reports are reviewed by the Environmental Advisory Committee 14 (EAC) that has been established by the NPDES permit. The EAC members represent the 15 Vermont Department of Environmental Conservation, the Vermont Department of Fish and 16 Wildlife, the New Hampshire Department of Environmental Services, the New Hampshire 17 Department of Fish and Game, the Massachusetts Department of Environmental Protection, the 18 Massachusetts Division of Fish and Wildlife, and the United States Fish and Wildlife Service 19 Coordinator of the Connecticut River Anadromous Fish Program. The reports are also reviewed 46w,20 by the Vermont Agency of Natural Resources which has the regulatory authority for enforcement

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 23 of 35 I of the NPDES permit As monitoring is a component of the current NPDES permit, it is 2 expected to continue during subsequent renewals or amendments.

3 f. Criterion 1(F) Shorelines [10 V.S.A. §1424 a(d)(8X12)!

4 Q47. Does the project involve the development of any shorelines?

5 Response: No. No changes will be made to intake or outlet structures on the 6 shoreline.

7 Q48. Describe how continued access to water and recreational activities will be 8 maintained.

4 9 Response: The VY Station is a secured site, so no access to the water for recreation is 10 provided from the Entergy Nuclear VY property.

II Q49. How will vegetation be utilized to screen project from the water and stabilize 12 the banks?

13 Response: There will be no change to the exterior appearance of the facility as 14 viewed from the Connecticut River.

15 g. Criterion 1(G) Wetlands 16 Q50. Are there any wetlands shown on the National Wetland Inventory (NWI) 17 maps on the project site?

18 Response: Yes. National Wetland Inventory (NWI) mapped wetlands are present on 19 the Entergy Nuclear VY property north of the VY Station. (See the Vermont Significant Habitat 20 Map for the Town of Vernon, Exhibit EN-SAS-14). Such wetlands and any wetlands

Prefiled Testimony of Sonja A.Schuyler Entergy Nuclear VY February 21, 2003 Page 24 of 35 1 hydraulically connected to NWI wetlands would be considered significant wetlands under the 2 Rules of the Vermont Water Resources Board. These wetlands would be considered Class 2 3 wetlands under the Vermont Wetland Rules.

4 Q51. WM the project comply with the Rules of the Water Resources Board 5 relating to significant wetlands?

6 Response: Yes. The project will not require any new construction outside of the VY 7 Station complex, so no significant wetlands will be impacted.

8 B. Criterion 2 Sufficient water available 9 Q52. Is sufficient water supply available to meet the needs of the power uprate?

i 10 Response: Yes. Sufficient water supply is available for the power uprate. Three 11 water systems provide the potable water, water for heating boilers, and make-up water for the 12 reactor water system: the Main Plant Water System, served by the West Well and the Southwest 13 Well; the Construction Office Building System, served by the COB well; and the New 14 Engineering Office Building System, served by the PSB well. The locations of these wells are 15 shown on the Site Plan, Exhibit EN-SAS-3. Source Water Protection Plans have been 16 established for the Main Well System, the COB Well System, and the NEOB Well, and are 17 shown in Exhibit EN-SAS-15. The three systems have been granted Public Water System 18 Permits to Operate (Exhibit EN-SAS-I 6).

19 The temporary office building for the power uprate will be connected to the water and 20 wastewater systems for the Plant Support Building. A Water Supply/Wastewater Disposal

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 25 of 35 I Permit (WW-2-1035-1) was issued for this connection by The Vermont Department of 2 Environmental Conservation (DEC) on February 3, 2003. A copy of this permit is attached as 3 Exhibit EN-SAS-17.

4 Potable water demand after the power uprate is not expected to increase, and heating 5 demand is expected to be the same. The amount of make-up water required for the reactor water 6 system will not increase. The existing wells have enough capacity to serve the needs of the 7 temporary workers who will be on-site for the power uprate construction. (See Exhibit EN-SAS-8 7).

9 C. Criterion 3 Burden on existing water sUprly 110 V.S.A. -1424 a(d)(12)l 10 Q53. Wm the uprate place an additional burden on the water supply for the 11 facility or other users?

12 Response: No. There will only be a temporary increase in the workforce during the 13 time period when the uprate construction is being performed, and as shown in Exhibit EN-SAS-7 14 sufficient water is available for domestic use during this period. Vernon Dam is located 15 downstream of the VY Station and uses river flow downstream of the VY Station to generate 16 electricity. Entergy Nuclear VY reimburses the owner of the Vernon Dam, for water lost to 17 evaporation using a negotiated formula. This practice would continue, so there would not be an 18 undue burden on the next down-stream user.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 26 of 35 2 D. Criterion 4 Soil Erosion and runoff characteristics of site 3 Q54. Will the uprate cause any changes to the site that would have the potential to 4 cause soil erosion or to alter the runoff characteristics of the site?

5 Response: No. The only exterior construction anticipated for the power uprate is the 6 installation of temporary office space using mobile modular units. Soil disturbance would be 7 minor and limited to any trenching, setting of foundation columns, hook-up of water, sewer, 8 telephone, and electricity. The runoff characteristics of the site would not change, and the area is 9 already served by storm drains as shown on the Site Plan, Exhibit EN-SAS-3.

0 E. Criterion 5 Highway congestion and traffic safety 11 Q55. Describe the access to the project.

12 Response: The site has one controlled access point on Governor Hunt Road. (See the 13 Site Location Map, Exhibit EN-SAS-2, and the Site Plan, Exhibit EN-SAS-3.)

14 Q56. What impact will this project have on average daily traffic and the peak 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />?

16 Response: There will be no increase in the number of regular employees after the 17 uprate, so the uprate will have no additional long-term impact on daily traffic or peak hours from 18 employee traffic. A traffic study has been prepared by Southern Vermont Engineering 19 Associates and is attached as Exhibit EN-SAS-18.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 I Page 27 of 35 Q57. Will there be any temporary impacts during construction?

2 Response: Yes. During the 2004 outage, 1,500 employees are expected to be on-site at 3 some time during the outage, which is expected to be less than 30 days. This number includes 4 regular employees, employees hired for the usual maintenance outage tasks, and employees 5 required for uprate construction. Sixty percent of the employees are expected to work 12-hour 6 shifts starting between 5:30 AM and 7:30 AM, and 40% of the employees are expected to work 7 12-hour shifts starting between 5 PM and 7 PM.

8 The traffic study showed that the level of service at the facility entrance on Governor 9 Hunt Road would go temporarily from "C"to "D" north of the intersection during the planned power outage in 2004. (See Exhibit EN-SAS-I 8). The American Association of State Highway 11 Transportation Officials (AASHTO) uses a letter rating from A to F to describe traffic 12 conditions, with "A" representing no delay and "F" representing maximum delay and congestion.

13 AASHTO recommends designing intersections such as the VY Station access to Governor Hunt 14 Road for level-of-service from "C" to "D". The Vermont Agency of Transportation uses the 15 AASHTO guidelines.

16 Thus, although the traffic delay at the intersection will increase during the outage, the 17 outage will not cause unacceptable congestion. The traffic study concluded that the temporary 18 traffic conditions on Route 142 would be acceptable during the outage.

VPrefiled Testimony of Sonja A. Schuylcr Etergy Nuclear VY Febniary 21, 2003 Page 28 of 35 1 Q58. Will the power uprate generate any additional truck trips at the facility?

2 Response: Yes. The increase in truck traffic as a result of the upgrade will be three 3 additional low-level radioactive waste shipments per year and one additional nuclear fuel 4 delivery per 18 months. These increases will not change the rating of the Governor Hunt Road 5 intersection as shown in the traffic study, Exhibit EN-SAS-18.

6 Q59. Does the facility have adequate parking available?

7 Response: Yes. No additional parking will be required for this project. The VY 8 Station has 455 parking spaces which is more than adequate for the normal workforce. During 9 maintenance outages a temporary parking area is set-up near the cooling towers and switchyard.

10 These areas have sufficient capacity to handle the additional workers that will be required during 11 the uprate construction. (See the Site Plan, Exhibit EN-SAS-3).

12 Q60. Will operation of the cooling towers during the winter create icing on nearby 13 roads?

14 Response: No. As presented in Mr. Yasi's Cooling Tower Plume Study, icing due to 15 cooling tower operation is not anticipated. The modeling did not indicate icing on roadways 16 during fall, winter or spring cooling tower operation.

17 F. Criterion 6 Educational Services 18 Q61. Will the uprate result in an increase in full time employees at the facility?

19 Response: No. The number of permanent employees will not change due to the 20 uprate, so this project will not result in an increase in the school population.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY FebNuary 21, 2003 Page 29 of 35 I G. Criterion 7 Municipal Services 2 Q62. What municipal services will be utilized by this project?

3 Response: The VY Station receives supplemental police protection, fire protection, 4 and rescue service from the Town of Vernon.

5 Q63. Will these services be available to the project and not place an unreasonable 6 burden on the municipality?

7 Response: Yes. Mr. Thayer's testimony documents the discussions with town 8 officials concerning this project and their reactions to the proposal.

9 HL Criterion 8 Scenic or natural beauty, aesthetics, historic sites, or rare and 10 irreplaceable natural areas 110 V.S.A. §1424 a(d1)(78)(9)(10lh1) 11 Q64. Describe the site as it exists now and as it will be after the project is 12 completed.

13 Response: The site is located on the west shore of the impoundment of the 14 Connecticut River that is formed by the Vernon Dam. To the north of the generating station, the 15 property is largely undeveloped except for the power lines that run north from the generating 16 station. (See the Site Location Map, Exhibit EN-SAS-2). To the west, the property is bordered 17 by residential lots that front on Governor Hunt Road. An interpretive center, the Governor Hunt 18 House, is located on the property with frontage on Governor Hunt Road. This interpretive center 19 is open to the public. The generating station itself is fenced and access is limited to persons who 20 work at the facility or have approved business at the facility. The perimeter fence around the

Prefiled Testimony of Sonja A. Scbuyler Entergy Nuclear VY February 21, 2003 Page 30 of 35 1 generating station is shown on the Site Plan, Exhibit EN-SAS-3. The entrance to the generating 2 station is controlled by a security guard house. To the south, the property is bordered by the 3 Vernon Dam Hydroelectric Station.

4 Q65. Will exterior signs and lighting be installed?

5 Response: No. The project will not require any additional exterior lighting or 6 signage.

7 Q66. Has an aesthetic analysis of potential changes due to the power uprate been 8 performed?

Response: Yes. Dodson Associates, Ltd. performed a visual analysis of the cooling 10 tower plume and evaluated the visual impacts using the Quechee Analysis that is used for Act 11 250 applications. This analysis is presented in the testimony of Mr. Dodson.

12 Q67. What did Mr. Dodson conclude?

13 Response: Mr. Dodson concluded that the project would not have an unduly adverse 14 aesthetic impact.

15 Q68. Will this project affect any known archaeological or historic sites?

16 Response: No. The site was reviewed by the Vermont Division for Historic 17 Preservation, which found no impact on archeological or historic sites. The Division's response 18 is presented in Exhibit EN-SAS-1 9.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY Februay 21, 2003 Page 31 of 35

• 1 Q69. Will this project have an adverse impact on unique or valuable natural areas 2 or rare and endangered species?

3 Response: No. Although mapped occurrences of rare and threatened species and 4 unique natural areas are shown on the Vermont Significant Habitat map (Exhibit EN-SAS-14),

5 the Vermont Nongame and Natural Heritage Program (VNNHP) reviewed the project and did not 6 find that any undue adverse impacts would occur to nongame resources or significant natural 7 areas. The letter from the VNNHP is presented in Exhibit EN-SAS-20.

8 Q70. Several points are shown on the Significant Habitat Map on or very near the 9 Entergy Nuclear VY property. Can you elaborate on the findings of the VNNHP?

10 Response: Yes. The VNNHP prepares Vermont Significant Habitat Maps for each 11 Town. Symbols on these maps indicate the locations of mapped deer wintering areas, wetlands 12 shown on the NWI maps, and dark polygons for areas where rare, threatened or endangered "13 species or significant natural areas have been recorded. Vermont extends statutory protection to 14 species that have been placed on the state or federal lists of threatened or endangered species. It 15 also regulates impacts to wetlands. The other items shown on the maps are monitored for 16 management purposes. I met with Everett Marshall, Database Manager for the VNNHP, and he 17 provided a listing of the occurrences for each mapped point that is attached as Exhibit EN-SAS-18 21. Because access to the Entergy Nuclear VY property is limited, natural communities have 19 been left relatively undisturbed compared to the natural communities below the dam. Rare plant

(.O species that have been recorded on the Entergy Nuclear VY property include: giant Solomon's

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 32 of 35 1 seal, tapering nrsh, and trailing stitchwort. Giant Solomon's seal occurs both above and below 2 Vernon Dam, but a larger concentration of plants has been recorded on the Entergy Nuclear VY 3 property. The giant Solomon seal community is being monitored by the VNNHP.

4 The only Vermont-protected species indicated on the Significant Habitat Map is the 5 threatened great St. John's-wort. It has been recorded immediately above the Vernon Dam near 6 the Entergy Nuclear VY property boundary, so it is possible that individuals could spread onto 7 the Vermont Yankee property. Since no development is planned for this part of the property, the 8 project would have no effect on this threatened species if it were to occur on the Entergy Nuclear h 9 VY property. The other rare species documented at this map location immediately above the 10 Vernon Dam include three aquatic plants, homed pond weed, small water-wort, and pygmy 11 weed; and a grass, Frank's love-grass, which is rare because Vermont is at the northern limit of 12 its range. These species were identified along the canoe portage and on mudflats in the river, so 13 not on Entergy Nuclear VY property.

14 Q71. Will this project have an adverse impact on wetland communities?

15 Response: No. As noted in the responses to Questions 50 and 51, the project will not 16 affect significant wetlands, the Class 2 wetlands shown on the NWI map. Since there will not be 17 any construction outside of the already developed VY Station complex, no impacts will occur to 18 other wetland communities that may occur on the Entergy Nuclear VY property.

19

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY Februa 21, 2003 Page 33 of 35 1 1.- Criterion 8 (A) Necessary wildlife habitat and endangered species 110 V.S.A. §1424 2 a(d)(4)(5)(6il 3 Q72. Will this project have an adverse impact on wildlife habitat?

4 Response: No. There will be no impact on terrestrial wildlife habitat because no 5 changes will be made to the facility footprint. Compliance with the conditions of the current 6 NPDES permit or any subsequent amendments will assure the protection of habitat values in and 7 adjacent to the Connecticut River.

8 Q73. Will this project have an adverse impact on endangered species?

9 Response: No. As noted above in the response to Question 69, the project has been 10 reviewed by the VNNHP and no concerns about impacts to endangered species have been raised II (See Exhibit EN-SAS-20). Although not tracked by the VNNHP, a bald eagle nest has been 12 reported downstream of the VY Station on Stebbins Island, which is in New Hampshire. The 13 uprate project will not impact this federally protected Threatened Species because compliance 14 with the conditions of the current NPDES permit or any subsequent amendments will assure the 15 protection of habitat values important for this species.

16 Q74. Will this project have an adverse impact on fish habitat?

17 Response: No. Compliance with the conditions of the current NPDES permit or any 18 subsequent amendments will assure the protection of habitat values in the Connecticut River.

19 Vermont Yankee has monitored fish habitat in the vicinity of the VY Station for more than 30 I 20 years. Seven representative important species have been selected for detailed study: Atlantic

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY February 21, 2003 Page 34 of 35 1 salmon, American shad, smalimouth bass, walleye, yellow perch, white perch, anid spottail 2 shiner. Monitoring to date confirms that habitat for these species has been adequately protected 3 by the NPDES permit.

4 J. Criterion 9(M0 Impact on Public Investments 110 V.S.A. 41424 a(d)(12)1 5 Q75. Is this project adjacent to any public facilities?

6 Response: Yes. A public park is located to the south of the facility by the Vernon 7 Dam fishway and the Vernon Elementary School is located on Governor Hunt Road. (See the 8 Site Location Map, Exhibit EN-SAS-2).

9 Q76. Will this project have an adverse impact on public facilities?

10 Response: No. The proposed project will have no impact on these facilities.

11 I11. 248 (B)(8) EFFECT ON OUTSTANDING RESOURCE WATERS 110 V.S.A. §1424 12 a(dXl3)]

13 Q77. Is this project located on any segment of the waters of the state that have 14 been designated as outstanding resource waters by the Water Resources Board?

15 Response: No. The project is located on the Connecticut River, which has not been 16 designated an outstanding resource water by the Vermont Water Resources Board. (See the 17 Letter from the Water Resources Board, Exhibit EN-SAS-22).

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear VY Fcbniray 21, 2003 Page 35 of 35 1 IV. EXECUTIVE ORDER 80-52: AGRICULTURAL RESOURCES 2 Q78. Have any primary or secondary agricultural soils been identified on the site?

3 Response: Yes. The agricultural soils of statewide importance have been identified 4 on the site.

5 Q79. Will the potential of these soils for agriculture or forestry be adversely 6 affected by this project?

7 Response: No. Since the power uprate will not require construction outside of the 8 existing developed area of the VY Station or an increase in paved areas, the proposed project will 9 not have an adverse impact on agricultural activities or productive agricultural soils. (See the 10 letter from the Vermont Department of Agriculture and Markets, Exhibit EN-SAS-23).

11 Q80. Does this conclude your testimony?

12 Response: Yes it does.

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear Vermont Yankee, LLC February 21, 2003 LIST OF EXHIBITS EN-SAS Exhibit # Item 1 Resume of Sonja A. Schuyler 2 Site Location Map 3 Site Plan 4 Discharge Permit - NPDES No. VT0000264, May 14,2002, Entergy Nuclear Vermont Yankee, LLC 5 2002 Air Pollutant Emissions Inventory Report for Entergy Nuclear Vermont Yankee, LLC, Facility IDM# WM 2335 6 Indirect Discharge Permit No: ID-9-003 6-1A, Entergy Nuclear Vermont Yankee, LLC 7 Memorandum from John Goodell, Southern Vermont Engineering Associates, to George Thomas, Entergy Nuclear Vermont Yankee, February 12,2003. Re:

Water System Capacity 8 Solid Waste Management Facility Full Certification F9906-AI, July 12, 2002, Entergy Nuclear Vermont Yankee, LLC 9 Vermont Yankee Nuclear Power Station Off-Site Dose Calculation Manual Revision 30, Appendix I, Revision 29, 1/11/02 10 Sludge and Silt Disposal Areas 11 Memorandum from George Thomas, Entergy Nuclear Vermont Yankee, LLC, to Sonja Schuyler, The Johnson Company, February 13, 2003. Re: Asbestos*

and lead-based paint waste.

12 Vermont Yankee Nuclear Power Station Hazardous material Containment and Contingency (HMCC) and Spill Prevention Control and Countermeasure (SPCC) Plan, Revision 5, September 27, 2002 13 Flood Insurance Rate Map, Town of Vernon, Vermont, Panel 5 and Panel 10

Prefiled Testimony of Sonja A. Schuyler Entergy Nuclear Vermont Yankee, LLC February 21, 2003 14 Town of Vernon Significant Habitat Map, Vermont Nongame and Natural Heritage Program 15 Source Water Protection Plans 16 Public Water Supply Permits, Entergy Nuclear Vermont Yankee, LLC, May 21,2002 17 Water Supply/Wastewater Disposal Permit WW-2-1035-1, Entergy Nuclear Vermont Yankee, LLC, February 3, 2003 18 A Study of Traffic for Vermont Yankee Nuclear Power Station, Vernon, Vermont; January 2003, SVE Associates 19 Letter from Emily Wadhams, State Historic Preservation Officer, Vermont Division for Historic Preservation, February 4, 2003. Re: Proposed Power Uprate.

20 Letter from Jodi Shippee, Vermont Nongame and Natural Heritage Program, January 3, 2003. R : Vermont Yankee Power Uprate 21 Vernon Dam Site Listings, Vermont Nongame and Natural Heritage Program, January 6, 2003 22 Letter from Jon Groveman, Executive Officer, Vermont Water Resources Board, January 7, 2003 23 Letter from Marian White, Vermont Department of Agriculture, Food, and Markets, January 3, 2003

EXHIBrr EN-SAS-2 Frr MRtV c"asm PAMMO AREAS LEAtHM0 ARDS.-

e WLL APPROMaMATE 1?\ srHE PLAN VERMONT YANKEE NUCLEAR POWER STATION SCALE: 1"=300' FEBRUARY 13, 2003

Entergy Nudear Northeast Enterg Nudear Operation, Inc.

Vermont Yankee

-AffEn-tergy 322 Go'enor Hunt Rd.

P.O. Box 157 Vernon, Vr 05354 Te4 802-2S7-7711 V ~January 16,2W03 M.WDaniel Riey, Environmental Bnginee, Agency of Natural Resources Deatmet of Environmental Conservation l C Py Air Pollution Control Division 1RECEIVE]

Waterbur, VT0571l-0402 Subject 2 Air Pollutant Emissions Inventory Report for A 2N 3 M]03 intergy Nuclr Vermont Ymnkee, UC I"SjjJ ..

Facility ID*#WM 2335*05 JOHNSON CO. INC. #1 D Mr. Riley; MONTPEUER. VT Patergy Nuclear Vermont Yankee. LLC (VY) is pleased to present fhe 2002 Air Pollutant Emissions Inventory for Vermont Yankee Nuclear Power Station in Vernon, Vermont.

For 2002, VY emissions for significant activities (e.g. hoas heating boiler and waste oil buers) remaned below the 10 tons per year (tpy) limit for 2002 per opt-out regulatory requiemeats.

Ire total emission quantity for 2002 was calculated to be 8.06 toos. Also for 2002. BNY emissions from insignificant activities (e.g. emmrgency diesels and John Deere diesel) each remained below the 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> m UMq run-time lEmit per opt-out regulatory requyfemets A summary table is attached.

Durin,-fteing outage (RFO) #23 In October 2002, VY utilvd a am-stationary temporary 400 kilowatt (KW) diesel generator equipped with a standud filtering device for the main tra S r*wcment activities. Te gencratortoa nm-timc was 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> at 50% capity at 17.4 gallons per hour. ft is d-- mo dWg of VY through telephone conversations with Vermont Agency of Natural Rescurce 'VTANR) personnel that non-stationary qou=e ane considered an insIghiflcant source if utilized for their intended purpose but exceeded 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of nm-time. As kuch. rela form the non-stationary temporury geneiator wem not applied to the 104onlyear limit for opting out of ft ir operating permit program.

Additionally, tiis submittal does Do contain a hazardous air contaminant emission inventory. All BNVY hazardous air contaminant emissions ae related to routine maintenance activities (e.g.

painting. cleaning, dc.) thus not subject to repting requirement.

If you have any questions concerning this submittal, please do not hesitate to telepbon¢ me at (S2)258-5525.

Sincery, Fidergy Nuclear Veimont yake,.LW Mulie C* aywai*/

.Enviio ntal Wiptciulis aiernisfty Superintendent EXEIBIT EN-SAS-5

. PAGE I OF 11 Attachment

VY AIR EMISSIONS RECORDKEEPING-2002 Grand Totl Ton House Heating 8flehs 8.06 Period GaonsUsed % Sulfur Ib'kgWl, S bkgaL, Ott Total Tons 53303 0.15 21.458 27.29 1.30 HHB Emission factors fror EPA AP-42 Section 1.3 211 -229/2002* 43000 0.15 21.45A 27.29 1.05 3/1-3/1=2002' 14500 0.15 21.456 27.29 0.35 25700 0.20 28.3104 27.29 0.40 sO2 142"AS W/1W=2002" 6800 0.27 W9.52 27.29 0.85 S03 20%S 24400 0.27 38.592 27.29 0.80 NOx 20 5/1.5/1/00 18800 0.27 38.88 27.29 O.82 Part 2 8/l.8W002 (LS) 2800 0.1 14.4 27.29 0.06 CO 5 7/1-713112002 0 0 27.9 0.00 VOC 0O252 8/1.8/3/2002 0 0 27.29 0.00 rce Metals 0.08

• 9/I1-0~'00M 0 0 27. 0.Q0 20979 0.23 33.12 27. 0.63 (LS) bndloates Low sufur desel was delIvered 11l/1-11/3Q~0/= 48124 0.23 33.12 27. 1U9 (I hxcates a SM50 #24ewoe mix was deliwred 12/4/02 & 12./27/02' 12804 0.20 2&8 27.29 0.38 ("),Indost a 70= Mlerowne mix was delivered 112/-1.121r1/002 43852 0.23 33.12 27.29 1.32 Totals 312882 9.14 Waste odl Emrstion factOs from EPA AP.42 Section 1.11 Total with average %Sulfur 312662 0.20 23.42 2729 7.93

,Waste Oil Surner SOx 10'%So NOx 18 Period Gallons Used % Sulfur lbtkgal. S lb/kgal. Ott Total Tons Part 41.6 CO 2.1 01/01/02-01/31/02 325.2 1.31 188.64 60.43 0.04 0.1 11(01.11/30/2002 406.2 1.31 140.17 60.43 0.04 Trace Metals 0.63 12/01-12/31/2002 409.2 1.31 188.64 60.43 0.05 0 60.43 0.00 OPT OUT PROVISION DIESEL HOUR METER READINGS .=

0 60.43 0.00 JUMni ur-&.'fM' urnW A WVU Date B EDG

, CW 0 80.43 0.00 1208.3 12/13=01 3835.9 12/21/2001 477 122/2001 0 60.43 0.00 120M.5 01/'1002 3840.5 01/21/202 481.7 0122/2002 Totals 1140.6 0.13 1207.9 02/13/20A 384&.1 020/200 488.4 02/22=2002

&4 12092 03/1Z. 38.5 03/16/00= 401.3 03/22/2002 VYAPF 0150.01 1/1/2002

= mergncy Dio Tank Vd. sZSoo gal 1211.2 04/10/2002 38=.2 b4/12 493.8 04/18/2002 1212.5 05/15 384.6 05/18=200 498.4 05/17/2002 05/04,2002 Delivery of 7M0 gallons .1214.4 08A112002 3857.2 0M=21/200 40&9 06/21/2002 1217.1 07/10 3861.4 0725900 510.2 07124/2002 12181 0/14 '3870.3 0518 0n 518.9 08/20/2002 VYAPF 0150.01 12/31/2002 Emergency Diesel Tank Volume. 49,250 1220.3 0/11 38002 32.8

• 2 523.1 0=I3/2002 1221.7 1001M 381.3 102 0= 522 1021 1222.9 11/1 388. 11/1 53.= 11/12/10M0 1224.2 12/111r 3888. 12/1W 533.3 12/18200 Total S ... A604 51.3R

EXHIBIT PAGE EN-SAS-5 3 OF 11 CERT[FICATION OF DATA ACCURACY For Purposes of Emission Calculations This form must be signed byan individual responsble for the completon and cetifimfion of the data contained in the forms attached which are intended to meet bbth the rtquiremefits of State Statute (10 V.S.A. 555 (c) and 3 V.S.A. 2822 0")(1B)) and the requirements for "Emission Statements" containedin the Federal Clean Air Act as amended In 1990. Cerlificatioi indicates that de signatory takes legal nsibility for the accuracy ofthe information on the form.

The datapresentedherein representsthebst availablelfomatdonandis trw accurate and complkte to the beit ofmy knowledg.

jItiC..hj: 4l 4 ~v;~enni~idid I

~S~%#

uintFul Print Full Title i2 hoI'/03:

Date o.tignatfre Telephone Number 1.

'. £

-I

I

• EXHIBIT EN-SAS-5

.PAGE.4 OF-H:..-

Vermont Akency of Natural Resourcme Coihiuuon somue 2002AIrhPolutantEmitsonslnvetorj PurCdtexia Mulntazs The infomation.dislayd ona tdi form is that which is on file for your facRy. Itis based on iiavento* fox completed for calendar year 2001 or the most recent year ava&ae. We need to update the information to calendar year 2002 Pl reviw the "infmationcontained in the boxes carefufly. If there is no value in a.box, wite in &hecorrec 2002 vale. If there is avalue, but it is incorrect for 2002, coss out the value and in its phace write the correct value.

If you have questions, or desire assistance with completing the inventory, Please cali Dan R&7e at (02)-241.885&

FacilitrName: VERMONT YANKEE Person Completing Invcntoy Form: I ~iuI~e I Faclity ID: WM2335 Source Descuiptiom house healing boilrs (2)

Stack Nsnn1cr 1

Soux= Numbe.

I Soe Numbe.

Source isuificafion Code 1-03-005-01 Haun Per Day 0lK Wmintr Throughputt (96: 401 Days Per Week [I ,] SPg'ThgroI*ut(90: 31 Weeks Per Year 11 1 Summer Throudgput (s): SOI H{ours Per Year' 4L~ Autumnn7 i.ghput  :-

(Over)

-.a

EXHIBIT EN-SAS-5 PAGE 5 OF 11 Combustion Source (continud FUaInglT: FU3L OIL (#2) 2002FuelConsumption: (suppbryuits) i 2/M , 6 W. ,

Sulfu Conteit of Fuel (9G): 1 *-W&OZ0 Ash Contntof fuel (

MaXmum Heat lnpil t(miiOnTU/hr Burnex Ratiog ]Boiteralati 16.7 l Maximum Actual Firing Ratw (nMlou BTUl~hlu 16.iI]

P==ctSpace Heat [ 100 _

Peromt Process Heat 0 Sta Parametkms Stack Number I.

Stack/Duct Dwiscarge Heih (feet 87.9 ji Stack/DuKt.In=e Diameter at Exit Gind'es) Vj.jjj

£i Go Temperature (d.& F). L i

Florw~ate at Exit (actual FTr(niWn L IZ]9 If an air pollution control device for the source exits inspect the following information and correct ifnecessay:

WSCkn Devo non I S02 Cowkw Dc~iinoe [7b77 7 Th~t Eff~idfcwr T NOx Comftj none kI TU0Mt&a~fi&=

I LIZI VC -. rcDcwi1mo

' Tjd LIII 00 Cont n= 1 noneImmv"Effie-If an estimated emission rate exists, please s ly the infonnation below:

LIZ]

Estimated Emission Rate-Basis of Fdmate If test data 4 years old or less is available I

.4

EXiIBIT EN-SAS-5 PAGE 6 OF 11 Vermnt Adencg oA Natural Resourc. Colalustion2Source 200AitrPollutantrrnjssonslnventorg For CttramiPolUntants TM informatio displqyd on ths form s tat wlch is crundy on file for your faci=ty. Itis based on inventoty forms completed for calendar year 2001 or fhe most recent year v la. Wenceto update the ir'mfionto calndarya2002. laerviewthe inforfion contaned in the boxes cardully. If xhre is no value in a lox, write in the correct 2002 value. If ftfer is a vilue, but itis incwect for 2002, cross out the value and in its place write the correct rluc If you ham questions, or desire assistance with completing the inventory, please call

• Dan Riey at (80-t241-888.

Facift Nam: VEMONT YANKEE Peron C*mpleftn Inventory Form: I (JL&ij( /~1~t'O-4~6( I Facffity ID : WM2335 Souroe Descrptom- wate ofl Awnue (2)

Stack Numbcr.

Source Number. 2

. Segm t Number Source CQassificaion Code 1-02-004-01 Hours Per Day " 0' Winter oughput (:

Dqs Per Week IE°1 SvrnThrougb* 09 :

Weeks Per Year I ° Suma 11rouftut (9: 0l Hours Per Year:. Auttnnn T1out ut (%:

(Ova) 4..

EXHMrr EN-SAS PAGE 7 OF 11 Combustion Source (continued)

S '=MM: FLOIL-(#*6 20 Fuel Conmu*m*t ,: unWi (supply tL o, . .I Sulfr Contnt of Fad f.%), 1i.3As hC.tnt of Fael /

MaxiH"m ]jeat bput (mi.lo" BTU/r.

Burner Lting 0I I Bofr~n [1111]

Mam3Actual Fixing Rate (milio BTU/bI) 0 Percent Space Hreat 1I]

Pemcnt Procs Heat 0 Stack ParAMetarS-:

StackNumben. 2 StdMuD Height (d [21.0 I

~ Stac/Duc~lmer Diamete at Eit (Inche) f 7-9 4 E,,t Gas Tempcqatr. (deg. F) [j 7-]

• Flow Rate at Exit (adal YFimii)

If an air pollution control device for the source exdsts inpect the following fOrtion and correct 3Tnecessa:

TSPCoicardD= I no _e-6 _M~t~~ id., f I S02 Ca* Dem I none I1~d~Emd~ Lw

, NOx .Comto DeIc now I Ufromer Liii VOG Contlmi= eIc,: -. I Lw 00 C*ol Dcin*Pb h=

IHan estiated cinision ratc exists, pleas suppl the informafion below:

EZJ Estimated Emission Lt Basis of Estima If tedt data 4yem old or less is available XMrrIT EN-SAS-s PAGE8 OF 11 Vemmot Aaencg cA Ntral Lsourc CoýUcnSource 002MAirPollutant n..ionsnvenTorg F"CZIfCft PCHolUfantX The infmnation disphyed ondhis form is dithtwch is curently on fMle for your facility. Itis based on inventor forms completed for calendar year 2001 or the most recent year available. We need to update the infornation to calndar year 2002. Pkase rcicw,the infocan ontained in the boxes carefuy. If them is no value in abox*write in the correct 202 value. If there is a value, but it is inconect for l202, crss out fte vwaue and in its place write the correctvalue.

Ifyou have questions, or desire 8i.h assistance completng the inventoy, plae call D=3 Riley at (802)24 1-M58.

FaciltyName: VEMONT YANKEE Pesn Cbu ei Inventory Form: I 31AI;C ---- 1 Facilt ID: WM2335 Source De aiption: Pmegeay Diemis (2)- 1675 bp

" St:kNumb:.

Source Nwnbc. 3.

Segment Numbcra 1 Somrce aassificadon Code 2-02-004-0l Hours Per Day iio] Wmnter¶Througaput (V 25I~

Dqs,Per Week. [ ii Spring Throughput OQ: 25i Weeks Per Year [ 0Z sumnmerlbvugw (9 Hour, PerYcan Aubnnu 7bvueqx (9 25~f (Over EXIHBrr E14-SAS-5 PAGE 9 OF 11 Corbusticm Som-c (contiu.ed)

FuelType: . MM OIL,(2) 2002 Fuel Consumption: (su.p* unit)/ 5 1 Sulfur Content of Fadl(%): O-9OW,1 )sh ConntwofRFOW()[~ Z Maximum Heat Input (mllion Bl/hr BIumr Boiler Bati [28.4 Mim Actual Irking Raft ( MUM

'illi ]

Perent SpaceHea. 0I Peroent Procs Heat [1ZI SU&Numbw. 3 StadkfDuct Diselirg Heigh (0=e0 29.I MA Gas Tmpeatm e (dcg IF). I SO ]

Flow Ptate at Exit (actual FTS/n~in) 63R98 If an air Ihition control device for the source exists inspect the fblowing information and coirctifnecesary:

+7WCa*leIDev now 802 C "tl= I*ow.I KOi Control Dei DorictiaF1lcec~

iJ I -I VOC C,,,reDcvii ,,o, I&Ienc-.

LZ~1 00 Conto Devi= non If an estimated eisIon rate eis% plea

.~er supply the information below:

Ei~J Estimated EFission Rate*

Basis of Estimate

• Iftstdata 4 yar old or ess i avalable It .

It

EXHAIBI EN-SAoo PAG'E 10 O0w*_____

EXHIBIT EN-SAS-S PAGE 11 OF 11 Combustion So=ce (continued)

FuelType: MM OH. (#2) 2M FuelC tin:mp:(sup*units) .

SufUhr ContentoFael f ): DW Or 10 A&h (tntent,of Fuel 50 Aimm Heat ipt (pmilion BTU/hr Mmm

• A rlving RPHate (on '1031 Percent Space Heat [i l Percest Proes Heat 100Z Shck Numnbe. 4 Stack/Dudt Dhcbarg Hcib (FeW [17111 SuA/Duct ,nn,,Dimxteat= Exit.nd, s) L.3-Eýit Gas Tempmar (dc.g 3D.., [. ISO Flow Rate at Exit (acdnl F`Mmin) 4,301 If an air pollution control device for the source exists inspect the fWllowing infortmt and.

conred ifnecessary:

I S02 Ckco Dew= nme0 NOx C-outrc Devi=e I

nowejTetclfiec ~

1 VOC Coftra!Dvice: o.

CO ContaDemim-1 -mth dCoeclficicn Lii lowo~

N1 n If an estinated emission rate exists, pleae supply the information below:

FMfdmen Lii Estimted Eission Rate E Basis of Fstimate I If test data 4 ,as old or less is available

-4.

EXHIBIT EN-SAS-6

- PAGE i OF 16 P

State of Vermont AaWCY OF NAnIRAL RESOURCES Dtpurtmet of Enykeninmtal Comemnorn OWW"W1* d P~h Wd VMM~

OpV'uW d FrAb, Paft w4 Asaftgim Wastewater Management-Division Vaportm of E,M u" CiweIft 103 South'Main St. - Sowing Bldg.

14004St. Waterbury VT 05671-0405 Telephone: (802) 241-3322 FAX: (802) 241-2596 June 10, 2002 Michael Kansler Senior Vice President abd Chlef Operatng Offer EFntegy Nuclear Vermont Yankee, LLC 440 Hamilton Avenue

-White Plains NY 10601 Re: Final ID-9.0038-IA PIN: NS75-0006 Entergy Nuclear Vemont Yankee, LLC Vemon, Vermont Dear Mr Kansler.

Encosed Is byour final IndrxectDischarge Permit ID-0-0038-lAwhch has 6een signed eCDr k

oh W4dwtr Management Division orh Conmfsoeof the Depaftent of Eironmet W received -o comments on the draft p*rmt during the comment perod so the final permt Is' essentaly the same as the dmftwhlch we sent to you for yourreview. Please read the entire permit carefullyand becomefanMlllwwih all ofitsterms and cditions. Please feelfreeto cal me at'802-241-3824 if you have any questions.

Fially,,enclosed please find a DEC Permt CustorSurveyForm Please completetheform and send itlo the Environmental Assistance Division at the address Ulsted'on the fbnm. Thank you.

John J. klseChf Indket Dbicr Permit Section

Enclosures:

FMial ID-x038-tA" DEC Customer Survey Form ccwffent:*

Barbara Wifliams. Vermont Yankee Nuclear Power Corporation Michael Baeduzzi, Senior VP, Vermont Yankee Nuclear Power Corporation Barbara MIpley, Esq., Wilson &White Efte Zol, Esq., Goodwin Procter Permit Fie ID-9-0036 K~m~~f%0% 61=T P""on Offims - BanVSssx Jt PlChrdý,anSýrn SL Mwhnbwy

EXMBIT EN-SAS-6 PAGE 2OF16" AGENCY OF NATURWL RESOURCES DEPARTMENT OF ENVIRONMENTAL CONSERVATION 103 SOUTH MAIN STREET WATERBURY, VERMONT 05676 ADhMCSMTVE AMENDMENT OFINDIRWF DISCHARGE PERMIT.

File Code LCT--9ý36 Pernit No.WJD-9-0036-IA °° PIN: NS75-M006 SECIkON A - "ADbUNISTRAMON" In cmupance with provisions of 10 V.S.A. §1263, and in acordance with the following condition%

dtEntew Nuclear Vcmxont Yankee, L 185 Old FeuyRoad Brattebro, Vermont 05302 is sutoied to idirectly disdhuae treated domestic nwage and other laboratay wastes defined herein fhm subsuface and mowd disposal syems Eurvng the Vermont Yankee Nuclear Pover Plant to fte pinmd water and Indi ty into the Connecticut River in the Town ofVencr , Vcmout. This adml~~tratve amendment .tansfersthe permit from the previous permittee, Vermont Yankee Nuldear power CorporntIon, to thlpe'nttft named.above. This adIe tamendment shall become effective on the date of sale of the facillty from Vermont Yankee Nuclear Power Corporation to Euteay Nuclear Vemont Yankee, LLW (see Condition A4 No other kubstantve changes have been made to the permit.

Erpirution Date Typo of Wate Thutment Syte DLposal System Town. *Vernon DnalagoBasin Lower Conmectkmt Rive °°

.. °°

-ReceiiSfiream ComncicutRiver °o°

°° Stream Flow.-

LQow Meod= Montly 1.971,129,600 gjd (cat) 7Q10 984,918,500 gpd (est)

Total Dsposal Capacity 14,347 gpd (normal operation) 26297 gpd (durinng plant outage)

Dilution Ratio (stream flow: effluent) 137,390D.1 at 1MM (normal operation) 68,650o. at 7QIO (no..nal oeration) 74,956:1 at 1MM (during plant outages) 37,454:1 at 7Q10 (duing plant outa*.e)

EXmBrr EN-SAS-6 Entetg Nuclear Veromont Yanl~me LLC PAGE 3 OF 16 DischarePcrmlt IC,-00364A-Pge 2 A2. Compliance Schedule:

The following schedule the actions and requirements necessary for compliace, with the conditions ofthis permit. no permittee shall complete the requirements in accordance with the dates indicated. See the designated section for spcific ddtaili.

Condition Afnd DcsgDpt1in Schwde P-ate A.3. Apply for tenewal of Indirect Bylgwno30,2.005 Dischbge Petmit

62. Have a Vermont Registered Annually in April ./

Professional Mnainee= complete an inspection ofill SeWag collection, treatment and disposal systens.

D2. Submit Annual Inspection Report Annually prior to June 1st D2. Submit schedule for implementing aigineca's reom~xatons Ammallyby July 15th D3. Submit tabultion ofpoading levels As qpecifed D4. Notify Secretazy of'pumping of As Spocd As Specifed samples B2(CpReord waer meftereadings As Specified I

B3(A)Collect and =*ayz groundwater AsSpeeifld B3()?~eaurc and record the depths As Specified. r to g*oundwate" In the monitor wells

,4(A)Collectand analyze receiving As Specified.

stream samples w

EXHIBIT EN-SAS-6 PAGE 4 OF 16 EneWy Nuclear Vermont Yanke, LLC DischargePermit ID-9-0036-IA Pap 3 A2..*M~an* ce* cni*

Conditiflon # ind DR M2(A), E2(C), M3(A), E3(B), FM4(A) By the 1Sth of the second month Submit results ofmonitorf following the date of sapling 19S. Submit Evanuaion by a water June 30,2005 quality specialist of onl reuie efflunuk ground, rnd surf=c water qulItY ddat and biological monitoring data A3. &W Mh permit, unles revoed or amended, shall be valid un til ofAI despite mny inteivadg change in Water Quality StMAdd or the classifimtio ofrecgte 'watei. Xenwal of this Id*ict D*L permit will be xulject to all rule applicable at the time of appNlaton.

fOrrenvaL, including biological gpdards to det.emine sitnffcant alteration of aquatic biot.

ojtte 9A M&lv for Ma rDret _hPernit renewdal bxJme 30. 2005.

Tlis 1dns live amendment shall become effective on the date of sale of the facility.

from Virmont Yaikee Nuclea Power iborponton t. Entergy Nudcer Vermont Yanke, LLC, and shall then spercede ID.9-06 whi became effective -on ctober 1, 2000. Ike permitfeedh submit wM-n noffaflcsao offlhe ale to the

$rawithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or on Mhe next buiness day folwing the closig date.

The Secretay may revoke this prmit in acomdnmo with 10 V.S. 1267.

A6. Trmmfergof Petii Mhspermit is not transferable wiftbot prior written approval ofw the cretary. The permittee sbal notify t Secretayimmedladt inmwxin before any sde, lease or other transfa of ownership, of the property ftom $iidx tho permitted discharge originates Ile proposed transfcre shll make application'for a pmit to be rdssedim* ntheir name. FaHi to apply shall be considered a violation ofthis permi. Responsglty for complimc with the conditions ofthis permit "haUbe the burden of the pennittea until such time as transfe of the permit to the ti-nfere Is complete. "Is permit shall be anmferred only upon showing by the permittee or proposed transfee of compliance with the Mowing conditions-

EXIHBiT EZN-SS-6 EtWg Nuclear Vermont Yanke, LLC PAGE 5 01,16 Discharg PerritID-9-0036-1A Page 4 A6. Transfer of Permit (continued':

a. The traniferee shall be a legal entity, financially and technicaWly competen to operate, inspect, =ainitain and replac the system;,

b. If the transferee is Zcorporation or other legal entity, it shall be demonstrated that such legal entity has legal authority to raise revnues for the proper operation, inspection, and maintenance of the sAstem and

c. The transfeme shall provide a written agreement containing a specific date for transfer of penint repnibility, coverage, and liabili between the current and new penniee(s) to the Secretary.

A7. Minor ModificatiMoI offPnits:

°..

Tho Secr=tary may modify thi permit without requiring a permit application, a public notice, or a pbliVc hearing to correct typographical cams, or to increase the monitoring frequency in accordance with Condition E(8) of this pelniL.

A8. IndMrect Dishare Rule-:

Thi indirec discharge was rvimed and originally qualified for an Indirect Discharge Pam*it in accordanc with Section 14-V-20"'0I*, In Situ, Tn-C.rund Efluent Testing, ofthe piriet The New Warehouse sawa trýatment and disposal soy was approved under Water Supply and Watwater Disposal Permit WW-2.o339. Tis indirect dscharge permit icporates by reference all ofthe tems and conditions of t permit with the exception of Condition #6.of WW.2-0339 which has been pq=eded by CoadMon D3 ofthis pem&L 9..

This Indirect discharge was wviewd aad qualified fot an fndirct Discharge Permdit n t accordance with Section 14-403 (C) of the Indirt.D1iharg Ruks for new indirect discharges of *swagev. No increase in sewage volume is allowed without the written approval of the Se~ct..y

EXHIBIT EN-SAS-6

]PAGE 6 OF.16 Enery NWIu Vtiin Ynke LLC Disharge PerMitD 0036-IA Page S A9. Riekf Ag*To In accordance with the Vermont Yankee Nuclear Power Corporation's security equIrements and sadard protocol for site bseeionsý the penmittee shall permit the Sertary or the Secretarys authorized repreentatve upon the presentation of their credentials:

a. To enterupon permwitee's premis in which any effluent souce treatment or disposal system is located or in whih any records a req*ed to be kept under the conditions of thepmlit;

b. To have acc= to and copyny reords required to be kept under conditios ofthis

-emt;

c. To inSped anymotog eqWpmnt or method required in ths pernit;

d. To sample any discharge ofwide, or groundwater or surface watt., and

e. To inspecatt rasonable times, My collection, treament, pollution mxnagement and disposal facilities required by this penmiL Alo. Pcmit.^

• t*.@j A copy of die approved plans and &spemi shll rmain at the office, ofthe peunittee and, upon request, shall be made avilable for InspectionbyatIited reptesenautmive ofthe Scecrtary.

AlI.'"WmorModtfivtlosToSfM M~iWmiNfit nn ofte cntineeri des~gnWhk do ado reduce the treatment effbxtienMs or incras Ohe capacit of th system maybe Vppoved in witg bytSo Scaretywitbout permilt Beore making modifications to die treatment and/or disposal sstem fthpermttee shall submi plans to the Sectaty for r*view and appovaL Ths plaus mst be skpoved bcfo anyof th noitflcaliors o additionwsa made.

EXHIBIT N.-SAS-4 PAGE 7 OF 6 Eat= Muclear Vermont Yankee, LLC Discharge Permit ID-9;0036-IA Page 6 A12. QCgoection of Failed Svstems:

The Secretary may, upon discretion, Le an Amendment to the Indirect Discýhae Permit for the des.gn and reconst*uction of a failed wastewater disposal system where the replacent system design was not previously approved.

cefore reconstraction of the failed system the pcwttee sl submit pln to the Secretaiy for-review and approval. The* plans must be approved before any reonstufionccurs. Due to the urpcy of the need to conec failed di systems, the Sewty will process these Amendments as soon as possible.

A13. Opeatin fees This indireat Dscae is subject to operating fees. Th permittee shall submit fhe opezting foes in accordance with procedurz= provided by the Secretary.

SECTION D "INDIRECT DISCHARGE" BI. Lnto-fb~kgd D The indirect dicharge is localedl'6 the Connecticut River in the Town of Vemnon In W-indham County, Vermont with a drainage area of 6,266 squaw mils at the point of compliance. The indirect discharge can be located on the USGS BattlebomVerwont 15' quadrangle map at Latitoe N 42o 40 54 and Lonf'tudiW e2 03049".

SatuM of Indirect Pischarx.

Ite discharge cons rimarlyoftrtd domaeo sewage and may also Waclude nan volumes of laboratory waste pimay pH buffd soluiom, acetio acdd (5% sohbsion) and potsium iodide (0.3% soluion).

The wastewateris ichrged-frtm sabsmface ond moundwatewater disposal qsy swith the followigapprovd cqpaetite I

U.

I.

EXHIBIT EN-ýAS-6 PAGE 8 OF.16 Entergy Nuclear Vcmbnt YmikeeM LLC DiagPrnit ID-9-0036lA ":

Papg7 B2.Ntr fidietDshrw eniud_

Normal Operation "Plant Outage" Design DIslSal System Design Capacity Capacity (gpd)

Main (North) System () 4,950 14,900 C.03. (Soulh) Systim 4,607 4,607 New Office Bulding System 2,160 2,160 New avdos System ( 2,000 .4,000 K Governor Hunt Houe System 540 540 Gatebibso 0isystem 90 90 TOTAS 14,347"__l 26,297

() Duringplant outages, the Main (Noth) system maybe loaded to a maximumn of 14,900 paloa pce day by lkoaing both cgsfng klwafelds (comined 9900 d) and the new 5,C)0 ipd leacfield. The outage lasts ximaely one moh and occs evey.18 month Dadn 6s outages Vermot Yankee Powv Coipoton adf temporary worke I to perform n the plant SDmuing plant outages, the New Warebouse System may be loaded to a maximum of4,0( 0 gallons per day by loafng both exiskt lawdf TIe low median monft flow (IMMF) of thed mcticeRirs 1,971,129,600 gpdandf teQt0 flowis oprmat 984,918S00 pPdL Dmringnormal" operation, fte fstram SlowdMulmt dilution ratio is 137,390A at LMMF and 68,650:. at 7QI0.

Durtigplantoutagestheram flowdekflsut diltion ratio is 74,956:1 at LMMF and 37,454:1 at7QlO.

Also, please see the Fact Sket for this permit.

SETION C "SYSTEM CONSTRUCTION" Cl. Aproved-Plans-Ex-istig Svtezms.

A listing of the approved plans for construction of the suPIrfame sewage disposal systems at Vermont Yankee whose dishrM are authorized by this permit can be found in thebf sheet pre-viously issued for ths penmit.

EXHIBITEN-SAS-6 Entergy Nucfear Vermont Yankee PAGE 9 OP 16 DischzrgPenit1D-9-0036-lA Page 9 SECTION D "SYSTEM OPERATION" DI. ee Q ra uireen:

• The wastewat disposal system shall be operated at all times in a manner that will (I) not permit the disharge of sewage onto the =fa ofthe ground; (2) not result in the surfcing of sewage-, (3) not result in the direct discharge of sewage into the waters of the State; (4) not result in a violation of Water Quality Standards; and (5)not cause a significant alteration of the aquatic biotain the receiving waters.

The disposal fields for the Main, New Warebouse, andNw Office Building sewag disposal systems shall be alternated on an anmual bass. The effluent disposal rate to sewage disposal system s not emcced the values lst in Condition B(2).

D2. AMEW InEvcgton: *:*

Annually during the month of Apari the permittee shall egage a professional e* reg r.d in the State of Vemont to make a thorough inspecdon, evaluation, and rqpor ofthe complete sewage collection, treatment and diposal system. The engineces inspection shall include, but not be limited to the following:

a. verification of the use of alternate disposal fields (Main, Now Warehous and Neaw of ice disposal aysep*)**

b. vetification ofthe properepermtion of the lift &ion pumps and alams:

o. inspecting am entir coUcetlon system, removing manbole covers to observe the condition ofte sewers and manholm and noting ,ysigns offinflow or excess infiltration;

d. vduating tho ton ofsolids a* m in e septic tAmn nd vctifing ft datoe of pumping of the tanks;

e. checing tho proper distributon of flýw and the levelness ofall distribution boxes in the disposal flclds E c c the*. depth of ponding in observation wells for tim fields In use during the inspection;

g. checking t cahlbration of the effluedt flow meer (ifapplicable); and

h. noting any noeessmy repai:s or umatence that needs to be pýzformed

ExHIBiT EN*-SAs-PAGE10OF16 Entergy Nuclear Vennont Yanket, LLW Disca. PeMIitWD-9-0036-lA Page9 I* A&jnnaIflspeet~on (coniued:

Before ]me lot each yar the pennittee s have aprofessional eineer s t an annual report that includes the following items:

a. a complete list of the items inspected and the results of the inspection;

b. a discusion of the rqom de p and matenane requ*red; C. the m=arul depth ofsbl)dg ad scum in all sTic tanks and

d. an vnluation ofxmetcred watez use, depth ofpondig and groundwater table levels in thie vicinity of the fdspl fields (if groundwater depth measurement is re .e Before Lubt I Mth each Y= the permittee s notify the Secretay in wifting stating-ow the cnicesr rr: doons ame to be implmented and Iieludng a scedleW for the requied and manteance, D3. Qpgaon During~llgnt QWM mwenftee &hallvonfpoi t s*=(H)od*

Main pump pternating syas. Mt allamfeldsdainplant outa*. At Icast evaytwo wek during outaM th p *-te sba meinasuare the depth ofponding in the obevh wedls in the Main (North) sysem. JU pemnitte shall verify that the New Warhusen system pum~p station is Fproprly alternating betwoen,both DI. Ovrto. Duda&n EWan go=t "olds during plant outag. At lead ev=y trio we* dwing outage the pennftc shall measu the depth ofpmo g in theo a vion wells in t*oWw Wachuw system. The penittee shall-x* it a t moftd ided a ements id th end ofeach outge priod, along with ft equhed flowrecods.  :

D4.

During tn systee's annual i ospecton the depth ofsludge and scm shall be measored in-all septic tanks nT septic tanks abe pumped IE 1)te sladg is closcrthla twelve (12) inches to the outlet bai or;,2) the scum layer is cloer th tmhe (3)inches to t septic tank outlet baffle or,3) if otherwise recommnended by the inspectin Sampling ofthe setic tank effluent for uditivoit in acorlance with the procedim fisted in the approved Quality AsswmacelQuality Control Plan must be done each time pumping oc=T, prior to LOW)pumping the tanks

EXHIBITEN-SAS-6" Entergy Nuclear Vermont Yankee, LLC PAGE II OF 16 Discharg Permit ID-9-0036-IA.

Page 10 D4. Sftage Diposal (continemd:

Before pumping the septage for land application, the pernifttee shall notify the Secretary in writing.

of the name mid address of the pumper and v* that the sludge has been tested for radioactivity and will be disposed of in accordance with the Solid Waste Management Facility Certification.

D5. System -Otionand MaIt  :

The sewage cb~lection, treatment, and disposal system shall be operated and maintained at all times, in a manner satisfactoty to the Secretary and in a manner tha will not pose a A*k to the public health and safety, or cause contamination of drinking water supplies, groundwater and/or surface water.

D)6. Revorti f FAiure:

The pernittee shall immediately report any failure of the wastewater collection, treatment, or disposal sytem to the Secretary, firtM by telephone on the first working day within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the fihlure and then in writing within 5 business days of the W=lure. The written notice shall include a discussion of the actions taken or to be taken to correct the failure.

Notification shall be to the Indirect Discharge Permit Section of the Department of Environmental Conservation at (802) 241-3M.Z Reporting of instances when daily average flow xceeds design flow will be initiated only when:

(a) a flow exceodence is associated with a physical or mechanical condition which compromises the perfoi '*ofthe smwa.dis al system; or (b) a flow exceedence ocicu fo thrde or norn consecutive days during zan outage period; or

"(c) a flow cxceedence occurs for two or mor consecutive days during a non-outage operating

• period.

Aiy design flow excedence shall be investigatedc to determine if it was associated with a problem in the system's performan*ce.

D7. DischamotBIdtons: D7-.

IThe pe*aittee shall not allow any person to discharge or case to be disharpd anytfng other than sanitary wastewater and the laboMtoy wastes authorized herein to this tratcint and disposal facility.

EXHIBIT EN-SAS-6 PAGE 12 OF 16 EnterW NcJea Venmont Yunkee LLC DiscargPemnit 0036-lA Page 11 SECTION E "MONITORING" El. gou~ty ~ * *t Plaw The aboraty identified in the Quality AsuraucdQuality Control Plan shall demonstrate successl pefomanxe for U.S. EPA check samples forall paametes and sha"l analyze any check samples povided bythe Secstmy. Failure to obbin an acceptable reslt for eith samples provided by the Searetry or EPA check samples may be a basis for requiring an dalnaealyiab hbora .

Kgf E2. P.fflnent Monitorini*"

A. m 1 The effluent to the disposal fields for the Main, C.O.B., New Wardiose and New Offie Buildi*g sewwp p sypm sk hal be mpled and analyzed as follow r e Meamnlts SUaOe Type SampUFftv"Acy

__ _ ..... . .d ...... Dafl rTdi . ... CC&Uo s BJowml Oqe Demmd fl0b Apri and 0d To "Sup&dSdS&

IVI Ckb Apr Md Otober PH S*lY. 0m*b AV mad Octobw TOW te Mnp= wlI Gtab Apid~adctbea Aimwa(azoi M4__ _ Grab. Apil adOctbebr T* 1 0mb ApwA,dobetor

________ra nV4 Club ApUuid~cober

___ bobm

___ axhv

• Ggsb AprilmdOctobw

__Im_ (CS)_ _ _ wmb A r

=**doborAct (0 jwy adtaay rcco dfly watram we muean dadt ir o s mfwtornrqbuc (See SMbdow)L I

The c ulsm~daheefet dof aubiaIs shall be mubmUed bo the Scretay pror to the 12 day Ofte 1Lsecod mouth folowhkg the daft ofs=zrhg.

EXHIBIT EN-§AS.-6 PAGE 13 OF 16 Entergy Nuclear Vermont Yankee,-LLc Discharge Permit ID-9-0036-IA Page 12 E2. Effluent Monitoring (continued):

3.. Sewage Volume:

The permittee shall install sewage flow meters on the Main Sewage Disposal system, the C.O.B. sewage disposal system, New Warehouse sewage disposal system and New Office Building system in order to monitor the daily sewage flow to eadc of these disposal fields.

Alternatively, the permittee may recozd the daily water meter readings for all units connected to these sewage disposal systems, along with any boted water utilized, to detenrm the total volume ofwater usod each day. The volume of water used and individal meter readings shall be submitted to the Seeretay by die 15lth ofthe month following the recording period.

B33. Grundwater Monitoring A. Chemical and Bacteriolotical MadtortinK.

The groundwater in the monitoring wells upgradient and downgradicat of the Main, C.O.B.,

New Warehouso and New Offie BuildWg sewage disposal fields, both primary and alternate, as identified in the Quality Assrntocel Quality Control plan, shall be sampled and analy;ed for the following parameters

?Arzmeter F$%sw=,mtUni~sts $ample1~y" Sam*e raquenq]

(S-d~~ og/. pb AprIlandOctober TOW qcUW enm(as to weg I ab Apmdlud~cober A~moula (ass i/ &=ab, AptUland Octbka nadtc(OSN Mq/ grab Aprillnd October MUIO lt(as to/ 06a Apgdlandpcber TotalDkIsotid lbosboss mg/ gab April and Octobe (itslP). _

Chkcxd&(a) MvgI vmb ArIl and October PH L.U. zmb Apgi mnOdaber Fscblerfchia coil Coloutes/IO00nil Stab ApWi and October Dept to OwmudvwaWe (below zes-Altuofamlg

-wn - _ __ _ _ _

Because ofchaqgn water table oditions, the samples fin the poundwater m' tors mglt uot U colleced on the sone day or la the sime week if water Is met available. Ifa monitor has wat* at any time dining dhew oth tmea smple is reuired to be collecied danalyzc For he pupm oftdds secion, wherefotweldy gtromndwwiafte mr tpart qed inApril md Octobr. Once a well is Impled, no f....crroundwatWi a iencotsw 1 lIbe required for tawel foirat mn "b. results of these sbalyc siall le abittod to the Secretay prim to thoe j day of the second month following the date ofmplng... ..

EXMIITEN-SAS-6 PAGE 14 OF 16 Entewg NUClea VerMont Yankec LW Darc'PeonftID-9-0036-IA Page 13 133. Gtymd waterMonitonLa (0continued:

B. QoMdw*ertewl The Quality Control/QualityAAsunce plan includes the location of a minimum of six gro. wfer monitors installed aound the Main, COS.. and Nw Warehouse disposal systems eacli three groundwater monitors installed around the New Office Building disposal fields, and two g watermonitors Instled wround the Goveor* Hunt and Gatbouse #1 disposal "ses each, to mouitor the level ofthe ground water table.

bM ree by thle depth to dwater (bow ground surface) shall be meamurd and recrded, at a friquacy dcetminod by the Secretary above that required in "3(A) above. Any each request would be in the form of a letter to the E4. RecvjingStreyam:jnjQ Indirect Discharge Permits normallyrequire regular chemical and biological monitoring ofthe receving waters. Due to the extremely large strem flow to effluent flow.ratio at low median monthly flow (apo 161,740:1), and the size of the C eccut River at the point of complimneem strea water ftquality Is not required for this syste&2 However, if the Secreary detenines tream movir to be necessary, thewpeanftte shall submit, upon writte nodto film the Secretary, sampling pocedur for cecal and biological sampling ofthe reedving waters within 90 days ofreceiig such notice. Ie requirunest for sampling and the frequency of sch sampling will be upon write notice from the Secretat,.

ES. 8wmmrWa t-to the S*cetayofall past efflunt and g quality data an determine what, ir any, short orlong term impacts theve have been on gwun.water quat. Ifthemical and biologkica monitoring ofthe receiving water was conducted, Ite result of that monioring shall also be evaluated.

IB6. Samplan and T-esft& Pm- :ue All wastewater, grmodwater and surface wate smpling; prsevation, hand ing and test procedeI used to comply with te monitoring requirements herem shall conform to procecres specified in the most current edition of Sndard Methods for the EXamination of Wster and N Im APHA - AWWA -WPCF, and the Vmnont Water Quality Standards unless written approval of an alternate method is recdved from the Agency.

EXHIBIT EN-SAS.6 EnteVgy Nuclear Vemont Yankeer LLC Discharge Permit ID-9-0036-IA Page 14 E7. MiscellaneouS:

If the Paemittee monitors any required parameter set forth in this permit for this treatment and disposal systim more fiequently than required by this permit, the results of such monitoring shall be included on the Discharge Monitoring Report Form.

All records and information resdting from the monitoring activities required by this permit including all rpcords ofanalyse performed and calbration and maintenance of instrumentation and recordings from continous monitoring instnntation shall be retained for a minimum of tee (3)years, or longe if requested by the secta. Records shall include laboratory bench sheets showing exact location, time and composites of sample as well as analytical proceures used, interim results obtained and an calculations supporting the reported test results.

ES. Additional Monitoring.

Tm Secctmy reserves the right to require additional monitoring of the system, in accordance with C. ton A(7) of this permit should operafion ofthe system Mi to mee the requirements of Conditions D(I) and D(5).

SECTION F- "COMPLIANCE REVIEW" If the results ofmonitoring the effluent and groundwater (Section B) show there is a possibility t atmhe aquatic permitting rtaia pffe Indirct.Disharg Rules may be exceeded at the designated sra flow conditions, the Secety may incm the fiviquency o; or change the location ofmonitoing of the ground and surface water. If continued monitoring and analyis indicates that a violation of the nt disposal rate., or s violation of the Vermont Water Quality Standard or a significant alteration ofthe aquatic biota bs occwured, is occfti.&

or is likely oCcur the Secre tay mayrequire the pennittee to take p priale corctive ations to eliminateto or reduce Otepossibility ofaviolation, The n of this ae am.ndment ofIndirect Discharge Permit ID-9-0036, to the EaterayNuclearVemontYakWee, LLC.. by the Seceay reies upon the dia, dedgns, judgement and other information supplied by the applicant, his consultants and othe" experts who have participated In the preparation of the application. The Secretary makes no assuran& that the systems will mee the performance objectives ofthe applicant and no wamrraties or guarane are given or implied.

EXHIBIT PAGEEN-SAS-6 16 OF 16 Entergy Nuclear Veronrt Yankee LLC Discharge, Permit ID-9-0036-I A Page 15 SECIION G - "EFFECTIVE DATE" This bxdirec Discg PendiID-9-0036-1A, issued to Enc Nucle Vczmont Yankee LLC,. for the disharp of waewater fiom the sewage teatmet and dispol sa"enm at the Eatcg Nuclear Vermont Ytnkee L,., facility in Vcnaon, Vermont becomes effective as de=Wd under Codton A(4).

DherRtect f Co*hmla ner Dqmatinent of EnvWIronmmentalcm Coejraln By Z WastewaterMunagmant Divis

. olh*

KL-ma1hdhtctG9.O3&63Apd

1.*

EXHImiT EN-SAS-7 iAGE 1 OF 2 SVE-Associates

. Engineering Surveying Landscape Architecture Planning February 12, 2003 George Thomas Mail Code 1225 Entergy Nuclear Vermont Yankee, L.L.C.

P.O. Box 250 Governor Hunt Road Vernon, Vermoht 05354

Dear George:

In response to your question of whether there is a sufficient water supply at the Vermont Yankee site for the next refueling outage (RFO 24), I have prepared a summary of relevant information:

Existing Water Supply The permitted well yields listed in Vermont Water Supply and Wastewater Disposal Permit #

WW-ID-0002 for the Vermont Yankee Site are as follow:

West Well= 73.3 gpm (West well supplies: admin bid, reactor bid, south warehouse, gate 1, gov. hunt house)

Plant Support Building (PSB) Well = 30 gpm Construction Office Building (COB) well = 9.4 gpm Southwest Well = 10.5 gpmn (not used regularly)

Estimated Water Demand During RFO 24 Number of employees expected during next refueling outage: 1500 + 200 (contingency) = 1700 Average water usage per employee (per VT Water Supply Rule): IS Average Day Demand (ADD): 1700 x 15 = 25,500 gpd Maximum Day Demand (MDD): 25,500 gpd 1720 minutes (assumes a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period per state requirement) = 35.4gpm NOTE: This is a very conservative assumption since it assumes all 1700 employees are at the site at the same time. The actual estimate is for 60% of the employees to work a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> day shift and 40% to work a I2 hour night shift.

The expected distribution of the 35.4 gpm Site MDD can be estimated for each well based on employee space and permit limits:

• PO Box 1818, Brattleboro, VT 05302 Phone (802)257-0561 Fax (802) 257-0721

" 47 Marlboro Street, Keene, NH 03431 Phone (603) 3551532 Fax (603) 355-2969.

2 Fiske Avenue, PO Box 1079, Greenfield MA 01302 Phone (413) 774-6698 Fax (413) 773-0875 Website: www.sv soc.com E-mail: inf&@sxassoc~son

I ..

EXHIBIT.Ek-SAS-7 P-*E 2 OF 2 PSB*Well Serving the PSB building with 160 employees and the temporary "Power Uprate Building" with apprbximatelly 30 employees.

190 employees x 15 gpd/employee ..2850 gpd MDD = 2850gpd 1720 min = 4.0 gpm COB Well.

. .Wter'usage at'the'COB building is monitored such ihat it does not excee.d the IndireCt Discharge Permit limit of 4607 gpd to its septic system. Assuming all usage i's in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, the MDD foi.

this well would be:

• MDD-4607 gpd /720 min. -6.4 gpm.

Please note that there is currently a project underway to add wvater storage tanks and booster.**

• pumps to the COB building water system. The goal of the project is.to alleviate problems of lIwo,.

system pressure during periods of peak demand.

West Well That portion of the site MDD that is not supplied by the other wells would be provided by the.

West well.

Site MDD = 35.4 gpm - 4.0 gpin (4B) - 6.4 gpm (COB) = 25.0 gpm Since the west well has an expected yield of 73.3 gpm,'it can be expected to reliably supply the remaining demand of 25.0 gpm I believe the information above should make a clear case that there is an adequate water supply at the plant for the next outage, however if you do have questions please call or e-mail.

Sincerely, SVE Associates John E. Goodell, P.E.

Cc: Sonja Schuyler, The Johnson Company Brian Tietze, Entergy Nuclear Vermont Yankee, L.L.C.

EXHIiT EN-SAS8g PAGE 1 OF-14 State of Vermont AGENCY OF NAT*RAL RF-opt*cFs Dqwmkt d Fb an Ps W4 rdf Deplrtmtent ot Eavircnmental Conseryaldon 0*1W d &MMO caVs Waster Manawn Diviion 8" Oog 103 South Main SbvAt Sew4n Buildin RELW SER~E AtM~IM AAM4 140045s.341hs TI2Oc.Vko W~r~M Wateobuty VT 057 1-0405 Phone: 802-241-3837 Fax: 802-241-2596 July 12,2002 Mr. Michael R. Kansler Senior Vice President Entergy Nuclear Vermont Yankee, LLC 440 Hamilton Avenue White Plains, NY 10601 RE: Entergy Nuclear Vermont Yankee Certificatlon Transfer

Dear Mr. Kansler,

Endosed please find the original Certification #1F9906-Ai,au*tr*iong the signed transfer copy of Solid Waste Managernent Facility frm Vermont Yankee Nuclear Power Corporation to of the previously Issued cerbficatlon #F9W,.

• i* The certification amendment was Issued Entergy Nuclear Vermont Yankee, LLC.

by the Department of Environmental Conservation July 2, 2002. on Also enclosed please find the applicaton Corporation sbmItted to the Nuclear Regulatory that Vermont Yankee Nuclear Power June 28. 1989, which contains waste standards Commission (NRC), and the cover letter dated radionudlides In the wl (site *fo). This application end sets maxmum allowable accmulatons of amendment. is referenced In Item Q of the certification Please read this certificaon amendment careful.

commerds, please feel free to contact me. Ifyou have any questions or Envkontnenta Analyst Residuals Management Section c: Barbara Ripley, Wilson &White Samuel Wender, Vermont Yankee Michael Bakluzzi, Vermont Yankee Plant Manager 4 Elise N. Zoll, Goodwin Proctor, LLP Enc: Final Certification VT Yankee apprication to NRC and associated cover letter K:iedus DEVWunMvp Yankee Transfc",na Lettar.wpd Offces. Bw*rsx .actztsJotois.

I rbury

EXHIBfr EN-SAS-8 PAGE 2 OF 14 SOLID WASTE MANAGEMENT FACILITY FULL CERTIFICATION 10 V.S.A. 6605 OPERATOR: Entergy Nuclear Vermont Yankee, LLC 440 Hamilton Avenue White Plains, NY 1.0601 Michael Kansler, Senior Vice AUTHORIZED REPRESENTATIVE:

President RESIDUALS MANAGEMENT FACILITY I.D. NUMBER: 253 CERTIFICATION NUMBER: F9906 - A FIELD DESIGNATIONS: North Field: FVN0101 South Field: FVN0102 MONITORING WELL DESIGNATIONS:

North Field: WVN0IOI WVN0102 WVN0103 South Field: WVN0201 WVN0202

.

• AS WVN0203 WVN0204 CERTIFICATION PERIOD'. Effective Date per Condition G of the Certification.

Eqlaon Date Septemrb 30, 2004.

PURPOSE OF CERTIRCATION AMENDMENT.: This is a transfer of the previously Issudd cerficaft-on, from Vermont Yankee Nuclear Power Cqporatlon to Entergy Nudear Vermont Yankee, LLC. Al conrditions of the certification Issued on November 17, 1999 remain the same, except for Condition G regarding the Certification transfer.

FACILITY LOCATION: The Sold Waste Management Faclt includes two land application sites located on the property of Vermont.Yankee Nuclear Power Plant in Vernon, Vermont, one temporary septage storage tank utized during operations, and any vehices and equipment necessary for proper operato of the faclity, which am kdenOW in fth Cerfication and described In the stbmitted management plan entitled, "APPUCATION FOR RECERTIFICATION OF VERMONT YANKEES SOLID WASTE MANAGEMENT FACILITY IN VERNON. VERMONT', dated March 31, 1999, which was received by the Department of Environmental Conservatlon on April 11999. The operation of the Facility has been previuly authorized under one full certiflcation.

FACILITY OPERATION: Stabilized septage Is pefmitted for use by land application during times of the year when the ground Is not frozen or snow covered, and when saturated soll Is at a depth greater thanthi-six (38) kiches below the bottom of the zone of Iorporation. During periods when land application is not permitted, any septage handled by the PermIttee wil be managed on-site until conditions allow for.land application. Septage Is required to be stabilized for pathogen and vector attraction reduction prior to land applicatio,, according to the Vermont Solid Waste Management Rules and 40 CFR Part 503. Stabilization will be achieved by the addition of hydrated lime [Ca(OH)J. or its equivalent, as provided inthis certification.

FrmuB"PAGEEN-SAS-8 3OF-1 Vermont Yankee Page 2.of 13 Solid Waste Management Facility Certification #F9906 - Al Land application rates of septage shall be established by the Permfttee prior to application based upon crop nutrient requirements, contribution of nutrients from other sources, and the actual nutrient content of septage.

APPUCATION REVIEW: The application for recerlification of the facility was reviewed in accordance-with the Vermont State Solid Waste Management Act, 10 V.SA §§6601 _L and the Solid Waste Management Rules, effective January 15, 1999 (Rules). The application Is on file in the office of the Wastewater Management Division, Department of Environmental Conservation, Agency of Natural Resources inWaterbury, VermontL FINDINGS

1. On April 1, 1999, Michael Saiduzzi, Manager of Verrnot Yankee Nudear Power Plant, of Vernon, Vermont (Pennittee), submitted an application to the Department for recertfcation of a Solid Waste Management Facility for a septage management system utilizing land application as the management strategy.

2. The application was certified to be In conformance with the Rules by Roland Luxenberg, P.E., of Aquaterra, South Burlington, Vermont, a professional engineer registered to practice In Vermont

3. In accordance with 10 V.S.A. § 6605 (f), the Applicant provided notice of the application as required by that statute.

4. The application was reviewed by the Department and determined to be adnintstratively Incomplete. Additional Information was submitted and the application was determrnod to be administratively complete on April 22, 199.

5. The public notice of Ihe application was advertised in the BmlUeboro Reformer and The Town Cder on May 7, 1999, and via direct mall to all parties stipulated by § 6.304 (h) of the Rules.

6. Draft Findings of Fact were developed for the Facility In July. 1999. The Secretar of the Agency of Natural Resources (Secretary) actv solicited comment on the draft findings of fact. The public comment period ran from July 19,199I through August 4, 1999. No comments regarding tf draft Findings were received by the Department

7. After the dose of public comment, the Department reviewed the application and draft findings of fact for conformance with the Rules.

8. The application was reviewed on Its technical merits and was determined to be technically complete.

9. A draft certification and Fact Sheet were developed for the Facility In October, 1999.

The Secretary actively solicited comment on the draft certfcation and Fact Sheet. The public comment period ran from October 22, 199 to November 15, 1999.

EXHBrr EN-SAS-4.

PAGE 4 OF 14 Page 3 of 13 Vermont Yankee Solid Waste Management Facility Certification #F9908 - Al CONDVONS AND REQUIREMENTS FOR OPERATION A. The Perintttee shaw perform all actions necessa for the proper management of septage inaccordance with the Application and the provisions of this certification.

B. The Permittee shall comply with the provisions, requirements and standards set forth In 10 V.S.A. §W601 e1 sMe and the Rules, except as expressly provided herein.

C. The sitesdentifWed in the Application at Vermont Yankee In Vernon, Vermont are the.

only authorized management fac.lties. Use of other sites for septage management via land application without prior written approval from the Secretaq is expressly prohibited and shall constitute grounds for revocation of this Certification.

D. The Construction Office Building (COB) tank Is the only authorized storage and treatment facility. Use of other fadjities for treatment or storage without prior written approval from the Secretary shall constitute grounds for revocation of this Certification.

• E. Septage generated by the Pemirtlee's on-site wastewater disposal systems is the only waste authorized for management via land application. Management via land application of other regulated solnd wastes without prior written approval from the Secretary shall constitute grounds for revocation of this Certification.

F. The Permittee shall comply with an existing federal aws, rules and regulations that apply to septage use and management practices and with the technical standards set forth In Section 405(d) of the federdl bean Water Act and 40 CFR Part 503 If an applicable management practice or numerical limitation for pollutants In septage more stringent than existing federal and state regulations Is promulgated under Section 405(d) of the Clean Water Act or40 CFR Part 503, this certification shall be modified or revoked and reissued to conform to the proulgated rgufatlon Paeittee sha comply with the lhndtations no later than the compliance date specifled Inte applicable regulations as required by Section 405(d) of the Clean Water Act Or 40 CFR Part 503.

COMPUANCE SCHEDULE" G. (1) This amended certification shag become effective on the date of sale of the facdly from Vermont Yankee Nuclear Power Corporatign to Entergy Nuclear Vermont Yankee, LLC and shal then supersede Certification No. F9906, signed November 17. 1999. The Permittee shall submit to the Department written notification of sale within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the dosing date.

(2) On or before March 31. 2004, the Pemftee shall either apply for full certiflcation of the Facility or submit a plan documenting the strategy for closure of the Facility.

MATERIALS AND SITE MANAGEMENT AND MONITORING REQUIREMEWTS H. The Permittee shall comply with all the siting conditions specified for diffuse disposal in Subchapter 5 of the Rules.

L The Permittee shall comply with all facility operation standards, requirements and

EXIIIBIT EN-SAS-8 PAGE 5 OF 14 VOrmont Yankee Page 4 of13 Solid Waste Management Facility Certification #F99006 - Al conditions specified in Subchapter 7 of the Rules Including, but not limited to, the following:

(1) 'Application of solid wastes on frozen or snow covered ground is proh'bited; (2) Application of solid wastes Is prohibited at times when saturated soil Is within three feet of bottom of the zone of Incorporation; and (3) ,A1i restrictlons set forth in Section 6-702(aX9) of the Rules.

J. The Permlttee shall remove septage from each of the on-site Wastewater systems located within the perimeter of the Vermont Yankee Nuclear Power Corporation (the Main COB, New Office Building, and New Warehouse tanks, Governor Hunt House, Gatehouse 1), and transfer it to the COB tank for storage until the laboratory results confirm the septage is of suitable quality for land spreading.

K The Permittee shall ensure that septage Is treated with lime to reduce pathogen content and vector attraction prior to land application. Treatment will be achieved by adding suffdent hydrated lime, [Ca(OH),] or its equivalent, to raise the pH to greater than or equal to 12.0 Standard Units (S.U.) and to maintain the pH at greater than or equal to 12.0 S.U. for a period of two (2) hours without eth addition of more lime. Dtect monitoring of septage pH, to demonstrate that the pH and hold time requrements are being met, shall be conducted and documented. Documentation of compliance with this requirement shall be submitted with the appropriate quarterly report.

L. Prior to land application, the Perrittee shall mark the edge of the usable acreage with temporary stakes or field flagging to Identify the boundaries for spreading.

M. The Permittee shall continue the soil lIming program to raise andlor maintain the soil pH of all land application sites to within the required range of 6.5 to 8.0 S.U. (aqueous).

Use of the fields Is specifica prohibited at times when the soil's pH is not in the specified range.

N. The following maximum annual site capacites were deternlied for the period of the certfication, If there Is any change in site management, such as Vie addition of other sources of nutrients, changes in crop rotation, or evidence of environmental Impaci, the Permittee shall calculate an appropriate revised application rate for the site.

000 ACEGAAT South Field haylgrass 1.9 acres 55.100 galtyr North Field hay/grass "7.4 acres 214,600 gaVyr Total - 9.3 acres 269.700 gallyr

0. All land application of stabilized septage at Vermont Yankee has taken place at the South Field application site. Septage has never been applied to the North Field site, and is considered a contingency management option. If the North Field site requires utizantio, pH and other site characterization parameters must be determined prior to septage application.

P. The Perrittee shall sample the waste, soils, groundwater, and plant tissues in accordance with the parameters and frequencies set forth in Table 2 of this certification.

E my1iT EN-SAS..8 PAGE 6 OF 14 Vermont Yankee Page 5 of 13 Solid Waste Management Facility Certification #1F990N - Al Testing for metals in the soil and plant tissues shall be for the available form, and shall be reported in milligrams per kilogram (mg/nkg), dry weight basis. Testing for metals In the waste shall be for the total form and shall be reported In unit mg/kg.

of Testing for metals in the groundwat6r shall be for the total dissolved form and shall be reported in units; 6f 4n1grams per liter (rng/i). The results of Othtesting shall be Included with the appropriate quarterly report. The soil radionuclide results shall be reported in microCurles per acre. The septage radlonucide results shall be reported In units of microCurles per kilogram, dry weight basis.

0. The entim content of the application that the Permittee submitted to the Nuclear Regulatory Commission (NRC), and the cover letter dated June 28, 1989 is referenced and adopted as conditions that must be met. Spedflcally, the appication contains waste standards and sets maximum allowable accumulations of radlonudides In the soil (site life).

To Insure the Intent of section 4.2.1 In the application to NRC is accommodated, in addition to gamma spectroscopic analyses of the samples, annual analyses shall be conducted for Strontium-89, Strontium-90 and tritium (1-3).

RECORD KEEPING AND REPORTING R. The Permittee shall submit quarterly reports to the Department by the 151 day of the month following the end of each quarter (April 15, July 15. October 15, and January 15).

S. The results of sampling required for radionuclide concentrations shall be submitted to the Department annually. (in a quarterly report), and shall be reported In units of microCurles per acre (soil), and microCurles per kilogram. dry weight basis (septage),

as spede* in (Q.).

T. All sampling and monitoring results and volumes of lime applied for soil pH control shall be Induded with the appropriate quarterly reporL U. If the results of any of the required monitoring shows an exceedence of a standard, the Permittee shall notify the Secretary in wrft of this fact and reasons for the non-compWne wihin ten (10) days of when the exceedence Is detecld, together with a proposed strategy for remedlatlon of conditions resulting in the exceedence.

V. If the results of any of the required groundwater monitorng shows an exceedenoe of a trigger value specified In Table I of this certification, the Permittee shall notify the Secretary Inwritng of this fact and reasons for the non-compliance within ten (10) days of when the exceedence is detected, together with a proposed strategy for remedatlon of conditions resulting In the exceedence. If such an exceedence occurs, the Secretary reserves the right to require the Permittee to:

(1) install additional sampling locatdons and/or expand groundwater quality analyses;-

(2) conduct all studies necessary to deterinTe the source of contamination; (3) take all actions necessary to control or repair the cause of any impacts.

(4) take all actions necessary to remedlate'any Impacts; and

EXHIBIT EN-SAS-"

PAGE 7 o*:

Vermont 'ankee. Page 6 of '13 Solid Waste Management Facility Certification #F9906 - Al (5) determine and specify the respons(s) to be Implemented, as authorized in Subchapter 7 of the Ground Water Rules.

W. The Pedrltee shll, In February or March of each year of the certficaion, refine cropping and fertilization plans for the upcoming growing season. By April 1 of each year of the certification period, the Permittee shall notify the Department of its intent for septage volumes and times for spreading at the Facility.

X. The Perrplttee shalt keep all records regarding activities,.managernent pradtices, complaints, and observations In a secure, dry place until field closure has been approved by the Secretary.

Y. Inthe event of any discharge or emisslon from the facility which poses a threat to public health and safety, a danger to the environment, or the creation of a nuisance, the event must be reported within twenty-four (24) hours, or on the next working day, to the Secretay, the local health officer, and the selectperons of the affected munkipalitdes.

7- Any and all complaints regarding odors from the Faciity received by the Permittee shall be reported to the Department within twenty-four (24) hours, or on the next working day, of their receipt, together with a report of the measures takeni to resolve the complaint If any response was necessary.

CLOSURE, &THERREQUIREMENTS AND CONDITIONS A.A Upon determination by the Secretary that no further land application will be conducted at the Facility, the Pemttee shall comply with the following post-closure requirements:

(1) Provide for control of public access to the facility for a period of twelve (12) months folowing the last application of septage; (2) Prohibit grazing of domestic food source animals for a period of six (6)months; and (3) Prohibit production of crops for direc human consumption for a period of thidy-six (36) months following the bst application of septage.

(4) Test the groundwater anrnuagy, In the spring after the thaw, for a minut of two years i(the site has received seventy-live percent (76%) of the mawdmum allowable cumulative level based on sol type for any of the metas monitored, or Ifthe Secretary determines a need. The required parameters are listed inthis Certification in Table Z The results shall be submitted to the Department%and (5) Test the soils biannually for a rminimum of two years If the site has received seventy-five percent (756A) of the mnaxdmum allowable cumulative level based on soll type for any of the metals monitored, or if the Secretary determinos a need.

The required parameters are listed in this Certification InTable 2. The results shall be submitted to the Department.

EXHIBIT EN-SAS-8 PAGE 8 OF 14 Vermont Yankee Page 7 of 13 Solid Waste Management Facility Certification #F9906 - Al GENERAL CONDMONS BB. This Certification does not convey any property rights of any sort or any exclusive privilege nor does it authorize any Injury to private property or any invasion of personal rights:

CC. This Certification is not alienable, transferable, or assignable without prior written approval of the Secretary. The request for such approval shall include an applicationr for reissuance under the new name and a written agreement which specifies the date of transfer'and Includes the signatures of the authorized representatives.

DD. Ifthe Permittee anticipates that any compliance date or operating condition will not be met, Permittee shall notify the Secretary Inwrit of this fact and reasons for the arntcpated non-oompliance at least five (5) days pdor to the compliance date or conditions In question.

EE. Thi Certification may be modified during its term for cause with the written approval of the Secretary. Ifthe Secretary determines that modification Is appropriate, only the conditions subject to modidications are reopened. Until a modiicamton is granted, all condltions set forth In this Certification remain in full fore and effect, pursuant to Section 6-307(a) of the Rules.

FF. This Certification may be revoked, Inwhole or in part, during its term in accordance with the Rules.

GG. The Permittee agrees lo Aw Agency of Natural Resources personnel access to the Faciity during normal business hours to perform such Inspections or other activities pursuant to 10 V.SA §6609 as may be required to ensure compliance with this Certification, with all applicable statutes and with the Rules.

HH. The Secretary retain the dght to require the Permittee to perform any other action he or she deems necessary In accordance with 10 V.S.A. O6610a.

EXHIBIT EN-SiS-8 PAGE 9 OF 14 Vermont Yankee Solid Waste Management Facility Page 8 of 13 Certification #F9906 - Al Table, I RESPONSE TRIGGER VALUES FOR CONCENTRATIONS OF COMPOUNDS INOGROUNDWATER PARAM9M GRWOUNWATER Arsenic 5.0 pgA Barium 1.0 mo/

Cadrmum Chloride 125.0 mgI Chromium 5.0.0 pg/

Copper 0.65 mg/I Lead 5.0pg/

Mercury 1.0 pg/

Molybdenum 20.0 pogI Nickel .50.0 pW Selenium 25.0 POg

.*Siover 50.0 pgW Sulfate 125.0 mg/

Zinc Z5nigA Polychlo*iated Biphenyls (PCBs] 0.25 Pg/I Ntrate Nitrogen 5.0 mg/

Total Dissolved Solids (rDS) 250.0 mg/

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Concentration levels of other parameters = of concern for deternining application rates and monitoring kimpacts upon the sites used for septage management Levels of the other parameters wil be evaluated on a case-by-case basis.

An analysis for Total Organic Halides (TOX) may be conducted i lieu of analyzIng PC8B' However. if TOX Is detected in conentrations equal to or greater than for 0.25 pg/I, then an analysis specific for PCBfs shall be conducted.

EXHIBIT EN-SAS-8 PAGE 10 OF 14 Vermont.Yankee Page 9 of 13 Solid Waste Management Facility Certification #F9906 - Al Table 2 RMOUIREfl SAMPLING ANDl TESTING FREQt3ENC-MS PLANT PAABMIETE jArser*k SOIL EOC Annual EOC Annuial EOC Bafum EOC EOC EOC Cadmium Annual EOC Annual EOC Chromfum* Annual EOC Annual EOC Copper Annual EOC Annual Annual EOC Lead Annual EOC EOC Mercury Annual EOC Annual Annual EOC Molybenum Annual EOC EOC Nickel Annual EOC EOC Selenium Annual EOC Anfwal EOC Slyer EOC" EOC Annual' EOC Annual EOC Total KIeka Annual Annual Annual' None Annlual' None Anmmoa Nirogen Annual Annual

• None Mfrate Mogen Annual° Annual EOC Toal Phosphorus Annual** Nonnua EOC Total Potasslum jAnnual 'Annual EOC Total Niftgen None None None None No ne Annual' None Chlork None None Percent Total None Dissoved Sokds None None Polycorknated None 80eny* s(PCBs) EOC EOC None Percent Solids; Annual None None None pH Annual

• Annual" None kg Requknerd None Annual None None Avelable Potassium None None None Avala"e Magneum Amnual' None.

None None AvaaIe RPosphorus None None None Annual" None None CEC None EOC None None Radonuclides Annual EOC None TCLP None None None

---

---- ----------- ----------M - -*

$: Plat Tissue,*mping Isrequiedprior I the end of the cerlcation. Me reat bo Psubted intoC applicaton.

req, W hIti COomnpr Schedule of to car ficti6on.

Annual (Sptage. Once In Wt p,,.V prr to fad ep*.a.on.

Annua (Groundwatr Once inVftmr png fte taw.

AnnMa1 It Must be sarnpled blannamly (spri and fan)tbbioilds are epr Inmore than on season per ye*.

EOC Sa k ptor bo le end of te ceraca IMn.resuf to wubmfttd into eapoc reqmn in the Comrtla=* sclfeule.

. Saffig at f"e year kiteas,. from the dab of ft Lit .nays Conctrfton levels of odwe pararmeters are of concern for deterraifri apptcation ratas and mwonlbln kripacts upontie ft estused for septage trnagernenL Levels of the o*e parameters wil be evaluated on a case--ycse bash.

An analysis for Total Organic Hades (TOX) may be conducted in Ieu of analyzing for Pcss. However. if TOX Is detected inconceatiuons equal to or greater than V"e appicable reguM my standard. On an analysis spec*i for PC*e shll be conducted.

EXHIBIT EN-SAS-s PAGE 11 OF 14 Vermont Yankee Solid Waste Management Facility Page10oof 13 Certification #F9906 - Al The Department issuance of this o Waste Manag;ment Facility upon the data, judgment, and other information supplied by the Certification relies Permittee, the hired professional consultants and other experts who have particpated In the prepration of the Application.

The Department makes no assurances that the system certified performance objectives of the operator and no warranties or guaranteesherein wit meet are given or Implied.

The Department staff has reviewed the above project and appication and finds it to conform WvMth current technical standards. It Is recommended that made and the Solid Waste Management Facility Certification be the foregoing findings be Issued.

I do affirmatively make the findings as recommended by the staff and approve this Certificatlon.

Dated this AL ay' Of .2002. at Waterbtiry, Vermont.

AGENCY OF NATURAL RESOURCES Chris Recchia, Commissioner Department of Environmental Conservation Wstwater Management Division Department of Environmental Conservation

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EXHIBI EN-SAS4i Vermont Yan Solid Waste Management Facility Page 1 3 of 13 Certification #F9906-AI ..

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VERMONT YANKEE SITE MAP (p GN-SITE WATfER, V/A*STEWATER, AND) SEPTAGE n

FACILITI

EXHIBIT EN-SAS-4 PAGE IOF 9 VHSoFFSITE DosE CALcOLATI rim MANUAL _REvisioN 3o)

1. Vequ to Amend htiw Appwgv Grated h~xuantto I0CFM2M.O2f~

Disposalof Sot, dated Septwier i'h, 2000, BVY 00-71 an Apprved lOCMIU.2002 Applicati CTAC No. MA9972r. dated imue 26%,

2001,NVY 01-66 I fRevision 29_ Date 1/11/0Q2 I-I

EXHIBIT EN-SAS-9.

PAGE 2 OF 9 VERMONT YANKEE NUCLEAR POWER CORPORATION 185 OLD FERRY ROAD, PO BOX 7002, BRATrI.BORO, VT 05302-7002 (802) 257-5271 September I1, 2000'"

BW 00-71 United States Nuclear Regaubloy Commission ATTN: Document Control Desk Wasdngton, DC 20555

Reference:

.(a) Letr, VYNPC to USNRC, -Request to Amend Previous Approvals S- Gamnted under 10 CFR 20302(a) for Disposal of Contaminated Septic Waste and Cooling Tower Silt to Allow for Disposal of Contaminat Soil" BVY 99-40, dated 7Ine 23,1999.

(b) Letter, VYNPC to USNRC, "-Sppleniedto Request to Amend Previous Approvls Granted under 10 CFR 20302(a) to Allow for Disposal of Contaminated SoIl," BY 00-02, dated Iama-y 4,2000.

(c) Letter, USNRC to VYNPC, "Vermont Yankee Nuclear Power Station, Iequest to Amend Previous Approvals C=atd under 10 CFR 20302(a) to Allow for Disposal of (_ontzmnad Soil CrAC No. MAS9S0),"

NVY O058;"JatcdJune 15,2000.

(d) Letter, USNRC to VYNPC, 'Revised Safety Evaluation - Approval.

Pursuant to 10-CFR20.2002 for Onstte Disposal of Cooling Tower Silt-Vermont Yankee Nuclear Power Station (TAC No. M96371);"

NVY 97-85, dated June 18,1997.

Vermont Yankee Nuckar Power Station idcense No. DPR-28 (Docket No. 50-271)

R10 est to AMe0.Preous ASIof On

• _ ted Puomant t 10 CMR 20.:20 for Dk22 of CoLftMjntg &if In accordance with 10 CFR 202002 (previously 10 CFR 20302(a)) Vermont Yankee (VY) subnjt this application to amend the, previously. granted approval to dispose of slightly contam*nated soil. Thls application expands the allowable waste strea'roinclude slightly coutamfinted soil generatzd as k residual -by-product of othei types of on-site o uction In Rfeee (a) and (b), VY requested approval to dispose of approeimatly 2S.5 mtm of acemulated soil that was generated due to construction Actvdie In addltton,.it was requested that VY be allowed to dispose of approxiuintely 283 m3 of soil that Is spread annually on station roads and walkways during the winter. NRC acceptance is documented In Reference Cc).

This aplicafion specifically requests approvaj to dispose of contaminated soil that is created due to other c-ite construction related ac&ifits Including but not limited to design change Implementation and land mnantenance.

I *1 ImM2t L U 11&2 1-2

ExUBrr EN-SAS-9.

PAGE 3 OF 9 3.,

VERMdNTYANKEE NUCLEAR POWER CORPORATION BVY O0.711Ipow 2 O,2 In additimon, requests that NRC's review recognfpi that4 although VY lzWicated inlMcre=ce (b)that the so4tAdsposal field (opproximately 13 acs Insize) Iscuwently expeted to be used ford sposal.oftl. subjec: mate'ial, VY is also auored tousc theternate north spoa flim S(approxtmdy 10re rn saim). A&roval to use bo the north ad south Be* for dlposal was granted In Refeece (4 VY': radiological impact assessments hav cousYatIvcly assumed ill of the disposal activities occur on the smaller south field to maxin ze potential calduated doses.

These assessments bound the situation wiere a portion of the land spreading occurs on The north field.

VY will continue to lhimt the total activity spr=ad, flom approximately 28.3 n3 of soil generated each yme', to within the limits assumed In the radiological assment previously submitted in Refence (b). .

A rAdiologi.cajpsssmmt and proposed operational contls for the inclusion of the additional material for on-site disposal was provided In Reference (b). The =essment demonstrates that the dose Impact opct from the proposed activity, in total with all past waste spreading operatio, will not appnd the dose limits hlresayirpposed for septic and cooling tower silt disposal. All soil analyses will be to envionmental lower limits ofdctloa.

The results ofall dsosal operations will be reported Inthe Annual Radioactive Efflueat Reletse Report. M combined radioklgcal mpac for al on4to disposal operatlps will continue to be lnited to a total body or organ dose of a maximally mqxosd merml'er of te public of less than oe menyew duringthe period of actve VY control-of the *e, or less than five mremnvar to an hadvertent intruder after termr1km& of active sie control.

Upon recWp ofryour approval, this request as well as the basis for apprval will be Incorporatod Into the Off-She Dose Calculation Manual.

We trust Ohat the information contained Inthe submittal Is sufficient. However, should you have any questions or require N rtl be nfomin cmceming this mater, please- coutat Mr. Jim.

[iVciM at SM2-20S-4236.

Sincerely,

• . Vumo~m Y*ThkIm'owuc- oiqaemm

• * ~.- +%

Licensing Manager cc.: USNRC Region I Administrator USNRC Resident Inspector -VYNPS USNRC Projed Manager- VYNPS VT Department of Pubtic Service 1-3

EXHIBIT EN-SAS-9 PAGE 4 OF.9.

SUMMARY

OF.VFMONT YANKEE CO¢lrrMPM J3VY NO.- L&M .6 The following table 1dtuti&is commitments =ade In tbsdocument by..Yermon'tYankitee Any other actons dscussed In thi subndmttd'represent Intended or plnned*actions by Vermont Yankfe. They are descrbed to the NRC for the NRC's Infonuatiwo and are not reguiatory come itments. Please notify theiicensing M xmger of any questions regarding thu document or my asmoda commltments.

COWER COMMlTED DATE None N/A VYAPF 0058.04 AP 0058, Rvision I Page ! of I 1-4 Revision 2_9 Date 1*/1_0*2

EXHIBIT EN-SAS-9 PAGE5 OF9 NUCLEAR REGULATORY COMMISSION WAS-MGTOK D.C. 200505-1 I-Jam 26, 2001 Mr. Mchael A. Baj i MVT 01-66 Vice President Operations Vermont Yankee Nudear Power 6 orporatlon*

.185 OIdFenyoroad.

P.O. Box 7002c Brattebo, VT 05302-7002 SUsJwrT: FOR VwwwON AN AMENDMWTO YANE NuOLE-AR AN APPROVED POWER sTATON 10 CFH-202002 sAFmYAPPUICAT1ON EVACUA~iloN (TAC NO..MANM2

Dear lr. BaIuzzl:

The U.S. Nuclear Regulatory Cammbjson (NRC) staff hqs completed Its review of the Vermont 4 Yankee Nuclear Power COrporaon (VYNPC) request dated September 11, 2000, to emend an approved 10 CFR 20.2002 viously 10 CFR 20.=02) appjlcatlon dated June 23, 1999, as-supplemkned on Januaz 4, 2000. The Icensee requested NRO approval to WkM the additio .c.

of $0W c Iadnated soll re from on nsd *activities, ncuM but not ImIted to, design cangelmpiementation and land maintaimc, to the**st of already approved materials (Le., sepdo waste, cooling tower 611 nd solVsand from roads and walrays) for onte dLsosaL Based on our revlbw, *o find the propos** changesd to be acceptable because the previously.

approved boundn con&,on6 vWW continue to be met. The encosre.to this letter providds'our safety evaluation of VYNPO's application.

Pursuant to the providons of 10 CFR Part 61. jhe NRC has publihe an Environmental Assessmeh and fmnding of No 81nflcant Impact Inthe FederelRldstoeronJune 14,2001 (66 FR 32M9).

dA. Zwoft*!l, Director of Licensing Prqect Management.-

Offlce of Nudear Reactor Regulation Docket No.60-271

Enclosure:

Safety Evaluation cc vdenr See next page II eVi -~~ Daft /lffl~a 1-5

EXHIBIT EN-SAS-9" PAGE6OF9 Vermont Yankee Nuclear Power Station cc:

• ~Regknal AdtnInsirator. H09W I Ms. dol B. Katz.-"..

USS. Nucl~ar Reui Corilsilyn .Box 83. .

476 Allendale R16ad Shelburne Falls, MA 01370 fang of Prusda, PA 19406 Mr. Rymond N. McCandless M. Davi Shaw, LLewOW Piban Potts &Tr.Mxol9ge Vermont Deparbment of Health Dfvison of Oocazpa*oal Dr° '

2300 N Street, w.

W. and RadlolgoC Health Washngton, DO 20037-1128 108 Cherny Street Burlngton, VT 05402 Ms. Chrote e S. bert Cooupbseoner epmt Vermont Department of Pub~o Servce Mr. Gautar Sen 112 aStd Street Licensing Mariager Monipefler, VT 05620-2001 VeWioroYhnXi Nuclear Pow M Michael H. workn, CIrman SOld Feny Road Publio Service Board P.O. Box 7002 State ot Verniont Bratkdxeo, Vr 05o,-70o2

• . :112 State 8treet Mo* . eterVT 05820-2701 Resdeht Inspedor.

Vermont Yankee Nuclar Power Ston Chairwkn, Board of Selectmen U. S. NucPear-Rogatory oonsbjrqn Town of Vernon P.O. Boxl76 P.O. Box 116 Vernon, VT 05&5 VewnoV 05354-011 Director, tts Emergency Mr. Ndiard E. MOullough ManagementAgency Operamng Evqedence Goorftdo ATTN: Jies Mudcerhdde Vermont Yankee Nuclear Power Stton 4W0 Worcester Rd.

P.O. BDx 167 Framlnghb , MA 01702-69 Governor Hunt Road Vernon, VT 05354 Jonatmn . Block Esq.

Main Street

.. 04.G i lsbe;Es.q. u P..O. onV03 . *.,-.

Putney, VT "053460568..

Deputy Attorney Generd. "

33 Captol Street Concord, NI 03301-6937 Che, Safety Unit Offide of the Attorney General S One Ashburton Place, 19th Floor Boston, MA 02108" II Revision.2L Date 1/11/02 1-6

EXHIBIT EN-SAS-9 PAGE 7 OF 9 UNITHD STATES NUCLEAR'REGULATORY COMMISSION WAS5HONTON, D.C- 2OMS-~CO

",,AFETY EVAzJUArON BY THE OFFCE OF NU-lEAR REACTOR R-GU-IATON

.- rY -a uft.OL i flA ." ' .,L..r~...

ERMOQNT YANKEE NUCLEAR POWE -1TAT]ON

`1.0 JNIBQUQIQ0 By letter dated September 11, 2000, Vermoht Yankee Nuclear Power Corporation.(VYNPCI icensee) =Wnlted a request to amend., Title 10 of the "CodeofFedemr Regudafions (10 CPR)

Section 20:002 (former 10 CFR 20.302) appl:atlon, dated June 23,1A99, as supplemented on Jammy 4,2W000, that was approved by ft U.S. Nucear Pegl toty Cormission (t=R).

This amendment will allow the adcltlon of slghtly icontaiated soil resuftig from or-site conticlon-related acdvites, kwnludf but not Wrnted to, design change Impententation and land maintenance, to the W of already approved materials (I.e., sepi waste, coolig tower St and Solsand from roads and walkways) for on-eke disposal via land spreadIng on designated

'in 1,SM. pursuait to 10 CPR 20:802 Xcurreht 10 CFR 20.2002), the licensee recelved approval from the NRC to routi

• d-ixm of contaminated septic waste In designated on-sihe areas..In 1997. the NRC amended the approved on-site disposal application to also Include contaminated coodng tower dlt mateflaL In 2000, the NRC amended the approved on-site dsposal application to also Include a oneotme disposal of dqgWy contamdnated soil and air annual.

disposal of 28.3 cublc meters of aghy contamlnated b/sand mateiaL Inthis 10 CF 20.2002 amenchent application. the Icensee requested that slightly conamiunhutd "oi resultNg from on-sie consinicton-relaled edivItles be disposed of on-efte on an annual basis until the end of theplant'a operating licen In2013. The antgpated annual volume of soil generated by on-aite construction, as Identiid by the Noensee, combined wM..

the soWsand generated from the annual ,inter spreading of sand on roads end walkways at the plaifsite will not ewceed 2U cibo meters. .Tiltsvolume .lthesame volume that was 8approved Inthe January 4, 2000. request The Ilcelseepef.ned a comprehensive.  ;

radological evauatlon which lnuded the annual disposal of 28.3 aabt meters of soil and sot sand materials, and shows that these materials can be managed ont-te Inthe same mann as the septic waste and cooring tower slit (Le., land spreadg on designated flelds).

2.0 EL.ALiQI.

The licensee will dispose of the future son material using a land spread'qrg techrdque consistent with the current commitnents for oh-shte disposal of septic waste, cooling tower its and san/soil material previously approved by the NRC. The licensee w]l continue to use the 1-7

EXHIBIT EN-SA$-9 PAGE8OF9 dosirgtod and aWpoved areas of th* pPOpety which nde oppmnately 1.9 acres, vdfhc currently receive the septio waste, cooft towerslt and sollsand matera, and aPPrWdmay 1o acm whc have not been prevwo used for disposal. Doeternnadon ofe rath d.oica dose Urpact of the new matera haW been made W~sed on fte sam dose assessment models

• r .udle anid pfiffmay WsmtionsrnL Adf

• Idreft*--wosem# m v * ..

T e eh

,k-mew%

Infonnation will bepr,recorded: control aid ný .-ecordsofal."eo 7110.- -"-

1. The radion dide Ccnwtraton detected Inthe matetial (measured to radiallon levels con=stent with the licensee's radological enWlroM-ieftal moi.Atoflt pfrogram);

2. The total volume of material disposed 3.. The total rbdioactivity In the dposal operation as wat as the total rad W*aUvlly accmulated on each disposal plot at the Ime eqeaft 5f

4. The plot on which the material was appled; S. Dose lakda'ons o wdrnu afwwable accumlated ac"viydelern* nsrequred to demonstrate that the dobe cdft values knposed (Le., iposed by t*. ppipv 1o CFR 20.M applcation dated aume a, 1M99) on the land qpradng q*1on have not been exqeeded.

-e bouning dose'conditi-nsft on-efe disposals am WfooW=

"I. The anmual dose to the whole body or any organ of a hypothmecal maxbmally exposed lndMdual must be less than 1.0 mrem.

2. Annual doses to the whole body and any organ of an Inadvertent Intrudar from the probable pathways of exposure must be less than 6 mrero.

S. D4 e opration must be et one of the approFed on-awo lons.. a

4. Total annual combined volume of sot and soWsand materials must not exeed 28.3 dublo meters.

To u ý,tthe addotlon of n*w material contaiin low iels of.avVit. Wi., not ceed.

the bao ng dose'Oondiions, for efth new spreading opeatfon the Scnsee wil Wcatb an estimate of the total mdioactvity that kiduded all past dsposals 6f sept waste, coollng tower.

.1::'* sl~, and sogl/sand and soil mateda on the desgnated dispos Plots. This will be capared im the bounding dose condmton value or equtvent mdocvt value on a per are basis.

The lcensee assessed the dose from sofl and sollsand material that may be receied by the n a exposed kxii&l during the perdod of plant controtover the property, and to an Inadvertent intruder after plant access control ends using the same pahway modeldng, assumptions, and dose calculation methods that were previously approved by the NRC for the

• septic waste and cooling tower slt dsposal& The dose models awe based on the guidnce In NRC Regulatory Wde 1.109. Revision 1 (1977).

,.]."0 Revision_2..2.. Date 1/11/02 I

"EXHIBITEN-SAS-9 PAGE 9 OF 9 t- .:-3 The licensee's dose assessment Is as 1011bM

1. Total annual doses ta the whole body and ca organ of the hothetYcaPfy nadWM exposed w Individual were estimated to be 0.115 rrem and 040 mrem respectie.

.7bese values are sthenithe r annual dose condon value of 1.0 mrem for thet e. of r od L - .

2. Total annual doses to the whole body and citical orgm of an Inadvertent Intruder the probable Ipahways of exposure were estoated to be 0.757 mern and 1.17 from orero.

These values are less than the prescribed annual dose condition value of 5.0 rnrem for the time pexI* after actve ese conroL

3. The dob cakluaffoi6 are based on projecUng the rMamurn potineW Impact .ofal 0 &posals (vast and ttu) on the pproved d a s.te.

3.0 CPMSQL QI iiq The staff rinds the icensee's proposed to disose of the lowevel radioactve solt pursuant to 10 CFR matedra, 20.200., In the saine manners IocaSonand v4thM the botindng dose coflditikn as the mateials (Le., septlo waste, co tower dt end sogoand from roads and wallays) pmviost appr"ed by the NRC to be acceptable.

The lcensee has commntted to pomanenly Jncopoate *i modcation Into Caculation Manual. their Offste Dose.

PrncdPaContrbtor .A. Haye" Date: June 26, 2001 t

I IRevitiozi 2L Date 1/111/02 1Z-9

C-

~.

.I0 VERMONT YANKEE NUCLEAR POWER STATION SVE Associates SLUDGE & SILT DISPOSAL AREAS SCALE: 1"=500' SVE Associates

--- a yebmlt~m v FEBRUARY 13. 2003

EXHIBIT EN-SAS-11

-ttEntergy MEMORANDUM RN=RrGYANUC.LAR NORTHEAST VERMONT YANKEE POWER UPRATEPROJECT 02/13n2003 File No.: VY/PUP 03-13 To: kl FronLw George Thornas.

Subject. PowerUprate.Reliao'Asbestos Waste Gneration The following estimated quabtltles; of asbestos waste have been developed in support of the Vemaont Yankee Power Uprate Project 1 High Pressmr Feedwatci Heatlkeplicemict Projct Approximately 1250 square feet of asbestos from the beaten plus about the same amint from attached piptng for a total of 2500 square feet This will equate to a volume of about 520 cubic feet assuming the asbestos is 2-5 inches thickh Note: The exteior of the ecedwow Heates are covered with paInt that contains a high.

concentration of lead.. (Sag=ce: Jhn Calchera, December 16, 2002)

Main Generator Rewind Project Approximately 75 cubic feet of asbestos removed from the generator stator bars that will be replaced during the rewind. (Sorce: Billnwittmer-January 28, 2003) .

Therefore, it Is estimated that a quantity of approximately 600 cubic feet of asbestos will require disposal following completion of power nprate related pojcts.

cW Lynn DeWald Julie Hayward

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EXHIBIT EN-SAS-15 IrAGEIOF6 i "'.N Source WateriProtection Plan Vermont Yankee Nuclear Power Station

• 320 Governor Hunt Road Vernon Vermont Main Well System WSID #8332

.4X Vi..

Vermont Yankee Plant Water System, WSID #8332 Source Protection Area LEGEND

• ,*~ -* *tous WseSite

% 14 [=Source Proteeflon Areff 4 ~ /\.PowerLine Oi 400 0 400 800 Fe Elem. School

[1) 54295 9 ~~?A:'.~ -Vermont Water Supply DivIs 44,~I~ .. s.I 4 44W

.8t23/00 v~..4 Former Epsons Gulf Southwest Well 4s.ýiiNii J j; 1jutt Site #931485 ~Mad;l' k atS*t

.4~Vemn 1

Yanke 5. Nuclear8 *S: ~4 ~ 18151 llt18i11

EXHIBIT EN-SAS-15 i - PAGE 3 OF66 I,

• Source Water Protection Plan Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, Vermont COB Well System WSID #20559 It="

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Vermont Yankee COB Water System, WSID #20559 Source Protection Area

• \*A.....

LEGEND M 114r-* UST Site

• . -RCRA Facility

'

• Solid Waste Facility

i. Hazardous WasteSl

• Source suIb [= .Source Protection A

/.,- iC Power Line

- I. Source 001 sub ne1400 0 400 8OOF N *. .Vermont Water Supply.Mi rmer Epso ns G l-f Site #931' PawIrnth. i

• ItllS Iti S Li C,

'**'<* *Vermont Yankee Nuclear 1

• * .. **~.. IfI. .

EXHIBIT EN-SAS-15 PAGES OF 6 Source Water Protection Plan Vermont Yankee Nuclear Power Station 320 Governor. Hunt Road Vernon, Vermont NEOB Well System WSID #20778

Ilf NEOB - Vermont Yankee Water System, WSID #20738 Source Protection Area LEGEND X .1 *A UST Site i* RCRASolid Waste Facility Facility

. Hazardous Waste Site e Source 1  %, r -'-i Source Protection Area Ssub* 41.%;,r "!, ,+; /^,A/ Power Line 500 0 500 1000 Fe(

I 'Q ton ,/-* :4~I iem Blem. School .. Vermont Water Supply.Dv"lIo

• 1D2.425,5 t .I 8123100

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FUZ tv ITilII I. *. Cit 1 ))

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r1 Gulf .. ,.,,,. lI, tsItI.li$lilt. I Ipsons 15 L

• ~.! ~ Vemxont Yankee uclear 4f-~

Cell Sovi et IIt ItI

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• il $111t I I fill* I i.t, tot

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EXHIBIT EN-SAS-1 6 PAGE loF 9 SENT BY: 6 2 ; 2: IMI WILSON & WHIUTEM-4odwiu Procter LLP ;1 3/11 State of Vermont okIpMr4 d rah rd yaw&

4ENCY OF NATURAL RES~tWR DV~ 0* Fe Wetof 4ylrunewwaICpfl.

PU &W WA2T, mt YomvnWjo ThCOjdPfBJdwj~

MMW SMWXbE F&M U MU 103v q*)fshf Wak 1"o$vrom.4os (l

H0NU)M2414400 TOL1R VT(8"&D t 30004 FAC1 B(X*2f41-32Z4 Ma21,2002 PIubli Wiak Sysini permit 110 Opctat WATER STM D1T1CATON NUMDR. 420559 PM

?MrIW: " Thz. teB Nucar WATER SYSTEM: -iteyMucdear Vermoat Yanke, LLC - COB Systft TOWN4: VCno, Vermont RESPONSE1Lw PERSON: J baa Wliams AUDI)RB: PP.O. DUx 157 320 Goyero Humn Rnad Vernon, Vc.rmoni 0S3S4 L Aufthdty

=&cmd forth.am Bnt- V" n-

": L,- CID- W'tCrSystea The Dcp ,mo Ias d mlnod the *e o n ur w'll 0114 coa41u a public bel- b tVthe roulowiecondt.f ard ova 6ignal ctpublk ealtb Hskstcretbo apemn*i I herbyhmwd IL FMPkd and Cmdctioasw Thefim vUowinfindbV Wstablvish didt this system is incosnplamce scewdwwcwith 10 WSA, §1673(6, a8d wigl 001 vonsttule 2public bclth ha2zr wig, thestaddsi oruignicn public hcuk A&.

a.

Su aorvlowcil

.ify COQd ti61n/

A- MrPDdiugOOz: WbuunT 011 I . Padlify Use:i

2. C4 0&ton: 2 3 .Sour=

1)

4. Number ofCoMn tjon* J ROed Bed& Well - COD Wdl (001)

5. Pbp"u0ao SMVecd. It P4ý wC" - asuftý ýSPV4&-Usz

E)MBIT~rEN-SAS.16 PAGE 2OF 9 6 2 ;2:1"N WILSON &MUITE-'Gorndwit Procter UIP 4 4/11 yoiu" YN"s .c33 7 umpm8~)6.1

• vhf Crumbpta ftp2 * ~"+J a,

A. Ba t!!!!LMXZc __ _ __ _ _ _____ME___5!___MEME A. BcE41s _____________nsm D. SVOC OMNI___Ing sctlg0Z*.*

-a P. Nibrae 02i2J1.

0. -CymdC__ _ _ _ _ __ _ _ _ _

H. GWUDISW 0813P _ __ __ __ _

'I 3.. Source@ Protifcton Au.Tho ne wi-alba~

foot adius Vic Sourda Proftcotioibah wasb*JttW 6q 12/31ADI Wj!ddltiona

-3 4.~4.rgitM11a ho~ pr7huW Ctczfldoa n Wot SyWmUai lsk dttiw--a Clas2.walw bcmMt hazard or adgnftan publ;hclth fE&.*

Ml GaidCond~tlaima

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• ~ 4 ~ i ., ~ v 'g.,.

EXHIBIT EN-SAS-16 PAGE3OF9 j SENT BY: 6 2 ; 2:1EK ; WILSON & HITE-.Gtodwis Procter LIP ;a a/11 Vrmms Ta--Sit--oOUS5)

• ur~m.Oam

1. This pcmit sUll become efftfive on the date of Wae offthe fitlity titan Vcn.:

Yanke Powe Corpor to E *,Nue erVeinaantYsnkee, L*L 0mnd th gqprced* Permit No. NS754)006, signd 3anumiy7, 2002 **7U pemitka thall mbmkit to the Depaun uitten notification ofthe sale within 24 hforn of ft closIng damt

• .2. ThIs permit Is valid for Six (6) yem fitn fte date oflhIs twin orrmewal j.Zcaj~plicatlo= The penJtWe siall submit a cdrnpkt applicallmorIbrlpan or 613s petmit, 90 days Weore this permt cxphrc The rcpliesti de cinesMmvh 21, 2009.

4. Sou Protioni PfmAupdaes am reqlredoewe evey tee ye=a fim the daft the ph: isapproved.

5 The peniltee shall comply with all ofth Drinking Water Qaality Moatodn&

" Rufrc* j*zsuato M V iont Wat Splyu C p21,-

21-6 &1am. To Goe extent that sch rquilremwts are not set forth Inthe af-oread Rule oc Corresponding faderal gdlations, lbo Water Supply Divisoa ofthe Vernont A4;cny of atmul Rewtuzee shall aotiy tho permnttee by mail of such reaqulmn Falidr to monitor In ascordance with dhe aforesid =qlcmets shal oonstitfte a vi~otalon oftIhk p=&lt The Stat ofVocmxmz AVmyofNatwuRcwum=

fleParbet OEvienet al ~nCDmtloz~

• atCb#crRoohd Cwinsmmioner Water SutyDivision As of thks 21' dxy of May, 2002 In Waftedmz Vcimoat.

cWSID 20559' Tim 1ta~inpn WSMS Rcnonal Mqnage Jean lcolbi, Complin-ce and C4rdfaton Chlef

.Dan Wilox, Regional Engineer, Wastate Managment Division I

EXHIBIT EN-SAS-16 PAGE4OF9 6 2 ; 2:16M ; WI LSON & HITE-4*oedwin Precier LIP ;I 8t'1t State of Vermont AGOCY OF MUA2RAL RESOURM~

DWWuyd d FMiafd vm bwldaft rae.,1rPs.md & WATER Mu*YDIV'ISON oSwuU9wo 01 g1mkwmCIl dlimf lueOld pUU7Dyldf

$we~b~ 103 SOU&hI.Mah Skct

• WatzbayVT 056714403 Ws 3~" F io EAU TBLVOOIB (82)241-3400

-dMFREE)VT(0U23-6 FACSDO1LE(802241-328 May21, 2002 Public WSW Sysum Pnat to Op*ee WATIE. SYSTEM IDENWICATION NUNER 8332 PIN N:NS7S.0O0 PERIANlTEE: 13utcwwyud=a WATERSYSTEM: te~Nuclear Vcmon1 Yanee 2.0.- Mainalant TOWNl: V.ernon RESPONSEBDL PERSON: BzrbznaVWillhms ADDRES.: 320 Govanor H~t Rd PO B= 157 Vcmon VT 05354 L Auowity In acconhc with 10 VSA §1671 stm. the following findiW Ad eopdjoi have b=en made for the E Nuclea m t yankhee UIC Main Plant Water Syste.

wVm iUh" Peqxmtent has detamrnnod tha fth cpcrtou o frib publ~e water qdweoi subjec4 to fthfolloing oooditiOm, wil not constute a publ*f hualthud era signpfcat publki heal dsk &acoM ae innhi Is he y sand.

IL Fihigs and Conclsons The Wblvo*g izdn* csabll that Uis stdRm is in CVuwe with the stidsds in a kc with 10 'VS& 1675(b). mdnwiwl noet enitut a pubik bu" h=iard or a 4df t A. Damaty ofrphy cl uio1ditions:

A. Dateof ~mos reen sanitarysorvcy: 1O/31MI

1. Facility Use: ndustW

2. Cls ton: 2 I. ,ou  :* * (2) odrock Wcl- WedWdll (001 )Southwest Wc (002)

4. Number of Connections: 1 S.Populstoc Served: 200

.PogiWW. ON-" - OLr6oIsWs JcszI~d nStgkl1 Johmcbwy

EXIBITr EN-SAS-16 PAGE 5 OF 9 IILSMN & WHITE-40odwit Procttr ULP :; 7Wit SEN*T BY: 6 2 ; 2:17P ;

aM~aW1WuuS VwVmbm .lda3aSyaku (SW)

Papi qlt;2002

2. Sn=mxayofmodt*r=.v,.u _Wanive rev D

• A.* Bactc&iooga p*as twdnv mooth, 014 tadaz 3ý CyaldQ 09124MS m d .

a 10C 09009S mut gtat ds D. SO Oi zne.. ,.f , .d A. SOC 02=22/01 met ix

a. VOC V0222101 met standards-0.NQae . . 02(01 . met stzndud

i. GWUDISW 0&31i ptby .....

I3 Sowto PsOtection Art= The 6o0= ptOo~tefon arca* for the West aid South West S Well are 500 footradl A source protection pla was'sutb*ttcd on 12/31/01 and a~donl Wmfo has been requecstedpiior to approval.

t .

4. pc~or Mintats lanT~Wai~yt~mIs 1~sfi~ as~ Cm 2water aystm. The pelnlhy Clas 2 cettified Operator; =rRkchad Gmius and Barb=r WilliMs The opvWeuos catificstlets awe vald unti 0630104.

S. The Dertmwt concnda t&g ahs waft eskm Is opxrated in compliance with h e sivmods adopWd uder 10 VSA, 91671 *. and does not constdit apublic heafltb= o a sloulluant pablio hemth rhk 11L o o it . .. "

1. The pemu f Yeao= ohs p= us wmug ed w ly In W with aU applcable provlsims of 10 VSA, §1671 it &., the les adopted thred and the FcdCra SaoDrhinkng WaterAct and utbsqucnt renglyldo

2. This permit maybe aspeaded or moled In csordance with 10 VSA. 41675.

3. This permit hiot trarsferable or asfstable and sal a omatcally become bralid upon a c*age otownershp ofthe water .sysem"

EXHIBIT EN-SAS-16

. PAGE6OF9 W BY: 0 2 ; 2:17PU WILSON VHITE-Gochwts Procter i p# 8/11 Vwmoat Y4&a..MaSh4YpSa *w03 May2I, 2002

1. This pemit shall become effective on the date ofsale ofthe filityftmn Vcemont" Ymnkee Powc Copoantlon to EntcrgyNuclear Vmnodt Yanicc, LLC " atd lbn

,hall eupt,0c Veacnt Yndk - Wn vtemPait W NS7.*-006. "

JAnuay 7,2002 ** 1U petu*ee All. umit to ihe D" *etwri tta notfication of It sale wiVhi 24 owts of the clozing date.

2. This permlt is valid for Six (6) yars from the date of this Isumm or rew&.

3.. Reapplicaflon Thp peamitee shall submit a complete application Mssumce of r.

fthipcrntt 90 dais before this pemit expA=s 7hm resp~zllcation deadline Is Umuzh 21,2oo8.

4. Source Protoction Plan updates arc rcqurd owce vtythe y= frm ft date the plan is approved.

V S. The p.rmittco bahLll coply with all oflhe Dnldn Water QuityMoAtosing R. w itspuvaut to d, Vewnumt Wster SuppMly Rhc apter2 2 1, Suleapt 2I-6 It q. To the eent that s .ch roquirwneuts am not sd lba in the afoead Rule or correspmdin fedcral gzp ons, the Watr SupplyDivision of tho Vermont Agency of Naturul Resoue sball not The pcmftc. by nail of ash requirennts. Failure to mooaito in accordance with the a d equir=nts sball-consfitut a violation of this perIt.

The State of Vaemot A~iw~y ofNatural Resourme flpsiment of Enyho, I Conservation Chazrspber~eccz!; tC4xnnissioer Water Sup:ly Division As or this 21't day of May, 2002 in Waterbwy, Vcmont.

JR:WP=mb e: WSID 8332 Tim RayWioxA, WSM, Re , Wal Mineagr Jean Nwicoal, Complis"c and Certificaton Chief

( D~~Ian wilcox, Regional Ehnbeer, Wastewater Management Divison

EXmlB1TrEN-SAs-16 PAGE 7 OF 9 Wff BY: 6 2 ; 2:16M  ; WILSON & IMTlE-Ooodwtlu 'rocter LIP ;# 9411 It &I State of Vermont AOENCY OW NATURAL RBSOUR(jS Np~rw4 r wmmebw azwmmtom O m WPa9*.li V& d d WAR SUPPLY DV;ION b*~ofd E~m. awmu irvon 7be01d?&tfyDIft 102 Soa& mahs tm 1EW UNMc FS E R HO3JE5o

• .Watczyw)VTOS~l-O C.

M . TfiONBg(022414400

.. OLYIER i- V" 10) 5234500" FACtb1(82)241.3MU4 May2l2002 Publi WaW Systa-

• enalt to Opcri WATBR SYSTEMr IDENTUJCATN NU)MEar 2073 PIN #- NS7S-OO0606 PRIUMITrEE EaitergwwucICa.

WATER SYSTEMZ Sy uclcai V~mnoot Yankee, LLC -NEOB RESPONSIBLE PERSON: Bclma* Williams ADDR1iSS 320 Govcmw Hunt Rd POBox157 VcmoYVT 05354

1. Autotity In mcmdanm with 10 VSA. 11671 S IM,, IOWMowing fin& and co uson bave b= ma& for the En yNclar Vemont YmtkmLLC--NBO Wter Syst* The Dpasmenzha dd mined "thatVe qmarulon oftt publovatcwsylci, subjcctto fthfoowin cmondtn, wil rot 0 ntift a public health hazard or a ublle thro, tisk sinificant aL FmdiNp0 and Conclusions Thefollowfng fizziu egstbliab thatth~ ~ mis in ccopUancw~ iestandardsin 1XXX mcwkdh 10 VSA, f 1675(b). mandilt m~t contiut a pu~blic heflt hazr or asignficant public ealth r I. Summay'ofPbyA codat=:

A 1)awo mormat woodmit-y muzv. 10/31/01 B. MaJor~indinmo

3. FatilityUw. omaukunldhg

2. Classficatlorn 2 3.Sou=c * (I)8cdrod*,Wof(0OI)

4. Numbcr of Ckmnection.s: I

5. Populaon Se &ed 160 Flep. Oc4.BwviuuS6JWieb~

EXHrLRFEN-SAS-16 PAGESOY 9 SWBY 6-13-2.9 ; 2.:ItN ; WILSON & JHITE-,GeofwI Procter UP  ;*ot1i1 sarusfe VIUAaa ,

• 1W 57

?wevudYkub" 2- Smmai'o w*rcf r quaity sav2 euls A. .*.tedoinical pao wlveMora ma itandards

.. .. uuC . _yu _-__-_

snmurds 10.________061_/99mViet C 10C 0412A9 metstandsds D. 60C ,,etu S/= tUdrds R 2tZMUM met tandar-F. 12/18/01 mt Vtandsrdr

a. HMwee met ddards ILi .IW .O,."* .by"a flon

3. Sour Protection Arm- The sce. prowtion areis for d*e Wcet and Seth West Well-afe S0$,ot 99dLu A saitsro6~tcct10nW VUnsAbIlitCeOn lMf3Wl and ad~faba~~eeiequst Prim to approvsl.

4. Operato Staub 7be NWOB Wite; Syste Iscbasifie as a Chas 2 watertsysteni TMe pdmroy Ck=s 2 ccr1ifipd qpczlor ame Rihard Gerdus end Barbara WiiM~s.

The .operon'certMfeWopsx nRad a utM o000M04.

DePftft~n= coacudla that fthi water syitM Isoperate in conip~wi~c with U6Th the vUndw& &dpted unde110 VSA, 116731e r. and does hot consftft apublio health bamzd or a algflcant public health risk

m. Gmeneconatow

• 7wI.person to vwhom is pc t bs issued must complyin ft ltapOicable

. provsrions of 10.VSA§1671 St &M., te reles adopted thereun*dr and tha Fedeal Sate Drinking Watcr Act and =Uepera rVadtfio

2. This pcmut may be xapclvd or rtveled in orance with 10 VSA, ft675.

"3. This pcmit is not ftsfbleaor sg aluta e and udlcly become invalid "

Upon a ch FoooWneriirP oflbo,*=r systm.

IV. -Special Conditons

EXHIBIT EN-SAS-16 PAGE9OF9 WILSONI A WHIIE-5sodwis *rocier LL 41l/11 SENt BY: 6 2 ; 2:20iM ;

• Yar~( Va~i.. ;1010311 I- ThWA penit awl bew==offective on tho date of sale oftoyrom V=ro Yankee Power Corpomlon to Eutcrg Nucicir Vemont Ysukee, LLC* and then shafl uria oded Vermont Yank=e- NEOB Peimit No. N875-006.6 4pgnd April 26- 1999 ** Ile P=f g)Ml wiboitto the Deparbtot wzrittm nofieaflonj of the =ale withn 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. of the closing date.

• ~2- ThWS PcnIt Is valid for Six (6) ymas frw the date of Ilis Issuance or renwawL.

3. Ieqpplictoa: 11w penimluc OWal subnint a Complete Ucalics& for rdsszanc of t0& paMit 90 dqi~bolore tids permit epirea. The reapplication deadline is MashI 214~

.. Source Protection Plan updafcs arc required once cyery fthr year from thes dafte the pl~a hs app~roved.

5. Tile pMniftte dal)comply with all offtheDrinkg Water Quaiiy Monftoniri RcquremnPts PorU1nt to Gbe V=sIftt Water Supply PAAe, Chatet 21, SubchapWe 2 t-6Ig l To the efte dnt shtuchrequlremcts ro nOt set forth inthea&fbrv=M Rule or corsodii federsi regulations, fthWater Suply Division ofdio Vermont A*=ziY OfNatun Rmsurce shall notl(Y dho pcrmitlee by nawl of audi requirementa Fallvro to monitor inacconlrtanc with the aforesaid tequfirer=nls; shalt'onstjtutoaviolatlonofIbs permit.

The StatcooVrMont Agency of Xxtura Rerources avistoperk1cdda. Couimislve Jay Rathcrfor, Director Watcr SUpyDIVIY Sion As ortlds 21'day ofMay. 2002 111 Wuatcrbury. Vermnt.

c:WSII) 20738 Timi IRaYxoi4d WSMS Regional Manger lean NicoI Compliance and Ccdtfication Chief Dan WilcX, Rt wial Eugiecr, WastewaterMmoagemem Division

reo u u U*:z6a CII/SVE (802) 257-0721 p.2

.XMB1T FýN-SASI17 PAGE 1 OF 3 4State of Vermont WATER SUPPLYfIWASTE WATER DISPOSAL PERMIT WW-2-1035-1 (PmN#S95-O0o6.06)

LAWS/REGULATION INVOLVED:

Environmental Protection Rules Chapter I and Chapter 21, Appendix A, Part 11 LANDOWNER: BNTERGY NUCLEAR VERMONT YANKEE, LLC.

ADDRESS: 185 OLD FERRY ROAD BRATL ORO, VT 05301-0500 This project, consisting ofthe construction ofa temporary office building t6 be connected to the existing water and wastewater systems savingtheplant support building, no increase in design flow, located at the Entergy Nuclear Vermont Yankee Power Plant on Governor Hunt Road in Vernon, Vermont is hereby approved under the requirements ofthe regulationsnamed above subject to the following conditions:

1. The project shall be completed as shown on a plan prepared by John Goodell, PE., titled:

"Tempori-y Building (sheet I of 1), dat6d January 22,2003, latest revision dated Yanuary 31, 2003 which has been stamped APPROVED by the Wastewater Management Division.

No changes s"all be made to the approved plan without prior written approval flom the Wastewater Management Division.

2. This project is approved for the following uses and maximum design wastewater flows. No changes to these uses and design sewage flows are allowed without prior written approval from the Division ofWastewater Management.

Ms fl9ow (E1 L

Temporary Office Building and existing Public Support Building (PSB) with both buildings having a combined m um of 160 employees @13.5 gpd/MWployee 2,160 GPD

3. This permit shall not be valid for the completed wastewater and water systems until the Secretary receives a signed and dated certifitation from a Vermont registered professional engineer or the installer that states: "I hereby certify that the installation-related information submitted is true and correct and that In the exercise of my reasonable professional judgment, the wastewater and water systems have been Installed in accordance with the permitted design and all permit conditions, were Inspected, were properly tested, and have successfully met those performance tests."

The wastewater and water systems Inspection certification(s) shall be completed prior to occupancy of the project and the Inspection certification statement(s) shall be submitted to the Springfieldd Regional Office and submitted to the municipality for filing w*thin 30 days of the final inspection.

I

rca uo ud UU:Z6a CII/SVE (802) 257-0721 p.3 EXHIBIT EN-SAS-17 PAGE 2 0F3 WATER SUPPLY/WASTEWATER DISPOSAL PERMIT #WW-2-1035-1 ENTRRGY NUCLEAR VERMONT YANKEE, LLC.

PAGB TWO

4. The water system shall be operated at all times in a manner that keeps the water supply free from contamination. Prior to the use *ofthe water system serving the temporary office buildin& the water shall be sampled and tested bya certified laboratoryforbiological content and shall be found to meet state drinking water standards. Results of the water test shall be submitted to the Division of Wastewater Management for review and approval prior to use of the temporary office building water system.

5. A copy of the approved plans and this permit shall remain on the project during all phases of construction and, upon request, shall be made available for inspection by State or local personnel.

6. All previous permits and Certifications of Compliance issued by Division of Wastewater Management fbr this project shall remain in full effect except where specifically modified or amended herein.

7. ApproVal of the wastewater treatment and disposal system to serve this project is given in Indirect Discharge Permit #ID-9-0036-2 signedby Marilyn Davis and dated April 22,1998.

All terms and conditions of that permit shall be complied with.

8. This project has been granted a 100%reduction in design wastewater flow, based on the proposed installation of water saving plumbing fixtures. Accordingly, the plumbing fixturts utilized throughout the project shall comply with the following performance specifications:

water closets - 3.5 gallons/flus, maximum; showerheads - 2.0 gpm, maximum; and lavatory/sink faucets (aerators or flow regulators) - 2.0 gpm, maximum. Fixtures complying with such performance standards shall be permanently maintained throughout the project.

9. The Division!s issuance of this Permit relies upon the data, designs, judgment and other

.information supplied by the applicant, his or her prof'esional consultants and other experts who have participated in prepaation of the application. The Division makes no assurance that the approved systmnz(s) will meot performance objectives of the applicant and no warranties or guarantees are given or implied.

10. This permit does not relieve you, as applicant, from obtaining all applicable approvals that may be required from the Public Service Board, Indirect Discharge Program, Water Supply Division, Departnient of Labor and Industry, Department ofHealth, other State Agencies or the Town prior to construction.

11. This permit shall inno way relieve you of the obligations o.fTitle 10 Chapter 48, Subchapter 4, for the protection of groundwater.

J.1f

p. 4.

,,, ,, u.J uU::ea CII/SVE (802) 257-0721 EXIuBrr EN-SAS-17

]PAGE 3 OF 3 I

WATER SUPPLY/WASTEWATER DISPOSAL PERMIT #WW-2-1035-ENTERGY NUCLEAR VERMONT YANKEE, LLC.

PAGE THREE

[2. In the event of a tranfer of ownership (partial or whole) ofthis project, the transferee shall become permittee and subject to compliance with the terms and conditions of this permit.

13. By acceptance of this permit tho permittee agrees to all9w representatives of the State of Vermont access to the property covered by the permit, at reasonable times, for the purpose ofascertaining compliance with Vermont environmental and health statutes and regulations and with the permit.

14. The conditions of this permit shall ron with the land and will be binding upon and enfo1cable against the permittee and all assigns and successom in interest The permitteo shall be responsible for recording this permit and theaNOTICE OF PERMIT :RECORDING in the Vernon Land Records within thirty (30) days of receipt ofthis permit and prior to the conveyance of any lot subject to thejursdiction of this permit.

CHRISTOPHER RBCCHL4, COMMISSIONER DEPARTMENT OF ENVIRONMENTAL CONSERVATION DATE: February 3, 2003 BY2)~s-' &-4 DANIIGL WILCOX REGIONA, ENGINEER Copies: Vernon TownPlanning & Board of Selectmen John Goodell, Pa.

Susan Hudson, Public Srvice Board Department of Labor & Industry Roger Thompson, Jr., Engineering Manager Yohn Akielaszk, Indirect Discharge Program Water Supply Division

• 1

t . .. * .

• o EXHiBIT EN-SAS-18 PAGE 1 OF 27 I

A STU.DY OF TRAJ3FIC FOR VERMONT YANKEE NUCLEAR POWER STATION VERNON, VERMONT JANUARY 2003

'OF~

S. PREPARED 1Y SVE ASSOCATES "RORO,1818 M BRATTLEBORO, VT 05302-1818

EXHIBIT EN-SAS-18 PAGE 2 OF 27 A STUDY OF TRAFFIC For VERMONT YANKEE NUCLEAR POWER STATION VERNON, VT INTRODUCTION The purpose of this study is to evaluate the impact to traffic of the proposed modification ofgeneration facilities at the existing site on Governor Hunt Road in Vernon, Vermont. The proposed modifications will increase generating capacity approximately 20% and will not require any.changes to the exterior of the plant nor to the general physical layout. No additional permanent employees will be required. Most construction work for this project will take place during a planned refueling outage in the spring of 2004.

The existing access to the Vermont Yankee (VY) facility is through the so-called Gate No. 1 located on Governor Hunt Road. This access is about 0.6 miles south of the north intersection of Governor Hunt Road with Vermont Route No. 142.

METHODOLOGY Traffic volumes for this study along existing roadways were based upon Vermont Agency of Tronsportation (VAOT) Automatic Traffic Recorder Station History 1975-2001 and 2000 VAOT (Route Log) annual average daily traffic (AADT). Counts of vehicles at Gate No. f in December 2002 and an employee and vehicles count during the last refueling outage were provided. Turning counts conducted at Gate I on December 22, 1997 were also utilized.

The project was evaluated for its impact during the refueling outage planned for the spring of 2004. Calculations were based upon "Regression Analysis for Traffic Projection" prepared by VAOT.

Projected traffic generation was based upon the existing counts at VY for an estimated 1700 employees during the next outage. The "Highway Capacity Manual" by Transportation Research Board was used to determine the level of service and capacity.

TRAFFIC VOLUMES Existing traffic volumes at VY were based upon vehicle counts at Gate No.l in December 2002 and were found to average 873 average vehicles per day (vpd) Monday through Thursday.

Based upon 2002 VAOT data, traffic volumes along VT Route No. 142 are 5,300 vpd north of the facility, and 2600 vpd south of the facility. This includes the current (normal, non-outage) trips to the VY facility.

EX Brr EN-SAS-la PAGE 3 OF 27 TRAFFIC VOLUMES (cont.)

The number of employees at the plant is not expected to change as a result of the increased power output. Consequently, traffic to the plant during normal operations (non-outage conditions) is not expected to change significantly. The only expected change in truck traffic will be one additional fuel shipment per 18 months and three additional low-level radioactive waste shipments per year. The outage scheduled for April 2004 will have additional traffic associated with it and therefore an analysis of its impact is conducted.

During the spring 2004 outage at VY there are expected to be 1,500 employees at the site, however for analysis of impacts to local roads during the outage, an estimate of 1,700 employees was used (1500 + 200 contingency). From vehicle and employee counts during the last outage at VY, the trips per day per employee is known and therefore with 1,700 employees, it is calculated that 3,689 vpd will be generated at VY during the next outage. Based on existing counts, this means a total of 2,816 vpd additional over normal operations. Sixty percent of the employees would work a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift-starting between 5:30 am and 7:30 am and the remaining 40% working a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift starting between 5:00 pm and 7:00 pm. During the periods where the two shifts overlap (5:30 am-7:00 am, 5:30 pm-7:00 pm), the peak hourly flow for the additional' outage traffic will be 704 vph (vehicles per hour). Based on a turning count conducted Doc 22, 1997 and the morning peak hourly flow (5:30 am-7:00 am), it is expected the additional outage traffic will be distributed as follows: 211 vph leaving VY heading

• / north, 70 vph leaving VY heading south, 317 vph entering VY from the north, and 106 vph entering VY from the south. Similarly, for the evening peak hourly flow (5:30 pm-7:00 pm) it is expected the additional outage traffic will result in 317 vph leaving VY heading north, 106 vph leaving VY heading south, 211 vph entering VY from the north, and 70 vph entering VY from the south.

TRAFFIC PERFORMANCE Traffic performance, in general, is defined by a qualitative descriptor as level of service (LoS). The level of service describes operational conditions within a traffic stream and their perception by motorists and generally describes these conditions in terms of such factors as speed and travel time, freedom to maneuver, traffic interruptions, comfort and convenience, and safety. Levels of service range from "A", representing little or no delay, to "F", representing forced or breakdown condition, extreme delay.

The American Association of State Highway and Transportation Officials (AASHTO) states that "collector streets should generally be designed for level-of-service "C" to "D". This is the design standard for VAOT except for urban areas where lower standards may be acceptable in certain cases.

EXHImIT N-SAS-ls PAGE 4 OF 27 TRAFFIC PERFORMANCE (cont.)

Analysis of Vermont Route No. 142 based upon "Highway Capacity Manual" indicates. that the level of service at peak hours during normal condition is at level of service "C". During the outage at peak hour of employee entrance and exit, the traffic south of the facility will be at a "C" LoS. North of the facility LoS would be "D".

SUMMARY

1.'- The traffic volumes and level of service of the facility during normal operations (non-outage) will not change with the generating capacity upgrade.

2. The level of service would be the same south of VY during the spring 2004 outage. North of VY, at the peak hour of entrance and exit of employees, the level of service would change from "C" to "D"..

3. The levels of service are acceptable on Route No. 142 during the outage as well as during nonnal operations.

F-XHrirr EN-SAS-ig

.PAGE5 OF 27 APPENDIX r BACKGROUND DATA I

Page I of I EXHIBIT EN-SAS-18 PAGE 6 OF 27 Peter Boemig From: Thomas, George igthomas@entergy.comn Sent: Friday, December 20, 2002 1:14 PM To: jgoodel@sveassoc.com Cc: Nichols, Craig; pboemig@sveassoc.com

Subject:

VY RFO Traffic Study Attached Is the data for automobiles thru Vermont Yankee Gate #1 and people thru Gate #2 during refueling outage RF023. Each worker passing through Gate #2 was only counted once during a day. Based upon my analysis, I feel the following parameters are appropriate for the traffic study for RF024.

Automobiles- 1500 per day (includes 300 additional cars for HP Turbine, Generator Rewind and Feedwater Heater Replacement).-

Distribution - 60% days; 40% rights Time of arrival - 5:30-7:30 am and 5:00-7:00 pm RFO 24 schedule -April 1-28, 2004 Please review the data; ifyou agree with the above parameters, authorization is granted to perform the study.

This email andany attachmentsthereto are intendedonlyfor the use by the addressee(s) named herein and containproprietaryandconfidentialinformationr If you are not the intendedrecipientof this email,you are hereby notifiedthat any dissemination,distributionr or copying ofthis email and any attachments thereto is strictlyprohibited Ifyou have receivedthis email in error,please notify me andpermanently delete the originalandany copy ofany email andany printoutthereof III n, -1. 1-P~tVUUV) -1.1-

EXHBIT EN-SAS-19 PAGE 7 OF 27 Date Days Nights DAYS NIGHTS TOTAL 10-06 442 296 442 296 738 10-07 627 378 627 378 1005 10-08 639 426 639 426 1065 644 443 644. 443 1087.

10-10 643 440 643 440 1083 10-11 605 438 605 438 1043 10-12. 512 381 512 381 893 10-13 486 411 486 411 897 10-14 594 414 594 414 1008 10-15 559 417 559 :417. 976.-"

10-16 597 425 597 425 1022 10-17 553 401 553 401 954 10-18 .550 398 550 398 948, 10-19 487 350 487 350 837 10-20 412 356 412 356 768 10-21 514 357 514 . 357 871 10-22 486 361 486 361 847 10-23 448 337 448 337 785 10-24 413 304 413 304 717 10-25 365 238 365 238 603 10-26 176 195 176 195 371

-1.2-

Page l-ot I EXHIBIT EN-SAS-18 PAGE 8 OF 27 Peter Boemig From: Patrick, John [JPATR90@prod.entergy.com]

Sent: Wednesday, December 18, 2002 4:59 AM To:' Thomas, George

Subject:

Vehicles on-site during RFO #23 George Here is the lst of all vehicles that entered Gate # I during RFO #23. Let me know ifthis Is what you needed.

Date Number 10-05 800 10-06 780 10-07 1100 10408 1100 10-09 800 10-10 1200.

10-11. 1020 10-12 900 10-13 880 10-14 1080 10-15 1040 10-16 1060 10-17 980 10-18 880 10-19 "840 10-20 840 10-21 1000 10-22 1040 10-23 880 10-24 780 10-25 680 10-26 340 Total number for the outage was 20,020 Average number per day was 910

Page 1 of I EXMBIT EN-SAS-18 PAGE 9 OF 27 Peter Boemig From: Paric&,.Johh [JPATR90@prod.entergy.com]

Sent: Monday, December 16, 2002 7:09 AM.

To: Thomas, George

Subject:

Personnel on site for RFO #23 George I was able to find the break down between days and nights of people on site during the Outage. Ifyou have any questions please give me a call.

Date Days Nights 10-06 442 296 10-07 627 378 10-08 639 426 10-09 644 443 10-10 643 440 10-11 605 438 10-12 512 -381 10-13 486 411 10-14 594 " 414 10-15 559 417 10-16 597 425 10-17 553 401 10-18 550 398 10-19 487 350 10-20 412 356 10-21 514 357 10-22 486 361 10-23 448 337 10-24 413 304 10-25 365 238 10-26 176 195

-1 d-

Page 1 of 1 EXHIBIT EN-SAS-18 PAGE 10 OF 27 Peter Boemig From: Thomas, George [gthxms@entergy.com]

Sent:. Tuesday, January 14,2003 12:23 PM To: John Goodell Cc: pboemig@sveassoc.com Subject- VY Truck Traffic In response to your request on truck traffic the following is provided:

As a result of Power Uprate, there wvll be one (1) additional fuel truck shipment per 18 month operating cycle and three additional low level radioactive waste shipments per year. The number of truck deliveries per day during the April 2004 refuelrig outage (RFO 24) is estimated at fifteen (15).

This email and any attachmentsthereto are intended onlyfor the use by the addressee(s)named herein andcontainproprietaryandconfidentialInformation. If you are not the intendedrecipientof this email,you are hereby notified that any dissemination,distribuiiotz or copying of this email and any attachmentsthereto is strictlyprohibited If you have receivedthis email in error,please notify me andpermanently delete the originaland any copy ofany imail and anyprintoutthereof

-l It AD0lA1

-1 9;-

PAM (21) e'<(O)Pge1o1 C Page I of I Ivet1 -* Ot~rA6.r 0 )

0 John Goodell EXHfIBIT EN-SAS-18 PAGE 11 OF 27 From: Thomas, George [gthomas@entergy.com]

Sent- Friday, January 03. 2003 11:37 AM To: jgoodell@sveassoccom

Subject:

FW. vehicles at gate #1 This Is In response to your request for vehicles and people.

--- Original Message-From: Patrckc, John Sent: Friday, January 03, 2003 10:08 AM

• To: Thomas, Gporge Subjec: vehkdes at gatd #1 George Total number of ID badges at Gate #2 Is 849 as of this date.

See attached for dec 02.

d:

• 7-

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EXHIBIT EN-SAS-18 PAGE 12 OF 27 400 420 -,;

4001 500' 320 80 80 4405" 420 &

440-,

4209 160 s0 80 460f 480P 4201/

44012 200 80 60 360 120 40 160 160 8O 60 400 31-Dec 320 total 82403 -

-1.7-

6 f ec Run Date: 2003101109 Vermont Agency of TranspotaUtion Technical Services Dlvision Traffic Research Unit Specilt Count -Volume 2000 Sts ID: s6axiT Town: BOrtaboO. Final AADT: 3400 functionul C*s* URA&.MNIOARTERIAL Count yw: VOLUJME Route No: VT142 Location: Bra1ebo10VT142VenmaSI Ctunterryp.: Tube Aal.

,af Date 0 2 3 4 5 6 7 9 .l0t'11 12 13 14 issts_ t is T__2a21 22 23TotalrFactor AoTACF Y6.

2=bsd242? "S IMi US~ fl 83 se Of 113$O tW IAI 0.96 IM

2MWI6Su 1? 19 it it II 17 v 62 1 02 124 1 t.1 SO110 1t4 120 .127104 112 M S 60 s ft 3 s 0 1IN$ 1"* 1.01 .M2M 2C00178un 20 7 7 5 ?721 U 3 74 4 126 t0 122 102 1152t 14* 123 120*6 9O 32r 30 21 1M 1.3 t.01,096 2w?

MODWI1MA 6 4 0 14 21 1M 242 2M0 31 M5 21? 212 '3U 300 S14 404 A27 2W1 142 101 75 . 63 ft f 4M5 0." IM .Y*0 400 20MMtTu. 13 7 ,t 17 ?132 26 373 32?2 24n 2" 0 262 Sit17 4 21121' s2M 13s 12* 74 67 -34

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EXMIBFITEN-SAS-18 FAGE 14 OF27 2000 (ROUTE LOG) AADT VAOT ROUTE 142 LOCATION LOCATION COUNTER AADT 0.00 Mass. State Une 0.80 Lily Pond Road x 147 1,200 A 0.80 "Lby Pond Road 3.92 Lily Pond Road x 376 .1,500 E 3.92 Lily Pond Road 4.27 Gov. Hunt Road 2,500 E 4.27 Gov. Hunt Road 5.40 Gov. Hunt Road x 374 .3,200A 5.40 Gov. Hunt Road 5.67 Tyler Hill Road 5,300 E 5.67 Tyler Hill Road 8.34 Broad Brook Road X372 4,500 E 8.34 Broad Brook Road 8.70 Brattleboro Town line x077 .4,500 E 0.00 Vernon Town Une 0.69 Cotton M31 Hill 4,500 E 0.69 Cotton Mill Hill 1.78 Mornlngside Road -X168 2,200A" 1.78 Mornlngskde Road 2.16 Bridge Street x167 3,400A 2.16 Bridge Street 2.17 VT 119 (US 5) 13,600 E AADT - Average Annual Daily Traffic VAOT - Vermont Agency of Tiansportation Counter - Automatic Traffic Recorder Station Location- Intersecting roadway, reference point and mile marker A - Actual tube count conducted E - Estimated based on traffic data in adjacent traffic sections

-1 ^

EXHIBIT EN-SAS-18 PAGE 15 OF 27 APPENDIX II-ANALYSIS

EXIBIT EN-SAS-18 EXISTING TRAFFIC AT.VY PAGE 16 OF 27 Dec 2002 Weekday Average (Mon - Thurs) 5240 Vehicles /12 Days = 437 Vehicles x 2 trips (entrance + exit) = 873 vpd Peak Hour of Adjacent Street from ITE (110) General Light Industrial (ITE - Institute of Transportation Engineers "Trip Generation" 61 Edn)

AM=..44 Peak HourAdi Street A.M. = .146= 127 vph (83% enter = 105 vph) 3.02 Average Vehicle Trips (17% Exit= 22 vph)

PM =.42 Peak Hour Adi Street P.M. =.139 121 vph (21% enter - 25 vph) 3.02 Average Vehicle Trips (79% exit 96 vph)

Direction of cars exiting @ Gate No. 1 (Doe 22, 1997) 151 North= 75%

50 South = 25%

EXISTING CONDITIONS - DESIGN HOUR AM Enter from North = 79 vph Enter from South = 26 vph Exit to North = 17 vph Exit to South = 6 vph PM Enter from North = 19 vph Enter from South = 6 vph Exit to North 72 vph Exit to South 24vph Vph - vehicles per hour Vpd - Vehicles per day

a.

EXHIBIT EN-SAS-I8 FAAGE 17 OF 27

-OUTAGE TRAFFIC Outage October 2002 (RFO # 23)

Average number of vehicles enter Gate No. 1 19000 vehicles 1000 vehicles x 19days 2 trips each vehicle (entering, exiting) = 2000 vpd Average number of employees entering Gate No. 2 = 17544 employees =

l9days 923 employees/day:

2000 vpd 2.17 vpe 923 employees/day Peak Day (October 10, 2002) = 1200 vehicles x 2trips/day " 2.21 vpe 1083employees 2004 Outage Traffic (RFO #24) 1700 employee x 2.17 vpe - 3689 vpd Time of Arrival - AM = 5:30 - 7:30 AM (60%)

PM = 5:00 - 7:00 PM (40%)

Note: Time of arrival not during peak AM OR PM hours.

ADDITIONAL TRAFFIC WITH OUTAGE 3689- 873 =2816 vpd 60% AM - 1690 vpd; 40% PM = 1126 vpd-423 vph (845 vpd) arrive between 5:30 and 7:30 AM

.423 vph (845 vpd) exit between 5:30 and 7:30 PM 281 vph (563 vpd) arrive b-etween 5:00 and 7:00 PM 281 vph (563 vpd) exit between 5:00 and 7:00 PM 4'

EXHIBIT EN-SAS-18 PAGE 18 OF 27 EXISTING TRAFFIC Gov. Hunt Rd. to Tyler Hill Rd. = 5300 vpd (North)

Based upon counts @ VAOT x 167 AM Hour 6:30 to 7:30= 5.6% of daily traffic

= 297 vph existing (Northbound 60% = 178, southbound 40% 119)

PM Hour 5:00 to 6:00 = 5.2% of daily traffic

= 276 vph (Northbound 40a = 110, Southbound 60% = 166)

Gov. Hunt Rd. to Pond Rd. = 2600 vpd (South)

AM Hour 6:30 to 7:30 = 146 vph

'Northbound 60% = 88, Southbound 40% = 58)

PM Hour 5:00 to 6:00 = 135 vph (Northbound 40% = 54, Southbound =60% 81)

OUTAGE TRAFFIC GoV. Hunt Rd. to Tyler Hill Rd. (75% of Traffic)

AM Hour 6:30 to 7:30 = 317 vph Southbound

= 211 vph Northbound PM Hour 5:00 to 6:00 = 211 vph Southbound

=317 vph Northbound Gov. Hunt Rd. to Pond Rd.

AM Hour 6:30 to 7:30 =70 vph Southbound

=106 vph f~orthbound PM Hour 5:00 to 6:00 106 vph Southbound 70 vph Northbound

EX~mIT EN-SAS-18 PAGE 19 OF 27 ROUTE 142 -NORTH OF FACILITY-@ OUTAGE AM Traffic -Northbound (178 + 211) = 389 vph (47%)

Southbound (119 + 317) = 436 vph (53%)

825 vph PM Traffic-Northbound (110 + 317) =427 vph.(53%)

Southbound (166 + 211) = 377 vph (47%)

804 vph ROUTE 142 - SOUTH OF FACILITY.,@ OUTAGE AM Traffic -Northbound (88 + 106) = 194 vph (60*/.)

Southbound (58 + 70) = 128 vph (40%)

322 vph PM Traffic - Northbound (54 + 70) - 124 vph (40%)

Southbound (81 + 106) = 187 vph (60%)

311 vph

-2.4-

EXHIBI EN-SAS-18 PAGE 20 OF 27 1985 HCM:TWO-LANE HIGHWAYS FACILITY LOCATION .... VT. ROUTE 142-NORTH OF VY ANALYST .............. PRB TIME OF ANALYSIS...... PM DATE OF ANALYSIS ..... 01-16-2003

.. ".OTHER INFORMATION.. . AM NORTH OF VERMONT YANKEE WITH OUTAGE TRAFFIC A) ADJUSTMENT FACTORS PERCENTAGE OF TRUCKS.*........................ 2 PERCENTAGE OF BUSES ............................ 0 PERCENTAGE OF RECREATIONAL VEHICLES ......... 0 DESIGN SPEED (MPH) ............................. 50.

PEAK HOUR FACTOR ............................ 1 DIRECTIONAL DISTRIBUTION (UP/DOWN) ........... 53 / 47 LANE WIDTH (FT) ............................. 11 USABLE SHOULDER WIDTH (AVG. WIDTH IN FT. ... 3 PERCENT NO PASSING ZONES ...................... 80 B) CORRECTION FACTORS ROLLING TERRAIN E E E f f f LOS T B R w d EV A 4 3 3.2 .8 .98 .94 B 5 3.4 3.9 .8 .98 .93 C 5 3.4 3.9 .8 .98 .93 D 5 2..9 3.3 .8 .98 .93 E 5 2.9 3.3 .9 .98 .93 C) LEVEL OF. SERVICE RESULTS INPUT VOLUME(vph): 825' ACTUAL FLOW RATE: 825 SERVICE LOS FLOW RATE V/C A 83 .04 B 306 .15 C 611 .3 D 937 .46 E 2062 .9

-2.5-

EXIBIT EN-SAS-is LOS FOR GIVEN CONDITIONS: D PAGE 21 OF 27

EXHIBIT PAGEEN-SAS-18 22 OF 27 1985 HCM:TWO-LANE HIGHWAYS FACILITY LOCATION .... VT. ROUTE 142-NORTH OF VY ANALYST............... PRB TIME OF ANALYSIS ..... PM DATE OF ANALYSIS ..... 01-16-2003-

• OTHER INFORMATION .... PM -NORTH OF VERMONT YANKEE WITH OUTAGE TRAFFIC A) ADJUSTMENT FACTORS PERCENTAGE OF TRUCKS ........................... 4 PERCENTAGE OF BUSES ............................ 0 PERCENTAGE OF RECREATIONAL VEHICLES......... 0 DESIGN SPEED (MPH) ............. ............. 50 PEAK HOUR"FACTOR ............................ 1 DIRECTIONAL DISTRIBUTION (UP/DOWN) ........... 53 / 47 LANE WIDTH (FT) .................................. 11 USABLE SHOULDER WIDTH (AVG. WIDTH IN FT.),.. 3 PERCENT NO PASSING ZONES...................... 80 B) CORRECTION FACTORS ROLLING TERRAIN E E E f f f LOS T B R w d V A 4 3 3.2 .8 .98 .89.

B 5 3.4 3.9 .8 .98 .86 C 5 3.4 3.9 .8 .98 .86 D 5 2.9 3.3 .8 .98 .86 E 5 2.9 3.3 .9 .98 .86 C) LEVEL OF SERVICE RESULTS INPUT VOLUME (vph): 804 ACTUAL FLOW RATE: 804 SERVICE LOS FLOW RATE V/C A 79 .04 B 284 *.15 C 569 .3 D 872 .46 E 1920 .9

.e EXHMIIT EN-SAS-IS LOS FOR GIVEN CONDITIONS: D PAGE 23 OF 27 0

I

EXHBrr EN-SAS-IS PAGE 24 OF 27 Q

1985 HCM:TWO-LANE HIGHWAYS FACILITY LOCATION .... T. ROUTE 142-SOUTH OF VY ANALYST .............. PRB TIME OF ANALYSIS ..... AM DATE OF ANALYSIS ..... 01-16-2003 OTHER INFORMATION .... AM SOUTH OF VERMONT YANKEE WITH OUTAGE TRAFFIC!

A) ADJUSTMENT FACTORS

-PERCENTAGE OF TRUCKS............................ 2 PERC!ENTAGE OF BUSES............................ 0 PERCENTAGE OF.-RECREATIONAL VEHICLES ......... 0 DESIGN SPEED (MPH) .......................... 50 PEAK HOUR FACTOR ............................ 1 DIRECTIONAL DISTRIBUTION (UP/DOWN) ............ 60 / 40 LANE WIDTH (FT) ............................. 11 USABLE SHOULDER WIDTH (AVG. WIDTH IN FT.)- 3 PERCENT NO PASSING ZONES ....................... 90 B) CORRECTION FACTORS ROLLING TERRAIN E E E f f f LOS T B R w d HV A 4 3 3.2 .8 .94 .94 5 3.4 3.9 .8 .94 .93 C 5 3.4 3.9 .8 .94 .93 D 5 2.9 3.3 .8 .94 .93 E 5 2.9 3.3 .9 .94 .93 C) LEVEL OF SERVICE RESULTS INPUT VOLUME(vph): 322 ACTUAL FLOW RATE: 322 SERVICE LOS FLOW RATE V/C A 79 .04 B 292 .15 C 585 .3 D 897 .46 1974 .9

-. I~

LOS FOR GIVEN CONDITIONS:.C EXHIBIT PAGEENSAS-18 25 OF 27

EXHIBIT EN-SAS-18 PAGE 26 OF 27 1985 HCM:TWO-LANE HIGHWAYS FACILITY LOCATION .... T. ROUTE 142-SOUTH OF VY ANALYST .............. PRB TIME OF ANALYSIS..... AM DATE OF ANALYSIS...... 01-16-2003 OTHER INFORM4ATION.. ;. PM" SOUTH! OF -VERMONT. YANKEE WITH OUTAGE TRAFFIC A) ADJUSTMENT FACTORS PERCENTAGE OF TRUCKS ..... *- -................... 4 PERCENTAGE OF TUSESC ......................... 0 PERCENTAGE OF RECREATIONAL VEHICLES .......... 0 DESIGN SPEED (MPH) .......................... 50 I

PEAK HOUR FACTOR ............................ 1 DIRECTIONAL DISTRIBUTION (UP/DOWN) ............ 60 / 40 LANE WIDTH (FT) ............................. 11 USABLE SHOULDER WIDTH (AVG. WIDTH IN FT.)... 3 PERCENT NO PASSING ZONES ....................... 90 B) CORRECTION FACTORS ROLLING TERRAIN E E E f f f LOS T B R w d HV A 4 3 3.2 .8 .94 .89 B 5 3.4 3.9 .8 .94' .86 C 5 3.4 3.9 .8 .94 .86 D 5 2.9 3.3 .8 .94 .86 E 5 2.9 3.3 .9 .94 .86 C) LEVEL OF SERVICE RESULTS INPUT"VOLUME(vph): 311 ACTUAL FLOW RATE: 311 SERVICE LOS FLOW RATE V/C A 75 .04 B 272 .15 C 545 .3 D 835  :. .46 E 1838:J" .9 -9 11-

I.

LOS FOR GIVEN CONDITIONS: C EXHIBIT EN-SAS-1i PAGE 27OF27

-2.12-I

1-o5& /-I/

STATE OF VERMONT AGENCY OF COMMERCEAND COMMUNITY DEVELOPMENT February 4, 2003

~RECEtVEU:'

Sonja A. Schuyler, Senior ScientistR The Johnson Company, Inc.

EIV D 100 State Street Montpelier, Vermont 05602 8 2

'.EPARTAIENT Re: Proposed Power Uprate, Entergy Nude r Vermo.5 c.

nceeem.

IF HOUSING & Vermont. NRC. Act 250. ONCO INC.

VMHVuNnT IFFAIRS MONTPELIER yT ivisim for. Dear Ms. Schuyler Thank you for the opportunity to comment on the above project having Nuclear Regulatory pWsarlcio Comsinnxo~x-,nt DHP #WD03-001). We understand that you are also seeking an enttp an Act4 *4Z) Q250-*

"drdqre The Division for Histoiic Preservation has reviewed this proposed dnderftaiig pursant to 36 CFR 800.4, regulations established by the Advisoiy Council on Historic Predersratibn to implement Section 106 of the'National Histbric Preservation Act. Project review consists of identifying the project's potential impacts to historic buildings and structures, historic

.rawa2 districts, historic landscapes and settings, and to known or potential archeological 3ff472f45FT resources. The Division also has reviewed this proposed undertaking for purposes of Criterion 8, 10 V.SA., Chapter 151 (Act 250). The purpose of the Division's review is to provide the Environmental District Commission with'the information necessary for them to make a positive finding .under the "historic sites" aspect of Criterion 8. For further Wo-rk information regarding the Division's Act 250 rules; please see our website at www.dhca.state.vt.us/DHP/general/nles.html.. While these rules impose no obligation on any Act 250 applicant, providing insufficient information to the District Commission with an initial application may result. in the project being delayed if the Commission determines they cannot make a positive finding under Criterion 8 without comments from the Division.

The bir6*Osed nm*iect invol',s ii crean f:the nower outiuf at the EntenwNudlear Vermont

EXHIBIT EN-SAS-19 February 6, 2003 PAGE 2 OF 2 Vernon, Entergy Nuclear Vermont Yankee Power Uprate Project Page 2 of 2 area will not likely yield information important to prehistory as the site has been previously disturbed. In addition, because corn-trnction of the power plant began in 1967, Vermont Yankee is less than fifty years old and thus not eligible for listing in the National Register of Historic Places. Therefore, it is our opinion that no historic resources will be

• efected by the proposed project.

If you have any questions or need clarification regarding any of the above, please do not hesitate to contact Judith W. Ehrlich, Environmental Review Coordinator, at (802) 828-3049.

Sincerely, VERMONT DIVISION FOR HISTORIC PRESERVATION Emily Wadhanms State Historic Preservation Officer

EXHJIIT EN-.SAS-20 State of Vermont AGENCY OF NATURAL RESOURCES

-DEPARIM T OF FISH AND W IL V~rtm,,nt of FIsh and WI *I.H 103 South Main Sret 10 Sooth Dow.rtm.nt of Forsts, P.,o.s snd *scmatio. Watbwy, Vemiont 05671-0501' Depsament of Environmwntal Conisrva I n TDD: M1N- nm-53)9 L..... V - J Nongame & Natural Heritage Program 3 January 2003 Sonja Schuyler*

The Johnson Company _J 100 State Street Montpelier, VT 05602 Re. Vermont Yankee power uprae JCO # 1-0561-1(058)

E

DeareSonja:

Everett MWardhaln asked thateI respond to your request for our review of the above-referenced project. We do not anticipate impacts to the known rare plants downstreamr as a result of the proposed increase in power output.

Please contact District Fisheries Biologists Ken Cox (88548828) and Jay McMewemy (885-8829) for consultation on potential fisheries impacts.

Thank you for consulting with the Vermont Department of Fish and Wildlife's Nongame and Natural Heritage Program. Please let us know if we can be of further assistane or for review of.

• changes to the proposal.

Sincerely, Jodi Shippee Nongame Wildlife Technicianf Database Assistant

.Tel: 802-241.4230 Email: jodi@fWd.anr.state.vt.us

, cc: Everett Marshall, Biologist/Data Manager; Ken Cox, Fisheries Biologist; Jay MeMenemy, Fisheries Biologist sqta opportutity Employer Reoaonal Offices - BarraiFwAy Jet tPknd.qdn~AM .Ihnthlvn,

EXHIBrT FEN-SAS-21 Vermont Nongame and Natural Heritage Program Vermont Department of Fish and Wildlife Vernon Dam Site Listings Generated by E.Marshall 1-06-03 Scientific Common Global State State Federal Last Name Name Rank Rank Status Status Seen

• • • below dam - 1st dot Scirpus purshlanus Pursh's bulrush G4G5 82S3 1991 Mimulus moschatus Musk flower G4G5 S2S3 1987

• • • above dam - 2nd dot north of Juncus acuminatus Tapering rush G5 SI 1968

• • • below dam - 2nd dot - 0.3 miles south of Eleocharis Intermedia Matted spikerush G5 S2S3 1984

• • • drainage north of dam Stellaria alsine Trailing stitchwort G5 $1 1984

• • "above dam - 1st dot north of Hypericum ascyron Great st. john's-wort G4 S2 T 1987

- Zannichelnia palustris Homed pondweed G5 S1 1982 Elatne minima Small water-wort G5 Si 1982 Tfiaea aquatica Pygmyweed G5 $2 1982 Eragrostis frankil Frank's love-grass G5 $2S3 1982

• "* below dam Silver maple-ostrich fern $3 1997 riverine floodplain forest

• • • above and below the dam Polygonatum biflorum var Giant solomon's seal G5T5 S1 2001 commutatum

EXIBIT EN.-SAS-22 Malinhg Address:

National Life Record, Center National lMe Records Drawer 20 Center Vermout Montpelier, mading Montpelier, VT 0562"20,1L. ~Location:

State of Vermont Water Resources Board Td: (802) 828-3309 January 7, 2003 1--6iija A. Schuyler THE JOHNSON COMPANY 100 State Street Montpelier, VT 05602

Dear Sonia:

RE: Entergy Nuclear Vermont Yankee - Power Uprate JCO #1-0561-1(058)

The project described in your letter to me dated January 2, on or anywhere near a body of water designated as an outstanding2003, is not located resource waters by the Vermont Water Resources Board (10 V.S.A. § 1424a). No portion of Connecticut River has In fact been so designated by this Board. Please the let me know if I can be of any further assistance in this matter.

rely,

Si on Grovemnan Executive Officer cc

Public Service Board Department of Public Service Department of Environmental Conservation, cto Wally McLean Q'W A

- w * -- -

EX[IIBIT EN-SAS-23 STATE OF VERMONT rAF .r:! rD &MARKETS Sonja Schuyler The lohnson Company, Inc.

100 State Street " JOHNSON CO. INC.

Montpelier, VT 05602 "MONTPEUEL VT 31 December 2002 I-Re: Entergy Nuclear Vermont Yankee, Vernon Act 250- criterion 9(B): Primary agricultural soils assessment Thank you for your December 30 te letter addressed to Chris White. I am responding since I took over this position nearly three years ago, If, as you indicate, the Power Uprate will have no impact on primary agricultural soils either beyond the existing building footprint or an increased in the paved areas there is so significant inipact to the total primary agricultural soils on the site and the Department has no objection.

As you know, any final determination of Act 250 9(B) issues is left to the local commission. However, please feel free to include this letter as an attachment to any filings you make with regard to this specific project. My telephone number, if you have additional questions, is $02-828-5434.

Cc: 'April Hensel, District 2 Coordinator

• 05EALOFOJ,.zr 116 STATE STREET IflO IORM ew~u "4axr.

DRAWER20 MONTPEUER, VT 05620-2901 I