ML12157A249

Attachment 25 to GNRO-2012/00039, Er Reference - Ggns. 2006c. Grand Gulf Nuclear Station, Storm Water Pollution Prevention Plan, Revision 13. July 2006

ML12157A249
Person / Time
Site:	Grand Gulf
Issue date:	05/23/2012
From:	Entergy Operations
To:	Office of Nuclear Reactor Regulation
References
GNRO-2012/00039
Download: ML12157A249 (73)

Text

Attachment 25 to GNRO-2012/00039 Attachment 25 to GNRO-2012/00039 ER Reference - GGNS. 2006c. Grand Gulf Nuclear Station, Storm Water Pollution Prevention Plan, Revision 13. July 2006

GRAND GULF NUCLEAR STATION STORM WATER POLLUTION PREVENTION PLAN Revision 13 3uly 2006 GGNSSWPP (REV 13)- I

TABLE OF CONTENTS Section Description Pa e 1.0 Introduction 3 2.0 Site Description 3 3.0 Facility Drainage 3 4.0 Pollution Prevention Team 4 5.0 Assessment of Potential Storm water Pollution Sources 4 6.0 Risk Identification/Potential Pollutant Summary 4 7.0 Spill History 10 8.0 Non-Storm water Discharges I1 9.0 Sampling Data 12 10.0 Best Management Practices 13 11.0 Phase 1I Compliance 16 12.0 Inspections 16 13.0 Record keeping 18 14.0 Training  !

15.0 Amendments 18 16.0 National Historic preservation Act 19 17.0 Endangered Species Act 19 18.0 Pollution Prevention Plan Certification 20 19.0 Figures 21 Figure I - Building Locations 22 20.0 Attachments 24 Attachment I - Regulated Areas of Industrial Activity 25 Attachment II - Storm Water Sampling Data 31 Attachment IMI - Annual Storm Water Inspection Form 33 Attachment IV - Small Construction Permit Requirements 35 Attachment V - Large Construction Permit Requirements 72 GGNSSWPP (REV 13) - 2

1.0 INTRODUCTION

1.1 The purpose of the Grand Gulf Nuclear Station (GGNS) Storm water Pollution Prevention Plan is to minimize storm water contamination and identify potential pollution sources.

1.2 Items in this plan requiring periodic evaluation during the year are described in Sections 4.0, 10.0, 11.0, 12.0, 13.0, 14.0, 15.0, Attachment IV and Attachment V.

2.0 SITE DESCRIPTION 2.1 The Updated Final Safety Report [UFSAR] figure 2.4-1 shows GGNS site property boundaries. The GGNS site covers approximately 2100 acres and borders the Mississippi River.

2.2 The site consists of office buildings, employee parking areas, a nuclear power generating station, industrial shop areas, laydown areas, waste accumulation areas, wastewater holding ponds, and storage tanks containing oil or chemicals.

2.3 Activities at site primarily involve electrical generation and transmission.

3.0 FACILITY DRAINAGE 3.1 UFSAR figures 02.4-007 and 2.4-8 shows the GGNS site drainage. Figure 1 shows building locations.

3.2 Of relevance to the GGNS site are two small and steep gradient streams.

The north stream (Stream A) is perennial with the south stream (Stream B) being intermittent. Storm water from the GGNS site enters one of these streams before reaching Hamilton Lake and the Mississippi River.

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4.0 POLLUTION PREVENTION TEAM 4.1 The designated Storm Water Pollution Prevention Manager at GGNS is:

a. Richard A. Scarbrough - Chemistry Superintendent 4.2 Designated Storm water Pollution Prevention committee members at GGNS consist of the following:

a. Ricky Buckley - Sr. Project Manager (Corporate)

b. Rusty Shaw - Chemistry Specialist

c. John Lassetter- Chemistry Supervisor 4.3 These individuals ensure that the plan is implemented as required by the general permit and are responsible for the annual inspection and any subsequent revisions needed to the plan.

5.0 ASSESSMENT OF POTENTIAL STORM WATER POLLUTION SOURCES 5.1 Although there are some significant materials such as metallic products exposed to storm water at the site, there are no significant materials such as process chemicals, raw materials, fuels, pesticides or fertilizers, exposed to storm water at GGNS.

5.2 Water treatment chemicals and petroleum products are stored in tanks, bins and drums. Tanks have secondary containment, while drums and bins are sealed unless in use. Therefore, exposure to storm water is not possible unless there is a leak or spill.

5.3 Attachment I, Regulated Areas of Industrial Activity, lists industrial areas that are present at the GGNS site and identifies the types of potential pollutants present.

6.0 RISK IDENTIFICATIONIPOTENTIAL POLLUTANT

SUMMARY

6.1 Since no manufacturing or chemical production occurs at GGNS, the areas judged to have a reasonable potential for adding pollutants to storm water are:

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a. Vehicle Maintenance

1. Vehicle Maintenance Shop - Servicing of vehicles and similar industrial equipment. This area consists of a vehicle wash rack, fuel truck containing diesel and gasoline, and intermittent industrial equipment such as trucks, cranes and portable generators. Servicing activities occur under a covered area except for occasional crane maintenance and the fuel truck is parked within a concrete containment structure.

Storm water runoff from this area drains either to an oily water separator or a sump prior to discharge into Stream A.

The pollutant of concern at this location is petroleum hydrocarbons.

b. Vehicle Fueling

1. Vehide Maintenance Shop Fueling Area - Diesel fuel and gasoline are stored in aboveground tanks behind the Vehicle Maintenance Shop for vehicle and industrial equipment fueling purposes. The tanks are located within a covered containment structure. Although the potential for minor spills exists during fueling activities, runoff from this area drains to an oily water separator prior to discharge into Stream A. The pollutant of concern at this location is petroleum hydrocarbons.

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c. Painting

1. Spray Paint Shop- The spray paint shop is located near the Energy Services Center. Spent sandblast material and metal items are stored at this area. Some spray painting is also done outside the shop. Runoff from this area drains to an open field below the shop area and does not affect water quality. The pollutants of concem at this location are iron and suspended solids.

d. Site Erosion

1. Spray Paint Shop Area - The shop is located on the edge of the bluffs in an area is subject to erosion. Runoff from this area drains to an open field below the shop area and does not affect water quality. The pollutant of concern at this location is suspended solids.

2. Ball field Renovation Area - Area is subject to erosion.

Runoff from this area drains to a stock pond. The pollutant of concern at this location is suspended solids.

3. Building and Grounds Area - The hill adjacent to this area is subject to erosion. Runoff drains into a concrete ditch prior to discharge into Sedimentation Basin A. The pollutant of concern at this location is suspended solids.

4. Vehicle Maintenance Shop Area - Drainage pipes are subject to erosion. Runoff from this area drains into Stream A. The pollutant of concern at this location is suspended solids.

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5. Stream A Storm Drains- Old Unit 2 storm water drainage pipes and flumes adjacent to Stream A are subject to erosion and no longer serve their intended purpose. These have been abandoned in place. Runoff from this area drains into Stream A. The pollutant of concern at this location is suspended solids.

e. Material Unloading

1. Vehicle Maintenance Shop Gasoline and Diesel Storage Tanks - Diesel fuel and gasoline are stored in aboveground tanks behind the Vehicle Maintenance Shop. The tanks are located within a covered containment structure. Tank unloading is associated with this location. Although the potential for minor spills exists, runoff from this area drains to an oily water separator prior to discharge into Stream A.

The pollutant of concern at this location is petroleum hydrocarbons.

2. Standby Diesel Fuel Generator Storage Tanks - Diesel fuel is stored in three underground tanks northwest of the Diesel Generator Building. Since tank unloading is associated with this area, the potential for minor spills exists.

Runoff from the unloading area drains to a holding tank.

The pollutant of concern at this location is petroleum hydrocarbons.

3. Energy Services Center Diesel Fuel Storage Tank -

Diesel fuel is stored in an underground tank at the Energy Services Center. Since tank unloading is associated with this area, the potential for minor spills exists. Runoff from this area drains into NPDES Outfall 016 prior to discharge into Sedimentation Basin A. The pollutant of concern at this location is petroleum hydrocarbons.

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4. Clean and Dirty Lube Oil Storage Tanks - Clean and dirty lube oil are stored in aboveground tanks east of the Turbine Building. The tanks are located within a concrete berm.

Since tank unloading is associated with this area, the potential for minor spills exists. The berm is manually drained into a storm drain prior to discharge into Sedimentation Basin B. The pollutant of concern at this location is petroleum hydrocarbons.

f. Material Storage

1. Radial Well Lube Oil Storage Tanks - Lube oil is stored in aboveground tanks at the Radial Wells (Mississippi River). These tanks have secondary containment.

Should a leak occur, runoff would drain onto the ground or into the river, depending upon the river stage. The pollutant of concern at these locations is petroleum hydrocarbons.

2. Fire Training Area - Diesel fuel is stored in a skip pan and a portable fuel tank at the fire training area in the northwest laydown area. In addition, empty fire extinguishers and wood materials are stored at this location. The fuel is burned in a skip pan for fire training purposes and is covered when not in use. Runoff from this area drains into an oily water separator prior to discharge into a holding pond. The pollutants of concern at this location are petroleum hydrocarbons and suspended solids.

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3. Building & Grounds Shop - The shop is located on the North Access Road. Metal and other equipment are stored outside the shop. Runoff from this area is controlled by concrete drains and chutes prior to discharge into Stream A via Sedimentation Basin A. The pollutants of concern at this location are suspended solids and iron.

4. Burn Pit Area - The Bum Pit Area is located east of the plant and adjacent to the switchyard. Occasionally, scrap metal and empty containers are stored at this area. Runoff from this area is controlled by concrete drains and chutes prior to discharge into Stream B. The pollutant of concern at this location is iron.

5. Spoils Area - Located East of the plant and adjacent to the Switchyard. Portions of this area are used for temporary storage of metal, industrial equipment and portable buildings.

The pollutants of concern at this location are suspended solids and iron.

6. Northeast Laydown Area - This area is located on the east side of the North Access Road. Metal, industrial equipment, concrete and wood materials are stored in this area. Runoff from this area is controlled by concrete drains and chutes prior to discharge into Stream A. The pollutants of concern at this location are suspended solids and iron.

7. Northwest Laydown Area - This area is located on the west side of the North Access Road. Metal, concrete and wood materials are stored in this area. Runoff from this area is controlled by concrete drains and chutes prior to discharge into Stream A. The pollutant of concern at this location are suspended solids and iron.

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8. Shooting Range - This is located on the west side of the Northwest Laydown area. Metal target stands and spent bullets are in the area. Runoff from this area into a holding pond and does not enter surface waters. The pollutants of concern at this location are iron, lead and suspended solids.

g. Construction Areas

1. Plant areas are periodically subject to temporary construction activities over time. These areas typically comprise less than five acres. Runoff from these areas has the potential to contain suspended solids. However, impact from these activities are minimal due to GGNS' onsite sedimentation basins. [See Attachment IV].

Attachment V lists current construction permits for construction activities with a potential to disturb more than 5 acres and includes requirements for managing these activities.

7.0 SPILL HISTORY 7.1 The Storm water Pollution Prevention Manager should update this section as needed, describing significant spills. For the purpose of this plan a significant spill is one which results in a notification to a regulatory authority.

7.2 The following reportable spills have occurred during the past three years:

a. Fuel Oil Mixture 7.3 Records of spill(s) should include the following, as appropriate:

a. Date: 5/15/2003

b. Weather conditions: Cloudy, Drizzle

c. Duration: Instantaneous

d. Cause: Ruptured 1 gallon container GGNSSWPP (REV 13) - 10

e. Environmental problems: None

f. Response procedures: Absorbed material onto pads and boom

g. Parties notified: National Response Center, MDEQ, MEMA

h. Recommended revision to the Plan and operating procedure and/or equipment needed to prevent recurrence: None.

8.0 NON-STORM WATER DISCHARGES 8.1 The following types of non-storm water discharges are authorized as long as they are listed in this Plan:

a. Fire fighting activities

b. Fire hydrant flushing

c. Potable water sources (e.g., water line flushing)

d. Irrigation drainage

e. Lawn watering

f. External building wash downs where chemicals, including detergents are not used

g. Rainwater from buildings and containment structures (free from oil or other chemical contaminants)

h. Pavement washing where spills or leaks of toxic or hazardous materials have not occurred (unless all spilled material has been removed) and where chemicals, including detergents, are not used

i. Air conditioning condensate

j. Natural springs

k. Uncontaminated groundwater

1. Foundation/footing drains where flows are not contaminated with process materials such as solvents or other chemicals

m. Washing of water treatment facility grounds, after salt additions, where spills or leaks of hazardous materials have not occurred 8.2 Chemistry personnel visually assessed the site for non-storm Water discharges during dry weather conditions on May 31, 1993. No illicit connections were discovered. No plant modifications have occurred since that inspection creating illicit connections or discharges that would cause harm to aquatic life or the environment.

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8.3 The potential sources of non-storm water identified during the initial and subsequent assessments are as follows:

a. Stream A (NPDES Outfall 013) receives non-storm water from:

1. NPDES Outfalls 010 and 016

2. Oily water separators from the Vehicle Maintenance Shop area

3. Site Processing Center (once-through cooling water)

4. Domestic/construction water and fire water

b. Stream B (NPDES Outfall 014) receives non-storm water from:

1. NPDES Outfall 007

2. Oily water separators from the Maintenance Shop, Diesel Generator Building and Fire Water Pump Houses

3. Administration Building HVAC Blowdown

4. Ionics demineralization water system bypass & reject water

5. Air conditioner condensate

6. Turbine Building cooling water discharge

7. Domestic/construction water and fire water

8. Construction Water Once-through Cooling 8.4 Discharges identified as inputs through permitted NPDES Outfalls are not illicit connections. See the NPDES permit for specific descriptions.

9.0 SAMPLING DATA 9.1 GGNS storm water outfalls have been sampled periodically using methods and techniques prescribed for compliance with the NPDES Permit. These results have not shown any evidence of industrial activities at GGNS contributing to storm water pollution. These are summarized in Attachment II.

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9.2 The Storm water Pollution Prevention Manager, or designee, should update Attachment 11 within 90 days of acquiring new sampling data or as required by the Mississippi Department of Environmental Quality

[MDEQ]. If these results are included in monthly NPDES Reports or otherwise transmitted to MDEQ, Attachment UIneed not be updated until this plan is revised.

10.0 BEST MANAGEMENT PRACTICES 10.1 Best management practices relied upon to control potential sources of storm water pollution are as follows:

a. Soil Erosion

1. Erosion is controlled by providing piped drainage, intercept ditches, diversion dikes, concrete flumes and ground cover.

2. Areas disturbed by site construction have been re-vegetated and stabilized.

b. Housekeeping

1. The following housekeeping practices are observed:

a) Maintaining dry, clean floors and ground surfaces.

b) Regularly disposing of garbage and waste material.

c) Providing adequate aisle space for material transfer and inspections.

d) Storing containers, drums and bags away from direct traffic routes.

e) Storing containers to prevent corrosion by contact with moisture.

f) Assigning responsibility for hazardous material to trained personnel.

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c. Preventive Maintenance

1. Preventative maintenance relating to storm water pollution is covered in Section 10.1 d.

2. Preventative maintenance primarily applies to maintaining berms and other containment structures to prevent releases.

d. Spill Prevention and Response

1. Potential spill and leak areas, including best management practices, relied upon are:

a) Vehicle and Equipment Maintenance

1) Check for leaking oil and fluids

2) Use low toxicity materials

3) Drain oil filters

4) Recycle engine fluids and batteries

5) Segregate and label wastes

6) Restrict solvent use b) Vehicle Fueling Station

1) Provide aboveground tanks

2) Automatic shut-off

3) Covered fueling area

4) Dry cleanup of spills c) Vehicle and Equipment Washing

1) Use designated cleaning areas

2) Use phosphate-free detergents d) Loading and Unloading Areas

1) Contain leaks during transfer

2) Check equipment for leaks

3) Prevent storm water runoff GGNSSWPP (REV 13)- 14

e) Aboveground Tanks

1) Comply with aboveground tank requ'irements

2) Properly train employees

3) Provide secondary containment

4) Provide tank safeguards, if necessary f) Painting

1) Segregate waste

2) Minimize the use of solvents

3) Proper storage of waste

4) Prevent storm water from contacting paint waste

2. Site procedures address spill prevention and response and are available to appropriate personnel through issuance of controlled procedure manuals.

3. Materials available to respond to spills or leaks are described in the Spill Prevention, Control and Countermeasures Plan.

4. Inspections of oil and chemical handling areas occur routinely.

a) Surveillance for valve closure at secondary containment structures is controlled by Operations Section Procedure 02-S-01-5, Shift Logs and Records.

b) Containment structures with oil storage equipment are checked for presence of oil by Plant Operations during routine rounds.

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C) In accordance with Procedure 01-S-08-12, Monitoring and Control of Non-Radiological Discharges (NPDES), Operations personnel observe rainwater for the presence of an oil sheen prior to draining. Waste drum handling areas are periodically inspected for leaks or container degradation by Chemistry personnel.

11.0 PHASE U COMPLIANCE 11.1 Effective on March 10, 2003, The Mississippi Department of Environmental Quality required controls to prevent or minimize pollutant impacts in any storm water runoff from construction activities that result in land disturbances of I or more acres. Construction activity on sites disturbing less than 1 acre are included if these activities are part of a larger common plan that would disturb I acre or more, with the following allowance:

Construction activities less than 5 acres are allowed and must comply with the Best Management Plans and additional instructions listed in this plan and Attachment IV. Construction activities disturbing more than 5 acres may require an MDEQ Construction Permit and must comply with the permit and/or any additional requirements [See Attachment V1.

12.0 INSPECTIONS 12.1 The Storm water Pollution Prevention Manager and committee members annually inspect the facility and material handling areas for evidence of pollutants entering the storm water drainage system.

Inspections of construction areas must also comply with the additional instructions listed in Attachment IV or Attachment V.

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For the purposes of this plan "annually" is defined as the calendar year between January 1 and December 31.

12.2 Chemistry personnel may also periodically inspect construction areas.

12.3 As part of the annual inspection, this team verifies that:

a. The storm drainage system is accurately reflected in the Plan.

b. The description of potential pollutant sources is accurately reflected in the Plan.

c. Management controls are properly implemented, when necessary.

12.4 Annual inspections may also include:

a. Areas where spills and leaks have occurred in the past

b. Material storage areas (tanks, drum storage)

c. Material handling areas (loading, unloading, transfer)

d. Waste generation, accumulation, storage and recycling areas.

e. Areas of construction, renovated areas, or any other areas of concern regardless of size, if deemed necessary by the Storm Water Pollution Prevention Committee.

12.5 The Ball field renovation area is inspected annually, as part of the annual storm water inspection. This is a verbal agreement with MDEQ and the commitment is documented in CR No. 1997-1274-00.

12.6 Annual inspection records should document the following and be recorded on a form similar to the one shown in Attachment IIn:

a. Date inspection occurred

b. Inspection team members

c. Corrective action (including notifications) 12.7 The Storm water Pollution Prevention Manager must submit the completed form to the Mississippi Department of Environmental Quality no later than the 28th day of January.

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13.0 RECORDKEEPING 13.1 The Storm water Pollution Prevention Manager shall retain records of maintenance activities, spills, inspections and results of tests, and flow measurements conducted on storm water for three years.

14.0 TRAINING 14.1 GGNS personnel receive guidance in spill response and reporting in annual General Employee Training.

14.2 Employees having specific responsibilities for storm water pollution prevention receive annual training in spill response, good housekeeping and materials management under the requirements of 29CFR1910.120.

15.0 AMENDMENTS 15.1 The Storm water Pollution Prevention Plan will be amended whenever:

a. There is a change in facility design, construction, operation, or maintenance which may increase the discharge of pollutants, or

b. The Plan proves to be ineffective in controlling storm water pollutants, or

c. Regulatory changes mandating changes in compliance, reporting, management practices, permitting or otherwise requiring amendments to this plan.

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16.0 NATIONAL HISTORIC PRESERVATION ACT 16.1 The Grand Gulf Nuclear Station was originally evaluated by the Mississippi Department of Archives and History during the construction of the facility. This evaluation determined that operation of the station will not result in any impact on historic and archaeological sites in the area

[Draft Environmental Statement, United States Regulatory Commission, May 1981, Page 5-7; Final Environmental Statement. United States Regulatory Commission, September 1981, Page 5-71.

NOTE Work orders and procedures must include cultural resource specific written directions for excavation and backfill work which calls for an immediate stop-work order should archeological, historical, or other cultural resources be uncovered during excavation. The construction supervisor is responsible for ensuring work stoppage and for notifying the Environmental Lead* of an inadvertent discovery.

In the event of an inadvertent discovery the Environmental Lead* will determine the inadvertent discovery's significance and if necessary. notify the State Historic Preservation Officer to consult with them regarding the discovery to determine if an additional archeological assessment is needed.

• Environmental Leads:

Rusty Shaw 601-437-7312 I John Lassetter 601-437-2115 17.0 ENDANGERED SPECIES ACT:

17.1 Although endangered species have been identified in the proximity of the Grand Gulf Nuclear Station none have been documented in the vicinity of this activity and the implementation of protective management plans is not required. The sighting of an endangered species such as an eagle or a black bear must be immediately related to the site environmental lead.

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18.0 POLLUTION PREVENTION PLAN CERTIFICATION 18.1 I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Signature: Sg/,-t'_----'

Title:

General Manager, Plant Operations Date: /2e-2* * ,. O GGNSSWPP (REV 13) - 20

19.0 FIGURES 19.1 Figure 1 - Building Locations GGNSSWPP (REV 13) - 21

GGNSSWPP (REV 13) - 22 RESERVED GGNSSWPP (REV 13) - 23

20.0 ATTACHMENTS Attachment I - Regulated Areas of Industrial Activity Attachment II - Storm Water Sampling Data Attachment III - Annual Storm Water Inspection Form Attachment IV - Small Construction Permit Requirements Attachment V - Large Construction Permit Requirements GGNSSWPP (REV 13) - 24

ATTACHMENT I Regulated Areas of Industrial Activity GGNSSWPP (REV 13) - 25

Regulated Areas of Industrial Activity Regulated Area Drainage Potential Pollutants Metal Containers- Unit 1 Warehouse Runoff to Basin B Some iron may be present instorm water discharge.

Unit 1 Warehouse Runoff to Basin B Since area iscovered, storm water Loading/Unloading Dock contact unlikely under normal operating conditions Unit 2 Warehouse Runoff to Basin A None under normal operating LoadinglUnloading Dock conditions.

Sulfuric Acid Tanks - Protected Area Runoff to Basin B Since tanks are located within secondary containment, no pollutants will be discharged.

Chemical Storage Area -Protected Area Runoff to Basin B Since area iscovered and has secondary containment, storm water contact unlikely under normal operating conditions.

Carbon Dioxide Tanks - Protected Area Runoff to Basin B Since tanks are painted, none are expected.

Refueling Water Storage Tank - Runoff to Basin B Although tank is located within Protected Area secondary containment, some suspended solids and iron may be present during discharge of the structure.

Condensate Storage Tank - Runoff to Basin B Although tank is located within Protected Area secondary containment, some suspended solids and iron may be present during discharge of the structure.

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Regulated Areas of Industrial Activity Regulated Area Drainage Potential Pollutants Empty Drum Storage Area- Runoff to Basin B Since drums are coated, none are Protected Area expected.

Transformers- Protected Area Runoff to Basin B Since transformers are located within secondary containment, none are expected.

Fire Water Storage Tanks - Runoff to Basin B Since tanks are painted, none are Protected Area expected.

Waste Neutralization Tank - Runoff to Basin B Since tanks are painted, none are Protected Area expected.

Maintenance Shop - Runoff to Basin B Since area is covered, storm Protected Area (used oil & water contact unlikely under chemical storage cabinets) normal operating conditions Administration Building HVAC - Runoff to Basin B No pollutants are expected under Protected Area normal operating conditions Protected Area Yard (compressed gas Runoff to Basin B Some iron may be present in bottles, garbage dumpsters, scrap storm water discharge.

metal bin, wood bins, shipping casks, LSA boxes & scaffolding)

Regeneration Tanks - Protected Area Runoff to Basin B No pollutants are expected under normal operating conditions Paint Shop -Protected Area Runoff to Basin B No pollutants are expected under normal operating conditions Cooling Tower (water Runoff to Cooling No pollutants are expected under treatment chemicals) Tower Basin normal operating conditions Sulfuric Acid Tank -Cooling Tower Runoff to Cooling Since tank is located within Tower Basin secondary containment, no pollutants will be discharged.

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Regulated Areas of Industrial Activity Regulated Area Drainage Potential Pollutants Nalco PCL-361 Tank -Cooling Runoff to Cooling Since tanks are located within Tower Tower Basin secondary containment, no pollutants will be discharged.

Sodium Hypochlorite Tank - Runoff to Cooling Since tanks are located within Cooling Tower Tower Basin secondary containment, no pollutants will be discharged.

Sodium Hypochlorite Tank - Aux. Runoff to Basin B Double walled tank located within a Cooling Tower building. No pollutants will be discharged.

Water Treatment Chemicals - Runoff to Basin B Since tanks are located within West Parking Lot secondary containment, no pollutants will be discharged.

Water Treatment Chemical - Runoff to Basin B Since drum is ina covered area, East Parking Lot storm water contact unlikely under normal operating conditions.

Standby Service Water Runoff to Basin A Since containers are kept closed and (chemicals) are made of plastic, no pollutants will be discharged.

Bum Pit Area (empty drums, scrap Runoff to Basin B Some suspended solids and iron metal &skip pans) may be present inthe storm water discharge.

Environmental Holding Area Runoff to Basin A Since area is covered and has secondary containment, storm water contact unlikely under normal operating conditions Vehicle Maintenance Shop Runoff to Basin A None are expected under normal (fuel truck, industrial equipment operating conditions.

&trash dumpster)

Vehicle Fueling Station Runoff to Basin A Since this area iscovered, none under normal operating conditions.

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Regulated Areas of Industrial Activity Regulated Area Drainage Potential Pollutants Aboveground Gasoline Tank - Runoff to Basin A Since area iscovered and has Vehicle Maintenance Shop secondary containment, storm water contact unlikely under normal operating conditions Sheet Metal Shop Runoff to Basin A None are expected under normal (unfinished metal, wood &rolloff) operating conditions.

Underground Diesel Storage Tanks Runoff to Basin B None are expected under normal operating conditions.

Northeast Laydown Area Runoff to Basin A Potential exists for suspended (industrial equipment, unfinished solids and iron to be present inthe metal, wood &concrete) storm water discharge.

Northwest Laydown Area Runoff to Basin A Potential exists for suspended (unfinished metal, wood &concrete) solids and iron to be present in the storm water discharge.

Clean &Dirty Lube Runoff to Basin B Since tanks are located within Oil Storage Tanks secondary containment, no pollutants will be discharged.

Aboveground Lube Oil Tank - Mississippi River None are expected under normal Radial Wells operating conditions.

Aboveground Fuel Oil Tank - Runoff to Basin B None are expected under normal Telecommunications Emergency operating conditions.

Generator Spray Paint Shop (sandblast Runoff to Field Some suspended solids and iron material, pallets &empty drums) Below Shop Area may be present instorm water discharge.

Building and Grounds Area Runoff to Basin A Some iron may be present in storm (metal and equipment) water discharge.

Ballfield Renovation Area Stock Pond Some suspended solids may be present instorm water discharge.

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Regulated Areas of Industrial Activity Regulated Area Drainage Potential Pollutants Fire Training Area (diesel fuel, Runoff to Fire Training Area Some petroleum hydrocarbons and fire extinguishers &foam) Holding Pond suspended solids may be present in storm water discharge.

Spoils Area Runoff to Basin B Some suspended solids and iron may be present in storm water discharge.

Construction Transformers - Runoff to Basin Aor B None are expected under normal Site Wide operating conditions.

ESC Water Softener Unit Runoff to Basin Aand B Some suspended solids inthe form of salts may be present in storm water discharges.

Hydrogen Storage Tank Runoff to Stream A None are expected under normal operating conditions.

Oxygen Storage Tank Runoff to Stream A None are expected under normal operating conditions.

Nitrogen Storage Tank Runoff to Stream A None are expected under normal operating conditions.

Nitrogen Storage Tank Runoff to Basin B None are expected under normal operating conditions.

North Active Security Barrier Runoff to Stream A None are expected under normal operating conditions.

Security Island Active Security Runoff to Basin B None are expected under normal Barrier operating conditions.

GGNSSWPP (REV 13) - 30

ATTACHMENT 11 Storm Water Sampling Data GGNSSWPP (REV 13) - 31

GGNS STORM WATER SAMPLING DATA DATES OUTFALL OIL&GREASE TSS FLOW TRC 1 pH 24 HOUR TOTAL NUMBER [PPM] [PPM] [MGD] PPM [SUI RAINFALL2 ZINC3

[Inches] [PPM]

1/11/2006 007 0 1 0.050 0.16 8.10 1.32 N/A 1/11/2005 013 N/A 23 0.35 N/A 6.83 1.32 N/A 1/11/2005 014 N/A 4 0.19 N/A 7.00 1.32 N/A 1/11/2005 016 N/A N/A 0.042 0 8.12 1.32 N/A 2/8/2005 007 0 7 0.050 0 7.34 0.84 N/A 2/15/2005 007 0 4 0.050 0 7.25 0.64 N/A 3/8/2005 007 0 3 0.050 0 7.42 1.48 N/A 3/8/2005 016 N/A N/A 0.042 0 7.07 1.46 N/A 3/22/2005 007 0 29 2.41 0 7.09 1.0 N/A 4/5/2005 007 0 0 0.050 0 8.17 1.23 N/A 4/5/2005 013 N/A 14 1.2 N/A 7.86 1.23 N/A 4/5/2005 014 N/A 9 0.13 N/A 7.03 1.23 N/A 4/5/2005 016 N/A N/A 0.007 0 8.24 1.23 N/A 4/19/2005 007 0 0 0.050 0 7.68 0.05 N/A 5/10/2005 007 0 5 0.050 0 7.59 0.45 N/A 6/7/2005 007 0 0 0.050 0 7.51 1.14 N/A 6/14/2005 007 0 2 0.050 0 7.33 0.09 N/A 7/5/2005 007 0 0 0.050 0 8.33 0.08 N/A 7/5/2005 013 N/A 6 1.6 N/A 7.62 0.08 N/A 7/5/2005 014 N/A 3 0.13 N/A 8.89 0.08 N/A 7/5/2005 016 N/A N/A 0.042 0 8.66 0.08 N/A 7/19/2005 007 0 0 0.050 0 8.14 0.32 N/A 8/16/2005 007 0 0 0.223 0 7.91 0.11 N/A 11/15/2005 007 0 0 0.050 0 7.08 0.06 N/A 12/06/2005 007 0 1 0.050 0 7.16 0.05 N/A 12/06/2005 016 N/A N/A 0.007 0.26 8.79 0.05 N/A 1/10/2006 007 0 5 0.050 0 8.49 0.31 N/A 1/10/2006 013 N/A 14 0.100 N/A 8.10 0.31 N/A 1/10/2006 014 N/A 5 0.050 N/A 8.92 0.31 N/A 1/10/2006 016 N/A N/A 0.007 0 8.35 0.31 N/A 1/16/2006 007 0 8 0.223 0 8.40 0.79 N/A 2/07/200 007 0 3 0.223 0 7.84 0.43 N/A 2/21/2006 007 0 0 0.050 0 7.63 0.02 N/A 3/21/2006 007 0 17 0.223 0 6.94 2.75 N/A 4/4/2006 007 0 0 0.223 0 6.99 0.40 N/A 4/4/2006 013 N/A 27 0.800 N/A 7.18 0.40 N/A 4/4/2006 014 N/A 6 0.190 N/A 7.82 0.40 N/A 4/4/2006 016 N/A N/A 0.007 0 7.16 0.10 N/A 5/5/2006 007 0 77 0.223 0 8.35 0.76 N/A 5/15/2006 007 N/A 16 N/A N/A N/A 1.26 N/A 5/16/2006 007 N/A 0 N/A N/A N/A 1.26 N/A 5/17/2006 007 N/A 0 N/A N/A N/A 0.05 N/A 5/18/2006 007 N/A 2 N/A N/A N/A 0.05 N/A

)TRC means Total Residual Chlorine 224 hour0.00259 days <br />0.0622 hours <br />3.703704e-4 weeks <br />8.5232e-5 months <br /> GGNS rain gauge measurement, that approximates time of sampling 3Reserved 4 Reserved I Data for the period January 2004 through December 2004 was included inrevision 10.

GGNSSWPP (REV 13) - 32

ATTACHMENT III Annual Storm Water Inspection Form GGNSSWPP (REV 13) - 33

Inspection Report and Certification Form For Storm Water Pollution Prevention Plan Evaluation Baseline Storm Water General NPDES Permit No. MSR000883 Owner and/or Operator:

Facility Name:

Facility Location:

Date and Time:

Inspector(s):

Date of Last Rainfall: Estimated Amount:

Deficiencies Noted During the Inspection (attach additional sheets if necessary):

Corrective Action Needed (attach additional sheets if necessary):

Corrective Action Compliance Schedule:

Based upon this inspection which I or personnel under my direct supervision conducted, I certify that all pollution control measures are adequate and have been implemented and maintained, except for those deficiencies noted above, in accordance with the Storm Water Pollution Prevention Plan filed with the Office of Pollution Control and good engineering practices as required by the above referenced permit.

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations.

I further certify that the Mississippi Office of Pollution Control has been notified of any changes pertinent to our storm water permit as required in Part I.C.

I Authorized Name (Print) Signature Date GGNSSWPP (REV 13) - 34

ATTACHMENT IV Small Construction Project Permit Requirements

[Greater than I acre but less than 5 acres]

Including:

Construction of Access Roads to Test Well and Geologic Core Bore Sites and Test Pits Appendix A: State Small Construction General Permit Requirements Appendix B: Environmental Regulatory Review for the Geologic Core Bore Sites and Test Pits GGNSSWPP (REV 13) - 35

Storm Water Pollution Prevention Plan (SWPPP) for Construction of Access Roads to Test Well and Geologic Core Bore Sites and Test Pits This plan is prepared to comply with the requirements prescribed by the Mississippi Department of Environmental Quality [MDEQJ Small Construction General Permit. As such, this document follows the plan development guidance provided in Part III of the Small Construction General Permit [Appendix A].

Details and additional guidance regarding the development and implementation of this plan were also provided by the following:

Mississippi Storm Water Pollution Prevention Plan Guidance Manual for Construction Activities The Mississippi Department of Environmental Quality [MDEQ] Small Construction General Permit The Grand Gulf Nuclear Station [GGNS] Storm Water Pollution Prevention Plan

[SWPPP]

The GGNS Spill Prevention and Countermeasures Plan [SPCC]

The GGNS National Pollution Discharge Elimination System Permit [NPDES]

RESPONSIBILITIES:

Enercon or their sub-contractors are responsible for determining the appropriate erosion control devices and methodologies and for construction project oversight including verifying compliance with this plan and any appropriate limitations and conditions.

Enercon or their sub-contractors are responsible for construction, construction contractor oversight and implementing and maintaining erosion controls as instructed and or delegated by Entergy Engineering. This includes inspections and erosion control maintenance requirements and compliance with this plan and any appropriate limitations and conditions.

GGNS Chemistry is responsible for obtaining permits, regulatory interpretations and transmitting required regulatory reports or notifications, such as noncompliance reports, to the proper regulatory authority. Chemistry is also responsible for independently verifying compliance with the appropriate regulations and GGNS management expectations.

Enercon or their sub-contractors: Are responsible for complying with applicable regulatory requirements and Entergy procedures and requirements.

GGNSSWPP (REV 13) - 36

PLAN AMENDMENTS: [Part III; Section A., Items 4 and 51 This plan shall be amended and required changes implemented within 15 days after notification by MDEQ that the plan does not meet minimum requirements. In addition this plan shall be amended:

1. Before there is a change in construction, operation, or maintenance which may potentially effect the discharge of pollutants to State waters and,

2. If the plan proves to be ineffective in controlling storm water pollutants including, but not limited to, significant sediment leaving the site and non-functioning Best Management Plans

[BMPs].

COMPLIANCE WITH LOCAL ORDINANCES: [Part Ill; Section B., Items I and 2]

There are no local ordinances mandating additional requirements beyond those already prescribed by the Small Construction General Permit. In addition no storm water discharges will enter a municipal sewer system.

SWPPP DETAILS: [Part III; Section C., Items I - 6)

OWNER/OPERATOR:

Entergy Operations, Incorporated Grand Gulf Nuclear Station [GGNS]

P.O. Box 756 Port Gibson, MS 39150 The following persons have day to day operational control of construction and test activities to ensure compliance with this SWPPP or other permit conditions.

Enercon Oversight and Construction:

Jim Kegerreis 601-437-2348 Contractor: TBD GGNSSWPP (REV 13) - 37

Enercon or their sub-contractors retain ultimate responsibility for determining the proper erosion control methods. Controls should, at a minimum, be in accordance with the standards set forth in "Planning and Design Manual for the Control of Erosion, Sediment and Storm Water" or other recognized manual of design as appropriate for Mississippi.

The planning and design manual can be obtained by contacting MDEQ at 601-961-5171 or may be found electronically at Mississippi State's educational website at http://abe.msstate.edu/csd/p-drn/. In addition, Mississippi's "Storm Water Pollution Prevention Plan (SWPPP) Guidance Manual for Construction Activities" is available by calling MDEQ at 601-961-5171 or on the MDEQ website at www.deq.state.ms.us.

These erosion controls shall address the following minimum components:

Vegetative Practices shall be designed to preserve existing vegetation where possible and re-vegetate disturbed areas as soon as practical after grading or construction. Such practices may include surface roughening, temporary seeding, permanent seeding, mulching, sod stabilization, vegetative buffer strips, and protection of trees.

Structural Practices shall divert flows from exposed soils, store flows or otherwise limit runoff from exposed areas. Such practices may include construction entrance/exit controls, straw bale dikes, silt fences, earth dikes, brush barriers, drainage swales, check dams, subsurface drains, pipe slope drains, level spreaders, drain inlet protection, outlet protection, detention/retention basins, sediment traps, temporary sediment basins or equivalent sediment controls.

Post Construction Control Measures shall be installed to control pollutants in storm water after construction is complete. These controls include, but are not limited to, on-site filtration of run off, flow attenuation using open vegetated swales, exfiltration trenches and natural depressions, constructed wetlands and retention/detention structures. Where needed, velocity dissipation devices shall be placed at detention or retention pond outfalls and along the outfall channel to provide non-erosive flow.

PROJECT SCOPE:

The construction of roads and maintenance of equipment storage areas including the limited removal of trees and the construction of unpaved access roads for the placement of geological/geotechnical test wells, bore holes and test pits. The total acreage that will be disturbed is conservatively estimated at 3.5 acres. The majority of these activities will take place west and south of the existing Protected Area (PA) perimeter.

GGNSSWPP (REV 13) - 38

EROSION AND SEDIMENT CONTROLS:

Primary potential impacts involve the construction of test pits, access roads in upslope areas, steep or unstable slopes, and the removal of trees in the immediate test areas, as required. Note that these areas have been previously disturbed by either silvacultural or previous construction activities and efforts will be made to utilize the existing old access

[logging] roads, where possible.

Other test areas include stabilized existing parking lots, paved roadways, and construction laydown areas minimizing potential surface water runoff impacts related to these sampling activities.

After testing is completed, access roads and similar disturbed areas will be re-vegetated to minimize future potential erosion impacts.

The construction of access roads and the temporary storage of vehicles and testing equipment, such as drilling pipe, are anticipated to have a similar or less impact than those activities typically observed during small scale silvacultural and construction operations.

As mentioned, much of the testing occurs in areas already stabilized and maintained at grade on property primarily covered either by concrete, asphalt or gravel. Draining for these areas is provided by concrete ditches, spillways and catch basins that enter into an unnamed tributary that traverses GGNS property and enters into a sedimentation basin and eventually Hamilton Lake. This tributary is far enough removed from the test access areas to preclude any significant impacts on riparian trees or buffer zones. Storm drains located in the vicinity of these areas also enter directly into a sedimentation basin through National Pollutant Discharge Elimination System [NPDES] Outfall 007. Based upon previous similar testing activities, storm water impacts upon Outfall 007 will be negligible. Storm drains in the vicinity of any test locations may be temporarily covered or otherwise secured to preclude any impact.

The sedimentation basins were excavated during construction of the GGNS facility and were originally designed to slow the flow of storm waters and allow sediments from construction activities to settle out of solution before entering State waters. Although the sedimentation basins have not been maintained to original design specifications they are still functional and provide additional protection by ponding runoff in these controlled areas.

The following controls will also be implemented, as required, to retain sediment on site:

Disturb the smallest area possible by using existing access routes when possible.

GGNSSWPP (REV 13) - 39

Strategically place silt fencing, hay bales, or other barriers as needed to filter and slow storm water runoff.

If required, temporarily cover storm drains to eliminate point sources of contamination.

Use hay bales, silt fencing, berms or other engineering controls to slow rainfall runoff velocities and prevent erosive flows.

Minimize the amount of cut and fill.

NON-STORM WATER DISCHARGES:

Non storm water discharges are regulated by the GGNS NPDES Permit. Contact Chemistry for approval before discharging any non-storm water.

NATIONAL HISTORICAL PRESERVATION ACT:

The Grand Gulf Nuclear Station was originally evaluated by the Mississippi Department of Archives and History during the construction of the facility. This evaluation determined that operation of the station will not result in any impact on historic and archaeological sites in the area [Draft Environmental Statement, United States Regulatory Commission, May 1981, Page 5-7; Final Environmental Statement, United States Regulatory Commission, September 1981, Page 5-7).

NOTE Work orders and procedures must include cultural resource specific written directions for excavation and backfill work which calls for an immediate stop-work order should archeological, historical, or other cultural resources be uncovered during excavation. The construction supervisor is responsible for ensuring work stoppage and for notifying the Environmental Lead* of an inadvertent discovery.

In the event of an inadvertent discovery the Environmental Lead* will determine the inadvertent discovery's significance and if necessary, notify the State Historic Preservation Officer to consult with them regarding the discovery to determine if an additional archeological assessment is needed.

• Environmental Leads:

Rusty Shaw 601-437-7312 John Lassetter 601-437-2115 GGNSSWPP (REV 13) - 40

HOUSEKEEPING PRACTICES:

GGNS requires the following housekeeping practices to minimize contamination of storm water:

Equipment Maintenance and Repair:

Major equipment repairs will be conducted at the Vehicle Maintenance Shop or offsite by the vendor.

Minor field repairs may be performed provided that precautions are taken to assure fuel or oil does not contaminate the ground or storm water.

These precautions include the use of drip pans, containment devices that are impervious to oil or fuel, absorbent pads and/or booms or other devices as required.

In addition, vehicle and equipment maintenance activities should not be performed outdoors during periods of precipitation. The equipment should be relocated, if possible, to an area that provides adequate protection from precipitation. In emergency situations a shelter may be improvised to shield the equipment from precipitation provided that controls are implemented to prevent the contamination of surface storm water runoff.

Concrete Chute Wash Off:

A holding pond must be excavated in a laydown or other area sufficient in size and volume to contain the concrete residue and rinse waters from cement delivery trucks plus additional freeboard to assure that these waters are not mixed and/or discharged with storm water. No other washing will be authorized.

Waste Receptacles:

Waste receptacles such as dumpsters, roll-off boxes and similar devices should be placed at convenient locations. Waste should be regularly collected and disposed of and not allowed to accumulate or overflow containers. In addition, workers should police access, testing, and construction areas to assure that trash and debris does not contaminate or is not removed by storm water run off.

Chemical Use and Storage:

All chemicals must be approved by the Site Chemical Control Coordinator before they are brought on site. After approval each chemical container must retain the proper label(s), including the chemical control label, and be properly stored as directed by the Site Chemical Control Coordinator and in accordance with site safety and fire protection requirements.

GGNSSWPP (REV 13) - 41

Chemicals may not be left unattended. When chemicals are not in use they must be properly secured and stored.

Protective clothing requirements are prescribed by GGNS Industrial Plant Safety.

All personnel, including contractors are required to comply with the appropriate GGNS procedures and expectations at all times.

Sanitary Facilities:

Sanitary facilities are located at various locations. If these are not sufficient portable facilities must be provided that are in good structural condition and routinely serviced.

Secondary Containment:

The storage of fuel and oil is governed by the GGNS Spill Prevention Control and Countermeasures Plan [SPCC]. Temporary fuel and oil storage as well as restrictions on draining water from containment devices must comply with the requirements of this plan.

Temporary fuel and oil containers must have containment of sufficient volume to contain their contents plus 10% additional freeboard. These must also be located in areas where they are protected from damage by vehicular traffic [Review the appropriate Environmental Regulatory Review for more detailed information].

In addition, temporary equipment not in use must also be provided with containment unless equipped with double walled tanks, skid pans or other devices capable of containing the entire contents of the tank.

Water may not be discharged from containment devices if there is a visible sheen or other evidence of contamination. Contact Chemistry for additional guidance prior to discharging potentially contaminated water from containment devices.

Releases of Fuel, Oil or other Substances:

Any spill, regardless of the volume, must be immediately reported to the Control Room [X2374 or Radio Channel 11. The control room will dispatch trained HAZMAT responders if necessary.

If possible, spills should immediately be controlled so they do not mix with storm water or pose a threat to state waters.

GGNSSWPP (REV 13) - 42

All spills must be promptly cleaned and contaminated sediments removed.

Chemistry will provide guidance for the remediation of spills and for the disposal of associated waste materials.

GGNS Chemistry evaluates all spills to determine reportability and the need to contact Federal or State regulatory officials. Verify that Chemistry has been contacted and is aware of the spill.

Chemistry contacts are:

Supervisor: John Lassetter 601-437-2115 Staff: Rusty Shaw 601-437-7312 GGNS procedures and expectations also require that all spills are documented by the Control Room using the Spill Report Form and that the incident is documented using a Condition Report [CR].

Scaled Site Map:

See maps on page 45 and 46.

Implementation Sequence:

Necessary erosion and sedimentation controls described in this plan will be implemented before any construction activities begin:

" Implementation of the testing and associated construction/clearing activities will begin April 1, 2006.

" These activities will be concluded approximately August 1, 2006.

Limitations and Requirements:

The limitations and requirements specified in the MDEQ Small Construction General Permit are included in Appendix A. Please note the following additional comments:

Inspection Requirements [Part IV; Item Cl: Inspections are performed by the person having direct management oversight of the project, or responsible designee, who retains the ability to maintain or modify existing erosion controls or implement additional controls as required. Chemistry makes independent inspections and verifications of compliance including suggestions and recommendations for improving erosion controls, as needed.

Retention of Records [Part IV; Item El: Original inspection forms are maintained with a copy of the SWPPP Permit by the person having direct management oversight of the GGNSSWPP (REV 13) - 43

project, or responsible designee, for inspection by MDEQ. When the project is completed copies of the inspections should be transmitted to file and the originals forwarded to Chemistry to be maintained on file for inspection for three (3) years from the date construction was completed.

Noncompliance Reporting [Part IV; Item F]: Chemistry transmits all regulatory reports and notifications to the proper regulatory authorities. Because a noncompliance has the real potential to result in an NPDES permit exceedance or other regulatory requirement GGNS Chemistry must immediately be made aware of any circumstances that could or do result in a noncompliance with the limitations and requirements specified in the MDEO Small Construction General Permit [Appendix A].

Any noncompliance may constitute a violation of State and Federal law and may provide grounds for an enforcement action GGNSSWPP (REV 13) - 44

Test Monitoring Well and Borehole Locations Note: 6 additional borings are at the proposed intake facility along the Mississippi River shoreline.

,.i( NSS\VPP (REV, 1-)- 45

Proposed Test Pit Locations Test Pits are designated by:

TP-lOO05" pmp w 1*o I GGNSSWPP (REV 13) - 46

APPENDIX A to the Small Construction Project Permit Requirements

[Greater than 1 acre but less than 5 acres]

State [MDEQ] Small Construction General Permit Requirements GGNSSWPP (REV 13) - 47

State of Mississippi Mississippi Department of Environmental Quality (MDEQ)

Office of Pollution Control (OPC)

Water Pollution Control STORM WATER SMALL CONSTRUCTION GENERAL PERMIT THIS CERTIFIES THAT SMALL CONSTRUCTION PROJECTS (EQUAL TO OR GREATER THAN ONE ACRE AND LESS THAN FIVE ACRES) ARE GRANTED PERMISSION TO DISCHARGE STORM WATER ASSOCIATED WITH CONSTRUCTION ACTIVITY UNDER THE TERMS AND CONDITIONS OF THIS PERMIT INTO WATERS OF THE STATE OF MISSISSIPPI in accordance with effluent limitations, inspection requirements and other conditions set forth in Parts I through VII hereof. This permit is issued in accordance with the provisions of the Mississippi Water Pollution Control Law (Section 49-17-1 et seq., Mississippi Code of 1972), and the regulations and standards adopted and promulgated thereunder, and under authority granted pursuant to Section 402(b) of the Federal Water Pollution Control Act.

MISSISSIPPI ENVIRONMENTAL QUALITY PERMIT BOARD Permit luned: Marck 11. 2003 ?emnit No. MSRIS Permit Expires: Februry 29, 2006 GGNSSWPP (REV 13) - 48

STORM WATER SMALL CONSTRUCTION GENERAL NPDES PERMIT TABLE OF CONTENTS Part I. Permit Applicability and Authorization A. Permit Area 3 B. Covered Discharges 3 C. Obtaining Authorization 3 D. On-going Construction Activities 3 E. Allowable Non-Storm Water Discharges 3 F. Responsibility for Permit Compliance 4

0. This Permit Does Not Authorize 4 H. Requiring an Individual Permit 4 Part I. Small Construction Notice of Intent (SCNOI)

A. Small Construction Notice of Intent (SCNOI) 4 B. Where to Submit the Small Construction Notice of Intent if Requested 5 Part III. Storm Water Pollution Prevention Plan (SWPPP)

A. SWPPP Development 5 B. Compliance with Local Storm Water Ordinances 5 C. SWPPP Details I. Owner or Operator 5

2. Erosion and Sediment Controls 5

3. Non-Storm Water Discharges 6

4. Housekeeping Practices 6

5. Prepare Scaled Site Map 7

6. Implementation Sequence 7 Part IV. Limitations and Requirements A. Non-Numeric Limitations 7 B. Implementation Requirements 7 C. Inspection Requirements 8 D. Documentation of Inspections 8 E. Retention of Records 8 F. Noncompliance Reporting 8 G. Termination of Permit Requirements 8 Part V. Other Permit Conditions A. Duty to Comply 8 B. Continuation of the Expired General Permit and Coverages under the Permit 9 C. Duty to Mitigate 9 D. Duty to Provide Information 9 E. Signatory Requirements 9 F. Duly Authorized Representative 9

6. Changes to Authorization 9 H. Certification 9 I. Oil and Hazardous Substance Liability 9 J. Property Rights 9 K. Transfers 10 L. Severability 10 M. Proper Operation and Maintenance 10 N. Bypass Prohibition to

0. Upset Conditions 10 P. Inspection and Entry 10 Q. Permit Actions I0 Part VL Reopener Clause A. Requirement to Obtain Individual Permit 10 B. Permit Modification. 10 Part VII. Definitions II Part VlI. Transfer of Small Construction General Permit Coverage and/or Name Change 13 Part IX. Inspection and Certification Form for Small Construction Erosion and Sediment IS Part X. Small Construction Notice of Intent (SCNOI) 17 GGNSSWPP (REV 13) - 49

Part L Permit Applicability and Authorization A. Pernmt Area. The permit covers all areas of the State of Mississippi.

B. Covered Discharges. Discharges composed entirely of storm water from small construction activities, except as noted in Part I. E., including clearing, grading. excavating and other land disturbing activities equal to or greater than one (1) acre and less than five (5) acres. I These discharges are automatically designated as small construction activities under the National Pollutant Discharge Elimination System (NPDES) storm water program and are automatically covered under this permit. Small construction activities disturbing less than one (I) acre are designated if:

• The project is part of a larger common plan of development or sale with a cumulative planned disturbance of equal to or greater than one (I) acre and less than five (5) acres (for example, individual or commercial lots that are part of a subdivision or a commercial development that initially impacts less than one (I) acre but will ultimately exceed the one (l) acre threshold2), or a The Executive Director of the Mississippi Department of Environmental Quality (MDEQ) designates the construction activity based on the potential for contribution to a violation of a water quality standard or for significant contribution of pollutants to waters of the State.

Small construction activity does not include routine maintenance that is performed to maintain the original line and grade, hydraulic capacity. and original purpose of the facility (for example, existing ditches, channels, or other similar storm water conveyances, as well as routine grading of existing dirt roads, asphalt overlays of existing roads, and other similar maintenance activities).

C. Obtaining Authorization. Owners or operators are authorized to discharge storm water associated with small construction activity under the terms and conditions of this permit upon commencement of small construction land disturbing activities (i.e., Construction may begin after development of the required Storm Water Pollution Prevention Plan (SWPPP) and the completion of the Small Construction Notice of Intent (SCNOI)).

D. On-going Construction Activities. Projects that are on-going as of March 10. 2003 and are equal to or greater than one (I) acre and less than five (5) and do not have coverage under Construction General Permit MSRIO must obtain coverage by complying with the terms and conditions of this permit.

E. Allowable Non-Storm Water Discharges. Owner or operators are authorized for the following non-storm water discharges. Except for flows from fire fighting activities, sources of non-storm water below that are combined with storm water discharges associated with construction activity must be identified in the Storm Water Pollution Prevention Plan (SWPPP). The SWPPP must identify and ensure the implementation of appropriate pollution prevention measures for the non-storm water component(s) of the discharge.

" Discharges from fire-fighting activities

" Fire hydrant flushings "Waters used to wash vehicles where detergents are not used "Water used to control dust

" Potable water sources including water line flushings "Routine external building wash down that does not use detergents "Pavement wash waters where spills or leaks of toxic or hazardous materials have not occurred (unless all spilled material has been removed) and where detergents are not used "Uncontaminated air conditioning or compressor condensate

" Uncontaminated ground water or spring water "Foundation or footing drains where flows are not contaminated with process materials such as solvents 1 This includes the total areadisturbed over the course of the project. Forhome sites - a minimum of 10,000ft2 per home site or the entire lot, if smaller, shall be included.

2Forsubdivision development, if the total acreagedisturbedfor the entire development is 5 acres orgreater then all lots are covered by Mississippi'sStorm Water ConstructionGeneral Permitfor constructionactivity over 5 acres (Large Construction).

GGNSSWPP (REV 13) - 50

F. Responsibility for Permit Compliance. The owner(s) of the property and any operator(s) associated with small construction activity on the property shall have joint and several responsibility for compliance with this permit.

G. This Permit Does Not Authorize:

" Discharges of hazardous substances or oil. This permit does not authorize the discharge of hazardous substances or oil resulting from an on-site spill.

" Post Construction Discharges. This permit does not authorize storm water discharges that originate from the site after construction activities have been completed and the site has undergone final stabilization.

" Discharges Covered by Another Permit. This permit does not authorize storm water discharges associated with construction activity that have been covered under an individual permit in accordance with Part I.

H. of this permit.

" Discharges Threatening Water Quality. This permit does not authorize storm water discharges from construction sites that the Executive Director determines will cause, or have reasonable potential to cause or contribute to, violations of water quality standards. Where such determinations have been made, the Mississippi Environmental Quality Permit Board (Permit Board) may notify the owner or operator that an individual permit application is necessary in accordance with Part I. H. of this permit. However, the Permit Board may authorize coverage under this permit after appropriate controls and implementation procedures designed to bring the discharges into compliance with water quality standards have been included in the Storm Water Pollution Prevention Plan.

" Discharges to Impaired Receiving Waters. The SWPPP must specifically identify Best Management Practices (BMPs) which ensure storm water will not cause or contribute to non-attainment of a water quality standard. In cases where the Permit Board becomes aware of potential impairment due to small construction activities, the Permit Board may require the submittal of the SWPPP in order to ascertain whether the selected BMPs are sufficient to comply with requirements of this permit or any other requirements of the Permit Board. The list of impaired receiving waters may be found on the MDEQ web site at www.deq.state.ms.us or by calling 601-961-5171.

H. Requiring an Individual Permit Upon notification of a small construction project, the Permit Board may require an alternate permit. The Permit Board may require any owner or operator of land disturbing activities of equal to or greater than one (1) acre and less than five (5) acres to apply for and obtain an individual NPDES permit. Any interested person may petition the Permit Board to take action under this paragraph. The Permit Board may require any small construction owner or operator to apply for an individual NPDES permit only if the owner or operator has been notified in writing. This notice shall include reasons for this decision, an application form and a filing deadline. The Permit Board may grant additional time upon request.

Part II. Small Construction Notice of Intent (SCNOI)

A. Small Construction Notice of Intent (SCNOI). Prior to the commencement of small construction activity, the owner or operator must complete a Small Construction Notice of Intent (SCNOI). The SCNOI and SWPPP described in Part Ill shall be submitted to the Mississippi Department of Environmental Quality (MDEQ) only upon request from MDEQ; however, the SCNOI and SWPPP must be maintained at the permitted site or locally available in case inspector review is necessary. Failure to complete a SCNOI prior to the commencement of construction activity or to submit a SCNOI when requested is a violation of State regulations. The SCNOI shall be retained by the owner or operator as required by Part IV. E. of this permit. Attachments to the SCNOI must include: a U.S. Geological Survey quadrangle map or copy (only if required to be submitted to MDEQ) showing site location and a Storm Water Pollution Prevention Plan (SWPPP).

GGNSSWPP (REV 13) - 51

B. Where to Submit the Small Construction Notice of Intent, if Requested. Complete and appropriately signed SCNOI forms must be submitted to:

Chief, Environmental Permits Division MS Dept of Environmental Quality, Office of Pollution Control P.O. Box 10385 Jackson, Mississippi 39289-0385 Part I[f. Storm Water Pollution Prevention Plan (SWPPP)

A. SWPPP Development. A SWPPP shall be developed and implemented by the owner or operator of a small construction project. The SWPPP must include a description of appropriate control measures (i.e., BMPs) that will be implemented as part of the construction activity to control pollutants in storm water discharges.

I. The SWPPP shall be retained at the permitted site or locally available. A copy of the SWPPP must be made available to the MDEQ inspectors for review at the time of an on-site inspection.

2. BMPs shall be in place upon commencement of construction.

3. The Executive Director of MDEQ may notify the owner or operator at any time that the SWPPP does not meet the minimum requirements of this permit. After notification, the owner or operator shall amend the SWPPP, implement the changes and certify in writing to the Executive Director that the requested changes have been made. Unless otherwise provided by the Executive Director, the requested changes shall be made within 15 days.

4. The owner or operator shall amend the SWPPP and implement the changes before there is a change in construction, operation, or maintenance, which may potentially effect the discharge of pollutants to State waters.

5. The owner or operator shall amend the SWPPP and implement the changes if the SWPPP proves to be ineffective in controlling storm water pollutants including, but not limited to, significant sediment leaving the site and non-functioning BMPs.

B. Compliance with Local Storm Water Ordinances.

I. In addition to the requirements of this permit, the SWPPP shall be in compliance with all local storm water ordinances and shall provide a brief description of applicable local erosion and sediment controls and post-construction BMPs.

2. When storm water discharges into a municipal storm sewer system, the owner or operator must make the SWPPP available to the municipal authority upon request.

C. SWPPP Details.

I. Owner or Operator. The SWPPP shall identify the "owner or operator" as defined in Part Vill. of this permit. The operator's name, complete mailing address and telephone number(s) shall be identified on the plan.

2. Erosion and Sediment Controls. The owner or operator shall list and describe controls appropriate for the construction activities and the procedures for implementing such controls. Controls shall be designed to retain sediment onsite and should:

" Divert upslope water around disturbed areas

" Limit exposure of disturbed areas to the shortest time possible

" Disturb the smallest area possible

" Preserve existing vegetation where possible, especially trees

" Preserve vegetated buffer zones around any creek, drain, lake, pond or wetland

• Slow rainfall runoff velocities to prevent erosive flows

" Avoid disturbing sensitive areas such as:

- Steep and/or unstable slopes

- Land upslope of surface waters

- Areas with erodible soils GGNSSWPP (REV 13) - 52

- Existing drainage channels

• Transport runoff down steep slopes through lined channels or piping

• Minimize the amount of cut and fill

• Re-vegetate disturbed areas as soon as possible

• Implement best management practices to mitigate adverse impacts from storm water runoff; and

• Remove sediment from storm water before it leaves the site by allowing runoff to pond in controlled areas to drop out sediment

• Filter runoff by using natural vegetation, brush barriers, silt fences, hay bales. etc.

At a minimum, the controls must be in accordance with the standards set forth in " Planning and Design Manual for the Control of Erosion, Sediment & Stormwater," or other recognized manual of design as appropriate for Mississippi. The planning and design manual can be obtained by calling 601/961-5171 or may be found electronically at Mississippi State's educational web site at http://abe.msstate.edu/csdlp-dm/. In addition, Mississippi's "Storm Water Pollution Prevention Plan (SWPPP) Guidance Manual for Construction Activities" is available by calling 6011961-5171 or on the MDEQ website at www.deq.state.ms.us. The erosion and sediment controls shall address the following minimum components.

a. Vegetative practices shall be designed to preserve existing vegetation where possible and revegetate disturbed areas as soon as practicable after grading or construction. Such practices may include surface roughening, temporary seeding, permanent seeding, mulching, sod stabilization, vegetative buffer strips, and protection of trees.

b. Structural practices shall divert flows from exposed soils, store flows or otherwise limit runoff from exposed areas. Such practices may include construction entrance/exit, straw bale dikes, silt fences, earth dikes, brush barriers, drainage swales, check dams. subsurface drains, pipe slope drains, level spreaders, drain inlet protection. outlet protection, detention/retention basins, sediment traps, temporary sediment basins or equivalent sediment controls.

c. Post construction control measures shall be installed to control pollutants in storm water after construction is complete. These controls include, but are not limited to on-site infiltration of runoff, flow attenuation using open vegetated swales, exfiltration trenches and natural depressions, constructed wetlands and retention/detention structures. Where needed, velocity dissipation devices shall be placed at detention or retention pond outfalls and along the outfall channel to provide a non-erosive flow.

3, Non-Storm Water Discharges. Except for flows from fire fighting activities, sources of non-storm water listed in Part 1.E. of this permit that are combined with storm water discharges associated with construction activity must be identified in the SWPPP. The SWPPP must identify and ensure the implementation of appropriate pollution prevention measures for the non-storm water component(s) of the discharge.

4. Housekeeping Practices. The owner or operator shall describe and list practices appropriate to prevent pollutants from entering storm water from construction sites due to poor housekeeping. The owner or operator shall:

" designate areas for equipment maintenance and repair and concrete chute wash off:

" provide waste receptacles at convenient locations;

" provide regular collection of waste;

" provide protected storage areas for chemicals, paints, solvents, fertilizers, and other potentially toxic materials;

" provide adequately maintained sanitary facilities; and provide secondary containment around on-site fuel tanks.

Releases into the environment of hazardous substances, oil. and pollutants or contaminants, which pose tLihreat to applicable water quality standards or causes a film, sheen or discoloration of State waters, shall be reported to the:

• Mississippi Emergency Management Agency (601) 352-9100

" National Response Center 1-800-424-8802 GGNSSWPP (REV 13) - 53

5. Prepare Scaled Site Map. The owner or operator shall prepare a scaled site map showing total area of the site, original and proposed contours (if practicable), direction of flow of storm water runoff, adjacent receiving water bodies, north arrow, all erosion & sediment controls (vegetative and structural), post construction control measures as described in Part Ill. C. 2. of this permit, and an estimate of the pre and post construction runoff coefficients of the site (see runoff coefficients in Part VIf.) and the increase in impervious area.

6. Implementation Sequence. The owner or operator shall prepare an orderly listing which coordinates the timing of all major land-disturbing activities together with the necessary erosion and sedimentation control measures planned for the project.

Part IV. Limitations and Requirements A. Non-Numeric Umitations.

Storm water discharges shall be free from:

1.debris, oil, scum, and other floating materials other than in trace amounts

2. eroded soils and other materials that will settle to form objectionable deposits in receiving waters

3. suspended solids, turbidity and color at levels inconsistent with the receiving waters

4. chemicals in concentrations that would cause violation of State Water Quality Criteria in the receiving waters B. Implementation Requirements&

The owner or operator shall:

I. implement the SWPPP as required;

2. install downslope and perimeter controls before any major land disturbing activities;

3. install needed erosion controls even if they may be located in the way of subsequent activities, such as utility installation, grading or construction. It shall not be an acceptable defense that controls were not installed because subsequent activities would require their replacement or cause their destruction;

4. implement controls as needed to prevent erosion and adverse impacts to receiving streams and shall install additional and/or alternative erosion and sediment controls when existing controls prove to be ineffective in preventing sediment from leaving the site;

5. maintain all erosion and sediment controls. As a minimum accumulated sediment shall be removed from controls when it reaches 113 to 1/2 the height of the control and properly disposed. Nonfunctioning controls shall be repaired, replaced or supplemented with functional controls within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery or as soon as field conditions allow;

6. implement the appropriate temporary or permanent vegetative practices within seven calendar days when a disturbed area will be left undisturbed for thirty days or more;

7. minimize off-site vehicle tracking of sediments;

8. remove any off-site accumulations of sediment at a frequency sufficient to minimize offsite impacts (e.g., fugitive sediment in street could be washed into storm sewers by the next rain and/or pose a safety hazard to users of public streets); and

9. comply with applicable State or local waste disposal. sanitary sewer or septic system regulations.

C. Inspection Requirements. Inspection of all erosion controls and other SWPPP requirements shall be performed during land disturbing activities. Inspections shall be performed:

I. at least once a week;

2. within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the end of a storm event of a half-inch or greater;,

3. as often as is necessary to ensure that appropriate erosion and sediment controls have been properly constructed and maintained and determine if additional or alternative control measures are required.

D. Documentation of Inspections. All inspections required by Part IV. C. of this permit must be documented and certified according to Part V. H. of this permit (see Part IX Inspection Form). Documentation must include the day and time the inspection was performed, who performed the inspection, any deficiencies noted, and corrective action needed. Documentation of all inspections must be kept with the SWPPP. Inspections must continue until such time that planned construction activities have been completed, land disturbing activities have ceased and disturbed areas have been stabilized with no significant erosion occurring.

GGNSSWPP (REV 13) - 54

E. Retention of Records. All records, reports and information resulting from activities required by this permit shall be retained by the owner or operator, on-site if practicable. for a period of at least three years from the date construction was completed.

F. Noncompliance Reporting.

1. Anticipated Noncompliance. The owner or operator shall give at least 10 days advance notice, if possible, before any planned noncompliance with permit requirements. Giving notice of planned or anticipated noncompliance does not immunize the owner or operator from enforcement for that noncompliance.

2. Unanticipated Noncompliance. The owner or operator shall notify the MDEQ orally within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time he or she becomes aware of unanticipated noncompliance. A written report shall be provided to the MDEQ within 5 working days of the time he or she becomes aware of the circumstances. The report shall describe the cause. the exact dates and times, steps taken or planned to reduce, eliminate, or prevent reoccurrence and, if the noncompliance has not ceased, the anticipated time for correction.

G. Termination of Permit Requirements.

1. If a SCNOI has not been requested by the Permit Board (SCNOI not submitted to MDEQ). Upon successful completion of all permanent erosion and sediment controls, inspections and reporting requirements are no longer required. The owner or operator must record the date of completion of all permanent erosion and sediment controls on the final inspection report.

2. If a SCNOI has been requested by the Permit Board (SCNOI submitted to MDEQ). Upon successful completion of all permanent erosion and sediment controls for a small construction project a written notification of such shall be submitted to the MDEQ. All inspection forms described in Part IV.

D. of this permit and provided in Part IX of this permit must be attached. Coverage is not terminated until done so in writing by the MDEQ.

Part V. Other Permit Conditions A. Duty to Comply. Any permit noncompliance constitutes a violation of the Mississippi Air and Water Pollution Control Law and is grounds for enforcement action or requiring permit application in accordance with Part 1.H.

of this permit. It shall not be a defense in an enforcement action that it would have been necessary to halt or reduce the regulated activity in order to maintain compliance with the conditions of this permit.

B. Continuation of the Expired General Permit and Coverages under the Permit. All general permits and coverages shall remain in full force and effect until the Permit Board makes a final determination regarding any reissuance, modification, or revocation.

C. Duty to Mitigate. The owner or operator shall take all reasonable steps to minimize or prevent any discharge in violation of this permit, which is likely to adversely affect human health or the environment.

D. Duty to Provide Information. The owner or operator shall furnish to the Permit Board, within a reasonable time, any information that the Permit Board may request to determine compliance with this permit.

E. Signatory Requirements. All SCNOIs shall be signed as follows:

I. For a corporation by a responsible corporate officer. For this permit, a responsible corporate officer means: (a) a president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision-making functions for the corporation; or (b) the manager of one or more manufacturing, production or operating facilities employing more than 250 persons or having gross annual sales or expenditures exceeding $25,000,000 din second-quarter 1980 dollars) if authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures;

2. For a partnership or sole proprietorship by a general partner or the proprietor, respectively; or GGNSSWPP (REV 13) - 55

3. For a municipal, State, Federal, or other public agency by either a principal executive officer or ranking elected official. For purposes of this section, a principal executive officer of a Federal agency includes: (a) the chief executive officer of the agency, or (b) a senior executive officer having responsibility for the overall operations of a principal geographic unit of the agency.

F. Duly Authorized Representative. All reports required by this permit and other information requested by the Permit Board shall be signed by a person described in Part V. E., above, or by a duly authorized representative of that person. A person is duly authorized representative when:

I. the authorization is made in writing by a person described in Part V. E., above, and submitted to the Permit Board, if requested;

2. the authorization specifies either an individual or a position having responsibility for the overall operation of the regulated activity, such as manager, owner or operator, superintendent or one having overall environmental responsibility (a duly authorized representative may be a named individual or any individual occupying a named position).

G. Changes to Authorization. If an authorization is no longer accurate because a different individual or position has permit responsibility, a new authorization satisfying the above requirements must be submitted to the Permit Board prior to or together with any reports, information or applications signed by the representative.

H. Certification. Any person signing documents under this section shall make the following certification: I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is. to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

1. Oil and Hazardous Substance Liability. Nothing in this permit shall relieve the owner or operator from responsibilities, liabilities, or penalties under Section 311 of the Clean Water Act (CWA).

J. Property Rights. The issuance of this permit does not convey any property rights of any sort, nor any exclusive privileges, nor does it authorize any injury to private property nor any invasion of personal rights, nor any infringement of Federal. State or local laws or regulations.

K. Transfers. Coverage under this permit is transferable after the former coverage recipient and new coverage recipient complete Form VIII. This form must be kept with your records. Submit to MDEQ only if an SCNOI has been submitted.

L. Severability. The provisions of this permit are severable, and if any provision of this permit. or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit shall not be affected thereby.

M. Proper Operation and Maintenance. The owner or operator shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the owner or operator to achieve compliance with the conditions of this permit including the storm water pollution prevention plan. Proper operation and maintenance includes adequate laboratory controls with appropriate quality assurance procedures and requires the operation of backup or auxiliary facilities when necessary to achieve compliance with permit conditions.

N. Bypass Prohibition. Bypass (see 40 CFR 122.41(m)) is prohibited and enforcement action may be taken against a owner or owner or operator for a bypass, unless: (a) The bypass was unavoidable to prevent loss of life, personal injury, or severe property damage; (b) There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied if the owner or operator should, in the exercise of reasonable engineering judgement, have installed adequate backup equipment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and (c) The owner or operator submitted notices per Part IV. G. of this permit.

GGNSSWPP (REV 13) - 56

0. Upset Conditions. An upset (see 40 CFR 122.41(n)) constitutes an affirmative defense to an action brought for noncompliance with technology-based permit limitations if a permittee shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant evidence, that: (1) An upset occurred and the permittee can identify the specific cause(s) of the upset, (2) The permitted facility was at the time being properly operated, (3) The permittee submitted notices per Part IV. G. 2. of this permit, and (4) The permittee took remedial measures as required under Part V. C. of this permit. In any enforcement proceeding, the permittee has the burden of proof that an upset occurred. No determination made during administrative review of claims that noncompliance was caused by upset, and before an action for noncompliance, is final administrative action subject to judicial review.

P. Inspection and Entry. The owner or operator shall allow the MDEQ staff or an authorized representative, upon the presentation of credentials and other documents as may be required by law, to.

I. enter upon the premises where a regulated activity is located or conducted or where records must be kept under the conditions of this permit;

2. have access to and copy at reasonable times any records that must be kept under the conditions of this permit; and

3. inspect at reasonable times any facilities, equipment or project site.

Q. Permit Actions. This permit may be modified, revoked and reissued, or terminated for cause. A request by the owner or operator for permit modification, revocation and reissuance, or termination, or a certification of planned changes or anticipated noncompliance does not stay any permit condition.

Part VI. Reopener Clause A. Requirement to Obtain Individual PermiL If there is evidence indicating potential or realized impacts on water quality due to storm water discharge covered by this permit, the owner or operator may be required to obtain individual permit in accordance with Part I. H. of this permit.

B. Permit Modification. Permit modification or revocation will be conducted according to 40 CFR 122.62, 122.63, 122.64 and 124.5.

Part VII. Definitions Best Management Practices (BMPs) means schedules of activities, prohibitions of practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants to waters of the United States. BMPs also include treatment requirements, operating procedures, and practice to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw material storage.

Control Measure as used in this permit, refers to any Best Management Practice or other method used to prevent or reduce the discharge of pollutants to waters of the United States.

Commencement of Construction Activities means the initial disturbance of soils associated with clearing, grading, or excavating activities or other construction-related activities.

Commission means the Mississippi Commission on Environmental Quality.

Clean Water Act "CWA" refers to the Federal Water Pollution Control Act, 33 U.S.C. section 1251 et seq.

Discharge of Storm Water Associated with Small Construction Activity as used in this permit, refers to a discharge of pollutants in storm water runoff from areas where soil disturbing activities (e.g.. clearing, grading, or excavation),

construction materials or equipment storage or maintenance (e.g., fill piles, borrow area, concrete truck washout, fueling), or other industrial storm water directly related to the construction process (e.g., concrete) are located.

Executive Director means the Executive Director of the Department of Environmental Quality.

Facility or Activity means any NPDES "point source" or any other facility or activity (including land or appurtenances thereto) that is subject to regulation under the NPDES program.

GGNSSWPP (REV 13) - 57

Large Construction Activity includes clearing, grading, and excavating resulting in a land disturbance that will disturb equal to or greater than five (5) acres of land or will disturb less than five (5) acres of total land area but is part of a larger common plan of development or sale that will ultimately disturb equal to or greater than five (5) acres. Large construction activity is covered by another general permit.

Larger Common Plan of Development or Sale means a contiguous area where multiple separate and distinct construction activities are occurring under one plan. The plan in a common plan of development or sale is broadly defined as any announcement or piece of documentation (including a sign, public notice or hearing, sales pitch, advertisement, drawing, permit application, zoning request, computer design, etc.) or physical demarcation (including boundary signs, lot stakes, surveyor markings, etc.) indicating that construction activities may occur on a specific plot.

Operator for the purpose of this permit and in the context of storm water associated with construction activity, means any party associated with a construction project that meets either of the following two criteria:

I. The party has operational control over construction plans and specifications, including the ability to make modifications to those plans and specifications; or

2. The party has day-to-day operational control of those activities at a project which are necessary to ensure compliance with a storm water pollution prevention plan for the site or other permit conditions (e.g., they are authorized to direct workers at a site to carry out activities required by the SWPPP or comply with other permit conditions). This definition is provided to inform permittees of MDEQ's interpretation of how the regulatory definitions of "owner or operator" and "facility or activity" are applied to discharges of storm water associated with construction activity.

Owner or operator means the owner or operator of any "facility or activity" subject to regulation under the NPDES program.

Permit Board means the Mississippi Environmental Quality Permit Board established pursuant to Miss. Code Ann. § 49-17-28.

Pollutant is defined at 40 CFR 122.2. A partial listing from this definition includes: dredged spoil, solid waste, sewage, garbage, sewage sludge, chemical wastes, biological materials, heal, wrecked or discarded equipment. rock, sand, sediment, silt, cellar dirt, and industrial or municipal waste.

Runoff Coeffident means the fraction of total rainfall that will appear at the conveyance as runoff (see values below).

Successful Completion of all permanent erosion and sediment controls means when land disturbing construction activities have been completed and disturbed areas have been stabilized with no significant erosion occurring.

Small Construction Activity is defined at 40 CFR 122.26(b)( 15) and incorporated here by reference. A small construction activity includes clearing, grading, and excavating resulting in a land disturbance that will disturb equal to or greater than one (1) acre and less than five (5) acres of land or will disturb less than one (1) acre of total land area but is part of a larger common plan of development or sale that will ultimately disturb equal to or greater than one (I) acre and less than five (5) acres. Small construction activity does not include routine maintenance that is performed to maintain the original line and grade, hydraulic capacity, or original purpose of the facility.

Storm Water means rainfall runoff, snowmelt runoff, and surface runoff.

Storm Water Pollution Prevention Plan "SWPPP" means a plan that includes site map(s), an identification of construction/contractor activities that could cause pollutants in the storm water, and a description of measures or practices to control these pollutants.

GGNSSWPP (REV 13) -58

Values of Runoff Coefficient C:

Lawns:

Sandy soil, flat 2%0.05-0.10 Sandy soil, average, 2-7%0. 10-0.15 Sandy soil, steep, 7% 0.15-0.20 Heavy soil, flat, 2% 0.13-0.17 Heavy soil, average, 2-7% 0.18-0.22 Heavy soil, steep, 7% 0.25-0.35 Business:

Downtown areas 0.70-0.95 Neighborhood areas 0.50-0.70 Residential:

Single family areas 0.30-0.50 Multi units, detached 0.40-0.60 Multi units, attached 0.60-0.75 Residential:

Suburban 0.25-0.40 Apartment dwelling areas 0.50-0.70 Industrial:

Light areas 0.50-0.80 Heavy areas 0.60-0.90 Parks, cemeteries 0.10-0.25 Playgrounds 0.20-0.35 Railroad yard areas 0.20-0.40 Unimproved areas 0.10-0.30 Streets:

Asphalt 0.70-0.95 Concrete 0.80-0.95 Brick 0.70-0.85 Drives and walks 0.75-0.85 Roofs 0.75-0.95 GGNSSWPP (REV 13) - 59

Part VIII. Transfer of Small Construction General Permit Coverage and/or Name Change Instructions: For Ownership Change-Complete all Items on this page (except Item VIII) and reverse side.

For Name Change Only-Complete Items 1,II, V, VI, VII, V III, and reverse side.

Item I. Item II.

Facility Name: Responsible official after transfer or name change:

Location: (Do Not Use P.O. Box) Name:

Street:

Title:

Mailing Address:

City: State: MS Zip: Street/P.O.

Box:

County:

City: State: - Zip:

Telephone:

Telephone (

Item IIl. Item IV.

Previous Permitteel: New Permitteel:

Mailing Address:

StreetlP.O. Box: Mailing Address:

Street/P.O.

City: State: Zip: Box:

Telephone: ( .)_City: State: __ Zip:

Telephone:

( .)

Item V. Item VI.

Industrial Activity SIC Code: Will Facility Operations Change? Yes __ No Brief

Description:

If yes, the appropriate applications and permits may required modification prior to change.

Item VII. Item VIII.

Will Facility Name Change? Yes____ No__ Signature for Name Change If Yes, Provide New Name for Permit Coverage. Print Name:

New Name:. Authorized Signature2:

Title:

Date:

Item IX.

We the undersigned transfer permit coverage MSR1 5 .- - (complete If known)

From:

To: Acquisition Date:

By signature below, the new permittee certifies that they are aware of the requirements of the Small Construction General Permit and agrees to accept responsibility and liability for permit compliance. The previous permittee by signature below Is transferring permit coverage to the new permittee.

Print New Permittee' Name Print Previous Permitteel Name 2

New Authorized Signature- Previous Authorized Signature Title Date Title Date 2 Permittee is a company or individual that is covered under the general permit.

'A Authorized Signature must be owner or operator.

Page I of 2 January 2003 GGNSSWPP (REV 13) - 60

Item X. Storm Water (Check One)

___The recipient certifies that they have received a copy of the SWPPP from the original owner.

_The recipient is developing a new SWPPP.

If other environmental permits are involved please contact MDEQ at 601I961-5171 for the appropriate MDEQ transfer form or see MDEQ's web site at www.deq.state.ms.us Submit to MDEQ only if an SCNOI has been submitted. If not submitted, you must keep this form with your records.

Page 2 of 2 SEPTEMBER 1999 GGNSSWPP (REV 13) - 61

Part IX. INSPECTION AND CERTIFICATION FORM FOR SMALL CONSTRUCTION EROSION AND SEDIMENT CONTROLS This form shall be kept on-site unless required to be submitted to MDEQ (see Part IV. G.)

Inspections must be done weekly and after a half-inch rainfall event.

Coverage number if SCOI submitted (MSR15 - - .

(Please Print)

Name:

Project Name:

Project Street Address: _

Project City and County:

Startup Date:

Mailing Address:

Mailing City/State/Zip Telephone Number _

Inspection Log Date and Time After a Half-inch Rain? Any Deficiencies Inspector(s)

Observed?

Yes or No Yes or No Yes or No Yes or No Yes or No Yes or No Yes or No Yes or No Yes or No Yes or No Deficiencies Noted During any Inspection (give date(s); attach additional sheets if necessary):

Corrective Action Taken or Planned (give date(s)); (attach additional sheets if necessary):

Based upon this inspection which I or personnel under my direct supervision conducted, I certify that all erosion and sediment controls have been implemented and maintained, except for those deficiencies noted above, in accordance with the Storm Water Pollution Prevention Plan filed with the Office of Pollution Control and sound engineering practices as required by the above referenced permit. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations.

Authorized Name (Print) Signature Date If requested, mail to: Chief, Environmental Permits Division; Mississippi Department of Environmental Quality P.O. Box 10385; Jackson, MS, 39289-0385 GGNSSWPP (REV 13) - 62

APPENDIX B To the Small Construction Permit Requirements

[Greater than 1 acre but less than 5 acres]

Construction of Access Roads to Test Well and Geologic Core Bore Sites and Test Pits Environmental Regulatory Review GGNSSWPP (REV 13) - 63

ATTACHMENT 9.2 ENVIRONMENTAL REVIEW FORM (TYPICAL)

SHEET 1 of 1

1. Facility: Grand Gulf Nuclear Station

2. Document Number: Grand Gulf COL

3. ER Number: NLA

4. Activity Reviewed: GeotechnicaVaeoloaical investigation work

5. Complete Screening Below (as applicable to each site):

Within Scope Modifcation/Revision/

Reference Approval Needed Section 2.0[1 ] References 0 Yes 0 No X N/A Section 2.0[21 References X Yes 0 No 0 N/A Section 2.0[4] References (ANO) 0 Yes 0 No X N/A 01 Yes 0 No Section 2.0[5] References (GGNS) X Yes 0 No 0 N/A C Yes X No Section 2.0[6] References (IP2) CJ Yes C1 No X N/A 01 Yes 0 No Section 2.0[7] References (IP3) [] Yes 0 No X N/A 0 Yes 0 No Section 2.0[8] References (JAF) 0 Yes C3 No X N/A 0 Yes 0 No Section 2.0[9] References (PNPS) EC Yes C3 No X N/A [] Yes [3 No Section 2.0[10] References (RBS) 0 Yes 0 No X N/A C Yes 0 No Section 2.0[ 11] References (VYNPS) 0 Yes 0 No X N/A 0 Yes 0 No Section 2.0[12] References (W3) 0 Yes 0 No X N/A C Yes 0 No

6. Ifwithin scope, attach cited relerence(s) and appropriate section(s) along with a brief discussion:

7. If a modification, revision or approval is needed, attach a brief discussion:

8. Prepared By: D.K. Crawley Date: 0/20/2006 GGNSSWPP (REV 13) - 64

ATTACHMENT 9.3 ENVIRONMENTAL EVALUATION FORM (TYPICAL)

SHEET 1 OF 1

1. Document Evaluated: Grand Gulf COL

2. Description of proposed change (attach additional sheets if needed):

Geotechnical/geological investigation work

3. Analysis of environmental impact (attach additional sheets if needed):

See Attached Regulatory Review

4. If applicable, alternatives for reducing environmental impact (attach additional sheets if needed):

N/A

5. Summary of basis for conclusions (attach additional sheets if needed):

See Attached Regulatory Review

6. Significant Adverse Environmental Impact Exists: 0 Yes X No

7.

References:

(attach additional sheets if needed):

See Attached Regulatory Review TOT. PREPARER DATE REVIEWER DATE PGS 9 D.K. Crawley 03/20/2006 R.D. Shaw 03/22/2006 GGNSSWPP (REV 13) - 65

ENVIRONMENTAL REGULATORY REVIEW ER: N/A Date: 02/28/2006 Reviewer: D.K. Crawley Activity: Geotechnical/geological investigation work This review is required by the following: Grand Gulf COL Site Activity Review Form Items:

N/A 50.59 Screening Items:

N/A Air OperatingPermit: N/A The GGNS Air Operating Permit [Mississippi Permit No: 0420-000231 does not regulate or prescribe limitations and conditions for geotechnical/geologic investigations provided that permanent fuel burning engines are not installed to facilitate the activities. [This implements the Clean Air Act regulations referenced in EN-EV-)115; Section 2, Items 2 and 5(c).]

NationalPollutionDischargeElimination System Permit [NPDES]: N/A This activity will not create any new or additional discharges or the addition of any chemicals requiring either a modification to the GGNS NPDES Permit or notification to the state permitting authority. The state permitting authority independently verified this - see GTC 2006/00007 and GTC 2006/00011. [This implements the Clean Water Act regulationsreferenced in EN-EV-1 15; Section 2, Items 2 and 5(g).]

Storm Water Permit/Plan:N/A This activity does not initially involve any construction or land disturbance in excess of 1 acre and does not add a new source of industrial activity that would require a either a Construction Notice of Intent or an amendment to the GGNS Storm Water Plan.

NOTE When it is determined that land disturbances such as bulldozing, tree clearing, equipment storage, or other construction activities inclusive to this project have the potential to exceed I acre; construction work must be stopped prior to exceeding the I acre limitation until a Construction Permit is transmitted to the state permitting authority.

If this work continues to expand and reaches the potential to exceed 5 acres, construction work must be stopped prior to exceeding the 5 acre limitation until the site environmental lead determines whether the state permitting authority will impose any additional requirements, such as a revised Construction Permit and the submittal of a Construction Notice of Intent.

[This implements the Clean WaterAct regulationsreferenced in EN-EV- 115; Section 2. Items 2 and 5(f). I GGNSSWPP (REV 13) - 66

Spill PollutionControl and CountermeasuresPlan [SPCCJ:

The GGNS SPCC Plan requires any container [including non-attended vehicle fuel tanks] with a capacity(2) equal to or greater than 55 gallons to be properly stored and maintained. This means that containers for fuel, Hydraulic Fluid, Lubrication Oil, or any other oil must have containment sufficient to contain the volume of oil stored in the container plus 10% additional volume for freeboard.

GGNS expects that oil/fuel containers are properly stored and managed so there are no spills onto the ground or into surface waters. Use absorbent pads or similar materials to contain and absorb fuel or oil leaks from vehicles or other equipment. Leaks and spills, regardless of volume, must be reported and documented in accordance with GGNS Administrative Procedure, 01-S 20, "Hazardous Materials Emergency Response Plan".

Footnote (2):

Capacity means the volume of the container, not the amount of material it contains. For example, the GGNS SPCC Plan regulates a 55-gallon drum containing 30 gallons of oil. The GGNS SPCC Plan does not regulate a 35-gallon drum containing 30 gallons of oil.

NOTE An oil or fuel spill in an amount sufficient to cause sheen upon surface waters [navigable waters] requires a notification to the U.S. Coast Guard National Response Center and subsequently state regulatory authorities. This is also a Nuclear Regulatory Commission reportable event. All efforts must be made to properly manage and prevent any oil or oil containing material from entering a navigable waterway [For the purposes of this document these include the storm drain system, sedimentation basins, streams, Mississippi River, barge slip, barrow pits, and Gin and Hamilton lakes].

[This implements the Clean Water Act regulationsreferenced in EN-EV-115; Section 2, Items 2 and 5(e).)

Endangeredand threatenedspecies:

Although endangered species have been identified in the proximity of the Grand Gulf Nuclear Station none have been documented in the vicinity of this activity and the implementation of protective management plans is not required. The sighting of an endangered species such as an eagle or a black bear must be immediately related to the site environmental lead. [This implements the EndangeredSpecies Act regulationsreferenced in EN-EV-115; Section 2, Items 2 and item 5(h).J GGNSSWPP (REV 13) - 67

National Historic PreservationAct:

The Grand Gulf Nuclear Station was originally evaluated by the Mississippi Department of Archives and History during the construction of the facility. This evaluation determined that operation of the station will not result in any impact on historic and archaeological sites in the area

[Draft Environmental Statement, United States Regulatory Commission, May 1981, Page 5-7; Final Environmental Statement, United States Regulatory Commission, September 1981, Page 5-71.

NOTE Work orders and procedures must include cultural resource specific written directions for excavation and backfill work which calls for an immediate stop-work order should archeological, historical, or other cultural resources be uncovered durng excavation.

The construction supervisor is responsible for ensuring work stoppage and for notifying the Environmental Lead* of an inadvertent discovery.

In the event of an inadvertent discovery the Environmental Lead* will determine the inadvertent discovery's significance and if necessary, notify the State Historic Preservation Officer to consult with them regarding the discovery to determine if an additional archeological assessment is needed.

Environmental Leads:

Rusty Shaw 601-437-7312 John Lassetter 601-437-2115

[This implements the NationalHistoric PreservationAct regulationsreferenced in EN-EV-I 15; Section 2, Item 2 and 5(h).J Updated FinalSafety Analysis Report [UFSARJ:

There are no environmental regulatory conditions or limitations requiring an amendment to any License Base Document including the GGNS UFSAR.

[This implements the Updated Final Safety Analysis Report requirements referenced in EN-EV- 115; Section 2, Item 5 (d).1 EnvironmentalProtectionPlan[EPPT:

There are no environmental regulatory conditions or limitations requiring an amendment to the EPP or notification to the Nuclear Regulatory Commission for the placement of temporary ground water monitoring wells or geologic bore holes.

[This implements the Environmental ProtectionPlan requirements referenced in EN-EV-115; Section 2.

Items 5 (b) and (h).1 Resource Conservation and Recovery Act (RCRA):

There are no waste management issues unless the material brought to the surface are not inert or typical driller's mud used in the process of drilling boreholes, including various mud, sand, and/or water.

[This implements the Resource Conservationand Recovery Act regulationsreferenced in EN-EV-) 15; Section 2. Item 2.]

GGNSSWPP (REV 13) - 68

OTHER ITEMS OF CONCERN:

Chemical Control:

All chemicals must be approved by Site Chemical Control Coordinator (SCCC) PRIOR to bringing them on-site. Follow the requirements in Nuclear Management Manual; ENS-EV-1 12; "Chemical Control Program" for control of Contractor Chemicals.

[

Reference:

Administrative Procedure; ENS-EV-112, "Chemical ControlProgram"].

Chemical Management and Disposal:

The Project Manager and vendor(s) are responsible for the management of any chemicals brought on site. These must be managed and disposed of as directed by the SCCC when the chemicals are approved for use. Any expenses incurred by GGNS Chemistry for either the management and/or disposal of vendor chemicals will be charged to the Project. [

Reference:

Administrative Procedure;ENS-EV-I 12; "Chemical Control Program"].

Groundwater Withdrawal:

MDEQ does not require a monitoring well to be permitted provided that the diameter of the well is less than 6 inches and the driller retains MDEQ certification. Wells with a diameter equal to or greater than 6 inches will require a permit. All wells require the approval of the Environmental Compliance Coordinator before the work is initiated [

Reference:

GTC 2006/000071.

Test Wells and Bore Holes:

Please note there are specific regulatory requirements for abandoning or decommissioning well and bore holes that penetrate water bearing strata greater than 25 feet in depth. All wells and boreholes that penetrate water bearing stratum with a depth of 25 feet or greater below land surface require decommissioning by an MDEQ licensed water well contractor. Those less than 25 feet in depth below the land surface do not require a licensed contractor but there are reporting requirements that apply regardless of who plugs the well or bore hole. We reauire that all drilling

[reaardless of denthl is performed by an MDEQ licensed contractor to assure these reoulatorv requirements are met.

[

Reference:

State Regulation LW-2, ChapterIV, Section G, Item 1].

Industrial Safety:

Any geologicallgeotechnical investigation work must comply with applicable Entergy fleet and GGNS site Industrial Safety procedures, requirements and expectations. Test pits and similar construction activities may involve obtaining Excavation Permits, Confined Space Permits, or otherwise require approval from the site Industrial Safety Coordinator* before work commences.

In addition specific personnel safety and Personal Protective Equipment requirements must also be verified before work commences.

• GGNS Industrial Safety Coordinator: Joe Tarnabine 601-437-2179 GGNS Ball field Site:

This fenced area across the road and southwest of the Unit 1 Cooling Towers (designated as the 10.5 acre Batch Plant and the 12.2 acre Construction Laydown Site in Plan Options 2 and 4; Figures 2 and 4, respectively] are protected by an agreement with the Mississippi Department of Environmental Quality. As such, access to this area is restricted unless approved by the site environmental lead. [

Reference:

CR number 1997-12741.

GGNSSWPP (REV 13) - 69

Regulatory definitions:

Monitorin Wegll- a well used to obtain data on the quality of water in an aquifer system or at specified depths and locations related to a potential source of pollutant.

Observation Well--- a well used primarily for measuring the water level in an aquifer.

Test Well ---a well drilled to explore for groundwater for a water supply well.

References:

Regulatory References [EN-EV-1 15; Section 2, Item 1]:

(a) 10CFR51.22, "Criterion for Categorical Exclusion; Identification of Licensing and Regulatory Actions Eligible for Categorical Exclusion or Other Wise not Requiring Environmental Review." Specifically 10CFR51.22(c)(9).

(b) NUREG-0575, Final Generic Environmental Impact Statement on Handling and Storage of Spent Light Water Power Reactor Fuel, 1979 (c) NUREG-1 092, Environmental Assessment for 10 CFR Part 72 "Licensing Requirements for the Independent Storage of Spent Fuel and High-Level Radioactive Waste," 1984 (d) NUREG-1 437, Generic Environmental Statement for License Renewal of Nuclear Power Plants, Final Report, May 1996 (and Addendum's)

Environmental Protection Agency References [EN-EV-1 15; Section 2, Item 2]:a (a) Clean Air Act (b) Clean Water Act (c) Endangered Species Act (and amendments)

(d) National Historic Preservation Act (and amendments)

(e) Resource Conservation and Recovery Act GGNSSWPP (REV 13) - 70

GGNS References [EN-EV-1 15; Section 2, Item 5]:

(a) Baseline Stormwater General NPDES Permit Number MSR000883 (b) GGNS Environmental Protection Plan, Appendix B to Operating License NPF-29 (c) GGNS Synthetic Minor Operating Permit 0420-00023 (d) GGNS Updated Final Safety Analysis Report (e) Grand Gulf Nuclear Station Spill Prevention Control and Countermeasure Plan (f) Grand Gulf Nuclear Station Stormwater Pollution Prevention Plan (g) NPDES Permit Number MS0029521 (h) NUREG-0777, GGNS Final Environmental Statement GGNSSWPP (REV 13) - 71

ATTACHMENT V Large Construction Permit Requirements

[Activities Disturbing Five (5) or More Acres]

RESERVED GGNSSWPP (REV 13) - 72