NL-12-1916, Request to Revise the Plant Service Water Pump Well Minimum Water Level Response to Request for Additional Information Regarding the Environmental Evaluation

Request to Revise the Plant Service Water Pump Well Minimum Water Level Response to Request for Additional Information Regarding the Environmental Evaluation

ML12284A299
Person / Time
Site:	Hatch
Issue date:	10/10/2012
From:	Ajluni M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-1916
Download: ML12284A299 (40)

Text

Mark J. Ailuni. P.E. Southern Nuclear Nuclear Licensing Director Operating Company. Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 October 10, 2012 SOUTHERN ' \ '

COMPANY Docket Nos.: 50-321 NL-12-1916 50-366 U. S. Nuclear Regulatory Commission ATIN : Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Request to Revise the Plant Service Water Pump Well Minimum Water Level Response to Request for Additional Information Regarding the Environmental Evaluation Ladies and Gentlemen:

On July 5,2012, Southern Nuclear Operating Company (SNC) requested amendments to the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 Technical Specifications (TS). The proposed amendments would revise the minimum water level referenced in the Units 1 and 2 TS Surveillance Requirement (SR) associated with the Limiting Condition for Operation (LCO) for the plant service water (pSW) system and ultimate heat sink (UHS) (LCO 3.7.2).

By letter dated September 11 , 2012, the NRC requested additional information regarding referenced submittal environmental evaluation. Enclosure 1 provides the response to the NRC request for additional information (RAI). Enclosure 2 provides the current HNP national pollutant discharge elim ination system (NPDES) permit. Enclosure 3 provides the current HNP surface water withdrawal permit.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

U. S. Nuclear Regulatory Commission NL-12-1916 Page 2 Mr. M. J. Ajluni states he is Nuclear Licensing Director of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern l\Iuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Swo' to and subs cr::;,e me this ~ day of (!)Jo b.v ,2012.

c.....

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\ Notary Public My commission expires: -,\_-_L_~.....:Z,-O_(3 Respectfully submitted, M. J. Ajluni /

Nuclear Licensing Director MJAlCLT /vas

Enclosures:

1. Response to Request for Additional Information Regarding the Environmental Evaluation

2. National Pollutant Discharge Elimination System (NPDES)

Permit

3. Georgia Surface Water Withdrawal Permit cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President - Hatch Mr. B. L. Ivey, Vice President - Regulatory Affairs Mr. B. J. Adams, Vice President - Fleet Operations RType: CHA02.004 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager - Fleet Mr. E. D. Morris, Senior Resident Inspector - Hatch State of Georgia Mr. J. H. Turner, Environmental Director Protection Division

Edwin I. Hatch Nuclear Plant Request to Revise the Plant Service Water Pump Well Minimum Water level Response to Request for Additional Information Regarding the Environmental Evaluation Enclosure 1 Response to Request for Additional Information Regarding the Environmental Evaluation to NL-12-1916 Response to RAI Regarding the Environmental Evaluation NRC Question 1 Please describe any alternatives considered for the proposed license amendment request (LAR) to revise the minimum water level referenced in Technical Specification Surveillance Requirements associated with the plant service water (PSW) system.

SNC Response The Southern Nuclear Operating Company (SNC) July 5, 2012 submittal proposed a Technical Specification (TS) change to revise the minimum water level in the PSW pump well, specifically TS Surveillance Requirement (SR) 3.7.2.1, from 60.7 feet (ft) mean sea level (MSL) to 60.5 ft MSL. The SR 3.7.2.1 verifies that the Altamaha River, the plant ultimate heat sink (UHS), is capable of supporting post-accident cooling requirements for a 30 day period. As stated in the referenced submittal cover letter and section 1.0 of Enclosure 1 to the submittal, this revised minimum water level will provide additional operational flexibility during periods of low river levels.

Edwin I. Hatch Nuclear Plant (HNP) continues to experience low river levels due to drought conditions. Figure 2, of the referenced July 5, 2012 submittal , illustrates the frequency that HNP low river level procedural actions have been initiated since 2002.

The technical areas impacted by the proposed TS change are listed in section 3.0 of the referenced July 5, 2012 submittal Enclosure 1. The potential impact of the lower PSW pump well minimum water level on pump operation requirements, supply of water to meet loss-of-coolant accident (LOCA) cooling requirements for 30 days post-accident, and potential environmental impact was evaluated.

The resultant updated design basis analyses support the proposed TS change.

The proposed PSW pump well minimum water level of 60.5 ft MSL still ensures a sufficient water supply over a 30 day period post-LOCA. It is noted that the proposed TS change preserves the shutdown requirement if the PSW pump well water level is lower than is supported by the updated design basis analyses.

Also, the surveillance frequency is not changed.

Since the referenced updated design basis analyses supported the proposed TS change, no other alternatives have recently been considered. As referenced in the NRC 1988 safety evaluation that approved the current HNP Units 1 and 2 PSW pump well minimum water level of 60.7 ft MSL, a temporary weir was installed across the river downstream of the HNP intake structure to support continued power generation. The temporary weir was later removed . Since the temporary weir was not required to support safe shutdown considerations, no licensing credit for the temporary weir was requested.

It is noted that any alternative to the proposed TS change that would seek to directly impact the river level at the HNP intake structure, such as a weir or a dam, would probably have much more of a potential environmental impact than the proposed TS change.

E1-2 to NL-12-1916 Response to RAI Regarding the Environmental Evaluation NRC Question 2 In 2004, the Nuclear Regulatory Commission staff (staff) prepared a revised biological assessment (ADAMS No. ML041910254) on the operational effects of the HNP on the endangered shortnose sturgeon, and the National Marine Fisheries Service (NMFS) concurred in 2005. Section 3.3, Environmental Evaluation, of the LAR does not specifically address the effects on endangered species. Please summarize any assessments conducted to address the effects on endangered species in general, and on the shortnose sturgeon, in particular.

Please clearly cite any documents or studies used to support the assessment.

SNC Response The referenced NRC staff prepared biological assessment (BA) on the operational effects of the HNP on the endangered shortnose sturgeon (ADAMS No. ML041910254) was reviewed by SNC. SNC concluded that the LAR proposed TS change does not impact or change the conclusions stated in the BA.Section IV.C of the BA describes that: The shortnose sturgeon's known behavior and use of the Altamaha River indicates a low potential for impingement or entrainment with the cooling water for HNP."Section V of the BA further states that HNP " ... is not located near designated critical habitat of the shortnose sturgeon."

The referenced BA describes in some detail the biological behaviors of the differing life stages of the shortnose sturgeon, and how those behaviors minimize the probability of shortnose sturgeon encountering the intake structure. The biological behaviors of the shortnose sturgeon described in the BA, specifically fertilized eggs sink quickly and adhere, larvae seek cover quickly, and the preference of the shortnose sturgeon to migrate in the thalweg, etc., have not changed since the issuance of the BA and are independent of HNP operations.

Section IV.B of the BA denotes that the closest upstream spawning area for the shortnose sturgeon is approximately 40 river kilometers from HNP, and no spawning areas are in the immediate area of the HNP intake. The highly localized, marginal increase in through-screen velocity projected for this proposed TS change will not have effects outside of the immediate area of the intake structure.

HNP continues to utilize a closed-cycle circulating water cooling system that will be unchanged by this LAR.Section IV.C of the BA states that " ... the staff noted that studies of intake and discharge effects of closed -cycle cooling systems have generally judged the impacts to be insignificant." The volume of water withdrawn from the Altamaha River by HNP will be unchanged by this LAR.

The potential environmental effects of the proposed TS change are limited to the immediate area of the HNP intake and discharge in the Altamaha River, with no terrestrial impacts. The location of HNP on the Altamaha River is not a designated critical habitat for any aquatic endangered species. Therefore, no previously unreviewed impacts on endangered species are anticipated due to this proposed TS change.

E1-3 to NL-12-1916 Response to RAI Regarding the Environmental Evaluation Based on the above information, SNC concluded that the proposed TS change will not result in any previously unreviewed impacts on shortnose sturgeon or other endangered species.

NRC Question 3 As described on page E1-12 of the LAR, please provide the report and results documenting the modeling study that was performed to assess the potential environmental impacts of continuing plant operations down to a river level of 60.5 feet mean sea level (ft MSL).

SNC Response The modeling study referred to in the LAR generated a technical report that was intended for SNC internal use and interpretation. It was not authored to be a complete, stand-alone report for public dissemination. A brief summary of the study conclusions is provided below.

The study was performed by a third-party contractor and utilized CORMIX Version 5.0 to perform discharge mixing zone analyses at a river level down to 60.5 ft MSL as measured at the HNP intake structure. Historical HNP discharge flowrates and temperatures were utilized to develop the model input, along with historical ambient river temperature data. A bathymetric survey was also performed at the HNP discharge point and at several downstream river cross sections.

A base case was modeled in CORM IX with an ambient river temperature of 97 degrees F, a temperature delta of 5 degrees F between the plant discharge and ambient river temperatures, and discharge flow of 27,444 gallons per minute (gpm). An appropriate discharge depth/width, river depth/width, and discharge protrusion distance into the river was utilized based on the physical discharge configuration and bathymetric information. Utilizing this base case, the discharge plume temperature difference from ambient was calculated to be 2.5 degrees F or less at 140 ft downstream from the point of discharge, with a plume surface area of 0.05 acres and a plume cross-sectional area 3% of the river cross-section.

The plume is generally fully mixed along a vertical cross-section with some lifting from the bottom in the near field due to buoyancy.

As stated on page E1-12 of the LAR, SNC concluded that state and federal limitations regarding water quality criteria and thermal impacts to the Altamaha River continue to be satisfied.

NRC Question 4 The last paragraph on page E1-12 of the LAR submittal states that: "The calculated intake through-screen velocity at the 60.5 ft MSL river elevation is 0.12 feet per second (fps) higher than the calculated velocity at the 60.7 ft MSL river elevation." Please provide the through screen velocity at the 60.7 ft MSL river elevation that was used for the above comparison.

E1-4 to NL-1 916 Response to RAI Regarding the Environmental Evaluation SNC Response The calculated intake through-screen velocity at ft river elevation is 2.81 fps.

NRC Question 5 On page E1-13 of the the applicant states that it did not any evidence of a significant in impingement or entrainment during the drought period in the Altamaha drainage basin during 2007 and 2008. Please provide on the amount of impingement and entrainment during the drought period as compared to a non-drought that led the applicant to the cited conclusion. In addition, provide if available, on the through-screen velocity during the drought period and the non-drought period.

SNC Response on pages -13 of the LAR, as a change, no significant in fish impingement and are anticipated from the fractional change of intake through-screen velocity.

The cited conclusion SNC did not observe any of a significant change in impingement or entrainment during the drought period experienced in the Altamaha drainage during 2007 and 2008 was on information from routine plant outside HI\IP personnel visually the river intake, including and screens, as of routine rounds.

such as excessive river are If an endangered was observed it would in the corrective action Based on such information from plant rounds, no changes in impingement or entrainment were observed during 2007 and 2008. It is noted that no empirical impingement or entrainment monitoring is performed by HNP, so there is no quantitative data available regarding impingement and entrainment.

A search of the HNP I'....OI1tI\/O program was performed no information was found that documented in impingement or during the 2007 and 2008 time period.

2007 and 2008. the Altamaha River within the QUl:1ltinr,c previously approved for operation of HNP. Compliance was maintained with 1 PSW pump well minimum level of 60.7 ft MSL.

Finally. no empirical monitoring of through-screen velocity is performed by HNP.

refer to the SNC response to NRC question 4 for a calculated intake through-screen velocity.

to NL-12-1916 Response to RAI Regarding the Environmental NRC Question 6 Please provide a copy of HNP's current permit and any changes or permitting revisions that would leC'Bs::mal[ea by proposed operational change.

SNC Response HNP's current national pollutant discharge number GA0004120, issued by the (EPD), is provided in Enclosure 2 By letter dated August 27, 2007, SNC submitted the en(:lo~)ea the NRC in accordance with section of HNP Units 1 and 2 Protection Plan.

The cover page of the NPDES permit June 30, 2012; however, Georgia did permit expiration date. In accordance with SNC submitted a renewal to advance of the permit expiration administratively extended, as allowed by Water Quality Control, Chapter 391 Georgia EPD.

No changes or revisions to the HNP are to support implementation of the proposed TS NRC Question 7 Please provide a copy of HNP's current water withdrawal permit and discuss any changes or permitting that would by the proposed operational change.

SNC Response HNP's current Georgia surface water withdrawal permit is provided in Enclosure 3 of this submittal.

No changes or revisions to HNP's current Georgia permit are required to support implementation of NRC Question 8 Please provide the volume (in million gallons withdrawn annually by HNP, Units 1 and from the last 5 years).

to NL-12-1916 to RAI Regarding the Environmental Evaluation a common structure for both as described in of the referenced July 2 SNC submittal 1. Therefore, surface water withdrawal data is not readily The annual volume of surface water withdrawn from Altamaha River by HNP Unit 1 and Unit 2 are summarized below. The withdrawal amounts ronf"l""'~f'I are calculated values on pump runtimes and pump theoretical The water withdrawal is not equipped with flow totalizers.

vu"... ",,,, provided are annual values reported in MGD. Withdrawals were done in accordance with the surface water withdrawal permit in Enclosure 3 of this Calendar Year 2007 - MGD Year 2008 - MGD Year 2009 - MGD Calendar Year 2010 - 56.70 MGD Year 2011 - MGD

-7

Edwin I. Hatch Nuclear Plant Request to Revise the Plant Service Water Pump Well Minimum Water Level Response to Request for Additional Information Regarding the Environmental Evaluation Enclosure 2 National Pollutant Discharge Elimination System (NPDES) Permit

Georgia Department of Natural Resources 2 Martin luther King, Jr. Drive, S.E .. Suite 1152 East Tower, Atlanta. Georgia 30334*9000 Noel Holcomb. CommissIoner Carol A. Couch. Director Environmental Protection Division 4041656-4713 r:' '~li ",-,.,..,..,

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~ .' . ' . '" Il; UH July 31, 2007 lJ~' . . .' .(

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Mr. Wayne Carr, Manager Environmental Services E .

Southern Nuclear Operating Company nVlronmentaJ' A'Tid/ll; ".

v Box 1295 Birmingham, Alabama -1295 Re: Permit No. GA0004120 Plant Hatch. Appling County

Dear Mr. Carr:

Pursuant to the Georgia Water Quality Control Act. as amended; Federal Clean Water Act. as amended; and the Rules and Regulations promulgated thereunder, we have issued the attached National Pollutant Discharge Elimination System (NPDES) permit for the specified wastewater treatment facility.

Please be  !:lO/n/ICl:lIO' that on and after date indicated in the attached NPDES permit, permittee must comply with ail the terms, conditions limitations of this permit.

Sincerely.

Carol A. Couch. Ph. D.

Director Attachments cc: Mr. Scott Gordon (w/attachments)

U. S. Environmental Protection Agency Coastal District - Brunswick

STATE GEORGIA DEPARTMENT Of NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION AUTHORIZATION TO DISCHARGE UNDER THE NATIONAl POllUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of the Georgia Water Quality Control Act (Georgia laws 1964. p. 416, as amended), hereinafter called the State Act; the federal Water Pollution Control Act. as amended (33 U.S. C. 1251 et seq.). hereinafter called the Federal Act; and the Rules and Regulations promulgated pursuant to each of these

Acts, Southern Nuclear Operating Company P.O. Box 1295 Birmingham. Alabama 35201 is authorized to discharge from a facility located at Plant Hatch, Units 1 &2, Appling County, Georgia to receiving waters Altamaha River. Altamaha River Basin In accordance with effluent limitations, monitOring requirements and other conditions set forth In Parts I, II and III hereof.

This permit shari become effective on July 31,2007.

This permit and the authorization to discharge shall expire at midnight, June 30, 2012.

Signed this day of July. 2007.

Environmental Protection Division

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES Page 2 of 25 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120 A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

1. During the period beginning effective date and lasting through June 30. 2012.

The permittee is authorized to discharge from outfall(s) serial number(s) 01 and 02 - Combined Plant Waste Streams.

Such discharges shall be limited and monitored by the permittee as specified below:

Effluent Discharge limitations Monitoring Requirements Characteristic (m ~/I) Measurement Sample Sample Daily Daily Inst. Frequency Type Location Avg. Max. Avg. Max.

Flow -- - - -- *3 *3 *3 Temperature (OF) --- --- ---- --- 1IWeek Grab *1 Free Available --- - ---- --- 1IWeek Multiple *1 Chlorine (FAC) Grabs *2 Total Residual - -- --- ------ 1IWeek Multiple *1 Chlorine (TRC) Grabs *2 Residual oxidant monitoring (TRC. FAC. TRO, and FAO) is only required when the dechlorination system is not in service.

If bromine or a combination of bromine and chlorine is utilized for control of biofouling. monitoring requirements for TRC and FAC shall be applicable to TRO (Total Residual Oxidants) and FAO (Free Available Oxidants). There is no difference in test methods between TRC/FAC and TRO/FAO.

The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored once per week on the final effluent by a grab sample.

There shall be no discharge of floating solids or visible foam in other than trace amounts.

• 1 Monitoring will be at the mixing chamber. which is the last point before discharge to river after combining of all waste streams.

• 2 DUring periods of chlorinated water discharge. Samplings should cover the entire period from beginning to end of chlorinated water discharge and shall be taken at 15 minute intervals.

• 3 See Part III. Special Requirements, Item 7.

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES Page 3 of 25 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

2. During the period beginning effective date and lasting through June 3D, 2012, the pennittee is authorized to discharge from outfall(s) serial number(s) 01A and 02A - Cooling Tower Blowdown from Units 1 and 2.

Such discharges shall be limited and monitored by the pennittee as specified below:

Effluent Discharge Limitations Monitoring Requirements Characteristic (mg/l) Measurement Sample Sample Daily Daily Inst. Frequency Type Location Max. Avg. Max.

Flow --- - - - --- ---- --- Blowdown

-0.5 - Line Free Available Chlorine (FAC)

-- 0.2 1!Week Multiple Grabs Blowdown Line Total Residual ----- - - ----- 1IWeek Multiple Blowdown Chlorine (TRC) - Grabs Line TRCTime 120 ---- ------- 1IWeek Multiple Blowdown (minutes/day/unit) - Grabs Line Total Chromium 0.2 ----- 1/Year Grab Blowdown

- Line Total Zinc 1.0 ----- ---- 1IYear Grab Blowdown

- Line Multiple grab samples are to be collected on 15 minute intervals during periods of FAC and TRC dIscharges. Samples are to be taken before each individual cooling tower blowdown combines with waste streams from other sources.

All numerical discharge limitations and monitoring requirements apply to the individual cooling tower blowdown from each generating unit. Also, see Part III, B. 4., 5., 6., and 16. beginning on page 22.

If bromine or a combination of bromine and chlorine is utilized for control of biofouling, limitations for TRC and FAC shall be applicable to TRO (Total Residual Oxidants) and FAO (Free Available Oxidants). There Is no difference in test methods between TRC/FAC and TRO/FAO.

Chromium and zinc are not added to these systems. MonitOring frequency shall be 1/Quarter if the addition of cooling tower maintenance chemicals containing these compounds is initiated by the pennlttee.

STATE OF GEORGIA PART!

DEPARTMENT OF NATURAL RESOURCES Page 4 of 25 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

3. During the period beginning effective date and lasting through June 30,2012, the permittee is authorized to discharge from outfall(s) serial number(s) 01 Band 02C - Cooling Tower Flume Overflow from Units 1 and 2.

Such discharges shall be limited and monitored by the permittee as specified below:

Cooling water may be discharged from the above outfall(s) on a frequent basis. The same discharge limitations apply as for outfalls 01A and 02A. During times of dechlorination, the permittee is required to monitor at the combined discharge structure, as appropriate, utilizing the same measurement frequency and sample type as specified for outfalls 01A and 02A.

During times when the dechlorination system is not in service, sampling can be done at the

• overflow or discharge line".

Multiple grab samples are to be collected on 15-minute intervals, during periods of FAC and TRC discharges.

See Part III, Special Requirements, Item 7.

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES Page 5 of 25 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

4. During the period beginning effective date and lasting through June 30, 2012, the permittee is authorized to discharge from outfalJ(s) serial number(s) 01J and 02B - Units 1 and 2 Cooling Tower Basin Overflows and Drains toStorm Drains.

Such discharges shall be limited and monitored by the permittee as specified below:

Cooling water may be discharged from the above outfall(s) on an intennittent basis. The same discharge limitations apply as for outfaHs 01A and 02A. If these outfalls are used in lieu of outfalls 01A and 02A, the permittee is required to monitor at the overflow flume or discharge line, as appropriate, utilizing the same measurement frequency and sample type as specified for outfalls 01A and 02A.

There shall be no discharge of floating solids or visible foam in other than amounts for discharges direct to the river.

See Part III, Special Requirements, Item 7.

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES Page 6 of 25 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

5. During the period beginning effective date and lasting through June 30.2012. the permittee is authorized to discharge from outfaU(s) serial number(s) 01 E and 02E Low Volume Wastes (Liquid Radwaste System. Units 1 and 2).

Such discharges shall be limited and monitored by the permittee as specified below:

Effluent Discharge Limitations Monitoring Requirements Characteristic Measurement Sample Sample *1 Mass(mg/l) Frequency Type Location Daily Daily Daily Inst.

Avg. Max. Avg. Max.

Flow -- -- -

• 2 *2 *2 Total Suspended Solids

-- -- 30 100 1/Quarter Grab Discharge Line Oil & Grease -- --- 15 20 1/Quarter Grab Discharge Line The permittee may drain chiller water containing sodium nitrite. disodium molybdate. and/or other approved corrosion inhibitors through this discharge. *3 Alternate corrosion inhibitors may be used in accordance with applicable permit requirements.

Compliance with United States Nuclear Regulatory Commission (NRC) requirements applicable to this discharge will be deemed to constitute compliance with this permit relative to radwaste component of this waste stream. Copies of all routine radiological liquid effluent and water quality monitoring reports submitted to the NRC shall be made available upon the request of the Division.

One set will be retained in the files of the Georgia EPD and the other will be forwarded to designated representatives in the U.S. EnVironmental Protection Agency. Region IV office.

• 1 Prior to mixing with other waste streams.

• 2 See Part III. Special Requirements, Item 7.

• 3 See Part III. Special Requirements. Item 11 .

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES Page 7 of 25 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

6. During the period beginning effective date and lasting through June 30. 2012. the permittee is authorized to discharge from outfall(s) serial number(s) 01G - Low Volume Waste (neutralization tank).

Such discharges shall be limited and monitored by the permittee as specified below:

Effluent Discharge Limitations Monitoring Requirements Characteristic Measurement Sample Sample Mass(mgJl) Frequency Type location *1 Daily Daily Daily Inst.

Avg. Max. Avg. Max.

Flow - - - -- *2 *2 "2 Total Suspended - ---- 30 100 1/Quarter Grab Discharge Solids line Oil & Grease ._-- - 15 20 1/Quarter Grab Discharge line

• 1 Prior to mixing with any other waste streams.

• 2 See Part III. Special Requirements. Item 7.

I NATURAL RESOURCES 8 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

7. During the period beginning effective date and lasting through the permittee is authorized to discharge from outfall(s) serial number(s) 01 H - Low VolUme Waste (pressure filter backwash).

"1 Prior to mixing with any other waste streams.

ORGIA PART!

NATURAL Page 9 of 25 ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

8. the period beginning l'>Tf~.t"1'I\Jl'> and lasting through 2012. the permittee is to discharge from outfall(s) number(s) 03 and 03A -Intake Screen and discharges shall monitored by the "'....."tt".'" as specified below:

discharge shall consist only of intake screen and If the Director determines that water quality are not being met as of this discharge so notifies the permittee in writing, permittee shall take aU ",,::;a,ctllrHanll'> steps to minimize any an\/Af5::A impact to waters of the

STATE OF GEORGIA PART I DEPARTMENT NATURAL Page 10 of ENVIRONMENTAL PROTECTION DIVISION Permit No. GA0004120

9. During the period beginning effective date and lasting through June 30, 2012, the permittee is authorized to discharge from outfall(s) serial number(s) 04 - Blowdown and Draining of Water from the Chiller Systems to Storm Drains.

Such shall be limited monitored by the permittee as specified below:

This discharge shall consist only of chiller water blowdown. If the Director determines that water quality standards are not being met as the result of this discharge and so notifies the permittee in writing, the permittee shall take aU reasonable steps to minimize any adverse impact to waters of the

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION [)IVISION Page 11 of 25 Permit No. GA0004120 B. SCHEDULE OF COMPLIANCE

1. The permittee shall achieve compliance with the effluent limitations specified for discharges In accordance with the following schedule:

N/A

2. No later than 14 calendar days following a date Identified In the above schedule of compliance, the permittee shall submit either a report of progress or, In the case of specific actions being required by Identified dates, a written notice of compliance or noncompliance, any remedial actions taken, and the probability of meeting the next scheduled requirement.

Note: EPD as used herein means the Environmental Protection Division of the Department of Natura' Resources.

EPD 2.21-1

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 12 of 25 Permit No. GA0004120 C. MONITORING AND REPORTING

1. Representative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge.

2. Reporting Monitoring results obtained during the previous three months shall be summarized for each month and reported on an Operation Monitoring Report (Form WQ 1.45). Forms other than Form WQ 1.45 may be used upon approval by EPD. These forms and any other required reports and Information shall be completed, signed and certified by a principal executive officer or ranking elected offiCial, or by a duly authorized representative ofthat panion, and submitted to the Division, postmarked no later than the 28th day of the month following the reporting period. Signed copies of these and all other reports required herein shall be submitted to the following address:

Georgia Environmental Protection Division Coastal District Office 1 Conservation Way Brunswick, Georgia 31520 All Instances of noncompliance not reported under Part I. B. and C. and Part II. A.

shall be reported at the time the operation monitoring report is submitted.

3. Definitions

a. The "dally average" discharge means the total discharge by weight during a calendar month divided by the number of days In the month that the production or commercial facility was operating. Where less than dally sampling Is required by this permit, the dally average discharge shall be determined by the summation of all the measured dally discharges by weight divided by the number of days sampled during the calendar month when the measurements were made.

b. The "dally maximum" discharge means the total discharge by weight during any calendar day.

EPD 2.21-2

STATE OF GEORGIA PART I DEPARTMENT Of NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 13 of 25 Permit No. GA0004120

c. The "dally average" concentration means the arithmetic average of all the dally determinations of concentrations made during a calendar month.

Dally determinations of concentration made using a composite sample shall be the concentration of the composite sample.

d. The "dally maximum" concentration means the dally determination of concentration for any calendar day.

e. For the purpose of this permit, a calendar day is defined as any consecutive 24-hour period.

f. "Bypass" means the Intentional diversion of waste streams from any portion of a treatment facility.

g. "Severe property damage" means substantial physical damage to property, damage to the treatment facilities which causes them to become Inoperable. or substantial and permanent loss of natural resources which can reasonably be expected to occur in the absence of a bypass. Severe property damage does not mean economic loss caused by delays In production.

4. Test Procedures Mon Itorlng must be conducted according to test procedures approved pursuant to 40 CFR Part 136 unless other test procedures have been specified In this permit.

5. Recording of Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following Information:

a. The exact place. date. and time of sampling or measurements, and the person(s) performing the sampling or the measurements;

b. The dates the analyses were performed, and the person(s) who performed the analyses;

c. The analytical techniques or methods used; and

d. The results of all required analyses.

EPD 2.21-3

STATE OF GEORGIA PART I DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 14 25 Permit No. GA0004120

6. Additional Monitoring by Permittee If the permittee monitors any pollutant at the locatlon(s) designated herein more frequently than required by this permit, using approved analytical methods as specified above, the results of such monitoring shall be Included In the calculation and reporting of required In Operation Monitoring Form (WQ 1.45). Such Increased monitoring frequency shall also be Indicated. The Division may require by written notification more frequent monitoring of other pollutants not required In this permit.

7. Records Retention The permittee shall retain records of all monitoring Information. Including all records of analyses performed, calibration and maintenance of Instrumentation.

copies of an reports required by this permit. and records of all data used to complete the application this permit, a period of at least three (3) years from the date of the sample, measurement. report or application. This period may be extended by request of the Division at any time.

8. Penalties The Federal Clean Water Act and the Georgia Water Quality Control Act provide that any person who falsifies, tampers with, or knowingly renders Inaccurate any monitoring device or method required to be maintained under this permit, makes any false statement, representation, or certification In any record or other document submitted or required to be maintained under this permit, Including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine or by Imprisonment, or by both. The Federal Clean Water Act and the Georgia Water Quality Control Act also provide procedures for imposing civil penalties which be levied for violations of the any permit or limitation to the Act, or negligently or Intentionally failing or refusing to comply with any final or emergency order Director of the Division.

EPD 2.21-4

STATE OF GEORGIA PART II DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 15 of 25 Permit No. GA0004120 A. MANAGEMENT REQUIREMENTS

1. Change In Discharge

a. Advance notice to the Division shall be given of any planned changes In the permitted facility or activity, which may result In noncompliance with permit requirements. Any anticipated facility expansions, production Increases, or process modifications must be reported by submission of a new NPDES permit application or, If such changes will not violate the effluent limitations specified In this permit, by notice to the Division of such changes. Following such notice, the penn It may be modified to specify and limit any pollutants not previously limited.

b. All existing manufacturing, commer<;lal, mining, and silviculture dischargers shall notify the Division as soon as It Is known or there Is reason to believe that any a<;tlvlty has occurred or will occur which would result In the discharge, on a routine or frequent basis, of any toxic pollutant not limited In the permit,lfthat discharge will exceed (I) 100 ~/I, (iI) five times the maximum concentration reported for that pollutant In the permit application, or (III) 200 I-'gli for acrolein and acrylonitrile, 500 I-'g/I for 2,4 dinitrophenol and for 2-rnethyl-4-6-c1lnltrophenol, or 1 mgll antimony.

c. All existing manufacturing, commercial, mining, and sllvl<;ultural dischargers shall notify the Division as soon as It Is known or there Is reason to believe that any activity has occurred or will occur which would result In any discharge on a nonroutlne or Infrequent basis, of any toxic pollutant not limited In the permit, If that discharge will exceed (I) 500l-'g/l, (II) ten times the maximum concentration reported for that pollutant In the permit application, or (III) 1 mgJl antimony.

2. Non<;ompllance NotIfication If, for any reason, the permittee does not complywlth, or will be unable to comply with any effluent limitation spe<;lfIed In this permit, the permittee shall provide the Division with an oral report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time the permittee becomes aware of the <;Ircumstances followed by a written report within five (5) days of becoming aware of such condition. The written submission shall contain the following Information:

a. A description of the discharge and cause of noncompliance; and

b. The period of non<;ompilance, Including exact dates and times; or, If not corrected, the anticipated time the noncompliance Is expected to <;ontlnue, and steps being taken to reduce, eliminate and prevent recurrence of the noncomplying discharge.

EPD 2.21-5

STATE OF GEORGIA PART II DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 16 of 25 Permit No. GA0004120

3. Operation The permittee shall at all times maintain in good working order and operate as efficiently as possible all treatment or control facilities or systems Installed or by the permittee to achieve compliance with the terms conditions of this permit. Proper operatIon and maintenance includes effective performance, adequate funding, adequate operator staffing and training. and adequate laboratory and process controls, Including appropriate quality assurance procedures. This prOVision requires the operation of back-up or auxiliary facilities or similar systems only when necessary to achieve compliance with the conditions the permit.

4. Adverse Impact The permittee shall take all reasonable steps to minimize or prevent any discharge In Violation of this permit which has a reasonable likelihood of adversely affecting human health or the environment, Including such accelerated or additional monitoring as necessary to determine the nature and Impact of the noncomplying discharge.

5. Bypassing

a. If the permittee knows In advance of the need for a bypass, It s hall submit prior notice to the Division at least 10 days (If possible) before the date of the bypass. The permittee shall submit notice of any unantiCipated bypass with an oral report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time the permittee becomes aware of the circumstances followed by a written report within five (5) days of becoming aware of such condition. The written submission shall contain the following Information:

1. A description of the discharge and cause of noncompliance; and

2. The period of noncompliance, Including exact dates and times; or. If not corrected, the anticipated time the noncompliance Is expected to continue, and steps being taken to reduce, eliminate and prevent recurrence of the noncomplying discharge.

b. Any diversion or bypass of facilities covered by this permit Is prohibited, except (I) where unavoidable to prevent of life, personal injury. or severe property damage; (II) there were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention untreated wastes, or maintenance during normal periods of equipment downtime (this condition Is not satisfied If the permittee could have installed adequate back-up equipment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance): and (III) the permittee submitted a notice as required above. The EPD 2.21-6

STATE OF GEORGIA PART II DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION 17 of 25 Permit No. GA0004120 treatment plant and total sewer system, to minimize discharge of the pollutants listed In Part I of this permit from combined sewer overflows or bypasses. Upon written notification by the Division.

the permittee may required to submit a plan and schedule for reducing bypasses. overflows. and Infiltration in the system.

6. Sludge Disposal Requirements Hazardous sludge shall disposed of in accordance with the regulations and guidelines established by the Division pursuant to the Federal Water Act (CWA) and the Resource Conservation and Recovery Act (RCRA). For land application of nonhazardous sludge, the permittee shall comply with any applicable criteria outlined In the Division's "Guidelines for land Application of Municipal Sludges. Prforto disposal of sludge by land application, the permittee II shall submit a proposal to Division for approval In accordance with applicable criteria In the Division's "Guidelines for land Application of MuniCipal Sludges'"

Upon evaluation of the permittee's proposal, the Division may require that more stringent control of this activity Is required. Upon written notification, the permittee shall submit to the Division for approval, a detailed plan of operation for land application of sludge. Upon approval. the plan will become a part of the NPDES Disposal nonhazardous sludge by other means, such as landflmng, must be approved by the Div1slon.

7.  ;;,n,IUQIV Monitoring Requirements The permittee sha1l develop and Implement procedures to Insure adequate year round sludge disposal. The permittee shail monitorthe volume and concentration of solids removed from the plant. Records shall be maintained which document the quantity of solids removed from the plant. The ultimate disposal of solids shall reported monthly (In the unit of Ibs/day) to the Division with the Operation Monitoring Report Forms required under Part I (C)(2) of this permit.

8. Power Failures Upon the reduction, loss, or failure of the primary source of power to said water pollution control facilities, the permittee shall use an alternative source of power If available to reduce or otherwise control production andlor all discharges In order to maintain compliance with the effluent limitations prohibitions of this permit.

If such alternative power source Is not In existence. and no date for its Implementation In Part I, the permittee shall halt, or otherwise control production andlor aU dIscharges from wastewater control facilities upon the reduction, loss, or fanure of the primary source of power to said wastewater control facilities.

EPD 2.21-7

STATE OF GEORGIA PART II DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 18 of 25 Permit No. GA0004120 B. RESPONSIBILITIES

1. Right Entry The permittee shall allow the Director of the Division, the Regional Administrator of EPA, andlor their authorized representatives, agents, or employees. upon the presentation of credentials:

a. To enter upon the permittee's premises where a regulated activity or facility Is located or conducted or where any records are required to be kept under the terms and conditions of this permit; and

b. At reasonable times. to have access to and copy any records required to be kept under the terms and conditions of this permit; to Inspect any facilities, equipment (Including monitOring and control equipment),

practices, or operations regulated or required under this permit; and to sample any or parameters In any location.

2. Transfer of Ownership or Control A permit may be transferred to another person by a permittee

a. The permittee notifies the Director in writing of the proposed transfer at least thirty (30) days In advance of the proposed transfer;

b. A written agreement containing a specific date for transfer of permit responsibility and coverage between the current and new permittee (Including acknowledgement that the existing permittee Is liable for violations up to that date. and that the new permittee Is liable for violations from that date on) Is submitted to the Director at least thirty (30) days In advance of the proposed transfer, and

c. The Director, within thirty (30) does not notify the current permittee and the new permittee of the Division's Intent to modify. revoke and reissue, or terminate the permit and to require that a new application be filed rather than agreeing to the transfer of the permit.

3. Availability of Reports Except for data deemed to be confidential under O.C.G.A. " 12-5-25 or by the Regional Administrator of the EPA under the Code of Federal Regulations, TItle 40, Part 2. all reports prepared In accordance with the terms of this permit shall be available for public Inspection at an office of the Division. Effluent permit applications, permittee's names and and permits shall not be considered confidential.

EPD 2.21-8

STATE OF GEORGIA PART II DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION 19 of 25 P.rmlt No. GA0004120

4. Permit Modification After written notice and opportunity for a I"lllllUlrlrl,n nlArWlIt may be modified, suspended, revoked or reissued In whole or In ........... Its term cause Including. but not limited to. the following:

a. Violation of any conditions of this permit;

b. Obtaining this permit by misrepresentation or failure to 11III'-iiIUlII'" fully all relevant facts;

c. A change In any condition that requires either a temporary or permanent reduction or elimination of the permitted discharge; or

d. To comply with any applicable effluent limitation pursuant to the order the United States District Court for the District of Columbia Issued on June 8,1916, In Natural Resources Defense Counclls.nc. et.a!. Y. Russell E.

Train, 8 ERC 2120(D.D.C. 1916). If the effluent limitation so Issued:

(1) Is different In conditions or more stringent than effluent limitation In the permit; or (2) controls any pollutant not limited in the permit.

5. Toxic Pollutants The permittee shall comply with effluent or pursuant to Section 301(a) of the Federal Clean Water Act for toxic pollutants, which are present In the discharge within the time proYlded In the regulations that establish these standards or prohibitions, even Ifthe permit has not yet been modified to Incorporate the requirement.

6. CMI and Criminal Liability Nothing In this permit shall be construed to relleYe the nAlll'nltt*

• cMlor criminal penalties for noncompliance.

1. State Laws Nothing In this permit shall be construed to preclude the Instltu1lon of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable State law or regulation under au1horlty preserved by Section 510 of the Federal Clean Water Act.

EPD 2.21-9

STATE OF GEORGIA PART II DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTEC'nON DIVISION Page 20 of 25 Permit No. GA0004120

8. Water Quality Standards Nothing in this permit shall be construed to preclude the modification of any condition of this permit when It Is determined that the effluent limitations specified herein fall to achieve the applicable State water quality standards.

9. Property Rights The Issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does It authorize any Injury to private property or any invasion of personal rights, nor any Infringement of Federal. State or local laws or regulations.

10. Expiration of Permit Permittee shall not discharge after the expiration date. In order to receive authorization to discharge beyond the expiration date, the permittee shaJi submit such Information, forms, and fees as are required by the agency authorized to Issue permits no later than 180 days prior to the expiration date.

11. Contested Hearings Any person who Is aggrieved or adversely affected by an action of the Director of the Division shall petition the Director for a hearing within thirty (30) days of notice of such action.

12. 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.

13. Best Management Pralctf4t:es The permittee will Implement best management practices to control the discharge of hazardous andlor toxic materials from anCillary manufacturing activities. Such actIvities Include. but are not limited to, materials storage areas, in-plant transfer, process and material handling areas; loading and unloading operations; plant site runoff; and sludge waste disposal areas.

EPD 2.21-10

STATE OF GEORGIA PART II DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 21 of 25 Permit No. GA0004120

14. Need to Halt or Reduce Activity Not a Defense It shall not be a defense for a permittee In an enforcement action that It would have been necessary to hatt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

15. Duty to Provide Information

a. The permittee shall furnish to the Director of the Division, within a reasonable time, any Information which the Director may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. The permittee shall also furnish upon request copies of records required to be kept by this permit.

b. When the permittee becomes aware that It failed to submit any relevant facts In a permit application or submitted Incorrect information In a permit application or any report to the Dlrector,lt shall promptly submit such facts and Information.

16. Stormwater Runoff In addition to the outfalls identified In Part I, Section A. of this permit, the permittee Is authorized to discharge stormwater runoff from pOint sources at this facility provided that these discharges do not cause violations of State water quality standards *ln the receiving streams.

17. Upset Provisions Provisions of 40 CFR 122.41 (n)(1)-(4), regarding "Upset" shall be applicable to any civil, criminal, or administrative proceeding brought to enforce this permit.

EPD 2.21-11

STATE OF GEORGIA PART III DEPARTMENT NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 22 of 25 Permit No. GA0004120 A. PREVIOUS PERMITS

1. All previous water quality permits Issued to this whether for construction or operation, are hereby revoked by the Issuance of this permit. This action Is taken to assure compliance with the Georgia Water Quality Control Act, as amended, and the Federal Clean Water Act, as amended. Receipt of the permit constitutes notice of such The conditions, requirements, terms and provisions of this permit authorlztng discharge under the National Pollutant Discharge Elimination System govem discharges from this facility.

B. SPECIAL REQUIREMENTS

1. There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for transformer fluid.

2. Any metal cleaning wastes generated will be contained for further treatment or disposal in a manner to permit compliance at time of discharge with requirements listed below or disposed of In a manner approved by the Division. This applies to any preoperational chemical cleaning of metal equipment also. The treatment and disposal procedures shall be discussed In the flow monitoring and characterization submittal.

3. The quantity of pollutants discharged In metal cleaning waste shall not exceed the quantity determined by multiplying the flow of metal cleaning wastes times the concentrations listed below. AU effluent characteristics shall be monitored 1/week by grab sampling when a discharge Is occurring.

Total Suspended Solids 30 100 011 and Grease 15 20 Copper 1.0 1.0 Iron 1.0 1.0

4. Neither free available chlorine (FAC). total residual chlorine (TRC), available oxidants nor total residual oxidants may be discharged from any unit for more than two hours In anyone day and not more than one unit In any plant may discharge free available or total residual chlorine at anyone time unless the utility can demonstrate to the Director that the units In a particular location cannot operate at or below this level of chlorination.

EPD 2.21~12

STATE OF GEORGiA PART III DEPARTMENT NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION Page 23 of 25 Perm't No. GA0004120

5. The free avallabie chlorine (FAC) or free available oxidant (FAO) average means the average over individual chlorine or oxidant release period which does not exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per day per unit. The FAC or FAO maximum Is the Instantaneous maximum which may occur at any time. Further, the permittee will develop a system for monitoring and recording total time of FAC, FAO. TRO. and TRC discharges. The shall be reported In a suitably form beginning with the first scheduled Operation Monitoring Report (OMR) and continuing on each OMR thereafter.

6. The permittee shall certify annually that no priority pollutant other than chromium or zinc Is above detectable limits In outfalls 01A, 0lA, 01 B. 02B, 02C, Oil. or 01J (cooling tower blowdowns or overflows). This certification may be on manufacturers certifications or engineering calculations.

7. In the event that waste streams for various sources are combined for treatment or discharge, the quantity of each pollutant 01" pollutant property controlled by this permit shall not exceed the specified limitations for that source.

8. The Director may modify any effluent limitation upon request of the permittee If such limitation Is covered by an approved variance or by an amendment to the Federal Clean Water Act.

.9. Annually, the permittee shall submit to the Director flow monitoring and characterization Information regarding the various waste streams.

10. The sewage treatment plant must be properly operated and maintained. This applies to 01

11. The permittee shall review the water treatment chemicals other than chlorine discharged to State waters. This Includes, but Is not limited to mlcroblocldes.

corrosion Inhibitors, and dispersants. chemicals shan be used and disposed of in accordance with the manufacturers Instructions unless other reqUirements are Imposed by EPD. The permittee shall submit to EPD a current Inventory of all water treatment chemicals discharged during the previous twelve months.

12. Forms other than the Form WQ 1.45 may be used for the quarterly Operation Monitoring Report upon approval by the EPD.

13. Summary of requirements from preceding items which are required year:

a. Metal cleaning waste treatment and disposal procedures.

b. Flow monitoring and characterization Information regarding various waste streams.

c. treatment chemical Inventory.

d. Cooling tower blowdown priority pollutant certification.

EPD 2.21-13

STATE OF GEORGIA III DEPARTMENT OF NATURAL ......::.."...,L.........

ENVIRONMENTAL PROTECTION DIVISION Page 24 of 25 Permit No. GA0004120

14. The effluent limits for all metals In this permit be defined and reported in terms oUotal recoverable metal In conformance with the appropriate language of the applicable Federal regulations.

15. Upon approval of the Director, the permittee shall. on a case.,e,y..case basis, be able to utilize alternative analytical methods, conversion factors. methodology, procedures, or new technologies. to ensure that the blomonitorlng and toxicity reduction requirements of m.c. and the testing/reporting requirements ofthe permit are adequately ac:ll::Jresslac:l.

16. No blocldes or sllmlcldes may be added to the cooling tower system, except for chlorine and bromine, without prior approval from the Georgia Environmental Protection Division. In some cases, It may be necessary to demonstrate that chemical additives are not In concentrations In the receiving stream to be harmful to aquatic life. This will Include and periodic testing the bloclde/sllmlclde active Ingredient.

17. The provisions of 40 CFR 122.4(1)(6)(1U) regarding waiver of the 5 day written report required by Part ItA.2. and Part ItA.5. of this permit shall be applicable and may be Implemented on a basis by EPD for noncompllances which are orally reported by the permittee within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery of the noncompliance condition.

18. permit authorIZes onslte disposal of sludge from the domestic wastewater treatment plan In accordance with the conditions and requirements specified In the EPD..approved Sludge Management Plan. Sludge may also be disposed offslte at approved facilities In accordance with applicable permit requirements.

19. If the results for a given sample are such that a parameter is not detected at or above the method detection limit or reporting limit, II value will reported that sample and the method detection limit or reporting limit wJII also reported. Such sample shall be deemed to be In compliance with the permit.

20. The Division recognizes the Inherent analytical variability In approved test methods and procedures and further agrees that such Issues can be raised by the permittee as a defense In an enforcement action.

21. The permittee Is authoriZed to discharge stormwaterfromthe outfalls Identified In Part I. A. of this permit provided that these discharges do not cause violations of State water quality standards In the receiving streams.

EPD 2.21-14

STATE Of GEORGIA PART III DEPARTMENT Of NATURAL RESOURCES ENVIRONMENT Al PROTECTION DIVISION of 25 Permit No. GA0004120 BIOMONITORING AND TOXICITY REDUCTION In order to determine whether the permittee is discharging wastes In concentrations or combinations, which may have an adverse Impact on the States water quality, the Division can require the permittee to conduct a blomonitorlng program.

Iftoxlclty Is believed to be present In the permittees effluent, the Division may require the permittee to develop a blomonltorlng screening program according to the following schedule:

1. Within 90 days of DiviSion notification a screening program study plan detailing the test methodology and test organisms shall be submitted for conducting a forty-eight hour acute test of the final effluent.

Note: If residual is present in the final from a treatment andlor disinfection process, a prechlorinated or dechlorinated sample will be tested.

2. Within 90 of Division approval of the study plan, the permittee shall conduct and submit the of the forty-elght hour acute test.

The division will then review the results of the forty-elght hour static acute test. Ifthe test criteria specified In study plan are exceeded, then the permittee shall within 90 days of written notification by the Division repeat steps 1. and above replacing the forty eight hour static acute test with the ninety-six hour test.

The division will then review Ifthe detailed In the nlnety-srx hour test toxicity. then within 90 of written notification by division submit to the division a plan to reduce the toxicity of the effluent. Within days of Division approval of this plan, the permittee shall Implement the plan and Initiate follow-up blomonltorlng ofthe effluent In accordance with the approved toxicity reduction plan. The toxicity reduction plan shall not be complete until the permittee meets the criteria detailed In the nlnety-slx hour test plan.

If there are substantial compositIon changes In the permittees effluent, the permittee may be required to. repeat the forty-elght hour static acute test upon notification by the Division. Unless otherwise advised, the permittee shall perform blomonltoring of the effluent as provided In C. 1. and 2. above, at a minimum of once very three years upon notification by the Division. On a case specific basis, chroniC toxicity testing procedures may be required. Upon approval by the Division, all of the will become part of the requirements this naFIT'II?

. The 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> criteria shall define toxiCity as a greater than 100/. mortality of the exposed test organisms In 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or less when the test solution contains volumes of effluent and dilution water proportional to the plant dally average flow the 1Q1 0 flow of the receiving stream, as determined using test procedures and methods, and statistical methods for evaluating test results. developed by the permittee and approved by the division pursuant to this section, or revised pursuant to Part iiI.B.13. above.

EPD 2.21-15

Soulhern Nuclear Opemting Company, Inc.

Post Office Box 1295 Birmingham. Alabama 35201*1295 Tel 205.992.5000 SOUTHERNA COMPANY August 2007 Energy toSerlJ1f Your 'WOrtd '"

Docket Nos.: 50-321 NL-07-1606 50-366 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant National Pollutant Discharge Elimination System (NPDES) Renewed Permit Ladies and Gentlemen:

In accordance with Section of the Edwin I. Hatch (HNP) Environmental Protection Plan (Units 1 and 2), Appendix B to Facility Operating License Nos.

DPR-57 and NPF-5, Southern Nuclear Operating Company hereby submits the renewed National Pollutant Discharge Elimination (NPDES) permit number GA0004120, issued by the Georgia Environmental Protection Division.

This letter contains no NRC commitments. If you have any questions, please advise.

J. M. Godfrey Manager Environmen JMG/MNW/daj

1. HNP National Pollutant Discharge Elimination System (NPDES)

Permit Number GA0004120 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. R Madison, Vice President - Hatch Mr. D. H. Vice - Engineering CHA02.004 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. R Martin, NRR Project Manager - Hatch Mr. J. A. Hickey, Senior Resident Inspector - Hatch

Edwin I. Hatch Nuclear Plant to Revise the Plant Service Water Pump Well Minimum Water Level Response to Request for Additional Information Regarding the Environmental Enclosure 3 Georgia Surface Water Withdrawal Permit

ENVIRONMENTAL PROTECTION DIVISION DEPARTMENT OF NATURAL RESO{JRCES STATE OF GEORGIA PERMlT TO WlTHDRA W, DIVERT OR IMPO{JND S{JRFACE WATER PERMIT HOLDER'S NAME Southern Nuclear Operating Company, Plant Hatch PERMIT NUMBER 001-0690-01 PERMIT HOLDER 'S ADDRESS 11028 Hatch Parkway North, Baxley, Georgia 31513 - Appling County In accordance with the provisions of the Water Quality Control Act , (O.CG.A. § 12-5-20 et seq.) as amended, and the Rules and Regulations for Water Quality Control, Chapter 391-3-6, promulgated pursuant thereto, this permit is issued to withdraw surface water from the (source) Altamaha River in the Altamaha River Basin for the purpose of cooline waler.

The permit holder must comply with the following limitations:

()) Ma ximum 24 hour: Withdrawal 103.6 MGD; Impoundment _ _ MGD; Diversion _ __ MGD (2) Not to exceed a monthly average of 85.0 MGD This permit is conditioned up~n the pern:;.it holder complying with the following:

STANDARD CO NDITIONS (1) The provisions of the Water Quality Control Act, as amended, or any of the Rules and Regulations promulgated thereto ;

(2) This pennit must not be transferred except with the approval of the Division; (3) The use of surface water is lim.ited to the quantities and purposes as specified herein; (4) The permit holder must submit annuall y to the Division , within 30 days of completion of the calendar year, a report listing for each month of the previous year : .

a. The gallons per day withdrawn, based on an average of the da il y withdrawals for the month;

b. The maximum 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> withdrawal; (5) And the attached special conditions, which are hereby, made a part of this perm.it.

[n ~C(;0rtlance with the application dated PI Oil 0 and in conformity 'w'jtb the statements and slIPF-orting datu en:;:~eJ r!; c,ci" or attached thereto, all of willch are filed with the Environmental Protection Division of the Department of Natura 1 Resources and are hereby made part of this Pennit.

Tills Pennit is effective from the date written below and is subject to revocatIon pursuant to the Georgia Water Quality Control Act, as amended , O.CG.A. § 12-5-31 (k).

Absent prior revocation in accordance with the above language, this Permit will expire on the 7lh day of April 2020 .

NATU ~ E

!fA T J R S SIr DATE : Director July 6,2011 Environmental Protection Division

. Department of Natural Resources

STATE OF' GEORGIA PAGE 2 OF 2 DEP ARTMENT OF' NATURAl, RESOURCES NO. 001-0690-01 ENVIRONMENT AL PROTECTION DlV1SION 6,2011

1. The permit holder withdraws water from the Altamaha River in County downstream of the US I river crossing, about ten miles north of the CIty of withdrawn must be measured or calculated at or immediately upon leaving the intake structure

2. The amount o[water withdrawn, less must be returned to the Altamaha River

3. In addition to Standard Condition Number (4), the holder must submit to Environmental Protection Division (EPD), within 10 ofcomplehon of the calendar a monthly "Surface Water Withdrawal for the ~ho'.vjng water withdrawals associated ';/JIh thi:. Pemut.

4. The pemut holder will abide by water conservatIOn The permit holder wd! abide by drought response

6. This surface water withdrawal permit and any future modificattOns Of fe-issuances is conditional upon implementation of the Water Conservation Plan. The holder must demonstrate an effort to increase water use

7. The perlTIJl holder shall nol transfer any water withdrawn via lhis Permit to any operating outside the Allamaha River Basin without EPD approval of such a transfer.

8. The holder will cooperate With the Environmental Protection DiVision (EPD) in the coordination of its water withdrawal associated with this PerlTIJt and the Groundwater Use Pemut Number:

001 0001.

The permit holder may seek modification of any of the terms of an upon written to the 0 [rector.