ML16126A222

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Annual Environmental Protection Plan Operating Report for 2015
ML16126A222
Person / Time
Site: Millstone Dominion icon.png
Issue date: 04/28/2016
From: Stanley B
Dominion Nuclear Connecticut
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
16-165
Download: ML16126A222 (11)
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Text

Dominion Nuclear Connecticut, Inc.

Rope Ferry Rd., Warerford, CT 06385 Mailing Address: P.O. Box 128 Waterford, CT 06385

<lorn.com APR 2 8 2016 U.S. Nuclear Regulatory Commission Serial No.16-165 Attention: Document Control Desk MPS Lic/AVM RO Washington, DC 20555-0001 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 2015 ANNUAL ENVIRONMENTAL PROTECTION PLAN OPERATING REPORT In accordance with Section 5.4.1 of the Environmental Protection Plan (EPP), Appendix B to the Millstone Power Station Unit 3 Operating License, Dominion Nuclear Connecticut, Inc. hereby submits the Annual Environmental Protection Plan Operating Report (AEPPOR), describing implementation of the EPP for the previous year.

Enclosure 1 transmits information for the period of January 1, 2015 to December 31, 2015.

Should you have any questions regarding this report, please contact Mr. Thomas G. Cleary at (860) 444-4377.

Sincerely,

~~~

Brandford L. Stanley Director, Nuclear Station Safety and Licensing

Serial No.16-165 2015 Annual Environmental Protection Plan Operating Report Page 2 of 2

Enclosures:

1 Commitments made in this letter: None.

cc: U. S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 R. V. Guzman NRC Project Manager Millstone Units 2 and 3 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.16-165 Docket No. 50-423 License No. NPF-49 Enclosure 1 MILLSTONE POWER STATION UNIT 3 2015 ANNUAL ENVIRONMENTAL PROTECTION PLAN OPERATING REPORT

  • JANUARY 1- DECEMBER 31, 2015 MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC. (DNC)

2015 Annual Environmental Protection Plan Operating Report (AEPPOR) 1.

Introduction:

This report covers the period January 1, 2015 through December 31, 2015. During 2015, Millstone Power Station Unit 3 (MPS3) operated near full generating capacity (99.04% ). Capacity factor for Cycle 17 to date (beginning Nov 17, 2014 though Dec 31, 2015) was 98.99%.

As required by the MPS3 Environmental Protection Plan (EPP), Appendix B to the MPS3 Operating License, this AEPPOR includes:

  • summaries and analyses of the results of environmental protection activities,
  • a list of EPP noncompliances,
  • a list of all changes in station design or operation which involved a potentially significant unreviewed environmental question, and
  • a list of non-routine reports, describing events that could have resulted in significant environmental impact.
2. Environmental Protection Activities:

2.1 Annual National Pollutant Discharge Elimination System (NPDES) Report of Ecological Monitoring (EPP Section 4.2).

Section 1O(A) of Millstone Power Station's (MPS) NPDES permit (the Permit),

as issued to Dominion Nuclear Connecticut, Inc. (DNC) by the Connecticut Department of Environmental Protection (now the Department of Energy and Environmental Protection, or DEEP) on September 1, 2010, requires, among other things, continuation of biological studies of supplying and receiving waters. These studies include analyses ofintertidal and subtidal benthic communities, finfish communities, entrained plankton, lobster populations, and winter flounder populations. Section 1O(A)(2) of the Permit requires an annual report of these studies to be sent to the DEEP Commissioner on or before July 31 of each year. The latest report that fulfills these requirements, "Annual Report 2014 - Monitoring the Marine Environment of Long Island Sound at Millstone Power Station, Waterford, Connecticut" (Annual Report), dated July 2015, presents results from studies performed during construction and operation of MPS, emphasizing those of the latest sampling year.

Characteristics of and changes to the biological communities noted in these studies are summarized in the Executive Summary section of the Annual Report, which is attached as part of this report.

2.2 Effluent Water Quality Monitoring:

Se_ctions__1 and _5 of _the Permit _require monitoring and recording of various water quality parameters at MPS intakes and at multiple monitoring points within the plant, including outfalls of each unit to the effluent quarry, and outfall of the quarry to Long Island Sound. Section 8 of the Permit requires that a monthly report of this monitoring be submitted to the DEEP. The report that fulfills these requirements, the "Monthly Discharge Monitoring Report" (DMR),

includes discharge data from all MPS units. Consistent with prior annual AEPPOR submissions, water flow, temperature, pH, and chlorine data pertaining to MPS3 are summarized in Table 1.

2015 AEPPOR Page 1 of 3

Each monthly DMR identifies NPDES permit exceedances (i.e., events where a parameter value was beyond permitted limits) or exceptions (i.e., events where Permit conditions were not met) for the month. During 2015, there were no exceedances or exceptions associated with any discharge associated with MPS3.

2.3 Air Program - Compliance Monitoring On November 19, 2015, the Station determined that the run time hour meter on the MPS3 'A' Emergency Diesel Generator does not advance when the engine is run in "maintenance mode", i.e., when the generator's field is not energized (flashed), allowing the engine to run unloaded. As a result of this electrical alignment, the hour meter does not advance. This design condition has existed since the engines were initially installed, and is not the result of an equipment failure. 40 CFR 63 Subp~rt ZZZZ and the MPS DEEP Title V Operating permit for sources of air pollution require the use of hour meters for compliance recordkeeping and reporting. Failure to accurately monitor engine use resulted in incorrect reporting of engine hours, fuel use, and emissions, and constituted a "Failure to Comply with local, state, and federal statutes, regulations, and permits ... " (from the Title V permit), but did not cause any adverse environmental impact. Subsequent corrective actions included the adoption of specific procedures to ensure that plant logs clearly note any operating time in maintenance mode, and an engineering request to permanently resolve the issue is being processed. All 2015 records have been amended to account for the maintenance mode hours.

2.4 NPDES Permit Renewal A complete application for reissuance of the MPS NPDES permit was due to CTDEEP by March 4, 2015. A team was established and milestones scheduled to ensure that a completed permit application was submitted to the DEEP in advance of the regulatory deadline. The permit application was submitted on February 6, 2015, and the DEEP issued a Notice of Sufficiency on March 6, 2015; therefore, _the permit is administratively continued and in effect until its reissuance. DEEP initiated a technical review of the application during the second half of 2015 and, as part of the process, submitted letters requesting additional information dated July 9, 2015 and October 20, 2015.

Responses to the DEEP requests were developed and submitted by letters dated September4, 2015, October 20, 2015 and December 17, 2015.

3. Environmental Protection Plan (EPP) Noncompliances:

No EPP noncompliances were identified for MPS3 in 2015.

4. Environmentally Significant Changes to Station Design or Operation:

No MPS3 design change records or system operating procedure changes initiated during 2015 included a determination that a significant unreviewed environmental impact could occur.

5. Non-Routine Reports of Environmentally Significant Events:

No MPS3 events in 2015 involved a situation that could result in a significant environmental impact.

2015 AEPPOR Page 2 of 3

No MPS3 events in 2015 involved a situation that could result in a significant environmental impact.

2015 AEPPOR Page 3 of 3

Table 1. MPS3 NPDES data summary, Jan 1-Dec 31, 2015. Selected water quality parameters for MPS3 111

  • Discharge Maximum 2015 Discharge Flow SWS FAC 6 (ppm} -

(10 gpd}

October November December Notes:

(1) Parameters are measured at MPS3 discharge (DSN OOlC), except for TRC (total residual chlorine), which is measured at MPS discharge (quarry cuts; DSN 001-1), and SWS FAC (service water system free available chlorine), measured at the reactor plant component cooling water system heat exchangers (DSN OOlC-5).

2015 AEPPOR Page 4 of 3

Attachment to the 2015 Annual Environmental Protection Plan Operating Report January 1 - December 31, 2015 Executive Summary Section of "Annual Report 2014 --Monitoring the Marine Environment of Long Island Sound at Millstone Power Station, Waterford, Connecticut" dated July 2015

Executive Summary-2014 Environmental Monitoring Annual Report Rocky Intertidal Studies barnacle abundance in recent years, and long-term increases in abundance of the common seaweeds Fucus Rocky intertidal monitoring studies during 2014 vesiculosus and Chondrus crispus.

continued to document ecological changes to the shore community near, and associated with, the Millstone Eelgrass Power Station (MPS) thermal discharge. These changes are not widespread, and remain restricted to Eelgrass (Zostera marina L.) was monitored at three approximately 150 m of shore-line on the east side of locations in. the vicinity of MPS. Data from 2014 the power station discharge to Long Island Sound (LIS). surveys indicated that the two study sites nearest to the The total number of algal species identified in 2014 MPS thermal plume* (Jordan Cove and White Point) was 85, well within the range of annual totals for supported healthy and expansive eelgrass populations, previous study years (73-99). consistent with results since the study began in 1985.

As in previous years, seasonal shifts in occurrence of While there has been moderate variability in abundance annual algal species were noted at Fox Island-Exposed and distribution over the entire study period at these two (FE) during 2014. These shifts included abbreviated sites, this variability was not related to MPS operation.

season for cold-water species (e.g., Monostroma Both predicted and measured thermal input to these sites grevillei, Spongomorpha arcta, and Dumontia contorta) from the cooling water discharge is at most minimal (<

and extended season for warm-water species (e.g., 1°C above ambient conditions) and well below levels Grinnellia americana, Dasya baillouviana, and considered stressful to eelgrass.

Bryopsis hypnoides). Similar shifts have been observed By comparison, high eelgrass population variability in most years since Unit 3 began operation (1986), with has been observed in the Niantic River, where complete the exception of the extended shutdown of all MPS and often sudden eelgrass bed losses were documented Units from March* 1996 to June 1998, when seasonality on six separate occasions prior to 2014. Data from the of these species at FE was more typical of other sites. 2014 survey show recolonization of some eelgrass beds Thermal effects on dominant species' abundance and in the Niantic River. Because the Niantic River is distribution patterns were also evident at FE in 2014, located well away from any influence of the MPS and most apparent in the low intertidal zone. Seasonally thermal plume, eelgrass population fluctuations there high abundance of Hypnea musciformis, a species must be related to environmental factors such as observed for the first time in 2001, and expanded increasing ambient seawater temperatures, disease, populations of Sargassum filipendula, Corallina increased turbidity, and waterfowl grazing. Results officinalis, and Gelidium pusillum now characterize the from this monitoring therefore suggest that fluctuations lower shore community at FE. Neosiphonia harveyi has in eelgrass populations observed at sites in the Niantic maintained a perennial population at FE in 2014; but River are due to changes in local and regional occurred mainly as a summer annual at sites unaffected environmental conditions and not to MPS operation.

by MPS.

Ascophyllum nodosum growth, represented as the most Lobster Studies recent internodal length, was greatest at Fox Island in 2014, but continued to demonstrate no clear relationships Impacts associated with recent MPS operations on the among monitoring sites, or correlation with station local lobster population were assessed by comparing operating conditions, indicating that the thermal plume results of the 2014 study year to data collected from 1978 from MPS has had little effect on local populations. through 2013. Emphasis has been placed on assessing Natural influences of other factors, -such as ambient long-term trends in the abundance and population temperature conditions, storms and wave action, nutrients characteristics of lobsters collected in the Millstone Point and light, play the dominant role in determining area.

Ascophyllum growing conditions in the Millstone area. Throughout LIS, the lobster population was stable or The rocky intertidal monitoring program has also increasing from 1978 through 1999. Commercial lobster documented regional patterns and modifications to catches in LIS precipitously declined from 2000 to 2014.

shore communities umelated to MPS operation. These In this study, lobsters in the MPS area showed a similar include the introduction to the region of three exotic red trend, with abundance indices (total catch and CPUE) algae (Antithamnion pectinatum in 1986, Grateloupia >74% lower in research pots and >99% lower in trawls turuturu in 2004, and Dasysiphonia (formerly during the past three years (2012-2014), compared to Heterosiphonia) japonica in 2010), decreases in highest levels in the 1990s. Declines in pot and in trawl Executive Summary

catches were unrelated to .MPS operations and attributed successional development in resppnse to more stable to an increase in mortality associated with ambient sedimentary environments. Surface deposit-feeding seawater temperature rise and temperature mediated oligochaetes and polychaetes continued to be dominant stressors that include a shell disease affecting lObster organisms at all sites in 2014. Multidimensional scaling populations from eastern LIS to the Gulf of Maine. showed distinct separation of communities affected by Declines in the abundance of legal-size lobsters were construction (IN) and initial operation of Unit 3 (JC and attributed in part to the outbreak of shell disease and to a BF). Changes in community structure and functional nearly 5 inm increase in the minimum legal-size since group dominance at subtidal benthic infauna} stations 1978. Recent reductions in landings oflegal-size lobsters during the period 1980-2014 reflect not only effects harvested by commercial lobstermen in eastern LIS related to construction and initial operation of.MPS Unit coincided with declines observed in this study, and 3, but other regional and/or local biotic and abiotic lobster catches remained severely depressed in other factors. Community changes at th<:: reference site (GN) areas of LIS since the lobster die-off observed in 1999. during the period 1980-2014 were attributed solely to Long-term trends observed in lobster population these latter factors, and not to operation of MPS.

characteristics over the past three decades (growth, female maturity, and egg-bearing lobsters) appear Winter Flounder Studies related to warmer ambient seawater temperatures and/or the recent outbreak of shell disease, and not .MPS Various life history stages of Winter Flounder have operation. Increased ambient water temperature may be been monitored since 1976 to determine what effect, if responsible for the increased susceptibility and any, MPS may have on the local Niantic River transmission of diseases affecting lobsters in LIS, which population, particularly through the entrainment of is at the southern boundary of their range of distribution larvae. Over the past two decades, low Winter Flounder in nearshore waters. Recent research suggests that abundance levels have been found throughout LIS by ocean acidification may also exacerbate shell disease. the Connecticut Department of Energy and The number of lobster larvae entrained through the Environmental Protection (CTDEEP). During the same

.MPS cooling water systems was highly variable and low time period, adult Winter Flounder abundance in the in recent years, due to low adult lobster abundance and Niantic River has remained low. A total of 15 adult low larval densities throughout LIS. Impacts associated flounder were captured in the 2014 Winter Flounder with impingement of lobsters at .MPS have been greatly spawning survey, with no recaptures from past years.

reduced by the use of aquatic organism return systems at Reflecting the trend of record low abundance, CPUE in Units 2 and 3., which return impinged lobsters to Niantic 2014 was 0.3 fish per standardized tow, the second Bay. lowest value of the time-series (1976-2014).

In 2014, larval abundances in Niantic Bay (Stations Benthic Infauna EN and NB) and Niantic River (Stations A, B, and C) were lower than 2013 values. All larval stages for the Benthic infauna} monitoring documented long-term Niantic River stations were some of the lowest values in trends in sediment characteristics at all the subtidal sites recent years, while larval abundances in Niantic Bay in the vicinity of.MPS. At the effluent station (BF), the were just below or close to average for the time-series.

sedimentary environment remains coarse, with low Relative to the Niantic River, larval abundance in

~ilt/clay which is related to discharge of cooling water Niantic Bay has increased in recent years, suggesting into LIS at the Quarry cuts. Sediments at the intake higher production in LIS rather than in estuaries such as station (IN) were consistent with -sediment the Niantic River. As expected from the low, late-stage characteristics prior to dredging during .MPS Unit 3 larval abundance in 2014, juvenile abundance from the construction. Sediments at Jordan Cove (JC) have Niantic River beam trawl survey was low.

stabilized following an earlier siltation event when The number of larvae entrained at .MPS is a measure increased water flow from the discharge after startup of of potential impact to Winter Flounder. Annual

.MPS Unit 3 scoured fine sediments surrounding BF and estimates of entrainment are related to both larval deposited them at JC. Sedimentary characteristics at the densities in Niantic Bay and .MPS cooling-water reference site at Giants Neck (GN) were similar to volume. The 2014 entrainment estimate of 86.2 million previous years' observations and continued to reflect reflected slightly lower than average Niantic Bay larval natural variability unrelated to .MPS. densities. An entrainment reduction of 55.7% (based on The 2014 infauna} communities at all sampling sites maximum permitted flow) in 2014 can be attributed to continued to respond to sedimentary environments. the use of the variable frequency drives (VFDs) during Dominant taxa at all sites were reflective of climax the "Interval" (defined in the .MPS NPDES permit as the communities that have undergone long-term Executive Summary ii

period "from April 4 to May 14 or the first day after juvenile and adult Silversides. Atlantic Menhaden May 14 when the intake water temperature reaches 52 larvae showed a significantly increasing trend in

°F, whichever is later, but no later than June 5") and the abundance, as did juveniles taken by seine and trawl. A Unit 2 outage, which lasted from April 5th to May 15th. significant decreasing trend was exhibited for Grubby Annual entrainment density (abundance index divided collected at the Intake, Jordan Cove, and Niantic River by total cooling water volume) has varied without trend trawl stations. Over the past 39 years, Cunner and since 1976, indicating that larval production and Tautog larval abundances have significantly increased.

availability in Niantic Bay remained relatively stable Juvenile and adult Cunner decreased in Intake and despite increased water use during the 1986-95 period Jordan Cove trawl and lobster pot catches and increased of three-unit operation and reduced cooling-water use in in Niantic River trawls. Trawl catches of juvenile and 1995-97. Correlations between entrainment estimates adult Tautog have significantly increased at the Niantic and abundance indices of post-entrainment age-0 River station, but decreased at Intake.

juveniles were positive. This implies no entrainment The magnitude of entrainment is dependent upon egg effect, as the more larvae that were available for and larval densities and condenser cooling water flows entrainment, the more larvae metamorphosed and during their periods of occurrence. Reductions in settled in Niantic River and Bay. This was also cooling-water flows have been implemented at MPS demonstrated by a comparison of annual entrainment with the use of VFDs during the peak period of Winter and juvenile year-class abundance, which suggested that Flounder annual spawning. In addition to the Unit 3 entrainment estimates were simply a measure of fish return, which was in operation at unit start-up in emerging year-class strength. Thus, entrainment is not 1986, impingement impacts were further reduced at an important factor in determining juvenile abundance. MPS with the installation of a fish return at Unit 2 in Processes that are unrelated to MPS operation and early 2000. The implementation of these mitigation which occur after juvenile Winter Flounder leave measures serve to minimize entrainment and shallow nursery waters during the fall of their first year impingement impacts at MPS.

of life seem to be operating to account for fewer adults. Annual variations in ichthyoplankton entrainment A bottleneck in recruitment may occur during the late likely reflected differences in spawning and transport of juvenile life stage (ages-1 and 2), probably from eggs and larvae within LIS. Other factors, such as predation. Environmental effects, including changes to extremes in seasonal water temperature, may al.so affect the Niantic River habitat (e.g., widely fluctuating larval growth and development. A number of temporal eelgrass abundance), a warming trend in regional and spatial changes were identified in the community of seawater temperature, and interactions with other fishes and macroinvertebrates collected in the MPS species (e.g., predation), especially during early life trawl monitoring program. These changes were history, are also important processes affecting Winter unrelated to the operations of MPS, but rather were Flounder population dynamics. associated with shifts in the dominance of individual Results from Winter Flounder studies through 2014 taxa* from changes in habitat, range extensions or suggest that MPS operations have had minimal effects contractions related to a warming trend in ambient on Winter Flounder biomass in the Niantic River. seawater temperature that has occurred over the past Declines in stock size have been greatly evident on a three decades, and changes in fishing rates and fishing regional basis, including Long Island Sound, Rhode regulations.

Island and all other Southern New England waters.

Entrainment during the larval life stages of Winter Flounder occurs, however there has been large variation in the amount of larval mortality and recruitment in recent years, both occurring independently of MPS operations.

Fish Ecology Studies Results from the Fish Ecology monitoring studies during 2014 indicate that no long-term abundance trends for various life stages of seven selected species could be directly related to MPS operation. No significant long-term trends in abundance were identified for Anchovy, Cunner and Tautog eggs, American Sand Lance, Anchovy, and Grubby larvae, or Executive Summary m

Dominion Nuclear Connecticut, Inc.

Rope Ferry Rd., Warerford, CT 06385 Mailing Address: P.O. Box 128 Waterford, CT 06385

<lorn.com APR 2 8 2016 U.S. Nuclear Regulatory Commission Serial No.16-165 Attention: Document Control Desk MPS Lic/AVM RO Washington, DC 20555-0001 Docket No. 50-423 License No. NPF-49 DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 3 2015 ANNUAL ENVIRONMENTAL PROTECTION PLAN OPERATING REPORT In accordance with Section 5.4.1 of the Environmental Protection Plan (EPP), Appendix B to the Millstone Power Station Unit 3 Operating License, Dominion Nuclear Connecticut, Inc. hereby submits the Annual Environmental Protection Plan Operating Report (AEPPOR), describing implementation of the EPP for the previous year.

Enclosure 1 transmits information for the period of January 1, 2015 to December 31, 2015.

Should you have any questions regarding this report, please contact Mr. Thomas G. Cleary at (860) 444-4377.

Sincerely,

~~~

Brandford L. Stanley Director, Nuclear Station Safety and Licensing

Serial No.16-165 2015 Annual Environmental Protection Plan Operating Report Page 2 of 2

Enclosures:

1 Commitments made in this letter: None.

cc: U. S. Nuclear Regulatory Commission Region I 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 R. V. Guzman NRC Project Manager Millstone Units 2 and 3 U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08 C2 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station

Serial No.16-165 Docket No. 50-423 License No. NPF-49 Enclosure 1 MILLSTONE POWER STATION UNIT 3 2015 ANNUAL ENVIRONMENTAL PROTECTION PLAN OPERATING REPORT

  • JANUARY 1- DECEMBER 31, 2015 MILLSTONE POWER STATION UNIT 3 DOMINION NUCLEAR CONNECTICUT, INC. (DNC)

2015 Annual Environmental Protection Plan Operating Report (AEPPOR) 1.

Introduction:

This report covers the period January 1, 2015 through December 31, 2015. During 2015, Millstone Power Station Unit 3 (MPS3) operated near full generating capacity (99.04% ). Capacity factor for Cycle 17 to date (beginning Nov 17, 2014 though Dec 31, 2015) was 98.99%.

As required by the MPS3 Environmental Protection Plan (EPP), Appendix B to the MPS3 Operating License, this AEPPOR includes:

  • summaries and analyses of the results of environmental protection activities,
  • a list of EPP noncompliances,
  • a list of all changes in station design or operation which involved a potentially significant unreviewed environmental question, and
  • a list of non-routine reports, describing events that could have resulted in significant environmental impact.
2. Environmental Protection Activities:

2.1 Annual National Pollutant Discharge Elimination System (NPDES) Report of Ecological Monitoring (EPP Section 4.2).

Section 1O(A) of Millstone Power Station's (MPS) NPDES permit (the Permit),

as issued to Dominion Nuclear Connecticut, Inc. (DNC) by the Connecticut Department of Environmental Protection (now the Department of Energy and Environmental Protection, or DEEP) on September 1, 2010, requires, among other things, continuation of biological studies of supplying and receiving waters. These studies include analyses ofintertidal and subtidal benthic communities, finfish communities, entrained plankton, lobster populations, and winter flounder populations. Section 1O(A)(2) of the Permit requires an annual report of these studies to be sent to the DEEP Commissioner on or before July 31 of each year. The latest report that fulfills these requirements, "Annual Report 2014 - Monitoring the Marine Environment of Long Island Sound at Millstone Power Station, Waterford, Connecticut" (Annual Report), dated July 2015, presents results from studies performed during construction and operation of MPS, emphasizing those of the latest sampling year.

Characteristics of and changes to the biological communities noted in these studies are summarized in the Executive Summary section of the Annual Report, which is attached as part of this report.

2.2 Effluent Water Quality Monitoring:

Se_ctions__1 and _5 of _the Permit _require monitoring and recording of various water quality parameters at MPS intakes and at multiple monitoring points within the plant, including outfalls of each unit to the effluent quarry, and outfall of the quarry to Long Island Sound. Section 8 of the Permit requires that a monthly report of this monitoring be submitted to the DEEP. The report that fulfills these requirements, the "Monthly Discharge Monitoring Report" (DMR),

includes discharge data from all MPS units. Consistent with prior annual AEPPOR submissions, water flow, temperature, pH, and chlorine data pertaining to MPS3 are summarized in Table 1.

2015 AEPPOR Page 1 of 3

Each monthly DMR identifies NPDES permit exceedances (i.e., events where a parameter value was beyond permitted limits) or exceptions (i.e., events where Permit conditions were not met) for the month. During 2015, there were no exceedances or exceptions associated with any discharge associated with MPS3.

2.3 Air Program - Compliance Monitoring On November 19, 2015, the Station determined that the run time hour meter on the MPS3 'A' Emergency Diesel Generator does not advance when the engine is run in "maintenance mode", i.e., when the generator's field is not energized (flashed), allowing the engine to run unloaded. As a result of this electrical alignment, the hour meter does not advance. This design condition has existed since the engines were initially installed, and is not the result of an equipment failure. 40 CFR 63 Subp~rt ZZZZ and the MPS DEEP Title V Operating permit for sources of air pollution require the use of hour meters for compliance recordkeeping and reporting. Failure to accurately monitor engine use resulted in incorrect reporting of engine hours, fuel use, and emissions, and constituted a "Failure to Comply with local, state, and federal statutes, regulations, and permits ... " (from the Title V permit), but did not cause any adverse environmental impact. Subsequent corrective actions included the adoption of specific procedures to ensure that plant logs clearly note any operating time in maintenance mode, and an engineering request to permanently resolve the issue is being processed. All 2015 records have been amended to account for the maintenance mode hours.

2.4 NPDES Permit Renewal A complete application for reissuance of the MPS NPDES permit was due to CTDEEP by March 4, 2015. A team was established and milestones scheduled to ensure that a completed permit application was submitted to the DEEP in advance of the regulatory deadline. The permit application was submitted on February 6, 2015, and the DEEP issued a Notice of Sufficiency on March 6, 2015; therefore, _the permit is administratively continued and in effect until its reissuance. DEEP initiated a technical review of the application during the second half of 2015 and, as part of the process, submitted letters requesting additional information dated July 9, 2015 and October 20, 2015.

Responses to the DEEP requests were developed and submitted by letters dated September4, 2015, October 20, 2015 and December 17, 2015.

3. Environmental Protection Plan (EPP) Noncompliances:

No EPP noncompliances were identified for MPS3 in 2015.

4. Environmentally Significant Changes to Station Design or Operation:

No MPS3 design change records or system operating procedure changes initiated during 2015 included a determination that a significant unreviewed environmental impact could occur.

5. Non-Routine Reports of Environmentally Significant Events:

No MPS3 events in 2015 involved a situation that could result in a significant environmental impact.

2015 AEPPOR Page 2 of 3

No MPS3 events in 2015 involved a situation that could result in a significant environmental impact.

2015 AEPPOR Page 3 of 3

Table 1. MPS3 NPDES data summary, Jan 1-Dec 31, 2015. Selected water quality parameters for MPS3 111

  • Discharge Maximum 2015 Discharge Flow SWS FAC 6 (ppm} -

(10 gpd}

October November December Notes:

(1) Parameters are measured at MPS3 discharge (DSN OOlC), except for TRC (total residual chlorine), which is measured at MPS discharge (quarry cuts; DSN 001-1), and SWS FAC (service water system free available chlorine), measured at the reactor plant component cooling water system heat exchangers (DSN OOlC-5).

2015 AEPPOR Page 4 of 3

Attachment to the 2015 Annual Environmental Protection Plan Operating Report January 1 - December 31, 2015 Executive Summary Section of "Annual Report 2014 --Monitoring the Marine Environment of Long Island Sound at Millstone Power Station, Waterford, Connecticut" dated July 2015

Executive Summary-2014 Environmental Monitoring Annual Report Rocky Intertidal Studies barnacle abundance in recent years, and long-term increases in abundance of the common seaweeds Fucus Rocky intertidal monitoring studies during 2014 vesiculosus and Chondrus crispus.

continued to document ecological changes to the shore community near, and associated with, the Millstone Eelgrass Power Station (MPS) thermal discharge. These changes are not widespread, and remain restricted to Eelgrass (Zostera marina L.) was monitored at three approximately 150 m of shore-line on the east side of locations in. the vicinity of MPS. Data from 2014 the power station discharge to Long Island Sound (LIS). surveys indicated that the two study sites nearest to the The total number of algal species identified in 2014 MPS thermal plume* (Jordan Cove and White Point) was 85, well within the range of annual totals for supported healthy and expansive eelgrass populations, previous study years (73-99). consistent with results since the study began in 1985.

As in previous years, seasonal shifts in occurrence of While there has been moderate variability in abundance annual algal species were noted at Fox Island-Exposed and distribution over the entire study period at these two (FE) during 2014. These shifts included abbreviated sites, this variability was not related to MPS operation.

season for cold-water species (e.g., Monostroma Both predicted and measured thermal input to these sites grevillei, Spongomorpha arcta, and Dumontia contorta) from the cooling water discharge is at most minimal (<

and extended season for warm-water species (e.g., 1°C above ambient conditions) and well below levels Grinnellia americana, Dasya baillouviana, and considered stressful to eelgrass.

Bryopsis hypnoides). Similar shifts have been observed By comparison, high eelgrass population variability in most years since Unit 3 began operation (1986), with has been observed in the Niantic River, where complete the exception of the extended shutdown of all MPS and often sudden eelgrass bed losses were documented Units from March* 1996 to June 1998, when seasonality on six separate occasions prior to 2014. Data from the of these species at FE was more typical of other sites. 2014 survey show recolonization of some eelgrass beds Thermal effects on dominant species' abundance and in the Niantic River. Because the Niantic River is distribution patterns were also evident at FE in 2014, located well away from any influence of the MPS and most apparent in the low intertidal zone. Seasonally thermal plume, eelgrass population fluctuations there high abundance of Hypnea musciformis, a species must be related to environmental factors such as observed for the first time in 2001, and expanded increasing ambient seawater temperatures, disease, populations of Sargassum filipendula, Corallina increased turbidity, and waterfowl grazing. Results officinalis, and Gelidium pusillum now characterize the from this monitoring therefore suggest that fluctuations lower shore community at FE. Neosiphonia harveyi has in eelgrass populations observed at sites in the Niantic maintained a perennial population at FE in 2014; but River are due to changes in local and regional occurred mainly as a summer annual at sites unaffected environmental conditions and not to MPS operation.

by MPS.

Ascophyllum nodosum growth, represented as the most Lobster Studies recent internodal length, was greatest at Fox Island in 2014, but continued to demonstrate no clear relationships Impacts associated with recent MPS operations on the among monitoring sites, or correlation with station local lobster population were assessed by comparing operating conditions, indicating that the thermal plume results of the 2014 study year to data collected from 1978 from MPS has had little effect on local populations. through 2013. Emphasis has been placed on assessing Natural influences of other factors, -such as ambient long-term trends in the abundance and population temperature conditions, storms and wave action, nutrients characteristics of lobsters collected in the Millstone Point and light, play the dominant role in determining area.

Ascophyllum growing conditions in the Millstone area. Throughout LIS, the lobster population was stable or The rocky intertidal monitoring program has also increasing from 1978 through 1999. Commercial lobster documented regional patterns and modifications to catches in LIS precipitously declined from 2000 to 2014.

shore communities umelated to MPS operation. These In this study, lobsters in the MPS area showed a similar include the introduction to the region of three exotic red trend, with abundance indices (total catch and CPUE) algae (Antithamnion pectinatum in 1986, Grateloupia >74% lower in research pots and >99% lower in trawls turuturu in 2004, and Dasysiphonia (formerly during the past three years (2012-2014), compared to Heterosiphonia) japonica in 2010), decreases in highest levels in the 1990s. Declines in pot and in trawl Executive Summary

catches were unrelated to .MPS operations and attributed successional development in resppnse to more stable to an increase in mortality associated with ambient sedimentary environments. Surface deposit-feeding seawater temperature rise and temperature mediated oligochaetes and polychaetes continued to be dominant stressors that include a shell disease affecting lObster organisms at all sites in 2014. Multidimensional scaling populations from eastern LIS to the Gulf of Maine. showed distinct separation of communities affected by Declines in the abundance of legal-size lobsters were construction (IN) and initial operation of Unit 3 (JC and attributed in part to the outbreak of shell disease and to a BF). Changes in community structure and functional nearly 5 inm increase in the minimum legal-size since group dominance at subtidal benthic infauna} stations 1978. Recent reductions in landings oflegal-size lobsters during the period 1980-2014 reflect not only effects harvested by commercial lobstermen in eastern LIS related to construction and initial operation of.MPS Unit coincided with declines observed in this study, and 3, but other regional and/or local biotic and abiotic lobster catches remained severely depressed in other factors. Community changes at th<:: reference site (GN) areas of LIS since the lobster die-off observed in 1999. during the period 1980-2014 were attributed solely to Long-term trends observed in lobster population these latter factors, and not to operation of MPS.

characteristics over the past three decades (growth, female maturity, and egg-bearing lobsters) appear Winter Flounder Studies related to warmer ambient seawater temperatures and/or the recent outbreak of shell disease, and not .MPS Various life history stages of Winter Flounder have operation. Increased ambient water temperature may be been monitored since 1976 to determine what effect, if responsible for the increased susceptibility and any, MPS may have on the local Niantic River transmission of diseases affecting lobsters in LIS, which population, particularly through the entrainment of is at the southern boundary of their range of distribution larvae. Over the past two decades, low Winter Flounder in nearshore waters. Recent research suggests that abundance levels have been found throughout LIS by ocean acidification may also exacerbate shell disease. the Connecticut Department of Energy and The number of lobster larvae entrained through the Environmental Protection (CTDEEP). During the same

.MPS cooling water systems was highly variable and low time period, adult Winter Flounder abundance in the in recent years, due to low adult lobster abundance and Niantic River has remained low. A total of 15 adult low larval densities throughout LIS. Impacts associated flounder were captured in the 2014 Winter Flounder with impingement of lobsters at .MPS have been greatly spawning survey, with no recaptures from past years.

reduced by the use of aquatic organism return systems at Reflecting the trend of record low abundance, CPUE in Units 2 and 3., which return impinged lobsters to Niantic 2014 was 0.3 fish per standardized tow, the second Bay. lowest value of the time-series (1976-2014).

In 2014, larval abundances in Niantic Bay (Stations Benthic Infauna EN and NB) and Niantic River (Stations A, B, and C) were lower than 2013 values. All larval stages for the Benthic infauna} monitoring documented long-term Niantic River stations were some of the lowest values in trends in sediment characteristics at all the subtidal sites recent years, while larval abundances in Niantic Bay in the vicinity of.MPS. At the effluent station (BF), the were just below or close to average for the time-series.

sedimentary environment remains coarse, with low Relative to the Niantic River, larval abundance in

~ilt/clay which is related to discharge of cooling water Niantic Bay has increased in recent years, suggesting into LIS at the Quarry cuts. Sediments at the intake higher production in LIS rather than in estuaries such as station (IN) were consistent with -sediment the Niantic River. As expected from the low, late-stage characteristics prior to dredging during .MPS Unit 3 larval abundance in 2014, juvenile abundance from the construction. Sediments at Jordan Cove (JC) have Niantic River beam trawl survey was low.

stabilized following an earlier siltation event when The number of larvae entrained at .MPS is a measure increased water flow from the discharge after startup of of potential impact to Winter Flounder. Annual

.MPS Unit 3 scoured fine sediments surrounding BF and estimates of entrainment are related to both larval deposited them at JC. Sedimentary characteristics at the densities in Niantic Bay and .MPS cooling-water reference site at Giants Neck (GN) were similar to volume. The 2014 entrainment estimate of 86.2 million previous years' observations and continued to reflect reflected slightly lower than average Niantic Bay larval natural variability unrelated to .MPS. densities. An entrainment reduction of 55.7% (based on The 2014 infauna} communities at all sampling sites maximum permitted flow) in 2014 can be attributed to continued to respond to sedimentary environments. the use of the variable frequency drives (VFDs) during Dominant taxa at all sites were reflective of climax the "Interval" (defined in the .MPS NPDES permit as the communities that have undergone long-term Executive Summary ii

period "from April 4 to May 14 or the first day after juvenile and adult Silversides. Atlantic Menhaden May 14 when the intake water temperature reaches 52 larvae showed a significantly increasing trend in

°F, whichever is later, but no later than June 5") and the abundance, as did juveniles taken by seine and trawl. A Unit 2 outage, which lasted from April 5th to May 15th. significant decreasing trend was exhibited for Grubby Annual entrainment density (abundance index divided collected at the Intake, Jordan Cove, and Niantic River by total cooling water volume) has varied without trend trawl stations. Over the past 39 years, Cunner and since 1976, indicating that larval production and Tautog larval abundances have significantly increased.

availability in Niantic Bay remained relatively stable Juvenile and adult Cunner decreased in Intake and despite increased water use during the 1986-95 period Jordan Cove trawl and lobster pot catches and increased of three-unit operation and reduced cooling-water use in in Niantic River trawls. Trawl catches of juvenile and 1995-97. Correlations between entrainment estimates adult Tautog have significantly increased at the Niantic and abundance indices of post-entrainment age-0 River station, but decreased at Intake.

juveniles were positive. This implies no entrainment The magnitude of entrainment is dependent upon egg effect, as the more larvae that were available for and larval densities and condenser cooling water flows entrainment, the more larvae metamorphosed and during their periods of occurrence. Reductions in settled in Niantic River and Bay. This was also cooling-water flows have been implemented at MPS demonstrated by a comparison of annual entrainment with the use of VFDs during the peak period of Winter and juvenile year-class abundance, which suggested that Flounder annual spawning. In addition to the Unit 3 entrainment estimates were simply a measure of fish return, which was in operation at unit start-up in emerging year-class strength. Thus, entrainment is not 1986, impingement impacts were further reduced at an important factor in determining juvenile abundance. MPS with the installation of a fish return at Unit 2 in Processes that are unrelated to MPS operation and early 2000. The implementation of these mitigation which occur after juvenile Winter Flounder leave measures serve to minimize entrainment and shallow nursery waters during the fall of their first year impingement impacts at MPS.

of life seem to be operating to account for fewer adults. Annual variations in ichthyoplankton entrainment A bottleneck in recruitment may occur during the late likely reflected differences in spawning and transport of juvenile life stage (ages-1 and 2), probably from eggs and larvae within LIS. Other factors, such as predation. Environmental effects, including changes to extremes in seasonal water temperature, may al.so affect the Niantic River habitat (e.g., widely fluctuating larval growth and development. A number of temporal eelgrass abundance), a warming trend in regional and spatial changes were identified in the community of seawater temperature, and interactions with other fishes and macroinvertebrates collected in the MPS species (e.g., predation), especially during early life trawl monitoring program. These changes were history, are also important processes affecting Winter unrelated to the operations of MPS, but rather were Flounder population dynamics. associated with shifts in the dominance of individual Results from Winter Flounder studies through 2014 taxa* from changes in habitat, range extensions or suggest that MPS operations have had minimal effects contractions related to a warming trend in ambient on Winter Flounder biomass in the Niantic River. seawater temperature that has occurred over the past Declines in stock size have been greatly evident on a three decades, and changes in fishing rates and fishing regional basis, including Long Island Sound, Rhode regulations.

Island and all other Southern New England waters.

Entrainment during the larval life stages of Winter Flounder occurs, however there has been large variation in the amount of larval mortality and recruitment in recent years, both occurring independently of MPS operations.

Fish Ecology Studies Results from the Fish Ecology monitoring studies during 2014 indicate that no long-term abundance trends for various life stages of seven selected species could be directly related to MPS operation. No significant long-term trends in abundance were identified for Anchovy, Cunner and Tautog eggs, American Sand Lance, Anchovy, and Grubby larvae, or Executive Summary m

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