ML17328A688

Annual Environ Operating Rept,Jan-Dec 1989.

ML17328A688
Person / Time
Site:	Cook
Issue date:	12/31/1989
From:	INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:
Shared Package
ML17328A687	List: ML17328A686 ML17328A688 ML17328A689
References
NUDOCS 9005040235
Download: ML17328A688 (124)

Text

nnua nvironmen a era in e January 1, Through December 31, 1989 indiana & Michigan Electric Company Bridgman, Michigan Docket Nos. 50.315 & 50-316 License Nos. DPR-58 & DPR-74 Docket 0 Accession 0 'PooSo Date Ma F~ of Ltr RegUla ory Docket File

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TABLE OF CONTENTS

~pa e I. Introduction II. Changes to the Environmental Technical Specifications III. Non-Radiological Environmental Operating Report A.l Plant Design and Operation A.2 Reporting Related to the NPDES Permit and State Certification B.l Environmental Monitoring C.l Aquatic Studies C.2 Asiatic Clam (Corbicula)

IV. Solid Radioactive Waste Treatment System Radiological Environmental Monitoring Program (REMP)

A. Changes to the Radiological Environmental Monitoring Program (REMP)

B. Radiological Impact of Donald C. Cook Nuclear Plant Operations C. Land Use Census

I LIST OF APPENDICES

~Aendix Title NPDES Nonroutine Reports - 1989 Herbicide Application Program - 1989 Asiatic Clam Monitoring Program - 1989 NPDES Permits 1989 Annual Report: Radiological Environmental Monitoring Program 5.A Radiological Environmental Monitoring Program Summary - 1989 5.B Data Tables 5.C Analytical Procedures Synopsis 5.D Summary of EPA Interlaboratory Comparisons 5.E REMP Sampling 6 Analytical Exceptions 5.F Land Use Surveys 5.G Summary of the Preoperational Radiological Monitoring Program 5.H Operational REMP Data 5.I Summary of the Blind Duplicate Sample Program 5.J TLD Quality Control Program Tritium Concentration Comparison Chart

I INTRODUCTION Technical Specification Section 6.9.1.6 and Appendix B, Part II, Section 5.4.1 require that an annual report be submitted to the Nuclear Regulatory Commission which details the results and findings of ongoing environmental radiological and non-radiological surveillance programs. This report serves to fulfill these requirements and represents the Annual Environmental Operating Report for Units 1 and 2 of the Donald C. Cook Nuclear Plant for the operating period from January 1, 1989 through December 31, 1989.

During 1989, based on the monthly operating reports for Unit 1 and Unit 2, the annual gross electrical generation, average unit service factors and capacity factors were:

Parameter Unit 1 Unit 2 Gross Electrical Generation (MwH) 5,654,030 6,899,890 Unit Service Factor (0) 69.1 74.3 Unit Capacity Factor - MDC* Net (0) 60.6 71.6

• Maximum Dependable Capacity Based upon the results of the radiological environmental monitoring program and the radioactive effluent release reports for the 1989 reporting year, it can be concluded that there were no adverse affects to the environment or to the general public due to the operation of the Donald C. Cook Nuclear plant.

CHANGES TO THE ENVIRONMENTAL TECHNICAL SPECIFICATIONS There were no changes to the Environmental Technical Specifications during the year of 1989.

III. NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT Environmental Protection Plan (EPP)

A.l Plant Design and Operation During 1989 no noncompliance with the Environmental Protection Plan occurred, nor were there any changes in station design, operations, tests or experiments which involved a potentially significant unreviewed environmental issue.

No construction activities during the reporting period occurred which required an environmental assessment of the activity.

A.2 Reporting Related to the NPDES Permit and State Certification NPDES Permit ¹MI0047856 was issued to Donald C. Cook Nuclear Plant for the groundwater remediation pro]ect.

The existing Permit ¹MI0005827 was amended to delete oil and grease sampling for outfalls OOA, OOB, and OOC.

B.l Environmental Monitoring During the month of May, Noxious Vegetation Control, Inc. applied a mixture of Karmex, Krovar, and Banvell 700 to 36 acres of land to control grass and weed growth on the plant site.

No right-of-way maintenance was performed on Cook Nuclear Plant lands in 1989.

C.l Aquatic Studies C.2 Asiatic Clam (Corbicula)

Diver-collected sand and gravel samples, beach areas and samples from service water structures at Donald C.

Cook Nuclear Plant were examined for the presence of the Asiatic clam Corbicula Fluminea in 1989. No veligers, small or adult clams, or empty shells were detected in any of the entrainment, diver-collected sand and gravel samples, or beach areas sampled. Two additional specimens of Corbicula were identified since the 1988 report. One was a live specimen removed from a non-essential service water pipe in December 1988.

The second specimen was a Corbicula half shell removed from a condenser tube on the outlet side of the Unit 2 East Main Feedpump Condenser Waterbox during a routine inspection on November 12, 1989. However, from our data, we concluded that no population has become established nor has a reproducing population been detected at the Cook Nuclear Plant. At present, Corbicula does not appear to be a threat to operation of the water systems at the Plant; however, because occasional specimens do occur, there will be an increase in our observation and monitoring program.

SOLID RADIOACTIVE WASTE TREATMENT SYSTEM During the year of 1989, there were no major changes to the Donald C. Cook Nuclear Plant's Solid Radioactive Waste Treatment System.

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM REMP The Radiological Environmental Monitoring Program is designed to serve the following purposes; Establish baseline radiation levels in the environment prior to the Plant's operation.

2. Monitor potential critical pathways of radioactive effluent to man.

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3. Determine radiological impact on the total environment caused by the operation of the Donald C. Cook Nuclear Plant.

A. Chan es to the Radiolo ical Environmental Monitorin

~Pro ram ~REHP A.l During 1989 two (2) new thermoluminescent dosimetry (TLD) stations were established.

A surveying firm conducted a remapping of the Donald C.

Cook Nuclear Plant area, using updated mapping technology. The survey generated new sector coordinates which affected the sector locations of existing TLD stations. As a result, no existing TLD stations were located in sectors A and D. A new TLD station was subsequently added to sector A (A-11) and to sector D (A-12).

A.2 The remapping of the Plant area also resulted in the refinement of the distances to the nearest residences for each land sector. The new distances were incorporated into the Plant's offsite dose assessment program.

A.3 A new analytical contractor, Teledyne Isotopes, began performing REMP analyses in November 1989. Services with the previous lab, CEP, have been discontinued.

B. Radiolo ical Im act.of Donald C. Cook Nuclear Plant 0 erations The various analyses of most sample media suggest that there was no discernible impact of the nuclear plant on the environment. The analysis of air particulate filters, charcoal cartridges, direct radiation by thermoluminescent dosimeters, fish, water, and sediments from Lake Michigan, drinking water, and food products, either did not detect any radioactivity or measured only naturally occurring radionuclides at normal background levels. Of the 174 milk samples analyzed for iodine-131, three samples had measurable activity, but very low concentrations. The highest iodine-131 concentration was only two times the required measurement sensitivity.

Tritium, measured at low levels in onsite wells, appears to be the only radionuclide attributable to Plant operations. The 1989 onsite tritium concentrations are well below the Technical Specification reporting levels and are 14% - 40% below the 1988 mean values.

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As stated in the 1988 Annual Report, the tritium activity in the onsite wells is attributed to primary to secondary leakage, It is anticipated that the repair of Unit 2 steam generators in 1988 will result in a decline in tritium concentrations. These tritium concentrations will continue to be evaluated as part of

.the REHP data reviews.

Land Use Census The 1989 Milk Farm Survey identified two minor changes from the 1988 survey. One milk farm changed ownership and an established farm added a dairy operation. These changes did not affect the milk sample collection program or the calculation of off-site doses through the milk pathway.

The milk animal previously identified as closest to the plant center line axis remains the closest milk animal.

The closest milk animals for each sector are identified in the Milk Survey Table at the end of Appendix F.

The 1988 Land Use Survey identified the need to verify the distance to the nearest residences in each of the land sectors. A review of drawings, photographs, and other documentation was performed by the AEP Civil Engineering laboratory to establish the new distances using available data. The results of this review were included in the 1988 Annual Environmental Operating Report.

A surveying firm was subsequently contracted to remap the Cook Nuclear Plant area and establish residence distances using updated technology. The new distances are reflected in the 1989 Annual Environmental Operating Report and have been incorporated into the Cook Nuclear Plant offsite dose assessment program.

I APPENDIX 1 NPDES NON-ROUTINE REPORT 1989

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NONROUTINH REPORTS EVENT DATE DFSCRIPTION February 24, 1989 Unit 2 Main Turbine Iuhe Oil Cooler Leak to the Nonessential Rervice Water System April 5, 1989 Unit 2 Main Turbine Luhe Oil Cooler Leak to the Nonessential Service Water Rystem Nay 10, 1989 Turbine Room Sump Continuous pH Praeter Was Found Inoperative Reptemher 19, 1989 Unit 2 Noncontact Coolincr Water Total Residual Chlorine Exceeded NPDFR Permit Limits Octoher 25, 1989 Product Recovery Unit Total Recoverable Petroleum Hydrocarbons Exceeded NPDES Permit Limits, and Weekly Influent. Samples for Total Suspended Solids Were Not Collected

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APPENDIX 2 HERBICIDE APPLICATION REPORT 1989

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Z IN'A NICHIOiAN IIOHNk January 2, 1990 Sobi<t 1989 Herbicide Spray Report - Cook Plant From Dane M. McKay.,-

To H. E. Brooks

SUMMARY

OF PROGRAM A. During the month of May, Noxious Vegetation Control, Inc.

applied a mixture of Karmex, Krovar and Banvell 720 to control grass and weed growth on the plant site.

Locations treated include:

KV switchgear yards, roadways, parking lots, perimeters of the sewage ponds, and controlled/uncontrolled areas inside the plant fence. A total of 224 lbs. of Karmex, 36 lbs. of Krovar, and 8.8 gals. of Banvell 720 was applied over 36 acres.

B. No right-of-wav maintenance was performed on Cook Plant lands in 1989 (see letter from R. J. Cheeney) attached.

C. Major areas covered and observations made in December.

1. Heavv weed growth on sides of Sewage Pond "B".

Verv few weeds on sides of Sewage Pond "A".

2. Road to Absorption Pond: Good weed control on road. No weeds found at all.

3. 765 KV Switchgear Yard: Sparse patches of grass growing throughout vard. Perimeter fence is clear of grass and weeds.

4. 345 Switchgear Yard: Sparse weed growth along south perimeter fence. Control is good in all other areas.

5. Railroad Tracks eas't of Training Center: 'ood weed control, no weeds found at all.

,6. CESA: Good weed control, a few weeds growing along foundation on the north side of the building.

7. Contractor Supervisors Parking Lot: Good weed control, no weeds found at all.

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1989 Herbicide Spray Report January 2, 1990 Page 2

8. East Sewage Plant: Grass and weeds growing along south and west sides of building.

9. South Sewage Plant: Grass and weeds growing along south and west sides of building.

10. 69 KV Switchgear Yard: Good weed control, no grass or weeds growing in yard or along fence.

North Perimeter Fence: Good weed control, no weeds found at all.

12. South Perimeter Fence: Good weed control, no weeds found at all.

13. East Perimeter Fence: Good weed control, no weeds found at all.

14. Old Training Center: Good weed control, some weeds along east side of building.

15. Contractors Trailer Complex: Sparse grass and weeds growing along base of trailers.

16. ICMS Office Trailers: Good control under trailers, no weeds found at all.

17. Insulators Fab Shop: Good weed control along building, no weeds found at'll.

18. Southwest Side of Turbine Building: Grass and weeds growing along foundation of building.

19. South End of Turbine Building: Grass and weeds growing along foundation of building.

20. Unit 1 RWST Area: Good weed control, no weeds found at all.

21. Unit 2 RWST Area: Good weed control, no weeds found at. all.

22-. Hydrogen and Nitrogen Storage Tank Area: Weeds growing along foundation of Auxiliary'uilding.

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1989 Herbicide Spray Report January 2, 1990 Page 3 New areas to be sprayed next year:

REMP Air Stations, Main Met Tower Building, Environmental Pole Barn, Environmental Warehouse, Construction Fab Shop, Diesel Fuel Oil Tank Berm, Unit 1 Emergency Diesel Fuel Unloading Berm.

The observations made in December clearly indicate that the thorough spraying program continues to control encroaching vegetation, resulting in a reduction of maintenance costs and improving overall plant site visibility.

Dane M. McKav DMM/js c J. j E. Rutkowski/ J. T. Wo cik D. M. Fitzgeral~

C. R. Mort 1989 Annual Environmental Operatincr Report

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COOK NUCLEAR PLANT HERBICIDE APPLICATION DATA 1989 Herbicide Application By: Noxious Vegetation Control, Inc.

Name of Applicator: Todd Thomas Gals. of Lbs. Lbs. Banvell Gals. Acres Date Location Karmex Krovar 720 H20 Covered 5-25-89 765 KV Yard 112 21 4.4 1750 21 5-25-89 345 KV Yard 16 .6 250 5-26-89 69 KV Yard, 32 1.25 500 Sewage Plant, Old Training Center, Peri-meter Fences, Trailer Com-plex, Contractor Supv. Lot, CESA 5-26-89 ICMS Trailers, 64 2.5 500 Fab Shoo, RWST Areas, Storage Tank Area, Road to Ponds, Sewaqe Ponds, Railroad Tracks 224 36 8.8 3000 36 lbs. lbs. Gallons Gallons Acres

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INDIANA NlCHIGAN POWER Date December 18, 1989 Subject Right-of-Way Maintenance Herbicide Use on Cook Plant Lands From R. J. Cheeney To D. MoKay Cook Plant There was no maintenance work done on Cook Plant lands in 1989.

Therefore, no herbicides were used. If you have any questions, please call me at Extension 2254.

R. J. Cheeney RJC:et c: H. E. Brooks Intra-System

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APPENDIX 3 ASIATIC CLAM MONITORING PROGRAM 1989

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A Technical Report To:

THE D. C. COO@ NUCLEAR PLANT AMERICANELECTRIC POWER SERVICE CORPORATION INDIANAAND MICHIGANELECTRIC COMPANY RESULTS OF TIM 1989 MONITORIING PROGRAM TO DETECT THE ASIATIC CLAM (CORBICUJA.)

IN THE VICINITYOF THE D. C. COOK NUCLEAR PLAtA'II'H A SUMIWWY OF 1982-1988 RESULTS By DAVID S. WHITE & SUSAN P. HENDRICKS

&VlCOCKBIOLOGICALSTATION ON KENTUCKYLAKE MURRAY STATE UNIVERSITY MURRAY, KENTUCKY 42071 (502) 474-2272 December 13, 1989

SURGERY Entrainment, diver-collected sand and gravel samples, beach areas and samples from service water structures at the D. C. Cook Nuclear Plant were examined for the presence of the Asiatic clam Corbicula fluminea in 1989. Data from the 1982 through 1989 monitoring program are summarized. No veligers, small or adult clams, or empty shells were detected in any of the entrainment, diver-collected sand and gravel samples, or beach areas sampling. One half shell of Corbicula was identified as a specimen taken from one of the condenser tubes on the outlet side of the Unit 42 East Main Feedpump Condenser water box during a routine inspection for condenser tubes leaks on November 12, 1989. One additional specimen of Corbicula from the Cook Plant was identified since the 1988 report. It was a live specimen removed from a non-essential service water pipe in December 1988. The only other confirmed report of the species was a single diver-collected empty shell we examined in 1984. No other Corbicula have been collected from any site in Lake Michigan in the immediate vicinity of the D.

C. Cook Nuclear Plant.. Live Corbicula were collected in Lake Michigan near the J. H. Campbell Power Plant (White et al. 1984) north of the D. C. Cook Nuclear Plant in November 1983. We have seen no published data or additional specimens to confirm that the population near the Campbell Plant still exists, but we have had verbal communication that it does. However, from our data, we concluded that no population has become established nor has a reproducing population been detected at the D. C Cook Nuclear Plant. At present, Corbicula does not appear to be a threat to operations of the water systems at the D. C.

Cook Nuclear Plant; however, because occasional specimens do occur, an increased level of observations or monitoring is recommended.

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INTRODUCTION Corbicula Duminea (Muller) (=Corbicula manilensis) was introduced into the Columbia River of Washington State in the late 1930s and since has spread eastward throughout the Mississippi River drainage and most recently (1980-1981) into Lake Erie. For Lake Michigan, a small population was detected near the J.

H. Campbell power plant (southeastern Lake Michigan) in November 1983 (White et al. 1984), and the first empty shell at D. C. Cook was identified 22 May 1984 from diver-collected sand and gravel from the water intake.

Biofouling of power plant service water systems by Corbicula in the Mississippi and southern drainages and now western Lake Erie has prompted monitoring of Great Lakes nuclear plants to allow for early detection and creation of control procedures. A monitoring program specifically for Corbicula was initiated at the D. C. Cook power plant in 1982. In that year, three 24-hour entrainment samples were examined for veligers (planktonic larvae) and small clams. Entrainment samples are collected in one of the forebays using a pump and either a 830 or 420 net following the methods summarized in Zdeba and White (1985). Dates of sampling in 1982 were late May, mid-August, and early October (Table 1). Entrainment samples were supplemented by collections of clam shells washed onto the beach in front of the power plant and near the mouth of the St. Joseph River. Beach walks of at least 300 meters were begun in late September and late October 1982 (Table 1). The St. Joseph River site was chosen as a possible point of entry of Corbicula into Lake Michigan. No Corbicula veligers or small clams were detected in 1982 in entrainment samples nor were specimens found in the more than 400 shells (primarily fingernail clams in the family Pisidiidae) collected in beach walks. Shells of Corbicula are much more sturdy than are shells of pisidiids; thus, if present in the lake, they should wash ashore (White 1979). Further, no Corbicula had been collected in lake benthos sampling programs from 1970 through April 1982 or in previous entrainment studies nor had there been any validated reports of Corbicula being collected from Lake Michigan or its drainage (Mackie et al. 1981, Zdeba and White 1985).

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TABLE 1 Sampling dates, sample type, and numbers of Corbicula collected from 1982 through 1989 at the D. C Cook Nuclear Plant.

Date Sample Type Diver- Internal Collected Water Entrainment Beach Walk Sand & Gravel Systems 1982 25-26 May none 18-19 Aug none 21 Sep none 5-6 Oct none 26 Oct none 1983 15-16 Jun none none 13-14 Jul none none 17-18 Aug none none 1984 22 May 14-15 Jun none none 12-13 Jul none none 16-17 Aug none none 1985 13-14 Jun none none July none 12-13 Jul none none none 15-16 Aug none none none

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1986 16-17 Jun none none 14-15 Jul none none 18-19 Aug none none 1987 15-16 Jun none none 15-16 Jul none none 10-11 Sep none none Fall none 1988 June none 24-25 Jun none none 22-23 Jun none none 19-20 Aug none none December 1989 26-27 Jun none none 25-26 Jul none none 16-17 Aug none none 26 Sept none 13 Oct none 12 Nov 16 Nov none

• intact empty Corbicula shell, identification date live Corbicula clam half Corbicula shell

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RESULTS OF SA2dPLING DURING THE 1983-1989 MONITORING PERIOD Entrainment samples, beach walk collections, and diver-collected gravel samples were again examined in 1983, 1984, 1985, 1986, 1987, 1988 and 1989.

Beginning in 1983, sampling periods were moved to mid-June, mid-July, and mid-August, based upon life cycle data gathered for western Lake Erie by Scott-Wasilk et al. (1983), The mid-August period for 1987 was delayed until early September due to pump malfunctions. All sampling pumps were working well in 1988 and 1989, and samples were again taken in June, July, and August (See Table 1 for sampling dates). No specimens of Corbicula (juveniles or veligers) were found in thorough examination of the 1989 entrairiment samples nor in the 1982-1988 entrainment samples. Several hundred Pisidiidae (fingernail clams)

Unionidae (freshwater mussels) and snails have been collected in the beach walks in 1989 and each previous year, but no Corbicula have been located on the beaches either at D. C. Cook or at the mouth of the St. Joseph River.

Two diver-collected samples (13 October and 16 November) from the intake structures were examined. Both contained sand, hundreds of fragments and half shells of Pisidiidae (fingernail clams), a few fragments of Unionidae (freshwater mussels), and numerous whole and fragments of snail shells. None of the clam fragments appeared to be Corbicula. Corbicula shells are much more resistant to breakage, and if present, should have been detected.

One sample was examined (26 September) that had been collected from the Unit I non-essential service water strainer by maintenance personnel. This sample also contained numerous fragments of Pisidiidae and some snail shell fragments but no Corbicula, On November 15, 1989, we received a single half shell of a clam that had been found lodged in one of the condenser tubes on the outlet side of the Unit 42 East Main Feedpump Condenser water box during a routine inspection for condenser tube leaks on November 12, 1989. This shell was confirmed as Corbicula. The shell was 21 mm long and in good condition Prior to this year's sampling and just after submitting the 1988 report, we received (23 December 1988) a live specimen of Corbicula collected from the" D.

C. Cook Plant. The clam was removed from a non-essential service water pipe that had been opened to correct a leak. According to Cook Plant personnel, approximately 760 feet of this pipe was visually checked and this was the only

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specimen found. The water pipe was 1" ID with a flow of 15-60 gal min i.

Water temperatures in the pipe reflected ambient Lake Michigan water, which at the time of collection was about 35 'F. The clam was kept alive in our laboratory for about a week until preserved in alcohol. The specimen was mature and aborted some newly-forming veligers upon preservation.

This brings the total number of Corbicula found at the D. C. Cook Plant to 3: one whole but empty shell identified May 1984, one live clam in December 1988, and one empty half shell in November 1989. Previously we had identified 10 live Corbicula from a November 1983 diver-collected sample near the J. C.

Campbell Power Plant, (White et al. 1984) which were assumed to be in their first year of growth. We have no additional hard data to conflrm if that population has survived or died out (word of mouth suggests that it has survived).

Data on that population, if remaining, might provide ecological insights for the potential of Corbicula establishment at D. C. Cook The shell identified in 1984 also appeared to be in its first year of growth. It was our opinion that the specimen was quite recent because it was intact, and it appeared to be of the same cohort as the specimens collected near the J. C. Campbell Power Plant.

The two specimens from the 1988 and 1989 samples appeared to be in their second year of growth and probably were mature.

From these very limited data, it is evident that Corbicula, at least in low numbers, does occur regularly in the vicinity of the D. C. Cook Plant. However, it appears that no detectable breeding population has become established and that Corbicula at this time does not present a threat to operations of the water systems. The finding of two large specimens of breeding age confirms that at least some Corbicula are living beyond the single season of the specimens collected in 1983 at the Campbell Plant and identified in 1984 at D. C Cook.

CONCLUSIONS No Corbicuja veligers or small clams were collected in the 1989 entrainment, diver collected samples, or beach samplings. Two large specimens were found in water supply pipes in 1988 and 1989. Survivorship appears to be, confined to the plant itself. We do not suspect that Corbicula is present in Lake Michigan in the vicinity of the D. C. Cook Nuclear Plant, but if occasionally present, the populations have remained so small as to be nearly undetectable and probably have not posed a threat to plant operations. Thus the potential for

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establishing a breeding population may exist and we would recommend an increased awareness of Corbicula with appropriate increased levels of observations of the water system and possibly increased monitoring.

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REFERENCES CITED Mackie, G. L, D. S. White, and T. W. Zdeba. 1980. A guide to freshwater mollusks of the Laurentian Great Lakes with special emphasis on the genus Pisidium. EPA-600/3-80-068. 144 pp.

Scott-Wasilk, J., G. G. Downing, and J. S. Leitzow. 1983. Occurrence of the Asiatic clam Corbicula fluminea in the Maumee River and Western Lake Erie. J. Great Lakes Res. 9:9-13.

White, D. S. 1979. The effect of lake-level fluctuations on Corbicula and other pelecypods in Lake Texoma, Texas and Oklahoma. Proc. 1st Internat.

Corbicula Symp. pp. 81-88.

White, D. S,, M. H. Winnell, and D. J. Jude. 1984. Discovery of the Asiatic clam, Corbicula fluminea in Lake Michigan. J. Great Lakes Res. 10:329-331.

Zdeba, T. W., and D. S. White. 1985. Part 4: Pisidiidae. 93 pp. In: D. S. White (ed.). Ecology of the zoobenthos of Southeastern Lake Michigan near the D. C Cook Nuclear Power Plant. Spec. Rept. Great Lakes Res. Div.,

Univ. Mich., Ann Arbor, Mich.

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APPENDIX 4 NPDES PERMITS 1989

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STATE OF MICHIGAN NATURAL REsouRcEs coMMissioN THOMAS J. ANOERSON RLENE J. FLUHARTY ROON E. BUYER

.ERRY KAMMER ELLWOOO A. MATTSON JAMES J. BLANCHARD, Governor O. STEWART MYERS RAYMONO POUPORE DEPARTMENT OF NATURAL RESOURCES STEVENS T, MASON BUILOINO P.O. BOX 30029 LANSING, Ml 48909 OAVIO F. HALES, Director September 1, 1989 CERTIFIED MAIL Indiana Michigan Power Company P.O. Box 60 Fort Wayne, Indiana 46801 Gentlemen:

SUBJECT:

NPDES Permit No. MI0047856 Donald C. Cook Nuclear Plant Bridgman, Michigan Your National Pollutant Discharge Elimination System (NPDES) Permit r has been processed in accordance with appropriate state and federal regulations. It contains the requirements necessary for you to comply with state and federal water pollution control laws.

REVIEW THE PERMIT EFFLUENT LIMITS AND COMPLIANCE SCHEDULES CAREFULLY.

These are subject to the criminal and civil enforcement provisions of both state and federal law. Permit violations are audited by the Michigan Department of Natural Resources and the United States Environmental Protection Agency and may appear in a published quarterly noncompliance report made available to agencies and the public.

Your monitoring and reporting responsibilities must be complied with in accordance with this permit. If applicable, Discharge Monitoring Report forms will be transmitted to you in the near future. These reports are to be .submitted monthly or otherwise as required by your NPDES permit.

Any reports, notifications, or questions regarding the attached permit or NPDES program should be directed to the following address:

Fred Morley, District Supervisor 621 North Tenth Street P.O. Box 355 Plainwell, Michigan '9080 . ,I .8CElVED I Telephone: (616): 685-9886 SEP 05 1989 5NVIRONNENTAL AFFAIRS R1090 3199 a5

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Zndiana Michigan Power Company Page 2 September 1, 1989 NOTE: All references within this permit made to the Water Quality Division or'hief of the Water Quality Division are to refer to the Surface Water Quality Division or Chief of the Surface Water Quality Division, respectively.

Sincerely, l~ 4.'~'>~ +~~'~~

William E. McCracken, P.E.

Chief, Permits Section Surface Water Quality Division 517-'373-8088

Enclosure:

Permit cc: EPA-Region V (2) 208 Agency - Southwest Michigan Regional Planning Commission Planning and Special Programs Section Mr. Fred Morley - Plainwell District (2)

Mr. Paul Blakeslee, Regional Supervisor, Region III Compliance and Enforcement, SWQD Data Entry, SWQD Point Source Studies (Grand Rapids District Office)

Files

PERMIT NO. MI0047856 MICHIGAN WATER RESOURCES COMMISSION AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.C. 1251 et seq; the "Act"), and the Michigan Water Resources Commission Act, as amended, (Act 245, Public Acts of 1929, as amended, the "Michigan Act"),

Indiana Michigan Power Company P.O. Box 60 Fort Wayne, Indiana 46801 is authorized to discharge from a facility located at Donald C. Cook Nuclear Plant One Cook Place Bridgman, Michigan 49106 designated as IN MI Power Co-Cook GWCU

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to the receiving water named the Lake Michigan in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I and II hereof.

e This permit for a new use takes immediate effect on the date of issuance, unless the applicant either administratively or 5udicially challenges any condition of this permit, in which case the entire permit is stayed and all authorizations explicitly or implicitly contained in the permit cease. Any person who feels aggrieved by this permit may file a sworn petition with the Executive Secretary of the Michigan Water Resources Commission, setting forth the conditions of the permit which are being challenged and specifying the grounds for the challenge. The Commission may re)ect any petition filed more than 60 days after issuance as being untimely. During the course of any administrative proceeding brought by a person other than the applicant, the conditions of this permit will remain in effect, unless the Commission determines otherwise.

This permit and the authorization to discharge shall expire at midnight December 1, 1989.

This permit is based on an application submitted on May 8, 1989.

Issued this 23rd Commission.

day of Au ust, 19 89, hy the Michigan Mater Resources ACTl~tiG Paul D. Zugger Executive Secretary

PERMIT HO. MI0047856 Page 2 of 12 PART I

) E. EEELUEHT LIMITRTI0Hs SHU MUHITURIRG REOUIREMEHTs

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1. Final Effluent Limitations, Outfa11 OIS Beginning upon faftfatfon of discharge aad lasting until expiration of this permit, the permittee fs authorized to discharge tvo hundred and sixteen thousand (216,000) gallons per day of treated groundwater and an unspecified amount of stormvater runoff through outfall OIS to lake Michigan. Such discharge shall be limited and monitored by the permittee as specified belov:

Dfschaz' Lfmftatfons lbs da . Other Limitatfons Monitorin Re frements Effluent Monthly Daily Monthly Daily Measurement Sample Chazacteristfc ~avaaa a Maafaaa ~avava ~ Maaiaaaa *a Daily Report Total Daily Plow BTX, see Part I.A.l.a., below: 20 ug/1 Monthly Grab Total Recoverable Petroleum Hydrocarbons, see Part I.A.1.a., below: 0.5 mg/1 Weekly Grab-.

Outfall Observation 5X/Week Visual a'TX shall be defined toluene, and xylenes fn as the summatfon Che of the concentrations of benzene, effluent dfscharge. BTX shall be analysed for using U.S. EPA Test Method 602 or approved equal. Total Recoverable Petroleum Hydzocarboas shall be analysed for using U.S. EPA Method 418.1. The reported detection level for the U.S. EPA test method 418.1 is 1.0 mg/1, lover detection levels have been reported on individual sample analysis. The permittee shall determine an appropriate detection level 'for the discharge from the treatment sysCcma

b. The rcccfvfng vater shall contain ao unnatural turbfdity, color, of1 film, floating solids, foams, settleable solids, or deposits as a result of this discharge.

c. Samples, measurements, and observations taken fn compliance vith the monitoriag requirements for outfall OIS shall be taken after the activaCed carbon treatment system and prior to discharge into the existing existing stozmwater collcctfoa system.

d. Any unusual chazacterfstics of the discharge (i.eas unnatural turbidity, color, oil fiIm, floating solids, foams, settleable solids or deposits) shall be reported immediately to the Plafnvell District Offfce of the Surface Water Quality Division followed vfth a written report vithin 5 days ditaflfng the fin'diags of the

,fmrestfgatfon and thi.steps taken to correct the condition.

e. 'n thy event Che permittee shall require Che discharge of vater treatment

'dditives, the permittee shall notify the Plainvell Dfstrict Supervisor of the Surface Water Quality Division. The permittee shall obCain mitten approval from thc Plafnwell District Supervisor to discharge such additives at a specified level.

The permit may be modified in accordance with the requirements of Part II.B.4 if a constituent of the addftive or additives requires limiting.

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PERMIT HO MI0047856 Page 3 of 12 PART I

~ Section B.

2. S ecial Condition - Basis of Design, Plans and Specifications, and an Operations and Maintenance Manual Best Available Treatment (BAT) is a two-stage activated carbon system, or equivalent. Prior to constxuction of the treatment system, the pexmi.ttee shall receive the approval of the Plainwell District Supervisor of the Surface Water Quality Division for: a basis of design, and plans and specifications.

Prior to discharge, the permittee sha11 receive the approval of an operations and maintenance manual for the proposed treatment system. The operations and maintenance manual shall include a sampling program, consistent with the approved design, for influent, intermediate stage, and effluent testing. The sampling program shall, upon approval, be considered a condition of this permit.

3. S ecial Condition - Short Term Waste Characterization Study N

hs,a condition of this permit and upon initiation of discharge the permittee shall monitor the discharge from the treatment system (identified as outfall OIS in this permit) and the influent to the treatment system for the constituents, at the frequency, and for the duration specified below. This monitoring is designed to.

determine whether these constituents are discharged in significant quantities. .The resuIts of the analysis of such. monitoring shall be submitted to the Supervisor of the Surface Water Quality Division in accordance with Part Plainwell,-'istrict I.C;3, Schedule of Compliance. If, upon review of the analysis, it is determi'ned that any of the materials. or constituents require limiting to protect the receiving waters in accordance with applicable ~ater quality standards, the permit may then be modified after public notice and Commission approval of the recommended permit modification in accordance with Part II.B.4.

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II'OHSTITUEHT SAMPLE TYPE SAMPLE PRE UENCY AHD DURATIOH TEST METHOD Total Suspended Solids Grab Weekly for Six (6) Weeks pH (Standard Units) Grab Weekly for Six (6) Weeks

4. S ecial Condition - Reopener Clause This permit may be modified or, alternatively, revoked and reissued to comply with any applicable standard(s) or limi.tation(s) promulgated under Section 301(b) (2) (c) (d), 304(b) (2) and 307(a) (2) of the Act, if the effluent standard(s) or limitation(s) so promulgated:

a. is(are) either different in condition or more stringent than any effluent limitation in the permit; or b'... contxol(s) any pollutant not limited. in the permit.

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Zmrr Ho. M10047856 Page 4 of 12 PART I

)Ssceian A.

5. S ecial Condition - Notification Requirement The discharger shall notify the Plainwell District Supervisor of the Surface Water Quality Division, in writing, within 10 days of knowing, or having reason to believe, that any activity or change has occurred or will occur which would result in the discharge of:

a. Detectable levels* of chemicals on the current Michigan Critical Materials Register or priority pollutants or hazardous substances set forth in 40 CFR 122.21, Appendix D, which were not acknowledged in the applicationee or listed in the application at less than detectable levels.

b. Detectable levels* of any other chemical not listed in the application or listed at less than detection, for which the application specifically requested information.

c. Any chemical at levels greater than five times the average level-reported

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in the'pplication++.

Any other monitoring results obtained as a requirement of this permit shall be reported in accordance with the schedule of compliance.

• The detectable level shall be defined as the Method Detection Limit (MDL) as given in Appendix B to Part 136, Federal Register, Vol. 49, No. 209, October 26, 1984, pp. 43430>>31.

+eThe application submitted on May 8, 1989.

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6. S ecial Condition Discharge to the Groundwaters This site is a known source of groundwater pollution. The issuance of this permit does not authorize any discharge to the groundwaters or venting of contaminated groundwaters to the surface waters, nor does it constitute a release of liability for any groundwater contamination at or around the site. The State reserves its rights to seek remedies to abate any groundwater contamination.

PEKMIT NO. M10047856 Page 5 of 12 PART I

~ B. MOHITORIHG MD REPORTZHG I. Representative Sampling Samples and measurements taken as required herein shall be representative of the volume and nature of the monitored discharge.

2. Reporting:

a. DMR Submittal Re uirements - The permittee shall submit Discharge Monitoring Report (DMR) forms to the Michigan Department of Natural Resources, Surface Water Quality Division, Data Entry Unit, P.O. Box 30028, Lansing, Michigan, 48909, for each calendar month of the authorised discharge period(s).

The DMRs shall be postmarked no later than the 10th day of the month .following each month of the authorized discharge period(s).

3. Definitions

a. r The monthly average discharge is defined as the total discharge by weight, or concentration if specified, during the reporting month divided by-the number of 'days in the reporting month that the discharge from the production or commercial facility occurred. If the pollutant concentration in any sample is less than the detection limit, regard that value as sero when calculating .

,'onthly average concentration. When less than daily sampling occurs, the monthly average discharge shall be determined by the summation of the measured daily discharges by weight, or concentration if spe'cified, divided by the number of days during the reporting month when the samples were collected, analyzed and reported.

b. The daily maximum discharge means the total discharge by weight, or concentration if specified, during any calendar day.

c. The Regional Administrator is defined as the Region V Administrator, U.S.

EPA, located at 230 South

Dearborn,

13th Floor, Chicago, Illinois, 60604.

d. The Michigan Water Resources Commission is located in the STEVENS T. MASON BUILDING. The mailing address is P.O. Box 30028, Lansing, Michigan, 48909.

e. The Chief of the Surface Water Quality Division's mailing address is P.O. Box 30028, Lansing, Michigan, 48909.

4. Test Procedures Test procedures for the analysis of pollutants shall conform to regulations published pursuant to Section 304(h) of the Act, under which such procedures may be required. I

PERMIT NO. MI0047856 Page 6 of 12 PART I Section B.

5. Recording Results Por each measurement ox sample taken pux'suant to the requirements of this permit, the permittee shall record the folio@tag information:

a. The exact place, date, and time of samplingg bo The dates the analyses vere performed)

c. The person(s) @ho performed the analyses;

d. The analytical techniques or methods used; and

e. The results of all required analyses.

Additional Monitoxing by Permittee I

If. the permittee monitors any pollutant at the locatioa(s) designated herein more frequently thea required by this permie, using approved analytical methods as specified above, the results. of such monitox'ing shall be included in the calculation and x'eporting of the values required in the Discharge Monitoring Repore. Such increised frequency shall also be indicated.

7. Records Retention All records and information resulting from the monitoring activities required by this permit including all records of analyses performed and calibration and maintenance of inserumeatation and recordings from continuous monitoring

.instrumentation shall be retained for a minimum of three (3) years, or longer if requested by the Regional Administrator or the Michigan Water Resources Commission.

PERMIT NO. MI0047856 Page 7 of 12 PART I Ce SCHEDULE OF COMPLIANCE

1. Prior to the commencement of discharge, the permittee shall notify the Plainwell District Supervisor of the Surface Water Quality Division.

2. 'Prior to construction of the proposed tieatment system, the permittee shall .

receive approval from the Plainwell District Supervisor of the Surface Water Quality Division for the basis of design and plans and specifications., Prior to discharge, the permittee shall receive approval from the Plainwell District Supervisor for an operations and maintenance manual, as required by Part I.A.2.

3. The permittee shall submit the analitical results of the Short Term Waste Characterization Study requirements specified in Part I.A.3, within ninty (90) days of initiating a discharge from outfall OOA.

4.. No later than 14 calendar days following a date identified in the above schedule of compliance, the permittee shall submit to the Plainwell District Supervisor of the Surface Water Quality Division either a report of progress or, in the case of specific actions being required by idencified dates, a uritten statement of compliance or noncompliance. Zn the latter case, the statement shall include the cause of noncompliance, any remedial actions taken, and the probability of meeting the next scheduled requirement. Failure to submit the written statement is gust cause to pursue enforcement action pursuant to the Commission Act and the Part 21 Rules.

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PEART HO MI0047856 Page 8 of 12 PART II A. MANAGEMENT REQUIREMENTS

1. Duty to Comply All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge'of any pollutant. identified in. this permit more frequently than or at a level in excess of that authorized shall constitute a violation of the permit.

It is the duty of the permittee to. comply with all the terms and conditions of this permit. Any noncompliance with the Effluent Limitations, Special Conditions, or terms of this permit constitutes a violation of Public Acts 245, of 1929, as amended, and/or PL 92-500, as amended, and constitutes grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or denial of an application for permit renewal.

2~ Change of Conditions Any anticipated facility expansion, production increases, or process modification which will result in new, different, or increased discharges .of pollutants must be reported by submission of a new application or, will not violate the effluent limitations specified in this permit, if such changes by notice to the Plainwell District Supervisor of the Surface Water Quality Division. Following such" notice, the permit may be modified to specify and limit any pollutant not previously limited.

3. Containment Facilities The permittee shall provide facilities for containment of any accidental losses of concentrated solutions, acids, alkalies, salts, oils, or other polluting materials in accordance with the requirements of the Michigan Water Resources Commission Rules, Part 5. This requirement is included pursuant to Section '5 of the Michigan Water Resources Commission Act 245, P.A. of 1929, as amended, and the Part 5 Rules of the General Rules of the Commissioh.

4. Operator Certification The permittee shall have the waste treatment facilities under direct supervision of an operator certified by the Michigan Water Resources Commission, as required by Section 6a of the Michigan Act.

5. Noncompliance Notification If, for any reason, the permittee does not comply with or will be unable to comply with any daily maximum effluent limitation specified in this permit, the permittee shall provide the Plainwell District Supervisor of the Surface Water Quality Division with the following information, in writing, within five (5) days of becoming aware of such condition:

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

b. The period of,noncompliance, including exact dates and times; or, if not corrected', the anticipated time the noncompliance is expected to continue, and the steps taken to reduce, eliminate and prevent recurrence of the noncomplying discharge.

I PERMIT NO, MZ0047856 Page 9 of 12 PART II

6. Spill Hotiffcation The permittee shall immediately report aay spill or loss of any product, by-product, intermediate product, oils, solvents, vast>> material, or aay other polluting substance vhfch occurs to the surface vatcrs or groundwatcrs of the state by calliag the Department of Natural Resources 24-hour Emergency Response telephone number, 1-800-292-4706 (calls from outmf-state dial 1-517-373-8166); and the permittee shall within tcn (10) days of the spill or loss, provide the state wfth a full written explanation as to the cause aad discovery of'he spill or'oss, clean~ and recovery measures taken, prevcntatfvc measures to be taken, and schedule of implementation. This requirement is included pursuant to Section 5 of the Michigan Water Resources Commission Act 245, P.h. of 1929, as amended.

7. Facili,ty Operation The permittee shall at all times properly operate and mafntain all treatment or control,facilitfcs or systems installed or used by the permittee to achieve

'compliance with the terms aad conditions of this permit.

8. Adverse Impact

'he permittee shall take all reasonable steps to mfnfmfzc aay adverse impact to the surface or groundvatcrs of the state resulting from noncompliance with any cf&lucnt Ihhitation spcciffcd in this permit fncludfng, but not limited to, such accelerated or additional monitoring as necessary to determine the nature and impact of the dfscharge fn noncompliance.

9. By-Passing Any divcrsfon from or by-pass of facilities necessary to maintain compliance vith the terms aad condftfons of thfs pcrmft fs prohibited, except (f) where unavoidable to prevcat loss of life, personal injury, or severe property damage, or (fi) vhcrc excessive storm drainage or runoff vould damage any facilities necessary for compliance with the effluent limitations and prohibitions of this permit. The permittee shall promptly notffy the Plainvcll District Supervisor of the Surface Water Quality Divfsion and the Regional Administrator, fn writing, of such diversion or by-pass.

10. Povcr Failures In order to maintain compliance with the effluent Ifmitations and prohfbftfons

'of thfs permit, the permittee shall either:

a. Provide an alternative povcr source sufficient to operate facflitfcs utilized by permittee to maintain compliance with the effluent limitations and condftfons of thfs permit vhfch provision shall be in'dfcated in.this permit by iacIusfoa of a specific'ompliance date in each appropriate .

"Schedule af Compliance for Effluent Limitations".

b. Upon thc. reduction, loss, or failure of one or more of the primary sources of power to facflftics utilized by the permittee to maintain compliance with the effluent limitations and conditions of this pcrmft, the permittee shall halt, reduce o" otherwise control production and/or all dfschargc fn order to maintain compliance with the effluent Ifmftatfoas and conditions of this permit.

I PERMZT HO MZ0041856 Page 10 of 12 PART II.

Section h.

II. Removed Substances Solids,:.sludges, filter backwash, or other pollutants removed from or resulting from treatment or control of wastawaters shall be disposed of in a manner such as to prevent any pollutant from such materials from entering navigable waters, or the entry of toxic or harmful contsminants thereof onto the groundwaters in concentrations or amounts detrimental to the groundwater resource.

12. Upset Koncompliance Hotification If a process "upset" (defined as an exceptional incident in which there is

.unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee) has occurred, the permittee who wishes to establish the affirmative defense of upset shall notify the Plainwell District Supervisor of the Surface Water Qua1ity Division by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of becoming aware of such conditions and within five (5) days,, provide in writing,'he following information:

a. " That an upset occurred and that the permittee can identify the specific cause(s) of the upset;

,'b. That the permitted wastewater treatment facility was> at the time, being properly operated;

c. That the permittee has specified and taken action on all responsible steps to minimize or correct any adverse impact in the environment resulting from noncompliance with this permit.

In any enforcement proceedings the permittee, seeking to establish the occurrence of an upset, has the burden of proof.

13. Any requirement of this permit which is included under the unique terms of the Water Resources Commission, Act 245, P.A. of 1929, as amended, and rules promulgated thereunder, is not enforceable under the Federal Clean Water Act regulations.

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I 'ERMIT NO. MI0047856 Page 11'of 12 PART II B RESP OHSIBILITIES

1. Right of Entry The permittee shall allow the Executive Secretary of the Michigan Water Resources Commission, the Regional Admiaistrator aad/or their authorized representatives> upon the presentation of credentials:

a. To enter upon the permittee's premises where an effluent source is located or in which aay records are required to be kept under the terms and conditions of this permit; and

b. At reaaoaable times to have access to aad copy any records required to be kept under the terms and conditions of this permit; to inspect any monitoring equipment or moaitoriag method required ia this permit; and to sample any discharge of pollutants.

2. Transfer of Ownership or Control Ia the eveat of aay chaage in control or ownership of facilities from which the authorized discharge emanates, the permittee shall notify the succeeding owner ar coatroller of the existence of this permit by letter, a copy of which shall be .='":

forwarded to the Plsinwell District Supervisor of the Surface Water Quality Division and,the Regional Administrator.

3 Oi Availability of Reports Except for data determined to be confidential under Section 308 of the Act and Rule 2128 of the Water Resources Commission Rules, Part 21, all reports. prepared in accordance with the terms of this permit shall be available for public inspection at

~the offices of the State Water Pollution Control A eac and the Regional Administrator. As required by the Act, effluent data shall aot be considered confidential. Knowingly making any false statement on any such report may result in the impositioa of criminal penalties as provided for in Section 309 of the Act aad Sections 7 and 10 of the Michigan.Act.,

4. Permit Modification After notice and opportunity for a hearing, this permit msy be modified, suspended, or revoked in whole or ia part during its term for cause iacluding, but not limited to, the following:

so Violation of any terms or conditions of this permit; Obtaining this permit by misrepresentation or failure to disclose fully, all relevant facts;. or c.-' change in any condition that requires either a temporary or permanent reduction or elimination of the authorized. discharge.

I PERMIT, NO. MI0047856 Page 12 of 12 PART II Section B.

5. Toxic Pollutanti Notwithstanding Part II.B.4 above, ff a toxic effluent staadard or prohfbftion (iacluding any schedule of compliance specified in such effluent standard or prohibftfoa) fs established under Section 307(a) of the Act for a toxic pollutant which is present in the discharge aad such standard or prohibition fs more stringent than any limitation for such pollutaat ia this permit, this permit shall be revised or modified fa accordance with the toxic effluent standard or prohibition and the permittee so aotiffed 6 Civil aad Criminal Liabflity Except as provided in permit conditfons on "By-Passing" (Part II.A.9, pursuant to 40 CFR 122.41(a)) and "Upset" (Part II.h.12, pursuant to 40 CFR 122.41(n)),

nothing fn this permit shall be construed to relieve the permittee from civil or criminal peaaltfes for noncompliance, whether or not such noncompliance is due to factors beyond his coatrol, such as accfdeats, equipment brea&owns, or labor disputes+

7. Ofl and Hasazdous Substance Liabiifty I kothfng ia this pezmft shall be coastzued to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee may be subject under Section 311 of the Act except as are exempted by federal regulatfons.

8. State Laws Nothing in thfs permit shall be construed to preclude the fastftution of 'any legal action or relfeve the permittee from any zespoasibilities, liabilities, oz penalties established pursuant to any applicable State law or regulation under authority pzeserved by Section 510 of the Act.

9. Pzoyerty Rights The issuance of this permit does not convey any property rights in either real or personal property> or any exclusive privileges, nor does ititauthorise violation of any Federal> State or local laws or regulations, nor does obviate the necessity of obtaining such permits or approvals from other-units of government as may be required by Iaw.

10. Severability The provisions of this permit aze severable, and ff any provision of this permit, or the applfcation of, any provision of this permit to any circumstaaces,. ff.

held invalids .the ayylication of such provision to other circumstances, and the iemafnder of thfs permft; 'shall not be affected. thereby.

11. Hotice to Public Utilitfes (Miss Dfg)

The issuance of this permit does aot exempt the permittee from giving notice to public utilfties and complyiag with each of the requirements of Act 53 of the Pubifc Acts of 1974, being sections 460.701 to 460.718 oi the Michigaa Compiled Laws> when

. constructing facflitfee to meet th>> terms of this permit.

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STATE OF MICHIGAN NATURAL RESOURCES COMMISSION

'AROMAS J. ANDERSON ARLENE J, PLUHARTY 3RDON E. GUYER KERRY KAMMER O. STEWART MYERS JAMES J. BLANCHARD. Governor DAVID 0 OLSON RAYMOND POUPORE DEPARTMENT OF NATURAL RESOURCES STEVENS T, MASON BUILDING P,O. BOX 30028 LANSING. Ml 48909 DAVID P, HALES. OveCIOt May 5, 1989 s>VI<

M4Y 8 i989 CERTIFIED MAIL 1VlRONMEN~

Indiana Michigan Power Company i et At>> ~

One Summit Square P.O. Box 60 Fort Wayne, Indiana 46801 Gentlemen:

SUBJECT:

NPDES Permit No. MI0005827 Cook Nuclear Plant Bridgman, Michigan Your National Pollutant Discharge Elimination System (NPDES) Permit has been processed in accordance with appropriate state and federal regulations.

It contains the requirements necessary for you to comply with state and federal water pollution control laws.

REVIEW THE PERMIT EFFLUENT LIMITS AND PERFORMANCE SCHEDULES CAREFULLY.

These are subject to the criminal and civil enforcement provisions of both state and federal law. Permit violations are audited by the United States Environmental Protection Agency and may appear in a published quarterly, noncompliance report made available to agencies and the public.

Your monitoring and reporting responsibilities must be complied with in accordance with this permit. If applicable, monthly operating report forms will be transmitted to you in the near future. These reports are to be submitted. monthly or otherwise as required by your NPDES permit.

Any reports, notifications, and questions regarding the attached permit or NPDES program should be sent to the following address:

Fred Morley, District Supervisor 621 North Tenth Street P.O'. Box 355 Plainwell, Michigan 49080 Telephone: (616) 685-9886 A I 028 wl c>>

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Indiana Michigan Power Company Page 2 May 5, 1989 NOTE: All references within this permit made to the Water Quality Division or Chief of the Water Quality Division are to refer to the Surface Water Quality Division or Chief of the Surface Water Quality Division, respectively.

Sincerely, z.N William E. McCracken, P.E.

Chief, Permits Section Surface Water Quality Division 517-373-8088

Enclosure:

Permit cc: EPA-Region V (2)

Files Mr. Steve Eldredge, Planning and Special Programs Section Mr. Fred Morley - Plainwell District (2)

Mr. Paul Blakeslee, Regional Supervisor, Region III Compliance and Enforcement, SWQD 208 Agency .- Southwest Michigan Regional Planning Commission Data Entry, SWQD Point Source Studies (Grand Rapids District Office)

I PERMIT No. MI0005827 MICHIGAN WATER RESOURCES COMMISSION AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTAhT DISCHARGE ELIMINATION SYSTEM In 'compliance with the provisions of the Federal Water Pollution Control Act, as amended,',

(33 U.S.C. 1251 et seq; thc "Act"), and the Michigan Water Resources Commission Act, as amended, (Act 245, Public Acts of 1929, as amended, the "Michigan Act"),

Indiana Michigan Power Company Onc Summit Square, P.O. Box 60 Fort Wayne, Indiana 46801 is authorized to discharge from a facility located at Cook Nuclear Plant Onc Cook Place Bridgman, Michigan 49106 designated as IN MI Power Co-Cook Plt to the receiving water named Lake Michigan in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I and II hexeof.

This permit takes effect immediately upon the date of issuance. Any pcxson who feels aggrieved by this permit may file a sworn petition with the Commission, setting forth the conditions of the permit which are being challenged and specifying the grounds for the challenge. The Commission may re)ect any petition filed more than 60 days after issuance 'as being untimely. Upon granting of a contested case to the applicant, the Commission shall revie~ the permit to determine which contested term shall be stayed until the Commission takes its final action. All other conditions of the permit remain in full effect. If the contested condition is a modification of a previous permit condition and the Commission determines the contested condition shall be stayed, then such previous condition remains in effect until the Commission takes final action.

During the course of any administrative proceeding brought by a person other than the applicant, the conditions of this permit will remain in effect, unless the Commission determines otherwise.

This permit aad the authorization to discharge shall expire at midnight Au ust 31, 1,990. In order to receive authorization to discharge beyond the date of expiration, the permittee shall submit such information aad forms as are required by the Michigan Water Resources Commission ao later than 180 days prior to the date of expiration.

This permit is based on an applicatioa submitted on May 4, 1979, as amended, .and shall supersede any and all Orders of Determination, Stipulation, Fiaal Orders of Det'ermination, or NPDES permits previously adopted by the Michigan Water Resources Commission.

e e Issued this 19th dsy of se tenhet; 1985. snd modified this end dey of A~zil 1987.

and modified this 20th day of April ~989 , by the Michigan Water Resources Commission superseding NPDES

'n Permit No. MI0005827, expiring 0 r 31, 1979, r

Pau D. Zugger

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Executive Secretary

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Peamat No. M2 0005827 Pa8e 2 of 22 PART I A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

1. Final Effluent Limitations - Outfalls 001, 002 & 003 (noncontact cooling water and low volume wastes)

During the period beginning on the effective date of this permit and lasting until permit expiration, the permittee is authorized to discharge a maximum of three billion two hundred ninety eight million five hundred eighty three thousand two hundred (3,298,583,200) gallons per day* of noncontact cooling water consisting of condenser cooling water and low volume wastes consisting of steam generator blowdown, heating boiler blowdown and filter backwash through outfalls 001, 002 and 003 to Lake Michigan. Such discharge shall be limited and monitored by the permittee as specified below:

Dischar e Limitations lbs/da Other Limitations Monitorin Re uirements Effluent Monthly Daily Monthly Daily Measurement Sample Characteristic ~Aveua e Maxfmum ~Aveua e Maximum Flow (MGD) Daily Report Total Daily Plow Temperature ('F) 3 instantaneous Intake Daily readings equally Discharge** Daily spaced over a 24-hr period Heat Addition (BTU/hr) 15.5 x 10 9 'aily Calculation Total Residual Chlorine (TRC)*** 0.1 mg/1 5 x weekly ~

3 grab samples equally spaced during discharge of chlorine Chlorine Discharge Time 30 min./day 5 x weekly Report discharge time Outfall Observation**** Daily Visual This flow is not to be considered as a limitation on either the quanity or rate over time of discharge.

• • The discharge, after mixing, shall not increase the temperature of Lake Michigan more than 3'F above the existing natural temperature or above the following monthly maximum temperatures:

JAN 45 .

FEB 45 MAR 45 APR 55

'AY 60 '0 JUN

'0JUL'UG 80 SEP

'80 OCT 65 NOV 60 '0DEC

• • • The permittee may use dechlorination techniques to achieve the appli'cable limitations using sodium thiosulfate or sodium suliite or other dechlorinating agents. agents approved by the Chief or the Surface Vater Quality Division as dechlorination The quanity oi reagent used shall be limited to 1.5 times the stoichiometric amount needed for dechlorination of applied chlcrine. The permittee shall report monthly the quaqity of each dechlorination reagent used per day.

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Permit No. MI 0005827 Page 3 of 12

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Part I-A-l. (continued)

• • • • Anyunusual characteristics of the discharge (i.e., unnatural turbidity, color, oil film, floating solids, foams, settleable solids, or deposits) shall be reported immediately to the District Office of the Surface Water Quality Division followed with a written report within 5 days detailing the findings of the investigation and the steps taken to correct the condition.

a. The term 'noncontact cooling water shall mean water used for cooling which does not come into direct contact with any raw material, intermediate product, waste product, or finished product.

b. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: weekly; grab sample.

c. The receiving water shall contain no unnatural turbidity, color, oil film, floating solids, foams, settleable solids, or deposits in quantities which are or may become ingurious to any designated use as a result of this discharge.

d. Samples, measurements and/or observations taken in compliance with the monitoring requirements above shall be taken as follows: intake - in the intake forebay; discharge - in Unit 1 and Unit 2 discharge bays for Outfalls 001 and 002, respectively. The monitoring requirements specified above do not apply for Outfall 003 since this discharge will be regulated by Outfalls 001 and 002.

e. In the event the permittee shall require the discharge of water treatment additives in addition to any previously approved by the Chief of the Surface Water Quality Division, the permittee shall notify the Division Chief. Written approval from the Chief of the Surface Water Quality Division to discharge such additives at specified levels shall be obtained prior to discharge by the permittee. The

'permit will be modified in accordance with the requirements of Part II, Section B-4 if a constituent of the additive or additives requires limiting."

Permit No.

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~ MI 0005827 Page a of ~1 Final Ef=luent Limitations - Outfalls OOA and OOB (steam generator blowdown)

Our>ng the period beginning on the effective date of this permit and lasting until permit expiration, the permittee is authorized to discharge a maximum of eight hundred sixty-four thousand (864,000) gallons per day of low volume wastes consisting of steam generator. blowcown'from each of the internal outfalls OOA and 00B through outfalls 001, 002 and 003 to Lake Michigan. Such discharge shall be limited and monitored by the permittee as specified below:

Oischarae Limitations ka/da lbs/dav Otner Limitations Monitorina Requirements Kf luent Monthly Oai ly Monthly Oai ly Measur ement Sample Charac=eristic Averaae Maximum Averaae Maximum Flow (MGO) Per Occurrence Report to,al daily flow Total Suspended Solids (mg/1) .30 100 Weekly Grab This flo'w is not, to be conside. ed as

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a limitation on either the quantity or rate over tire of discharge.

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a. Samoles, measurements and/or. observations taken in comoliance with the monitoring requ',rements a:-ove snail be taken on both outfalls 00A and 00B prior to mixina with nonc=r,tac. c"ol ng wate. in the irt ke forebay (see figure 1.on paae '7 of 12).

b. In th vent the oermittee shall require the discharge of water tree~-;.e..t additives, the permittee shall no" i=y the Chief of the Surface Water Quality Oivision. he permitt shall obtain wr tten a",prove'rom the Chief of the Surface Mater Quality Oivision to discharge such a:d'tives at a soeci ied level. Tne permit may be modified in ac"ordance with t.".e requirements of Part. II, Section B-4 if a constituent of the additive or additives requires lim; na.

Permit Ho. MI 0005827 Page 5

'f 12 diffluent Final Limitations - Outfall OOC (heating boiler blowdown)

F Ouring the oeriod beginning on the effective date of this permit and lasting until permit expiration, the permit.ee is authorized to discharge a maximum of nineteen thousand Q9,000) gallons per day>> of low.volume wastes consisting of heating boiler blowdown from the internal out'fall OOC through outfalls 00i, 002 and 003 to Lake Michigan. Such-discharge shall be limited and monitored by the permittee as specified below:

Oischar e Limitations ka/da bs/da Other Limitations Monitor inc Reouiremen:s Effluent Montnly Oai ly Monthly Oai ly Measurenent Sama le Charac=eris'.ic Avcrace Maximum Averaae Naxieuta Freauencv Tvae Flow (MGD) Per Occurrence Report total daily f',ow Total Suspended Solids (mg/1) 30 100 Per Occurrenc *~ Grab This flow is not to be considered as a limitation on either the quantity or rate over t a:e

'ischarge.

otal Suspended Solids are to be monitored once pe. occurrence or weekly if the heatinc boiler is operated continuously for periods greater than one week.

a. Sa:-..oles, measur ements and/or obset"iations taken in comoliance with the monitor nc reouire:..'nts above snal'. be aken after the heating boil .s and prior to the intake forebay !see figure 1 on page 7 of 12).

b. I~ the event tne penittee shall require the discharge of water treatment addi:;ves,

-".e pe~i-=ae shall no ifv the Chief of the Surface Mater ".uality Division. Tne permi:-ae snail ob:ain written aporoval from the Chief of the Surface stater guality Oivision to discharce such additives ac a soecified level. T~e permi: may be modified in accorda."

with tne requir ements of Part II, Section 8-4 if a const'.-.uent o-. the addi ive'or ad."'::< s requir es limiting.

Permit No. page 6 of 12 4, Final Effluent Limitations - Outfall 00F (filter backwash)

During the period beginning on the effective date of this permit and lasting until permit expiration, the permittee is authorized to discharge a maximum of five hundred eighty-three thousand two hundred (583,200) gallons per day* of low volume wastes'consisting of filter backwash from internal outfall 00F through outfalls 001, 002, and 003 to Lake Michigan. Such discharae shall be limited and monitored by the permittee as specified below:

Oischar e Limitations k /da bs/da Other Limitations Nonitorin Re ui rements Effluent Monthly Dai ly Monthly Dai ly Measurement Sample Characteristic ~Avera e Maximum ~Avera e Maximum ~F ~Te Flow (MGD) Daily Report total daily flow Total Suspended Solids (mg/1) 30 100 Meekly Grab Oil and Grease (mg/l)~ 15 Monthly Grab

<<This. flow is not to be considered as a limitation on either quantity or rate over time of discharge.

~After one year of monitoring for oil. and grease, the permittee may attempt to demonstrate that further monitoring and limits for oil and grease for internal 00F is no longer necessary. Opon successful demonstration by the permittee, this monitoring may be deleted from the permit. Any submittals shall be to the Chief of the Surface Water guality Division.

a. Samples, measurements and observations taken in compliance with the monitorina requirements above shall be taken prior to mixing with noncontact cooling water in intake forebay {see fiaure 1 on page 7 of 12};

b. In the event the permittee shall require the discharge of water treatment additives in addition to any previous'ly approved by the Chief of the Surface Water guality Division, the permittee shall notify the Division Chief. Hritten approval from the Chief of the Surface Water guality Division to discharge *such additives at specified levels shall be obtained prior to discharge 6y the permittee.

The permit will be modified in accordance with the requirements of Part II, Section B.-4 if, a 'constituent of the additive or additives requires limiting.

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150,0UO Ib/hr Nell No. I Vis) tor'5 Hain Ht 4ullcr Potable ond Cen'I or

~n r Vat r $ 7,000 OPD Outfall 001 (HI )OI) frun Unit I or 2 14 tended Ou ~ I Sccp494 1apoons Icaic Up Voter Plan Aeration SIP Operated Alternately Wll Ho. 2 Plant Sanitary 0.015 ICO Arp.

Ut.

II'aci-Up 0.0)l 4CO Haa lntcrna I Clutfall OOC

{HI 1961 0.0)6 H60 Arp.

Internal Outfall OOA {HI 397) 0~4ltr O. II? ICD Ar . 0.266 ICO 144 rth tch basin

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$ 01 C~

H A4 I sscntl ~ I Scrrlcc Votrr Horne 'I tort Up 78 h W f lash flesh Outla)1 (ill (Hl 3911 t Clrrul ~ tlnp Vatri Dlscharpe Iln I t Stean 17uo'ltfshurc lschp boy Unit I Stn. Oen lllb ICO Arp., 1711 Wdl l44 Unit I HotbUP Outfall Wter Plant Repcncrat Ion fur bine 0

Int ~ Le Roon tHI )741 lurcbay Unit 7 Hale-Up 1.417 Dn-Sl tc Sunp Absorption Valor Plant Pond ln-Plant Sunps Ducrall cnl/ IHI )ill Unit 7 Unit k Stn Isc floor Oral Clrculatlhp Vrlrr Cll\charpc llnll 7 Stean 17Nl'cf shure Hchp brr Ii?5 ICD Arp. Q I/lb ICO l44 Norao I Start Up I sscnt I ~ I flash loni lash fani 5 err I ca l4 t cr 211.8 ICO Internal Outfall 008 Nl 398

0. 109 H60 4.9., 0.787 HOD Haa C4

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90

$ 07 Outfall 00f Vastcw!er fleer Olapran. 198O IN Donald I ~ CooL Nuclear P)4nt Prc-filter bociwsh lo Unit I C. E. Ihui - 7/20/4$ c) or Unit W Olscharpe 4ay Rcr Ised - II/Ib/46 0.0972 HQl arp.

I4CC41) CNI) OI'C ln9 DSrhp U4$ Us@ I a? days 0.58)7 Wk naa. )s I I

~ I'ale ~ //4 real Are. ~ A)9 Hl U 444

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Permit No. MI 0005827 Page~of ~

Final Effluent Limi.tations - Intake Screen Backwash During the period beginning on the effective date of this permit and lasting until the expiration date of, this permit, the permittee is author ized to discharge an unspeci'fied amount of intake screen backwash to Lake Michigan. The Company shall collect and remove debris accumulated on the intake trash bars and dispose of such material on land in an appropriate manner.

6. Final Effluent Limitations During the period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee shall not discharge any polychlorinated biphenyls to receiving waters of the State of Michigan as a result of plant operations.

Cooling Water Intakes The permittee shall submit to the Chief of the Surface Water guality Division a detailed study plan and time schedule for conducting environmental monitoring to determine the effects of the cooling water intake and obtain his approval thereof on or before NA-com leted . The studies shall be adequate to demonstrate if the existing.'coo ng water intake design, location, construction, and capacity reflects the best technology available for minimizing adverse environmental impact in accordance with Section 316(b), Public Law 92-500. The study shall be completed and tne report thereon submitted on or before NA.

If, on the basis of the study report and applicable standards established pursuant to Section 31&(b) of Public Law 92-500, the Comnission determines that the intake structures do not reflect the best technology available for minimizing adverse-environmental impact, it will so notify the company, specifying the reason(s) for its determination, and the company shall submit to the Chief of the Surface Water guality Division, within 90 days of such notification, its plan and construction time schedule for minimizing the environmental impact of the intake structure.

~ Special Condition The Nuclear Regulatory Coamission is responsible for regulating discharges of radioactive materials.

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Permf t No. MI 0005827 Page 9 of 12 ll. I I I C Rltt This permit may be modified or, alternatively, revoked and reissued to comply with any appl.icable standard(s) or limitation(s) promulgated under Section 301(b}(2)(c)(d), 304(b)(2) and 307(a)(2) of the Act, if the effluent standard(s) or limitation(s} so promulgated:

a. is(are) either different in condition or more stringent than any effluent limitation in the permit; or lll.~-ll b.

The control(s) any pollutant not limited in the permit.

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discharger shall notif'y the Chief of the Surface Mater gualfty Ofvision, in writing, within 10 days of knowing, or having reason to believe, that a change in facility operation, maintenance, or construction has resulted or.

will result in the discharge of:

l. '.Oetectable levels* of chemicals on the current Michigan Critical Materials Register or priority pollutants or hazardous substances set forth in 40 CFit Vol. 48; No. 64, April 1, 1983, Par t 122.21, Appendix 0, pp. 14176-14177 which were not acknowledged fn the application<<or listed in the application at less than detectable

'levels.

2. Oetectable levels>> of any other chemical not listed in the applicati'on or listed at less than detection, for which the application specifically requested information.

3. Any chemical at 1evels greater than five times the average level reported in the application*<<.

Any other monitoring results obtained as a requirement of this permit shall be reported in accordance with the schedule of compliance.

<<The detectable level shall be defined as the ilethod Oetection Limit (HOL} as given in Appendix 8 to Part 136, Federal Register, Vol. 49, No. 209, October 26, 1984, pp. 43430-31.

<<<<The application received ."1ay 4, 1979 and updated April 26, 1985.

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Permf t No. MI 0005827 Page 10 of ~2 PART I MONITORING ANO REPORTING Representative Sampling Samples and measurenents taken as required herein shall be representative of ttte volume and nature of the monitor ed discharge.

2.

IA Reportinp: Ir QA ~ applicable to your facility ", Dha not aoplicable to your feei.'-.I

~ MOR Submf ttal Reoufremen - The permf ttee shall submit Monthly Operatfng Reoor-forms to the Data Center of the Michigan Department of Natural Resources for eacn I (MOR) calendar month of the authorf zed discharge per fod{s'). The MOR's shall be postmarked no later than the 10th day of the month following each month of the authorized discharge period(s).

QA b. Retained Self-monitori R uir maents - The permittee shel I maintain a year-to-date og of retained se -monitoring results and provide such log for inspec:ion

.to the staff of the a

Q (1.) Surface Mater Duality Division of the Mfchfaan Oeoarfment nf Not>>ral Resources. ~

Q (2,) Environmental Health Services Division, Michfgan Department of P.ural fc Heal th ~

(3.) Northern Peninsula Df vision, Michigan Department of Public Heal th Q (4.) Divfsi'on of Health Facf1f ty t.icensing.h Car tiffcation, Michigan Department of-Publi c Heal th upon request.

The permittee shall certify, in writing, to the Chief of the Sur,ace

'tater guality Division of the Department of Natural Resources in accordance.with the Schedule of Compliance Part I, C-NA, .".=t; (1.) al1 retained self-monitoring rwuirerrtents have been ccmolied Ni o inc a year-to-date log has been maintained.

(2..'he flow rate(s) (if part of retained self-monitoring resuIa) =.rom all out.alls have been substantially ie same as the flow rate(s) authorizec by this permit, or ff (3.) the flew rate(s) (if part of retained self-monitor'ing results) is ',are';

suostantfally dff erent from the flow rate(s) authorized by iis "ermi: ana 4e oermittee snail provide reasons for the difference in -low ra.es.

D c. Grouncuater monitorin - The permit:ee shall submi monthly Operatinp Raoo."-.

with the monitdring requirerrtents set forth in Part III..

('R) forms to tne Oata Center of the Michigan Department of Natura1 Resources in acc".rcancc, no later >an;the 10th day.of ~>e m'onth following each completed report period.

The MOR's shall be pos ..a.<ac, NA d. Firs 'Permit - aistin or orooosed .=ad'.i - Uoon fssuanca o- -.,".e -'."s:

'~it for ~

an existing or proposed faci it@ tne oernit=e is>>emot -rom suom: 'nc "".";;

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r a oerioo of ninety 90) days rom the date t.".e pe~i: is issued.

Perni- Reissuance cr Moaificat on - ".-or any parameter added to .".e on'-.:r;=

requirements as a resu - of permit reissuance or modification of the current permit,:.".e oerr'ittee rrill be exert fram subt.fttfnn <R data for that parameter for a period of n'".e=I (90) davs from the date the permit is issued.

Permit No. M I 0005827 Page 11 of 12'.

3. Oefinitions a

a. The monthly average discharge is defined as the total discharge by weight, or concentration if specified, during the reporting month divided by the number of days in 'the reporting month that the discharge from the production or coamercial facility occurred. When less than daily sampling occurs, the monthly average dihcharge shall be determined by the suamation of the measured daily discharges by weight, or concentration if specified, divided by the number of days during the reporting month when the samples were collected, analyzed and reported.

ifdaily discharge means the total discharge by weight, or

b. The maximum concentration specified, during any calendar day.

c. The Regional Administrator is defined as the Region V Administrator, U.S. EPA, located at 230 South Oearborn, 1,3th Floor, Chicago, ?11inois 60606.

d. The Michigan Water Resources Conmission is located in the Stevens T.

Mason Suilding. The mailing address is Box 30028, Lansing, Michigan 48909.

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4. Test Procedures Test procedures f'r the analgsis of pollutants shall ronform to regulations

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pub>ished pursuant to Section 304(h) of the Act, under wnich such procedures may oe required.

5. Recording Results For each measurement or sample taken pursuant to he reouirements af this permit, the permit.ee snail record the following information:

a. The exact place, date, and time of samoling;

b. he dates the analyses were performed;

c. The person(s) who performed the analyses;

d. The analytical techniques or methods used; and

e. The results of all requir ed analyses.

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Permit No. ~ MI 0005827 Page 12 of 12

6. Additional Monitoring by Permittee'f the permittee monitors any pollutant at the Iocation(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 the values required in the Monthly Operating Report. Such increased frequency shall also be indicated.

7. Records Retention All re'cords and information resulting from the monitoring activities required by this permit including all records of analyses performed and calibration and maintenance of instrumentation and recordings from continuous monitoring instrumentation shall be retained for a minimum of three (3) years, or longer if requested by the Regional Administrator or the Michigan Water Resources Comaission.

C. SCHEDULE OF COMPLIANCE

1. The permittee shall continue to operate the installed facilities to achieve the effluent limitations specified for outfalls 001, 002-

2. The permittee shall comply with the requirements of Section 10, Part II-A in accordance with the following:

a. Submit plans for approval to the Chief of the Surface Water guality Division necessary to comply with the primary power provision of Section 10 in Part II on or before NA.

b. The permittee shall comply with the requirements of items 10a or 10b contained in Part II on or befor e NA. Nbtwithstanding the preceding sentence, the permittee shall at alT times halt, reduce or otherwise control production in order to protect the waters of the State of Michigan upon reduction or loss of the primary source of power.

3. 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 statement of compliance or noncomp'lienee. In the latter case, the statement snail include the cause of noncompliance, any ramediai actions taken and the probability of meeting the next scheduled requirement. Failure to submit the written statement is just cause to pursue enforcement action pursuant to the Commission Act and the Part 21 Rules.

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"-rmic No. ~I 0005827 Page L of 5 PART II h NLNACEHENT REQUIREMENTS

1. Duty ta Comply Ail discharges authorl.aed herexa shall be consistent m.ch the terms and conditions of this permit. The discharge of aay pollutant identified in this pcrmic '

mare frequeatly than or at a Level in excess of that authorized shall consticute vlolac1oa of the perm1t ~

It is the duty of the permittee to comply vich all the terms and conditions af this permit. Any naacompLiaace vith chc Effluenc Limitations, Special Conditions, or terms of this permit constitutes a violation of Public Acts 245 of 1929, as amended, and/or PL 92-500, as amended, and constitutes grounds for enforccmeat accion; for permit termiaatioa, revocacian and reissuancc, or modification; or denial of an application for permit reneval.

2. Change of Conditions Any anticipated facility expansion, production increases, or process modi-

~ication vhich vill result in nev, different, or increased discharges of pollucants

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est be reported by submission of a aev application or, if such changes vill aoc

.'iolate che effluent limitacions specified in chis permit, by notice to. the permit

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issuing authority of such changes. Folloving such notice, the permit may be modified

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to specify and limic any pollucanc nuc previously Limited.

3.

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Concaiament Facilities Thc permittee shall provide facilities for containment oi any accidental Losses oi conceatratcd soLutions, acids, alkal'es, salts, oils, or other polluting materials in accordance vich the requirements of the Nichigan Pacer Rcsour"es Conmissinn Rules, Part 5. This requirement is iacluded pursuanc to Section 5 of che Aichigan Hater Resources Commission Acc, 1929 PA 245, as amended, and the Para 5 rules oi the General Rules oi'hc Commission.

Operator Certification Thc permittee shall have che vaste treatment facilit'cs under direc= supe-vision of an operator certified by che Michigan Rater Resources Commission, as rcqu'red by Section 6a of the Michigan Act.

Noncompliance Notification If, for. any re'ason', the permittee does noc comply vith or vill be unable to comply vich any daily maximum cfilueac Limitacion specified ia this pernic, chc ermxtccc shall provide the Chief oi che Suriacc later equality Division vich che

>LLoviag '.'niormacion, in vriciag, vichia five (5) days oi becoming avarc oi such condition:

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

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Perad.t No. HI 0005827 Page ~ OE

b. The period of noncompliance, including exact daces and times; or, if not corzected, the anticipated time the noncompliance is expected to continue, and the steps being taken to reduce, eliminate and prevent

'ecurzence of che noncomplyiag discharge.

6. Spill Notification The permittee shall immediately report any spill or loss of any product, by-produce, incermediate product, oils, solvents, waste macerial, oz any other pollut-ing substance wh*ch occurs to the surface vaters or groundvaters of the state by calling the Department of Natural Resources 24-hour Emergency Response 1-800-292-4706; aad the permittee shall vithin tea (10) days of the spill telephone'umber or loss, pzovid>> the state with a full vrittea explanatioa as co che cause and discovery of the spill or loss, cleanup and recovery measures taken, preventative measures co be taken, and schedule of implemencatioa. This requirement is included pursuant to Section 5 of the Michigan Water Resources Commission Act, 1929 Ph 245, as amended.

7. Facility Operation The pezmittee shall at all cimes pzoperly operate aad maiatain all tzeatment control facilities or'ystems installed or used by che permictce to achieve compLiance

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8'. Adverse Impact.

The permittee shall take all reasonable steps co minimize any adverse mpact to the surface or gzoundvaters of che stace result.'ng fzom noncompliance with any effluent limication specified ia this permic, including, but noc Limiced to, such accelerated or additional moni.toring as necessary to determine the nature and~ impact of the discharge in noncompliance.

9. Sy-Passing Any diversion Erom or by-pass of faci.lities necessary to maintain compL'nce

<<ich the. terms and condi ions oi this permit is prohibited, excepc (i) where unavoi'-

able co prevent loss oi life, personal injury, or severe prooerty damage, or (ii) where excessive storm drainage or runoEf would damage any facili ies necessary Eor compl.'ance with the effluenc limitacions and prohibitions of this permit. The permittee nocify the Aichigan Water Resources Commission and the Regional Admiaistzacoz, shal'romptly

'a writing, oi such diversion or by-pass.

10. Power Failures In order to maincain compliance with the effluent 1'mitations aad prohibi-tions of this permit, the permittee shall either:

a ~ Provide an alcernative power source sufficient to operace facilities utiliaed bv permittee to maintain compliance wich the effluent Limi=a-and conditions of:his permit which prov'sion shall be iadicac d ons th's permit by inclusion of a specific compliance date in each appropriate "Scnedule o Compliance for c.ffluent 'imicacions".

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Permit No. MI 0005827 Page 3 of 5

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b "Upon the reduction, loss, oz failure of one oz coze of the primary sources of povez to facilities utilized by the permittee to maintain compliance vith the effluent limitations and conditions of this permit, the permittee shall halt, reduce or othervise control production and/or all discharge in order to maintain compliance vith the effluent limitations and conditions of this permit.

11. Removed Subs tances Solids, sludges, filter backvash, oz other pollutants removed fzom or resulting from treatment or control of vastevaters shall be disposed of in a manner such as to'prevent any pollutant from such materi.als from entering navigable vaters, or the entry of toxic or harmful contaminants thereof onto the groundvaters in concen-trations or aaunts detrimental to the groundvater resource.

12. Upset noncompliance Notification lf a process "upset" (defined as an exceptional incident in vhich theze

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is unintentional and temporary noncompliance vith technology based permit effluent

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limitations because of factors beyond the reasonable control of the permittee) has occurred, the permittee vho vishes to establish the affirmative defense of upset

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hall notify the Chief of the Surface Water Quality Division by telephone vithin 4 'hours'f becoming avare of such conditions and,vithin five (5) days,, provide in vriting, the folloving information:

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a.~ That an upset occurred and that the permittee 'can'dentify the speci ic cause(s) of the upset;

b. That the permitted vastevater treatment facility vas, at the time, being properly operated;

c. That the permittee has specified and taken action on all responsible steps to minimize or correct any adverse impact in the environment resulting from noncompliance vith his permi=.

Tn any enforcement proceedings, the permittee seeking to establish the occurrence oi an upset, has the burden of proof.

13. Any requirement of this permit vhich is included unde 'he unique terms of michigan, the Hater Resources Commission, A'ct 245, P.A.1929 , as amended, and rules promulgated thereunder, is not enforceable under the r"ederal C1ean ~ater Act regulations.

Permit No. Page 4 of 5 RESPONSIBILITIES 1.. Right of Entry The permittee shall allow che Executive Secretary of che Michigan Water Resaurces Commission, the Regional Administrator and/or cheir authorised represen-tacives, upan che presentation of the credentials:

a. To enter upon che permictee's premises vhere an ef'luent source is Locatid or in vhich any records are required to be kept under che terms and conditions of this permit; and

b. At reasanable times co have access to and copy any records required to be kept under the terms and conditions of this permit; to inspect any monitoring equipment or monitoring method required in thi,s permit; and to sample any discharge of pollutancs.

2. Transfer of Ownership or Concrol In the event of any change in control or ownership of facilities from vhich the authorised discharge emanate, the permittee shall notify che succeeding er or controller of the existence of this permit by letter, a copy of vhich shall be forwarded to the Michigan Water Resources Commission and the Regional Administrator.

3. Availability of Reports Excepc for daca decermined co be confidential under Section 308 of che Act and Rule 2128 af che Water Resources Commission Rules, Part 21, all reports prepared in accordance with the terms of this permit shall be available for publi=

inspection at the offi.ces of. che State Wacer Pollucion Control A'encv and che Reg.'anal Administrator. As required by the Act, effluent data shall aoc be consdered can=-

dential. Knowingly making any false statement on any such repor= may resul in the impasition of criminal penalties as provided for in Sect on 309 of the Ac and Sections 7 and LO of che Michigan Act.

4. Permit Modification After notice and oppartunicy for a hearing, this permit may be modified suspended, or revoked in vhole or in part during its term for cause including, buc not limiced co, the following:

a. Violation of any terms or condicians af this permit;

b. Obtaining this permic by misrepresentation or fai'ure co disclose

,fully, all relevant faces; or A change in any condition thac requires ei.cher a emporary or permanent reduccion or eliminati.on of the authorized dis'charge.

l Permit No. HI 0005827 Page 5 of 5

5. Toxic Pollutaats Notwithstanding Part II, B-4 above, if a toxic effluent scandard or pro-hibition (including any schedule of compliance specified in such efflueat standard or prohibicion) is established under Section 307(a) of the Act for a toxic pollucanc which is present in the discharge and such standard or prohibicion is more stringent than any limication for such pollutaat ia chis permit, this permit shall be revised or modified in accordance vith the toxic effluent standard or prohibition and che permittee so notified.

6. Civil and Criminal Liability Except as provided ia permit conditions on "By-Passing" (Part II, A- 9) and "Pover Failures" (Part II, A-10), nochiag in this permit shall be construed co relieve che permittee from civil or criminal penalties for noncompliance, whether or aoc such noncompliance is due to Eactors beyond his control, such as accidencs, equipment breakdovns, or labor disputes.

7. ~ Oil

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and Hazardous Substance Liabilicy Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which che permittee may be subject under Section 311 of che Acc

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except as are exempced by federal regulations.

8. State Lavi Nothing in this permit shall be conscrued to preclude the iascicucion of any legal.action or relieve the permittee from any responsibilities, liabi'it'es, or penalties established pursuant co any applicable State lav or regulacion unde" authority preserved by Section 510 of che Act.

9. Property Rights The issuance of this permit does noc convey any property rights ia or personal property, or any exclusive privileges, nor does it authorize violaci-

the'eal of any Pedera, Stare or local laws or regulat'ons, noz -'oes it obviate the necessity ==

obtaining such permits oz approvals fzom ocher units of government as may be requizec by 'aw.

10. Severability The provisions of rhis permit are severable, aad ii any provision oE this permit, or the application of aay provision oE chis permi co any circumstances, i~ held invalid, che applicacion oE such provision ot other circumicances, and che remainder of this permit, shall noc be'afficced thereby.

il. Noc'ce co Public Ut lit es (Miss Oig)

.he issuance of this permit does noc exempt the permittee from giving nocice co public utilities and complyiag with each of the requirements of Acc 53 of the public Acts of 1974, being sections 460.701 co 460.718 of che Michigan Compiled Laws, when constructing Eaci'lities co meet the terms of this permit.

Permit No, MI 0005827 Page 1 of 2 PERMIT CONDITIONS PART III A. GROUNDMATER DISCHARGE AUTHORIZATION The permittee is authorized to discharge from its wastewater treatment facility to the groundwaters of the state in accordance with the conditions below. This authorization shall continue until the Michigan Mater Resources Coamission makes its final determination on a state groundwater discharge permit.

B. GROUNDWATER DISCHARGE REgUIRBKNTS During the period beginning on the date of issuance of this permit and lasting until the expiration date of this permit, the permittee is authorized to discharge process wastes and sanitary wastes to the groundwater. Such discharges shall be monitored by the permittee as specified below:

Process wastes shall be disposed of into the ground in such a manner and by means of such facilities and at such location that they shall not injuriously affect public health, welfare, or coamercial, industrial, domestic, agricultural, recreational, or other uses of the underground waters.

I Monitoring requirements for boiler water treatment systems process water (water softener, clarifiers, make-up demineralizers) and boiler cleaning water prior to discharge into the ground.

PARAMETER TO BE MEASURED ~EIEUENCY TYPE OF SAMPLE Flow Continuous pH Continuous . Daily maximu, minimum Cadmium At times of boiler cleaning Grab water discharge Oil & Grease Weekly Grab Sulfate (S04) At all times when regeneration of 24-Hr. Composite ion exchange resins occurs Chloride (CL) Weekly 24-Hr. Composite Total Phosphorus Weekly 24-Hr. Composite Chemical Oxygen Demand Weekly 24-Hr. Composite Total Dissolved Solids At all times when regeneration of 24-Hr. Composite ion exchange resins occurs Monitoring requirements for sanitary wastewaters prior to discharge into the ground:

PARAMETER TO BE MEASURED FRE(RUENCY REPORT Flow Continuous

'tate which seepage area is List when seepage areas List beginning and being utilized are alternated ending date and tihe of use of each seepage area

I Permit No, Ml 0005827 Part III-B (continued)

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.,~ni toring requir ements for groundwater collected in monitoring wells:

PARAMETER TO BE MEASURED FRE UENCY TYPE OF SAMPLE Record static water elevation quarterly Reading .at time of sampling pH quarterly Grab Total Chronium (Cr) quarterly Grab Copper (Cu) quarter ly Grab Sul fate(S04) quarterly Grab Chloride (Cl) quarterly Grab Hardness guar terly Grab Nitrate-Nitrogen as N quarterly Grab Sodium (Na) quarterly Grab Polychlorinated Biphenyls quarterly Grab Chemical Oxygen Demand quarterly Grab Boron (B) quarter ly Grab Total Phosphorus (P) quarterly Grab Total Dissolved Solids quarterly Grab Cadmium quarterly Grab Oil 5 Grease quarterly Grab

l Permit No. HI 0005827 MIXING ZONE Facility: Indiana E Michigan Electric Company Outfall Number Receivin Water Dischar e Location 001, 002, 003 Lake Michigan Berrien County, Lake Township (Town 65, Range 19W)

Sections 5, 6, 7 E 8 The mixing zone for purposes of evaluating compliance with the State Water guality Standards is defined as an area of Lake Michigan equivalent to that of a circle with a radius of 2811 feet (570 acres) centered at the point of discharge.

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