ML19274D854

Forwards Suppl 1 to Proposed Change 74,Tech Specs App B Re Water Quality Limits & Surveillance Requirements

ML19274D854
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	02/23/1979
From:	Johnson W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Office of Nuclear Reactor Regulation
References
WVY-79-18, NUDOCS 7902260463
Download: ML19274D854 (42)

Text

{{#Wiki_filter: Proposed Change No. 74 Supplement No. 1 VERMONT Y AN KEE NUCLEAR POWER CORPORATION SEVENTY SEVEN GROVE STREET B.3.2.1 PC 74-3 PUTLAND, VensoNT osvoi REPLY TO: ENGINEERING OFFICE TURNPIKE RO AD WESTBORO. M ASS ACHUSETTS 015 81 TELEPHONE 6 ' 7-36 6-9 0 t 1 WVY 79-18 Fe'. aary 23, 1979 United States Nuclear Regulato;y . mission Wa shing ton, D. C. 20555 Attention: Of fice of Nuclear Reactor Regulation

Reference:

(a) License No. DPR-28 (Docke t No. 50-271) (b) Vermont Yankee Nuclear Power Corporation letter to the U.S. Nuclear Regulatory Commission dated August 16, 1978 (Proposed Change No. 74) (c) U.S. Nuclear Regulatory Commi Sion letter to Yankee Atomic Electric Company dated October 13, 1978 (d) Atomic Safety and Licensing Appeal Board decision of De c ember 27, 1978 in the matter of Tennessee Valley Authority Yellow Creek Nuclear Plants, Units 1 and 2 (ALAB-515)

Subject:

Supplement Cae to Proposed Change No. 74, Appendix B Technical Specification Change Pur s uant to Section 50.59 of the Commissions' Rules and Regulations, Vermont Yankee Nuclear Power Corporation proposed a complete rewrite of the Appendix B Technical Specifications, Reference (b). The USNRC, af ter discussions with the licensee, approved only a portion of the change which was related to open cycle operation, Reference (c). Vermont Yankee Nuclear Power Corporation hereby proposes to supersede the outstanding portion of Reference (b) with the enclosed Technical Specification proposal. PROPOSED CHANGE: Reference is made to Vermont Yankee Nuclear Power Corporation's operating license (No. DPR-28) and Appendix B to this operating license. We propose to modify these documents as follows: A. Operating License No. DPR-28 Delete the following " Environmental conditions" specified on page 4: Parag raphs E.1, E. 2, E. 3, and E. 4. 790226o % 3

s S U.S. Nuclear Regulatory Commission Feb rua ry 23, 1979 Attn: Office of Nuclear Reactor Regulation Page 2 B. Appendix B Technical Specifications Replace Appendix B of the Technical Specifications with Attachment A to this letter. The proposed change is intended to replace license conditions of Appendix B with the water quality limits and surveillance requirements that fall within the jurisdiction and authority of the U.S. Environmental Protection Agency and the Vermont Agency of Environmental Conservation which were established in compliance with the Federal Water Pollution Control Act Amendments of 1972 (FWPCA). [EASON FOR CRANGE: Uater quality limits and environmental surveillance requirements are presently imposed on the Vermont Yankee Nuclear Power Corporation by two agencies: (1) the U.S. Nuclear Regulatory Commission and (2) the State of Vermont - Agency of Environmental Conservation. Vermont Yankee's request for deletion of limiting conditions for operations for certain water quality parameters and related environmental surveillance requirements contained in the Appendix B Technical Specifications is based upon the fact that the U.S. Environmental Protection Agency and State of Vermont have been charged with the responsibility to regulate pollutant discharges into water bodies under the FWPCA. Vermont Yankee believes that the present Appendix B Technical Specifications represent unnecessary duplicative efforts among regulatory agencies. The intent of this proposed change, to eliminate regulatory overlap, is fully consistent with Section 101 (f) of FWPCA, where it is stated that: "It is the national policy that to the maximum extent possible the procedures utilized for implementing this Act shall encourage the drastic minimization of paperwork and interagency decision procedures, and make the best use of available manpower and funds, so as to prevent needless duplication and unnecessary delays at all levels of government." Section 511 of the FWPCA provides that nothing under the National Environmental Policy Act shall be deemed to authorize any Federal agency to review any effluent limitation or other requirement established pursuant to the FWPCA, or to impose, as a condition of any license or permit, any effluent limitation other than any such limitation established pursuant to the FWPCA. In Reference (d) the Atomic Safety and Licensing Appeal Board determined that the Federal responsibility for water quality standards and pollution control has been shif ted to EPA as its exclusive province (see Section III.4, pp. 20 and 21). As a result of previous NRC determinations (Reference c) and after implementation of these changes to Appendix B, the four Environmental conditions referenced above are no longer appropriate. The determination required in Paragraph E.1 has already been made (Reference c) and the NPDES permit will assume jurisdiction of the items discussed in Paragraphs E.2, E.3, and E.4.

s U.S. Nuclear Regulatory Commission February 23, 1979 Attn: Office of Nuclear Reactor Regulation Page 3 BASIS FOR CHANCE: Pursuant to the Federal Water Pollution Control Act, the State of Vermont National Pollution Discharge Elimination System (NPDES) Permit Program Regulations were approved by the U.S. Environmenta' Protection Agency on March 11, 1974 and amended on January 11, 1977. In accordance with Federal and State regulations, the Vermont Yankee Nuclear Power Corporation has been issued NPDES Permit VT 0000264 which became effective July 8, 1975. On March 14, 1978 Vermont Yankee submitted to the Vermont Agency of C wironmental Conservation its report in support of an amendment to its NPDES Permit entitled "316 Demonstration, Vermont Yankee Nuclear Power Station, Environmental Impact Asucssment", dated March, 1978. This report presented engineering, hydrological, and biological information in support of Vermont Yankee's request, pursuant to Sections 316a and 316b of the Federal Water Pollution Control Act, for alternative thermal ef fluent limitations. The rationale for the proposed alternative thermal ef fluent limitations was the result of the evaluation of data obtained from chemical, physical and biological studies begun in 1967, and hydrological and biological studies conducted during 921 days of open-cycle operation f rom 1974 through 1978 reported as Vermont Yankee Hydrothermal and Biological Studies, Phases I-V, and summarized in the 316 Demonstration Report. The studies characterized the thermal plumes caused by Vermont Yankee's discharge under a range of plant operating conditions, river flow rates, and river temperatire. These data were used to examine the impact of the thermal plume on sident aquatic biota. In addition, the effects of impingement and entrs_ ament were studied. The results demonstrated that Ve rmont Yankee's open-cycle operation has not significantly altered the distribution, abundance or diversity of resident aquatic biota. The Vermont Agency of Environmental Conservation reviewed the results of Vermont Yankee's hydrothermal and biological studies as reported in the 316 demonstration study and tentatively determined ou June 26, 1978, pursuant to 40CFR122.15(b)(1), to amend Vermont Yankee's NPDES permit to allow open-cycle operation during the period October 15 to May 15 subject to the following thermal limitations: (a) the temperature at Monitor 3 during open-cycle operation shall not exceed 65 F. (b) the rate of change of temperature at Monitor 3 shall not exceed 5 F per hour. (c) the increase in temperature above ambient at Monitor 3 shall not exceed 13.4 F. A public hearing was held on the draf t NPDES permit on August 4, 1978. The permit was issued on September 12, 1978. The Vermont Agency of Environmental Conservation's determination to amend the Vermont Yankee NPDES permit to incorporate the above thermal limitations was based on a

1 U.S. Nuclear Regulatory Commission February 23, 1979 Attn: Office of Nuclear Reactor Regulation Page 4 determination that the discharge will not significantly alter the distribution, abundance or diversity of resident aquatic biota and that the protection of a balanced, indigenous community of shellfish, fish and wildlife in and on the Connecticut River will be assured. The thermal limits now specified in NPDES Permit No. VT 0000264 were reviewed and approved by the U.S. Nuclear Regulatory Commission on October 13, 1978 see Reference (c). The NRC conclusion in Reference (c) states "On the basis of our analysis, it is concluded that there will be no significant environmental impact attributable to the proposed action other than has already been predicted and described in the Final Environmental Statement and subsequent Environmental Impact Appraisals." In lieu of the present NRC Appendix B water quality limits and surveillance requirements, Vermont Yankee is herewith submitting a proposed change which will incorporate by reference limitations placed upon Vermont Yankee operation by the State of Vermont, Agency of Environmental Conservation, thus clarifyin6 the respective roles of NRC and the State regarding statutory authority pursuant to the FWPCA. In compliance with the provisions of that Act, the Vermont Yankee Nuclear Power Corporation is authorized by the Vermont Agency of Environmental Conservation to discharge liquid effluents from its facility located at Vernon, Vermont into the Connecticut River in accordance with the conditions of their discharge permit No. VT0000264, as amended. This permit became ef fective September 12, 1978 and shall expire at midnight June 30, 1980. A copy of the permit is provided as Attachment C. Vermont Yankee has made a comparison of limits and surveillance requirements imposed upon the operation of the Vermont Yankee Nuclear Power Station by the NRC, Appendix B Technical Specification and NPDES Permit (Attachment B). We have concluded that effluent limitations and surveillance requirements specified in the NPDES Permit are either identical to the NRC requirements or, where differences exist, are more than adequate to assure protection of the environment. Ve rmont Yankee believes the proposed change is wcrranted considering (1) the absence of any significant adverse environmental impacts due to operation of the Vermont Yankee station and (2) the jurisdictional authority of the U.S. Environmental Protection Agency and State of Vermont as set forth in the FWPCA. SAFETY CONSIDERATIONS: This proposed change does not present any hazard considerations not described or implied in the license applications as amended. This proposed change has been reviewed by the Vermont Yankee Nuclear Safety Audit and Review Committee. F J DETERMINATION: This proposed change requires an approval that involves

i U.S. Nuclear Regulatory Commission February 23, 1979 Attn: Office of Nuclear Reactor Regulation Page 5 a single environmental issue and is deemed not to involve a significant hazards consideration. For these reasons, Vermont Yankee Nuclear Power Corporation proposes this change as a Class III Amendment. A payment of $4,000.00 was included with Reference (b). Since this letter merely modifies a previous request, no additional payment is required. Vermont Yankee Nuclear Power Corporation believes that the NRC revised fee schedule is illegal. Vermont Yankee is aware that this fee schedule is being contested before the U.S. Court of Appeals for the Fif th Circuit and therefore submitted the referenced fee under protest without waiving its right to contest the validity of this fee or the entire NRC fee schedule, and without waiving any right to recover, in whole or in part, all fees paid or to be paid under the invalid f ee schedule. SCHEDULE OF CHANCE: This change shall be incorporated into the Vermont Yankee Technical Specifications immediately upon Commission approval. We trust this information is acceptable to you; however, should you have any questions please feel free to contact us. Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION d W. Johnson Vice President COMMONWEALTH OF MASSACHUSETTS) )ss. COUNTY OF WORCESTER ) Then personally appeared before me, W. P. Johnson, who, being duly sworn did state that he is Vice President of Vermont Yankee Nuclear Power C orp o ra t ion, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Vermont Yankee Nuclear Power Corporation, and that the statements therein are true to the best of his knowledge and belief. Robert H. Groce Notary Public My Commission Expires September 14, 1984 _. gl, 0

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VYNPS Attachment"A 1.0 LIMITING CONDITIONS FOR OPERATION 2,0 REPORTING REQUIREMENTS 1.1 CONDENSER COOLING WATER 2.1 CONDENSER COOLING WATER Applicability: Applicability: Applies thermal and chemical effluent limitations In addition to the applicable reporting requirements of upon the operation of Vermont Yankee. Title 10, Code of Federal Regulations, the following identified reports shall be submitted to the Director of the appropriate Regional Office of Inspection and Enforcement and the Director of the Office of Nuclear Reactor Regulation (c/o Distribution Services Branch). Obj ective : 1. Routine Reports The purpose of the specification is to assure that A. Monthly NPDES Discharge Monitoring Report effluent releases into the Connecticut River are (1) consistent with the well-being of the existing The results of monitoring except radionuclides, Connecticut River ecosystem and (2) in accordance as required by NPDES Permit No. VT0000264, shall with the Federal Water Pollution Control Act, as be reported and submitted on a monthly basis by amended, and state water quality regulations duly the 25th of the month following the completed imposed upon the operation of the Vermont Yankee report period. Nuclear Power Station. B. Annual Environmental Monitoring Report Specification: An annual Environmental Monitoring Report covering A. All thermil and chemical discharge limits shall the previous calendar year shall be submitted. be in accordance with the limits and conditions This report shall include the following informatio expressed in:

1) The results of the Nonradiological

1) NPDES Discharge Permit No. VT0000264 by Environmental Monitoring Program required by the State of Vermont - Agency of Environmental NPDES Permit No. VT0000264.

Conservation.

2) A tabulation of the concentration of radio-Limits and conditions contained in the above referenced nuclides in liquid effluents released to the document, which set thermal and chemical effluent Connecticut River.

limitations upon the operation of Vermont Yankee, are herewith, incorporated by reference in Section 1. 0 of 2. Nonroutine Reporting the Vermont Yankee - Appendix B Technical Specifications. A. NPDES Noncompliance Reports B. All future modifications to the above referenced document shall automatically become part of this Events resulting in noncompliance with the terms specification as of the effective date of such and. conditions of NPDES Permit No. VT0000264 s 1

~ VYNPS 1.0 LIMITING CONDITIONS FOR OPERATION 2.0 REPORTING REQUIREMFaNTS change. The NRC Office of Nuclear Reactor shall be the subject of written repor*.s Regulation shall be notified of any change. submitted within five days of becoming aware of such conditions. +. / 2

t Basis: As required by Section 402 of the Federal Water Pollution Control Act Amendments of 1972 (FWPCA), 33 U.S.C. 1251 et seq. the Vermont Yankee Nuclear Power Corporation has received a final NPDES Permit from the State of Vermont - Agency of Environmental Conservation for discharges from its facility located at Vernon, Vermont. This permit identified as NPDES Pormit No. VT0000264 as amended became effective September 12, 1978 and shall expire at midnight June 30, 1980. e t 1 l 3 e

Page 1 0.C. - Open Cycle C.C. - Closed Cycle ATTAC11 MENT B COMPARISON OF APPENDIX B TECIINICAL SPECIFICATION AND NPDES PER!!IT LIMITS NRC EPA COMMENT A. DISCIIARGE TEMPERATURE 0.C. NONE O.C. NONE _ C.C. NONE C.C. 81 F X (Blowdown) 93 F Max. A'. RIVER TEMPERATURE AT 13.4 F AT Oct. 15 13.4 F AT Oct. 15 MONITOR #3 5 F per llour to S F per llour to g 65 F Maximum May 15 65 F Maximum May 15 B. CllEMICAL CONCENTRATIONS CllLORINE - 0.1 mg/l free 0.2 mg/l free residual <2 0F DISCHARGE residual max. No time max. limit 0.5 mg/l total residual iirs/ day max. pli - 6. 5 - 8. 5 6.5 - 8.5 C. RIVER FLOW 1200 CFS minimum at NONE On July 31, 1970, the Federal Vernon Dam. If less Power Commission issued an than 1200 CFS, VY must order to New England Power Co. operate closed cycle requiring them to provide a minimum of 1200 CFS D. FISH KILL No limit on any species. Limit only on Atlantic salmon & American shad; 0.1% of maximum number of these species anticipated to pass Vernon based on number stocked or released. (Report impingement inmediately of shad or salmon). 3

Page 2 0.C. - Open Cycle C.C. - Closed Cycle ATTACllMENT B (continued) COMPARISON OF APPENDIX B TECHNICAL SPECIFIC ^ TION AND NPDES PERMIT MONITORING REQUIREMENTS NRC EPA COMMENT A. RIVER FLOW RATE Continuous from Hydrotail Hourly averages from Hydro Tail Race Cauge is inaccurate Race Gauge Logs due to Operations of Northfie Mountain Pump Storage Plant. RIVER Continuous at Monitors 367 Continuous at Menitors 3&7 B. TEMPERATURE ---= DISCHARGE NONE DAILY: Max., Min., & Mean 0.C. & C.C. RIVER Continuous at Monitors 367 Continuous at Monitors 367 C. pH DISCHARGE Continuous NONE D. CllLORINE RESIDUAL Continuous during Grab samples during DISCIIARGE chlorination chlorination RIVER Continuous at Monitors 3&7 Continuous at Monitors 3&7 E. DISSOL7ED OXYGEN DISCHARGE NONE Quarterly grab at discharge (Also at Monitors 3&7) RIVER Conductivity & Turbidity Propose deleting continuous F. WATER QUALITY PARAMETER Continuous at Monitors 3&7 16 Parameters - Quarterly monitoring of conductivity DISCllARGE grabs at discharge & & turbidity at Monitors 367 NONE Monitors 3&7 G. PHYTOPLANKTON/ NONE Monthly at Monitors 3&7 ZOOPLANKTON H. ENTRAINMENT 2 per month (0.C.&c.C.) 1 per month on 0.C. The phase studies have docu-None on C.C. mented the low value of these studies during the winter months and on C.C. I. BENTHIC FAUNA NONE 1 per month from May through November at Stations 2, 3, 4 and 5 4

Page 3 l O.C. - Open Cycle C.C. - Closed Cycle ATTACIDfENT B (continued) COMPARISON OF APPENDIX B TECHNICAL SPECIFICATIONS AND NPDES PERMIT MONITORING REQUIREMENTS NRC EPA COMMENT J. FISH IMPINGEMENT All fish impinged are Oct. 15 - Oct. 31: 3/ week For NPDES, all fish impinged identified by species, Nov.

1/ week during the surveillance size and quantity Dec.-Feb.

1/ month neriods are identified, Mar.1-Apr.15

1/ week weighed, and measured and Apr.16-May 15

3/ week reported in the annual environmental report K.

FINFISH NONE Annually: 500 no. of dam & 500 so. of dam [ e 0

Page 4 t 4 ATTACHMENT B (continued) COMPARISON OF APPENDIX B TECHNICAL SPECIFICATION AND NPDES PERMIT REPORTING REQUIREMENTS NRC EPA COMMENT 1. ROUTINE Annual Environmental (a) / nnual Environmental Will include impingement Monitoring Report Monitoring Report and a summary of annual liquid releases of radio-(b) Monthly NPDES Discharge nuclides to the Connecticut Monitoring Report River. 2. NON-ROUTINE 30 day written report NPDES non-compliance i Report: 5 days i f 1 4 4

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^ "" s w w a-fl9gfi State of Vermont 2:Q.h." AGENCY OF ENVIRONMENTAL. CONSERVATION y.44 MARTIN L JOHNSON, Secretary Department of Fish and Game Montpelier, Vermont 05602 Department of Forests and Parks [nn $r i Ir[i OFFICE OF THE SECRETARY Division of Environmental Protection Division of necreation September 11, 1978 Division of Plannin;: Natural Resources Conservation council I-c. William R. Adams, Jr. Regional Administrator Room 2203 John F. Kennedy Federal Building Boston, )1A 02203 Re: Amended Discharge Permit Vt. Yankee Nuclear Power Corp. - Vernon VT0000264 3-1053 13-17-002

Dear Mr. Adams:

Transmitted herewith pursuant to 40 CFR 122.18 and 124.47 is a copy of an Amended Discharge Permit which I have today issued to the Vermont Yankee Nuclear Power Corporation, 77 Grove Street, Rutland, Vermont 05701 permitting it to operate its Nuclear Power Station at Vernon, Vermont in the open cycle mode during the pericd October 15 through May 15 As required by 40 CFR 122.18, I wish to advise you that the permit contains thermal effluent limitation less stringent than required by Sections 301 and 306 of the Clean Water Act (P.L. 95-217). As further required by 40 CFR 122.18 the following evidence was used in making my final determination to issue this permit which had previously been proposed pursuant to 40 CFR 122.17: (1) 316 Demonstration - Engineering, Hydrological and Biological Information and Environmental Impact Assessment - Vermont Yankee Nuclear Power Corporation (Aquatec, Inc., March 1976) including the results or Vermont Yankee Hydro Thermal and Biological Studies Phases I-IV carried out between 1974 and 1977 and . referenced therein. (2) Written comments and objections received during the public comment period (June 28 - August 18, 1978) provided for in our Public Notice dated June 28, 1978. These comments and objections included a letter from Diana P. Sidebottham, President and Chairman, Legal and Technical Committee of the New England Coalition on Nuclear Pollution, Inc. to Agency of Environmental Conservat1~on dated August 18, 1978 transmitting a Review of 316 Demonstration (Item #1 above) dated

r ~ August 14, 1978 by John R. Clark. (3) Letter dated August 31, 1978 from John W. Beck, Executive Vice President, Vt. Yankee Nuclear Power Corporation to Donald W. Webster, Hearing Examiner, Agency of Environmental Conservation transmitting Vt. Yankee's technical Response to Mr. Clark's Review (Item #2 above) prepared by W.D. Countryman, R.M. McNeer and D.J. Max dated August 30, 1978. r (4) Memorandum from Angelo Incerpi, Chief Fisheries' Biologist, Vt. Dept. of Fish and Game to David L. Clough, Director, Water Quality Division, dated IL.y 19, 1978. (5) Oral and written statements presented at the inform 1-tional public hearing held in Brattleboro on August 4, ~ 1978. (6) Memorandum from David L. Clough, Director, Water Quality Division to me dated Sep. ember 7, 1978 responding to Mr. John R. Clark's comments. (7) Memorandum from Angelo Incerpi, Chief Fisheries Biologist to me dated September 11, 1978 in response to Mr. Clark's commenta. (8) Memorandum from Donald W. Webster, Hearing Officer to me dated September 11, 1978, providing a staff summary of procedures for the amendment process. Items (1) through (5) have been previously transmitted to EPA through Mr. Ted Landry of the Permits Branch. Items (6) through (8) are transmitted herewith. You will note that the permit has an effective date of October 11, 1978, which is 30 days from the date of issuance. This period is to allow the statutory time for any appeals that might be made under State Law (10 V.S. A. $1269) and Federal Law. Because of the importance to the permittee of having this permit become effecuive at the earliest possible time, I would appreciate your timely review of this permit. Should you have any comments to make I also would appreciate a response at your earliest convenience. Thank you for your attention to this matter. 61 cerely you AN ( . /M s Brendan J. Whit,aker, Secretary AGENCY OF EINFRONMENTAL CONSERVATI0:I BJW/ cc: Ted Landry, Permits Branch, EPA Region I g em men... g

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d .E,- 51.*. AGENCY OF EN VillON31 ENTAL CONSEllVATION Siontpelier, Vennont 05602 Department of Fish and Game Department of Forests.Parbs, and Recreation Department of Water Resources Environmental Board Division of Environmantal Ergineering Division of Enwonmental Protection Natural Fiesources Conservation Council 8eptember 7, 1978 MEMORANDUM TO: Brendan J. Whittaker, Secretary Agency of Environmental Conservation THRU: Reginald A. LaRosa, Acting Commissioner Department of Water Resourcas FROM: David L. Clough, Director Water Quality Division RE: Final Recommendations - Vermont Yankee 316a Amendments I have reviewed the te n,imony ord written submissions to the record resulting from the subject hearing held on August 4, 1978. The principal objection to issuance of the amendments proposed by the Agency was fron the New England Coalition on Nuclear Pollut,,on Inc., as pre pared by Dr. John R. Clark in a report dated August 14, 1978-Also reviewed was the response to Dr. Clark's testimony by Vermont Yankee which was submitted on Argast 31, 1978. Ms. Esther Poneck on behalf of the Coalition and speaking for Dr. Clark at the hearing, objected to the proposed permit on the grounds 3 hat the supporting studies were inadequate and inconclusive. Dr. Clark had discussed the 316a report with me by telephone the day be fore the hearing and had not seen a copy of the report at thEb time. Dr. Clark requested that I read him the table of cor tents which I did and it was my understanding that this was his or.ly exposure to the report prior to the hearing. On that bi. sis I can give his " hearsay" testimony by Ms. Pcneck no credibility and consider it somewhat irrcsponsible. Dr. Clark's written objections revolve primarily around the sampling technique used in plankton studies and the apparent growth of some planktonic forms during the passage of cooling water through the plant which Dr. Clark says is impossible in a once-through cooling scenario. It is ny understanding that the sampling techniques used were routine and widespread in the " business" and in fact they were reviewed by biologists from Vermont, New Hampshire, Massachusetts and EPA through the review of the subject studies by the Technical Advisory Committee 4hich helped develop the scope of the studies.

o." . a d Page 2 Final Recommendations - Vermont Yar.kee 316a Amendments September 7, 1978 The contention by Dr. Clark that plankton growth during cooling water passage through the plant is " preposterous" is not supported and is due either from an incomplete reading of the report or a failure to understand the circulating water scenario. In fact, a portion of the cooling water, even during so-called open cycle, is continuously recirculated to maintain optimum condensor operating conditions. Therefore, growth of plankton in the warm water environment thus created is. completely possible and has been widely observed in similar situations. The whole question of plankton increases or decreases in the circulating water or in the river itself is somewhat academic to begin with. The ambient plankton populations in the river between the months of October-May are so low as to be inconsequential regardless of the impact of the circulating water. Dr. Clark concludes'that the finfish studies are inadequate end inconclusive and that impingement could be a problem in some of the open cycle months. It is my impression that a great deal of finfish work was done and it does appear adequate to me. In addition, the state fisheries biologists on the TAC were a part of the review process throughout and to my knowledge have been well satisfied with the conduct of the studies and the interpretation of the results. The highest levels of impingement were observed in October, March and April but the numbers and weight of fish involved remain highly insignificant regardless of the percentages involved - i.e., a daily average of about one-half pound of minnows was impinged throughout the four study phases. Dr. Clark's further concerns with impact on migratory fish during the April and October periods have been much discussed by the technical people in the Agency and are well covered by the permit conditions relating to termination of open-cycle if such effects are observed. In summary, my final recommendation would be to issue the requested amendments as proposed in our preliminary draft for which the hearing was held on August 4th subject to the revised notification procedure in PART I,(A),(1),(b.)(3)(1) which I suggested at that time. RAL/

.g n eq l J, State of Vermont g.p,,w s .e. AGENCY OF ENViltONMENTAL CONSERVATION Montpelier, Vermont 05602 0FFICE OF Tile SECRETARY Department of Fish and Game Department of Forests, Parks,and Recreation Depa.*reent of Water Resources Environmental Board Division of Environmental Engineering Division of Environmental Protection 7 Natural Resources Conservation Council 9 7 MEMORANDUM TO: For the Record FROM: Angelo Incerpi, Fisheries Biologist

SUBJECT:

Vt. Yankee amended Discharge Permit The Fisheries Division of Vermont Fish and Game Department has reviewed and made suggestions tov:ards the modification of the Vermont, Yankee permit. There were some areas of concern; however, these were directed towards future migrations of anadromous fish during the freshwater phase of their life cycle. The Vt. Yankee Nuclear Power Corporation realizing our concerns have agreed to continue studies regarding thermal effects on water quality parameters as well as on the fishery resources. We have reviewed the proposed operational permit and feel that it contains the necessary safeguards to protect the fisheries in the Connecticut River. The permit clearly states that the Secretary of the Agency of Environmental Conservation can modify the permit if problems become evident. With these safeguards as stated in the amended permit Fish and Game interests have adequate protection. AI: psp

W Vf% of Vermont 'j g y,, State . u..,. & AGENCi OF ENVlllONMENTAL CONSEllVATION E w Montpelier, Vermont 05602 OFFICE OF Tile SECRETARY Department of Fish and Game Department of Forests, Parks,and Recreation Department of Water Resources Environmental Board Division of Environmental Engineering ation C7v"nca September 11, 1978 N tu I Reso e Ccens Vermont Yankee Cooling Towers Staff Summary - Procedural History I. Procedural: 1. Vermont Yankee prepared a "316" report-March 1978 and submitted the report with petition for the amendment to the present discharge permit. 2. During the first week of June 1978, a public information hearing was scheduled for July 11, 1978. 3. Because additional time was required for staff review, the hearing scheduled for July ll, 1978 was cancelled with the hearing to be rescheduled for a later date. 4. Public hearing was rescheduled for August 4, 1978 in Brattleboro with date for filing of comments of August 18,1978. 5. On June 28, 1978, legal notices were filed with newspapers. 6. On July 3 and July 10, 1978, legal notices were published. II. Public Hearing: 1. Public information hearing was held in Brattleboro on August 4, 1978. 2. No parties (other than the applicant, Vermont Yankee) entered an appearance prior to the scheduled hearing, nor did any party present at the hearing enter their appearance or request to appear. 3. Vermont Yankee presented their application for amended and supporting materials (ie "316" report, etc.) 4. Staff personnel of the Agency of Environmental Conservation testified pertaining the proposed amended permit and proposed further revision to the amended permit.

Page 2 Summary / Vermont Yankee September 11, 1978 5. Esther Poneck of the New England Coalition on Nuclear Pollution spoke at the hearing of August 4, 1978, and stated that a Dr. John R. Clark of Washington, D.C. would file written comments within the comment period, w III. Subsequent filings: 1. On the afternoon of August 18, 1978, comments of Dr. John R. Clark, Fisheries Biologist of Washington, D.C. were received with letter of transmittal from Diana Sidebottham of the New England Coalition on Nuclear Pollution. 2. Subsequently, Vermont Yankee filed a rebuttal to Dr. Clark'u statement. IV. Findings and Recommendations: 1. It is the opinion of the Agency staff that the statement of Dr. Clark raised no significant issues requiring further action or consideration by the Secretary, and the Hearing Officer so finds. 2. The Hearing Officer concurs with the recommendation of the Agency staff that an amended permit should be granted to Vermont Yankee permitting open mode cooling operation as contained in the draft permit, as amended. [7M e Donald W. Webster Hearing Officer

~ j [, Permit No. 3-1053 s r, Application No. 13-17-002 + NPDES No. VT0000264 AMENDED DISCHARGE PERFET In compliance with the provisions of the Vermont Water Pollution Control Act, as amended, (10 V.S.A. Chap. 47 1 1251 et, sco; the "Act"), Vermont Yankee Nuclear Power Corporation 77 Grove Street Rutland, VT 05701 is authorized to discharge from a facility located at ' Covernor Hunt Road Vernon, Vermont 05354 to receiving waters named the Connecticut River (Class B, Type III) in accordance with ef fluent limitations, monitoring requirements and other conditions set forth in Parts I, II, and III hereof. This permit shall become effective on October 12, 1978 This permit and the authorization to discharge shall expire at midnight, June 30, 1980 Original Discharge Permit #3-1053 issued on July 8, 1975 This Amended Permit signed on Septenber 12, 1978 -7 t____ % I /] / 1 /- i \\, ^ WNt. al i J,L Vf.., G= Secretary, Agency of Environmental Conservation Form WR-88

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1. ART I$

Permit No. 3-1053 A. EFFLUENT LI!!ITATIOiS A!iD MO:11 TORI!!G REQUIREPI:iTS (Special Conditions) Except as specified in Paragraphs 1 through 12 below, the permittee is not authorized to discharge to the Connecticut River an ef fluent to which-any pollutants have been added. l. The permittee is authorized to discharge controlled amounts of heathd . water and other liquid waste to the Connecticut River provided that: a. Such discharges do not violate applicable Vermont. water quality standards and are not adverse to: huma health and safety; the environment in the vicinity of Vernon; and fish ana other wildlife, including their value as fish gnd game and their habitat and ecology. b. The permittee is required to operate its circulating water cooling facilities in a closed-cycle mode except as follows: (1) Experimental open-cycle test programs which are approved by the Vermont Yankee Technical Advisory Committee and the Secretary of the Vermont Agency of Environmental Conservation. (2) If, during pouer operation, an unexpected failure results in a complete loss of the cooling tower system, the above closed cycle restriction may be modified for a period not to exceed twenty-feur (24) hours to permit an orderly shutdcun by utilizing the main condenser as a heat sink and operating in an open-cycle modo. (3) During the period October 15 through May 15 open-cycle operation is allowed provided that: (i) The temperature at Monitor 3 during open-cycle operation shall not exceed 65*F. Ilowever, when the terperature reaches 60*F the permittee shall notify the Secretary within 24 hours of each occurrence. (ii) The rate of change of temperature at Mon. tor 3 shall not i exceed 5'F per hour. (iii) The increase in temperature above ambient at Menitor 3 shall not exceed 13.4*F. (iv) For purposes of this sub-paragraph " rate of change of temperature" shall mean the difference between consecutive hourly average temperatures and " increase in temperature above ambient" shall mean plant induced temperature increase as shown by equation 1.1 (defined at Page 1-8 of Vermont Yankee's 316 Demonstration: Ennincerinn, Ilydrolor,1c21 & Biolocical Information and Environcrntal Impact Assessment O! arch 19 78).

Page 2 of 18 Permit No. 3-1053 -{ (v) Notwithstanding the above, the Secretary may with respect to the period October 15 thru May 15 impose more stringent ( ' fluent linitations for control of the thermal component of Vermont Yankee's discharge, including a . requirement of closed cycle operation, if he determines that open cycle operation is having an adverse ef fect on resident or anadromous fish species in the river. Vercont Yankee will be given notice and opportunity for hearing prior to the imposition of such more stringent ef fluent limitations, unless the nature of the adverse effect will not allei sufficient time to give such notice and opportunity for hearing, in which event'the Secretary'shall hold a hearing within 10 days of his action if requested by " the permittee. Nothing in this sub-paragraph shall be construed to linit the power of the Secretary to modify this permit as provided in Part II B 4 c hereof. e e - -n.nm ,,e

bc Pe rmit No. 3-1053 'y, A mixing zone for open/ hybrid cycle operation may be designated if c. appropriate af ter cocpletion of the permitr.ce's further hydro-thermal and biological studies. d. A mixing zone is designated for cooling tower blevdown under closed-cycle operation. The blowdown mixing zone shall not exceed an area of three (3) acres contiguous to the discharge outfall. 3 Any heated water discharged in the Vernon Pool under the terms of e. this permit shall be aerated or otheniisc treated to provide a content of dissolved oxygen substantially at the level of saturation. 2. Racks and screens preventirg fish and other wildlife from entering the condenser water intake must be operated and maintained in a manner as previously 2pproved by the Vermont Water Resources Board. Solids collected on the traveling screens shall not be reintroduced into the Connecticut River. 3. All radioactive liquid wastes collected in the plant will be processed through a treatment systen, including filtering and/or demineralization, to concentrate the radioactive mate tial. Radioactive material removed from the liquid will be processed and disposed of in accordance with Nuclear Regulatory Commission regulations. Low level radioactive wastes may be released to the Connecticut River after treatment pursuant to procedures contained in the Summary Report cgt Liould Radwaste Svstem, Vermont Yankee Nuclear Power Corporation, submitted to the Vermont Water Resources Board on December 11, 1968, and subsequent submissions dated March 26, 1970, November 20, 1970, and November 6,19 71, subject to the following restrictions: a. The average annual concentration of radionuclides, except tritium, in liquid effluents relea ed to the unrestricted environment shall not exceed one one-hundreth (1/100) of the limits specified in Table II, Appendix B,10 CFR 20. b. The maximum instantaneous concentration of radionuclides, except tritium, in liquid ef fluents released to the unrestricted environment shall not exceed one-tenth (1/10) of the limits specified in Table II, Appendix V, 10 CFR 20. c. The maximum annual quantity of radionuclides, except tritium, in liquid ef fluents released to the unrestricted environment shall not exceed five (5.0) curies. d. The estimated annual average concentration of tritium in liquid ef fluents released to the unrestricted environment shall not exceed 0.005 microcuries per liter. c. The permittee shall report to the Agency of Environmental Conservation any abnormal releases of radioactivity, in liquid ef fluents, which are required to be reported to the Nuclear Regulatory Commission. s

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age o Pe rmit No. 3-1053 f. The permittee shall monit'- the concentrations of radionuclides in liquid effluents released to t.2 Connecticut River and report such data nanually to the Agency of Environmental Conservation. 4. The permittee shall conduct an environmental mon!.toring program to ceasure and rec,ord physical, chemical, and biological data to assure compliance with the requirements of this per rlt in accord with, Environmental M ;f ring Studies, Connecticut Rive; near Vernon, Vermont, NPDES No. VT00002f>'. (Attachment A to this permit). The permittee shall subatt cn annuc1 report of such conitoring to the Agency of Environmental Conservation. e 9 8 ,w,

~. i 5. EFFLUENT LIMITATIONS AND Mb:!ITORING REQUIREMENTS or, the date During the period beginning of signing and lasting through June 30, 1980 the permittee is autho"ized to discharge from outfall(s), serial number (s) 001 (Circult,.ing Uater Discharge) Such discharges sbc~. be limited and monitored by the permittee as specified below: Effluent Characteristic Discharge Limitations Monitoring Requirements kg/ day (1bs/ day) Other Units (Specify) Measurement Sample Daily Avg Daily Max Daily Avg Daily Max Frequency Type Flow-m / Day (RCD) (1) Closed Cycle 36,700 (9. 7) 73,400 (19.4) Daily Weekly Avg. (2) Open Cycle 2,000,000 (543) ' Daily Ucekly Avg. Temperature, Closed Cycle 27'C (81*F) 34*C (9 3* F) (a) Continuous Daily Avg. Chlorine Fres Residual 0.2 mg/l (b) (c) Crab Chloriae Total Residual 0.5 ng/l (b) (c) Grab Sodium Weekly Crab Sulfate Weekly Grab The pit shall not be less than 6.5 standard units nor greater than 8.5 standard units.!Lqd shqlLle monitorl, d hot Applicable There shall be no discharge of floating solids or visible foam in other than trace amounts. Samples taken in compliance with the monitoring requirements specified above shall be taken at the following location (s): Samples shall be taken at locations whicli are m m m representative of the effluents discharged. a a H e-(a) If, under normal operating conditions, the supplementary blowdown spray pond becomes u inoperable, daily ins tantaneous maximum tempe ratures of 110*F sre permitted, provided 5 that the maximum time above 93*F does not exceed 7 days during any one month. (b) Not to exceed two hours per day. g (c) Monitoring only during chlorination. J. m O w i

6. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS on the date During the period beginning of signing and lasting through June 30, 1980 the permittee is authorized to discharge from outfall(s), seria.1 number (s) 001A (Plant licating Blowdoten) ~ ~ Such discharges shall be limited and monitored by the permittee as specified below: Effluent Characteristic Discharce Limitations Monitorine Recuirements ~~ kg/ day (Ibs /d., Other Units (Specify) Measurement Sample Daily Avg Daily Max Daily Avg Daily Max Frequency Type Flow-m / Day (MCD) 1,1 -(0.0003) 1.9- (0.0005) Estimate Phosphorus Grab

• Shall be monitored when discharged.

The pit shall not be Icss than 6.5 standard units 'nor greater than 8.5 standard units and shall be monitored. Not Applicable Not pplicabicj [here shall be no discharge of floating solids or visible foam in other than trace amounts. Samples taken in compliance with the monitoring requirements specified above 7 hall be taken at the following location (s): Before combining with cooling water. 2 2 5! 3 fl R = i t p i o u I m

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EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS on the date During the period beginning of signing and lasting through June 30, 1980 the permittee is authorized to discharge trom outfall(s), serial number (s) 001B (Pake-up deminealizer regenerate waste) Such discharges shall be limited and monitored by the permittee as specified below: Effluent Characteristic Discharge Limitations Monitorine Requirements kg/ day (1bs/ day) Other Units (Specify) Measurement Sample Daily Avg Daily Max Daily Avg Daily Max Frequency Type Flow-m / Day (MCD) 33 -(0.010) 91 - (0.024) Estimate Total Suspended Solids 2.724 (6) 9.08 (20) Crab

• Shall be monitored when discharged (approximately once every two weeks)

The pH shall not be less than 6.5 standard units nor greater than 8.5 standard units and shall be monitored. Not Applicable There shall be no discharge of floating solids or visible foam in other than trace amounts. Sampics taken in compliance with the monitoring requirements specified above shall be taken at the following location (s): point of discharge 7 2f s! e B i: Ei ? s i = 0, i j Y H l o E" i i

8. EFFLUE!TI LIMITATIONS AND MONITORING REQUIREMENTS on the date During the period beginning of signing and lasting through June 30, 1980 the per.aittee is authorized to discharge from outfall(s), serial number (s) 001C (Water treatment sand filter backwash) Such discharges shall be limited and monitored by the permittee as specified below: 1 Effluent Characteristic Discharce Limitations Monitorine Requirements kg/ day (1bs/ day) Other Units (Specify) e Measurement Sample Daily Avg Daily Max Daily Avg Daily Max Frequency Type Flow-m / Day (MCD) 3.8 -(0.001) 182-(0.048) Estimate Total Suspended Solids 5.448 (12) 18.16 (40) Grab I Shall be monitored when discharged (approximately twice per week) i l. I !i i The pH shall not be less than 6.5 standard units nor greater than8.5 standard units and shall be monitored. Not Applicabic There shall be no discharge of floating solids or visibic foam in other than trace ar.' Sampics taken in compliance with the monitoring requirements specified above shall t. taken at the i following location (s): point of discharge. E' El E! 3 U$ o, ~ om e 5 0

~ 9. EFFLUE!TE LIMITATIONS AND MONITORING REQUIREMENTS on the date During the period beginning of signing and lasting through June 30,1980 the permittee is authorized to discharge from outfall(s), serial number (s) Such discharge (Radioactive Liquid Discharge) 002 s shall be limited and monitored ' y the permittee as specified below: c Effluent Characteristic Discharne Limitations Monitorine Reauirements kg/ day (lbs/ day) Other Units (Specify) Measurement Sample Daily Avg Daily Max Daily Avg Daily 1Dx Frequency Type ~ Flow-m / Day (MCD) 36,336 (9.6) 109,008 (28.8) Radioactivity

• See Special Condition 3 (f) for monitoring.

The pH shall not be less than standard units nor greater than standard units and shall be monitored. Not Applicable There shall be no discharge of floating solids or visibic foam in other than trace amounts. Samples taken in compliance with the monitoring requirement; specified above shall be taken at the following location (s): Samples shall be taken at locations which are ? ? 9! representative of the radioactive cifluents s y 2 Q discharges. p s n O, W 5 w V I

Page 10 of 18 Permit No. 3-1053 10. In addition to the discharges specified in paragraphs 5-9 above the permittee is authorized to discharge f rom the following storm drains: 006 1: orth Storm System Discharge Point 007 East Storm System Discharge Point 008 South Storm System Discharge Point Ef fluent limits and monitoring reports will not be required for these discharges, however, future storm drain and mannole construction shall conform to Agency policy for storm water treatment. 11. The permittee granted permission to conduct a test program for Calgon corrosion inhibitors as described in Appendix C of the October 28, 1976 sub cds sion by, llowa rd S. Lew i.s. However, the continued use of a corrosion inhibitor shall only be approved by an amendment to this permit. 12. The permittee is authorized to use Drewsperse 738, a proprietary condenser cleaning compound, as needed, during periods of high river water turbidity, to maintain condenser cleanliness. The amount of Drewsperse 738 to be used shall not exceed 72 gallons (600 lbs.) at maximum flow and shall be reduced in proportion to flow reduction to maintain a concentration not in excess of 10 ppm. ....~

y s r-rt I i j Page 11 of 18 Permit No. 3-1053 B. SCitEDULE OF COMPLIANCE 1. The permittee shall achieve compliance with the ef fluent limitations specified for discharges in accordance with the following schedule: NONE 2. No later than 14 calendar days following a date identified in the above schedule of compliance, the permittee shall submit either a report of progress or, in the case of specific actions being required by identified dates, a written notice of compliance or noncompliance. In the latter case, the notice shall include the cause of noncompliance, any remedial actions taken, and the probability of meeting the next scheduled requirement. NONE O e 6 -o ~'

Page 12 of 18 Permit No. 3-1053 C. MONITORING AND REPORTING 1. Representative Samoling Samples and censurements taken as required herein shall be repre-sentative of the volume and nature of the monitored discharge. 2. Reporting 3 Monitoring results except radionuclides data shall be reported as specified on an approved Discharge Monitoring Report Form, postmarked no later than the 25th day of the month following the completed reporting period. The first report is due on Septerber 25, 1978. Duplicate signed copics of these, and all other reports reauired herein,. shall be sdamitte'd to the Secretary and the Regional Administrator at the following addresses: Agency of Environmental Conservation Environmental Protection Agency Montpelier, Vermont 05602 Region I John F. Kennedy Federal Building NPDES Permit Section. Boston, Massachusetts 02203 Attention: Permits Branch 3. Definitions For purposes of this permit, the following definitions shall apply. Average - The arithmetic mean of values of analyses from samples taken at the frequency required for such parameter over a specific operating period. Composite ba.ple - A sample consisting of a minimum of eight grab samples collected at regular intervals over a normal operating day and combined proportional to flow, or a sample continuously collected proportional to flow over a normal operating day. Daily Average - The mean value of the analyses of at least eight grab samples collected at regular intervals over a normal operating day. Grab Sample - An individual sample collected in a period of less than 15 minutes. Daily Average Discharge - the total discharge by weight during a calendar month divided by the nunber of days in the month that the production or commercial facility was operating. k'here less than daily o ,e ~ + n g

Page 13 of 18 Permit No. 3-1053 sampling is required by this perndt, the daily average discharge shall be determined by the su=mation of all the measured daily discharges by weight divided by the number of days during the calendar month when the measurements were made. Daily tbximum Discharge - The maximum permissable total discharge during any calendar day. Closed Cycle Operation and Blowdown - The circulating water system mode in which water is circulated through the cooling towers to dissipate condenser heat, s The only water discharged to the river during closed-cycle operation is the blowdown from the cooling towers. Blowdcun reters to the water continuously removed from the cool side of the cooling tower collection basins to rid the cooling towers of dissolved solids. 4. Test Procedures Test procedures for the analysis of pollutants shall conform to regulations published pursuant to Section 304 (g) of the Federal Water Pollution Control Act, under which such procedures may be required. Guidelines establishing these test procedures have been pubL.shed in the Federal Register as Vol. 38, No. 199, Part II, dated October 16, 1973. 5. Recording of Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information: a. The exact place, date, and time of sampling; b. The dates the analyses were performed; c. The person (s) who performed t' - analysas; d. The analytical techniques or methods used; e. The results of all required analyses and, f. Weather conditions, plant operating condition, and any unusual or abnormal condition shall also be noted.

Page 14 of 18 Permit No. 3-1053 6. Additional Monitoring by Per:1ttee If the permittee monitors any pollutant at the location (s) designated herein more f requently than required by this permit, using approved analytical =cthods as specified above, the results of such monitoring shall be included it. the calculation and reporting of the values required in the Discharge Monitoring Report Form. Such increased frequency shall also be indicated. 7. Records Retention All records and information resulting from the monitoring activities require.d by this permit including all r teords 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 Secretary or the Regional Administrator. e ,.- e .w e g ge

e Page 15 of 18 Permit No. 3-1053 TART II A. IfANAGE15NT REQUIRE!ENTS 1. Change in Discharge All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this )cr=it eore frequently than or at a 1cvel in excess of that authorized shall constitute a violation of the permit. Any anticipated f acility expansions, production increases, or process modifications which will result in new, di f ferent, or increased discharges of pollutants must be reported by submissions of a new permit application or, if such changes will not violate the effluent limitations specified in this permit, by notice to the permit issuing authority of such changes. Folicwing such notice, the permit may be codified to specify and limit any pollutants not previously limited. 2. Noncompliance Notification If, for any reason, the permittee does not comply with or will be unable to comply with any daily maximum ef fluent licitation specified in this permit, the permit'tce shall provide the Secretary and the Regional Administrator with the following inforeation, in writing, within five (5) days of becoming aware of such condition: A description of the discharge and cause of noncompliance; and a. b. The period of noncompliance, incleding exact dates and times; or, if not corrected, the anticipated time the noncompliance is expected to continue, and steps being taken to reduce, climinate and prevent recurrence of the noncomplying discharge. Persons holding Discharge Permits shall comply with a and b above by c. submitting the required information with an application for an Emergency Pollution Permit. 3. Facilitics Operation The permittee shall at all times maintain in good working order and operate as ef ficiently as possibic all treatment or control facilities or systems installed or used by the permittee to achieve compliance with the terms and conditions of this permit. 4. Adverse Impact The permittee shall take all reasonable steps to minimize any adverse impact ta navigable waters resulting from noncompliance with any ef fluent limitations specified in this permit, including such accelerated or additional monitoring as necessary to determine the nature and impact.,of the noncomplying uischarge. 5. Bypassing Any diversion from or bypass of facilitics necessary to maintain compliance with the terms and conditions of this permit is prohibited, except (i) where unavoidable to prevent loss of life or severe property damage, or (ii) where excessive storm drainage or runof f would damage any facilities necessary for compliance with the ef fluent limitations and prohibitions of tais permit. The permittee shall promptly notify the Secretary and the Reg.?6. 1 Ad=inistrator in writing of each such diversion or bypass.

Page 16 of 18 Permit No. 3-1053 6. Removed Substances Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters shall be disposed of in a nsnner such as to prevent any pollu'. ant from such materials from entering navigable waters. 7. Power Failures In order to maintain compliance with the effluent limitations and prohibitions of this permic, tbc permittee shall either: a. In accordance with the Schedule of Compliance. contained in Part I, provide an alternative power source suf ficient to operate the wastewater control facilities ; or, if such alternative power source is not in existence, and no date for its impicmentation appears in Part 1, b. Halt, reduce or otherwise control production and/or all discharges upon the reduction, loss, or failure of the primary source of power to the wastewater control facilitics. B. RESPONSIBILIFIES 1. Right of Entry The permittee shall allow the head of the State water pollution control agency, the Regional Administrator, and/or their authorized representatives, upon the presentation of credentials: a. To enter upon the permittee's premises where an effluent source 14 located or in which any records are required to be kept under the terms and conditions of this permit; and b. At reasonabic times to have access to and copy any records required to be kept under the terms and conditions of this permit; to inspect any monitoring equipecat or monitoring method required in this permit; and to sampic any discharge of pollutants. 2. Transfer of Ownership or Control In the event of any channe in control or ownership of facilitics from which the authoriacd discharges emanate, the permittee shall notify the succeeding owner or controller of the existence of this permit by letter, a copy of which shall be forwarded to the Secretary and to the Agency of Environmental Conservation. 3. Availability of Reports Except for data determined to be confidential under Section 1259 (c) of the Act, all reports prepared in accordance with the terms of this permit shall be availabic for public inspection at the offices of the State water pollution

) Page 17 of 18 Permit No. 3-1053 control agency and the Regional Administrator. As required by the Act, effluent data shall not be considered confidential. Knowingly making any false statement on any such report cay result in the imposition of criminal penalties as provided for in Section 1275 (b) of the Act. 4. Permit Modification Af ter notice and opportunity for a hearing, this permit may be modified, suspended, or revoked in whole or in part during its term for cause including, but not limited to, the following: Violation of any terms or conditions of this permit; a. Obtaining this permit by misrepresentation or failure to disclose fully all b. relevant facts; or A change in any condition that requites either a temporary or permanent c. reduction or elimination of the authorized discharge. 5. Toxic Pollutants Notwiths tanding Part II, B-4 above, if a toxic ef fluent standard or prohibition standard or (including any schedule of compliance specified in such ef fluent prohibition) is established under Section 307 (a) of the Federal Water Pollution Control Act for a toxic pollutant which is present in the discharge and such standard or prohibition is more stringent than any limitation for such pollutant in this permit, this permit shall be revised or modified in accordance with the toxic effluent standard or prohibition and the permittee so notified. 6. Civil and Criminal Liability Except as provided in permit conditions on " Bypassing" (Part II, A-5) and "Powcr Failurcs" (Part II, A-7), nothing in this permit shall be cons trued to re'.icyc the permittee from civil or criminal penaltics for noncompliance. 7. Oil and Hazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any Icgal action or rc11cvc the permittee from any responsibilities, liabilities, or penaltics to which the permittcc is or may be subject under Section 1281 of the Act. 8. State Laws Nothing in this permit shall be construed to preclude the institution of any Icgal action or rc11cvc the permittee from any responsibilitics, liabilitics, or penaltics established pursuant to any applicabic State law or regulation under authority preserved by Section 510 of the Federal Water Pollution Control Act.

Page 18 of 18 l 1 Permit No. 3-1053 l 9. Property Rights convey any property rights in eithbr real I. Issuance of this permit does not i any or personal property, or any exclusive privileges, nor does it author ze injury to private property or any invasion of personal rights, nor any l infringement of Federal, State or local laws or regulations. l 10. Severability The prov sions of this permit are severable, and if any provision of this ~ to any circumstance, permit, or the application of any provision of this permitis held i shall not be affected thereby. and the remainder of this permit, PART III DIRER REQUIREMINTS of the Agency of Environmental Conservation in "Any action on the part revicuing, commenting upon or approving plans and specifications for facilities shall not relieve the construction of wastewater treatment limitations the permittee from its responsibility te achieve ef fluent forth in this permit and shall not constitute a waiver of, or act set of estoppel against any remedy availabic to the Agency, the State of for failure to meet any requirement Vermont or the federal government set forth in this partit or imposed by state or federal law."

Fage 1 of 4 l ENVIRONMENTAL MONITORING STUDIES CONNECTICUT RIVER NEAR VERNON, VERMONT NPDES NO. VT0000264 WN UURING MONITORING COMMENTS PARAMETER FREQUENCY AND/OR DATEC LCCATIONS River flm/ data will be tabulated f rom the River Flow Rate Hourly Vernon Dam records of the Vernon Hydroelectric Cenerating Station. Tempe rature Continuous Vermont Yankee Water temperature data will be monitored with Monitor Stations 3 in situ probes in the river and with tank senso and 7 of the Honeywell U-20 Water Quality Monitors. Data will be telemetered to the Vermont Yankee control room for use in plant operation and wil be tabulated in the annual report as hourly, daily, and monthly means, Vernon Pool and/or One survey to characterize Vermont Yankee's i See Comments Connecticut River discharge thermal plume will be conducted durin downstream of Vernon each spr?ng and fall period of special studies to asress Vermont Yankee's open cycle operation Dam on anadromous fish. Continuous Vermont Yankee Analog record of pH collected by Honeywell U-20 pH Monitor Stations 3 monitors will be reduced to daily pH maxima and and 7 minima. i Analog record of i0 collected by Honeyuell W-20 Dissolved Oxygen Continuous Vermont Yankee Monitor Stations,3 munitors will be reduced to daily means and and 7 daily maxima and minima with their times of occurrence. Vermont Yankee Grab sampics will be analyzed for the followin, 16 Water Quality Quarterly Dissolved oxygen, turbidity, pH, Monitor Stations 3 parameters: l Parameters alkalinity, total and calcium hardness, chlorl< and 7 and Vermont l Yankee cooling water sulfate, total phosphorus, total and suspended solids, chromium, copper, iron, sodiun and zin discharge '. l

Attachment A 6 Page _j! _ of 4 ~ ENVIRONMENTAL MONITORING STUDIES CONNECTICUT RIVER NEAR VERNON, VERMONT NPDES NO. VT0000264 MONITORING MONITORING COMMENTS l PARAMETERS FREQ'IENCY AND/OR DATES f or ATT 0*!s Phytoplankton Monthly Ve).mont Yankee Organisms will be identified to lowest feasible Zooplankton

.onitor Stations 3 taxonomic level and enumerated as their normally and 7 occurring unit.

Entrainment a) Phytoplankton Monthly when Vermont Yankee Connecticut River at Duplicate samples will be collected and analyzed Zooplankton is operating in hybrid or Vermont Yankee intake to determine the identity of organisna present open cycle cooling-modes structure and cooling and the ratio of living to dead organisms in water discharge to the samples. the river b) Ichthyoplankton Daily in April, May and Vermont Yankee intake Ichthyoplankters will be counted and will be June until spring spawning bay during open cycle identified when feasible. habits of resident finfish operation; in river are documented near intake structure during closed cycle operation Benthic Fauna Monthly, May thrcugh Vermont Yankee Monthly samples will be collected by Ekman dredge Novembe r Stations 2, 3, 4, at river quarter points. These dredge samples and 5 will be supplemented at each station by three collections utilizing cage samplers retrieved after 30 to 60 days in the river. Organisns will be counted and identified to lowest practicable taxonomic level. 4 / e

Attachment A Page 3 of 4 ENVIRONMENTAL MONITORING STUDIES CONNECTICUT RIVER NEAR VERNON, VERMONT NPDES No. VT3000264 MONITORING MONITORING COMMENTS pp, FREQUENCY AND/OR DATES LOCATIONS Fish Impingement During hybrid or open Vermont Yankee All fish impinged will be identified, weighed, cycle operation, one 24 circulating water and measured. Immediate notification of the hour saeple in accord with traveling screens impingement of any American shad or Atlantic salmon will be made to the Secretary, and the following '.hedule: frequency of sampling will be increased to a daily basis until seven (7) consecutive days Period Fren uency have passed with no further impingement of Oct 15 -Oct 31 3/ Week either of these tuo species. All impinged huvemb e r 1/ Neck specimens of American shad and Atlantic Dec - Feb 1/ month salmon shall be preserved. During the periods Mar 1 - Apr 15 1/Ueck April 16 through May 15 and October 15 through Ap r 16 ->by 15 3/ Week Octooer 31, if the number of Atlantic salmon smolt or American shad impinged reaches one-tenth of one percent of the maximum numbers of these fish anticipated to be passing the Vernon area cach year, Vermont Yankee will revert to closed cycle operation for the remainder of the period. The maximum number of Atlantic salmon smolt anticipated to be passing the Vernon area cach year will be determined as the total number of salmon stocked upstream of the Vernon Dam that will be neo years old that calendar year. The maximum number of American shad anticipated to be passing the Vernon area cach year is the number of shad eggs and/or the nucher of eggs estimated to be released by gravid females stocked up. stream of Vernon Dan that calendar year. G G

a w . Page 4 of 4 ENVIRON!! ENTAL MONITORING STUDIES ~ CONNECTICUT RIVER NEAR VERNON, VER:10NT NPDES NO. VT0000264 MONITORING C05 DENTS MONITORING LOCATIONS PARA}ETERS FREQUENCY AND/OR DATES least A representative sacple consisting of at Finfish Annually 500 fish north of Vernon Dam and 500 fish south Vermont Yankee Stations 2 to 8 of Vernon Dam will be collected each year. All fish collected will be identificu and weight and Scales fo r a ge-total length will be measured. grouth determinations will be collected f rom the following species: All salmonids, American i sh d, walleye, smallmot.th bass, largemouth b' ass,.' Vermont Yankee yellow perch, and white perch. will explore special studies to assess the of Vernant Yankee's open cycle operation impact of anadromous fish in the on the movement vicinity of the plant. m / NWMW6e*W M-

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