ML20138M859

Final NPDES Permit NJ0005622 Issued to Public Svc Electric & Gas Co

ML20138M859
Person / Time
Site:	Salem
Issue date:	10/16/1985
From:	Kurisko P NEW JERSEY, STATE OF
To:
Shared Package
ML20138M856	List: ML20138M853 ML20138M859
References
NJ0005622, NJ5622, NUDOCS 8512230194
Download: ML20138M859 (76)

Text

__ __ _. _ _

t .t 6 tate of Netu 3rrstg

.;CNN w GASTON R . P E. as n e DEPARTMENT OF ENVIRONMENTAL PROTECTION cQc 7e7ge

,g DIVISION OF WATER RESOURCES CN 029 TRENTON, NEW JERSEY 08625 CERTIFIED MAIL RETURNED RECEIPT REQUESTED Mr. James A. Shissias General Manager, Environmental Affairs Public Service Electric & Gas Co. ..

80 Park Plazh . OCT 161985. . . . . .. .

Mail Code IOC Newark, N.J. 07101 _

OCT 18 ~.w,:0 Re: NJPDES Permit No. NJ0005622 3'",'f: c3; Effactive Date: Decenber 1,1985 jNi$ L "'

E;3

Dear Mr. Shissias:

.J' u ...t

{

Enclosed is the final NJPDES/DSW Permit and Notice of Authorization to discharge pollutants to the Delaware River, issued in accordance with the New Jersey Pollutant. Discharge Elimination System Regulations, N.J.A.C. 7:14A-1 g seq. Violation of any condition of this permit may subject you to significant penalties.

Within 30 calendar days following your receipt of this permit, under N.J.A.C. 7:14A-8.6 you may submit a request to the Administrator for an adjudicatory hearing to reconsider or contest the conditions of this permit. Regulations regarding the format and requirements for requesting an adjudicatory hearing may be found in N.J.A.C.

7:14A-8.9 through 8.13. The request should be made to.

Administrator Water Quality Management Element Division of Water Resources CN-029 Trenton, New Jersey 08625 Application for renewal of this permit must be submitted at least 180 days prior to expiration of this permit pursuant to N.J.A.C. l 7 : 14 A-2.1 ( f) 5.

If you have any questions on this action, please contact Mr. Edward H. Post, P.E., Chief, Industrial Permits Section at (609) 292-0407.

Very truly yours, ,

E:

8512230194 851223 Paul C. urisko, P.E., Chief PDR ADOCK 05000272 Industrial Waste Management Bureau P PDR Water Quality Management

~.

New Jersey is An Equal Opportunity Employer Q r J

~

e .

STATE OF NEW JERSEY

" DEPARDIENT OF ENVIRONMENTAL PROTECTION y"1),

9

' 1 CN 402 .

Trenton, N.J. 03625 i i. s1 PERMIT The New Jersey Department of Environmental Protection grants this permit in accordance with your application, attachments accompanying same application, and applicable laws and regulations. This permit is also subject to the further conditions and stipulations enumerated in the supporting documents which are agreed to by the permittee upon acceptance of the permit.

Permit No. Issuance Date Effective Date Expiration Date NJ0005622 October 15, 1985 December 1, 1985 Noveter 30, 1990 Name and Address of Apphcant IAcation of Activity / Facility Name and Address of Owner Public Service Electric & Cas Co. Salem Generating Station Public Service Electric & Cas 80 Park Place Artificial Island 80 Park Place N;wsrk, N.J. 07101 Lower Alloways Creek Twp. Newark, N.J. 07101 Salem Co., N.J.

Issuing Division Type of Permit Statute (s) Application No.

N.J.S.A NJ0005622 W ter Resources NJPDES-DSW 58:10A-1 et seq.

This permit grants permission to:

Discharge to Zone 5 of the Delaware River in accordance with the affluent limitations, monitoring requirements, and other conditions set forth in.e Parts I, II, III, and IV hereof. .

'Ihis permit does not include any MJPDES Discharge to Ground Water (DGW) permit required in accordance with N.J.A.C. 7:14A--l et seq. Also, this permit _does not constitute a waiver frcra obtaining an MIPDES-DGW permit as per Section 10.7 of the NJPDES Regulations. 'Ihe Departznent reserves the right to modify this DSW permit at any time to include a DGi permit section.

Approved by the Department of Environmental Protection -

By the Authority of: # / /g 2 /d//3./[

/

Jrhn W. Gaston, Jr., P.E.

Dir:ctor, Div. of Water Resources jdMsN r

((

ue t . n.gi < ty wn e g===n*

'[

O De wortf permit masns "appropel, cert (/kstion, registation, etc. " (GENERAL CONDITIONS ARE ON THE REVERSE SIDE.)

Form oEP407 (3/333 r

'O PSEG de 80 Park P!aza. Newark, NJ 07101/ 201430-5558 MAILING ADDRESS / P O 90 x 570. Nw. ark. NJ 07101 James A.Shissias General Manager Environmental Af fairs l'RINCIPAL ENGINEER -

October 22, 1985

, 3V1804M TAL LICENSING J 'Hr TTO

.n: . , ,

e-l OCT 2 3 Geb To the Vice-President - Nuclear  ; ryg g .

General Attorney - Law Department l ggg ,

I rce FINAL NJPDES PERMIT }

I rd""""'* *

• SALEM GENERATING STATION Attached is the Salem Generating Station New Jersey Pollutant Dis-charge Elimination System (NJPDES) Discharge to Surface Water renewal permit. The pe rmi t , which was issued on October 15, 1985, is to take effect on December 1, 1985. The Company has until November 15, 1985 to request an adjudicatory hearing to reconsider or to contest the permit conditions. .

Some of the important permit conditions and limitations are noted below:

1) Compliance wit n main circulating water discharge temperature and temperature rise above ambient permit limits are to be met by numerically averaging the temperatures of each unit's main circulating water discharge pipes together. This " averaging" is as per our request and should address many of the previous tempera-ture non-compliance conditions. Main circulating water discharge temperature is now limited to 110 F which is SOF lower than in the previously expired NJPDES permit. The main condenser temperature rise limitation of 27.5 F0remains unchanged.

2) Main circulating water discharges - a total residual chlorine (TRC) limitation of .2 mg/l will now replace the previous permit's free available chlorine limitation. This change is required by U.S. EPA steam electric guidelines. Chlorination on the main circulating water system will be limited to two hours per day per unit as compared to the current chlorination schedule of 1-1/2 hours per circulating water pump per day. A provision in the permit allows for longer periods of chlorination provided the permittee can demonstrate to the agency that extended periods of chlorination are needed to control macroinvertebrate fouling.

Compliance with the TRC limitation has been specified to be by grab sample once per two hour chlorination period.

3) Service water system - continuous chlorination is permitted provided that the TRC of the service water prior to mixing with main condenser cooling water will not exceed . 2 mg /1. Compliance with this limitation is to be performed by grab sample once every eight hours.

Tne Enerlg y Pecole

+s s; .

I

so 2 1985 tobar 224 g imposed on the effluent main old i

rior to mixing with Previously, the the A

6-9 pH limitation is now be n with the

) from the non-rad waste circulating waterbasin p discharges.f this dischargeof the pH condenser had allowed the buffering oThe was appropriatenessan item the pcrmit stream condenser cooling on water.an internal wasteseveral fossil plant test permits.

limitation contested in using Mysid Shrimp as theon the company has An acute bioassay toxicityIftestformed four tests four times per yearshow no m

5) cp cies is requiredeffluent. to be per may be requested.

non-rad toxicity, waste basin on a modificat i

now have effluent Salem site water discharges from theliance samplingentrequired.

6) Storm .

limitations specified and comp an Industrial Waste Managemstorage, and disp I 1 classified Salem as treatment, We feel this isclassifica-

7) DEP has Facility which imposes on RCRAthe facility. attempting to get this regulatory requirementsand change, we are a serious soon as possible.should be tion altered.

staff review this permit asand limitations 1985 so that a If Please have your the permit conditionsthan November 12, requested.

if needed, mayplease be contact Eric

-Written' objection toforwarded ing request, this to this permit, office no later timsly- adjudicatory hearany questions pertaining to you haveat extension 5860 '

l

-Sysnson b/

M (

7

( .

CC: J. H. Balletto .

C. Sulzberger

-g g ..- - - - - - --

e .

Chscklist P:gi 1 of 1 Permit No. A/J,W)f E CHECKLIST OF PARTS AND MODULES CCP.FRISING THIS NJPDES PEPEIT

1. Cover Page

2. Che-klist

3. Part I (General Conditions for All NJPDES Discharge Permits)

4. Part II - Additional General Conditions for the types of NJPDES Permits checked as follows:

Part II - A (Municipal / Sanitary)

/ Part II - B/C (Industrial / Commercial / Thermal)

Part II - L (SIU)

Part II - Iletr (Industrial Waste Management Facility)

Part II - DGN Specify type (s):

5. Part III - Effluent Limitations and Monitoring Requirements Part III - A

! Part III - 5/C Part III - L Part III - DGW Specify type (s):

6. Part IV - Special Conditions Part IV - A

/ Part IV - B/C Part IV - L Part IV - InttF Part IV - DGN Specify type (s):

i 7. I c.c E.

- ( , , ci C l

n f

Part I

• . i Paqs 1 of 16 STATE OF NEW JERSEY DEPARIMNT OF DNIRONNDfIAL PROTECTICN DIVISION OF WATER RISCURCES GDIERAL CONDITIONS FOR ALL NJPDES DISCHARGE PEEMITS

1. Duty to Cosely A. The permittee shall comply with all conditions of this New Jersey Pollutant Discharge Elimination System (NJPDES) permit. No pollutant shall be discharged more frequently than authorized or at a level in excess of that which is authorized by the pemit. The discharge of any pollutant not specifically authorized in the NJPDES permit or listed and quantified in the NJPDES application shall constitute a violation of the permit, unless the pemittee can prove by clear and convincing evidence that the discharge of the unauthorised pollutant did not result from any of the permittee's activities which contribute to the generation of its wastewaters.

Any permit noncompliance constitutes a violation of the New Jersey Water Pollution Control Act (N.J.S.A. 58:10A-1 tet _seg.; hereinafter referred to as the State Act) or other authority of the IUPDES regulations (N.J.A.C. 7:14A-1t et sg.) and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.

B. A permittee shall not achieve any of fluent concentration by dilution. Nor shall a permittee increase the use of process water 'or cooling water or otherwise attempt to dilute a discharge as a partial or complete substitute for adequate treatment to achieve permit limitations or water quality standards.

C. The permittee shall comply with applicable offluent standards or prohibitions established under Section 307 ~ (a) of the " Federal Water Pollution Control Act" (FL 92-500 g _seg.; hereinaf ter referred to as the Federal Act) and Section 4 of the State Act for toxic pollutants within the time provided in the regulations that establish these standards or prohibitions, even if the permit has not yet been modified to incorporate the requirement.

D. The State Act provides that any person who violates a permit condition implementing the State Act'is subject to a civil penalty not to exceed $10,000 per day of such violation. Any person who willfully gr negligently violates permit conditions implementing the State Act is subject to a fine of not less than $2,500 nor more than $25,000 per day of violation, or by imprisonment for not more than 1 year, or both.

E. The permittee is required to comply with all other applicable federal, state and local rules,-

regulations, or ordinances. The issuance of this permit shall not be considered as a waiver of any other requirements.

2.- Permit Btpiration This permit and the authorization to discharge shall expire at midnight on the expiration date of the permit. . The permittee shall not discharge af ter the above date of expiration of the permit.

A. Duty to Reapply. If the permittee wishes to continue an activity regulated by a NJPDES permit af ter the expiration date of the permit, the permittee shall apply for and obtain a new permit.

(If the activity is to be continued, the permittee shall complete, sign, and submit such

_information, forms, and fees as are required by the Department no later than 180 days before the expiration date.) The permittee shall follow the requirements stated in paragraph 12.A. when signing any application, e

Ptrt I , ,

PIq) 3 cf 16 B. Centinuation of Expiring Permits (1) The conditions of an expired permit are continued in force pursuant to the " Administrative Procedure Act," N.J.S. A. 52:14B-11, until the ef fective date of a new permit if:

a. The permittee has submitted a tinely and complete application for renewal as provided lu Sections 2.1 and (3.2 DSW) (4.4 IWF) (5.8 UIC) and Subchapter 10 of the NJPDES Regulations; and

b. The Department through no fault of the permittee, does not issue a new permit with an ef fective date under Section 8.6 of the NJPDES Regulations on or before the expiration date of the previous permit (e.g. , when issuance is impracticable due to time or resource constraints). I (2) Permits continued under this section remain fully ef fective and enforceable.

(3) Enforcement. When the permittee is not in compliance with the conditions of the expiring or expired permit the Departmett may choose to do any or all of the following:

a. Initiate enforcement action based upon the permit which ha"; been continued;

b. Issue a notice of intent to deny the rew pe! nit under Section 8.1 of the NJPDE Regulations. If the permit is denied, the owner or operator would then be required to cease the activities authorized by the continued permit or be subject to enforcement action for operating without a permit;

c. Issue a new permit under Subchapters 7 and 8 o. the NJPDES Pequ1ations with appropriate conditions; or

d. Take other actions authorized by the NJPDE Regulations or the State Act.

3. Duty to Halt or Reduce Activity A. It shall not be a defense for a permittee ir. an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

B. Upon reduction, loss, or failure of the treatment facility, the permittee shall, to the extent necessary to maintain compliance with its permit, control production or discharges or both until the facility is restored to its permitted limits or an alternative method of treatment is provided. This requirement applies, for example, when the primary source of power of the j treatment facility fails or is reduced or lost.

t

4. Duty to Mitigate The permittee shall take all reasonable steps to minimize er correct any adverse impact on the environment resulting from concompliance with this permit, including but not limited to accelerated and/or additional types of monitoring, temporary repairs or other mitigating measures.

5. Proper Operation, Maintenance and Licensing A. The permittee shall at all times maintain in good working order and operate as ef ficiently as possible all treatinent works, f acilities, and systems of treatment and control (and related appurtenances) for collection and treatment which are installed or used by the permittee for l

E . .

Part I

_i- Page 3 of 16 water pollution control and abatement to achieve compliance with the terms and conditions of the persit. Proper operation and maint nance includes but is not limited to effective performance based on designed facility removals, adequate funding, ef fective management, adequate operator staffing and training and adequate laboratory and process controls including appropriate quality assurance procedures as described in 40 CF1t Part 136 and applicable State I4w and regulations.

All permittees who operate a treatment works, except for sanitary landfills and land application of sludge or septage, must satisty the licensing requirements of the " Licensing of Operators of Nestewater and Water Systems" N.J.S.A. 58:11-64 ett seg, or other applicable law. This paragraph requires the operation of back-up or auxiliary facilities or similar systems when necessary to achieve compliance with the conditions of the permit or where required by applicable law or regulation.

B. Facilities Operation and Operator Certification. The operation of any treatment works shall be under the supervision of an operator on the first day of operation of the treatment works and continually thereaf ter in accordance with paragraph 5.A above. The cperator shall meet the requirements of the Department of Environmental Protection of the State of New Jersey pursuant to the provisions of N.J.S.A. 58:11-64 g _seg and amendments thereto. The name of the proposed operator shall be submitted to this Department in order that his qualifications may be determined prior to inititating operation of the proposed treatment works.

- 6. Permit Actions .

A. This permit may be modified, suspended, revoked and reissued, or terminated for cause. The

- filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or a notifica; ion of planned changes or anticipated noncompliance, does not stay e.ny permit condition.

B. Causes for modification, revocation and reissuance, and suspension are set forth in N.J.A.C.

7:14A-2.12 et sg .

C. The following are causes for terminating or modifying a permit during its term, or for derying a permit renewal applications (1) Noncompliance by the permittee with any condition of the permit; (2) Failure to pay applicable fees (N.J.A.C. 7:14A-1.8), including the annual NJPDES permit fee which. bas been assessed by the New Jersey Department of Environmental Protection (NJDEP, hereinafter referred to as the Departmect);

(3) The permittee's failure in the application or during the permit issnance process of a National Pollutant Discharge Elimination System (NPDES), Discharge Allocation Certificate (DAC), IUPDIS, Treatment Works Approval (TWA) or Construct and Operate permit to disclose fully all relevant facts, or the permittee's sisrepresentation of any permit condition; (4) A determination that the permitted activity endangers human health or the environment and can only be regulated to acceptable levels by permit modification or termination; (5) When there is a change in any condition that requires either a temporary or a permanent reduction or elimination of any discharge controlled by the permit (for example, plant closure or termination of discharge by connection to a Domestic Treatment Works (DTW);

(6) The nonconformance of the discharge with any applicable facility, basin or areawide plans; 9

.- 1 Part I , ,

Page 4 of 16 (7) If such permit is inconsistent with any duly promulgated effluent limitation, permit, regulation, statute, or other applicable state or federal law; or (8)

If a toxic effluent standard or prohibition is established pursuant to New Jersey Water Pollution Control Act H.J.S.A. 58:10A-1 g seg. or the regulations adopted pursuant to it, for a toxic pollutant which is present in the discharge, and such is more strincent than any limitation for such pollutant in this permit, this permit shall be revised or modified in accordance with the toxic ef fluent standard or prohibition and the permittee so notified of the revision or modification and date of required compliance.

7. Prorerty Rights, Liability, and Other Laws A.

This permit does not convey and property rights of any sort or any exclusive privileges.

B.

Nothing in this permit shall be deemed to preclude the institution of any legal action nor relieve the permittee from any responsibilities or penalties to which the permittee is or may te subject to under an- ; federal, state or local law or regulation.

C.

Nothing in this permit shall te construed to exempt the permittee from complying with the rules, regulations, policies, and/or laws lodged in any agency or subdivision in this State having legal jurisdiction.

8. Duty to Provide Information A.

The permittee shall furnish to the Director, Division of Water Fesources, NJDEP, (hereinafter referred to as the Director),within a reasonable time, any information which the Director may request to determine whether cause exists for modifying, suspending, revoking and reissuing, or terminating this permit, er to determice compliance with this permit. The permittee shall also

. furnish to the Director, upon request, copies of records required to be kept by this permit.

B.

Where the permittee becomes aware that he has failed to submit any relevant facts in a permit application, or has submitted incorrect information in a permit application or in any report to the Director, the permittee shall promptly submit such facts or information.

9 Inspection and Entry A.

The permittee shall allow the Regional Administrator of the United States Environmental Protection Agency (USEFA), the Department, or any authorized representative (s) , upon the presentation of credentials and other documents as may be requi' red by law, to:

(1)

Enter upon the permittee's premises where a discharge source is or might be located or in  !

which monitoring equipment or records required by a permit are kept, for purposes of inspection, sampling, copying or photographing. Photography shall be allowed only as related to the discharge; i (2)

Have access to and copy, at reasonable tires, any records that must be kept under the conditions of this permit; (3) Inspect, at reasonable times, any facilities, equipment (includicq monitoring and control equipment), practices, or operations regulated or required under this permit; and (4)

Sample or monitor, at reasonable times, for the purpose of assuring permit corp 11ance or as otherwise authorized by the State Act, any substances or parameters at any location. This shall include, but not be limited to, the drilling or installation of monitoring wells for

• Part I Pagt 5 of 16 the purpose of obtaining samples of ground water, soil and vegetation and seasuring ground water elevations.

B. Any refusal by the permittee, facility land owner (s), facility lessee (s), their agents, or any other person (s) with legal authority, to allow entry to the authorized representatives of the IUDEP and/or USEPA shall constitute grounds for suspension, revocation and/or termination of this permit.

C. By acceptance of this permit, the permittee hereby agrees, consents and authorizes the representatives of the IUDEP and/or USEPA to present a copy of this permit to any municipal or state police officer having jurisdiction over the premises occupied by the permittee in order to have said officer effectuate compliance with the right of entry, should the permittee at any time refuse to allow entry to said inspectors.

D. By acceptance of this permit, the permittee waives all rights to prevent inspections by authorised representatives of the IUDEP and/or USEPA to determine the extent of compliance with any and all conditions of this permit and agrees not to, in any ma mer, seek to charge said representatives with the civil or criminal act of trespass wher they enter the premises occupied by the permittee in accordance with the provisions of this authorization as set forth hereinabove. ,

10. Ground unter Monitoring Wells The permittee shall install and maintain ground water monitoring wells if required by this permit at locaticos and according to specifications provided by the Department. All permit required monitoring wells shall be installed within 30 days of the Effective Date of the Permit. The monitoring wells shall provide turbidity-free water at a minimum rate of two gallons per minute or what the formation will yield with a proper 1v installed and developed ground water monitoring well.

then a moottoring well cannot be used for the purpose of sample collection or ground water level measurements, the permittee shall replace the well at his own expense within 30 days of the missed

. sampling and/or measurement date. Said unuseable wells shall be sealed, also at the permittee's own p expense, in accordance with Department well sealing specifications within the same 30 day period in

whidt the well is replaced. Monitoring wells as required in this permit shall be considered as a

monitoring device, which are required to be maintained under the provisions of the New Jersey Water Pollution Control Act N.J.S.A. 58

10A-10(f).

All monitoring wells must be installed by a New Jersey licensed well driller. The elevation to the soarest hundredth of a foot of the top of each well casing shall be established by a New Jersey l licensed land surveyor within 30 days of the installation of the monitoring wells. The elevation established shall be in relation to the New Jersey geodetic control datus. Ground water monitoring wells and all point source discharges to ground water shall be located by horizontal control (latitude and loogitude) using third order work, class II specification and by vertical control (elevation) using third order work. Within 30 days of the installation date of the monitor well, the permittee shall submit to the Department completed " Ground Water Monitoring Well Certifications -

? Fo%ss A and B for each well required to be sampled by the permit. Within 60 days of the. Effective l

Date of the Permit, the permittee shall submit to the Department a plot plan of the facility showing the location of all discharges and the ground water manitoring well locations. The scale of the plot plan shall be at least one inch equals fifty (50) feet.

! Each groucd water monitoring well casing shall have permanently affixed to it a monitoring well mmber to be assigned by the Department, elevation of the top of the well casing, elevation of the j top of the well casing above the ground level and latitude and longitude of the monitoring well.

i I

I i'

L n n

Prrt I , .

Page 6 of 16

11. ftraitorirq and Pecords A.

Sanples and neasmments take for the purpose of umitonig shall be representative of the emitored activity.

B.

'Ihe State Act provides that any perscn dio falsifies, tapers with, or knrwirv]ly re: tic =

irmacurate any nmitering device or rethod required to be maintained under this pemit shall, uptn crxivictico, be punished by a fine of no nore than $10,000 gr violatim, or by rrpriarriert for not nore than 6 rrnths per violaticn, or by both. , 'Ihis is specifically intended to include, but not be limited to, grn:nd water umitoring wils and lysiteters. .

C. 1

'Ihe a[plicant shall perform all analyses in accordance with the aralytical test procedures  ;

a[ proved under 40 GR Part 136. Mere no approved test prrw+re is available, the aIplicant nust indicate a suitable analytical prrxxx'ure and cust prtuide the Department with literature referentes or a detailed descriptim of the prrn%. 'Ibe Departrent nust aIprove the test Irrnere before it is used. 'Ihe laboratory perfomug the analyses for crrpliance with this permit nust be asproved ancycr wrtifial by the Departrent for the analysis of those specific i=.duis. Informaticn atricerning laboratory approval and/or mrtificaticn may be cbtained frm:

New Jersey Department of Divirtrrental Protectim -

Office of Quality Assurance CN 409 Trentcn, New Jersey 08625 (609) 292-3950 D. 'Ihe permittee shall retain re 2ds of all emitoring inferration, includ2ng all calibraticn and naintenance records and all original strip chart recordings for cmtinuous nmitanng irstrtrentaticn, ocpies of all reports required by this permit, and remrds of all data used to crrplete the applicaticn for this permit, for a pricd of at least 5 years fztn the date of the saple, measurcrrrit, report or applicaticn. 'Ihis period may be exteided by rtquest of the Departnent at any tine.

E. Records of amitoring informaticn shall incitder (1) 'Ihe date, exact place, and tine of sanplire er measurunents; (2) 'Ihe indivicbal(s) who Wiua the sanpling or neasurarents; I

(3) '1he date(s) analyses were performed; (4) 'Ihe indivichal(s) Mio Wivuni the analyses;

('i) 'the analytical tedniques or nethods usal; and (6) 'Ihe results of such analyms.

F. Ptx11torirg results shall be reprted cm a Discharge Pt:nitoring itTort (DF) and/or cn the Departrmt's itx11toring Reprt Ibrm (MRF); or, W1ere there forms cb not apply, in another format a[prozed by the Dcpartment.

e .

Part I Psge 7 of 16 G. If the permittee monitors any pollutant more frequently than required by the permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted in the DMR, MRF, or other approved format.

H. Calculations for all limitations which require averaging of seasurements shall utilize an arithmetic mean unless otherwise specified by the Department in the permit.

I. Discharge Monitoring Reports (1) Monitoring results shall be summarized and reported on the appropriate Monitoring Report Forms following the completed reporting period. Signed copies of these, and all other reports required herein, shall be submitted to the following address:

Water Quality Management Division of Water Resources CN 029 Trenton, New Jersey 08625 ATIN: Monitoring Reports (2) If a contract laboratory is utilized, the permittee shall submit the name and address of the laboratory and the parameters analyzed at the time it submits its monitoring reports ~

(See Section 11.E. above). Any change in the contract laboratory being used or the parameters analyzed shall be reported prior to or together with the monitoring report covering the period during which the change was made.

J. Monitoring Reports. Monitoring results shall be reported at the intervals and starting date specified elsewhere in this permit.

K. Compliance Schedules. Reports of compliance or noncompliance with, or any progress reports on, interia and final requirements contained in any empliance schedule of this permit shall be submitted no later than 14 days following each schedule date.

12. Signatory Requirement A. Signature Requirements. All permit applications, except those submitted for Class II wells for a UIC discharge (see paragraph B) shall be signed as follows:

(1) For a corporation, by a principal executive of ficer of at least the level of vice president; (2) For a partnership or sole proprietorship, by a general partner or the proprietor, respectively; or (3) For a municipality, state, federal or other public agency, by either a principal executive officer or ranking elected official.

B. Reports. All reports required by permits, other information requested by the Department and all permit applications submitted for Class II wells under N.J.A.C. 7:14A-5.8 shall be signed by a person described in paragraph A of this section or by a duly authorized representative coly ifs (1) The authorisation is made in writing by a person described in paragraph A of this section;

Part I, .

Prg7 8 of 16 (2)

The authorization specifies either an individual or a position having responsibility for the overall operation of the regulated f acility or activity, such as a position of plant manager, operator of a well or well field, superinten hot or person of equivalent responsibility; and (3) The written authorization is submitted to the Dapartment.

C. Changes to Authorization.

If an authorization under paragraph B of this section is no longer accurate because a dif ferent individual or position has responsibility for the overall operation of the f acility, a new authorization satisfying the requirecents of paragraph B of this section shall be submitted to the Department prior to or together with any reports, information, cr applications to be signed by an authorized representative.

D.

Certification (N.J. A.C. 7:14A-2.4(d)). Any person signing any document under paragraph A or B of.this section shall make the following certification: "I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document and all attachments and that, based on my inquiry of those individuals immediately responsible for obtaining the information, I believe the submitted information is true, accuratv, and complete.

I an aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment."

E. yalse Statements.

Any person who knowingly makes a false statement, representation, or certification in any application, record, or other document filed or required to be maintained under the State Act shall upon conviction, be subject to a fine of not more than $10,000.00 or by imprisonment for not more than 6 months or by both.

13. Peporting Changes and Violations A. Planned Changes.

The permittee shall give notice to the Department as soon as possible of any planned physical alterations or additions to the permitted facility. The permittee shall comply with N.J.A.C. 7:14A-12.1 ej s_og. which requires approval for building, installing, modifying, or operating treatment works. (NOTE: Sewer Dttensions require such an approval. A connection of a single building through which less than 2000 gpd flows by gravity through a single lateral is exempt from the requirement to obtain the approval of this Department.). Construction of a sewer extension without this Department's approval will be a violation of this permit.

B. Anticipated Noncompliance.

The permittee shall give reasonable advance notico to the Department of any planned changes in the permitted facility cr activity which may result in noncompliance with permit requirements. *

14. Reporting Noncompliance A.

The permittee shall report any coccompliance which may endanger health or the environment. The k permittee shall provide the Department with the following information:

(1) A description of the discharge; (2) Steps being taken to determine the cause of noncompliance; (3) Steps being taken to reduce and eliminate the concomplying discharge; (4) The period of noncompliance, including exact' dates and times. If the noncompliance has not been corrected, the anticipated time when the discharge will return to compliance;

~, ,

• e Part I Pag? 9 of 16 (5) n e cause of the noncompliance; and (6) Steps being taken to reduce, eliminate, and prevent reoccurence of the noncomplying discharge.

B. Tne permittee shall orally provide the information in paragraphs A.(1) through (3) to the DEP Hotline (609) 292-7172 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> f r om the time the permittee becomes aware' of the circumstances.

(. . The permittee shall orally provide the inforaation in paragraphs A.(4) through (5) to the DEP Hotline within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the time the permittee becomes aware of the circumstances.

D. A written submission shall also be provided within 5 days of the time the permittee becomes aware of the circumstances. The written submission shall contain the information in A.(1) through (6).

E. Other Noncespliana. The permittee shall report all instances of noncompliance not reported under paragraphs 11.J, 11.K, 13.A, and 14.A through D at the time monitoring reports are submitted. The reports shall contain the information required in the written submission listed in paragraph 14.D.

F. The following shall be reported to the Department in accordance with paragraphs 14.A through D:

(1) In the case of any discharge subject to any applicable toxic pollutant effluent standard under Section 307(a) of the Federal Act or under Section 6 of the State Act the information required by paragraphs 14.A(1) through (3) regarding a violation of such standard shall be provided to the Department within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the time the permittee becomes aware of the circumstances. The information required by paragraphs 14.A(4) through (6) shall be pro-vided to the Department within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time the permittee becomes aware of the cirem stances. Where the information is providad orally, a written submission covering these points must be provided within five working days of the time the permittee becomes aware of the circumstances covered by this paragraph.

1- (2) In the case of other discharges which could constitute a threat to human health, welfare, or the environment, including but not limited to, discharge of pollutants designated under Section 311 of the Federal Act, under Section 6 of the State Act, under the " Spill Compensation and Control Act", N.J.S.A. 58:10-23.11 et seg., or under the " Safe Drinking Water Act", N.J.S.A. 58:12A-1 g 3 ., the information required by paragraph 14. A (1) through (3) shall be provided to the Department within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the time the permittee becomes aware of the circumstances. The information required by paragraphs 14.A(4) through (6) shall be provided to the Department within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time the permittee becomes aware of the circumstances. Where the information is provided orally, a written submission covering these points must be provided within five working days of the time the permittee becomes aware of the circumstances covered by this paragraph.

(3) The information required in paragraphs 14. A(1) through (3) shall be provided to the Department within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> where a discharge described under paragraphs 14.F(1) or (2) is located upstream of a potable water intake or well field. The information required by paragraphs 14.A(4) through (6) shall be provided to the Department within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If this information is provided orally, a written submission covering these points must be provided within five days of the time the permittee becomes aware of the discharge.

(4) Any bypass which violates any effluent limitations in the permit shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless paragraphs 14.F(1) through (3) are applicable. (See Section 15.)

f

P rt I e

• P g2 10 of 16 (5) Any upset which violates any ef fluent limitation in the permit shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless paragraphs 14.F(1) through (3) are applicable. (See Section 16.)

(6) Violation of a maximum daily discharge limitation for any of the pollutants listed by the Department in the permit shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless paragraphs 14.F(1) through (3) are applicable (See N.J.A.C. 7:14A-3.13(a)7.1.

15. Bypars A. Bypass not exceeding limitations. The permittee may allow any bypass to occur which does not cause effluent limitations to be exceeded, but only if it is also for essential maintenance to assure efficient operation. These bypasses are not subject to the provisions of paragraphs B.

and C. of this section.

B. Notice (1) Anticipated Bypass. If the permittee knows in advance of the need for a bypass, he shall submit prior notice, if possible, at least thirty (30) days before the date of the bypass.

(2) Unanticipated Bypass. The permittee shall submit notice of an unanticipated bypass as ,

required in paragraph 14.F.(4).

C. Prohibition of Bypass (1) Bypass is prohibited, and the Department may take enforcement action against a permittee for bypass unless:

a. Bypass was unavoidable to prevent loss of life, personal injury, or severe property damage;

b. There were no feasible alternatives to the bypass, such as the use of auxiliary treatment facilities, retention of untreated wastes, or maintenance during normal periods of equipment downtime. This condition is not satisfied if the permittee could have installed adequate backup equipment to prevent a bypass which occurred during normal periods of equipment downtime or preventive maintenance; and

c. The permittee submitted notices as required under paragraph B of this section.

(2) The Department may approve an anticipated bypass, af ter considering its adverse ef fects, if the Department determines that it will meet the three conditions listed above in paragraph C.(1) of this section.

16. Upset A. Effect of An Upset. An upset may constitute an af firmative defense to an action brought for noncompliance with such technology-based permit effluent limitations if the requirements of paragraph B. of this section are met. Where no determination was made during administrative review of claims that noncompliance was caused by upset, and there has been no Departmental action for noncompliance, the lack of such determination is final administrative action subject to judicial review.

B. Conditions Necessary for A Demonstration of Upset. A permittee who wishes to establish the affirmative defense of upset shall demonstrate, th:.ough properly signed, contemporaneous operating logs, er other relevant evidence that:

I

~. .

hrt I PM 2 11 of 16 (1) An upset occurred and that the permittee can identify the specific cause(s) of the upset; (2) The permitted f acility was at the time being properly operated; (3) The permittee submitted notice of the upset as required in paragraph 14.F.(5); and (4) The permittee complied with any remedial measures required under Section 4 above.

C. Purden of Proof. In any enforcement proceeding the permittee seeking to establish the occurrence of an upset has the burden of proof.

17. g ccency Plan (DSW and DGW permits only)

A. The permittee shall develop, submit, and implement an Emergency Plan report prepared in accordance with 1.J.A.C 7:14A-3.12 (b) unless exempted pursuant to N.J.A.C. 7:14A-3.12(e). If not previously submitted to and approved by NJDEP, the Daergency Plan (or a request for exemption) must be submitted within six (6) months of the effective date of the pernit unless otherwise required by N.J. A.C. 7:14A-3.12(a).

B. Liability (1) Submission of an Emergency Plan pursuant to this section shall not exempt a permittee from liability for violations arising from an emergency situation. A permittee shall take all necessary actions to mitigate the damage to the waters of the State arising frca an emergency situation. Such actions shall not be limited by the emergency operating plan and the manual of procedures.

(2) Exemption from development of ha Beergency Plan under this section does not exempt the permittee from liability for viola'. ions arising from an emergency situation. Such permittee shall take all necessary acticns to mitigate the damage to the waters of the State arising from an emergency situation.

C. Violations yailure to submit an emergency plan in compliance with paragraph A. of this section and failure to implement the energency plan shall each constitute a violation of this permit.

18. Residuals Management A. Collected grit and screenings, scums, sand bed sands, slurries, and sludges, and all other solids from the treatment process shall be disposed of in such a macner as to prevent such materials from entering the ground and/or surface waters of the state except in accordance with a NJPDES permit. If for any reason such materials are placed in the water or en the lands where they may cause pollutants to enter the ground and/or surface waters of the State, the following information shall be reported to the Division of Water Resources Enforcement Element together with the monitoring data required in Part I, Section 11.I.:

(1) Dates of occurrence; (2) A description of the noncomplying discharge (nature and volume);

(3) Cause of noncompliance; (4) Steps taken to reduce and eliminate the noncomplying discharge; and f

. +

P:rt I' Page 12 cf 16 (5) Steps taken to prevent recurrence of the condition of noncompliance.

B. The permittee shall not be permitted to store sludge on-site beyond the capacity of the structural treatment and storage componenets of the treatment facility, except in accordance with a NJPDES Dnergency On-site storage Persit. Nor shall the permittee be permitted to store sludge on-site in any manner which is not in accordance with Solid Waste Management Rules, N.J.A.C. 7:26-1 g sg. Any violations must be reported by the permittee to the Division of Water Resources Enforcement Element within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

C. The permittee shall comply with the Sludge Quality Assurance Regulations (N.J..A.C. 7:14-4.1 et

,sg.). Where quality information is required by these regulations analyses must reflect the quality of the final sludge product of {hich the permittee must dispose.

D. The permittee shall dispose of sludge from this facility in compliance with the New Jersey Solid Waste Management Act N.J.S.A. 13:1E-1 g g., which requires conformance with Statewide and District Sludge Management Plans, and prohibits the disposal of municipal sewage sludge in ~

landfills. The permittee shall also comply with all applicable rules and regulations promulgated pursuant to the Federal Resource Conservation and Recovery Act governing the treatment, storage and disposal of hazardous waste.

E. The permittee shall at all times have on file with the Department proof of proper disposal at a facility duly licensed and permitted by the State to dispose of sludge. To satisfy this re-quirement the permittee shall submit proof of ownership or contractual arrangement with a permitted facility for the composting, land application, thermal reduction, or other approved method of sludge disposal.

Where such permitted sludge disposal does not extend the full ters of this permit, the permittee shall submit similar proof of new permitted disposal arrangements which shall become effective no later than the expiration date of previous arrangements. All such proofs of disposal site' must be submitted to the Bureau of Permits Administration in duplicate to:

Chief Bureau of Permits Administration CN-029 '

Trenton, N.J. 08625 ATTN: Sludge Disposal Site Proof F. By issuance of this permit the Department hereby gives the permittee notice that the permittee is bound by the New Jersey Pollutant Discharge Elimination System regulations regarding proper sludge disposal (Section 25 (a)13.).

t

_e .

' s-G. The pemitte st.11 comply with the Rules and Regulations for the Statewt , gemen.t Septace Disposal (N.J.A.C. 7:14-5.1 g sg .).

H. The permittee shall conform with the requirements under Section 405 of the Federal Act governing the disposal of sewage sludge from publicly cwned treat =ent v e - aM with Sections 4 and 6 of the State Act.

19. Discharge Permitted The permittee shall discharge to surface waters, land or ground waters of the State, directly or indirectly, only as authorized herein and consistent with the terms and conditions of this permit.

20. Operation Restrictions The operation of a vaste treatment or disposal facility shall at no time creates (1) a direct discharge to surf ace waters of the State, except as authorized by NJDEP; (2) a persistent standing or ponded condition for water or waste on the permittee's property except as specifically authorized by-this permit, or (3) any standing or ponded condition for water or waste on adjacent properties unless ,

these activities are specifically included within the permit.

21. 011 and Hasardous Substance Liability The imposition of responsibilities upon, or the institution of any legal action against the permittee under Section 311 of the Federal Act shall be in conformance with regulations promulgated pursuant to Section 311 of the Federal Act governing the applicability of Section 311 to discharges from facilities with NPDES permits.

22. Reopener Clause for Toxic Effluent Limitations Notwithstanding any other condition of this permit, if any applicable toxic ef fluent standards, limitation or prohibition (including any schedule of compliance specified in such effluent standard or prohibition) is promulgated under Sections 301(b)(2)(C) and (D), 304(b)(2), and 307(a)(2) of the Federal Clean Water- Act or Sections 4 or 6 of the State Act for a toxic pollutant and that effluent standard, limitation, or prohibition is more stringent than any limitation on the pollutant in the permit (or controls a pollutant not limited in the permit), this permit shall be promptly modified or revoked and reissued to confore to that effluent standard, limitation or prohibition.

23. Availability of Information

4. IATPDES permits, effluent data, and information required by NJPDES application forms provided by the Regional Administrator or Director (including information submitted on the forms themselves r

. e Part I , ,

Piga 14 of 16 and any attachments used to supply information required by the forms) shall be available for public inspection at the offices of the Director.

B. In addition to the information set forth in paragraph A., any other information submitted to EFA and/or the Department in accordance with the conditions of this permit shall be made available to the public without further notice unless a claim of business confidentiality is asserted at the time of submission in accordance with the procedures in 40 CFR Part 2 (Public Information) and/or Subchapter 11 of the " Regulations Concerning the New Jersey Pollutant Discharge Elimination Systen." ,

C. If a claim of confidentiality is made for information other than that entrerated in paragraph A., the information shall be treated by the Department in accordance with the procedures in N.J.A.C. 7:14A-11.1 g3 Only information determined to be confidential under those procedures shall not be made available by NJDEP for public inspection.

24. Effective Date of Fermit A. This permit shall become effective in its entirety on the date indicated (Effective Date) on the first page of this permit unless a request for an adjudicatory hearing is granted pursuant to the provisions of N.J.A.C. 7:14A-8.11 et ,s_eg.

B. For purposes of judicial review, final agency action on a permit does not occur unless and until a party has enhausted its administrative remedies under N.J. A.C. 7:14A-8.9 et seg. Any party which neglects or fai h to seek such review thereby waives its opportunity to exhaust available agency reredies.

25. Transfer of Permit A. This permit is rot transferable to any person except af ter notice to the Department. The Department say require modification, revocation, or revocation and reissuance of the permit to change the name of tre permittee and incorporate such other requirements as may be necessary under the appropriate Act. (See N.J. A.C. 7:14A-2.12; in some cases, modification or revocation and reissuance is mandatory).

B. Transfer by Modification. Except as provided in paragraph (C) of this section, a permit may be transferred by the permittee to a new owner or operator only if the permit has been modified or revoked and reissued (under Section 2.12(c)1.ii.) or a minor modification made (under Section 2.14(a)4. of the NJPDES Regulations), to identify the new permittee and incorporate such other requirements as may be necessary under the State and Federal Acts.

C. Automatic Transfers. As an alternative to transfers under paragraph (B) of this section, any I NJPDES permit, except a UIC permit for a well injecting hazardous vaste, may be automatically transferred to a new permittee if t (1) The current permittee notified the Department in writing by certified mail of the proposed transfer as follows:

a. Where production levels, products produced, rates of discharge, and wastewater characteristics will remain unchanged, the followirg information shall be submitted at least 90 days prior to a proposed transfer date:

(1) Name and address of current facility; (2) Name and address of rew owners;

c e .

Ptrt I Par 15 of 16 (3) NJPDES permit number;

_(4) Names of the new principal persons responsible; (5) Names of persons upon when legal process can be served; and (6) A notarized stetement signed by the new principal officer stating that he has read the NJPDES permit and agrees to abide by all the conditions of the permit and that the production - levels, products produced, rates of discharge, and wastewater characteristics will remain unchanged.

b. Where there will be a change in production levels, products produced, rates of discharge, or wastewater characteristics, the information required in paragraph 25.C(1)(alabove shall be submitted at least 180 days prior to a proposed transfer date.

(2) The current permittee shall include in the notice of proposed transfer a written agreement between the existing and new permittee which includes a specific date for transfer of permit responsibility, coverage, and liability between the parties. In the case of a UIC permit, the notice shall demonstrate that the financial responsibility requirements of Section 5.10(a)7. of the IUPDES Degulations will be met by the new permittee; .

(3) The Department does not notify the existing permittee and the proposed new permittee, within thirty (30) days of receipt of notice of proposed transfer, of an intent to modify, revoke or revoke and reissue the permit or, for a discharge to surface water (DSN), require a DAC. A modification under this paragraph may also be a minor modification under Section ,

2.14 of the IUPDES Regulations. If such notim is not received, the transfer is effective on the date specified in the agreement mentioned in paragraph 25.C(2) of this section; and (4) menever the regulated discharge has ceased prior to the proposed permit transfer, any  !

compliance schedule shall not be automatically reinstated but shall be subject to revision or complete withdrawal if circumstances leading to its imposition have changed.

26. Severability The provisioes of this permit are severable, and if any prevision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other cifcumstances, and the remainder of this permit, shall not be af fected thereby.

27. Star of Conditions, N.J.A.C. 7:14-8.10 A request for an adjudicatory hearing shall not automatically result in a stay of t'he conditions of this permit.

28. Definitions ,

A. Unless otherwise stated, all terms shall be as defined in the " Regulations Concerning the New dersey Pollutant Discharge Elimination S 1 sten", N.J.A.C. 7:14A-1 el m.

I (1) " Aliquot" means a sample of specified volume used to make up a total composite sample.

l (2) "Bypas s" means the intentional diversion of wastes from any portion of a treatment l facility. I n E

Part I '

Paga 16 of 16 (3) " Composite" means a combination of individual (or continuously taken) sampler (aliquets) of at least 100 milliliters, collected at. periodic intervals ever the entire discharge day.

~

The composite must be flow proportional; either the time interval between each aliquot or the volume of each aliquot must be proportior.a1 to either the stream flow at the time of sampling or the total stream flow since the collection of the previous aliquot. Aliquets may be collected sentially or automatically. For, a continuous discharge, a minipua of 24 aliquots (at hourly intervals) shall be collected and combined to constitute a 24-hour composite sample. For intermittent discharges of more than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> duration, aliquots shall be taken at a minimum of 30-minute intervals. For intermittent discharges of less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> duration, aliquots shall be taken at a minimum of 15-sinute intervals. '.

(4) *EDP" means Effective Date of Permit. t (5) " Grab" means an individual sample of at least 100 milliliters collected over a period not exceeding 15 minutes. ,

(6) " Monthly" means one day each month (the same day each month) and a normal operating day (e.g., the 2nd Tuesday of each month).

i (7) ' " Multiple Grab Composite" - means a combination of individual samples (aliquots) collected

• at a specified frequency over a specified time period. . Each aliquot must be collected in a .

glass vial with septus cap, filled to the top leaving to air bubbles, and iced until delivered for analysis. Each aliquot shall be analysed individually. The recorded value will be flow proportioned average of the individual analyses for the specific time period.

(8) " Upset" means . an exceptional incident in which there is unintentional and temporary noncompliance with technology-based permit offluent limitations because of factors beyond the reasonable control of the permittee. An upset does not ir.clude noncompliance to the l

extent caused by operational error, inprcperly designed treatment facilities, inadequate treatment facilities, lack of preventative maintenance, or careless or improper operation.

(9) " Weekly" means every seventh day (the same day each week) and a rormal operating day.

29. ~Arrual Permit Tee, N.J.A.C. 7:14A-1.8 The permittee shall pay the annual NJPDES permit fee which has been assessed by the Department.

WQM122-A/CMafen ,

l r

I t

. . _ _ - - . - - ~ , _ _ . , , _ _ _ - ~ . , _ - . , , . , - . _ . . - , , . _ _ _ _ . _ . . - . , , _ _ . _ , . . . , . - ~

~, ,

a i

Port II - B/C Page 1 of 1 ADDITIONAL ENERAL CONDITIONS FOR KTPDIS/DSN PEletITS FRGt INDUSTRIAL /COBOERCIAL Ale /OR THERMAL DISCHARGES

1. The following additional conditions applicable to specified categories of DSN permits in accordance with N.J.A.C. 7:14A-3.11, in addition to those set forth in N.J.A.C. 7:14A-2.5, 3.10 and 3.12, hereby apply to all DEN permits within the categories specified below:

Ekisting manuf acturing, commercial, mining, and silvicultural dischargers and research facilities. In additico to the reporting requirements under Section 2.5(a)12 and Sectico 3.10 of N.J.A.C. 7:14A-1 el gg. all existing annufacturing, commercial, mining, and silvicultural dischargers and research facilities must notify the Department as soon as they know or have reason to believe A. That any activity has occurred or will occur which would result in the discharge of any toxic pollutant which is not limited la the permit, if that discharge will exceed the highest of the following "netificatico levels."

(1) One hundred micrograms per liter (100 mg/1);

(2) Dre hundred micrograms per liter (200 ug/1) for aerolein and acrylonitrile; five hundred atcrograms per liter (500 ug/1) for 2,4-dinitrophenol and for 2-eathyl-4, 6-dinitrophenol; and one milligran per liter (1 ag/1) for antisocy; (3) Five (5) times the nazimum concentration value reported for the pollutant in the permit applicatico in accordance with N.J.A.C. 7:14A-10.3(a)9. or 10.3(a)12; or (4) The level established by the Department in accordance with N.J.A.C. 7:14A-3.13(a)6.

B. That they (escept for research facilities) have begun or expect to begin to use or manufacture as an intermediate or final product or byproduct any tonic pollutant which was not reported in the permit applicatico under N.J.A.C. 7:14A-3.2 and 10.3(a)11.

2. If the permittee is required by this permit to aceitor for 011 and Grease and/or Petroleum Hydrocarbons, samples shall be collected and analysed in accordance with the 011 and Grease Effluent Limitations, N.J.A.C. 7:14A-14.1 ej _sg.

3. Submission of Monitorine Reports Nooitoring results for each reporting period shall be summarized and reported on the appropriate Noettoring Report Forms and shall be submitted postmarked no later than the 25th day of the month following the completed repcrting period.

i l

i l

1 f

Pcza 1 of 7 pages Parmit No. NJ0005622 ,

Part III - B/C

~~

1.A EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning EDP and lasting through .EDP + 5 years the permittee is authorized to discharge from outfall(s) serial number (s) 481, 482, 483, 484, 485, and 486.

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

' ~

Effluent Characteristic Discharge Limitations Monitoring Requireme kgs/ day (1bs/ day) other units (specified)

Measurement S.

Avz. Monthly Max. Daily Avg. Monthly Max. Daily Frequency -

Flow-m 3/ Day (MCD) N/A N/A N/A N/A Continuous -- i Temperature, Influent 0F(OC) N/A N/A N/A N/A Continuous -

Temperature, Efflue C N/A N/A N/A 110(43.3) Continuous -

Temperature, Diff.F(O gtc OF(O

)* )*

N/A N/A N/A 27.5(15.3) Calculated --

Heat. Facility (mIU/hr)* N/A N/A N/A 30, 600 Calculated --- i Total Suspended Solids (ag/l ** N/A N/A 30 45** Monthly Gra Petroleum Hydrocarbons (og/1 N/A N/A N/A 10 Month 1y Gra j Chemical Oxygen Demand (ag/l *** N/A N/A N/A 50 Monthly Gra Chlorine-Free Available N/A N/A 0.2 0.5 Continuous during per (mg/1)**** Chlorination Chlorine-Total Residual N/A N/A N/A 0.2 **** GrM (ag/1)****

• See Part IV, Section 1, I and J for clarification of thermal limitations and DMR reporting methods.

• • Total Suspended Solids shall not exceed 45 mg/l on a 7-day average. The limitations are net values. ,

• • • If one year of monitoring data indicates no net addition of C00, the pemittee may request deletion

, of the monitoring requirement. Monitoring results shall be on a net basis.

• • • • TRC samples shall. be taken once during each period of chlorination. As indicated in Part IV, bection 1, F and 3.B.

The pH shall not be less than 6.0 standard units nor greater than 9.0 standard' units and shall be monitored weekly using grab samples.

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): At the outfalls of discharges 481, 482, 483, 484, 485, and 486.

Page 2 of 7 pages -

Parmit No. NJ0005622 i

Pcrt III - B/C -

, }

s l.B . EFFIEENT LIMITATIONS AND MONITORING RNQUIREMENTS During the period beginning EDP and lasting through EDP: 4 5 years i

i the permittee is authorized to discharge from outfall(s) serial number (s) 437 l .

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

Monitoring Requirements Effluent Characteristic Discharas Limitations kss/ day'(ibs/ day) other units (specified)

Measurement Sample Avg. Monthly Max. Daily, Frequency *

• Type Avg. Monthly Max. Daily i

j Flow-m3/ Day (MGD) N/A NM g yA my  %

Temperature-Ef f. CF (*C) N/A N/A N/A 86(30) Monthly **** Grab i

l Petroleum Hydrocarbons N/A N/A 10 -

15 Monthly ***** . Mult Grab i Pel -

(eg/1) i; Monthly C ab 3

,IE*" N/A N/A N/A 100

]

Total Suspended Solids (ag/1) N/A N/A 30,45*

• 100 Monthly Grab ,

h 1'

• Total Suspended Solids aball not exceed 45mg/l as a 7 day average. , >

• • During' the first precipitation event of the month which causes a discharge during working hours' and which,is preceded by a minimum dry. period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

~

• • • Upon written request from the permittee this limit may be changed to 50mg/l of Total Organic Carbon.

• • • • Temperature shall be monitored when boiler blowdown is discharged.

The per-

• • • • • The permittee shall take samples 15, 30 and 45 minutes after the onset of the discharge.

I

~

mittee shall analyze each sample. individually and report a maximum value for the samples, i

The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be

}

monitored monthly using grab samples.**

l 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 i location (s): at the outfall of discharge 487.

e l

a

+

Page 3 of 7 pages Permit No. NJ0005622 PART III - B/C

] 1.C. EFFLUENT LIMITATIONS AND MONITORING nmOUIREMENTS i.

During the period beginning and lasting through the permittee is authorized to discharge sanitary wastewater from outfall(s) serial number (s):487A.

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

! EFFLUENT CHARACTERISTIC'

{

DISCHARGE LIMITATIONS MONITORING REQUIREMENTS kgs/ day (lbs/ day) other units (specified)

} Avg. Monthly Measurement Sample Max.-Daily Avg. Monthly Max. Daily Frequency Type Flow-m3/ Day (MGD) N/A N/A 0.2 N/A 4

BODS kg/ day (lbs/ day) Daily Grab 0.97(2.14) (1) N/A N/A N/A Monthly Grab BOD 5 (%) 87.5 (as a minian) N/A  !

Total Suspended Solids N/A N/A Monthly Calculatec '

(mg/1) N/A N/A 30,45(2) 100 Monthly Composite F.Coli(MPN/100 ml) N/A N/A .200(3) 400(3) Monthly

! Oil and Grease (mg/1) N/A N/A N/A 10 Grab

, Monthly Grab 1

(1) Based upon 87.5% reduction and FSOD of 3 lbs/ day, see Part IV.K for details.

(2) Total Suspended Solids shall not exceed 45 mg/l as a 7-day average.

(3)This average shall be the geometric mean over.a 30 consecutive day period and the maximum shall be the geometric mean over a 7 consecutive day period.

The pH shall not be less'than 6.0 standards units nor greater than 9.0 standard units and shall be monitoried Monthly using grab samples.

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

Semples taken in compliance with the monitoring requirements specified above shall be taken at the following location (s) : At the outfall of discharge 487A.

This permit shall supercede the limitations contained in TNAs S-10-71-4173, SO2-80-5899 and SC-2-805899.

)

e n

9

Paqa 4 cf 7 pages Parmit No. ' NJ0005622 ,

PART III - B/C .

1 1.D . EFFLUENT LIMITATIONS AND MONITORING RROUIRRMENTS During the period beginning and lasting through EDP; 4 5 years the permittee is authorized t6 Ncharge from outf all(s) serial number (s) 489.

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

Effluent Characteristic Discharge T, imitations Monitoring Requirementt kgs/ day (lbs/ day) other units (specified)

Measurement Sample Avg. Monthly Max. Daily Avg. Monthly Max. Daily Frequency **, Type Flow-mffay3 (MGD) N/A N/A N/A N/A Monthly Crab a eum Hydrocadons Monthly * **

• Mult le j

N/A N/A lu 15 xygen mand f "j , N/A N/A 'N/A 100 Monthly Grab Total Suspended Solids' 30,45* 100 Monthly Grab j (ag/1) N/A N/A

1. Total Suspended Solids shall not exceed 45mg/l as a 7 day average.

• • During the first precipitation event of the month which causes a discharge during working hours and which is preceded by a. minimum dry period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

• • • Upon written request from'the permittee this limit may be changed to 50mg/l of Total Organic Carbon.

• • • Temperature shall be monitored when boiler blowdown is discharged.

• • • The permittee shall take samples 15, 30 and 45 minutes after the onset of the discharge. The per-nittee shall analyze each sample individually and report a maximum value for the samples.

The pH shall not be less than 6.0 standards units nor greater than 9.0 standard units and shall be monitored Monthly using grab samples.

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

d Camples taken in compliance with the monitoring requirements specified above 'shall be taken at the following location (s): At the outfs11,o,f , discharge 489.

Pcg2 5 of 7 pages Permit No. NJ0005622 ~

Part III - B/C 1.E EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS During the period beginning EDP and lasting through EDP: 4 5 years the permittee is authorized to di'scharge from outfall(s) serial number (s) 48C Such discharges shall be limited and monitored by the permittee as specified below:

Effluent Characteristic Discharme Limitations Monitoring Requirements kgs/ day'(1bs/ day) other units (specified)

Measurement Sample Avg. Monthly Max. Daily Avg. Monthly Max. Daily Frequency Type N/A N/A N/A N/A Continuous Flow-m3/ Day (MCD)

Tenperature F (OC) N/A N/A N/A yfx Monthly Grab Total Suspended Solids (mg/1) N/A N/A 30,45* 100 Twice Monthly Ccxnposite d 50 'IVice Monthly Composite

,D, E*" N/A N/A N/A Pe Hydrocarbons 10 15 Twice Monthly Grab N/A N/A Amnonia as NH4 (mg/1) N/A N/A 35 70 Twice Monthly Grab Copper (mg/1) N/A N/A N/A 0.2 Twice Monthly Composite Zine (mg/1) N/A N/A N/A 0.6 Twice Monthly Composite Iron (mg/1) N/A N/A N/A 1.0 Twice Monthly Composite Chromitzn-Hexavalent N/A N/A 0.1 Twice Monthly Composite N/A (mg/1)

Toxicity-96 hr. LC50 N/A N/A N/A > 50% by voitune See Part IV, Section 2 of pennit The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored monthly using grab smples.

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): At the outfall from the wastewater treatment plant, DSN 48C.

• Total Suspended Solids shall not exceed 45 mg/l on a 7-day average.

• • g g itt ,en reg egt grom the permittee, this limit may be changed to 20 mg/l

o .

Part III - B/C Page 6 of 7 Pages Permit No. NJ0005622

2. SURFACE WATER QUALITY REQUIREMENTS The permittee shall discharge so as not to violate Surface Water Quality Standards for Zone 5 of the Delaware River, pursuant to N.J.A.C. 7:9-4.1 et-- seq., including but not limited to, the following:

A. General Criteria

1. The waters shall not contain substances attributable to municipal, industrial, or other discharges in concentrations or amounts sufficient to preclude the specified water uses to be protected. Within this requirement:

(1) the waters shall be substantially free from unsightly or malodorous nuisances due to floating ~

solids, sludge deposits, debris, oil, scum; and substances in concentrations or combinations which are toxic or harmful to human, animal, plant or aquatic life, or that produce color, taste, or odor in the water, or that taint fish or shellfish flesh.

2. In no case shall concentrations of substances exceed those values given for rejection of water supplies in the United States Public Health Service Drinking Water Standards.

B. Alkalinity (mg/1)

Must be maintained between 20 and 120.

C. Fecal Califorms Samples shall be taken at such frequency and location as to permit valid data interpretation. Geometric average not to exceed 770 per 100 ml. from R.M. 78.8 to 59.5, and 200 per 100 ml. from R.M. 59.5 .to 48.2.

D. Detergents, Synthetic (Methylene Blue Active Substances (MBAS)} (mg/l)

Maximum 30-day average of 1.0 E. Dissolved Oxygen (mg/l)

Minimum 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> average concentration shall not be less than 3.5. at R.M. 78.8, 4.5 at R.M. 70.0 and 6.0 at R.M. 59.5.

Seasonal average for periods from April 1 to June 15 and from September 16 to December 31 not less than 6.5 for the entire zone.

t

Part III - B/C Page 7 of 7 Pages Permit No. NJ0005622 F. pH (standard units)

Must be maintained between 6.5 and 8.5.

G. Phenols (mg/1)

Maximum of 0.01, unless exceeded due to natural conditions.

H. Radioactivity (picocuries per liter)

Alpha emitters - maximum 3.

Beta emitters - maximum 1,000..

I. Solids, Total Dissolved (Filterable Residue)

Not to exceed 133 percent of background.

J. Temperature and Heat Dissipation Areas

~

1. Temperature, except in designated heat dissipation areas shall not be raised above ambient temperature by more than 4 degrees Fahrenheit during the pericd from i . September through May nor more than 1.5 degrees Fahrenheit during the period from June through August, nor shall maximum temperatures exceed 86.

2. Except by special~ permission granted on a case by case basis, the allowed heat dissipation areas shall have a maximum dimension of length of 3500 feet measured from the point where the waste discharge enters the stream.

K. Threshold Odor Number Not to exceed 24 at 60 degrees Celsius.

L. Turbidity (Nephelometric Turbidity Unit - NTU)

Maximum 30 day average of 40 NTU, and a maximum of 150 NTU at any time, unless exceeded due to natural causes.

f

Part IV - B/C Page 1 of 6 Permit No. NJ0005622

1. ADDITIONAL REQUIREMENTS OF THIS PERMIT A. Operation of Treatment Works The operation of the treatment works shall be under the continual supervision of an operator. The industrial operator shall meet the requirements of the Department of Environmental Protection of the State of New Jersey for an N2 License, pursuant to the provisions of N.J.S.A. 58:11-64 and amendmcnts thereto. The operator of the sanitary wastewater treatment plant shall meet the requirements for an S2 license or equivalent.

B. In addition to the discharge monitoring report submitted to 4 NJDEP in accordance with paragraph 11.I. (1) in Part I of this .

permit, the permittee shall also submit a duplicate signed copy of these, and all other reports required herein, to the following address (es) :

Regional Administrator Delaware River Basin Region II Commission U.S. Environmental Protection Agency P.O. Box 736 26 Federal Plaza West Trenton, NJ 08628~

New York, N.Y. 10278 ATTN: Mr. Seymour P. Gross ATTN: Permits Administration Branch Supervising Civil Eng.

All monitoring reports shall be submitted on a monthly basis.

C. Pursuant to N.J.A.C. 7:9-5.4 (b) (5) , effective year-round disinfection shall be required for all t.reated wastewater discharges containing pathogenic organisms.

D. In accordance with the DRBC Administrative Manual-Part III Basin Regulations-Water Quality recodified and revised to include amendments through March 10, 1980, the following shall be applied:

'* A. Stream Quality Objectives

1. Radioactivity I a. alpha emitters maximum 3 pc/l (picocuries per liter) ;

b. beta emitters-maximum 1,000 pc/1.

l

, n

Part IV - B/C Page 2 of 6 Permit No. NJ0005622 E. State and Local Requirements

1. Hazardous Waste Management The permittee shall store, transfer, and dispose of its hazardous wastes in compliance with the " Manifest" provisions pursuant to N.J.A.C. 7:26-1 et seg.

2. Radiation 1

a. The permittee shall comply with all regulations set forth in N.J.S.A. 26:2D-1 et seg. in regard to Radiation Protection.

b. All radioactive wartes shall be collected, removed, and disposed of in accordance with N.J.A.C. 7:28-11.1 .

et. seq.

F.1. Total. residual chlorine may not be discharged from any single generating unit for more than two hours per day. However, since

the permittee has demonstrated that the service water system, a

nuclear safety.related system, has a macro invertebrate fouling problem, TRC discharges in excess of two hours per day are allowed to accomodate continuous chlorination of the service water' system, provided that TRC discharges resulting from the main cooling condenser cooling water chlorination do not exceed two hours per day.

2. Monitoring shall be performed once during each two (2) hour period of chlorination of the main condensers at the permitted outfalls, DSN 481-486 and once during each eight (8) hour period of chlorination of the service water system at each outlet from the

. -service water system to the main outfall. The amount of TRC discharged from each service water system outlet shall not exceed 0.2 mg/1.

3.The-permittee shall maintain a log noting the time and duration of chlorination of the main condensers.

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

H. The. permittee shall comply with all effluent limitations, monitoring requirements and other licensing conditions of the

. Nuclear Regulatory Commission.

1

-. ,. , _ . _ __ _ _ . _ _ . . _ . . - -.0,. - . . _ . -__._.f. ._ . . _ _ _ _

Part IV-B/C Page 3 of 6 Pages Permit No. NJ0005622 I.1.The net amount of heat per unit time is determined by the product of the heat capacity, discharge flow and discharge-intake temperature difference 2.The effluent temperature to be reported on the facility DMRs will, for the discharges 481-483, be calculated as the combined average of each of the separate discharges, 481-483, and will, for the discharges 484-486, be calculated as the combined average of each of the separate discharges 484-486. Likewise, the calculations of the net temperature difference will be determined by subtracting the ambient river water temperature from the average effluent temperature of 481-483 and of 484-486.

J. The thermal effluent limitations specified in this permit shall remain in effect until such time as final determinations are made by the State on the imposition of alternative thermal effluent limitations and on the location, design, construction, and ,

capacity of the cooling water intake structures pursuant to Section 316 (a and b) respectively, of the Federal Water Pollution Control Act as amended (P.L.92-500). Alternative thermal

-effluent limitations or thermal effluent limitations based upon load allocations and other factors may be imposed and/or appropriate mixing zone dimensions may be defined as a result of the determination. A schedule of compliance may be imposed upon the permittee to meet final thermal effluent limitations.

K. The wastewaters, prior to discharge into Zone 5 of the Delaware River, shall be treated to a degree providing, as a minimum, 87.5 percent reduction of biochemical oxygen demand in conformity with the Delaware River Basin Commission's (DRBC) " Water Quality Standard ". The permittee has an allocation of 3 lbs/ day of first

stage carbonaceous oxygen demand (FSOD) , which must be met at all times.

i L. The permittee shall satisfy the requirements as set forth in the provisions covering the generation, storage, handling, and

disposal of sludges and/or hazardous solid wastes in accordance with N.J.A.C. 7

26-1 et seq.

4 4

L Q

• -' Part IV - B/C Page 4 of 6 Pages Permit No. NJ0005622

2. BIOMONITORING REQUIREMENTS Acute Toxicity The permittee shall conduct 96-hour definitive flow-through o'r definitive modified static renewal bioasnay tests, conducted in replicate, of its wastewater discharge at a frequency of one test every three months. If the first four tests show no measurable acute toxicity, the permittee may petition the Department for modification of the biomonitoring requirements. The first bioassay test shall be initiated no later than three months from EDP, unless~otherwise specified by the NJDEP.

A. All bioassays shall be conducted in accordance with the following procedures:

(1) Bioassay procedure shall conform to the

" Regulations Governing Laboratory Certification ~

and Standards of Performance" (N.J.A.C. 7:18).

Subchapter 6 of the regulations contains the criteria and procedures for bioasssy testing and analysis. The laboratory per-forming your bioassay testing will have to be within the laboratory certification program.

(2) The bioassay shall provide a measure of acute toxicity as determined by the wastewater concentration which causes 50% mortality of the appropriate test organisms over a 96-hour period. Test results shall be expressed in terms of Lethal Concentration (LC) - and reported as 96-hour LC-50.

(3) With receiving waters having a salinity greater than 1 ppt., the mysid shrimp (Mysidopsis bahia) is recommended. The test temperature shall be 22*C + 2 C.

Refer to N.J.A.C. 7:18-6.6 (Alternate species option) .

B. The following information shall be submitted within two months from the Effective Date of Permlt:

(1) An identification of the certified bioassay laboratory responsible for the conduct of the bioassay tests.

f

Part IV - B/C Page 5 of 6 Pages Permit No. NJ0005622 (2) A detailed description of the methodology to be utilized in the conduct of the tests, in-cluding equipment, retention time of the 1 wastewater in the treatment plant, collection

. method of a representative effluent sample, and name and source of test organisms.

(3) A schematic diagram which depicts the location that the effluent samples will be taken; the diagram shall indicate the location of effluent sampling in relation to any wastewater treatment facilities and Discharge Serial No. 48C.

C. If the results of the 96-hour bioassay indicate greater than lot mortality in the control, the permittee shall conduct an .

additional 96-hour bioassay, in replicate, no later than 10 days after completion of the above referenced test.

D. Bioassay results shall be reported on a form provided and shall be submitted within 60 days after completion of the tests. Results shall also be reported on the permittee's Discharge Monitoring Reports (DMR).

E. The information requested (B1 through B3) and the bioassay test results (D) shall be submitted to:

Bureau of Permits Administration Water Quality Management Division of Water Resources CN-029 Trenton, New Jersey 08625 Bureau of Systems Analysis and Wasteload Allocation Division of Water Resources CN-029 Trenton, New Jersey 08625 0

9

, --- *+r-e,w e y-,*--- vm-v---y + ---n-- - - - - - = - - - - ,

'O B Part IV - B/C Page 6 of 6 Pages Permit No. NJ0005622

3. COMPLIANCE SCHEDULE A. The permittee shall comply with all provisions of the Consent Order, Docket No. EPA-CWA-II-82-77, signed on May 27, 1993.

B. The compliance deadline for the TRC BAT limitation shall be November 19, 1985. At the time that TRC limitations become effective the free available chlorine (FAC) limitations and monitoring will no longer be required.

O h

e 9

, . . . , - . - - .-._-..,m., _

. , _ , . _ . . __ _ _ . . - _ - _c.- ,- , , . . - , , -

' Page 1 of 9 Permit No. NJ0005622

. Part V STATE OF NEW JERSEY i ' DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF WATER RESOURCES -

ADDITIONAL REOUIREMENTS FOR AN INDUSTRIAL WASTE MANAGEMENT FACILITY, N.J.A.C. 7:14A-4.1 et seq.

4.1 Purpose This subchapter establishes the requirements for compliance with the State Act concerning hazardous waste as defined in Section 1.10 for owners and operators of an industrial waste management 4

facility as described in section 4.2.

4.2 Scope (a) Specific inclusions An industrial waste management facility (IWMF) includes the following:

1. Wastewater treatment units which arc subject to regula-tion under Sections 402 or 307(b) of the Federal Act and that:

1. receive, and treat.or store an influent wastewater which is a hazardous waster or

11. generate, store, or treat a wastewater treatment sludge or' residue which is a hazardous waste; and i

111. the hazardous wastewater is exclusively received from intracompany and intrastate sources.

2. The treatment or storage of hazardous, waste in a surface

. impoundment;

3. A land treatment facility for hazardous waste.

4. Injection wells that dispose of hazardous waste, and associated surface facilities that treat, store, or l l dispose of hazardout waste. However, the owner and operator with a UIC permit shall be deemed to have a IWMF permit for the injection well itself provided there

, is compliance with the requirements of Section 4.5(a).

4 a

, . , . - . - . . , _ , . - . . - - - - - . . , , . , , . . , , . . . . . _ , - . _ . - . . , , , , . . , , . , , _ ^ O - _---- ,_ - ,-.

4 Page 2 of 9 Permit No. NJ0005622

. Part V 4

(b) Specific exclusions The foLlowing exclusions to this subchapter are required to obtain a Razardous Waste Facility (HWF) cermit oursuant to N.J.A.C. 7:26-12.1 et seq.

1. Wastewater treatment unit which meet the requirements of j

paragraphs (a) (1) (1) through (ii) but not paragraph (a

fro)m(1) (iii) becauseorhazardous intercompany interstatewastewater sources. is received ,

2. A surface impoundment where hasardous wastes will remain at the facility site after closure is completed.

3. The treatment, storage or disposal of hazardous waste ~

sludges in sludge drying beds and landfills.

(c) General requirements. ,

1. The_ owner or operator of an IWMF as described in paragraph (a)1. above shall be deemed to possess a NJPDES/IWMF permit-by-rule provided there is compliance

+ with the standards soecified in Section 4.6, unless the Department terminates eligibility for a permit-by-rule in accordance with Section 4.5(c)2.

2. Where eligibility for an IMMF permit-by-rule has been terminated by the Department, the owner or operator of the IWMF shall apply for and is required to obtain an IWMF permit which incorporates and requires compliance

. with Section 4.$4.

i 3. The owner or ~ operator of an IWMF as described in i paragraphs (a) (2) and (3) above shall obtain a NJPDES/IWMF permit in accordance with Section 4.4.

I 4.3 Definitions I

The following definitions apply to this subchapter.

" Existing Facility" - means a facility which was in operation or for which construction has commenced, on or before November 19, l 1980. Construction had commehced if the owner or operator has obtained all necessary Federal permits as well as any permit '

i required by the Solid waste Administration and either

! a. a continuous physical, on-site construction program han begun, or l

I Page 3 of 9 Permit No. NJ0005622

. Part V

b. the owner or operator has entered into contractual oblica-tions which cannot be cancelled or modified without substan-tial loss for the construction of the facility to be completed within a reasonable time.

" Land Treatment Facility" - means a facility or part of a facility at which hazardous waste is applied onto or incorporated into the 4

soil surface; such facilities are disposal facilities if the waste will remain after closure.

" Wastewater treatment unit" means a device which:

1

1. Is part of a wastewater treatmeat facility which is sub-ject to regulations under either Section 402 or section 307 (b) of the Federal Act; and *

2. Receives and treats or stores an influent wastewater which is a hazardous waste as defined in N.J.A.C.

7:26-1.1 et seq., or generates and accumulates a wastewater treatment sludge which is a hazardous waste as defined in N.J.A.C. 7:26-1.1 et sec., or treats or stores a wastewater treatment sludge which is a hazar-dous' waste as defined in N.J.A.C. 7:26-1.1 et sea.

" Tank" - means a stationary device, designed to contain an accum-mulation of hazardous waste which is constructed of non-earthen structural material (s) (e.g., wood, steel, plastic, reinforced concrete, etc.) which provides the necessary structural strength to totally contain the waste.

4.4 Application for a permit" l (a) Except as provided in Section 4.5 (permit-by-rule), an IWMF shall apply for a permit in accordance with this Section.

Applicants shall refer to N.J.A.C. 7:26-12.1 et sea. (Permit ~

Requirements for Hazardous Waste Facilities - Rules of the Solid Waste Administration) for requirements and procedures for submission of an application for an IWMF permit. Such IWMF's'shall comply with all of the requirements set forth therein with the exception of the following:

1. An environmental impact and health statement is not required for a IWMF.

2. A disclosure statement is not required for a IWMF.

)

, . . . . -n...._...n, --.n _,.,,._._,,--.-,_n,_.- , , - , . _ , _ , , , - - ,,. f _ _ ,,,n.c--- --.-.--.w--,

. 1 Page 4 of 9 Permit No. NJ0005622 Part V (b) For land treatment facilities only.

- In addition to complying with the requirements of N.J.A.C.

. 7:26-12.1 et seq. an applicant for a land treatment facility shall comply with N.J.A.C. 7:14A-10.8 and 40 CFR 265.270 through 282.  !

(c) For surface impoundments only.

l In addition to complying with the requirements of N.J.A.C.

7:26-12.1 et sea. an applicant for a IWMF permit for a sur-face impoundment which treats, stores, or disposes of hazar-dous waste shall comply with N.J.A.C. 7:14A-10.7.

(d) Existing INMF facilities. Prior to final disposition of a ,

INMF permit application, an existing IwMF facility may con-tinue to operate in accordance with the standards and proce-dures set forth at N.J.A.C. 7:26-12.3. In addition to the requirements set forth at N.J.A.C. 7:26-12.3(e) an owner or operator of an existing land treatment facility shall comply with the standards set forth at 40 CFR 265.270 through 282.

4.5 Permits-by-rule

, Notwithstanding ar.y other provision of this subchapter or M.J.A.C.

7:14A-7 and 8 the following shall be deemed to have a IWMF permit if the conditions listed are mets (a) Injection wells. The owner or operator of an injection well disposing of hazardous waste, if the owner or operator:

1. Mas a permit for underground injection issued under N.J.A.C. 7:14A-5.1 et seq.;

2. Complies with the conditions of that permit and the l

recuirements of N.J.A.C. 7:14A-5.12 (requirements for wells injecting hazardous waste) .

. (b) Publicly owned treatment works. A POTW which accepts for treatment hazardous waste, if the owner or operator:

1. Mas a NJPDES permit as required by N.J.A.C. 7:14A-1.3;

2. Complies with the conditions of that permitt and -

3. Complies with the following regulations:

i

. . _ . - . - . , . . . - . - _ - - - r - - - - - _._ - - -

Page 5 of 9 Permit No. NJ0005622

, Part V

i. N.J.A.C. 7:26-7.6(a) Identification number;  ;

ile N.J.A.C. 7:26-7.1 et seg. Une of manife'st system; i

111. N.J.A.C. 7:26-9.4(1) Operating record; iv. N.J. A.C. 7: 26-9.4 (j) Annual report.

4. If the waste meets all Federal State and local pretreatment requirements whic$ would,be applicable to the waste if it were being discharged into the new through a sewer, pipe, or similar conveyance.

(c) Wastewater Treatment Units. .

. 1. The owner or operator of a wastewater treatment unit if ~

he/she complies with the requirements of Section 4.6, unless required to have an individual permit under (c)2.

i of this paragraph.

j 2. The Department may terminate eligibility for a permit-by-rule under this section and require an cwner or operator of a wastewater treatment unit to appiv for and e obtain a IWMF permit under this subchapter, ift

1. The owner or operator violates any condition of Section 4.6.

ii. The owner or operator is conducting other activi-ties which, require an individual IWMF permits or 111. The Department determines that the requirements of Section 4.6 are not suf ficient to protect public human health or the environment and that additional requirements concerning hazardous waste facilities (Rules of the Solid Waste Administration) pursuant to N.J.A.C. 7:26-10.1 et sea. are required to pro-vide such protection.

l 4.6 Standards for wastewater Treatment Units subiect to a permit-by-rule (a) Purpose, scope, and applicability.

1. The purpose of this part is to establish minimum stan-dards which define the acceptable management of certain hazardous wastes and the acceptable practices for industrial waste management facilities as defined in Section 4.2(a)1.

.-v--- y -.,,-wyw,,.yy._-m-,---,,v.-_

, _ - , _ w_ - - - , - _ _ - __------.-,-,-.--,-,,% . , _ _ - - - _ . -._ v - ,. .m , vw

Page 6 of 9 Permit No. NJ0005622 Part V

2. The standards in this part apply, in lieu of the s re.quirements of N.J.A.C. 7:26-9.1 through 11.1 et seq.

toIowners and operators of eligible industrial Caste management facilities.

(b) EPA Idenification Number.

1. The owner or operator must not treat or store a hazar-dous waste in a wastewater treatment unit without having received an EPA identification number.

2. An owner or operator who has not received an EPA iden-tification number may obtain one by applying to the Department.

(c) Security.

1. The owner or operator must prevent the unknowing entry, and minimize the possibility for the unauthorized entry, of persons or livestock into or onto the wastewater treatment unit, unless:

1. Physical contact with the waste contained in the unit will not injure unknowing or unauthorized per-sons or livestock which may enter the unit, and

11. Disturbance of the waste or equipment by the unknowing or unauthorized entry of persons or livestock into or onto the unit will not cause a violation of the requirements of this section.

(d) Inspections.

1. The owner must inspect the wastewater treatment unit for malfunctions and deterioration, operator errors, and discharges which may be causing-or may lead to - (1) i unauthorized release of hazardous waste to the environ-  ;

ment or (2) a threat to human health. The owner or i operator must conduct these inspections often enough to 1 identify problems in time to correct them before they may pose a threat to or harm human health or the environment. For DSws, such inspections and the basis for the inspection shall be addressed in an emergency plan as required in N.J.A.C. 7: 14A-3.12.

O

r, ,

Page 7 of 9 Permit No. NJ0005622 Part V

2. 1. The owner or operator must develop and follow a written schedule for inspecting all monitoring equipment, safety and emergency equipment, security devices, and operating and structural equioment (such as tank walls and pumps) that are important to preventing environmental or human health hazards.

s

11. The owner or operator must keep this schedule at the facility.

iii. The schedule must identify the types of problems (e.g., malfunctions or deterioration) which are to be looked for during the inspection (e.g., inopers-tive pump, leaking fitting, heavy corrosion). ~

iv. The frequency of inspection may vary for the items on the schedule. It should be based on the rate of possible deterioration of the equipment and the probability of an environmental or human health incident if any deterioration or malfunction or operator error goes undetected between inspections.

v. The owner or operator must remedy any deterioration or malfunction of equipment or structures detected in an inspection. This must be done on a schedule which ensures that the problem does not lead to an environmental or human health hazard. Where a hazard is imminent or has already occurred, reme-dial actio,n must be taken immediately.

vi. The owner or operator must record inspections in an inspection log. He must keep these records for at least three years from the date of inspection. At the minimum, these records must include the date and time of each inspection, the name of the inspector, a recording of the observations made, and the date and nature of any repairs or other remedial actions taken as a result of inspection observations.

(e) General operating requirements.

1. The emergency plan required in N.J. A.C. 7:14A-3.12 shall address the requirements of this caragraph.

a

f. .

. s Page 8 of 9 Permit No. NJ0005622

. Part V 2.

The owner or operator of a watewater treatment unit must ensure that the treatment process conducted in the unit ddes not:

1. Generate extreme heat or pressure, fire or explosion, or violent reaction;

11. Produce uncontrolled toxic mists, fumes, or gases in sufficient quantities which may pose a threat to human healths 111. Produce uncontrolled flammable fumes or cases in sufficient auantities to pose a risk of fire or explosion i

iv.

Damage the structural integrity of the tank or equipment containing the waster or

v. Through like means may pose a threat to human i

health or the environment.

3. Hazardous waste or treatment reagents must not be placed in a wastewater treatment unit if they could cause the unit or any of its equipment to rupture, leak, abnor-mally corrode, or otherwise fail before the end of its l intended life.

4 Wastewater treatment unit must be desianed, constructed and operated so as to prevent hazardous wastes from being discharged into or on any land or water during the operating life 'of the unit.

i (f)

Manifest system recordkeeping and reporting.

The owner or operator must comply with the following require- '

ments

. sources: with respect to hazardous waste received from offsite i

1. N.J.A.C. 7:26-7.1 et seq., .Use of manifest systemt

2. N.J.A.C. 7 : 26-9. 4 (1) , operating record;

3. N.J.A.C. 7:26-9.4(35, Annual report.

U l

i l

.. - _.- - - - - - - - - - - - - - - - ~ ^ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

Page 9 of 9 Permit No. NJ0005622

. Part V (g) Closure.

At closure, the owner or operator of the wastewater treatment unit must remove all hazardous waste and hazardous waste residues from the unit and comply with N.J. A.C. 7:26-7.1 ej sea.

(h) Reporting. '

1. Any discharge of hasardous waste from a wastewater treatment unit must be reported to the Department in accordance with the " Spill Compensation and control Act" N.J.S.A. 58:10-23.11(e), and the owner or operator of the unit must report to the Department the following information: -

1. Name, address, and telephone number of the owner or operatorp

11. Name, address, and telephone number of the facility; 111. Date, time, and nature of the incident; iv. Name and quantity of material (s) involvedt

v. The extent of injuries, if any; vi. An assessment of actual or potential hazards to human health or the environment, where this is applicable; and vii. Estimated quantity and disposition of recovered material that.resulted from the incident.

l 6

O e

'l

-,, - - - . , , ..m., ,,,_,,,,,.-------.-._,..-m-,,,, ,,--------,,-n.v, ,yr. - - ---

• e $

I 9 tate of Notti .hrrsey DEPARTMENT OF ENVIRONMENTAL PROTECTION DIVISION OF WATER RESOURCES CN 029 )

TRENTON NEW JERSEY 00625 l JOHN W. O ASTON J R., P.E, DIRK C, .40FM AN, P.E.  !

OIRECTOR _ DEPUTY DIRECTOR NIOu794 Public Service Electric and Gas Company 80 Park Plaza ,

Muil Code 10C ~

Newark, New Jersey 07101 ATTENTION: James A. Shissias, General Manager Environmental Affairs RE: Comments on NJPDES-DSW Draft Permit Renewal Salem Generating Station, NJ0005622 Lower Alloways Creek Township, Salem County

Dear Mr. Shissias:

l We have reviewed your comments on the Draft Permit for the Salem l Generating Station and have the following responses to the issues raised in your letter:

I. General Comments -

1. The location of the outfalls for discharges 481-486 on the facility location map will be changed as requested.

2. The heading on the vicinity map (Page 3A of 24 Pages) will be changed to represent the Salem Generating Station rather than the Hope Creek Station.

3. The sentence describing the auxiliary cooling water system on the statement of Basis will be reworded as requested.

4-6 The maximum flow values indicated on the permit summary tables will be changed as requested under the

" application value" column.

New Jersey is An Equa! Opportunity Employer h

C .. .

7. The reference for the double asterisk for discharge 48C on the permit summary table (Page 23 of 24 Pages) will be added, and the maximum flow value will be changed as requested.

8. The monitoring methods specified for discharge 487 and 489 are in accordance with the New Jersey Oil and Grease Effluent limitations, N.J.A.C. 7:14A-14.1 et seg. for surface water runoff and aill remain in the permit.

9. All new NJPDES-DSW permits will require submittal of the permittee's Discharge Monitoring Reports (DMR's) postmarked by the 25th day of the month following the reporting period.

10. The Consent Order EPA-CNA-II-82-77 is referenced in the compliance schedule. Therefore, it is not necessary to refer to it again in this portion of the permit. The wording of A.7.d. will remain unchanged.

II. Effluent Limitations and Monitoring Requirements

1. We believe that the EPA Regional Guidance memorandum, though not a mandatory effluent guideline, is a valid basis for establishing non-contact cooling water and storm runoff limitations using Best Professional Judgment.

l

2. Discharges 481-486:

, a. PSEEG may continue to monitor the flow of the ,

cooling water outfalls using the indirect flow measurement by the calculation method employed for the former permit term, provided

, that' documentation is furnished to show that l this method is just as accurate as direct measurement by a flow monitoring device.

b. We believe that the DRBC effluent temperature limitation of 43.3*C (110* F) is applicable to the cooling water outfalls at Salem regardless of their distance from the shoreline and surface of the Delaware River.

Therefore, this limitation will remain in the permit. However, we will accept PSE&G's proposal of June 27, 1984 for the method of calculating and' reporting temperature

' effluent and net difference values. We intend to add the following paragraph to the permit to specify this method:

1 j The effluent temperature to be i reported on the facility DMR's will, I

l l

. .=_ ~ - _ - - - . , , , , -

_.-_.__o-,-.__..._.__.L..-_.,..._._..-,_.._..

I. ..

for the discharges 481-483, be calculated as the combined average of each of the separate discharges, 481-483, and will, for discharges 484-486, be calculated as the combined average of each of the separate discharges 484-486. Likewise, the calculations of the net temperature difference will be determined by subtracting the ambient river water temperature from the average effluent temperature of 481-483 and of 484-486.

c. Since COD in the ecoling water streams could be from the intake water, the 50 mg/l maximum limitation for these outfalls will be designated as a net value. We will also add a notation stating that if, after one year of monitoring, it is shown that there is no not addition of COD in the effluent, the permittee may request that the Department delete the COD limitation and monitoring requirements.

d. Since PSEEG does not currently use, nor intend to use corrosion inhibitors containing copper, i chromium, or zine in the non-contact cooling water pipes at Salem, all references to these compounds will be eliminated from the 4 non-contact cooling water outfall effluent tables. However, if PSEEG ever decides to use any corrosion inhibitors in the future, PSE&G must so notify this Division since a permit modification may be required.

e. The DRBC value of 100 mg/l is intended for industrial wastewater treatment facilities, not non-contact cooling water. A limitation of 20 mg/l maximum is normally imposed for non-contact cooling water. Therefore, PSEEG should have no problem meeting the 30 mg/l 30-day average and 45 mg/l 7-day average net limitations imposed.

f. Continuous monitoring requirements for the parsmeter TRC will be modified to once during e'.ch 2-hour period of chlorination of the main condensers at the permitted outfalls, DSN 481-486, and once during each 8-hour period of chlorination of the service water system at each outlet from this system to the main outfall. Please note that the final permit will allow continuous chlorination of the service water system. Therefore, we do not O

I. .

feel that further relaxation of the monitoring frequency is warranted.

g. The words "during chlorination periode at the plant outfalls" will be added to the FAC continuous monitoring requirements as you have requested.

h. The net value for TSS was meant for both the 30 mg/l monthly average and the 45 mg/l 7-day average on the cooling water outfalls. Part II.2.C. of this letter addresses the COD limitation.

3. Discharge 48C, Limitations until July 1, 1985:

Since the compliance date for the industrial wastewater treatrent plant was July 1, 1985, this table is no longer necessory and will be deleted from the Final Permit. .

4. Discharge 48C, Limitations after July 1, 1985:

a.l. As stated in our letter of February 29, 1984, we will remove the affluent temperature limitation from this outfall. However, monitoring will be required to determine whether a limitation is necessary. The permittee may request that this monitoring be deleted once it develops monitoring data to support such a request.

2. We believe it is likely that COD will be added in the boiler blowdown and equipment and yard drain wastewaters treated in the wastewater treatment facility, and we do not believe that ammonia monitoring is interchangeable with COD monitoring.

Therefore, the COD monitoring and limitation will remain-in the permit.

3. The EPA Steam Electric Power Generating Guidelines require that all discharges, including internal waste streams meet the pH limitation of 6-9. Therefore, the pH limitations and monitoring requirements will remain in the permit,

b. The wasteweter treatment plant does contain toxic substances such as copper, chromium, and zinc. Therefore, the toxicity (bioassay) limitation of 96-hour LC 50250% by volume pursuant to N.J.A.C. 7:9-5.7 has been

n.

specified in the permit and is applicable to the wastewater treatment plant effluent prior to dilution with the facility cooling water in accordance with N.J.A.C.

7 :14 A-2. 5 (a) (1) (ii) which prohibits attaining effluent limitations by dilution. The above will be included in the Final Permit Statement of Basis.

It is important to note that the bioassay analytical proceduresas addressed by the

" Regulations Governing Laboratory Certification and Standards of Performance" (N.J.A.C. 7:18) are referenced in the permit bioassay requirements.

Please note that the Final NJPDES-DSW Permit recommends use of the mysid shrimp (Mysidopsis bahia) for biomonitoring as the appropriate salt water / estuarine test

• organism for the saline . areas of the Lower Delaware River.

5. Discharge 487:

a. The flow monitoring is applied at this outfall to determine the quantity of flow attributable to the sources other than the sewage treatment plant, including auxiliary boiler blowdown, fire pump house building sump drains, the turbine area flood pump and yard drains. Since PSEEG must perform several other analyses at this outfall, determining a method of flow measurement should not present an unresolvable problem.

b. Considering the small amount of the affluent at this outfall attributable to boiler blowdown which we source of heat, webelieve believe the is the 86primary F (30 C) effluent temperature limitation is reasonable and that PSEEG should not have a problem meeting it.

c. As stated earlier (in II-1.), we believe that this document, though not a mandatory effluent guideline, is a valid basis fer establishing storm runoff limitations using Best Professional Judgment and that the 100 mg/l maximum effluent limitation for COD is reasonable and achievable provided " good housekeeping" is practiced at the site.

t

l

d. The 45 mg/l TSS limitation is a 7-day average l as indicated in the note at the bottom of the effluent table, rather than a daily maximum. l However, since a maximum daily limitation of '

100 mg/l was established at discharge 487A, which comprises most of discharge 487, the 100 mg/l daily maximum will also be applied at the outfall of discharge 487.

6. Discharge 487A:

a. In accordance with recommendations of the Division's Southern Region Enforcement Element, the following changes have been made in the requirements for 487A:

1. A flow limitation of 0.02 MGD as a 30-day average has been imposed. ,

2. A requirement to report the BOD 5 percent -

reduction value on a monthly basis has been included. The limitation of 87.54 minimum reduction remains.

3. The concentration limitations for BOD 5 have been deleted, as the DRBC mass limitation of 2.14 pounds per day is more stringent.

4. The type of sampling required for BOD 5 has been changed from composite to grab.

5. A statement has been included noting that the limitations contained in this permit shall supersede the limitations contained in TWA's S 71-4173, SO 2-80-5899 and SC-2-805899.

7. Discharge 489:

a. Our comments for 5 (a) and (c) are also applicable to this outfall.

b. We will also add the 100 mg/l daily maximum limitation' for TSS to this outfall while retaining the 30 mg/l monthly average and 45 mg/l 7-day average values in the permit.

Please note that a Part V will be added to the Final Permit as the Salem Generating Station's wastewater treatment basin, t

r * ,

formerly a part of RCRA Part A, has been classified as an Industrial Waste Management Facility (IWMF), as it is part of the permittee's wastewater treatment system. There fore , it is subject to the IWMF requirements specified in part V.

The Final NJPDES-DSW Renewal Permit for PSE&G's Salem Generating Station will be issued in accordance with the preceding responses.

If you have any questions regarding these responses, please contact me or Ms. Melisse Wilusz of my staff at (609) 292-0407.

Sincerely, Edward H. Post, P.E., Chief Industrial Permits Section Bureau of Industrial Waste Management WQM70 tmc cc: E. Svensen, PSE&G G. Meyer, USEPA - Region II S. Gross, DRBC E. Londres, DWM Engineering, Permits & Licensing 1

n t

p-

'

• v. <

f.._

1. ,b@\b,

• ** e PSEG Puthe Serwce Elenre and Gas Campanj 80 Park P:aza. T10C Newk, N J. 07:01 23U430-53ES James A. Shissias Genera! Manager Enwronmental Affairs 3 ,, ._,_ ,,,,_,,.

February 15, 1984 Mr. Arnold Schiffman P og Administrator-Water Quality Management 6p N.J. Department of Environmental Protection Division of Water Resources FE y g Industrial Waste Management CN-029 0F NE , JERSEY Trenton, New Jersey 08625 fg* RONutMTALPROTECTION ca DN,. .

Dear Sir:

COMMENTS - DRAFT NJPDES PERMIT NJ 0005622 .

SALEM GENERATING STATION PUBLIC SERVICE ELECTRIC AND GAS COMPANY In response to the public notice dated January 24, 1984 concerning the issuance of draft NJPDES Permit NJ 0005622 for discharge to surface water, we include comments for your review.

I. General Comments:

1. Attachment I, page 3 of 24 pages: Discharges 481 through 486 on the map should be shown in the order as 481 through 486 running south to north.

2. Page 3A of 24 pages: The title heading " Vicinity Map for Proposed Hope Creek Generating Station in Delaware River" should be changed to " Map for Salem Generating Station".

The location of Hope Creek Generating Station has no bearing in this permit.

3. Attachment II, page 4 of 21 pages Under the category, description of limitations and conditions, DSN 481, 482, 483, 484, 485 and 486. The second to last sentence states, "It should be noted that reactor and turbine auxiliary cooling water is also discharged . . . " .In order to avoi2 any misinterpretation on the part of the public this sentence should be reworded as, "It should be noted that reactor auxiliary and turbine "

auxiliary cooling water is also discharged. . . .

4. Permit summary table, page 18 of 24 pages: The maximum flows indicated for discharges 481A/482A and 484A/485A are incorrect. The correct maximum flow for these discharges is .040 MGD.

95 5000 t2Vi e n

Mr. Arnold Schiffman Page 2 February 15, 1984

5. Permit summary table, page 20 of 24 pages: The maximum flow indicated for discharge 487 should be .02 MGD. The maximun discharge from 487A which is directed into discharge 487 is .02 MGD.

6. Permit summary table, page 22 of 24 pages: The maximum flow for discharge 489 should be .05 MGD as is already indicated on the flow schematic found on page 3B of 24 pages in the decft permit.

7. Permit summary table, page 23 of 74 pages: COD is referenced by a double asterisk; however, no such reference is shown on the bottom of the page. The maximum flow for dis-charge 48C should also be corrected to .74 MGD to agree with -

the flow schematic found on page 3B of 24 pages.

8.- Page 6, Part II, Item 9: The requirement for " multiple grab" requiring sampling of the discharge during a precipita-tion event at 15, 30 and 45 minutes after the onset of the discharge would require PSE&G to hold a worker on standby each time rainfall was predicted until the actual precipitation started to insure that the once per month sample was obtained. Furthermore, the method by which multiple grab is apolied to discharges 487 and 489 requiring a minimum dry period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is extremely restrictive in the sense of how does one actually implement such a sampling scheme into the operational routine of plant personnel? We suggest as an alternative twice monthly grab sampling.

9. Monitoring and reporting requirements - page 7, part II, Item B (2)(a): The requirement of submitting monthly DMR reports postmarked no later than the 10th day of the month following the completed reporting period is a sub-stantial change. The "old" permit required reporting on the 28th day of the month following the completed reporting period. . The 10th day of the month, while it is already in effect at most of PSE&G's fac(lities, is quite restrictive when applied to Salem. Salem Generating Station, because of its distance from PSE&G's centralized certified laboratory, the Linden SNG facility (Linden, New Jersey), utilizes th'e services of an outside New Jersey certified laboratory - Century Environmental Labs (N.J. La b Ce rt. No. 08153) to perform many of -the analyses. This coupled with the increased frequency of sampling required by the draft permit would require the company to pay premium and' overtime rates to obtain the necessary I. " turnaround" for analysis of the samples.

b o

Ar. Arnold Schiffman Page 3 February 15, 1984

10. Additional effluent limitations and monitoring requirements, page 20, part IV, Item D: This paragraph should be reworded to include Consent Order EPA-CWA-II-82-77 thermal requirements.

The paragraph should be rewritten as shown:

"The thermal effluent limitations specified in this permit shall remain in effect unless the results of the discharge-intake temperature study performed pursuant to Consent Order EPA-CNA-II-82-77 warrant modification and until such time final determinations are made by the state on the imposition of alternative thermal effluent limitations. . . . .

II. Effluent Limitations and Monitoring Requirements:

1. EPA Regional Guidance Letter to Establish Limits: The EPA's chief of the toxic and Inorganic Waste Section's Regional Guidance letter dated December 8, 1978 has been used -

extensively in establishing cooling water and surf ace water runoff limits in this permit. The practice of using such guidance letters to astablish extra requirements while avoiding the public rulemaking requirements of the Federal Administrative Procedure Act have been previously contested by the Utility Water Act Group of which PSE&G is a member. In response to this action by UWAG, the EPA has restated many'of the guidance documents as "nonmandatory".

2. Discharges 481-486, page 14, Part IV:

A. The draft permit requires flow measurement to be continuous.

It is our interpretation that NJDEP accepts our present method of indirect flow measurement by calculation as is now employed under the "old" permit rather than the installation of direct measuring devices (i.e. flow nozzles). The installations of direct flow measuring devices into the circulator piping is impractical because of the lack of a " straight run" in an accessible area. An engineering rule of thumb "for flow measurements" is to have a straight run of pipe up to 30 pipe diameters upstream of the flow device.

(Reference Baumeister & Marks " Standard Hand Book for Mechanical EngineerrJ , 7th Edition, page 3-70). The pipe diameter of the citialator piping is 8 feet. This argument was.previously accepted by the EPA. For the " expired" NPDES permits at each of the PSE&G generating facilities.

The indirect method for flow measurement utilizes both the design point on the pump head curves and operator logs (number of pumps in/out of service) to calculate flow (refer to attachment I - April 15, 1976 letter to EPA

. Region II).

f

Mr. Arnold Schiffman Page 4 February 15, 1984 B. The draft permit temperature limitation of 1100F maximum daily has been referenced to DRBC Guidelines.

The DRBC " Interpretive Guideline No. 1" states:

" Effluent Quality Requirements

.(3) Public Safety

a. Temperature, maximum 1100F (43.3 0C)

Where readily accessible to human contact."

The discharge piping for the non-contact cooling water discharges 500 feet from the shore and 42 feet under the surf ace of the Delaware River. It is extremely questionable that this 1100F limit is applicable .

because this discharge is not readily accessible to human contact.

PSE&G recommends that the "old" permit value of 1150F remain.

C. The draf t permit has a COD limit of 50 mg/l daily maximum. The immediate question that needs to be asked is where is COD being introduced into the non-contact cooling water? The impact of any COD from the non rad waste basin is insignificant. The maximum discharge flow from the waste treatment plant is .14 MGD. This discharge (48C) mixes with the non-contact cooling water discharges 481, 482, 484 and 485. The total flow any two of the discharges 481, 482, 484 and 485 prior to mixing is approximately 1075 MGD. This results in a mixing factor of a 1 to 1400 ratio. Another way to interpret this is tnat for every mg/l of COD in the non rad waste discharge there would be only .7 Arg/l in the non-contact cooling water.

This is outside the measurable range by analytical test methods. The only other source of COD would be the river itself.

D. The requirement for monitoring of chromium, copper, and zine should be removed from the permit as with all references to use of a . corrosion inhibitor. PSEEG with-drew its request to use a corrosion inhibitor for the non-contact cooling water in a meeting with Ms. Melisse Wilusz and Dr. R. Califano on January 18, 1984.

--- , , ,.--,.-- .,,--n., - , ,. , ,, .- .-. ~ , , , . , - ,

. = _ _ -

Mr. Arnold Schiffman Page 5 February 15, 1984 l t

E. The draft permit establishes a limit for total suspended solids at 45 mg/l maximum daily. This is an apparent misapplication of the DRBC Stream Quality Objectives under 3.10.4D1 which states:

" Suspended Solids: For waste water treatment facilities not to exceed:

1) 30 mg/l as a 30 day average;

2) 45 mg/l as a 7 day averager

3) for industrial waste water treatment facilities, up to 100 mg/l as an average of -

samples collected during a 30 day period may be permitted, provided that reduction of at least 85 percent as a 30 day average is achieved."

! The above clearly indicates that the 100 mg/l daily maximum is the intended DRBC limit for an industrial wastewater treatment facility. In.a conversation with NJDEP-DWR personnel it was indicated that the 100 mg/l limit was not applicable because the non-contact cooling discharge wasn't categorized as " industrial waste water treatment facilities".

This, however, could also be interpreted that t.O DRBC sus-pended solids limits apply (because of the lead in DRBC sentence quoted above) or that no maximum daily limit applies. PSE&G recommends that the limits 30 mg/l for a 30 day average, 45 mg/l for a 7 day averaga and 100 mg/l for maximum daily remain as the applicable limits. A further clarification of this effluent limitation is needed.

F. The draft permit requires continuous TRC chlorine residual monitoring. PSE&G's investigation into this matter has

' found that there are no acceptable continuous TRC monitoring instruments presently available. The term " acceptable" is defined here to mean:

. . - . -. .- . , .o. - . r- . . - _

Mr. Arnold Schiffman Page 6 February 15, 1984

1) An instrument that utilizes an EPA /NJDEP approved analytical method for determining TRC;

2) An instrument that will hold.a calibration between routine maintenance checks;

3) An instrument that is repairable and serviceable by " field" personnel.

Prior to the "first round" of permits in 1976, PSE&G under-took a study of FAC chlorine monitoring instruments. In that study several manufacturers continuous monitcrs were ,

evaluated side by side. The results of that study indicated that none of the instruments would hold calibrations, each required considerable maintenance. Our operating experience since that time has proved conclusively that they are inaccurate, subjected to calibration drift, and require extensive service. Our study on the continuous monitoring has yielded similar results. .PSE&G will be ready to present this study data to the state by mid March. As an alternate to continuous TRC monitoring, PSE&G recommends that once/ week grab sampling using an amperometric titrator -

during chlorination periods be incorporated as the frequency for sample monitoring.

G. The draft permit requires that FAC chlorine residual monitoring be continuous under the new permit. It would be more appropriate to modify.this to "The free available chlorine shall be monitored contin-uously during chlorination periods at the plant outfalls". Without such wording every time the monitor is taken out of service during non-chlorination periods, the plant would technically be in violation of its permit.

H. The statement "(net values)" following the 30 mg/l total suspended solids average monthly should also be applied to the maximum daily and seven day average as well. COD should also be expressed as net' values.

i o

E. ,

o .. .

Mr. Arnold Schiffman Page 7 February 15, 1984

3. Discharge 48C, Page 18, Part IV, effluent limitations in affect up to July 1, 1985:

A. The draft permit establishes an 86 0F max daily effluent limit. The limit is referenced to the NJ Surface Water Quality Standards. This is a misapplication of those standards, which0 states that the temperature is not to exceed 86 F as measured 3500 feet downstream from the receiving waters mixing zone. As the flow schematic on page 36 of 24 pages illustrates, the non-rad waste basin discharges into the non-contact cooling water, which then discharges to the river. Furthermore, the river water temperature alone reaches 860F, on hot summer days. PSE&G has previously submitted this comment to Mr. Paul Kurisko in our letter of 2/15/84. (Attachment II). .

In a telephone conversation with Ms. Melisse Wilusz on February 17, 1984, she indicated that the State was willing to change the 86 F limit to 110 referencing this to the DRBC effluent guidelines. As was stated previously, the DRBC Interpretive Guideline No. I relates to."where readily accessible to human contact".

This discharge is within the plant perimeter in an enclosed piping to the non-contact cooling water.

PSE&G's position is that no temperature discharging limitation on this waste stream should exist.

B. The draft permit is mandating monthly composite samples for chemical oxygen demand. This was applied through best professional judgement (BPJ). A review of the wastes identified by both our application and priority pollutant scans indicate that ammonia would be the primary generator of COD. However, a limit already exists for ammonia of 35 mg/l average monthly and 70 mg/l max. daily. Furthermore, as was already presented the impact of any COD from th'e non-rad waste basin is insignificant because of the flow' ratio of this discharge to that of the non-contact cooling water.

C. The draft permit requires pH to be measured at the outfall from the waste water treatment plant, DSN 48C.

This is contrary to previous agreement to measure pH at the non-contact cooling water discharge utilizing the buffering action of this waste stream. (Refer to attach-ment I for 1979 correspondence between PSE&G and the NJDEP).

1 I

< - e4 Mr. Arnold Schiffman Page 8 ,

February 15, 1984 If this requirement stands, PSE&G would be required to install a neutralizing injection system prior to dis-charging non-rad wastes. This in turn would result in -

increasing the dissolved solids in this waste stream.

In a telephone conversation with Ms. Melisse Wilusz on '

February 17, 1984, she indicated that the State was con-sidering modifying this effluent limit to 6-10 ph but keeping the monitoring point still at the non rad waste outfall. PSE&G's position remains that the buffering action of the non-contact cooling water is the most environmentally sound. PSE&G finds it acceptable to include monitoring at the WTP, but the compliance point should remain at the discharge of the non-contact cooling water.

4. Discharge 48C, Page 19, Part IVr Effluent Limitations in Affect -

after July 1, 1985:

A. Comments previously mentioned for parts 3 (a)-(c) are also applicable here.

B. The draft permit imposes biomonitoring requirements on this discharge stream in the form of a 95 hr. LC 50 toxicity. testing. PSE&G considers such toxicity monitoring as inappropriate:

1) The draft permit's " Statement of Basis",

page 5 of 24 fails to provide the reason for imposing toxicity monitoring.

2) If NJDEP uses EPA Regional Guidance to establish this monitoring requirement and effluent limit, it may be illegal to do so. As was stated previously UWAG has challenged the EPA on this because the use of

guidance letters bypass the public comment period required by the Federal Administrative Procedure Act and CWA section 304 (h).

3) Section 304(h) of the CWA requires that analytical methods are accurate and reproducible before the agency can force dischargers to use them. Presently, there are no EPA regulations establishing valid promulgated toxicity testing methods. There are many factors which influence the results of toxicity testing which bring into question the accuracy and reproducibility of the testing when used for compliance monitoring. Some examples are:

a) Collection and handling of the test fish species b) Salinity and temperature acclamation from holding tanks to the test tank.

r- - -m.+.--m-.m. . -- - --- -

. a l

sy s Mr. Arnold Schiffman Page 9 February 15, 1984 c) Disease problems in the test fish d) Size of test species

4) If the imposition of toxicity testing is being based upon the New Jersey Water Quality Standards, PSE&G would strongly protest this as a misapplication of those standards. This effluent does not discharge directly to the river. The non-rad waste basin effluent's only interaction with the aquatic biota of the Delaware is by proportion of its ef fluent to that of the non contact cooling water flow. As was pointed out previously, this proportion is approxi-Considering the 50% lethal limit mately 1 to 1400.

is what the state applies to its water' quality .

standards; this is equivalent to a .036% lethal limit at the non rad waste discharge.

5) In our NJPDES renewal application for this permit, the toxic pollutants have been identified through the priority pollutant scans. These are below federal acute toxicity levels. New Jersey's Surface Water Quality Standards N.J.A.C. 7:9-5.4(c) states:

"The following are statements of policy concerning bioassay procedures:

1. 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> modified static or 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> flow-through bioassay will be utilized as definitive bioassays in determining the impact of a wastewater discharge which is presumed to be toxic to aquatic life."

Since these pollutants are below the acute toxicity levels, and coupled with the additional dilution of the non-contact cool ng water, and using the above NJDEP policy statement, it is inconsistent that any toxicity testing is; required.

6) The priority pollutant scahs of the river indicate that there are pollutants more toxic than the pollutants in this waste stream. The dilution water used in the toxicity test could adversely impact on the results and evaluation of overall test results.

4

^

v., m.m_y..-e _ -

m.-- . - , , , ,

e.

vts Mr. Arnold Schiffman

.Page 10 February 15, 1984 ,

7) The non-rad waste discharge is mostly demineralized well water whereas the Delaware River in the vicinity of Salem ranges in salinity of .5 to 20.0 ppt depending on seasonal changes affecting the magnitude of freshwater input into the Delaware system as a whole. Therefore, any toxicity testing on this waste stream would not.be reflective of the aquatic environment surrounding Salem no matter which test species was chosen.

5. Discharge 487, Page 15, Part IV:

A. The draft permit rsquires grab sampling for flow. This system comprises an underground concrete collection pit with an oil / water separator. The overflow discREPye flows by gravity feed to the river by underground piping. -

There is no practical manner to install a flow device in this system. In addition, the flow from this point source is at a maximum of .02 MGD which is primarily from the discharge of 487A (the sewage treatment plant) which does have a flow monitoring device and which is required to monitor flow by the draft permit on a daily grab basis.

B. In the draft permit, the temperature of the effluent is 4

to be limited to 860F. According to the draft permit, this is based upon the 1978 EPA Regional Guidance letter.

PSE&G has already stated UWAG's position questioning the legality of. mandating limits based upon these guidance letters.

From a practical standpoint, even the N.J. Surface Water Quality Standards only. apply such a temperature limita-tion as being applicable to a measurement 3500 feet down-stream from the receiving waters mixing zone. The DRBC limit of 1100F from interpretive guideline No. I would be the only applicable limitation because of its dis-I charge right at the shoreline and within.l.5 feet under the surface of the river.

Tha draft permit limits COD to 100 mg/1. Again this C. . was applied using the 1978 Regional Guidance letter. -

Our comment II-5(b) previously mentioned, is also applic-1 l

able here.

l

. -- . - - . . - . - .- n ,

FL ..

e . pi Mr. Arnold Schiffman Page 11 February 15, 1984 D. The draft permit establishes a maximum daily total suspended solids limit of 45 mg/1. Our comment II-2 (e) is a' Iso app;icable here.

6. Discharge 487A, Page 16, Part IV:

PSEEG accepts the limits established for this discha'rge.

7. Discharge 489, Page 17, Part IV:

PSEEG's comments 5 (a), (c) and (d) are equally applicable to the draft limits for this discharge.

If you have any questions concerning these comments, please call Eric Svenson at (201) 430-5860.

Sincerely, s

9 6,m

TO PSEGiE1 80 Park Plaza, Newark, NJ 07101/ 201430 5858 MAILING ADDRESS / P O. Box 570. Newark. NJ 07101

[

G' James A. Shissias General Manager Environmental Affairs

. November 14, 1985 Administrator Water Quality Management Element Division of Water Resources NJ Department of Environmental Protection CN-029 Trenton, New Jersey 08625

Dear Sir:

REQUEST FOR ADJUDICATORY HEARING NJPDES DSW PERMIT NO. NJ 0005622 SALEM GENERATING STATION This is to acknowledge receipt on October 18, 1985 of the Final NJPDES/DSW Permit Number NJ0005622 for Salem Generating Station.

In accordance with the provisions of NJAC 7:14A-8.9, et seq.,

Public Service Electric and Gas Company hereby requests an adjudi-catory hearing to consider issues relating to the imposition of .

certain conditions contained in the Final Permit.

('M

('_) The specific contested factual questions and permit conditions proposed for adjudication are set forth in this request and in the attachments. Where appropriate, we have included suggested revised or alternative permit conditions which would, in the judgment of the permittee, properly implement the purposes and policies of applicable New Jersey and federal law. Additional information in support of the within request appears in the administrative record as such record is defined in NJAC 7:14A-8.8. Because significant portions of the subject Final Permit are at issue, the necessary hearing time for adjudication cannot be estimated with accuracy but we estimated should not exceed two days.

It is the opinion of the permittee that the contested parameters, limits, and sampling requirements contained in the subject Final Permit exceed standards needed to protect the environmental balance and quality of the Delaware River. Further, multiple bases have been incorrectly applied in determining permit parameters and their limits. Such has been the case with the Department's heavy reliance on EPA Region II " Regional Guidance" and "Best Professional Judgment" which makes this permit inconsistent with other permits issued within EPA Regions II and III and the Delaware River Basin as administered by DRBC. Comments on the original draft permit, which are part of the administrative record, indicate that certain standard conditions in the Final Permit do not relate to the operation of Salem Generating Station. Any such unrelated standard conditions

(,.s' should be deleted. Finally, the permittee questions the N establishment of permit conditions and limitations that were not part of the issuance of the draft permit. The permittee requests that such conditions and limitations be amended and/or deleted.

-3  :, 2-y a e M 5JU0 s WO

Page 2-

. .

• November 14, 1985

[ The permittee contends'that Permit requirements to protect the

\ environment.should reflect the potential effect that the discharge from the facility will have on the environment. Excessive, redundant, inappropriate, and unnecessary limits or requirements do not serve the purpose of applicable New Jersey and federal law and are unnecessarily costly. Internal corporate administrative controls, those established to comply with the Nuclear Regulatory Commission, Federal and State Spill Regulations, and Worker and Community .

Right-to-Know regulate the release of all substances that could aftect the quality of the discharge from the~ Station. In addition, the New Jersey Board of Public Utilities has-mandated that the permittee institute cost effective measures to avoid or delay rate increases that result in higher electric energy costs to the citizens of New Jersey. A substantial financial impact on both the permittee

- and the electrical consumers of New Jersey will result from the imposition of these contested permit conditions.

The subject Final Permit is scheduled to be ef fective on December 1, 1985. Pursuant to NJAC 7:14A-8.10, Public Service Electric and Gas Company hereby applies for a stay of each and every contested permit condition pending resolution of this appeal. Such stays should be granted since the Final Permit does not contain conditions which address any environmental issues which could,-if unresolved, pose an environmental threat or impact any irreplaceable resources. More.-

l

-over, the existing Permit is currently providing effective environmental

/ protection for those issues on which a stay is requested and would be (ms)/ complied with in accordance with NJAC 7:14A-8.19(c) during the period of the stay until a determination of those issues is made.

In accordance with NJAC 7:14A-8.9(c)4, all persons contemplated by subsections i, ii, and iii thereof shall be made available by the permittee to appear and testify without cost or expense to any party upon motion of any party or upon order of the Administrative Law Judge 4

or the Judge's own motion. .

. Representatives of Public Service Electric and Gas Company are available ,

to meet with you or your representatives to review, discuss, and, hope- I i

fully, resolve any of the matters raised by the Request for an Adjudicatory Hea ring.

Respectfully submitted,

~JT .Y., M!EU EY:

4.t$.C. Cinh3 Genertl Managar - Ewironmental Affairs cc: Paul Kurisko bec: Vice President-Nuclear 1

Assistant Vice President-Nuclear Operations Support General Manager-Nuclear Licensing and Assurance Manager-Nuclear Licensing and Assurance l' General Manager-Salem Operations General Attorney-Law Department Licensing Manager - Nuclear Assurance and Regulation

^O 'J.H. Balletto, R. Dolan, A.P. Graham, Carl Sulzberger, Esq.

g e , SALEM GENERATING STATION NJPDES DSW PERMIT NO. NJ 0005622 CONTESTED PERMIT CONDITIONS

( l. = CONTESTED PERMIT CONDITION: General Conditions for all NJPDES Discharge Permits, Part I, Page 10 of 16, Item 14f(6).

ISSUE: The wording in the above cited section requires all maximum daily discharge limitation violations to be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. NJAC 7:14A-3.13(a)7, on which this requiy+ ment was based reads " Pollutants for which the permittee must report violations of maximum daily discharge limitations under NJAC 7:14A-3.10(a) 6 shall be listed as such in the permit."

ALTERNATIVE PERMIT CONDITIONS: Revise the wording to reflect the language as it appears in NJAC 7:14A-3.13(a)7 and specifically identify those parameters requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification.

II. CONTESTED PERMIT CONDITION: Non-contact cooling water effluent limits (DSN 481-486):

(a) Page 1 of 7, Part III, Item 1.A Effluent Limitations and Monitoring Requirements, Discharge Serial Numbers 481, 482, 483, 484, 485 and 486.

ISSUE

The imposition of a gross limit for Petroleum Hydrocarbons

' is excessive and inappropriate for once-through cooling water -

- discharges. It is more likely that the probable source of

1. O Petroleum Hydrocarbons will be the river itself. As such, this limit should be on a " net" basis or deleted.

The sampling frequency for Total Residual Chlorine is excessive in relation to the controlled nature of the main condenser and service water discharges.

The imposition of a .2 mg/l TRC limit on the service water dis-charge prior to mixing requires sampling connections be installed

- on the existing buried service water piping (a total of six pipes). This installation will be expensive because of the excavation required, and the moving of equipment to obtain access in the area excavation. In addition, both Salem Nuclear Units will have to be'out of service to physically install the sample connections which would result in a very expensive expenditure for the Company and the rate payers. The Company believes it more 3

appropriate for the reasons stated above and by the Company's August 9, 1984 letter to the Department to impose the .2 mg /l TRC limit for the Service Water system at the point of compliance for Discharges 481-486.

The establishment of a 110 degree F maximum temperature limita-tion is inappropriate since the DRBC Regulations on which this

. limitation was based specify such a temperature limit for situations where the effluent is readily accessible to human contact. The discharge piping for the non-contact cooling water i discharges are on the bottom of the river, 500 feet from shore and 42 feet under the surface of the Delaware River.

-,ww -

rz-,. , - . - - , , _ , - - , _ . . - . , . .

' ^

The COD limitation is unnecessary. The only possible sources

['~' ^) of COD will be either the river itself or the non-rad waste basin. Any contribution from the non-rad waste basin will 1 be non-detectable in the non-contact cooling water because of the I ratio of the flow volumes involved. In addition, the cited l basis for this limit was an EPA Regional Guidance document which inappropriately bypasses normal rulemaking procedures for As such, establishing such "across-the-board" limitations.

the regulated community has not been afforded the opportunity of evaluating whether such conditions and limitations stand up to scientific scrutiny.

ALTERNATIVE PERMIT CONDITION: Refer to Attachments A.1-A.2 III. CONTESTED PERMIT CONDITION: Storm Water, Aux. Boiler Blowdown, and Sewage Treatment Plant combined effluent -

(a) Effluent Limitations and Monitoring Requirements, DSN 487, Page 2 of 7, Part III, Item 1.B.

ISSUE: The sampling requirement imposed is unrealistic.

The discharge is comprised of reveral other flows rather than just stormwater. The present pe'rmit wording, to sample during the first precipitation event which causes a discharge, needs modification to reflect the combined nature of this dis- -

charge.

D 5-% The Temperature and COD limits have been based on an EPA Regional Guidance document. As has previously been stated, such guidance documents when used to establish "across-the-board" limits for all permittees cannot bypass normal rulemaking procedures. As such, the regulated community has not been afforded the opportunity of evaluating whether such conditions and limitations stand up to scientific scrutiny.

ALTERNATIVE PERMIT CONDITION: Refer to Attachment B.

IV. CONTESTED PERMIT CONDITION: Sewage Treatment Plant (a) Page 5 of 7, Part III, l.C Effluent Limitations and Monitoring Requirements, DSN 487A.

ISSUE: A flow limitation has been established at .2 MGD.

In previous correspondence, the Department stated that this limit would be .02 MGD. If this limit was meant to be .02 MGD, the Company challenges this value as being overly restrictive.

The Sewage Treatment Plant is designed to run at a continuous design flow of 35,000 gallons per day. The average of the pre-vious monthly Discharge Monitoring Reports tabulate a flow equal to .0 29 MGD.

ALTERNATIVE PERMIT CONDITION: Set average monthly Flow Limitation

(-]/

(, equal to .035 MGD

• • i / h V. CONTESTED PERMIT CONDITION: Storm Water Discharge O

(a) Page 4 of 7, Part III, 1.D Effluent Limitations and Monitoring Requirements, DSN 489.

ISSUE: The COD limitation has been based on an EPA Regional Guidance document. The appropriateness of establishing permit limits in such an "across-the-board" manner bypasses the proper rulemaking process. As such, the regulated community has not been afforded the opportunity of evaluating whether such conditions and limitations stand up to scientific scrutiny.

ALTERNATIVE PERMIT CONDITION: Delete COD requirement.

VI. CONTESTED PERMIT CONDITION: Non-Radioactive Waste Basin effluent limits:

(a) Page 5 of 7, Part III, Item 1.E - Effluent Limitations and Monitoring Requirements, Discharge Serial Number: 48C.

ISSUE: The imposition of COD, Chromium, Toxicity (bioassay) limits and sampling requirements are inappropriate and excessive for this discharge. The Department has incorrectly used multiple bases for imposing these parameters in the permit. The imposition of these parameters and limits are inconsistent with other Final

/~T Permits issued within EPA Regions II and III.

The imposition of the point of compliance for pH to be the point of discharge of the WTP is also excessive and inappropriate, especially since the environment derives no benefit from this requirement. Using the non-contact cooling water to buffer the WTP pH has long been an accepted practice (most recent correspondence with EPA dated October 18, 1985 - Attachment D).

This new requirement would necessitate the installation of extra treatment equipment to add extra chemicals which would result in additional TDS being discharged. Furthermore, this new requirement may adversely impact the level of metal removal treatability of the Non-Rad Waste Basin.

ALTERNATIVE PERMIT CONDITION: Refer to Attachment C.

VII. CONTESTED PERMIT CONDITION: N2 Operator (a) Part IV, Page 1 of 6. Additional Requirements of this Permit, A. Operation of Treatment Works.

ISSUE: The Final Permit states, "The operation of the treatment works shall be under the continual supervision of an operator.

The industrial operator shall meet the requirements of the Department of Environmental Protection of the State of New Jersey

. for an N2 license."

f--

-V l

+ - - . + - -- - , - s -- , e ,

.J ** i

,O The assignment of the N2 classification to the operator of the Non-Rad Waste Basin has primarily been based upon an EPA

> toxicity rating system that groups industrial facilities into

toxicity groups. As such, Salem Generating Station has been

-required to obtain a higher classification license than is actually needed.to operate the waste treatment plant.

ALTERNATIVE PERMIT CONDITION: The operator classification

specified in the permit should be an N1 rather than an N2.

I- VIII. CONTESTED PERMIT CONDITION: Biomonitoring Requirements (a) Page 4 of 6, Part IV, Acute Toxicity ISSUE: The requirement to perform acute bioassay testing on the waste treatment plant effluent is inappropriate since this discharge is an internal waste stream. Furthermore, without some clarification in wording such testing becomes more a measure of pH toxicity rather than that of the other ,

components of this waste stream.

f In addition, the Department's designated test species, Mysid Shrimp, is inappropriate for Salem Generating Station.

' ALTERNATIVE PERMIT CONDITION. The requirement for bioassay testing should be deleted.

IX. CONTESTED PERMIT CONDITION: Industrial Waste Management Facility

' Classification (a) Pages 1 through 9, Part V, Additional Requirements for an Industrial Waste Management Facility ISSUE: Salem Generating Station has been classified an Industrial Waste Management Facility by the Division of Water Resources because the facility is technically still registered as a RCRA TSD facility. Furthermore, the facility does l not meet-the definition of an IWMF as specified by NJAC 7:14A-4.2.

On March 4, 1983, Public Service Electric and Gas Company in a letter to DEP's Division of Waste Management requested the withdrawal from RCRA interim TSD status. DEP has failed to take action on this matter. It is inappropriate for DEP to classify the facility an IWMF when the delays in declassification'or delisting of the interim status rests with the agency itself.

ALTERNATIVE PERMIT CONDITION: Delete IWMF requirements from this permit.

O V

, , _ - e i p -s-O X. CONTESTED PERMIT CONDITION: Compliance With Other Requirements (a) Page 2 of 6, part IV, Additional Requirements of This Permit, Item 1(e)2.

(b) Page 2 of 6, part IV, Additional Requirements of This Permit, Item 1(h).

ISSUE: The US Nuclear Regulatory Commission (USNRC) has federal preemption of the regulation of nuclear material for the health and safety of the public. Salem Generating Station is accountable to the USNRC for these requirements and it is felt that the additional State requirements do not add to the safe operation of the facility, but instead impose an additional regulatory and administrative burden.

ALTERNATIVE PERMIT CONDITION: Delete these requirements from the NJPDES permit.

(s 4

v

ATTACNMENT A.!

Page 1 ot 7 pages I.A Permit No. NJ0005622 E F FIE EN T,L I,M l_ TAT,10,NS AND MON 1 TOR _ING, _R_EQU!R,EME,N,TS Part !!! - BK During the the period permittee beginning EDP and lasting through EDP + 5 years is authorized to discharge from outfallis) serial nrmher(s) 481, 482, 483, 484, 485 and 486.

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

EI I I._ue n,t_ _Ch_a ra_c t e r_i n t i c Discharge Limitation Monitorinu Requirements kgs / day ( I bs / day ) other units (specified) Measurement Avg. Monthly Max. Daily Avg. Sample Max. Frequency Monthly Type Daily Flow-m 3 /da y (MGD) N /A Temperature, Influent"F ("C) N /A N /A N /A N /A Continuous Temperature, Effluent "P ("C)* N /A N /A N /A N /A Continuous Temperature, Diff. F("C)8 N /A N /A N /A N /A  !!S (46.1) Continuous Heat, Facility ( MBTU /h r. )

• N /A N /A 27.5 (15.3) Calculated N /A Total Suspended Solids ( mg /1 ) *

• N /A N /A N /A 30,600 Calculated Petroleum Hydrocarbons (mg /1 ) 30 45** Monthly N /A N /A Grab Chlorine-Free Available N /A N /A N /A 10 Net Monthly Grab

( mg /l ) **** 0.2 U.5 Continuous during periods Chlorine-Total ****

Residual N /A N/A of Chlorination (mg /l ) N /A 0.2 ****

Grab See Part IV, Section 1, I and J for clarification of thermal limitations and DMR reporting methods.

Total Suspended Solids shall not exceed 45 mg/l on a 7-day average. The limitations are net values.

TRC samples shall be taken as indicated in Part I V,Section I, F and 3.B.

The pH shall not be samples. less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored weekly using grab 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 At the outfalls of discharges 481, 482, 483, 484, 485 and 486. taken at the following locations (s):

l

.y u .

I

(_/ ATTACHMENT A.2 Part IV - B /C Page 2 of 6 Permit No. NJ0005622 E. State and Local Requirements Hazardous Waste Management

~

1.

> The permittee shall store, transfer, and dispose of its hazardous wastes in compliance with the " Manifest" provisions pursuant to N.J.A.C. 7:26-1 et seq.

F.1. Total residual chlorine may not be discharged from any single generating unit for more than two hours per day. However, since the_ permittee has demonstrated that the service water system, a nucear safety related system, has a mac,ro invertebrate fouling problem, TRC discharges in excesslof two hours per day are allowed to accommodate continuous chlorination of the service water system, -

provided that TRC discharges resulting from the main cooling condenser cooling water chlorination do not exceed two hours per

()

day.

2. Monitoring for TRC from the main condensers shall be performed on each outfall (DSN 481-486) during the chlorination of the main condensers. Monitoring for TRC from the Service Water System shall be performed weekly during each eight (8) hour period of chlorination of the service water system monitored at outfalls DSN 481-486.

.3. The permittee shall maintain a log noting the time and duration of chlorination of the main condensers.

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

4

() l

ATTACHMEZT O. Page 2 et 7 page]

P;rmit No. NJ UUU 5622 Part I I I-B /C 1.H EFfLQEN_T_LINITATIONS_AND MONITOR _ING REQUIREMENTS ,

During the period beginning EDP and lasting through EDP + 5 years the permittee is authorized to discharge from outfall(s) serial number (s) 487 such discharges shall be limited and monitored by the permittee as specified below:

Effluent Characteristic Discharge Limitation Monitoring Requirement kgs / day (lbs/ day) other units (specified)

Measurement Sample Avg. Monthly Max. Da i ly Avg. Max. Frequency Type Monthly Daily F low-m 3 /da y (MGDI N /A N /A N /A N /A Monthly Grab Temperature-Eff. OF (DC) N /A N /A N /A 110 (43.31 Monthly **** Grab Petroleum Hydrocarbons ( mg /1 ) N /A N /A 10 15 Monthly Multiple Grab Total Suspended Solids ( rm3 /l ) N /A N /A 30,45* 100 Monthly Grab Total Suspended Solids shall not exceed 45 mg/l as a 7 day average.

Temperature shall be monitored when boiler blowdown is discharged.

The pH shall not be samples.** less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored monthly using grab 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):

at the outfall of discharge 487.

. O O O

ATTACHMENT C.

Page 5 of 7 pages Permit No. NJ0005622 Part !!!-B/C 1.R Eff_L_UENT LIMITATIONS AND MONITORING _ REQUIREMENTS During the period beginning EDP and lasting through EDP + 5 years the permittee is authorized to discharge from outfall(s) serial number (s) 48C Such discharges shall be limited and monitored by the permittee as specified below:

Effluent Characteristic D_ischarge Limitation Monitoring Requirements kgs/ day (Ibs/ day) other units (specifled)

Measurement Sample Avg. Monthly Max. Daily Avg. Max. Frequency Type Monthly Daily F low-m 3 / day (MGD) N /A N /A N /A N /A Continuous --

Temperature "F (OC) N /A N/A N /A N /A Monthly Grab Total Suspended Solids (mg /1 ) N /A N /A 30,45* 100 Twice Monthly Composite Petroleum Hydrocarbons (mg /1 ) N /A N /A 10 15 Twice Monthly Grab Ammonia as NH 4 (mg /l ) N /A N/A 35 70 Twice Monthly Grab Copper (mg /l ) N /A N /A N /A 0.2 Twice Monthly Composite Zinc (mg /l ) N/A N /A N /A U.6 Twice Monthly Composite tron (mg /l ) N /A N /A N /A  !.0 Twice Monthly Composite The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units after buffering with the main condenser cooling water and shall be monitored monthly at the discharge of DSN 481-486 using grab samples.

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):

At the outfall from the wastewater treatment plant, DSN 4HC.

• • Total Suspended Solids shall not exceed 45 mg/l on a 7-day average.

Upon written request from the permittee, this limit may be changed to 20mg/l of Total organic Carbon.

9

= *

~ - - - -- FMM D

• r.A-( l-D I) + ] p g .y_

P$e+% G4V AFFA/R6 AUTO . TEL.$rc.o pf.g=q T ( 0 c-O y$ /*h*%

W ~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY wasMINGTON, D.C. ao460 OCT I 81995 Mr. Louis Canziani New York State

• Department of Environmental Conservation '

Room 6126 Two World Trade Center New York. NY 10047

Dear Mr. Canziani:

' I This is to confirm our recent conversation regarding $

. effluent limitations guidelines for the steam electric power t .,

industry (40 CFR Part 423).

s In my letter of June 22, 1984 to Ms. Ursula Basch of -

your office, I summarized the applicability of the steam electric regulation pH limitation as applicable to low volume .

waste streams when such wastewaters are commingled with a (once-through) cooling waters. The interpretation that I provided was not in accord with prior information and instruc-tions provided to EPA and State permitting authorities on _

this subject. ,

Y l The pH limitation per Part 423 applies at the "and-of- '

{

pipe" discharge to surface waters when the wastewater discharge

• l contains low volume wastewater that is commingled' with once-

' l through cooling water. However, the intent of Part 423 is ,'

also that the total suspended solids and oil and grease limitations applicabla.to low volume wasta streams be applied to the low' volume ' waste component of such a combined discharge prior to comm.ingling of the individual waste streams.

I apologize. for any confusion in perm.it development or .I delays in permit issuance that may have occurred in this matter. If you have any further questions, please contact me at (202) 382-7131. -

. . l Sincerely, fDennis Ruddy' __

-J Project Officer '

Industrial Technology Division

~O l

l t

. l l

l

- ATI7 chm E ,~ .

~

' ~O PSEG!Em S0 Park Plaza, Newark, NJ 07101/ 201430 5858 M Af LING ADDRESS / P O Box 570. Newark. NJ 07:01 James A.Shissias General Manager Environmental Affairs November 7, 1985 Mr. David Schrier Bureau of Hazardous Waste Classification and Manifest Division of Waste Management Department of Environmental Protection 32 E. Hanover Street Trenton, NJ 08625 Dear Mr. Schrier WITHDRAWAL OF TSDF INTERIM STATUS FOR ,

SALEM NUCLEAR GENERATING STATION EPA ID. NO. NJD 077070811

(

on March 4, 1983 this office submitted to the Bureau of Hazardous Waste Engineering a request for TSDF interim status withdrawal for Salem Generating Station. On March 23, 1983 the Bureau of Hazardous Waste Engineering informed this offica that the request had been forwarded to the Bureau of Hazardous Waste Classification and Manifest and to the Industrial Treatment Works Section of the Division of Water Resources for review of the declassification and delisting request. (See attached letters along with waste analyses and the Part A application) .

On October 16, 1985 the Division of Water Resources issued a NJPDES Permit with Industrial Waste Management Facility provisions for Salem Generating Station to become effective on December 1, 1985. This permit was issued because the facility in question was still a TSDF under interim status, since no action had been taken on our delisting request.

This matter was discussed with Mr. Edward Post, Section Chief Industrial NJPDES Permits of the Division of Water Resources. He indicated that the IWMF classification would be withdrawn as soon as your group delists the facility as an interim status TSDF. In addition at a recent inspection of the Salem Generating Station Mary Jorgensen, DWM Southern Field Office, states that the

~ facility did not require TSDF interim status and that she would note this in her report and subsequently recommend that it be x'

removed from interim status.

" s 5 M r q. = = ? c 4 95 5XG A7.f J 5:*

i

~

Mr. D. Schrier 11/7/85 l

In light of the circumstanas noted and the limited time between now and December 1, 1985 we would appreciate any effort to  !

expedite our request for delisting.

If you need any additional information you can call me or Mr. Ronald F. Venturi at (201) 430-5865.

l Sincerely yours,

/f- "

CC E. Post - NJ DEP F. Coolick - NJ DEP BCC J. Balletto' R. Venturi. -

O O-