ML20203F996

Annual Environ Operating Rept for 1985

ML20203F996
Person / Time
Site:	Palisades
Issue date:	12/31/1985
From:	Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8604280204
Download: ML20203F996 (31)

Text

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. - g, ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 1985 ANNUAL ENVIRONMENTAL OPERATING REPORT January 1 - December 31, 1985 f

25 Pages i

M 2SO204 851231 gDR ADOCK 05000255 '

PDR .,

.OC0486-0068-NLO2

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b Palisades Nuclear Plant Annual Non-Radiological Environmental Operating Report

1.0 BACKGROUND

Appendix B to Provisional Operating License Number DPR-20 for the =

Palisades Nuclear Plant, Consumers Power Company, is entitled " Environ- c mental Protection Plan (Non-Radiological)". This document requires Consumers Power Company to submit to the Nuclear Regulatory Commission '

an Annual Environmental Operating Report prior to May 1 of each year which describes implementation of the Environmental Protection Plan.

The period covered by this annual report is January 1 to December 31, 1985.

The Plant operated at greater than 90% of the demonstrated capacity from p January I until November 30. The Plant was shutdown during December for refueling. The reactor was critical for 7,490 hours0.00567 days <br />0.136 hours <br />8.101852e-4 weeks <br />1.86445e-4 months <br /> and the generator was on line for 7,344 hours0.00398 days <br />0.0956 hours <br />5.687831e-4 weeks <br />1.30892e-4 months <br /> producing 5.6 giga watt hours gross electri-cal power (5.3 GWH net). .

The operation of the Palisades Plant did not result in any overall ,

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impact on the envitonment surrounding the Plant. h b

2.0 ENVIRONMENTAL IMPACT EVALUATIONS Evaluations of environmental inpact were performed on two major con-struction activities during 1985. These evaluations did not involve any previously unreviewed environmentai questions. Summaries of the activi-ties and the evaluations performed are included in Appendix A.

3.0 UNUSUAL ENVIRONMENTAL EVENTS On September 6, twenty-two small birds were found to have died near the Palisades Support Building. Six of the birds were submitted for analy-l sis to the Michigan Animal Health Diagnostic Laboratory. The lab determined that the birds died from skull fractures. The evaluation of this incident indicated that the birds probably flew into the closed windows of the Support Building as this is a common occurrence with migratory birds. This event was determined not to be related in any manner to the operation of the Plant.

I RP0286-0033A-OP02

• O 4.0- ENVIRONMENTAL MONITORING 4.1 Meteorological Monitoring to Document Effects of Cooling Tower Operation on Meteorological Variables No activities in this area for 1985.

4.2 _ Herbicide Application Herbicide applications to brush and trees along the exit corridor of Line.306B (Palisades-Tallmadge #1) was completed in June 1985.

Brush control treatments along this 345 k" transmission line are on an approximate six year cycle. The work was conducted by Davey Tree Expert Company under General Office Forestry supervision.

Treatments consisted of foliage spraying with Tordon 101 (Picloram and 2,4-D) in a 1% solution with water or mixed with Garlon 4 (Triclopyr) at a rate of two quarts Tordon 101 plus one quart Garlon 4 in 991 gallons of water. Application rate was between 66 and 200 gallons per acre depending on brush size and density.

Scattered and larger trees and brush were cut or frilled and treated to prevent sprout and sucker regrowth. Approximately.five pints of Tordon RTU (Picloram and 2,4-D) and two pints of Banvel CST (Dicamba) were used for these treatments. A total of 24.24 acres along the exit corridor of Line 306B were treated with

-herbicides in 1985.

All herbicides, treatment methods, rates, etc., are in accordance with Federal and State pesticide use regulations. Records and additional information on these herbicide treatments are available from General Office Forestry.

5.0 REVISED PERMITS The Michigan Department of Natural Resourses reissued the Plant NPDES Permit en May 21, 1985. A copy of this permit was provided to USNRC by letter dated August 1, 1985. The reissued NPDES Permit is included as Appendix B.

6.0 NON-ROUTINE REPORTS  !

6.1 Spills Reported During 1985 In compliance with State and Federal spill reporting requirements, fourteen spill incidents were reported to the Michigan Department of Natural Resources during 1985. A summary of the spill events is contained in Appendix C.

6.2 NPDES Compliance In accordance with NPDES reporting requirement, eighteen NPDES Notification Reports were submitted to the Michigan Department of Natural Resources. These reports are summarized in Appendix D.

RP0286-0033A-OP02

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APPENDIX A OC0486-0068-NLO2

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Appendix A Environmental Evaluations Security Intrusion Alarm Modification This modification required removal of an additional 30 feet of the north dune.

The sand removed in cutting back the dune was placed in a spoils area adjacent to the dune. This spoils area was used for original site grading. The entire area was surveyed by the Company's Terrestrial Biologist and the closest occurrence of the endangered species " Pitchers Thistle" was over 400 feet to l the north. In order to protect the environment for these plants, the area was i roped off. Construction Permits obtained te perform the work were as follows:

l VB Soil Erosion and Sedimentation Permit 80101020 l

Michigan Department of Natural Resources Permit 85-12-116G Shore Erosion Stabilization Project Triangular concrete prisms and rock fill material was placed at the shore line from the mixing basin north to the protected area north boundary. It was determined that there was minimal environmental impact associated with this proj ect. Construction Permits obtained to perform the work were as follows:

Army Corporation of Engineero Regional Permit 80-200-1 Michigan Department of Natural Resources Permit 85-12-116G RP0286-0033A-0P02

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l APPENDIX B l

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- 000486-0068-NLO2 L-_.___-.___

STATE OF MICHIGAN APPENDIX B

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4ATURAL RESOURCES CChateS$tose y,sj g eensos. JAMES J. BLANCHARD, Govemor

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r 'f3 3 f DEPARTMENT OF NATURAL RESOURCES o STEWART WVERS STEVENS T. MASON SULDING I.

mAvuom.o poupoat Box 3

_m.. u~s,No. 002s.

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r CERTIFIED MAIL f .ETUFiN May 31, 1985 t ECElPT I EQUESTED v.

P. i CERTIFIED MAIL 6-Consumers Power Company - -

212 West Michigan Avenue Jackson, Michigan 49201 Re: NPDES Permit No. MI 0001457 Palisades Plant. Covert Michigan

Dear Gentlemen:

Your application for a National Pollutant Discharge Elimination System (NPDES) Permit has been processed in accordance with appropriate state and federal regulations.

Your NPDES Permit contains: 1) limitations which require you to monitor your effluent in accordance with Part I, Section A; and 2) a schedule of compliance for submittal of information concerning other permit require-ments.

REVIEW THE PERMIT EFFLUENT LIMITS AND PERFORMANCE SCHEDULES CAREFULLY.

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

Your monitoring and reporting responsibilities shall be complied with in accordance with Part I, Section B of this permit. If spplicable, monthly operating report forms will be transmitted to you in the near future.

These reports are to be submitted monthly or otherwise as required by your NPDES permit.

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

N Fred Morley, District Supervisor 621 North Tenth Street P.O. Box 355 Plainwell, Michigan 49080 Telephone: (616) 685-9886 f,"' @*

Consumers Power Company May 31, 1985-Page 2 NOTE: All referen'ces within this permit made to the Water Quality Division or Chief of the Water Quality Division are to refer to the Surface Water Quality Division or Chief of the Surface Water Quality Division, respectively.

Sincerely, Yl11l1l~. $ k h/_ sl._om William E. McCracken, P.E.

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

Enclosure:

Permit cc: EPA-Region V (2)

Files Water Quality Surveillance Compliance Section #1 Fred Morley - Plainwell District Land Application Unit 208 Agency - Southwest Michigan Regional Planning Commission

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9 Permit No. MI 0001457 MICHIGAN WATER RESOURCES COMMISSION AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provi,sion of the Federal Water Pollution Control Act, as amended, (33, U.S.C.1251 et seq; the "Act"), and the Michigan Water Resources Comission Act, as amended. (Act 245, Public Acts of 1929, as amended, the " Michigan Act"),

Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 is authorized to discharge from a facility located at Palisades Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 to receiving water named Lake Michigan in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I and II hereof.

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

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

This permit and the authorization to discharge shall expira at midnight April 30. 1990 .

In order to receive authorization to discharge beyond the date of expiration, the permittee shall submit such information and forms as are required by the Michigan Water Resources Comission no later than 180 days prior to the date of expiration.

! This pemit is based on an application dated March 27, 1980 and uodated October 18, l'D4 ,and snall supersede any and all Orders of Determination, Stipulation, Final Orders of Detemination, or NPDES Pemits previously adopted by the Michigan Water Resources Comission.

Issued this 21st day of May 1985 , by the Michigan Water Resources Comission superseding NPDES Permit No. MI 0001457 , expiring September 30, 1980.

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Permit No. MI 0001457 Page 2 of 9 PART I A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS ,

1. Final Effluent Limitations - Outfall 001 (mixing basin cischarge)

During the period beginning on the effective date of this permit and lasting until the expiration of this permit, the permittee is authorized to discharge a maximum of one hundred thirty-five million two hundied thousand (135,200,000)* gallons per day of treated wastewater through the mixing basiet outfall 001 to Lake Michigan consisting of the combination of the following defined individual discharges:

Internal Outfall Descriptions Maximum Flow (MGD)*

00A - South cooling tower suction basin overflow 25.9 008 - North cooling tower suction basin overflow 23.8 OOC - Cooling tower blowdown 86.0 000 - Radwaste wastewater 0.1 00E - Neutralizer tank wastewater 0.1

,, 00F - Turbine sump oil separator including 0.1 Volume Reduction System

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

The discharge shall be limited and monitored by the permittee as specified below:

Discharge Limitations kg/ day (lbs/ day) Other Limitations Monitoring Requirements Montnly Daily Montnly Daily Measurement Sample Effluent Type Characteristic Average Maximum Average Maximum Frequency 3

Flow, M / Day (MGD) Daily Temperature (OF)

Intake Daily Continuous **

Discharge Daily Continuous **

Heat Discharge Rate 1.3 x 109 BTU /hr Daily Calculation In addition to the Heat Discharge Rate limitations specified above, the discharce shall not' increase the temperature of Lake Michigan at the edge of a mixing . zone equivalent to 72 acres (a defined area equivalent to that of a circle of radius of 1,000 feet) more than 30 above the e,xisting natural temperature or above the following monthly maximum temperature:

MAR APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB 45 45 45 55 60 70 80 80 80 65 60 50 Outfall Observation *** Daily Visual

• • 0nce per shift (3 times daily) grab sample measurement is oermissible when either the continuous monitor or recorder is out of service for calibration or repair.

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

7 Pennit No. MI 0001457 Page 3 of 9 PART I-A Discharge Limitations kg/ day (lbs/ day) Other Limitations Monitoring Recuirements Effluent Monthly

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Daily Monthly Daily Measurement sample Characteristic Average Maximum Average Maximum Frecuency Type Total Residual Chlorine (TRC) Three grab Issuance date to May 31, 1987 0.2 mg/l Per occurrence samples After June 1, 1987 equally 0.1 mg/l 0.2 mg/l Per occurrence June 1 - Seotember 30 spaced during October 1 - May 31 0.05 mg/l 0.2 mg/l Per occurrence chlorination Chlorine Application Time **** 120 mins. Report applica-tion time -

• • • • The amount of chlorine applied shall be limited to the minimum amount needed to prevent biofouling. The pernittee may use dechlorination techniques to achieve the applicable limitations, using sodium thiosulfate or sodium sulfite as dechlorination reagents. The quantity of reagent used shall be limited to 1.5 times the stoichiometric amount needed for dechlorination. The pemittee shall report monthly the quantity of i each dechlorination reagent used per day.

The " monthly average" value for TRC shall be calculated by detennining the mean value of all TRC analyses done during the month. Analyses which show no detectable TRC shall be included as values of zero in calculating the mean value. The detection limit shall be 0.02. mg/l or less.

The " daily maximum" shall not be exceeded for any individual sample, even though three grab samples are taken during periods of chlorination.

The pemittee has the opportunity to demonstrate to the Michigan Water Resources Ccamission that the TRC limits cannot be consistently achieved. Such demonstration shall be made on or before June 1, 1987 . If the pemittee makes a successful demonstration to the Canunission, this pennit may be modified consistent with the protection of the receiving water.

L The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be a.

monitored as follows: continuous **; report daily minimum and maximum.

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

c. Samples, measurements, and observations taken in compliance with the monitoring requirements above shall be taken as follows: intake - prior to entering the plant; discharge - prior to discharge to Lake Michigan; chlorine - prior to entering water from which fish are not precluded.

. d. In the event the pennittee shall require the discharge of water treatment additives in addition to or in greater quantities than those identified in the pemittee's NPDES application (Revision 3) dated November 11, 1981, and aoproved by l

the Chief of the Surface Water Quality Division on March 11, 1982, the pemittee shall notify the Olvision Chief. Written approval from the Chief of the Surface Water Quality Division to discharge such additives at specified levels shall be obtained prior to discharge by the permittee. The pennit'will be modified in accordance with the requirements of Part II, Section B-4 if a constituent of the additive or additives

! requires limiting.

Permit No. MI 0001457 Page 4 of 9

2. Final Effluent Limitations - (Internal outfalls 00A through 00F)

During the period beginning on the effective date of this permit and lasting until the expiration of this permit, the permittee 's authorized to discharge the following discharges through the mixing basin outfali 001 to Lake Micnigan. Sucn discharges shall be limited and monitored at internal points identified as 00A, 008, 00C, 000, 00E, and 00F, by the permittee as specified below:

Discharge limitations kg/ day (lbs/ day) Other Limitations Monitoring Requirements Effluent Monthly Daily Monthly Daily Measurement Sample Characteristic Average Maximum Average Maximum Frequency Type 00A & 008 - cooling tower suction basins overflow Flow, M 3/ Day (MGD) Daily 00C - cooling tower blowdown Flow, M 3/ Day (MGD) Daily 000 - radwaste wastewater Flow, M 3/ Day (MGO) Per Batch Grab Total Suspended Solids (mg/1) 30 100 Per Batch Grab Total Phosphorus (mg/1) 2 Per Batch Grab 00E - neutralizer tank wastewater Flow, M 3/ Day (MGD) Per Batch Total Suspended Solids (mg/1) 30 100 Per Batet Grab 00F - turbine sump oil separator including volume reduction system Flou, M 3/ Day (MGD) Daily 011 and Grease (mg/1) 15 20 Weekly Grab

a. Samples and ceasurements taken in compliance with the monitoring requirements above shall be taken prior to discharge to the mixing basin or co-mingling with other wastewater,

b. In the event the permittee shall require the discharge of water treatment additives in addition to or in greater quantities than those identified in the permittee's NPDES application (Revision 3) dated November 11, 1981, and approved by the Chief of the Surface Water Quality Division on March 11, 1982, the permittee shall notify the Division Chief. Written approval from the Chief of the Surface Water Quality Division to discharge such additives at specified levels shall be obtained prior to discharge by the permittee. Th9 permit will be modified in accordance with the requirements of Part II, Section B-4 if a constituent of the additive or additives requires limiting.

Page 5 of 9 Permit No. MI 0001457

3. Final Effluent Limitations During the ' period beginning on the effective date of this permit and lasting until the expiration date of this permit, the permittee is required to dispose of debris removed from intake trash bars and screens on land in an appropriate manner.

4. Final Effluent Limitations Effective upon the date of issuance of this permit, the company shall not discharge any polychlorinated biphenyl canpounds such as those commonly used for transformer fluids.

5. Special Condition This permit may be modified, or, alternatively revoked and reissued to comply with any applicable standard (s) or limitation (s) promulgated under Section 301(b)

(2)(c)(d), 304(b)(2) and 307(a)(2) of the Act, if the effluent standard (s) or limitation (s) so pranulgated:

a. is(are) either different in conditions or more stringent than any effluent limitation in the permit; or ,

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

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Permit No. MI 0001tE7 Page 6 of 9

6. special Condition - Notification Requirement The discharger shall notify the Chief of the Surface Water Quality Division, in writing, within 10 days of knowing, or having reason to believe, that any activity has occurred or will occur which would result in the discharge of:

1. Detectable levels

• of chemicals on the current Michigan Critical Materials Register or priority pollutants or hazardous substances set ferth in 40 CFR 122.21, Appendix L,1983 which were not acknowledged in the application ** or listed in the application at less than detectable levels.

2. Detectable levels

• of any other toxic substances not listed in the appli-cation or listed at less than detection, for which the application specifically reques ted inf ormation.

3. Any toxic substances at levels greater than five times the average level reported in the application **.

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

• The detectable level shall be defined as the Method Detection Limit (MX.) as given in Appendix 8 to Part 136. Federal Register. Vol. 49 No. 209. October 26,1984. pp. 43430-31.

• • The application dated March 27, 1980 and amended on October 18, 1984.

t pemi: No. MI 0001a57 Page 7 of 9 CART I

3. MONITORING AND REPORTING .

1. Representative Samoling Samoles and measurements taken as recuirec nerein snall e represents:1ve of :ne volume and nature of :ne monitorec cisenarge.

2. Reporti ng : b= acolicaele to your facility; b=notacolicable:: vcur facili:v A a. MCR Submi t:21 Recuirements - The cer:1: tee snall su:mit Monthly 0:erating Re:ce

(*CR) fems to :ne Oa:a Center of me Micnigan Decar=ent of Natural Rescurces for eacn calencar montn of :ne autnorizec c1senarge :er10c(s). The 90R's snall be cs=artec no later : nan tne 10:n cay of tne month folicwing eacn mor:n of :ne aumori:ec c1senarge per100(s).

b 3. Retained Sel' Moni t:rine Recuir-ents - The cemittee snall maintain a year-to-cate log of retainec self-moni cring results anc Orovice suen log for ins:ecti:n c :ne staff of :ne O (1.) Sur# ace Water Ouality J19isicn/Grouncwater Ouality Jivisicn Of .te

tienigan..'ecartment of .*iatural Resources.

(2.) Environmental Heal:n Services Division, Micnigan Decarcen of Dua.lic Heal:n O (3.). scr:nern peninsula 04 vision, Micnigan Decar=ent of Puelte sealtn C (4.) Divisten of Heal:n Facility Licensing & Certification M1cnigan Oecar=ent of Public Heal:n u:en recuest.

The cemittee snail certif~y in writing :: :n'e Chief ~f :ne Surface Water Qualt:y Oivision/Gr unewater Ouality Division of me Oe:arment Of Natural Rescurces,'in accorcanca ~ ~~ "

w1 = :ne Senecule of Cercliance Part I, C- NA , nat:

(1.) all retainec self-monitoring recuirements nave been c: rolled at:n anc a year-::-cate leg nas been raintainec.

(2.) One flew rate (s) (if part of retained self-monitoring results) fr:m all cu falls nave :een suestantially :ne same as :ne flaw ra:e(s) autacr1:ec y :nts :ern1: or if (3.) ne ' low rate (s) (if part of reliained self-cenitoring results) is (are) sucstant1 ally different from :ne ficw rate (s) authorized by :nis :em1: anc the semittet snail Orovice "easons for ne cid'erence in flow rates.

hc. Grounewa ter wenit:r ng - The :emittee snall saemi: Monthly Ocera:1ng Recor:

(90R) foms :o :ne Oata Center of :ne Micnigan Decarrent of Natural Resources in ac::r:anca wi tn '.ne mo ni to ri ng recui rements s e t fo rtn i n P a rt I , A N A . The MOR's snall ce pos=artec no later : nan tne 10tn day of :ne montn folicwing eacn completed recort period.

d. Fi rs t Demit - Existirq cc Deceased ~acility - Upon issuance of :ne first pern1: f0r an exis:1ng or rocosec f ac111ty :ne ern1::ee is exemot frca sucmitting MOR's for a ceriod of n1nety (90) cays from the cate ne permit is issuec.

b e. Per9it Geissuance er ucci'4 cation For any carareter acced to :ne -unit:r'9g recuirements as a result of ern1: reissuance or modification of the current em1 % One cemittee will be exe-c; fr:c succittinn 'm data for :nat :arareter for a ceriod of niaety (901 cavs fren :ne cate the :emi: is issued.

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Dermit No. _MI 0001457 9 age g of o

3. Cefinitions

a. The mentnly average discnarge is defined as the :::al 01senarge :y weign , or concentration if specified, curing ne recorting man:n diviced my

- :ne numoer of days in the recorting montn that tne cisenarge from ne =recuction or commercial facility occurrec. When less : nan daily sampling occurs, :ne montnly average discnarge snall be ceterm1nec ey tne sannation of One measurec daily disenarges by .eight, or concentra:1cn if s;ecifiec, civicec ey :ne numcer of cays curing :ne reperting men:n nen :ne samoles .ere collec:ec, analyzec anc reccr:ec.

. c. The caily maximum disenarge means :ne total discnarge ey weign:, er concentration if specified, curing any calencar day.

c. The Regicnal Administrat r is defined as the Regien V Acministra:Or, U.S. E?A, located at 230 Sou:n Cear:orn,13:n Floor, Chicago, Illinois 60606.

. d. The Micnigan 'Ja:er Rescurces C:mmission is located in :ne Stevens T.

wasen Building. The mailing accress is Box 3CC28, Lansing, Micnigan 48909.

a. Tes Prececures Tes: ;rocecures for :ne analysis of OcIlutants snali conform to regula: 1:ns

u

lisnec ;ursuant :: Section 304(n) of :ne ac t, under nlen sucn prececures may

e requirec.

5. Reccccing Results For aach measurement er sacole taken cursuant to :ne recuirements of :nis

ermit One :ermittee snall record tne following infarma:1on:

a. The exac: place, date, anc time of samoling;

3. The dates ne analyses .ere :erformec;

c. The :ersen(s) wno :erformec :ne analyses;

c. The analytical technicues or me:necs used; anc

e. The results of all requirec analyses.

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Pe nnit No. MI 0001457 Page o of a

6. Additional Monitoring by Permittee .

If the permittee monitors any pollutant at the location (s) designated herein more frequently than required by this pemit, using approved analyticpl methods as specified above, the results of such monitoring shall be included in the calculation and reporting of the values required in the Monthly Operating Report. Such increased frequen y shall also be indicated.

7. Records Retention All records and infonnation resulting from the monitoring activities required by this pemit including all records of analyses perfomed and calibration and maintenance of instrumentation and recordings from continucas monitoring instrumtntation shall be retained for a minimum of three (3) years, or longer if requested by the Regional Administrator or the Michigan Water Resources Commission. ,

C. SCHEDULE OF COMPLIANCE

1. The permittee shall continue to operate the installed facilities to achieve the effluent limitations. specified for outfall(s) 001 .

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

a. Submit plans for aoproval to the Chief of the Surface Water Quality Division necessary to comoly with the primary power provisicn of Section 10 in Part II on or before NA .

b. The pemittee shall comply with the requirements of items 106 or 10b contained in Part II on or before NA , Notwithst4nding the preceding sentence, tne permittee snall at all t1mes halt, reduce.

l or otherwise control production in order to protect the water, of the l State of Michigan upon reduction or loss of the primary source of power.

l 3. 4 later than 14 calendar days following a date identified in the above l

schedule of compliance, the remittee shall submit either a report of progress l

or, in the case of specific actions being required by idantified dates, a l

written statement of compliance or noncompliance. In the latter case, the

! statement sna11 include the cause of noncompliance, any remedial actions taken, f

adn the procebility cf meeting the next scheduled recuirement. Failure to subm1t the written statement is just cause to pursue enforcement action pursuant to the Coninission Act and the Part 21 Rules.

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r Permit No. MI 0001457 Page 1 of 5 i

PART II A. MANAGEMENT REQUIREMENTS

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

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

2. Change of Conditions Any anticipated f acility expansion, production increases, or process modification which will result in new, different, or increased discharges of pollutants must be reported by submission of a new application or, if such changes will not violate the ef fluent limitations specified in this permit, by notice to the permit issuing authority of such changes. Following such notice, the permit may be =cdified to specify and limit any pollutant not previously limited.

3. Containment Facilities The permittee shall provide f acilities for containment of any accidental losses of concentrated solutions, acids, alkalies, salts, oils, or other polluting materials in accordance with the requirements of the Michigan Water Resources Commission Rules. Part 5. This requirement is included pursuant to Section 5 of the Michigan Water Resources Commission Act, 1929 PA 245, as amended, and the Part 5 ru12s of the General Rules of the Co==ission.

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

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

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MI 0001457 Page 2 of 5 Permit No.

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

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

6. Spill Notification The permittee shall immediately report any spill or loss of any product, by-product, intermediate product, oils, solvents, waste material, or any other polluting substance which occure to the surface waters or groundwaters of the state by calling the Department of Natural Resources 24-hour Emergency Response telephone number 1-800-292-4706; and the permittee shall within ten (10) days of the spill or loss, provide the state with a full written explanation as to the cause and discovery of the spill or loss, clean-up and recovery measures taken, preventative measures to be taken, and schedule of implementation. This requirement is included pursuant to Section 5 of the Michigan Water Resources Commission Act, 1929 PA 245, as amended.

7. Facility Operation The permittee shall at all times properly operate and maintain all treatment or control facilities or systems installed or used by the permittee to achieve l compliance with the terms and conditions of this permit.

S. Adverse Impact The permittaa shall take all reasonable steps to minimize any adverse impact to the surface or groundwaters of the state resulting from noncompliance with any ef fluent limitation specified in this permit including, but not limited to, such accelerated or additional monitoring as necessary to determine the nature and impact of the discharge in noncompliance.

9. By-Passing Any diversion from or by-pass of facilities necessary to maintain compliance with the ter=s and conditions of this permit is prohibited, except (i) where unavoidable to prevent loss of Jife, personal injury, or severe property damage, or (ii) where excessive storm drainage or runoff would damage any facilities necessary for compliance with the effluent limitations and prohibitions of this permit. The permittee shall promptly notify the Michigan Water Resources Commission and the Regional Administrator, in writing, of such diversion or by-pass.

10. Power Failures In order to maintain compliance with the effluent limitations and prohibitions of this permit, the permittee shall either:

a. Provide an alternative power source suf ficient to operate facilities utilized by permittee to maintain compliance with the effluent limita-tions and conditions of this permit which provision shall be indicated in this permit by inclusion of a specific compliance date in each appropriate " Schedule of Compliance for Effluent Limitations".

Permit No. MI 0001457 Page 3 of 5

b. Upon the reduction, loss, or failure of one or more of the primary sources of power to facilities utilized by the permittee to maintain compliance with the effluent limitations and conditions of this permit, the permittee shall halt, reduce or otherwise control production and/or all discharge in order to maintain compliance with the effluent limitations and conditions of this permit.

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

12. Upset Noncompliance Notification If a process " upset" (defined as an exceptional incident in which there is unintentional and temporary noncompliance with technology based permit affluent limitations because of factors beyond the reasonable control of the permittee) has occurred, the permittee who wishes to establish the af firmative defense of upset shall notify the Chief of the Surface Water Quality Division by telephone within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of becoming aware of such conditions and within five (5) days, provide in writing, the following information:

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

b. That the permitted wastewater treatment facility was, at the ci=e, being properly operated;

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

In any enforce =ent proceedings, the permittee is sceking to establish the occurrence of an upset, has the burden of proof.

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

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Permit No. MI 0001457 Page 4 of 5

5. RESPONSIBILITIES

1. Right of Entry The permittee shal1 allow the Executive Secretary of the Michigan Vater Resources Commission, the Regional Administrator and/or their authorized representatives, upon the presentation of credentials:

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

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

2. Transfer of Ownership or Centrol In the event of any change in control or ownership of facilities from which the aathorized discharge emanate, the permittee shall notify the succeeding owner or controller of the existance of this permit by letter, a copy of which shall be forwarded to the Michigan Water Resources Commission and the Regional Administrator.

3. kratlability of Reports Extapt for data determined to be confidential under Section 308 of the Act and Rule 2128 of the Water Resources Commission Dules, Part 21, all reports prepared in accordance with the terms of this permit shall be available for public inspection at the offices of the State Wacer Pollution Control Agency and the Regional Administrator. As required by the Act, effluent data shall not be considered confidential. Knowingly making any false statement on any such report may result in the imposition of criminal penalties as provided for in Section 309 of the Act and Sections 7 and 10 of the Michigan Act.

4 Permit Modification Af ter notice and opportunity for a hearing, this permit may be mcdified, suspended, or revoked in whole or in part during its term for cause including, but not limited to, the following:

a. Violation of any terms or conditions of this permit;

b. Obtaining this permit by misrepresentation or failure to disclose fully, all relevant facts; or

c. A change in any condition that requires either a te=porary or permanent reduction or elimination of the authorized discharge.

Permit No. MI 0001457 Page 5 of 1

5. Toxic Pollutants Notwithstanding Part II, B-4 above, if a toxic effluent standard or prohibition (including any schedule of compliance specified in such ef fluent standard or prohibition) is established under Section 307(a) of the Act for a toxic pollutant which is present in the discharge and such standard or prohibition is more stringent than any limitation for such pollutant is this permit, this permit shall be revised or modified in accordance with the toxic effluent standard or prohibition and the permittee so notified.

's. Civil and Criminal Liability Except as provided in permit conditt ans on "By-Passing" (Part 11. A-9) and " Power Failures" (Part II. A-10), .othing in this permit shall be construed to relieve the permittee from civil or criminal penalties for norcompliance, whether or not such noncompliance is due to factors beyond his control, such as accidents, equipment breakdowns, or labor disputes.

7. Oil and Kazardous Substance Liability Nothing in this permit shall be construed to preclude the institution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties to which the permittee may be subject under Section 311 of the Act except as are exempted by federal regulations.

8. State Laws ,

J Nothing in this permit shall be construed to preclude the inacitution of any legal action or relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to any applicable State law or regulation under authority preserved by Section $10 of the Act.

9. Property Rights i

The issuance of this per=it does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize j violation of any Federal, State or local laws or regulations, nor d?es it obviate the necessity of obtaining such permits or approvals f rom other units of government as may be required by law.

l 10. Severability The provisions of this permit are severable, and if any provision of this permit, or the applicaItion of any provision of this* permit to any circumstances, if held invalid, the application of such provision to other circumstances, and I the remainder of this permit, shall not be affected thereby.

11. Notice to Public Utilities (Miss Dig)

The issuance of this permit does not exempt the permittee from giving notice to public utilities and complying with each of the requirements of Act 53 of the 4 Public Acts of 1974, being sections 460.701 to 460.718 of the Michigan Compiled Laws, when constructing f acilities to meet the terms of this permit.

. . .~

MIXING ZONE Permit No. MI 0001457 Consumers Power Co.

. Palisades Plant

27780 81de Star Memorial Hwy.

Covert, MI 4

i Outfall Number Receivina Stream Discharge Location 001 Lake Michigan Section 5. T29 R17W.

Covert Township Van Buren County .

For toxic and other pollutants, the volume of receiving water used in assuring that effluent limitations are sufficiently stringent to meet Water Quality Standards is the area in Lake Michigan equivalent to that of a circle having a radius of 1,000 feet centered ever the point of discharge.

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Appendix C l

l 1985 Spill Events April 9, 10, 1985 l "A" Cooling Tower Acid Spill l

l As a result of bolt failure at a flange on the acid feed system, 332 gallons

! of 98% sulfuric acid were lost to the ground. The acid was partially neutral-ized and then disposed of as hazardous waste.

May 1, 1985 Neutralizer Tank Acid Spill A failure of the connection of a piping system at the neutralizer tank result-ed in the loss of 840 gallons of acid solution (equivalent to 11.8 pounds of H2SO4 ).  ;

May 2, 1985 Neutralizer Tank Caustic Spill l

Overfilling of the caustic storage tank resulted in caustic solution being pumped to the neutrilizer tank. Because uf the leak discussed above not being repaired, 413 pounds of caustic (1,875 gallons of solution) were lost to the ground. This spill and the above one were cleaned up by removal of the soils j and disposal of as hazardous vaste.

l June 14, 1985 l

"A" Cooling Tower Acid Leak The discharge piping at the acid feed pump developed a hole resulting in the loss of 250 gallons (3,800 pounds) of 98% acid to the ground. The soils i contaminated by this event were disposed of ar hazardous waste.

1 i NOTE: Each of the above spills were reported to USEPA as required by CERCLA (superfund).

l l

l July 6, 1985 l "A" Acid Spill l

A failure in the PVC line from the acid feed pump to the cooling tower result-l ed in a loss of about 10 gallons of 98% sulfuric acid to the ground. Thin material was disposed of as hazardous waste.

1 I

i RP0286-0033A-0P02 .

July 31, 1985 T-10 Fuel Storage Tank Fill Basin Overflow During an unexpected shutdown, "A" cooling tower overflowed and the resultant flood of water replaced the fuel oil contained in the T-10 tank fill basin.

About 10 gallons of fuel oil were lost to Lake Michigan. No oil sheen was detected on the lake during the incident.

August 22, 24, 26, 29, 1985 September 8, 1985 Lubricating 011 Spill to Lake Michigan During each of the above days, oil was observed in the cooling towers suction basin overflows, and the mixing basin. On the August 26, 29, and September 8, 1985, visible oil was observed in Lake Michigan. After the spill on September 8, the source was finally detected as the main lube oil coolers (earlier observation of this equipment indicated no leakage) the coolers were repaired and returned to service. These coolers were disabled and reinspected during the December-February Refueling Outage.

September 16, 1985 T-130 overflow During a valve operation, dilution water was backed up into the M-18 oil / water separator. The overflow of this tank filled T-130 waste oil storage tank causing the overflow from T-130. The vent for this tank is outside the building allowing for a loss of about five gallons of oil to the ground and psvement. The oil was cleaned up and disposed of and the vents on M-18 and T-130 modified to allow overflows to be contained.

September 19, 1985 "A" Cooling Tower Acid Spill The acid dilution trough inside the cooling tower developed a leak and sprayed acid and water (pH 1.5) onto the ground. The spill solution was pumped back into the tower and the reminder was neutralized in place with lime (CaOH,). A piece of Plexiglas was installed to prevent additional leakage and the trough was repaired during the December-February Refueling Outage.

October 28, 1985 "B" Cooling Tower Acid Spill During fill of "B" cooling tower acid tank, about four gallons of 98% sulfuric acid were sprayed on the ground and absorbed by the sand. The sand was disposed of as hazardous waste and the line was repaired.

RP0286-0033A-OP02

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APPENDIX D i

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4 OC0486-0068-NI.02 i .

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• Appendix D ,

1985 NPDES Non-Compliances DATE OUTFALL PARAMETER NON-COMPLIANCd l

January 10, 1985 00F 011 and Grease Exceeded 20 mg/l daily limit, actual value reported was 72.2 mg/1.

January 14, 1985 00F Oil and Grease Exceeded 20 mg/l daily limit, actual value reported was 56.1 mg/1.

l l

January 21, 1985 00F Oil and Grease Exceeded 20 mg/l daily limit, actual value reported was 50.2 mg/I.

l January 28, 1985 00F Oil and Grease Exceeded 20 mg/l daily limit, actual value reported was 60.0 mg/1.

January, 1985 00F Oil and Grease Exceeded 15 mg/l monthly average, actual monthly l

average was 42 mg/1.

February 4, 1985 00F Oil and Grease Exceeded 20 mg/l daily limit, actual value i reported was 58.2 mg/1. l l

Feb ruary 10, 1985 00F Oil and Grease Exceeded 20 mg/l daily limit, actual value reported was 24.8 mg/1.

NOTE: The outf all designation "00F" is as per the new NPDES Permit, the designation previously was "00G.

t RP0286-0033A-OP02

4 Appondix D ,

1985 NPDES Non-Compliances DATE OUTFALL PARAMETER NON-CCMPLIANCE February II, 1985 00F Oil and Crease Exceeded 20 mg/l daily limit, actual value reported was 25.6 mg/1.

Feb rua ry, 1985 00F Oil and Crease Exceeded 15 mg/l monthly average actual monthly average was 27.3 mg/1.

April 15, 1985 00F 011 and Grease Exceeded 20 mg/l daily limit, actual value reported was 56.0 mg/1.

May 23. 1985 001 pH Accidental release of neutralizers La.k resulted in measured discharge pH of 5.5. About 3,000 gallons of neutralizer tank waste were released.

August 26, 1985* 001 Oil in Small traces of oil in makeup basin carrying over Discharge to mixing basin and into Lake Michigan.

August 29. 1985* 001 011 in Small traces of oil in makeup basin carrying over Discharge to mixing basin and into Lake Michigan.

l l

• See Appendix D Spills for Discussion l

l l

RP0286-0033A-OP02

Appendix D ,

i 1985 NPDES Non-Compliances DATE OUTFALL PARAMETER NON-COMPLIANCE September 8, 1985* 001 011 in Small traces of oil in makeup basin carrying over Discharge to mixing basin and into Lake Michigan.

September 21, 1985 00F 011 and Crease Exceeded 20 mg/l daily maximum, actual value was 34.2 mg/1.

October 21, 1985 00F Oil and Grease Exceeded 20 mg/l daily maximum, actual value was 26 mg/1.

October 28, 1985 001 Total Residual Exceeded daily maximum of 0.20 mg/1, actual value

' Chlorine was 0.24 mg/1.

1 i

December 1, 1955 001 pH During period when recording instruments are out I for repair, sampling must be conducted every eight hours, however, this was not done from November 30, 1985 at 1630 hrs. until 0830 hrs on December 1, 1985.

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• See Appendix D Spills for Discussion R20286-0033A-OP02 i

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penrramus NC

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! General Off6ces: 1946 West Pernail Roed, Jack son, MI 49201 * (517) 788 0550 ~

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l Jattes G Keppler, Administrator

[ Region III l US Nuclear Reguistory Commission 799 Roosevelt Road Clen Ellyn, IL 60137 l

DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

l 1985 ANNUAL ENVIRONMENTAL OPERATING REPORT Appendix B (Environmental Protection Plan) to Provisional Operating License No DPR-20 for the Palisades Plant requires Consumers Power Company to subuit the Environmental Operating Report annually prior to May 1. The attached report covering the period from January I to December 31, 1985 fulfills the referenced report requirements.

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Brian D Johnson Staff Licensing Engineer CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection & Enforcement NRC Resident inspector - Palisades Attachment

., ff SW OC0486-0068-NLO2 I I I

' APR J 11986 L __ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___