Text

Response to Request for Additional Information for License Renewal Application Environmental Report
	ML091600712
Person / Time
Site:	Cooper
Issue date:	05/18/2009
From:	Minahan S; Nebraska Public Power District (NPPD)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NLS2009036
	Download: ML091600712 (383)
	v • d • e

N Nebraska Public Power District "Always there when you need us" NLS2009036 May 18, 2009 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Response to Request for Additional Information for License Renewal Application Environmental Report Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. Letter from Tam Tran, U.S. Nuclear Regulatory Commission, to Stewart B. Minahan, Nebraska Public Power District, dated May 1, 2009, "Request for Additional Information for the Review of the Cooper Nuclear Station License Renewal Application (TAC No. MD9763 and MD9737)."

2. Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S.

Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal Application."

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District to respond to Section A of the Nuclear Regulatory Commission (NRC) Request for Additional Information (Reference 1) related to the License Renewal Application Environmental Report (Appendix E of Reference 2).

These responses are provided in Attachment 1. Additionally, as discussed with the Cooper License Renewal NRC Project Manager, miscellaneous errata changes are provided for the Environmental Report in Attachment 2.

Should you have any questions regarding this submittal, please contact David Bremer, Licensing Renewal Project Manager, at (402) 825-5673.

COOPER NUCLEAR STATIONPI PO. Box 98 / Brownville, NE 68321-0098 Telephone: (402) 825-3811 / Fax: (402) 825-5277 www.nppd.com

NLS2009036 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on /ae Sincerely, tewart B. Minahan Vice President-Nuclear and Chief Nuclear Officer

/wv Attachments cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Project Directorate IV-1 Senior Resident Inspector w/ attachments USNRC - CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution w/o attachments CNS Records w/ attachments

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS©"

Correspondence Number: NLS2009036 The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None I &

I I I I I I PROCEDURE 0.42 REVISION 23 PAGE 19 OF 26

NLS2009036 Attachment I Page 1 of 5 Attachment 1 Response to Request for Additional Information for Cooper Nuclear Station License Renewal, Additional Information Request for the Review of the Environmental Report (ER)

Cooper Nuclear Station, Docket No. 50-298, DPR-46 The Nuclear Regulatory Commission (NRC) Request for Additional Information regarding the License Renewal Application Environmental Report is shown in italics. Nebraska Public Power District's (NPPD) response to each question is shown in block font.

NRC Request

1. Relative to the review of Cooper Nuclear Station (CNS) environmentalpermits, the staff requests the submittal of the 14 CNS permits (CNS PermitsIndex) supportingthe license renewal application.

(1) CNS operatinglicense (2) NPDESpermit (NPDESPermit Application)

(3) IndustrialStormwater Permit (4) Air ConstructionPermit (Low Emitter Status Notice and Open Burn Permits)

(5) RCRA Notification (6) Injection Well Permit (7) Registered Well Information (8) Water Withdrawal Right (9) Public Drinking Water Supply Permit (10) South Carolina Waste TransportPermit (11) Tennessee Radioactive Waste License (12) Utah GeneratorSite Access Permit (13) Construction Stormwater Permit - ISFSI (14) 404 Permit - Dredge Intake (404 Permit - Ice Deflector)

NPPD Response The permits and other specified documents listed above are provided as Enclosures 1.1 through 1.14 to this Attachment. Regarding Item 4, it should be noted that CNS does not have any currently active Open Bum Permits. However, the two most recent expired Open Burn Permits have been provided for information.

NLS2009036 Page 2 of 5 NRC Request

2. The CNS Environmental Report referred to Hydrogeologic Investigation Workplan, dated November 2007, andpreparedfor Nebraska Public Power District (NPPD)by Conestoga Rovers andAssociates. The staff requests the submittal of this reference (and 2009 Hydrogeologic Report as appropriate),for the license renewal (LR) review.

NPPD Response The Hydrogeologic Investigation Work Plan dated November 2007 that was prepared for NPPD by Conestoga Rovers and Associates is included as Enclosure 2.1 to this Attachment. However, activities associated with the 2009 Hydrogeologic Report have not yet been completed (which is why the Work Plan is still designated as being in draft form), but may be provided upon request after the report has been finalized.

NRC Request

3. During the onsite environmental audit, the applicant stated that a company Jebro is a state-licensedoil recycling and disposalfacility, and it takes ownership of the used oil that NPPDsends to Jebro. The staff requests documentationand information relatedto Jebro'squalification/permitto dispose of the waste for review.

NPPD Response Upon further investigation, it has been determined that Jebro does not require a state-issued license or permit. Rather it holds an Environmental Protection Agency (EPA) Resource Conservation and Recovery Act (RCRA) Identification Number which designates Jebro as approved for handling hazardous waste. The letter providing Jebro's EPA RCRA Identification number is provided as Enclosure 3.1 to this Attachment. It should be noted that CNS utilizes this facility for oil recycling only.

NRC Request

4. During the onsite environmental audit, the applicantstated that NPPD sends mixed waste to a disposalfacility in Clive, Utah. The facility is licensedfor receipt of hazardous low-level radioactive waste. The staff requests documentation related to the mixed-wastefacility and the method of mixed-waste treatment (disposal)be provided,for the LR review.

NPPD Response The state approval for the Envirocare of Utah, Inc. mixed waste Operating Plan/Permit is provided as Enclosure 4.1 to this Attachment. Due to the size of thepermit itself, the following web link is provided in lieu of providing a hardcopy enclosure:

NLS2009036 Page 3 of 5 http://www.hazardouswaste.utah.gov/HWBranch/CFFSection/EnvirocarePermit.htm.

A separate electronic file of this document has been forwarded to the NRC License Renewal Project Manager for CNS.

The treatment method for the mixed waste sent to this facility in 2009 by CNS was macro-encapsulation. The waste is processed in accordance with Section 3.1.3.3, "Mixed Waste Requiring Treatment," to EnergySolution's "Bulk Waste Disposal and Treatment Facilities -

Waste Acceptance Criteria," Revision 7, November 2008. This document is provided as .2 to this Attachment.

NRC Request

5. During the onsite environmental audit, the applicantstated that CNS environmental programs are governed by NPPDEnvironmental Policy Directive which describes the corporate commitment to environmental compliance andstewardship. The staff requests documentation relatedto NPPDEnvironmental PolicyDirective and associatedCNS recycling implementations be provided,for the LR review.

NPPD Response The NPPD Environmental Policy Directive describes the corporate commitment to environmental compliance and stewardship. Contained within that directive is the following environmental principal (see Enclosure 5.1 to this Attachment):

"Ensure proper handling, treatment, and disposal of all waste streams while taking steps to control their generation and encourage pollution prevention, recycling, and development of markets for certain wastes."

NPPD executes this principle in Corporate Environmental Manual Chapter 12, "Waste Minimization" (see Enclosure 5.2 to this Attachment). This chapter provides recycling strategies for the key sources of waste. Cooper implements recycling through the "NPPD Green Team."

The Green Team issues an annual Recycling Report (see Enclosure 5.3, "2008 Recycling Report," which includes the Green Team Charter in the last two pages).

NRC Request

6. During the onsite environmental audit, the applicantstated that the average 2007 dose (40 CFR 190) to members of the public (combined dose from gaseous, liquid, and direct shine radiation)has been calculatedto be 0. 5 mrem. The staff requests documentation relatedto this calculationbe provided,for LR review.

C

NLS2009036 Page 4 of 5 NPPD Response NPPD establishes compliance with 40 CFR 190 through Offsite Dose Assessment Manual (ODAM) surveillance requirement DSR 3.4.1.1, which annually performs a cumulative dose calculation due to radioactive material in gaseous and liquid effluents. This ODAM calculation is provided in the annual Radioactive Effluent Release Report, most recently submitted on April 30, 2009. At the NRC's request, NPPD performed a computation of 40 CFR 190 compliance utilizing thermolucent dosimeter (TLD) readings. The results were an annual average dose of 0.5 mrem for 2007, which is well within 40 CFR 190 limits. In a conference call held with the NRC on May 13, 2009, it was determined that further documentation of this TLD dose computation was not required.

NLS2009036 Page 5 of 5 Enclosures to Attachment 1 1.1 CNS operating license 1.2 NPDES permit (NPDES Permit Application) 1.3 Industrial Stormwater Permit 1.4 Air Construction Permit (Low Emitter Status Notice and Open Bum Permits) 1.5 RCRA Notification 1.6 Injection Well Permit 1.7 Registered Well Information 1.8 Water Withdrawal Right 1.9 Public Drinking Water Supply Permit 1.10 South Carolina Waste Transport Permit 1.11 Tennessee Radioactive Waste License 1.12 Utah Generator Site Access Permit 1.13 Construction Stormwater Permit - ISFSI 1.14 404 Permit - Dredge Intake (404 Permit -Ice Deflector) 2.1 Hydrogeologic Investigation Work Plan 3.1 EPA RCRA ID No. IAD020201604 issued to Jebro Inc.

4.1 State of Utah Operating Plan/Permit Approval to Envirocare of Utah, Inc.

4.2 EnergySolutions Bulk Waste Disposal and Treatment Facilities Waste Acceptance Criteria, Revision 7 5.1 Corporate Environmental Policy Directive 5.2 Corporate Environmental Manual Chapter 12, "Waste Minimization" 5.3 2008 Recycling Report

.1 to Attachment 1 CNS Operating License

NEBRASKA PUBLIC POWER DISTRICT DOCKET NO. 50-298 (COOPER NUCLEAR STATION)

FACILITY OPERATING LICENSE License No. DPR-46

1. The Atomic Energy Commission (the Commission) having found that:

A. The application for license filed by the Nebraska Public Power District (the licensee) complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I and all required notifications to other agencies or bodies have been duly made; B. Construction of the Cooper Nuclear Station (facility) has been substantially completed in conformity with Provisional Construction Permit No. CPPR-42 and the application, as amended, the provisions of the Act and the rules and regulations of the Commission; C. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; D. There is reasonable assurance: (i) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; E. The licensee is technically and financially qualified to engage in the activities authorized by this operating license in accordance with the rules and regulations of the Commission; F. The licensee has satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this operating license will not be inimical to the common defense and security or to the health and safety of the public; 1 of 5

H. After weighing the environmental, economic, technical,and other benefits of the facility against environmental costs and considering available alternatives, the issuance of Facility Operating License No. DPR-46 (subject to the conditions for protection of the environment set forth herein) is in accordance with 10 CFR Pa-t 50, Appendix D, of the Commission's regulations and all applicable requirements of said Appendix D have been satisfied; and The receipt, possession, and use of source, byproduct, and special nuclear material as authorized by the license will be in accordance with the Commission's regulations in 10 CFR Parts 30, 40, and 70, including 10 CFR Sections 30.33, 40.32, 70.23, and 70.31.

2. Facility Operating License No. DPR-46 is hereby issued to the Nebraska Public Power District to read as follows:

A. This license applies to the Cooper Nuclear Station, a boiling water nuclear reactor and associated equipment (the facility), owned by the Nebraska Public Power District.. The facility is located near Brownville in Nemaha County, Nebraska, and Atchison County, Missouri, and is described in the "Final Safety Analysis Report" (Amendment 7) as supplemented and amended (Amendments 8 through 30), and the Environmental Report as supplemented and amended (Supplements 1 through 6).

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses Nebraska Public Power District:

(1) Pursuant to Section 104b of the Act and 10 CFR Part 50, "Licensing of Production and Utilization Facilities," to possess, use, and operate the facility at the designated location near Brownville in Nemaha County, Nebraska, and Atchison County, Missouri, in accordance with the procedures and limitations set forth in this license; (2) Pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time /018 special nuclear material as reactor fuel, in accordance with the limitations for /018 storage and amounts required for reactor operation, as described in the Final /018 Safety Analysis Report, as supplemented and amended, and the licensee's filings /018 dated June 20, 1975 and September 22, 1975; /018 (3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and /018 use at any time any byproduct, source and special nuclear materials as sealed /018 neutron sources for reactor startup, sealed sources for reactor instrumentation /018 and radiation monitoring equipment calibration, and as fission detectors in /018 amounts as required; /018 (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and /018 use in amounts as required any byproduct, source or special nuclear materials /018 without restriction to chemical or physical form, for sample analysis or instrument /018 calibration or associated with radioactive apparatus or components; and /018 2 of 5

(5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not /018 separate, such byproduct and special nuclear materials as may be /018 produced by operation of the facility. /018 C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 2419 megawatts (thermal).

(2) Technical Specifications The Technical Specifications contained in Appendix A as revised through /107 Amendment No. 232, are hereby incorporated in the license. The /232 licensee shall operate the facility in accordance with the Technical Specifications.

(3) Physical Protection The licensee shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Cooper Nuclear Station Safeguards Plan," submitted by letter dated May 17, 2006. /

(4) Fire Protection /199,**

The licensee shall implement and maintain in effect all provisions of the /199,**

approved fire protection program as described in the Cooper Nuclear Station /199,**

(CNS) Updated Safety Analysis Report and as approved in the Safety /199,**

Evaluations dated November 29, 1977; May 23, 1979; November 21, 1980; /199,**

April 29, 1983; April 16, 1984; June 1, 1984; January 3, 1985; August 21, /199,**

1985; April 10, 1986; September 9, 1986; November 7, 1988; February 3, /199,**

1989; August 15, 1995; and July 31, 1998, subject to the following provision: /199,**

/199,**

The licensee may make changes to the approved fire protection program /199,**

without prior approval of the Commission only if those changes would not /199,**

adversely affect the ability to achieve and maintain safe shutdown in the /199,**

event of a fire. /199,**

3 of 5

Revised by letter dated March 5, 2007

- Revised by letter dated August 9, 2007

(5) Additional Conditions /178

/178 The Additional Conditions contained in Appendix C, as r~evised -through /178 Amendment No. 178, are hereby incorporated into this license. Nebraska /,178 Public Power District shall operate the facility in accordance with the /178 Additional Conditions. /178 (6) Deleted /206 (7) Mitigation Strategy License Condition /**

Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

A. Fire fighting response strategy with the following elements:

(1) Pre-defined coordinated fire response strategy and guidance (2) Assessment of mutual aid fire fighting assets (3) Designated staging areas for equipment and materials (4) Command and control (5) Training of response personnel B. Operations to mitigate fuel damage considering the following:

(1) Protection and use of personnel assets (2) Communications (3) Minimizing fire spread (4) Procedures for implementing integrated fire response strategy (5') Identification of readily-available pre-staged equipment (6) Training on integrated fire response strategy (7) Spent fuel pool mitigation measures C. Actions to minimize release to include consideration of:

(1) Water spray scrubbing (2) Dose to onsite responders (8) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except-the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

4 of 5

- Revised by letter dated August 9, 2007

(9) Upon implementation of Amendment No. 230 adopting TSTF-448-A, /230 Revision 3, the determination of control room envelope (CRE) unfiltered air /230 inleakage as required by SR 3.7.4.4, in accordance with Specification /230 5.5.13.c.(i), the assessment of CRE habitability as required by Specification /230 5.5.13.c.(ii), and the measurement of CRE pressure as required by /230 Specification 5.5.13.d, shall be considered met. Following implementation: /230 (a) The first performance of SR 3.7.4.4, in accordance with Specification /230 5.5.13.c.(i), shall be within the specified Frequency of 6 years, plus the /230 18-month allowance of SR 3.0.2, as measured from July 12, 2004, the /230 date of the most recent successful tracer gas test. (The tracer gas test /230 was stated to have been performed in July, 2004, in the September 30, /230 2004 letter response to Generic Letter 2003-01). /230 (b) The first performance of the periodic assessment of CRE habitability, /230 Specification 5.5.13.c.(ii), shall be within the next 9 months. /230 (c) The first performance of the periodic measurement of CRE pressure, /230 Specification 5.5.13.d, shall be within 18 months, plus the 138 days /230 allowed by SR 3.0.2, as measured from May 4, 2007, the date of the /230 most recent successful pressure measurement test. /230 D. (Not Used) /190 E. This license is effective as of the date of issuance and shall expire at midnight, January 18, 2014. /143 FOR THE ATOMIC ENERGY COMMISSION ORIGINAL SIGNED BY A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:

Appendices A&B - Technical Specifications Appendix C - Additional Conditions Date of Issuance: January 18, 1974 5 of 5

APPENDIX C ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. DPR-46 Nebraska Public Power District shall comply with the following conditions on the schedules noted below:

Amendment Implementation Number AdditionalConditions Date 178 This amendment authorizes the relocation of Within 90 days of the certain Technical Specification requirements to date of this licensee-controlled documents. Implementation amendment.

of this amendment shall include the initial relocation of these Technical Specification requirements to the appropriate documents, as described in Table RL of Details Relocated from Current Technical Specifications and Table R of relocated current Technical Specifications that are attached to the NRC staffs Safety Evaluation enclosed with this amendment.

178 The schedule for the performance of new and Within 90 days of the revised Surveillance Requirements (SRs) shall be date of this as follows: amendment.

For SRs that are new in this amendment, the first performance is due at the end of the first surveillance interval that begins on the date of implementation of this amendment. For SRs that existed prior to this amendment whose intervals of performance are being reduced, the first reduced surveillance interval begins upon completion of the first surveillance performed after implementation of this amendment. For SRs that existed prior to this amendment that have modified acceptance criteria, the first performance is due at the end of the first surveillance interval that began on the date the surveillance was last performed prior to the implementation of this amendment. For SRs that existed prior to this amendment whose intervals of performance are being extended, the first extended surveillance interval begins upon completion of the last surveillance performed prior to implementation of this amendment.

Amendment 178

Enclosure 1.2 to Attachment 1 NPDES Permit (NPDES Permit Application)

Nebraska Department of Environmental Quality Wastewater Section Suite 400, The Atrium, 1200 'N' Street PO Box 98922 Lincoln, NE 68509-8922 Tel. 402/471-4220 Fax 402/471-2909 Authorization to Discharge Under the National Pollutant Discharge Elimination System (NPDES)

This NPDES permit is issued in compliance with the provisions of the Federal Water Pollution Control Act (33 U.S.C. Sees. 1251 et. seq. as amended to date), the Nebraska Environmental Protection Act (Neb. Rev. Stat.

Sees. 81-1501 et. seq. as amended to date), and the Rules and Regulations promulgated pursuant to these Acts.

The facility and outfalls identified in this permit are authorized to discharge wastewater and are subject to the limitations, requirements, prohibitions and conditions set forth herein. This permit regulates and controls the release of pollutants in the discharges authorized herein. This permit does not relieve permittees of other duties and responsibilities under the Nebraska Environmental Protection Act, as amended, or established by regulations promulgated pursuant thereto.

NPDES Permit No.: NE0001244 IiS File Number PCS 36750-P Facility Name: NPPD Cooper Nuclear Station Permittee Nebraska Public Power District Facility Location: Two and one-half miles south of Brownville, Nebraska Legal Description NE /, NW /, Section 32, Township 5 N, Range 16 W, Nemaha County, Nebraska Receiving Water Missouri River, segment NEI-10000 of the Nemaha River Basin Effective Date: July 1, 2007 Expiration Date: June 30,2012 Pursuant to a Delegation Memorandum dated July 26, 1999 and signed by the Director, the undersigned hereby executes this documnt on behalf of the Director.

Signed this day of2 Page 1 of 20

Cooper Nuclear Station NPDES Permit Number NEOO0 1244 Effective Date: July 1, 2007 Page 2 of 21 TABLE OF CONTENTS PART I. EFFLUENT LIMITS AND MONITORING REQUIREMENTS .................................................................. 3 A. Outfall 001- Discharge of Once Pass Through Cooling W ater .............................................................. 3 B. OutfalI 002B- Clear Well Discharge and Outfall 004 Emergency Overflow ........................................ 4 C. Outfall 002C - Floor Drains ..................................................................................... .............5 D. Outfall 004 - RO Reject and Boiler Blowdown W astestreams .............................................................. 6 E. Outfall 008 -W aste Sample Tank ............................................................................................................... 7 F. Outfall 009 - Sample Tank Floor Drain ................................................................................................. 8 PART II. COMPLIANCE SCHEDULE FOR EVALUATING COOLING WATER INTAKE STRUCTURE(S) AT COOPER NUCLEAR STATION ................................................................................................................................................... 8 PART 1fl. COMPLIANCE SCHEDULE FOR MEETING FINAL TOTAL RESIDUAL CHLORINE (TRC) LIMITS ......... 9 PART IV. OTHER REQUIREMENTS AND CONDITIONS ..................................................................................... 10 A. Polychlorinated Biphenyls (PCB) .............................................................................................................. 10 B. Radionucelides ............................................................................................................................................ 10 C. Narrative Limits .................................................... .................................................................................... 10 D. Disposal of Sewage Sludge ........................................................................................................................ 10 E. M ethod Detection Limit Reporting Requirements ................................................................................. 10 APPENDIX A - STANDARD CONDITIONS THAT APPLY TO NPDES AND NPP PERMITS ................................ 11 A. General Conditions .................................................................................................................................... 11 B. M anagement Requirements ....................................................................................................................... 12 C. M onitoring and Records ............................................................................................................................ 13 D. Reporting Requirements ............................................................................................................................ 15 E. -Operation and Maintenance ....................................................................................................................... 18 F. Definitions ............................................................................................................................................... 20 G. Abbreviations ............................................................................................................................................. 21

Cooper Nuclear Station NPDES Permit Number NE001244 Effective Date: July 1, 2007 Page 3 of 21 Part I. Effluent Limits and Monitoring Requirements A. Outfall 001- Discharge of Once Pass Through Cooling Water The discharge of once pass-through cooling water from Outfall 001 to the Missouri River must be consistent with the description provided in the permit application and any supplemental information submitted used in the development of this permit. The discharge from Outfall 001 shall be monitored and subject to the limits set forth below in Table 1 oavo

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Cooper Nuclear Station NPDES Permit Number NEO0O 1244 Effective Date: July 1, 2007 Page 4 of 21 B. Outfall 002B- Clear Well Discharge and Outfall 004 Emergency Overflow The discharge of low volume wastewater from Outfall 002B must be consistent with the description provided in the permit application and any supplemental information submitted used in the development of this permit. The discharge from Outfall 002B shall be monitored and subject to the limits set forth below in Table 2.

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Cooper Nuclear Station NPDES Permit Number NE000 1244 Effective Date: July 1, 2007 Page 5 of 21 C. Outfall 002C - Floor Drains The discharge of categorical low volume wastewater from Outfall 002C must be consistent with the description provided in the permit application and any supplemental information submitted used in the development of this permit. The discharge from Outfall 002C shall be monitored and subject to the limits set forth below in Table 3.

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Cooper Nuclear Station NPDES Permit Number NEO0O 1244 Effective Date: July 1, 2007 Page 6 of 21 D. Outfall 004 - RO Reject and Boiler Blowdown Wastestrgams The discharge of low volume wastewater from Outfall 004 must be consistent with the description provided in the permit application and any supplemental information submitted used in the development of this permit. The discharge from Outfall 004 shall be monitored and subject to the limits set forth below in Table 4.

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Cooper Nuclear Station NPDES Permit Number NEOO0 1244 Effective Date: July 1, 2007 Page 7 of 21 E. Outfall 008 - Waste Sample Tank The discharge of tank waste low volume discharge from Outfall 008 must be consistent with the description provided in the permit application and any supplemental information submitted used in the development of this permit. The discharge from Outfall 008 shall be monitored and subject to the limits set forth below in Table 5.

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Cooper Nuclear Station NPDES Permit Number NE0001244 Effective Date: July 1, 2007 Page 8 of 21 F. Outfall 009 - Sample Tank Floor Drain The discharge sample tank low volume wastewater from Outfall 009 must be consistent with the description provided in the permit application and any supplemental information submitted used in the development of this permit. The discharge from Outfall 009 shall be monitored and subject to the limits set forth below in Table 6.

I. 1k ~II.~*~f~111 ~ I M101 9,911"MR, N" 101'

" ... '.....

Paraietes ,Storet* Units Units Dispharge Limits Monitoring . ample

arameters 30 Day'Average Maximum Frequency Type Calculated or Flow 50050 MGD Report Report Semiannually Metered Oil and Grease 00552 mg/L Report 10 Semiannually Grab Total Suspended 00530 mg/L 30 100 Semiannually Grab Solids Limits Mofiitoring

Sa e p-Arai0e0ers0 Units Dica9e 0 S emnna Grab pH 00400 Standard 6.5 9.0 Semiannually Grab I I ~Units II wp-O~fob], eS , , .,p Part II. Compliance Schedule for Evaluating Cooling Water Intake Structure(s) at Cooper Nuclear Station The Nebraska Public Power District (NPPD) shall continue to evaluate selected technologies to reduce impingement of fish and shellfish at the cooling water intake structure(s) at Cooper Nuclear Station. The NPPD shall send a report to the NDEQ annually by March 1 that gives an account of the evaluation of selected technologies from the previous calendar year (Jan. through Dec.). This schedule may be modified in accordance with NDEQ Title 119 and written notice from the NDEQ.

Cooper Nuclear Station NPDES Permit Number NEO0O 1244 Effective Date: July 1, 2007 Page 9 of 21 Part III. Compliance Schedule for Meeting Final Total Residual Chlorine (TRC) Limits Upon issuance of this permit, the Nebraska Public Power District (NPPD) shall implement the compliance schedule set forth below for meeting final TRC limits in Table 1 by installing equipment for dechlorination and/or by submitting a study that demonstrates that the TRC limits in Table 1 ought to be modified. This schedule may be revised in accordance with the requirements set forth in NDEQ Title 119 and written notice from the NDEQ.

The reporting requirements for TRC in Table 1 shall apply until completion of the schedule set forth below at which time the current final limits in Table lwill apply or revised limits approved by the NDEQ based on an environmental study will apply.

The NPPD shall send a report to the NDEQ every 6 months outlining progress in achieving the compliance schedule set forth below.

1. Six Months On or before six months after the issuance of this permit, the NPPD shall complete and submit a plan for an environmental study to the NDEQ for review. The study design may include sampling, modeling, or testing that would determine if the final residual chlorine concentration in Table 1 for the effluent discharge from Cooper Nuclear Station to the Missouri River could be revised.

2. One Year On or before one year after the issuance of this permit, the NPPD shall submit the results of the environmental study to the NDEQ for evaluation. The NDEQ will determine if the study demonstrates whether the current final limits for TRC in Table 1 shall continue to apply or if the current final TRC limits in Table 1 should be revised based on the conclusions of the study.

3. Two years On or before two years after the issuance of this permit, the discharge form Cooper Nuclear Station shall routinely meet the current final limits in Table 1 or revised limits approved by the NDEQ that are based on the results of the NPPD environmental study.

Cooper Nuclear Station NPDES Permit Number NE0001244 Effective Date: July 1, 2007 Page 10 of 21 Part IV. Other Requirements and Conditions A. Polychlorinated Biphenyls (PCB)

There shall be no discharge of polychlorinated biphenyl compounds such as those commonly used for transformer fluid. At the discretion of the NDEQ, this requirement for no discharge of PCBs can be confirmed either by chemical analysis of the discharge effluent or by an engineering study which would demonstrate that PCBs are not present in the final discharge.

B. Radionuclides The discharge of beta particles and photon emitters from Cooper Nuclear Station to the Missouri River shall not exceed 4 millirems per year. To document compliance with this limit, the NPPD shall submit an annual report to the NDEQ by June 1 of each year for radionuclide releases from Cooper Nuclear Station to the Missouri River from the preceding calendar year (January - December) that provides the date of release and a list of radionuclides released reported in terms of both activity (pCi/1) and exposure (millirems).

C. Narrative Limits Discharges authorized under this permit:

Shall not be toxic to aquatic life in surface waters of the State outside the mixing zones allowed in NDEQ Title 117 - Nebraska Surface Water Quality Standard; Shall not contain pollutants at concentrations or levels that produce objectionable films, colors, turbidity, deposits, or noxious odors in the receiving stream or waterway; and Shall not contain pollutants at concentrations or levels that cause the occurrence of undesirable or nuisance aquatic life in the receiving stream.

D. Disposal of Sewage Sludge The permittee shall dispose of sludge in accordance with 40 CFR Part 503. which is administered by EPA Region VII. Adherence to these regulations does not exempt the permittee from applicable NDEQ requirements.

The permittee preparing and/or applying sewage sludge shall develop all of the information required in 40 CFR Part 503.17. This information shall be retained as required by 40 CFR Part 503.

Any proposed biosolids application site must be approved by the NDEQ prior to the initial biosolids application.

E. Method Detection Limit Reporting Requirements The minimum detection limit (MDL) is defined as the level at which the analytical system gives acceptable calibration points. If the analytical results are below the MDL then the reported value on the DMR shall be a numerical value less than the MDL (e.g. <0.005).

Cooper Nuclear Station NPDES Permit Number NEO0O 1244 Effective Date: July 1, 2007 Page 11 of 21 Appendix A - Standard Conditions that Apply to NPDES and NPP Permits These general conditions are applicable to all NPDES and NPP permits. These conditions shall not preempt any more stringent requirements found elsewhere in this permit.

A. General Conditions

1. Information Available All permit applications, fact sheets, permits, discharge data, monitoring reports, and any public comments concerning such shall be available to the public for inspection and copying, unless such information about methods or processes is entitled to protection as trade secrets of the owner or operator under Neb. Rev. Stat.

§81-1527, (Cum. Supp. 1992) and NDEQ Title 115, Chapter 4.

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

The permittee shall comply with all conditions of this permit. Failure to comply with these conditions may be grounds for administrative action or enforcement proceedings including injunctive relief and civil or criminal penalties.

The filing of a request by the permittee for a permit modification, revocation and re-issuance, termination or a notification of planned changes or anticipated noncompliance, does not stay any permit condition.

3. Duty to Mitigate The permittee shall take all reasonable steps to minimize, prevent or correct any adverse impact to the environment resulting from noncompliance with this permit, including such accelerated or additional monitoring as required by the NDEQ to determine the nature and impact of the noncompliant discharge.

4. Permit Actions This permit may be modified, suspended, revoked or reissued, in part or in whole, in accordance with the regulations set forth in NDEQ Titles 119, Chapter 24. In addition, this permit may be modified, revoked and reissued to incorporate standards or limitations issued pursuant to Sections 301 (b)(b)(c), 30 l(b)(b)(d),

304(b)(b), 307(a)(b), or 405(d) of the Clean Water Act and Public Law 100-4 (i.e., industrial categorical standards and municipal sludge regulations).

5. Land Application of Wastewater Effluent The permittee shall be permitted to discharge treated wastewater effluent by means of land application in accordance with the regulations and standards set forth in NDEQ Title 119, Chapter 12, 002.

6. Toxic Pollutants The permittee shall not discharge pollutants to waters of the state that cause a violation of the standards established in NDEQ Titles 117, 118 or 119. All discharges to surface waters of the state shall be free of toxic (acute or chronic) substances which alone or in combination with other substances, create conditions unsuitable for aquatic life outside the appropriate mixing zone.

Cooper Nuclear Station NPDES Permit Number NEOQO 1244 Effective Date: July 1, 2007 Page 12 of 21

7. Oil and Hazardous Substances/Spill Notification Nothing in this permit shall preclude the initiation of any legal action or relieve the permittee from any responsibilities, liabilities or penalties under Section 311 of the Clean Water Act. The permittee shall conform to the provisions set forth in NDEQ Title 126, Rules and Regulations Pertainingto the Management of Wastes. If the permittee knows, or has reason to believe, that oil or hazardous substances were released at the facility and could enter waters of the state or any of the outfall discharges authorized in this permit, the permittee shall immediately -notify the Department of a release of oil or hazardous substances. During Department office hours (i.e., 8:00 a.m. to 5:00 p.m., Monday through Friday, except holidays), notification shall be made to the Nebraska Department of Environmental Quality at telephone numbers (402) 471-2186 or (877) 253-2603 (toll free). When NDEQ cannot be contacted, the permittee shall report to the Nebraska State Patrol for referral to the NDEQ Emergency Response Team at telephone number (402) 471-4545. It shall be the permittee's responsibility to maintain current telephone numbers necessary to carry out the notification requirements set forth in this paragraph.

8. Property Rights The issuance of this permit does not convey any property rights of any sort or any exclusive privileges nor does it authorize any damage to private property or any invasion of personal rights nor any infringement of federal, state or local laws or regulations.

9. Severability If any provision of this permit is held invalid, the remainder of this permit shall not be affected.

10. Other Rules and Regulations Liability The issuance of this permit in no way relieves the obligation of the permittee to comply with other rules and regulations of the Department.

11. Inspection and Entry The permittee shall allow the Director or his authorized representative, upon the presentation of his identification and at a reasonable time:

a. to enter upon the permittee's premises where a regulated facility or activity is located or conducted, or records are required to be kept under the terms and conditions of the permit,

b. to have access to and copy any records required to be kept under the terms and conditions of the permit,

c. to inspect any facilities, equipment (including monitoring and control), practices or operations regulated or required in the permit, and

d. to sample or monitor any substances or parameters at any location.

12. Penalties Violations of the terms and conditions of this permit may result in the initiation of criminal and/or civil actions. Civil penalties can result in fines of up to $10,000.00 per day (Neb. Rev. Stat. §81-1508, as amended to date). Criminal penalties for willful or negligent violations of this permit may result in penalties of $10,000.00 per day or by imprisonment. Violations may also result in federal prosecution.

B. Management Requirements 1.. Duty to Provide Information The permittee shall furnish to the Department within a reasonable time, any information which the Department may request to determine whether cause exists for.modifying, revoking and reissuing, or terminating this permit; or to determine compliance with this permit. The permittee shall also furnish to the Department upon request, copies of records retained as a requirement of this permit.

Cooper Nuclear Station NPDES Permit Number NE0001244 Effective Date: July 1, 2007 Page 13 of 21

2. Duty to Reapply The permittee shall apply for a re-issuance of this permit, if an activity regulated by this permit is to be continued after the expiration date of this permit. The application shall be submitted at least 180 days before the expiration of this permiton an application form supplied by the Department, as set forth in NDEQ Titles 119, Chapter 5 002.

3. Signatory Requirements All reports and applications required by this permit or submitted to maintain compliance with this permit, shall be signed and certified as set forth in this section.

a. Permit applications shall be signed by a cognizant official who meets the following criteria:

i) for a corporation: by a principal executive officer of at least the level of vice-president, ii) for a partnership or sole proprietorship: by a general partner or the proprietor, respectively, or iii) for a municipality, state, federal or other public facility: by either a principal executive officer or highest ranking elected official.

b. Discharge monitoring reports and other information shall be signed by the cognizant official or by an authorized representative.

c. The cognizant official designates an authorized representative. The authorized representative is responsible for the overall operation of the facility (i.e., the WWTF Operator, the City Manager, the Public Utilities Superintendent or similar person).

d. Any change in the signatories shall be submitted to the Department, in writing, within 30 days after the change.

e. Certification. All applications, reports and information submitted as a requirement of this permit, shall contain the following certification statement:

"I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information including the possibility of fine and imprisonment for knowing violations."

C. Monitoring and Records

1. Representative Sampling Samples and measurements taken as required within this permit shall be representative of the discharge. All samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted by any other waste stream, body of water or substance. Monitoring points shall not be changed without notification to the Department and with the written approval of the Director.

a. Composite sampling shall be conducted in one of the following manners:

i) continuous discharge - a minimum of one discrete aliquot collected every three hours, ii) less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - a minimum of hourly discrete aliquots or a continuously drawn sample shall be collected during the discharge, or iii) batch discharge - a minimum of three discrete aliquots shall be collected during each discharge.

Cooper Nuclear Station NPDES Permit Number NE000 1244 Effective Date: July 1, 2007 Page 14 of 21

b. Composite samples shall be collected in one of the following manners:

i) the volume of each aliquot must be proportional to either the waste stream flow at the time of sampling.or the total waste stream flow since collection of the previous aliquot, ii) a number of equal volume aliquots taken at varying time intervals in proportion to flow, iii) a sample continuously collected in proportion to flow, and iv) where flow proportional sampling is infeasible or nonrepresentative of the pollutant loadings, the Department may approve the use of time composite samples.

c. Grab samples shall consist of a single aliquot collected over a time period not exceeding 15 minutes.

d. All sample preservation techniques shall conform to the methods adopted in NDEQ Title 119, Chapter 21, 006 unless:

i) in the case of sludge samples, alternative techniques are specified in the 40 CFR, Part 503, or ii) other procedures are specified in this permit.

2. Flow Measurements Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be used to insure the accuracy and reliability of measurements. The devices shall be installed, calibrated and maintained to insure that the accuracy of the measurements. The accepted capability shall be consistent with the type of that device. Devices selected shall be capable of measuring flows with a maximum deviation of +/- 10%. The amount of deviation shall be from the true discharge rates throughout the range of expected discharge volumes. Guidance can be obtained from the following references for the selection, installation, calibration and operation of acceptable flow measurement devices:

a. "Water Management Manual," U. S. Department of Interior, Bureau of Reclamation, Second Edition, Revised Reprint, 2001, 327 pp. Available from the National Technical Information Services (NTIS)

b. I*NPDES Compliance Inspection Manual," U. S, Environmental Protection Agency, Office of Enforcement and Compliance Assurance, Publication EPA 300-B-94-014 September 1994. This document is available from the NationalTechnical Information Services (NTIS).

3. Test Procedures Test procedures used for monitoring required by this permit shall conform to the methods adopted in NDEQ Title 119, Chapter 21, 006 unless:

a. in the case of sludge samples, alternative techniques are specified in the 40 CFR, Part 503, or

b. other procedures are specified in this permit.

4. Averaging of Measurements Averages shall be calculated as an arithmetic mean except:

a, bacterial counts which shall be calculated as a geometric mean, or

b. where otherwise specified by the Department.

Cooper Nuclear Station NPDES Permit Number NEOOO 1244 Effective Date: July 1, 2007 Page 15 of 21

5. Retention of Records The permittee shall retain records of all monitoring activities for a period of at least three years (except five years for biosolids data) as set forth in NDEQ Titles 119, Chapter 14 001.02. The types of records that must be retained include, but are not limited to:

a. calibration and maintenance records,

b. original strip chart recordings,

c. copies of all reports required by this permit,

d. monitoring records and information, and

e. electronically readable data.

The permittee shall retain records of monitoring required by this permit that are related to biosolids use and disposal for a period of five years or longer, as required in NDEQ Titles 119, Chapter 14.

6. Record Contents As set forth in NDEQ Title 119, Chapter 14, records of sampling or monitoring information shall include:

a. the date(s), exact place, time and methods of sampling or measurements,

b. the name(s) of the individual(s) who performed the sampling or measurements,

c. the date(s) the analyses were performed,

d. the individual(s) who performed the analyses,

e. the analytical techniques or methods used,

f. the results of such analyses, and

g. laboratory data, bench sheets and other required information.

D. Reporting Requirements

1. Immediate Notification

a. NPP permittees shall report immediately to the publicly owned treatment works (POTW), any discharge to the POTW that may result in a violation of NDEQ Title 119, Chapter 26.

b. All permittees shall report immediately to the NDEQ:

i) discharges of oil or hazardous substances which threaten waters of the state or public health and welfare, and ii) discharges causing in-stream toxicity (i.e., a fish kill) or an immediate threat to human health.

Initial notification may be verbal. A written noncompliance notification shall be submitted as set forth in Section D. 3 of this Appendix.

2. Test Procedures Test procedures used for monitoring required by this permit, shall conform to the methods adopted in NDEQ Title 119, Chapter 27 unless:

a. In the case of biosolids samples, alternative techniques are specified in the NDEQ Title 119, Chapter 14; or

b. Other procedures are specified in this permit.

3. 24-Hour Reporting

Cooper Nuclear Station NPDES Permit Number NEO0O 1244 Effective Date: July 1, 2007 Page 16 of 21 As set forth in NDEQ Title 119, Chapter 14 the permittee shall report to the NDEQ, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of becoming aware of:

a. any noncompliance which may endanger the environment or human health or welfare,

b. any unanticipated bypass,

c. all upsets,

d. any discharge to a POTW that causes a violation of the prohibited discharge standards, or

e. any noncompliance of an effluent limitation in this permit.

Initial notification may be verbal. A written noncompliance notification shall be submitted as set forth in Section D. 3 of this permit.

As set forth in NDEQ Title 119, Chapter 26, if sampling performed by an industrial user (NPP permittee) indicates a permit effluent violation, the permittee shall notify the Department and the city within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of becoming aware of the violation. The permittee shall resample and have it analyzed. The results of the resampling analysis shall be submitted to the Department and the city within 30 days after becoming aware of the violation.

4. Written Noncompliance Notification

a. The permittee shall submit a written noncompliance report to the NDEQ:

i) within five days of becoming aware of any noncompliance with the:

(a) NP? effluent limitations or requirements set forth in this permit, or (b) NPDES toxic pollutant effluent limitations or requirements set forth in this permit.

ii) within seven days of becoming aware of any other noncompliance with the NPDES requirements and/or effluent limitations set forth in this permit.

b. The written notification shall be submitted on a noncompliance form supplied by the Department and shall include:

i) a description of the discharge and cause of noncompliance, ii) the period of noncompliance, including exact dates and times, or if not corrected, the anticipated time the noncompliance is expected to continue, and iii) the steps taken to reduce, eliminate and prevent the reoccurrence of the noncompliance.

The submittal of a written noncompliance report does not relieve the permittee of any liability from enforcement proceedings that may result from the violation of permit or regulatory requirements.

5. Quarterly Discharge Monitoring Reports (DMIs)

The permittee shall report the monitoring results required by this permit on a DMR form supplied or approved by the Department. Monitoring results shall be submitted on a quarterly basis using the reporting schedule set forth below, unless otherwise specified in this permit or by the Department.

Monitoring Quarters DMR Reporting Deadlines January - March April 28 April - June July 28 July - September October 28 October - December January 28 If the permittee monitors any pollutant more frequently than required by this permit, using procedures specified in this permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted on the DMR. The frequency of the analysis shall also be reported on the DMR.

Cooper Nuclear Station NPDES Permit Number NEOOO 1244 Effective Date: July 1, 2007 Page 17 of 21

6. Changes in Discharge Any facility expansion, production increases or process modifications which will result in new or substantially increased discharges of pollutants or a change in the nature of the discharge of pollutants must be reported by the permittee 180 days prior to the expansion, increases or modifications, either by amending his original application or by submitting a new application. This permit may be modified or revoked and reissued as a result of this notification to maintain compliance with applicable state or federal regulations.

7. Changes in Toxic Discharges from Manufacturing, Commercial, Mining and Silvicultural Facilities Permittees discharging from manufacturing, commercial, mining and silvicultural facilities shall report to the Department:

a. if any toxic pollutant not limited in this permit is discharged from any NPDES outfall as a result of any activity that will or has occurred and results in its routine or frequent discharge. The Department shall be informed if that discharge exceeds the following notification levels:

i) 100 micrograms per liter (0.1 mg/L) for any toxic pollutant, ii) 200 micrograms per liter for acrolein and acrylonitrile (0.2 mgiL),

iii) 500 micrograms per liter for 2,4-dinitrophenol and for 2-methyl-4, 6-dinitrophenol (0.5 mg/L),

iv) 1000 micrograms per liter for antimony (1 mg/L),

v) five times the maximum concentration value reported for that pollutant in the permit application or vi) an alternative level established by the Director, and

b. if any toxic pollutant not limited in this permit is discharged from an NPDES outfall as a result of any activity that will or has occurred and results in its nonroutine discharge. The Department shall be informed if that discharge exceeds the following notification levels:

i) 500 micrograms per liter (0.5 mg/L) for any toxic pollutant, ii) 1000 micrograms for antimony (1 mg/L),

iii) ten times the maximum concentration value reported for that pollutant in the permit application, or iv) an alternative level established by the Director.

8. Changes in Sludge Quality The permittee shall provide written notice to the Department of any alteration or addition that results in a significant change in the permittee's sludge use or disposal practices. This permit may be modified or revoked and reissued as a result of this notification to maintain compliance with applicable state or federal regulations.

9. Changes of Loadings to Publicly Owned Treatment Work (POTW)

POTW's shall notify the Department of the following:

a. any new introduction of pollutants from dischargers subject to the categorical pretreatment discharge limitations set forth in NDEQ Title 119, Chapter 27, and

b. any substantial change in the volume or character of pollutants being introduced into the POTW.

Notification shall be made 180 days in advance whenever possible. Information on the quantity and quality of new discharges and their anticipated impact on the POTW shall be included.

Cooper Nuclear Station NPDES Permit Number NE0001244 Effective Date:. July 1, 2007 Page 18 of 21

10. Transfers The permittee shall notify the Department at least 30 days prior to the proposed transfer of ownership of this permit or the permitted facility to another party. The Department may modify or revoke and reissue this permit as set forth in NDEQ Title 119, Chapter 24.

11. Compliance Schedules The permittee shall submit a written report of compliance or noncompliance with any compliance schedule established in this permit. The written report shall be submitted within 14 days following all deadlines established in the compliance schedule. If compliance has not been achieved, the report shall include an alterlnative completion date, an explanation of the cause of the noncompliance and an explanation of the steps being taken to ensure future compliance. The submission of this report does not ensure the Department's acceptance of alternative compliance dates nor does it preclude the Department from initiating enforcement proceedings based upon the reported noncompliance.

E. Operation and Maintenance

1. Proper Operation and Maintenance The permittee shall, at all times, maintain in good working order and operate as efficiently as possible, any facilities or systems of control installed by the permittee in order to achieve compliance with the terms and conditions of this permit. This would include, but not be limited to, effective performance based on designed facility removals, effective management, adequate operator staffing and training, adequate laboratory and process controls, and adequate funding which reflects proper user fee schedules.

2. Treatment System Failure and Upset An upset is an affirmative defense to an enforcement action brought for noncompliance with technology-based permit effluent limitations if the permittee can demonstrate, through properly signed, operating logs or other relevant evidence, that:

a. an upset occurred and the specific cause was identified,

b. that the facility was properly operated and maintained at such time,

c. the Department was notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the permittee becoming aware of the upset, and

d. the permittee took action to reduce, eliminate and prevent a reoccurrence of upset, including minimizing adverse impact to waters of the state.

Cooper Nuclear Station NPDES Permit Number NEO0O 1244 Effective Date: July 1,2007 Page 19 of 21

3. Bypassing Any diversion from or bypass of the treatment facilities is prohibited, unless:

a. It is unavoidable to prevent loss of life, personal injury or severe property damage; i) No feasible alternative exists, i.e., auxiliary treatment facilities, retention of untreated wastes or maintenance during normal periods of equipment downtime; ii) The permittee submits notice to the Department within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of becoming aware of the bypass or if the bypass is anticipated or should have been anticipated, the Department is notified at least ten days prior to the bypass; and iii) The bypass is conducted under conditions determined to be necessary by the Director to minimize any adverse effects.

b. If the bypass is needed for regular preventative maintenance for which back-up equipment should be provided, the bypass will not be allowed. When a bypass occurs, the burden is on the permittee to demonstrate compliance with items "a" through "d" above.

c. Additionally, ISPP permittees shall report any bypasses to the POTW. Unanticipated bypasses shall be reported immediately and anticipated bypasses shall be reported at least ten days in advance.

d. All NPDES permittees shall notify the general public that a bypass of the treatment system is occurring. The public notification shall include:

i) Location of the bypass; ii) The date the bypass started; iii) Anticipated length of time the bypass will occur; and iv) An estimate of the totalvo0lume of wastewaterfbypassed.

4. Removed Substances Solids, sludge, filter backwash or other pollutants removed in the course of treatment or control of wastewater shall be disposed of at a site and in a manner approved by the Nebraska Department of Environmental Quality. The disposal of nonhazardous industrial sludges shall conform to the standards established in or to the'regulations established pursuant to 40 CFR, Part 257. The disposal of sludge shall conform to the standards established in or to the regulations established pursuant to 40 CFR, Part 503. If solids are disposed of in a licensed sanitary landfill, the disposal of solids shall conform to the standards established in NDEQ Title 132. Publicly owned treatment works shall dispose of sewage sludge in a manner, that protects public health and the environment from any adverse effects which may occur from toxic pollutants as defined in Section 307 of the Clean Water Act. This permit may be modified or revoked and reissued to incorporate regulatory limitations established pursuant to 40 CFR, Part 503.

Cooper Nuclear Station NPDES Permit Number NEE0001244 Effective Date: July 1, 2007 Page 20 of21 F. Definitions Administrator: The Administrator oftheUSEPA.

Aliquot: An individual sample having a minimum volume of 100 milliliters that is collected either manually or in an automatic sampling device.

Biweekly: Once every other week.

Bimonthly: Once every other month.

Bypass: The intentional diversion of wastes from any portion of a treatment facility.

Daily Average: An effluent limitation that cannot be exceeded and is calculated by averaging the monitoring results for any given pollutant parameter obtained during a 24-hour day.

Department: Nebraska Department of Environmental Quality.

Director: The Director of the Nebraska Department of Environmental Quality.

Industrial Discharge: Wastewater that originates from an industrial process and / or is noncontact cooling water and / or is bojler blowdown.

Industrial User: A source of indirect discharge (a pretreatment facility).

Monthly Average: Is an effluent limitation that cannot be exceeded. It is calculated by averaging any given pollutant parameter monitoring results obtained during a calendar month.

Passive Discharge: A discharge from a POTW that occurs in the absence of an affirmative action and is not authorized by the NPDES permit (e.g. discharges due to a leaking valve, discharges from an overflow structure) and / or is a discharge from an overflow structure not designed as part of the POTW (e.g.

discharges resulting from lagoon berm / dike breaches.).

Publicly Owned Treatment Works (POTW): A treatment works as defined by Section 212 of the Clean Water Act (Public Law 100-4) which is owned by the state or municipality, excluding any sewers or other conveyances not leading to a facility providing treatment.

Semiannually: Twice every year Significant Industrial Use (SIU): All industrial users subject to Categorical Pretreatment Standards or any industrial user that, unless exempted under Chapter 1, Section 115 of NDEQ Title 119, discharges an average of 25,000 gallons per day or more of process water; or contributes a process waste stream which makes up 5 percent or more of the average dry weather hydraulic or organic capacity of the POTW; or is designated as such by the Director on the basis that the industrial user has a reasonable potential for adversely affecting the POTW's operation or for violating any National Pretreatment Standard or requirement.

30-Day Average: Is an effluent limitation that cannot be exceeded. It is calculated by averaging any given pollutant parameter monitoring results obtained during a calendar month.

Total Toxic Organics (TTO): The summation of all quantifiable values greater than 0.01 milligrams per liter (mg/l) for toxic organic compounds that may be identified elsewhere in this permit. (If this term has application in this permit, the list of toxic organic compounds will be identified, typically in the Limitations and Monitoring Section(s) and/or in an additional Appendix to this permit.)

Toxic Pollutant: Those pollutants or combination of pollutants, including disease causing agents, after discharge and upon exposure, ingestion, inhalation or assimilation into an organism, either directly from the environment or indirectly by ingestion through food chains will, on the basis of information available to the administrator, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunction (including malfunctions in reproduction) or physical ,deformations, in such organisis or their offspring.

Cooper Nuclear Station NPDES Permit Number NE0001244 Effective Date: July 1, 2007 Page 21 of 21 Upset: An exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee, excluding such factors as operational error, improperly designed or inadequate treatment facilities or improper operation and maintenance or lack thereof.

Volatile Organic Compounds (VOC): The summation of all quantifiable values greater than 0.01 milligrams per liter (mg/l) for volatile, toxic organic compounds that may be identified elsewhere in this permit. (See the definition for Total Toxic Organics above. In many instances, VOCs are defined as the volatile fraction of the TTO parameter. If the term "VOC" has application in this permit, the list of toxic organic compounds will be identified, typically in the Limitations and Monitoring Section(s) and/or in an additional Appendix to this permit.)

Weekly Average: Is an effluent limitation that cannot be exceeded. It is calculated by averaging any given pollutant parameter monitoring results obtained during a fixed calendar week. The permittee may start their week on any weekday but the weekday must remain fixed. The Department approval is required for any change of the starting day.

"X" Day Average: An effluent limitation defined as the maximum allowable "X" day average of consecutive monitoring results during any monitoring period Where "X" is a number in the range of one to seven days.

G. Abbreviations CFR: Code of Federal Regulations kg/Day; Kilograms per Day MGD: Million Gallons per Day mg/L: Milligrams per Liter NOI: Notice of Intent NDEQ: Nebraska Department of Environmental Quality NDEQ Title 115: Rules ofPracticeand Procedure NDEQ Title 117: Nebraska Surface Water Quality Standards NDEQ Title 118: Ground Water QualityStandardsand Use Classification NDEQ Title 119: Rules and RegulationsPertainingto the Issuance of Permitsunder the NationalPollutant DischargeEliminationSystem NDEQ Title 126: Rules and Regulations Pertainingto the Management of Wastes NDEQ Title 132: IntegratedSolid Waste ManagementRegulations NPDES: National Pollutant Discharge Elimination System NPP: Nebraska Pretreatment Program POTW: Publicly Owned Treatment Works pg/L: Micrograms per Liter WWTF: Wastewater Treatment Facility

Nebraska Public Power Distric

.:coop!! Nuclear Stationl,

-Permit No. NE2**12l fNPDES, Permit Renewal Application December 28, 2005 qq-G sz~

Associates

SPermit Renewal Application Prepared for:

Nebraska Public Power District Cooper Nuclear Station 2 and %/2Miles South Brownville, NE 68321 Prepared by:

GBMC & Associates 219 Brown Lane Bryant, AR 72022 December 28, 2005

CONTENTS Application Summary Combined Form 1 & 2C Area Maps Flow Diagram/Water Balance Wastewater Treatment Process Ouffall Summaries Potential Pollutants Present DMR Data Summary Analytical Data December 28, 2005 i

Application Summary APPICATI9N

SUMMARY

Nebraska Public Power District (NPPD), Cooper Nuclear Station (CNS) is a nuclear fuel electric generating facility located near Brownville, Nebraska. CNS is currently permitted through the Nebraska Department of Environmental Quality (NDEQ), National Pollutant Discharge Elimination System (NPDES) Permit No. NE0001244. CNS' current NPDES Permit expires on June, 30, 2006; therefore, this application package is' being submitted to request a renewal of the existing NPDES permit. Included with this application package are Form 1 and 2C, Area Maps, Flow Diagram/Water Balance, as well as other pertinent information necessary to complete the permit renewal process. Listed below are items that we would like to bring to your attention.

" Based on discussion between NPPD/NDEQIEPA Region 7 the agreed method for establishing the discharge limit for CNS is to use 87.5 0F and add on our maximum At across the condenser. NPPD is providing two At's for consideration in determining the discharge limit, the seasonal (April - October) maximum At is 25.6°F and the annual average monthly maximum At is 28.2°F. Using the agreed upon method, this would a yield a discharge limit between 113.1 °F and 115.7 0F.

" Outfall 005 currently is a surface discharge to a land application site. This application provides the necessary information to continue permitting Outfall 005 under NPDES.

However, we believe that Outfall 005 is eligible for authorization by rule and we request that NDEQ make that determination as the permit is being redrafted.

Unless otherwise noted, data from a period of record beginning in January 2003 and ending in September 2005 was used throughout the application for flow statistics and other application summary requirements.

" In accordance with Title 119, Chapter, Section 007, NPPD is submitting the following information concerning the cooling water intake structure:

Facility Description The Cooper Nuclear Station (CNS) is located on the Missouri River in Nemaha County, Nebraska. The plant has a single nuclear unit with a once-through cooling system. The CWIS is located on the west shoreline, as shown in Figure 1. Pertinent data is provided below.

Pertinent Data - Cooper Nuclear Station.

Location - Brownville, Nebraska Water Body - Missouri River Estimated Intake Flow

Circulating water pumps - 1,450 cfs o Total- 1,521.3 cfs December 28, 2005

Intake velocities-o Between weir wall and CWIS - - 4 ft/sec o Under curtain wall - 1.1 ft/sec o Trash rack - 0.7 ft/sec o Screens - -2.0 ft/sec Water Level

Elevations (above mean sea level)-

o Maximum - El. 899.0 ft o Minimum - El. 874.5 ft o Normal - El. 880.0 ft (summer)

Direction of flow - South East

Width of river- 800 ft (approximate)

Water depths - (in front of intake) o Maximum - 47 ft o Minimum - 18 ft o Normal- 28 ft

River flow - (release from Gavins Point Dam) o Average (April 1- Dec 1) 25,000 cfs - 35,000 cfs o Average (other) - 6,000 cfs - 20,000 cfs o Annual mean - 38,251 cfs (USGS Gauge #06807000, Nebraska City 1930-2001)

The design intake flow 1,521.3 cfs is only 4% of the mean annual river flow (38,251 cfs).

Therefore, CNS is only subject to the impingement mortality performance standard because it uses less than 5% of the mean annual river flow.

Icing considerations - ice common in winter - Heated water re-circulated, ice deflector barges, Sedimentation/dredging issues - very heavy silt loading, divers required frequently.

Other information - river is highly channelized with swift currents and fluctuating flows.

Facility Structures Intake structure o Location - western shore o Configuration - flush shoreline structure, with sheetpile deflector wall o Length - 137 ft o Number of bays - 4 o Bay width - 22 ft Curtain wall location - 53.3 ft from center line of circulating water pumps o Bottom curtain wall - El. 867.5 ft o Invert- El. 852.5 ft Top of trash rack - El. 903.5 ft o Trash rack material - 3/8 in. vertical bars o Trash rack bar spacing - 3 in. on center o Debris loading - a 10-yard truck full every month, divers remove sand from intake Bays, vacuumed every 4 months or as needed December 28, 2005 ii

Traveling water screens o Location - 33 ft from centerline of circulating water pumps o Number- 8 o Type - Modified dual flow (installation to be completed in 2006) o Rotation speeds - 8.2 fpm continuously rotated o Bay length - 9.7 ft o Bay width - 5.6 ft o Screen width - 4.2 ft o Mesh size and geometry - 1/8 x 1/2 in. smooth-top mesh o Spray wash pumps - 2 (rated at 2,000 gpm at 130 psig, actual at 3,000 gpm at 130 psig) o Spray nozzle configuration - backwash, upper and lower header o Volume- 19.4 gpm per nozzle, 17 nozzles, 330 gpm o Pressure 60 psig o Fish return (trough/ pipes) - steel 18 in. diameter pipe discharges downstream of intake

" Service Water o Number of bays- 1 o Type - Modified dual flow o Bay length - 9.7 ft o Bay width - 5.6 ft o Screen width - 4.2 ft o Curtain wall location - 63 ft from center line of service water pumps o Bottom curtain wall - El. 867.5 ft o Invert - El. 857.5 ft Top of trash rack - El. 903.5 ft o Trash rack material - 3/8 in. vertical bars o Trash rack bar spacing - 3 in. on center vertical bars o Traveling water screens - 1, same as others, except mesh is 5 mm perforated plastic mesh o Flow - 32,000 gpm max

Circulatingwater pumps o Number of pumps- 4 o Inlet - El. 856.0 ft O Rating - 1750 hp @ 277 rpm O Flow per pump - 159,000 gpm @ 35Ft TDH December 28, 2005 Mi

CHANNEL LINE SHEEWUILE CELL #1 STRUCTURE GUIDE 5' STABILIZED CHANNEL LINE DREDGE AREA Figure 1. Site Configuration of the Cooper Nuclear Station.

December 28, 2005 iv

Intake Structure The intake structure is located at Latitude 40°21'47.17" N and Longitude 95038'24.22" W. In front of the CWIS is a guide wall and submerged weir constructed of steel sheet piling which runs parallel to and at distance of 14.25 feet (ft) from the face of the intake.

The weir is physically attached at its upstream terminal to the circular cell which was left in place after the remaining cofferdam structure was removed following construction of the CWIS. The downstream terminal is 40 ft below the downstream comer of the CWIS.

No connection is made to the shore at the downstream terminal. The top elevation of the upstream portion is El. 885 ft (all elevations for CNS refer to mean sea level) which is 5 ft higher than normal summer river El. of 880 ft. The top of the weir gradually changes from El. 885 ft at the upstream terminal to a submerged downstream most weir section of El. 867.5 ft.

The purpose of the guide and weir walls is to reduce the sediment input to the CWIS. It accomplishes this by forcing bed load and other material contained in the river to flow around and past the CWIS. When the level of the river is higher than EL. 867.5 ft, most of the water spills over the top of the wall. The bed load, which is composed of heavier and larger diameter particles, is usually found in the bottom part of the river, moves along the weir wall and is directed away from the CWIS. When river level drops, a higher percentage of water goes around the weir rather than going over it. As river level drops, a higher percentage of bed load comes into the CWIS. During 2005 turning vanes were installed in front of the CWIS to redirect bed load away from the intake structure.

Water for the facility is drawn through five intake bays. Four of these bays provide circulating water to the generating unit while the other is used for service water. Each circulating water bay has an invert of El. 852.5 ft while the service water bay is El. 857.5 ft. A curtain wall with an attached ice control tunnel is located at the inlet to the structure. The bottom of the curtain wall is at El. 867.5 ft, creating a 15 ft vertical opening for water to enter the bottom of the CWIS. At the face of this opening there is grizzly bars spaced 12 in. on-center to screen large debris. Downstream of the grizzly bars is a trash rack with 3/8 in. bars spaced 3 in. on-center. This trash rack extends from the intake invert to the top deck El. 903.5 ft. The trash rack is equipped with a trash rake, which is used to clean the racks. Divers are used as needed to clean the trash racks and to remove sand from the intake. Figures 2 and 3 provide plan and cross section views of the CWIS, respectively.

Each circulating water intake bay splits into two screen bays, while the service water intake bay narrows to a smaller screen bay. These bays are 9.7 ft in length by 5.6 ft wide, providing space for 4.2 ft wide dual flow screens. Each bay is fitted with modified dual flow traveling screens designed with fish collection baskets. The modified dual flow screens operate at 90 degrees to the water flow. Fish and debris are collected on both the ascending and descending sides of the dual-flow screen which allows only filtered water to pass downstream to the pumps. Fish and debris are removed by a high pressure screen wash system and conveyed back to the river. Installation of the modified dual flow traveling screens began during 2005 and will be completed by 2006, to address debris carry-over problems encountered with the original flow through traveling screens. A decision was made by NPPD to install fish collection baskets on the dual flow screens to address future 316(b) issues. The present design and December 28, 2005 V

construction does not include installation of the low pressure spray system or a separate fish return trough and conveyance system to return fish back to the river.

Each screen has 1/8 x 1/2 in smooth top mesh and is rotated continuously at 8.2 fpm to prevent excess debris build up. A high pressure screen backwash system providing 3,000 gpm at 30-60 psig is used to remove fish and debris from the screens. Water for the screenwash is drawn from the service water pumps. Fish and debris flushed from the screens are returned to the river via an 18 in. steel pipe. This steel pipe discharges downstream from the intake. The existing screen wash system does not have the capacity to provide the required flow to support both the low pressure fish protection spray system and the high pressure debris removal system. Installation of the low pressure removal and fish return system is being evaluated, with installation being proposed during planned upgrading of the of the screen wash and sparger systems.

The two systems are being upgraded to provide continued and reliable operation of the traveling water screens and service water system in the future.

Four circulating water pumps provide the circulating water for the facility. Each pump can draw 159,000 gpm. The pump design water level is at El. 875.0 ft, with a minimum submergence level at El. 865.0 ft. Below this level, the plant cannot continue generation. There are four service water pumps providing a combined flow of 32,000 gpm. Velocities in the intake structure are 1.1 ft/sec under the curtain wall, 0.7 ft/sec at the trash racks, and approximately 2.0 ft/sec at the traveling water screens. These velocities were calculated at low water levels (El. 874.5 ft) and maximum circulating water pump flow (159,000 gpm per pump).

Existing Hydraulic Conditions Flow of the Missouri River at CNS is largely controlled by the Gavins Point Dam located about 200 miles upstream in Yankton, South Dakota. The river is about 800 ft wide and flows in a southeasterly direction. The flow is highly channelized with swift flows and heavy sediment transport. To minimize the effects of sedimentation on the intake, turning vanes and a low sheetpile wall is located in front of the intake bays. Wing dams are located on the Missouri side of the river to force the flow into a central channel. The water levels in the river range from a maximum at El. 899.0 ft to a minimum at El. 874.5 ft, with a normal level at El. 880.0 ft. The annual mean river flow is 38,251 cfs (1930-2001) at the USGS gauging station at Nebraska City, Nebraska. This gauging station is located approximately 30 river miles north of the CNS CWIS. During the winter, ice is very common on the river. To prevent ice damage, ice deflector barges are installed during the winter months. To prevent the formation of frazzle ice, some of the main condenser discharge water (25-30%) is re-circulated through the ice control tunnel and released in front of the trash rack within the CWIS while the remaining water is discharged about 1,300 ft downstream of the intake via a discharge canal.

December 28, 2005 Vi

"N t\ 7N OTI, I--

SERAJCE WATER PUMPS

- I1 0 _j CIRCULATING LI~

WATER PUJMPS 32 - 1.5' r Im-

!- - --- - ~i TRAVELING SCREENS

~L ~1 ~ ý ~< [rý1 r~17. ,-BAR RACKS 3_c_>ý 15ý 0-:;;41 Ill-ýO t 10ý__ý 97' 1.1 i 1-22" - 6'- 1 13L L 22I 30 Figure 2. Cooper Intake Structure - Plan.

December 28, 2005 vAl

CIRCULATING WATER PUMP ICE CONTROL TUNNEL SLUICE GATES EL. 852'-6" Figure 3. Cooper Intake Structure - Section.

December 28, 2005 vilil

Form 1 & Form 2c A Nebraska Department Of Environmental Quality Wastewater Section Suite 400, The Atrium, 1200 'N' Street PO Box 98922 Lincoln, NE 68509-8922 Tel. 402/471-4220 Fax4O2/471-2909 NPDES Combined Form I & 2C National Pollutant Discharge Elimination System Permit Application for a Facility Discharging Wastewater from Manufacturing and Commercial Operations.

This Area is for Agency Use NPDES Number NEOO001244 -7 1S Number jDate Rec'd

1. Facility Information A. Owner of Facility (Pernittee)

Nebraska Public Power District Street 2 and '/2 miles south

- City Brownville State NE Zip 68321 B. Name of Facility Cooper Nuclear Station C. Facility Contact Person

. . LA Ph 402-825-5323 Email sbminah(anppd.com D. Facility Mailing Address Street PO Box 98 City Brownville State NE Zin 68321 above)

Locationfrom (if different E.Facility E. Facility Location (if different from above)

Street Street City State zip Zip F. Facility Legal Description NE Y of the NW V4,Section 32 ,Township 5. N, Range I6E (E or W), Nemaha County G. Business Activity and Facility Operations (continued on next page)

Standard Industrial Classification (SIC) Code(s) Applicable to the Facility 4911 Page I of 12 REV (5/03)

Description of Operations and Services:

Electric generating facility using nuc]lear fuel.

2. Wastewater Sources (check applicable items)

A. A~plication Status (check one) 2LXX NPDES Permit Reapplication for Existing Source NPDES Permit Application for New Source B. Additional Forms Required Facility discharging domestic wastewater Submit NPDES Form 2A XX Facility discharging industrial wastewater Submit NPDES Form 2C Facility discharging nonprocess wastewater Submit NPDES Form 2E Facility is a fish hatchery or fish farm Submit NPDES Form 2B Industrial facility discharging storm water Submit NPDES Form 2F

-Land application of treated effluent Submit Land Application Form

3. Other Existing Environmental Permits Permit Number XX NPDES (discharge to surface water) NE0001244 NPP (Nebraska Pretreatment Permit)

IX UIC(underground injection of fluids)(yes) NE0208256 XX RCRA (hazardous waste)(yes) NED055071062 Air Permit(yes)

Other (specify)

XX Storm water NER000059

_L.___Public Water Supply (non-community) NE3150505

4. Map Attach to this application a topographic map (7.5 minute USGS) of the area extending to at least one mile beyond property boundaries.

The map must show the outline of the facility, the location of each of its existing and proposed intake and discharge structures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs, rivers, and other surface water bodies in the map area.

5. Facility Flow Diagram Attach a line drawing showing the water flow through the facility. The diagram must show all regulated and non-regulated process wastewater flows, and all points of discharge to sanitary sewer, storm sewers, surface waters, septic tanks, injection wells, or other discharge points including floor drains. Indicate sources of intake water, operations contributing wastewater to the effluent, and wastewater treatment units along with each discharge outfall. Construct a water balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls.

Page 2 of 12 REV (5/03)

6. Process Wastewater Treatment System Information A. Does the process wastewater undergo treatment before discharge to the receiving water?.

X Yes No Provide a description of the wastewater treatment process. Include a description of the physical; chemical, or biological treatment processes used to treat the wastewater. (a schematic diagram of the treatment process should also be provided)

SEE WASTEWATER TREATMENT PROCESS ATTACHMENT Maximum Daily Flow (MGD) 0,016 MGD Design Daily Flow (MGD) N/A Average Daily Flow (MGD) 0.016 MGD Design Maximum Flow (MGD) N/A B. Is there any sludge (i.e. any solid, semisolid, or liquid waste) generated from the process wastewater treatment system?

--e _.Yes No If yes, provide an attachment specifying sludge treatment and disposal practices. - See wastewater treatment process attachment, Outfall 005.

C. Does the treatment works land-apply treated wastewater.?

XX Yes (If yes, request a separate application form) No

7. Operator Information A. Treatment Facility Operator (Last. First.) and Phone Number Duane Sabins Ph 402-825-5274 Email dksabin( ).nmdpcom Operator Certification Number 2644 Operator Class Grade 3 B. Operator's Mailing Address Street Same as first page City NA State NA Zip NA C. Operation/Maintenance Performed by Contractor(s)

Are any operational or maintenance aspects (related to wastewater treatment and effluent quality) of the treatment works the responsibility of a contractor? yes 2XX no If yes provide the following Name Ph Email Street City State Zip Responsibilities of Contractor Page 3 of 12 REV (5/03)

D. Compliance Sampling Is compliance sampling of the discharge effluent the responsibility of a contract laboratory? XX yes ___no If yes provide the following Name Midwest Laboratories, Inc. Ph 402-334-7770 Email Street 13611 B Street City Omaha State N-LE Zip 68144 Responsibilities of laboratory Analytical Chemistry Name -Environmental Analysis South, Inc. Ph - Email Street 4000 East Jackson Blvd City Jackson State MO Zip 63755 Responsibilities of laboratory Tox Lab

8. "Non-Discharged" Wastes Provide descriptions and quantities of wastes generated that are not discharged to the POTW or Waters of the State (provide attachment if more space is needed). Also describe how these wastes are disposed of:

None

9. Outfall Information How many separate outfalls discharge to the receiving waters? 9 A. Location of Outfall(s) (Include an attachment to the permit for the following information if there are more than three ouffalls).

(SEE OUTFALL

SUMMARY

ATTACHMENT)

Outfall 001 S VA Quarter, SW_.. Quarter, Section 29, Township 5L North, Range 16 tff /West),NeWaha County, NE Latitude (deg. 4 min.

r 21 sec 41.5 N ) Longitude (deg. 95 min. 38 se 22.8 W)

Name of receiving waters Discharge canal to Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Cooling water Flow 625(mgd) Operation -Flow Operation Flow Operation Flow Outfall 002 A S !/ Quarter, SW % Quarter, Section 2L9_ , Township L.._._North, Range 16 dROWest), Nemaha County, NE Latitude (deg .4.0 in. 21 see 44.7N Longitude (deg. 95 min. 38 see 22.5W Name of receiving waters Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Roof Drains Flow N/A Operation ______Flow Total (both operations) Flow: 0.03 mgd Operation Sumps (outside bower block) Flow N/A Operation Flow Page 4 of 12 REV (5/03)

Outfall 002B S 1/2A Quarter, SW 'AQuarter, Section 29 Township L_.North, Range 16 (JEO*est), Nemaha County, NE Latitude (deg .40 rain. 21 sec 44.7 N ) Longitude (deg. 95 rmin. 38 sec 22.5W Name of receiving waters Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and nonprocess wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Emergency Outfall 004 overflow Flow N/A Operation Industrial well bypass Flow N/A Operation - Flow Operation Flow Outfall 002C S A .Quarter, SW 'AQuarter, Section 29 Township 5_North, Range 16.West), NeaaCounty, NE Latitude (deg .40 min. 21 sec 44.7 N ) Longitude (deg. 95 min. 38 sec 22.5W Name ofreceiving waters Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e~g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Floor Drains Flow N/A Operation Diesel Generator Room Sump Flow N/A Operation HVAC Blowdown Flow N/A Operation Turbine Fan Heater Flow Total (all operations) Flow: 0.005 mad Outfall 003 S !6 Quarter, SW /.. Quarter, Section 29 , Township 5._North, Range 16 _*West), Nemaha County, NE Latitude (deg. 40. min. 21 sec 45.9 N ) Longitude (deg. 95rin. 38 sec 24.0 W_)

Name of receiving waters Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Screen Backwash (Missouri River water) Flow 6.49 mgd Operation Flow Operation Flow Operation Flow Outfall 004 S '/2 Quarter, SW '4 Quarter, Section 29 , Township L..North, Range 16 MMWWest), Nemaha County, NE Latitude (deg.400 rain. 21 sec 40.5 N ) Longitude (deg._.2L__min. 38 sec 20.9 W)

Name of receiving waters Discharge canal to Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation R.O. Reiect Flow N/A Operation Flow Total (both operations)Flow: 0.03 med Operation Boiler Blowdown Flow N/A Operation Flow Page 5 of 12 REV (5/03)

Outfall 005 NE % Quarter, NW 1/4/4 Quarter, Section 32 Township 5_North, Range 16 (MJest), Nemaha County, NE Latitude (deg. 40 min. 21 sec 32.8 N )Longitude (deg. 95 min. 38 sec 27.7W)

Name of receiving waters N/A Land Application Name of watershed if known N/A Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Sanitary Flow N/A Operation Flow Total (both operations) Flow: 0.21 mgd Operation Fire training Dad runoff Flow N/A Operation Flow Outfall 006 S 1/2/2 Quarter SW 1/4/Quarter, Section 29, Township jNorth, Range J16 .. West), Nemaha County, NE Latitude (deg.40 min. 21 sec 39.8N )Longitude(deg. 95 min. 38 sec 22.3W)

Name of receiving waters Discharge canal to Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Service water "once through" Flow N/A Operation Flow Total Flow: 27.6 mgd Operation Flow N/A Operation Flow Outfall 008 S V2 Quarter, SW Quarter, Section 29 ,Township __North, Range 16 0 est), Nemaha County, NE Latitude (deg. 40 min. 21Lsec 44.4 N ) Longitude (deg 95. min. 38 sec -W Name of receiving waters Discharge canal to Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Low volume wastewater from primary plant systems Flow 0.016 mad Operation 'Flow Operation Flow Operation Flow Outfall 009 S '/ Quarter -SW Quarter, Section 29*, Township 5_North, Range 16_*(] est), Nemaha County, NE Latitude (deg. 40 rain. 21 sec 44.4 N) Longitude (deg 95.min. 38 sec 28.8 W)

Name of receiving waters Discharge canal to Missouri River Name of watershed if known Missouri River Provide a description of all operations contributing wastewater to the effluent to include both process and non process wastewater (e.g.

noncontact or sanitary) and the average flows contributed by each process.

Operation Low volume wastewater from primary plant systems Flow no discharge in past 5 years Operation Flow____

Operation Flow N/A -Operation Flow Page 6 of 12 REV (5/03)

B. Except for storm runoff, leaks or spills, are any of the discharges described above intermittent or batch? Yes If yes, provide the following information:

T 1 T Outfall Operations Frequency Flow Rate Total Volume Duration in Number Contributing Flow (specify averages) (in MGD) (in gal.) Days days/week months/yr average maximum average I maximum 002A002A Sumps Storm Water & Variable 5.3' 0.03 0.22 Variable Variable N/A 2

002B RO Rgect, Boiler HAS NOT DISCHARGED IN PREVIOUS 5 YEARS Blowdown 002C00C HVAC Drains,Biowdown Sumps, Variable 5.6 0.0005 0.004 Variable Variable N/A Fire Training Pad, 005 Sanitary (Land N/A 2.3 0.21 0.29 N/A N/A N/A Applied) 008 Waste sample tank N/A N/A 0.016 ONLY ONE DISCHARGE IN PREVIOUS 5 YEARS (RCA) 009 Floor drains (RCA) N/A HAS NOT DISCHARGED IN PREVIOUS 5 YEARS

1. Frequency determined by dividing the number of months where discharge occurred by the number ot months examined (33 months of records, January 2003 through September 2005, were reviewed).

2. Outfall 002B is an emergency outfall for the settling basin that normally discharges via Outfall 004.

10. Production A. Does an Effluent Guideline limitation or standard apply to your facility? (e.g. metal finishing, fertilizer manufacturing, etc)

XX Yes (complete item 10 B below) No (go to Section II)

B. Are the limitations in the applicable Effluent Guideline expressed in terms of production or other measure of operation?

(e.g., pounds of pollutant per million pounds of production)

_ Yes (complete table below) No XX (go to Section 11)

Page 7 of 12 REV (5/03)

Affected Outfalls Quantity per Day Units of Measure Specify Operation, Product, or Materials N/A

11. Intake and Effluent Characteristics A. List the sources of intake water Source Gallons per day (gpd)

Municipal System N/A Ground Water Industrial well: 0.0lmind (Ave)

Other Circulation water: 736 mad (Avg)

Total Service water: 28.6 mgd (Avg)

B.Which (if any) industrial category listed in Attachment A, Table I does your facility fall under? Steam Electric Power Plant Provide an attachment to this application that lists all the pollutants listed in Attachment A, Tables II-V, which you know or have reason to believe are or may be discharged from any outfall. Also provide the source of the pollutants, the outfall they are discharged from and approximate amount discharged. If you have analytical results for any of these pollutants, please attach these as well.

NDEQ may require additional information and/or analysis of these pollutants at a later date.

C. Provide the results of at least one analysis for every pollutant in this table for each outfall. This testing may be waived by the NDEQ in some circumstances or additional tests may be required by NDEQ to complete the application process. (provide an attachment for additional outfalls)

Outfall Number: 001/006 Pollutant Units Maximum daily value Average monthly value No. of analyses Biochemical oxygen demand (BOD) mg/L 3.0 3.0 1 Chemical oxygen demand (COD) m/L 6.0 6.0 1 Total organic carbon (TOC) m/L 7.05 7.05 1 Ammonia (asN) mg/l 0.1 0.1 1 Flow MGD 948 625 33 Temperature OF 109.2 75.7 33 pH S.U. Maximum = 8.7 Minimum = 6.8 33 Outfall Number: 004 Pollutant Units Maximum daily value Average monthly value No. of analyses Biochemical oxygen demand (BOD) mg/L 4.0 4.0 1 Chemical oxygen demand (COD) mg/L 5.0 5.0 1 Total organic carbon (TOC) mg1L 8.32 8.32 1 Ammonia (as N) mg/L >0.1 >0.1 1 Flow MGD 0.48 0.03 10 Temperature -F Ambient - --

pH S.U. Maximum = 8.5 Minimum = 6.9 10 Page 8 of 12 REV (5/03)

Outfall Number: 005 Pollutant Units Maximum daily value Average monthly value No. of analyses Biochemical oxygen demand (BOD) mg/L 20.0 20.0 !

Chemical oxygen demand (COD) .mg/L 106 106 I Total organic carbon (TOC) mg/L --.... _

Ammonia (as N) mg1L <0.1 <0.1 1 Flow MGD 1_0.63 0.21 7 Temperature OF Ambient -- -

pH S.U. Maximum = 9.7 Minimum = 8.0 3 D. Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on a receiving water in relation to your discharge within the last three years?

XX Yes No If yes, identify the tests and describe their purpose below Acute toxicity has been conducted at outfall 004 as required in the existing NPDES Permit.

Page 9 of 12 REV (5/03)

12. Other Information Use the space below to expand upon any of the above questions or to bring to the attention of the reviewer any other information you feel should be considered in establishing permit limitations for the facility.

SEE APPLICATION

SUMMARY

13. Certification (see Signatory Authorization Form for designation of Cognizant Official)

I certify that I am familiar with the information contained in the application, that to the best of my knowle~ige and belief such information is true, complete, and accurate, and if this permit is granted, I agree to abide by the Nebraska Environmental Protection Act (Neb. Rev. Stat. Sees. 81-1501 e. seg. as amended to date) and all rules, regulations, orders, decisions promulgated there under, and subject to any legitimate appeal a to e a licai nder the Act Cognizant Official's signature, e " Date-D-a 12 1)i ;o Cognizant Official's Printed N John C. McClure Title Vice President & General Counsel Page 10 of 12 REV (5/03)

Nebraska Department of Environmental Quality NPDES/NPP SIGNATORY AUTHORIZATION FORM This form is to be used to identify or update information pertaining to the facility. THIS FORM MUST BE SIGNED BY THE COGNIZANT OFFICIAL. The Coenizant Official and Authorized Revresentative can be the same nerson.

Facility Name: Nebraska Public Power District Permit No. NE Address: 2 and 2miles South City Brownville Zip 68321 County Nemaha Location (Street Directions to) See Area Maps Phone (402)825-5000 PERMITTEE List the NAME of the company, business, governmental entity, or person that owns the facility and that will be responsible for the permit compliance:

COGNIZANT OFFICIAL This person is responsible for the permit, signing reapplications, signing DMRs or designating someone to sign DMRs (Authorized Representative) and other correspondence. For a municipal, only the mayor, chairperson or city manager may sign as the Cognizant Official. Seepage 10for requirements.

Name John C. McClure Title Vice President & General Counsel

Mailing Address 1414 15h Street City Columbus State Nebraska Zip 68601-0499 Phone (402)563-5773 Home Ph (optional)

AUTHORIZED REPRESENTATIVE (Do not complete if same as Cognizant Official)

This person is designated by the Cognizant Official and is responsible for receiving, completing and signing DMRs, and receiving other correspondence (i.e., city clerk, plant operator). Seepage 10for requirements.

Name K. Michael Kmumland Title Environmental Protection Supervisor

Mailing Address 1414 1Sth Street .City Columbus State Nebraska Zip 68601-0499 Phone (402)563-5329 Home Ph (optional)

If you represent this Facility as/for a Contractor, list: Contractor's Name Contractor's AAArl, Phone OPERATOR This person is responsible for the operation and maintenance of the plant. Seepage 10for requirements.

Name Stewart B. Minahan Title General Manager of Plant Operations Certification #

Mailing Address 2 and !12Miles South Phone (402)825-5323E If you represent this Facility as/for a Contractor, list: Contractor's Name Contractor's Address Phone

Mailing Address: DMRs will be mailed to this address. DO NOT use a home or personal address unless necessary.

Please use city/village office address or facility/corporate address, etc. This address should remain the same, even with changes in the facility's Cognizant Official or Authorized Representative.

Mailine Address: DMRs will be mailed to this address. DO NOT use a home or personal address unless necessary.

Please use city/village office address or facility/corporate address, etc. This address should remain the same, even with changes in the facility's Cognizant Official or Authorized Representative.

Page I11of 12 REV (5/03)

NPDES/NPP SIGNATORY AUTHORIZATION FORM (continued)

W! 'K .,,T.ZAI')AA

.. tP" Facility Name: NPPD-Cooper Nuclear Station Per .J~* 0.

COMMENTS COGNIZANT OFFICIAL SIGNATURE Jn DATE_

PRINTED NAME OF COGNIZANT O____1____John___C.__Mc__lure_

SIGNATORY AUTHORIZATION FORM REQUIREMENTS Cognizant Official. Nebraska Department of Environmental Quality, Title 119, Chapter 10 and Title 127, Chapter 29. All permit applications submitted to the Department shall be signed:

001.01 in the case of a corporation, by a principal executive officer of at least the level of vice-president; 001.02 in the case of a partnership, by a general partner;,

001.03 in the case of a sole proprietorship, by the proprietor; and 001.04 in the case of a municipal, state or other public facility, by either a principal executive officer or ranking elected official.

Authorized Representative. Nebraska Department of Environmental Quality, Title 119, Chapter 10 and Chapter 127, Chapter 29 002. All other correspondence, reports and DMRs shall be signed by a person designated in 001.01 through 001.04 above or a duly authorized representative if such a representative is responsible for all the overall operation of the facility from which the discharge originates; the authorization is made, in writing, by the person designated under 001.01 through 001.04 above; and the written authorization is submitted to the Director. Any change in the signatures shall be submitted to the Department, in writing, within 30 days after the change.

Operator. Nebraska Department of Environmental Quality, Title 123, Chapter 15 001 A competent operator familiar with the principles of wastewater treatment and disposal and skilled in the operation of the plant equipment, shall be in charge of each wastewater works. The operator shall make such operations tests as may be specified by the Department.

The operator may be required to be certified according the NDEQ Title 197.

Nebraska Department of Environmental Quality A TTN: Sharon Brunke, NPDES Permit Unit Suite 400,1200 N Street, The Atrium PO Box 98922 Lincoln, Nebraska 68509-8922 Telephone (402) 471-4220 Fax (402) 471-2909 Page 12 of 12 RV(5/03)

Attachment A Table I-Testing Requirements for Organic Toxic Pollutants by Industrial Category for Existing Disclaimers GCUMS Fraction X1%

1 f ~Base./

Industrial category Volatile Acid neutral Pesticide Adhesives and Sealants ........... \2\ \2\ \2\

Aluminum Forming ................. \2\ \2\ ........

Auto and Other Laundries ......... Q \2\ \2\ \2\

Battery Manufacturing ............ \2\ ........... \\ ..........

Coal Mining ...................... 02\ \2\ U\

Coil Coating ..................... \2\ \2\ \2\

Copper Forming ................... \2\ \2\ \2\ ....

Electric and Electronic 2\ \2\ \2\ \

Components ......................

Electroplating ................... \\ \2\ \2\

ExplosivesManufacturing ................. \2\ \2\ ..........

Foundries ........................ \2\ \2\ \2\ .....

Gum and Wood Chemicals ........... 0 \2\ \2\ \

Inorganic Chemicals Manufacturing \\ \2\ \2\ ........

Iron and Steel Manufacturing ..... \2\ \2\ \2\ ........

Leather Tanning and Finishing .... \2\ \2\ \2\ \2\

Mechanical Products Manufacturing \2\ \2\ \2\

Nonferrous Metals Manufacturing.. \2\ \2\ \\22\

Ore Mining ....................... \\ \2\

\2\ \2\

Organic Chemicals Manufacturing.. \2\ \2\ \2\ \2\

Paint and Ink Formulation ........ Q \2\ \2\

Pesticides ....................... \2\ \2\ \2\ \2\

Petroleum Refining ............... \2\ \\ \2\ \2\

Pharmaceutical Preparations ...... \2\ \2\ \2\

Photographic Equipment and \2\ \2\ \2\ \2\

Supplies .......................

Plastic and Synthetic Materials \2\ \2\ \2\ \?.

Manufacturing ...................

Plastic Processing ............... \2\ ........ .... ........

Porcelain Enameling .............. \2\ ......... \2\ \

Printing and Publishing .......... \2\ \2\ \2\ \2\

Pulp and Paper Mills ............. \2\ \2\ \2\ \2\

Rubber Processing ................ \2\ \2\ \2\ .........

Soap and Detergent Manufacturing. \2\ \2\ \2\ .....

Steam Electric Power Plants ...... \2\ \2\ \2\ ........

Textile Mills .................... \2\ \2\ \2\ \2\

ITimber Products Processing ....... \2\ \2\ \2\ \2\

\1\ The toxic pollutants in each fraction are listed in Table 11.

\2\ Testing may be required.

Attachment A Table H- Organic Toxic Pollutants In Each of Four Fractions in Analysis by Gas Chromatography/Mass Spectroscopy (GS/MS) (continued on next page)

Volatiles I Vacrolein 17. V 1,2-dichloropmpane

2. Vacrylonitrile 18. V 1,3-dichloropropylene

3. V benzene 19. V ethylbenzene

5. V bromofonn 20. V methyl bromide

6. V carbon tetrachloride .21. V methyl chloride

7. V chlorobenzene 22. V methylene chloride

8. V chlorodibromomethane 23. V 1,1 ,2,2-tetrachloroethane

9. V chioroethanc 24. V tetrachloroethylene

]0. V 2-chioroethylvinyl ether 25. V toluene I I V chlorofonn 26. V 1,2-trans-dichloroethylene

12. V dichlorobromomethane 27. V 1,1,1-trichloroethane

14. V 1,1-dichloroethane 28. V 1,1 ,2-trichloroethane

15. V 1,2-dichloroethane 29. V trichibroethylene

16. V 1,l-dichloroethylene 31. V vinyl chloride Acid Compounds 1.A 2-chlorophenol 7A 4-nitrophenol

2. A 2,4-dichlorophenol 8A p-chloro-m-cresol

3. A 2,4-dimethylphenol 9A pentachlorophenol

4. A 4, 6-dinitro-o-cresol I OA phenol

5. A 2,4-dinitrophenol 11 A 2,4,6-trichlomphenol 6A 2-nitrophenol BaselNeutral (continued on next page)

IB acenaphthene 16B 2-chloronaphthalene 2B acenaphthylene 17B 4-chlorophenyl phenyl ether 3B anthracene 18B chrysene 4B benzidine 19B dibenzo( ah )anthracene 5B benzo(a)anthracene 20B 1,2-dichlorobenzene 6B benzo(a)pyrene 21B 1,3-dichlorobenzene 7B 3,4-benzofluoranthene 22B 1,4-dichlorobenzene 8B benzo(ghi)perylene 9B 23B 3,3'-dichlorobenzidine benzo(k)fluoranthene 24B diethyl phthalate 1OB bis(2-chloroethoxy)rnethane 25B dimethyl phthalate 11B bis(2-chloroethyl)ether 26B di-n-buty] phthalate 12B bis(2-chloroisopropyl)ether 27B 2,4-dinitrotoluene 13B bis (2-ethylhexyl)phthalate 28B 2,6-dinitrotoluene 14B 4-bromophenyl phenyl ether 29B di-n-octyl phthalate 15B butylbenzyl phthalate 30B 1,2-diphenylhydrazine (as azobenzene)

Attachment A Table H- Organic Toxic Pollutants in Each of Four Fractions in Analysis by Gas Chromatography/Mass Spectroscopy (GS/MS) (continued)

BaselNeutral (continued) 31B fluroranthene 40B nitrobenzene 32B fluorene 4 1 B N-nitrosodimethylarnine 33B hexachlorobenzene 42B N-nitrosodi-n-propylamine 34B hexachlorobutadiene 43B N-nitrosodiphenylamine 35B hexachlorocyclopentadiene 44B phenanthrene 36B hexachloroethane 45B pyrene 37B indeno(1,2,3-cd)pyrene 46B 1,2,4-trichlorobenzene 38B isophorone 39B napthalene Pesticides IP aldrin 14P enddn 2P alpha-BHC I 5P endrin aldehyde 3P beta-BHC 4P i 6P heptachlor gamma-BHC 5P 17P heptachlor epoxide delta.BHC.6P _.8PfPCB-I 242 chlordane 19P PCB- 1254 7P 4,4'-DDT 20P PCB-1221 8P 4,4'-DDE 2 IP PCB-1232 9P 4,4'-DDD 22P PCB-1248 lOP dieldrin 23P PCB- 1260 l IP alpha-endosulfan 24P PCB-1016 U2P beta-endosulfan 25P toxaphene 13P endosulfan sulfate Table Ill Other Toxic Pollutants (Metals and Cyanide) and Total Phenols Antimony, Total Nickel, Total Arsenic, Total Selenium, Total Beryllium, Total Silver, Total Cadmium, Total Thallium, Total Chromium, Total Zinc, Total Copper, Total Cyanide, Total Lead, Total Phenols, Total Mercury, Total

Attachment A Table IV-Conventional and Nonconventional Pollutants Total Residual Color Surfactants Fecal Coliform Aluminum, Total Fluoride Barium, Total Nitrate-Nitrite Nitrogen, Boron, Total Total Organic Oil and Cobalt, Total Grease Phosphorus, Total Iron, Total Radioactivity Magnesium, Total Sulfate Molybdenum, Total Sulfide Manganese, Total Sulfite Tin, Total Titanium, Total

Attachment A Table V--Toxic Pollutants and Hazardous Substances Required To Be Identified by Existing: Disclaimers if Expected To Be Present Toxic Pollutants Asbestos Hazardous Substances Acetaldehyde Kelthane Allyl alcohol Kepone Allyl chloride Malathion Amyl acetate Mercaptodimethur Aniline Methoxychlor Benzonitrile Methyl mercaptan Benzyl chloride Methyl methacrylate Butyl acetate Methyl parathion Butylamine Mevinphos Cap tan Mexacarbate Carbaryl Monoethyl amine Carbofuran Monomethyl amine Carbon disulfide Naled Chlorpyrifos Napthenic acid Coumaphos Nitrotoluene Cresol Parathion Crotonaldehyde Phenolsulfanate Cyclohexane Phosgene 2,4-D (2,4-Dichlorophenoxy acetic acid) Propargite Diazinon Propylene oxide Dicamba Pyrethrins Dichlobenil Quinoline Dichione Resorcinol 2,2- Dichloropropionic acid Strontium Dichlorvos Strychnine Diethyl amine Styrene Dimethyl amine 2,4,5- T (2,4,5- Trichlorophenoxy acetic acid)

Dintrobenzene TDE (Tetrachlorodiphenylethane)

Diquat 2,4,5- TP [2-(2,4,5- Trichiorophenoxy) propanoic acid]

Disulfoton Trichlorofan Diuron Triethanolamine dodecylbenzenesulfonate Epichlorohydrin Triethylamine Ethion Trimethylamine Ethylene dianfine Uranium Ethylene dibromide Vanadium Formaldehyde Vinyl acetate Furfural Xylene Guthion Xylenol Isoprene Zirconium Isoorooanolamine Dodecylbenzenesulfonate

Area Maps

3I Nebraska Public Power District Cooper Nuclear Station Sections 19, 20, 29, 30, 31, 32 Township 5 North

Range 16 East Nemaha County 2 and 112 miles south Brownsville, Nebraska 68321 10 I

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002o (0.03 MOD) 002b(nFow-N/A) 002c (0.005 MCD)

Wastewater Treatment Process WASTEWATER TREATMENT PROCESS Future Treatment Upgrades (Outfall 0011006)

A chlorination system may be added on the Missouri River intake water systems, circulation water system (Outfall 001) and service water system (Outfall 006). The location of the chlorination systems would be prior to the main condenser on the circulation water system and prior to the heat exchangers on the service water system (see flow diagram / water balance).

Average Flows: Outfall 001 - 625 MGD, Outfall1006 - 27.6 MGD Settling Basin (Outfall 004)

Industrial well water goes through the reverse osmosis (RO) treatment system, the RO reject water from the system then goes to the Outfall 004 settling basin for treatment.

Average Flow: Outfall 004 - 0.03 MGD Oil/Water Separator I Sanitary Lagoons (Outfall 005)

Runoff from the fire training pad is directed through an oil and water separator then collected and held in a portable frac tank. The frac tank (as needed) is then emptied into a series of two sanitary treatment lagoons. Wastewater from the lagoons is pumped (land applied) via Outfall 005 onto the permitted land application site on an intermittent basis.

Average Flow: Outfall 005 - 0.21 MGD Primary Plant Systems Wastewater Treatment Low Volume Waste (Waste Sample Tanks, Outfall 008)

Low volume wastes from the primary plant systems are collected in one of two temporary storage tanks (Outfall 008). Each waste collection tank holds approximately 22,000 gallons.

The collected wastewaters are generated from the reactor cleanup system, the residual heat removal system, equipment drains in the radioactivity control area (RCA), and decants from residual phase separator tanks. Wastewater from these tanks cycle through a closed loop treatment system and are treated by filtration and deep-bed demineralization until the purity is suitable for reuse. Once the cleaned water is suitable for reuse, it is transferred to a 450,000 gallon condensate storage tank for reuse throughout the primary plant systems. If the treated water exceeds the needs of the primary plant systems and exceeds the capacity of the treated wastewater storage tanks, a discharge via Outfall 008 will be sent to the Missouri River via the discharge canal. Since the water clean up process is relatively expensive, efforts are taken to reuse/recycle all low volume wastewater, thus discharge is a rare event. Outfall 008 has only discharged once (June, 2003) during the past five years.

Outfall 008 is sampled at the tanks described in this section. It is not physically possible to sample Outfall 008 at its point of discharge since the discharge ties into the service water line December 28, 2005 I

that discharges via Ouffall 006 which is located underwater in the main (Outfall 001) discharge canal.

Average Flow: Outfall 008 - 0.016 MGD Low Volume Waste (Floor Drain Tank, Outfall 009)

Low volume wastes from the floor drains in the primary plant systems (specifically from the RCA) are collected in a temporary 20,000 gallon storage tank (Outfall 009). Currently, wastewater from this tank is slowly fed into the same closed loop treatment system as described for Outfall 008 above and reused throughout the primary plant systems. If this normally recycled water exceeds the needs of the primary plant systems and also exceeds the capacity of the treated wastewater storage tanks, a discharge via Outfall 009 could occur. In that event the highly treated water would be discharged to the Missouri River via the main (Outfall 001) discharge canal. However, current procedures at CNS require that any discharge of low volume wastewater from the primary plant systems would occur through the Outfall 008 storage tanks. Since the water clean up process is relatively expensive, efforts are taken to reuse/recycle all low volume wastewater, thus discharge is a rare event. Ouffall 009 has not discharged during the past five years.

Outfall 009 is sampled at the tank described in this section. It is not physically possible to sample Outfall 009 at its point of discharge since the discharge ties into the service water line that discharges via Outfall 006 which is located underwater in the main (Outfall 001) discharge canal.

Average Flow: Outfall 009 - N/A December 28. 2005 2

Outfall Summaries CNS NPDES Ouffall Summaries Missoun miver water, 'OflCe [ tnir5 lime, gland seal water from however the station Once through 625 mgd (avg) 001 Once through cooling water a pump, and the requests to be cooling intake structure floor permitted to chlorinate drains the unit 002a Storm water runoff None 0.03 mgd (avg).

block)drains/Sumps (outside power Roof Storm water Clear-well (industrial well ground 002b water bypass) discharge. Outfall Well water Not applicable None N/A 004 Emergency Overflow Diesel generator, turbine fan Well water/HVAC Chemical treatment for 002c heater, boiler room floor drains, BdLow volume waste. HVAC, see MSDS 0.0005 mgd (avg) and HVAC blowdown owdown sheets 003 Screen backwash Missouri River Water Not applicable None 6.49 mgd (avg) pH adjustment, filters, 004 RO reject water, and boiler Well water Low volume waste RO Chemical treatment. Settling 0.03 mgd (avg) blowdown treatment pond Well water, and water Batch discharge Land application from sewage from the firepad used Sanitary waste, and Firepad oil/water (land application) in lagoon system for fire brigade LVW separator and lagoons the growing season.

training 0.21 mgd (avg)

None at this time, Once through service water Once through however the station 006 equipment non-contact cooling Missouri River ceoug requests to be 27.6 mgd (avg) water discharge cooling permitted to chlorinate the unit Batch discharge, one 008 Primary plant systems waste Demineralized well LVW Filtered and discharge (0.016 sample tank in the radioactive water demineralized mgd) in previous five control areaears December 28, 2005 1

CNS NPDES Outfall Summaries 009 09 nmary tank viant sjystems sample floor drains in the radioactive IDemnineralized well water jFiltered LWdemnineralized and N/A-no discharge previous five years IIcontrol area I III December 28, 2005 2

Potential Pollutants NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Outfall 009 IRndiosctivitv IPrmarv Plant Systems I No Data No Data I I

IPdmarv Plant Svstems

NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Outfall 008 I ^A; IPrimnni Plant+.tQmMc I Nn fla)ta No Data I

,1

NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Outfall 005 ITotal Orqanic Nitrooen Sanitary No Data Phosphorus, Total Sanitary No Data Oil & Grease Fire Training Pad Runoff No Data Surfactants Fire Training Pad Runoff No Data Nitrate-Nitrite Sanitary No Data Sulfate Sanitary No Data Sulfide Sanitary No Data Arsenic, Total Background (groundwater) No Data Selenium, Total Background (groundwater) No Data Iron, Total Background (groundwater) No Data

NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Ouffall 004 IArsenic, Total Background (groundwater) (sumps) No Data ISelenium. Total --- Background (groundwater) (sumps) No Data

NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Outfall 002C IOil and Grease IDrains / Sumps I No Data Molybdenum Total HVAC blowdown treatment chemicals) No Data

NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Outfall 002B 4

tuit' flf, 'Zraoa I ni., ~hh .. ,,~ ~AI~IInfr.~L'~ Ks Ir).+.

Phosphorus, Total Chemical Additive No Data Fecal Coliform Source Water No Data Nitrate-Nitrite Source Water No Data Sulfate Chemical Additive No Data Sulfide Chemical Additive No Data Iron, Total Source Water No Data

NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Outfalls 001andlor 006 Tnt~l Arn~ni,* Nlitrnnun Rn=lrr.A W*tp.r 1%in1l*t*

Phosphorus, Total Source Water No Data Fecal Coliform Source Water No Data Nitrate-Nitrite Source Water No Data Sulfate Source Water No Data Sulfide Source Water No Data Iron, Total Source Water No Data

NPPD - Cooper Nuclear Station Potential Pollutants Believed to be Present at Ouffall 002A Oil and Grease Roof Drains / Sumps No Data Magnesium, Total Roof Drains / Sumps No Data Sulfate Roof Drains I Sumps No Data Arsenic, Total Groundwater (sumps) No Data Selenium, Total Groundwater (sumps) No Data Iron, TotalI tRoof Drains / Sumps No Data

DMR Data Summary 001 NPPD COOPER NUCLEAR BROWNVILLE Temperature. Fahrenheit pH Flow MONITORING OC ON MONITORING C MONTORING PERIOD END QTY MAXIMUM *Ty AV*ERAGE PERIOD END MAXIMUM ONLEE MAXIMUM MINIMUM AVEGE PATM DATE MAXIMUM Sep-05 8.0 8.0 Sep-05 942.64 836.09 Sep-05 103.3 92.3 Aug-05 8.4 8.4 Aug-05 945.84 884.14 Aug-05 107.2 100.3 Jul-05 8.4 8.4 JUl-05 948 923.09 Jul-05 109.2 101.3 Jun-05 8.2 8.2 Jun-05 942.64 907.07 Jun-05 104.2 93.6 May-05 8.2 8.2 May-05 904.38 874.72 May-05 95 83.3 Apr-05 8.4 8.4 Apr-05 942.64 788.87 Apr-05 94.5 76.5 Mar-05 8.2 8.2 Mar-05 797.12 876.4 Mar-05 - 73.2 63.9 Feb-05 8 8 Feb-05 594.2 200.11 Feb-05 69.6 46.5 Jan-05 6.8 6.8 Jan-05 464.9 206.06 Jan-05 68.7 45.9 73.9 62.9 Dec-04 8.1 8.1 Dec-04 470.9 412.08 Dec-04 Nov-04 8.2 82 Nov-04 810.18 587.39 Nov.04 81.3 66.1 Oct-04 8.2 8.2 Oct-04 942.62 506.24 Oct-04 88.3 72.4 Sep-04 8.4 8.4 Sep-04 942.64 892.08 Sep-04 101 91.6 Aug-04 8.4 8.4 Aug-04 938.94 889.66 Aug-04 102.9 95.6 Jul-04 82 82 Jul-04 938.94 935.1 AJu-04 104.5 96.5 Jun-04 8.2 8.2 Jun-04 945.84 932.98 Jun-04 98.2 90 May-04 8.1 8.1 May-04 813.36 642.13 May-04 92.5 85.2 Apr-04 8.5 8.5 Apr-04 589.84 581 Apr-04 88.2 79.6 Mar-04 8 8 Mar-04 677.1 497.66 Mar-04 81.9 68.6 Feb-04 7.7 7.7 Feb-04 299.01 291.48 Feb-04 72.9 62.3 Jan-04 7.4 7. Jan-04 375.85 294.64 Jan-04 73.4 62.5 Dec-03 8 8 Deo-03 690.06 365.68 Dec-03 73.8 59.7 Nov-03 7.5 7.5 Nov-03 804.12 724,98 Nov-03 73.8 63.1 Oct-03 8.3 8.3 Oct-03 942.64 638.6 Oct-03 89.2 78 Sep-03 8.6 8.6 Sep-03 942.64 847.57 Sep-03 100.8 87.8 Aug-03 8.1 8.1 Aug-03 945.84 887.8 Aug-03 107%6 101.7 Jul-03 8.1 8.1 Jul-03 943.26 917.16 Jul-03 105.3 97.7 Jun-03 8.2 82 Jun-03 813.36 193.25 May-03 8.1 8.1 May-03 942.64 761.72 Apr-03 8.7 8.7 Apr-03 813.36 472.18 Mar-03 8.

8.1 1J.

1 8.1 8.1

002A NPPD COOPER NUCLEAR BROWNVILLE ConductMtv nH TSS MONITORING ON MOITOR COe ON PEE IDD DIS CHAR G E IND PROEN IND DISIC;HARGE OC CONC PERa*D DISCHARGE IN CN CN MX M A E A DAEMXM MINIMUM DATE MAMUM AVERAGE NA Sep5 sep-o5 NA Sep-0 NA Aug-05 NA Aug-OS NA Aug-OS NA Jul-05 10.1 10.1 Jul-0 _ 7.4 7A ul-s _ 2.2 22 Jun-05 120 120 Jun-OS - 8.1 8.1 Jun-OS ________ 3 3 May-05 90.1 90.1 May-0s 8.8 8.6 May-05 ________ 1.1 1.1 Apr-05 110 110 Apr-05 7.7 7.7 Apr.05 3.5 3.5 Mar-05 117 117 Mar.05 7.5 7.5 Mar-S _1.04 1.04 Feb-05 _ 40.4 40.4 Feb-0 7.4 7.4 Feb-OS 2 2 Jan-05 NO DISCHARGE Jan-0S NO DISCHARGE Jan-OS NO DISCHARGE Dec-04 NO DISCHARGE Dec.04 NO DISCHARGE Dec-04 NO DISCHARGE Nov-04 NO DISCHARGE Nov-04 NO DISCHARGE

Nov-04 NO DISCHARGE Oct-04 NO DISCHARGE_ Oct-04 NO DISCHARGE Oct-04 NO DISCHARGE Sep-04 NO DISCHARGE Sep-04 NO DISCHARGE Sep.04 NO DISCHARGE Aug-04 50 5o Aug.04 7.7 7.7 Aug-04 1.8 1.8 Jul-04 NO DISCHARGE Jul-04 NO DISCHARGE Jul0 NO DISCHARGE Jun-04 107 97.1 Jun 7.7 7.6 Jun-04 2 2 May-"04 57.0 56.8 May-04 7.8 7.3 May-04 4.55 2.78 Apr-04 NO DISCHARGE Apr-04 NO DISCHARGE Apr-04 NODISCHARGE Mar-04 55 55 Mar-04 8.7 8.7 Mar-04 2.8 2.6 Feb-04 NO DISCHARGE Feb-04 NO DISCHARGE Feb.04 NO DISCHARGE Jan-04 NO DISCHARGE Jan-04 NO DISCHARGE Jan-04 NO DISCHARGE Dec-03 NO DISCHARGE Dec-03 NO DISCHARGE Dec-03 NO DISCHARGE Nov-03 NO DISCHARGE Nov-03 NO DISCHARGE Nov-03 NO DISCHARGE Oct-03 NO DISCHARGE Oct-03 NO DISCHARGE Oct-03 NO DISCHARGE Sep-03 NO DISCHARGE Sep-03 NO DISCHARGE Sep-03 NO DISCHARGE Aug-03 42.3 42.3 Aug-03 7.7 7.7 Aug-03 2.8 2.8 Jul-03 NO DISCHARGE Jul-03 NO DISCHARGE Jul-03 NO DISCHARGE Jun-03 33.3 33.3 Jun.3 7.9 7.9 Jun-3 8.4 8.4 May-03 49 49 May-03 8.5 8.5 May-03 64 34.7 Apr-03 52 52 Apr-03 _ 7.9 7.9 Apr-03 5 5 Mar-03 105 105 Mar-03 8.1 8.1 Mar-03 7 7 Feb-03 113 113 Feb-03 8.3 1 8.3 Feb-03 1.85 1 1.85

002A NPPD COOPER NUCLEAR BROWNVILLE Oil & Grease Flow MOMMORI CNIC CONC mrTRIN P DED DISCHARGE I EIOD D DISCHARG IND ITY Sep-OS NA Sep-OS NA Aug-05 NA Aug-OS NA Jul-05 BELOW DETECT LIMIT/NO DETECT Jul-05 0.217 0.217 Jun-OS BELOW DETECT LIMIT/NODETECT May-05 _ 0.08 0.06 May-05 BELOW DETECT LIMIT/NODETECT Apr-0S BELOW DETECT LIMIT/NODETECT Apr-05 0.022 0.022 Mar-0S BELOW DETECT LUMIT/NO DETECT Mar-O _ 0.013 0.013 Feb-05 BELOW DETECT LIMIT/NODETECT Feb-05 0.022 0.022 Jan-05 NO DISCHARGE Jan-OS NO DISCHARGE Deo-04 NO DISCHARGE Dec-04 NO DISCHARGE NOV-04 NO DISCHARGE Nov-04 NO DISCHARGE Oct-04 NO DISCHARGE Oct-04 NO DISCHARGE Sep-04 NO DISCHARGE Sep04 NO DISCHARGE Aug-04 BELOW DETECT LMIT/NO DETECT Aug-04 0.088 0.066 Jul-04 NO DISCHARGE Jul-04 NO DISCHARGE Jun-04 BELOW DETECT LIMIT/NODETECT Jun-04 0.009 0.0005 May-04 BELOW DETECT LIMIT/NODETECT May-04 0.0008 0.0006 Apr-04 NO DISCHARGE Apr-04 NO DISCHARGE Mar-04 BELOW DETECT LIMIT/NODETECT Mar-04 _0.0001 0.0001 Feb.04 NO DISCHARGE Feb-04 NO DISCHARGE Jan-04 NO DISCHARGE Jan-04 NO DISCHARGE Dec-03 NO DISCHARGE *Dec-03 NO DISCHARGE Nov-03 NO DISCHARGE Nov-03 NO DISCHARGE _

NO DISCHARGE Oct-03 NODISCHARGE Sep-03 NO DISCHARGE Sep-03 NO DISCHARGE Aug-03 BELOW DETECT UMIT/NO DETECT Aug-03 0.0004 0.0004 Jul-03 NO DISCHARGE Jul-OS NO DISCHARGE Jun-03 BELOW DETECT UMIT/NO DETECT Jun-03 00005 0.0005 May-03 BELOW DETECT UMIT/NO DETECT May-03 0.0004 0.0004

002C NPPD COOPER NUCLEAR BROWNVILLE gpH TSS MONITC)I*NQGCNC CN _ _IORN CONC CON PERIOD E _D DISCHARGE IND PERIOD END DISCHARGE IND CC MINIUM Sep-05 NO DISCHARGE Sep-05 NO DISCHARGE Aug-05 NO DISCHARGE Aug-05 NO DISCHARGE Jul-05 NO DISCHARGE Jul-05 NO DISCHARGE Jun-.05 NO DISCHARGE Jun-05 NO DISCHARGE May-05 NO DISCHARGE May-05 NO DISCHARGE Apr-05 8 8 Apr-05 3 3 Mar-05 7.7 7.7 Mar-05 1 1.2 12 Feb-05 7.7 7.7 Feb-05 8 8 Jan-05 7.5 7.5 Jan-05 8 8 Dec-04 7.8 7.8 Dec-04 1.5 1.

Nov-04 8.4 8.4 Nov-04 1.75 1.75 Oct-04 8 8 Oct-04 17 17 Sep-04 NO DISCHARGE Sep-04 NO DISCHARGE Aug-04 8.1 8.1 Aug-04 1.9 1.9 Jul-04 NO DISCHARGE Jul-04 NO DISCHARGE Jun-04 NO DISCHARGE Jun-04 NO DISCHARGE May-04 NO DISCHARGE May-04 NO DISCHARGE Apr-04 7 7 Apr-04 0.7 0.7 Mar-04 8.2 8.2 Mar-04 2.8 2.6 Feb-04 NO DISCHARGE Feb-04 NO DISCHARGE" Jan-04 7.9 7.9 Jan-04 I1 1.4 Dec-03 NO DISCHARGE Dec-03 NO DISCHARGE Nov-03 7.7 7.7 Nov-03 1.8 1.8 Oct-03 8.4 7.3 Oct-03 1.1 0.8 Sep-03 NO DISCHARGE Sep-03 NO DISCHARGE _ _

Aug-03 NO DISCHARGE Aug-03 NO DISCHARGE Jul-03 NO DISCHARGE Jul-03 NO DISCHARGE Jun-03 8.5 8.5 Jun-03 13 13 May-03 NO DISCHARGE Apr-03 5 5 Mar-03 0 0 81.5 23 S Feb-03 A-Mn*

002C NPPD COOPER NUCLEAR BROWNVILLE O11 A Grna*A Flow MONITORING OC MONITORING ON MAXIMUM PERIOD ENO DISCHARGE IND PERIOD END DISCHARGE [INO " MAXIMUM AVRG 2I DATE Sep-05 NO DISCHARGE Sep-OS NO DISCHARGE Aug-05 NO DISCHARGE Aug-05 NO DISCHARGE Jul-05 NO DISCHARGE Jul-05 NO DISCHARGE Junr05 NO DISCHARGE Jun-05 NO DISCHARGE May-05 NO DISCHARGE May-05 NO DISCHARGE Apr-05 BELOW DETECT LIMIT/NO DETECT Apr-05 HNA Mar-05 BELOW DETECT LIMIT/NO DETECT Mar-05 - 0.0004 0.0004 Feb-05 8.8 8.8 Feb-05 I 0.0003 0.0003 Jan-05 BELOW DETECT LIMIT/NO DETECT Jan-05 0.00007 0.00007 Dec-04 BELOW DETECT LIMIT/NO DETECT Dec-04 _0.00001 0.00001 Nov-04 BELOW DETECT LIMIT/NO DETECT Nov-04 0.00004 0.00004 Oct-04 BELOW DETECT UMIT/NO DETECT Oct-04 _o0.0015 0.0015 Sep-04 NO DISCHARGE Sep-04 NO DISCHARGE Aug-04 BELOW DETECT UMIT/NO DETECT Aug-04 o.00003 0.00003 Jul-04 NO DISCHARGE Jul-04 NO DISCHARGE Jun-04 NO DISCHARGE Jun-04 NO DISCHARGE May-04 NO DISCHARGE May-04 NO DISCHARGE Apr-04 BELOW DETECT LIMIT/NO DETECT Apr-04 0,00002 0.00002 Mar-04 BELOW DETECT,LIMIT/NO DETECT Mar-04 0.00004 0.00004 Feb-04 NO DISCHARGE Feb-04 NO DISCHARGE Jan-04 BELOW DETECT LIMIT/NO DETECT Jan-04 0.0002 0,0002 Dec-03 NO DISCHARGE Dec-03 NO DISCHARGE Nov-03 BELOW DETECT LIMIT/NO DETECT Nov-03 0.0003 0.0003 Oct-03 BELOW DETECT LIMIT/NO DETECT Oct-03 0.0004 0.0004 Sep-03 NO DISCHARGE Sep-03 NO DISCHARGE Aug-03 NO DISCHARGE Aug-03 NO DISCHARGE Jul-03 NO DISCHARGE Jul-03 NO DISCHARGE Jun-03 5.7 5.7 Jun-03 0.0002 0.0002 May-03 NO DISCHARGE May-03 NO DISCHARGE Apr-03 BELOW DETECT LIMIT/NO DETECT Apr-03 0.0004 0.0004 Mar-03 <5 <5 Mar-03 0.004 0.004 Feb-03 47.1 24.6

004 NPPD COOPER NUCLEAR BROWNVILLE Conductviltv TSS MONITORING C CQNC DISCHARGE IND CONC CONC PERIOD ENDJ DISCHARGE IND CNC CONC PERIOD END DISCHARGE IND M J CO G PEIOD.

END QMUE MINIMUM Sep-05 698 698 Sep-05 81 81 Sep-05 5.41 5.41 Jun-05 720 720 Jun-05 85 827 Jun-os 15 15 Mar-05 875 875 Mar-05 7.8 7,8 Mar-05 10.6 10.6 t*-d ;733733 Dec-04 8.1 8.1 Dec-04 5.4 5.4 Sep-04 NO DISCHARGE Sep-04 NO DISCHARGE Sep-04 NO DISCHARGE Jun-04 813 813 Jun-4 7.89 7.89 Jun.-04 10.5 10.5 Mar-04 828 828 Ma-04 7.7 7.1 Mar.04 11.6 10.4 Dec-03 _________ 743 743 Dec-03 al 8.1 Dec-03 2.8 2.8 Sep-03 710 710 7.8 6.9 Sep-3 _ _ 9 9 Jun-03 m_868 888 Jun-03 13 1

004 NPPD COOPER NUCLEAR BROWNVILLE Oi A Grease Flow Toxicity MONITORING G PERIOD DISCHARGE IND PEIDEDDISCHARGE IND G DISCHARGE IND MAXIM AVERAGE END DATE END AE MAIM VEAG DATE Sep-05 BELOW DETECT UMITINO DETECT Sep-05 0.483 0263 Oct-04 Pass/Pass Jun-05 BELOW DETECT LIMf/NO DETECT Jun-05 0.122 0.076 Oct-03 Pass/Pasa Mar-05 BELOW DETECT UMIT/NO DETECT Mar-05 0.000062 0.000038 Dec-04 BELOW DETECT UMIT/NO DETECT Dec-04 0.00005 0.00002 Sep-04 NO DISCHARGE Sep-04 NO DISCHARGE _ i Jun-04 7.96 7.96 Jun-04 0.00004 0,00003 Mar-04 BELOW DETECT UMIT/NO DETECT Mar-04 . _ 0.00003 0.00002 Dec-03 BELOW DETECT UMITiNO DETECT Dec-03 _ 0.00009 0.00003 Sep-03 BELOW DETECT UMITINO DETECT Sep-03 0.000057 0.000029 Jun.3 BELOW DETECT UMITINO DETECT Jun-03 I Mr.* I <* ,,

005 NPPD COOPER NUCLEAR BROWNVILLE Flow Conductivity PH CONC C.67 PERIOD END ERIODED DISCHARGE IND QTY CTY DATE DAMMAXIM VERA Sepm5 Sep-05 0.251 0.251 Sep-05 825 578 9.56 Sep-04 9.73 8.01 Aug-05 0.129 0.341 Sep-04 650 617.5 735 Sep-03 9.5 Jul-0 NO DISCHARGE Sep-3 735 Jun-SO NO DISCHARGE May-oS NO DISCHARGE Apr-05 NA Mar-05 NO DISCHARGE Feb-OS NO DISCHARGE Jan-05 NO DISCHARGE Dec-04 NO DISCHARGE Nov-04 NO DISCHARGE Oct-G4 NO DISCHARGE Se"-4 Aug.04 Jul-04 0.251

.0.125 0.251 0.157 0.125 0.251 H

Jun-04 0.503 0.314 May-04 NO DISCHARGE Apr-04 NO DISCHARGE Mar-04 NO DISCHARGE Feb-04 NO DISCHARGE Jan-04 NO DISCHARGE Dec-03 NO DISCHARGE Nov-03 NO DISCHARGE Oct-03 NO DISCHARGE Sep-03 NO DISCHARGE Aug-.03 0.00001 0.00001 Jul-03 NO DISCHARGE Jun-03 NO DISCHARGE May-03 NO DISCHARGE Apr-03 NO DISCHARGE Mar-03 NO DISCHARGE Feb-03 NO DISCHARGE

005 NPPD COOPER NUCLEAR BROWNVILLE NH3 N02 TKN Chloride DICARGE IND Isep-I5NA wiI Se-4 11.3 815 Sp 0 0

006 NPPD COOPER NUCLEAR BROWNVILLE Temperature pH Flow MONITORING CONC CONC MONITORING CONC CONC PERIOD END QT T D0 END MAXIMUM AVERAGE PERIOD END MAXIMUM MINIMU

_ MAXIMU AVERA DATE Jun-05 68 68 Jun-05 8.24 8.24 Jun-05 37.2 29.4 Dec-04 87.8 87.8 Dec-04 7.7 7.7 Dec-04 37.2 27.9 Jun-04 7.3 7.3 Ju__04 37.2 27

008 NPPD COOPER NUCLEAR BROWNVILLE TSS Oil & Grease Flow MO N " CC CONC DISCHARGE IND CONC CONC END SCHARGE IN AM GE MAXIMUM A NO DISCHARGE M 2MMAXIM MINIMU G END DA EIDDISCHARGE IND MAXIM OTY AVERAGE QTY Apr-05 NO DISCHARGE Apr'- I NO DISCHARGE Apr-05 NO DISCHARGE SNO DISCHARGE -

D t.O4 NODISCHARGE 000-04 _NODISCHARGE Deo.04 NO DISCHARGE Jun-04 L NODISCHARGE Jmun0 NODISCHARGE Ju-04 NO DISCHARGE 003 NODISCHARGE ýMý1 ISCHAGE O

009 NPPD COOPER NUCLEAR BROWNVILLE pH TsR Oil & *reasn -Flow

,CDv MONITORING G PERIOD UISCHARGE IND l" DISCHARGE IND C MINIMUM PRIODED DISCHARGEIND - I RIOD DISCHARGEIND PERIODND ENDDAT M9WAEA NNO DISCHARGE iuý5 NO DISCHARGE

,uhm-OS NODISCHARGE Juls NODISCHARGE - -

UDe-04 NO DISCHARGE Deo-04 NODISCHARGE Dec-04 NODISCHARGE ___ I Dec-04 NoISCARG JuC-04 NO DISCHARGE Jun-04 NO DISCHARGE Jun.04 NODISCHARGE- J-N4 NODISCHARGE Dec-03 NO DISCHARGE Dec-03 NO DISCHARGE I Dec-03 NODISCHARGE

Analytical Data Al%Midwest Ref. Lab #: 119932 P port Numer 05-221-2049 %'*4 Laboratories Inc.

13611 '8* Stret Omaha, Nebraska 68144-3693 * (402) 334-7770

FAX (402 334-9121

.www.mldwestlabs.com REPORT 01? ANALYSIS For: (5307) 1{PPD-COOPER NUCLEAR STATION Mail to:

NPPD-COOPERt NUCLEAR STATION (402)825-381I Date Reported: L0/19/05

~Va ~ fVr% nfl Date Received: 08/04/05 "n1r 1 VU DI.1iU U

PO/Proj. #: 4400003210 BROWNVILLE NE 68321-0098 LAGOON DISCHARGE Lab number: 1099436 Sample ID: START

>1 Level Detection Analyst- Verified-Analysis Found Units Limit Method Date Date Ammonlacal nitrogen n.d. mg/L 0.10 EPA 350.2 roib-01/05 emw-08/OHg Biochemical oxygen demand 20 mg/b 2 SM 521OOB jar-0B/0 ormw-08A09 Chemical oxygen demand 106 mg/L 5 ASTM D 1252-95-B liua-OB/05 cmw-08109 Chloride 117 mg/b 20 EPA 325.2 jjdMO/09 crnii-089 Conductance 625 US/cm 2 SM 2510 B ding-O8/04 ecmw-08/t39 Kjeldahl nitrogen 4.84 mg/b 0.50 EPA 351.3 nnjb.a08M cmtw.O08/0 Nitrate/Nitrite Nitrogen U,d. ng/L 0.2 EPA 353.2 Jad-08A05 ormw-ORViB Total suspended solids 31 mg/L 4 USGS 1-3765-85/SM2540D Ucin-O8/04 crnw-O0aA9 pH 9.56 S.U. EPA 150.1 dntg-08,'04 crnw-0&109

'1~

0 Notes:

n.d. - Not Detected.. Respectfully Submitted 0

0 The solid analyses have been weighed to a constant weight by leaving the samples

'4 in the oven overnight. This protocol is an approved variation from the stated method.

Heather RaniglSue Ann Seitz/Rob Ferris Client Services

'a

.4

.4 0

n

.4

.4 Our reports and leters ate for the exdlusive and confidential use of our cleants and may not be 'oducdltn whole or In pait, nor may any reference be made to the work, the results, or the company In any advertisIng, news release, or other public announcements without obtaining our preorwrittenautehorI'zation.

M*!\ Midwest Ref. Lab #: 119933 Report Number 05-265-2214

\ - Laboratories, Inc, 13811IB" Street 4 Omaha, Nebraska 68144-3693 - (402) 334-7770

FAX (402) 334-9121 RET67k1MILYSIS For: (5307) NPPD-COOPER NUCLEAR STATION Mail to: UCLEAR STATION (402)825-3811 Date Reported: 09/22/05 NPPD-COOPER N. SDate Received: 09/15/05 il 1 PO X98: PO/Proj. #: 4400003210 BROWNVILLE NE 68321-0098 LAGOON DISCHARGE Lab number. 1112453 Sample ID: FINISH I

Level Detection Analyst- Verifted-Analysis Found Units Limit Method Date Date I

0 Ammoniacal nitrogen Biochemical oxygen demand Chemical oxygen demand 0.17 mgi'L 70 mg1L 244 mg/L 0.10 50 2

1 EPA 350.2 SM 5210B ASTM D 1252-95-B imdl-09/16 cch-09/20 jlc.09121 crnw4J9119 ecnw-09122 cruw-09122 Chloride 79 rnigL EPA 300.0 dmg-09120 cmrw-09/22 530 uS/cm 2 SM 2510 B dmng.0911,5 crnw.09122 Conductance z Kjeldahl nitrogen 10.4 ing/Is 0.50 EPA 351.3 injb-09/19 uniw-09t20 Nilrale/Nitrite Nitrogen n.d. rng/L 0.2 EPA 353.2 lad-09116 cmnw-09/ 16 Total suspended solids 100 mg/L 4 USGS 1-3765-85/SM2540D lkm.09/11 mxnw-09122 pH 9.67 S.U. EPA 150.1 dmg-09115 einw.09=2 ID Notes:

L-1 ml n.d. - Not Detected. Respectfully Submitted ml The solid analyses have been weighed to a constant weight by leaving the samples G'I I in the oven overnight. Thiis protocol is an approved variation from the stated method.

Heather ig/Sue Ann Seilz/Rob Ferris Client S ices

'-4 ID 0

N.

-4 N

0~

'-4 Ourreports and letters ae for the exclusive and onfdMenUli use of ouar clients and may not be reepduced In Mlole or u1port, nor may n reference be made

AN Midwest Ref. Lab 4: 135613 Report Number

'05-362-2086 NJ/ Laboratories, Inc!

13611 "B Street - Omaha, Nebraska 68-144-3693 - (402) 334-7770 .FAX (402 334-9121

.wvww midwestlabs.com REPORT OF ANALYSIS~

Mail to: ~NPPD-COOPER NILICLEAR STATION. For: ( 5307) NPVPD-COOPER NUCCLEAR STATION~

KRISTINE OHRAB LO (402)825-381 1 Date Reported: 12/28/05~

72676 648A -AVE Date Received: 12/15/05 BROWNVILLE NE 68321-0098 P0/Proj. #: 4500047892 Date Sampled: 12/14/105.

WASTEWATER ANALYSIS Lab number: 1140341 Level- Detection, Analyst- Verified-Analysis Found Units Limit ~Method Date Date

!..

Sample ID: 001 CIRCULATING WATER . ... . . :

Ammoniacal nitrogen 0.10 mg/L 0~.10 EPA 350.2 'injb-12/ 15 cmwl-2/16, Biochemical oxygen~dernand 3nig/L 2 SM 5210B~ cch-12/1S5 cnw-12/28i Chemical oxygen demand 6n-tg/L 5 ~ASTM D 1252-95-B jc-12/21~ cmw~-12728 Total organic carbon 7.05 mg/L 1.00 EPA 415.1 cmwI12/22 cmw-12/2-8.

=:.: , -, :.-* *.* :..,;,:.

Sample ID: 004 SLUDGE POND:

Amimoniacal nitrogen n ýd. mg/L 0.10 -EPA 350.2 ijb-12/15 cirw- 12/16 Biochemical oxygen demand !!*!*i::ili!,

4 mg/L 2 SM 521013 cch-1 2/15 cnmw-12/28 Chemnical oxygen demand 5 'mg/L 5 ASTM D 1252-95-B jlc-12M2 cmwv-12/28 Total organic carbon 8.32 mg/L 1.00 EPA 415A~ ýmwv7I2!22 cmw- 12/28 Notes:

nAd. -Not Detected, Respectfully Submitted Heather Ramig/Sue:Ann, Seitz/Rob Ferris

. . .Client Services opt oiportn and letters are for the excluesie and confidential ose of our clients andi may not be reproduced in whole or in part.i nor ma iny relereanw bie rnaae

to the work, the results, or the company inany advertising, news release or other pub~lic annowncementMS V6isho1t obtlining 'out prfor wiritten authonrization.

.3 to Attachment 1 Industrial Stormwater Permit

ISTATE OF NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY Randolph Wood Suite 400. The Director Atrium

.RO. Box 98922 u V' 0, RIC1 Lincoln, Nebraska 68509-8922 Phone (402) 471-2186 E. Benjamin Nelson Governor NEBRASKA DEPARTMENT OF ENVIRONMENTAL QUALITY-AUTHORIZATION TO DISCHARGE UNDER THE STATE OF NEBRASKA NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) 5q NPDES Permit Number NERO000.

A general NPDES permit for industrial storm water discharges to waters of the State of Nebraska In compliance with the provisions of the Federal Water Pollution Control Act (33 U.S.C. Secs. 1251 et.

seq. as amended to date), the Nebraska Environmental Protection Act (Neb. Rev. Stat. Secs. 81-1 501 et. seca. as amended to date), and the Rules and Regulations promulgated pursuant to these Acts, the Nebraska Department of Environmental Quality is hereby issuing this general permit authorizing the discharge of pollutants to waters of the State. This general permit establishes prohibitions, limitations and other conditions pertaining to these discharges. This general permit does not relieve permittees of other duties and responsibilities under the Nebraska Environmental Protection Act, as amended, or established by regulations promulgated pursuant thereto.

This permit shall become effective on September 18, 1997.

This permit shall expire at the end of the 5 year period ending September 17, 2002.

Pursuant to the Delegation Memorandum dated January 30, 1995 and signed by the Director, the undersigned hereby executes this document on behalf of the Director.

Signed this J3iday of . , t-, 9 Patrick W. Rice, Assistant Director Page 1 of 42 An Equal Opporiunity.Affirmative Action Employer' fl.-. . - ... 0' 0CCe Vape'

Industrial Storm Water General Permit NPDES Permit Number NER000000 Effective Date September 18, 1997 Page 2 of 42 A.

SUMMARY

OF PERMIT CONTENTS Page Authorization Page ..................................................... 1 Section A. Summary of Permit Contents .......................................... .... 2 S ection B, Applicability ........................... ............................... 3

1. Discharges Authorized by this Permit ........................................ 3 2 . Area of Ap plication ........................................................ 3

3. Lim itations on Coverage .................................................... 3

4. Facilities Authorized Under the Previous General Permit ....... ; .................... 4 Section C. Notification and Discharge Authorization Procedures ........................... 4

1. Subm ission of Initial Notification ............................................. .4

.2. Contents of the Notice of Intent ........................................ 5

3. Additional Notification Requirements that Apply to Some Facilities .................... 5

4. Authorization to .Discharge .................................................... 5

5. Revocation of Discharge Authorization ......................................... 6

6. Requiring an Alternative Permit and Application .............................. 6

7. Notification Requirements for the Relocation of Portable Facilities .................. 7

8. Site Specific Discharge Authorizations, Denials and Revocations for Portable Facilities .... B

9. Notification of Operational Changes Relative to Facility Portability .................... 8 10, Notification of Term ination ................................................... 8 Section D. Storm Water Pollution Prevention Plan (SWPPP) .......................... 8

1. General ............ ........................................ ... 8

2. Content of Storm Water Pollution Prevention Plan .... . *......................... 9

3. Facility Inspections ......................................................... 11 )

4. SW PPP Reviews and Updates ................ .................... ......... 11

5. Professional Engineer's Certification ........................................... 12

6. Reduced Requirements for Enclosed Facilities ................................... 13

7. SW PPP Implementation Deadlines ............................................ 14

8. Reporting Requirements ...................... ....................... 14 Section E. Monitoring Requirements and Procedures ................................... 15

1. Effluent Monitoring Requirements ............................................. 15

2. Sampling and Analytical Protocols .............................................. 15

3. Storm Event Monitoring ................................... 16

4. Monitoring Station Requirements .............. ............................... 16 Section F. Other Conditions and Requirements ........................................ 17 Section G. Reporting and Record Keeping Requirements ................................ 17 APPENDIXES Appendix A - Standard Conditions for NPDES and NPP Permits ...................... 19 Appendix B - Definition: Storm Water Discharges Associated with Industrial Activity ......... 31 Appendix C - Water Bodies where Written Discharge Authorization is Required ............ 36 Appendix D - Information and Signatures Required in NOIs ............................ 39 Appendix E - W ater Priority Pollutants .............................................. 42 ATTACHMENTS Notice of Intent (NPDES Form ISW-NOI) and Instructions Storm Event Monitoring Report Form (NPDES Form SW-SEMR)

Non-Compliance Report Form (NPDES Form NCR-BMPP)

Relocation Notice (AQC/NPDES Form RN) and Instructions )

Physical Examination Report Form (NPDES Form PE)

Exemption Notice for Category xi Facilities (NPDES Form ISW-EX)

Industrial Storm Water General Permit NPDES Permit Number NEROOQOO Effective Date September 18, 1997 Page 3of42 B. APPLICABILITY

1. Discharges Authorized by this Permit

a. Contingent upon the Notification and Discharge Authorization procedures set forth in Section C, this permit authorizes "storm water discharges associated with industrial activity" as defined in NDEQ Title 119- Rules and Regulations Pertaining to the Issuance of Permits Under the National Pollutant Discharge Elimination System, Chapter 1.062, except discharges from construction sites as explained in Section B.3.d. The definition for "storm water discharges associated with industrial activity" is contained in Appendix B of this permit.

The terms "industrial storm water" and "industrial storm water discharges" are used synonymously in this permit to refer to "storm water discharges associated with industrial activity", except discharges from construction sites.

b. This permit may also be used to authorize the discharge of storm water from facilities other than those with "storm water discharges associated with industrial activity," if the Department determines that coverage under this permit is appropriate to control the discharge of pollutants (e.g., a permit required pursuant to NDEQ Title 119 Chapter 2 001.06A). In these instances, written discharge authorization is required (See Sections C.4.a and C.4Ji)-

c. This permit is applicable to discharges from both stationary and portable facilities. 'Additional notification and discharge authorization procedures apply to portable facilities as set forth in Section C.7 and C.8 of this permit.

2. Area of Application This permit has application throughout the State of Nebraska.

Special authorization procedures apply to facilities seeking to discharge to certain State Resource Waters or waters protected as public drinking water supplies in the White River basin.

These waters are identified in Appendix C and the discharge authorization procedures are described in Section CA of the permit.

3. Limitations on Coverage This permit does not authorize the following types of storm water discharges associated with industrial activity:

a. those regulated by an existing NPDES permits; b, those for which storm water effluent guideline limitations apply;

c. those the Director has determined to have reasonable potential to violate a surface or ground water quality standard;

)

Industrial Storm Water General Permit NPDES Permit Number NER000000 Effective Date September 18, 1997 Page 4 of 42

d. those associated with construction activities as defined in Title 119 - Rules and Regulations Pertaining to the Issuance of Permits Under the National Pollutant Discharge Elimination System, Chapter 1.06. (Construction sites of 5 acres or more are required to apply for storm water permits. This general permit does not apply to construction sites. The Department should be contacted for permit options for these sources. See Section C,1 for telephone number and mailing -address.);

e. those adversely effecting an endangered or threatened species as defined in Nebraska Game and Parks Commission Title 163, Chapter 6004, or their critical habitats;

f. those composed of or containing leachate from a landfill as defined in NDEQ Title 132 -

Integrated Solid Waste Management Regulations, Chapter 1 045; or

g. those which the Director, after review of the Notice of Intent or other information, determines would ýbe more effectively regulated with a facility specific, a basin specific, or an industry group permit.

4. Facilities Authorized Under the Previous General Permit Facilities authorized to discharge under the previously issued NPDES General Permit (i.e.,

NPDES Permit Number NEROOOQO; Expiration Date September 17, 1997) shall have authorization to discharge under this permit subject to the terms and conditions set forth below in Sections B.4.a and B.4.b. )

a. Facilities authorized to discharge under the previous permit shall be considered in compliance with this permit through December 31, 1997, provided the permittee complies with all of the terms and conditions of the previous general permit.

b. Facilities authorized to discharge under the previous permit that wish to extend coverage beyond December 31, 1997, shall submit the ISW-NOI form (See Sections C.1 through C.4 below) on or before November 30, 1997.

C. NOTIFICATION AND DISCHARGE AUTHORIZATION PROCEDURES

1. Submission of Initial Notification.

Eligible facilities, as defined in Section B above, may apply for authorization to discharge under this general permit using the Notice of Intent (NOI) procedures set forth below. The NOI shall be submitted in writing on NPDES form ISW-NOI or equivalent approved form. The NOI form can be obtained by contacting the Nebraska Department of Environmental Quality, The address and telephone number current at the time of permit issuance are provided below.

Permits and Compliance Section Nebraska Department of Environmental Quality P.O. Box 98922 1200 N Street, The Atrium, Suite 400 Lincoln, Nebraska 68509-8922 Telephone (402) 471-4239

Industrial Storm Water General Permit NPDES Permit Number NER0000D Effective Date September 18, 1997 Page 5 of 42

2. Contents of the Notice of Intent.

Appendix 0 contains the description of the information required to be submitted in the NOI.

The ISW-NOI form, an attachment to this permit, meets the requirements set forth in Appendix D.

3. Additional Notification Requirements that Apply to Some Facilities

a. The Department may request additional information from the source to facilitate the review of the NOI, or to finalize a determination related to the granting of an authorization to discharge or requesting an application for a facility specific, a basin specific, or an industry group permit.

b. Facilities that discharge storm water through a large or medium municipal separate storm sewer system, shall concurrently submit a copy of NPDES form ISW-NOI (or other.

appropriate notification form) to the operator of that system. A large or medium municipal separate storm sewer system is defined as a system located in an incorporated city with a population of 100,000 or more. This includes the cities of Lincoln and Omaha.

c. Other government agencies (e.g., the US Army Corps of Engineers, local City/County Government, or the local Natural Resource District) mayhave additional notificatio, requirements. Submittal of the NPDES form ISW-NOI does not relieve the applicant of responsibility to comply with the requirements of other government agencies.

4. Authorization to Discharge

a. Except as provided in Sections CA.b through C.4.j, C.5 or C.8, a facility is granted authorization to discharge 30 days after the Department receives a complete NOI.

b. The Department may act to grant an applicant authorization to discharge at any time following the receipt of a completed NOI by providing a written notification to the permittee (e.g., prior to end of the 30 day review period specifidd in Section C.4.a).

c. The Department may require additional information to be submitted as a part of the NOI process. Authorization to discharge can not be granted until after the additional information is received, or until the issue prompting the request is resolved. The 30 day period specified in Section C.4.a, restarts each time additional information is received by the Department.

d. The Department may extend the 30 day authorization period set forth in Section C.4.a to provide a longer review period, or require a written discharge authorization to be obtained.

The Department shall provide the applicant with written notice and explanation of any such action within 30 days after the application is received.

e. Written discharge authorization from the Department is required for discharges to the State Resource Waters and Public Drinking Water Supplies identified in Appendix C. Permittees with portable facilities should refer to Sections C.7 and C.8 for relocation notification and

authorization pro cedures that apply for temporary discharges to these stream -segments and water bodies.

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f. Written authorization to discharge is required whenever an application contains a request for a compliance extension for completion of the SWPPP pursuant to Section D.7.c of this permit.

g. The Department may deny authorization to discharge under the terms and conditions of this permit by providing the applicant with a written notice of the denial and an explanation of the basis for the determination.

h. The Department may require the submittal of an application for a facility specific permit or an NOI for an alternative general permit. The Department shall provide an explanation of the basis for any such request.

i If authorization to discharge under the conditions of this permit is sought pursuant to Section 8.1 .b Of this permit, written discharge authorization is required.

j. All permlttees must meet the requirements set forth in Section B of this permit. Failure to do so shall negate any authorization to discharge granted pursuantto this subsection.

5. Revocation of Discharge Authorization The .Director may revoke a permittee's authorization to discharge under the terms and conditions of this permit for any of the following:

)

a. the discharge has a reasonable potential to violate a surface or ground water quality standard;

b. the discharge is adversely affecting an endangered or threatened species as defined in Nebraska Game and Parks Commission Title 163, Chapter 6 004, or their critical habitats; and

c. a permittee falls to submit an alternative permit application requested pursuant to Section C.6.

6. Requiring an Alternative Permit and Application a, The Director may require any person authorized to discharge under the terms and conditions of this permit to apply for and obtain either a facility specific NPDES permit or an alternative NPDES general permit. A written notice that an alternative permit application is required shall be provided by the Department. This notice shall include:

i. a brief explanation of the basis for the determination; ii. an application or NOI form for the alternative permit; and iii. a deadline for submitting the application for the alternative permit.

The Director may grant additional time for the submittal of an alternative application following the initial notice described above.

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b. Conditions that may constitute a basis for requesting an alternative application include, but are not limited to:

i. the discharge is a significant contributor of pollution; ii. the facility is not in compliance with the terms -and conditions of the permit; iii. additional pollution control or prevention technology have become .available; iv. the promulgation of new effluent limitations that apply to the source;

v. the approval of a water quality management plan containing requirements applicable to the source; vi. the identification of conditions or pollutant sources not previously recognized; and vii. the issuance of an alternative general permit that applies to the discharge.

c. Authorization to discharge under the terms and conditions of this permit shall be terminated upon the issuance of the alternative permit or the granting of discharge authorization under another alternative general permit.

7. Notification Requirements for the Relocation of Portable-Facilities

a. The permittee shall provide the Department with notification of the relocation of .agy facility at least 20 days in advance of each relocation (A 10 day advance notice maybe used by facilities not subject to relocation notice procedures established pursuant to NDEQ,,Title 129

- Nebraska Air Quality Regulations). Notification shall be provided using the "Relolcation Notice Form" (See Permit Attachments) or equivalent. The following information shall be provided:

i. the NPDES permit number (i.e., NEROOQOO0) and the NPDES reference number (e.g.,

NER000001), if Itis available; ii, the name of the facility; iii. the legal description of the proposed relocation site; iv. the name of the receiving stream;

v. the identification of any storm water discharges to State Resource Waters or public drinking water supply identified in Appendix C (See Section C,8.a below); and vi. the anticipated dates of operations at the new location.

b. When a facility is relocated so that storm water will be discharged through a large or medium municipal separate storm sewer system, the permittee shall concurrently provide written notification of the relocation to the operator of the municipal separate storm sewer system through which they will discharge. A large or medium municipal separate storm sewer system is defined as a system located in an incorporated city with a population of 100,000 or more. This includes the cities of Lincoln and Omaha.

c. The Department may request additional information as necessary to evaluate a relocation request (See section C.a).

2)

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8. Site Specific Discharge Authorizations, Denials and Revocations for Portable Facilities

a. Portable sources shall obtain written authorization from the Department on a site specific basis prior to discharging industrial storm water to any of the State Resource Waters or public drinking water supplies identified in Appendix C. Discharges to other waters of the State do not require written discharge authorization, but site specific denials or revocations of discharge authorizations can be made by the Department (See Section C.8.b below).

b. The Department may deny or revoke authorization to discharge for portable facilities at specific locations due to potential impacts on: water quality, State Resource Waters, listed endangered or threatened species, habitat critical to an endangered or threatened species, or human health or safety. The Department shall provide the permittee with a written notice of the denial or revocation, and an explanation of the reason for the denial. Temporary denials may be required to provide time to review additional information submitted pursuant to Section C.7.c.

9. Notification of Operational Changes Relative to Facility Portability The permittee shall notify the Department in writing if a facility is "converted" from a stationary to a portable facility, or vice-versa.

10. Notification of Termination The permittee shall notify the Department in writing if termination of authorization to discharge under this permit is sought or required. In instances where facility modifications result in the cessation of storm water discharges associated with industrial activity, the termination notice shall be submitted within 30 days after the modifications are completed.

D. STORM WATER POLLUTION PREVENTION PLAN (SWPPP)

1. General

a. The permittee shall develop, maintain and implement a SWPPP for their facility that:

i. minimizes the discharge of pollutants in storm water runoff; ii. ensures storm water discharges do not result in, or significantly contribute to, violations of NDEQ Title 117 - Nebraska Surface Water Quality Standards or NDEQ Title 118 -

Ground Water Quality Standards and Use Classifications; and iN. maintains compliance with the other requirements of this permit (e.g., Sections F.1 and F.2).

b. The SWPPP shall be implemented within the time frames established in Section D.7. The permittee shall maintain the SWPPP as a document at the permitted facility, and shall ensure that the.staff responsible for carrying out duties pursuant to the SWPPP are properly .

trained and kept informed with respect to their duties.

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c. The permittee shall make the SWPPP available for review by the Director or an authorized representative during any on-site inspection. The permittee shall provide copies of the SWPPP document to the Department within seven days after receiving a request.

d. The Director may require a permittee to revise their facility's SWPPP:

i. if it does not meet the requirements of Section D.1.a; ii. ifcontainment practices are inadequate; iii. if more effective pollution control or prevention procedures are available and practical; or iv. to meet basin specific water quality goals.

2. Content of Storm Water Pollution Prevention Plan Except as set forth in Section D.6 below, the following items shall be incorporated into the SWPPP.

a. Facility Map(s)

The permittee shall identify facility structures, pollutant sources, outfalls, monitoring points, run off drainage areas and ground cover characteristics on one or more site maps~or drawings.

b. Identity of Potential Pollutants, Outfalls and Monitoring Stations The SWPPP shall identify all outfalls, monitoring stations, and the pollutants that may be potentially discharged from each outfall.

i. In developing the list of potential pollutants discharged from the facility, permittees shall consider the inclusion of all of the following:

(a) All pollutants for which an effluent guideline exists to which the facility is subject; (b) All pollutants regulated or monitored under an existing NPDES permit to which the facility is subject; (c) Any substance for which a release of 500 lb./year or more is indicated on the most recent USEPA Form R report {i.e., Toxic Chemical Release Inventory Form required pursuant to Section 313 of the Federal Emergency Planning and Community Right-to Know Act (Title Ill of the Superfund Amendments and Reauthorization Act of 1986),

Public Law 99-499); and (d) Any other pollutant the permittee has reason to be believe could be discharged in storm water in quantities creating potential water quality impacts.

Industrial Storm Water General Permit NPDES Permit Number NEROOOQO0 Effective Date September 18, 1997 Page 10 of 42 ii. Provided justification exists, not all of the potential pollutants identified by the above criteria, need to appear on the outfall specific lists, However, the SWPPP shall include documentation on why they were not included. The example below should help illustrate such a scenario, EXAMPLE: A facility with a zinc phosphating process would be in the metal finishing category which has effluent guidelines for 7 metals (i.e., cadmium, chromium, copper, lead, nickel, silver, and zinc), cyanide and total toxic organics. Therefore, all of these would be identified in the SWPPP In accordance with Section D.2.b.li above. However, Ifthe facility had no significant sources of the other metals or of cyanide, then only zinc would be identified for possible monitoring. If all storage, loading and processing areas that might be subject to zinc exposure were covered, Itmay be appropriate to exclude zinc as well. The total toxic organic (MTO) parameter for the metal finish category includes a list of 111 organic compounds.

However, of these 111 compounds only benzene and toluene are used in appreciable quantities. Two other solvents, xylene and acetone are also used in significant quantities.

Therefore, acetone, benzene, toluene, and xylene were included on the list of organic compounds for possible monitoring.

iii. The sampling information provided is to be general in nature and shall include:

identification of the sampling point, how samples will be taken (manual or automatic sampler), which parameters will require grab versus composite samples, how flows will be estimated, and how composite samples will be collected (flow or time composites).

Section E.2 provides additional information on sampling and testing.

iv. Portable facilities need not develop outfall specific procedures and information, but they do need to identify the potential pollutants that could be released from the facility.

c. Pollutant Control Strategy The permittee shall identify potential pollution sources and control strategies used to minimize the discharge of pollutants. The pollutant control strategy shall consider the use of containment structures, roof coverings, preventive maintenance, good housekeeping, pollutant source minimization and spill prevention practices.

d. Spill Prevention and Response Practices

i. The permittee shall take measures to prevent spills and to prevent any spills that might occur from impacting waters of the State. This shall include the closure or berming of storm drainage inlets in the immediate vicinity of fueling and liquid chemical transfer areas, or other protective measures, so as to prevent the ready release of spilled fuel or liquid chemicals via storm drains. The spill prevention measures taken shall be identified in the Spill Prevention and Response section of the SWPPP.

ii. The plan shall identify facility personnel responsible for its implementation. Facility personnel responsible for implementing the plan shall be available at all times during facility operations. Spill reporting requirements are set forth in NDEQ Title 126 and in Appendix A, Section A.6 of this permit.

Industrial Storm Water General Permit NPDES Permit Number NEROOOOO Effective Date September 18, 1997 Page 11of42 iii. The spill response plan developed shall conform to the requirements of Chapter 18 of NDEQ Title 126 - Rules and Regulations Pertaining to the Management of Wastes (Contact the Department at the address or telephone number in Section C. 1 for a current copy of this regulation.) and Appendix A, Section A.6 of this permit.

iv. Spill Prevention, Control and Countermeasure (SPCC) Plans developed pursuant to 40 CFR Part 112 may be incorporated into the Spill Prevention and Response Practices section of the SWPPP by reference.

e. Employee Training The permittee shall develop an employee education program that ensures the SWPPP will be effectively implemented. This training program shall identify the employees (or employee positions) that will be subject to the training.

3. Facility Inspections

a. Except as set forth in Section D.6 below, the permittee shall conduct facility inspections as set forth below.

i. All facilities shall be inspected at least semi-annually to ensure that the SWPPP..is being effectively carried out.

ii. At portable sources, the permittee shall conduct inspections within the first seven days after relocation and at least one additional time within the first 90 days of operation.

b. The permittee shall maintain records of the facility inspections for a period of at least three years. At a minimum, the following information shall be included in these records:

i. who conducted the inspections, ii. when inspections are conducted, iii. the findings of the inspections, iv. any corrective actions taken, and

v. when the corrective actions were implemented.

4. SWPPP Reviews and Updates

a. Except as set forth in Section D.6 below, the SWPPP shall be reviewed, at least annually, to ensure it is effective in minimizing the discharge of pollutants, and, if necessary, updated.

K.)

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b. The SWPPP shall be updated and the necessary changes implemented within 30 days after any of the following, unless a Department approved extension is obtained-

i. any SWPPP review that indicates changes are needed; ii. the recognition of any deficiencies or needed changes discovered as a result of facility inspections (See Section D.3); or iii. any changes at the facility that require the SWPPP to be modified.

c. The permittee shall maintain records of the following information relative to all SWPPP reviews and changes for a period of at least 3 years: /

i. who conducted the review; ii. the findings of the review; and iii. any changes made to the SWPPP.

5. Professional Engineer's Certification

a. Except as set forth in Section D.6 below, facilities subject to the Superfund Amendments and Reauthorization Act, Title III Form R reporting requirements for Section 313 Water Priority Pollutants shall have their SWPPPs reviewed and certified by a professional engineer. The submittal of a Form A report (i.e., when the total reportable amount is less than 500 lb.) does not trigger this requirement. Portable facilities are also exempt from this requirement, unless the Department directs them otherwise. The Form R reporting requirements are set forth in 40 CFR Part 372. The Section 313 Water Priority Pollutants are listed in Appendix E of this permit.

b. The certification shall include the following statements:

i. that the certifying engineer has examined and is familiar with the SWPPP, the facility and this permit; and ii. that the SWPPP has been prepared in accordance with good engineering practices and will satisfy the requirements of NPDES permit NERO00000.

c. The certification of the plan shall be accomplished within one of the following time frames:

i. for existing sources which were required to submit Form R reports in the previous year, within 90 days of when authorization to discharge is granted; ii. for existing sources which were not required to submit Form R reports in the year preceding the granting of authorization, within 90 days of the submittal deadline for the Form R report; and iii. for new sources, at the time the facility becomes operational, unless the permittee can reasonably assume that Form R reporting will not be required.

The SWPPP shall be recertified every 5 years or as soon as practicable after significant modifications are made to the facility or the SWPPP.

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6. Reduced Requirements for Enclosed Facilities

a. Unless otherwise directed by the Department, facilities meeting the criteria set forth below are not required to comply with the SWPPP requirements set forth in Sections D.2.a, D.2.b, D.2.c, DA3, D.4.a and D.5,. These facilities are required to comply with the Spill Prevention and Response Practices set forth in Section D.2.c, the employee training requirements of Section D.2.e (i.e., Employees must be informed and trained in spill prevention and response procedures.) and the SWPPP update and record keeping requirements set forth in Sections D.4.b and D.4.c (i.e., Permittees are not required to review Spill Prevention and Response Procedures annually, but must address any deficiencies and must keep records of any changes made to the procedures,). The criteria for identifying facilities that may be subject to these reduced SWPPP requirements are as follows:

i. facilities in which all process areas, storage areas, loading areas, and transfer processes are enclosed, and in which containment is provided for bulk storage areas; and ii. facilities in which all process areas are enclosed and in which any storage, transfer or loading areas are determined by the Department not to pose a significant pollution potential.

b. With respect to Section D.6.a.ii above, the following are generally considered to pose no significant pollution potential:

i. the temporary storage of wooden pallets that are not contaminated with oil, solvent or chemical contamination; ii. the temporary storage of cardboard and paper materials that are not contaminated with oil, solvent or chemical contamiination; iii. the temporary storage of empty, sealed drums provided the outside of the drums are free of contamination; iv. loading operations involving containerized materials where the capacity of the containers do not exceed 500 lb. for solids and 55 gallons for liquids;

v. loading operations involving non-water soluble, solid products or supplies that are not dusty or granular and that do not pose an appreciable threat for release of oil, solvent or other chemical contamination (e.g., structural metal, equipment, parts);

vi. pneumatic and mechanical transfer operations for solid materials that are designed and operated so as to prevent fugitive dust emissions; vii. liquid transfer processes that are designed and operated so as to preclude any routine leakage and so that any inadvertent leakage is contained; and viii. vehicle fueling areas capable of accommodating 4 or less vehicles simultaneously where there is no storm drain in the immediate vicinity, and the location of the fueling station and the surrounding topography make it unlikely that a fuel spill would reach waters of the State in significant quantities (i.e., an exempt fueling station would be located in a flat or contained area with no immediately adjacent streams or drainageways so that an that any spills would be contained on the property using procedures identified in the Spill Prevention and Response Plan).

The above listing does not preclude the Department's authority with respect to Section D.2.a to make case-by-case decisions as to what processes pose or do not pose a significant pollution potential.

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c. Although this subsection relieves some permittees of certain responsibilities with respect to SWPPP requirements, these permittees are responsible for ensuring, that adequate procedures (e.g., SOPs) exist to ensure compliance with the permit, and that periodic procedure and facility reviews are conducted.

7. SWPPP Implementation Deadlines

a. New sources shall complete and implement the SWPPP by the time facility operations commence, except as provided in Section D.7.c of this permit.

b. Existing sources shall complete and implement the SWPPP on or before the time authorization to discharge under the terms and conditions of this permit is granted (See Section C.4), except as provided in Section D.7.c of this permit.

c. The Department may provide the permittee up to 90 days to comply with the provisions in Section D for the development and implementation of a SWPPP. The permittee must submit a written request that explains the circumstances justifying the requests. Proposed compliance extensions are not approved until, and unless, the permittee receives a written acceptance notice from the Department.

8. Reporting Requirements

a. If the SWPPP was not complete at the time the NOI was submitted (See Section C.2.g), the permittee shall submit to the Department a written notice certifying the completion and ..

implementation of the SWPPP, or, if deadlines established in Section D.7 are not met, a non-compliance report (See section D.8.b below). Noticesthat certify compliance with completion deadlines shall be submitted within 14 days, while non-compliance reports shall comply with the deadlines established in Appendix A, Sections 0. 1 thru D.3.

b. The permittee shall report instances of non-compliance using NPDES Form NCR-BMPP in accordance with Appendix A, Sections D.1 thru D.3 of this permit. NPDES Form NCR-BMPP is included as an attachment to this permit. Reportable instances of non-compliance include, but are not necessarily limited to:

i. failure to implement a SWPPP in compliance with the requirements of Section D.2 or the time schedules set forth in Section D.7; ii. failure to carry-out any requirement of this permit (Examples could include: failure to conduct facility inspections, Section D.3; failure to review or update the SWPPP, Section D.4; failure to keep required records, Sections D.3.b, D.4.c or E.1.e; or failure to certify the SWPPP, Section D.5.); and ill. the occurrence of storm water discharges in violation of Sections F. I or F.2 of this permit, In addition to the reporting requirements above, the permittee needs to be familiar with and comply with the reporting requirements set forth in Appendix A Section D.

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 15of42 E. MONITORING REQUIREMENTS AND PROCEDURES

1. Effluent Monitoring Requirements Routine periodic monitoring of storm water is not required unless requested.by the Department.

a. Quantitative analyses for pollutants in storm water discharges may be required by the Department for any of the following reasons:

i. the identification of potential ground and surface water quality impacts to.which the permittee may be contributing; ii. the failure by the permittee to implement pollution prevention or pollution control procedures set forth in the facilities Storm Water Pollution Prevention Plan; iii. the recognition of potential pollutant sources during site inspections or investigations; and/or iv. to obtain information for watershed basin or industry group studies.

b. The permittee shall report the results of all quantitative analyses of storm water discharges within 45 days of the sampling date unles's otherwise directed by the ;Departmenit.,,,Analytical results shall be submitted using NPDES Form SW-SEMR which is an attachme6nti.'this permit. This reporting requirement includes monitoring that was not required by the permit and monitoring that was conducted using protocols not set forth in this permit.

I-J c. The Department may require permittees to conduct periodic physical examinations-of storm water discharges from faility outfalls, and to provide written reports on the findings of physical examinations. In general, physical examinations involve the checking of'grab samples, and/or the effluent itself, for characteristics of color, odors, turbidity, hydrocarbon sheens, and other indications of pollution. NPDES Form PE (See Attachments) may be used to record physical examination observations. The Department may require physical examinations due to site-specific, industry group, basin, or watershed concerns.

d. The permittee shall investigate and identify the source and cause of pollution identified as a result of physical examinations or quantitative analyses. Corrective actions will be taken as necessary to maintain compliance with Sections D.1.a and D.4 of this permit.

e. Records of all monitoring activities, including the results of physical examinations, quantitative analyses, and storm event monitoring (See -Section E.3 below), shall be retained by the permittee for a period of 3 years as set forth in Appendix A, Section C.5 and C.6.

2. Sampling and Analytical Protocols The sampling procedures set forth below shall be used for storm water monitoring required pursuant to Section E. 1.a, unless the Department specifies or approves alternative procedures.

The sampling protocols used shall accurately portray the mass of the pollutants discharged during the time interval monitoring is carried out.

a. Samples shall be collected from discharges resulting from a rainfall event that is greater than 0.1 inch in magnitude and occurs at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after any previous storm events of 0.1 inch or greater.

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b. Grab samples shall be used for monitoring: pH, temperature, cyanide, total phenols, residual chlorine, petroleum oil, oil and grease, bacterial counts, xylene and compounds in the volatile fraction of the total toxic organic parameter. Grab samples shall be collected in the first 15 minutes of a storm event discharge.

c. Composite samples shall be used to monitor for most other parameters. Composite samples shall be taken in accordance with the requirements set forth in Appendix A Section C.1. If discrete composite sampling is used, at least 3 aliquots shall be obtained and the maximum interval between sampling events shall not exceed 15 minutes. Sampling shall begin within the first 15 minutes of discharge and shall not extend beyond 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , unless there Is reason to believe that pollutant discharge rates increase after that time.

d. For discharges from holding ponds or other impoundments with a retention period greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (estimated by dividing the volume of the detention pond by the estimated volume of water discharged during the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months previous to the time the sample is collected), grab samples may be used instead of composite samples.

e. Sample analysis procedures shall conform to the procedures specified in Appendix A, Section C.3.

3. Storm Event Monitoring The permittee shall collect the following information for each storm event monitored pursuant to Section E.1. of this permit, unless the Department specifies otherwise.

a. The date, duration (in hours), start and ending times, and magnitude (in inches) of the storm event sampled.

b. The total volume of storm water discharged. The permittee may calculate runoff volume from the magnitude of the storm, the area drained and the runoff coefficient. The calculation method used must be approved by the Department.

c. The duration between the storm event samples and the end of the previous measurable (greater than 0.1 inch rainfall) storm event.

4. Monitoring Station Requirements

a. The permittee shall designate a monitoring point for each storm water outfall. Unless otherwise approved by the Department, the drainage area discharging through any monitoring point shall be under the control or ownership of the permitted facility.

b. Each monitoring point shall provide a representative sample of the storm water being discharged. Flow monitoring provisions shall be provided unless the permittee can accurately estimate discharge flows as set forth in Section E.3.b above.

c. The Department can require the source to redesignate existing sample points or designate additional sample points:

i. if dilution flows from non-regulated areas are present, or ii. to provide more detailed information on potential pollutant sources that exist at a facility.

Industrial Storm Water General Permit NPDES Permit Number NEROOOOO Effective Date September 18, 1997 Page 17 of 42 F. OTHER CONDITIONS AND REQUIREMENTS

1. Discharges shall be free from toxic substances, which alone or in combination with other substances, create conditions unsuitable for aquatic life.

2. Discharges shall not contain pollutants at concentrations or levels that produce objectionable films, colors, turbidity, deposits, or noxious odors in the receiving stream or waterway.

3. The use of the attached NPDES Form ISW-EX is not required. Category xi facilities wishing to notifly the Department that they are exempt from the storm water definition, muse this form to do so, or they may submit anotherform of written notice. The ISW-EX form explains the exemption available to some category xi facilities.

4. The attachments to this permit (i.e., Forms ISW-NOI, SW-SEMR, NCR-BMPP, RN, PE, and ISW-EX) may be modified by the Department provided the modified forms satisfy the..

notification and repprting requirements set forth in this permit are met. If information'is submitted on an outdated form, opportunity to resubmit.the information shall be provided the permittee, or, at the discretion of the Department, submittals on outdated forms may :be accepted.

G. REPORTING AND RECORD KEEPING REQUIREMENTS This section summarizes reporting and record keeping requirements set forth in other sections of this permit. This section is intended as an aid to permittees in identifying and complying with these requirements, and contains references to the Sections of the permit where the requirements are set forth.

This summary list does not contain all the reporting and record keeping requirements that-may be required by various Department regulations, nor does it relieve the permittee of -the responsibility to comply with reporting requirements not listed below.

1. All facilities must submit an initial Notification of Intent; additional information submittal requirements may also exist for some facilities (Sections C. I thru C.4).

2. Portable facilities must submit a notification of location changes at least 20 days in advance of relocation (Section C.7).

3. Notification is required when changes are made that effect facility portability (Section C.9).

4. Termination notification requirements are set forth in Section C.10.

5. A copy of the SWPPP must be submitted within 7 days if requested by the Department (Section D.1 .c).

6. Chapter 18 of NDEQ Title 126 - Rules and Re1Qulations PertaininQ to the Management of Wastes contains spill reporting requirements. Section D.2.d.ii of this permit requires the Spill Prevention and Response Practices of the SWPPP to comply with this regulation. Appendix A, Section A.6 also contains information on spill reporting.

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7. Records of permittee conducted facility inspections must be kept for at least 3 years (Section D.3.b).

8. Records of SWPPP reviews and changes must be kept for at least 3 years (Section D.4,c).

9. If the SWPPP was not complete at the time the NOI was submitted, the permittee must provide notification of It's completion and implementation (Sections D.8.a)

10. When appropriate, non-compliance reports using NPDES Form NCR-BMPP must be submitted (Section D.8.b and Appendix A, Sections D.1 thru D.3). Some non-compliance situations may require immediate and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months reporting as set forth in Appendix A ,Sections D.1 and D.2.

11. The results of all quantitative analyses performed must be reported using NPDES Form SW-SEMR. This includes monitoring that is not required by the permit or that may not conform to permit required conditions (Section E.1.b).

12. Written reports on the results of any physical examinations of storm water may also be required (Section E.1.c).

13. Records of all monitoring activities and results must be kept for a period of three years (Section E.1 .e and Appendix A, Sections C.5 & C.6).

14. In addition to -the reporting and record keeping requirements referenced above, Appendix A also contains reporting and record keeping requirements that may apply to some storm water dischargers. References to these requirements are listed below:

)

a. Appendix A, Section B.I. - Duty to Provide Information,

b. Appendix A, Sections C.5 & C.6 - Retention of Records and Record Contents,

c. Appendix A, Section D.1 - Immediate Notification,

d. Appendix A, Section D.2.- 24-Hour Reporting, .

e. Appendix A, Section D.3 - Written Non-Compliance Notification

f. Appendix A, Section D.4 - Quarterly Discharge Monitoring Reports

g. Appendix A, Section 0.5- Changes in Discharge

h. Appendix A, Section D.6 - Toxic Discharge Reporting Requirements,

i. Appendix A, Section D.7- Changes in Sludge Quality,

j. Appendix A, Section D.9. - Transfers

k. Appendix A, Section E.2 - Upset Reporting, and I. Appendix A, Section E.3 - Bypass Reporting

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 1 8, 1997 Page 19of42 APPENDIX A - Standard Conditions for NPDES and NPP Permits.

These general conditions are applicable to all NPDES and NPP permits. These conditions shall not preempt any more stringent requirements found elsewhere in this permit.

A. General Conditions

1. Information Available All permit applications, fact sheets, permits, discharge.data, monitoring reports, and any public comments concerning such shall be available to the public for inspection and copying, unless such information about methods or processes is entitled to protection as trade secrets of the owner or operator under Nob, Rev.

Stat. §81-1527, (Curm, Supp, 1992) and Title 115, Chapter 9.

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

The permittee shall comply with all conditions of this permit, Failure to comply with these conditions may be grounds for administrative action or enforcement proceedings including injunctive relief arid civil or criminal penalties.

The filing of a request by the permittee for a permit modification, revocation and reissuance, termination or a notification of planned changes or anticipated noncompliance, does not stay any permit condition.

3. Duty to Mitigate The permittee shall take all reasonable steps to minimize, prevent or correct any adverse impact to the environment resulting from no'ncompliancp with this permit, including such accelerated or additional monitoring as required by the NDEQ to determine the nature and impact of the noncompliant discharge.

4. Permit Actions This permit may be modified, suspended, revoked or reissued, in part .or in whole, in accordance with the regulations set forth in NDEQ Titles 119 and/or 127. In addition, this permit may be -modified, revoked and reissued to incorporate standards or limitations issued pursuant to Sections 301 (b)(2)(c), 301 (b)(2)(d),

304(b)(2), 307(a)(2), or 405(d) of the Clean Water Act, Public Law 100-4 (i.e.. industrial categorical standards and municipal sludge regulations) and Title 121.

5. Toxic Pollutants The permittee shall not discharge pollutants to waters of the State that cause a violation of the standards established in NDEQ Titles 117, 118 or 121. All discharges to surface waters of the State shall be free of toxic (acute or chronic) substances which alone or in combination with other substances, create conditions unsuitable for aqualic life outside the appropriate mixing zone.

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 20 of 42 Appendix A (continued)

6. Oil and Hazardous Substances/Spill Notification Nothing in this permit shall preclude the initiation of any legal action or relieve the permittee from any responsibilities, liabilities or penalties under Section 311 of the Clean Water Act. The permlttee shall conform to the provisions set forth in NDEQ Title 126 in the event of a release of a reportable quantity of oil or hazardous substances. If the permittee knows, or has reason to believe, that oil or hazardous substances were'released at the facility and could enter waters of the State or any of the outfall discharges authorized in this permit, the permittee shall Immediately notIfy the Department of a release of oil or hazardous substances. During Department office hours (i.e., 8:00 a.m, to 5:00 p.m., Monday through Friday, except holidays), notification shall be made to the LUSTIER Section (telephone number

.402/471-4230). When the LUST/ER Section cannot be contacted, the permittee shall report to the Nebraska State Patrol for referral to the NDEQ Emergency Response Team (telephone number 402/471-4545). It shall be the permittee's responsibility to maintain current telephone numbers necessary to carry out the notification requirements set forth above.

7. Property Rights The issuance of this permit does not convey any property rights of any sort or any exclusive privileges nor does it authorize any damage to private property or any invasion of personal rights nor any infringement of federal, state or local laws or regulations.

8. Severability If any provision of this permit is held invalid, the remainder of this permit shall not be affected. )

9. Other Rules and Regulations Liability The issuance of this permit in no way relieves the obligation of the parmlttee to comply with other rules and regulations of the Department.

10. Inspection and Entry The permittee shall allow the Director or his authorized representative, upon the presentation of his identification and at a reasonable time:

a. to enter upon the permittee's premises where a regulated facility or activity is located or conducted, or records are required to be kept under the terms and conditions of the permit,

b. to have access to and copy any records required to be kept under the terms and conditions of the permit,

c. to inspect any facilities, equipment (including monitoring and control), practices or operations regulated or required In the permit, and

d. to sample or monitor any substances or parameters at any location.

11. Penalties Violations of the terms and conditions of this permit may result in the initiation of criminal and/or civil actions. Civil penalties can result in fines of up to $10,000.00 per day [Neb. Rev. Stat. §81-1508, as amended to date. Criminal penalties for willful or negligent violations of this permit may result in penalties of $10,000.00 per day or by imprisonment. Violations may also result in federal prosecution.

Industrial Storm Water General Permit NPDES Permit Number NEROOOOO Effective Date September 18, 1997 Page 21 of 42 Appendix A (continued)

B. Management Requirements

1. Duty to Provide Information The permittee shall furnish to the Department witlijn a reasonable time, any information which the Department may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit; or to determine compliance with this permit. The permittee shall also furnish to the Department upon request, copies of records retained as a requirement of this permit.

2. Duty to Reapply The permittee shall apply for a reissuance of this permit, If an activity regulated by this permit is to be continued after the expiration date of this permit. The application shall be submitted at least 180 days before the expiration of this permit on an application form supplied by the Department, as set forth in NDEQ Titles 119 and/or 127.

3. Signatory Requirements All reports and applications required by this permit or submittedto maintain compliance withtffishpermit, shall be signed and certified as set forth in this section.

ta.Permit applications shall be signed by a cognizant official who meets the following criteria:

(1) for acorporation: by a principal executive officer 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 facility: by either a principal executive officer or highest ranking elected official.

b. Discharge monitoring reports and other information shall be signed by the cognizant official or by an authorized representative.

c. An authorized representative is designated by-the cognizant official. The.authorized representative is responsible for the overall operation of the facility (i.e., a plant manager, a well field operator or a wastewater treatment plant superintendent).

d. Any change in the signatories shall be submitted to the Department, in writing, within 30 days after the change.

e. Certification. All applications, reports and information submitted as a requirement of this permit, shall contain the following certification statement:

'I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel propedy gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the irformation, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information including the possibility of fine and imprisonment for knowing violations."

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 22 of 42 Appendix A (continued)

C. Monitoring and Records

1. Representative Sampling Samples and measurements taken as required within this permit shall be, representative of the discharge.

All samples shall be taken at the monitoring points specified in this permit and, unless otherwise specified, before the effluent joins or is diluted by any other waste stream, body of water or substance. Monitoring points shall not be changed without notification to the Department and with the written approval of the Director.

a. Composite sampling shall be conducted in one of the following manners:

(1) continuous discharge - a minimum of one discrete aliquot collected every three hours, (2) less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months - a minimum of hourly discrete aliquots or a continuously drawn sample shall be collected during the discharge, or (3) batch discharge - a minimum of three discrete aliquots shall be collected during each discharge.

b. Composite samples shall be collected in one of the following manners:

(1) the volume of each aliquot must be proportional to either the waste stream flow at the time of sampling or the total waste stream flow since collection of the previous aliquot, (2) a number of equal volume aliquots taken at varying time intervals in proportion to flow, (3) a sample continuously collected in proportion to flow, and (4) where flow proportional sampling is infeasible or nonrepresentative of the pollutant loadings the Department may approve the use of time composite samples.

c. Grab samples shall consist of a single aliquot collected over a time period not exceeding 15 minutes.

d. All sample preservation techniques shall conform to the methods adopted in NDEQ Title 121, Chapter 8, unless:

(1) in the case of sludge samples, alternative techniques are specified in the 40 CFR, Part 503, or (2) other procedures are specified in this permit.

2. Flow Measurements Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be used to Insure the accuracy and reliability of measurements. The devices shall be installed, calibrated and maintained to insure that the accuracy of the measurements are consistent with the accepted capability of that type of device. Devices selected shall be capable.of measuring flows with a maximum deviation of +/- 10% from the true discharge rates throughout the range of expected discharge volumes.

Guidance in selection, installation, calibration and operation of acceptable flow measurement devices can be obtained from the following references:

a. "Water Management Manual," U. S. Department of Interior, Bureau of Reclamation, Second Edition, Revised Reprint, 1974, 327 pp. Available from the U. S. Government Printing Office. Washington, DC 20402. Order by Catalog Number 127.1912:W29/2, Stock Number SIN 24003-0027.

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 23 of 42 Appendix A (continued)

b. "Flow Measurement in Open Channels and Closed Conduits," U.S. Department of Cominerme, National Bureau of Standards, NBS Special Publication 484, October, 1977, 982 pp. Avallable in paper copy or microfiche from National Technical Information Service (NTIS), Springfield, VA 22151.

Order by NTIS Number PB.273 535/5ST.

c. "NPDES Compliance Sampling Manual," U. S. Environmental Protection Agency, Office of Water Enforcement, Publication MCD-51, May, 1988, 140 pp. Available from the General Services Administration (SFFS), Centralized Mailing Lists Services, Building 41, Denver Federal Center, Denver, CO 80225.

3. Test Procedures Test procedures used for monitoring required by this permit, shall conform to the methods adopted in NDEQ Title 121, Chapter 8 unless:

a. in the case of sludge samples, alternative techniques are specified In the 40 CFR, Part 503, or

b. other procedures are specified in this permit.

4. Averaging of Measurements Averages shall be calculated as an arithmetic mean except:

a. bacterial countswhich shall be calculated as a geometric mean, or

b. where otherwise specified by the Department.

5. Retention of Records The permittee -shall retain records of all monitoring activities for a period of at least three years (five years for sludge; see below) as set forth in NDEQ Titles 119 and/or 127. The types of records that must be retained include, but are not limited to:

a. calibration and maintenance records,

b. original strip chart recordings,

c. copies of all reports required by this permit,

d. monitoring records and information, and

e. electronically readable data.

The permittee shall retain records of monitoring required by this permit that are related to sludge use and disposal for a period of five years or longer, as required in 40 CFR, Part 503.

6. Record Contents Records of sampling or monitoring information shall include:

) a. the date(s), exact place, time and methods of sampling or measurements,

Industrial Storm Water General Permit NPDES Permit Number NEROOOOO Effective Date September 18, 1997 Page 24 of 42 Appendix A (continued)

b. the name(s) of the individual(s) who performed the sampling or measurements,

c. the date(s) the analyses were performed,

d. the individual(s) who performed the analyses,

e. the analytical techniques or methods used,

f. the results of such analyses, and

g. laboratory data, bench sheets and other required information.

D. Reporting Requirements

1. Immediate Notification

a. NPP permittees shall report immediately to the publicly owned treatment works (POTW), any discharge to the POTW that may result in a violation of NDEQ Title 127, Chapter 3.

b. All perrnittees shall report immediately to the NDEQ:

(1) discharges of oil or hazardous substances which threaten waters of the State or public health and welfare, and (2) discharges causing in-stream toxicity (i.e., a fish kill) or an imiYnediate threat to human health. )

Initial notification may be verbal. A written noncompliance notification shall be submitted as set forth in Section D. 3. of this Appendix.

2. 24-Hour Reporting The permitiee shall report to the NDEQ, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of becoming aware of:

a. any noncompliance which may endanger the environment or human health or welfare,

b. any unanticipated bypass as set forth in NDEQ Titles 119 and/or 127,

c. all upsets as set forth in NDEQ Titles 119 and/or 127,

d. any discharge to a POTW that causes a violation of the prohibited discharge standards set forth in NOEQ Title 127, Chapter 3, or

e. any noncompliance of an effluent limitation in this permit.

Initial notification may be verbal. A written noncompliance notification shall be submitted as set forth in Section D. 3. of this permit.

If sampling performed by an industrial user (NPP permittee) indicates a permit effluent violation, the permittee shall notify the Department and the city within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of becoming aware of the violation.

The permittee shall resample and have it analyzed. The results of the resampling analysis shall be submitted to the Department and the city within 30 days after becoming aware of the violation.

)

Industrial Storm Water General Permit NPDES Permit Number NER000000 Effective Date September 18, 1997 Page 25 of 42 Appendix A (continued)

3. Written Noncompliance Notification

a. The permittee shall submit a written noncompliance report to the NDEQ:

(1) within five days of becoming aware of any noncompliance with the:

(a) NPP effluent limitations or requirements set forth in this permit, or (b) NPDES toxic pollutant effluent limitations or requirements set forth in this permit.

(2) within seven days of becoming aware of any other noncompliance with the NPDES requirements and/or effluent limitations set forth in this permit.

b. the written notification shall be submitted on a noncompliance form supplied by the Department and shall include:

(1) a description of the discharge and cause of noncompliance, (2) the period of noncompliance, including exact dates and times, or ifnot corrected, therantlclpated time the noncompliance is expected to continue, and (3) the steps-taken to reduce, eliminate and prevent the reoccurrence of the noncompliance.

The submittal of a written noncompliance report does not relieve the permnittee of any liability from enforcement proceedings that may result from the violation of permit or regulatory requirements.

4. Quarterly Discharge Monitoring Reports (DMRs)

The permittee shall report the monitoring results required by this permit on a DMR form supplied or approved by the ibepartment. Monttoring results shall be submitted on a quarterly basis using the reporting schedule set forth below, unless otherwise specified in this permit or by the Department.

Monitoring Quarters DMR Reporting Deadlines January - March - April 28 April - June July 28 July - September October 28 October-- December January 28 Ifthe permittee monitors any pollutant more frequently than required by this permit, using procedures specified in this permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted on the DMR. The frequency of the analysis shall also be reported on the DMR.

S. Changes in Discharge Any facility expansion, production increases or process modifications which will result in new or substantially increased discharges of pollutants or a change in the nature of the discharge of pollutants must be reported by the permittee 180 days prior to the expansion, increases or modifications, either by amending his original application or by submitting a new application. This permit may be modified or revoked and reissued as a result of this notification to maintain compliance with applicable state or federal regulations.

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 1 8, 1997 Page 26of42 Appendix A (continued)

6. Changes in Toxic Discharges from Manufacturing, Commercial, Mining and Silvicultural Facilities Permittees discharging from manufacturing, commercial, mining and silvicultural facilities shall report to the Department:

a. If any toxic pollutant not limited in this permit is discharged from any NPDES outfall as a result of any activity that will or has occurred and results in Its routine or frequent discharge. The Department shall be Informed Ifthat discharge exceeds the following notification levels:

(1) 100 micrograms per liter (0.1 mg/I) for any toxic pollutant, (2) 200 micrograms per liter for acrolein and acrylonitrdle (0.2 mg/I),

(3) 500 micrograms per liter for 2,4-dinitrophenol and for 2-methyl-4, 6-dinitrophenol (0.5 mg/I),

(4) 1000 micrograms per liter for antimony (1 mg/I),

(5) five times the maximum concentration value reported for that pollutant in the permit application or (6) an alternative level established by the Director, and

b. if anytoxic pollutant not limited inthis permit is discharged from an NPDES outfall as a result of any activity that will or has occurred and results in Its nonroutine discharge. The Department shall be informed ifthat discharge exceeds the following notification levels: )

(1) 500 micrograms per liter (0.5 mg/I) for any toxic pollutant, (2) 1000 micrograms for antimony (1 mg/i),

(3) ten times the maximum concentration value reported for that pollutant in the permit application, or (4) an alternative level established by the Director.

7. Changes in Sludge Quality The permittee shall provide written notice to the Department of any alteration or addition that results in a significant change in the permittee's sludge use or disposal practices. This permit may be modified or revoked and reissued as a result of this notification to maintain compliance with applicable state or federal regulations.

8. Changes of Loadings to Publicly Owned Treatment Work (POTW)

POTWVs shall notify the Department of the following:

a. any new introduction of pollutants from dischargers subject to the categorical pretreatment discharge limitations set forth In NDEQ Title 121, Chapter 2, and

b. any substantial change in the volume or character of pollutants being introduced into the POTW.

Notification shall be made 180 days in advance whenever possible. Information on the quantity and quality of new discharges and their anticipated impact on the POTW shall be included.

Industrial Storm Water General Permit NPDES Permit Number NEROO00 Effective Date September 18, 1997 Page 27 of 42 Appendix A (continued)

9. Transfers The permittee shall notify the Department at least 30 days prior tothe proposed transfer of ownership of this permit or the permitted facility to another party as set forth in NDEQ Title 119, Ghapter 12 and/or NDEQ Title 127, Chapter 14. The Department may modify or revoke and reissue this permit according to the regulations set forth in NDEQ Titles 119 and/or 127.

10. Compliance Schedules The permittee shall submit a written report of compliance or noncompliance with any compliance schedule established in this permit. The written report shall be submitted within 14 days following all deadlines established in the compliance schedule. If compliance has not been achieved, the report shall Include an alternative completion date, an explanation of the cause of the noncompliance and an explanation of the steps being taken to ensure future compliance. The submission of this report does not ensure the Department's acceptance of alternative compliance dates nor does It preclude the Department from Initiating enforcement proceedings based upon the reported noncompliances.

E. Operation and Maintenance

1. Proper Operation and Maintenance The permittee shall, at all times, maintain in good working order and operate as efficiently as possible, any and facilities conditionsor of systems of control this permit. This Installed by the but wouldinclude, permittee not be In orderto, limited to effective achieve compliance with the terms performance-.based on designed facility removals, effective management, adequate operator staffing and training, adequate laboratory and process controls, and adequate funding which reflects proper user fee schedules.

2. Treatment System Failure and Upset An upset is an affirmative defense to an enforcement action brought for noncompliance with technology-based permit effluent limitations if the permittee can demonstrate, through properly signed, operating logs or other relevant evidence, that:

a. an upset occurred and the specific cause was Identified,

b. that the facility was properly operated and maintained atsuch.time,

c. the Department was notified within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the permittee becoming aware of the upset, and

d. the permittee took action to reduce, eliminate and prevent a reoccurrence of upset, including minimizing adverse impact to waters of the State,

3. Bypassing Any diversion from or bypass of the treatment facilities Is prohibited, unless:

a. it is unavoidable to prevent loss of life, personal injury or severe property damage,

b. no feasible alternative exists, i.e., auxiliary treatment facilities, retention of Untreated wastes or maintenance during normal periods of equipment downtime,

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 28of42 Appendix A (continued)

c. the permittee submits notice to the Department within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of becoming aware of the bypass or if the bypass is anticipated or should have been anticipated, the Department is notified at least ten days prior to the bypass, and

d. the bypass is conducted under conditions determined to be necessary by the Director to minimize any adverse effects.

If the bypass is needed for regular preventative maintenance for which back-up equipment should be provided, the bypass will not be allowed. When a bypass occurs, the burden is on the permittee to demonstrate compliance with Items "a"through "d" above.

Additionally, NPP permlttees shall report any bypasses to the POTW. Unanticipated bypasses shall be reported immediately and anticipated bypasses shall be reported at least ten days in advance.

All NPDES permlttees shall notify the general public that a bypass of the treatment system is occurring.

'The public notification shall include:

a. location of the bypass,

b. the date the bypass started,

c. anticipated length of time the bypass will occur, and

d. an estimate of the total volume of wastewater bypassed. )

4. Removed Substances Solids, sludge, filter, backwash or other pollutants removed in the course of treatment or control of wastewater shall be disposed of at a site and in a manner approved by the Nebraska Department of Environmental Quality. The disposal of nonhazardous industrial sludges shall conform to the standards established In or to the regulations established pursuant to 40 CFR, Part 257, The disposal of sludge shall conform to the standards established in or to the regulations established pursuant to 40 CFR, Part 503. If solids are disposed of In a licensed sanitary landfill, the disposal of solids shall conform to the standards established in Title 132. Publicly owned treatment works shall dispose-of sewage sludge in a manner that protects public health and the environment from any adverse effects which may occur from toxic pollutants as defined in Section 307 of the Clean Water Act. This permit may be modified or revoked and reissued to incorporate regulatory limitations established pursuant to 40 CFR, Part 503.

F. Definitions Administrator: The Administrator of the USEPA, Aliquot: An individual sample having a minimum volume of 100 milliliters that is collected either manually or in an automatic sampling device.

Biweekly: Once every other week.

Bimonthly: Once every other month.

Bypass: The intentional diversion of wastes from any portion of a treatment facility. )

industrial Storm Water General Permit NPDES Permit Number NER00000D Effective Date September 18, 1997 Page 29 of 42 Appendix A (continued)

Daily Average: An effluent limitation that cannot be exceeded and is calculated by averaging the monitoring results for any given pollutant parameter obtained during a 24-hour day.

Department: Nebraska Department of Environmental Quality.

Director: The Director of the Nebraska Department of Environmental Quality.

Industrial User: 'Asource of indirect discharge (a pretreatment facility).

Monthly Average: An effluent limitation that cannot be exceeded, calculated by averaging the monitoring results for any given pollutant parameter obtained during a calendar month.

Publicly Owned Treatment Works (POTW): Atreatment works as defined by Section 212 of the Clean Water Act (Public Law 100-4) which Is owned by the state or municipality, excluding any sewers or other conveyances not leading to a facility providing treatment.

30-Day Average: An effluent limitation that cannot.be exceeded, calculated by averaging the monitoring results for any given pollutant parameter obtained during a calendar month.

Total Toxic Organics (TTO): .The summation of all quantifiable values greater than 0.01 milligrams per liter

((mg/I)for toxic organic compounds that may be identified elsewhere in this permit. (Ifthis term has application in this permit, the list of toxic organic compounds will be identified; typically in the Limiftations and Monitoring Section(s) or in an additiohal Appendix to this permit.)

Toxic Pollutant: Those pollutants or combination of pollutants, including disease causing agents, after discharge and upon exposure, ingestion, inhalation or assimilation into an organism, either directly from the environment or indirectly by ingestion through food chains will, on the basis of information available to the administrator, cause death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunction (including malfunctions in reproduction) or physical deformations, in such organisms or their offspring.

Upset: An exceptional incident in which there is unintentional and temporary noncompliance with technology based permit effluent limitations because of factors beyond the reasonable control of the permittee, excluding such factors as operational error, improperly designed or inadequate treatment facilities.or improper operation and maintenance or lack thereof.

Volatile Organic Compounds (VOC): The summation of all quantifiable values greater than 0.01 milligrams per liter (mg/l) for volatile, toxic organic compounds that may be identified elsewhere in this permit. (See the definition for Total Toxic Organics above. In many instances, VOCs are defined as the volatile.fraction of the TTO parameter, If the term "VOC" has application in this permit, the list of toxic organic compounds will be identified; typically in the Limitations and Monitoring Section(s) or in an additional Appendix to this permit.)

Weekly Average: An effluent limitation that cannot be exceeded, calculated by averaging the monitoring results for any given pollutant parameter obtained during a fixed calendar week. The permittee may start their week on any weekday but theweekday must remain fixed unless a change is approved by the Department.

"X"Day Average: An effluenl limitation defined as the maximum allowable "X"day average of consecutive monitoring results during any monitoring period where "X"is a number in the range of one to seven days.

Industrial Storm Water General Permit NPDES Permit Number NERO0000D Effective Date September 18, 1997 Page 30 of 42 Appendix A (continued)

G. Abbreviations CFR: Code of Federal Regulations kglDay: Kilograms per Day MGD: Million Gallons per Day mg/L: Milligrams per Liter NDEQ: Nebraska Department of Environmental Quality NDEQ Title 115: Rules of Practice and Procedure NDEQ Title 117: Nebraska Surface Water Quality Standards NDEQ Title 118: Ground Water Quality Standards and Use Classification NDEQ Title 119: Rules and Regulations Pertainino to the Issuance of Permits Under the National Pollutant Discharge Elimination System NDEQ Title 121: Effluent Guidelines and Standards NDEQ Title 126: Rules and Regulations Pertaining to the Management of Wastes NDEQ Title 127: Rules and Regulations Goveming the Nebraska Pretreatment Program NDEQ Title 132: Rules and Regulations Pertaining to Solid Waste Management NPDES: National Pollutant Discharge Elimination System NPP: Nebraska Pretreatment Program POTW: Publicly Owned Treatment Works uglL: Micrograms per Liter WWTF: Wastewater Treatment Facility

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997

Page 31 of 42 Appendix B - Definition for "Storm water discharge associated with industrial activity" The following definition is set forth in Nebraska Department of Environmental Quality Title 119, Rules and Reaulations Pertaining to the Issuance of Permits Under the National Pollutant Discharge Elimination System, Chapter 1.062, which adopts the Federal definition set forth in 40 CFR Part 122.26(b)(14).

Storm water dischare associated with industrial activity means the discharge from any conveyance which is used for collecting and conveying storm water and which is directly related to manufacturing, processing or raw materials storage areas at an industrial plant. The term does not include discharges from facilities or activities excluded from the NPDES program under 40 CFR part 122. For the categories of industries Identified In paragraphs (b)(14)(i) through (x)of this section, the term includes, but Is not limited to, storm water discharges from Industrial plant yards; Immediate access roads and rail lines used or traveled by calriers of raw materials, manufactured products, waste material, or by-products used or created by the facility; material handling sites; refuse sites; sites used for the application or disposal of process waste waters (as defined at 40 CFR part 401);

sites used for the storage and maintenance of material handling equipment: sites used for residual treatment, storage, or disposal; shipping and receiving areas; manufacturing buildings; storage areas (Including tank farms) for raw materials, and intermediate and finished products; and areas where Industrial activity has taken place In the past and significant materials remain and are exposed to storm water. For the categories of industries Identified Inparagraph (b)(14)(xi) of this section, the term includes only storm water discharges from all the areas (except access roads and rail lines) that are listed in the previous sentence where material handling equipment or activities, raw materials, intermediate products, final products, waste materials, by-products, or industrial machinery are exposed to storm water. For the purposes of this paragraph, material handling activities include the storage, loading and unloading, transportation, or conveyance of any raw material, Intermediate product, finished product, by-product or waste product. The term excludes areas located on plant lands separate from the plant's industrial activities, such as office buildings and accompanying parking !ots as long as the drainage from the excluded areas Is not mixed with storm water drained from the above described areas. Industrial facilities (including industrial facilities that are Federally, State, or municipally owned or operated that meet the description of the facilities listed Inthis paragraph(b)(14)(i)-(xi) of this section) include those facilities designated under the provisions of paragraph (a)(1)(v) of this section. The following categories of facilities are considered to be engaging in "industrial activity* for purposes of this subsection:

JU facilities subject to storm water effluent limitations guidelines, new source performance standards, or toxic pollutant effluent standards under 40 CFR subchapter N(except facilities with toxic pollutant effluent standards which are exempted under category (xi) in paragraph (b)(14) of this section);

fj. Facilities classified as Standard Industrial Classifications 24 (except 2434), 26 (except 255 and 287), 28 (except 283), 29, 311. 32 (except 323), 33, 344, 373; fiii) Facilities classified as Standard Industrial Classifications 10 through 14 (mineral industry) including active or inactive mining operations (except for areas of coal mining operation no longermeeting the definition of a reclamation area under 40 CFR 434.11(1) because the performance bond issued to the facility bythe appropriate SMCRA authority has been released, or except for areas of non-coal mining operations which have been released from applicable State or Federal reclamation requirements after December 17, 1990) and oil and gas exploration, production, processing, or treatment operation, or transmission facilities that discharge storm water contaminated by contact with or that has come into contact with, any overburden, raw material, intermediate products, finished products, byproducts or waste products located on the site of such operations; (inactive mining operations are mining sites that are not being actively mined, but which have an Identifiable owner/operator, Inactive mining sites do not include sites where mining claims are being maintained prior to disturbances associated with the extraction, beneficiation, or processing of mined materials, nor sites where minimal activities are undertaken for the sole purpose of maintaining a mining claim);

Industrial Storm Water General Permit NPDES Permit Number.NEROOOOO Effective Date September 18, 1997 Page 32 of 42 Appendix B (continued) fivi Hazardous waste treatment, storage, or disposal facilities, Including those that are operating under Interim status or a permit under subtitle C of RCRA:

fy) Landfills, land application sites, and open dumps that receive or have received any indutrial wastes (waste that Is received from any of the facilities described under this subsection) including those that are subject to regulation under subtitle D of RCRA; (vi) Facilities involved in the recycling of materials, including metal scrapyards, battery reclaimers, salvage yards. and automobile junkyards, including but limited to those classified as Standard Industrial Classification 5015 and 5093:

Lyi Steam electric power generating facilities, Including coal handling sites;

{vyJii Transportation facilities classified as Standard Industrial Classifications 40, 41, 42 (except 4221-4225), 43, 44, 45, and 5171 which have vehicle maintenance shops, equipment cleaning operations, or airport deicing operations. Only those portions of the facility that are either Involved In vehicle maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication), equipment cleaning operations, or which are otherwise identified under paragraphs (b)(14)(i)-(vii) or (ix)-(xl) of this section are associated with industrial activity; Lix) Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used Inthe storage treatment, recycling, and reclamation of municipal or domestic sewage, Including land dedicated to the disposal of sewage sludge that are located within the confines of the facility, with a design flow of 1.0 mgd or more, or required to have an approved pretreatment program under 40 CFR part 403. Not Included are farm lands, domestic gardens or lands used for sludge management where sludge Is beneficially reused and which are not physically located in the confines of the facility, or areas that are in compliance with section 405 of the CWA; lxi Construction activity including clearing, grading and excavation activities except: operations that result in the disturbance of less than five acres of total land area which are not part of a larger common plan of development or sale; WIli Facilities under Standard Industrial Classifications 20, 21, 22, 23. 2434, 25, 265, 27, 283, 285, 30, 31 (except 311). 34 (except 3441), 35, 36, 37 (except 373), 38, 39, 4221-25, (and which are not otherwise included within categories (ii)-(x));

industrial Storm Water General Permit NPDES Permit Number NERODOOO0 Effective Date September 18, 1997 Page 33 of 42 Appendix B (continued)

Clarification Notes:

1) Facilities identified in subparagraph (x) of the definition (I.e., construction sites > 5 acres) are not covered by this general permit.

2) The 40 CFR Subchapter N categories are listed below. Facilities subject to storm water effluent limltatlonguldalines, new source performance standards or toxic pollutant effluent standards under these categories are subparagraph (i) sources, except those facilities subject to toxic pollutant effluent standards that are exempted in subparagraph (xl) of the definition.

However, Section B.3.b of the permit does not allow sources subject to storm water effluent limitations to be covered by the permit (See Note 3 below).

Part 405 Dairy Products Processing Point Squrce Category Part 406 Grain Mills Point Source Category Part 407 Canned &Preserved Fruits &Vegetables Processing Point Source Category Part 408 Canned &Preserved Seafood Processing Point Source Category Part 409 Sugar Processing Point Source Category Part 410 Textile Mills Point Source Category Part 411 Cement Manufacturing Point Source Category Part 412 Feedlots Point Source Category Part 413 Electroplating Point Source Category Part 414 Organic Chemicals, Plastics, and.Synthetic Fibers Part 415 Inorganic Chemicals Manufacturing Point Source Category Part 417 Soap and Detergent Manufacturing Point Source Category Part 418 Ferdlizer Manufacturing Point Source Category Part 419 Petroleum Refining Point Source Category Part 420 Iron &Steel Manufacturing Point Source Category Part 421 Nonferrous Metals Manufacturing Point Source Category Part 422Phosphate Manufacturing Point Source Category Part 423 Steam Electric Power Generating Point Source Category Part 424 Ferroalloy Manufacturing Point Source Category Part 425 Leather Tanning &Finishing Point Source Category Part 426Glass Manufacturing Point Source Category Part 427 Asbestos Manufacturing Point Source Category Part 428 Rubber Manufacturing Point Source Category Part 429 Timber Products Processing Point Source Category Part 430 Pulp, Paper, &Paperboard Point Source Category Part 431 The Builder's Paper &Board Mills Point Source Category Part 432 Meat Products Point Source Category Part 433 Metal Finishing Point Source Category Part 434 Coal Mining Point Source Category Part 435 Oil &Gas Extraction Point Source Category Part 436 Mineral Mining &Processing Point Source Categbry Part 439 Pharmateutical Manufacturing Point Source Category Part 440 Ore Mining &Dressing Point Source Category Part 443 Paving &Roofing Materials Point Source Category Part 446 Paint Formulating Point Source Category Part 447 Ink Formulating Point Source Category Part 454 Gum &Wood Chemicals Manufacturing Point Source Category Part 455 Pesticide Chemicals Point Source Category Part 457 Explosives Manufacturing Point Source Category Part 458 Carbon Black Manufacturing Point Source Category Part-459 Photographic Point Source Category Part 460 Hospital Point Source Category Part 461 Battery Manufacturing Point Source Category Part 463 Plastics Molding &Forming Point Source Category Part 464 Metal Molding &Casting Point Source Category Part 465 Coil Coating Point Source Category

Industrial Storm Water General Permit NPDES Permit Number NER00000O Effective Date September 18, 1997 Page 34 of 42 Appendix B (continued)

2) The 40 CFR Subchapter N categories are listed below.... (continued)

Part 486 Porcelain Enameling Point Source Category Part 467 Aluminum Forming Point Source Category Part 468 Copper Forming Point Source Category Part 469 Electrical & Electronic Components Point Source Category Part 471 Nonferrous Metals Forming & Metal Powders Point Source Category

3) The 40 CFR Subchapter N categories that contain storm water effluent limitations are listed below. Discharges subject to storm water effluent limitations are not eligible to discharge under the terms and conditions of this permit as set forth In Section B.3.b. of the permit.

Part 411 Cement Manufacturing Point Source Category Part 412 Feedlots Point Source Category Part 418 Fertilizer Manufacturing Point Source Category Part 419 Petroleum Refining Point Source Category

.Part 422Phosphate Manufacturing Point Source Category Part 423 Steam Electric Power Generating Point Source Category Part 434 Coal Mining Point Source Category Part 436 Mineral Mining &Processing Point Source Category Part 440 Ore Mining & Dressing Point Source Category Part 443 Paving & Roofing Materials Point Source Category

4) The following summary information on Standard Industrial Codes (SIC) may prove useful to potential applicants in assessing the applicability of this permit to'their facility(s).

Subparagraph (i0)sources. All ofthese SIC designations refer to manufacturing facilities. )

SIC 24 Lumber &Wood Products except 2434 Wood Kitchen Cabinets SIC 26 Paper & Allied Products except 265 Paperboard Containers & Boxes except 267 Converted Paper &Paperboard Products, except Containers & Boxes SIC 28 Chemicals &Allied Products except 283 Drugs SIC 29 Petroleum Refining & Related industries SIC 311 Leather Tanning and Finishing SIC 32 Stone, Clay, Glass, & Concrete Products except 323 Glass Products, Made of Purchased Glass SIC 33 Primary Metal Industries SIC 3441 Manufacturing Metal Cans SIC 373 Ship & Boat Building and Repairing Subparagraph (viii) sources, The "40" series SIC designations refer to facilities involved with transportation, communication, electric, gas, and sanitary services. SIC 5171 refers to wholesale trade facilities.

SIC 40 Railroad Transportation SIC 41 Local & Suburban Transit & Interurban Highway Passenger Transportation SIC 42 Motor Freight Transportation and Warehousing except 4221 Farm Product Warehousing & Storage except 4222 Refrigerated Warehousing & Storage except 4225 General Warehousing and Storage SIC 43 United States Postal Service SIC 44 Water Transportation SIC 45 Transportation by Air SIC 5171 Petroleum Bulk Stations &Terminals (Wholesale Trade)

Industrial Storm Water General Permit NPDES Permit Number NER000000 Effective Date September 18, 1997 Page 35 of 42 Appendix B (continued)

Subparagraph (xl) sources which are not otherwise covered in Sections (ii)- (x), The "20" and "30" series SIC designations refer to manufacturing facilities. The "42" series SIC designations refer to facilities involved in motor freight transportation and warehousing.

SIC 20 Food &Kindred Products SIC 21 Tobacco Products SIC 22 Textile Mills Products SIC 23 Apparel & Other Finished Products Made From Fabrics & Similar Products SIC 2434 Wood Kitchen Cabinets SIC 25 Furniture & Fixtures SIC 265 Paperboard Containers & Boxes SIC 287 Converted Paper &Paperboard Products, except Containers &Boxes SIC 27 Printing, Publishing, &Allied Industries SIC 283 Drugs SIC 285 Paints, Varnishes, Lacquers, Enamels, and Allied Products SIC 30 Rubber & Miscellaneous Plastics Products SIC 31 Leather & Leather Products except SIC 311 LeatherTanning and Finishing SIC .323 Glass Products, Made of Purchased Glass SIC 34 Fabricated Metal Products, except Machinery &Transportation Equipment except SIC 3441 Manufacturing Metal Cans SIC 35 Industrial & Commercial Machinery & Computer Equipment SIC 36 Electronic & Other Electrical Equipment &Components except Computer Equipment SIC 37 Transportation Equipment excapt-SIC 373 Ship & Boat Building & Repairing

- SIC 38 Measuring, Analyzing, &Controlling Instruments; Photographic, Medical & Optical Goods; Watches'& Clocks SIC 39 Miscellaneous Manufacturing Industries SIC 4221 Farm Product Warehousing & Storage SIC 4222 Refrigerated Warehousing & Storage SIC 4.225 General Warehousing and Storage

Industrial Storm Water General Permit NPDES Permit Number NEROOO000 Effective Date September 18, 1997 Page 36 of 42 APPENDIX C - State Resource Waters and Public Drinking Water Supply Stream Segments This appendix identifies stream segments and water bodies for which a written authorization is required to allow the discharge of storm water under the terms and conditions of NPDES General Permit NERO00000 (See Section C04 and C.7 of the permit). This appendix references these stream segments by County to facilitate the completion of the Notice of Intent and Relocation Notice forms. Infilling out these forms, tlhe applicant need only identify the stream segment or water body by name; the other information supplied is not needed on the forms.

Boyd County Missouri River from the South Dakota border to the Knox County line; Class A State Resource Water; (Stream segment: NI1,10000)

Niobrara River from the Keys Paha County line to the Knox County line; Class A State Resource Water;, (Stream segments: N12-1 0000 & N13-10000)

Brown County Calamus Rivei from it's headwaters to the Rock County line; Class B State Resource Water; (Stream segments: L02-11300, L02-11400, L02-11500 & L02-11600)

Niobrara River from the Cherry County line to the Rock County line; Class A State Resource Water; (Stream segments: N3-1 0000 & N13-20000)

Lona Pine Creek from it's headwaters to the confluence of Bone Creek; Class B State Resource Water; (Stream segments: N13-12300 and N13-12400) )

Cedar County Missouri River from the Knox County line to the Dixon County line; Class A State Resource Water; Public Drinking Water; Threatened species: Lake & Pallid Sturgeon; (Stream segment: MT2-10000)

Cherry County Niobrara River from the confluence of the Snake River to the Keya Paha/Brown County lines; Class A State Resource Water; (Stream segments: N13-20000)

Dakota County Missouri River from the Dixon County line to the confluence of the Big Sioux River;, Class A State Resource Water; Public Drinking Water; Threatened species: Lake & Pallid Sturgeon; (Stream segment: MT2-1 0000)

Dawes County Chadron Creek from it's headwaters. to it's confluence with the White River; Public Drinking Water Standards; (Stream Segment: WHI-11300)

Cunninnham Creek from it's headwaters to it's confluence with Indian Creek; Class A State Resource Water, (Stream segment: WHI-11710)

Dead Man's Creek from it's headwaters to the Sioux County line; Public Drinking .Water Standards; (Stream Segment*. WH1 -30100)"

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 37 of 42 Appendix C (continued)

Dawes County (continued)

Soldier Creek from the Sioux County line to It's confluence with the White River; Class A State Resource Water, (Stream segment: WH1-20300)

Squaw Creek from It's headwaters to the National Forest Boundary; Class A State Resource Water; (Stream segment WH1-20120).

White River from the Sioux County line to it's confluence with Soldier Creek; Class B State Resource Water; Public Drinking Water;, (Stream segment: WHI-30000)

White RIver from Soldier Creek to the South Dakota border; Public Drinking Water standards; (Stream segments: WHI-10000 and WHi-20000)

Dixon County Missouri River from the Cedar County line to the Dakota County line; Class A State Resource Water; Threatened species: Lake & Pallid Sturgeon; (Stream segment: MT2-1 0000)

Garfield County Calamus River from the Loup County line to the confluence with North Loup River; Class B State Resource Water; (Stream segment: L02-11300)

Holt County Elkhom River from the confluence of the North and South Forks to Holt Creek; Class B State Resource Water;, (Stream segment: EL4-40000)

Niobrara River from the Rock County line to the Knox County line; Class A State Resource Water; (Stream segment: N12-1 0000)

Keith County North Platte River from Kingsley Dam to the confluence of Whitetail Creek; Class B State Resource Water; (Stream segment: NPi-40000)

Otter Creek from it's headwaters to Lake C.W. McConaughy; Class B State Resource Water; (Stream segment: NP2-10300)

Keya Paha County Niobrara River from the Cherry County line to the Boyd County line; Class A State Resource Water; (Stream segments: N13-10000 & N13-20000)

Knox County Missouri River from the confluence of the Niobrara River to the Cedar County line; Class A State Resource Water; Public Drinking Water; Threatened species: Lake &Pallid Sturgeon; (Stream segment: MT2-1 0000)

Missouri River from the Boyd County line to the confluence of the Niobrara River; Class A State Resource Water; (Stream segment: Nil-1-0000)

Industrial Storm Water General Permit NPDES Permit Number NER000000 Effective Date September 18, 1997 Page 38 of 42 Appendix C (continued)

Knox County (continued) hNlobrara River from the Boyd/Holt County line to its confluence with the Missouri River; Class A State Resource Water, (Stream segment: N12-.10000)

Verdlare Creek from the confluence of the North Branch Verdigre Creek to it's confluence with the Niobrara River; Class A State Resource Water; (Stream segment: N13-10100)

Loup County Calamus River from the Rock County line to the Garfield County line; Class B State Resource Water; (Stream Segment: L02-11300)

Richardson County Unnamed creek which discharges to the Missouri River in Section 5, Range 3 North, Township 17 East and flows through Indian Cave State Park (Only the upper reaches of this creek extend beyond the boundaries of Indian Cave State Park,), Class A State Resource Water; (Stream segment: NE1-10700).

Rock County Calamus River from the Brown County line to the Loup County line; Class B State Resource Water; (Stream Segment: 12-021300)

Long Pine Creek segments near the Brown County line; Class B State Resource Water; (Stream segments:

N13-12300 and N13-12400)

Niobrara River from the Brown County line to the Holt County line; Class A State Resource Water; (Stream segments: N13-10000)

Sioux County Dead Man's Creek from the Dawes County line to it's confluence with the White River; Public Drinking Water Standards; (Stream Segment: WH1-30100)

Middle Fork Soldier Creek from It's headwaters to it's confluence with Soldier Creek; Class A State Resource Water, (Stream segment: WH1-20310)

Soldier Creek from it's headwaters to the Dawes County line; Class A State Resource Water; (Stream segments: WH1-20300 & WHI-20400)

White River from it's headwaters to the Dawes County line; Class B State Resource Water; Public Drinking Water standard; (Stream segments: WH1-30000 &WHI-40000)

Industrial Storm Water General Permit I 'NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 39 of 42 APPENDiX D - Information and Signatures Required in NuIs As a minimum, Notices of Intent (NOls) shall contain the following information to be considered complete. NPDES Form ISW-NOI, which is an attachment to this permit, meets these requirements.

A. The facility name and location shall be provided, The physical location shall be expressed both in descriptive-terms (ie., street address, or if not available, in relationship to .repognizable landmarks),

and in a legal description designated in terms of section, township, range and county. The legal description shall be provided to the nearest .1116th of a section, where possible (e,g,, NW1/44, SW1/4, S10, T15N, R 11E, Douglas County). Portable facilities are exempt from -this.requirement unless they are already located in Nebraska at the time the ISWoNOl form is submitted.

B. Portable facilities need to be identified as such on the NOI.

C. The facility shall be identified as a new or existing source, If a new source, the date -of anticipated facility start-up shall be provided. If an existing source, any previous or existing NPDES permits shall be identified, and the date of start-up shall be provided or approximated.

D. The identification, mailing addresses, and signatory authorizations for the facility "owner or operator", the "cognizant official", and the "authorized representative" shall be provided. The qualifications and responsibilities for "owner/operators," "cognizant officials", and "authorized representatives" are set forth below.

1. The term "owner or operator" is defined in NDEQ Title 119 Chapter 1 044 as follows:

"Owner or operator" means the owner or operator of any facility or activity subject'to regulation under this Title.

More than one owner/operator may be responsible for a facility and they may jointly share responsibilities with respect to this permit. Ifthis is the case, each owner/operator must specify a cognizant official which will need to sign the application (See below).

2. The "cognizant official" is responsible for signing all permit applications and meets the requirements set forth in NDEQ Title 119 Chapter 10.001:

"All permit applications submitted to the Department shall be signed:

001.01 In the case of corporation, by a principal executive officer of at least the level of vice-president; 001.02 In the case .of a partnership, by a general partner; 001.03 In the case of a sole partnership, by a general partner; and 001.04 In the case of a municipal, State or other public facility by either a principal executive officer or ranking elected official."

)

Industrial Storm Water General Permit NPDES Permit Number NER000000 Effective Date September 18, 1997 Page 40 of 42 Appendix D (continued)

3. The "authorized representative" is the primary facility contact for correspondence and monitor reporting, and must meet the requirements set forth in NDEQ Title 119 Chapter 10.002:

"All other correspondence, reports and DMR's shall be signed by a person designated in 001.01 through 001.04 above or a duly authorized representative if such representative is responsible for the overall operation of the facility from which the discharge originates; the authorization is made in writing by the person designated under 001,01 through 001.04 above; and the written authorization is submitted to the Director."

Only one authorized representative may be specified for any given facility.

E. The following information. concerning the facility:

1. a brief description of the type of activity resulting in "storm water discharges from industrial activity";

2. the 4-digit Standard Industrial Classification (SIC) codes that best represent the principle activities provided by the facility;

3. identification of the "storm water discharges from industrial activity" definition subcategory which applies to the facility (See Appendix B); and '

4. an indication as to whether the facility will be subject to the reduced SWPPP requirements authorized in permit Section D.6 and a brief explanation as to why.

F. The following information concerning the storm water outfalls shall be provided for all facilities except portable facilities:

1. the number of storm water outfalls present,

2. the identification and location of storm water ouff ails,

2. a brief description of any storm water treatment systems used,

3. thereceiving stream for each outfall, and

4. the identificatidn of any storm water discharges to any large or medium municipal storm water systems (More information is provided in Section C.3.b concerning requirements for these sources.).

G. A declaration that the Storm Water Pollution Prevention Plan (SWPPP) has been completed, or a schedule for the completion of the SWPPP shall be provided. If the schedule does not comply with the deadlines established in Sections D.7.a or D.7.b, the justification required by Section D.7.c must be included in the NOI. If the SWPPP was not complete at the time the NOI was submitted, the permittee is required to notify the department of it's completion as set forth in Section D.6. 8..* )

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 41 of 42 Appendix D (continued)

H; The following certification statement shall be contained in the NOI and the NOI shall be signed by the Cognizant Official.

I certify under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible for gathering the information, the-information submitted is, to the best of my knowledge and belief, true, accurate and -complete, I am aware that there are significant penalties for submitting false information including the po~sibility of fine and imprisonment for knowing violations.

I further certify that:

1. I, or qualified members of my staff, have reviewed and understand the terms and conditions of NPDES General Permit Number NER000000;

2. the facility identified in this NOI meets the "Applicability" requirements set forth in Section B of the-permit; and

3. I understand that the submission of this NOI obligates the facility identified in this NOI to comply with the terms and conditions of the Permit NEROOOOOO, provided authorization to discharge is obtained.

.)

Industrial Storm Water General Permit NPDES Permit Number NEROOOOOO Effective Date September 18, 1997 Page 42 of 42 Appendix E: Water Priority Pollutants This is the list of 65 Toxic Pollutant Groups (which includes 126 specific substances) specified in § 307(a) of the Clean Water Act.

37) Haloethers (not listed elsewhere in this list),

1) Acenophthene including: Chlorophenylphenyl ethers

2) Acrolein Bromophenylphenyl ethers

3) Acrylonitrile bis(dischloroisopropyl) ether

4) Aldrin/Dieldrin bis-(chloroethoxy) methane

5) Antimony and compounds polychlorinated diphenyl ethers

6) Arsenic and compounds 38) Halomethanes (not listed elsewhere in this list),

7) Asbestos including: methylene chloride

8) Benzene methylchloride

9) Benzidine methylbromide

10) Beryllium & compounds bromoform

11) Cadmium & compounds dichlorobromomethane

12) Carbon tetrachloride 39) Heptachlor &metabolites

13) Chlordane (technical mixture and metabolites) 40) Hexachlorobutadiene

14) Chlorinated benzenes (other than dichlorobenzenes) 41) Hexachlorocyclohexane (all isomers)

15) Chlorinated ethanes, including: 42) Hexachlorocyclopentadiene 1,2-dichloroethane 43) Isophorone 1,1.-trichloroethane 44) Lead & compounds hexachloroethane 45) Mercury & compounds

16) Chloroalkyl ethers (chloroethyl, and mixed ethers) 46) Naphthalene

17) Chlorinated naphthalene 47) Nickel & compounds

18) Chlorinated phenols (not listed elsewhere in this list), 48) Nltrobenzene including: tdchlorophenols & chlorinated cresols 49) Nitrophenols, including

19) Chloroform 2,4-dinitrophenol

20) 2-.Chlorophenol dinitrocresol

21) Chromium & compounds 50) Nitrosamines

22) Copper & compounds 51) Pentachlorophenol

23) Cyanides 52) Phenol

24) DOT & metabolites 53) Phthalate esters

25) Dichlorobenzenes 54) Polychlorinated biphenyls (PCBs) 1,2-dichlombenzene 55) Polynuclear aromatic hydrocarbons, Including:

1,3-dichlorobenzene benzanthracenes 1,4-dichlorobenzene benzopyrenes

26) Dichlorobenzidlne benzofluoranthene

27) Dichloroethylenes chrysenes 1,1-dichloroethylene dibenzanthracenes 1,2-dichloroethylene indenopyrenes

28) 2,4-Dichlorophenol 56) Selenium &compounds

29) Dlchloropropane & dichloropropene 57) Silver & compounds

30) 2,4-Dmethylphenol 58) 2,3,7,8-Tetrachlorodibenzo-p-dloxin (TCDD)

31) Dinitrotoluene 59) Tetrachloraethylene

32) Diphenylhydrazine 60) Thallium &compounds

33) Endosulfan &metabolites 61) Toluene

34) Endrin & metabolites 62) Toxaphene

35) Ethylbenzene 63) Tdchloroethylene

36) FRuoranthene 64) Vinyl chloride

65) Zinc & compounds

.~t )

Enclosure 1.4 to Attachment 1 Air Construction Permit (Low Emitter Status Notice and Open Burn Permits)

STATE OF NEBRASKA "DEPARTMENT OF ENVIRONMENTAL QUALITY Michael J. Under Director Suite 400, The Atrium 1200 'N' Street P.O. Box 98922 Lincoln, Nebraska 68509-8922 CONSTRUCTION PERMIT Phone (402) 471-2186 FAX (402) 471-2909 Mike Johianns Governor PERMIT TO CONSTRUCT AN AIR CONTAMINANT SOURCE IS HEREBY ISSUED TO:

Nebraska Public Power District PO Box 499 il APR 20 W04 IIi 114 15th' Street Columbus, Nebraska 68602-0499 FOR THE SPECIFIC CONSTRUCTION OF:

One Emergency Generator and One Fire Pump TO BE LOCATED AT:

Cooper Nuclear Station 1200 Prospect Road 2 miles South of Brownville Brownville, Nemaha County, Nebraska Pursuant to Chapter 14 of the Nebraska Air Quality Regulations, the public has been notified by prominent advertisement of this construction of an air contaminant source and the thirty (30) day period allowed for comments has elapsed. This Construction Permit approves the construction of one existing 405-kilowatt diesel-fired emergency generator and one existing 535-horsepower emergency fire pump..

Compliance with this permit shall not be a defense to any enforcement action for violation of an ambient air quality standard.

This permit is issued with the following conditions:

General Conditions I. This permit is not transferable to another source or location., (Title 129, Chapter 17)

Ii. Holding of this permit does not relieve the owner/operator of the source from the responsibility to comply with all applicable portions of the Nebraska Air Quality Regulations and any other requirements under local, State, or Federal law. (Title 129, Chapter 41) 1LT. Any applicant who fails to submit any relevant facts or who has submitted incorrect information in a permit application shall, upon becoming aware of such failure or incorrect submittal, promptly submit such supplementary facts or corrected information. If the source wishes to make changes at the facility that will result in change(s) to values, specifications, and/or locations of emission points that were indicated in the permit application (or other supplemental NPPD Cooper Nuclear Station-36750c01.doc .. .

Construction Permit-Page I An Equal OpportunitgAffirrnatlueAction Employer 4D Punted with soyInk on recycled paper 6

information provided by the applicant and reviewed by the Department in issuance of this permit), the source must receive approval from the Department before the change(s) can be made. In addition, any modification which may result in an adverse change to the air quality impacts predicted by atmospheric dispersion modeling (such as changes in stack parameters or increases in emission rates, potential emissions, or actual emissions) shall have prior approval from the Department. The source shall provide all necessary information to verify that there are no substantive changes affecting the basis upon which this permit was issued. Information may include, but not be limited to, additional engineering, modeling and ambient air quality studies.

(Title 129, Chapter 17, Section 006, 007. &0g.o IV. Approval to construct, reconstruct and/or modify the source will become invalid if a continuous program of construction is not commenced within 18 months after the date of issuance of the construction permit, if construction is discontinued for a period of 18 months or more, or if construction is not completed within a reasonable period of time. (Title 129, Chapter 17, Section W2 V. The owner/operator of the source shall provide a notification to the Department of the anticipated date of initial startup, postmarked not more than 60 days nor less than 30 days prior to such date, and of the actual date of initial startup, postmarked within 15 days after such date, of each independently operable emission unit, process, or group of equipment or emission units. (Title 129, Chapter 17, Section 012 & Chapter 18, Section 001.01)

VI. The permittee shall allow the Department, EPA or an authorized representative, upon presentation of credentials to (Title 129, Chapter 8, Section 012.02):

(A) Enter upon the permittee's premises at reasonable times where a source subject to this permit is located, emissions-related activity is conducted or records are kept, for the purpose of ensuring compliance with the permit or applicable requirements; (B) Have access to and copy, at reasonable times, any records, for the purpose of ensuring compliance with the permit or applicable requirements; (C) Inspect at reasonable times any facilities, pollution control equipment, including monitoring and air pollution control equipment, practices, or operations, for the purpose of ensuring compliance with the permit or applicable requirements; (D) Sample or monitor at reasonable times substances or parameters for the purpose of ensuring compliance with the permit or applicable requirements.

VII. Applicable regulations:. Title 129 - Nebraska Air Quality Regulations as amended February 7, 2004.

VIII. This permit may contain abbreviations and symbols of units of measure which are defined in 40 CFR Part 60.3. Other abbreviations may include, but are not limited to, the following: Code of Federal Regulations (CFR), Carbon Monoxide (CO), Nitrogen Oxides (NOx), Particulate Matter (PM), Particulate Matter less than or equal to 10 micrometers (PM1 0), Prevention of Significant Deterioration (PSD), Sulfur Dioxide (SO 2), Volatile Organic Compounds (VOC).

IX. Open fires are prohibited except as allowed by Title 129, Chapter 30.

NPPD Coope~r Nuclear Station-36750c0l.doc Construction Permit-Pago 2

X. The source shall not cause or permit fugitive particulate matter to become airborne in such quantities and concentrations that it remains visible in the ambient air beyond the property line.

(Title 129,'Chapter 32)

XI. Application for review of plans or advice furnished by the Director will not relieve the source of legal compliance with any provision of these regulations, or prevent the Director from enforcing or implementing any provision of these regulations. (Title 129, Chapter 37)

XII. If and when the Director declares an air pollution episode as defined in Title 129, Chapter 38, Sections 003.01B, 003.01C, or 003.01D, the source shall immediately take all required actions listed in Title 129, App. I until the Director declares the air pollution episode terminated.

Specific Conditions XIII. Specific terms and conditions of this permit:

(A) Fuel that may be.combusted in the emergency generator and fire pump shall be limited to distillate fuel oil with a sulfur content of 0.5 percent by weight or less. (Title 129, Chapters 19 and 24)

(B) Fuel combustion in the emergency generator shall be limited to 257,500 gallons combined per any period of twelve (12) consecutive calendar months. At no time during the first II calendar months after the date of permit issuance shall total fuel usage during these months exceed 257,500 gallons in the emergency generator. (Title 129, Chapter 19)

(C) Fuel combustion in the fire pump shall be limited to 177,150 gallons per any period of twelve (12) consecutive calendar months. At no time during the first 11 calendar months after the date of permit issuance shall total fuel usage during these months exceed 177,150 gallons in the fire pump. (Title 129, Chapter 19)

(D) Opacity shall be less than 20 percent, as determined by an EPA approved method, in accordance with Title 129, Chapter 20, Section 005.

(E) Records shall be maintained on-site for a minimum period of five (5) years. These records shall be clear and readily accessible to Department representatives and shall include the following:

(1) Records of fuel certifications for distillate fuel oil sulfur content to show compliance with Condition XII.(A).

(2) Records of the monthly fuel usage in the emergency generator and fire pump for each month and the previous period of twelve (12) consecutive calendar months to show compliance with Conditions XIII.(B) and XIII.(C). These records shall be updated by the 15h day of each month to include data from the previous month.

Pursuant to a Delegation Memorandum dated May 3, 2000, and signed by the Director, the undersigned hereby executes this document on behalf of the Direct _

Date [ Sh lley *aderly irAdministrat0i- '

Quality Divion NPPD Cooper Nulear Station-36750c01.doG Construction Permit-Page 3

N Nebraska Public Power District

'Almuls rhere when yotc need aes" March 27, 2009 W. Clark Smith, Permitting Section Supervisor Air Quality Division Nebraska Department of Environmental Quality PO Box 98922 Lincoln, Nebraska 68509-8922 Re: Low Emitter Status for NPPD's Cooper Nuclear Station, NDEQ Facility [D# 36750

Dear Mr. Smith:

Nebraska Public Power District (NPPD) is submitting the enclosed Low Emitter Worksheet for its Cooper Nuclear Station (CNS) located in Brownville, Nebraska. The potential to emit from the emission units at CNS is above the Class I permit threshold per Title 129, Chapter 5; however, the actual emissions from the emission units at CNS are below the levels specified in Title 129, Chapter 5, Section 00l.02A. Therefore, as per Title 129, Chapter 5, Section 001.03B, CNS is exempt from the duty to obtain an operating permit under the Low Emitter Rule because it meets all the criteria specified in Title 129, Chapter 5, Sections 001.03B1 through 001.03B5, each of which are addressed individually below:

" Section 001.03B 1: NPPD-CNS is not otherwise required to obtain an operating permit.

" Section 001.03B2: Actual emissions records are being submitted for the last five years demonstrating that each regulated pollutant does not exceed the levels specified in Title 129, Chapter 5, Section 001.02A.

Section 001.03B3: No credit is being claimed for controls because the emission units at CNS do not have any controls.

" Section 001.03B4: NPPD-CNS will provide the pertinent information when requested by Department of Environmental Quality (Department).

Section 001.03B5: NPPD understands that obtaining the Low Emitter status does not shield the owner or operator from the duty to comply with any other applicable requirement under Title 129, nor shield the owner or operator from enforcement action for the violation of any other applicable requirement under Title 129.

By submitting this request to obtain the Low Emitter status, NPPD has fMlfilled the obligations of the air quality operating permit program of Title 129 and is also not required to submit an operating permit application. It is NPPD's understanding that after the Department approves the Low Emitter status for CNS, NPPD is not required to submit annual certificates of compliance and semi-annual deviations reports. In addition, NPPD is not required to submit annual air emissions inventory reports, unless requested by the Department.

GENERAL OFFICE 1414 15th Street / P.O. Box 499 1Columbus, NE 68602-0499 Telephone: (402) 564-8561 1 Fax: (402) 563-5551 http://www.nppd.com

Once the Low Emitter status is approved, NPPD proposes to use the following methodology for demonstrating compliance with the Low Emitter status. The attached table shows that the emission units present at CNS that are being considered in the Low Emitter status include three stationary emergency generators, one stationary diesel fire pump, ten (10) kerosene-fired portable space heaters and other ancillary equipment such as multiple petroleum fuel storage tanks and parts washers. ft must be noted that there are less than 10, kerosene-fired portable generators at CNS, however, NPPD is using 10 space heaters to represent a worst-case that also allows NPPD to add more space heaters until the total number of space heaters reaches 10. Mobile generators are not included in this evaluation as per instructions received from the Department because the mobile generators are not regulated under the stationary sources regulations. The regulated pollutant emitted in greatest quantity at CNS is oxides of nitrogen (NOx). Therefore, NOx becomes the limiting pollutant and NPPD needs to only track and verify that annual emissions of NOx stay below the relevant threshold. If NOx emissions are below the threshold, then the other regulated pollutants will automatically be less than the threshold due to the nature of equipment at CNS as discussed further below.

NPPD has performed an analysis and is proposing an approach for compliance demonstration that will not require NPPD to track throughputs and emissions from the portable space heaters, petroleum fuel storage tanks and the parts washers. The same approach has been used in preparing the Low Emitter Worksheet. Since NOx is the pollutant of concern from the combustions sources at CNS, NPPD has calculated the potential to emit (PTE) NOx from 10 kerosene-fired portable space heaters as if those heaters were operated 8760 hours0.101 days 2.433 hours 0.0145 weeks 0.00333 months per year. As shown in the attached calculations, PTE NOx from 10 kerosene-fired portable space heaters is 1.07 tons per year (tpy), which represents the worst case emissions from these units. Subtracting 1.07 tpy from the 50 tpy actual emissions threshold gives 48.93 tpy. Therefore, if NPPD can assure that the annual actual emissions from the emergency generators and the diesel fire pump will stay below 48.93 tons, it will stay below the emissions threshold required for maintaining the Low Emitter status for CNS and is not required to monitor the actual fuel usage in the 10 kerosene-fired portable space heaters.

The PTE for volatile organic compounds (VOCs) from the equipment at CNS is less than 100 tpy and actual emissions for VOCs are less than 50 tpy. Therefore, NPPD is not required to track the throughputs of petroleum fuels and the solvents used in the parts washers because the VOCs emissions from them are minimal. This is similar to qualifying for a no-permit-required status for those pollutants and therefore, it is reasonable to not track those throughputs and VOC emissions.

This approach was discussed with you by Piyush Srivastav of Nebraska Air Quality Specialties.

In summary, NPPD-CNS is applying to be covered under the Low Emitter program for operating permit regulations because the actual emissions of the relevant pollutants has been and will be less than 50 tpy. NPPD will not be tracking the throughput of petroleum fuels in the various tanks located at CNS, fuel usage in the kerosene-fired portable space heaters and the materials used in parts washers due to insignificant emissions associated with them. In addition, NPPD will restrict the actual NOx emissions from the stationary diesel generators and the stationary diesel fire pump to less than 48.93 tpy, which will assure that the facility-wide actual emissions of all relevant pollutants do not exceed the 50 tpy Low Emitter threshold.

Thank you for your review of this submittal. If there are any questions, please call Hope Hasenkamp-Gibbs at (402) 563-5864 or me at (402) 563-5355.

Sincerely, oseph L. Cit , Jr.

Corporate Environmental Manager Enclosures cc: S. B. Minahan w/ enc.

Bc: J. C. McClure w/o enc.

B. J. O'Grady w/ enc.

D, L. Willis w/ enc.

M. T. Boyce w/ enc.

D, E. Buman w/ enc.

R. L. Beilke w/ enc.

K. M. Krumland w/ enc.

C. 0 Stipp w/ enc.

H. C. I-Tasenkamp-Gibbs w/ enc.

ENV - 541.0310 w/enc.

CERTIFIED MAIL RETURN RECEIPT NUMBER 7007 0220 0001 6123 2504

Low Emitter Worksheet - General Nebraska Department of Environmental Quality, Air Quality Section P.O. Box 98922, Lincoln, NE 68509-8922 Ph: (402) 471-2189 FACILITY INFORMATION Name of Facility Cooper Nuclear Station, Nebraska Public Power District Facility ID # 36750 Address 1414 15th Street, Columbus. Nebraska 68601 Phone (402) 563-5864 Name of Person to Whom Questions may be Addressed Hope C. Hasenkamp-Gibbs EMISSIONS INFORMATION For each of the pollutants listed in the table below, record the amount and year from which the greatest emissions resulted during the last 5 years. You will need past emission inventories or other emission records, if available.

Example For, exampole, consider the following fiv year emissions history for a facility:

Year CO NO,, Lead PM 10 SO,. VOC Single HAP Other HAPs 1993 23 13 0.3 42 25 9 0.4 5 1994 26 12 0.4 38 23 12 0.6 4.4 1995 45 8 0.2 36 21 10 0.6 4.6 1996 18 16 0.6 32 18 13 0.3 6.1 1997 21 12 1 35 16 12 0.7 4.8 The table on this worksheet would be filled subsequently with:

Greatest Other CO NOx, Lead PM1o SO. VOC Single HAP HAPs Emissions 45 16 1.0 42 25 13 0.7 6.1 (tpy)

YEAR 1995 1996 1997 1993 1993 1996 1997 1996 Actual Emissions From This Facility Fill out this table in a similar manner to the example, using your facility's data.

Greatest Other CO NO, Lead PM10 SO, VOC Single HAP HAPs Emissions (tpy) 2.41 9.00 0.00 0.16 1.41 0.22 0.01 0.00 YEAR 2006 2006 2006 2006 2006 2006 2006 2006 Certification of Truth, Accuracy, and Completeness Note: This certification must be signed by a responsible official as defined inTitle 129, Chapter 1, Section 093.

I understand, under penalty of law, that, based on information and belief formed after reasonable inquiry, the statements and information contained on this form are true, accurate, and complete.

Signature of Responsible OfficialI Name &Title (printed) Date Stewart Minahan 3/26/09 Vice President & Chief Nuclear Officer Please return to NDEQ at the address listed at the top of the page.

CNS Low Emitter Worksheet Total Fuel Used (gallons) Year CO NOx Lead PM10 sOx VOC SinlHe HAP Other HAPs Total 35791 2004 2.10 7.83 0.00 0.14 1.24 0.20 0.01 0.00 11.52 33016 2005 1.97 7.29 0.00 0.13 1.15 0.18 0.01 0.00 10.73 40771 2006 2.41 9.00 0.00 0.16 1.41 0.22 0.01 0.00 13.21 35468 2007 2.08 7.77 0.00 0.14 1.23 0.20 0.01 0.00 11.43 30635 2008 1.78 6.72 0.00 0.12 1.06 0.16 0.01 0.00 9.85 Highest Emissions 2.41 9.00 0.00 0.16 1.41 0.22 0.01 0.00 Year 2006 2006 2006 2006 2006 2006 2006 2006

2004 fuel use is estimated 2005 2004 EOF Gen Fire Pump DG1 DG2 Total EOF Gen Fire Pump DG1 DG2 Total CO 0.01 0.03 1.03 1.03 2.10 CO 0.03 0.03 0.98 0.93 1.97 NOx 0.01 0.10 3.86 3.86 7.83 NOx 0.02 0.10 3.68 3.49 7.29 Lead 0.00 0.00 0.00 0.00 0.00 Lead 0.00 0.00 0.00 0.00 0.00 PM10 0.00 0.00 0.07 0.07 0.14 PM10 0.00 0.00 0.07 0.06 0.13 SOx 0.00 0.02 0.61 0.61 1.24 SOx 0.00 0.02 0.58 0.55 1.15 VOC 0.00 0.00 0.10 0.10 0.20 VOC 0.00 0.00 0.09 0.09 0.18 Single HAP 0.01 Single HAP 0.01 Other HAP 0.00 Other HAP 0.00 2006 2007 EOF Gen Fire Pump DGI DG2 Total EOF Gen Fire Pump DG1 DG2 Total CO 0.03 0.02 1.18 1.18 2.41 CO 0.02 0.02 1.02 1.02 2.08 NOx 0.02 0.08 4.45 4.45 9.00 NOx 0.02 0.07 3.84 3.84 7.77 Lead 0.00 0.00 0.00 0.00 0.00 Lead 0.00 0.00 0.00 0.00 0.00 PM10 0.00 0.00 0.08 0.08 0.16 PM10 0.00 0.00 0.07 0,07 0.14 SOx 0.00 0.01 0.70 0.70 1.41 sOx 0.00 0.01 0.61 0.61 1.23 VOC 0.00 0.00 0.11 0.11 0.22 VOC 0.00 0.00 0.10 0.10 0.20 0.01 Single HAP 0.01 Single HAP Other HAP 0.00 Other HAP 0.00 2008 EOF Gen Fire Pump DG1 DG2 Total CO 0.01 0.03 0.87 0.87 1.78 NOx 0.01 0.13 3.29 3.29 6.72 Lead 0.00 0.00 0.00 0.00 0.00 PM10 0.00 0.00 0.06 0.06 0.12 SOx 0.00 0.02 0.52 0.52 1.06 VOC 0.00 0.00 0.08 0.08 0.16 Single HAP 0.01 Other HAP 0.00

LIST OF EMISSION UNITS CONSIDERED FOR LOW EMITTER STATUS - NPPD COOPER NUCLEAR STATION e -:T4

...

COMBUSTION SOURCES Diesel Generator (DG-1) Diesel generator building Diesel Generator (DG-2) Diesel generator building Diesel Generator (BOF) East of NRC Building Diesel Fire Pump Fire pump building 10 Portable Nipko heaters Multiple locations PETROLEUM FUEL STORAGE TANKS 2,500 gallon diesel AST Diesel generator building 2,500 gallon diesel AST Diesel generator building 33,572 gallon diesel UST South of machine shop appendage building 33,572 gallon diesel UST South of machine shop appendae building 8,000 gallon mobile diesel AST Low Level Radiological Waste Pad 550 gallon diesel AST Fire pump house 275 gallon kerosene AST Inside 75K gallon AST secondary containment dike 300 gallon diesel AST Inside 75K gallon AST secondary containment dike 300 gallon diesel AST Inside 75K gallon AST secondary containment dike 300 gallon gas AST Inside 75K gallon AST secondary containment dike 55 gallon diesel AST Inside 75K gallon AST secondary containment dike 75,000 gallon AST West of offgas filter building 1,000 gallon mobile diesel AST MTF Stored at Maintenance Training Facility 300 gallon gas AST MTF 300 gallon diesel AST MTF 300 gallon gas AST By the Sewage lagoon 300 gallon diesel AST CNS Fire Pad 1000 gallon Propane Tank CNS Fire Pad MISCELLANEOUS 6 Parts washers Various Shops

Kerosene-Fired Portable Space Heaters (Table 1)

NPPD-CNS Heat Input Capacity Kerosene Throughput MMBtu/hr gal/hr Hours of Operation 5,760 1.7 J(10 Units Combined) 12.2 (based upon 135,000 btu/gal)

Kerosene is a distillate oil fuel, so distillate oil fuel emission factors are used.

Crttefia pollutant emission factors are from AP-42, Chapter 1.3, Tables 1.3-1, 1.3-2, and 1.3-3 (09M98)

PM includes both filterable and condensable PM.

S02 emissions calculated using the sulfur content HAP emission factors are from AP-42 Table 3.3-2 (10/96) since there are no HAP emission factors in Chapter 1.3

Table 2 POTENTIAL EMISSIONS CALCULATIONS (EOFemergency diesel generator)

Cooper Nuclear Station Emission Emission Emission Emissions Unit No. Engine Model Generator Set Power*, hp Usage, Pollutant Factor Factor Factor lb/hr tons/yr Application hrs/yr Units Source NEW Standby 6785 8,760 PM1o 0.13 g/hphr PowerTech Engines 1.94 8.52 5060 kw I NOx 6.67 g/hphr PowerTech Engines 99.77 437.00 SO 2 0.50 lb/hr mass balance 0.50 2.19 VOC 0.06 g/hphr PowerTech Engines 0.90 3.93 CO 0.34 g/hphr PowerTech Engines 5.13 22.47 EOFDG 6063-HK35 Standby 603.2 8,760 PM10 0.40 g/hphr Detroit Diesel Corp 0.53 2.33 in 405 kw NO, 6.90 g/hphr Detroit Diesel Corp 9.18 40.19 permit so,2 1.80 lb/hr mass balance 1.80 7.88 VOC 0.97 g/hphr Detroit Diesel Corp 1.29 5.65 CO 8.50 g/hphr Detroit Diesel Corp 11.30 49.51 Totals IbAir tons/yr

Required power input (hp) = Generator Rating (kW)/Efficiency/0.746 kW/hp PM,0 2.48 10,85 EOFDG = 105 kW/0.9/0.746 = 156.4 hp NO, 108.95 477.20 TSCDG = 405 kW/0.9/0.746 = 603.2 hp S02 2.30 10.07 Generator ratings obtained from Kohler Power Systems for the generators VOC 2.19 9.58 operating in standby mode at 60 hz. CO 16.43 71.98 Preparedby Nebraska Air Quality Specialties

Table 3 Potential To Emit From Combusting Diesel in diesel fire pump - Cooper Nuclear Station Maximum PTE Emission levels from use of Diesel FuelI'___O Unit # NOx NOx CO CO VOC VOC Sax SOx , PMO, total PMIO, total PM, total PM, total Capacity Maximum Emission Emissions Emission Emissions Emission Emissions Emission Emissions Emission Emissions Emission Emissions (MMBtu/hr) Operating Factor Factor Factor* Factor** Factor Factor Hour__yr (lb/MMBtu) (tons__r_ (lbrMMBtu) (tons/yr) (ib/MMBtu) (tons/yr) lbIMMBtu) (tons/yr) (lbiMMBtu) (tons/yr) QlbiMMBtu) (tons/yr)

FP-D-D 5.64 8760 3.2 79.1 0.85 21.0 0.0819 2.0 0.505 12.5 0.0573 1.4 0.1 2.5 Totals 1 5.64 1 79 21 22... 12 1 2 NOxlb/hr= 18.05 COIb/hr= 5 VOCIbihr=0 SOx lb/hr= 3 PM10lb/hr=0 PMlbIhr= 1

Emission factor for nonmethane TOC used for VOC

- For diesel with a sulfur content of 0.5% by weight Table 3 use emission factors from Tables 3.4-1 and 3.4-2 in AP-42, Fifth Edition, Supplement 8, 10/96.

Prepare by Nebras.ka Air QulJity Specleftias

Table 4 Potential To Emit From Combusting Diesel In existing grandfathered units - Cooper Nuclear Station Maximum PTE Emission levels from use of Diesel Fuel Unit # NOx CO VOC SOx PM10, total PM, total Capacity Maximum Emission Emissions Emission Emissions Emission Emissions Emission Emissions Emission Emissions Emission Emissions (MMBtu/hr) Operating Factor Factor Factor* Factor - Factor Factor Hourslyr (lb/MMBtu) (tonslyr) (lb/MMBtu) (tonslyr) (lb/MMBtu) (tons/yrL (lb/MMBtu) (tons/yr) (lb/MMBtu) (tons/yr) (Ib/MMBtu) (tons/yr)

DG-D-1 37.68 8760 3.2 528.1 0.85 140.3 0.0819 13.5 0.505 83.3 0.0573 9.5 0.1 16,5

.DG-.D-2 37.68 8760 3.2 528.1 0.85" 140.3 0.0819 13.5 0.505 83.3 0.0573 9.5 0.11 16.5 Totals 1 75.36 1 1056 281 27 167 19 33

Emission factor for nonmethane TOC used for VOC

- For diesel with a sulfur content of 0.5% by weight Table 4 use emission factors from Tables 3.4-1 and 3.4-2 in AP-42, Fifth Edition, Supplement B, 10/96.

Preparedby Nebraska Air Quality Specialties

VOCs EMISSIONS FROM PETROLEUM FUEL STORAGE TANKS (Table 5)

TANK INVENTORY (Capacity in gallons)

Petroleum Tanks - combining all tanks present at CNS 2,500 4-03-011-55 Standing and Breathing Loss 2,500 Storage Capacity VOC Emission Control Control Annual 33,572 (1000gal/yr) Factor Factor Efficiency Emissions 8,000 (lb/1000gal) (lb/yr) 8,000 500 0.02 1 0 10.00 550 275 Petroleum Tanks - combining all tanks present at CNS 300 4-03-011-20 Working and Withdrawl Loss 300 Annual VOC Emission Control Control Annual 300 Throughput Factor Factor Efficiency Emissions 55 (1000gallyr) (lb/1000gal) (lblyr) 7,500 500 0.0002 1 0 0.10 1,000 300 Total Tank Emissions (Iblyr) 10.10 300 Total Tank Emissions (tonslyr) 0.01 300 300 Tank emission factors from AIRS, no equivalent factors found in AP-42 or FIRE. TOTAL 66,052 Highest recorded fuel usage during the last 5 years was 40,771 gallons per year.

Therefore, using an extrmely conservative assumption of 500,000 gallyr storage capacity and 500,000 gal/yr annual throughput yields only 10.10 Ib/yr of VOCs emissions Preparedb' Nebraska Air Quaiy Specialties

Open Burning Permit Date Issued 2 This permit issued to:

Owner's Name: PJ i- Phone#_________

Bum location:- C9)

Person supervising burning: /Phone# ~ £ /

DATE and time of bum: ý 9- 2 9 ;.* - ', from 6*7e0 to ,:'0 6 c_

DA-Fýý TIME TIME DESCRIPTION OF MATERIAL TO BE BURNED: ./z'&,q/L&4 -A,-

Signature of person(s) assuming responsibility in event fire becomes out of control:

Signed:_ _ _--__ Dispatcher Phone# = 7 /-3/'

This permit Is being Issued In accordance with nebraska 1(tattl 81-520.01. AddItional permits may be required from the Department of Invlmnmantal Ouallv Phona f4021471-2186.

Open Burning Permit Date Issued 4 ~

- I This permit issued to:

Owner's Name: " . /U6 Phone #.

Burn location:

Person supervising burning: Phone # e-9 DATE and timeof bum: I-/ - 7b/Z DATE

/- b3 from S TIME toORD to TIME DESCRIPTION OF MATERIAL TO BE BURNED: "7. .

o ,,

- . _ _ #

Signature of person(s) assuming responsibility in event fire become

Ut *c 1:

Signed: Dispatcher'Phone# 7!ý- 1/39 This permit Is being Issued In accordance with Nebraska Statute 81 (See Back) Air quality regulations may necessitate an additional permit from the Duiartment of Envlromental Control. Phone (402) 471-2186.

.5 to Attachment 1 RCRA Notification

Keith R, Karel EnvironmentalSpecialist- Waste PH: 402-563-5332 December 1"9, 2006 Ms. Teri Swarts Nebraska Department of Environmental Quality Suite 400, The Atrium 1200 'N' Street Lincoln, NE 68509-8922 RE: Revised Notification of Regulated Waste Activity - EPA Form 8700-12

Dear Ms. Swarts:

Enclosed is the revised Notification of Regulated Waste Activity Forms for two (2)

Nebraska Public Power District (NPPD) facilities, This information is provided to notify your department on address corrections for the NPPD York Operations Center and Cooper Nuclear Station.

If you have any questions concerning this, please contact me at 402-563-5332.

Sincerely, Keith R. Karel Environmental Specialist - Waste KRK:csa Enc.

bc: J. L. Citta, Jr. w/o enc.

K. M. Krumland w/o enc.

J. 0. Raymond w/enc.

C. 0. Stipp w/enc.

File ENV-547.1130

RcRA Subitle .C Site Identification Form Read all instructions -before completing the -form.

37

OMB#: 2050-0028 Expires 0613012009 SEND COMPLETED United States Environmental Protection Agency FORM TO:

The Appropriate State or EPA RegionnI Office. RCRA SUBTITLE C SITE IDENTIFICATION FORM

1. Reason for Reason for Submittal:

Submittal (See Instructions To provide Initial Notification of Regulated Waste Activity (to obtain an EPA ID-Numberfor hazardous waste, on page 13.) universal waste, or used oil activities)

MARK ALL BOX(ES) ?* To provide Subsequent Notification of Regulated Waste Activity (to update site identification information)

THAT APPLY I As a component of a First RCRA Hazardous Waste Part A Permit Application 7 As a component of a Revised RCRA Hazardous Waste Part A Permit Application (Amendment #___)

- As a component of the Hazardous Waste Report

2. Site EPA ID EPA IDNumber Number (page 14) I NI El Di1 01 51 51101 71w 1110 1 61 21

3. Site Name Name:

(page 14) Nebraska Public Power District Cooper Nuclear Station

4. Site Location Street Address:

Information 72676 648A Avenue (page 14) City, Town, or Village: Brownville State: Nebras] a County Name: Ne-maha Zip Code: 68321 400

5. Site Land Type Site Land Type: 2 Private g County E. District Z Federal - Indian - Municipal T- State D Other (page 14)

6. North American A. B.

Industry I 21 21 iI 11 1 I 31 1 2 1 21 11' 11 11 1 Classification System (NAICS) C. D.

Code(s) for the I- 1 I1 I III Site (page 14)

7. Site Mailing Street or P. 0. Box: 72676 648A AV9fue Address (page 15) City, Town, or Village: Brownville State: Nebraska Country: 1-.A Zip Code: 68321-0098

8. Site Contact First Name: K MI-- Last Name:

Person Keith IKarel (page 15) Phone Number: 402-563-5332 Extension:5332 Email address: krkarel@nppd.com rae npd*o Nebraska Public

9. Operator and A. Name of Site's Operator, NerDaate Became Operator (mmlddlyyyy) 974 Legal Owner Power Distftbt:i Yw '07/01/

of the Site Operator Type: - Private - County - District - Federal Indian -Municipal ixState - Other (pages 15 and 16) Nebraska Public B. Name of Site's Legal Owner: .ebraska ,Public Date Became Owner (mmlddlyyyy):

07/01/1 74 Owner Type: - Private - County " District - Federal " Indian - Municipal f State - Other EPAFom70012(Rvied 7/00) Pge1 f, EPA Form 8700-12 (Revised 0712006) Page I of 3

EPA ID NO: i1q I E I D II Of 51 5 11 01 71 1 if Of 61 21 OMB#: 2050-0028 Expires 0613012009

9. Legal Owner StreetorPO.Box: 1414 15th Street P.0 Box 499 (Continued)

Address City, Town, or Village: Columbus State: NE Country: U"S.A Zip Code: 68602-0499

10. Type of Regulated Waste Activity Mark "Yes" or "No" for all activities; complete any additional boxes as Instructed. (See instructions on pages 17 to 20.)

A, Hazardous Waste Activities Complete all parts for I through 6.

Y-12 N 0 1. Generator of Haiardous Waste Y O N %1 2. Transporter of Hazardous Waste If "Yes", choose only one of the following - a, b, or c.

Y 0 NXI 13. Treater, Storer, or Disposer of ZI a. LQG: Greater than 1,000 kg/mo (2,200 tbs./mo.) Hazardous Waste (at your site) Note: A of non-acute hazardous waste; or hazardous waste permit is required for this activity.

0 b. SQG: 100 to 1,000 kg/mo (220 - 2,200 lbs.lmo.)

of non-acute hazardous waste; or Y O N P 4. Recycler of Hazardous Waste (at your site)

,,c. CESQG: Less than 100 kg/mo (220 lbsJmo.)

of non-acute hazardous waste Y 0 N [] 5. Exempt Bolier and/or Industrial Fu rnace In addition, indicate other generator activities. If "Yes", mark each that applies.

0L a. Small Quantity On-site Burner Y 0- N &_d. United Stales Importer of Hazardous Waste Exemption Q0 b. Smelting, Melting, and Refining Y 0 N 03 e. Mixed Waste (hazardous and radioactive) Generator Y 0 N.I 6. Underground Injection Control Universal Waste Activities C. Used Oil Activities Y 0 N 11. Large Quantity Handler of Universal Waste (accumulate Mark all boxes that apply.

5,000 kg or more) [refer to your State regulations to determine what is regulated], Indicate types of universal Y E N W 1. Used Oil Transporter If "Yes", mark each that applies.

mark all boxes that apply:

O a. Transporter Manage 0] b. Transfer Facility

a. Batteries 0]

Y 03 N 13 2. Used Oil Processor and/or Re-refiner

b. Pesticides 0 If"Yes", mark each that applies.

c. Mercury containing equipment 0] El a. Processor 0] O b. Re-refiner

d. Lamps

e. Other (specify) 0] YD N M 3. Off-Specification Used Oil Burner

f. Other (specify) 0]

Y 0l N IA4, Used Oil Fuel Marketer

g. Other (specify) []

If "Yes", mark each that applies.

0 a. Marketer Who Directs Shipment of Off-Specification Used Oil to Y L N 0 2. Destination Facility for Universal Waste Off-Specification Used Oil Burner Note: A hazardous waste permit may be required for this activity , b. Marketer Who First Claims the Used Oil Meets the Specifications Page 2 of 3 EPA Form 8700-12 EPA 07(2006)

(Revised 07/2006) 8700-12 (Revised Page 2 of 3

I .. I.,

' EPA ID NO: i V i F, I D[ I 0-.'1 5 1 5 11 Vi 7 1 1110 1 6 1 2 1 OMB-#: 2050-0028 Expires 06130/2009 OMB#: 2050-0028 Expires 0613012009

*EPAIDNO:iNl El Dii 0~i 5 5,0:ul7l 111016

11. Description of Hazardous Wastes (See instructions on page 21.)

A. Waste Codes for Federally Regulated Hazardous Wastes. Please list the waste codes of the Federal hazardous wastes handled at your site. List them in the order they are presented in the regulations (e.g., D001, D003, F007, Ul 12). Use an additional page if more spaces are needed.

D._00,1 ..... D003 .... _D008 D_009 B. Waste Codes for State-Regulated (i.e., non-Federal) Hazardous Wastes. Please list the waste codes of the State-regulated hazardous wastes handled at your site. List them in the order they are presented in the regulations. Use an additional page if more spaces are needed for wasle codes.

12. Comments (See instructions on page 21.)

8. Site Contact Person Nebraska Public Power District 14141.15th Street P.O. Box 499 C.Allrntliic Wi? rR~fl9-flLiQQ Columbus MR 68609-nAQQ Attn:' Keith4[R. Karel

5. Site Land Type - Politic-al Subdivision of the State

13. Certification. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

For the RCRA Hazardous Waste Part A Permit Application, all operator(s) and owner(s) must sign (see 40 CFR 270.10 (b) and 270.11). (See instructions on page 21.)

Signature of operator, owner, or an Name and Official Title (type or print) Date Signed authorized representative (mmlddlyyyy)

Joe L. Citta, Jr. , Corporate Environmental::' /. .

EPA Form 8700-12 (Revised 0712006) Page 30of 3

.6 to Attachment 1 Injection Well Permit

- 9 z STATE OF NEBRAS]

IR U OF ENVURONMýENAL QUALTY l 0 Suite 400, The Atrum E, 1200 'N' Street DC 7P.O. Box 98922 Lincoln, Nebraska 68509-8922 Phone (402) 471-186

__ __ _D, P, 69 I u 4-Mike Johanns Gouernor November 17, 2000 RETURN RECEIPT REQUESTED Mr. Guy R. Horn Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499

Dear Mr. Horn:

The Nebraska Department of Environmental Quality (NDEQ) has reviewed your application for a Class V injection well. Enclosed is your authorization to operate the well. This is an authorization to operate and an approval of the construction details of the well. A construction permit may need to be obtained through your local building inspector or Natural Resources District before construction begins or any upgrades or changes are made to the well.

If you have any questions concerning this authorization, please feel free to contact me at (402) 471-4982.

Sincerely, David L. Miesbach UIC Coordinator Ground Water Unit Water Quality Division DLM/rd Clsv/letter/cvr5 Enclosure An Equal OpportunltjVAfjrrniatfe Action Emptloyer PrInted voLhBOy inkon recyclad paper DEC 062

DEPARTMENT OF ENVIRONMENTAL QUALITY AUTHORIZATION FOR CLASS V WELL UNDERGROUND INJECTION Authorization Number NE0208256 In compliance with the Nebraska Environmental Protection Act, Neb. Rev.

Stat. Secs. 81-1501, 81-1502, 81-1504 through 81-1510 and 81-1527 (Reissue, 1994) and the Nebraska Administrative Procedure Act, Neb. Rev. Stat. Secs.84-901 through 84-903,84-905 through 84-919 and the Rules and Regulations and Standards adopted pursuant thereto, Cooper Nuclear Station - NPPD is authorized to conduct Class V underground injection of fluid using 10 - 5D2 storm water drainage wells located in the NE % of the NW / of Section 32, Township 5 North, Range 16 East, Nemaha County, Nebraska.

This activity will be conducted in accordance with all rules and regulations pursuant to Title 122 - Rules and Regulations for Under-round Iniection and Mineral Production Wells.

This authorization shall become effective on November 17, 2000 and shall expire on November 16, 2010.

Pursuant to a Delegation Memorandum dated January 12,1999 and signed by the Director, the undersigned hereby executes this document on the behalf of the Director.

____day of 2000 Signed this dayof__"__f 2000 Patrick W. Rice Assistant Director

.7 to Attachment 1 Registered Well Information

Nebraska Department of Natural Resources Data Bank Database Through: Feb 13 2009 Processed: 2/16/2009 10:29:02 AM REGISTERED GROUNDWATER WELLS DATA RETRIEVAL Note:

Information on Public Water Supply Wells is not available through this interface. Contact the Department of Natural Resources (Data Bank) at 402-471-2363 for more information.

For explanation on use, status and other well information, please see Legend and Notes below.

Lggend and Nqte Criteria: TwnID - 5 RngiD - 16 RngDir - E Section - 32 County IN 64 18 Stations met this criteria.

Registration# Use County Name Completion Date Acres Irrig Pump Col Dia Owner's Name Well ID Status NRD Name Filing Date Gallons/Mln Pump Depth and Address Permit Number Well Location Deconmmissioned Date Static Level Well Depth Owner ID Footage Times Replaced Pumping Level Well Log Latitude Longitude G-1490010 Q Nemaha 12/6/2007 - - Nebraska Public Power District 189901 A Nemaha 5/7/2008 --- --- Owner ID: 69649 5N 16B 32 NWNB-- 10of 41 R POBox1740 Q11M LýOsgsQ M" 0 0 ft Columbus, NE 68602 Ve as PD 40r 21'43.02" 095' 38' 22.80" G-149001H Q Nemaha 12/ 12/.2007 - - Nebraska Public Power District 189902 A Nemaha 5/7/2008 - - Owner ID: 69649 5N 16E 32 NWNE-- loft 42 ft POBox 1740 OI& L= M]'ILt 0 10 ft Columbus, NE 68602 View as PDF 400 21'40.86" 0950 38' 27.06" G-1490011 Q Nemaha 11/1912007 - - Nebraska Public Power District 189903 A Nemaha 5/7/2008 ...... Owner ID: 69649 5N 16E 32 NWNE--- 10ft 40ft POBox1740

[ier Info Logs M*Apj 0 10ft Columbus, NE 68602 View as F 400 21'37.62" 0950 38' 21.30" G-149001J Q Nemaha 11/20/2007 - - Nebraska Public Power District 189904 A Nemaha 5/7/2008 ..--- Owner ID: 69649 5N 16E 32 NWNE --- ]Oft 99ft POBox 1740 OOt.Qh ,.fo LMg. Map.2 0 10 ft Columbus, NE 68602 Vjow s PF 40'21'37.50" 095' 38'21.00" G-149001K Q Nemaha 12/13/2007 - - Nebraska Public Power District 189905 A Nemaha 5/7/2008 --- --- Owner ID: 69649 5N 16E 32 NWNE--- 10f 45ft POBox1740 Otfher Info Logs MaMIt 0 10 f Columbus, NE 68602 View as PDF 40 21'42.24" 0950 38'21.30" G-149001B Q Nemaha -- 11/15/2007 - -- Nebraska Public Power District 189896 A Nemaha 5/7/2008 .... Owner ID: 69649 5N 16E 32 NWVNE-- 10ft 40ft POBox1740 ther Info L=gg Mapit 0 0 ft Columbus, NE 68602 r.ew asPDF 40° 21' 49.50" 0950 38' 34,44" G-349001C Q Nemaha 11/15/2007. - - Nebraska Public Power District 189897 A Nernahe 5/7/2008 ..-- Owner ID: 69649 5N 16E 32 NENW --- loft 90ft PO Box 1740 Other Info & MapiJ 0 10of Columbus, NE 68602 e s400 21' 49.00" 0950 38' 34.00"

G-149001D Q Nemaha 12/6/2007 Nebraska Public Power District 189898 A Neinaha 517/2008 Owner ID: 69649 5N 16- 32 NBNW loft 41 ft PO Box 1740 "

OtherLnfo LoMa MV-11 0 lOft Columbus, NE 68602 View as 11D 40021' 46.50" 0950 38' 28.68" G-149001E Q Nemaha 12/6/2007 - - Nebraska Public Power District 189899 A Nemaba 517/2008 ... Owner ID: 69649 5N 16E 32 NENW --- loft 35ft POBox1740 Other Lgo biwlt 0 loft Columbus, NE 68602 View as FD 400 21' 44.16" 0950 38'25.86" G-149001F Q Nemaha 12/20/2007 - - Nebraska Public Power District 189900 A Nemaha 5/7/2008 ..... Owner ID: 69649 5N 16E 32 NENW--- loft 80ft POBox1740 Oherlnf

Logs M11119 0 10 ft Columbus, NE 68602 View as PDF 400 21'44.16" 095° 38'25.86" 1_1 Registration# Use County Name Completion Date Acres Irrig Pump Col Dia Owner's Name Well ID Status NRD Name FilingDate Gallons/Mn Pump Depth and Address Permit Number Well Lomtion Decommissioned Date Static Level Well Depth Owner ID Footage Times Replaced Pumping Level Well Log Latitude Longitude G-100340 C Nemaha 2/16/.2002 - 4 In Nebraska Public Power District 138089 A Nemaha 3/21/2003 150 gpm 63 ft Owner ID: 23329 N34 SN 16E 32 NENW -- 27.5 ft 71 R1 1200 N Street Suite 400 PO Box 499 Other foL .Mg 250S 2233E ManpIt 1 32 ft Columbus, NE 68602 View as 40 21' 47.00" 095* 38' 27.00" G-100339 C Nemaha 2/7/2002 - 4 in Nebraska Public Power District 138090 A Nemaaha 3/21/2003 150 gpm 63 ft Owner ID: 23329 N33 5N 16E 32 NENW -- 29 i 75 ft 1200 N Street Suite.400 PO Box 499 Qt _rf.Qoigg 300S .2137E Mapt I1 3911 Columbus, NE 68602 View as PDF 400 21'47.00" 0950 38' 28.00" G-143738B L Nemaha 9/.25/2006 - - Nebraska Public Power District 182901 X Nemaha 2/13/2007 .... Owner ID: 83918 5N 161 32 NBNW 11/2007 13.5 ft 25 ft 648 A Avenue OenLan 325S 1575E MLtJ 0 -- Brownville, NE 68321 View as PDF G-149001A Q Nenauha 12/6/2007 . - Nebraska Public Power District 189906 A Nemaha 5/712008 ... Owner ID: 69649 5N 16E 32 NENW--- 10ft 41 ft PO Box 1740 Other Infoogs M IapJ ' . 0 1 ft Columbus, NE 68602 View as . 40o2144.10, 095' 38' 32.20" G-030088 C Nemiaha 4/12/1968 - 5 in Consumers Public Power District 36936 A Nernaha 8/12/1968 503 gpm --- Owner ID: 5727 5N 16E 32 NENW - 13 ft 62 ft 1452 25th Avenue Other Info Logs 720S 1540W Map LJ. 0 30 1f Columbus, NE 68601 Vimv as 1_DF G-030089 C Nemaha 4/10/1968 - 5 in Consumers Public Power District 36937 A Nemaha 8/12/1968 530 gpm -- Owner D: 5727 5N 16E 32 NENW - 13 f 62 ft 1452 25th Avenue Other Ilno Logs 845S 1620W Map it 0 39 ft Columbus, NE 68601 View as PDF G-040718 I Nemaha 11/23/1973 - 8 In Nebraska Public Power District 47961 A Nenmaha 3/14/1974 750 gpm -- Owner ID: 23329 5N 16E 32 NENW --- 1811 73 R 1200N Street Suite400 PO Box 499 Other In Lg 255S 1834E Manpt 0 35 ft Columbus, NE 68602 View as PDF G-143738A L Nemaha 9/13/2006 - - Nebraska Public Power District 182900 X Nemaha 2/13/2007 --- Owner ID: 83918 5N 16E 32 SWNW 11/2007 12.5ft 25 ft 648AAvenue OtherInfo Logs 1725S 700EMapLi1 0 - Brownville, NE 68321 Itemwa-S _ F I I I I__I

Data copy ofrequested wells asBar(l) delimited file.

Data -copy of Geo Logs for reuesated wells as Barh) delimited file.

Daaopy of Casing Screen for requested wells as Bar(I) delimited file.

Data copy of Grout Grnvel for requested wells as Bar(l) delimited file.

Le*end and Notes

.8 to Attachment 1 Water Withdrawal Right

Surface Water Rights Page I of I State of Nebraska Department of Natural Resources Surface Water Rights Data Claims, Applications, and Appropriations (in Application Number order)

Source Carrier Use Grant Date Doc '

-et Anot- Foo LocatiOn County Div. in of p. aticll Ai Not Apropr-lat or CFS/AF Priority Nun --

r- - --

- ---

MIS90UR-t RIVER Sec:32 T: 5 R:I6E Nexuaha IF NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLeAR STATION Co 1488.41 5/10/1972 D 1071 1 Water Right records were listed processed: 15-Nov-02 Critera = AppNt-m IN (1071)

.*[ °._.J http://nrcnt2.nrc.state.ne.us/cgi-win/watright~exelSwrSearchApnum -11/15/2002 1/520

Enclosure 1.9 to Attachment 1 Public Drinking Water Supply Permit

NEBRAsIA HEALTH AND HUMAN SERVICES SYSTEM STATE OF NEBRASKA DF*'RTMENT OF SERVICES o DEPARTMENT OF REGULATION AND LICENSURE MIK- JOHA\NS, GOVERNOR DEPARTMENT OF FINANCE AND SUPPORT May 3 1, 2000 Nebraska Public Power District Cooper Nuclear Station 1414 15 Street Columbus, NE 68601 Re: Public Water - Nemaha County - NE3150505 - Permit Issuance - Non-Transient, Non-Community Public Water Supply System

Dear Sir/Madam:

This office has received the "Application for a Permit to Operate a Public Water Supply System." After a review of this application, this system has been found to be in substantial compliance with Nebraska's Regulations Governing Public Water SuS&ly, 179 NAC 2. As such, the Nebraska Drinking Water Program is pleased to issue permit number NE3150505 to Nebraska Public Power District - Cooper Nuclear Station.

Under current regulations, this permit is issued for.an indefinite period of time and is subject only to continued compliance with the following regulations:'

I. This Permit To Operate a Public Water Supply System is null and void if the information displayed on it is not completely accurate.

2. This permit is not transferable.

3. If this public water supply system is sold, it is the seller's responsibility to notify the buyer of the requirements to have a permit, a Grade IV Certified Water Operator or higher, and to otherwise be in compliance with Title 179, NAC 2.

4. If the system is sold or has a name change, a new permit with the correct information on it must be obtained.

.Nebraska's Resulations Goveming Public Water Supply, 179 NAC 2 requires all PWSS to implement a preventative maintenance program (see section 008.02). One of the requirements of this program is to take action as necessary to protect the system from encroachments that ire likely hazards to the'system. Please see Nebraska's Regulations Goveming Water Well Construction. Pumo Installation and Water Well Abandonment Standards, Title 178 NAC 12.

179 NAC 2 also requires all PWSS to implement a cross-connection/backflow prevention program (see 008.0E). This means that the PWSS must have an on-going program for the effective detection and elimination of cross-connections and the prevention of backflow or back-siphontge.

The system must also correct any deficiencies noted by the Drinking Water Program personnel during the last inspection. Please contact the Drinking Water Program field representative should the system need assistance in addressing these deficiencies.

Whenever the Drinking Water Program can be of assistance, please contact the Monitoring and Compliance Section at (402) 471-0930 or your Nebraska Drinking Water Program Field Representative. The Field Representative in your area is Russell Topp, Lincoln office, 402-",

471-0519.

Sincerely Jack L. Daniel, Section Administrator Environmental -ealth Protection Section ILD/sm Enclosure c: Russell Topp, -HHS-R&L Sharon McDonald, HHS-R&L DEPARTMENT OF HEALTH AND HUMAN SERVICES REGULATION AND LICENSURE PO Box 95007, LINCOi.N, NE 68509-5007 PHONE (402) 471-2133 AV EQLAL O,qORullv1I/A F/AI:I.LTIITA. CTIO.VEAWfI.OIA.R WITI ISOY INKON RI(YCLF.I) PAPER PRINTEDr Phone 402-471-2713 - Fa.:VRJY1.6 43 6 - 7Ty 402-471-9570

Of II I DepartmentofHeaIth and Hfnan Services Regulation and LDenture L e* **

Nebraska Public Power District e,4 c NY4x NE3150505 a2 III

e a- Cooper Nuclear Station Nemaha County, NE

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Enclosure 1.10 to Attachment 1 South Carolina Waste Transport Permit

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Enclosure 1.11 to Attachment 1 Tennessee Radioactive Waste License

S"ATE or TuN Nusssn DEPARTMaNT OF ENVIRONMENT AND CONSERVATION DivisION OF RADIOLOGICAL .RA-TLI L&C ANNEX - ToIRD FLOOR 401 'CrnRCHIIMREST NASRYmLL,, TNIESSzz 37,43-1532 Dteombrl., 2008 NdraskalIlublic Power Disirict Cooper NIdoar Station P.O. Box 98 Browaville, Ndtaakm 68321 RE: P,,ioaeive Waste Licons-fo-Dedivay Mr. Kuttler Attached lto tstwis yDur Tennessee Radioactive Wastel-ce .for-llivery.number T-N*OO2-L09 issued vwith an txpiratiow dale of Dectmber 31, 2009.

Ifwcmay b offiuthersaitanc plase fed fre t+vntaotnmoat (615) 532-0405.

Health Physicist Divisioj6 of Rad6logcal.Health Attaoinente

STAT* OF TamNersse; DEPARTMENT OF ENVIRONMENT AND CfONSK:RVATION DIVISION Of RADI1OLOGICAL HEALTH L&C A.NNEX - THIRD FLOOR 401] CHURCH S*RE-ET

'NASHVILLE, ,TuNx:ESsEE 37243-1532 LICENSEE Nebraska Public PowerDistfict Delivet yLicease Number: T-,EOO2-L09 Cooper Nuclear Station P.O.'Box 98 Date of Expiration: D2ecembe31.-2009 Brownville, Nebraska 68321 Pursuant to Tennessee-Department of unvirownent -and Conservation Regulations, and in reliance on statements.'and zepresentations.made by -the licensee in application:dated November 12, 2008, with attachments, a .license.is .hereby issued authorizin~g the licensee to ship radioactive material describe below to a licensed disposal/processing facility within Tennessee. 'This license is subject to all applicable 'niles and regulations of the Tennessee Department of.Environment and Conservatibn-and orders ofthe Divisian of Radioktgical Health, now or hereafter in effect.

The license authorizes 'shipment of 'ny radioactive mateiial (except :special nuclear material

sufficient'to form a -critical mass) in any chemical and/or physical form and in.a quantity not to exceed the possession limit of the licensed re'pient.

Th'elicensee-is authorized to ship radioactive material fromthc facility. ocated at:

Cooper NucI=a-station Brownville, Ncbraska 68321 into or within Tennessee to a dispos4alprocessing facility that is licensed byTemnesseeto-reccive such nmaterial.

The licensee :shall 'comply with all applicable provisions; of the regulations and'conditions of the reipient .faclity's lictnse.

Effective date ofthbslicense: jA!yY..1 For theCmumissioner Teunessee Department of Environment and Conservation Date: DRecember 1,2008 Ay.

Health Physicist

Di~sion of Radiologicai Health

Enclosure 1.12 to Attachment 1 Utah Generator Site Access Permit

State of Utah DEPARTMBNT OF ENViRONMENTAL QJAUTY Division of Radiation Control JON M. HUNTSMAN Richard W.,Sprott. DanW.L FimerfocIk Governor &recutive Diredtor Division Director CARY HERBERT LieuwInai Governor December 1,2008 Mr. Joe Kuttler Nebraska Public Power District PO Box 98 Brownville, NE 68321

Dear Mr. Kuttler:

Subject:

Generator Site Access Permit Number 0111000042 The Generator Site Access Permit for Nebraska Public Power District is&complete -and approved.

The expiration date-is -13/2010.

If you have any questions, please.cail IEdith Barker of my staff at: (801) 536-0077.

UTAH RADIATION CONTROL BOARD Lk, Executive Secretary Enclosure cc: AllanErichsen, EnergySolutions Jule Fausto, DEQ Transportation Specialist Bret Rogers, EnergySolutions 168NOM10 Wcst:'PO-Box 144850, Salt Lake City, UT 941.14A&B50 ieI~'hone(801 5364250. faoj~ml; (801.)533-409.7 s~quik F'rittedon 100% rec'ydedpaper

UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF RADIATION CONTROL GENERATOR SITE ACCESS PERMIT ACCESSING A LAND DISPOSAL FACILITY WITHIN UTAH UNDER THE PERMIT REQUIREMENTS IN.R313-26-3 R313-26 of the Utah Radiation Controt Rules establishes the termns for a Generator Site Access Permit Program which authorizes waste generators, waste processors and waste collectors tv deliver radioactive wastes:to a land disposal .facility located within the state.

Name: Nebraeka Puiblic Power Diatrict IPermit Number:.0.1110:00042 Address: PO :Box 9 8 Expiration date: 1/3/1.1 Brownville, NE, 68321 Password: ,dY.VLwVf7 Your.paýsword Is.requrodto =relow yo)ur permit onlina,

,twolbhl.informoaltn In a.socurelocation.

Conditions:

1. The-waste. gencrator,.waste .processorand waste collectorshall comply with thc provisions of R313-26

.and the requirements as.set -forthin R31349-l 0C.

2. The permit nuniber shall accompany.all waste generator, waste processor and wastu o6lectorshipmcnts

-o.the land disposallafdilities withn the state of Utah.

3. .Generator Site Acces permittees shWll be subject to the provisions ofRuleR31344 for violations of federal regulations, state rules or requirements in the current land. disposal facility.Operating liene

.regardingradioactive.Waste .paokaging, trnsportation, labeling, notification.classification, :marking, manifesting ordescription.

UTAH RADIATION CONTROL BOARD irt19*oDa Regigtrgtiou Date ActiviitioaDatc L4Qý' 2 Dane L. Finerfmck,-Executili~secretauy Forsedarity reasons.your peti wi-wll nor be veadveuntil afler-aY2-hour-w, ingperiod.

Pleasenote: There will be.an adjustmentto *le expirationdateforon4fine renewals. Pleaqeallow 30 .days for expiration adjustmen-t notiricalion,

Enclosure 1.13 to Attachment 1 Construction Stormwater Permit - ISFSI

"Ev/il S o3Yo STATE OF NEBRASKA S Dave Heineman DEPARTMENT OF ENviRONMENTAL QUALITY Governor Michael J. Linder Director Suite 400, The Atrium 1200 'N' Street P.O. Box 98922 Lincoln, Nebraska 68509-8922 Phone (402) 471-2186 FAX (402) 471:2909 October17, 2007 website: www.deq.state.ne.us Mr. Patrick Pope Nebraska Public Power District 2060 West Platte River Drive Doniphan, NE 68832 RE: Issuance of storm water discharge authorization for the Cooper Nuclear Station Independent Spent Fuel Storage construction project located North of Cooper Nuclear Station approximately 2 miles south of BrownvilleNE, in Nemaha County, NE (NPDES Authorization Number NER105716)

Dear Mr. Pope:

This is to acknowledge receipt of the CSW-NOI form on October 12, 2007, for the project referenced above.

This project has authorization to discharge storm water under the terms and conditions of NPDES General Permit NER100000.

Please submit a written notice of the start and the completion of the project as required in Permit Section C.7.

The enclosed CSW-START and CSW-END forms may be used for this purpose. The CSW-START form does not need to be submitted if the project is started within 30 days of the September 30, 2007 date as specified in the CSW-NO1 Form.

If you have any questions concerning this NPDES storm water discharge authorization, please contact Mary Schroer at (402) 471-8330..

Enclosures:

CSW-START and CSW-END forms copy w encl: Mr. K. Michael Krumland Nebraska Public Power District 1414 15th Street111 ' UV VfL[lE\lr Columibus, NE 68601 II cc, 0 Cc: C.O~ ll~OCT" 18'- 2007- LI A C4. ,'512, Y7tr An, Equal Opportunlt$Mjlirmative Action Employer Inpdntod .41h -n1.k-l -1.'.l.d nono A,

STATE OF NEBRASKA Wastewater Section Nebraska Department of Environmental Quality 1200 'N' Street, Suite 400, The Atrium PO Box 98922 Lincoln, NE 68509-8922 Tel. 402/471-4220 Fax 402/471-2909 NPDES Form CSW-START - Notice of Start-up of Construction Activity This form may be used to notify the Department that construction activity has been started. at a site having coverage under the NPDES general perm it for storm water discharges from construction sites, NERI 00000. Submittal of this form fulfills the requirements of.Section C.'I.a.of thepermit.

This form is not the Notice of Intent or.NOI form which is used to request discharge authorization. An NOI must be submitted prior to or concurrent with* this form to obtain discharge authorization.

NPDES Authorization Number: NER105716 Permit Number NER100000 Name of Project: Cooper Nuclear Station Independent Spent Fuel Storage Location of Project: North of Cooper Nuclear Station approximately 2 miles south of Brownville,NE, in Nemaha County, NE Date Construction Activities were or will be Commenced:

Signature of Authorized Representative or Cognizant Official ** Date -

Printed Name Title Telephone Number:

- The qualifications and responsibilities of the "cognizant official" are set forth below and inNDEQ Title l19Chapter 10.001:

All permit applications submitted to the Department shall be signed:

001.01 In the case of corporation, by a principal executive officer of at least the level of vice-president; QU-02 In the case of a partnership, by a general partner; 001.03 In-the case of a sole partnership, by a general partner; -and 001.04 In the case of amunicipal, State or other public facility by either a principal executive officer or ranking elected official."

The qualifications and responsibilities for the "authorized representative" are set forth in NDEQ Title 119 Chapter 10002:

"All other correspondence, reports and DMR's shall be signed by a person designated in 001.01 through 001.04 above or a duly authorized representative if such representative is responsible for the overall operation of the facility from which the discharge originates; the authorization is made in writing by the person designated under 001.01 through 001.04 above; and the written authorization is submitted to the Director."

Submit the completed form to:

Mail Address: Location Address:

Wastewater Section Wastewater Section Nebraska Department of Environmental Quality Nebraska Department of Environmental Quality PO Box 98922 1200 'N' Street, The Atrium, Suite 400 Lincoln, NE 68509-8922 Lincoln, NE 68509

STATE OF NEBRASKA Wastewater Section Nebraska Department of Environmental Quality 1200 'N' Street, Suite 400, The Atrium PO Box 98922 Lincoln, NE 68509-8922 Tel. 402/471-4220 Fax 402/471-2909 NPDES Form CSW-END - Notice of Completion of Construction Activity This form may be used to fulfill the requirementsof Section C.7.b of the NPDES general permit for storm water discharges from construction sites, NERI 00000. This notice should be submitted when 95% of a permitted construction site has been stabilized with perennial vegetation or other permanent cover. Coverage under the permit is typically terminated 180 days after 95% of the site is stabilized (See permit Section B.4.a).

NPDES Authorization Number. NER105716 PenmitNumber NERI00000 Name of Project: Cooper Nuclear Station Independent Spent Fuel Storage Location of Project: North of Cooper Nuclear Station approximately 2 miles south of BrownvilleNE, in Nemaha County, NE Date when 95% of the area of the site was stabilized:

Proposed date for ending permit coverage: **

- Must be at least 180 days after the date when 95% of the site was stabilized..

Signature of Authorized Representative or Cognizant Official ** Date Printed Name Title Telephone Number:

- The qualifications and responsibilities of the "cognizant official" are set forth below and in NDEQ Title 119 Chapter 10.001:

All permit applications submitted to the Department shall be signed:

001.01 In the case of corporation, by a principal executive officer of at least the level of vice-president; 001.0f2 In the case of a partnership, by a general partner; 001.03 In the case of a sole partnership, by a general partner; and 001.04 In the case of a municipal, State or other public facility by either a principal executive officeror ranking elected official."

- The qualifications and responsibilities for the 'authorized representative" are set forth in NDEQ Title 119 Chapter 10D02:

"All other correspondence, reports and DMR's shall be signed by a person designated in 001.01 through 001.04 above or a duly authorized representative if such representative is responsible for the overall operation of the facility from which the discharge originates; the authorization is made in writing by the person designated under 001.01 through 001.04 above; and the written authorization is submitted to the Director."

Submit the completed form to:

Mail Address: Location Address:

Wastewater Section Wastewater Section Nebraska Department of Environmental Quality Nebraska Department of Environmental Quality PO Box 98922 1200 'N' Street, The Atrium, Suite 400 Lincoln, NE 68509-8922 Lincoln, NE 68509

Enclosure 1.14 to Attachment 1 404 Permit - Dredge Intake (404 Permit -Ice Deflector)

ENV '-r?'.2.03Ko DEPARTMENT OF THE ARMY ( 0!- /0322 CORPS OF ENGINEERS, OMAHA DISTRICT NEBRASKA REGULATORY 0VFICE-KEARNEY 1430 CENTRAL AVENUE STREET, SUITE 4 KEARNEY, NEBRASKA 68847-6856 REPLY TO ATTENTION OF: April 1, 2002 Mr. David Overhue Nebraska Public Power District P.O. Box 499 Columbus, Nebraska 68602-0499

Dear Mr. Overhue:

Enclosed is a Department of the Army Permit, Number NE 01-10322. This project involves maintenance dredging of the water intake structure at Cooper Nuclear Station.

Please note the special condition(s) on page 4 of the permit. You are requested to notify this office when the work has been started and also when completed.

If you have any questions regarding this permit, please write to the above address or call Keith Tillotson at 308-234-1403 and reference the above permit number.

Sincerely, t- Michael Rabbe Nebraska State Program Manager Enclosure C. 5App

DEPARTMENT OF THE ARMY PERMIT Pennittee: Nebraska Public Power District Permit No: NE 2001-10322 Issuing Office: Omaha District, Corps of Engineers NOTE: The term "you" and its derivatives, as used in this permit, means the permittee or any future transferee. Tile term "this office" refers to the appropriate district or division office of the Corps ofEngineers having jurisdiction over the pernmitted activity or the appropriate official of that office acting under the authority of the commanding officer.

You are authorized to perform work in accordance with the terms and conditions specified below.

Project

Description:

Dredge the water intake structure at Cooper Nuclear Station as needed and discharge the dredged material into the Missouri River, downstream firom the intake structure, An excavator on a barge will be used. This includes after-the-fact approval of the dredging in or around April 1,2001 of approximately 350 cubic yards of accumulated sediment at the entrance of the water intake structure and discharge of the material into the Missouri River.

Project Location:

Right bank of Missouri River, river mile 532.5, North 1/4 of Section 32, Township 5 North, Range 16 East, Nemaha County, Nebraska Permit Conditions:

General Conditions:

1. The time limit for completing the work authorized ends on March 31, 2012. If you find that you need more time to complete the authorized activity, submit your request for a time extension to this office for consideration at least one month before the above date is reached.

2. You must maintain the activity authorized by this pemit in good condition and in conformance with the terms and conditions of this permit. You are not relieved of this requirement if you abandon the pen-nitted activity, although you may make a good faith transfer to a third party in compliance with General Condition 4 below. Should you wish to cease to maintain the authorized activity or should you desire to abandon it without a good faith transfer, you must obtain a modification of this permit f'rom this office, which may require restoration of the area.

3. If you discover any previously unknown historic or archeological remains while accomplishing the activity authorized by this permit, you must immediately notify this office of what you have found. We will initiate the Federal and state coordination required to determine if the remains warrant a recovery effort or if the site is eligible for listing in the National Register ofHistoric Places.

ENG Form 1721, Nov 86 EDITION OF SEP 82 IS OBSOLETE. (33 CFR 320-330)

4. If you sell the property associated with this permit, you must obtain the signature of the new owner in the space provided and forward a copy of the permit to this office to validate the transfer of this authorization.

5. If a conditioned water quality certification has been issued for your project, you must comply with the conditions specified in the certification as special conditions to this permit. For your convenience, a copy of the certification is attached if it contains such conditions.

6. You must allow representatives from this office to inspect the authorized activity at any time deemed necessary to ensure that it is being or has been accomplished in accordance with the terms and conditions of your permit.

Special Conditions:

See page 4.

Further Information:

1. Congressional Authorities: You have been authorized to undertake the activity described above pursuant to:

(X) Section 10 of the River and Harbors Act of 1899 (33 U.S.C. 403).

(X) Section 404 of the Clean Water Act (33 U.S.C. 1344).

Section 103 of the Marine Protection, Research and Sanctuaries Act of 1972 (33 U.S.C. 1413).

2. Limits of this authorization.

a. This permit does not obviate the need to obtain other Federal, state, tribal, or local authorizations required by law.

b. This permit does not grant any property rights or exclusive privileges.

c. This permit does not authorize any injury to the property or rights of others.

d. This permit does not authorize interference with any existing or proposed Federal project.

3. Limits of Federal Liability. In issuing this permit, the Federal Government does not assume any liability for the following:

a. Damages to the permitted project or uses thereof as a result of other permitted or unpermitted activities or from natural causes.

b. Damages to the permitted project or uses thereof as a result of current or future activities undertaken by or on behalf of the United States in the public interest.

c. Damages to persons, property, or to other permitted or unpermitted activities or structures caused by the activity authorized by this permit

d. Design or construction deficiencies associated with the permitted work.

2

e. Damage claims associated with any future modification, suspension, or revocation of this permit.

4. Reliance on Applicant's Data: The determination of this office that issuance of this permit is not contrary to the public interest was made in reliance on the information you provided.

5. Reevaluation of Permit Decision. This office may reevaluate its decision on this permit at any time circumstances wanrant.

Circumstances that could require a reevaluation include, but are not limited to, the following:

a. You faii to comply with the terms and conditions of this permit.

b. The information provided by you in support of your permit application proves to have beenfalse, incomplete, or inaccurate (See 4 above).

c. Significant new information surfaces which this office did not consider in reaching the original public interest decision.

Such a reevaluation may result in a determination that it is appropriate to use the suspension, modification, and revocation procedures contained in 33 CFR 325.7 or enforcement procedures such as those contained in 33 CFR 326.4 and 326.5. The referenced enforcement procedures provide for the issuance of an administrative order requiring you to comply with the terms and conditions of your permit and for the initiation of legal action where appropriate. You will be required to pay for any corrective measures ordered by this office, and if you fail to comply with such directive, this office may in certain situations (such as those specified in 33 CFR 209.170) accomplish the corrective measures by contract or otherwise and bill you for the cost.

6. Extensions. General condition 1 establishes a time limit for the completion of the activity authorized by this permit. Unless there are circurmtances requiring either a prompt completion of the authorized activity or a reevaluation of the public interest decision, the Corps wil normally give favorable consideration to a request for an.extension of this time limit.

Your signature below, as permittee, indicates that you accept and agree to comply with the terms and conditions of this permit.

This permit becomes effective when the Federal official, designated to act for the Secretary of the Army, has signed below.

KURT F. UBBELOHDE COLONEL, CORPS OF ENGINEERS (DISTRICTENGINEER) / (DATE)

MICHAEL RABBE Nebraska State Program Manager When the structures or work authorized by this permit are still in existence at the time the property is transferred, the terms and conditions of this permit will continue to be binding on the new owner(s) of the property. To validate the transfer of this permit and the associated liabilities associated with compliance with its terms and conditions, have the transferee sign and date below.

(TRANSFEREE) (DA TE) 3

U.S. GPO: 1988-520-324 Nebraska Public Power District NE 2001-10322 SPECIAL CONDITIONS

1. Before each dredging event, if separated by 1 year or more from the previous event, the permittee will follow the procedure described in the Corps of Engineers Inland Testing Manual.

2. Notify the Corps of Engineers at least one week prior to each dredging event, giving the date(s) of operation and the approximate amount of sediment to be dredged.

3. The Corps of Engineers will be notified by close of business day if an accumulation of dredged material occurs at the point of discharge. The Corps will determine any corrective measures.

4. Discharge will occur in the thalweg but outside of the 300-foot wide navigation channel.

5. Submit to the Corps of Engineers within 30 days of permit issuance a contingency plan for the prevention and control of spills of fuels, oils, and other hazardous materials originating from the dredge equipment. The barge will be equipped with adequate spill control materials.

4

STATE OF T. aDEPARTMENT OF ENVIRONMEN TAL QUAUTY o* 1 .- n ,,,,.\Micl hael J. Linder Director Suite 4100, The Atrium 1200 'N' Street 0.Box 98922 t~

frrw I%_ .y~.,yX~ Lincoln, Nebraska 68509-8922 Phone (,

402) 471-2186 Mike Johanns 402) 471-2909 Governor NV Nebraska Public Power District P.O. Box 499 Columbus, NE 68602-0499 RE: State Water Quality Certification for Section 404 Application NE 01-10322, Dredge sediment from Cooper Nuclear Power Station water intake structure, as needed, Missouri River, Nemaha County, NE.

Dear Applicant:

We have reviewed the information received regarding the above-referenced application and feel the activity will comply with Section 401 of the Clean Water Act of 1977, as amended by the Water Quality Act of 1987, subject to meeting the following condition:

Follow the steps described in the Corps of Engineers Inland Testing Manual concerning possible sediment contaminants.

Notify NDEQ by letter at least one week prior to each dredging session, describing date the operation is planned and the anticipated amount of sediment to be dredged. Include the Corps of Engineers project number (NE 01-10322) in each letter.

We therefore, by this letter, provide Section 401 Water Quality Certification. This certification does not constitute authorization to conduct your project. It is a statement of compliance with Surface Water Quality Standards only, which is one requirement to gain authorization from the U.S. Army Corps An Equol OpporiunftlWAfilrrnaklue Achton Employer

& Printed withsoy Ink on recyclod paper

of Engineers in the form of a Section 404 permit. If you have any questions, please feel free to call Terry Hickman on my staff, at (402) 471-2875. -I Sincerely, Patrick W. Rice Assistant Director TH cc: Keith Tillotson, US Army Corps of Engineers Steve Anschutz, US Fish & Wildlife Service Frank Albrecht, Nebraska Game & Parks Commission Tom Taylor, US Environmental Protection Agency

DEPARTMENT OF THE ARMY CORPS OF ENGINEERS, OMAHA DISTRICT 215 NORTH 17TH STREET OMAHA, NEBRASKA 66102-4978 REPLY TO A13ENT1ON OF October 8, 1999 Nebraska Regulatory Office - Wehrspann 8901 South 154th Street, Suite I Omaha, Nebraska 68138-3621 Nebraska Public Power District Attn: David Overhue 14 14 1 51h Street Columbus, NE 68602-0499

Dear Mr. Overhue:

Reference your letter dated September 14, 1999 requesting reauthorization of Department of the Army permit number NE 1997-10285. The project is located orn the Missouri River in Section 32, Township 5 North, Range 16 West, Nemaha County, Nebraska. Provided the information furnished with your original application signed October 13, 1997 has not changed, the proposed activity is reauthorized'by this extension-letter.

The letter of permission covering your project is being extended for a period often years from the date of this letter. This reauthorization is valid under the following condition(s):

The ice deflectors are installed each year in the same location and that the dimensions of the ice deflectors do not change. If you should need different dimensions of deflectors in the future, you will need to contact the Corps of Engineers.

This authorization does not eliminate the need to obtain other applicable federal, tribal, state or local permits. If you have any questions concerning this reauthorization, please contact me at the letterhead address or telephone (402) 896-0896 and reference file number NE 1997-10285.

Sincerely, isa Peterson Project Manager Prinled on Recycled Paper

Enclosure 2.1 to Attachment 1 Hydrogeologic Investigation Work Plan

DRAFT HYDROGEOLOGIC INVESTIGATION WORK PLAN Groundwater Protection Initiative Cooper Nuclear Station Brownville, Nebraska Prepared For:

Nebraska Public Power District Agreement No. 4200001069

DRAFT TABLE OF CONTENTS Page 1.0 IN TROD UCTIO N ............................................................................................................. 1 1.1 OBJECTIVES ............................................ 2 1.2 REPORT ORGANIZATION .......................................................................... 2

2.0 BACKGROUND

AND RECONNAISSANCE ................................................................ 3 2.1 STATION DESCRIPTION ............................................................................... 3 2.2 SURROUNDING LAND USE ....................................................................... 4 2.3 REGIONAL INFORMATION ............................................................................. 5 2.3.1 G EOLO GY ............................................................................................................. 5 2.3.2 HYD RO G EO LOGY ........................................................................................ 6 2.3.3 GROUNDWATER FLOW .............................................................................. 6 2.3.4 SURFACE WATER BODIES .......................................................................... 7 2.3.5 SURROUNDING AREA GROUNDWATER USE ...................................... 7 2.4 STATION-SPECIFIC GEOLOGY AND HYDROGEOLOGY ..................... 9 2.4.1 EXISTING ON-SITE WELLS .......................................................................... 9 2.4.2 STATION GEOLOGY .................................................................................... 10 2.4.3 STATION HYDROGEOLOGY ..................................................................... 11 2.4.4 GEOPHYSICAL SURVEY ............................................................................ 12 2.4.5 SURFACE DRAINAGE ................................................................................. 12 2.5 REVIEW OF HISTORICAL INFORMATION .......................................... 13 2.5.1 PERMITTED TRITIUM RELEASES ........................................................... 13 2.5.2 REVIEW OF HISTORICAL RELEASES ...................................................... 14 2.5.3 UTILITIES THAT MAY BE POTENTIAL TRITIUM-MIGRATION PATHW AYS .................................................................................................. 17 2.5.4 PREVIOUS INVESTIGATIONS RELATED TO TRITIUM ....................... 17 2.5.4.1 TRITIU M D A TA ............................................................................................. 17 2.5.4.2 GROUNDWATER REMEDIATION ........................................................... 17 2.6 AREAS FOR FURTHER EVALUATION .................................................... 18 3.0 PRELIMINARY SITE CONCEPTUAL MODEL ........................................................... 21 4.0 SC OPE OF W O RK ........................................................................................................... 23 4.1 TASK 1 - WELL INVENTORY .......................................................................... 23 4.2 TASK 2 - INSTALLATION OF NEW MONITORING WELLS ................ 23 4.3 TASK 3 - INSTALLATION OF STAFF GAUGES ...................................... 24 4.4 TASK 4 - SURVEYING ................................................................................. 25 4.5 TASK 5 - INSTALLATION OF PERMANENT PUMPS .......................... 25 4.6 TASK 6 - HYDROLOGIC MEASUREMENTS ........................................... 25 4.7 TASK 7 - GROUNDWATER SAMPLING .................................................. 26 4.8 TASK 8 - SURFACE WATER AND STORMWATER SAMPLING ...... 27 4.9 TASK 9 - PRECIPITATION .......................................................................... 27 4.10 TASK 10 - DATA ANALYSIS ..................................................................... 28 4.11 TASK 11 - REPORTING ............................................................................... 28 048354(l) CONESTOGA-ROVERS & ASSOCIATES

DRAFT 5.0 SCH EDU LE ............................................................................................................................. 29 CONESTOGA-ROVERS & ASSOCIATES (1) 048354 (l) CONESTOGA-ROVERS &ASSOCIATES

DRAFT LIST OF FIGURES (Following Text)

FIGURE 1 SITE LOCATION MAP FIGURE 2 STATION BASE MAP FIGURE 3 CROSS-SECTION LOCATION MAP FIGURE 4 GEOLOGIC CROSS-SECTION A-A' FIGURE 5 GEOLOGIC CROSS-SECTION B-B' FIGURE 6 GEOLOGIC CROSS-SECTION C-C' FIGURE 7 BEDROCK CONTOUR MAP FIGURE 8 AREAS FOR FURTHER EVALUATION (AFE)

FIGURE 9 PRELIMINARY SITE CONCEPTUAL MODEL FIGURE 10 PROPOSED WELL AND SAMPLING LOCATIONS CONESTOGA-ROVERS & ASSOCIATES (1) 048354 (l) CONESTOGA-ROVERS &AssocIATES

DRAFT LIST OF TABLES (Following Figures)

TABLE 1

SUMMARY

OF EXISTING WELL NETWORK TABLE 2

SUMMARY

OF AVAILABLE TRITIUM DATA TABLE 3

SUMMARY

OF AREAS FOR FURTHER EVALUATION TABLE 4 PROPOSED MONITORING WELL LOCATIONS AND RATIONALE TABLE 5 PROPOSED SURFACE WATER LOCATIONS AND RATIONALE LIST OF APPENDICES (Following Tables)

APPENDIX A STATION-SPECIFIC DOCUMENTS REVIEWED APPENDIX B FIELD INVESTIGATION METHODS APPENDIX C CRA HEALTH AND SAFETY PLAN APPENDIX D PROPERTY ACCESS/UTILITY CLEARANCE DATA SHEET APPENDIX E CRA STANDARD OPERATING PROCEDURES APPENDIX F REPORTING AND DATA VALIDATION APPENDIX G SCHEDULE 048354 (l) CONESTOGA-ROVERS &ASSOCIATES

DRAFT

1.0 INTRODUCTION

This report is a Hydrogeologic Investigation Work Plan (Work Plan) for the Cooper Nuclear Station (CNS) in Brownville, Nemaha County, Nebraska (Station).

Conestoga-Rovers & Associates (CRA) along with Bartlett Nuclear, Inc. (Bartlett) have prepared this Work Plan on behalf of the Nebraska Public Power District (NPPD). The location of the CNS is presented on a USGS topographic map (Figure 1).

This Work Plan has been prepared to assist in the development of an enhanced groundwater-monitoring program with an emphasis on the early detection of radionuclides for NPPD's CNS. This program is known as the Groundwater Protection Initiative and follows an industry-wide proactive effort focusing on groundwater monitoring capabilities within the legal boundaries of the facility. The Nuclear Energy Institute (NEI), an industry stakeholder group, has prepared guidance to identify actions to improve utilities' management and response to instances where the inadvertent release of radioactive substances may result in low but detectable levels of plant-related materials in subsurface soils and water. These actions are described in detail in their Industry Ground Water Protection Initiative - Final Guidance Document (June 2007).

Preparation of this Work Plan has considered the recommendations and guidance within the NEI Guidance Document.

The Electric Power Research Institute (EPRI) is also preparing a guidance document for the Groundwater Protection Initiative. CRA/Bartlett are aware of the technical aspects of the EPRI guidance and expect that this Work Plan will adhere to the relevant recommendations of the guidance upon its final issuance. CRA/Bartlett will review EPRI's final guidance document when received and update this Work Plan, if necessary.

The Work Plan recommends Areas for Further Evaluation (AFEs) regarding potential impacts to groundwater from radioactive leaks or spills. CRA's development of recommended AFEs is based on information provided by Station staff and Bartlett.

The Work Plan also considers historic spills and releases and areas where potential spills and releases may occur in the future.

This Work Plan contains:

A description of the AFEs identified at the Station and the basis for including each AFE in the Work Plan; CONESTOGA-ROVERS & ASSOCIATES 048354(1) 048354 (l) 1 CONESTOGA-ROVERS &AssocIATES

DRAFT

The specific investigation techniques to be used to investigate each AFE, the overall groundwater system, and potential pathways at the Station; and

" Necessary supporting documentation, procedures, and appendices for field personnel to implement the proposed scope of work.

1.1 OBJECTIVES The objectives of this Work Plan are:

" The assessment of existing hydrogeological data;

" Evaluation of the need for a geophysical survey to augment existing data to optimize the installation of groundwater monitoring points;

Preparation of a preliminary Site Conceptual Model (SCM);

Development of a well installation work plan; and

Preparation of a short-term monitoring plan.

1.2 REPORT ORGANIZATION The remainder of this Hydrogeologic Investigation Work Plan is organized as follows:

Section 2.0 - Background and Reconnaissance: this Section presents the Station background; summarizes the regional and Station-specific geology, hydrogeology, and groundwater flow; documents the results of CRA and Bartlett's visit at CNS; summarizes previous environmental investigations and releases; and identifies AFEs;

Section 3.0 - Preliminary Site Conceptual Model: this Section presents a preliminary SCM utilizing text and figures based on existing available information;

Section 4.0 - Scope of Work: this Section describes the Scope of Work to be implemented including a description of the proposed activities and rationale; and

" Section 5.0 - Schedule: this Section presents the schedule for the implementation of tasks and reporting.

2 CONESTOGA-ROVERS & ASSOCIATES (1) 048354 (l) 048354 2 CONESTOGA-ROVERS &AssocIATES

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2.0 BACKGROUND

AND RECONNAISSANCE This section presents a summary of the Station background information, identifies AFEs and describes the physical setting and the Station. CRA and Bartlett visited the Station on June 20 and 21, 2007. CRA and Bartlett were accompanied by John Martin (Project Manager) during the visit and during the review of documents at the Station.

Additional NPPD and CNS employees provided support during the document review process and their contact information is provided in the table shown below. A list of the documents reviewed is presented in Appendix A. The following sections present a summary of the historical Station information and data provided as they relate to the planned Groundwater Protection Initiative radionuclides investigation.

The following Station contacts provided information and support for this Work Plan:

John Martin, FMP 4U2-825-M12 immarti~nppd.com Dennis Beauchaine 402-825-2729 Ron Yantz 402-825-2983 Kyle Kriesel 402-825-2876 Chris Stipp 402-825-5227; costipp@nppd.com Ken Fike 402-825-5492 Kevin Tanner 402-825-5857 Mark Unruh 402-825-5470 2.1 STATION DESCRIPTION This Section presents the Station-specific background information pertinent to the Hydrogeologic Investigation. Figure 2 presents the Station Base Map, which includes the relevant Station features.

The CNS is located in Brownville, Nemaha County, Nebraska on the west side of the Missouri River. The Station is located approximately at latitude 40' 21' 41" north and longitude 950 38' 28" west. The Station address is 72676 678 A Avenue, Brownville, Nebraska, 68321. The ground surface elevation surrounding the primary Station structures is approximately 903 feet above mean sea level (amsl). The typical elevation of the Missouri River is 880 feet amsl. A north-south trending levee is situated north of 048354(l) 3 CONESTOGA-ROVERS &ASSOCIATES

DRAFT the major Station structures. The elevation of the levee's crest is approximately 902 feet amsl. Topographic relief across the Station is less than 10 feet.

NPPD owns a total of 1,351 acres on both sides of the Missouri River. The developed portion of the CNS property is approximately 885 acres. The CNS property includes approximately 236 undeveloped acres in Nebraska and 230 undeveloped acres east of the Missouri River in Atchison County, Missouri (www.nppd.com / newsroom/-cns brochure.pdfo.

Since 1974, the Station has operated one boiling light-water reactor; the unit has an electrical generating capacity (net) of approximately 791 Megawatts-electric (www.nppd.com / About Us/ EnergyFacilities / Facilities / cns.asp). Additional Station structures include the turbine and reactor buildings, radwaste building, two sanitary lagoons (lined), sludge lagoon (unlined), switchyards, sewage treatment plant, a drinking water treatment system, an administrative/ training center, and miscellaneous auxiliary buildings. No discharge lines exist off of the Station's property. Approved discharges of radionuclides are discharged to an on-site discharge canal prior to entering the Missouri River.

The CNS is owned by the NPPD based in Columbus, Nebraska. The NPPD was previously named the Consumers Public Power District (CPPD). The CNS operates pursuant to NRC Operating License DPR-46. NPPD's license will expire January 18, 2014 (www.nrc.gov/info-finder /reactor/cns.html).

2.2 SURROUNDING LAND USE The area around the CNS is predominantly rural, characterized by farms. Properties immediately adjacent to the Station consist of agricultural and open land to the north, east, south, and west. The major portion of the CNS is bounded on the east by the Missouri River.

The Radiological Environmental Monitoring Program (REMP) 2007 Annual Radiological Environmental Report (January 1 - December 31, 2006) includes a listing of the residences, gardens, and dairy animals within a five-mile radius of the station (NPPD, 2007).

There are no major metropolitan areas within 50 miles of the Station. The Station is 2.25 miles from Brownville, Nebraska. The nearest major metropolitan areas are Lincoln, 048354(l) 4 CONESTOGA-ROVERS & ASSOCIATES

DRAFT Nebraska, approximately 60 miles northwest; Omaha, Nebraska, approximately 100 miles north; and Kansas City, Missouri, approximately 100 miles southeast.

2.3 REGIONAL INFORMATION The following section presents a general summary of the geology, hydrogeology, groundwater flow conditions, and surface water bodies near the Station. The following discussion was developed based on available literature, a review of the Station documentation (Appendix A), and information obtained during the July 2007 Station visit.

2.3.1 GEOLOGY The CNS is located in the Drift Hills section of the Central Lowland physiographic province. The Drift Hills section is characterized by gently dipping rock strata, mainly Paleozoic in age (approximately 400 million years old) and by an undulating, glaciated topography, maturely dissected by the streams of the Missouri River drainage system (Fememar, 1931).

The Station is located on the broad flood plain of the Missouri River. The geologic strata consist of soil deposits, sedimentary rocks, and a deep basement of granitic rock. The soils at the structure locations are alluvial and glacio-fluvial deposits comprised of surficial fine-grained soils (silty sand, sandy silt, silty clay, and clay) and the underlying sands (grading fine to coarse with depth). The sedimentary rocks underlying the flood plain are Pennsylvanian (approximately 320-286 million years old) and Permian (approximately 286-245 million years old) in age, consisting of alternating shale and limestone formations. The granite basement rock controls the major geologic structures of the area namely the Nemaha Anticline, the Redfield Anticline, and the Forest City Basin. Associated with the anticlines are two faults, the Humboldt Fault and the Thurman-Wilson Fault. The Nemaha Anticline developed mountainous relief late in the Paleozoic era and was subsequently buried. The Humboldt Fault, about twenty miles west of the Station at its closest point, has apparently ceased in major tectonic activity in post Permian time; however, it is believed that deep seated adjustments are still continuing and are the cause of earthquakes along the Nemaha Anticline. The Forest City Basin, east of the Humboldt Fault, underlies the Station and consists of approximately 3,500 feet of sedimentary rocks. Geologic survey and subsurface exploration did not give any evidence of faults at the Station.

048354 (l) 5 CONESTOGA-ROVERS & ASSOCIATES

DRAFT Locally, the stratigraphy is best represented by a section through the bluffs along the westerly boundary of the Station. It shows Peorian loess, Kansas till, limestone and shale of the Permian system, and limestone, shale, sandstone, and occasional thin beds of coal of the Pennsylvanian system. The contact between 'the Pennsylvanian and Permian systems is unconformable and occurs in the bluff at approximately elevation 930 feet amsl (CPPD, 1967).

2.3.2 HYDROGEOLOGY The Station is located on a depositional plain bordering the Missouri River at river mile 532.5. This portion of the Missouri River is termed the Lower Brownville Bend. The United States Army Corps of Engineers (USACE) has stabilized the channel by use of pile dikes and bank protection in an attempt to control meandering of the river within the alluvial floodplain. There are six dams upstream of the Station, and none downstream. According to the Preliminary Safety Analysis Report (PSAR), a minimum Nebraska City flow of 31,000 cubic feet per second (cfs) is maintained for navigational purposes from March through November. During the winter months, a minimum flow of 3,000 cfs is required for sanitary purposes.

The CNS is not located in a designated recharge area for any aquifer; however, recharge to the unconsolidated alluvial deposits does occur over the Station (CPPD, 1967). Both the overburden and the underlying bedrock formations (except for the Nyman Coal) are considered regional aquifers. The bedrock formations below the Station have relatively low primary porosity (CPPD, 1967). Groundwater is stored and transmitted in the bedrock through a network of secondary fractures and joints. Groundwater flow is predominantly along the bedding planes.

2.3.3 GROUNDWATER FLOW In general, groundwater flows from higher elevations to lower elevations with discharge to streams, creeks, and rivers. Regional groundwater flow is to the east and east-southeast discharging to the Missouri River. During flooding of the Missouri River, temporal flow variations can occur resulting in reversal of the groundwater gradient in the vicinity of the Station (CPPD, 1967).

6 CONESTOGA-ROVERS & ASSOCIATES (1) 048354 (l) 6 CONESTOGA-ROVERS &ASSOCIATES

DRAFT 2.3.4 SURFACE WATER BODIES The Station is located adjacent to and on the West Bank of the Missouri River. No other permanent surface water bodies exist within the immediate vicinity of the Station.

2.3.5 SURROUNDING AREA GROUNDWATER USE CRA conducted a search of the Nebraska Department of Natural Resources website to identify water wells within the vicinity of the Station. The water well database includes all irrigation wells installed since 1953 and all water wells since 1983. The database search revealed 328 water wells within Nemaha County. Eight of the 328 water wells are wells at CNS. Of the remaining 320 wells, only three were identified within Brownville. According to database, two of the three identified wells (one owner) are irrigation wells located approximately 2.8 miles southwest of the Station. Two wells were installed May 2005 to depths of 129 and 137 feet. A static water level of 78 feet and a measured pumping rate of 250 gpm were recorded for these two wells. The third well (same owner) is an irrigation well located approximately 2.4 miles south-southwest of the Station. This well was installed in June 2003 to 62 feet. A static water level of 9 feet and a measured pumping rate of 1,000 gpm were recorded for this well.

According to CNS' Updated Safety Analysis Report (USAR) (2006), there are six wells within one mile of the plant site, two of which are site wells to supply plant needs. The remaining four are listed as follows:

1. Farm well approximately 0.7 miles south-southwest from the reactor building, for domestic use, 1 1/4" casing size, pump less than 10 gallons per minute (gpm), static water level approximately 15 feet. Driven sand point installation will not permit drawdown measurements.

2. Farm well approximately 0.7 miles south-southwest from reactor building, for livestock use, seven inch casing size, pump less than 10 gpm, static water approximately 15 feet. The domestic type installation does not include the means for drawdown measurements.

3. Farm well approximately 0.8 miles west from the reactor building, for domestic and livestock use. The well is hand dug, approximately 3 1/2 feet in diameter with a rock-lined wall. Well capacity is less than 10 gpm; static water level is approximately 15 feet.

Drawdown data is not available.

048354 (l) 7 CONESTOGA-ROVERS & ASSOCIATES

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4. Farm well approximately 1.0 miles west-northwest from the reactor building. This is an abandoned, hand dug, rock lined well on an abandoned farmstead.

All of the wells within one mile of the CNS site are small farm wells that were installed to supply domestic and livestock water needs for the individual farmsteads. These wells fall into three classes; drilled and cased wells, hand driven sand points and hand dug, rock or brick lined wells. The wells are shallow and draw their water from the same general aquifer that yields very high solids water with high iron and manganese concentrations. Because of the private nature of these domestic wells and absence of test connections, data is not available for maximum pumping rates and water levels.

Therefore, water level is estimated from engineering data from the site wells that were installed in the same, flat, Missouri River bottomland.

Some residences located near the Station (but greater than one mile) have individual potable water supply wells. Drinking water for these residences is typically obtained from wells completed within the alluvial deposits. The off-site well depths vary from 10 to 40 feet below ground surface (bgs), and they generally produce less than 10 gpm.

The pumping system for Nemaha County Rural Water District No. 1 draws water from wells located 5.2 miles north-northwest of the CNS. The wells are located one mile from the Missouri River approximately five miles up river from the CNS. The Nemaha County Rural Water District No. 1 began distributing water to rural areas in 1971 and is replacing many of the farm wells as principal water supply.

The nearest downstream Nebraska village is Nemaha, which is about two miles downstream and 2 1/2 miles west of the river. Present water supply is from about 80 private residential wells ranging in depth from 16 to 18 feet and a municipal water system. The latter has a total capacity in excess of 250 gpm from two municipal wells located at 7th and Ottoe Streets and 4th and Ottoe Streets. They are eight-inch cased wells drilled to approximately 80 feet in depth. Normal static water level is approximately 30 feet. They are equipped with submersible pumps rated at 60-gpm capacity at normal system head. Drawdown is minimal, estimated to be less than six feet. The aquifer receives recharge from the Nemaha River. Specific engineering information was not catalogued at installation. The above information was retrieved from existing city water system records.

Rulo, population 412, is located on high ground within three miles of the river and south of Nemaha and approximately 35 miles downstream of the Station. The town has 048354 (l) 8 CONESTOGA-ROVERS & ASSOCIATES

DRAFT private residential wells for its water supply. There are, however, wells at Rulo, which supply the town of Falls City, population 5,598, about ten miles west from the river.

There are no known wellhead protection areas or EPA-designated sole source aquifers in the immediate vicinity of CNS.

2.4 STATION-SPECIFIC GEOLOGY AND HYDROGEOLOGY 2.4.1 EXISTING ON-SITE WELLS Table 1 presents an overview of the existing well inventory including water supply wells and monitoring wells. Available well construction details are also provided in Table 1.

Figure 2 presents the existing wells. The well names and aquifers are listed below:

" Water Supply Well #1 (presumed overburden);

Water Supply Well #2 (presumed overburden);

" River Well A (overburden);

River Well B (overburden);

Fire Well (presumed overburden); and

Piezometers B-1, B-12, and B-31 (overburden).

There are two active potable water supply wells (#1 and #2) onsite that provide drinking (and industrial) water to the Station. In general, one of the two potable water supply wells serves as a backup for the other well. Each of the two supply wells has a pumping capacity of 250 gpm; normal pumping rate is 125 gpm. Both water supply wells together provide 250 gpm for short-term industrial use. Complete well construction and survey information are not available for the potable water supply wells. Well depths, casing type, and casing interval were obtained from a review of the Nebraska Department of Natural Resources website www.dnrdata.dnr.ne.gov/wellssql.

River Wells A and B are industrial wells that supply water for pumps seals. Complete well construction and survey data are not available for the River Wells. According to a review of engineering drawings provided by CNS personnel, the River Wells A and B have been relocated and redrilled at their current locations. The former locations of River Wells A and B were approximately 100 feet and 125 feet from their current locations, respectively. The reason for the redrilling of the River Wells is unknown.

Complete well construction and survey information are not available for the River Wells 048354(l) 9 CONESTOGA-ROVERS &ASSOCIATES

DRAFT A and B. Well depths, casing type, and casing interval were obtained from a review of the Nebraska Department of Natural Resources website www.dnrdata.dnr.ne.gov/wellssql.

The Fire Well supplies water to the Fire Protection Tanks as needed. Well construction, well depth, and survey data are not available for the Fire Well.

Existing monitoring wells at the Station include three piezometers (B-1, B-12, and B-31).

These three piezometers were installed during the soil boring investigation program associated with the Independent Spent Fuel Storage installation (ISFSI) project. The primary purpose for the installation of these piezometers was to obtain groundwater levels/ gradients across the Station property. Currently, the three piezometers are used for monitoring Station groundwater levels and for collection of samples for analysis.

They are not used for water supply. Based on planned construction for the IPFSI, piezometer B-13 will be abandoned.

According to the ISFSI project report (URS, 2006), six additional piezometers were installed during the pre-construction phase of the Station building; however, it is unknown if these piezometers still exist, and if so the status of their condition.

2.4.2 STATION GEOLOGY The Station is situated on relatively flat ground comprised of floodplain deposits. The Station is underlain by an overburden of alluvial deposits (silt, sand, and some gravel),

and bedrock. The alluvial deposits have been characterized into three subdivisions:

upper alluvium, alluvium, and lower sandy alluvium.

The bedrock underlying the overburden consists of interbedded shales, siltstones, limestones, and sandstones of the Pennsylvania-age Wabaunsee Group. In descending order beneath the Station, the following six formations comprise the Wabaunsee Group:

Dry Shale

Dover Limestone

Nyman Coal

Langdon Shale

Tarkio Limestone

Willard Shale 048354 (l) 10 CONESTOGA-ROVERS & ASSOCIATES

DRAFT These six formations along with the overburden deposits comprise approximately the first 100 feet of subsurface lithology. The overburden thickness ranges from approximately 60 to 80 feet.

Figure 3 presents the cross-section lines in plan view. Generalized geologic cross-sections, adapted from figures prepared by Woodward-Clyde-Sherard &

Associates for the Preliminary Safety Analysis Report (CPPD, 1967) are shown on Figures 4 through 6. The contours of the surface of the bedrock have been interpreted on the basis of the boring and seismic survey data during pre-construction investigations. A bedrock contour map based from these data is presented as Figure 7.

2.4.3 STATION HYDROGEOLOGY Typically, groundwater flow in the overburden and bedrock is from west to east beneath the Station with discharge to the Missouri River. The groundwater at the Station area is in hydraulic connection with the Missouri River (CPPD, 1967), which has a typical river elevation is 880 feet amsl. On occasion, groundwater flow in the overburden (alluvial deposits) is from the river towards the Station (east to west) due to elevated river stage.

Based on regional geologic information, the top few feet of bedrock are slightly weathered and any significant transport of water within the bedrock is likely through this weathered zone (CPPD, 1967).

Average Station grade is 903 feet amsl. Flood control is maintained by a series of upstream dams constructed by the USACE. According to the PSAR, the maximum plant circulating flow (river inflow) would be approximately 650,000 gpm in peak summer months, equivalent to approximately 1,400 cfs. Therefore, the Station would require approximately one-third (1,400 cfs) of the river flow under worst-case conditions (3,000 cfs) as discussed in Section 2.3.2.

The groundwater table beneath the Station generally occurs within 15 to 30 feet of the ground surface. Groundwater level data obtained during pre-construction investigations indicated a groundwater elevation of 881 feet amsl. Based on an average overburden thickness of 70 feet, approximately 40 to 55 feet are saturated. Groundwater in the overburden occurs under unconfined conditions. Groundwater levels collected from two piezometers installed at the Station in 2006 indicate groundwater elevations of 867 feet and 876 feet amsl (URS, 2006): The creation of impervious surfaces during Station construction has likely caused a reduction in groundwater recharge to groundwater.

048354(l) 11 CONESTOGA-ROVERS &AssocIATES

DRAFT Hydraulic conductivity (K) was computed from an analysis of data obtained from the USACE pumping tests on the pressure relief wells. The results indicate that the K of the sand ranges between 10 x 10-2 and 20 x 10-2 centimeters per second (cm/sec). These figures are in agreement with the range 6 x 10-2 to 9 x 10-2 cm/sec stated by the USACE as typical for the Missouri Valley sands. The permeability of the gravel and sand just above the rock surface is expected to be higher than the overlying sands and may be on the order of 10 cm/sec (CPPD, 2007).

Structural fill constructed below grade prior to plant construction likely affects localized groundwater flow under and around the buildings, specifically within the overburden.

According to Station personnel, groundwater intrusion into the Station buildings below grade areas has occurred through utility conduits. In addition, flood stages of the Missouri River have occurred in the immediate vicinity of the Station permitting groundwater intrusion into Station structures. CNS has confirmed groundwater intrusion in the High Pressure Coolant Injection (HPCI) building.

2.4.4 GEOPHYSICAL SURVEY One of the objectives of this Work Plan is the evaluation of the need for a geophysical survey. The consideration for a geophysical survey was to augment existing data to assist in optimizing the location of monitoring wells. Based on a review of the available geological information, CRA and Bartlett have determined a geophysical survey would not offer added value to the proposed investigation. The pre-construction data along with subsequent investigations provide an adequate view of the subsurface. In addition, limitations exist with geophysical equipment in the presence of numerous overhead and subsurface utilities. Following installation of the proposed monitoring wells and the two initial sampling events, CRA and Bartlett will re-evaluate the need for a geophysical survey.

2.4.5 SURFACE DRAINAGE Except for the Missouri River, located east of the Station, there are no naturally occurring surface water bodies in the immediate vicinity of the Station. The Missouri River receives discharge (roof drains) from Station Outfall #002 under the Station's NPDES permit. According to Station personnel, sampling and reporting of Outfall #002 for NPDES purposes will no longer be required as of 2008.

048354 (l) 12 CONESTOGA-ROVERS &ASSOCIATES

DRAFT Two active sewage lagoons are located southwest of the Station's Protected Area (See Figure 2). Discharge from the lagoons occurs ýby irrigation to a five-acre area. According to the PSAR, the lagoons are "suitably" lined. Based on information provided by CNS personnel, the lagoons are presumably clay-lined. The sewage lagoons are sampled annually for select radionuclides; tritium analysis was added in 2006. Based on the presumption that the lagoons are clay-lined (engineered), limited to no interaction between the lagoons and surface and subsurface water flow is expected.

2.5 REVIEW OF HISTORICAL INFORMATION This section provides a review of:

Documented (permitted and unpermitted) tritium releases, 0 Utilities that may be potential tritium-migration pathways.

Previous investigations related to tritium, and

Systems evaluations conducted by Station personnel and Bartlett.

The following evaluation is based on CRA's and Bartlett's review of information provided by the Station. The results of this review combined with the understanding of groundwater flow at the Station are then used to determine the Areas for Further Evaluation (AFEs).

2.5.1 PERMITTED TRITIUM RELEASES The Station is authorized to release tritium-containing material in two permitted, effluent pathways:

1. Radioactive water is treated and discharged in a batch process to the main radwaste discharge line. This pathway provides significant dilution of effluents prior to release to off-site media. Discharged concentrations and volumes are controlled by Station release permits, and calculated for dilution prior to release to the Missouri River. The Station currently discharges to the Missouri River from two liquid effluent locations:

NPDES Outfall 002A located approximately due east of the southeast corner of the Turbine Building (roof and yard drains) at the Head Wall; and 048354 (l) 13 CONESTOGA-ROVERS & ASSOCIATES

DRAFT 0 Discharge Canal (also known as the Seal Well).

The roof drains merge at the southeast corner of the plant and the effluent is directed due east to the Missouri River at Outfall 002A.

2. Noble gases, halogens and tritium vapors are discharged at the following atmospheric gaseous release points (# locations):

Reactor Building (1);

Turbine Building (4);

Augmented Rad Waste Building (1); and

Elevated Release Point (1).

According to the 2006 Annual Radioactive Effluent Release Report (NWS 1900-2007),

the predominant wind direction is south.

Liquid and gaseous effluent releases for 2006 for tritium were calculated as follows (CNS, 2007):

Liquid batch release of approximately 0.54 curies

" Gaseous effluent releases of approximately 20 curies Permitted liquid releases could have an impact on groundwater due to equipment malfunction such as underground pipe leakage, which could then migrate to the river or on-site supply wells and off-site potable wells.

2.5.2 REVIEW OF HISTORICAL RELEASES A review of provided historical Radiological Safety Incident Reports provided by CNS with potential links to groundwater contamination since plant licensing indicates that impact on groundwater is relatively low. Only seven documented incidents of liquid radiological releases (or potential releases) occurred since licensing in 1974. The following is a summary of those reports and their current impact to the groundwater.

For reference purposes the CNS plant grade is 903 feet amsl and the Missouri River surface water elevation is approximately 880 feet amsl (USACE).

1. Z-Sump (Elevated Release Point) Explosion - November 5, 1975. Hydrogen buildup in and around Z-Sump was ignited by electric air sampler pump. The incident report provides no reference to any radiological release. It was only included as an indicator of potential pathway between the Z-sump and the 048354 (l) 14 CONESTOGA-ROVERS & ASSOCIATES

DRAFT surrounding environment. Small quantities of condensate water collect in the base of the Z-Sump and are pumped to the Rad Waste Building via two (2) small sump pumps (Drawing 2192, 2193). The Z-Sump manway elevation is (889 feet) and the Air Removal (AR) and Feedwater Return (FDR) lines come in at 881 ft. These data indicate that radiological materials in the Z-Sump could potentially migrate to the surrounding soil following heavy precipitation or seasonal runoff. Radiological data indicate that this surrounding soil has been contaminated with low levels of radioactive material (RAM). Additionally plant personnel indicate that the soil area around the manway was contaminated in the 1970's during flood conditions with Co-60.

2. Off-Gas Building Explosion - January 7,1976 (NCR-677). An ice plug formed at the top of the Elevated Release Point (ERP) and discharge was reduced. A hydrogen buildup occurred in the Off-Gas Building and the building Continuous Air Monitor (CAM) was at full scale. The explosion demolished the 32-foot by 48-foot building.

Following the event the Condenser was purged for 120 minutes (Event 2). Activity levels released to the environment were calculated to be 11% and, 53% of the maximum permissible concentrations for the two events at about 10 meters above surrounding ground. No additional radiological data were provided however the surrounding soil and Z-Sump area (#1 above) could have potentially been contaminated from this blockage in flow, increased activity build-up, and explosion.

3. South Condensate Storage Tank Overflow - No Date Confirmed. Health Physics Log "Provided HP coverage and assistance at Condensate Storage Tank (CST) (tank overflowing). Built dirt dam around area to contain water. Posted area. Water was 17.22 maximum permissible concentrations (MPC's)." Later the same shift "Released area of CST spill - 3 drums of contaminated dirt." The South CST has no secondary containment to recover any overflow. This event provided a direct route to the groundwater overburden and the groundwater. Total volume of the release is unknown and tritium analysis of the spillage .was not performed. The tritium groundwater impact was viewed as insignificant. Based on the Health Physics Log records, the spill occurred over a relatively short time period (5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months between initial response and release of area) and impacted soils were remediated.

4. South Condensate Storage Tank Overflow - November 2, 1976. While transferring water from the fuel-pool to CST the CST was overfilled. The water ran on the ground to approximately 20 feet north into a roadside ditch. Initial water samples from ditch were 1.97E-04 'microcuries per milliliter (uCi/ml) (1.97E05 picocuries per liter [pCi/1]). Radiological Survey indicated soil contact reading 3.75 millirems per 048354 (l) 15 CONESTOGA-ROVERS & ASSOCIATES

DRAFT hour (mrem/hr) and 2 mrem/hr at 3 ft. Gamma spec results indicated Mn-54, Co-60, Co-58 and Nb-95. Removed approximately 6 inches of soil from affected area and resample until less than 10CFR20 Appendix B requirements. Eight, 55-gallon drums of soil were removed. Plant personnel estimated that approximately 50 gallons of water was spilled to ground. No tritium data were available. This event provided a direct route to the groundwater overburden and the groundwater. Total estimated volume of the release is minimal and tritium analysis of the spillage was not performed.

5. North Rad-Waste Door - June 23, 1983. Condensate water spill out of north door (No. 501) was confined to an area of approximately 30-feet by 500-feet including asphalt and soil. The amount of water spilled was estimated at 25 to 40 gallons. A soil sample taken immediately after the spill contained a total of 32.13 MPC. This was comprised of 1-131 (26.9 MPC), Cs-137, Cs-134, Mn-54, Co-58, Co-60. Plant personnel removed approximately 1.5 to 3 inches of surface layer. Area was released when soil sample was <1MPC. No tritium data were available. This event provided a direct route to the groundwater overburden and the groundwater. Total estimated volume of the release is minimal and tritium analysis of the spillage was not performed.

6. Z-Sump - September 17, 1999. Off-gas transient from the Augmented Off-gas (AOG) led to reactor shutdown and secondary containment was breached at Z-Sump. Certified health physicist (CHP) analysis concluded that the event did not result in an unmonitored release of radioactivity from CNS. See #1 above for analysis of contamination potential from breaching Z-Sump.

7. Z-Sump - March 10, 2003. Z-Sump manway cover leaking water from the inside.

Bolt penetrations and gasket area leaking to front portion of sump cover. See #1 above for analysis of contamination potential from breaching Z-Sump.

The above radiological spills and potential releases, some of which may have impacted the groundwater pathway at the time of the spill, are not likely current sources to groundwater. This is based on review of the records, remediation efforts performed for all incidents, current and historical REMP data, and the estimated release volumes were low to moderate and over a short time period. Further, the two of the three spills that may have actually impacted the groundwater occurred 24 to 31 years ago over which time natural and radiological groundwater attenuation has occurred.

16 CONESTOGA-ROVERS & AssocIATEs (1) 048354 (l) 16 CONESTOGA-ROVERS &AssocIATES

DRAFT 2.5.3 UTILITIES THAT MAY BE POTENTIAL TRITIUM-MIGRATION PATHWAYS Based on documents provided by Station personnel, CRA has completed a review of the Station's subsurface utilities, depths, sizes, locations, and paths. CRA has completed this review to identify potential preferential groundwater migration pathways to other on-Station or off-Station receptors.

The identified underground utilities at the Station include:

Storm and sanitary sewers lines;

Radwaste Discharge Line;

Condensate Loop; and

Electrical and telephone conduits; and

" Various piping lines for raw water supply and process water.

2.5.4 PREVIOUS INVESTIGATIONS RELATED TO TRITIUM No formal previous investigations related to tritium have been completed at the Station.

2.5.4.1 TRITIUM DATA Two potable water supply wells exist at CNS. Although these wells are not for tritium-investigative purposes, tritium water samples have been collected. The results of samples collected from the potable water supply wells are summarized in Table 2.

2.5.4.2 GROUNDWATER REMEDIATION No groundwater remediation related to tritium has ever been required or completed at the Station.

048354 (l) 17 CONESTOGA-ROVERS & ASSOCIATES

DRAFT 2.6 AREAS FOR FURTHER EVALUATION The locations of the AFEs are presented on Figure 8. CRA and Bartlett determined the AFEs based on information provided by the Station personnel including a list of the systems that contain or may contain tritium.

The AFEs are discussed in Table 3 and listed below:

" AFE #1 - Condensate Storage Tank - North Area

" AFE #2 - Major Building Structures - Groundwater Infiltration

" AFE #3 - NPDES Outfall #002

" AFE #4 - Radwaste Discharge Line

" AFE #5 - Condensate Storage Tank - South Area

AFE #6 - Elevated Release Point Sump

AFE #7 - Catch Basins

" AFE #8 - Condensate Loop

" AFE #9 - High Pressure Core Injection (HPCI) Building AFE #1 - Condensate Storage Tank-North Area The Condensate Storage Tank (CST) is located in the Protected Area north of the Reactor Building. The tank is constructed of carbon steel. An outer ring of carbon steel surrounds the CST. Water within the CST and outer ring is potentially contaminated with tritium. CNS routinely analyzes water samples from the outer ring for tritium.

Besides the outer ring, the tank is otherwise unbermed. The surface surrounding the CST consists of gravel and is therefore pervious. A leak from the tank or outer ring could provide a source of tritium to the surface or subsurface.

AFE #2 - Major Building Structures - Groundwater Infiltration The major building structures include the Reactor, Turbine, Rad Waste, and Multi-Purpose Facility Buildings and associated structures. Numerous sumps and drains exist in these structures that could potentially contain water contaminated with tritium. A leak of the sumps, drains, or radwaste line could provide a source of tritium to the subsurface. In addition, groundwater infiltration to subgrade portions of the Major Building Structures has historically occurred. Groundwater infiltration occurs via in-leakage through utility conduit penetrations of the subgrade perimeter walls. Any 048354(l) 18 CONESTOGA-ROVERS &ASSOCIATES

DRAFT groundwater infiltration could potentially come into contact with radioactive materials, and subsequent outleakage could provide a source to the groundwater. CNS has collected water samples in subgrade areas following groundwater infiltration; analytical results indicated tritium impact (maximum tritium concentration of 5,180 pCi/L).

AFE #3 - NPDES Outfall #002 Outfall #002 is the discharge point for roof drain and surface water (stormwater) runoff at the Station. The discharge could potentially contain tritium due to precipitation washout of permitted releases of airborne tritium. CNS collects samples from Outfall

002 in accordance with their NPDES permit. Outfall #002 is not currently sampled for tritium analysis.

AFE #4 - Rad Waste Discharge Line The Rad Waste Line runs from the Rad Waste Building, through the Control Building, through the Turbine Building, into and under the Diesel Generator Building, and eventually ends at the Seal Well of the Discharge Canal. Water within the Rad Waste Line is potentially contaminated with tritium.

AFE #5 - Condensate Storage Tank-South Area The Condensate Storage Tank (CST) is located in the Protected Area south of the Reactor Building. The tank is constructed of carbon steel and is unbermed. Water within the CST is potentially contaminated with tritium. The surface surrounding the CST consists of gravel and is therefore pervious. A leak from the tank could provide a source for a release of tritium to the surface or subsurface. The CST is not currently sampled for tritium analysis.

AFE #6 - Elevated Release Point Sump The Elevated Release Point (ERP) Sump is located directly under the ERP Tower approximately 13 feet below grade. The ERP Sump may contain elevated tritium because it is a release point for gaseous effluent. The ERP Sump is susceptible to surface water infiltration. For example, flooding of the Station occurred in 1993 and water was documented to have entered the sump manway at that time. The infiltration of surface water into the sump may potentially provide a mechanism for release of tritium to surface water. The ERP Sump is not currently sampled for tritium analysis.

048354 (l) 19 CONESTOGA-ROVERS &ASSOCIATES

DRAFT AFE #7 - Catch Basins Numerous stormwater catch basins exist within the Protected Area of the Station.

Depths of the catch basins range from approximately 5 to 15 feet. Upon inspection during the June 19, 2007 Station visit, CRA/ Bartlett observed several of the catch basins.

CNS personnel informed CRA/Bartlett that the catch basins are open-bottom conduits.

These catch basins could serve as a pathway for surface runoff or groundwater potentially contaminated with tritium. The catch basins are not currently sampled for tritium analysis.

AFE #8 - Condensate Loop The Condensate Loop runs from the Reactor Building southward under the Station surface grade, turns west for approximately 200 feet, loops in a sharp turn and runs east toward the CST-South Area, then turns south to the ERP sump. The Condensate Loop is constructed of mastic-wrapped carbon steel and is located approximately 7 to 10 feet below grade. Due to its age, carbon steel construction, and subgrade location, the condition of the Condensate Loop is unknown. A leak from the Condensate Loop could serve as a source for water potentially contaminated with tritium. The water (and/or water vapor) within the Condensate Loop is not currently sampled for tritium analysis.

AFE #9 - High Pressure Core Injection (HPCI) Building The HPCI Building is located directly adjacent (south) of the southwest corner of the Reactor Building. Groundwater infiltration has been observed in the subgrade portion of the south side of the HPCI Building. Analytical data from a groundwater sample (collected above the building floor at elevation 881 amsl) of the in-leakage indicated tritium impact. Due to its location on the downgradient portion of the Station, this area could serve as a source for groundwater potentially contaminated with tritium. CNS has collected water samples in subgrade areas following groundwater infiltration; analytical results indicated tritium impact (maximum tritium concentration of 58,000 pCi/L).

20 CON ESTOGA-ROVERS & ASSOCIATES 048354(1) 048354 (l1) 20 CONESTOGA-ROVERS &ASSOCIATES

DRAFT 3.0 PRELIMINARY SITE CONCEPTUAL MODEL As part of the preparation of this Work Plan, CRA developed a preliminary Site Conceptual Model (SCM) for the Station using historical CNS data. Figure 9 presents a visual representation of the preliminary SCM. This section presents the preliminary SCM, which serves as the basis to evaluate the fate and transport of tritium in the groundwater at the Station.

This is a preliminary SCM based on existing data that assimilates the Station operating history, potential contaminant sources, plant layout, and Station hydrogeology to explain how and where releases of contaminants may occur, how they would move through the environment, and what impact they may have on human health and the environment. In formulating the SCM, assumptions were made about many factors, including the types and thickness of geologic formations, their hydraulic properties, and groundwater flow. These assumptions will be evaluated as part of implementation of this Work Plan (see Section 4 for details).

The Station consists of approximately 1,355 acres; primary structures are located in Brownville, Nebraska along the Missouri River. The generating system consists of one boiling water reactor, steam turbine generators, heat-dissipation systems, and associated auxiliary facilities. The Station's reactor began commercial operation in February 1974.

Permitted discharges are discharged to the Missouri River and atmosphere.

The Station is underlain by overburden material and bedrock. The overburden consists of fill and unconsolidated floodplain sediments that consist of sand, silty-sand, clay, clayey-silt, and sandy-silt. The thickness of the overburden is approximately 70 feet.

The underlying bedrock consists of interbedded shales, limestones, and sandstones.

Limited groundwater data is available at this time. A preliminary existing well inventory was completed in preparation of this Work Plan. Based on these data, groundwater flow in both the overburden and bedrock is from west to the east with discharge to Missouri River. At times of floodstage, a temporal reversal in groundwater flow may occur.

Man-made structures, groundwater withdrawals, and surface water bodies influence groundwater flow at the Station. Station structures are completed below the water table to depths of 56 feet within the overburden, are surrounded by 30 feet of structural fill, and therefore influence groundwater flow and tritium migration.

21 CONESTOGA-ROVERS & ASSOCIATES (1) 048354 (l) 21 CONESTOGA-ROVERS & ASSOCIATES

DRAFT Overburden groundwater is diverted around and under Station structures. Pumping of the Station's two potable supply wells and two River Wells (A and B) influence groundwater flow in the overburden, in which the wells are completed. The two potable water supply wells are located 750 feet west of the northwest corner of the Augmented Radwaste Building. The River Wells A and B are located approximately 150 feet north of the northwest corner of the Control Building. Although these wells pull groundwater towards them, the risk to these wells is limited due to their distance from Station structures. This is supported by existing tritium results from the two potable water supply wells, which are below the analytical Lower Limit of Detection (LLD).

The AFEs are presented on Figure 8 and discussed in Table 3 and listed below:

AFE #1 - Condensate Storage Tank-North Area

AFE #2 - Major Building Structures - Groundwater Infiltration

" AFE #3 - NPDES Outfall #002

AFE #4 - Rad Waste Discharge Line

AFE #5 - Condensate Storage Tank-South Area

AFE #6 - Elevated Release Point Sump

AFE #7 - Catch Basins

AFE #8 - Condensate Loop

AFE #9 - High Pressure Core Injection (HPCI) Building These nine AFEs are potential sources of tritium to groundwater. Once entering the subsurface, tritiated groundwater would migrate primarily with groundwater flow in the overburden or shallow fractured rock to surface water discharge points (e.g., the Missouri River) or groundwater withdrawal points. Potential human receptors of tritium releases to groundwater are off-site recreational users of the Missouri River or residential users of groundwater. The closest potable well is located approximately 0.7 miles south-southwest of the Station. Potential ecological receptors of tritium releases to surface water are aquatic and wildlife associated with the Missouri River.

048354 (l) 22 CONESTOGA-ROVERS & ASSOCIATES

DRAFT 4.0 SCOPE OF WORK This section presents the Scope of Work for the tritium groundwater investigation.

Details regarding implementation of these tasks are presented in Appendices B through E. Appendix B provides a description of the detailed field investigation methodologies to be used during the investigation. Appendix C provides a generic Health and Safety Plan. Appendix D provides a property access/utility clearance data sheet for the Station. Appendix E presents CRA's Standard Operating Procedures that are relevant to this project. Appendix F describes reporting and data validation.

4.1 TASK 1 - WELL INVENTORY Figure 2 presents a map of the Station with the existing water well network. Table 1 presents the details of the existing water wells at the Station. An initial inventory of the existing well network is considered complete. A second phase of the well inventory will consist of visiting each well, opening the well cap, measuring the depth-to-water, measuring flow rate (if pumping), and sounding the total well depth. Based on the results, one or more of the existing wells may be used in the subsequent sampling in addition to the proposed new monitoring wells. The well inventory results may be inconclusive with regard to the usability of an existing well(s). Subsequent testing, like downhole video surveying the well, may be recommended based on the well inventory results to a make final decision regarding the inclusion of the well in the monitoring program.

4.2 TASK 2 - INSTALLATION OF NEW MONITORING WELLS Figure 10 presents the recommended locations of the proposed monitoring wells. The proposed locations are based on a review of the data provided, the hydrogeology at the Station, and the current understanding of historic or potential release areas. A listing of the proposed monitoring wells and the rationale for their location is presented in Table 4.

CRA anticipates that the proposed wells will be drilled using the air rotary drilling method for rock wells and the hollow-stem auger drilling method for overburden wells.

Rock wells will be completed as open boreholes with steel casing secured several feet into the rock to prevent overburden material from entering the borehole. Overburden wells will be constructed of PVC screen and casing with surrounding sand pack and 048354(l) 23 CONESTOGA-ROVERS & AssocIATES

DRAFT grout in the annular space. Both overburden and bedrock wells will be completed with locking well caps and either flush mount of stickup steel protective casing. All wells will be installed in accordance with the Field Investigation Methods (Appendix C).

Typical well construction diagrams for overburden and bedrock wells are included in Appendix C.

Prior to commencement of drilling activities, the Station will review and approve all proposed drilling locations. Ground Penetrating Radar (GPR) is typically performed to confirm that no underground utilities are present at each location. Additionally, an air knife (aka soft-dig) or hydrovac is utilized to verify utilities are not present at each proposed location to a depth to be determined by the Station protocol (generally 10 to 20 feet bgs.

To protect stickup protective casings in high traffic or vulnerable areas, installation of barriers (bollards) around the wells is proposed. Steel bollards constructed of 4-inch steel pipe filled with concrete should be placed in boreholes installed around select wells. The depth of the borehole should be a minimum of 3 feet below grade.

CRA proposes a nested overburden/bedrock well (MW-7 S and D) to be installed approximately 50 feet south-southeast of the ERP. This location will serve as an early release detection point (of the ERP and further upgradient potential sources) with respect to any potential off-site receptors and will provide a better understanding of groundwater flow southeast of the Station. Figure 10 shows the proposed well locations. A listing of the proposed monitoring wells and the rationale for their location is presented in Table 4.

CRA and Bartlett recommend that piezometers B-1 and B-31 be maintained and potentially used for the hydrogeologic investigation. At a minimum, depth-to-water and depth-to-bottom levels should be collected prior to monitoring well installation drilling and during all rounds of groundwater sampling associated with this project.

4.3 TASK 3 - INSTALLATION OF STAFF GAUGES CRA will use existing Station surface water elevation monitoring data and install staff gauges in a manner appropriate to the depth and flow velocity of the River to maintain the staff gauges in a stable position. The proposed staff gauge locations coincide with the proposed surface water sampling locations as shown on Figure 10.

24 CONESTOGA-ROVERS & ASSOCIATES (1) 048354 (l) 24 CONESTOGA-ROVERS &ASSOCIATES

DRAFT 4.4 TASK 4 - SURVEYING After the new wells and any staff gauges are installed, the newly installed wells, staff gauges, and select existing wells will be surveyed relative to mean sea level. In addition, some CNS features or structures also will be surveyed for location and elevation to ensure accuracy with existing site plans.

The top of each well casing will be surveyed to the nearest 0.01 foot relative to the National Geodetic Vertical Datum (NGVD), and a survey point will be marked on the well casing or staff gauge. The survey will include the ground elevation at each well to the nearest 0.10 foot relative to the NGVD. The well location will be surveyed to the nearest 1.0 foot. A surveyor licensed in Nebraska will survey the location coordinates to proper Nebraska State Plane coordinates.

4.5 TASK 5 - INSTALLATION OF PERMANENT PUMPS CRA can install permanent pumps in each of the monitoring wells that will be part of the groundwater monitoring program. The type of pumps to be installed will be determined based on the information obtained during well drilling and construction. At this time, we recommend bladder pumps. The bladder pump is a widely used pump for low-flow sampling, which is the preferred sampling method. CRA can evaluate the use of other types of pumps and/or sampling methods as the project progresses (i.e., as the wells are installed we will learn more about the yield of the formation).

4.6 TASK 6 - HYDROLOGIC MEASUREMENTS CRA will collect hydrologic data during the implementation of the Work Plan. Synoptic depth-to-water measurements will be collected during the two proposed sampling events in all monitoring wells. Water level measurements will be collected using an electronic depth-to-water probe accurate to +/- 0.01 foot. The measurements will be made from the survey mark at the highest point on each well's inner riser or steel casing.

The depth-to-water will be converted to elevations based on the surveyed ground elevation at each well head. Any staff gauge measurements will be converted to elevations based on the surveyed elevation at each staff gauge. CRA's SOPs (Appendix E) will be followed during the implementation of this task.

048354(l) 25 CONESTOGA-ROVERS &ASSOCIATES

DRAFT 4.7 TASK 7 - GROUNDWATER SAMPLING CRA proposes two rounds of groundwater samples from the final groundwater monitoring network. Table 4 summarizes the locations and rationale for the collection of groundwater samples. The duration between the two sampling rounds should be approximately 90 days and will coincide with the Station REMP sampling to the extent possible.

Groundwater samples will be collected from overburden and bedrock wells using low-flow purge techniques in accordance with CRA's SOPs (Appendix E). CRA can use temporary pumps for this sampling event or install permanent pumps (see Section 4.5).

Currently, the two potable water supply wells are sampled for tritium quarterly.

Tritium has not been detected in any samples from these wells. A sampling program to include additional onsite water supply wells (e.g. The Fire Well and River Wells A and B) should be developed. The purpose of the program would be to capture potential unmonitored surface or subsurface level leakage. This sampling program will augment the early warning deep and shallow well sampling program, particularly for CST berm or shallow underground pipe leakage. Further, the sampling program will augment the Station's existing IE Bulletin 80-10 program to better demonstrate compliance with identification of unmonitored releases or contamination of radiological clean interface systems. CRA/Bartlett recommends sampling of proposed surface water sampling locations (see Section 4.8) concurrent with the groundwater sampling program.

All samples will be shipped to CNS' existing contract laboratory for analysis. Initial samples will be analyzed for the following parameters (to a minimum of the LLDs noted in Table 4.12-1 in NUREG 1302).

" Tritium (H-3)

Gamma spec parameters which include:

" Mn - 54

" Fe - 59

Co - 58

Co- 60

Zn - 65

" Zr-Nb-95 26 CONESTOGA-ROVERS & ASSOCIATES (1) 048354 (l) 26 CONESTOGA-ROVERS &AssocIATES

DRAFT

1-131 0 Cs - 134

Cs-137 0 Ba-La-140 Based on the results of the first sampling event, the parameter list may be modified for the second sampling event.

4.8 TASK 8 - SURFACE WATER AND STORMWATER SAMPLING The collection of surface water and stormwater samples is recommended in conjunction with the groundwater sampling events. Figure 10 depicts the proposed sample locations. Table 5 summarizes the proposed locations and rationale for the collection of these samples. Three surface water sample locations are proposed 1. Missouri River (upstream from the Intake Structure), 2. Discharge Canal, and 3. Missouri River (downstream from the Discharge Canal). Samples will be collected using the existing CNS grab sample techniques for surface water (CNS, 2007). The collection of stormwater samples from catch basins is proposed. All samples will be shipped to a contract laboratory for analysis. Initial samples should be analyzed for the same parameters as the groundwater samples. Sample analysis parameters for any additional round of sampling would be determined based on the results of the initial analysis.

CRA understands that the Station currently samples the Outfall #002 as part of its NPDES sampling program. The collection of a water sample from Outfall #002 is recommended in conjunction with the groundwater sampling events.

4.9 TASK 9 - PRECIPITATION CRA recommends that an on-site precipitation program be developed to monitor precipitation at the Station. The resulting data would provide a basis to understand the potential effects of rainfall on tritium releases via gaseous effluents, and its subsequent effects on the groundwater regime. Points of interest within the program may include condensate storage tank berms and surroundings and the sewage lagoons. Analytical data have shown trace levels of tritium in the Missouri River, which are deemed Station related (NPPD, 2007). These trace levels need further evaluation to determine their origin from either permitted liquid discharges, gaseous effluent washout in (deposition via) precipitation, or inadvertent leakage to groundwater. On-site precipitation 048354(l) 27 CONESTOGA-ROVERS &ASSOCIATES

DRAFT monitoring programs have been initiated at several nuclear facilities. CRA/ Bartlett can provide assistance in procurement of precipitation collectors, if requested.

4.10 TASK 10 - DATA ANALYSIS Following the completion of field activities, CRA/Bartlett will evaluate the data. This will include review and analysis of the newly acquired data collected under this Work Plan and relevant historical data. The latter will include groundwater, surface water and other tritium data collected under historical programs including REMP data and other routine monitoring programs.

The data will be reviewed using one or more of the following techniques (but not limited to):

Graphs (hydrographs and time versus concentration);

Isoconcentration maps;

Cross-sections;

Top of bedrock map;

Structural thickness maps;

Statistical analysis; and

Data trends.

4.11 TASK 11 - REPORTING Following completion of the scope of work, CRA will prepare a Hydrogeologic Investigation Report (HIR). Included in the HIR will be a revised SCM and a long-term Groundwater Monitoring Work Plan. The HIR will present the results of the field activities and the findings of the tritium investigation. The report will provide a long-term monitoring plan, including frequency of monitoring, sample locations, and methods. Further details regarding reporting and data validation are presented in Appendix G.

28 CONESTOGA-ROVERS & ASSOCIATES 048354 (1) 048354 (l) 28 CONESTOGA-ROVERS &ASSOCIATES

DRAFT 5.0 SCHEDULE Major project milestones for the Groundwater Protection Initiative are included in Appendix G.

Project milestones and their associated dates of completion cannot be ascertained until the Work Plan is reviewed and approved by all appropriate entities. Assuming Work Plan approval by October 31, 2007, it is anticipated that monitoring well installation activities will commence in fall 2007 and be completed by December 31, 2007.

Following monitoring well installation and development, two synoptic rounds of groundwater sampling are planned. The groundwater sampling events should be spaced apart a minimum of 90 days. Upon receipt of the second round of results all data will be reviewed and analyzed. The preliminary SCM contained herein will be revised as necessary, and a Hydrogeologic Report (including a long-term work plan) prepared with recommendations for further activities.

CRA/Bartlett will keep NPPD informed of the progress of all tasks as part of routine communications with Station personnel. In addition, CRA/Bartlett personnel and resources will be made available as needed for any additional stakeholder group (e.g.

NRC, Nebraska Department of Environmental Quality, USACE, etc.) meetings or conference calls. The schedule is subject to change based on future discussions with NPPD.

29 CONESTOGA-ROVERS & ASSOCIATES 048354 (1) 048354 (l) 29 CONESTOGA-ROVERS &AssocIATES

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COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA PROPOSED WELL AND SAMPLING LOCATIONS SCORMETOBA-ROVERS A ASSOCIATES

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DRAFT TABLE 1

SUMMARY

OF EXISTING WELL INVENTORY GROUNDWATER PROTECTION INITIATIVE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Stainless Steel Screen 55-River Well (A) NW of Fab Building Yes Yes No 75 10 75' bgs. Steel Casing 0 - 55' NA bgs Well logs not available. Information obtained from Nebraska Department of Stainless Steel Screen 51- Natural Resources website-River Well (B) NW of Fab Buildng Yes Yes No 75 10 71' bgs. Steel Casing 0 - 51' NA bgs Fire Well Adjacent to Fire No Yes No NA NA NA NA Well log not available.

Protection Tanks Along roadway west Potable Water Supply Well (#1)* of Tech Support Yes Yes No 62 NA NA NA Each well is designed for 250 gpm pumping capacity. Normal pumping rate Building is anticipated to be 125gpm with one well in service. Maximum short tern plant Along roadway west demand is approx. 250 gpm which is the Potable Water Supply Well (#2)* of Tech Support Yes Yes No 62 Unknown NA NA capacity of the plant Makeup Water Building Treatment System.

In Misc. Storage Area Screened 15-25' bgs- This monitoring well is slated for Piezometer B1 northeast of Training No No Yes 25 B Screened 1025'bgs- 15.4 bgs (9-26-06) destruction as construction is proposed at Building location.

Piezometer B12 North of Tech No No Yes 25 B Screened 15-25'bgs- 11' bgs (9-12-06)

Support Building Screened 10-25' bgs 6 Monitoring well is utilized in program to monitor facility groundwater levels.

Bartlett/CRA propose well be maintained and possibly used in tritium investigation for water levels at a minimum and possibly Southwest of Low- a sample collection point.

Piezometer B31 level Rad Waste No No Yes 25 B Scrned 15-25 bgs Unknown Storage Pad Screened 10-25' bgs-Notes:

1) NA - Not available.

2) bgs - below ground surface.

3) gpm - gallons per minute.

4) - Well numbers ate for information purposes only.

5) - Nebraska Department of Natural Resources website http://dnrdata.dnr.ne.gov.

6) - Final Report, Comprehensive Geo Investigation ISFSI Project (URS, 2006).

T-1 o4S354(l) PagelAof 1 CONESTOGA-ROVERS & ASSOCIATES

DRAFT TABLE 2

SUMMARY

OF AVAILABLE TRITIUM DATA GROUNDWATER PROTECTION INITIATIVE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Missouri River - Upstream (Station No. 28) Surface Water 2JD06 <LLD a LLD Missouri River - Downstream (Station No. 35) Surface Water 2006 <LLD a LLD Roof Runoff (NPDES 002A) Surface Water 6/2212006 1.40E-06 1,400 Roof Runoff (NPDES 002A) Surface Water 7/10f2006 1.46E-06 1,460 Roof Runoff (NPDES 002A) Surface Water 8/12006 1.40E-06 1,400 Roof Runoff (NPDES 002A) Surface Water 3/27)2007 4.35E-07 435 Roof Runoff (NPDES 002A)

Surface Water 4/112007 1.98E-06 1,980 Roof Runoff (NPDES 002A) Surface Water 4/25/2007 2.56E-06 2,560 Rain Ring Surface Water 5/4r2006 1.88E-06 1,880 Rain Ring Surface Water 6/12/2006 4.91E-06 4,910 Rain Ring Surface Water 7/19f2006 1.101-06 1,100 Rain Ring Surface Water 8/14/2006 < LLD < LLD Rain Ring Surface Water 11/4/2006 1.88E-06 1,880 Sewage lagoon Surface Water 5/5/2006 a LLD a LLD Sewage lagoon Surface Water 7/19,2006 2.16E-06 2,160 Sewage lagoon Surface Water 8/30)2006 < LLD < LLD Sewage lagoon Surface Water 9/20,2006 < LLD < LLD Sludge pond Surface Water 7/19/2006 < LLD < LLD Sludge pond Surface Water 3/14/2007 1.77E-06 1,770 Electical Sump (Security) Surface Water 9/20/2006 1.25E-06 1,250 Groundwater inleakage to Turbine Building foor Groundwater 5/15/2007 5.1E-06 5,180 B-11 test hole Groundwater 9/22/2006 4.91E-07 491 B-1 test hole Groundwater 11/1/2006 a LLD a LLD Plant w*ell water Groundwater 4/12/2006 a LLD < LLD Wall seepage into Rx 881' HPCI quad Groundwater 5/16/2007 5.80E-05 58,000 Stateon No. 11 ion-sile well) Groundwater 2006 a LLD a LLD Staton No. 47 (off-site well) Groundwater 2006 < LLD < LLD T-2 0482354 (1) P4ge1 of 2 CONE5TOGA-ROVERS& ASSOCIATES

DRAFT TABLE 2

SUMMARY

OF AVAILABLE TRITIUM DATA GROUNDWATER PROTECTION INITIATIVE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Wall seepage ARW pipe gallery Water 5/17/2007 3.83E-07 1 383 Mystery pipe TG 882' Water 4/12/2006 < LLD LLD Circ water Water 6116/2006 7.88E-07 788 Circ water Water 8/14/2006 1.07E-06 1,070 REC A service water Water 711912006 2.60E-05 2,600 DI water Water 4/12/2006 < LLD < LLD DI water Water 5/26/2006 5.23E-07 523 DI water Water 6/22/2006 < LLD < LLD DI water Water 7/26/2006 2.25E-08 22.5 DI water Water 8/24/2006 3.38E-07 338 Notes:

1. ODAM Low Limit for Detection for Ground Mter is 1E-6 uci/cc.

2. ODAM Low Limit Detecton for Surface water is 1E-5 ud/cc.

3. Chemistry counting on the Packard Liquid Scinillation analyzer low limit deltection is considered 5E-7ucid/ or 500 pciAiter.

4. Data as listed above, LLD references less than or equal to background.

5. uCi/cc - Microcuies per cubic centimeter (equivalentto uCi/L).

6. pCi/L - Picocuries per Liter.

7. 1 uCi = 1,000,000 pCi.

8. * - Various dates; quarterly samples from January until May 2006 then monthly until December 2006.

9. Station No. 11- On-Site water supply well.

10. Station No. 28 - Surface water from Missouri River, I to 3 miles upstream of intake structure.

11. Station No. 35 - Surface water from Missouri River, 1/4 to 3 miles downstream of Station.

12. Station No. 47 - Off-site well, approximately xx miles southwest of Station.

13. Values shown in bold indicate result exceeds the EPA drinking water standard of 20,000 pCi/L.

T-2 D48354 (1) P0ge 2 4f02 CONE5=OA-ROVERS & ASSOCIATE5

DRAFT TABLE 3

SUMMARY

OF AREAS FOR FURTHER EVALUATION (AFE)

GROUNDWATER PROTECTION INITIATIVE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Condensate Storage Tank North-northwest of Reactor Fire Well and River Yes, from Rain Ring 1 None None <LLD to 4,910 2006 *

(CST) - North Building Wells A and B surrounding CST Major Buidling Structures South of Reactor Buildings /

2 (Reactor, Turbine, East of Diesel Storage Tank None None None Yes < LLD to 5,180 2006 / 2007*

Radwaste, and MPF Area Buildings)

NPDES Outfal1 002 North of Radwaste Building Yes (surface 3 running west to east then None None None water[roof< LLD to 2,560 2006/ 2007 Discharge southeast to River discharge Inside Radwaste Building through Turbine Building, 4 Radwa Dischage Line down and under adjacent None None None No Radwaste Discharge Line buildingeast of Turbine Building and exiting into Seal Well south of Diesel Tank area Southeast of Turbine Condensate Sth Building/East of Reactor None None None No (CST) - Southuilding T-3 048354 (l) Page I of 2 CONESTOGA-ROVERS & ASSOCIATES

DRAFT TABLE 3

SUMMARY

OF AREAS FOR FURTHER EVALUATION (AFE)

GROUNDWATER PROTECTION INITIATIVE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Southeast of Turbine Elevated Release Point 6 Building/East of Reactor None None None No (ERP) Sump Building Various Locations No (sample collected 7 Catch Basins None None None from electrical vault- NA NA (see Figure 8) See Table 1)

South of Reactor Buildings /

8 Condensate Loop North of Diesel Storage Tank None None None No -

Area High Pressure Core . Southwest corner of Reactor Yes, from High P Cor Southwes corne None None None groundwater in- 58,000 5/16/2007 Injection (HPCI) Building Building leakage Notes:

1. NA - Not available

2. * - Various dates.

3. pCi/L - picocuries per liter.

4. " - Analysis at CNS, complete QA/QC not applied to said sample.

T-3 048354 (l) Page 2 of 2 CONESTOGA-ROVEM & MSOCIAnS

DRAFT TABLE 4 PROPOSED MONITORING WELL LOCATIONS AND RATIONALE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Upgradient overburden monitoring well for hydraulic control Misc. Storage Area and to monitor background conditions. Piezometer B-1is AFE #1 and #2 MW-1 S northwest of Condensate No Overburden 30-40 located nearby; however, it was noted that the piezonseter is (Upgradient)

Storage Tank-North slated to be abandoned. Ability to establish vertical hydraulic gradient (with MW-ID).

Completed 10 to Upgradient bedrock well for hydraulic control and to monitor Misc. Storage Mic trg Area ra AFE #1,noAPE #2 C t 15 MW-ID s of rto 15 feet fetBeinto background conditions. Piezometer B-1 is located nearby; D northwest St-1 of Condensate (Upgradent) edrock however, it was noted that the piezometer is slated to be Storage Tank-North 80-best. abandoned. Ability to establish vertical hydraulic gradient (with (est. 80- 100 bgs) MW-1S). 1st bedrock hydraulic control point.

160 fret southeast of -Shallowoverburden monitoring well for hydraulic control and M1-2 S Condensate Storage Tank AFE #1 Yes Overburden 30-40 to monitor potential releases for tritium from noted AFEs.

(North) Presumed downgradient position relative to Condensate Storage Tank-North (AFE #1). 2nd overburden hydraulic control point.

Shallow overburden monitoring well for hydraulic control and 50 feet north of to monitor potential releases for tritium from noted AFEs.

MW-3 S Augmented Radwaste AFE #2, AFE #7 No Overburden 30-40 Located nearby AFE#2, Radwaste Building and storm catch Building basin. A release to the surface outside the building door has been documented. 3rd overburden hydraulic control point.

Shallow overburden monitoring well for hydraulic control and to monitor potential releases for tritium from noted AFEs.

50 feet east of Turbine Location to AFE#2, Turbine Building. Groundwater has MW-4 S Building AFE #2, AFE #6 Yes Overburden 30-40 infiltrated basement structures in Turbine Building. Tritium has been detected in samples collected from basement. Ability to establish vertical hydraulic gradient (with MW-4D). 4th overburden hydraulic control point.

Downgradient bedrock monitoring well for hydraulic control and to monitor for potential releases for tritium from noted AFEs. Location to AFE#2, Turbine Building. Located in 50 feet east of Turbine APE~~omlee YsBdokito

20 AP 6 1 etit dowogradlient position relative to main structures and APEs.

M-4 D 50Bfee Tuld inb AFE #2oAFE #6 Yes Bedrock betro 2nd bedrock hydraulic control point. Groundwater has (est. 80 - 100 bgs) infiltrated basement structures in Turbine Building. Tritium has been detected in samples collected from basement. Ability to establish vertical hydraulic gradient (with MW-4S). 2nd bedrock hydraulic control point.

T4 048354(l) PagelSof 2 CONESTOGA-ROVERS & ASSOCIATES

DRAFT TABLE 4 PROPOSED MONITORING WELL LOCATIONS AND RATIONALE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Downgradient overburden well for hydraulic control and to 125 feet southeast of the AFE# AFE #4, APE monitor potential releases for tritium from noted AFEs. Location MW-5 S southeast corner of the # Yes Overburden 30-40 to AFE #2. Turbine Building and AFE #4, Radwaste Discharge Main Shop Building Building, and AFE #5, Condensate Storage Tank-South. 5th overburden control point.

30 feet west of northwest Downgradient overburden well for hydraulic control and to MW-6 S comer of Fuel Oil Storage AFE #2 and AFE #8 Yes Overburden 30-40 monitor potential releases for tritium from noted AFEs. Location Tank to AFE #8, Condensate Loop. 6th overburden control point.

Farthest downgradient overburden monitoring point on Station 250 feet south of Elevated property. Approximately 250 feet sidegradient/downgradient MW-7 S Release Tower AFE #6 No Overburden 30-40 from AFE#6, Elevated Release Point Sump. 7th overburden hydraulic control point. Ability to establish vertical hydraulic gradient (with MW-7D). 7th overburden control point.

Downgradient bedrock monitoring well for hydraulic control Completed 10 to and to monitor potential releases for tritium. Farthest MW-7 D Release Tower AFE #6 No feet into 15bedrk downgradient bedrock monitoring point on Station property.

Bedrock Approximately 250 feet sidegradient/downgradient from AFE#6, Elevated Release Point Sump. Ability to establish (est. 80 - 100 bgs) vertical hydraulic gradient (with MW-7S). 3rd bedrock control point.

Downgradient overburden monitoring well for hydraulic control

- Adjacentto southwest and to monitor potential releases for tritium from noted AFE.

MW-8 coer of HPCI Building AFE #9 Yes Overburden 30-40 Close location to AFE #9, subgrade infiltration historically noted, preliminary data indicated tritium impact. 8th overburden control point.

T-4 G48354 (1) Page 2 of 2 CONESTOGA-ROVERS & ASSOCIATES

DRAFT TABLE 5 PROPOSED SURFACE WATER SAMPLING LOCATIONS GROUNDWATER PROTECTION INITIATIVE NEBRASKA PUBLIC POWER DISTRICT COOPER NUCLEAR STATION BROWNVILLE, NEBRASKA Sample location to evaluate Missouri River Upstream from Intake Structure No upgradient/upstream background water quality.

Missouri River Downstream from Station discharge points No Sample location to evaluate water quality downstream.

Sample location to evaluate water quality at Discharge Canal (Seal Well) Middle to end of discharge canal (depending on Yes end of discharge canal prior to River logistics and safety) discharge. Evaluate any potential groundwater-to-discharge canal pathway.

Sewage Lagoon (East) South of Reactor Building No Sample location to evaluate surface water body and potential for precipitation fallout.

Sewage Lagoon (West) South of Reactor Building No Sample location to evaluate surface water body and potential for precipitation fallout.

Outfall 002A East of Turbine Building along bank of Missouri Sample location to evalaute exisitng surface River No water-to-groundwater pathway concurrent with groundwater sampling events.

Sample locations to evalaute exisitng Basins Various locations across Station (see surface water-to-groundwater pathway Figure 10) concurrent with groundwater sampling events.

T-5 04835(l) PageNS of 1 CONESTOGA-ROVERS & ASSOCIATES

Enclosure 3.1 to Attachment 1 EPA RCRA ID No. IAD020201604 Issued to Jebro Inc.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 7 *ppo' REGION VII 726 MINNESOTA AVENUE KANSAS CITY, KANSAS 66101 iL82 1 i996 Mr. Michael Marlow Jebro Inc.

2303 Bridgeport Drive Sioux City, Iowa 51111

Dear Mr.Marlow:

RE: Jebro Inc.

2303 Bridgeport Drive Sioux City, Iowa EPA RCRA ED No. IAD020201604 This is to acknowledge that you have filed a Notification of Regulated Waste Activity for the installation' located at the address shown above to comply with Section 3010 of the Resource Conservation and Recovery Act (RCRA).

Your Environmental Protection Agency (EPA) RCRA Identification Numbef for the referenced installation appears above. This EPA RCRA ID Number must be included on all shipping manifests for transporting hazardous wastes; on all Biennial Reports that generators of hazardous waste, and owners and operators of hazardous waste treatment, storage and disposal facilities, must file with EPA; on all applications for a Federal Hazardous Waste Permit; and other hazardous waste management reports and documents required under Subtitle C of RCRA.

We hope the enclosed information will be of use to you. If you have any questions regarding this letter, please call our Iowa RCRA Hazardous Waste Inquiry Helpline, (913) 551-7861 or the Region VII Toll-Free Hot Line, 1-800-223-0425.

Sincerely, Harriett L. Jones Permits Team Leader Iowa RCRA and State Programs Branch Air, RCRA, and Toxics Division Enclosures cc: Joseph Obr, Iowa Department of Natural Resources (w/o encl)

RECYCLE**

Enclosure 4.1 to Attachment 1 State of Utah Operating Plan/Permit Approval I to Envirocare of Utah, Inc.

STATE OF UTAH PLAN APPROVAL April 4, 2003 PERMITTEE:

Envirocare of Utah, Inc.

Tooele County, Utah EPA Identification Number UTD 982598898 Pursuant to the Utah Solid and Hazardous Waste Act, 19-6-101, et. Seq., Utah Code Annotated 1953, as amended, and the regulations promulgated there under by the Utah Solid and Hazardous Waste Control Board, codified in the Utah Administrative Code R315, and pursuant to the Solid Waste Disposal Act, 42 U.S.C. 3251 et. sec., as amended by the Resource Conservation and Recovery Act of 1976, 42 U.S.C. 6901 et. sec., and the Hazardous Waste Amendments of 1984 (HSWA), a plan approval (hereinafter called a Permit), is issued to Envirocare of Utah, Inc.

(hereinafter referred to as the Permnittee), to operate a hazardous waste treatment, storage, and.

disposal facility in Tooele County, Utah at latitude 400 41' 000" North and longitude 1130 06' 030" West.

The Permittee shall comply with all the terms and conditions of this Permit. The Permit consists of Modules I through VII, and associated Attachments. The Permittee shall also comply with all applicable State rules, including R315-1 through R315-9, R315-12 through R315-14, R315-16, R315-50, and R315-101.

Applicable rules are those that are in effect on the date of issuance of this Permt and any self-implementing provisions and related rules that, according to the requirements of HSWA, are automatically applicable to the Permittee's hazardous waste management activities, notwithstanding the conditions of this Permit.

This Permit is based on the premise that the information submitted in the original permit application dated July 22, 1987 as modified by subsequent amendments, permit modification requests received throughout the term of the original permit, the pemut renewal application received October 28, 1999, as modified by the submission of subsequent amendments, is accurate. The Permittee's failure in the application or during the permit issuance process to disclose fully all relevant facts, or the Permittee's misrepresentation of any relevant facts at any time, may be cause for the termination or modification of this Permit, the initiation of enforcement action, including criminal proceedings, or any combination to these remedies. The Permittee shall inform the Executive Secretary of the Utah Solid and Hazardous Waste Control Board (the Executive Secretary) of any deviation from or changes in the information on which the application was based which would affect the Permittee's ability to comply with the terms and conditions of this Permit. The Executive Secretary will enforce all terms and conditions of this Permit. Any challenges to any condition of this Permit shall be appealed to the Utah Solid and Hazardous Waste Control Board in accordance with the applicable provisions of the Utah Code Annotated.

)

This Permit is effective as of April 4, 2003, and shall remain in affect until April 4, 2013, unless revoked and reissued pursuant to R315-3-4.2, terminated pursuant to R315-3-4.4, or continued in accordance with R315-3-5, and the conditions of this permit.

Signature: Date: &A 2 oc-Dennis R. Downs Executive Secretary Utah Solid and Hazardous Waste Control Board

Utah!

Where ideas connect Department of Environmental Quality Division of Solid and Hazardous Waste Michael 0 Leavitt 288 North 1460 West Governor P 0 Box 144880 Dianne R Nielson, Ph D Salt Lake City, Utah 84114-4880 FxecuiiVe Director (801) 538-6170 Dennis R Downs (801) 538-6715 Fax Direcor (801) 536-4414 T D D www deq utah gov April 4, 2003 Dwayne 0 Nielson, President Envirocare of Utah, Inc.

605 North 5600 West Salt Lake City, Utah 84116

Subject:

Mixed Waste Facility; State-issued Part B Permit Renewal Dear Mr Nielson On October 28, 1999, Envirocare of Utah, Inc , submitted an application to the Utah Division of Solid and Hazardous Waste to renew its State-issued Part B (muxed waste) Permit. The current permit for the Envirocare Mixed Waste Facility was issued November 30, 1990, and expired November 30, 2000. By rule, the facility was allowed to continue operations under the existing permit until final action was taken

_ on the renewal application A draft permit for the Envirocare of Utah, Inc Mixed Waste Facility was made available for public review and public comment. The comment period ended on September 27, 2002. Comments were received during this period. The Division of Solid and Hazardous Waste reviewed the permit renewal application, in light of the public comments, and thereafter requested that Envirocare make appropriate revisions to portions of the renewal application After reviewing the revisions and supporting information, the draft permit was reissued for public comment This comment period ended on March 14, 2003.

The Executive Secretary has now determined that the pernut renewal application is complete and acceptable and hereby reissues the Envirocare of Utah, Inc , State-issued Part B Permit Envirocare shall replace the expired permut with this reissued permit. The effective date of the reissued permit shall be April 4, 2003, and shall remain in effect for a period of 10 years, and shall expire on April 4, 2013.

Enclosed is a copy of the reissued permit, excluding drawings If you have any questions regarding this letter, please contact Otis Willoughby at 538-6170.

Sinc fely, ennis R. Do ExecutiveSecretary Utah Solid and Hazardous Waste Control Board DRD\OHWIts c: Bill Sinclair, UDRC Terry Brown, EPA Myron Bateman, E.H.S., M.P.A., Health Officer Tooele County Health Department

Enclosure 4.2 to Attachment 1 EnergySolutions Bulk Waste Disposal and Treatment Facilities Waste Acceptance Criteria, Revision 7

ENERGYSOLUTIONS Bulk Waste Disposal and Treatment Facilities Waste Acceptance Criteria Revision 7 (Includes Class A LLRW, Mixed Waste, and lle.(2) Disposal Embankments) k I

Corporate Office Disposal and Treatment Facility 423 West 300 South, Suite 200 Interstate 80, Exit 49 Salt Lake City, UT 84101 Clive, UT 84029 Phone: (801) 649-2000 Phone: (435) 884-0155 Fax: (801) 537-7345 Fax: (435) 884-3549

TABLE OF CONTENTS SECTION 1 INTRODUCTION 1.1 P U RPO S E ........................................................................................................................................ I 1.2 S CO PE ............................................................................................................................................. 1 1.3 R ESPON SIB IL ITIE S ...................................................................................................................... 2 SECTION 2 SITE AND FACILITY DESCRIPTION 2.1 SELECTION OF THE CLIVE DISPOSAL SITE LOCATION ................................................. 3 2.2 LICENSES, PERMITS, AND AUTHORIZATIONS ................................................................. 3 2.3 SITE LOCATION AND ACCESS .............................................................................................. 4 2.4 DISPOSAL AND TREATMENT FACILITIES ......................................................................... 4 2.5 ALARA CRITERIA FOR THE BULK WASTE AND TREATMENT FACILITIES ............... 7 SECTION 3 WASTE CRITERIA 3.1 ACCEPTABLE RADIOACTIVE WASTES ............................................................................ 10 3.1.1 Class A Low-Level Radioactive Waste ....................................................................... 10 3.1.2 N O RM /N ARM W aste .................................................................................................. 14 3.1.3 Class A Mixed Low-Level Radioactive Waste ................................................................. 14 3.1.3.1 Acceptable Hazardous Waste Codes ............................................................ 14 3.1.3.2 LDR Compliant Mixed Waste ..................................................................... 15 3.1.3.3 Mixed Waste Requiring Treatment ............................................................... 15 3.1.4 11 e.(2) B yproduct M aterial ............................................................................................ 18 3.1.4.1 Radionuclide Concentration Limits .............................................................. 18 3.1.4.2 Acceptable Forms of 1le.(2) Byproduct Material ......................................... 19 3.1.4.3 Certification of 11 e.(2) Byproduct Material .................................................. 19 3.1.4.4 Shipping Paperwork for I le.(2) Byproduct Material .................................. 19 3.1.5 Special N uclear M aterial .............................................................................................. 20 3.1.5.1 Condition I - Percent Enrichment of Uranium-235 ..................................... 20 3.1.5.2 Condition 2 - Specified Limits for Waste Containing SNM ........................ 21 3.1.5.3 Condition 3 - Characterization of Waste Containing SNM ......................... 23 3.1.5.4 Condition 4 - Generator's Certification ....................................................... 24 3.1.6 Polychlorinated Biphenyl (PCB) Radioactive Waste .................................................... 24 3.1.6.1 PCB Remediation Waste .............................................................................. 25 3.1.6.2 PCB Bulk Product Waste .............................. .............................................. 26 3.1.6.3 PC B Articles ................................................................................................ 26 3.1.6.4 PC B C ontainers ................................................................................................ 28.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities Revision 7 Waste Acceptance Criteria

3.1.7 UCNI and Export Controlled Waste ............................................................................ 28 3.1.8 C helating A gents ............................................................................................................... 28 3.1.9 A sbestos and B eryllium ................................................................................................ 28 3 .1.10 L ab P acks .......................................................................................................................... 29 3.2 ACCEPTABLE FORMS OF RADIOACTIVE WASTE .......................................................... 29 3.2.1 Soil or Soil-Like W astes ............................................................................................... 29 3.2 .2 D eb ris ................................................................................................................................ 30 3.2.2.1 Standard Size D ebris ....................................................................................... 30 3.2.2.2 Oversize Debris and Large Components ................................. 30 3.2.3 G aseous W aste .................................................................................................................. 32 3.2.4 Waste Containing Free Liquids .................................... :............................................... 32 3.3 PROHIBITED RADIOACTIVE AND MIXED WASTE ........................................................ 33 SECTION 4 WASTE ACCEPTANCE PROCESS 4.1 WASTE PROFILING PROCESS .............................................................................................. 34 4.2 WASTE CHARACTERIZATION ........................................................................................... 34 4.3 RADIOACTIVE WASTE PROFILE RECORD ........................................................................ 36 4.3.1 Generator and Waste Stream Information ................................................................... 36 4.3.2 Waste Physical Properties and Packaging ................................................................... 37 4.3.3 Radiological Inform ation .............................................................................................. 37 4.3.4 Chemical Composition and Hazardous Waste Evaluation ........................................... 39 4.3.5 Special Nuclear Material Exemption Certification Form ............................................. 41 4.3.6 PCB Waste Certification Form ........................................................................... ;............. 41 4.4 TREATABILITY AND SOLIDIFICATION STUDY SAMPLES ........................................... 41 4.5 WASTE PROFILE REVIEW AND APPROVAL ................................................................... 42 4.6 NOTICE TO TRANSPORT .......................................................................................................... 43 SECTION 5 SHIPMENT SCHEDULING AND MANIFESTING 5.1 GENERATOR SITE ACCESS PERMIT ................................................................................... 44 5.2 SH IPPIN G C HE C K LIST ............................................................................................................... 44 5.3 5 WORKING-DAY ADVANCED SHIPMENT NOTIFICATION ......................................... 44 EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities Revision 7 Waste Acceptance Criteria

5.4 SH IPPIN G PA PER W O RK ............................................................................................................ 46 5.4.1 Instructions for the Uniform LLRW Manifest Forms 540, 541, and 542 ..................... 46 5.4.2 Electronic Submittal of the Uniform LLRW Manifest ................................................ 48 5.5 90-DAY SHIPPING FORECAST .............................................................................................. 48 SECTION 6 PACKAGING AND TRANSPORTATION 6.1 COMPLIANCE WITH TRANSPORTATION REGULATIONS ............................................ 49 6.2 WASTE PACKAGING GUIDELINES ................................................................................... 49 6.2.1 Bulk Packaging ................................................................................................................. 49 6.2.2 Non-bulk Packaging (Disposal Containers) .................................................................. 50 6.3 HIGHWAY TRANSPORTATION ........................................................................................... 52 6.4 RA IL TRA N SPORTA TION ......................................................................................................... 53 6.5 RELEASE OF SHIPPING CONVEYANCES .......................................................................... 53 APPENDIX A CONTACT INFORMATION EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 111 Revision 7 Waste Acceptance Criteri a

SECTION 1 INTRODUCTION 1.1 PURPOSE EnergySolutions has developed this Bulk Waste Disposal and Treatment Facilities - Waste Acceptance Criteria (BWF WAC) document to assist waste generators and their contractors by providing information about the capabilities and requirements of EnergySolutions' disposal and treatment facilities.

EnergySolutions is authorized to receive:

Class A Low-Level Radioactive Waste (LLRW)

" NORM/NARM

" Class A Mixed LLRW (i.e., radioactive and hazardous)

11 e.(2) Byproduct Material

PCB Radioactive, and

" Other various forms and types of radioactive wastes The BWF WAC provides information on EnergySolutions' waste acceptance processes including:

Waste characterization and profiling,

Pre-shipment sampling and analysis,

Waste packaging, transportation and delivery,

" Waste receipt, verification sampling and acceptance, and

Waste treatment and disposal These waste acceptance criteria collectively pertain to the Bulk Waste and Treatment Facilities which are described in detail below. The BWF WAC does not apply to EnergySolutions' Containerized Waste Facility (CWF). Please refer to the CWF WAC which can be downloaded from EnergySolutions' website at www.energysolutions.com.

1.2 SCOPE Numerous state and federal agencies regulate the management, transportation, treatment and disposal of radioactive and hazardous materials. This document provides guidance on EnergySolutions' waste acceptance process and should be used in conjunction with current copies of EnergySolutions' licenses, permits and applicable state and federal regulations. These license, permits, and regulations take precedence over any information contained in this document. Generators may request variances from the BWF WAC on a case-by-case basis. EnergySolutions will evaluate such requests and provide written notification to the generator if the variance is approved.

EnergySolutions' licenses and permits along with links to applicable parts of the Utah Radiation Rules are included on EnergySolutions' website at www.energysolutions.com. In addition, Appendix A of this document contains a list of contact information for both EnergySolutions and the State of Utah. For additional information, representatives of EnergySolutions' Business Development Department are available to answer any questions and can be contacted at (801) 649-2000.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities Revision 7 Waste Acceptance Criteria

1.3 RESPONSIBILITIES The generator is responsible to characterize, classify, schedule, manifest, package and transport waste shipments to EnergySolutions' disposal facility in accordance with the BWF WAC, licenses, permits, and applicable state and federal regulations. For waste classification, generators must have in place a quality control program to ensure compliance with the waste classification requirements. The generator or authorized representative must complete and submit a Radioactive Waste Profile Record to EnergySolutions for review and approval prior to shipment. Additional forms and certifications may also be required such as the Special Nuclear Material Exemption Certification, the PCB Waste Certification, and the Land Disposal Restriction Notification and/or Certification. Section 4 details the waste profiling process. The generator or authorized representative should be available to resolve issues that arise associated with waste shipments.

EnergySolutions is responsible to safely and compliantly receive, treat (if applicable), and dispose of waste shipments in accordance with all applicable permits, licenses, and regulations. EnergySolutions will provide disposal and/or treatment certificates upon request from the generator. In addition, EnergySolutions will contact the generator to resolve non-conforming waste shipments or discrepancies with the contractual terms and conditions associated in accordance with the receipt and management of waste shipments.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities Revision 7 Waste Acceptance Criteria

SECTION 2 SITE AND FACILITY DESCRIPTION 2.1 SELECTION OF THE CLIVE DISPOSAL SITE LOCATION The initial selection of the EnergySolutions disposal site location dates back to the late 1970s when the Department of Energy (DOE) and the State of Utah began the cleanup of an abandoned uranium mill site.

The Vitro mill site, located in central Salt Lake City, was one of the first sites cleaned up under the DOE Uranium Mill Tailings Remediation Action (UMTRA) Program.

The DOE investigated 29 sites to identify the safest permanent disposal site for these materials. After eight years of characterization and evaluation of several sites, the DOE selected the Clive site located in Utah's West Desert approximately 75 miles west of Salt Lake City. The site's remote location, low precipitation, naturally poor groundwater, and low-permeability clay soils were some of the attractive qualities of the area.

From 1984 to 1988, the Vitro tailings were relocated to Clive and placed in an above-ground disposal cell.

Since acquiring land adjacent to the Vitro disposal embankment and obtaining a disposal license, the vision of EnergySolutions' Clive facility has been to provide a private disposal option for material from cleanups and generators of radioactive waste in separate disposal embankments similar to those used for DOE's Vitro project. The Clive site has received waste from cleanups carried out across the country including projects by the Environmental Protection Agency (EPA), DOE, Department of Defense, and private companies. The initial disposal license was for Naturally Occurring Radioactive Material (NORM). Since 1988, EnergySolutions' Radioactive Material License (RML) has been amended several times, expanding the types of radioactive materials to include low-level radioactive waste (LLRW), in addition to NORM.

2.2 LICENSES, PERMITS, AND AUTHORIZATIONS EnergySolutions is permitted, licensed, and authorized to receive, treat, and dispose Class A LLRW, NORM/NARM, Class A Mixed LLRW, 1le.(2) Byproduct Material, Special Nuclear Material based on concentration limits, as well as Polychlorinated Biphenyl (PCB) Radioactive Waste, and PCB Mixed Waste in accordance with the following documents:

Radioactive Material License (RML) Number UT 2300249, as amended

" Class A LLRW as defined in Utah Administrative Code R313-15-1008

" Class A Mixed LLRW (radioactive and hazardous)

" NORM/NARM

Special Nuclear Material (concentration based limits) 1 le.(2) Byproduct Material License Number UT 2300478, as amended

1le.(2) Byproduct Material as defined by the Atomic Energy Act, as amended State-Issued Part B Permit Number UTD982598898, as amended

Storage, treatment, and disposal of Mixed Waste

" Authorizes disposal of specific types of PCB regulated waste in the Mixed Waste disposal facility EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 3 Revision 7 Waste Acceptance Criteria

Groundwater Quality Discharge Permit Number UGW450005, as amended

Authorizes disposal of specific types of PCB regulated waste in the Class A LLRW disposal facility

> Special Nuclear Material (SNM) Exemption Order issued by the NRC, as amended

Authorizes receipt, storage, treatment, and disposal of waste containing SNM based on concentration limits rather than mass limits

> TSCA Coordinated Approval issued by the EPA Region 8, as amended

PCB Radioactive and PCB Mixed Waste (40 CFR Part 761)

Section 3 details the various waste types and waste forms that are acceptable at EnergySolutions. Waste streams that are subject to multiple regulations must meet the requirements for each applicable regulation.

2.3 SITE LOCATION AND ACCESS EnergySolutions' operations are conducted on and adjacent to Section 32, Township 1 South, Range 11 West, SLM, Tooele County, Utah. The facility is about 75 miles west of Salt Lake City and about three miles south of Interstate 80, Exit 49. The site is conveniently accessed by both highway and rail transportation.

The disposal site mailing address is:

EnergySolutions LLC Clive Disposal Site Interstate 80, Exit 49 Clive, UT 84029 (84083 if using Fed Ex)

Phone: (435) 884-0155 EnergySolutions receives waste shipped via bulk truck, containerized truck, enclosed truck, bulk railcars, rail boxcars, and rail intermodals. The transportation access allows EnergySolutions to operate throughout the entire year. The disposal site is accessed by the Union Pacific Railroad at EnergySolutions' private siding. EnergySolutions uses more than ten miles of track and three locomotives for railcar management. Covered railcar rotary dumper and covered railcar decontamination facilities allow for the efficient unloading, decontamination and return of rail shipments.

2.4 DISPOSAL AND TREATMENT FACILITIES The design and operation of the EnergySolutions disposal site provides a long-term disposal solution with a minimal need for active maintenance after closure. EnergySolutions uses an above-ground engineered disposal cell. The design of these cells is patterned after DOE and EPA specifications for the VITRO disposal embankment. Each licensed disposal embankment meets or exceeds the applicable regulatory requirements.

Figure 2-1 shows the locations of EnergySolutions' waste treatment, disposal, and operations areas at the Clive facility. EnergySolutions' waste operations are managed as three facilities:

"Bulk Waste Facility" (BWF) - including Mixed Waste, LARW, 1le.(2) and Class A LLRW

" "Containerized Waste Facility" (CWF) - located within the Class A LLRW area

" "Treatment Facility" (TF) - located in the southeast corner of the Mixed Waste area EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 4 Revision 7 Waste Acceptance Criteria

Figure 2-1. EnergySolutions' Disposal and Treatment Facilities Bulk Waste Facility Waste shipped for direct disposal that is compliant with the ALARA Criteria described below is managed at EnergySolutions' Bulk Waste Facility (BWF). Such waste is either removed from the container or filled with a grout-like mixture to minimize void spaces. Waste that is removed from the shipping container is typically compacted into 12-inch soil lifts. Waste that consists of debris items that do not have a dimension small enough to be compacted into the 12-inch soil lifts are disposed of using grout in a different disposal area within the BWF. Waste is directly disposed at the Class A LLRW, Mixed Waste, or I Ie.(2) disposal embankments. Bulk containers (e.g., intermodals, gondolas, etc.) and non-bulk containers (e.g., drums, boxes, etc.) are acceptable for receipt at the BWF.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 5 Revision 7 Waste Acceptance Criteria

The Bulk Waste Facility (BWF) includes the following disposal embankments and structures:

Class A LLRW and NORM disposal embankment

" 11 e.(2) Byproduct Material disposal embankment

Mixed Waste disposal embankment for LDR compliant solid waste

Intermodal unloading facility for unloading and staging bulk waste shipments for disposal

Railcar Rollover facility for unloading and staging bulk waste shipments for disposal

Rail Wash Facility for decontamination, surveying, and releasing of railcars

Container Wash Facility for decontamination, surveying and releasing of bulk containers Containerized Waste Facility Waste shipped for direct disposal exceeding EnergySolutions' ALARA Criteria is managed at the Containerized Waste Facility (CWF). Waste must be packaged in disposal containers (e.g., drums, boxes, liners, etc.) instead of bulk containers (e.g., intermodals, gondolas, etc.) for shipments to the CWF since EnergySolutions will not remove such waste from its container due to the elevated dose rates. Please refer to EnergySolutions' CWF WAC for information on shipping waste to the CWF.

Shipments to the CWF typically are shipped in a shielded transportation package such as a cask as illustrated in Figure 2-2.

Figure 2-2. Cask Shipment at the Containerized Waste Facility Treatment Facility Waste shipped to EnergySolutions for treatment or liquid solidification prior to disposal is managed at EnergySolutions' Treatment Facility. The Treatment Facility is shown in Figure 2-1 as "TF". The EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 6 Revision 7 Waste Acceptance Criteria

Treatment Facility is designed for radioactive waste that requires treatment for RCRA constituents and for liquid radioactive wastes requiring solidification prior to disposal. EnergySolutions' Mixed Waste treatment and solidification capabilities include:

" Chemical Stabilization - Including oxidation, reduction, neutralization and deactivation.

Amalgamation - For the treatment of elemental mercury.

" Macroencapsulation - For the treatment of radioactive lead solids, RCRA metal-containing batteries and hazardous debris.

" Microencapsulation - To reduce the leachability of hazardous constituents in mixed wastes that are generally dry, fine-grained materials such as ash, powders or salts.

Liquid Solidification - For the solidification of radioactively contaminated liquids such as aqueous solutions, oils, antifreeze, etc. to facilitate land disposal. Mixed waste liquids can also be treated and solidified at the Treatment Facility.

" Vacuum Thermal Desorption of Organic Constituents - For the thermal segregation of organic constituents from wastes including wastes with PCBs. Waste containing PCB liquids is also acceptable for VTD treatment. The organic liquid condensate must be treated prior to final disposal. The non-liquid waste residue will be further treated for metal contaminates (if required) and disposed at the Mixed Waste embankment.

Debris Spray Washing - To remove contaminants from applicable hazardous debris.

Each of these treatment technologies are discussed in further detail in Section 3.1.3.

Currently, all waste processed at the Treatment Facility are disposed in the Mixed Waste disposal embankment. The Treatment Facility includes open and covered waste storage areas for storing, sampling, and staging Mixed Waste shipments, including the following buildings and areas:

" Mixed Waste Operations Building

Mixed Waste Treatment Building

" Liquids Storage Building

Mixed Waste storage, staging and sampling areas 2.5 ALARA CRITERIA FOR THE BULK WASTE AND TREATMENT FACILITIES EnergySolutions has implemented an "As Low As Reasonably Achievable" (ALARA) Criteria to minimize worker exposures. The ALARA Criteria is not a license condition but is used as the primary distinction between waste that is acceptable for direct disposal at the BWF and CWF. Wastes with higher dose rates exceeding the ALARA Criteria are disposed at the CWF where waste packages are directly disposed without sampling and actual waste handling. Conversely, wastes with dose rates less than the EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 7 Revision 7 Waste Acceptance Criteria

ALARA Criteria may be disposed at the BWF since the waste is sampled and, in most cases, removed from the shipping container.

As shown in the table below, these ALARA Criteria define allowable external contact dose rates and loose surface contamination limits for waste managed at the BWF.

Removable Surface Contamination External Contact Dose Rate On Exterior Surfaces of Debris 2

< 200 mR/hr on manifested container < 500 dpm a/100 cm 2

< 500 mR/hr on external, accessible < 50,000 dpm p,7/100 cm surfaces of waste in container

< 80 mR/hr on contact of unshielded bulk containers with resin External Contact Dose Rate Limits The external contact dose rate limit of 200 mR/hr applies to the manifested container (e.g., drums/boxes on a flatbed truck or enclosed van, bulk containers such as intermodals, sealands, cargo containers, etc.).

For example, if drums or boxes are shipped in a bulk container, such as an intermodal, and the intermodal is manifested as the strong, tight container, then the external contact dose rate of 200 mR/hr applies to the intermodal and not to the drums or boxes inside the intermodal. The drums and boxes in this case would be considered waste and must not contain any item with dose rates exceeding 500 mR/hr on the external, accessible surfaces of the item.

The dose rate for debris items such as pipes should only be measured on the exterior surfaces and on the plane surface of the opening of the pipe to demonstrate compliance with the ALARA Criteria. For example, the internal pipe surfaces may exceed the 500 mR/hr dose limit only if the surface plane to the opening of the pipe is less than 500 mR/hr. Shield plates used to cover the opening of the pipe should not be used solely to lower the dose rates below the criteria since EnergySolutions is required to remove or penetrate into the debris items to fill internal voids with grout material.

Another example is DAW placed into 55 gallon drums and compacted into pucks. The dose rate criteria apply to the external 'surfaces of the puck itself and not to the DAW inside the puck.

Resin External Contact Dose Rate Limits Resins shipped in bulk containers must comply with the ALARA Criteria. This is due to the required resin blending process that necessitates worker proximity to the waste. Resins shipped in disposal containers such as drums, boxes, liners, etc. may be acceptable at the BWF for grouting if the container is compliant with the ALARA Criteria for non-bulk packages. Resins shipped to the BWF must be shipped under a Waste Profile specific for resins unless specifically approved in writing by EnergySolutions.

Resins with dose rates that exceed these limits must be disposed at the CWF.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities Revision 7 Waste Acceptance Criteria

Removable Surface Contamination Limits The same ALARA principles apply to the removable surface contamination limits. The main concern is controlling loose contamination on the exterior surfaces of debris items removed from the container.

Fixatives may be applied to the debris items to reduce the removable contamination levels below the specified limits.

Requests for Exceptions Requested exceptions to the ALARA Criteria are evaluated on a case-by-case basis. For example, Mixed Waste exceeding the ALARA Criteria will be evaluated since the CWF cannot accept Mixed Waste for disposal. Generators must provide radiation and contamination surveys of the container and/or waste item when requesting approval to exceed the ALARA Criteria. Dose rate measurements at one foot from the waste should be provided on the radiation survey. The transportation mode and manifested package information should also be included with the request. The generator must receive written approval for exemptions to the ALARA Criteria prior to shipment of the waste.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities Revision 7 Waste Acceptance Criteria

SECTION 3 WASTE CRITERIA 3.1 ACCEPTABLE RADIOACTIVE WASTES The type, form, and quantity of LLRW, NORM, 1le.(2) byproduct material, and mixed waste that EnergySolutions can receive for treatment and disposal is governed by the various licenses and permits under which EnergySolutions operates. EnergySolutions has been issued an Agreement State Radioactive Material License (License'#UT 2300249, as amended) by the Utah Division of Radiation Control (DRC). This license authorizes EnergySolutions to receive Class A LLRW, NORM, and NARM waste. EnergySolutions has been issued a separate license to receive and dispose of uranium and thorium mill tailings byproduct material as defined by section 1le.(2) of the Atomic Energy Act of 1954, as amended.

The Utah Division of Solid and Hazardous Waste (DSHW) issued EnergySolutions a State-Issued Part B Permit (Permit #UT 982598898, as amended) to treat and dispose of hazardous waste which is also contaminated with LLRW, NORM, or NARM wastes (mixed waste). Early in 1999, EnergySolutions received a Permit modification which authorized the receipt and disposal of PCB Radioactive and PCB Mixed wastes. In 2002, EnergySolutions received a TSCA Coordinated Approval from the EPA to expand PCB receipt and disposal options. The TSCA Coordinated Approval has been subsequently expanded to include additional types of PCB radioactive and PCB mixed wastes.

3.1.1 Class A Low-Level Radioactive Waste EnergySolutions is authorized to receive Class A Low-Level and Mixed Low-Level Radioactive Waste.

These wastes must be classified in accordance with the requirements of the Utah Administrative Code (UAC)

R313-15-1008, Classification and Characteristics of Low-Level Radioactive Waste. Utah rule R313-15-1008 is similar to the NRC Waste Classification requirements in 10 CFR 61.55 with the addition of Radium-226.

Generators must have in place a quality control program to ensure compliance with the waste classification requirements and prepare and retain with manifest documentation a record documenting the generator's waste classification analysis. Shippers and generators should also review NRC IE Bulletin No. 79-19 to ensure compliance with applicable training requirements in managing LLRW.

The information provided below is a summary of the waste classification regulations and how generators must classify their LLRW prior to shipment to EnergySolutions. Further guidance. is provided in NRC's "Branch Technical Position on ConcentrationAveraging and Encapsulation", as amended (BTP). All generators shipping LLRW to EnergySolutions must comply with the NRC's BTP as specified in Condition 16 of the Radioactive Material License.

Determination of waste class involves two considerations. First, consideration must be given to specific long-lived radionuclides listed in Table I of UAC R313-15-1008. Second, consideration must be given to specific short-lived radionuclides listed in Table II of UAC R313-15-1008. The waste is Class A if the radionuclides listed in either Table I or Table II are not present in the waste. Both tables are provided below.

The concentration limits for determining waste class are given in curies per cubic meter with the exception of the following Table I radionuclides which are given in nanocuries per gram: alpha-emitting transuranic radionuclides with a half-life greater than five years, Pu-241, Cm-242, and Ra-226. The following bullets outline the steps for determining waste class per R313-15-1008.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 10 Revision 7 Waste Acceptance Criteria

Classification Tables from UAC R313-15-1008 Table I Radionuclide Ci/m3 nCi/g C-14 8 C-14 (act) 80 Ni-59 (act) 220 Nb-94 (act) 0.2 Tc-99 3 1-129 0.08 Alpha-emitting transuranics

> 5 year half-life 100 Pu-241 3,500 Cm-242 20,000 Ra-226 100

When the waste does not contain any radionuclides listed in either Table I or II, it is Class A.

When the concentration does not exceed 0.1 times the value in Table 1,the waste is Class A.

When the concentration exceeds 0.1 times the value in Table I, but does not exceed the value in Table I, the waste is Class C. EnergySolutionsis not authorized to receive Class B and Class C waste.

For wastes containing mixtures of radionuclides listed in Table I, the total concentration shall be determined by the sum of fractions rule as illustrated in the example below.

When the waste does not contain any of the radionuclides listed in Table I, classification shall be determined based on the concentrations shown in Table II.

Table I1 Column I Column 2 Column 3 Radionuclide Ci/m 3 Ci/m 3 Ci/m3 Total of all radionuclides <

5 year half-life 700 *

H-3 40 *

Co-60 700 *

Ni-63 3.5 70 700 Ni-63 (act) 35 700 7,000 Sr-90 0.04 150 7,000 Cs-137 1 44 4,600

There are no limits established for these radionuclides in Class B or C wastes. Practical considerations such as the effects of external radiation and internal heat generation on transportation, handling, and disposal will limit the concentrations for these wastes. These wastes shall be Class B unless the concentrations of other radionuclides in Table II determine the waste to be Class C independent of these radionuclides.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities i1 Revision 7 Waste Acceptance Criteria

" When the concentration does not exceed the value in Column I of Table II, the waste is Class A.

When the concentration exceeds the value in Column 1 but does not exceed the value in Column 2 of Table 1I, the waste is Class B.

When the concentration exceeds the value in Column 2 but does not exceed the value in Column 3 of Table II, the waste is Class C.

" For wastes containing mixtures of the radionuclides listed in Table II, the total concentration shall be determined by the sum of fractions rule.

For waste material that contains more than one radionuclide, the waste must be classified by applying the sum of fractions rule described in UAC R313-15-1008(1)(g). This rule states: (

"For determining classification for waste that contains a mixture of radionuclides, it is necessary to determine the sum of fractions by dividing each radionuclide's concentration by the appropriate limit and adding the resulting values. The appropriate limits shall all be taken from the same column of the same table. The sum of fractions for the column shall be less than 1.0 if the waste class is to be determined by that column."

The following examples demonstrate the application of the sum of fractions rule in determining waste class.

EXAMPLE #1: A generator has one 55 gallon container of soil contaminated with plutonium-238, radium-226, uranium-234, uranium-235, uranium-238, cesium-137, and strontium-90. The density of the soil is 1.6 g/cm 3 and is used to convert concentration units from pCi/g to Ci/m 3 . The radionuclide concentration in the container is as follows:

Table I Table II Class A Class A Container Container Concentration Concentration Concentration Concentration Limit Limit Radionuclide (pCi/g) (Ci/m3 )* (pCi/g) (Ci/m 3 )

Pu-238 3,000 4.8 E-03 10,000 - -

Ra-226 6,000 9.6 E-03 10,000 - -

U-238 5,000 8.0 E-03 ...

U-235 1,100 1.8 E-03 ....

U-234 5,000 8.0 E-03 ....

.Sr-90 5,000 8.0 E-03 - - 0.04 Cs-137 8,000 1.3 E-02 - - 1

The soil density (1.6 g/cm 3) is used to convert from pCi/g to Ci/m 3 .

The sum of fractions rule is applied to the container according to the radionuclides listed in Table I and II as follows:

3.OE+03 6.OE+03 Table 1: +. =9.OE-01 1.OE+04 1.OE+04 8.OE-03 1.3E-02 Table II: +- =2.6E - 02 4.OE- 02 1.OE + 00 EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 12 Revision 7 Waste Acceptance Criteria

Based on the sum of fractions rule, the waste in this container is determined to be Class A waste (i.e., 90 percent of the Class A limit for Table I radionuclides). This container is acceptable for disposal at EnergySolutions since it meets the sum of fractions rule.

The uranium radionuclides are not included in the sum of fractions calculation since these radionuclides are not included in Table I or II of R313-15-1008.

EXAMPLE #2: A generator has one 55 gallon container of Dry Active Waste (DAW) contaminated with americium-241, technetium-99, europium-155, colbalt-58, and cesium-135. The density of the DAW is 0.25 g/cm 3 and is used to convert Table II units from pCi/g to Ci/m 3. The radionuclide concentration in the container is as follows:

Table I Table II Class A Class A Container Container Concentration Concentration Concentration Concentration Limit Limit Radionuclide (pCi/g) (Ci/m 3)* (pCi/g) (Ci/m 3)

Am-241 6,000 1.5 E-03 10,000 --

3 Tc-99 900,000 2.3 E-01 0.3 Ci/m - -

Eu-155 150,000 3.8 E-02 - - 700 Co-60 100,000 2.5 E-02 - - 700 Cs-135 500,000 1.3 E-01 ....

The DAW density (0.25 g/cm 3) is used to convert from pCi/g to Ci/m 3.

The sum of fractions rule is applied to the container according to the radionuclides listed in Table I and II as follows:

6.OE+03 2.3E-01 Table 1: +- =1.4E + 00 1.OE+04 3.OE-01 3.8E-02 2.5E-02 Table 11: + =9.OE - 05 7.OE + 02 7.OE+ 02 Based on the sum of fractions rule, the waste in the DAW container exceeds the Table I Class A concentration limit and would not be acceptable at EnergySolutions. Note that Cs-135 is not included in the sum of fractions calculation since this radionuclide is excluded in Table I or II ofR313-15-1008.

Waste Classification Labels on Packages All waste packages containing LLRW, including Mixed LLRW, must be labeled either "Class A Unstable" or "Class AU" and appropriately marked in Block 16 of the Uniform Low-Level Radioactive Waste Manifest Form 541. There are no State or Federal regulations that prescribe the size or color of the classification labels. The Utah DRC, however, requires that each package be labeled with a minimum of 0.5-inch lettering in contrasting color (refer to the "Generator Site Access Permit Enforcement Policy - Utah Division of Radiation Control", as amended). This requirement also applies to bulk packaging (e.g., intermodals, gondolas, etc.).

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LLRW Compact Export Approval EnergySolutions' disposal site is not classified as a LLRW compact site under the Federal Low-Level Radioactive Waste Policy Act, as amended. Condition 9A of the Radioactive Material License requires generators to demonstrate that the LLRW has been approxved for export to EnergySolutionsprior to the initial shipment of waste. Approval is required from the LLRW compact of origin, or for states unaffiliated, the state of origin. This license condition only applies to non-DOE generators of LLRW and excludes Mixed LLRW. In addition, EnergySolutions is not authorized to receive LLRW from the Northwest Compact.

Please contact EnergySolutions for assistance in complying with this license condition.

3.1.2 NORM/NARM Waste EnergySolutions' Radioactive Material License allows receipt and disposal of Naturally Occurring or Accelerator-Produced Radioactive Material (NORM/NARM). NORM/NARM does not include Byproduct, Source, or Special Nuclear Material and generally contains radionuclides in the uranium and thorium decay series. Since NORM/NARM waste is not considered LLRW, the waste classification regulations do not apply.

3.1.3 Class A Mixed Low-Level Radioactive Waste EnergySolutions is authorized to receive Class A Mixed Low-Level Radioactive Waste (Mixed Waste) for (1) disposal, or (2) treatment and disposal. Mixed Waste is defined by EnergySolutions' State-Issued Part B Permit (# UTD982598898) as:

Waste defined by the Low Level Radioactive Waste Policy Act, Public Law 96-573; this is radioactive waste not classified as high-level radioactive waste, transuranics waste, spent nuclear fuel, or byproduct material as defined by section 11 e.(2) of the Atomic Energy Act, and contains hazardous waste that is either listed .as a hazardous waste in Subpart D of 40 CFR 261 and/or exhibits any of the hazardous waste characteristics identified in Subpart C of 40 CFR 261, or hazardous waste which also contains naturally occurring radioactive materials.

In accordance with 40 CFR 268.7, a Land Disposal Restriction Notification and/or Certification must accompany each shipment of Mixed Waste. This includes former hazardous wastes that have been treated to remove the Hazardous Waste Codes.

3.1.3.1 Acceptable Hazardous Waste Codes The specific EPA Hazardous Waste Codes that may be received by EnergySolutions are identified in its Statue-Issued Part B Permit. A copy of this permit is included on EnergySolutions' web site at www.energysolutions.com or on the Utah Division of Solid and Hazardous Waste web site at www.hazardouswaste.utah.gov/HWBranch/CFFSection/EnvirocarePermit.htm. The following Utah Hazardous Waste Codes are not acceptable at EnergySolutions: F999 and P999.

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3.1.3.2 LDR Compliant Mixed Waste Mixed Waste must be analyzed to determine if treatment is required prior to disposal. Mixed Waste that is determined to be compliant with the Land Disposal Restriction (LDR) treatment standards specified in 40 CFR 268 may be directly disposed in EnergySolutions' Mixed Waste disposal embankment.

EnergySolutions is required to verify LDR compliance for all Mixed Waste streams prior to disposal.

Condition 14.B of the Radioactive Material License prohibits EnergySolutions from disposing of characteristic Mixed Waste after treatment in the LLRW disposal embankment. EnergySolutions has extended this condition to Mixed Waste treated by generators at their facility. The waste profile must describe the waste as having undergone treatment. As a result, any waste that at the point of generation was considered a hazardous waste per 40 CFR 261 will be disposed of in the Mixed Waste disposal embankment.

As noted above, an LDR Certification must be included with the shipping paperwork for treated Mixed Waste (including formerly characteristic or listed hazardous waste).

3.1.3.3 Mixed Waste Requiring Treatment EnergySolutions may also receive Mixed Waste that requires treatment in order to comply with LDR treatment standards. EnergySolutions is approved under the State-Issued Part B Permit to operate a mixed waste treatment facility. Mixed Waste that is not LDR compliant may be treated by EnergySolutions using one of the following treatment technologies or methods:

, Chemical Stabilization, Oxidation, Reduction, Neutralization, and Deactivation

Macroencapsulation of hazardous debris or radioactive lead solids

Debris Spray Washing

Microencapsulation

Thermal Treatment of Organics

Mercury Treatment (Amalgamation)

Chemical Stabilization Chemical stabilization involves the addition of approved chemical reagents in accordance with a waste-specific treatment formula and is performed in mixers at EnergySolutions' Treatment Facility. Formula additions of waste, reagents, and water involve the following chemical processes to chemically bind contaminants to reduce their ability to leach from the waste.

Stabilization (STABL)

Deactivation (DEACT)

Neutralization (NEUTR)

" Oxidation (CHOXD)

" Reduction (CHRED)

Formula development may also be applied to Mixed Waste with very low levels of organic contaminants that require chemical destruction in order to meet total concentration based standards versus a leach standard as determined by the Toxicity Characteristic Leaching Procedure (TCLP) test. Mixed Waste requiring chemical stabilization may be sized and homogenized using various equipment including shredders, vibrating screens, and mixers. In order to evaluate chemical compatibility with the stabilization treatment process, generators shipping waste with Hazardous Waste Codes DOO 1, D002, or D003 must provide a list of specific chemicals in each container with the shipping paperwork.

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Macroencapsulation of Hazardous Debris' and Radioactive Lead Solids Mixed Waste consisting of hazardous debris may be macroencapsulated in accordance with the "Alternative Treatment Standards for Hazardous Debris" as specified in 40 CFR 268.45. Figure 3-1 illustrates macroencapsulation of hazardous debris in a container using a polymer or performed in-cell using pozzolanic material. Treditment of hazardous debris via macroencapsulation must meet the following criteria:

"Macroencapsulation of hazardous debris requires application of surface coating materials such as polymeric organics (e.g., resins and plastics) or use of a jacket of inert inorganic materials to substantially reduce surface exposure to potential leaching media" (40 CFR 268.45).

In order for hazardous debris to qualify for this alternative treatment, the waste must comply with the debris definition in 40 CFR 268.2(g).

"Debris means solid material exceeding a 60 mm particle size that is intended for disposal and that is: A manufactured object; or plant or animal matter; or natural geologic material. However, the following materials are not debris: Any material for which a specific treatment standard is provided in Subpart D, Part 268, namely lead acid batteries, cadmium batteries, and radioactive lead solids; Process residuals such as smelter slag and residues from the treatment of waste, wastewater, sludges, or air emission residues; and intact containers of hazardous waste that are not ruptured and that retain at least 75% of their original volume. A mixture of debris that has not been treated to the standards provided by § 268.45 and other material is subject to regulation as debris if the mixture is comprised primarily of debris, by volume, based on visual inspection" (emphasis added).

Figure 3-1. Macroencapsulation of Hazardous Debris Therefore, packaged waste subject to macroencapsulation (MACRO) may contain other material that does not meet the debris definition (e.g., paint chips, scale, etc.) to the extent that the mixture is "comprised primarily of debris". Consistent with the ALARA principle, this definition provides generators with flexibility in managing waste streams requiring treatment without having to sort and segregate non-debris items prior to treatment. However, as noted in 40 CFR 268.2(h), "deliberate mixing of other hazardous material with debris to change its treatment classification (i.e., from waste to hazardous debris) is not allowed under the dilution prohibition in § 268.3."

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Radioactive Lead Solids (RLS) are another type of hazardous waste that requires treatment via macroencapsulation. Radioactive Lead Solids include, but are not limited to, all forms of lead shielding and other elemental forms of lead. There are no size criteria for RLS unlike the 60 mm particle size requirement for hazardous debris. As such, smaller forms of RLS such as lead shot or fines require macroencapsulation prior to disposal.

EnergySolutions' MACRO treatment capability accommodates any size or weight of hazardous debris, thus enabling the generator to reduce the amount of time and cost associated with preparing waste packages for shipment. Generators with large debris over 20,000 pounds requiring macroencapsulation will provide the following information to EnergySolutions for review during the waste acceptance process: drawings, photographs, dimensions, weight, description of access ports to internal voids, radiological dose rate and contamination levels, and loading plans.

Debris Spray Washing Debris Spray Washing is another alternative treatment option utilized by EnergySolutionsto treat hazardous debris. High pressure water is sprayed at the debris surface to remove hazardous constituents to a "clean debris surface". This treatment technology is best if used on non-porous debris such as metal. "Clean debris surface" criteria are specified in 40 CFR 268.45:

"Clean debris surface means the surface, when viewed without magnification, shall be free of all visible contaminated soil and hazardous waste except that residual staining from soil and waste consisting of light shadows, slight streaks, or minor discolorations, and soil and waste in cracks, crevices, and pits may be present provided that such staining and waste and soil in cracks, crevices, and pits shall be limited to no more than 5% of each square inch of surface area."

Microencapsulation Microencapuslation (MICRO) is a technology used on Mixed Waste to reduce the leachability of the hazardous constituent. The types of Mixed Waste most suitable for MICRO include, but are not limited to, ash, powders, and salts. MICRO involves the combining of waste with molten polyethylene to form a material that does not leach hazardous constituents in excess of established TCLP treatment standards.

Mixed Waste is placed into the mixer with polyethylene. These are mixed at a high frequency with shear and frictional forces until the polyethylene melts and mixes with the waste to create a microencapsulated waste form. The treatment system includes size separation, size reduction, and a waste dryer for waste preparation prior to treatment.

Thermal Treatment of Organics Mixed Waste streams contaminated with organic hazardous constituents are among the most difficult waste streams to treat. The LDR treatment standards are expressed in terms of total organic concentrations (i.e.,

mg/kg) versus TCLP concentration based standards. As such, treatment of organic contaminated waste streams requires either destruction or removal of the organic constituent from the waste.

EnergySolutions utilizes Vacuum-Assisted Thermal Desorption technology (VTD) to treat organic contaminated waste streams including waste streams containing PCBs. Waste containing PCB liquids is also acceptable for VTD treatment.

Mixed Waste streams are heated in the VTD system at sufficient temperatures to volatize the organic constituents which are then condensed and collected as a liquid. The thermally treated residue is then EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 17 Revision 7 Waste Acceptance Criteria

sampled to verify LDR compliance. In some cases, the treatment residue will require additional treatment to stabilize hazardous metals prior to disposal. The organic liquid condensate will require further treatment to comply with LDR treatment standards.

Mercury Treatment Elemental mercury contaminated with radioactive materials must be treated via amalgamation per 40 CFR 268.40. Amalgamation of elemental mercury involves the mixing of reagents with the mercury to produce a non-liquid, semi-solid amalgam that reduces the potential emissions of elemental mercury vapors to the air.

The Utah DSHW also requires the amalgamation treatment to reduce the leachability of elemental mercury to below the characteristic concentration limit of 0.2 mg/L TCLP. This requirement applies to amalgamated mercury treated at either EnergySolutions' Treatment Facility or treated at another facility and shipped to EnergySolutions for disposal. Generators may ship elemental mercury contaminated with radioactive materials to EnergySolutions for treatment and disposal.

EnergySolutions is also capable of treating both Low (< 260 ppm Hg) and High Mercury Subcategory waste streams (> 260 ppm Hg). Waste streams containing Low Subcategory Mercury must be treated to less than 0.025 mg/L TCLP mercury. The EPA requires High Mercury Subcategory waste streams be treated thermally by incinerating (IMERC) or retorting (RMERC). EnergySolutions has received a site-specific treatment variance from the Utah Solid and Hazardous Waste Control Board to treat High Mercury Subcategory waste streams via stabilization instead of IMERC or RMERC. Consequently, waste streams containing High Subcategory Mercury are treated via stabilization and analyzed post-treatment to ensure the TCLP mercury results are less than 0.2 mg/L.

Hazardous debris that is contaminated with mercury may be macroencapsulated in accordance with the "Alternative Treatment Standards for Hazardous Debris" as specified in 40 CFR 268.45. Elemental mercury must be removed from hazardous debris to the maximum extent practical including, but not limited to, draining pumps, hoses, pipes, etc. and wiping excessive mercury from external surfaces.

3.1.4 lle.(2) Byproduct Material EnergySolutions is licensed by the Utah DRC to receive and dispose of 11 e.(2) byproduct material as defined by the Atomic Energy Act, as amended. I le.(2) byproduct material is defined as the tailings or waste produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content. Shipments of 1le.(2) waste will be managed and disposed of in a separate disposal embankment specifically licensed and designed for this material.

3.1.4.1 Radionuclide Concentration Limits EnergySolutions may accept 11 e.(2) byproduct material with an average concentration in any transport vehicle (truck or railcar) not to exceed 4,000 pCi/g for natural uranium or for any radionuclide in the Radium-226 series, 60,000 pCi/g for Thorium-230, or 6,000 pCi/g for any radionuclide in the thorium decay series.

EnergySolutions' 11 e.(2) Byproduct Material License does not require a sum of fractions calculation. The concentration limits are based on the average concentration of the 1le.(2) byproduct material over the transport vehicle upon receipt and not each individual container on the transport vehicle.

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3.1.4.2 Acceptable Forms of lle.(2) Byproduct Material In addition to soil and soil-like 11 e.(2) byproduct material, EnergySolutions may accept 11 e.(2) contaminated debris. The generator must certify in the Radioactive Waste Profile Record that the debris was either generated during the cleanup of an 11 e.(2) facility or is an integral part of the operations of extraction or concentration of uranium or thorium.

All debris must be less than 10 inches in at least one dimension and no longer than 12 feet in any dimension.

Debris that exceeds this size limit (e.g., 1le.(2) oversize debris) is not acceptable for disposal under the II e.(2) license. Generators with 1 e.(2) contaminated debris that are unable to size the debris prior to shipment must contact EnergySolutions' Customer Service representative to make necessary arrangements for EnergySolutions to size the debris upon receipt.

Shipments of 11 e.(2) byproduct material containing free liquid will be considered nonconforming and managed in accordance with EnergySolutions' 11 e.(2) license.

3.1.4.3 Certification of lie.(2) Byproduct Material EnergySolutions requires that each generator or owner certify in writing that the waste is 11 .e(2) byproduct material as defined by the Atomic Energy Act, as amended. Specifically, the generator or owner must certify that the waste materials are tailings or waste produced by extraction or concentration of uranium or thorium from any ore processed primarily for its source material content. The generator or owner must also certify that the waste material does not contain any other radioactive waste or hazardous waste. The generator or owner must provide the following information as it relates to the 1 e.(2) byproduct material:

License under which the waste was processed

Licensee that was issued the license

License issue and/or expiration date

" Issuing agency

Type of license

Volume of tailings The generator or owner must attach to the certification a list of all radiological and non-radiological constituents in the waste and the maximum and average concentrations of such constituents. EnergySolutions will perform an independent verification as to the accuracy of the information contained in the certification.

3.1.4.4 Shipping Paperwork for lle.(2) Byproduct Material Although 1 le.(2) byproduct material is specifically excluded from the definition of Low-Level Radioactive Waste; EnergySolutions requires that all shipments be manifested using the Uniform Low-Level Radioactive Waste Manifest (NRC Forms 540 and 541). However, I le.(2) byproduct material does not have to be classified in accordance with the requirements of URC R313-15-1008. Generators may enter "N/A" in column 16 of the NRC Form 541 for Waste Classification.

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3.1.5 Special Nuclear Material Condition 13 of the Radioactive Material License incorporates the Special Nuclear Material Exemption issued by the NRC. Under specified'conditions, the exemption allows EnergySolutions to possess waste containing SNM in greater mass quantities than prescribed in 10 CFR Part 150 without obtaining an NRC license pursuant to 10 CFR Part 70. The conditions are based on concentration limits of SNM in the waste and have been established by the NRC to ensure criticality safety. Special Nuclear Material (SNM) is defined in the UAC R313-12-3 as:

Plutonium, uranium-233, uranium enriched in the isotope 233 or in the isotope 235, and other material that the U.S. Nuclear Regulatory Commission, pursuant to the provisions of Section 51 of the Atomic Energy Act of 1954, as amended, determines to be Special Nuclear Material, but does not include source material; or any material artificially enriched by any of the foregoing but does not include source material.

Each generator shipping waste containing SNM (i.e., uranium enriched in U-235, U-233, Pu-236, Pu-238, Pu-239, Pu-240, Pu-241, Pu-242, Pu-243, or Pu-244) must complete and sign EnergySolutions' SNM Exemption Certification form as part of the waste profiling process. A copy of this form must also accompany each radioactive waste manifest for waste streams that contain any of the above isotopes. The SNM Exemption Certification form lists specific requirements that must be met in order for EnergySolutions to receive and accept waste containing any amount of SNM.

The NRC developed the SNM Exemption conditions based on criticality studies and independent calculations. A variety of scenarios were analyzed to determine limiting criticality conditions for waste materials containing SNM. The NRC determined that several conditions in addition to concentration limits would be required to assure criticality safety. A discussion of their approach is documented in the Safety Evaluation Report Regardingthe ProposedExemption from Requirements of 10 CFR Part 70 (SER) (Docket 40-8989). Specific guidance from the SER is included in this section.

The following information provides general guidance on completing the SNM Exemption Certification form. These guidelines are grouped into four sections similar to the sections on the form.

3.1.5.1 Condition 1 - Percent Enrichment of Uranium-235 The first section contains a table that lists U-235 concentration limits and related measurement uncertainty values for four different scenarios. These scenarios allow for different enrichments, waste configurations and commingling with moderating material in different percentages. The measured concentrations and associated uncertainties of U-235 in individual waste containers at time of receipt must not exceed the values listed in the RML, Condition 13. Generators with, low SNM concentrations relative to the specified limits may select the most restrictive scenario which allows more flexibility in demonstrating compliance with other conditions in the SNM Exemption. Check "Not Applicable" if the waste does not contain enriched U-235. Other SNM isotopes including U-233, Pu-236, and Pu-238 through Pu-244 and their associated limits are also listed.

The measurement uncertainty values listed in the last column of the table represent a maximum allowable concentration limit rather than a percentage value. The NRC provides the following guidance in the SER:

Staff considers that a reasonable measurement uncertainty value (one-sigma) would be in the range of 15 percent. Staff used 30 percent (two-sigma) in calculating the operational limit to increase the confidence level that the concentration of the waste based on a measurement EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 20 Revision 7 Waste Acceptance Criteria

would not exceed the subcritical value. Other radiochemistry techniques may be used to quantify the concentration of these radionuclides. These techniques typically have lower measurement uncertainty levels, but introduce sampling uncertainty. The measurement uncertainty levels are included in condition I and represent 15 percent of the maximum concentration value. A concentration value was used for the measurement uncertainty rather than a percentage value to allow greater flexibility for generators with waste having very low SNM concentrations.

3.1.5.2 Condition 2 - Specified Limits for Waste Containing SNM Each generator must certify to all five conditions listed in this section and provide justification based on process knowledge, physical observations, and/or testing. These conditions are categorized as follows:

SNM Isotope Concentration Limits

Spatial Distribution Requirements

Bulk Chemical Limits

Unusual Moderator Limits

Soluble Uranium Limits These conditions require the generator to adequately characterize the waste in terms of the range and variability of SNM concentrations in the waste.

SNM Isotope Concentration Limits Condition 2.a requires the generator to certify that concentrations of SNM in individual waste containers do not exceed the applicable U-235 concentration limit and the concentration limits for all isotopes listed in Table 1 of the SNM Exemption Certification form. Generators must certify that measurement uncertainty values from radiological testing are less than the maximum allowable concentration values listed in Table 1. As previously stated, a concentration value was used for the measurement uncertainty rather than a percentage value, to allow greater flexibility for generators with waste having very low SNM concentrations.

Spatial Distribution Requirements Condition 2.b requires the generator to certify that the SNM is homogeneously distributed throughout the waste or that the SNM concentrations in any contiguous mass of 600 kilograms (1,323 lbs) do not exceed on average the specified limits. This certification may be based on process knowledge or testing of the waste. The SER provides the following guidance on verifying spatial distribution of SNM:

Knowledge of the process by which the waste was generated or laid down may assure that the concentration varies smoothly throughout the volume with a maximum in a known location. It is then only necessary to measure the concentration at this maximum plus other measurements confirming smooth variation. In other cases where a smooth variation in SNM concentration in the waste is not present, additional measurements and characterization will be needed.

If spatial distribution of SNM in the waste is not known through process knowledge, generators may be able to certify to this requirement by using the following example.

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EXAMPLE: A generator's waste stream contains less than 10 percent enriched U-235.

Based on the limits in Condition 1, the corresponding U-235 concentration limit is 1,900 pCi/g. The mass of U-235 at a concentration of 1,900 pCi/g in 600 kg of waste can be calculated using the specific activity for U-235 (2.16X10 6 pCi/g) as follows:

1,900 -2 x 600,000g S

2.16X10 6 06 pc = 527.8 g U235 g

If the total mass of U-235 per container does not exceed the mass of U-235 in 600 kg of waste at 1,900 pCi/g, then compliance with the spatial distribution requirement can be achieved. Therefore, for this example, the mass of U-235 in the waste containers must not exceed 527.8 grams. Compliance with DOT regulations must also be met for shipments containing SNM.

Radioactive liquid waste containing SNM may also be accepted for solidification prior to disposal provided the SNM concentration does not exceed the SNM concentration limits specified in Condition 1. For containers of liquid waste with more than 600 kg of waste, the total activity (pCi) in the manifested container must not exceed the SNM concentration in Condition I times 600 kg of waste. For example, the maximum activity of Pu-239 in any manifested container of liquid waste is 6.0 mCi as shown below:

10,000'* x 600,000 g = 6.0x109 pCi = 60miP-3 99 The maximum activity of SNM in the liquid waste is limited by the volume of liquid shipped in a container and the concentration of SNM in the waste. Consequently, to comply with this condition, the Pu-239 concentration allowed in the liquid waste decreases as the size of the shipping container increases.

Bulk Chemical Requirements Condition 2.c excludes wastes containing "pure forms" of chemicals containing carbon, fluorine, magnesium, or bismuth in bulk quantities except as allowed by the conditions in Section 1 (e.g., a pallet of drums, a B-25 box). By "pure forms," it is meant that mixtures of the above elements such as magnesium oxide, magnesium carbonate, magnesium fluoride, bismuth oxide, etc. do not contain other elements. Demonstration of compliance with this condition may be based on process knowledge or testing.

The exclusion of bulk quantities of these chemicals in waste containing SNM is based on the criticality studies conducted by Oak Ridge National Laboratories (ORNL) for the NRC. The ORNL studies used silicon dioxide (SNOD) to represent the waste matrix in performing criticality calculations. Additional studies were performed replacing the silicon in the SiO 2 matrix with other common elements and determined that the above chemicals produced more reactive systems. Therefore, the NRC implemented this condition to restrict waste forms that contain pure forms of these chemicals.

Unusual Moderator Limits Condition 2.d limits the total quantities of beryllium, hydrogenous material enriched in deuterium, or graphite to one percent or less of the total weight of the waste (except as allowed by the conditions in EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 22 Revision 7 Waste Acceptance Criteria

Section 1). Information supporting this requirement may be based on process knowledge, physical observations, or testing. The following explanation from the SER provides the basis for this limit:

Unusually effective neutron moderating materials, such as beryllium, graphite, or heavy water, could provide a more reactive matrix.. Previous evaluations have shown that the presence of large amounts of beryllium can permit criticality to occur at lower concentrations of SNM in soil. Therefore, limiting unusual moderators is required to assure the effectiveness of the SNM concentration limits in maintaining criticality safety. Because prohibiting unusual moderators could result in problems demonstrating compliance, staff decided to set a finite maximum limit on unusual moderators.

Soluble Uranium Limits Condition 2.e limits highly soluble forms of uranium in waste packages to 350 grams of uranium-235 or 200 grams of uranium-233. If the waste contains mixtures of U-233 and U-235, the waste must meet the sum of the fractions rule on a container basis. Highly soluble forms of uranium include, but are not limited to: uranium sulfate, uranyl acetate, uranyl chloride, uranyl formate, uranyl fluoride, uranyl nitrate, uranyl potassium carbonate, and uranyl sulfate. Compliance with this condition may be based on process knowledge or testing.

This condition is based on an evaluation performed by the NRC to determine mechanisms that could increase the concentration of SNM in the waste. The SER identifies one such mechanism which involves the potential for highly soluble uranium to be readily leached with water and concentrate in thewaste. Generators must evaluate each waste stream to determine the chemical composition of uranium in the waste and to ensure that the presence of highly soluble forms of uranium do not exceed the mass limits specified above.

3.1.5.3 Condition 3 - Characterization of Waste Containing SNM The NRC developed specific pre-shipment requirements that have been implemented into the waste profiling process. EnergySolutions reviews this information to determine if the pre-shipment waste characterization and assurance plan is complete and that the supporting information is sufficient to demonstrate compliance with all SNM Exemption requirements. This section describes the information that must be attached to the Waste Profile and includes the following items:

Waste Description

Waste Characterization Summary

" Uniformity Description

Manifest Concentration Condition 3.a requires the generator to describe how the waste was generated, the physical form of the waste, and the uranium chemical composition. The uranium chemical composition of the waste is required to support condition 2.e which limits highly soluble forms of uranium. If compliance with this requirement cannot be demonstrated by process knowledge, approved laboratory methods are available to determine the uranium leaching characteristics of the waste.

Condition 3.b requires the generator to describe how the waste was characterized, the range of SNM concentrations, and the analytical results with error values used to develop the concentration ranges. This information is required to support Conditions 1, 2.a, and 2.b. Generators must sufficiently sample and characterize the waste to ensure that the SNM concentrations do not exceed the specified limits and that the SNM is homogeneously distributed throughout the waste.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 23 Revision 7 Waste Acceptance Criteria

A description of the spatial distribution of SNM in the waste is required by Condition 3.c. This description supports the certification of Condition 2.b. The NRC provides guidance in the SER to assist generators in demonstrating compliance with this requirement. Section 3.3.3.2 contains the related NRC guidance.

Condition 3.d requires a description of the methods that will be used to determine the SNM concentrations on the manifests. If concentrations of SNM are significantly lower than the specified limits or the SNM is uniformly distributed throughout the waste, generators are not necessarily required to perform direct measurements on every container. Appropriate methods such as scaling factors may be used in these instances. As SNM concentrations approach the limits, however, generators must perform more extensive characterization to determine the range and variability of SNM in the waste. The following NRC guidance is provided in the SER:

Where the concentration is a small fraction of the concentration limit and characterization results indicate relatively small variation in that concentration, using scaling factors would be an appropriate method to determine SNM concentrations in individual waste containers.

However, where the concentration of SNM approaches the concentration limit or the characterization results indicate large variations in SNM containers, using direct measurements on each package would be an appropriate method to determine SNM concentrations in individual waste containers.

Waste packages that contain elevated concentrations of SNM must be characterized by direct measurements which should involve sampling and/or radiological testing procedures for individual packages.

3.1.5.4 Condition 4- Generator's Certification The generator's certification of compliance is required in the final section. Each generator must certify that the information provided on the SNM Exemption Certification form is complete, true, and accurate.

The form and all supporting information must be attached to the Waste Profile upon submission to EnergySolutions. In addition, the SNM Exemption Certification form must be included with each waste manifest. The information supporting the form, however, should not be included with the manifest.

3.1.6 Polychlorinated Biphenyl (PCB) Radioactive Waste EnergySolutions is authorized to receive and dispose of most types of PCB/radioactive and PCB/mixed wastes defined by the EPA in 40 CFR 761. The EPA issued EnergySolutions a TSCA Coordinated Approval for receipt and disposal of drained PCB Articles and PCB Containers that contained PCBs at concentrations equal to or greater than 500 ppm. Wastes received under the TSCA Coordinated Approval must be disposed in the Mixed Waste disposal embankment. All PCB waste shipped to the Mixed Waste disposal facility must be accompanied with a Uniform Hazardous Waste Manifest. As required by 40 CFR 761, the Uniform Hazardous Waste Manifest must include the date the PCB waste was removed from service. Articles and containers of PCB waste must also be dated with the removed from service date per 40 CFR 761.65(c)(8).

Empty PCB containers that contained PCBs at concentrations less than 500 ppm may be disposed in the Class A LLRW Facility; however, this waste will require a Uniform Hazardous Waste Manifest and include the removed from service date on each outer container. A Uniform Hazardous Waste Manifest is not required for any other PCB wastes disposed at the Class A LLRW Facility.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 24 Revision 7 Waste Acceptance Criteria

The following sections describe the types of PCB waste categories acceptable for disposal at the Class A.

LLRW or Mixed Waste disposal embankments. Asterisks indicate PCB waste categories that require disposal in EnergySolutions' Mixed Waste disposal embankment.

EnergySolutions' Ground Water Quality Discharge Permit (GWQDP) and State-Issued Part B Permit prohibit the receipt of any PCB liquids except for 1) intact, non-leaking PCB Small Capacitors or 2) PCB waste that will be treated via VTD. Shipments of PCB wastes containing unauthorized free liquids will not be accepted by EnergySolutions unless re-profiled to a VTD'waste stream. Generators shipping PCB wastes in re-usable containers must be lined to prevent PCB contamination on the internal surfaces of the container.

Containers contaminated with PCBs will be returned to the shipper as a PCB Container.

3.1.6.1 PCB Remediation Waste PCB Remediation waste is waste containing PCBs as a result of a spill, release, or other unauthorized disposal, at the following concentrations: (1) Materials disposed of prior to April 18, 1978, that are currently at concentrations >_50 ppm PCBs, regardless of the concentration of the original spill; (2) materials which are currently at any volume or concentration where the original source was > 500 ppm PCBs beginning on April 18, 1978, or > 50 ppm PCBs beginning on July 2, 1979; and (3) materials which are currently at any concentration if the PCBs are spilled or released from a source not authorized for use under this part. PCB remediation waste means soil, rags, and other debris -generated as a result of any PCB spill cleanup, including, but limited to soil, gravel, dredged materials, such as sediments, settled sediment fines, and aqueous decantate from sediment, sewage sludge containing < 50 ppm PCBs, buildings and other man-made structures (such as concrete floors, wood floors, or walls) porous surfaces, and non-porous surfaces. Unless sampled and analyzed in accordance with 40 CFR 761.283, .286, or

.292, the PCB waste shall be assumed to contain _>50 ppm PCBs (40 CFR 761.6 1(a)(5)(i)(B)(2)(i)).

PCB Remediation Waste Category Definition -Acceptable Non-liquid Cleaning Includes non-porous surfaces and other non-liquid materials such as rags, Materials and PPE gloves, booties, other disposable PPE, and similar materials resulting from PCB cleanup activities.

Yes PCB Remediation waste containing < 50 ppm or < 100 [tg/100 cm2.

< 50 ppm or 2

< 100 ig/l 00 cm PCB Remediation waste containing >_50 ppm or > 100 ýtg/100 cm 2 .

>50 ppm or 2 Yes*

_100 p.g/100 cm Requires disposal in EnergySolutions' Mixed Waste disposal embankment.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 25 Revision 7 Waste Acceptance Criteria

3.1.6.2 PCB Bulk Product Waste PCB Bulk Product waste is waste derived from manufactured products containing PCBs in a non-liquid state, at any concentration where the concentration at the time of designation for disposal was > 50 ppm PCBs. PCB Bulk Product waste includes bulk wastes or debris from the demolition of buildings and other man-made structures manufactured, coated, or serviced with PCBs.

PCB Bulk Product Waste Category Definition Acceptable Presumed or known to Plastics (such as plastic insulation from wire or cable; radio, television and leach < 10 ptg/L PCBs computer casings; vehicle parts; or furniture laminates); preformed or molded rubber parts and components; applied dried paints, varnishes, waxes or other similar coatings or sealants; caulking; Galbestos; non-liquid building demolition debris; or non-liquid PCB bulk product waste from the shredding Yes of automobiles or household appliances from which PCB small capacitors have been removed (shredder fluff).

Other PCB Bulk Product waste that leaches PCBs at < 10 ug/L of water measured using a procedure used to simulate leachate generation.

Presumed or known to Paper or felt gaskets, fluorescent light ballasts with PCBs in the potting leach _>10 pig/L PCBs material > 50 ppm Yes*

Requires disposal in EnergySolutions' Mixed Waste disposal embankment.

3.1.6.3 PCB Articles A PCB Article is any manufactured article, other than a PCB Container, that contains PCBs and whose surfaces have been in direct contact with PCBs. A "PCB Article" includes capacitors, transformers, electric motors, pumps, pipes and any other manufactured item (1) which is formed to a specific shape or design during manufacture, (2) which has end use functions dependent in whole or in part upon its shape or design during end use, and (3) which has either no change of chemical composition during its end use or only those changes of composition which have no commercial purpose separate from that of the PCB Article.

EnergySolutions received a TSCA Coordinated Approval from the EPA to receive and dispose of drained PCB Articles. PCB Articles must be drained of all liquid to the maximum extent practical but in no case shall the liquid exceed one percent of the waste volume (all free liquid must be absorbed). PCB Articles that have been drained must be filled with sufficient absorbent material to absorb all remaining liquid. Some PCB Articles also require flushing with solvents for a specified time period (e.g., PCB Transformers).

EnergySolutions is also able to process PCB Large Capacitors and leaking PCB Small Capacitors through VTD.

The following table lists the various types of PCB Articles and whether the material is acceptable for disposal in either the mixed waste disposal embankment or LLRW disposal embankment.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 26 Revision 7 Waste Acceptance Criteria

PCB Articles Category Definition Acceptable PCB Transformers Any transformer that contains > 500 ppm PCBs. Yes*'

PCB Capacitors Any capacitor that contains > 500 ppm PCBs. Capacitor is a device for (Intact and non-leaking) accumulating and holding a charge of electricity and consisting of conducting surfaces separated by a dielectric. Assume PCBs >_500 ppm in a capacitor of unknown concentration made prior to July 2, 1979. Assume PCBs < 50 ppm in a capacitor made after July 2, 1979.

PCB Small A capacitor which contains less than 3 lbs of dielectric fluid. A Capacitors capacitor whose total volume is less than 100 cubic inches may be considered to contain less than 3 lbs of dielectric fluid. Includes fluorescent light ballasts containing intact and non-leaking PCB small Yes*

capacitors and PCB potting material (< 50 ppm).

PCB Large High or A large high voltage capacitor contains 3 lbs or more of dielectric fluid Low Voltage and which operates at or above 2,000 volts. A large low voltage Capacitors capacitor contains 3 lbs or more of dielectric fluid and which operates Yes*

below 2,000 volts.

PCB Hydraulic Machines Includes die casting machines 2 Yes*

PCB-Contaminated Any electrical equipment (such as transformers, capacitors, and circuit Electrical Equipment breakers, including those in railroad locomotives and self-propelled cars) which contain > 50 ppm and < 500 ppm PCBs in the dielectric fluid. In the case of dry electrical equipment, the electrical equipment Yes is PCB-Contaminated if it has PCBs > 10 ug/100 cm 2 and< 100 ug/100 cm2 as measured by a standard swipe test (40 CFR 761.123).

Other PCB Articles PCB Article

(> 500 ppm PCBs) Yes*

PCB-Contaminated Any article which contains _> 50 ppm and < 500 ppm PCBs in the Article dielectric fluid. In the case of dry electrical equipment, the electrical equipment is PCB-Contaminated if it has PCBs > 10 ug/100 cm 2 and <

100 ug/100 cm 2 as measured by a standard swipe test per 40 CFR Yes 761.123.

Requires disposal in EnergySolutions' Mixed Waste disposal embankment.

Requires solvent flushing.

2 Requires solvent flushing if PCB concentrations > 1,000 ppm.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 27 Revision 7 Waste Acceptance Criteria

3.1.6.4 PCB Containers A PCB Container is any package, can, bottle, bag, barrel, drum, tank, or other device that contains PCBs or PCB Articles and whose surfaces have been in direct contact with PCBs. PCB Containers must be emptied to the extent practical and not contain any free standing liquid. All PCB Containers received for disposal require a Uniform Hazardous Waste Manifest and removed from service dates. Waste containing PCBs in a liquid or solid phase is acceptable for VTD treatment (refer to Section 3.1.3.3).

PCB Container Category Definition Acceptable

_500 ppm PCBs The PCB concentration of material which was contained in the PCB Containers was _>500 ppm Yes*

< 500 ppm PCBs The concentration of material which was contained in the PCB containers was <

500 ppm Yes Requires disposal in EnergySolutions' Mixed Waste disposal embankment.

3.1.7 UCNI and Export Controlled Waste EnergySolutions has been granted approval from the DOE to receive Unclassified Controlled Nuclear Information (UCNI) and Export Controlled radioactive waste. This type of waste primarily originates from the DOE gaseous diffusion enrichment facilities. DOE generators must contact EnergySolutions prior to shipping UCNI and Export Controlled radioactive waste.

3.1.8 Chelating Agents EnergySolutions is authorized to dispose of waste containing up to 22 percent by weight chelating agents in the Mixed Waste disposal embankment. Waste disposed of in the LLRW disposal embankment must contain less than 0.1 percent by weight chelating agents. Generators may ship waste containing greater than 22 percent chelating agents to EnergySolutions' Treatment Facility once approved during the waste profiling process. EnergySolutions will treat waste containing greater than 22 percent chelating agents prior to disposal in order to comply with this requirement.

3.1.9 Asbestos and Beryllium EnergySolutions is authorized to dispose of waste containing both friable and non-friable asbestos. The asbestos waste must be described in the Radioactive Waste Profile Record and packaged, marked, and labeled in accordance with applicable federal regulations. Friable asbestos must not be packaged in bulk containers unless approved in writing by EnergySolutions.

Asbestos waste that requires wetting to prevent dispersion must be inspected to minimize free liquids.

However, unless the waste is to be solidified at the Treatment Facility, the free liquid may not exceed one percent of the waste volume. Absorbent material must be added to containers when free liquids are present. Waste streams containing greater than one percent free liquid by waste volume may be shipped to EnergySolutions' Treatment Facility for solidification prior to disposal. Contact EnergySolutionsprior to shipping waste streams that contain free liquids.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 28 Revision 7 Waste Acceptance Criteria

Waste containing other potential inhalation hazards such as beryllium must be described in the Waste Profile and documented on the 5 Working-Day Advanced Shipment Notification form. A quantitative description of potential beryllium surface contamination and air monitoring measurements both before and after any fixatives or wrapping are applied should be included in the Waste Profile for beryllium contaminated waste. The description should also include information about the current management of the beryllium contaminated waste including specific work control procedures in handling and packaging the waste for shipment, details of the beryllium protection program as applicable, and air monitoring measurements, etc. Beryllium contaminated waste must be packaged in 55-gallon or smaller drums unless approved in writing by EnergySolutions.

3.1.10 Lab Packs Lab packs are described as small containers of liquid with varying hazardous waste codes that are placed in a larger shipping or storage container. EnergySolutions is authorized to receive lab packs in which all of the contents are known and acceptable for treatment or disposal. Lab packs require a specific Waste Profile that must be approved by EnergySolutions prior to shipment. Generators must provide a description of unused chemicals within containers with the shipping paperwork.

3.2 ACCEPTABLE FORMS OF RADIOACTIVE WASTE EnergySolutions' Radioactive Material License authorizes the receipt of radioactive waste in the form of liquids and solids. Solid radioactive waste must contain less than one percent free liquid by waste volume. Generators shipping solid waste must minimize free liquid to the maximum extent practicable.

Conversely, liquid radioactive wastes contain greater than one percent free liquid by waste volume (e.g.,

sludge, wastewater, evaporator bottoms, etc.). EnergySolutions will determine if a waste contains free liquids by either visual inspection or by performing the Paint Filter Liquid Test (EPA SW-846 Method 9095). Liquid radioactive waste is solidified at EnergySolutions' Treatment Facility prior to disposal.

Solid waste includes, but is not limited to, the following forms of waste: soil, sludge, dry active waste, metal, concrete, wood, glass, resin, etc. For simplicity, these waste forms are categorized into either soil or debris waste streams due to the placement criteria specified in the license.

3.2.1 Soil or Soil-Like Wastes EnergySolutions constructs the disposal embankment by achieving specified compaction criteria and minimizing void spaces in the disposal lift. Construction of the disposal embankment in this manner ensures long-term integrity of the disposal facility. Soil and soil-like waste material are placed in the disposal embankment and compacted in 12-inch soil lifts. The license requires these soil lifts to be compacted to greater than 90 percent of optimum density and at a moisture content not to exceed three percentage points above optimum moisture as determined by the Standard Proctor Method (ASTM D-698). Consequently, soil or soil-like waste must have soil-like properties and conform to the following specifications. Otherwise, the waste material will be considered debris and managed for disposal as described in Section 3.2.2.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 29 Revision 7 Waste Acceptance Criteria

Soil/Soil-Like Properties

" Greater than 70 percent by weight compactable material less than 3/4" particle size and 100 percent compactable material less than 4" particle size

Maximum dry density greater than 70 pounds per cubic foot (dry weight basis)

Moisture content of the soil or soil-like waste must not exceed three percentage points above optimum moisture upon receipt at EnergySolutions

Maximum dry density and optimum moisture must be determined by Standard Proctor Method ASTM D-698 EnergySolutions may request a preshipment sample to perform an independent compaction test using Standard Proctor Method ASTM D-698. Generators must include their compaction test results as part of the waste profile submittal.

Shipments of soil or soil-like waste streams may contain some standard size debris in waste packages.

The percentage of allowable debris in the waste stream must be listed in the waste profile. Soil or soil-like waste streams with moisture content exceeding three percentage points above optimum moisture are acceptable by EnergySolutions and require additional handling prior to disposal. Contact EnergySolutions' Customer Service representatives prior to shipping soil or soil-like waste streams with elevated moisture content.

3.2.2 Debris Waste material not meeting the specified soil or soil-like properties is considered debris by EnergySolutions. Debris includes both decommissioning and routinely generated operational waste including, but not limited to, radiologically contaminated paper, piping, rocks, glass, metal, concrete, wood, bricks, resins, sludge, tailings, slag, residues, and personal protective equipment (PPE) that conforms to the debris size requirements.

3.2.2.1 Standard Size Debris Debris is defined into two broad categories based on size. The first category is standard debris and includes materials that are less than 10 inches in at least one dimension and no longer than 12 feet in any dimension. Debris that does not meet this size criterion is categorized as oversize debris.

Standard size debris is uniformly distributed throughout the 12-inch soil lifts. EnergySolutions adds either native clay or radioactive soil to the debris. Each soil lift is limited to the amount of debris that may be placed with soil to achieve the required compaction criteria. Depending upon the conditions of the disposal agreement, some generators that have both soil and debris may be able to achieve cost savings by delivering these materials together such that the shipping package contains enough soil to mix with the debris to achieve compaction requirements. All debris must be placed in such a way to minimize void space in the soil lift.

3.2.2.2 Oversize Debris and Large Components Waste material is considered oversize deblris if the debris has at one dimension greater than 12 feet or does not have one dimension less than 10 inches. Since oversize debris cannot be compacted directly into the soil EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 30 Revision 7 Waste Acceptance Criteria

lifts, this material is placed in different areas of the disposal embankment where void spaces are minimized to the maximum extent practicable both in and around the debris.

Bulk oversize debris, such as a large component, is also disposed of using this alternative disposal process. EnergySolutions has received and disposed of several large components over 250 tons including steam generators, reactor heads, turbine components, and other large equipment as illustrated in Figure 3-2. Generators should identify these types of materials as part of the vwaste profiling process.

This will allow EnergySolutions to evaluate the off-loading and placement of the large component prior to shipment.

Generally, single items over 20,000 pounds are considered large components and require special handling and engineering reviews prior to placement. The type of information required for large components includes drawings, photographs, weight, dimensions, description of enclosed voids, packaging configuration, rigging and loading plan, identification of lifting points, transportation mode, and radiological characterization and survey documentation. Void spaces within large components must be made accessible via a minimum of two access ports to allow grout in-fill during disposal operations at the Clive disposal facility. Access ports must be at least four inches in diameter unless approved in writing by EnergySolutions. Containers of oversize debris must exclude soil or soil-like waste due to placement criteria.

EnergySolutions may also elect to dispose of dispersible waste forms (e.g., filtercake, dusty material, etc.)

or waste with elevated dose rates by not emptying the waste from the container. Although ion-exchange media (resin) meets the standard size debris criteria, resins are not emptied from the container but grouted to minimize void spaces. Consequently, resin waste streams must be shipped under a resin specific waste profile unless approved in writing by EnergySolutions. Void spaces in and around the containers are minimized to the maximum extent practicable.

Figure 3-2. Large Component Disposal EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 31 Revision 7 Waste Acceptance Criteria

3.2.3 Gaseous Waste EnergySolutions is authorized to receive gaseous waste in accordance with Utah Administrative Code R313-15-1008(2)(a)(viii). Gaseous waste must be packaged at an absolute pressure that does not exceed 1.5 atmospheres at a temperature of 20 degrees Celsius and the total activity of any container shall not exceed 100 Curies. This information must be identified in the Radioactive Waste Profile Record.

3.2.4 Waste Containing Free Liquids Wastes containing free liquids greater than one percent by volume are considered liquid waste streams.

Generators may use visual inspection of the waste or the Paint Filter Liquids Test to determine if the waste contains free liquids. The Radioactive Waste Profile Record must describe the physical, chemical, and radiological characteristics of the liquid waste. EnergySolutionsreceived approval from the Utah DRC to receive radioactive liquid wastes that are aqueous based. Non-aqueous radioactive liquids require case-by-case approval from the Utah DRC.

EnergySolutions will perform a solidification study on a sample of the liquid waste prior to authorizing shipments. Liquid waste must be solidified and disposed at the Mixed Waste Facility. EnergySolutions has permitted liquid storage tanks to accommodate liquids delivered in tankers and other DOT approved bulk containers.

For generators with waste streams that may contain free liquids, the process by which the liquid will be minimized to less than one percent of the waste volume must be documented in the Radioactive Waste Profile Record. Approval of these waste streams would be considered authorized free liquids.

The presence of unauthorized free liquid within a package or shipment is a significant cause of non-compliance. Each incoming shipment will be tested for free liquids in accordance with EnergySolutions' Waste Characterization Plan using visual inspection of the waste or the Paint Filter Liquids Test.

If a solid waste shipment is found to contain unauthorized free liquids greater than one percent of the waste volume in any manifested container, EnergySolutions is required to promptly notify the generator and the Utah DRC. EnergySolutionsmay stop shipments of waste material until the cause of the problem is identified and corrected. The Waste Characterization Plan requires that the generator submit a quality control program that identifies the root cause of the problem and outlines corrective actions that will be taken to correct the problem and the quality controlmeasures that will be implemented to prevent recurrence. Until this corrective action plan has been submitted, reviewed, and approved by EnergySolutions' Quality Assurance Manager, no further shipments may be permitted from the waste generator's site.

In order to control free liquid within the waste material, the use of absorbent materials is strongly recommended. Sufficient absorbent material to absorb twice the volume of the potential liquid should be used. Experience has shown that some soil matrices actually 'bleed' moisture out during transport due, to vibration. If testing indicates that the waste material, as shipped, could exceed the optimum moisture content (as determined by the Standard Proctor Test) and that a risk of waste form separation exists while the shipment is en, route, the precautionary addition of absorbents prior to shipment is strongly advised. To ensure that adequate absorbents are added, generators should also consider testing the moisture content of each shipment.

Although uncommon, in some cases it is possible for precipitation to enter the package resulting in free liquids. Detailed inspections should be completed before waste is placed in transit to ensure the package meets strong-tight criteria and that water cannot enter. EnergySolutions does not maintain a list of approved EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 32 Revision 7 Waste Acceptance Criteria

absorbents or manufacturers. If absorbents are added to the waste, the specific absorbent must be identified in the Radioactive Waste Profile Record (Section B.5).

3.3 PROHIBITED RADIOACTIVE AND MIXED WASTE Condition 16 of the Radioactive Material License prohibits receipt of the following wastes:

Sealed sources defined in UAC R313-12 as "radioactive material that is permanently bonded or fixed in a capsule or matrix designed to prevent release and dispersal of the radioactive material under the most severe conditions which are likely to be encountered in normal use and handling" (e.g., instrument calibration check sources, smoke detectors, nuclear density gauges, etc.).

" Radioactive waste which is classified as Class B, Class C, or Greater Than Class C waste.

Solid waste containing unauthorized free liquids.

Waste material that is readily capable of detonation, of explosive decomposition, reactive at normal pressure and temperature, or reactive with water or air.

Waste materials that contain or are capable of generating quantities of toxic gases, vapors, or fumes harmful to persons transporting, handling, or disposing of the waste.

Waste materials that are pyrophoric. Pyrophoric materials contained in wastes must be treated, prepared, and packaged to be nonflammable.

Waste materials containing untreated biological, pathogenic, or infectious material including contaminated laboratory research animals. Generators desiring to ship this type of waste must document in the Radioactive Waste Profile Record the process used to treat the potential non-radiological hazard. Sharps including needles, scalpels, knives, syringes, pipettes, and similar items having a point or sharp edge or that are likely to break during transportation must not be packaged in bulk containers unless written approval is given by EnergySolutions. When these items are used in the medical industry or related research, they must be treated to remove the biohazard. Documentation of such treatment must be included in the Waste Profile.

The following Mixed Wastes are not acceptable for treatment or disposal at the Mixed Waste facility:

Hazardous waste that is not also a radioactive waste

Wastes that react violently or form explosive reactions with air or water

Pyrophoric wastes and materials

DOT Forbidden, Class 1.1, Class 1.2 and Class 1.3 explosives

Shock sensitive wastes and materials

Compressed gas cylinders, unless they meet the definition of empty containers

Utah waste codes F999 and P999 EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 33 Revision 7 Waste Acceptance Criteria

SECTION 4 WASTE ACCEPTANCE PROCESS 4.1 WASTE PROFILING PROCESS This section details EnergySolutions' waste characterization and profiling process. Profiling a waste stream involves collecting samples and obtaining analytical results for the parameters specified on EnergySolutions' Radioactive Waste Profile Record (Waste Profile). The Waste Profile serves the following functions: (1) enables EnergySolutions to evaluate wastes for acceptance, (2) maintains an operating record for the material during acceptance, storage, treatment, if applicable, and disposal of waste shipments, (3) provides a historical record of the waste project for each waste stream, and (4) ensures compliance with EnergySolutions' licenses and permits. The Waste Profile and related instructions can be downloaded from EnergySolutions' web site at www.energysolutions.com. An EnergySolutions Technical Services Representative is also available to assist in the waste profiling process.

The waste profiling process consists of the following steps as illustrated in Figure 4-1:

Initial discussions

. Waste characterization

Waste Profile Record completion and submittal

Treatability and/or solidification study sample submitted, if requested

Profile review and approval

Notice to Transport Initial discussions of the waste stream are critical in ensuring that the waste profiling process is accurate and efficient. Technical Services representatives are a resource to the generator in completing this process.

4.2 WASTE CHARACTERIZATION Early in the process, the generator samples the waste stream where applicable and begins to accumulate the analytical data required in the waste profile record described below. It is critical that chemical analyses are performed by laboratories certified by either the State of Utah or the National Environmental Laboratory Accreditation Conference (NELAC). Generators may contact the Utah Department of Health at (801) 584-8501 or visit their website at http://health.utah.gov to obtain information on the Utah Laboratory certification requirements. Laboratories certified by NELAC are listed on the US EPA's website at www.epa.gov/nerlesdl/land-sci/nelac/accreditlabs.html. Technical Services representatives can also provide current laboratory certification information. Once the analytical support data is available, the generator completes the Waste Profile record as described in the following section.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 34 Revision 7 Waste Acceptance Criteria

Figure 4-1. Waste Acceptance Process

1 Generator Contacts ES_ _ _ _

Generator Samples Informal Review of Waste, ....

-

Waste A cceptability I Utah Certified or NELAC I Lab Performs Analysis I

~0 (D

Generator Completes .

Waste Profile Form and Submits Profile .

Package to ES Inteac t ive SDialogue & Profile Review and Supprtin~ gProfile Info Approval Process I Generator Sends Sample for Treatability or Solidification Study if --

Requested by ES Waste Profile Approved by ES Generator Submits 1st Manifest for Review and Approval ES Issues Notice to Transport --

ES = EnergySolutions EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 35 Revision 7 Waste Acceptance Criteria

4.3 RADIOACTIVE WASTE PROFILE RECORD The waste profile record is a document required by EnergySolutions' licenses and permits. It provides information in the following areas:

" Generator and waste stream information

" Physical properties and packaging

" Radiological information

Chemical composition and hazard evaluation Waste generators must complete a Radioactive Waste Profile Record for every waste stream shipped to EnergySolutions. To complete this form, the generator should use process knowledge along with analytical laboratory results. The form contains the following sections.

Generator and Waste Stream Information These sections request generator contact information and general overview of the type of waste material, physical characteristics, transportation and package modes, identification of specific radionucildes, and the average and range of radionuclide concentrations.

Chemical and Hazardous Waste Characteristics (LLRW or MW)

The generator selects the applicable attachment for describing the chemical properties for either LLRW or Mixed Waste. These attachments request the chemical information to evaluate the waste relative to RCRA regulations. Only one of these attachments is required to be signed and submitted to EnergySolutions with the Waste Profile.

" SNM Exemption Certification This form requests the radiological information to evaluate waste containing SNM with respect to the SNM Exemption issued by the NRC and incorporated into EnergySolutions' license. Condition 3 of the SNM Exemption Certification form requests specific information to be included with the narrative of the Waste Profile.

PCB Waste Certification This form requests information about the type of Polychlorinated Biphenyls (PCBs) waste included with the waste stream. PCB waste streams must be profiled separately from non-PCB waste streams.

EnergySolutions uses this form and supporting information to evaluate PCB waste streams with respect to EnergySolutions' permits and TSCA regulations in 40 CFR 761.

4.3.1 Generator and Waste Stream Information This section includes contact information for generators, including addresses and responsible parties. The contact information is required for the generator's representative as well as for the individual completing the Waste Profile. The generator must answer a series of questions designed to categorize the waste material that is profiled. The generator identifies the following:

If the waste is hazardous, and whether it has been treated or requires treatment at EnergySolutions

" If the waste is Low-Level Radioactive Waste and subject to LLRW Compact Export approval

If the waste contains Special Nuclear Materials, PCBs, or asbestos EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 36 Revision 7 Waste Acceptance Criteria

4.3.2 Waste Physical Properties and Packaging The physical and geotechnical properties of the waste include gradation of the material, density range, a full description of the physical composition and characteristics of the waste, moisture content, optimum moisture, and maximum dry density determined by the Standard Proctor Method (for soil or soil-like materials).

The purpose of the physical and geotechnical testing requirements is to demonstrate that the material can be managed at EnergySolutions under existing license/permit requirements and in accordance with EnergySolutions' waste disposal placement methods.

The gradation of the waste may be determined through analysis or waste process knowledge. After an assessment of the entire waste stream, the generator is expected to estimate the amount of material that would pass through the various screens indicated. This information is necessary to determine the method of waste placement.

In this section, the generator addresses questions regarding free liquids. If the waste contains free liquids, the Waste Profile requires a description including the quantity and nature (aqueous or non-aqueous) of the liquid. Solid waste profiled to contain free liquids must be minimized to the maximum extent practical but in no case shall the free liquid exceed one percent of the waste volume uponarrival and inspection at the EnergySolutions disposal site. Waste streams containing PCBs must not contain any free liquids unless shipped for VTD treatment.

The waste description is continued by addressing several items in a narrative description and history of the waste provided by the generator as an attachment, referred to as Attachment B.5. The narrative should include the following items as applicable:

The process that generated the waste

Waste material physical composition and characteristics

Radiological and chemical characterization method

Information requested on the SNM Exemption Certification form, if applicable

The type and description of PCB waste, if applicable

Basis for determining manifested radionuclide concentrations

Description and amounts of absorbents, if applicable

Basis of non-hazardous or hazardous waste determinations

Treatment processes, if applicable

. Product information or Material Safety Data Sheets associated with the waste as applicable

Information requested in other sections of the Waste Profile 4.3.3 Radiological Information All waste streams must be analyzed to determine the radionuclide concentrations in the waste. The waste must be characterized via gamma spectroscopy, liquid scintillation, or other standard radiochemistry methods to determine the radionuclide concentrations in the waste'. Indirect measurements such as dose-to-curie or use of scaling factors may also be used if the process has been validated with direct measurements. Radiological analysis does not need to be performed by a Utah-Certified laboratory. Non-gamma emitting radionuclides such as Fe-55 and Ni-63, may be scaled from the gamma spectral analysis obtained. from testing the material EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 37 Revision 7 Waste Acceptance Criteria

if the waste generator has specific process knowledge of the material being profiled (10 CFR Part 61 analyses).

Please note that discrepancies between radiological information, particularly concentration ranges, and waste manifest documents could delay or prevent acceptance of a shipment. The Waste Profile must always be reviewed with the waste manifest documents prior to shipping waste to EnergySolutions. In the event that radiological, physical, or chemical properties of a profiled waste stream have changed, an update to the Waste Profile must be submitted and approved before such waste can be shipped to EnergySolutions.

EnergySolutions requires that generators evaluate the maximum dose rates and contamination levels anticipated in each waste stream. In the radiological section of Waste Profile, the generator indicates whether or not the maximum dose rate on accessible surfaces exceeds the ALARA Criteria as described in Section 2.3.1.

While EnergySolutions is permitted to receive Class A LLRW, certain radionuclides are subject to additional controls established by the Utah DRC. For example, Radium-226 is limited to 10,000 pCi/g.

In addition, the Utah DRC regulates the following radionuclides under Condition 29E of EnergySolutions' Radioactive Materials License:

Aluminum-26

" Berkelium-247

Calcium-41

Californium-250

" Chlorine-36

" Rhenium-187

Terbium-157

Terbium-158 EnergySolutions is required to provide a one-time notice for each generator shipping one of these radionuclides to the Class A disposal embankment. For waste shipped for disposal at the Mixed Waste disposal embankment, EnergySolutions must provide a one-time notification for each generator shipping waste containing Chlorine-36 and Berkelium-247. The generator includes the anticipated presence of these nuclides in the radiological information provided in the Waste Profile.

Finally, the generator lists the radionuclides present in the waste stream in conjunction with the expected maximum manifested concentration and the weighted average concentrations expected for each radionuclide. The generator is expected to manifest values for each shipment that are within the maximum values stated in this section of the Waste Profile. In the event that a generator needs to ship waste to EnergySolutions that exceeds the limits in the radiological information section of the Waste Profile, the generator may submit a revised Waste Profile to EnergySolutions for review and approval.

Any additional information including laboratory results for gamma spectroscopy or radiochemistry analysis must be attached to the Waste Profile. Radiological characterization methods and the basis for determining manifested radionuclide concentrations should be included in Attachment B.5 as described above.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 38 Revision 7 Waste Acceptance Criteria

4.3.4 Chemical Composition and Hazardous Waste Evaluation In accordance with the response to the hazardous waste question posed in the generator and waste stream information section, the generator provides one of two attachments with the Waste Profile addressing the chemical composition of the waste.

For hazardous wastes, the generator provides a completed and signed copy of the Hazardous Waste Analysis Certification Attachment. The chemical and hazardous characteristics of the waste stream must be provided in extensive detail. The purposes of chemical testing are to (1) demonstrate that the waste meets specific waste acceptance chemical requirements; and (2) demonstrate that the waste is either non-hazardous, compliant with RCRA treatment standards, or will require treatment prior to disposal. In addition, analysis is required to qualify wastes that may contain other specific regulated constituents.

EnergySolutions' licenses and permits require the results of the following minimum analyses be provided with the Waste Profile:

Analysis EPA SW-846 Method(s) pH (liquids only) Method 9045 PFLT (solid waste only) Method 9095 Organics (Totals) Method 8260 & 8270 Results from applicable concentration based treatment standards The results of these analyses are documented on the Hazardous Waste Analysis Certification Attachment and attached to the Waste Profile.

The Hazardous Waste Analysis Certification Attachment also includes waste codes applicable to the waste stream with corresponding treatment standards or technology codes and worst case concentrations.

This information is critical in evaluating wastes for treatment at EnergySolutions.

Applicable Underlying Hazardous Constituents (as defined in 40 CFR 268.48) and other chemicals present are identified at the end of the attachment.

For non-hazardous waste streams, the generator provides a signed copy of the Low-Level Radioactive Waste Certification Attachment. EnergySolutions' licenses and permits require the results of the following analyses be provided with the Waste Profile:

Analysis EPA SW-846 Method pH (liquids only) Method 9045 TCLP Metals Method 6010/7470 TCLP Herbicides. Method 8151 TCLP Pesticides Method 8081 TCLP Semi-volatiles Method 8270 TCLP Volatiles Method 8260 EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 39 Revision 7 Waste Acceptance Criteria

The individual chemical compounds required for these analyses are listed on the Low-Level Radioactive Waste Certification Attachment and correspond to the characteristic D-list constituents (D004 through D043) identified in 40 CFR 261.24 Table 1 as shown below.

40 CFR 261.24 Table 1 TABLE 1-MAXIMUM CONCENTRATION OF CON-TAMINANTS FOR THE TOXICITY CHARACTERIS-TIC 2

Regu-EPA HW Contaminant CAS No. latory No.1 Level (mg/L)

D004 Arsenic .............. 7440-38-2 5,0 D005 Barium ............... 7440-39-3 100.0 D018 Benzene ..... ............... 71-43-2 0.5 D006 . Cadmium ....... ............. 7440-43-9 1.0 D019 Carbon tetrachloride 56-23-5 0,5 D020 Chlordane ...................... .57-74-9 0.03 D021 Chlorobenzene .............. 108-90-7 100.0 D022 Chlorofonn .......... 67-66-3 6.0 D007 Chromium .................... 7440-47-3 5.0 D023 o-Cresol ................. 95-48-7 4200.0 D024 mn-Cresol .............. 1 08-39-4 4200.0 D025 p-Cresol ............. 106-44-5 4200.0 D026 Cresol .......... . ............ ............. 4200.0 D016 2,4-D ...... ........... 94-75-7 10.0 D027 1,4-Dichlorobenzene ...... 106-46-7 7.5 D028 1,2-Dichloroethane ........ 107-06-2 0.5 D029 1,1-Dichloroethylene 75-35-4 0.7 D030 2.4-Dinitrotoluene ......... 121-14-2 30.13 D012 Endrin ............ ............. 72-20-8 0,02 D031 Heptachlor (and its ep- 76-44-8 0.008 oxide).

D032 Hexachlorobenzene ...... 118-74-1 30.13 D033 Hexachlorobutadiene ..... 87-68-3 0.5 D034 Hexachloroethane .... 67-72-1 3.0 D008 Lead ............................... 7439-92-1 5.0 D013 Lindane _... .......- ..... 58-89-9 0.4 D009 Mercury .......................... 7439-97-6 0.2 D014 Methoxychlor .............. 72-43-5 10.0 D035 Methyl ethyl ketone ....... 78-93-3 200.0 D036 Nitrobenzene ............ 98-95-3 2.0 D037 Pentrachlorophenol ........ 87-86-5 100.0 D038 Pyridine .......................... 110-86-1 35.0 D010 Selenium .................... 7782-49-2 1.0 D011 Silver ............... 7440-22-4 5.0 D039 Tetrachloroethylene ....... 127-18-4 0.7 D015 Toxaphene ............ 8001-35-2 0.5 D040 Trichloroethylene . 79-01-6 0.5 D041 2,4.5-Tdchlorophenol ..... 95-95-4 400.0 D042 2,4,6-Tdchlorophenol .... 88-06-2 2.0 D017 2,4,5-TP (Silvex) ............ 93-72-1 1.0 D043 Vinyl chloride ................. 75-01-4 0.2 1Hazardous waste number.

2 Chemical abstracts service number.

3Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level.

4If o-. m-, and p-Cresol concentrations cannot be differen-tiated, the total cresol (D026) concentrafion is used. The regu-latory level of total cresol is 200 mgI.

The attachment also in'cludes a question as to whether or not the waste was at the point of generation of a hazardous waste, and a section to address former hazardous waste codes and additional chemical constituents.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 40 Revision 7 Waste Acceptance Criteria

As stated previously, the chemical analysis must be performed by a laboratory holding a NELAC or State of Utah certification. Data provided to the generator prior to any discussions of waste characterization with EnergySolutions may be acceptable for waste profiling purposes upon investigation of associated quality control sample data.

EnergySolutions may waive the chemical laboratory analyses if the material is not amenable to chemical sampling and analysis (e.g., debris items including metal pieces, concrete, plastic, etc.). Justification for waiving the chemical analyses must be provided in the narrative in Attachment B.5. Technical Service representatives can provide direction in cases where the waste meets such a description.

4.3.5 Special Nuclear Material Exemption Certification Form Waste containing Special Nuclear Material (SNM) must comply with the SNM requirements for concentration, spatial distribution, chemical mixture, solubility and chemical composition of SNM isotopes as described in Section 3.1.5 of the BWF WAC. The SNM Exemption Certification form guides the generator through the supporting information that must accompany the Waste Profile and each shipment of waste containing SNM. In addition to answering the questions on the form, the generator includes descriptions in Attachment B.5 for the requirements listed in items 3(a) through 3(d) of the SNM form. A completed and signed copy of the SNM Exemption Certification form must accompany the shipping paperwork for waste shipments containing Special Nuclear Material.

4.3.6 PCB Waste Certification Form EnergySolutions' Statue-Issued Part B Permit and Groundwater Quality Discharge Permit include the authorizations and requirements for EnergySolutions to receive PCB waste regulated for disposal under 40 CFR 761. The PCB waste types acceptable at EnergySolutions are listed in Section 3.1.6 of the BWF WAC. The generator must include a description of the type of PCB waste in the narrative of Attachment B.5. The PCB Waste Certification form does not need to accompany the waste shipment unless requested by EnergySolutions during the Waste Profile approval process.

4.4 TREATABILITY AND SOLIDIFICATION STUDY SAMPLES For waste streams requiring treatment or solidification, EnergySolutions will request a preshipment sample to perform a treatability and/or solidification study during the waste profiling approval process.

This allows EnergySolutions to develop the necessary treatment and solidification formula prior to receipt of the waste. Preshipment samples are not required for waste streams requiring treatment via macroencapsulation. EnergySolutions may'request additional preshipment samples during the waste profiling process to evaluate the waste material prior to receipt.

Preshipment samples should represent the waste material destined for shipment to EnergySolutions.

Representative sampling techniques appropriate to radiological and hazardous wastes should be employed in obtaining these samples. Treatability study samples should represent the "worst case" for a waste stream destined for treatment at EnergySolutions. The samples should contain the highest anticipated levels of chemical contaminants in the waste steam to ensure that EnergySolutions can develop a treatment formula that is adequate for the entire waste stream. EnergySolutions may be required to perform additional treatability studies if the waste shipments contain chemical constituents of concern at concentrations that are higher than the treatability study sample.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 41 Revision 7 Waste Acceptance Criteria

Preshipment samples may not be shipped to-EnergySolutions without prior authorization. At a minimum, a preliminary Waste Profile will need to be created that describes the waste and its generation. This preliminary Waste Profile must include both chemical and radiological assessments and must be approved by EnergySolutions prior to shipment of the sample. When approved for shipment, EnergySolutions will provide a Preshipment Sample Authorization Record to the generator.

Samples should be packaged into one or more sealed containers in such a manner that the sample container will not break during normal shipping conditions. Generally, the volume of sample requested will be less than 5 gallons. Sample containers should be labeled with the waste stream number, date, and a sample ID number. Sample closure devices should also be sealed with a custody or anti-tamper seal to ensure sample integrity.

Preshipment samples sent to EnergySolutions must be properly classed, described, packaged, marked, labeled, and in condition for transport as required by the DOT Hazardous Materials Regulations (HMR) contained in 49 CFR Parts 171 through 180. The Preshipment Sample Authorization forms must be completed and attached to the outside of the shipping package. A Uniform LLRW Manifest (Forms 540/541) must also accompany the shipping paperwork. The manifest number for the shipping paperwork is the Waste Stream ID number (e.g., XXXX-YY). The samples must be sent to the following address:

EnergySolutions Attention: Sample Control US 1-80, Exit 49 Tooele County Clive, UT 84029 (84083 if using Fed Ex)

Phone: (435) 884-0155 Treatability studies normally require 30 to 45 days to complete. Please keep this in mind when planning the first shipment of waste. Rush treatability studies are possible; however, there are higher costs for this service. Please contact EnergySolutions if a rush treatability study is required to meet a disposal schedule.

4.5 WASTE PROFILE REVIEW AND APPROVAL EnergySolutions will assist waste generators throughout the waste profiling process to ensure shipping and acceptance of the waste can be accomplished within the desired timeframe. In order to facilitate timely shipment and receipt of waste materials, EnergySolutions requests that the Waste Profile forms and analytical reports be provided as far in advance of the anticipated shipping date as possible. Upon receipt, EnergySolutions will complete a preliminary review of the waste profile information provided. Comments concerning the Waste Profile will usually be provided within two weeks of EnergySolutions' receipt of the profile information. If additional information is required for pre-acceptance, EnergySolutions will specify the information needed and communicate this to the generator. A comprehensive internal review is completed once all information has been submitted.

In order to assist each generator and accomplish the profile review and approval process as quickly as possible, EnergySolutions has developed a two-phase review process. During the first phase, an EnergySolutions Technical Services Representative will review and assess the Waste Profile, accompanying documentation, and analytical data for acceptability. If necessary, EnergySolutions will provide comments that delineate additional information needed for approval. This process typically takes EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 42 Revision 7 Waste Acceptance Criteria

one to two weeks. Once the additional information or revisions have been received by EnergySolutions and found to be satisfactory, phase 2 of the process begins.

The second phase involves and independent evaluation of the Waste Profile by EnergySolutions' Compliance and Operations representatives. EnergySolutions will notify the generator as soon as the review and approval process is completed.

At this point, the waste stream has been "pre-approved" for management at EnergySolutions, since the waste has been shown to be in compliance with all waste acceptance criteria. EnergySolutionswill issue a Notice to Transport once the Waste Profile has been approved and a contractual disposal agreement or necessary funding is authorized for the waste stream.

4.6 NOTICE TO TRANSPORT EnergySolutions will issue a Notice to Transport to the generator that authorizes subsequent waste shipments. The Notice to Transport is completed and issued once the Waste Profile is completed and approved by EnergySolutions. A Notice to Transport is also issued in the following situations:

The Waste Profile is revised in such a way that additional evaluations are required (radiological, chemical, or physical properties change significantly)

An annual update letter is received for Mixed Waste streams 0 The approval to ship is restored after the Notice to Transport is revoked In the event that the Notice to Transport is revoked, customers will not be able to schedule shipments until the approval to ship is restored and a new Notice to Transport is issued.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 43 Revision 7 Waste Acceptance Criteria

SECTION 5 SHIPMENT SCHEDULING AND MANIFESTING 5.1 GENERATOR SITE ACCESS PERMIT Prior to the first shipment of waste material to EnergySolutions' disposal site, generators must receive a Generator Site Access Permit (GSAP) issued by the Utah DRC. Utah Administrative Code R313-26 establishes the terms for a Generator Site Access Permit Program that authorizes waste generators, waste processors, and waste collectors to deliver radioactive wastes to a disposal facility within Utah.

Generators may apply for the GSAP on-line at the Utah DRC's website at www.radiationcontrol.utah.gov/DRC_prmt.htm.

The GSAP number must be listed in Block 5 of the Uniform LLRW Manifest Form 540 and correspond to the shipper's name and facility. Shippers must ensure the GSAP is renewed annually with the Utah DRC.

Shippers are subject to the provisions contained in the "Generator Site Access Permit Enforcement Policy" as amended, UAC R313-14, and UAC R313-19-100 for violations of state rules or requirements in the current land disposal facility operating license regarding radioactive waste packaging, transportation, labeling, notification, classification, marking, or manifesting requirements.

5.2 SHIPPING CHECKLIST To assist generators with shipments to EnergySolutions, the "Shipping Checklist" shown below in Figure 5-1 provides general contact, scheduling, and manifesting information. Generators and shippers should use this checklist in conjunction with their shipping procedures to ensure compliance with EnergySolutions' waste acceptance process. EnergySolutions' Technical Service Representatives are available to assist generators and shippers during the shipment scheduling and transportation process.

5.3 5 WORKING-DAY ADVANCED SHIPMENT NOTIFICATION Generators must schedule the shipment to arrive at the facility a minimum of five working days prior to the requested shipment arrival date. EnergySolutions strongly encourages generators to submit the 5 Working-Day Advanced Shipment Notification form prior to the shipment departing from the generator's site. A completed copy of the 5 Working-Day Advanced Shipment Notification form must be sent to the attention of EnergySolutions Scheduling Department to establish an arrival date for each shipment. This form may be downloaded from EnergySolutions' website at www.energysolutions.com. This form must be completed and either emailed to scheduling@energysolutions.com or faxed to the site at (435) 884-3549. Once this form has been received, the Scheduling Department will confirm the shipment's arrival date with the shipper. If all required information is not available at the time of submission, updates may be provided as the information becomes available. The Scheduling Department must be informed in the event that there are delays in the shipment scheduled arrival date.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 44 Revision 7 Waste Acceptance Criteria

Scheduling: Must be established at least 5 working days in advance of requested arrival date D A "Notice to Transport" has been issued by EnergySolutions for the Waste Profile.

D Submitted "5 Working Day Advanced Shipment Notification" form to request shipping schedule.

Email form to scheduling@energysolutions.com or fax to (435) 884-3549.

El Shipping schedule has been confirmed by EnergySolutions.

EnergySolutions' Shipping & Receiving Scheduler: (435) 884-0155.

Advanced Manifesting: Must be submitted prior to releasing each shipment/conveyance D Manifested information is consistent with the approved Waste Profile.

Verify that all manifested radionuclides are listed in the approved Waste Profile and that manifested concentrations do not exceed the approved ranges.

D Verified consignee information on manifests (see below).

Consignee: EnergySolutions,LLC Contact: Shipping and Receiving Clive Disposal Site Phone: (435) 884-0155 Interstate 80, Exit 49 Clive, UT 84029 D Verified Shipment ID/Manifest Number (XXXX-YY-ZZZZ)

XXXX is the generator number, YY is the Waste stream number, and ZZZZ is the shipment number (starting with 0001 for the first shipment/conveyance and incrementing by one for each additional shipment/conveyance). If a Hazardous Waste Manifest is submitted, include the Shipment ID Number in Block 15.

D Verified valid Utah Site Access Permit number in Block 5 on Form 540. Generators must apply for the permit with the Utah Division of Radiation Control (DRC). The Shipper Name and Facility must be consistent with the Utah Site Access Permit number.

D Verified that Block 9 of Form 540 specifies EnergySolutions' "Treatment Facility" or "Bulk Waste Facility". Enter "Bulk Waste Facility" for LLRW, I Ie.(2) Byproduct Material, and Mixed Waste shipped for direct disposal or enter "Treatment Facility" for waste streams requiring treatment by EnergySolutions prior to disposal.

D Submitted manifests to EnergySolutions at least three working days prior to the shipment arrival date.

If possible, please export the manifests and send electronically via email to manifest@energysolutions.com. Otherwise, fax manifests to "Shipping and Receiving - Manifest" at (80 1) 413-5643. If applicable, include the LDR Notification/Certification forms, Hazardous Waste Manifest, and SNM Exemption Certification form.

Shipment Paperwork and Inspection ED The original shipping paperwork/manifests accompany each shipment (conveyance). If applicable, include the LDR Notification/Certification forms and Hazardous Waste Manifest for each shipment.

E] If applicable, a completed and signed copy of the SNM Exemption Certification form and DOE/NRC form 741 has been included with the shipping papers.

Dj If applicable, the Uniform Hazardous Waste Manifest lists all hazardous waste codes associated with the shipment.

D Containers have been inspected'and comply with DOT packaging requirements. Waste must be packaged in a strong, tight container at a minimum.

FD Containers do not contain unauthorized free standing liquids.

D If applicable, containers are labeled "Class A Unstable" or "Class AU". Refer to Block 16 of NRC Form 541.

Figure 5-1. Shipping Checklist EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 45 Revision 7 Waste Acceptance Criteria

Shipments containing radionuclides with total activities exceeding the limits listed below must be specified on the 5 Working-Day Shipment Notification form and approved prior to waste shipment.

Californium-252 (in excess of 5.4 Ci)

Co-60 (in excess of 8.1 Ci) 0 Cs-137 (in excess of 27 Ci)

Gd-153 (in excess of 270 Ci)

Ir-192 (in excess of 22 Ci)

Pm-147 (in excess of 11,000 Ci) 0 Se-75 (in excess of 54 Ci) 0 Tm-170 (in excess of 5,400 Ci)

Yb- 169 (in excess of 81 Ci) 5.4 SHIPPING PAPERWORK Advance copies of the Uniform Low-Level Radioactive Waste Manifest (Forms 540/541, and 542 if applicable) are required to be sent to EnergySolutions at least three working days prior to the shipment arrival date. Shippers must submit the shipping paperwork electronically via email to manifest@energysolutions.com or fax to "Shipping and Receiving - Manifest" at (801) 413-5643.

EnergySolutions encourages submittal of the Uniform LLRW Manifest electronically by exporting the manifest information to a specified file format as discussed below. The advance manifest must include the Uniform LLRW Manifest, and if applicable, LDR Notification/Certification forms, Uniform Hazardous Waste Manifest, and SNM Exemption Certification form.

Additional shipping paperwork may be required depending on the type of waste being shipped to EnergySolutions. Multiple waste streams on a single conveyance must include a unique set of shipping paperwork for each manifested shipment. The following paperwork may also need to accompany the shipping paperwork as applicable:

" SNM Exemption Certification form. This form must be completed, signed, and included with the shipping paperwork for shipments containing Special Nuclear Material.

" LDR Certification and/or Notification form must contain the information required in 40 CFR 268.7.

EnergySolutionsrequires that this information be provided with each shipment of Mixed Waste or waste that has been treated to meet 40 CFR 268 treatment standards.

" Uniform Hazardous Waste Manifest must be included with the shipping paperwork for waste shipments of Mixed Waste. As applicable, EnergySolutionsrequests that shippers list the gross weight on the manifest.

5.4.1 Instructions for the Uniform LLRW Manifest Forms 540, 541, and 542 The NRC's guidance document "Instructions for Completing the NRC's Uniform Low-Level Radioactive Waste Manifest" (NUREG/BR-0204, Rev. 2, July 1998) should be used by shippers when preparing the shipping paperwork. EnergySolutions requires shippers to include information in both metric units and English units following the International Standard of Units (SI). Additionally, EnergySolutions has specific information that should also be included on the Uniform LLRW Manifest.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 46 Revision 7 Waste Acceptance Criteria

Form 540

" Block 5, "Shipper" must list the shipper's company name and facility that corresponds to the Utah Generator Site Access Permit (GSAP) number. Shippers shipping on behalf of the generator and using their GSAP number should list "(shipper's company name) on behalf of (generator's name)".

" Block 5, "Shipment Number" and "Shipment ID Number" may be used by the shipper for their own tracking purposes. In most cases, shippers use the "Manifest Number" in Block 8 as the "Shipment ID Number".

Block 8, "Manifest Number" must list the EnergySolutions shipment number in the following format: (XXXX-YY-ZZZZ) where XXXX is the generator number, YY is the waste stream number, and ZZZZ is the shipment number (starting with 0001 for the first shipment and incrementing by one for each additional shipment).

Block 9, "Consignee" must list EnergySolutions' disposal site address as shown below, contact name and telephone number. The address must specify EnergySolutions' "Treatment Facility" or "Bulk Waste Facility". List "Bulk Waste Facility" for LLRW, I Ie.(2) Byproduct Material, and Mixed Waste shipped for direct disposal or list "Treatment Facility" for waste streams requiring treatment by EnergySolutionsprior to disposal.

EnergySolutions, LLC Clive Disposal Site - Bulk Waste Facility Interstate 80, Exit 49 Clive, UT 84029 Form 541

" Block 6, "Container Description" specifically applies to the disposal container. For bulk shipments (e.g., gondola railcars, intermodals, etc.), list "11" for "Bulk, Unpackaged Waste" along with the bulk packaging descriptor if the bulk package does not contain other manifested packages inside.

For example, a gondola railcar with a super-load wrapper would be listed as "1 A" in Block 6.

" Blocks 7 and 8, "Volume" and "Waste and Container Weight" must list the gross volume and weight of the disposal container and contents. For bulk, unpackaged waste where the waste package will not bedisposed (e.g., gondola railcar, intermodal, etc.), list the weight and volume of the waste.

Block 15, "Radiological Description" must also include a column for the radionuclide concentration expressed in units of pCi/g.

Block 16, "Waste Classification" must list "AU" for Class A Unstable LLRW. Waste packages must also be labeled either "Class A Unstable" or "Class AU". For NORM or 1 e.(2) waste material, enter "N/A" since the waste classification requirements are not applicable.

Form 542 Form 542, "Manifest Index and Regional Compact Tabulation) is required for processors and collectors of LLRW who are shipping LLRW attributed to others for ultimate disposal at EnergySolutions.

EnergySolutions requires that processors or collectors submitting the Form 542 do so electronically using the file transfer protocol described in Section 5.4.2 due to the size of the manifest.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 47 Revision 7 Waste Acceptance Criteria

5.4.2 Electronic Submittal of the Uniform LLRW Manifest EnergySolutions developed a document titled "Electronic Submittal of the Uniform Low-Level Radioactive Waste Manifest" to assist generators with the electronic submittal of the Uniform Low-Level Radioactive Waste Manifest (Forms 540, 541 and 542). Generators are able to submit their manifests electronically in a comma-delimited file format to the EnergySolutions disposal facility for review and distribution. Upon arrival, manifests are imported directly into EnergySolutions' waste tracking system.

Manifest information is checked against the information contained in the generators Waste Profile. Any discrepancy will be automatically flagged, allowing potential problems to be fixed well in advance of shipment arrival.

Electronic manifest submittal has numerous benefits for both the generator and EnergySolutions which include:

" Generators are able to e-mail their shipping manifests directly to the site, reducing the time and expense of express mailing or faxing copies to the disposal facility.

The generator can use the electronic signature feature, eliminating the need for any advance hard copies to be sent to EnergySolutions.

" EnergySolutionspersonnel can print the required copies of'the manifest, including electronic signature, and distribute for proper review.

" The import of manifest information directly to EnergySolutions' waste tracking system will eliminate manual data entry.

Electronic submittal will significantly reduce the time it takes EnergySolutions personnel to process the advanced paperwork.

5.5 90-DAY SHIPPING FORECAST The 90-Day Shipping Forecast is used by EnergySolutions to properly staff and ensure adequate resources are available to ensure efficient and timely management of waste shipments. Generators are strongly encouraged to provide EnergySolutions with a 90-Day Shipping Forecast for all upcoming shipments. Current shippers will receive a fax or email from EnergySolutions every month and are requested to return the shipping forecast to EnergySolutions within three working days of receipt. The forecast can also be emailed to the appropriate Client Service Manager.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 48 Revision 7 Waste Acceptance Criteria

SECTION 6 PACKAGING AND TRANSPORTATION 6.1 COMPLIANCE WITH TRANSPORTATION REGULATIONS Each shipment of waste material sent to EnergySolutions for disposal must be properly classed, described, packaged, marked, labeled, and in condition for transport as required by the Department of Transportation (DOT) Hazardous Materials Regulations (HMR) contained in 49 CFR Parts 171 through 180. Shipments of radioactive waste that are exempt from DOT regulations must be shipped to EnergySolutions' disposal site in packages that prevent release of the waste during transit. Specifically, all waste packages must be secure to

1) prevent rain or snow from entering the manifested waste package and 2) prevent waste from being exposed to the environment at any time during transit. Shippers should review NRC JE Bulletin No. 79-19 for training requirements applicable to radioactive waste management.

EnergySolutions will inspect each shipment arriving at its disposal facility for compliance with the applicable licenses and/or permits including compliance with DOT HMR requirements. EnergySolutionswill notify the generator of a non-compliant shipment and determine the best course of action to resolve the discrepancy in a safe, compliant, and timely manner.

6.2 WASTE PACKAGING GUIDELINES EnergySolutions receives waste for disposal either in bulk or in non-bulk packages. The packaging used must be authorized for the specific material being shipped by the HMR. Each generator is responsible for ensuring that the packaging used meets the appropriate regulations. The shipper of waste material is responsible for the certification of the packaging as meeting the DOT requirements. The DOT and NRC have published a joint guidance document to assist shippers of LSA and SOC material. The title of this document is "Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Objects" (NUREG-1608 or RSPA Advisory Guidance 97-005). The document is available from either agency. The following minimum packaging requirements must be met for all packages received at EnergySolutions.

6.2.1 Bulk Packaging Generators are able to minimize packaging and transportation costs by utilizing bulk packages that are intended for re-use. EnergySolutions receives various bulk packages illustrated in Figure 6-1 which include gondola railcars with either hard-top lids or super-load wrappers, intermodals, sealands, cargo containers, roll-offs, etc. Bulk packages are unloaded at EnergySolutions and then decontaminated, surveyed, and returned in accordance with the requested radiological release criteria specified in Section 6.5. Bulk packaging must conform to the following requirements:

" Bulk packaging must, at a minimum, meet the applicable requirements contained in 49 CFR 173.24, General Requirements for Packagings and Packages and in 49 CFR 173.410, General Design Requirements.

Bulk packaging must be covered. The top must be completely enclosed with no opening along the sides or openings in the top.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 49 Revision 7 Waste Acceptance Criteria

Bulk packaging (e.g., railcars, trucks, trailers, etc.) must also be tightly sealed to prevent waste from leaking out or water fromnleaking in to the package. Packages containing unauthorized free liquids will be considered non-compliant.

Bulk packaging must be clean. It must not have any waste material, or other material that could be mistaken for waste material, on the outer surface. EnergySolutions will perform contamination surveys on suspect areas of the package to ensure compliance with DOT regulations.

Bottom dump railcars and end-dump trucks are not permitted unless approved in writing by EnergySolutions.

Bulk packaging in intermodals, sealands, cargo containers, roll-offs, etc. must have ISO connectors on the top comers as illustrated in Figure 6-1 to allow the containers to be lifted from the top unless approved in writing by EnergySolutions.

Friable asbestos is prohibited in bulk packages unless approved in writing by EnergySolutions.

Each bulk container, which requires marking, will be properly marked in accordance with 49 CFR 172 Subpart D.

Bulk packaging may not contain a mixture of bulk, unpackaged waste and manifested packaged waste (e.g., an intermodal containing loose unpackaged soil with manifested disposal containers within the same intermodal).

6.2.2 Non-Bulk Packaging (Disposal Containers)

EnergySolutions receives non-bulk packages (disposal containers) including boxes, drums, super sacks, etc.

The disposal container is generally disposed of with the waste contents and will not be returned to the generator. EnergySolutions recommends drums be palletized to reduce the amount of time required to offload drum shipments. Palletized drums are also safer to manage at the disposal site. Generators may be charged extra for shipments containing non-palletized drums. Drums on one pallet must be from the same waste stream unless approved in writing by EnergySolutions. Contact EnergySolutions to request approval to ship non-palletized drums prior to shipment. Non-Bulk packaging must conform to the following requirements:

Non-Bulk packaging must, at a minimum, meet the applicable requirements contained in 49 CFR 173.24, General Requirements for Packagings and Packages and in 49 CFR 173.410, General Design Requirements.

Containers must be properly sealed to prevent load movement from "pumping" dust-laden air out of the container.

Containers must be clean. They must not have any waste material, or other material, which could be mistake for waste material, on the outer surface. EnergySolutions will perform contamination surveys on suspect areas of the package to ensure compliance with DOT regulations.

Containers in a shipment must be properly loaded and blocked and braced securely to prevent shifting and damage during transport. The specific transport loading requirements contained in 49 CFR 174 for rail and 49 CFR 177 for highway should be examined as well as 49 CFR 393 Subpart I, Protection Against Shifting and Falling Cargo.

Although preferred, containerized rail shipments are not required to be enclosed or covered.

Do not have unnecessary container closures; e.g., welding of drum rings or box lids.

Non-bulk packages will not be returned to the generator.

" Overpack containers only when necessary (e.g., to meet DOT requirements) for shipment.

EnergySolutions prefers drums to be palletized to reduce the amount of time required to offload drum shipments. Palletized drums are also safer to manage at the disposal site. The pallets must EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 50 Revision 7 Waste Acceptance Criteria

be strong enough to withstand collapse during transit. The drums should be securely banded to the pallet.

Truck or railcar beds used to transport containers must be free of all loose material, waste or otherwise.

Each container that is required to be labeled will be properly labeled in accordance with the requirements of 49 CFR 172 Subpart E and UAC R313-15-1008.

Each container that is required to be marked will be properly marked in accordance with the requirements of 49 CFR 172 Subpart D and/or 49 CFR 173.421 and Subpart 425.

4-V~%~

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 51 Revision 7 Waste Acceptance Criteria

Figure 6-1. Bulk Shipping Containers 6.3 HIGHWAY TRANSPORTATION For highway shipments (Figure 6-2), EnergySolutions is locatedjust three miles south of Interstate 80 at the Clive Exit (Exit 49). Highway shipments should arrive for receipt and acceptance between 7:00 AM to 12:00 PM MST, Monday through Friday only. Shipments that arrive after 12:00 PM may not be accepted until the next day unless special handling arrangements have been previously approved.

Figure 6-2. Truck Highway Shipments Shipments are generally unloaded on a first-come, first-served basis. Non-compliant shipments may result in unexpected delays. Shipments may take up to four hours to be checked in, inspected, surveyed, evaluated, EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 52 Revision 7 Waste Acceptance Criteria

and unloaded. Consequently, drivers should be informed that there are no eating facilities within the vicinity of the site.

6.4 RAIL TRANSPORTATION Rail shipments will be delivered to the EnergySolutions' rail siding by the Union Pacific railroad on a predetermined schedule (Figure 6-3). Once at EnergySolutions' siding, they will be moved into the disposal site by EnergySolutions' equipment.

Figure 6-3. Rail Shipments Since the signed copies of the Uniformed Low-Level Radioactive Waste Manifest or Uniform Hazardous Waste Manifest forms do not travel with the railcars during transport, the original signed manifest must be mailed or electronically transferred to the Clive Disposal Facility. The documents must arrive at the Clive Disposal Facility a minimum of 3 working days prior to the receipt of the rail shipment.

6.5 RELEASE OF SHIPPING CONVEYANCES The timeframe for the release of shipping conveyances (e.g., trucks, intermodal containers, railcars, etc.)

is based on the specific contractual arrangements that have been established between each generator and I EnergySolutions. Generators must request the type of radiological release prior to the shipment's arrival and must be allowed under the Terms and Conditions of the disposal agreement. The requested release types must be authorized by EnergySolutions' Business Development Department. Containers released to the Unrestricted Use criteria require significantly more time and expense due to the resources needed to meet these release criteria. EnergySolutions performs the following types of radiological releases as listed in the following table.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 53 Revision 7 Waste Acceptance Criteria

EnergySolutions Radiological Release Criteria Release Type Criteria Reference Unrestricted Use Removable and fixed surface contamination levels are US NRC Regulatory isotope specific. The most restrictive isotopic removable Guide 1.86, June 2

surface contamination levels are less than 20 dpm a/100 cm 1974 and 200 dpm j3-7/100 cm 2 . The most restrictive isotopic (Consistent with total surface contamination levels are less than 100 dpm EnergySolutions' 2 2 (X/100 cm and 1,000 dpm 03-7/100 cm . The contamination RML Condition 27) levels apply to all internal and external surfaces. Contact EnergySolutions' Business Development Department to make contractual arrangements for this type of release.

Return to Service Removable surface contamination levels must be less than 49 CFR 173.443(c) 220 dpm a/] 00 cm 2 and 2,200 dpm p3-7/100 cm 2 . The radiation dose rate at each accessible surface must be less than 0.5 mrem!hr. The contamination levels apply to all internal and external surfaces of the transport vehicle.

DOT Empty Removable surface contamination levels on the outside of 49 CFR 173.428 the package must be less than 220 dpm ax/100 cm 2 and 2,200 dpm 7/100cm 2 . Removable surface contamination levels on the inside of the package must be less than 22,000 dpm 2 2 (X/100 cm and 220,000 dpm P3-y/100 cm . The package must be emptied of contents to the extent practical.

Sole Use Removable surface contamination levels on the outside of2 49 CFR 173.443(d) the transport vehicle must be less than 220 dpm (x/100 cm and 2,200 dpm P-7/100 cm 2 . The radiation dose rate on the internal surfaces must be less than 10 mrem/hr or 2 mremlhr at one meter from the surface.

EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities 54 Revision 7 Waste Acceptance Criteria

APPENDIX A CONTACT INFORMATION Ener2ySolutions Corporate Office Phone: (801) 649-2000 Fax: (801) 537-7345 Technical Service Fax: (801) 413-5664 Shipment Scheduling Phone: (435) 884-0155 Fax: (435) 884-3549 Email: scheduling@energysolutions.com I Shipping & Receiving Phone: (435) 884-0155 Fax: (801) 413-5643 Email: manifest@energysolutions.com EnergySolutions Website: www.energysolutions.com State of Utah Utah Dept of Environmental Quality: www.deq.state.ut.us Utah Division of Radiation Control (DRC) Email: drcadmin@utah.gov Utah Division of Radiation Control Website: www.radiationcontrol.utah.gov Utah DRC - Generator Site Access Permit: (801) 536-0077 Utah DRC - Generator Site Access Permit: www.radiationcontrol.utah.gov/DRC_prmt.htm Utah DRC Rules: www.radiationcontrol.utah.gov/rules.htm Utah Division of Solid and Hazardous Waste: www.hazardouswaste.utah.gov Utah DSHW Rules: www.hazardouswaste.utah.gov/rpc.htm Utah Dept of Health - Lab Certification: health.utah.gov/els/labimp/envlabcert.html State-Issued Part B Permit: www.hazardouswaste.utah.gov/HWBranch/CFFSection/EnvirocarePermit.htm EnergySolutions November 2008 Bulk Waste Disposal and Treatment Facilities A-1 Revision 7 Waste Acceptance Criteria

Enclosure 5.1 to Attachment 1 Corporate Environmental Policy Directive

Policy No. ENV DISTRICT POLICY Issue Date 03-30-06 Page 1 of 3 ENVIRONMENTAL Nebraska Public Power District (NPPD or the District) will conduct all aspects of its business in an environmentally responsible manner. This document provides the general environmental policy statement and guiding environmental principles for NPPD.

NPPD is dedicated to protecting environmental quality while meeting the energy needs of Nebraska. Therefore, NPPD will be managed and operated in a manner that reflects our commitment to environmental compliance and stewardship.

This policy applies to all NPPD operations and employees.

NPPD will adhere to the following environmental principles to meet NPPD's Commitment to the Environment (Attachment 1):

Ensure environmental factors are an integral part of planning, design, construction, and operational decisions.

" Comply with all applicable environmental laws and regulations.

Participate with other organizations to develop effective and reasonable environmental laws and regulations.

Maintain an ongoing assessment of our activities, address non-conformances, and systematically review and continuously improve our environmental management systems and policy.

" Ensure proper handling, treatment, and disposal of all waste streams while taking steps to control their generation and encourage pollution prevention, recycling, and development of markets for certain wastes.

" Establish performance measures to track and direct operations.

" Establish and implement appropriate procedures regarding environmental regulations.

" Acknowledge our responsibilities to be good stewards of the resources entrusted to NPPD.

Retention Code A30

Policy No. ENV DISTRICT POLICY Issue Date 03-30-06 Page 2 of 3 Author: Joe Citta Next Review Date: 12-15-09 Reviewed By: Karla Tremel Date Reviewed: 03-29-06 Ron BodAsche o iecr Date Approved: 03-30-06 Approved By: Board of Directors Modified Attachment 1 to reflect Ron 03-23-06 Joe Citta Asche as President and CEO.

01-19-07 Joe Citta Annual review. No changes.

12-31-07 Joe Citta Annual review. No changes.

01-19-09 Joe Citta Annual review. No changes.

Retention Code A30

Policy No. ENV DISTRICT POLICY Issue Date 03-30-06 Page 3 of 3 ATTACHMENT 1 MANAGEMENT'S COMMITMENT TO THE ENVIRONMENT (42Management

MMITMENT to the ENVIRONMENT NPPD is committed to operating in an environmentally responsible manner. We. are, dedicated to protecting environmental quality while meeting the energy needs of Nebraska.

Therefore, the District will be managed and operated in a: manner that reflects: our commitment to environmental compliance and stewardship.

Ronald D. Asche President and CEO IN Nebraska Public Power District Alwu , thmenhou n. d us Retention Code A30

Enclosure 5.2 to Attachment 1 Corporate Environmental Manual Chapter 12, "Waste Minimization"

CHAPTER 12: WASTE MINIMIZATION 12: Waste Minimization Plan I. Subject Area/Activity Scope II. NPPD Operations Affected III. Regulatory References IV. NPPD Policy/Program References V. Corporate Plans/Interpretations/Guidance Federal Requirement National Policy NPPD Waste Minimization Philosophy Program Elements Top Management Support Characterization of Waste Generated and Waste Management Costs Periodic Waste Minimization Assessments Cost Allocation System Encouragement of Technology Transfer Program Implementation and Evaluation In Addition Recordkeeping Requirements Reporting Requirements Regulatory - NDEQ VI. Training Requirements A. Hazardous Wastes Miscellaneous Solvent Mixtures Scrap Lead Solvent Rags Spent Lead-Acid Batteries Spent Nickel-Cadmium (NiCad) Batteries (Wet- and Dry-Cell)

Waste Acid Waste Antifreeze (Ethylene Glycol)

Section 2. Solid and Hazardous Waste Page 12-1 June 2008

CHAPTER 12: WASTE MINIMIZATION Waste Freon and Freon/Oil Mixtures Waste Mercury, Mercury Batteries, and Mercury-Contaminated Material Waste Paint Liquids, Paint/Solvent Still Bottoms Waste Petroleum Naphtha, Waste Cleaning Compound Aerosol Cans Waste Solvent Mixture (Mixed Waste)

Used Oil and Solvent Mixes (Mixed Waste)

B. Nonhazardous Wastes Used Oil Paper Cardboard Aluminum Cans Wood Tires Section 2. Solid and Hazardous Waste Page 12-2 June 2008

CHAPTER 12: WASTE MINIMIZATION I. SUBJECT AREA/ACTIVITY SCOPE This Waste Minimization Plan provides the District locations with a document that meets the regulatory requirement for large quantity generators (LQG) of hazardous waste to have "a program in place to reduce both the volume and toxicity of hazardous wastes generated to the extent economically feasible." The regulatory requirements for such a program are found in Sections 3002(b) and 3005(h) of the Resource Conservation and Recovery Act (RCRA),

as amended by the Hazardous and Solid Waste Amendments Act of 1984 (HSWA).

The scope of this plan has been expanded to include certain large-volume nonhazardous waste streams as well as hazardous waste streams.

II. DISTRICT OPERATIONS AFFECTED Although the requirement to have a waste minimization program in place applies specifically to large quantity hazardous waste generators, this plan can be used as a model by any District facility which generates hazardous and nonhazardous waste, regardless of its generator status under RCRA.

III. REGULATORY REFERENCES

1. 42 U.S.C. 6922(b) and 6925(h)

2. 40 CFR Part 262

3. Nebraska Standards for Hazardous Waste Generators - Part 262, 15A NCAC/3A.0007

4. Nebraska Standards Applicable to Generators of Hazardous Waste, R.61-79.262

5. Pollution Prevention Act of 1990, 42 U.S.C. 13101, et seq.

6. EPA Form 8700-22, The Uniform Hazardous Waste Manifest and Instructions

7. Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program, 58 FR 31114 (May 28, 1993)

8. Nebraska Department of Environmental Quality Aerosol Can Waste Document (12/2005)

IV. NEBRASKA PUBLIC POWER DISTRICT POLICY/PROGRAM REFERENCES Section 2. Solid and Hazardous Waste Page 12-3 June 2008

CHAPTER 12: WASTE MINIMIZATION V. CORPORATE PLANS/INTERPRETATIONS/GUIDANCE Federal Requirement The Solid Waste Disposal Act, as amended by RCRA and HSWA, requires large quantity generators of hazardous waste to implement programs to reduce both the volume and toxicity of hazardous wastes generated to the extent economically feasible. Large quantity generators are also required by law to certify that they have such a program in place when they sign the hazardous waste manifest.

National Policy EPA is committed to a national policy for hazardous waste management that places a high priority on waste minimization. In the Pollution Prevention Act of 1990, Congress stated that the national policy of the United States is that "pollution should be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other release to the environment should be employed only as a last resort and should be conducted in an environmentally safe manner." Therefore, waste minimization includes both:

1. Source reduction

2. Environmentally sound recycling On May 28, 1993, EPA issued Interim Final Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Plan (58 FR 31114). In this guidance, the Agency outlined what it believes to be the basic elements in "good" waste minimization plans. These basic elements include:

1. Top management support

2. Characterization of waste generation and waste management costs

3. Periodic waste minimization assessments

4. Appropriate cost allocation

5. Encouragement of technology transfer

6. Program implementation and evaluation Section 2. Solid and Hazardous Waste Page 12-4 June 2008

CHAPTER 12: WASTE MINIMIZATION NPPD Waste Minimization Philosophy The hierarchy of the waste minimization program at the District is as follows:

1. Hazardous and nonhazardous waste should be eliminated or reduced at the source whenever feasible.

2. Hazardous and nonhazardous waste that cannot be eliminated at the source should be recycled or reused in an environmentally safe manner whenever feasible.

3. Hazardous and nonhazardous waste that cannot be eliminated or recycled should be treated in an environmentally safe manner.

4. Disposal or other controlled release into the environment should be used only as a last resort and be conducted in an environmentally safe manner, complying with all local, state, and federal regulations.

Program Elements The NPPD plan has been expanded to include certain nonhazardous waste streams.

Additionally, it applies not only to large quantity hazardous waste generators, but also to all types of waste generators.

The NPPD waste minimization philosophy incorporates the basic elements identified in the EPA guidance document.

TOP MANAGEMENT SUPPORT One of the District's underlying principles recognizes waste minimization as an essential element of the District's commitment to protecting and enhancing our environment. This commitment is supported by the District's Environmental Policy, which is signed by the President/CEO. All employees are responsible for integrating environmentally responsible practices into their work activities, including, but not limited to, waste minimization.

CHARACTERIZATION OF WASTE GENERATED AND WASTE MANAGEMENT COSTS The company has developed various ways to track types, amounts, hazardous constituents, and generation dates of wastes at the various facilities. This also provides a true accounting of waste disposal costs, including sample costs, approval costs, disposal costs, and transportation costs. On occasion, the District may use the Electric Power Research Institute (EPRI) "Life Cycle" cost analysis to better understand and evaluate the "true costs" associated with these products, including waste disposal costs.

Section 2. Solid and Hazardous Waste Page 12-5 June 2008

CHAPTER 12: WASTE MINIMIZATION PERIODIC WASTE MINIMIZATION ASSESSMENTS Periodic assessments of location environmental programs are conducted to identify areas for improvement in minimizing NPPD's hazardous and nonhazardous waste.

ENCOURAGEMENT OF TECHNOLOGY TRANSFER The Corporate Environmental Department is responsible for ensuring that technical information on waste minimization is communicated throughout the District. This is accomplished through various means, including articles in District publications, use of consumable review teams at power generation locations to identify and implement new source reduction initiatives, and various websites or emails.

PROGRAM IMPLEMENTATION AND EVALUATION Periodic assessments are conducted to review waste minimization program effectiveness.

Data obtained from the various tracking systems are used to determine whether individual waste stream volumes are increasing or decreasing annually.

Recordkeeping Requirements No specific recordkeeping requirements are associated with this plan. There are, however, recordkeeping requirements associated with the hazardous waste manifest and regulatory required biennial waste minimization reports. These are described in detail in "Reports Requiring Information From the Manifest" in Chapter 5 of Section 2 of this manual.

VI. TRAINING REQUIREMENTS No training requirements are associated with this waste minimization plan. However, NPPD personnel involved with identifying, handling, or otherwise managing hazardous wastes shall be provided with general and technical waste minimization information routinely. No training requirements are associated with managing nonhazardous waste.

A. HAZARDOUS WASTES The waste streams listed below are discussed in more detail on the following pages:

1. Miscellaneous solvent mixtures

2. Scrap lead

3. Solvent rags

4. Spent lead-acid batteries Section 2. Solid and Hazardous Waste Page 12-6 June 2008

CHAPTER 12: WASTE MINIMIZATION

5. Spent nickel-cadmium (NiCad) batteries (wet and dry cell)

6. Waste acid

7. Waste antifreeze (ethylene glycol)

8. Waste freon and freon/oil mixtures

9. Waste mercury, mercury batteries, and mercury-contaminated material

10. Waste paint liquids, paint/solvent still bottoms

11. Waste petroleum naphtha, waste cleaning compound

12. Aerosol cans

13. Waste solvent mixture (mixed waste)

14. Used oil mixed with solvents As a waste minimization philosophy, a hierarchy of source reduction, recycling, and disposal is identified as an approach for each of the listed waste streams. Under each waste stream, possible sources of generation are identified. Possible alternatives for consideration are provided for each waste stream under Source Reduction, Recycling, and Disposal.

Options are not limited to those listed and utilization of advanced technologies and products is encouraged.

Miscellaneous Solvent Mixtures HAZARDOUS WASTE IDENTIFICATION CODES DOO1, D004, D005, D006, D007, D008, D009, D010, DO 11, FOO1, F003, or F005 WASTE DESCRIPTION Miscellaneous solvent mixtures are hazardous because of the ignitability characteristic; the possible toxicity characteristic for arsenic, barium, cadmium, chromium lead, mercury, selenium, and silver; and if they contain, F-listed solvents.

METHOD OF GENERATION Miscellaneous solvent mixtures are generated at various locations as a result of normal cleaning, maintenance, and laboratory analytical activities. Specific areas of generation include use in parts cleaners, general cleaning/degreasing activities, and through the analysis of fuel oils.

Section 2. Solid and Hazardous Waste Page 12-7 June 2008

CHAPTER 12: WASTE MINIMIZATION WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Substitute F-listed solvents with nonregulated solvents (e.g., use PF-Degreaser or ZEP cleaner in place of 1, 1, 1 Trichloroethane).

b. Substitute F-listed solvents with solvents that are hazardous only because of the ignitability characteristic.

c. Segregate F-listed solvent wastes from other liquid wastes.

2. Recycling

a. Recycling on-site, using solvent recovery unit, and reuse solvent (paint thinners).

b. Add filtration systems to parts washers to extend solvent life.

c. Ship to vendor for off-site solvent recovery.

3. Disposal

a. Ship to vendor for disposal. Material is burned as a fuel for energy recovery at various facilities (i.e., cement kilns). Environmental should be contacted to ensure proper disposal.

ADDITIONAL GUIDANCE None.

Scrap Lead HAZARDOUS WASTE IDENTIFICATION CODES D008 WASTE DESCRIPTION Hazardous waste because of the toxicity characteristic for lead.

METHOD OF GENERATION Generated during repair and removal of lead piping, shielding, and sheeting.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Proper maintenance reduces the frequency of lead repair and removal.

Section 2. Solid and Hazardous Waste Page 12-8 June 2008

CHAPTER 12: WASTE MINIMIZATION

2. Recycling

a. Ship to a vendor that accepts lead scrap for reclamation in a secondary lead smelter.

3. Disposal

a. Scrap lead is subject to federal land-disposal restrictions when landfilled. Scrap lead being landfilled shall be treated using a metals recovery process.

ADDITIONAL GUIDANCE None.

Solvent Rags HAZARDOUS WASTE IDENTIFICATION CODES FOOl, F002, F003, or F005 (varies)

WASTE DESCRIPTION Rags contaminated with any F-listed solvent.

METHOD OF GENERATION At various locations from normal cleaning or maintenance activities involving the use of F-listed solvents.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Substitute F-listed solvents with nonregulated solvents (e.g., use ZEP cleaner in place of 1, 1, 1 Trichloroethane).

b. Substitute F-listed solvents with solvents that are hazardous only because of the ignitability characteristic.

c. Segregate solvent rags from other rags at the point of generation.

d. Ban the use of F-listed solvents for most applications.

2. Recycling

a. Launder and reuse solvent rags either on-site or using an industrial laundering service. Rags laundered for reuse are not considered hazardous wastes per guidance from EPA Region VII.

Section 2. Solid and Hazardous Waste Page 12-9 June 2008

CHAPTER 12: WASTE MINIMIZATION

b. Ship to vendor for fuel blending. This fuel is burned for energy recovery at a cement kiln.

3. Disposal

a. Incineration.

ADDITIONAL GUIDANCE None.

Spent Lead-Acid Batteries HAZARDOUS WASTE IDENTIFICATION CODES D002, D008 WASTE DESCRIPTION Hazardous waste because of the toxicity characteristic for lead and the corrosivity characteristic for sulfuric acid. The acid may be in the form of a liquid or a gel.

METHOD OF GENERATION Automotive batteries are replaced at location garages when damaged or unable to maintain a charge. Spent lead-acid batteries are also generated at other locations.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Follow normal changeout schedule recommended for equipment maintenance.

b. Test to determine whether changeout is necessary.

2. Recycling (Exchange with local vendor.)

ADDITIONAL GUIDANCE None.

Section 2. Solid and Hazardous Waste Page 12-10 June 2008

CHAPTER 12: WASTE MINIMIZATION Spent Nickel-Cadmium (NiCad) Batteries (Wet-and Dry-Cell)

HAZARDOUS WASTE IDENTIFICATION CODES D002, D006, or D008 (varies)

WASTE DESCRIPTION Spent Wet-Cell NiCad Batteries Hazardous wastes because of their corrosivity and levels of cadmium.

Spent Dry-Cell NiCad Batteries Hazardous wastes because of their levels of cadmium and lead.

METHOD OF GENERATION NiCad batteries are rechargeable and are used primarily in cordless rechargeable appliances.

In power plants, they are used for emergency lighting and as backup power for diesel generators. NiCad batteries are replaced when damaged or unable to maintain a charge.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Follow normal changeout schedule recommended for equipment maintenance.

b. Test to determine whether changeout is necessary.

2. Recycling

a. Ship to vendor (RBRC) for nickel and cadmium metals recovery or ship to York Operations Center.

3. Disposal

a. NiCad batteries should always be recycled, not disposed.

ADDITIONAL GUIDANCE None.

Section 2. Solid and Hazardous Waste Page 12-11 June 2008

CHAPTER 12: WASTE MINIMIZATION Waste Acid HAZARDOUS WASTE IDENTIFICATION CODES Battery Acid D002 Waste Acid D002, D006, D007, D008 WASTE DESCRIPTION Waste Battery Acid Hazardous waste because of the corrosivity characteristic and the toxicity characteristics for cadmium, chromium, and lead.

METHOD OF GENERATION Waste Battery Acid Generated when automotive batteries are drained before being sent for lead recovery.

Waste Acid Generated from sources such as metal cleaning operations and from sulfuric acid tank sludge cleanout.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Follow normal changeout schedule recommended for equipment maintenance.

b. Test to determine whether changeout is necessary.

2. Recycling

a. Waste acid, which is hazardous only because of the corrosivity characteristic, may be reused as a product "treatment" in the station wastewater treatment system for neutralization purposes. The station chemistry group shall approve this reuse before the waste acid is reused.

3. Disposal Section 2. Solid and Hazardous Waste Page 12-12 June 2008

CHAPTER 12: WASTE MINIMIZATION

a. Neutralization.

ADDITIONAL GUIDANCE None.

Waste Antifreeze (Ethylene Glycol)

HAZARDOUS WASTE IDENTIFICATION CODES D004 or D008 (varies)

WASTE DESCRIPTION May be hazardous because of the toxicity characteristics for arsenic and lead.

METHOD OF GENERATION Generated at various locations from normal vehicle maintenance and routing chiller maintenance.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Follow normal changeout schedule recommended for equipment maintenance.

b. Test to determine whether changeout is necessary.

2. Recycling

a. Use an approved supplier for ethylene glycol recycling, either on-site or off-site.

3. Disposal

a. Used hazardous ethylene glycol should only be recycled, not disposed.

b. Discharge nonhazardous ethylene glycol through the conventional wastewater system within limits specified by the NPDES permit.

ADDITIONAL GUIDANCE None.

Section 2. Solid and Hazardous Waste Page 12-13 June 2008

CHAPTER 12: WASTE MINIMIZATION Waste Freon and Freon/Oil Mixtures HAZARDOUS WASTE IDENTIFICATION CODES F002, U121 WASTE DESCRIPTION May be hazardous if considered F-listed or because they are included on the EPA's U-list.

METHOD OF GENERATION Generated periodically by normal maintenance on HVAC refrigeration systems. Also generated through disposal of unused product. (See CFC Chapter.)

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Substitute newer nonregulated freons for hazardous freons.

b. Ensure that oldest stock is taken from the warehouse first.

c. Follow normal changeout schedule recommended for equipment maintenance.

d. Test to determine whether changeout is necessary.

2. Recycling

a. Send for freon recycling through hazardous waste supplier.

3. Disposal

a. Incineration.

ADDITIONAL GUIDANCE See Section 11 of the Corporate Environmental Manual.

Waste Mercury, Mercury Batteries, and Mercury-Contaminated Material HAZARDOUS WASTE IDENTIFICATION CODES D009 Section 2. Solid and Hazardous Waste Page 12-14 June 2008

CHAPTER 12: WASTE MINIMIZATION WASTE DESCRIPTION Hazardous waste because of the toxicity characteristic for mercury.

METHOD OF GENERATION Mercury Collected from broken thermometers, old switches, manometers, and mercury batteries.

Mercury-Contaminated Material Usually the result of small spills and in the form of soil or clothing.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Substitute non-mercury instruments.

b. Attempt to collect as much elemental mercury as possible when cleaning up spills. Recycle this elemental mercury. (If the elemental mercury is not 99% pure, it shall be treated as hazardous waste or recycled.)

2. Recycling

a. Ship elemental mercury and mercury batteries to a vendor for mercury recovery.

3. Disposal

a. For disposal of mercury-contaminated material, hazard6us waste landfill.

ADDITIONAL INFORMATION According to EPA's land ban final rule concerning characteristic hazardous wastes, mercury wastes > 260 ppm mercury shall undergo retorting or roasting before land-disposal, effective May 8, 1992. Mercury wastes< 260 ppm mercury may be solidified to render the waste < TCLP limit for mercury before land-disposal at a hazardous waste landfill.

ADDITIONAL GUIDANCE None.

Section 2. Solid and Hazardous Waste Page 12-15 June 2008

CHAPTER 12: WASTE MINIMIZATION Waste Paint Liquids, Paint/Solvent Still Bottoms HAZARDOUS WASTE IDENTIFICATION CODES DOOl, F003, or F005 (varies)

WASTE DESCRIPTION Paint liquids are hazardous wastes because of ignitability (flashpoint < 140Ei F) and may contain F-listed solvents.

METHOD OF GENERATION Paint Liquids Generated through disposal of excess paint and expired product.

Paint/Solvent Still Bottoms Generated through use of on-site solvent recovery units.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Ensure painters use oldest stock from warehouse first.

b. Ensure painters take only the amount of paint needed to the jobsite to do the job, and the entire amount is used.

c. Substitute with a paint that does not contain hazardous constituents.

d. Attempt to return surplus to manufacturer or sell product through Nebraska Public Power's Investment Recovery area.

2. Recycling

a. Use solvent recovery units to reclaim paint solvents for reuse, thereby reducing the liquid content of liquid paint wastes.

b. Ship to vendor for fuel blending. This fuel is burned for energy recovery at a cement kiln.

3. Disposal

a. Incineration.

Section 2. Solid and Hazardous Waste Page 12-16 June 2008

CHAPTER 12: WASTE MINIMIZATION ADDITIONAL GUIDANCE None.

Waste Petroleum Naphtha, Waste Cleaning Compound HAZARDOUS WASTE IDENTIFICATION CODES Petroleum Naphtha DOO1, D018, D039 Cleaning Compound D006, D007, D008, DO 18, D021, D022, D039, D040 WASTE DESCRIPTION Waste Petroleum Naphtha Hazardous waste because of the ignitability characteristic (flashpoint < 140W F) and the toxicity characteristics for benzene and tetrachloroethylene.

Waste Cleaning Compound Hazardous waste because of the toxicity characteristics for cadmium, chromium, and benzene.

METHOD OF GENERATION As solvents used in parts washers, may be generated at various maintenance locations or at the garage.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Substitute newer, nonhazardous solvents (e.g., PF degreaser, ZEP cleaner) for hazardous solvents.

2. Recycling

a. Ship to vendor for solvent reclamation.

Section 2. Solid and Hazardous Waste Page 12-17 June 2008

CHAPTER 12: WASTE MINIMIZATION

3. Disposal

a. Contact Environmental Department for guidance on disposal.

ADDITIONAL GUIDANCE None.

Aerosol Cans HAZARDOUS WASTE IDENTIFICATION CODES D003 WASTE DESCRIPTION Aerosol cans.

METHOD OF GENERATION At various locations from use of consumable products that are packaged in aerosol cans.

Discarded, empty, or non-functioning aerosol cans meet the definition of a reactive waste unless the can is punctured.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Only use enough product to perform a task, minimize over-spray.

b. Consider purchasing material in bulk and use compressed air rechargeable sprayers.

2. Recycling

a. Collect aerosol cans and contract with a vendor for puncturing of cans and recycling of scrap metal.

b. Collect aerosol cans, purchase a can puncturing device, collect punctured cans and recycle as scrap metal.

3. Disposal

a. Aerosol cans that are not punctured and drained are considered a hazardous waste based upon meeting the criteria for a reactive waste (D003). In this case, the aerosol cans shall be counted towards a facility's generator status.

Section 2. Solid and Hazardous Waste Page 12-18 June 2008

CHAPTER 12: WASTE MINIMIZATION

b. Conditionally-exempt small quantity generators (less than 220 lbs. of hazardous waste generated per month) are allowed to dispose in a regulated municipal landfill up to 43 lbs. per day of non-punctured/non-drained aerosol cans.

c. Small and large quantity generators handle aerosol cans that are non-punctured/non-drained as a hazardous waste.

d. Aerosol cans that are punctured and drained are not considered a hazardous waste and can be disposed in a regulated municipal landfill.

ADDITIONAL GUIDANCE None.

Waste Solvent Mixture (Mixed Waste)

HAZARDOUS WASTE IDENTIFICATION CODES F001, F002, F003, F005 WASTE DESCRIPTION Hazardous because they are, or contain, F-listed solvents.

METHOD OF GENERATION Generated by specific cleaning of equipment/components inside the Radiation Control Area (RCA) with F-listed solvents.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Be specific, limited, and controlled in using F-listed solvents within the plant.

Use F-listed solvents only when mandated by the manufacturer or when a nonhazardous product will not perform the function. This strategy is part of the training received by employees using solvents.

b. The Cooper Nuclear Station has a Chemical Control Program to minimize procuring and using F-listed solvents.

2. Recycling

a. Ship to an approVed vendor to be burned for energy recovery.

3. Disposal Section 2. Solid and Hazardous Waste Page 12-19 June 2008

CHAPTER 12: WASTE MINIMIZATION

a. Contact the Environmental Department for guidance on disposal.

ADDITIONAL GUIDANCE None.

Used Oil and Solvent Mixes (Mixed Waste)

(Radioactive)

HAZARDOUS WASTE IDENTIFICATION CODES F001, F002, F003, F005, D006, D008 WASTE DESCRIPTION Hazardous because of the toxicity characteristics for cadmium and lead and because they contain F-listed solvents.

METHOD OF GENERATION Generated by collecting used oil and solvents in the same storage container. All used oil within the Protected Area at Cooper Nuclear Station is considered radioactively contaminated until cleared by Radiological Protection.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Solvents and oils shall be segregated to eliminate the collection of solvents and used oil in the same container. This shall eliminate generation of this waste stream. Hazardous solvent use can be reduced by substituting nonhazardous solvents.

2. Recycling

a. Ship to vendor to be burned for energy recovery.

3. Disposal

a. None currently available.

ADDITIONAL GUIDANCE None.

Section 2. Solid and Hazardous Waste Page 12-20 June 2008

CHAPTER 12: WASTE MINIMIZATION C. NONHAZARDOUS WASTES The waste streams listed below are discussed in more detail on the following pages:

1. Used oil

2. Paper

3. Cardboard

4. Aluminum cans

5. Wood

6. Tires Used Oil HAZARDOUS WASTE IDENTIFICATION CODES Unregulated.

WASTE DESCRIPTION Used oil contaminated with dirt, water, metals, and/or nonregulated solvents is not currently regulated under RCRA as a hazardous waste, but as off-spec oil. Occasionally, used oil may exhibit hazardous characteristics or become contaminated, requiring it to be disposed of as hazardous waste.

METHOD OF GENERATION Generated continuously by normal maintenance activities (e.g., pump motor oil changeouts)

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Follow normal changeout schedule recommended for equipment maintenance.

b. Test oil before changeout to determine whether it still meets specification.

c. Use oil/water separator to reduce the volume of any water mixed with the used oil. Then discharge the water to the wastewater treatment system.

2. Recycling

a. If the used oil is hazardous, it can be shipped to a fuel blender for ultimate disposal.

Section 2. Solid and Hazardous Waste Page 12-21 June 2008

CHAPTER 12: WASTE MINIMIZATION

3. Disposal

a. Nebraska Public Power District does not land dispose of used oil.

b. If the used oil is hazardous, it may be sent to an incinerator for disposal.

ADDITIONAL GUIDANCE See Section 8 of the Corporate Environmental Manual.

Paper HAZARDOUS WASTE IDENTIFICATION CODES Unregulated.

WASTE DESCRIPTION Wood fiber paper products.

METHOD OF GENERATION Generated throughout the Nebraska Public Power District system primarily from the administrative function.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Copy on two sides, whenever possible.

b. Use electronic mail whenever possible.

c. Print electronic mail only as necessary.

d. Reduce printing orders to exact quantities required. Renegotiate printing contracts so that specific printing overage is not considered a standard practice.

e. Reuse scrap paper for office notes, scratch pads, etc.

2. Recycling Waste paper shall be sorted as follows and shipped to the respective collection facility.

Carbon paper and wrappers from reams of paper are not recyclable.

a. White paper and computer paper.

b. Colored/mixed paper, including envelopes of all kinds but no slick paper.

c. Magazines and newspapers. (These should be sorted if possible.)

Section 2. Solid and Hazardous Waste Page 12.-22 June 2008

CHAPTER 12: WASTE MINIMIZATION

d. Books/manuals/registers.

e. Phone books. (These materials are recycled by local communities in July-August of each year. They should be recycled locally if possible.)

3. Disposal

a. Only carbon paper and wrappers should be disposed of with regular trash.

ADDITIONAL GUIDANCE Many employees collect office paper individually and provide the paper to schools, daycare facilities, scout troops, and other organizations. This practice is supported and encouraged.

Employees need to be cognizant of record retention policies.

Cardboard HAZARDOUS WASTE IDENTIFICATION CODES Unregulated.

WASTE DESCRIPTION Wood fiber.

METHOD OF GENERATION Generated through shipping and receiving activities and office administration.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Request that bulk products be shipped banded or shrink wrapped instead.

2. Recycling

a. Loose cardboard should be flattened, stacked, and banded before being shipped.

b. Gray colored "groundwood" cardboard is not recyclable with cardboard.

Examples of this material include oil filter boxes and the backing of lined pads.

3. Disposal

a. Cardboard disposal may be prohibited by some municipal landfills.

Section 2. Solid and Hazardous Waste Page 12-23 June 2008

CHAPTER 12: WASTE MINIMIZATION ADDITIONAL GUIDANCE None.

Aluminum Cans HAZARDOUS WASTE IDENTIFICATION CODES Unregulated.

WASTE DESCRIPTION Soft drink containers.

METHOD OF GENERATION Generated throughout the Nebraska Public Power system.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction None.

2. Recycling

a. Collect aluminum cans in plastic bags and ship or be resold as scrap aluminum.

b. Collect aluminum cans in plastic bags and recycle locally. Many programs have been set up to benefit local charities (e.g., sending cans to local volunteer fire departments with the proceeds from sale benefiting burned children).

3. Disposal

a. Aluminum cans contain valuable metal and should always be recycled, not disposed.

ADDITIONAL GUIDANCE None.

Section 2. Solid and Hazardous Waste Page 12-24 June 2008

CHAPTER 12: WASTE MINIMIZATION Wood HAZARDOUS WASTE IDENTIFICATION CODES Unregulated.

WASTE DESCRIPTION Nontreated, nonhazardous wood products, including pallets, crating, and construction waste.

METHOD OF GENERATION Generated throughout the Nebraska Public Power system, primarily from shipping and receiving activities.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Create an on-site reuse program where all usable pallets are collected and reissued for reuse. Negotiate with suppliers to obtain specific-size pallets, if needed.

b. Return pallets to vendors/suppliers through contract purchase negotiations.

2. Recycling.

a. Scrap wood may be accumulated at power generation sites until a sufficient quantity exists to bring in a wood grinder or have a scrap wood recycler pick up.

3. Disposal

a. As a last resort only, dispose of scrap wood in permitted landfills.

ADDITIONAL GUIDANCE See Section 2, Chapter 8, "Treated Wood."

Tires HAZARDOUS WASTE IDENTIFICATION CODES Unregulated as a hazardous waste, but regulated by Nebraska Department of Environmental Quality Title 132 - IntegratedSolid Waste Management Regulations.

Section 2. Solid and Hazardous Waste Page 12-25 June 2008

CHAPTER 12: WASTE MINIMIZATION WASTE DESCRIPTION Car, trailer, truck, and equipment tires.

METHOD OF GENERATION Generated at various locations from normal vehicle maintenance.

WASTE MANAGEMENT STRATEGIES USED AT NEBRASKA PUBLIC POWER DISTRICT

1. Source Reduction

a. Follow normal changeout schedule recommended for equipment maintenance.

Avoid damage to tires through careless handling.

b. Evaluate whether tire changeout is needed.

2. Recycling

a. Trade in with a tire dealer that uses an approved tire recycler.

3. Disposal

a. Tires were banned from land disposal in Nebraska as of September 1, 1998.

ADDITIONAL GUIDANCE See Chapter 11 in Section 2 of the Corporate Environmental Manual.

Section 2. Solid and Hazardous Waste Page 12-26 June 2008

.3 to Attachment 1 2008 Recycling Report

Nebraska Pub lic Power District 2008 Recycling Report N4PPD'

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Nebraska Public Power District 2008 Recycling Report The following report summarizes Nebraska Public Power District's (NPPD) recycling efforts in 2008.

The results demonstrate the value of recycling activities to NPPD as a part of corporate environmental stewardship (doing the right thing) and from a financial perspective.

In the interest of promoting pollution prevention and recycling activities, it is important to establish a philosophy that all activities are important, whether large or small, at a corporate, facility and individual level. This is particularly true for a diverse company such as NPPD. Not only is NPPD diverse in the people working for us and their particular beliefs and behaviors, but also greatly diverse in the size and location of our facilities and the types of waste materials generated. In 2008, activities took place at all levels and at varied locations. Each activity is an important part of the overall effort and plays a role in demonstrating the culture of NPPD and its employees.

At NPPD's major facilities, as well as other work locations, recycling efforts are varied and depend largely upon the size of the location, the size of the work force, the types of materials handled, and the availability of recycling options. In a perfect world, all waste material would be recycled. But the reality is that in many instances there are limiting factors that determine which efforts are practical to pursue. Limiting factors include the distance to recycling facilities; a lack of storage space for collected items; and materials not generated in enough volume or frequency to make implementation of recycling practical.

The Environmental Department staff routinely receive requests from employees about recycling options for various materials. This demonstrates that the "environmental conscience" of NPPD employees continues to develop. Inquiries range from what to do with old paints or computers at home, to recycling of plastic bottles or plastic bags, to what options are available for materials and equipment that might be generated as the result of major facility or transmission/distribution projects.

One of the main purposes of having an established Green Team is to have designated persons at NPPD work locations to "champion" recycling or pollution prevention activities. The Green Team Charter is in place to define the Green Team focus (copy attached). The foundation of the charter continues to be based upon pollution prevention or P2 concepts that include the three R's of reduce, reuse and recycle.

The Green Team provides a vehicle to identify, as well as implement, opportunities to increase and/or improve pollution prevention efforts at individual locations and on a company-wide scale. Another key purpose of the Green Team is to promote pollution prevention activities and to educate employees about the importance of pollution prevention. In 2008, a monthly "Green Tip" was included in EZNews and this will continue in 2009.

In 2008, employee membership on the Green Team increased to 30 (list attached). The members are from various NPPD locations around the state, including Beatrice, Canaday, Columbus, Cooper Nuclear Station, Doniphan, Gerald Gentleman Station, Norfolk, North Platte, Scottsbluff, Sheldon Station and the York Operations Center.

NPPD employees are not only expected to "lead by example" at work, but also have this opportunity to do so within our communities. GGS employees cleaning up Sutherland Reservoir, Scottsbluff employees participating in Recycle Your Cycles, and GO employees participating in the 2008 Energy Fest are a few instances where NPPD employees set an example for employees and the public. Details of each of these events can be found later in this report At NPPD, investment recovery activities continue to be a key aspect of recycling efforts. Investment recovery activities represent a proven opportunity to provide a financial return to NPPD. According to the 2008 Investment Recovery Report, these activities resulted in a return of $1,697,704.83. Copies of the 2008 Investment Recovery Report are available from Chet Harger at cwharge@nppd.com.

Investment recovery activities include the sale of scrap, outdated, or obsolete materials that may no longer serve a useful purpose for NPPD. In some instances these materials may still have value to others for reuse or scrap. Examples include the sale of vehicles, computers and other electronic equipment, aluminum wire, steel cable and transformers, copper, brass, etc.

The following is a summary of some of the typical materials recycled and the amounts collected in 2008. The variety of materials and amounts demonstrate that NPPD employees are actively engaged in pollution prevention activities.

Cardboard 32,642 pounds Paper 218,125 pounds Steel 1193.4 tons Aluminum 291.8 tons Copper 136,120 pounds Fly Ash/Bottom Ash 28,127 tons (Sheldon Station - Marketed or Utilized Onsite)

Fly Ash/Bottom Ash 118,260 tons (GGS- Marketed or Utilized Onsite)

Brass 17,562 pounds Lamps 5,180 pounds (10,360 bulbs @ 1/2 lbs per 4 foot lamp)

Batteries 75,090 pounds Computer Equipment 36,743 pounds Used Oil 113,014 gallons (recycled or burned for energy recovery)

Misc Wood 67 pickup loads The following are highlights of various activities completed at NPPD locations throughout 2008.

These activities again demonstrate that colleagues are engaged and working to increase our recycling efforts.

Doniphan

In 2008, Doniphan recycled 3,564 pounds of paper, 547 pounds of cardboard and 220 gallons of used oil. Doniphan also began collecting plastic bags and tin cans on a regular basis, as well as continuing to collect plastic bottles, fluorescent lamps and used oil.

Kearney

During Earth Week 2008, the Kearney Office held a "Clean Your Files" event in which employees were encouraged to take time to clean their office areas and files. During the event, approximately 1,250 pounds of paper was collected for recycling.

Canaday Station

During Earth Week 2008, the Canaday Station held a "Clean Your Files" event in which employees were encouraged to take time to clean their office areas and files. During the event, approximately 475 pounds of paper was collected for recycling Cooper Nuclear Station (CNS)

In 2008, 51.2 tons of office paper were collected and picked up by International Paper (previously Weyerhaeuser) for recycling, an increase of 12.3 tons from 2007.

CNS also recycled 6,800 pounds of batteries, 8,500 pounds of electronic waste, and 2,675 pounds of fluorescent lamps.

" To increase recycling, various recycling containers were distributed throughout the CNS Sheridan Training Center including vending machine areas, instructor offices and classrooms.

Beatrice Power Station (BPS)

In 2008, BPS collected approximately 1,400 pounds of office paper for recycling.

As part of Earth Day Week in 2008, BPS held a Green Challenge contest for employees.

Employees were provided boxes to collect paper for a week. At the end of the week, the employee collecting the most material for recycling received a $25 gift certificate.

York Operations Center (YOC)

" During Earth Week 2008, the YOC held a "Clean Your Files" event in which employees were encouraged to take time to clean their office areas and files. During the event, approximately 2,000 pounds of paper was collected for recycling.

" In 2008, YOC arranged for the recycling of 24,138 pounds of electronic equipment for NPPD.

This included PCs and other office electrical equipment.

YOC sent 99,438 gallons of mineral oil from transformers for recycling in 2008.

Scottsbluff / Chadron / Ogallala

Scottsbluff, Chadron and Ogallala offices continue to discourage the use of paper or plastic drink ware and utensils. All three locations take advantage of ceramic mugs and dishes for employee use as each of the break rooms have dishwasher availability.

" In 2008, the Chadron facility utilized an outside document destruction service to clear out old files and paperwork that were being "stored" in the loft area of the garage. Documents needed for retention as the office of record were organized and moved to a new location.

" The combined efforts of all three locations in 2008 resulted in the collection of 5,181 pounds of paper, 1,525 pounds of cardboard, 340 pounds of plastic and 75 pounds of aluminum for recycling.

" On May 5th, the Scottsbluff office also hosted the third annual "Recycle Your Cycles" event sponsored by Keep Scottsbluff/Gering Beautiful, NPPD and Nebraska Department of Environmental Services. A total of 120 bicycles were dropped off at the NPPD parking lot where five bicycle technicians used parts to create 17 adult bikes and 13 children's bikes. They are distributed without charge to community members through Kiwanis and Panhandle Community Services.

Sheldon Station

In 2008, 2,584 tons of bag-house ash was utilized for soil stabilization by Sheldon Station or others. In addition, 25,543 tons of bottom ash was utilized by McCabe for re-use. Each ton of fly ash or bottom ash marketed or utilized onsite represents a ton of fly ash or bottom ash that does not go into the onsite landfill.

Sheldon Station burned 4,981 gallons of used oil on the coal pile for energy recovery in 2008.

Columbus GO (CGO)

" In 2008, the CGO collected 51,700 pounds of office paper that was sent to the Columbus Recycling Center. An additional 11,300 pounds of shredded paper was also collected.

Arrangements were made to get better at collecting cardboard at the CGO for recycling which resulted in 17,780 pounds of cardboard collected in 2008. Grand total paper and cardboard collected at the CGO for the year was 80,780 pounds or nearly 40.5 tons.

" As part of Earth Day 2008, CGO Green Team members held a "Clean Your Files and Work Area" paper recycling drive at the CGO. The drive ran from April 21s through April 24th with 10,320 pounds of paper collected.

In 2008 the Information Technology and Telecom (ITT) department virtualized over 50 computer servers in the CGO datacenter resulting in estimated annual power and cooling energy savings of $8,000. Virtualization is the ability to run multiple computing environments independent of each other on the same physical server.

" On October 7 th, CGO Green Team members participated in the 2008 Energy Fest by volunteering to pick up trash and separating out recyclables. Plastic bottles and aluminum cans generated during the event were collected for recycling. Keep Columbus Beautiful provided recycling containers for the event. The event was held at Frankfort Square in downtown Columbus and included Energy Partners Loup PPD and Cornhusker PPD.

In conjunction with the GO Can Care-A-Van food drive held May 2 7 th through May 2 9 th, the CGO Green Team members held a plastic bag collection. Bags were sorted and either taken to the Columbus Recycling Center for recycling, or provided to the Platte County Food Pantry for re-use. An exact number of bags collected could not be determined, but was easily in the thousands and the volume filled one corner of the CGO Breakroom.

As part of America Recycles Day activities, the CGO Green Team members held a Coat Drive at the CGO from November 4th through November 21st. A total of 114 adult and childrens coats were collected during the event. A generous amount of hats, gloves, mittens, scarves, and boots were also collected. All items were delivered to local charities, where they provided to those in need, free of charge.

Gerald Gentleman Station (GGS)

In 2008, GGS marketed 77,400.16 tons of fly ash and 37,802.24 tons of bottom ash. From the marketing of fly ash and bottom ash, GGS realized a revenue stream of $106,362.40 in 2008.

GGS utilized 3058.06 tons of bottom ash onsite. Each ton of fly ash or bottom ash marketed or utilized onsite represents a ton of fly ash or bottom ash that does not go into the onsite landfill.

" GGS burned 8375 gallons of used oil on the coal pile for energy recovery in 2008.

As part of Earth Day Week activities, 22 volunteers at GGS conducted a trash clean up around Sutherland Reservoir on April 22 d. Recreational areas covered included Sutherland Inlet and

Outlet, the Cooling Pond, the Golf Course and Hershey Beach. Over three pick-up loads of trash were collected duringthe afternoon.

Norfolk

Norfolk Centralized Customer Care Center (CCCC) employees were requested to calculate their home energy use with the Apogee Home Energy Calculator, become familiar with the additional information provided, and print off the energy savings recommendations.

Participants received an item that will provide another means of using less energy to save NPPD kilowatts.

During a five week period beginning in August 2009, the CCCC sponsored a "Green Game Challenge" for employees. Each week participants were given a "green" challenge. Once the challenge was met, participants drew a playing card. At the end of the month the person with the best "poker hand" won a nice prize. Following is a brief outline of the challenges.

1st Week: Determine your carbon footprint with an on-line calculator.

2nd Week: Explain how you could REDUCE your purchases with decisions to use alternative products.

3rd Week: Hands on activity to REUSE items that will be provided.

4th Week: Build a "landfill Sculpture" with plastic throw aways.

5th Week: Bring aluminum cans during the last week to RECYCLE

NPPDGREEN TEAM NPPD Green Team Members Beatrice Gerald Gentleman Station Angie Carroll Chet Harger Kim Herrera Doug Harris Peggy Tockey Canaday Station Norfolk Ron Wagnitz Rich Braun Columbus Georgia Wyatt Cindy Abernathy North Platte Ev Chittenden Barb Gay Kay Nichols Gene Hahn Hope Hasenkamp-Gibbs Scottsbluff Mark Kunhart Ralph Hefti Colleen Mathewson Sue Ligenza Larry Linder Sheldon Station Steve Petersen Joe Citta Todd Chinn Cooper Nuclear Station York Operations Center Tanya Cowley Jeff Raymond Tim Francis Rusty Ruhl Chris Stipp Connie Siemek Jason Rosenkranz Doniphan Greg "Lucky" Young

Nebraska Public Power District "Green Team Charter" (Page 1 of 2)

Vision: Nebraska Public Power District will be recognized by our customers for our use of good environmental practices related to pollution prevention (P2) supporting NPPD's vision to enhance the quality of life in Nebraska.

Mission: Identify, develop, and promote pollution prevention, waste minimization, and cost-savings opportunities throughout the District.

Objective: Formalize the NPPD Recycling Program to maximize environmental, pricing, and product quality benefits. Source reduction, re-use and recycling practices will form the foundation for these efforts. Investment Recovery and Environmentally Preferred Purchasing strategies will also be employed as part of this effort.

Strategies:

o Present "Green Team" concept to, and obtain commitment from senior management to support the team's efforts.

o Establish a cross-sectional, multi-discipline "Green Team" to identify opportunities that have either environmental and/or pricing benefits.

o Identify and designate "Recycling Coordinators" at NPPD's major generation and operation facilities. The facilities will include CNS, Beatrice, Sheldon, CGO, YOC, Kearney, Doniphan, Canaday, Norfolk, North Platte, GGS, and Scottsbluff. Also identify and designate one or two "Recycling Coordinators" to represent Customer Service and Delivery. The "Recycling Coordinators" will promote, monitor and coordinate recycling activities for their respective location or business unit.

o Develop and implement a recycling information collection process. It is expected that this will be done utilizing an on-line tool whereby employees can submit data about their recycling efforts and the data is tabulated. The team will partner with NPPD ITT on this effort.

o Provide training and education opportunities for "Green Team" members about pollution prevention (P2) and Environmentally Preferred Purchasing (EPP) strategies and the benefits that can result from such efforts. Tools such as the Federal Government Comprehensive Procurement Guidelines (CPG) will be evaluated.

o Prioritize, research, and document identified opportunities.

o Identify and utilize grants or other cost-sharing opportunities to help support various recycling projects or efforts (Keep Nebraska Beautiful, Environmental Trust Fund, State Recycling Association, etc.)

Nebraska Public Power District "Green Team Charter" (Page 2 of 2) o Develop policies and procedures to implement identified opportunities.

o Educate NPPD employees about P2 strategies and promote benefits of identified opportunities by developing a recycling awareness strategy to enhance employee knowledge of the environmental and economic benefits of recycling. The team will work with Corporate Communications on this effort.

o Document and report efforts to management, publicize successes internally and externally, and recognize and reward employee initiatives.

NLS2009036 Page 1 of 4 Attachment 2 Errata Changes to the Environmental Report As a result of ongoing preparations for the License Renewal Environmental Audit, NPPD identified the following corrections/enhancements to the License Renewal Application Environmental Report:

1) Page 2-2, last paragraph contains the following sentence: "The facility has'been landscaped with trees, shrubs, and grass native to the area."

This sentence should be revised to read: "The facility has been landscaped with ttees shrubs; and grass native to the area."

2) Page 2-94, 5 th paragraph contains the following sentence: "A 100-meter tower and an auxiliary 10-meter tower,-located approximately 3,230 feet and 1,597 feet, respectively, from the northwest comer of the reactor building are used to gather the meteorological data."

This sentence should be revised to read: "A 100-meter tower and an auxiliaryl 0-meter tower, located approximately 31,230 feet and 1,597 feet, respectively, from the northwest comer of the reactor building are used to gather the meteorological data."

3) Page 2-94, 5 th paragraph contains the following sentences: "In 2008, a new 100-meter tower is being erected and fully instrumented approximately 2,000 feet northwest of the original 100-meter meteorological tower erected in 1981. The equipment and monitoring system for the new 100-meter tower is nearly identical to that currently operational on the original 100-meter tower. The meteorological monitoring system associated with the new 100-meter tower is to become fully operational in April 2009 and is described below."

The above sentences should be deleted. On Page 2-95, after 4 th paragraph, insert the following paragraph: "A new 100-meter meteorological tower is being planned for 2010. The design details are incomplete, but the new tower will meet or exceed the

,performance standards of the existing tower and will be fully compliant with NRC requirements."

4) Page 3-2, 5 th paragraph contains the following sentence: "The downstream terminal is 40 ft below the downstream comer of the CWIS."

NLS2009036 Page 2 of 4 The above sentence should be revised to read: "The downstream terminal is approximately 40 ft below the downstream comer of the CWIS [NPPD 2008, Section XII-2.2.7.2]."

5) Page 3-3, 1st paragraph contains the following sentences: "Twenty-three 10 ft long by six ft high sheet pile turning vanes were installed riverward of the weir wall with top elevations of EL. 860 ft. Installed at a 22 degree angle to the outer weir, and extending beyond the downstream terminus of the weir, these turning vanes redirect sand and gravel outward away from the weir and CWIS."

The above sentences should be replaced with: "An array of 20 submerged flow turning vanes has been installed east of the guide wall in the river channel. Each vane is constructed of steel sheet piling and driven into the river bed to a top elevation below barge navigation depth. The vane array functions to induce scouring of the river bed adiacent to the guide wall to prevent sediment accumulation. The prevention of sediment accumulations increases the effectiveness of the guide wall. [NPPD 2008, Section XII-2.2.7.21"

6) Page 3-3, 3 rd paragraph is redundant to information contained in the 2 nd paragraph.

Delete the 3 rd paragraph.

7) Page 3-3, 4 th paragraph contains the following sentence: "Each screen has 1/8 by 1/2 in.

smooth top mesh and is rotated continuously at 8.2 fpm to prevent excess debris build up.

The above sentence should be revised to read: "Each circulating water screen has 1/8 by 1/2 in. smooth top mesh, and the service water screen is 5 mm perforated plastic mesh.

Each screen has a high and slow speed, but -anA-is normally rotated continuously at the slow 8.2 fpm speed to prevent excess debris build up."

8) Page 3-6, 4h paragraph contains the following sentence: "The ISFSI Facility will provide storage locations for Holtec International HI-STORM IOOS(B) Casks."

The above sentence should be revised to read: "The ISFSI Facility will provide storage locations for Heltec International HIT STORM" 1OOS(B)dry fuel storage Gcasks."

9) Page 3-24, last paragraph contains the following sentence: "Refueling and maintenance outages typically last approximately 30 days."

The above sentence should be revised to read: "Refueling and maintenance outages are typically scheduled for last-approximately 30 days."

NLS2009036 Page 3 of 4

10) Page 3-33, Figure 3.2-4 depicts the CNS Intake Structure Section. Replace this page with the enclosed revised Figure 3.2-4.

11) Page 4 -6 3 , 3 rd paragraph contains the following sentence: "The site generally schedules its outages in the spring, and may have an average of approximately 700 to 900 temporary workers on-site for the duration of the outage."

This sentence should be revised to read: "The site generally schedules its outages alternately in the sSpring and Fall at 18-month intervals, and may have an average of approximately 700 to 900 temporary workers on-site for the duration of the outage."

12) Replace Table 9.2-1 Pages 9-2 and 9-5 with the enclosed revised pages.

Revised pages that reflect the above revisions are provided in the Enclosure to this Attachment.

NLS2009036 Page 4 of 4 Enclosures to Attachment 2 Page 2-2 Page 2-94 Page 2-95 Page 3-2 Page 3-3 Page 3-6 Page 3-24 Figure 3.2-4 Page 4-63 Table 9.2-1, Pages 9-2 and 9-5

Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage approximately 16,501.' The population declined during most of the 1900s and was just 6,430 by 2000. Atchison County is primarily rural. [NMRCG, p. 16]

There are no known missile sites within a ten-mile radius of the CNS plant site. Only one airport, the Auburn Municipal Airport, is located within a ten-mile radius of the CNS plant site.

The location of this airport in relation to CNS is shown on Figure 2.1-2. The Auburn Municipal Airport has two turf runways with lengths of 2,800 feet and 2,200 feet, respectively. This limits the use of this airport to light single engine and partially loaded twin engine "executive" type aircraft. Landing and departure flight paths of aircraft using this airport are generally within one-half mile of the airport boundary. There are no current plans for airport expansion. [NPPD 2008b, Section 11-1.5]

Station Features The principal structures of the station are the reactor building, turbine building (including service area appendages), control building, controlled corridor, radwaste building, augmented radwaste building, intake structure, off-gas filter building, elevated release point, diesel generator building, multi-purpose facility, railroad airlock, drywell and suppression chamber, miscellaneous circulating water system structures (circulating water conduits, seal well, etc.), optimum water chemistry gas generator building, and office building [NPPD 2008b, Section XII-1.0]. Figure 3.2-1 shows the general features of the CNS site. Section 3.2 describes key features of the station, including reactor and containment systems, cooling and auxiliary water systems, radwaste systems, and transmission facilities.

The Protected Area is completely enclosed by a security fence, with-access to the station controlled at a security gate. A plant security system monitors the Protected Area, as well as the buildings within the station. Normal access to the site is by a paved entrance road built across the site from Nemaha County road 648A Avenue, located on the west side of the property. Access was previously available by connection to a railroad spur line of the Burlington Northern Railroad, but this was abandoned by Burlington Northern. The Steamboat Trace Recreational Trail now runs along the previous railroad right-of-way [NPPD 2008b, Section II-1.4]. The exclusion area, as defined by 10 CFR 100.3, surrounds the site as shown in Figure 2.1-7. The nearest residences lie 0.9 miles beyond the site boundary to the northwest

[NPPD 2008g, Section III].

The structures of CNS have been designed to provide a neat appearance, both from the river and from the county road that provides access to the site. The nearest point of view of the station is from the river that runs through the property. However, most traffic on the river is barge traffic. Predominant features are the reactor building, which is approximately 290 feet tall, the elevated release point (325 feet) and meteorological tower (328.8 feet). CNS is a modern, functional structure with a minimum of open steel framing. [NPPD 1971, Section IV-4.14] The facility has been landscaped with shrubs and grass native to the area. The view from the county road shows a distant plant surrounded by cultivated agricultural land. The 239 undeveloped acres on the Missouri (east) side of the river provides a wooded view from the river.

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Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage rainfall for the Lincoln and Omaha, Nebraska, areas is 7.0 inches/hour for a five-minute duration for a ten-year return period. Converting this value to a rate equivalent to that used in the design of drainage facilities yields 3.1 inches per hour for a 60 minute duration and a ten-year return period [NPPD 2008b, Section 11-3.1.3].

U.S. Department of Commerce Weather Bureau and U.S. Department of the Army, Corps of Engineers, Hydrometeorological Report No. 33 dated April 1956, from which it was determined that the "probable maximum precipitation" for the site area is 23.5 inches total rainfall for a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. This value has been determined from Figure 17 (August) of the aforementioned report. Converting this value to a rate equivalent to a one hour rainfall, by using the Civil Engineering Bulletin No. 528, revised March 1965, published by the Department of the Army, office of the Chief of Engineers, which determines a rainfall rate per hour from a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, the "probable maximum precipitation" for the site area was conservatively determined to be 3.56 inches per hour for a ten-year return period [NPPD 2008b, Section 11-3.1.3].

The States of Nebraska, Missouri, Kansas, and Iowa are located within 50 miles of the CNS plant site. A review of state and federal regulatory agency websites indicates that there are no counties in non-attainment status for any of the listed priority pollutants (particulates, including PM10 and PM2.5; nitrogen oxides; sulfur oxides; carbon monoxide) or criteria pollutants (lead and ozone). The only counties in these four states that are in a non-attainment status are located in eastern Missouri, more than 250 miles southeast of CNS. These counties are located in the St.

Louis Standard Metropolitan Statistical Area and are in non-attainment status for at least one of the following: ozone, PM2.5, or lead [USEPA 2006a].

Class I areas, as defined in the Clean Air Act, are the following areas that were in existence as of August 7, 1977: national parks over 6,000 acres, national wilderness areas and national memorial parks over 5,000 acres, and international parks. There are no Mandatory Class I Areas located within 50 miles of CNS. [USEPA 2006b]

2.11.1 Meteorological System The current CNS meteorological system consists of two monitoring sites located at a grade level of approximately 889 feet AMSL. A 100-meter tower and an auxiliary 10-meter tower, located approximately 1,230 feet and 1,597 feet, respectively, from the northwest corner of the reactor building are used to gather the meteorological data.

The 100-meter tower is fully instrumented with independent dual sensors (Systems A and B) for wind speed, wind direction, and temperature at three levels: 1Om, 60m, and 100m. System A contains Met One sonic sensors for measuring wind speed and wind direction, and Climatronics temperature sensors. A Climatronics relative humidity sensor is mounted at the 10m level and a Climatronics tipping bucket rain gauge with Alter wind shield is mounted at the base of the 100m tower. System A also includes a Climatronics Station Pressure Sensor mounted inside the main shelter at the base of the tower. Three differential temperatures are calculated from the temperature sensors for 1OOm-1Oin, 1OOm-60m, and 60m-1Om. Identical to System A, System B contains Met One sonic sensors for measuring wind speed and wind direction and Climatronics temperature sensors. Three differential temperatures are calculated from the temperature sensors for 1OOm-1Om, 1OOm-60m, and 60m-1Om. The wiring for each system is 2-94

Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage run through separate conduit from the tower base to each measurement level. Two independent elevators are mounted on different tower faces with two electric winches that carry the six instrument carriages up and down the tower for maintenance and calibration. To minimize tower interference, System A is mounted on the south face in the direction of the mean wind, and System B is mounted on the northwest face in the direction of the secondary peak in the mean wind.

The signals from the tower instrumentation are interfaced with the meteorological shelter equipment, including six Campbell Scientific, Inc., CR3000 Data Loggers and two off-the-shelf heavy-duty-grade personal computers (PCs). Three of the dataloggers serve as interfaces between the tower and Climatronics temperature system. All of the data loggers are programmed to receive meteorological data from both the A and B sensors on the tower. Three of these data loggers are programmed to produce and store 15-minute and hourly averaged values for all parameters, i.e., wind, temperature, dew point, precipitation, etc. Two of these data loggers are each hard wired into an independent PC, where data from each of the A and B sensors are stored.

Two of the dataloggers serve as redundancy in the event of a single failure while a third is set up with a modem connection and telephone line to access the data remotely in the event the line from the 100m shelter to the CNS Plant Computer (PMIS) is interrupted or fails. These 15-minute and hourly averages are transmitted from the two main dataloggers to two PCs in the 100m shelter. Data validation software, based on CNS site-specific meteorological criteria, is then run on each 15-minute and hourly averaged data. Data that fail specific tolerance and/or meteorological checks are flagged and color coded before being transmitted each 15 minutes and hourly to the PMIS using line drivers. A validated 15-minute and hourly data string that represents the best data from both the A and B systems is also generated and transmitted to PMIS from the 100m shelter PCs.

Backup meteorological data may be obtained from the National Weather Service Office located in Valley, Nebraska, which offers projected wind speed, wind direction, and temperature up to the 10,000-foot level. Information can be obtained by telephone or by the National Warning System. [CNS 2008c, Section 7.5.2]

A new 100-meter meteorological tower is being planned for 2010. The design details are incomplete, but the new tower will meet or exceed the performance standards of the existing tower and will be fully compliant with NRC requirements.

2.11.2 Radiological Environmental Monitoring Program Air Sampling Program Continuous air sampling is performed at 11 locations using continuous air samplers mounted in louvered enclosures similar to U.S. Weather Bureau instrument shelters. Air sampling consists 2-95

,Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage CheckPlus Leading Edge Flow Meter ultrasonic flow measurement instrumentation. NPPD made the necessary modifications to CNS to increase the licensed core rated power by 1.62 percent from 2,381 MWt to 2,419 MWt during the April 2008 outage. [NPPD 2007a, Section 1.0]

Fuel for CNS is made of low-enrichment (less than 5 percent by weight) high-density ceramic uranium dioxide fuel pellets stacked within Zircaloy-2 cladding that is evacuated, backfilled with helium, and sealed with Zircaloy end plugs welded in each end [NPPD 2008, Section 111-2.5; NPPD 2008, Section X-4.5.1.1]. Based on core design value, CNS operates at an individual rod average fuel burnup (burnup averaged over the length of a fuel rod) of no more than 62,000 MWD/MTU, which ensures that peak burnups remain within the acceptable limits specified in Appendix B to Subpart A of 10 CFR Part 51 (Table B-I) [USNRC 2006].

The primary containment system is designed, fabricated, and erected to accommodate without failure the pressures and temperatures resulting from or subsequent to the double-ended rupture or equivalent failure of any coolant pipe within the primary containment. The reactor building, encompassing the primary containment system, provides secondary containment when the primary containment is closed and in service, and provides for primary containment when the primary containment is open, as required. The two containment systems and such other associated engineered safety features as may be necessary are designed and maintained so that off-site doses resulting from postulated design basis accidents are below the values stated in 10 CFR Part 100. [NPPD 2008, Appendix F-2.2.5] The primary containment system for CNS is a reinforced concrete structure completely enclosing the reactor vessel.

3.2.2 Cooling and Auxiliary Water Systems 3.2.2.1 Circulating Water Intake Structure The circulating water system uses water taken from the Missouri River. Water passes through trash racks and then through traveling screens. A major portion of the flow is directed to the circulating water pumps, which deliver water to the main condenser. A smaller portion of Missouri River water is used by the service water pumps. The discharge from the condenser and from the service water system is returned via the discharge channel to the river. [NPPD 2008, Section XI-6.3]

The circulating water intake structure (CWIS) is located on the west shoreline as shown in Figure 3.2-2 [NPPD 2006b, Section 2.1]. Figures 3.2-3 and 3.2-4 provide plan and cross-section views of the CWIS, respectively. In front of the CWIS is a guide wall and submerged weir constructed of steel sheet piling that runs parallel to and at distance of 14.25 feet (ft) from the face of the intake. The weir is physically attached at its upstream terminal to the circular cell that was left in place after the remaining cofferdam structure was removed following construction of the CWIS. The downstream terminal is approximately 40 ft below the downstream corner of the CWIS [NPPD 2008, Section XII-2.2.7.2]. No connection is made to the shore at the downstream terminal. The top elevation of the upstream portion is El. 885 ft (all elevations for CNS refer to AMSL), which is 5 ft higher than normal summer river elevation of 880 ft. The top of the weir gradually changes from El. 885 ft at the upstream terminal to a submerged downstream-most weir section of El. 867.5 ft. [NPPD 2006b, Section 2.2]

3-2

Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage The purpose of the guide wall and weir is to reduce the sediment input to the CWIS. It accomplishes this by forcing bed load and other material contained in the river to flow around and past the CWIS. When the level of the river is higher than El. 867.5 ft, most of the water spills over the top of the wall. The bed load, composed of heavier and larger diameter particles, is usually found in the bottom part of the river and moves along the weir wall to be directed away from the CWIS. When river level drops, a higher percentage of water goes around the weir rather than going over it. As river level drops, a higher percentage of bed load comes into the CWIS due to eddy effects at the terminal end of the weir. Therefore, during 2005 turning vanes were installed in front of the MWIS to redirect bed load away from the intake structure.

[NPPD 2006b, Section 2.2] An array of 20 submerged flow turning vanes has been installed east of the guide wall in the river channel. Each vane is constructed of steel sheet piling and driven into the river bed to a top elevation below barge navigation depth. The vane array functions to induce scouring of the river bed adjacent to the guide wall to prevent sediment accumulation. The prevention of sediment accumulations increases the effectiveness of the guide wall. [NPPD 2008, Section XII-2.2.7.2]

Water for the facility is drawn through five intake bays. Four of these bays provide circulating water to the generating unit while the other is used for service water. Each circulating water intake bay splits into two screen bays, while the service water intake bay narrows to a smaller screen bay. These bays are 9.7 feet in length by 5.6 feet wide, providing space for 4.2 feet wide dual flow screens. Each bay is fitted with modified dual flow traveling screens designed with fish collection baskets (see Figure 3.2-5). The modified dual flow screens operate at 90 degrees to the water flow. Fish and debris are collected on both the ascending and descending sides of the dual-flow screen which allows only filtered water to pass downstream to the pumps.

Fish and debris are removed by a high pressure screen wash system and conveyed back to the river. Installation of the modified dual flow traveling screens began during 2005 and was completed in 2006, to address debris carry-over problems encountered with the original flow through traveling screens. A decision was also made by NPPD to install fish collection baskets on the dual flow screens to address future 316(b) issues. However, the present design and construction does not include installation of the low pressure spray system or a separate fish return trough and conveyance system to return fish back to the river. [NPPD 2006b, Section 2.2]

Each circulating water screen has 1/8 by 1/2 in. smooth top mesh, and the service water screen is 5 mm perforated plastic mesh. Each screen has a high and low speed, but is normally rotated continuously at the slow 8.2 fpm speed to prevent excess debris build-up. A high pressure screen backwash system providing 3,000 gpm at 30-60 psig is used to remove fish and debris from the screens. Water for the screenwash is drawn from the service water pumps.

Fish and debris flushed from the screens are returned to the river via 3-3

Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage having the potential for containing radioactive materials. Gaseous radioactive wastes include noble gases, radioiodine, particulates, Carbon-14, and tritium.

(3) Solid radioactive wastes: solids from the reactor or auxiliary systems, solids in contact with reactor or auxiliary systems operations, or those materials processed through the radwaste system and solidified. [NPPD 2008, Section IX-1.0]

Storage of radioactive materials is regulated by the NRC under the Atomic Energy Act of 1954, and storage of hazardous wastes is regulated by the United States Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act of 1976.

In 2007, the site began preparation work for the installation of an ISFSI Facility on the north end of the CNS site in an area which was previously disturbed and outside the existing Protected Area. The ISFSI Facility will provide storage locations for dry fuel storage casks. The site ISFSI Facility has been sized to include spent fuel assemblies to maintain spent fuel pool reserve core margin for CNS, based upon an additional 20-year license renewal term.

3.2.3.1 Liquid Waste Processing Systems and Effluent Controls The liquid radwaste (LRW) system includes an augmented treatment subsystem that is no longer in use. The LRW system (non-augmented) is described below. [NPPD 2008, Section IX-2.0]

The LRW system for CNS was designed to accept process wastes from two nuclear units.

Since CNS is only a single unit, the system is larger than would normally be necessary. The LRW system collects, processes, stores, and disposes of all radioactive liquid wastes. [NPPD 2008, Section IX-2.5.1]

Included in the LRW system are the following components and systems:

a. piping and equipment drains carrying potentially radioactive wastes;

b. floor drain systems in areas that may contain potentially radioactive wastes;

c. tanks, piping, pumps, process equipment, instrumentation, and auxiliaries necessary to collect, process, store, and dispose of potentially radioactive wastes; and

d. tanks and sumps used to collect potentially radioactive wastes.

[NPPD 2008, Section IX-2.5.1]

Equipment was selected, arranged, and shielded to permit operation, inspection, and maintenance with acceptable personnel doses. For example, tanks and processing equipment that are expected to contain significant radiation sources are located behind shielding, and similarly sumps, pumps, valves, and instruments are located in radiologically controlled access rooms or shielded spaces. In addition, the radwaste equipment was selected to minimize the need for maintenance. Operation of the waste system is essentially manual start-automatic stop. [NPPD 2008, Section IX-2.5.1]

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Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage activities are described in the body of the license renewal application. The additional inspection activities are consistent with normal plant component inspections and therefore are not expected to cause significant environmental impact. The majority of the aging management programs are existing programs, some requiring modest modifications.

3.5 Employment The non-outage work force at the site consists of approximately 750 persons (see Table 3.5-1).

During refueling outages, there is typically an additional 700-900 contractor employees on-site.

Refueling outages occur every 18 months. NPPD has no plans to add non-outage employees to support plant operations during the extended license renewal period.

Refueling and maintenance outages are typically scheduled for approximately 30 days. The number of workers required on-site for normal plant outages during the period of extended operation is expected to be consistent with the number of additional workers used for past outages at the site, which is approximately 700-900 temporary workers.

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Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage CIRCULATING WATER PUMP-TRASH RACK

.1 I EL. 903" - 6' ICE CONTROL TUNNEL SLUICE GATES

-+ I-EL. 852' - 6' Figure 3.2-4 CNS Intake Structure Section 3-33

Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage Interstate 29 on the Missouri side of the river, and on Interstate 29 just north of US Highway 136 in Missouri.

Section 2.10.2 further discusses the LOS for traffic routes serving CNS for workers and shipments. Regulatory Guide 4.2, Supplement 1, "Preparation of Supplemental Environmental Reports for Applications to Renew Nuclear Power Plant Operating Licenses," Section 4.18 states, "LOS A and B are associated with small impacts because operation of individual users is not substantially affected by the presence of other users. At this level, no delays occur and no improvements are needed". US Highway 136 in the vicinity of CNS carries an LOS designation of Level B. All other roads in the vicinity carry an LOS Level A designation.

Based on available information, the Nebraska and Missouri traffic counts did not include temporary traffic increases due to annual outages at the site. The site generally schedules its outages alternately in the Spring and Fall at 18-month intervals, and may have an average of approximately 700 to 900 temporary workers on-site for the duration of the outage. Peak traffic during outages would be expected to be leaving and entering the site from 5:30 to 7:00 a.m. and from 6:30 to 8:00 p.m. Compensatory measures, such as staggered shift starting and quitting times, are not needed, but occur to facilitate security checkpoint processing. This helps ensure that the increased traffic flow during outages will continue to maintain a reasonable level of service.

4.19.6 Conclusion As noted in Section 3.3, there are no refurbishment activities required for CNS license renewal and no expected increases in the total number of employees that will be on-site during this same period. Although LOS road designations in the vicinity of CNS are adequate, compensating measures, such as staggered shift starting and ending times, are taken by the site to account for the increased traffic flow during outages to maintain a reasonable level of service. Therefore, impacts on local traffic will be SMALL and further mitigation measures are not warranted.

4.20 Historic and Archaeological Resources 4.20.1 Description of Issue Historic and Archaeological Resources 4.20.2 Finding from Table B-I, Appendix B to Subpart A SMALL, MODERATE, or LARGE. Generally plant refurbishment and continued operation are expected to have no more than small adverse impacts on historic and archaeological resources.

However, the NHPA requires the federal agency to consult with the SHPO to determine whether there are properties present that require protection. See 10 CFR 51.53 (c)(3)(ii)(K).

4.20.3 Requirement [10 CFR 51.53(c)(3)(ii)(K)]

All applicants shall assess whether any historic or archaeological properties will be affected by the proposed project.

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Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage Table 9.2-1 CNS Environmental Permits and Compliance Status Agency Authority Requirement Number Expiration Date Authorized Activity NRC Atomic Energy Act, Operating license DPR-46 January 18, 2014 Operation of CNS.

10 CFR 50 NDEQ Federal Water Pollution NPDES Permit NE0001244 June 30, 2012 Discharge of wastewaters to Control Act Section 402 water of the State.

NDEQ Federal Water Pollution General NPDES Permit NER000059 September 17, Discharge of stormwater to I Control Act Section 402 2002* waters of the State.

NDEQ Title 129, Nebraska Air Permit to Construct an Air Not applicable Not applicable Operation of air emission Quality Regulations Contaminant Source sources (one emergency generator and one fire pump).

NDEQ Title 128, Nebraska Hazardous Waste NED055071062 Not applicable Hazardous waste generation Hazardous Waste Generator Identification Regulations NDEQ Title 122, Rules and Class V Well Underground NE0208256 November 16, 2010 Underground injection of Regulations for Injection fluid using 10-5D2 Underground Injection stormwater drainage wells and Mineral Production Wells NDNR Neb. Rev. Stat.46-602 to Well registration G-030088 Not applicable Onsite potable well 46-604 NDNR Neb. Rev. Stat.46-602 to Well registration G-030089 Not applicable Onsite potable well 46-604 9-2

Cooper Nuclear Station Applicant's Environmental Report Operating License Renewal Stage TDEC Tennessee Department of CNS Radioactive Waste T-NE002-L08 December 31, 2008 Shipment of radioactive Environment and License for Delivery material into Tennessee to a Conservation Regulations disposal/processing facility UDEQ Utah Radiation-Control Generator Site Access 0111000042 January 3, 2009 Accessing a land disposal Rules R313-26 Permit facility in Utah NDEQ Federal Water Pollution General NPDES Permit NER100000 December 31, 2012 Discharge of stormwater Control Act Section 402 from the ISFSI construction project to waters of the State.

USACE Clean Water Act Section Section 404 Permit NE 2001-10322 March 31, 2012 Dredging at intake structure 404 and discharge of dredge material to Missouri River.

USACE Clean Water Act Section Section 404 Permit NE 1997-10285 October 8, 2009 Ice deflectors for intake 404 structure.

NDEQ has administratively continued this permit.

DOT U.S. Department of Transportation NDEQ Nebraska Department of Environmental Quality NDNR Nebraska Department of Natural Resources NHHSS Nebraska Health and Human Services System NRC U.S. Nuclear Regulatory Commission NWPCC Nebraska Water Pollution Control Council SCDHEC South Carolina Department of Health and Environmental Control TDEC Tennessee Department of Environment and Conservation (Division of Radiological Health)

UDEQ Utah Department of Environmental Quality (Division of Radiological Health)

USACE United States Army Corp of Engineers 9-5

NLS2009036, Response to Request for Additional Information for License Renewal Application Environmental Report

Contents

Text

Subject:

References:

Dear Sir or Madam:

SUMMARY

SUMMARY

SUMMARY

SUMMARY

Dear Mr. Smith:

Dear Ms. Swarts:

Dear Mr. Horn:

Dear Sir/Madam:

Dear Mr. Kuttler:

Subject:

Dear Mr. Pope:

Enclosures:

Dear Mr. Overhue:

Description:

Dear Applicant:

Dear Mr. Overhue:

2.0 BACKGROUND

SUMMARY

SUMMARY

SUMMARY

1.0 INTRODUCTION

2.0 BACKGROUND

SUMMARY

SUMMARY

SUMMARY

SUMMARY

SUMMARY

Dear Mr.Marlow:

Subject:

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