ML20062E836

Applicant Sceg'S Answer to NRC Staff Motion for Summary Disposition of Intervenor B Bursey'S Contentions A6 & A7. Sceg Agrees That Summary Disposition Be Granted;There Is No Genuine Issue of Matl Fact.Documentation & Cert of Svc Encl

ML20062E836
Person / Time
Site:	Summer
Issue date:	12/04/1978
From:	Conner T, Wetterhahn M CONNER, MOORE & CORBER
To:
References
NUDOCS 7812130025
Download: ML20062E836 (43)

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UNITED STATES OF AMERICA

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DgG '/ 7 NUCLEAR REGULATORY COMMISSION (9 Y 4

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SOUTH CAROLINA ELECTRIC & ) Docket No. 50-395 GAS COMPANY, et al. ) /f (Virgil C. Summer Nuclear

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Station) ) r APPLICANT' S ANSWER TO NRC STAFF MOTION [

FOR

SUMMARY

DISPOSITION ,

On October 3, 1978, the Nuclear Regulatory Commission;

("NRC" or " Commission") Staff moved that Contentions A6 and A7 admitted as issues in controversy in the captioned pro-ceeding be dismissed pursuant to 10 C.F.R. S2.749 in that no

- genuine issue of material fact existed. In Applicant's Response to Memorandum and Order Denying Motion for Dismissal of Intervenor dated October 2, 1978, South Carolina Electric and Gas Company (" Applicant") indicated that it supported

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the Staff Motion and would present further bases for dismissal in its own motion for summary disposition to be filed in ap-proximately one month.

The Memorandum and Order of the Atomic Safety and Licensing Board (" Board") dated November 7, 1978 notes the applicability of revised S2.749 which provides for filing of motions for summary disposition not later than 45 days prior to the time fixed for a hearing. Applicant,-therefore, will file its own motion on the other contentions within that time 781213002 f

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frame as contemplated by that Memorandum and Order. That Memorandum and Order called for the Intervenor to file an answer to the Staff's motion within 20 days after service.

In view of these circumstances and the provisions of 10 C.F.R. S2.749(a) which permit any party to respond to a motion for summary disposition with or without affidavits, Applicant moves that this pleading be accepted by the Atomic Safety and Licensing Board as its answer to the Staff Motion.

As more fully discussed below, Applicant fully supports the Staff Motion. Applicant submits that with respect to Contentions A6 and A7, there are no material facts to which there exists a genuine issue to be heard and therefore the two contentions should be dismissed.

Contention A6 .

The matter of the environmental impact of the intake and discharge of water from the Summer Station and thermal .

effluents from the Station was fully analyzed and considered at the construction permit stage by the Applicant, the l Staff, the Atomic Safety and' Licensing Board, and the Atomic Safety and Licensing Appeal Board. At that time, the i presiding Atomic Safety and Licensing Board found:

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1/ In South Carolina Electric and Gas Company (Virgil C.

Summer Nuclear Station, Unit 1), ALAB-114, 3 AEC 253 (1973), the Appeal Board stated that it had reviewed the Licensing Board's decision and the record, and, with one exception not relevant here, was satisfied "(1) that the l Board made all the findings requisite to its authorization I

of the issuance of the construction permit; and (2) that each of those findings is supported by reliable, prorative and substantial evidence of record." .

l

• 55. The Staff as part of its environ-mental review considered in detail the effects of~ discharges from the plant

.r- on the Broad River and on the Monticello Reservoir. The Staff concluded that there would only be minimal effect on the Broad River and on the Monticello Reservoir. (FES, pp. V-4 to V-39, XII-22) The Board finds that there will only be minimal effects on the Broad River and the Monticello Re-servoir as a result of discharges from the Summer Station.2/

The Board further found that the balance between the benefits and costs involved in the construction and opera-tion of the facility favored the granting the construction permit to the Applicant.

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In' weighing this cost-benefit balance, the Board included the "[d]ischarge of large quanti-4/

ties of heated water into the impoundment."--

Subsequent to that time, the State ,of South Carolina has is' sued NPDES Permit No. SC0030865 (" Permit") to the Applicant for the Summer Station.~ With regard to thermal discharges, this permit limits the monthly average surface temperature of up to 32.2*C (90*F) from Monticello Reservoir l and also places a requirement that this surface temperature should not be greater than 1.66*F (3.0*F) above the ambient l --'

2/ South Carolina Electric and Gas Company (Virgil C. Summer 1

Nuclear Station, Unit 1), LBP-73-ll, 6 AEC 213, 223 (1973).

l 3/ Id.

_4/ Id.

_5/ A copy of the original permit is attached. The only sub-sequent change to the Permit involved a change in the timing i

for submittal of routine reports and is not related to the issues in this proceeding. See the Affidavit of William E.

Moore at p. 2.

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El temperature, as defined in the Permit, on a monthly basis.

At th'e construction permit stage, at the time the NRC reviewed the thermal impact of the discharges on Monticello Reservoir and the Broad River, the same water quality require-ment regarding heat limitation, i.e., that streams entering the Broad River have an average temperature rise of less

_7/

than 3*F, was in existence and was applicable. The Commission examined the Alden Model and found it to be

_8 conservative _/ in that the predicted isotherms would be more favorable, i.e., even less extensive:than predicted by the '

Alden Model. Viewing the environmental impact of thermal discharges from the plant on the Broad River and on the Monticello Reservoir, the Staff conclnded that there would only be minimal effect on the Broad River and on the Monticello Re servoir. - As previously noted, the Atomic Safety and Licensing Board, at the construction permit stage, also' ,

_6/ Moreover, additional monitoring requirements and the require-ments to conduct certain studies related to the discharge plume and intake pursuant to S316(b) of the Federal Water

, Pollution Control Act (Permit at p. 10 of 18) were imposed in the Permit.

_7/ FES at V-5.

8/ Id. at V-19 and Appendix B. Again, this analysis was done before effluent limitations were set by the EPA or an NPDES Permit had been issued by the Station. The State issuance of an NPDES Permit was based upon the Alden Model and because of the existence of that Permit, the NRC is precluded from looking behind it. Even were the NRC to have the jurisdiction to look at the Alden Model, the record is uncontroverted that it is conservative.

_9/ LBP-73-11 at 223 citing FES pp. V-4 to V-39, X-11-22.

found that there would only be minimal effects on the Broad River and the Monticello Reservoir as a result of discharges '

from the Summer Station.--10/ Bccause the water. quality require- t ments are the same now as then, the Commission analysis was donc at the level of discharges permitted by state standards as reflected in the present NPDES Permit.

Associated with the construction of the Summer Station and Monticello Reservoir ~is a separate recreation area at the north end of the 'Monticello Reservoir where a high quality fishing area of several hundred acres will be created.--11/

This environmental amenity should be considered as a positive factor in the cost benefit balance. Thus since the impact of discharges are expected to be minimal, and there are positive water-related aspects of the facility, e.g., the fishing area, there can be no question that the cost-benefit balance could be tilted against operation of the plant.

The Staff's Motion for Summary Disposition treats, in detail, the factual assertions contained in the contention.

_ To avoid duplication, Applicant has examined the Staff Motion on this contention and fully concurs in and supports such motion and supporting affidavits. --12/

For his part, Mr. Bursey has not identified any wit-13/ -

nesses associated with this contention. At most he alleges-10/ Id.

11/ Affidavit of William E. Moore at 2.

12/ Id.

13/ Intervenor Brett Bursey's Answers to Interrogatories of NRC Staff at 7.

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is that there are " numerous instances in the FES [ construction 1-permit phase) and related documents that are deficient in regards to the specific impact of the Summer plant on the ecosystem.'" He has been unable to give any specificity to this assertion.

l Moreover, although clearly limited by the Board to consideration of cooling system impacts at the' level of dis-() charges permitted by the NPDES Permit issued by the State of South Carolina for.the Station, the thrust of the Intervenor's responses indicates that he is seeking to attack the NPDES Permit and State water quality standards', and the permit issuing process. These are matters which, as this Board has already recognized, it may-not consider. As an example, in response to Staff Interrogatory A6-6, Intervenor states that

"[i]t is not clear if the Applicant's plan to average the

() daily releases to stay within the allowable limits is ac-ceptable. . . It is clear,'however, that such averaging is the method specified in the NPDES Permit. As another

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example, Mr. Bursey appears to be attempting to argue with the 90*F temperature limit and the 3*F monthly average set i

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.x w + w :w.wwp 14/

l lar the State of South Carolina in the NPDES Permit.

With regard to the intake velocity, Mr. Bursey er- -

roneoucly asserts that the intake velocity is substantially greater than 0.5 fps, i.e., 1.3 fps, per second because of the location he has chosen to determine that value, i.e.,

through the screens. The approach velocity, which is the parameter of interest, is approximately 0.5 fps or less depending on the water level in the reservoir. As discussed in the Affidavit of W. E. Moore, velocities of 0.5 fps or less are such that the impact of impingement is not expected to be significant. Furthermore~, the 0.5 fps occurs at the emergency drawdown-level. At higher levels, the approach .

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velocity would be less. 5/ Mr. Bursey could not dispute 17/

these approach velocities.-- ,

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14/ Id. at 8. In Intervenor's Response to NRC Staff Motion Yor Summary Disposition of Contentions, the naked assertion is made that the " original figures of 4.3 degrees above ambient for returning effluents has been loweredLto 3.0 to l coincide with state requirements." There is no basis given for that figure. The highest predicted temperature at'any time, i.e., instantaneous v. averaged temperature permitted i

by the NPDES Permit, is 4.2*F for the hypothetical case of~

two units. Even in that case, the 3.0*F permitted by the NPDES permit is achieved. The FES at p. V-17 recites the i

finding of the Alden analysis: ,

! The average daily water temperature rise at the discharge of the pumped storage plant into l' the Broad River will be less than 3'F rise with a 25'F temperature rise for two nuclear units. '

( The maximum measured temperature rise in the Broad l River during any phase of the pumped storage pro-cess will be 4.2*F. [ emphasis in original]

l The Staff's model predicts even a lesser effect. See Appendix B to the FES at p. 4.

I.

15/ Bursey June 13, 1978 Dep. Tr. at 127.

16/ Affidavit of Moore at 2.

17/ Bursey June 13, 1978 Dep. Tr. at 128.

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The contention asserts that fish mortalities'are "ex-cessive" although Mr. Bursey has not established any standards for giving a quanitative assessment for'such an assertion.

Mr. Bursey has also admitted that he had not " quantified" 19/

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these alleged impacts, the alleged impacts were merely

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" abstractions" ~ and he had "not yet been able to adjudge 2_1/

the total impact of that." Moreover, Mr. Bursey recognized that an operational monitoring program would be performed and it was capable of detecting any adverse effects.

In effect, Mr. Bursey's contention is without supporting basis and it remains an unparticularized assertion. He has failed to make any showing whatsoever that the cost benefit balance for the facility would be tilted against the is-suance of an operating license for the facility by considera-tion of the impact associated with thermal discharges at the levels specified in the NPDES Permit for the Station. There .

is no genuine issue of fact remaining and the motion for summary disposition should be granted.

Contention A7 O With~ regard to Contention A7, Applicant has reviewed the NRC Staff Motion for Summary Disposition and the position taken l

. 18/ Id. at 131.

19/ Id.

20/ Id.

21/ Id.

22/ Id. at 132.

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therein is consistent with that of the Applicant as dis-cussed below and as presented in the Final Safety Analysis Report and Environmental Report. Applicant has thoroughly analyzed the possibility of an accidental release of radio-nuclides in liquids from the V. C. Summer Nuclear Station and, as discussed below, such hypothesized releases will not affect local or regional water groundwater supplies. The analysis considered the specific design of the Summer Station and potential failure of four types of tanks. A comparison of the volumes and concentration of the radicisotopes in these four types of tanks revealed that the hypothesized O rupture of a waste holdup tank was the limiting case.

The capacity of the waste holdup tank is 10,000 gal-lons. For conservatism it was assumed t, hat at the time of the rupture of the tank it was full and had an isotope composition equivalent to the composition of reactor coolant, a conservative assumption. It was assumed that at the time of the accident that the entire tank, underlying foundation c

l - and adjoining walls rupture. The liquid in the waste holding tank is assumed to immediately contact the saturated geological material adjacent to the tank.

1 1

Two possible flow paths were analyzed in detail. The 23/ Affidavit of William R. Baehr at 2-5.

24/ Id. at 2.

G l

method of analysis is fully described in Section 2.4.13.3.2 of the FSAR.~~25/

r-Section 2.4.12.2 of the FSAR discusses groundwater flow, paths for such an accident. Even if such a spill were to occur at the same time as the minimum historic flow in the Broad River of 149 CFS was occurring, the peak concentration of Cs , the controlling isotope, would be in order of magnitude less than the maximum permissible concentration of 26/

Cs for unrestricted areas stated in 10 CFR 20.

The analysis of the groundwater spill has conserva-

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tively neglected the initial dilution provided by water impounded in Parr Reservoir nor has any credit been taken -

for additional dilution provided by tributory inflow at-downstream locations along the Broad River.

The Applicant has, in Section 2.4.12.1 of the FSAR, analyzed other surface water flow paths, including a path where radioactive material from a postulated.accide'nt reached the Monticelle Reservoir, an unlikely occurrence due to operational procedures and topographic considerations.

U'S Based upon the evaluation of surface water flow paths, the above described scenario, i.e., waste holdup tank spill to the Broad River, is the limiting one.

25/ Id,. at 3.

26/ Id. .

27/ Id.

28/ Id. .

i

• s, Ihe' Applicant has analyzed under typical conditions the time necessary for a slug of radioactive effluent to travel

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to Colwn}bia, South Carolina. The City of Columbia is the- '

nearest downstream

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surface water user and is located approxi-mately 28 miles below Parr Dam. The travel time to Columbia has been calculatedfto be 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. During the assumed drought conditions, the travel time would be greater, approxi-mately 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />. Moreover, if the travel time were 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, it would mean that there was greater dilution in the-river than for which credit was taken in the accident anal ~ysis described above.~~29/

O .

Various measures are taken to assure that the planned controlled release of small amounts of radioactive effluents meet all NRC requirements. Initially, 1,iquid effluents from the liquid radioactive waste processing systems can only be released through the monitor tank. Prior to releasing the contents of any tank, an analysis of its contents must be 3Sl made. Moreover, a system of detectors and valves which shut automatically if excessive levels of radioactivity are detected are utilized to prevent the release of radioactive materials above pre-set levels.

The' Applicant's emergency plans consider the spill of

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~31 radioactive effluents.into the Broad River. ~/ Contact with 29/ Id. at 3-4.

32/ Id. at 4.

31/ Id. at 4-5.

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the Department of Health and Environmental Control and City of Columbia water supply authorities indicate that sufficient .

storage is available to shut the intake gates on the Broad .

River in Columbia should an unanticipated radioactive release occur until it has passed. Thus the Applicant has sufficient -

equipment and procedures to anticipate, detect and/or mitigate any. accidental release to the Broad River even during low flow conditions.

Mr. Bursey, for his part, has admitted that he has not discovered any mechanism or any means for. accidental release of radioactive material not analyzed by the Applicant in its Application. His concerns are admittedly merely generalized and he has no mechanisms identified which would cause any release not analyzed by Applicant. It is thus clear that Mr. Bursey has raised no substantial issue of fact related to Contention A7 and summary disposition should be granted in favor of the Applicant.-

l O 32/ Deposition o'f Brett Bursey dated June 13, 1978 at p. 141.

l See also Deposition of Brett Bursey of' August 3, 1978 at l 159.

33/ Id. at 147. .

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t Conclusion For the foregoing reasons, with regard to Contentions -

A6 and A7, there are no material f acts to ' hich there exists an issue to be heard, and, therefore, summary disposition should be granted and these two contentions dismissed.

Respectfully submitted, CONNER, MOORE & CORBER 7 FM b'), .

Troy B. Conner, Jr.

9/

0 .

Mark J..Wetterhahn Counsel,for the Applicant -

December 4, 1978 -

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G O

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UNITED STATES OF AMERICA' t NUCLEAR REGULATORY COMMISSION A In the Matter of )

)

SOUTH CAROLINA ELECTRIC & ) Docket No. 50-395 GAS COMPANY, et al. )

) * '

i (Virgil C. Summer Nuclear' )

i Station) )

AFFIDAVIT OF WILLIAM E. MOORE REGARDING CONTENTION AG William E. Moore being first duly sworn according to law comes forward and states:

l

() My nane is William E. Moore. I am employed by ,

South Carolina Electric & Gas Company as Manager of Hydro-electric Engineering. In this position I am responsible for the conduct of environmental programs associated with the V. C. Summer Nuclear Station. I am familiar with the design of the Summer Station as it relates to discharges and am familiar with the effects of discharges at the Company's other steam electric power plants. A copy of a statement of

() my professional qualifications is attached hereto as Attach-ment I and incorporated herein by reference.

I have reviewed the NRC Staff Motion for Summary Disposition as it relates to Contention A6, including the i

relevant Affidavits. The material presented therein is consistent with the position of the Applicant, South Carolina I

Electric & Gas Company, as discussed below and as presented in the Final Safety Analysis Report and Environmental Report.

I .

--y..,.,... . _ _ _ - ,, . , - _ , . , , - . _ . _ . _ . , , . _ _ . - ., _ _ - . . - _ . - - , , , ., .,

t Applicant agrees that there are no genuine issues of material .

fact remaining and that summary dispo'sition should be granted for Contention A6.

The State of South Carolina has issued NPDES Permit No. SC0030065, a copy of which is attached as Attach-ment II, and incorporated by reference herein. With regard i to thermal discharges, the State's requirements as to water quality contained therein are the same as existed at the construction permit stage.

Associated with the construction of the Summer Station and impoundment is a separate recreation area of three hundred acres where a high quality fishing lake has been created. Such area is referenced in Section 2.4.1.2 of the Environmental Report which is incorporated herein by reference.

As described in Section 3.4.1.2.1.of the Environ- ,

mental Report, the intake screen appraoch velocity is 0.5 fps or less depending on the level of water in the impoundment.

O))b& f. W M William E. Moore [

l SWORN to me before me this / sf . day of December 1978.

f l Notar D M.

Public for Soutli Carolins(

My commission expires i b/ s 0 .

l l

. ATTACHMENT I 1-NAME: William E. Moore POSITION: Manager, Hydro Engineering FORMAL EDUCATION: 1959 Graduated University of South Carolina, Columbia,

. South Carolina '

B. S. Mechanical Engineering 1967 Graduated Michigan State University Nuclear Engineering Environmental Courses at U. S. Public Health Taft Institute, Cincinnati, Ohio REGISTRATION: Registered Professional Engineer O State of South Carolina EXPERIENCE:

1975 - Present South Carolina Electric and Gas Company, Columbia, South' Carolina, Fairfield Pumped Storage Facility, as Manager, Hydro Engineering, I report to the Group Managcr of Production Engineering. I am

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responsible for all aspects of hydro-electric licensing., license maintenance, and designs. I am also responsible for

. -all environmental matters of Production-Engineering Projects prior to commercial operation exclusive of radiological surveillance.

1969 - 1975 South Carolina Electric and Gas Company, Columbia, South Carolina, Senior Engineer - Staff Assistant to Vice President - Production and Operations.

I had responsible' charge for boiler

, overhauls and all environmental matters.

l Responsible charge for relicensing hydro facilities and the preparation and processing of a new license for Fair-field Pumped Storage Facili.ty including all permits and approvals. Responsible for environmental program and the design of dams, generating facility, and roads, railroads, relocations, and all other l

modifications to existing hydro facili-ties required for the new Fairfield Pumped Storage Facility.

i l

ATTACl! MENT I .

1967 - 1969- South Carolina Electric and Gas Company, Columbia, South Carolina, Engineer, as .

Assistant to Vice President - Construction, Operations, and Production, I had the

- responsibility for evaluation and refitting of electrostatic precipitators to all existing coal fired boilers and testing the electrostatic precipitators.

Also design modification and testing sewage handling, cooling ponds, ash ponds and other similar work.

1962 - 1967 South Carolina Electric and Gas Company, Columbia, South Carolina, Chemical

! Engineer, Central Laboratory. Reported to the Manager of Production and was responsible for water analysis, quality and water treatment programs for all company power plants. Responsible for

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developing cost estimates for construc-tion and supplying large quantities of water to industrial and other customers.

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Responsible for all company environ-

• montal programs including water and gaseous emissions. Responsible for design and construction of modifications and enlargoment of water purification and demineralizer equipment.

1961 - 1962 South Carolina Electric and Gas Company, -

Columbia, South Carolina, Results Enginee'r, McMeekin Station. Reported to the Plant Superintendent and had responsi-

.f ble charge of all of the below and

- responsible for design of modifications to reduce cost and improve officiency.

Responsible for design, construction, purchasing of equipment - apparatus -

glassware and chemicals for now central laboratcry. .

1959 - 1962 ' South Carolina Electric and Gas Company, Columbia, South Carolina, Results E'qineer Trainee. Reported to the Rt_'lts Engineer and assisted with performance test and calculations

! relative to operation of power plant whic included combustion, boiler, turl.ne, pumps, and heators. Assisted l

witb supervision and operation of water l

- plant which included clarifiers, filters, chlorinators, and domineralizers. .

l Assisted with supervision and performed all laboratory tests which included coal, ash, and water chemistry and lub oils test.

r-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

SOUTH CAROLINA ELECTRIC ) Docket No. 50-395

& GAS COMPANY, et al. )

. )

(Virgil.C. Summer Nuclear )

Station)

)

AFFIDAVIT OF WILLIAM R. BAEHR REGARDING CONTENTION A7

() William R. Baehr being first duly sworn according to law comes forward and states:

My name is William R. Baehr. I am employed by South Carolina Electric & Gas Company a's Health' Physicist and E'nvironmental Coordinator. In this position I have reviewed and am familiar with the design provisions and proposed operating procedures of the Summer Station designed to '

prevent the accidental release of radioactive liquids for

() (' the facility and the assumptions and methodology used in the calculation of doses due to such hypothetical releases. I am also familiar with the provisions c.ontained in the facility Emergency Plan for dealing with such hypothetical releases. A copy of a statement of my professional qualifi-cations is attached hereto as Attachment I and incorporated herein by reference.

I have reviewed the NRC Staff Motion for Summary Disposition as it relates to Co'ntention A7, including the relevant Affidavits. The material presented therein is

i consistent with the position of the Applicant, S'outh Carolina Electric and Gas Company, as discussed below and as presented in the Final Safety Analysis Report and Environmental Report.

Applicant agrees that there are no genuine issues of material fact remaining and that summary disposition should be granted for Contention A7.

Applicant has thoroughly analyzed the possibility of an accidental release of radionuclides in liquids from the V.

Summer Nuclear Station and, as discussed below, such hypo-thesized releases will not affect local or regional water groundwater supplies.1 This analysis considered the specific

(]

e design of the Summer Station and potential failure of four types of tanks.2 A comparison of the volumes and concentra-tion of the radioisotopes in these four types of tanks revealed that the hypothesized rupture of a waste holdup tank was the limiting case.3 The capacity of the waste holdup tank is.10,000 gallons.

For conservatism it was assumed that at the time of the rupture of'the tank it was full and had an isotope composi-tion equivalent to the composition of reactor coolant, a conservative assumption. It was assumed that at the time of the accident that the entire tank, underlying foundation and adjoining walls rupture. The liquid in the waste holding tank is assumed to immedintely contact the saturated geologi-

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cal material adjacent to the tank.4 1FSAR S2.4.13.3 at p. 2.4-46.

2FSAR S2.4.13.3.1 at p. 2.4-46. l 3FSAR S2.4.13.3 at p. 2.4-46.

4 FSAR S2.4.13.3.1 at p. 2.4-46a.

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Two possible flow paths were analyzed in detail. The ,

method of analysis if fully described in Section 2.4.13.3.2 1

of the FSAR.

Section 2.4.12.2 of the FSAR discusses groundwater flow paths for such an accident. Even if such a spill were to occur at the same time as the, minimum historic flow in the l

Broad River of 149"CFS was occurring, the peak concentration l37 of Cs , the controlling isotope, would be in order of magnitude less than the maximum perm.issible concentration of g- Cs l37 for unrestricted areas stated in 10 C.F.R. 20.

' The analysis of the groundwater spill has conservatively neglected the initial dilution provided by water impounded in Parr Reservoir nor has any credit been taken for additional dilution provided by tributory inflow at downstream locations along the Broad River.5 The Applicant has, in Section 2.'4.12.1 of the FSAR, analyzed other surface water flow paths, including a path

• where radioactive material from a postulated accident reached U' . the Monticello Reservoir, an unlikely occurrence due to operational procedures and topographic considerations.

Based upon the evaluation of surface water flow paths, the above described scenario, i.e., waste holdup tank spill to the Broad River, is the limiting one. i The Applicant has analyzed under typical conditions the time necessary for a slug of radioactive effluent to travel l

5FSAR Sw.4.12.1 at p. 2.4-35.

, j l

to Columbia, South Carolina. The City of Columbia is the i nearest downstream surface water user and is located approxi- 4 mately 28 miles below Parr Dam.6 The travel time. to Columbia has been calculated to be 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />. During the assumed drought conditions, the travel time would be greater, approximately 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />. Moreover, if the travel time were 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />, it would mean that there was greater dilution in the river than for which credit was taken in the accident analysis described above.7

. Various measures are taken to assure that the planned controlled release of small amounts of radioactive effluents meet all NRC requirements. Initially, liquid effluents from the liquid radioactive waste processing system can only be released through the monitor tank. Prior to releasing the contents of any tank, an analysis of its contents must be made. Moreover, a' system of detectors and valves which shut automatically if excessive levels of radioactivity are detected are utilized to prevent the release of radioactive materials above pre-set levels.8

[ The Applicant's emergency plans consider the spill of radioactive effluents into the Broad River.9 Contact with i

t the South Carolina Department of Health and Environmental I

and the City of Columbia water supply authorities indicate l

l l

l 6Id. at p. 2.4-34.

7FSAR S2.4.12.1 at p. 2.4-35.

l 8 FSAR Sll.4 at 11.4-1 through 11.4-21 and OLER S3.5.5 at

p. 3.5-23 through 3.5-35.

9FSAR Appendix 13A (South Carolina Electric & Gas Company V. C. Summer NucJear Station Radiation Emergency Plan) l and FSAR S2.4-12.1 at p. 2.4-34.

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

that sufficient storage is available to shut'the intake gates on the Broad River in Columbia should an unanticipated.

'r'adioactive release occur until it has had time to pass.

Thus the Applicant has sufficient equipment and procedures to anticipate, detect and/or mitigate any accidental release to the Broad River even during low flow conditions.

ll lbL k0 William R. B'aehr G?

SWORN to me before me this  ! day of December 1978.

I Not AL y Public for So th Caroliny My commission expires '/ @; O .

e 0

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- _ . :__ -R- --. - . -

ATTACHMENT I NAME: William R. Baehr POSITION: -

Health Physicist and Environmental Coordinator i

FORMAL EDUCATION: Georgia Institute of Technology - ,

School of Nuclear Engineering ,Gradu-ated 6/12/71 M.S. Nuclear Engineering, Radiological Science Option (AEC Health Physics Fellowship)

Lenoir Rhyne College - Physics Depart-ment Graduated 5/19/69 --B.S. Physics i EXPERIENCE: -

5 1977 - Present South Carolina Electric and Gas Company, Columbia, South Carolina, as Health Physicist and Environmental Coordinator, Nuclear Operations and System Planning Department. Duties-and responsibilities

) include: Reviews and makes recommenda-l tions related to Health Physics aspects -

of plant design and operatione. Provides technical and staff support for.the in-plant Health Physics group. Reviews and coordinates activities involving nuclear '

i project related non-ratiological moni-toring (Meteorological, Biological, l Hydrological, etc.). Designs, imple-ments, operates and manages a]l aspects of the off-site Environmental Surveil-lance Program and its laboratory and staff. Coordinates Nuclear Operations' involvement in licensing efforts in the areas of Health Physics and Environ-mental affairs.

1973 - 1977 South Carolina Electric and Gas Company, ColunLia, South Carolina, as Health Physicist-Staff, Production Engineering Department. Duties and responsibilities included: Responsible for the engineering '

review of Health Physics related design parameters for V. C. Summer Nuclear Station. Responsible for the conduct and coordination of the Biological, Hydrological, Meteorological and Micro-seismic Monitoring Programs. Coordinated the preparation of the Operating License .

Environmental Report and those sections of the FSAR related to Health Physics t

. ATTAC!! MENT I and environmental concerns. Responsible for the design, implementation, and .-

operation of the Environmental Surveil-  :

lance' Program.

1971 - 1973 Georgia Department of Iluman Resources, Radiological Health Unit, Atlanta,

• Georgia as a Radiation Safety Officer.

Duties and responsibilities included:

Evaluation and licensure of Georgia users of Radioactive Materials. Inspec-

. tion of Licensees, Maintenance and Calibration of radiation detection instruments. Emergency Response.

Formulation of initial state Radio-logical Emergency Plan. Planning, development, and initial impleaentation of the state's Environmental Surveil-lance Program (including design, labora-

', tory set up, selection of equipment and

[4, methods, etc.).

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of .

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SOUTI! CAROLINK ELECTRIC & ) Docket No. 50-395 GAS COMPANY, et al. )

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(Virgil C. Summer Nuclear )

Station) , ) ,

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicant's Answer to NRC Staff Motion for Summary Disposition," dated December 4, 1978, in the captioned matter, have been served upon the following by deposit in the United States mail this 4th day of December, 1978: ,

r Ivan W. Smith, Esq. George Fischer, Esq.

Chairman, Atomic Safety and Vice President and General

, Licensing Board Counsel U. S. Nuclear Regulatory South Carolina Elec cric & Gas.

Commission Company Washington, D. C.. 20555 Post Office Box 764 Columbi'a, South Carolina 29202 Dr. Frank F. Hooper Member, University of Steven C . Goldberg, Esq.

Michigan Office of the Executive Legal '

Camp Filibert Roth Director Iron River, Michigan 49335; U. S. Nuclear Regulatory Commission Mr. Gustave A. Linenberger Washington, D. C. 20555 a Member, Atomic Safety and Licensing Board Panel Mr. Brett Allen Bursey

( .s) U. S. Nuclear Regulatory Route 1, Box 93-C Commission Little Mountain, South Carolina Washington, D. C. 20555 29075 Chairman, Atomic Safety and Mrb Chase R. Stephens Licensing Appeal Board Panel Docketing and Service Section-U. S. Nuclear Regulatory Office of the Secretary Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Chairman, Atomic Safety and Licensing Board Panel Richard P. Wilson, Esq.

t U. S. Nuclear Regulatory Assistant Attorney General Commission S.C. Attorney General's Office Washington, D. C. 10555 P. O. Dox 11549 29211 Columbia, S.C. .

Mark '3. . Wetterhahn

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SG Cli!K"3!A HAEET GF RTJ A TIIOIllZATION TO DISCilAltGL UNDEILTIIE N ATION AL POLLU PANT DISCil AII' .E ELIM .

i Control Act of South In compliance with the provisions of the Pollut on) and with (33 U.S.C.

the provisions o 1251 et seq; Carolina (S. C. Code 63-195 et Act, r.cq, as amendedas amended l

the l'cderal Uater Pollution Control the "Act"), .

South Carolina Electric & Gas Company P.O. Box 764 29202

. Columbia, S.C.

is authorized to discharge from a facility located at Virgil C. Summer fluclear Station ,

Parr, South Carolina to receiving waters named Broad River i ents and other with effluent limitations, monitoring III hereof. requ rem in accordance I conditions set forth in Parts I, II, and JUL 211976 This permit shall become ef f ective on hall expire at midnight, This permit and the authorization to. discharge.s JUL 21 1981 JUN 211976 Signed this l ,

ks ([ g (E tream l 2l{.Qaw$ in e-o ck , M .D . , M . l' . ll .

lhin an /d East &.hter and Oualit.y Control

_F.1:enneth A l Conmissioner . . . . . . -

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS .

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• During the perio'd beginning on'[%ctiva date and lasting thro G 9xpiration -

the permittee is authorized to cfhdharge from outfall(s) serial number (s) 001 - Once through cooling water. .

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

Effluent Characteristics . Discharge Limitations Monitoring Requirements Monthly Instantaneous Measure ent Sa-ale Avg. Maximum Frequency Type l Flow-=3/ Day (MGD) N/A N/A Continuous

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. Recorder or Pum.p Logs i Discharge Temperature'OC(OF) N/A 45(113) Continuous Recorder i

Intake Te=perature OC(OF) N/A N/A_ Continuous Recorder

! Plume Temperature O C(OF) 32.2(90) N/A' 1/ quarter Multiple Gra

) Plume Temperature Rise OC(OF) 1.66(3.0) N/A 1/ quarter Multiple Grabs j . Plume Surface Area (Acres) , N/A 6700 1/ quarter Calculations j Surface Temperatures 1/ - . -

Continuous Recorders i

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,1_/ The points of surface temperature monitoring shall be 1) at the intake structure of the Fairfield Pumped Storage I

, Facility in the most practicable and representative , point at a depth of one foot and 2) on the south side of S.@

Highuay #99 dam as close to the ' dam as practicable at a depth of one foot. (this. point shall represent tha ambica l .

temperature). A more appropriate location for ambient temperature may be approved. if data shows the valic'ity of

, , such a change. A monthly average surface temperature as high as 32.7 C(90 F) may be discharged from Monticello

Reservoir, however, this surface temperature shall not be greater th,n 1.660C(3.00F) abeve ambient temperature i on a =onthly average basis. Surface temperatures shall be considered only during the generating moda of the

} Fairfield Pumped Storage Facility.

j Eighteen months after com=creial operation, the permittee shall develop monthly receiving water temperature dist

! butions for normal and critical hydrological (flow, , reservoir elevation, tidal stage, etc. as applicable)'and me ological conditions at maximum plant output. Isotherm plots, both p?an and cross-sectional and tabulations of a down to the 10C excess temperature in no more than 20C increments (a minimum of three values) shall be' provided Zones of passage shall be defined. Measuiement methods, modeling techniques, assumptions and calculations shall be included.

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l Sam:31es taken in compliance with the monitoring requirements specified above shall be taken at the following ca location (s): Discharge temperature shall be monitored at the outlet corresponding to an individual unit 8 prior to mixing with other waste streams, intcke temperatures shall be. taken at the plant intake, plume &

) temperatures within the thermal plume, and surface temperatures as described above. S 1 .

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A. ETFLENT LIMITATIONS AND MONITORING REQUIREMENTS

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During the period beginning effecL,4).date and lastin;; through c'*:,dra: ion ,

the per=ittee is authorized to discharge from outfall(s)- serial number (s) 002 - Service k'ater Pond Such discharges shall be limited and t:onitored by the, permittee as specified below:

Discharge may occur from service water pond through the condenser cooling water intake structure. This occurs only uhen the circulating cooling water pumps are taken out of service.

Effluent Characteristic Discharge Limitations . Monitoring Fecuirceents

. Daily Avg. Daily Max. Measurement Sar- le Frequency Type Floe-=3/ Day (MGD) -

N/A N/A fer Occurrence Instantant. s Te:perature N/A N/A' Per Occurrence Grab 9

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EFFi.UENTLIMITATIONSANDMONITOPf). REQUIREMENTS

. t G' Durir.g the period beginning effective date'and lasting through expiration .

the permittee is authorized to discharge from outfall(s) serial number (s) - 003 - Rad Waste -

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

Compliance with the requirements of the United States Nuclear Regulatory Comission will be deemed to.

constitute compliance with this permit. Permittee shall submit to the South Carolina Department of Health and Environmental Control and Environmental Protection Agency, Region IV, copies of all environmental monitoring reports submitted to the NRC. such reports may be submitted with other monitoring reports required by this permit.

i In the event that low volume or =etal cleaning wastes as defined in 40 CFR Part 423 are discharged through

' this serial nu=ber, treatment and conitoring shall be provided to assu'e r that discharges are in co=plicnce 4

with require =ents of Part 423.12 (See serial 006, 007, and 008). ~

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EFFLUEllT LIMITATI0:iS AND MONK /,'IriG REQUIREMENTS f*

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. Caring the period beginning effective,date and lasting through ex:)iration ,

the permittee is authorized to discharge from outfall(s) serial nrmber(s) 004*- Steam Generator Blowdewn Such discharges shall be limited :iu monitored by the permittee as specified below:

Effluent Charact' eristic . Discharoe Limitations Monitorina.Recuire er Daily Avg. Daily Max. Measurement Sarc Frecuency .

Flow-m3/ Day (MGD) N/A N/A 1/ month Instantan

• Cil and Grease (mg/1) -

15 20 1/ month Grab Total Suspended Solids (mg/1) 30 l'J0 1/ month Grab 1.0 1.0 1/ month Grab Ccpper, Total (mg/1)

Iron, Total -(mg/1) 1.0 1.0 1/ month Grab 1

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

- Samples taken in compliance 'with the~ monitoring requirements specified above shall be taken at the followi

.- location (s): discharge from the steam generator blowdown treatment fccility. prior to mixing with any other -

waste stream.

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• Serial number assigned for identification and monitoring purposes.

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A},j A. EFFLUENT LIMITATIONS AND MONITORIEG I P{IREMENTS g-

- During the period beginning. effectiVdate and lasting through~ expiration date

! the permittee is authorized to discharge froa outfall(s) serial number (s) 005**- Sanitary treatment plant dischar -e- '

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

Monitoring Requirements Discharge Limitations Effluent Characteristic Concentration (eg/1) Other Uni ts (Specify)_ .

Daily Mc.: , Measurenent Sample i Monthly Weekly Daily- Monthly Geometric Frequency Type

. Avg Avg Max

. Mean*

2/ month Instantaneous ,

!. Flow-m / Day (MGD) N/A N/A N/A N/A N/A t Composite 50D5 (mg/1) 30 45 '6b N/A N/A' 2/ month .

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N/A 2/ month Co: posite TSS (mg/1) 30 45 60 N/A .

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2/ month Grab 8

Fecal Coliform Bacteria N/A N/A N/A 200/100 ml. 400/100 ml I -

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The pH shall not be les.s than 6.0 standard units nor greater 9.0 than standard units and shall be conitored twice per month by grab.

Thereshallbenodischargeo[floatingsolidsorvisiblefoaminetherthantraceamounts.

l Sc=ples taken in compliance with the monitoring requirements specified above shall be taken at the following location (s): at the sewage treatment plant discharge prior to mixing with any other waste stream.

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• For purposes of calculating the geometric mean, a value of '1/100 mi shall be assigned 'to each n.

determination which yields a value Icss than 1/100 ml. The monthly geenetric mean limitation I

is not applicable if only one sample is taken during the month.

• • Serial number assigned for identification and monitoring purposes. -

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A. EFFLUENT LIMITATIONS AND MONITf REQUIREMENTS' [

During the period beginning effective date and lasting through expitation the permittee is authorized to discharge from outfall(s.) serial nunQer(s) 006*and 007*- Low Volume Waste Sour.e2 Such discharges shall be limited and monitored by the permittee as specified below:

Effluent Characteristic Discharge Limitations Monitoring Requirements

- Daily Avg. Daily Max. Measurement Samole Freauency Tyre Flcw-m 3/ Day (MGD) N/A N/A 1/ week Instant- 1 Gil and Grease (mg/1) 15 20 1/ week Grab Total Suspended Solids (mg/1) 30 100 1/ week Grab Lew volume waste sources shall mean taken collectively as 'if from one source, waste water from all sources except those f-r vhich specific limitations are otherwise required in this permit, including, .

but not limited to waste waters from wet scrubber air pollution control systems, ion exchange water treamtment systems, water treatment eyaporator blowdown, laboratory and sampling streams, floor drainage, cooling tower basin cleaning wastes and blowdown from recirculating house service water systems.

The pH shall not be less' than 6.0 standard units nor greater than 9.0 standard units and shall be monitored once per week by grab.

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

Samples taken in. compliance with the monitoring requirements specified above shall be taken at the following lecction(s): discharge from the low volume wastewater treatment facility (s) prior to mixing with any other ;;,

waste stream. -

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• Discharge 006 is defined as the combined effluent from the treatmtnt systems handiing the non-nuclear plant drains and the water treatment sludges. Discharge 007 is defined as the effluent from the treat- v, g g

ment system handling ion exchange regenerant water. serial number for identification and conitoring purposes. g 8

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A. EFFLUEf!TLIMITATIONSANDM0k5INGREQUIREMENTS [

Curing the pericd beginning effective date and lasting 'through expiration ,

the permittee is authorized to discharge from outfall(s) serial.nceber(s) 008*- Metal Cleaning Wastes Such discharges shall be limited and monitored by the permittee as specified below:

! Effluent Characteristic Discharce Limitations Monitoring Recuirt

. Daily Avg. Daily Max. . Measurement j

' F.eouencyif i Flow-m 3/ Day (MGD) .N/A. N/A 1/ day Instani i 011 and Grease (eg/1) 15 20 1/ueek Grab i Total Suspended Solids (mg/1) 30 -

100 1/ueck 8 Hr. t Copper, Total (rg/1) 1.0 1.0 1/ueek 8 Hr. (

l 8 Hr. (

i Iron, Total (mc/1) -

1.0 1.0 1/ week l

Metal cleaning wastes shall mean any cleaning compounds, rinse waters, or any other waterborne residues derived free cleaning any metal process equipment including, but not limited to,. boiler tube cleaning,-

i boiler fireside cleaning and air preheater cleaning.

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' ir.e pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall. be monitored continuously or at a . lesser frequency commensurate with treatment systan instituted.

Th'ere shall be no discharge of ficating solids or' visible foam in other than trace amounts.

I f Samples taken in compliance with the monitoring requirements specified abova shall be taken at the following

! ~1ocation(s): discharge from the metal cleaning wastes treatment facility (s) prior to mixing with any othe'-

I waste stream. .

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• Discharge occurs only during chemical cleaning activities. Serial number assigned for identification and monitoring purposes.

l 1/ In the event of batch treatment monitoring shall be adequate to characterize the discharge.

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t It is' reco== ended that the applicant control the discharges of hirh - phesphate wastes (such' as these e::perienced during pre-operational clean-out of - piping and equipment) to 1.0 mg/l phusphate in order l ,

to maintain acceptable nutrient leads on Monticello Reservoir.

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d'c 2 A. EFT'.*'ENT LIMITATIONS AND MONITC( dv/

• Q REQUIRDENTS .

and lasting through expiration During the period beginning ]/ .

l the permittee is authorized to. discharge from outfall(s) serial number (s) 009 * .- Point cource(s)-runoff

' (rom construction

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

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- Diccharge Limitations Monitorin( Kequire=ents l Effluent Chsracteristic ,

l Measurement Sample Instantaneous Maximum

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Frequency Type i

r Flow-m 3/ Day (MGD) N/A 1/ week Grab

' Total Suspended Solids (=g/1) 50 2/ l/ week Grab Construction runoff shall include. rainfall runoff discharged to navigable waters through any disecrnible,

' confined and/or discrete conveyance from any constructier. activity and any carth surface disturbed by such activity from the inception of any construction until construction i.s cc=plete and disturbed carth is returned to a vegetative or other cover commensurate with the intended land use. .

NOTE: Monitoring of point cource construction runoff and any point source site runoff shall commence ,

on the effective date of this permit. .

9.0~ standard units and shall be The pH shall not be less than 6.0 standard units "n'or greater than - n.

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cenitored once per week by grab 2/. .

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

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Sa=ples taken in compliance with the monitoring requirements specified above shall be taken at the

• fol'.cwing location (s): point (s) of discharge from treatment system prior to mixing with other waste my streams. .

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o hs required by this permit,

,1] July 1, 1977 or on start of construction of waste treatment faciliti

• g whichever is earlier. E l

2,/ Applicable to any flow up to the flow resulting If an from a 24-hourisrainfall impoundment event utilized with a probable by permittee, it

'recurrance interval of once in ten years.

l shall be capable of containing a 10aycar, 24-hour rainf all event. Jj 1 M~ -MhardlconuimfLEMBigoring _ purpe':cs.

PARI I

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Page 10 of '18 Permit No. SC0030856

r B. SCEllDULE OF C0iiPLIAllCE

1. The permittee nhall achieve compliance with the ef fluent limitations specifie -

for discharges in accordance with the following schedule:

a. Start biological study 316(b) - (Intake) 60 days af ter commercial operation of Nucicar Unit I.

b. Biological report 316(b) --18 months after commercial operation of the Nucleal Unit I.

c. Start thermal plume analysis - 60 days af ter com=creial operation of Nuclear Unit I.

d. Thernal ef fects monito' ring (1) Implement Study - commercial generating date of Fairfield Putp Storage Unit I.

ccr.creial operation cf (2) ' Final preoperational report - 00 days a..n Nuclear Unit 1.

h, (to include both pre and post operational findings) -

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(3) Final Report 2 years after commercial operation of Nuclem

• Unit.l.

(4) Interim reports shall be subitted to the South Carolina Departtrent of IIcalth and Environmental Control and U.S. Environmental Protection I. gene; cvery six months af ter the study is impicmented for a period1.continuing until two years after commercial operation of Nuclear Unit s

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2. No later than 14 calendar days following a date identified in the above schedule of compliance, the permittee shall submit cither a report of pro-gress or, in the case of specific actions being rcquired In the latter by identified case, the dates, no-a written notice of compliance or noncompliance. k tice shall include the cause of noncompliance, any recedial actions ta en, and the probability of inceting the next scheduled requirement.

IKEmyW\Wo. 89MMSMD C. 110illTORIliG AliD REPORTIf:G .

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1. Re[ite.seMative Sampling ~

Samples and m'casurements taken as required herein shall be representative of the volume and nature of the monitored discharge. .

2. Repo.tting Monitoring results obtained during the previous 3 months shall be summarized for cach month and reported on a Discharge Monitoring Report Form (EPA llo. .

3320-1), postmarked no later than the 28th day of the month following the com-pleted reporting period. The first report is due on October 28, 1976. '

Duplicate signed copics of these, and all other reports rcquired herein shall be submitted to thu Regional Administrator and the State at the following ad-dresses:

hvironr. ental Protectf en .*,gan::y S:.uth Carell:n Tc;;at tr ent of I'calth and f7p Water Enforcement Branch En'vironmental Control ,

f\,a 1421 Peachtree Street, U.E. Attention: NPDES Permits Section Atlanta, Georgia

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30309 2600 Eull Street -

Columbia, S.C.

l 29201

. 3. Sefinition,5

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a. The " daily average" discharge means the total discharge by weight during a calendar month divided by the number of days in the month that the pro-duction or commercial facility'was operatinh. Phere less than daily sam-pling is required by this permit, the daily average discharge shall be determined by' the summation of all the measured daily discharges by weight divided by the number of days during the calendar month when the measure- -

ments were made.

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b. The " daily maximum" discharge means th4 total discharge by weight during

) ,) any calendar day.

4. Test ' Procedures -

l Test procedures for the analysis of pollutants.shall. conform to regulations pub-lished pursuant to Section 304(g) of the Act; under which such procedures may be re' quired.

Recording of ReS Lts l 5.

l For cach measurement or sample taken pursuant to the requirements of this permit,

! the permittee shall record the fo.llowing information:

l a.

l The exact place, date', and time of sampling; .

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h. The dates the analyses were perforned; -

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

, .. . PART.I .

cf 18 Page 12 Permit No. SC0030356

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. d. The analytical techniques or methods used; and

c. The results of all required analyses.

6. Mditional llonitoring bt) Pcwittee

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If the permittee monitors any pollutant at the location (s) designated herein more frequently than required by this permit,-using approved analytical meth-ods ac specified above, the results of such monitoring shall be included in the calculation and reporting of the val ~u es required in the Discharge lioni-toring Report Form (EPA No. 3320-1). Such increased frequency shall also bc indicated.

7. Recondo Rc.tenttion All records and information resulting from the monitoring activitics required

[N by this permit including all records of analyses performed and calibration and

'\d maintenance of instrumentation and recordings from continuous monitoring in-strumentation shall be retained for a minimud of three (3) years, or longer if requested by the Department,of Ilealth and Environmental Control.

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Permit tio. SC0030856

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A. MMlAG$MEilT REQUIRD1ENTS

1. Change in Dischange All discharges authoriicd hercin shall be consistent with the terms and conditions of this pemit. The discharge of any pollutant identified.in this permit more frequently than or at n Icvel in excess of that author-ized shall constitute a violation of the permit. /ny anticipated facil-ity expansions, production increases, or process modifications which will result in new, different, or increased discharges of pollutants must be reported by submission of a new UPDES application or, if stich changes will-not violate the effluent limitations specified in this permit, by notice to the permit issuing cuthority of such changes. Following such notice, the permit may be modified to specify and limit any pollutants not previ-ously limited. .

2. l.'cr:cca.ptim:ce !.'OtlUcation

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If, for any reason, the permittee does not comply with or vill be unable

- . to comply with any daily maximum effluent limitation specified in this pcmit, the permittee shall provide the Department of IIcalth and Environ-mental Control with the following infomation, in writing, within five (5) days of becoming aware of such condition: _

a. A description of the discharge and.cause of'noncomp'11ance; and

b. . The period of noncompliance, including exact dates and times; .or, if not

. corrected, the anticipated time the noncompliance is expected to contin-uc', and steps being taken to reduce, climinate and prevent recurrence of the noncomplying discharge. .

3. FaciUlles Opchation -

The permittee shall at all' times maintain in good working order and operate

+ as efficiently as possible all treatment or control facilities or systems installed or used by the permittee. .

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( 4. ~. Adverse impact .

The permittee shall take all reasonable steps to ninimize any adverse impact to navigabic waters resulting f rom noncompliance with any ef fluent limitations specified in this permit, including such accelerated or additional monitoring as necessary to determine the nature and impact of the noncomplying discharge.

5. Bypassing ,

Any diversion from or bypass of facilitics necessary to maintain compliance with the terms and conditions of this permit is prohibited, except (i) where unavoidable to prevent loun of life or severe propfrty damage, or (ii) where excessive storm drainanc or runof f would damage any facilities necessary for compliance with the ef fluent limitations and prohibitions of this permit.

The permittec ; hall promptly notify the 11cpartment of !!calth and Environmental Control in writ.ing of each :;uch diversion or bypasu. .

PART II

, Page lo of 18 .

Permit !!o. SC0030856 G. Removed SubMances "

l Solids, sludges, filter hackuanh, or other pollutants removed in t!ic course of treatment or. control of vastewaters shall be disposed of in a manner such as to prevent any pollutant from such materials from entering navigable waters. .

7. Pcwcr' Failures In order to maintain compliance with the effluent limitations and.prohibi-tions of this permit, the permittee shall either:

a. In accordance with the Schedule of Compliance contained in Part I, pro-vide an alternative power source sufficient to operate the wastewater control facilitics; or, if such aitcrnative power source is not in cxistence, and no date for its implementation appears in Part I,

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, Italt, reduce or otherwise control production and/or all discharges upon the reduction, loss, or failure of the primcry source of power,to the wastewater control facilitics.

B. RESPONSIBli_ITIES

1. PJgitt of Entjuj

• The permittee shall allou the Commissioner of the Department of Health and Environmental Control, the Regional Administrator, and/or their r.uthorized representatives, upon the presentat, ion of credentials: -

('\g' a. To enter upon the permittee's premises where an. effluent source'is lo-q , ,)

cated or in which any records are required to be kept under the terms and conditions of this permit; and ,

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

2. TraitSf ch of Gonctsstip of Controt 1 -

I In the' event of a..y .hange in control or ownership of facilitics f rom which the author 17.cd discharges emanate, the permittee shall notify the succeeding owner or contreller of the existence of this permit u*y letter, a copy of which shall be, forwarded to the Department of 1;calth and Envi~ronmental Con-trol.

3. Austilabilitt) of Reports '

Incept' for data determined to be confident'n1 under Sect ion 30S of the Act, all reports prepared in accordance with the teins of this permit shall be available for public

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PART II .

Panc 15 of 18 Permi t No. SC0030356

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inspection at the offices of the Department of Ucalth and Environmental Control and the Regional Administrator. As required by the Act, ef fluent data shall not be considered confidential. Knowingly making any false statement on any

- such report may result in the imposition of criminal penaltics as provided for in Section 309 of the Act.

4. PsunLt I.fodification ,

After notice and opportunity for a hearing, this permit may be modified, suspended, or revoked in whole or in part during its terra for cause including, but not limited to, the following:

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

b. 01-tnining this permit by misrepresentation or f ailure to disclose fully all

(- relevant facts; or A-}' -

c. A change in any condition that requires either a temporary or permanent 1 reduction or elimination of the authorized discharge.

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

. prohibition and the permittee so notified. .

Civil and Criminal Liability m 6.

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'# Except as provided in permit ccaditions on " Bypassing" (Part II, A-5) and

" Power Failures" (Part II, A-7), nothing in this permit shall be construed to relieve' the permittee from civil or criminal penaltics for noncompliance.

7. Oil and Itawtdous Substance Liability ,

Nothing in this permit shall be construed to preclude the institution of any Icgal action or relieve the permittee from any responsibilities, liabili tic s ,

or penaltics to which the permittee is or may be subject under Section 311 of the Act. .

8. State Laws Nothing in thin permit shall be construed to preclude the institution of any legal act ion or relieve the permittee from any respensibilitics, liabilitics,

. or penalties entablished pursuant to any applicable State law or regulation

. under authority preserved by Section 510 of the Act.

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Panc 16 of' 18 Permi t flo. SC0030356 N

9. Phoperbj Pigkt6 The issuance of this permit does not convey any property rights in citiier real or personal, property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringe-ment of Federal, State or local laws or regulations.

10. SevcrabiELbj The provisions of this permit are severabic, and if any provision .of this permit, or the application of any provision of this permit to any circumstance, is hcId invalid, the application of such provision to other circunstances, and the remainder of this permit, shall not be af fected thereby.

PART III (fHER 'REQUIREMEHTS fi -

A. In the event that waste streams from varicus seurces are combined for treatment or discharge, the quantity of each po.lutant or

' pollutant property attributable to cach controlled waste source shall not exceed the specified limitation for that waste source.

B. If the permit. tee, af ter monitoring for at least six months, deter-mines tha t he is consistently meeting the. effluent limits contained herein, the permittee may request of the S.C.D.H.E.C. tha t the monitoring requirement.s be reduced to a lesser frequency or be eliminated.

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

D. The company'shall notify the S. C. D. II. E. C. in writing not

- {,,' ; later than sixty (60) days prior to insituting use of any additional

, y, e biocide or chemical used in cooling systens, '

which may be toxic to aquatic life other than those previously reported to the

.Enviror. mental Protection Agency. Such notification shall include:

1.  !!ame and general composition of biocide or chemical *

2. Quantities to be used . .

3. Frequencies of use

4. Proposed discharge concentration

5. EPA registra tion number if applicable.

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P it tio.- SC0030856 E. In accordance with Section 316(b) of the Act, by * , the permittee shall design; submit spncific details for review, modification and approval by the South Carolina Department of Ilealth and Environmental Control; and implement an approved program ;

to monitor nekton' and shellfish-impinged on plant intake structures and fish eggs and larvae and other organisms entrained by the cool _ing water system. Such study'shal be in conformance with "Dasic Guide to the Design of 316 Derronstrations, Region IV epa (August 7, 1974)."

. f During this study period the permittee is encouraged to experiment with systems, methods or procedures to minimize impingemnt and entrainment effects. By ** ,

t! : p::rmittee shall submit a summary report to the South Carolina Department of Ilealth and Environmental Control as to the effects of the present cooling water intake with regard to Section 316(b) of the Act. If significant impingement and entrainment is occurring, this report shall include:

1. An evaluation of facility or procedure modifications i.f necessary, to minimize the environmental impact of the cooling water intake.

2. An evaluation of methods to return viable nekton and shellfish collected on the intake screens to, ambient temperature water at a point outside the influence of the rlent intake and discharge, and -

n'. 3. Proposed facilities or modifications with attendant implementation schedule (s) s for implementing 1 and/or 2 above.

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Should any required biological study results indicate the possible need for off-stream cooling or other modifications to the present cooling water system, the above

. discussion shall include an evaluation of the effects on impingement and entrain-ment of such system mcdifications.

At the conclusion of this study period, subject to opportunity 'for review and hearing, the permittee shall implement procedures and or facility construction associated with the intake struc.ture(s). .

F. By commercial generating date of Fairfield Pump Storage Unit #1, the' permittee shall design; submit specific details for review, modification and approval; and implement approved studies to conitor the projected thermal effects provided in Water Quality Demonstration dated April 7, 1975. This monitoring program shall include pre-operatio QI3 and post-operational effects of the thernal discharge on Monticello Reservoir.

G. Intake screen wash system water may be discharged without limitations or monitoring

. requirements.

H. For the purpose of this permit, the monthly average, other than for fecal coliforn bacteria, is the arithmetic mean of all the composite samples collected in a one-month period. The monthly average for fccal coliform bacteria is the geometric

.mean of' samples collected in a ohe-month period. -

L For the purpose of this permit, the weekly averanc, other than for fecal coliform ba'cteria, is the arithmetic mean of all the composite samp]cs collected during a one-ucek period. The ucekly average for fecal coliform bacteria is the geometric mean of' samples collected in a one-ucek period.

J. For t he purpose of t his permit, a calendar day shall be defined as any

, continuoun 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. ,

K.  ?!chton shall he defined as free swirrming aquatic animals whether of freshwater or uarine oripin.

$60 daya af ter commercial operation of thiclear Unit f.1. ,

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'H U dt No. SdiD30856

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l L. During periods of cold water teraperature ccaditions conduciv6..' to cold shock, .,

operation of the plant, in r.o far as practicabic, shall be such as to assurc '

that cold kill of fish will not occur.

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