ML061710504

Letter to H. Berkow, NRR, from J. Cook, Consumers Power Co. - Forwarding Midland Site Stabilization Report

ML061710504
Person / Time
Site:	Midland
Issue date:	10/02/1986
From:	Jackie Cook Consumers Power Co
To:	Berkow H Office of Nuclear Reactor Regulation
Gilles N, NRR/ADRA/DNRL/NGBD, 415-1180
References
RP0886-0047A-MP02 NUDOCS 8610200370, NUDOCS 8610200372
Download: ML061710504 (110)

Text

REGULATORY IFORMifTION DISTRIBUTION SY 'Ell (RrIDS)

ACCESSION NDR:0610200370 DOC.DATE: 86/10/02 NOTARIZED: NO DOCKET #

FACIL:50-329 Midland Plant, Unit 1, Consumers Power Co. 05000329 50-330 Midland Plant., Unit 2, Consumers Power Co. 05000330 AUTH. NMAE AUTHOR AFFILIATION COOK, J. W. Consumers. Power Co.

RECIP. NAME RECIPIENT AFF2ILIATION BERKOW, H. N. Standardization ,*: Special Project Directorate SUJ3JECT: Forwards "Midlaitd Site Stabilization Rept2 " providing response to request for info re environ review op util.

request to withdraw 860EI21 OL application. Agreement w/Dow Chemical Co reached re facility conversion.

DISTRIIBUTION CODE: A0OID COPIES RECEIVED:LTR ESIZE:

7ilLE: OR Submittal: General Distribution NOIES:App for permit renewal. Requested exp date 89120J. 05000329 App for permit renewal. Requested exp date 890701. 05000330 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME L.TTR ENCL ID CODE/NAME LTTR ENCL WR-B EB J 1 PWR-B PEICSB 2 2 PWR-D FOB 1 1 PWR-B SSPDLA 0 PWR-B SSPD" 01 5 5 MICHAELS, T 1 1 VWR-B PEICSB 1 1 PWR-B RSB 1 1 I Ni ER NAL: 09 6 6 ADII/LFMB 0 rELD/HD62 0 1 1

NRfl/OflAS I I 1 EX.TERNAL: E(-1kk BRUSKE.-5 I 1 LPDR 03 1 1 NRC: PYuP 02 3- 1 NSIC 05 1. 1 crjR~ £~c~/~

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-(0:Rec 31 TOTAL NiINBER OF CO]PIES REUIURED: LTTR ,ENCL.

WConsumers Power company James W Cook Vice President - Projects, Engineering and Construction General Offices: 1945 West Parnall Road, Jackson, MI 49201 * (517) 788-0453 October 2, 1986 Mr Herbert N Berkow, Director Standardization and Special Projects Directorate Division of PWR Licensing-B Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 MIDLAND ENERGY CENTER DOCKET NOS 50-329 AND 50-330 RESPONSE TO REQUEST FOR INFORMATION FOR ENVIRON'MENTAL REVIEW FILE: 1300, 0485.2, 0485.11 SERIAL: 32848

References:

1) H N Berkow letter to J W Cook, Request for Additional Information for Environmental Review of Applicant's Request to Withdraw the Midland Plant, Units 1 and 2, Operating License Application, dated August 21, 1986

2) NRC Staff Response to Consumers Motion for Authorization to Withdraw Operating License Application, dated August 25, 1986

3) J W Cook letter to H R Denton, Withdrawal of Licensing Applications, Serial 32744, dated July 1, 1986

4) CPCo Motion for Authorization to Withdraw Operating Licensing Application and for Dismissal of Operating License and Order of Modification Proceedings and Motion for Termination of Appeal Board Jurisdiction, dated July 11, 1986 0%

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5) CPCo Response to July 16, 1986 Board Order, dated August 15, 00 1986 O0

.G0 Reference 1 requested specific responses to six questions dealing with the

• C" current site status, environmental stabilization activities, and future site I'-o plans. Communications between our staffs has resulted in identifying specific items to be addressed. Reference 2 informed the ASLB that the 01<

questions will be answered in an Environmental Report (Site Stabilization 0 Plan) to form the basis of the Staff's environmental review and ultimately of

.-4.

its Environmental Assessment. The enclosure to this letter, the Midland Site 4'- ~L 0C0986-001OA-ILP02 Oe-sLpr

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,4oo,4c1 'I

2 Stabilization Report, provides a complete responses to the Staff's questions and requests for information.

References 3, 4 and 5 provided information relevant to the Staff's six questions. We have just recently reached an agreement in principle with Dow Chemical Company to convert the Midland Energy Center to a combined-cycle, gas-fired cogeneration facility. The responses in the Site Stabilization Report which address questions as to what happens if the conversion option does not come to pass should not be construed to mean that we expect any other outcome other than a successful completion as a combined-cycle, gas-fired cogeneration plant.

From 9 to 12 September, 1986, Central Michigan experienced heavy rains, resulting in widespread flooding. The Tittabawassee River crested on 13 September with the waters reaching approximately the 614 foot elevation at the Midland Site. Other than the Outage Building, the Site facilities experienced no significant damage. Some storm-related erosion corrective measures will be necessary.

Consumers requests that if your review of the report identifies any areas where clarification or additional information is necessary, the Staff should feel free to directly work with our staff to conclude the review. We ask that these matters be expedited to the extent possible to support our 1986 nuclear plant abandonment activities.

JWC/WRB/lr CC: HRDenton, NRC TSMichaels, NRC JGKeppler, NRC Reg III Service List OC0986-0010A-HP02

3 SERVICE LIST Frank J Kelley, Esq Steve Gadler, Esq Attorney General of the 2120 Carter Avenue State of Michigan St Paul, Minnesota 55108 Carole Steinberg, Esq Assistant Attorney General Atomic Safety & Licensing Environmental Protection Div Appeal Panel 720 Law Building US Nuclear Regulatory Commission Lansing, MI 48913 Washington, DC 20555 Myron M Cherry, Esq Chief, Docketing & Services Cherry & Flynn US Nuclear Regulatory Commission Suite 3700 Office of the Secretary Three First National Plaza Washington, DC 20555 Chicago, IL 60602 Ms Mary Sinclair Lynne Bernabei, Esq 5711 Summerset Street Thomas Devine, Esq Midland, MI 48640 Louis Clark, Esq Government Accountability Project Mr Joseph Rutberg of the Institute for Policy Studies Asst Chief Hearing Counsel 1901 Q Street, NW US Nuclear Regulatory Commission Washington, DC 20009 Office of the Executive Legal Director Hr D W Montgomery Washington, DC 20555 Babcock & Wilcox PO Box 1260 Atomic Safety & Licensing Lynchburg, VA 24505 Board Panel US Nuclear Regulatory Commission James E Brunner, Esq Washington, DC 20555 Consumers Power Company 212 W Michigan Avenue Ms Barbara Stamiris Jackson, MI 49201 5795 North River Road, Route 3 Freeland, MI 48623 Samuel A Haubold, Esq Kirkland & Ellis Alan S Rosenthal, Chairman 200 East Randolph Drive Atomic Safety & Licensing Chicago, IL 60601 Appeal Panel E/W 532 Thomas S Moore US Nuclear Regulatory Commission Atomic Safety & Licensing Washington, DC 20555 Appeal Panel E/W 532 Mr Gustave A Linenberger, Jr US Nuclear Regulatory Commission Atomic Safety & Licensing Washington, DC 20555 Board Panel US Nuclear Regulatory Commission Washington, DC 20555 Charles Bechhoefer, Esq Dr Jerry Harbour Atomic Safety & Licensing Atomic Safety & Licensing US Nuclear Regulatory Commission Board Panel Washington, DC 20555 US Nuclear Regulatory Commission Washington, DC 20555 0C0986-OOIOA-MP02

MTDLAND SITE STABTLTZATION REPORT DOCKET NOS 50-329 AND 50-330 October 2, 1986 8610200372 861002 PDR ADOCK 05000329 A PDR RP0886-0047A-MP02 WRB 9/19/86 REIGULATO YDOCKETf FllE. UPOY

TABLE OF CONTENTS

1. SCOPE 1

2. GENERAL SITE STABILIZATION

3. SITE STATUS A. Power Block Area 2 B. Access Road and Parking Areas 4 C. Poseyville Laydown Area 5 D. Cooling Pond Area 5 E. Transmission Corridor 7

4. CONCLUSION 9 TABLE Table 1 - Construction and Miscellaneous Facilities FIGURES Figure 1 - August 1983 Aerial View of MEC Site Figure 2 - April 1986 Aerial View of MEC Main Plant Area Figure 3 - FSAR Figure 1.2-1, Station Arrangement Figure 4 - Environmental Report Figure 2.1-1, Site Plan ATTACHMENTS - MDNR Letter Dated 8/28/84, Re Midland Cooling Pond Dewatering Program - MDNR Letter Dated 10/18/84, Re NPDES Permit No MI 0042668 Midland Nuclear Plant (Authorizes Dewatering of the Cooling Pond) - CPCo Letter PBL-0685-2 80EPIO.1, Dated 6/12/85, Re Special Conditions 30, 31 and 32 of NPDES Permit No MI 0042668 with Enclosed "Midland Cooling Pond Dewatering Program Summary Report" - CPCo Letter Hitt 114-84, Dated 12/17/84, transmitting "Midland Cooling Pond Maintenance Program" - MDNR Letter Dated 9/26/85, Re Approval of Midland Cooling Pond Maintenance Program and Midland Cooling Pond Dewatering Program Summary Report - Form 8-K; CPCo Report to the Securities and Exchange Commission, dated September 19, 1986 RP0886-0047A-MP02

MIDLAND SITE STABILIZATION REPORT I. SCOPE This report addresses the actions taken by CPCo relative to the Midland Energy Center (MEC) following suspension of construction in July 1984.

The activities associated with the plans to convert the NEC to a natural gas combined-cycle plant, the abandonment of nuclear facilities and the related Construction Permit/Operating License application termination are described. Specifically addressed is the "Request for Additional Informa-tion for Environmental Review of Applicant's Request to Withdraw the Midland Plants, Units 1 and 2, Operating License Application" in H N Berkow's letter to J W Cook dated August 21, 1986.

2. GENERAL SITE STABILIZATION On July 16,1984, the Board of Directors of CPCo ordered shutdown of design, construction and testing activities for the Midland Plant.

Initial activities were to secure the remedial soils work, place the plant systems and equipment in a long-term layup mode, implement a preventive maintenance and storage program and demobilize the construction forces.

The purpose of these activities was to maintain the plant in such a way as to preserve the option to restart the project.

Initial site stabilization actions included draining the cooling pond, filling open excavations, improving site drainage, grading and seeding and placing riprap in vulnerable areas. No additional actions are presently necessary for the environmental protection of the site in the shut down condition. Some activities of a maintenance nature continue and are described in following report sections. Future actions associated with other industrial site use would fall under the purview of the Michigan Department of Natural Resources (MDNR). Donald L Inman, Chief, Environ-mental Enforcement Division, MDNR is responsible for assuring compliance with state environmental laws. His office telephone number is (517) 373-3503 and his address is Michigan Department of Natural Resources, Box 30028, Lansing, Michigan 48909.

3. SITE STATUS On April 8, 1986, the Company's Board of Directors authorized conversion of Unit 1 of the Midland Project to a natural gas-fired, combined-cycle generating plant. On June 18, 1986 the Board authorized abandonment of the nuclear steam supply systems and other buildings and components of the Midland Project which are not usable for the gas-fired, combined-cycle plant. An environmental report was submitted on July 11, 1986 to the Department of Energy Economic Regulatory Administration in support of an exemption from the Fuel Use Act of 1978 requested for the plant conver-sion. Site construction (eg, demolition of unnecessary buildings, exten-sion of fill area for gas turbines) would begin no earlier than 1987. On September 17, 1986 the Dow Chemical Company and Consumers Power Company announced that they had reached an agreement in principle to work together RP0886-0047A-NP02

2 to convert the plant into a natural gas combined-cycle cogeneration plant (see Form 8-K, Attachment 6).

The gas conversion and nuclear abandonment is specifically addressed for the various site areas in later report sections. As this effort moves forward, or should some other plan be developed for future use of the site, it will be necessary to secure appropriate approvals and authoriza-tions or modifications to existing approvals from federal, state and local agencies prior to implementation. Precise identification of future site land uses, and resultant erosion and runoff control measures, and soil stabilization activities are not possible at this time.

Overall, the currently existing facilities will remain in place. Figure 1 is an aerial view of the site taken in August 1983. As can be seen, construction utilized nearly all of the available area. Figure 2 is an April 1986 aerial view looking northeast toward the Power Block Area with the Dow industrial facilities in the background.

Salvage activities will continue through the end of 1986 and beyond. Many of the non-permanent buildings will continue to be used as warehousing for salvageable equipment. These facilities are also usable in support of future construction. Facilities not normally occupied are locked if there are hazards associated with unauthorized entry. A security force has remained in place to control site entry and to maintain routine site security inspections.

A. Power Block Area Description The power block area described in the Environmental Report as 10 acres, included the land north of the cooling pond at a nominal 634 foot elevation (ER-OLS Section 2.1.3.1). This area contains the reactor buildings, turbine building, diesel generator building, auxiliary building and miscellaneous permanent and temporary ancil-lary, support and warehousing structures. For the purpose of this report, however the term "Power Block Area" refers to all of the area "on the hill," and the property north of this area to the river, comprising a total of about 52 acres. Construction has utilized nearly all of this property.

FSAR Figure 1.2-1; Station Arrangement (provided as Figure 3) shows the constructed facilities in the power block area. This area is zoned industrial and is adjacent to Dow Chemical's facilities, includ-ing a brine pond.

Status Structures currently remaining which are in addition to those shown in Figure 1.2-1 are listed in Table 1. For construction of the Gas Conversion Option, the Project Field Office, Change House, Welders Test Shop, Site Access Control Building, and Support Services Building RP 0886-0047A-MP02

3 would all be removed and the gas turbines would be placed in the area these structures occupy. Consumers Power does not plan to dismantle any of other structures. To do so would be costly and not to the advantage of the Company or its customers. The structures do not represent a hazard or other adverse condition.

The following structures will be abandoned regardless of the final site disposition:

Unit 1 and 2 reactor buildings Auxiliary Building North of Column Row "G" Radwaste Building Calibration Building Cooling Tower The remaining structures shown on Figure 1.2-1 will be utilized in the gas-fired, combined-cycle power plant.

At the time of Project shutdown, the underpinning work in progress was reviewed and a plan was developed to stabilize the structures. This plan was implemented. The activities required for stabilization were concurred with by Region III and verified by site inspections as documented in Inspection Reports (50-329/84-22 & 84-26 and 50-330/

84-23 & 84-27). Monitoring of the area since that time has confirmed the adequacy of the building underpinning in its present configura-tion. The plans for plant conversion will require that the soils remedial program be completed in a manner which assures suitability of the structures for their use in the converted plant. Presently physical barriers are in place to prevent unauthorized access. In the unlikely event that the facility is not completed as a gas-fired, combined-cycle power plant, then suitable physical barriers and administrative controls will remain in place to prevent unauthorized entry into the underpinning areas.

Following the termination of construction, trailers and some other temporary construction support buildings were removed. Environmental protection measures included grading and assurance of proper drainage.

Salvage of equipment and construction facilities remains as an ongoing effort. The wells and freezewall vertical elements remain in place although the surface piping has been removed. Some construction utilities (power, natural gas, compressed air) and equipment (shoring, cribbing), parking piers, support slabs and foundation of removed structures remain in place. Debris has been and will continue to be disposed of in a licensed landfill. Hazardous wastes were disposed of by utilizing licensed contractors.

The temporary Heater Boiler Structure is in use to provide winter heating for the plant buildings. The remaining structures listed in Table 1 currently serve as warehousing for materials being salvaged.

They represent a future resource as construction support facilities for the gas conversion option or other site power plant or industrial RP0886-0047A-M1P02

4 use. When and if they are removed, debris will be disposed of in a licensed landfill.

Summary Site stabilization work in the power block area is complete. The area is served by a storm drainage system, to which a program of routine maintenance applies. Riprap is in place in areas subject to erosion.

Seeding or indigenous vegetation covers the embankments. Grading and other specific measures are being employed, as necessary, to address specific conditions resulting from the ongoing salvage operations.

Facilities currently in place will remain except as specifically mentioned above.

B. Access Road and Parking Areas Description Included in this 95-acre area is all the site property north of the cooling pond dike and west of the Power Block Area. Except for extreme westerly end, all the area between the pond dike and Bullock Creek has been utilized for parking and roads. Within this area are the Outage Building, Zack Storage Building, Warehouse No 2, the Support Services Building, Meteorological Tower and miscellaneous construction support temporary structures. The construction and miscellaneous structures are listed in Table 1. A drainage system is in place for this area.

Status The parking areas consist of a hard packed surface. Concrete parking piers and fencing remain in place. Some indigenous vegetation is taking hold in areas where there is no current traffic. These parking areas will be useful for future plant construction and operation.

The 100-meter meteorological (Met) tower is located on the edge of the site boundary directly west of the power block area. Met tower routine maintenance includes assurance of structural integrity and obstruction marking. The Met tower is not required for gas-fired, combined-cycle conversion since preconstruction air quality monitoring is not required. If a coal conversion project is undertaken, pre-construction air quality monitoring is a requirement. The Met tower represents a future resource for low band frequency (two-way radio) support of Company operations in the Central Region. Regardless of final plant disposition, there are no plans to remove the Met tower.

The buildings remaining in the parking areas are to be kept for support of the gas-fired, combined-cycle plant construction and for ongoing salvage efforts. The exception is the Support Services Building as mentioned in A, above. At such time it is determined that it is in the Company's best interest to remove the temporary build-ings, the debris will be disposed of in a licensed area landfill.

RP0886-0047A-MP02

5 The site access road is contained in a narrow corridor of land bounded by Dow Chemical property to the north and private lands to the south.

A stockpile of fill material remains on the south side of the road.

These materials will be used for the gas-fired, combined-cycle plant.

There is also an adjacent stockpile, not owned by Consumers, on private property. This stockpile area is surrounded and contained by heavy indigenous vegetation.

An intermittently flowing old Dow brine well is located on the south edge of the parking lot area. Some erosion was recently found where the water flows to a drainage ditch. This has been corrected.

Summary The access road and parking lot areas are environmentally stable and no further actions are required. The structures within these areas will be kept for ongoing and future site purposes.

C. Poseyville Laydown Area Description This approximately 68-acre area is located off but adjacent to the site. Tt extends from the west side of the cooling pond to Poseyville Road. An underground drainage system was installed during its con-struction. The surface consists of a 4 to 12-inch thick limestone layer.

Status The laydown area contains cribbing and temporary storage structures for construction materials and plant equipment. Significant consoli-dation and/or material removal has taken place because of the ongoing salvage efforts. The area will continue to be used for storage and represents a resource for the future gas-fired, combined-cycle plant construction. When, and as the temporary facilities are removed, resulting debris will be disposed of in a licensed land fill area.

The Midland Training Center is located within the laydown area. The Center and the approximately 6-acre parcel on which it is situated do not belong to the Company. A major tenant in the building is Great Lakes Junior College. The Company currently occupies part of the building.

The laydown area is environmentally stable.

Summary No remaining stabilization activities are necessary in the laydown area. It is our current intent that the area be preserved as a future resource, irrespective of the disposition of the Midland Site proper.

RP0886-0047A-MPO2

6 D. Cooling Pond Area Description The Cooling Pond Area (see ER Figure 2.1-1, provided as Figure 4) consists of the 880-acre cooling pond, the strips of land outside of the west and south pond dikes (about 90 acres), and the 148-acre Tittabawassee River floodplain east and northeast of the cooling pond.

The narrow strips of land bordering the dike perimeter contain pond and dike ditches and the rerouted agricultural drains which formerly flowed through the cooling pond area. The floodplain area contains several transmission line towers and start-up line poles (see Section 4.E), the cooling pond dikes, the railroad bridge, the pond outlet structure (formerly, the superseded outlet structure, now NPDES Permit Outfall 003), and the emergency access road.

The railroad bridge crossing the Tittabawassee River, the widening of the River, and the construction of the cooling pond and associated structures were accomplished under Michigan Water Resources Commission and US Corps of Engineers permits issued in 1969. The River was widened to compensate for loss of floodplain resulting from Plant construction and the railroad bridge was constructed so as not to interfere with floodwater flow. (Environmental Report-OLS, Sections 2.1.1.2, 2.1.3.3.2, 2.2.1, 12.1, Q&R FPM 1)

Status Following the July 1984 determination to halt construction of the Midland Nuclear Plant, Consumers Power Company obtained Michigan Department of Natural Resources (MDNR) approval of a Cooling Pond Dewatering Program. Dewatering of the cooling pond was necessary to allow for the demobilization of the temporary dewatering wells and the freezewall system associated with the auxiliary building underpinning activities during the caretaker/layup status of the project. The main objective of the program was to control the potential environmental impacts associated with the dewatering and the ongoing maintenance of the cooling pond and related site water runoff.

The major program elements included initial dewatering of the pond at discharge rates which were environmentally acceptable and that would not exceed State water quality standards for the Tittabawassee River, to the extent practicable relocating cooling pond fish to the river, and providing for the collection and appropriate disposal of organic materials from the pond.

Staff of the MDNR Environmental Enforcement, Surface Water Quality, Fisheries, Groundwater Quality, Wildlife and Air Quality Divisions, and a representative of the Michigan Department of Public Health were designated to review various aspects of the Company's dewatering proposal for approval. (Attachment 1)

RP08 86-0047A-MPO2

7 The Company received, from the Michigan Water Resources Commission (MWRC), NPDES Permit modifications to completely dewater the cooling pond and to discharge stormwater runoff and site dewatering from the dewatered pond. Notice of the revised Permit was published in Septem-ber 1984. The revised Permit was discussed before the Michigan Environmental Review Board in October and was issued by the MWRC on October 18, 1984. (Attachment 2)

The revised NPDES Permit authorizes pond dewatering and contains a number of special conditions designed to address environmental mat-ters. The Cooling Pond Dewatering Program Summary Report (Attachment

3) describes the pond water discharge, water quality, fish relocation, residuals management and avifauna observations from the 1984 dewatering program. These activities were conducted in accordance with the requirements of NPDES Special Conditions 30, 31, 32 and 33.

Special Condition 29 of the Permit required the submittal and approval of a Cooling Pond Maintenance Program to control stormwater runoff and site dewatering discharges. The Company continues to implement this MDNR approved program. While the site remains in caretaker/layup status, the Cooling Pond Maintenance Program controls site stormwater drainage, site dewatering and pond area runoff. Attachment 4 includes a copy of the program including a sketch of the site showing the location of the water discharge. Following the initial dewatering, several small dams and a settling basin were built internally in the cooling pond and the banks of an internal drain were seeded with grass. The MDNR District Supervisor approved the Cooling Pond Mainte-nance Program and the Cooling Pond Dewatering Program Summary Report (Attachment 5). After a site visit in early September 1985, he found "the Maintenance Program to be satisfactorily implemented. In fact, the runoff control measures were very successful in controlling erosion and sediment discharges after approximately eight inches of rain in three days just prior to the visit" (Ibid). No additional federal, state or local approvals are necessary at this time for site layup.

The 880-acre cooling pond comprises over 70% of the 1235-acre plant site. Additionally, stormwater drainage from the power block area drains into the cooling pond. The Cooling Pond Maintenance Program continues to control erosion and sediment discharge from the cooling pond as storm water is discharged in accordance with the NPDES Permit.

All measures of that program have been implemented. As of early fall 1986, the pond appears to have about an 85% vegetative cover.

There are no plans to remove or add any structures in the Cooling Pond Area. They will all be used in the gas-fired, combined-cycle power plant. There is an ongoing program to control vegetation along the security fence and to monitor dike integrity. Regrading was done on the north dike area just west of the access road where a large clay stock pile was removed. Some further work in this area will be required as a result of storm damage the week of September 7, 1986.

RP0886-0047A-MPO2

8 Summary Site stabilization work has been implemented under the Cooling Pond Maintenance Program. Stormwater releases from the dewatered cooling pond are regulated under the NPDES Permit. The pond dike embankments have a good vegetation cover. Perimeter ditch slopes are vegetated and kept maintained. Facilities currently in place will remain.

E. Transmission Corridor Description 138 kV Start-Up Lines Two lines are involved (Environmental Report-OLS, Section 3.9.4.2 and Figure 3.9-2))

One line terminates at one of the start-up transformers and extends approximately 950 feet to tap an existing circuit at a tower on the Plant site.

The other line terminates at the other start-up transformer and extends to a single circuit type TH tower utilizing intermediate wood poles. The remainder of this line adjacent to the dike to Gordonville Road utilizes single wood poles, davit arm structures. From there along Gordonville Road to the Tittabawassee substation the line is supported on steel towers. The area disturbed by construction (com-pleted in 1980) for the 138 kV lines is minimal.

345 kV Lines Two 345 kV bus tie lines originate at the turbine building wall of the plant and extend across the north pond area with structures located adjacent to the dikes. The lines parallel an existing 138 kV tower line and go to the Tittabawassee Substation. The area disturbed by construction (completed in 1982) for these towers is approximately 0.05 acres. (Environmental Report-OLS, Section 3.9.4.3 and Figure 3.9-2)

The Tittabawassee to Kenowa/Thetford line is located in an existing corridor that was purchased prior to 1982. Double circuit towers were utilized. The corridor, excluding the wider, 1 mile long exit at Tittabawassee will accommodate two 345 kV tower lines. The first 8.0 miles south from the Tittabawassee exit also accommodates two 138 kV tower lines and the next 7.6 miles accommodates one 138 kV tower line.

A 138 kV line was built in the north 8.0 miles of the corridor in 1972. The 345 kV line (construction completed in 1983) Is located 100 feet east of the existing 138 kV line.

The length of the line is 27.3 miles. The average area disturbed for installation of each set of tower anchors is a 40-foot square. A total of 153 towers required for the entire line caused the RP0886-0047A-MPO2

9 disturbance of 5.6 acres of land, exclusive of any compaction by construction vehicles along the tower centerline. (Environmental Report-OLS, Section 3.9.4.4 and Figures 3.9-2, 3.9-3A through 3.9-3H, and 3.9-9.)

Status There is no current evidence of erosion or other adverse conditions in the transmission corridors. The 27.3 mile 345 kV double circuit line is now being utilized and CPCo has filed with the MPSC, separately from Midland, to include these in the rate base. They are an integral permanent part of our overall transmission system.

Right-of-Way Maintenance (Environmental Report-OLS, Section 5.5.3) is an ongoing activity. Consumers Power Company's methods of maintenance comply with existing Federal and State guidelines pertaining to approved maintenance practices of transmission line rights-of-way.

Tree and shrub screens established during construction clearing are preserved and maintained by selective manual trimming or removal.

Only selected tree species are removed either manually or with herbicide.

All herbicide application is performed only as directed by Federal and State laws by commercial applicators licensed by the State of Michi-gan. Only those herbicides approved by the Environmental Protection Agency for utility right-of-way application are used and they are applied in strict compliance with manufacturer recommendations. Field operations are supervised by trained foresters certified by the State of Michigan to assure compliance with the Consumers Power Company Tree Clearing Specifications and Job Methods Manual.

Summary Regardless of the final disposition of the Midland Plant, Consumers Power Company intends to keep the transmission line facilities from the plant to the Tittabawassee substation in the present configura-tion. They are necessary for the proposed gas conversion or other power plant project and enhance the value of the property's use as an industrial site. As noted above, the 345 kV lines to Kenowa/Thetford lines are currently in use. Their future use is in no way dependent on final disposition of the Midland site.

4. CONCLUSION The Midland Energy Center Site has been environmentally stabilized.

Ongoing stabilization activities will be of a maintenance nature appropri-ate to any industrial facility and will be covered by State permits as necessary. Future activities on the site will be conducted in accordance with applicable regulation of the governmental agencies having jurisdic-tion over such activities.

RP0886-0047A-MP02

TABLE 1 CONSTRUCTION AND MISCELLANEOUS FACILITIES POWER BLOCK AREA Paint Storage Facilities Tent Storage Area Insulation Storage Buildings Temporary Heater Boiler Structure B&W Building RC Pump Storage Building Engraving Shed Access Stairs Underpining Access Shed (NE Corner Turbine Building)

ACCESS ROAD AND PARKING AREA Storage Shed Mergentime Maintenance Shop Huber's Maintenance Trailer B&W Fabrication Shop HVAC Fabrication Shop and Storage Building Warehouse 2 Foundations for 2 Additional Support Service Buildings South of Current

.Support Service Building LAYDOWN AREA Environmental Trailer Access Trailer Miscellaneous Storage Facilities RP0886-0047A-MP02

1983 AERIAL PHOTO 4

MIDLAND SITE AREA

(

g~ao~osig-77 Figure 1

I Figure 2

STATE OF MICHIGAN Attachment 1 "URAL RESOURCES COMSts.ON rHOMAS J ANOERSON E R CAROLLO JAMES J. BLANCHARD, Governor JACO A HOEFER STHILENFSELS HILARY F SNELL DEPARTMENT OF NATURAL RESOURCES PAUL H WENOLER STEVENS T. MASON BUILDING HARRY H WHITELEY BOX 30028 LANSING. MI 48909 RONALD 0. SKOOG. Doeaor August 28, 1984 Mr. Paul C. Hittle Director of Environmental Activities Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 Re: Midland Cooling Pond Dewatering Program

Dear Mr. Hittle:

This is to provide the Department's response to two issues which were raised at our August 20, 1984 meeting and to identify staff contacts who are reviewing your proposal.

Prior to discharging, the NPDES permit needs to be modified to authorize the complete dewatering of the cooling pond. The company must up-date its permit application by formally requesting authorization to dewater the pond, Including a request to discharge via the pond outlet structure.

That request should be submitted in writing to Paul Zugger, Executive Secretary of the Water Resources Commission. The proposed modification will be processed and placed on public notice in accordance with Commission rules. We currently intend to schedule this for Commission action at the October 18, 1984 meeting. The current permit authorizes an intermittent discharge of cooling pond blowdown, hydrostatic test water, auxiliary boiler blowdown, system flush waters, site dewatering and stormwater runoff, and the dewatering discharge may be commenced pursuant to the terms of the permit. However, the intermittent discharge must cease on October 18, 1984, unless the Water Resources Commission grants authorization for the continued dewatering of the cooling pond.

The Groundwater Quality Division has determined that the organic material removed from the lagoon (dead fish and vegetation) is subject to the disposal regulations of the Solid Waste Management Act, 1978 PA 641, as amended. This means that the material must be disposed of at a licensed Type II landfill. Consumers' proposal to dispose of the material on-site is unacceptable, unless the Company obtains the necessary license.

Departnent staff who are reviewing and/or coordinating the review of the various aspects of the dewatering proposal are listed below.

Overall Coordination: Don Irman and Valerie Harris Environmental Enforcement 517-373-3503 Flow Rate: Steve Casey Surface Water Quality 517-373-8088 Water Quality: Steve Casey Fish Discharge: Tom Doyle Fisheries Division 517-373-1280 Collection and Disposal of Organic Material: Dave Dennis Groundwater Quality 517-373-2794 Avifauna Monitoring: Stephen Schmitt Wildlife Division 517-373-9358 Permanent Discharge: Chang Bek Surface Water 517-373-8088 Potential Odor: Mark Reed Air Quality Division 517-771-1731 Public Health: Roy Kiaviter Division of Envirormental Program Health Relations, MDPH 517-373-8050 I would suggest that Department staff maintain direct contact with their counterparts at Consumers for an expeditious resolution of technical questions.

After we receive and review your "Appendix A", outlining the disposal of the organic material, a second meeting may be beneficial. In the mean-time, please feel free to contact Don Inman or Valerie Harris if you have any questions.

ýy.

I nl I

ck D. Bail*

• ef vironmental tE Enforcement Division

-373-3503 Surface

&-aul Zugg7-Quality Division D. Wate 517-373-1949 JDB:VSH:cf cc: Inman, Harris Casey, Doyle, Dennis Scthmitt, Bek, Reed

STATE OF MICHIGAN AAttachment 2 TE.MAS AONDRSON 4 JAMES J. BLANCHARD. Governor E.R.CAROLLUO SARPENE J.FLUH.AR sTEPHEN F. MONSMA DEPARTMENT OF NATURAL RESOURCES

0. STEWART MYERS STEVENS T. MASON BUILDING RAYMOND POUPORE BOX 30028 HARRY H. WHITELEY LANSING, MI 48909 RONALD 0. SKOOG. Director October 18, 1984 CERTIFIED MAIL Mr. Paul Hittle Consumers Power Company 2.12 West Michigan Avenue Jackson, Michigan 49201 Re: NFDES Permit No. MI 0042668 Midland Nuclear Power Plant

Dear Mr. Hittle:

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

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

REVIEW THE PERMIT EFFLUENT LIMITS AND PERFORMANCE SCHEDULES CAREFULLY.

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

Your -monitoring and reporting responsibilities shall be complied with in accordance with Part I, Section B of this permit. If applicable, monthly operating report forms will be transmitted to you in the near future. These reports are to be submitted monthly or otherwise as required by your NPDES permit.

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

Terry Walkington, District Supervisor Saginaw State Office Building 411-J East Genesee Saginaw, Michigan 48607 Telephone: (517) 771-1731

Mr. Paul Hittle October 18, 1984 Page 2 NOTE: All references within this permit made to the Water Quality Division or-Chief of the Water Quality Division are to refer to the Surface Water Quality Division or Chief of the Surface Water Quality Division, respectively.

Sincerely, William E. McCracken, P.E.

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

Enclosure:

Permit cc: EPA-Region V (2), Data Center, Files, Water Quality Surveillance, Point Source Studies Compliance Section #2, Terry Walkington, Saginaw District, Land Application Unit, 208 Agency - East Central Michigan Planning and Development Region

Permit No. MI 0042668 MICHIGAN WATER RESOURCES COMMISSION AUTHORIZATION TO DISCHARGE UNDER THE NATIONAL POLLUTANT DISCHARGE ELLXINATION SYSTEM In compliance with the provisions of the Federal Water Pollution Control Act, as amended (33 U.S.C. 1251 er. sec.; the "Act"), and the Michigan Water Resources Co.mission Act, as amended (Act 2-5, Public Acts of 1929, as amended, the "Michigan Act"),

Consumers Power Company 212 West Michigan Avenue Jackson, Michigan 49201 is authorized to discharge from a facility located a:

Midland Nuclear Power Plant Site 3500 East Miller Road Midland, Michigan 48640 receiving water named the Tittabawassee River and Bullock Creek.

In accordance with effluent limitations, monitoring requirements and other condi-tions set forth in Parrs I and I1 hereof.

This permit shall become effective on the date of issuance and shall be final in the absence of a request for a hearing filed within 15 days after receipt thereof.

This permit and the authorization to discharge shall expire at midnight, June 30, 1987. In order to receive authorization to discharge beyond the date of expiration, the permittee shall submit such information and forms as are required by the Michigan Water Resources Commission no later than 180 days prior to the date of expiration.

This permit is based on the Company's application dated February 28, 1978, as amended, and shall supersede any and all Orders of Determination, Stipulation, or Final Orders of Determination previously adopted by the Michigan Water Resources Commission.

Issued on November 2. 1982, and modified on this 18th day of October. 1986 for the Michigan Water Resources Commission, superseding State Permit No. M 00057, issued June 6, 1974 and Order of Determination No. 1426, issued October 15, 1970.

. Executive *.cary

Pr.=it No. MI 0042668 Page 2 Of 33 PART I EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

1. Interim Effluent Limitations - Complete Dewatering of the Cooling Pond During the period beginning when special conditions 30, 31, 32 and 33 are approved by the Chief of the Surface Water Quality Division and ending when the Cooling Pond has been completely dewatered, ****the permittee is allowed to completely dewater the cooling pond of hydrostatic test water, auxiliary boiler blowdown, system flushwater, stormwater runoff, site dewatering and stored river water from outfall 003 into the Tittabawassee River.4 Such discharges shall be limited and monitored by the permictee as specified below:

Discharge Limitations kg/day (lbs/day) Other Limitations Monitoring Requirements Effluent Monthly Daily Monthly Daily Measurement Sample Characteristic Average Maximum Average Maximum Frequency Type Flow, 3/Day (MGD)* Daily Continuous Total Suspended Solids 30 mg/l 100 mg/l Daily' 24-Hr. Composite 1 Net**Amonia (as N)

October-May 260(573) 350(772) 6 mg/l Daily 24-Hr. Composite 1 June-September (No net discharge as 6 mg/l Daily1 24-Hr. Composite 1 a 30-day average)

Net**BOD5 1 1000(2205) Daily1 Dailyl 24-Hr. Compositel1 September-May 2e-August 780(1720)*** 24-Hr. Composite

,tem Flush Water See "e" below Temperature Daily 1 Grab Hydrogen Sulfide Daily2 Grab Undissociated Hydrogen Sulfide 25 ug/l Daily2 Calculation Outfall Observationg Daily Visual

.*The permittee shall observe the Tittabawassee River at outfall 003 daily. If the discharge is causing visible stream bank or stream bed erosion, the discharge must be immediately reduced until the visible bank or stream bed erosion has ceased. If flooding conditions (banks full or over-flowing) occur in the Tittabawassee River downstream of the discharge, the discharge must be stopped immediately.

• • The term net shall be defined as the difference between the intake and discharge quantities.

• • • There shall be no discharge of cooling pond blowdown when the river flow at the Midland USGS gage station is less than 300 cfs.

• • • • The cooling pond shall be considered completely dewatered when the elevation of water first decreases to a level of 600 feet Mean Sea Level (MSL) in the emergency cooling water resevoir and to a level of 601 MSL at outfall 003.

This monitoring requirement shall be relaxed to twice weekly grab samples until the level of water in the cooling pond falls below 610 MSL at outfall 003.

Permit No. MI 0042668 Page 3 of 33 Part I-A-i (continued)

This monitoring requirement shall be relaxed to twice Rrab samples until the level of water in the cooling pond falls below 610 USL at outfall 003.

3 Any unusual characteristics of the discharge which would not be expected from hydrostatic test water, auxiliary boiler blowdown, system flushwater, stormwater runoff, site dewacering and stored river water (i.e., turbidity, discoloration, oil film, suspended solids, etc.) shall be reported immediately to the District Office of the Surface Wbter Quality Division followed by a written report within 5 days detailing the findings of the investigation and the steps taken to correct the condition.

4 Discharges from outfall 001 and outfall 003 during the same month are expressly prohibited unless the combined discharge from out-fall 001 and outfall 003 is in compliance with the effluent limitations for outfall 003.

a. The discharge shall not cause excessive foam in the receiving waters. The discharge shall be essentially free of floating and settleable solids.

b. The discharge shall not contain oil or other substances in amounts sufficient to-create a visible film or sheen on the receiving waters.

c. Samples taken in compliance with the monitoring requirements above shall be

-ken prior to discharge to the Tittabawassee River.

d. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: Dailyl; grab sample.

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

Pem-it No. MI 0042668 Page 4 of 33 Final Effluent Limitations -Discharge of Stormwater Runoff and Site Dewatering While the Plant is in Layup/Caretaker Status During the period beginning when the Cooling Pond is completely dewatered**** and ending when the Cooling Pond is refilled, the permittee is allowed to discharge storm-water runoff and site dewatering from outfall 003 to the Tittabawassee River. Such discharge shall be limited and monitored by the permittee as specified below:

Discharge Limitations kg/day (lbs/day) Other Limitations Monitoring Requirements Effluent Monthly Daily Monthly Daily Measurement Sample Characteristic Average .Maximum Average Maximum Frequency Tyne Outfall Observation* Daily Visual Suspended Solids*** 30 mg/l 100 mg/l Daily** 24-Hr. Composite

• Any unusual characteristics of the discharge which would not be expected from stormwacer runoff and site dewatering (i.e., turbidity, discoloration, oil film, suspended solids, etc.) shall be reported immediately to the District Office of the Surface Water Quality Division followed by a written report within 5 days detailing the findings of the investigation and the steps taken to correct the condition.

"hen discharging.

,his discharge limitation and monitoring requirement shall apply until the cooling

.pond maintenance program (special condition Z9) has been fully implemented and approved by the Chief of the Surface Water Quality Division.

• • • • The cooling pond shall be considered completely dewatered when the elevation of water first decreases to a level of 600 feec Mean Sea Level (MSL) in the emergency cooling water resevoir and to a level of 601 feet MSL at outfall 003.

a. The discharge shall not cause excessive foam in the receiving waters. The discharge shall be essentially free of floating and settleable solids.

b. The discharge shall not contain oil or other substknces in amounts sufficient to create a visible film or sheen on the reck+/-ving waters.

c. Samples taken in compliance with the monitoring requirements above shall be taken prior to discharge to the Tittabawassee River.

d. In the event the permittee shall require the discharge of water treatment additives, the permittee shall notify the Chief of the Surface Water Quality Division. The permittee shall obtain written approval from the Chief of the Surface Water Quality Division to discharge such additives at a specified level. The permit may be modified in accordance.

with the requirements of Part II, Section B-4 if a constituent of the additive or additives ranuires limiting.

iermie No. MI 0042668 Page 5 of 33

3. Interim Effluent Limitations - Discharges During Construction and Preoperational Testing During the period beginning with the date of issuance of this permit and ending when both Unit I and Unit 2 comence coercial operation, the permit:ee is allowed the intermittent discharge of cooling pond blowdowu, hydrostatic test water, auxiliary boiler blowdown, system flush waters, site dewatering and stor=water runoff from.outfall 001 into the Tictabawassee River. Such discharges shall be limited and monitored by the permittee as specified below:

Discharge Limitations kg/day (lbs/dav) Other Limitations Monitoring Recuirements

ffluent Monthly Daily Monthly Daily Measurement Sam-ole

haracteris tic Average Maximm Average Maximum Frecuencv Tv-e

?low, M3?/day (MGD) Daily*

otal Suspended Solic[s 30 mg1l 100 mg/l Daily/Weekly** Grab ret*'* Ammonia (as N)

October-Hay 260(573) 350(772) 6 Mg/1 Daily/Weekly** Calculi~

tion June-September (No net discharge as 6 mg/l Daily/Weekly** Calculz a 30-day average) tiLon S BOD5-

--_p t embe-May 1000(2205) Daily/Weikly-* Cal culi tior.

June-Augus t 780( 172O)**** Daily/Weekly*- Calculi tion 7ystem Flush Water See "e" Below

• Per discharge occurrence.

• • Once daily when discharging less than seven consecutive days; once weekly when discharging more than seven consecutive days.

The term net shall be defined as the difference between the intake and discharge quantities.

• There shall be no discharge of cooling pond blowdown when the river flow at the Midland USGS gage. station is less than 300 cfs.

Permit No. MýI 0042668 ?age 6 of 33 Interim Effluent Limitations (continued)

a. The discharge shall not cause excessive foam in the receiving waters.

The discharge shall be essentially free of floating and settleable solids.

b. The discharge shall not contain oil or-other substances in amounts suf:Lcienc to create a visible film or sheen on the receiving waters.

c. Samples taken in compliance with the monitoring requirements above shall be taken prior to discharge to the Tittabavassee River.

d. The pE shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: Daily/Weekly*", per discharge occurrence; grab sample.

a. In the event the permittee shall.require the use of water treatment addizives in addition to or in greater quantities than those identified in the permictee's NPDES application (Revision 3) dated November 11, 1981 and approved by the Chief of the Water Quality Division on March 11, 1982, the permitree shall notify the Division Chief. Written approval from the Chief of the Water Quality Division to use such additives at specified levels shall be obtained prior to usage by the permitree. The permit will be modified in accordance with the requirements of Par 11I, Section A-i if a constituent of the additive or additives requires limiting.

Interim Limitations - Makeup Demineralizer Regeneration Waste During the period beginning with the date of issuance of this permit and ending when the cooling pond blowdoWn system to the river is placed in-operation, but in no case, later than when both Unit 1 and Unit 2 co~m-nce commercial operation, the makeup demineralizer yegeneration wastewater shall be discharged to the Dow Chemical Company treatment system.

5. Interim Limitations - Temporary Laboratory Trailer Wastewater During the period beginning with the date of issuance of this permit and ending when the cooling pond blowdown system to the river is placed in operation, but in no case later than when both Unit 1 and Unit 2 comence commercial operation, all temporary laboratory trailer wastewater shall be collected and discharged to the Dow Chemical Company treatment system.

Permit* No. MI 0042668 Page 7 of 33 Final Effluent Limitations - Outfall 001, Combined Plant Discharge During the period beginning with the commencement of discharge and lasting until. the expiration date of this permit, the permittee is authorized to discharge up to a maximum of one hundred and forty-three million (143,000,000) gallons per day of wastewaters fro cooling pond, oily waste treatment system, evaporator building neutralizing sump, Unit I and Unit 2 neutralizing sump, laundry waste treacent system, liquid radwaste system and forty three million four hundred thousand (43,400,000) gallons per day of radwaste dilution water from outfall 001 into the Tittabawassee River. Such discharge shall be limited and monitored by the permictee as specified below:

Discharge Limitations kg/day (lbs/day) Other Limitations Monitorine Recuirements f fluent Monthly Daily Monthly Daily Measurement Sample haracteristics Average Maximum Average Maximum Freouencv Tvye

'yow, M3/day (MOD) Daily atural* River Temperature (Background), oF Daily Continuous Repor: daily average and daily maximu The temperature of the discharge shall not increase the temperature of the river

-t the edge of the mixing zone on an average temperature basis greater than 5 0

)ve the natural* river temperature provided that at no time shall the temperature tthe edge of the mixing zone be greater than the following monthly maximum:

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC

41. 40 50 63 76 84 85 85 79 68 55 43

• For purposes of this permit, natural river te=perature is defined as a point on the Tittabawassee River upstream of the Midland Plant Discharge but downstream of the confluence of the Chippewa and Tittabawassee River. The actual location is to be determined following a river temperature study conducted by the permict:e.

Mixing Zone. The thermal mixing zone, for the purposes of evaluating compliance with water quality standards, is defined as the area enclosed within the right k of the Tittabawassee River starting from the point of discharge and extending 1,700 feet downstream from the discharge structure.

The above defined mixing zone may be modified upon demonstration by the permittee that said mixing zone is more stringent than necessary to protect the uses of the river downstream of the mixing zone as determined by a shoving that the thermal component of the discharge does not adversely affect'the minimum dissolved oxygen levels in the river or restrict the passage of fish and fish food organisms in such manner that their immediate and future populations are signifi-cantly affected. Such modification shall be made in accordance with Part II, Section B-4 herein.

?ertmi* NIC. MI 0042668 ?age,8 of 33 i.- Final Effluent Limitations (continued)

Discharge Limitations kq/dav (lbs/day Ocher Limitations Moni:oring Recuiremenes Effluent Monthly Daily Daily Teasurement Sample Tharacteristic Average Maximum Maximum Frequency Tyze Cotal Dissolved Solids (TDS): Report daily average and daily maximum (calculated from continuous conductivity reading).

Intake River Concentration (TDS) Daily Con:inuous River Concentration at Freeland Bridge (TDS) Daily Continuous Che total dissolved solids concentration of the discharge ihall not increase the river

oncenuration a= Freeland Bridge above 300 mg/1 on a monthly average or more than 730 =g/l it any time.

iet**Ammonia (as N)

October - May 260(573) 350(772) 6 mg/l Daily. Calculacion June - September No Net Discharge as a 30 day ave*** 6 mg/l Daily Calculation get**BOD...

S~epce~ber - May 1000(2205) -- Daily Calculation e Au%,ust**** 780(1720) -- Daily Calculation

)utf all Observation***** All Year - Daily Visual

[he permictee may demonstrate to the Commission chat higher BOD.. and/or ammonia l.=i:s ire acceptable.

The authorization for discharge of wastewacer and limitations on the discharge set forzh in

his permit are based upon minimum seasonal design flows in the Tictabawassee River. To issure that the Commission's Water Quality Standards are mec, the pe--mirtee shall not iischarge wasrewater from the cooling pond or Unit I and 2 neutralizing sumps******

hen for 15 Minute or more river flows downstream of Lingle Drain are less than those

pecified below

When River Flow*(cfs) below Lingle Drain is Less Than: During Neuw:ralizing Neurraiizing Cooling Pond Sumos 332 June 1 -August 31 341 332 September 1 - September 30 355 '272 October 1 - April 30 603 500 May I - May 31 kRiver flow monitoring to determine compliance with this requirement shall be performed Dursuant to Special Condition 21, page 22 of 33 of chis permit.

Per-mt jo. .1 0042668 Page 9 of 33

6. Final Effluent Limitations (continued) 4Net discharge is defined as the difference between the intake and discharge pciutant 5s.

• • • Fin.al a ionia discharge limitation to be determ-ined by Michigan Water Resources

(':RC) based on results of a sire specific study co establish rhe appropriate acute and chronic ammonia toxcit7y leve*l in the Titrabawassee- River. See Special Condi:ion

1. 28- for study requirements.

• • • • Final BOD.I discharge limitation to be determined by MWRC based on results of the DNR's Tirtabawassee River investigation and the company's Short-Term Waste Character-izacion Study for BOD See Special Condition #26 for study requirements.

• • • • • Any unusual characteristics of the discharge which would noc be expected from the above authorized discharge (i.e., unusual turbidity, discoloration, oil film, suspended matter, etc.) shall be reported immediately to the District Office of the Water Quality Division, followed with a written report within five (5) days derailing the findings of the investigation and the steps taken to correct the condition.

• • • • • • This discharge prohibition may be modified by the Commission based upon the results of the ax-onia toxicity study specified in Part I, Sec A.28 Special Condition.

a. The discharge shall not cause excessive foam on the receiving waters.

The discharge shall be essentially free of floating and settleable solids.

b. Samples taken in compliance with the monitoring requirements above for

,fall 001 shall be taken at a point prior to discharge into the Tictabawassee River and BOD.3 without mixing with radwaste dilution water.

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

Permit No. MI 0042668 Page lo of 33 Final Effluent Limitations - Outfall 002, Condensate Return Pump House Drainage During the period beginning with the commencemnit of discharge and lasting until the expiration date of this permit, the permittee is authorized to discharge up to a maxinm of twelve thousand (12,000) gallons per day of condensate return pump house drainage on an intermittent basis to Bullock Creek from outfall 002.

This drainage consists of minor pump seal leaks, groundwater seepage, and high quality condensate resulting from equipment repairs or maintenance. Such discharge shall be made consistent with the following restrictions:

(1) Discharge of groundwater seepage and minor seal leaks; no effluent monitoring or sampling requirements.

(2) Discharge of condensate resulting from drainage or failure of equipment.

Discharge Limitations ka/day (lbs/day) Other Limitations Monitoring Requirements ffluent Monthly Daily Monthly Daily Measurement Sample haracteristics Average Maximum Average Maximum Frecuencv TVye low, M4/day (MGD) Daily*'

utfall Observation** Daily* Visual

• Per discharge occurrence.

Any unusual characteristics of the discharge which would not be expected "'aom a above authorized discharge (i.e., turbidity, discoloration, oil film, suspended matter, etc.) shall be reported immediately to the District Office of the Water Quality Division, followed with a written report within five (5) days detailing the findings of the investigation and the steps taken to correct the condition.

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: Daily*; grab.

b. Samples taken in compliance with the monitoring requirements above shall be taken at.outfall 002 prior to discharging to Bullock Creek.

c. All discharges under A. 7(2) shall be reported in writing to the District I!

Office of the Water Quality Division within ten (10) days of each occurrence.

Said reports shall include the cause of the discharge, the volume of the discharge, and the results of the analysis and observations required in A. 7(2)..a and b.

d. In the event the permittee shall require the use of water treatment additives in addition to or in greater quantities than those identified in the permictee's NPDES application (Revision 3) dated November 11, 1981 and approved by the Chief of the Water Quality Division on March 11, 1982, the permittee shall notify the Division Chief. Written approval from the Chief of the Water Quality Division to use such additives at specified levels shall be obtained prior to usage by

-"e permittee. The permit will be modified in accordance with the requirements Part II, Section B-4 if a constituent of the additive or additives requires

_miting.

PerMit No. MI 0042668 Page 11 of 33 Final Effluent Limitations - Cooling Pond Discharge (OOA) Pribr to Outfall 001 During the period beginning with the commencement of discharge and lasting until the expiration date of this permit, the permittee is authorized to discharge up to a maximum of one hundred and forty-two million (142,000,000) gallons per day of cooling pond blowdown and miscellaneous low-volume wastes consisting in part of site storm drainage, site dewatering, Units 1 and 2 clean waste sump, Unit 1 and Unit Z neutralizing sumps, evaporator building neutralizing sumpp, oily waste storage tank overflow, iron removal sump, condensate storage tank overflow and/or drain and service water cooling tower blowdown through outfall 001 into the Tittabawassee River. Such discharge shall be limited and monitored by the permittee as specified below:

Discharge Limitations kg/dav (lbs/dav) Other Limitations Monitoring Recuiremen:s Iffluent Monthly Daily Monthly Daily Measurement Samp.le

.haracteristics Average Maxi-.,m Average Maximum Freauencv Type

.low, Ma/day (MMD) Daily*-

liochemical Oxygen Demand, 5-day Once Weekly* Grab Ionia (as N) Once Weekly* Grab Once Daily* Grab

otal Dissolved Solids

otal Residual Chlorine (TRC)** 0.2 mg/I 0.3 mg/l*** Once Daily* Grab

ooling Pond Blowdown Time*** Daily* Report Discharge Ti

wge Temperature, o7 Si ee Table I "Allowable Discharge Daily* Continuous Taemperature", p. 13 of 33 Report dai!3 average and daily -axi=

• When c6oling pond is discharging. When the Tittabawassee River flows, downsstream of Lingle Drain, are less than the minimum seasonal design flows specif--ed for the cooling pond in Part I.Aý6, the permitree shall report the discharge to outf-a2!! 001 at each 15 minute interval. If no discharge, the per-miLtee shall report zero.

• fr To be measured by the amperonetric titration technique or other methods approved by the Chief of the Water Quality Division.

• 'When the cooling pond blowdown time exceeds 160 minutes in any 24-hour period, the maximum concentration of TRC shall not exceed 0.083 mg/I.

The permictee may use dechlorination techniques to achieve the applicable limitations using sodium thiosulfate or sodium sulfite or other dechlorinating agents approved by the Chief of the Water Qualit7 Division as dechlorination reagents. The quantity of reagent used shall be limited to 1.5 times the stoichiomecric amount needed for dechlorination. The permittee shall report monthly the quantity of each dechlori-nation reagent used per day.

The permittee may demonstrate to the Commission that no chlorine limitations or aitoring is necessary.

Per'it No. MI 0042668 Page 12 of 33

5. Final Effluent Limitations (continued)

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: Once daily*; grab sample.

b. Samples taken in compliance with the =nitoring requireoments above shall be taken at a point prior to discharge through 001 and prior to =iing with any other wastewaters and/or the radwaste dilution water.

c. In the event the permittee shall require the use of water treatment additives in addition to or in greater quantities than those identified in the permittee's NPDES application (Revision 3) dated November 11, 1981, and approved by the Chief of the Water Quality Division on March 11, 1982, the permiccee shall nocify the Division Chief. Written approval from the Chief fo the Water Quality Division to use such additives at specified levels shall be obtained prior to usage by the perm=itee. The permit will be mdified in accordance with the requirements of Part I, Section A-I if a constituent of the additive or additives requires limiting.

Permit No. MI 0042668 Page 13 of 33 TABLE 1 ALLOWABLE DISCRARGE TL'r.!RATUI=S

,IDLAND PLANT COOLING POND BLOWDOWN Discharge Temperature M(onh)

December 75(1)(2)

January 75 (1)(2)

February 75(1)(2)

March 80(I)(2)

April 85(3)

May 95(3)(4.)

95(3)(4)

June 95(3)(4)

July 95 (3)(4)

August September 95(3)(4)

October 90(3)

November 85 (3)

(1)

Maximum weekly average temperature.

(2) itn the event of a Plant shutdown, sudden termination of the discharge will not occur. Rather, the normal pond discharge criteria will be followed until the discharge reaches five (5) cfs at which time discharge may be terminataed.

(3)Maxi-ni temperature, except as provided in Foocnote 4.

(4)Discharges of up to five (5) cfs are permitted when discharge temperatures are greater than 95 ° but not greater than 100°F. No discharge is allowed when the cooling pond blowdown discharge temperature is greater than 100°F.

Permit No. MI 0042668 Page 14 of 33

• . Final Effluent Limitations - Oily Waste Treatment System (OOB)

During the period beginning with the commencement of discharge and lasting until the expiration date of this permit, the permirtee is authorized to discharge up co a maximum of two hundred eighty eight thousand (288,000) gallons per day of wastewater from the oily waste treatment system consisting of auxiliary boiler blowdown, floor drains and precipitation from the outdoor transformer area through outfall 001 into the Tittabavassee River. Such discharge shall be limited and monitored by the permittee as specified. below:

Discharge Limitations kg/day (lbs/dav) Other Limitacions Monitoring Recuirements ffluent Monthly Monthly Measurement Sample haracteris tics Average Maximum* Average Maximum* Frequency Tvye low, M/day (MGD) Weekly oral Suspended 33(72) 109(240) 30 mgfl 100 mg/l Weekly Grab Solids il and Grease** 16(36) Z2(48) 15 mg/l 20 mg/l 2X Monthly Grab

' Weekly maxi-um for total suspended solids and monthly maximum for oil and grease.

• • The permittee may demonstrate that "No visible film" is more stringent than the above concentration limitation.

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall monitored as follows: Weekly; grab sample.

b. Samples taken in compliance with the monitoring requirements above shall be taken at a point prior to mixing with any other wastewaters and/or radwasce dilution water and prior to discharge to outfall 001.

c. In the event the permittee shall require the use of water treatment additives in addition to or in greater quantities than those identified in the pe-mic-ee's NPDES application (Revision 3) dated November 11, 1981, and approved- by the Chief of the Water Quality Division on March 11, 1982, the permittee shall notify the Division Chief. Written approval from the Chief of the Water Quality Division to use such additives an specified levels shall be obtained prior to usage by the permittee. The permit will be modified in accordance with the requirements of Part 1I, Section A-I if a constituent of the additive or additives requires limiting.

Pmi tNo. MI 0042668 Page 15 of 33

). Final Effluent Limitations - Evaporator Building Neutralizing Sum. (00C)

During the period beginning with the commencement of discharge and lasting until the expiration date of this permit, the permittee is authorized to discharge up co a maximum of two hundred twenty thousand (220,000) gallons per day of wastawater from the evaporator building neutralizing sum., consisting of makeup demineralizer system regeneration waste, the evaporator building laboratory waste, chemical addition and storage area floor drains through outfall 001 into the Tit:abawassee River. Such discharge shall be limited and monitored by the permittee as specified

-below:

Discharge Limitations kg/dav (lbs/day) Other Limitations Monitorin. Recu£ir-mencs

.ffluent Monthly Daily Monthly Daily Measurement Sample Tharacteristics Average Maximum Average Maximum Frecuencv Type "loa, M3 /day (MGD) Daily*

Cotal Suspended 25(55) 83(183) 30 mg/l 100 mg/l Daily** Grab Solids rocal Phosphorus 0.8(1.8) 1 mg/I Daily** Grab (as P)

, Per occurrence of each batch discharge.

• - Per occurrence of each batch discharge when discharging through outfall 001.

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall ve monitored as follows: Daily**; grab sample.

b.

• Sam*les taken in compliance with the monitoring requirements above shall be taken at a point prior to mixing with any other wastewaters and/or radwaste dilution water and prior to discharge to outfall 001.

c. In the event the permictee shall require the use of water treac=ent addi:ives in addition to or in greater quantities than those identified in the permittee's NPDES application (Revision 3) dated November II, 1981, and approved by the Chief of the Water Quality Division on March 11, 1982, the permittee shall notify the Division Chief. Written approval from the Chief of che" Water QualiC7 Division to use such additives at specified levels shall be obtained prior to usage by the parmittee. The permit will be modified in accordance with the requirements of Part 11, Section A-I if a constituent of the additive or additives requites limizing.

Pe=it No. H 0042668 ?age 16 of 33 I.Final Effluent Limitations - Unic 1 and Unic 2 Neucralizing Sdnp (OOD)

During the period begimnim; wi!h" the coc:encemenc of discharge and lascing until the expiration date of this permit, the permiccee is authorized to discharge up co a wax*im of one hundred six thousand (106,000) gallons per day of Unit I and Unit Z neutralizing su=p wascevatar, consisting of Unit I and Unit 2 condeasace polisher regeneration waste and secondary plant laboratory wastewater, through out!fall 001-into the Tictabavassee River. Such discharge shall be limited and monitored by the pe-mittee as specified below:

Discha e Li=itations kq/dav7 (lbs/dav) Other Li=itations Honi:oring Reouiremen:s fluent Mouthly Daily Monthly Daily heasuremenm Sample tracreriscics Average Maxim= Average Max; -m Frecuencv !ype v, f3/day (,CD) Daily*

aI Suspended 12(27) 40(88) 30 mg/l 100 mg/I Dail.y*- Grab

alids 30ma (as N) Day!7** Grab Per occurrence of each batch discharge. When the Tic

abawassee RIver flows, do-instresm

" Lingle Drain, are less than the mini== seasonal design flows specified for the I and 2 meutralizing sumps in Part I.A.6, the permiztee shall report the disc-ar;e

fall 001 at each U5 mi=.ce imver-al.. -f no discharge, the perm=:zee shall rt.C zero.

• Per occurrence of each batch discharge when dischargi-g through outfall 001.

a. The pH shall no: be less than 6.0 nor greater than 9.0. The pH shall be momitored as follows: Daily**; grab sample.

b. Sa=ples taken in cc=pliance with the moni:orimg requir-ments above shall be taken a: a point prior to mixi=g with any other wastewaters and/or radwasce dilution water and prior to discharge to outfall 001.

c. In the even: the permictee shall require the use of water treatment addi:ives in addition to or in greater quantities than those specified in the permit:ee's NPDES applica:ion (Ravision 3) dated November 11, 1981, and approved by the Chief of the Water Quali7 Division on March 11, 1982, the permit:ee shall notify the Division Chief. Writ:en approval fr== the Chief of the 7ater Quali=7 Division to use such additives at specified levels shall be obtained prior to usage by the permictee. The permit will be modified in accordance with the requirements of Part LI, Section B-4 if a conustiuent of the additive or additives requires laiming.

Permit No. Ml 0042668 Page 17 of -.33 Z. Final Effluent Conditions - Laundry Waste Treatment System (OOE)

During the period beginning with the co-encement of discharge and lasting until the expiration date of this permit, the permittee is authorized to discharge up to a maximum of eight thousand (8,000) gallons per day of laundry waste treat=ment system wastewater through outfall 001 into the Tittabawassee River. Such discharge shall be limited and monitored by the permittee as specified below:

Discharge Limitations kg/day (lbs/dav) Other Limitations Monitoring Reauirments Effluent .Monthly Daily Mon*hly Daily Measurement Sam le Characteristics Average Maxi-m Average Maximum Frecuencv Tvye Flow, M3 /day (MGD) Daily*

Total Suspended 0.9(2.0) 3..0(6.7) 30 mg/l 100 mg/1 Daily* Grab Solids

• Per occurrence of each batch discharge.

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: Daily*; grab sample.

b. Samples taken in compliance With the monitoring requirements above shall be taken at a point prior to mixing with any other cooling or process wastewaters T radwaste dilution water and prior to discharge to outfall 001.

c. In the event the permittee shall require the use of water treatment additives in addition to or in greater quantities than those specified in the permirtee's NPDES application (Revision 3) dated November 11, 1981, and approved by the Chief or the Water Quality Division on March 11, 198Z, the permitree shall notify the Division Chief. Written approval from the Chief of the Water Quality Division to use such additives at specified levels shall be obtained prior to usage by the permittee. The permit will be modified in accordance with the requirements of Part 1I, Section A-I if a constituent of the additive or additives requires limiting.

Parmit No. MI 0042668 Page 18 of 33

"" Final Effluent Conditions - Liquid Radwaste Treatment System (OOF)

During the period beginning with the comencement of discharge and lasting until the expiration date of this permit, the permittee is authorized to discharge up to a maximum of forty thousand (40,000) gallons per day of liquid radwaste treat=ment system wastewater through outfall 001 into the Tictabawassee River.

Such discharge shall be limited nd monitored by the permitree as specified below:

Discharge Limitations kx/dav (lbs/day) Other Limitations Monitoring Recuirements ffluent Monthly Daily Monthly Daily Measurement Sample haracteriscics Average Maximum Average Maxi=m Frecuencv Tvne low, M3/day (MGD) Daily*

otal Suspended 4.5(10) 15(33) 30 mg/l 100 mg/l Daily* Grab Solids

• Per occurrence of each batch discharge.

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monitored as follows: Daily*; grab sample.

b. Samples taken in compliance with the monitoring requirements above'shall be taken at a point prior to mixing with any ocher cooling or process wastewaters or radvaste dilution water and prior to discharge to outfall 001.

c. In the event the permictee shall require the use of water treatment additives

,a addition to or in greater quantities than those specified in the permictee's NPDES application (Revision 3) dated November 11, 1981, and approved by the Chief of the kater Quality Division on March 11, 1982, the permittee shall notify the Division Chief. Written approval from the Chief of the Water Quality Division to use such additives at specified levels shall be obtained piror to usage by the permittee. The permit will be modified im accordance with the requirements of Part 11, Section A-1 if a coustituent of the additive or additives requires limiting.

Permic No. .4 0042668 Page 19 of 33

• Final Effluenr Limitations - Eadvaste Dilution Water (OOG) through Outfall 001 During the period beginning with the date of issuance of this pe=mit and lasting until the expiration date, the permittee is authorized to discharge a maxximum of forty-three million, four hundred thousand (43,4O0,O00) gallons per

-day of radwaste dilution water into the Tittabawassee River. Such discharge shall be limited and monitored by the permittee as specified below:

Discharge Limitations ksIday (Lbs/day) Other Limitations Monitorin; Recuiremenrs

.ffluent Monthly Daily Monthly Daily Measurement Sample

,haracteristics Average maxi".m Average Maxin"I Freouencv Tvve lows, M3/day (MGD) Daily per discharge occurrence

a. The discharge shall not interfere with the monitoring requirements for A-6 through A-13 of this permit.

b. When the cooling pond blowdown is not being discharged or is insufficient for radwasce dilution, the permittee may use radwasce dilution as restricted above.

Permij No. MI 0042668 Page 20 of 33

". Final Effluent Limitations - Cooling Tower Blowdown (OOH), Temporar7 High Pressure and Auxiliary Boiler Blowdown and Drains (001)

Beginning with the coe-ncemenr of discharge and lasting until the expiration date of this permit, the permictee is authorized the intermittent discharge of service water cooling cower blowdown into the cooling pond and the intermittent discharge of temporary high pressure and auxiliary boiler blowdown to the oily waste treatment system. Such discharges shall be limited and monitored by the permittee as specified below:

Discharge Limitations kS/dav (lbs/dav) Other Limitations Monitoring Reoui-emen.s ffluent Monthly Daily Monthly Daily Measurement Sample haracteristics Average Maxim-m Average Maximum Frecuencv Tvye ooling Tower Blowdown

'low, M3/day (MGD) Daily*

aterials Added for See "c" below.

Corrosion Inhibition

.uxiliarv Boiler Blowdovwn 3

w, M /day (MGD) Daily*

?er discharge occurrence.

a. The pH shall not be less than 6.0 nor greater than 9.0. The pH shall be monicore& as follows: Daily*; grab sample.

b. Samples taken in compliance with dhe monitoring requirements above shall be taken:

(1) For cooling cower blowdown: Prior to discharge to dhe cooling pond.

(2) For auxiliary boiler blowdown: Prior t6 discharge to the oily waste treatment system.

c. In the event the permictee shall require the use of water treacment addi-ives in addition to or in greater quantities than those specified in the permittee's NPDES application (Revision 3) dated November 11, 1981, and approved by the Chief of the Water Quality Division on March 11, 1982, the permittee shall notify the Division Chief. Written approval from the Chief of the Water Quality Division to use such additives at specified levels shall be obtained prior to usage by the permittee. The permit will be modified in accordance with the requirements of Part II, Section A-i if a constituent of the additive or additives requires limiting.

Permit No. MI 0042668 Page 21 of 3.1

• Final Limitations - Trash Bar Debris, Stationary and Travelling Screen Backwash and Debris Beginning on the date of issuance of this permit and lasting until the expiration date, the permictee shall collect and remove debris collected on river intake trash bars and screens and dispose of such material by the manner specified in the application. River intake screen backwash water may be discharged back to the Tittabavassee River. Debris collected from the circulating water and pond blowdown screens and trash bars shall be disposed of by the manner specified in the application.

17. Final Limitations - Sanitary Sewage Beginning with the commencement of discharge and lasting until the expiration date, all sanitary sewage from the Midland Plant and the Training and Visitor's Center shall be discharged to the Dow Chemical Company wastewater treatment system.

If the permittee elects to dispose of the sanitary sewage by another manner, the permictee shall notify the Chief of the Water Quality Division of the intended disposal method and obtain his approval at least 30 days prior to the commencement of discharge.

18. Final Limitations - Evaporator Blowdown Beginning with the commencement of discharge -and lasting until the expiration date of this permit, evaporator blowdown from the process steam system shall be

-itinely discharged to the Dow Chemical Company treatment system.

19. Final Limitation - Polychlorinaced Biphenyls Effective on the date of issuance of this per-mit, the Company shall not discharge any polychlorinaced biphenyls resulting from Plant operations to the waters of the State of Michigan.

20. Final Limitations - Wastewater Treatmen: Sludges or Residuals The permitree shall not discharge sludges or residuals resulting from wastewater trea=tent facilities into the waters of the Stare.

I

Per=i: No. ýI 004'26008Pae2of3 ?age, 22 of 33 Specia.l Condition -

The perm=+/-:ae sha.ll oui:or and report the Tictabawassee RIver flows at che U.S.G.S. Gaj+/-ng Scarion and downs-ream of ULigle Drain and the per=ic:ee's Lnclka flows as spec+/-i.fad below. The purpose of chis =o=i:oring -_s co assess :he .==ac:

of che pe-i=:ee's facili:7 operation on Ti::abawassee River flows.

Ti=zabasassee River and ntnake W~cnicoring Recuir-mencs*

At the U.S.G.S. Report da*!y mi=ninum and Gag*ng Station daily average flows Downsrr.eam of Lingle Drai=** Report calculated.daily iinum and daily averaste river flows. C~hen :ihe Trttawabassee iver flows are below che .followin-g min+/-=_d esg S1f9iiows chose flows are co be recorded at 15 +/-izuta i=c-rvaLs and :he. resul:s :eorted.

.River Flow (cfs) Below Lizle Drain Duzq 332 June L - August 31 Sepce--ber I - Seoce-_he- 30 355 October I - April 30 603 Y.y7 - May 31 Iz ake Report daily average and dall y i:cake 4a_-u=

flow

• Chief of the ýJater QualiZ7 Division '-rill review che info---acion obtained from the above monioring and if it is dster-ined char chis moUi=ori=g requirement should be

=odi:ied, che pe.-.- :ee shall,be so notified.

• • The flow downstream of Lingle Drain is defined as the sum of che instantaneous flow

rom che U.S.G.S. Gaging Station, the instantaneous flow from Cansumers Power C=m.any outfall 001, che instantaneous flow from Dow Chemical Company outf all 031, and che desig flow of the Midland Wastewater Trea=menu ?lanc (equal to 13 cfs) mizus the instantaneous water intake rate by Consumers Power Company.

Pernmi No. MI 0042668 Page 23 of 33

12. Special Condition - River Intake Monitoring Requirements The Michigan Water Resources Commission has tentatively determined that the location, design, construction and capacity of the Midland Plant intake structure reflects the best technology available for minimizing adverse environental impact in accordance with Section 316(b) of Public Act 92-500, as amended (the Act).

During the period beginning 60 days following the start of commercial operation of the second unit and for a period of one year, the permittee shall conduct a study to measure the numbers and species of fish impinged and entrained at the river intake structure to determine if the intake structure does comply with the requirements of.Section 316(b) of the Act. One hundred twenty (120) days following completion of such study, the permittee shall submit the findings of the study to the Chief of the Water Quality Division. Such study shall be conducted in accordance with an approved study plan and the Schedule of Compliance in Par: I, Section C-4.

If on the basis of the study report and applicable standards established pursuant to Section 316(b) of the Act, the Comission determines that the intake structures do not reflect the best technology available for minimizing adverse environmental impact, it will so notify the Company, specifying the reason(s) for its determination, and the Company shall submit to the Chief of the Water Quality Division, within 90 days of such notification, its plan and construction time schedule for minimizing the environmental impact of the intake structure.

23. Special Condition - Thermal Monitoring Requirement The permittee shall determine the extent of the 5 IF temperature increase isotherm in the downstream vicinity of outfall 001 during the spring, sumner, and fall seasons. Such study shall be carried out wich the site operating at a minimum of 70 percent of total capacity following- the start of commercial operation of the second unit.

One hundred twenty (120) days following completion of such study, the permitree shall submit the findings of the study to the Chief of the Water Quality Division.

The purpose of the study will be to confirm the thermal discharge is consistent with temperature Water Quality Standards. Such study shall be conducted in accordance with an approved study plan and the Schedule of Compliance in Part 1, Section C-5.

Permit No. MI 0042668 Page 24 of 33 Special Condition - Automatic Makeup and Blowdowu System (A2BS) Verification Study Requirements During the period beginning 60 days following the start of co-mercial operation of Units I and 2 and lasting for a period of one year, the permittee shall completa a poscoperacional verification study to confirm.that the automatic feed forward monitoring system (AMBS) will provide the necessary controls such that the discharge from outfall 001 is consistent with total dissolved solids (TDS) and thermal Water Quality Standards. One hundred twenty (120) days following completion of such study, the permittee shall submit the findings of the study to the Chief of the Water Quality Division. Such study shall be conducted in accordance with an approved study plan and the Schedule of Compliance in Part I, Section C-6. Upon verifica-tion of the AMBS, the AMBS shall be used to demonstrate compliance with the ther-al and TDS Water Quality Standards.

25. Special Condition - Toxics Limitations Provision This permit may be modified, or, alternatively revoked and reissued to comply with any applicable standards or limitations promulgated under Sections 301(b)(C)( D),

304(b)(2) and 307(a)(2) if the effluent standards or limitations so promulgated:

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

b. Controls any pollutant not limited in the permit.

Parmit No. MI 0042668 Page- 25 of 33

• Special Condition - Short Term Waste Characterization Study As a condition of this permit, beginning upon commencement of Unit I and 2 operation, the permittee shall monitor effluents from laundry waste treatment system and oily waste treatment system for the constituents at the frequency and for the period specified below. This monitoring will be required to demonstrate that these constituents are not contained in significant quantities. The results of the analysis of such monitoring shall be submitted one year after the two units operation to the Chief of the Water Quality Division. If, upon review of the analysis, it is determined that any of the materials or constituents require limiting to protect the receiving waters in accordance with applicable Water Quality Standards, the permittee will be so informed. The permit will then be modified in accordance with Part I1, B-4.

Constituent Samole Type Samule Frecuencv Samole Duracion BOD 5 Grab Once Weekly Six Months

27. Special Condition - Pre and Postoperacional Ecological Monitoring Program The permittee shall conduct a pre and postoperational ecological monitoring program to determine the impact of plant operation on the aquatic ecosystem of the Tittabawassee River. Such studies shall be conducted in accordance with approved study plans and the Schedule of Compliance in Part I, Section C-7.

If on the basis of the pre and postoperational ecological monitoring program

,ort, the Coission determines that the operation of the plant is adversely

... acting the aquatic ecosystem of the Tittabawassee River, the Commission will so notify the permittee. Such notification shall specify the reason(s) for the Commission determination. The permittee shall submit to the Chief of the Water Quality Division within 90 days of such notification, a plan and construction time schedule for reducing the adverse impacts to levels acceptable to the Commission.

28. Special Condition - Site Specific Invesn:garlon to Deter-=ie Acute and ChroiLc A-onia Toxicity Levels The permittee shall conduct a site specific study to determine the acute and chronic -:nLa toxicity level for the Tittabawassee River commencing in the su-er of 1983. Such study shall be conducted in accordance with the approved study plan and the Schedule of Compliance in Part I, Section C-8.

The Michigan Water Resources Commission will then use the results of the a-onia toxicit7y study to determine the Tittabawassee River's assimilative capacity and to establish appropriate a=oia discharge limitations to p-zotacr the receiving waters in accordance with applicable Water Quality Standards. Permit lm4ics for

-onnia discharges will then be modified in accordance with Part II, Section B-4.

Permit No. MI 0042668 Page 26 of 33

"". Special Condition - Cooling Pond. Maintenance Program The permittee shall maintain the dewatered cooling pond to control the suspended solids concentration in the stormwater runoff and site dewatering discharged from the cooling pond. This cooling pond maintenance program shall be conducted in accordance with an approved plan and the Schedule of Compliance in Part I, Section C-12.

30. Special Condition - Tittabawassee River, Cooling Pond and Dewatering Discharge Water Quality Monitoring Program The permittee shall monitor the water quality of the Tittabawassee River, the cooling pond and the dewatering discharge while the cooling pond is being dewatered.

This monitoring shall be conducted in accordance with an approved plan and the Schedule of Compliance in Part 1, Section C-13.

31. Special Condition - Release of Unharmed Fish to the Tittabawassee River The permittee shall make a reasonable effort to transfer fish in the cooling pond unharmed to the Tittabawassee River. This program shall be conducted in accordance with an approved plan and the Schedule of Compliance in Part I, Section C-14.

32. Special Condition - Avifauna Disease Prevention and Control Program The permittee shall make a reasonable effort to prevent and, if necessary, control the outbreak of avifauna disease in conjuction with the dewatering of the cooling pond.

"'s program shall be conducted in accordance with an approved plan and the Schedule of pliance in Part I, Section C-15.

Permit No. MI 0042668 Page 27 Of 33

33. Special Condition - Program for Effective Residuals Management (PERM)

In addition to the requirements in Part II, Section A-'9 herein, the permi.ttee dhall provide for the effective management and/or disposal of residuals, i.e., solids, sludges, ash, grit, dead fish, aquatic plants and other substances removed from or resulting from treatment of the wastewater. Residuals disposal shall be accomplished in such manner and at such locations that the disposal practices shall not result in unlawful pollution of the air, surface waters or groundwaters of the state nor create nuisance conditions. Such management and/or disposal program shall be set forth in a "Program for Effective Residuals Management" prepared by the permittee. The program shall include but is not limited to the following:

1) a management plan (treatment, transportation, stofage, disposal, contingency plans);

2) an inventory of residuals production, storage, and disposal for a period of at least one year;

3) an analysis of the residuals;

4) a monitoring program;

5) if land application is proposed, site maps, soil analysis, application rates, proposed vegetation, and.other pertinent information; and,

6) if groundwater degradation potential exists, a hydrogeologic study.

The program shall be submitted to and receive the approval of the Saginaw

-strict Supervisor of the Surface Water Quality Division in accordance with the Schedule.of Compliance Part I, C-16 of this permit. Subsequent to approval, disposal of residuals resulting from treatment of wastewater shall be in accordance with the program. If the permittee desires to make any substantial changes in the program, such proposed changes shall be submitted to and be approved by the Saginaw District Supervisor of the Surface Water Quality Division prior to implementation. Substantial changes shall include but not be limited to: a change in disposal method or sice; a change in treatment method; a change in storage method or site; a change in monitoring parameters or monitoring frequency; an increase in application rate; or a change in residuals quantity or characteristics. Any residual disposal inconsistent'with the approved program shall be considered a violation of this permit.

Permit No. MI 0042608 Page 28 of 33 PART I B. MONITORING AND REPORTING

1. Representative Sampling Samples and measur~ements taken as required herein shall be representative of the volume and nature of the monitored discharge.

2. Reporting All reports shall be postarked no later than the 10th day of the month following each completed report period.

a. Existing Discharge - First Permit Issuance The permittee shall submit monitoring reports containing results obtained during the previous month. The first report shall be submitted within 90 days of the date of issuance of this permit.

b. Proposed Discharge The permittee shall submit monitoring reports containing results obtained during the previous month. Monitoring shall commence at the time discharge first occurs.

c. Existing Discharge - Permit Modified or Reissued With No New Parameters The permittee shall continue to submit monitoring reports containing results obtained during the previous month.

d. Existing Discharge - Permit Modified or ReisSued With New Parameters Previously Not Monitored The permittee shall continue to submit monitoring reports containing results obtained during the previous month for parameters currently monitored. The first report for parameters specifically excluded in Part I-A shall be submitted within 90 days of the date of issuance of this permit.

Permit No. MI 0042668 Page 29 of 33 Definitions

a. The monthly average discharge is defined as the total discharge by weight, or concentration if specified, during the reporting month divided by the number of days in the reporting month that the discharge from the production or commercial facility occurred. When less than daily sampling occurs, the monthly average discharge shall be determined.by the summation of the measured daily discharges by weight, or concentration if specified, divided by the number of days during the reporting month when the samples were collected, analyzed and reported.

b. The daily maximum discharge means the total discharge by weight, or concentration if specified during any calendar day.

c. The Regional Administrator is defined as the Region V Administrator, U.S. EPA, located, at 230 South

Dearborn,

13th Floor, Chicago, Illinois 60604.

d. The Michigan.Water Resources Commission is located in the Stevens T. Mason Building. The mailing address is Box 30028, Lansing, Michigan 48909.

e. The term 24-hour composite means a combination of at least 8 sample aliquots of at least 100 milliliters, collected at periodic intervals during the operating hours of a facility over a 24-hour period. For volatile pollutants, the aliquots must be combined in the laboratory immediately before analysis. The composite must be flow proportional; either the time interval between each aliquot or the volume of each aliquot must be proportional to either the stream flow at the time of sampling or he total stream flow since the collection of the previous aliquot. Aliquots may be oollected ,nanually or automatically.

4. Test Procedures Test procedures for the analysis of pollutants shall conform to regulations published pursuant to Section 304(h) of the Act, under which such procedures may be required.

5. Recording Results For each measurement or sample taken pursuant to the requirements of this permit, the permittee shall record the following information:

a. The exact place, date, and time of sampling;

b. The dates the analyses were performed;

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

d. The analytical techniques or methods used; and

e. The results of all required analyses.

,,r. No. MI 0042568 Paqe h of 33

6. Additicnal Mcnitcrin- by -er... ee If the permit.ee nmnitors any pollutant at tha location(s) designated herein more frequently than required by this perrmit, using approved analy-ical m*ethods as specified above, the results of such monitoring shall be included in the calculation and rzporting cf the values required in the Mcnthly Ocerazing Report. Such increased frequency shall also be indicated.

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

C. SCHEDULE OF COMPLIANCE

1. The pe.mitt.e shall achieve comp.liance with the interim effluent limitin specified in Par. -,A-1,3, 4, 5 as follows:

a. If permit*:e chooses to dischar-ge through Outfall .01 or Outfall 003, compliance shall occur with the commencement of.discharge.

b. If pe,,itt*e elects to discharge at a point other than Outzfal 001, or Outfall 003, the pemittee shall notify, in writing, tne Chief of the Water Quality Division and obtain his approval of the alternate sites 30 days prior to commencement of discharge.

C. Within thirty days of the date of issuance of '.spei..., -s-.e permittee shall notify the Chief of the Water Qualicy Oivisicn oi their intent to use C-1, a or b above.

2. The permittee shall achieve compliance with the final effluent limitations in Part I, A-I through A-20 as follows:

a. For wastewater treatment systems and associated flow monitoring and effluent sampling schemes corleted prior to the-date of issuance of this permit, the permittee shall submit as built~plins and specifications to the Chief of the Water Quality Division within 120 days follcwing the date"*of issuencie of this permit.'

b. For those wastewater treatment systems scheduled to be designed and/or constructed after the date of issuance of this permit, the permitt.e shall submit final plans and specifications .to the Chief of the Water.Quality Division within 120 days following the date of issuance of this permit.

c. On July 1, 1982, and every six months thereafter until attaining commercial operation of both Unit 1 and Unit 2, the permittee shall submit a progress report to the Chief of the Water Quality Division.

Such report shall include, but not be limited to, progress in design, construction and testing of wastewater treatment systems. .

Permit No. MI 0042668 Page 31 of 33

'edule of Compliance (continued)

3. The permittee shall comply with the requirements of Section 10, Part II-A in accordance with the following:

a. Submit plans for approval to the Chief of the Water Quality Division necessary to comply with the primary power provision of Section 10 in Part II on or before N/A.

b. The permittee shall comply with the requirements of items 10a or 10b contained in Part II on or before N/A. Notwithstanding the preceding sentence, the permittee shall at all times halt, reduce or otherwise control production in order to protect the waters of the State of Michigan upon the reduction or loss of the primary source of power.

4. The permittee shall achieve compliance with the provisions of the postoperational river intake monitoring requirements (Part I, A-22) in accordance with the following schedule. All submittals shall be to the Chief of the Water Quality Division of the Department of Natural Resources.

a. By no later than 90 days prior to the start of commercial operation of the second unit, the permittee shall submit the river intake monitoring study plan for approval.

b. The permittee shall notify, in writing, when the second unit reaches the status of commercial operation.

c. Within 120 days of the conclusion of the one-year postoperational intake study, the permittee shall submit a final report.

5. The permittee shall achieve compliance with the thermal monitoring requirement for Outfall 001 (Part I, Section A- 23) in accordance with'the following schedule.

All submittals shall be to the Chief of the Water Quality Division of the Department of Natural Resources.

a. By no later than 90 days prior to the start of commercial operation of the second unit, the permittee shall submit the thermal monitoring study plan for approval.

b. The permittee shall notify, in writing, when the second unit reaches the status of commercial operation.

c. One hundred twenty (120) days following completion of the thermal monitoring, the permittee shall submit a final report.

Permit No. MI 0042668 Page 32 of 33 Schedule of Compliance (continued)

6. -The perrittee shall achieve compliance with the AMBS verification study requirement for Outfall 001 (Part I, Section A-24) in accordance with the following schedule. All submittals shall be to the Chief of the Water Quality Division of the Department of Natural Resources.

a. By no later than 90 days prior to the start of commercial operation of the second unit, the permittee shall submit the AMBS verification study plan for approval.

b. The permittee shall notify, in writing, when the second unit reaches the status of commercial operation.

c. Within 120 days of the conclusion of the one-year AMBS verification study, the permittee shall submit a final report.

7. The permittee shall achieve compliance with the pre and postoperational monitoring requirement (Part I, Section A-27 in accordance with the following schedule. All submittals shall be to the Chief of the Water Quality Division of the Department of Natural Resources.

a. The permittee shall conduct the preoperational phase of the ecological monitoring program pursuant to the scope of study approved by the Chief of the Water Quality Division on March 16, 1982.

b. The final preoperational report and-the scope of study for the post-operational phase of the ecological monitoring program, including the schedules, shall be submitted to the Chief of the Water Quality Division for approval by July 30, 1983.

c. One hundred twenty (120) days following completion of the postoperational phase of the ecological monitoring program, the permittee shall submit a final report.

8. The permittee snall achieve compliance with the acute and chronic ammonia toxicity study requirements (Part I, A-28 in accordance with the following schedule. All submittals shall be to the Chief of the Water Quality Division of the Department of Natural Resources;

a. By no later than March 31, 1983, the permittee shall submit the ammonia toxicity study plan for approval.

b. Within 120 days of the conclusion of the ammonia toxicity study, the permittee shall submit a final report.

9. If the Company elects to demonstrate to the Michigan Water Resources Commission that higher levels of chlorine, 6005 and/or ammonia are acceptable, it shall submit a study plan for determining safe levels of total residual chlorine, BOD 5 , and/or ammonia in its discharges and obtain approval thereof from the Chief of the Water Quality Division.

Permit No. MI 0042668 Page 33 of 33 Schedule of Compliance (continued)

10. The permittee may demonstrate to the Michigan Water Resources Commission that no chlorine limitations or monitoring is necessary.

11. No later than 14 calendar days following a date identified in the above schedule of compliance, the permittee shall submit either a report of progress or, in the case of specific actions being required by identified dates, a written notice of compliance or noncompliance, any remedial actions taken, and the probability of meeting the next scheduled requirement.

12. The permittee shall achieve compliance with the Cooling Pond Maintenance Program requirement (Part I, Section A-29) in accordance with the following schedule. All submittals shall be to the Chief of the Surface Water Quality Division of the Department of Natural Resources.

a. Submit a final plan for approval for the Cooling Pond Maintenance Proqram on or before October 26, 1984.

13. The permittee shall achieve compliance with the Tittabawassee River, Cooling Pond and Dewatering Discharge Water Quality Monitoring Program requirement (Part I, Section A-30) in accordance with the following schedule. All submittals shall be to the Chief of the Surface Water Quality Division of the Department of Natural Resources.

a. Submit a final plan for approval for the Tittabawassee River and Coolfng Pond Water Quality Monitoring requirenient on or before October 26, 1984.

14. The permittee shall achieve compliance with the Release of Unharmed Fish to the Tittabawassee River requirement (Part I, Section A-31) in accordance with the following schedule. All submittals shall be to the Chief of the Surface Water Quality Division of the Department of Natural Resources.

a. Submit a final plan for approval for the Release of Unharmed Fish to the Tittabawassee River requirement on or before October 19, 1984.

15. The permittee shall achieve compliance with the Avifauna Disease Prevention and Contol Program requirement (Part I, Section A-32) in accordance with the following schedule. All submittals shall be to the Chief of the Surface Water Quality Division of the Department of Natural Resources.

a. Submit a final plan for approval for the Avifauna Disease Prevention and Control Program on or before October 26, 1984.

16. The permittee shall achieve compliance with the PERM requirements of Part I, A-33 of this permit in accordance with the following schedule. All submittals shall be to the Saginaw District Supervisor of the Surface Water Quality Division.

a. On or before Hovember 9, 1984 , submit and receive approval of a "PERM".

h nn riv, hafni-cf, vi, 9-

Permit No. M1 002668 Page I of 4 PART II A. MANAGEIMEN1T PEQUI.'E.E-TS 1: Change in Discharge All discharges authorized herein shall be consistent with the terms and conditions of this permit. The discharge of any pollutant identified in this permit m~ore frequen:ly than or at a level in excess of that authorized shall constitute a violation of the permit. Any anticipated facility 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 such changes will not violate the effluent limitations specified in this permit, by notice to the permit issuing authority of such chances.

Following such notice, the permit may be modified to specify and limit any poiiutarn:.s not previously limited.

2. Containment Facilities The permittee'shall provide approved facilities for containment of any accidental losses of c~ncentrated solutions, acids, alkalies, salts, oils, or other polluting materials in accordance with the requirements of the Michigan ater Resources C,.mission Rules, Part 5.

3. Operator Certification The permittee shall have the waste treatment facilities under the di-*ct suoervision of an operator ceartified by t*.ie Mifchican Water Resources Co,.isslon, as required by Section 6a of the Michigan Act.

4. honcom=.iance Notification If, for any reason, the permittee does not comply with or will be unable to comply with any daily maximum effluent limitation specified in this permit, the per-mittee shall provide the Regional Administrator and 'the Stalte with the follcwing information, in writ-ing, within five (5) days. of becoming aware of such condition:

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

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

5. Spill Notification The permittee shall irrnediately report any spill or loss of any product, y-product, intermediate product, oils, solvents, waste material, or any other polluting substance which occurs to the surface or groundwaters of the state by calling the Cepartn.enc of Natural Rescurces 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Emergency Response telephone number l.8OO-292-4706; and, the permittee shall within ten (10) days of the spill or. loss provide :he State with a full written explanation as to the cause-and discoverv of the soil] or loss, clean uo and recovery measures taken, preventative

-permit No. MI 004265-8 Page 2 of 4

6. Facilities Operation The permittee shll at all tim.es maintain in good working order and operat-.

as efficiently as possible, all treatment or control ,aciiities or systems ins?-alied or used by the permittee to achieve compliance with the tarms and conditions of tnis perni t.

7. Adverse Impact The permittee shall take all reascnable steps to minimize any -adverse'impeact to navigable waters resulting from nQnccmpiiance with any effluent limitations specified in this permit, including such accelerated or additicnal monitorig as necess~ary to determine the nature and impact of the noncomplying discharge.

8. By-passing Any diversion from or by-pass of facilities necessary to maintain compliance with the terms and conditions of this per-mit is prohibited, except (i) where unavoid-able to prevent loss of life or severe property damage, or (ii) where excessive st.orm drainage or runoff -.wiuid damage any facilities necessary for compliance with tne effluent limic?*ions and prohibitions of this permit. The oermittae. shall pr.,mp,:ly notify the Michigan 'ater Resources Con.mission ana the Regional Administrator, in writing, of such diversion or by-pass.

9. Removed Substances Solids, sludges, filter backwash, or other pollutants removed fr-m cr resulting from trea..en:.or* control of wastewaters shall be disposed of in a manner such as to prevent any pollutant from such materials from entering ravigabih wat-rs, or the entry, of toxic or harmful contaminants thereof onto the groundwaters in concentrations or amounts detrimental to the groundwater resource.

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

a. Provide an alternative pov.er source sufficient to operate facilities utilized by parmittee to maintain ccmpliance with the effluent limitations and conditions of this permit which provision shall be indicated in this permit by inclusion of a specific compliance date in each appropriate "Schedule of Compliance for Effluent Limitations",

or

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

• .RESPONSIS B' Ll'IE W. TEp~t:.IrES S. Right of -"ntry The permittee shall allow t*e Executive Secretary of the Michigan Water Resources CorIAission, the Regional Administrator and/or their authorized repre-sentarives, upon t*;e presentation of the credentials:

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

b. At reasonable times to. have eccess to and copy any records required to be kept under the .tears and conditions of this permit; t'o inspect any monitoring equilpm.nt or mcnitoring method required in this permit; an& to sample any discharge of pollutants.

2. Transfer of Owinership or Corntrol In the event of any change in c=ntrol or c'wnership of facilities fr'om which the authorized discharge emanate- -e oermittee shail notify the suczceding owner or controller of :he existence c. this permit by ietzer, a copy of which shall. be forwarded to the Michigan 'm'ater Resources Co*R, ission and the Regional Administrator.

3. Availability of Reports Except for data determined t-o be confidential under Section 303 of the Act and .u1e 212- of the Water Resources Cormission Rules, Part 21, all reports preparea in accorcance with the terms of rnis permit shall be avaiiao*e for ,oublic inspection a- the o-.-icas of the State '.a-.ar Pollution Control Agency and the Regional Administrator. As required by the Act, eff"luent dat% shall not be consider-e confidential. Knowingly making any false statement on any such report may result in the imposition of criminal penalties as provided for in Sectlcn -09 of the Act and Sections 7 and 10 of the iMichigan Ac,:.

4. Permit Modification After notice and opportunity for a hearing, this permit may be modified.,

isuspended, or revoked in whole or in part during its ter.m for cause including, but nor limited to,. the following:

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

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

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

o. MI 0042568 Page 4 .of 4

5. Toxic Pollutants Notwithstanding Part 11, B-4"above, if a toxic effluent standard or rohibition (including any schedule of cOmnpiiance specified in such effluent tandard or prohibition) is established under Section 307(a) of the Act for a

.oxic pollutant which is present in the discharge and such standard or pro-.

,ibition is more stringent than any limitation for such pollutant in this per-nit,

.hi.s permit shall be revised or modified in accordance with the toxiý effluent

,:a:dard or prohibition and the permittee so notified.

6. Civil and Criminal Liability Except as provided in permit conditions .on "By-passing" (Part I1, A-3) ind Power Failures" (Part i1, A-10), nothing in this permit shall be construed to Relieve the permittee from civil or criminal penalties for noncompliance, whe-her

)r not such noncompliance is due to factors beyond his control, such as accidents,

.quipment breakdowns, or labor disputes.

7. Oil and Hazardous Substance Liability

,iothirg in this. cermit shall be construe'a to. preclude the institution of legal action or reliieve thI2 parmittee from any responsibilities, I iabil itiess, nalties to which the permittee may be subject under Section 311 of the Ac-.

8. State La-is Nothing In this permit shall be construed to preclude the institution of any legal action or reiieve the permittee from any responsibilities, .labilities, or penalties established oursuant to any applicable State law or regulation under authority preserved t.y Sec:ion 510 of the Act.

9. .1roperty Rights The issuance of this permit does not convey any.property rights in either real or pe,'sonal property, or any exclusive privileges, nor does it authorize any Federal, State or local laws or regulations, nor does it obviate the necessity of obtaining such permits or approvals from other units of government as may be required by law.

10. Severability The provisions of this permit are severable, and if any provision of this permit, or the application of any provision of this permit to any circumstances, is held invalid, the application of such provision to other circumstances, and the r-nainder of this permit, shall not be affected thereby.

11. Notice to Public Utilities It is further made a condition of this permit that the applicant give notice to public utilities in accordance with Act 53 of the Public Acts of 1974, being section 460.701 to 460.718 of the Michigan Compiled Laws, and comply with each of the

CONSUMERS POWER COMPANY Midland Nuclear Power Plane Midland, Michgian MI 0042668 The thermal mixing zone for-outfall 001, for the purpose of evaluating compliance with the water quality standards, is defined as the area enclosed within the right 1/4 of the Tittabawassee River starting from the point of discharge and extending 1,700 feet downstream from the discharge.

The mixing zone for outfall 002, for the purpose of evaluating compliance with water quality standards, is defined as the area enclosed within the right 1/4 of the Bullock Creek from the point of discharge to the Tittabawassee River.

The mixing zone for outfall 003, fbr the purpose of evaluating compliance with water quality standards, is defined as the right 1/4 of the Tittabawassee River starting from the point of discharge and extending 300 feet downstream.

Attachment 3 consumers Power Company General Offices: 212 West Michigan Avenue. Jackson, Michigan 49201

• Area Code 517 788-0550 June 12, 1985 PBL-0685-2 80EPI0. 1 Mr Paul D Zugger, Chief Water Quality Division Department of Natural Resources PO Box 30028 Lansing, MI 48909 Dear Mr Zugger On October 4, 1984 you approved the study plans required by Special Conditions 30, 31 and 32 of the Midland Plant NPDES Permit No M10042668. Implementation of the plans has been completed. The enclosed data report entitled "Midland Cooling Pond Dewatering Program Summary Report" summarizes the study results.

Yours very truly P Bradley Latvaitis Senior Aquatic Biologist CC TLWalkington, DNR - Saginaw KZollner, Jr, DNR - Lansing

MIDLAND COOLING POND DEWATERING PROGRAM

SUMMARY

REPORT Prepared By Consumers Power Company June 1985 MI0585-0023A-ENO3

1 INTRODUCTION In July 1984, Consumers Power Company commenced the shutdown of the Midland Nuclear Plant. The orderly shutdown process placed the Plant in a caretaker/

layup status. To allow demobilization of dewatering wells and a freezewall system required to support underpinning construction activities, the shutdown included dewatering of the Midland cooling pond. Pond dewatering also allowed the Company to efficiently maintain the integrity of auxiliary building excavations and to avoid potential safety hazard, soil stability and building monitoring equipment maintenance concerns.

The Midland cooling pond was an artificially created water body with a surface area of 880 acres and a design volume of 12,600 acre feet (Figure 1). The main purpose of the cooling pond was to provide a closed loop to supply and receive cooling water from the circulating and service water systems of the Midland Plant. The pond was filled with water pumped from the Tittabawassee River during the spring of 1978 and winter of 1978-79. The top of the imper-vious cooling pond dikes are at elevation 632 feet Mean Sea Level (MSL).

Water elevation at design full pond conditions is 627 feet MSL. On the average, pond bottom is at elevation 615 feet MSL. The lowest area of the pond is at elevation 601 feet MSL. The northeast corner of the Midland pond includes a 39 acre area with pond bottom elevation to 593 feet MSL. At elevation 604 feet MSL, the northeast pond corner contained 272 acre feet of water.

During Midland Plant operation, discharge from the Midland pond was to take place from outfall 001, the blowdown discharge structure (Figure 1). Using Outfall 001, the pond could be lowered to an elevation of about 618 feet MSL, the centerline of the pond discharge pipes. At elevation 618 feet MSL, the cooling pond contained approximately 4800 acre feet of water. Since this outfall was only useful for partial pond dewatering, use of the pond outlet structure (Outfall 003) to completely dewater the pond (Figure 1) was neces-sary. Therefore, on September 6, 1984 a request to modify NPDES Permit No MI 0042668 was submitted. On October 18, 1984, the Michigan Water Resources Commission (MWRC) issued a modified NPDES Permit which authorized complete dewatering of the Midland cooling pond through Outfall 003 and the continued discharge of stormwater runoff and site dewatering from the dewatered pond.

Pond dewatering was initiated on October 19, 1984 and completed on December 19, 1984. This report summarizes dewatering program activities and provides a tabulation of data collected as required in NPDES Permit Parts I.A.1, 30, 31, 32 and 33. The report consists of two sections, results and summary. The results section includes the following: pond water discharge, water quality, fish relocation, residuals management and avifauna observa-tions. Data are provided in the report appendix.

MI0585-0023A-EN03

FIGUrE 1 MIDLAND POWER PLANT COOLING POND p.- s"Is Wage *?UMvokel Dow owe folcloAfte twil~ft

• ~r--~ top

,v.u a ,ciAmse stwnvvei (Outfall 001) ii N

o 0lu Structure SCAM. NI WfR OR 0 SCALE IN FIECT

3 RESULTS Rond Water Discharge Cooling pond discharge through Outfall 001 was conducted during the first 18 days of October 1984 in accordance with the effluent limitations and monitor-ing requirements of NPDES Permit MI 0042668 issued November 2, 1982. During this period, pond elevation dropped from 625.4 feet MSL to 619.3 feet MSL.

Cooling pond dewatering using Outfall 003 commenced at 0130 hours0.0015 days <br />0.0361 hours <br />2.149471e-4 weeks <br />4.9465e-5 months <br /> on October 19, 1984 in accordance with the effluent limitations and monitoring requirements of modified NPDES Permit MI 0042668 issued October 18, 1984.

Appendix A summarizes pond discharge from Outfall 003.

By NPDES Permit definition, complete dewatering was achieved on December 19, 1984 when the elevation of water first decreased to a level of 600 feet MSL in the emergency cooling water reservoir and to a level of 601 feet MSL at Outfall 003. During the 62-day dewatering period (October 19 to December 19),

pond water was discharged on 48 days with continuous discharge (24 consecutive hours) on 29 days. To.meet NPDES effluent limitations, maintain dike stabili-ty and construct interior dikes and settling basins as required in the Cooling Pond Maintenance Program (NPDES Part I.A.29), discharge was limited on 19 days and terminated on 14 days of the 62-day dewatering period (Appendix A).

Pond water discharge flows ranged from 241.6 cfs (156 million gallons) on October 7 to 17.1 cfs (11 million gallons) on November 19. The outfalls were observed daily during discharge. Erosion of the discharge channel, Tittabawassee River banks or stream beds did not occur. Additionally, flood conditions did not occur in the Tittabawassee River during the cooling pond discharge period.

Water Quality A list of water quality parameters, methods and monitoring frequency required per Parts I.A.1 and I.A.30 of the modified NPDES Permit is provided in Table

1. Sampling was conducted in the pond prior to initiation of dewatering (Appendix B), and in the Tittabawassee River and discharge effluent during the dewatering period (Appendix C). River and effluent sample collection loca-tions are illustrated in Figure 2. Tittabawassee River samples were collected at two locations immediately upstream (Locations 1 and 2), at four locations in a transect approximately 300 feet downstream (Locations 3, 4, 5 and 6), and at the effluent channel (Location 7).

As required, when the pond elevation fell below 610 feet MSL (October 31, 1984) effluent sampling was conducted with an ISCO Model 1680 composite sampler. Each composite sample was comprised of collections taken at three-hour intervals over the discharging period. During days when discharge was conducted for less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Appendix A) and an insufficient compos-ite sample, by volume, was collected, a grab sample was collected and ana-lyzed. Composite samples (or grab samples when substituted) were analyzed for dissolved oxygen, five-day biochemical oxygen demand, total suspended MI0585-0023A-EN03

4 TABLE 1 - Water Quality Parameters, Methods, and Monitoring Frequency PARAMETER METHOD FREQUENCY*

Temperature 1,2,3 pH US EPA 1979a 150.1 1,2,3 BOD 5 APHA 1 9 7 6 b, p543 1,2,3 DO APHA 1976, p 4 40 1,2,3 Phosphorus (Total) APHA 1976, p 4 7 9 1,2,4 Ammonia as Nitrogen US EPA 1979, 350.3 1,2,3 TDS APHA 1976, p 9 4 1,2,'4 TSS APHA 1976, p9 2 1,2,3 Oil and Grease Observation 2,3 Fecal Coliform APHA 1976, p801 2,4 Hydrogen Sulfide APHA 1980c, p4 4 8 2,3

• Monitoring Frequency 1 Once in the pond prior to dewatering.

2 Weekly in the river at pond elevations greater than 610 feet MSL. Twice weekly in the river at pond elevations less than 610 feet MSL.

3 Twice weekly in the effluent at pond elevations greater than 610 feet MSL.

Daily .in the effluent at pond elevations less than 610 feet MSL.

4 Twice weekly in the effluent at pond elevations less than 610 feet MSL.

a American Public Health Association (APHA), 1976. Standard Methods for the Examination of Water and Wastewater, 14th Edition American Public Health Association, American Water Works Association and Water Pollution Control b Federation, Washington, DC.

US Environmental Protection Agency (EPA), 1979. Methods for Chemical c Analysis of Water and Wastes, EPA 60014-79-020.

As reference a except 15th edition, 1980.

M10585-0023A-ENO3

FIGURE 2 5

MIDLAND POND DEWATERING SAMPLE COLLECTION LOCATIONS L

Tittabawassee River Midland Plant Location of Pond Outlet Cooling. Pond Structure

1. Upstream of discharge, west side of river.

2. Upstream of discharge, east side of river.

3. Near edge of pond discharge mixing zone.

4. Middle of pond discharge mixing zone.

5. Far edge of pond discharge mixing zone.

6. Outside. of the pond discharge mixing zone.

Cooling pond effluent.

6 solids and ammonia nitrogen. In addition, daily effluent grab samples were collected and analyzed for pH, temperature, oil and grease, sulfide and molecular hydrogen sulfide (Appendix C). On days when river samples were collected, effluent grab samples were also analyzed for total dissolved solids, total phosphorous and fecal coliform bacteria (Appendix C).

All NPDES permit water quality monitoring requirements were fulfilled except that one grab sample was not collected on November 28 and a composite sample was lost on December 12 due to sample line freezing. Also, mass loading limits for BOD were apparently exceeded on October 26 and October 30 and documented in *NPDES Notification" Incident No MID-84-12-AD01 (see Appendix D).

Comparing results of effluent grab samples to upstream river grab samples (Appendix C), the effluent generally consisted of higher dissolved oxygen, total suspended solids, BOD5 and slightly increased pH, as anticipated.

Effluent temperatures and total phosphorous were lower, overall. Values for sulfide, molecular hydrogen sulfide, total dissolved solids and ammonia nitrogen were similar in the river and effluent. Fecal coliform values were also quite similar except when compared to the highest river values in October when effluent fecal coliform counts were much less. Water quality analysis laboratory control results are provided in Appendix E.

Fish Relocation The Midland pond was filled with water pumped from the Tittabawassee River during the spring of 1978 and the winter of 1978-1979. During pond fill, small aquatic organisms such as fish eggs and larvae passed through the 3/8-inch traveling screens on the pond intake system and survived to inhabit the pond. Some Juvenile fishes were also carried over the traveling screens and became pond inhabitants. Semiannual pond fish collections indicated a diverse and abundant fishery inhabited the pond. Part I.A.31 of the NPDES permit required an effort to release unharmed fish to the Tittabawassee River.

In compliance with this permit requirement, a fish relocation program was initiated on September 21, 1984. During the dewatering period four trap nets were set continuously and tended as necessary. In an attempt to reduce fish mortality due to crowding, following completion of pond dewatering in Decem-ber, two trap nets were fished from January through March in the emergency cooling water reservoir.

The relocation program was very successful. A total of approximately 25,000 fish weighing about seven tons were released unharmed into the Tittabawassee River (Appendix F). In addition, an undetermined number of fish were dis-charged during the dewatering process. During therelocation program, only about 1350 pounds of fish were either selectively removed (600 pounds of carp) or injured and removed for disposal. Of the 1350 pounds, 1000 pounds were taken during January when weather conditions precluded transfer.

M10585-0023A-EN03

7 Residuals Management To minimize the potential for water quality deterioration, pollution of air and nuisance conditions due to oxidation of organic material, pond dewatering was conducted during cool water temperatures when the water was most saturated with oxygen and the process of organic deterioration was minimal. In addi-tion, Part I.A.33 of the NPDES permit required a program for effective residu-als management (PERM). Monthly PERM reports detailing residuals management were prepared and submitted to the MDNR from October through April.

Prior to initiation of dewatering, between September 20 and 27, 1984, mechani-cal harvesting of aquatic macrophytes (vegetation) was accomplished. Harvest-ing resulted in the removal and disposal of approximately 240 cubic yards of aquatic vegetation. This material was disposed of at the City of Midland landfill. Vegetation removal helped maintain discharge water quality, aided the collection of fish, and helped minimize avifauna disease and nuisance conditions.

Fish which were not collectable by trap net during the fish relocation effort were collected by commercial seine. At the completion of dewatering in late December and following ice-out when bottom conditions allowed (April), seines were used to collect fish in the deepest remaining pond water (the former emergency cooling pond). Approximately 32,000 pounds of fish were removed in December and 24,000 pounds in April. The vast majority of these fish (approx-imately 98%) were carp and gizzard shad. All were disposed of at the City of Midland landfill.

In addition, about 6,835 pounds of dead fish were hand-dipped, double bagged and disposed of at the City of Midland landfill. These fish were mainly gizzard shad and juvenile sunfish that experienced winterkill. Including seine collections (56,000 pounds), fish relocation program losses (1,350 pounds) and winterkill losses (6,835 pounds), approximately 64,185 pounds (80.3 cubic yards) of fish were disposed of at the City of Midland landfill.

Finally, daily pond- perimeter observations were conducted to detect obnoxious odors. No odors were detected or citizen's complaints received. The PERM and fish relocation program proved highly successful.

Avifauna Observations Although the collection and disposal of organic material and cool weather helped to reduce the potential for avifauna disease, a program of field observations was conducted daily, beginning October 1, 1984, per NPDES Part I.A.32 requirements to monitor pond avifauna for disease symptoms and identify situations conducive to disease development. No evidence of disease potential or unusual disease incidence was observed. The avifauna monitoring log is provided in Appendix G. At the completion of logged observations on December 15, 1984, daily observations by Plant personnel continued through April 1985 with similar results.

MI0585-0023A-EN03

8

SUMMARY

During Midland pond dewatering, close contact was maintained with the Michigan Department of Natural Resources regarding dewatering flow rate, water quality sampling, fish relocation, collection and disposal of organic material, odor observations and avifauna disease monitoring. Compliance was achieved with NPDES permit Parts I.A.1, 30, 31, 32 and 33. The objectives of the cooling pond dewatering program, to dewater the pond and to manage the potential environmental effects, were met in a timely and cost effective manner.

MI0585-0023A-EN03

APPENDIX MIDLAND POND DEWATERING PROGRAM

SUMMARY

REPORT CONTENTS A. Summary of 1984 pond dewatering discharge from Outfall 003, Midland Plant.

B. Results of background pond water quality monitoring conducted at Midland Plant on September 21, 1984.

C. Midland pond dewatering program water quality monitoring results.

D. NPDES Notification Incident No. MID-84-10-ADOI.

4. Water quality analysis laboratory quality control results for the. Midland Pond Dewa-tering Program, 1984.

F. Approximate number and weight of fish collected in the Midland cooling pond and relocated in the Tittabawassee River September 1984 to March 1985.

G. Midland Energy Center cooling pond dewatering avifauna disease contingency plan monitoring log - 1984.

MI0585-0023A-EN03

1 of 2 APPENDIX A

SUMMARY

OF 1984 POND DEWATERING DISCHARGE FROM OUTFALL 003, MIDLAND PLANT Discharge Rate Discharge Date (cfs/mgd) Period (hrs) Comment 10/19 188.3/122 20.0 Start 0130-Discharge terminated to repair flow meter 10/20 158.9/103 16.6 Additional flow meter adjustments 10/21 128.9/81 14.3 Regulated in response to 10/15 BOD5 data 10/22 128.4/83 15.0 10/23 131.2/85 15.0 10/24 187.3/121 21.8 Regulated in response to 10/19 BOD 5 data 10/25 231.5/149 24.0 10/26 240.1/155 24.0 10/27 241.6/156 24.0 10/28 238.4/160 25.0 Time change resulted in 25-hour day 10/29 229.7/148 24.0 10/30 199.1/129 23.8 10/31 48.6/31 7.8 Regulated in response to 10/26 BOD data and to maintain dike stagility 11/01 71.1/46 13.2 Regulated in response to pond turbidity observations and to maintain dike stability 11/02 0 0 11/03 0 11/04 0. 0 11/05 49. 1/32 14.8 Regulated in response to pond turbidity observations.

11/06 77.0/50 24.0 11/07 27.6/18 9.6 Regulated in response to pond turbidity observations. Main pond reduced to channels.

11/08 30.4/20 9.6 Regulated in response to pond turbidity observations.

11/09 21.8/14 9.7 Regulated in response to pond turbidity observations.

11/10 0 0 11/11 0 0 11/12 0 0 11/13 34.5/22 14.8 Regulated in response to water accumulation (drainage west to east) and turbidity observations.

11/14 52.4/34 24.0 11/15 52.8/34 24.0 11/16 30.6/20 14.0 Discharge terminated to allow water to accumulate.

11/17 0 0 MI0585-0023A-EN03

2 of 2 APPENDIX A

SUMMARY

OF 1984 POND DEWATERING DISCHARGE FROM OUTFALL 003, MIDLAND PLANT Discharge Rate Discharge Date (cfs/mgd) Period (hrs) Comment 11/18 0 0 11/19 17.1/11 6.5 Discharge terminated in preparation for settling basin and dike construction.

11/20 0 0 11/21 0 0 Initiate mechanical pumping from circulating water discharge area to emergency pond and emergency pond to settling basin.

11/22 0 0 Pumping emergency pond.

11/23 0 0 Pumping emergency pond (OFF 1220 hours0.0141 days <br />0.339 hours <br />0.00202 weeks <br />4.6421e-4 months <br />).

11/24 0 0 11/25 0 0 11/26 36.6/24 15.3 Regulated in response to water accumulation and turbidity obser-vations. Resume pumping.

11/27 24.1/16 10.8 Regulated in response to pond turbidity and water availability.

11/28 25.7/17 12.4 Regulated in response to turbidity observations. Resume pumping.

11/29 47.2/30 24.0 11/30 45.4/29 24.0 12/01 44.8/29 24.0 Regulated to maintain flow.

12/02 41.4/27 24.0 12/03 37.1/24 24.0 0845 to 1525 hours0.0177 days <br />0.424 hours <br />0.00252 weeks <br />5.802625e-4 months <br />, generator repair, flow record lost.

12/04 37.8/24 24.0 12/05 37.9/25 24.0 Pumping circulating water discharge area to emergency cooling water reservoir.

12/06 49.1/32 24.0 12/07 49.1/32 24.0 12/08 49.1/32 24.0 Regulated to maintain flow.

12/09 49.1/32 24.0 12/10 49.8/32 24.0 12/11 50.9/33 24.0 12/12 50.0/32 24.0 12/13 52.4/34 24.0 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />, add 16" pump to emergency cooling water reservoir.

Regulated to maintain flow.

12/14 52.2/34 24.0 12/15 49.2/32 24.0 12/16 59.1/38 24.0 12/17 55.6/36 24.0 12/18 52.3/34 24.0 12/19 40.0/26 18.0 Discharge terminated at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />; pond dewatering complete.

MI0585-0023A-EN03

ANDIX B RESULTS OF BACKGROUND POND WATER QUALITY MONITORING CONDUCTED AT MIDLAND PLANT ON SEPTEMBER 21, 1984 Quadrants and Stratification Zones*

Parameter Units P1-U PI-M PI-L P2-U P2-M P2-L P3-U P3-H P3-L P4-U P4-M P4-L 8.1 8.2 8.1 8.1 8.i 8.1 pH SU 8.2 8.2 8.0 8.5 8.5 8.5 oC Temperature 18 18 18 18 18 18 18 18 18 19 18 18 Dissolved Oxygen mg/L 8.4 8.4 8.4 8.5 8.5 8.5 8.3 8.2 8.2 8.2 8.2 8.1 BOD (5) mg/L 1.6 3.0 1.6 1.4 2.0 2.9 1.6 1.4 2.0 1.6 1.8 2.4 Total Phosphorus mg/L as P 0.04 0.04 0.01 0.03 0.03 0.01 0.04 0.03 0.02 0.02 0.02 0.02 Ammonia, NH3 as N mg/L as N <0. 1 0.1 <0. 1 <0.1 <0.1 <0.1 <0.1 <0.1 <0. 1 <0. 1 <0. 1 <0. 1 Total Dissolved Solids mgfL 369 375 381 368 380 386 384 373 379 392 384 387 Dried at 180*C Total Suspended Solids mglL 8 8 29 6 8 43 6 8 20 4 8 17.

Dried at 105*C

• Quadrant Locations Stratification Zones P - Northwest U - Within one meter of the surface P 2 - Southwest M - Mid-depth P 3 _ Southeast L - Within one meter of the bottom P4 Northeast M1II84-0030A-EN03

APPEND. MIDLAND eOND DEWATERING PROGRAM Page 1 of 9 WATER QUALITY MONITORING RESULTS

___________ - _______________ - 7 T - 1 Molecular Oil (2)

Date Time pH Temp DO BOO Sul fide H2 S TSS TDS NH 3 -N Total-P Fecal (1)

SAMPLE ID Sampled Sampled (S.U.) (*C) (mg/L) (mg/L) (uq/LI (ug/L) (mg/L) (mg/L) (mg/L) (mq/L) Coliforms Grease River 1 10-19-84 1030 8.0 .19 9.2 2.4 61.5 5.9 10.6 498 0.15 .0.05 66 -

River 2 " 1050 8.1 16 9.1 1.5 58.6 4.4 10.0 430 0.45 0.04 220 -

River 3 " 1105 8.3 16 9.4 1.4 55.8 3.0 31.2 376 <0.14 0.02 INTC -

River 4 " 1120 8.2 15 9.3 1.5 57.5 3.7 21.2 502 0.12 0.05 TNTC -

River 5 " 1135 8.3 15 9.3 1.7 51.2 2.7 14.0 548 0.20 0.05 TNTC -

River 6 " 1150 8.3 15 9.1 2.3 51.2 2.7 10.6 444 0.84 0.06 TNTC -

£ffluent Gray to 1230 8.4 16 9.6 1.7 48.2 2.0 27.2 382 <0.14 0.02 14 -

River 1 10-23-84 0917 8.3 11.2 9.6 2.7 64.4 3.4 10.6 516 0.22 0.08 TNTC -

River 2 It 1046 7.8 10.4 9.2 7.2 58.6 8.7 21.2 528 1.2 0.04 1000 -

River 3 " 1048 8.2 9.7 10.0 2.2 54.3 3.5 12.8 422 <0.14 0.01 450 River 4 to 1057 8.3 10.8 10.1 1.9 52.7 2.8 11.4 428 <0.14 0.05 750 -

River 5 i 1107 8.3 10.6 10.1 2.6 49.7 2.6 9.8 554 0.16 0.03 1375 -

River 6 of 1110 8.2 9.7 9.7 3.8 51.2 3.3 11.8 466 0.85 0.09 1145 -

• Lfluent Grab i 1115 8.1 10.2 9.4 1.4 48.2 3.6 9.8 368 <0.14 0.05 55 -

Effluent Grab 10-26-84 1205 8.2 10.2 9.9 2.0 66.1 5.6 8 398 <0.14 0.04 -

River 1 10-30-84 1030 8.2 10.4 9.6 2.9 <10.2 <0.65 7 204 <0.14 0.06 20 -

River 2 " 1038 8.2 10.1 9.1 3.0 <10.2 <0.65 4 280 0.81 0.08 177 -

River 3 " 1045 8.3 10.6 9.9 2.4 10.2 0.54 13 480 <0.14 <0.01 130 -

River 4 '. 1052 8.4 10.5 10.0 2.9 17.8 0.57 22 710 <0.14 <0.01 50 -

River 5 " 1100 8.3 10.4 9.6 2.3 10.2 0.54 6 400 <0.14 0.05 120 -

River 6 1105 8.3 10.5 .9.5 2.2 11.9 0.63 6 164 0.30 0.15 0 Elfluent Grab 1150 8.5 11.1 10.0 2.2 14.4 0.31 24 478 <0.14 <0.01 121 -

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APPEND MIDLANL -o1ND DEWATERING PROGRAM Page 2 of 9 WATER QUALITY MONITORING RESULTS Molecular oi 1 (2)

Fecal (1) £ Date Time pH Temp DO OD Sul fide H2 S TSS TDS NH 3 -N Total-P (m/LI (ma/IL tmaJLI Pol iforms SAMPLE ID Sampled Sampled (S.U.) (*C) (mq/L) (mq/L) (uq/Ll I (un/Ll (mo/LI Etfluent Grab 11-1-84 1100 7.9 13 20.4 2.4 Ii Composite I 5:- 4-- 61100 ,9.7 1.1 22- _-<0-14 8.1 5.8 10.4 2.6 13,7 0.1 27.0_ 378 <0,14 0.01 66 Composite 11-O6-81 1030 1100 7.7, 6.6 10.4 3.7 C12.9 e2.3 3.8 332 <0.14 0.04 0 -

River 1 11-6-84 2.4 <12.9 <2.3 5.6 328 1.1 0.14 290 -

River 2 i 1105 7.7 7.4 9.8 1110 7.9 6.3 10.5 2.3 (12.9 C1.5 6.2 356 <0.14 0.04 25 -

River 3 .

1.8 <12.9 <1.5 2.8 350 <0.14 0.06 90 -

Ritver 4 _" 1115 7.9 6.5 10.4 1.6 <12.9 <1.2 3.0 330 <0.14 0.07 0 -

River 5 .. .... 1120 8.0 6.5 10.2 13.7 1.6 3.6 330 0.62 0.05 0 -

River 6 1125 7.9 6.9 9.8 2.1 13.7 41.0 36.4 378 <0.14 <0.01 66 -

Effluent Grab 1200 8.1 5.8 10.4 1.7

. Composite 4__8_

_ 9.8 1 4.7 34.2 .< 0.14 Effluent Grab 11-7-84 1045 7.8 4.4 38.2 5.7 Effluent Grab 11-8-84 1100 8.0 6.0 21.8 2.1 Composite ____ 10.4 ~____2.0__ 50 ____ 0.17 ____

Effluent Grab 11-9-84 1006 8.2 6.3 27.2 2.3 53 ... _

P.. .4.4 44 4.

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APPEND. MIDLAN. .OND DEWATERING PROGRAM Page 3 of 9 WATER QUALITY MONITORING RESULTS 7  :. V T - - - - I - - - -

Holecul ar Oil (2)

Date Time pH Temp DO BOO Sulfide H22S .TSS TDS NH 3 -N Total -P Fecal (1) &

SAMPLE ID Sampled Samoled (S.U.3 (*C) (mg/L) (mo/L) (uo/L) (ua/Ll (wi Ll (mo/LI 1mm i' I.,. JT. P-1 4 For.ms River 1 11-13-84 1422 8.5 3.4 11.5 2.3 < 11.5 < 0.31 7.5 352 < 0.14 0.06 40 -

River 2 to 1426 8.4 4.1 11.0 2.2 11.5 0.37 7.0 348 < 0.14 0.04 145 River 3 ', 1429 8.4 3.0 11.4 2.2 18.1 0.58 9.0 374 < 0.14 0.07 0 River 4 " 1432 8.4 3.1 11.4 2.4 11.5 0.37 7.8 366 < 0.14 0.14 5 River 5 " 1435 8.4 3.3 11.2 2.0 14.8 0.47 7.6 380 < 0.14 0.08 10 -

River 6 " .1439 8.4 4.1 10.8 2.5 < 11.5 < 0.37 9.2 354 < 0.14 0.07 0

£fiuent Grab ' 1532 8.5 3.0 11.6 3.4 13.7 0.37 7.4 378 < 0.14 0.07 3 Gomoste1113:8 oo Composite .. 1_-__-8_000 1000 11.0 1.8 2.0 < 0.14 Effluent Grab 11-14-84 1000 8.2 2.9 < 11.5 < 0.74 _

Composite 4* __8 _ 11.7 2.9 5.5 <0.14 Effluent Crah 11-15-84 1000 8.0 3.8 < 11.0 < 1.1 River 1 11-16-84 0800 8.2 3.8 10.6 2.3 < 11.0 < 0.7 3.5 356 < 0.14 0.08 45 River Z - 0805 8.2 4.0 10.2 2.8 < 11.0 < 0.7 3.5 352 1.2 0.07 0 -

River 3 0810 8.3 3.4 10.5 2.7 < 11.0 < 0.6 3.5 362 <0.14 0.05 0 -

River 4 0815 8.3 3.6 10.6 3.7 < 11.0 < 0.6 5.5 368 <0.14 0.06 0 -

River 5 0820 8.3 3.6 10.6 2.9 < 11.0 < 0.6 1.5 378 <0.14 0.14 0 -

River 6 0825 8.3 3.9 10.4 3.3 < 11.0 < 0.6 4.0 360. 0.57 0.04 45 -

Effluent Grab 0845 8.2 2.0 11.2 3.4 < 11.0 < 0.7 28.5 368 <0.14 0.08 42 -

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APPENL MIDLAK. ND DEWATERING PROGRAM Page 4 of 9 WATER QUALITY MONITORING RESULTS

- - -

'7 Molecular Oil (2)

Time pH Temp DO BOD Sul fide H2 S TSS TDS NH3 -N Total-P Fecal (I) * &

Date (S.U.I (mg/L] (uq/L) (uq/L) (mci/LI (mq/L) (mq/LI (mc/LI Coiliforms Grease SAMPLE ID Sampled Sampled ( C) (mg/L)

River 1 11-19-84 1005 8.0 1.6 12.3 0.8 <12.6 <1.2 1.6 414 0.16 0.19 14 River 2 11-19-84 1020 8.2 2.1 11.8 2.3 <12.6 <0.8 14.8 414 1.6 0.20 is -

River 3 11-19-84 1030 8.3 0.9 12.1 1.8 <12.6 <0.7 11.2 416 <O.14 0.13 0 -

River 4 11-19-84 1033 8.3 1.4 11.9 1.4. <12.6 <0.7 6.4 422 <0.14 1,.7 -

River 5 11-19-a84 1036 8.4 1.5 12.1 1.1 <12.6 <0.4 1.4 434 <0.14 0.08 0 River 6 11-19-84 1015 8.1 1.8 11.9 0.8 <12.6 <0.9 3.4 426 1.1 0.06 200 Effluent Grab 11-19-84 1108 8.3 0.1 12.5 2.2 <12.6 <0.7 11.4 372 0.15 0.04 12_J. -

Effluent Grab 11-26-84 1010 8.3 9.0 29.7 1.6 River 1 11-27-84 1015 8.3 4.6 11.6 2.6 <11.2 <0.5 4.0 432 <0.14 0.06 5 River 2 11-27-84 1020 8.3 5.3 11.2 2.5 <11.2 <0.5 3.2 522 0.84 0.18 0 River 3 11-27-84 1035 8.3 4.8 11.4 2.3 12.9 0.5 4.4 740 <0.14 0.08 0 -

River 4 11-27-84 1040 8.3 4.7 11.2 2.6 41.2 <0.5 4.4 704 <0.14 0.23 0 -

River 5 11-27-84 1050 8.3 4.7 11.2 2.1 28.5 1.2 3.2 556 0.32 0.10 0 River 6 11-27-84 1100 8.2 5.5 10.9 2.8 28.5 1.8 4.0 530 1.1 0.10 0 -

Effluent Grab 11-27-84 1110 7.8 4.7 11.0 4.2 12.9 1.9 95.2 398 <0.14 0.01 8 -

Composite u11-27-R4 11-26-84 1010 iO _ 10.3 2.7 24.7 <0.14 A o.i I' ,I*

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APPE. MIDLA, JD DEWATERING PROGRAM P8 *,. 5 of 9 WATER QUALITY MONITORING RESULTS Molecular Oil (2)

Date Time pH Temp DO BOD Sul fide H2 S TSS TDS NH3 -N Total -P Fecal (1)

SAMPLE ID Sampled Sampled (S.U.} (0C) (mq/L) (mg/L) (ug/L) (ug/L) (mg/IL (mg/L} (mg/L) (mg/LL Coliforms Grease River 1 11-29-8 1530 8.5 3.9 12.0-- 3.0 <1 ,3 <0,3 48 330 <O.14 O.08 In.

RLver 2 11-29-8 1535 8.0 4.0 11.9 3.0 <11.] <1.1 3.6 332 <0,14 0.23 0-River 3 11-39-8z 1540 .0 4.0 .. 12.2 _-3<11._ 3 16.1 5.2 334 <0.14 0.06 0 ELuer 4 11-29-8 1545 8.1 5.9 10.8 2.1 <1 1.3 (<0.9 3.2 134 <0.SI14 0.1 --- -

R....r, B I Sci A.29 R1-9 155 11-4 2.4 <11-1 <0.9 2.8A324 <(I.-14 0-04--.--

R r 6 teU .. 111-l I .555 A.2 1.8 11.6 2.5 15A3 1.0 3.6 342 <0.14. 0to.0-Effluenr Grab __ 1-2-R0- 1210 R8. 4.0 12.2 5.0 12.6L. 1-2 26-R 372 0R 0807 4 -

2981 1330 CoMDooslte 11-30-84 1400 11.0 1.6 16.0 <0. 14 Effluent Grab 1l-30-Bd 1400 8.8 5.0 <1,.-, <0.1 Composite . __-__-__ __2_0_ Iill *. ________

12-30-28 1300 Cnqmposte .1-OI-Rd i 1nn I1.0 4.6 2_0- .14 Effluent Grab 12-01-8d 1100 8.6 4.0 12.6 0.3

=2-01-B, II00-Composite 17-O7-gg I Inn0 11.6 4.3 14.0 <0.14 Pffltiont rr.*h 17/02/R, 1300 R-2 7-7 11-A 0-9 12/02/8, 1300 rompon-.Irfa1 lTf3/R*E ngin 11.4 4-n ýPA- <0.14 rffl,,,*nr rrah [ 1710I1R ngiO A-4 7-n I5R .

Composite 13I8* 8%38 11.6

-- 5.5 8.4 <0.14 C 'I I.

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APPE. MIDL.. .OND DEWATERING PROGRAM Page 6 Of 9 WATER QUALITY MONITORING RESULTS

- - - V. V - . - r - _________

Holecular Oil (2)

Date Time pH Temp (SC DO BOD Sulfide I H2 S TSS TDS NH 3 -N Total -P Fecal (1)

• AMPI.P. 1i1 Samol ed (S.U.1 (mg/L) (mo/L) (uo/L) (mo/LI (mo/L} (ma/LI (ma/L) Coliforms Grease SAPL ID Sam.e Sam.e -SU. -.-. _

River 1 12-04-8d 1100 8.3 1.1 12.6 4.5 29.2 1.8 2.8 376 <O 14 , .220 -

River 2 12-04-8, 1105 8.2 1.2 12.4 4.0 29.2 1.8 3.2 346 0.21 0.O. 0 -

River 3 12-04-8, 1110 8.3 0.7 i2.8 4.3 29.2 1.6 4.0 378 0.17 i..0 0 -

River 4 12-04-8, 1120 8.2 0.6 12,8 4.6 26. 3 l,7 1.6 39A . 14 . O. 0 -

River 5 12-04-81 1130 8.1 0.7 12.6 4. , 32 .2 2.4 1.6 4134 <0. 14 0.3 -

River ..6 12-04-8' 1140 8.1 1.5 12.4 3.8 59.1 4.4 7.6 41A o.?fi o-Q4 Ign-Effluent Grab 12-04-8, 1200 8.7 0.1 13.4 5.7 <510.7 <0.9 22.4 366 <0-14 Q O4 _ n -

C.Qpg~site 12-05-8, 0930 17.6 4.,R_ <n-14 Effluent Grab - 1.2/ULQ8 0930 A.5 0.7 <10.7 <0.1 -_.

- 12-5-8d 0930 Com pos ite - 1 --- i-. f) 1nfl I IL. rI A i. 0_1.4

<S -A Efls ,Pnr rrab II-0*-R innn 8.8 0.7 23.3 0.24 -------

River 1 12-07-8, 1015 6.9 0 12.8 4.0 <13.0 <0.07 4.4 632 0.14 0.05 20 -

River 2 12-07-8 1020 8.8 0.1 13.0 4.7 <13.0 <0.14 13.6 510 1.1 0.05 0 -

River 3 12-07-8 1030 8.6 0 13.6 5.1 <13.0 <0.41 5.6 670 0.32 0.04 0 -

River 4 12-07-8, 1035 8.6 0 13.6 5.0 <13.0 <0.41 5.2 718 0.28 0.04 0 -

River 5 12-07-8 1040 8.7 0.1 13.6 5.3 <13.0 <0.28 7.2 700 0.18 0.05 0 -

River 6 12-07-86 1045 8.6 0.1 13.2 4.8 <13.0 <0.41 8.0. 518 0.53 0.05 0 -

Effluent Grab 12-07-8 1100 8.7 0.1 13.6 6.3 <13.0 <0.28 14.0 392 0.19 0.05 0 -

12-06-8, 1000 Composite 1 - -R _ I__

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APPENDI MIDLA,. aD DEWATERING PROGRAM Page 7 of 9 WATER QUALITY MONITORING RESULTS Molecular Oil (2)

Date Time pH Temp DO BOD Sulfide H2 S TSS TDS NH 3 -N Total-P Fecal (1) &

Samol ed 1C} (uci/LI (ma/Li SAMPLE ID Sampled (S.U.1 (mg/L) (mc/LL (ug/L}

12-7-84 SMLID Smld*C u/) (A) (ma/L) (ma /L) (m. /1.1 Col4i forms G~reasme Composite 12-8-84 1100 1000 12.4 5.3 5.6 0.15 Effluent Grab 12-8-84 1000 8.8 0.9 <13.0 <0.14 Composife 12-8-84 12-9-84 1000 1500 10.6 3.6 2.4 <0.14 Effluent Grab 12-9-84 1500 8.2 1.3 <13.0 <0.83 12-9-84 1500 Composite 12-10-84 1300 11.6 3.6 6.0 <0.14 Effluent Grab 12-10-84 1300 8.5 1.3 <13.0 <0.48 River 1 12-11-61 1430 8.4 0.8 12.4 2.0 <12.5 <0.53 2.0 536 <0.14 0.14 5 -

River 2 12-11-8ý 1440 8.3 0.9 12.3 3.2 <12.5 <0.66 2.0 444 <0.14 0.38 0 -

River 3 12-11-8 1450 8.3 0.7 12.2 1.8 <12.5 <0.66 5.2 538 <0.14 0.08 0 -

River 4 12-11-84 1500 8.4 0.6 12.2 2.2 <12.5 <0.53 2.8 554 <0.14 0.07 0 -

River 5 12-11-8, 1510 8.4 0.7 13.2 3.9 16.0 0.68 2.0 536 <0.14 0.10 0 River 6 12-11-8i 1520 8.3 0.9 12.4 3.2 <12.5 <0.66 1.6 456 <0.14 0.04 0 -

Effluent Grab 12-11-8 1530 8.6 1.5 12.0 3.7 <12.5 <0.27 9.6 366 <0.14 0.07 0 12-10-8d 1300 Composite 12-11-8 1530 11.2 2.9 5.2 <0.14 Composite 12-1-8 1530 2-12-8 1100 11.4 4.1 7.6 <0.14 Effluent Grab 12-12-8 1100 8.5 1.5 <12.5 <0.33 Composite 12-12-8ý 1100 9.9 2.6 27.2 0.19 Effluent Grab 12-13-84 1200 8.4 1.2 17.2 0.73 23.2 1

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APPt.. C MIDL...., POND DEWATERING PROGRAM Page 8 of 9 WATER QUALITY MONITORING RESULTS Molecular Oil (2 Date Time pH Temp DO BOD Sulfide H2 S TSS TDS NH3 -N Total-P Fecal (1)

(mq/L) (uq/L) (mq/L) (ma/L) (ma IL) Coliforms Grease SAMPLE ID Sampled Sampled (S.u.) (*C) (mq/L) (uq/LL (mq/L) 1.7 18.8 1.0 4.8 400 <0.14 0.08 110 -

River 1 12-14-84 1045 8.3 1.3 11.4 2.8 <12.5 <0.80 7.6 362 <0.14 0.05 0 -

River 2 12-14-84 1050 8.2 1.2 11.6 11.4 2.4 <12.5 <0.80 9.2 428 <0.14 0.06 0 -

River 3 12-14-84 1055 8.2 1.1 2.4 14.0 1.1 7.6 350 <0.14 0.05 0 -

River 4 12-14-84 1100 8.1 1.1 11.3 1.1 11.2 2.4 <12.5 <0.80 5.2 426 <0.14 0.05 0 -

River 5 12-14-84 1105 8.2 1.2 12.1 2.9 <12.5 <0.80 6.4 378 <0.14 0.04 75 -

Piver 6 12-14-84 1110 8.2 1.1 12.1 3.8 <12.5 <0.53 41.6 392 <0.14 0.13 0 -

Effluent Grab 12-14-8j 1150 8.4 Composit__e 12-14-8f 1150 11.8 3.3 _ _ 38.0 <0.14 Composite Cmo.e12-14 12-15-0 ll56 0900

-

10.0 2.4 14.4 <0.141 Effluent Grab 12-15-84 0900 8.3 1.5 <12.3 <0.50 Comoste 12-15-8d 0900 Composite 12-16-L 0500 11.0 3.1 10.2 <0.14 Effluent Grab 12-16-8 1500 8.4 3.4 <12.3 <0.40 Composite 12-16-8 1500 3.5 28.4 0.41 12-17-6, 1100 10.9 Effluent Grab 12-17-0 1100 8.2 3.2 <12.3 <0.8

,S.

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APPENDI.

MIDLANu POND DEWATERING PROGRAM Page 9 of 9 WATER QUALITY MONITORING RESULTS n I *I ~ -

Molecular Oil (2)

Date Time pH Temp DO BOD Sulfide H2 S TSS TDS NH 3 -N Total-P Fecal (1) (&P SAMPLE ID Sampled Sampl ed (S.U.) I C) (mg/L) (mo/L) (ui/L) (ua/LI (mo/LI (ma/LI (ma/LI (mu/LI fni Ifnrm*

River 1 12-18-84 1025 8.6 2.9 12.1 3.0 11.7 0.25 6.0 468 <0.14 0.04 0 River 2 12-18-84 1030 8.4 2.6 12.0 3.2 <11.7 <0.50 6.0 388 0.71 0.04 0 River 3 12-18-84 1033 8.2 3.0 12.0 3.3 11.7 0.74 14.8 500 0.20 0.06 0 River 4 12-18-8d 1036 8.2 3.0 12.0 3.0 <11.7 <0.74 6.4 498 <0.14 0.05 0 -

River 5 12-18-8a 1039 8.2 3.0 11.4 2.7 11.7 0.74 7.4 488 <0.14 0.06 0 River 6 12-18-8, 1042 8.2 2.5 12.5 3.7 <11.7 <0.74 6.6 394 0.20 0.02 10 Effluent Grab 12-18-8, 1055 8.5 1.0 12.1 4.3 <11.7 <0.37 124 382 <0.14 <0.01 0 12-17-8, 1100 Composite 12-16-8, 1100 12.1 4,7 I8.8 I.1 River 1 12-19-81 1515 8.3 1.3 12.1 3.2 <12.2 <0.65 7.4 424 0.14 0.08 10 -

River 2 12-19-8, 1520 8.3 1.3 11.9 3.3 <12.2 <0.65 7.6 362 0.27 0.06 0 -

River 3 12-19-8, 1525 8.0 1.3 11.9 3.6 <12.2 <1.2 11.0 434 0.15 0.08 0 -

River 4 12-19-8x 1530 8.1 1.3 12.2 4.2 <12.2 <0.97 10.0 446 0.15 0.04 0 -

Rover 5 12-19-8 1535 8.1 1.3 11.8 3.4 <12.2 <0.97 10.0 424 < 0.14 0.07 0 _

River 6 12-19-8, 1540 8.1 1.3 12.0 3.8 <12.2 <0.97 8.0 378 <0.14 0.08 0 -

Effluent Grab 12-19-86 1600 8.3 0.7 12.3 4.3 <12.2 <0.65 29.2 370 0.22 0.04 0

=2-18-8, 1100-Composite 12-19-8g 1100 11.2 3.2 28.2 0.14 12-19-8 1100 Composite 12-19-8 1800 11.2 3.6 64.2 0.31 (1) TNTC - oo Numer(us To Count (2) Visual Oi and Gre se - (M) in icates p esence of oil or ,r1ase, (-) indicates absence of oil or gre se

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1 of 2 File No P10.2.1 APPF11DIX D Incident No: MID-84-10-ADO1 NPDES NOTIFICATION Apparent Difference From Daily Average/Maximum Limitation November 7, 1984 Plant: Midland Permit No: MI 0042668 Outfall

Description:

Cooling Pond Dewatering Outlet Outfall Code No: NK Structure (Outfall 003)

Parameter: BOD 5 Parameter Code No: 47023

1. Date of Incident: 10/26 & 30/84

2. Identification of specific effluent limitation or monitoring requirement affected:

Daily maximum BOD5 mass load limit of 2205 lb/d.

3. Description of Incident:

The BOD grab sample collected on 10/26/84 at 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br /> measured 2.0 mg/l. The analytical results were received 10/31/84 at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />. The daily average discharge flow rate on 10/26/84 measured 240.1 cfs. Therefore, the calculated BOD load for 10/26/84 was 2593 lbs/d. The BOD grab sample collected on 10/10/84 at 1150 hours0.0133 days <br />0.319 hours <br />0.0019 weeks <br />4.37575e-4 months <br /> measured 2.2 mg/l. The analytical results were received 11/5/84 at 1230 hours0.0142 days <br />0.342 hours <br />0.00203 weeks <br />4.68015e-4 months <br />. The daily average discharge flow rate on 10/30/84 mea-sured 199.6 cfs. Therefore, the calculated BOD load for 10/30/84 was 2371 lbs/d. Although samples were neither required nor taken during the period 10/27/84 to 10/29/84 it is possible that the daily maximum BOD5 load limit may have been exceeded during this interim period.

4.. Apparent Cause:

The combination of discharge flow rate and BOD5 concentration resulted in the apparent exceedances of the daily maximum BOD5 load limit. Also due to the nature of the BOD analysis, the results are not received until five days after the sample was taien by which time the incident had already occurred.

5. If not immediately corrected, the anticipated time the condition is expected to continue:

NA

6. Corrective Action - The following corrective action was taken or will be taken to reduce, eliminate and prevent recurrence:

Nothing could be done about the lag time in receiving the BOD5 analytical re-sults. However, when the BOD results of the 10/26/84 sample were received on 10/31/84, the daily average discharge flow on 10/31/84 was reduced to 48.6 cfs.

RP1184-0055A-TJO1

2 of 2 File No P10.2.1 APPENDIX D Incident No: MID-84-10-AD01

7. Additional Comments:

Although there were no observable adverse impacts to the Tittabawassee River water quality or the aquatic biota in the river as a result of the elevated BOD5 discharge, the pond discharge flow rate was greatly reduced.

Additionally' the discharge was terminated about 1320 hours0.0153 days <br />0.367 hours <br />0.00218 weeks <br />5.0226e-4 months <br /> on 11/01/84 because of increasing pond turbidity, resulting from heavy rainfall on exposed pond bottom.

8. Signed: R L Fobesyf*

RP1184-0055A-TJO1

APPENDIX E WATER QUALITY ANALYSIS LABORATORY QUALITY CONTROL RESULTS FOR THE MIDLAND POND DEWATERING PROGRAM, 1984 Quality Control Concurrent analyses of quality control standards (known reference standards) were limited to ammonia and total phosphorus measurements. Similar standards were either not applicable or not available for the remaining parameters.

AMMONIA - N Certified Measured Analysis Data Quality Control Standard ID Concentration Concentration (mg/L as N) (mg/L as N) 10-31 EPA Concentrate #3 0.28+/-0.05 0.27 11- 2 EPA Concentrate #3 0.28+/-0.05 0.29 11-16 EPA Concentrate #4 1.90+/-0.11 1.98 11-28 EPA Concentrate #3 0.28+/-0.05 0.26 11-30 EPA Concentrate #4 1.90+/-0.11 1.88 12-14 EPA Concentrate #4 1.90+/-0.11 1.90 12-26 ERA 9901 8.3 +/-0.7 7.9 TOTAL PHOSPHORUS Certified Measured Analysis Data Quality Control Standard ID .Concentration Concentration (mg/L as N) (mg/L as N) 11-16 EPA Concentrate #4 0.35+/-0.02 0.35 11-27 EPA Concentrate #4 0.35-0.02 0.34 11-30 EPA Concentrate #4 0.35+/-0.02 0.36 12-14 EPA Concentrate #4 0.35+/-0.02 0.35 12-26 ERA 9901 5.2 +/-0.7 5.5 Note: Laboratory quality control activities were followed at recommended frequencies for all parameters per analysis methods (see text, Table 1).

Documentation is available from individual data sheets which will be retained by Consumers Power Company for one year.

MI0585-0023A-EN03

APPENDIX F APPROXIMATE NUMBER AND WEIGHT OF FISH COLLECTED IN THE MIDLAND COOLING POND AND RELOCATED IN THE TITTABAWASSEE RIVER September 1984 to March 1985 Percent Composition Species Approximate Number Approximate Wt(Lbs) Number Weight(Lbs)

Alewife 113 19 0.54 0.16 Gizzard Shad 2,815 2,291 13.44 19.26 Carp 687 967 3.28 8.13 White Sucker 39 65 0.19 0.55 Crappie Sp 12,931 6,380 61.73 53.63 Bass Sp 475 405 2.27 3.40 Rock Bass 145 97 0.69 0.82 Sunfish Sp 1,153 253 5.50 2.13 zllow Perch 1,344 .524 6.42 4.40 Walleye 65 388 0.31 3.26 Bullhead Sp 405 105 1.93 0.88 White Bass 775 403 3.70 3.39 TOTAL 20,947 11,897 February Collection Not Estimated* 1,275 March Collection Not Estimated* 790 GRAND TOTAL -25,000 13,962 limilar to September through December collections, but dominated by juvenile fish.

NOTE: Fish collected during January were not successfully relocated.

MI0585-0023A-EN03

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Attachment consumers Power Paul C Hittle company Dire or, Envivirnwotal Deparomnct General Offices: 212 West Michigan Avenue, Jackson. MI 49201 *(517) 788-1930 December 17, 1984 Hitt 114-84 Mr Paul D Zugger, Chief Water Quality Division Department of Natural Resources PO Box 30028 Lansing, MI 48909 Dear Mr Zugger My letter of September 28, 1984, transmitted the Midland Cooling Pond Mainte-nance Program in accordance with Part I.A.29 and Part I.C.12 of the NPDES Permit 0042668. Attached is a copy of the revised program. This revision is based on the comments provided by Terry L Walkington in his November 20, 1984 letter and during his site visit on December 12, 1984.

All components of the program have been implemented, except those described below, which will be implemented shortly. Pond dewatering discharges (Permit Part I.A.1) will be completed in December 1984. The dam on the former Stewart Road culvert and the dam on the trench to the Service Water Intake will be installed during December 1984 or as soon as freezing conditions allow. Pumps will be used during non-freezing weather and removed during freezing weather.

Grass seeding of the banks of the former Waite-Debolt Drain will occur in the spring of 1985.

We would appreciate your approval of this program. If you have any questions about the program, please call P B Latvaitis at (517) 788-1975.

Yours very truly PCH/RFG/fmh CC JDBails, DNR BWMarguglio, JSC-220A TWalkington, DNR

1 COOLING POND MAINTENANCE PROGRAM After complete dewatering of the cooling pond, the Cooling Pond Maintenance Program is conducted to control the suspended solids concentration in storm-water runoff and site dewatering discharged from the cooling pond. The program is designed to collect and discharge stormwater and associated de-watering well discharge. There are three primary areas of water accumulation; the emergency cooling water reservoir (ECWR), the circulating water discharge (CWD) structure area and the area near Outfall 003.

Site storm drainage (as identified in the NPDES Application, Revision 3, submitted November 11, 1981) and water from rainfall and associated site dewatering well discharges accumulates in the ECWR and CWD areas. The area near Outfall 003 contains water pumped from the ECWR and CWD, rainfall and pond area runoff. Most of the 880 acre cooling pond either slopes toward Outfall 003 or is drained to the former Waite-Debolt Drain which conveys water to the area near Outfall 003. Discharge will be conducted from Outfall 003 in compliance with Part I.A.2 of NPDES Permit 0042668.

The attached sketch of the cooling pond shows the location of the former Waite-Debolt Drain on the pond bottom and the location of a drainage ditch from the ECWR to the area near Outfall 003. Also shown are the pump loca-tions, the settling basin for ECWR pumped discharge, the backwater areas along the drainage ditch from the ECWR to the outfall, the aggregate dam above the former Stewart Road culvert, the backwater area behind this dam, and the pooled area near Outfall 003. Water accumulating near the CWD structures is pumped over the baffle dike into the emergency cooling water reservoir. Water MI0984-6867A-ENO2

.* '

• 2 accumulating in the ECWR is pumped to a settling basin and then flows to the backwater on the ditch leading to Outfall 003. This backwater area formed by high points on the ditch slows velocities and reduces suspended solids concen-trations. Outfall 003 is normally closed. The discharge gates are opened when visual inspection of accumulated water indicates the effluent will be acceptable.

Several additional features maintain low total suspended solids concentrations in the collected stormwater discharged from Outfall 003. The inner slopes of the cooling pond dike and the baffle dike are protected with riprap. The riprap extends from the dike crest (632 ft MSL) to the toe of the dike or to elevation 615 ft MSL, whichever is higher. The 18 in thick riprap layer rests on a 12 in thick crushed rock bedding layer. Where the dike slope extends below elevation 615 ft MSL it is protected by a 12 in layer of crushed rock to the toe of the dike. Therefore, rainfall and runoff are not expected to cause erosion of these dike slopes. Water pumped from the CWD structures area is released directly onto the riprapped east slope of the baffle dike, using this surface as a controlled spillway into the ECWR. A small dam across the trench connecting the ECWR with the Service Water Intake (SWI) prevents water accumu-lating in the ECWR from seeping into the plant area. The small pool between this dam and the SWI is pumped as needed, onto aggregate into the ECWR. In the emergency cooling water reservoir the water depth is maintained at a minimum of about 2 ft by pumping. This depth minimizes the possibility of pumping water with high suspended solids concentrations. Localized sumps for the pumps maintain desired pumping levels while minimizing suspended solids releases. Water pumped from the ECWR is released to a 75 ft diameter, 4 ft MI0984-6867A-ENO2

3 deep, riprap lined settling basin adjacent to the ECWR and about 1550 ft from the Outfall 003 structure. The suction points of pumps in the ponded areas are in cages off the bottom of the sump to minimize suspended solids concen-trations in the pump discharge.

An aggregate dam just above the former Waite-Debolt Drain culvert under the former Stewart Road forms a backwater along the lower portion of the former drain to slow water velocity and reduce any suspended solids concentrations.

Additionally, with the discharge gates on Outfall 003 normally closed, a backwater pool forms to about elevation 602-603 ft MSL at the outlet. Again, this pool reduces velocities from all contributing sources and allows any suspended solids to settle.

The cooling pond bottom is expected to revegetate naturally. Additionally, grass seeding of the banks of the former Waite-Debolt Drain will also form a sediment filter and help to stabilize the banks.

The discharge gate at Outfall 003 will be opened periodically (after suspended solids have settled) to allow discharge of the stormwater to the river.

12/17/84 M10984-6867A-ENO2

N\ 51 S 35000 PLANT SSTEtf.!n" i S 7000 DISJG -TUflm SRU SCALE 000 F CHID SW!63 S 30 1.

IE 1

C1 T Settling BDa*n Aggregate Dam -- ft..m..

Attachment 5 State Office Building 411-J East Genesee Saginaw, Michigan 48607 September 26, 1985 Mr. Paul C. Hittle Consumers Power Company 212 W. Michigan Avenue.

Jackson, Michigan 49201 Re: Midland Cooling Pond Maintenance Program and Midland Cooling Pond Dewatering Report

Dear 2Mr. Hittle:

This documents approval of the Midland Cooling Pond 1aintenance Program submitted to the Chief of our Divion on December 17, 1984, and the Midland Cooling Pond Dewatering Program Summary Report submitted June 12, 1985.

The December 1984 submittal included revisions we requested in Novo-mber 20, 1984, correspondence and a December 12, 1984, site visit. All prior review comments ware satisfied in the revised Program. This approval has been delayed because of questions regarding the operators' certification which were discussed exten-sively w;ith rA. Ron Fobes during the period December 1984 through February 1985. Part II.A.3. of INPDES Permit No. M1-0042668 re-quires, "The permittee shall have the waste treatment facilities under the direct supervision of an operator certified by the Michigan Water Resources Commission, as required by Section 6a of the M-lichigan Act." The facilities are classified Ald and A2f.

Another site visit was made by the Nriter on September 6, 1985, whereby a tour was provided of the pond by company representa-tives. We found the Maintenance Program to be satisfactorily implemented. In fact, the runoff control measures were very successful in controlling erosion and sediment discharges after approximately eight inches of rain in three days just prior to the visit.

/

.. un rstand -- that the issue of operator certification will be ralol-vcd by sufficient numbers of operators taking the Induýt--ia!

o'-ti-ication Exam this November to have qualified cartified personnel on site at Midland in the future. We request your response at a later date to list the personnel so certified who arc designated responsible for the Cooling Pond Maintenance Program.

The Dewatering Stu=uary Report was complete and very oatirfactory and :natii:fies Opecial Conditions 30, 31, and 322 :,f the NPDES Permit.

IWe will be making routine inspections of the Cooling Pond in the L:.ture as with other armittcd discharges. L-t u'* know if there are any concerns ar quostions regarding this facility for wuhich

%e may assist your staff.

Sincerely, Terry L. Walkington, P.E.

Saginaw District Supervisor Surface Water Quality Division 517/771-17.'.7

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-.3 C,: P. Bradley Latvaitus, C.P.C., Jackson

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Attachment 6 FORM 8-K SECURITIES AND EXCHANGE COMMISSION Washington, DC 20549 CURRENT REPORT Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 Date of Report: September 17, 1986 CONSUMERS POWER COMPANY (Exact name of registrant as specified in charter)

Michigan 1-5611 38-0442310 State of Incorporation Commission File No. IRS Employer Identification No.

212 West Michigan Avenue Jackson, MI 49201 (Address of principal executive offices)

Registrant's telephone number, including area code: (517) 788-1030 RP1183-0001K-TE01

Item 5. Other Events.

On September 17, 1986, the Dow Chemical Company and Consumers Power Company (the "Company") announced that they had reached an agreement in principle to work together to convert the Company's Midland plant into a natural gas-fueled combined-cycle cogeneration plant, and issued the fol-lowing press release.

DOW CHEMICAL, CONSUMERS POWER TO JOIN IN EFFORT TO CONVERT MIDLAND PLANT IANSING, Mich., September 17, 1986 - 7he Dow Chemical Corpany and Consumers Power Ccupany today announced that they have reached an agreement in principle to work together to convert the idled Midland nuclear plant into a natural gas cambined-cycle cogeneration plant.

Under terms of the agreement, Dow would became an equity participant in the project and would receive the steam and electrical needs of its Michigan Division Midland Plant fram the new facility. Dow and Consumers Power have also agreed to seek a recess of their current legal proceedings concerning the Midland nuclear plant while the two cacpanies complete a final agreement.

Such an agreement would resolve all differences between the two carpanies.

The natural gas ccmbined-cycle project is expected to qualify under the federal Public Utilities Regulatory Policy Act (PURPA) as a cogeneration facility. PURPA was enacted by Congress to encourage development of electrical generating plants that could produce steam as well as electricity.

The Dow plant uses large anmunts of steam, thus making the proposed generating plant more efficient and leading to conservation of natural gas.

SIGNATURE Pursuant to the requirements of the Securities Exchange Act of .1934, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

CONSUMERS POWER COMPANY Dated: September 19, 1986 By: J. F. Paquette, Jr.

J. F. Paquette, Jr.

Executive Vice President and Principal Financial Officer RP1183-OOOIK-TEOL