ML051590214

NPDES Permit No. TN00226450 Biocide/Corrosion Treatment Plan Change

ML051590214
Person / Time
Site:	Sequoyah
Issue date:	05/26/2005
From:	Pace P Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TN00226450
Download: ML051590214 (16)

Text

Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 May 26, 2005 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT - NPDES PERMIT NO. TN00226450 BIOCIDE/CORROSION TREATMENT PLAN CHANGE The enclosure provides the changes to SQN NPDES Permit No.

TN00226450 Biocide/Corrosion Treatment Plan as required by SQN Environmental Technical Specification Section 5.5.2, Changes in Permits and Certifications.

If you have any questions concerning this matter, please call me at (423) 843-7170 or J. D. Smith at (423) 843-6672.

Sincerely, P. Pace Manager, Site Licensing and Industry Affairs Enclosure

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P on renecycl Piger

ENCLOSURE TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

NPDES PERMIT NO. TN00226450 BIOCIDE/CORROSION TREATMENT PLAN CHANGE

STATE OF TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION 401 CHURCH STREET L & C ANNEX 6H FLOOR April 27, 2005 NASHVILLE, TN 37243-1534 Stephanie A. Howard Principal Environmental Engineer Tennessee Valley Authority, Sequoyah Nuclear Plant P.O. Box 2000 Soddy-Daisy, TN 37379-2000 Re: TVA-Sequoyah Nuclear Plant NPDES Permit No. TN0026450 Biocide/Corrosion Treatment Plan Approval

Dear Ms Howard:

The Division of Water Pollution Control (Division) has received and reviewed your letter of March 7, 2005 requesting authorization to implement changes to the raw water treatment plan at the Sequoyah Nuclear Plant (SQN). The revised plan, which you submitted with the letter, included four parts, (1) a copy of the plan in tabular format with accompanying rationale, (2) a plan overview and supporting documentation, and (3) a copy of MSDS sheets and product bulletins for the chemicals to be used, and (4) additional information describing how treatment would be carried out. The format for the plan was discussed at a meeting between SON and WPC staff in Chattanooga in June 2004. It should also be noted that TVA Watts Bar Nuclear (WBN) Plant is situated upstream of SQN on the same waterway and that some (same] products were previously approved for use at WBN. Some products may have already been approved for use at the SON facility, but this approval is an update on the use and properties of those

[chemical] products. The Division appreciates the effort made by TVA to update the format and expand .the information in the plan, which makes review much easier.

The SQN raw water treatment plan involves the use of eight (8) chemicals, applied to treat piping systems essential to safety in the event of a shutdown. The chemicals, following treatment under appropriate circumstances, will be discharged to the Tennessee River through the NPDES permitted Outfall 101 (ERCW Train A & B and the RCW) and Outfall 110 (supplemental condenser cooling water line when in closed mode). The chemicals include two corrosion inhibitors, one biodetergent, one oxidizing biocide (chlorination/bromination), three non-oxidizing biocides (quaternary ammonium compounds for mollusk control), and sodium silicate (detoxification). The use of some of these chemicals was approved by the Division in the past based on specific discharge conditions. Other chemicals are new to the plan.

There are certain basic criteria that the Division is following in reviewing this plan to assure that the effluent quality is protective of receiving stream quality. Based on data

.. t -

Stephanie A. Howard Page 2 of 10 provided by TVA and/or the chemical vendor we have calculated maximum concentrations of the active ingredient(s) in the discharge in order to compare those values with acute and chronic criteria for the ingredients. The objective is to assure that the discharge concentration does not exceed the acute toxicity criteria for each ingredient. The maximum concentration of each active ingredient for Outfalls 101 and 110 - combined has been calculated to compare to the chronic toxicity criteria for [each active ingredient] at the end of the mixing zones. Based on those calculations, some values could exceed CCC criteria, however, TVA has committed not to exceed specific effluent concentrations and it is anticipated that the reactive properties of those chemicals should reduce the concentrations after mixing to acceptable levels. Because there are no federal or state criteria developed for most of the active ingredients in these chemicals, criteria have been derived based on data from the EPA EcoTox database (See Table 1 attached), from TVA, and from the chemical vendors. These derived criteria are compared to the maximum anticipated chemical ingredient instream concentration in Table 2 and discharge concentration in Table 3. Where TVA has committed not to exceed a specific effluent concentration and daily mass loading, those values have been made a condition of the plan approval, provided that water quality criteria are met.

For purposes of this plan evaluation, reference to chemical means the vendor chemical

-name including all active constituents. Where concentration limits have been established, we have specified whether that concentration limit applies to a specific ingredient, to the whole chemical, or to an indicator element for which analytical procedures are available. Unless otherwise specified, where mass limits are applied, they refer to the active ingredient(s) based on maximum daily feed rate.

The eight chemicals are discussed individually below and the conditions for their use are specified. Each chemical is approved for use effective April 27, 2005, subject to these specific conditions:

Chemical Name: Nalco PCL-401 Primary Ingredient: Anionic Copolymer CAS No.: None Provided This chemical is a dispersant designed to prevent the formation of scale in the system.

The chemical contains an anionic copolymer that is proprietary in makeup. Division records show this chemical was included in the submittal as part of the raw water treatment plan for WBN in August 1996 .(see letter from Odis E. Hickman, Jr. to Paul Davis). Acute aquatic toxicity data has been presented in the plan from the NALCO MSDS and from TVA data. Based on this data a 48 hr LC50 for Daphniamagna of 798 mg/i has been utilized to derive a criterion maximum concentration (CMC) of 399 mg/A and a criterion continuous concentration (CCC) of 79.8 mg/I. TVA has agreed to keep concentrations of the active ingredient at or below 0.2 mg/L in the effluent. Conditions for approval of PCL-401 are (1) that the concentration of the chemical shall not exceed 0.2 mg/I. in the plant effluents based on mass balance calculations, and (2) that the total quantity of chemical discharged shall not exceed 1,480 lbs per day.

Stephanie A. Howard Page 3 of 10 Chemical Name: Nalco PCL-222 Primary Ingredient: Copolymer-Phosphate blend CAS No.: (Individual Component CAS numbers available from the Manufacturer)

This chemical contains a copolymer-phosphate blend and is used as a dispersant designed to prevent the formation of scale in the system. Acute aquatic toxicity data was not initially available from NALCO MSDS. However, TVA stated in their B/CTP that "toxicity of PCL-222 is assumed to be similar to PCL-401'% and that "tests will be conducted at a toxicity lab under contract to the manufacturer'. Tests were performed March 5-12, 2005, and ASci Corporation, Environmental Testing Laboratory provided TVA with data for test endpoints as NOEC and LOEC, which were forwarded to the division on or about March 30, 2005. Division records show this chemical was included in a submittal as part of the raw water treatrfient plan for WBN in August 1996 (see letter from Odis E. Hickman, Jr. to Paul Davis).

TVA proposes to keep concentrations for each active ingredient (copolymer and phosphate) at or below 0.2 mg/I in the effluent. Conditions for approval of PCL-222 are (1) PCL-222 is injected into the ERCW Train A & B system only during warm weather months, (2) PCL-222 is injected into the RCW system continuously, except during periods of other chemical injection, (3)that the concentration of each active ingredient of PCL-222 shall not exceed 0.2 mg/I in the plant effluents based on mass balance calculations, and (4)that the total quantity of chemical discharged shall not exceed 760 lbs per day for the copolymer, and 2280 lbs per day for the phosphate as detailed in the SQN Raw Water Chemical Application Guide.

Chemical Name: NALCO Biodetergent 73551 Primary ingredient: Ethylene oxide-Propylene oxide copolymer CAS No. None Provided This chemical is a non-ionic copolymer used in advance of non-oxidizing biocide applications to remove and disperse soft foulant deposits in cooling water systems. This chemical was previously approved for use in a July 16, 2004 letter to TVA from Ed Polk.

Nalco Biodetergent 73551 replaced the surfactant, DMAD (CL363 dimethylamide), which was phased out of production in June 2004. Frequency of use would be approximately 208 days per year and duration of use would be about 0.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per day with a maximum daily usage of 50 lbsfday for all three-injection points.

Data from the EPA EcoTox database shows that the chemical ethylene oxide exhibits acute toxicity to D. magna at 83 to 300 mg/A and to P. promelas at 63 mg/l to 150 mg/i.

Data from the Nalco MSDS shows acute toxicity of the chemical to D. magna with a reported LC50 of >1000 mg/I. The MSDS also shows chronic toxicity to P. promelas at an IC25 of 527 mg/I and for Ceriodaphnia dubia at an IC25 of 141 mg/A.. Data presented by TVA for the active ingredient show chronic toxicity (IC25) to P. promelas of 105.4 mg/I and to C. dubia of 28 mg/I. TVA has agreed to keep the effluent concentration of the active ingredients at or below 2.0 mg/I. Based on these data, conditions for approval of this chemical are (1) the plant effluent concentration of the active ingredients in Nalco

Stephanie A. Howard Page 4 of 10 Biodetergent 73551 shall not exceed 2.0 mg/l at any time based on mass balance calculations, (2) the maximum quantity of the active ingredients used shall not exceed 50 lbs per day for all three injection points, and (3) treatment durations shall not exceed 30 minutes at 2-3 times per week into ERCW Train A, ERCW Train B and RCW systems.

Chemical Name: NALCO Towerbrom 960 Primary Ingredient: Sodium Dichloroisocyanurate -

CAS Nos. 2893-78-9 Secondary Ingredient: Sodium Bromide CAS Nos. 7647-15-6 This chemical mixture is an oxidizing (chlorinating/brominating) biocide used for control of slime producing organisms, i.e., Asiatic clams and zebra mussels. The chemical mixture contains 85% to 95% sodium dichloroisocyanurnate and 5% to 10% sodium bromide. This chemical was previously approved by the Division, at WBN for non-discharge use in biological control of the cooling towers (see Thomas E. Roehm letter to Odis E. Hickman of September 6,1996).

TVA is requesting to be allowed to increase the chlorine discharge limit at Outfall 101 when using Towerbrom 960 to a maximum discharge concentration of TRO of 0.10 mg/L from the current maximum of 0.058 mg/L. The increase in the maximum limit is based on the following statement from TVA.

'The application period of Towerbrom must be increased in order to ensure growth of Asiatic clams and zebra mussels entering the plant system is limited to a size that will not restrict flow to equipment essential for the safe shutdown of the nuclear plant. During spring of 2004, SQN's ability to safely shutdown was threatened due to infestation of Asiatic clams with sizes up to 318' Inch. The non-oxidizing biocide kills Asiatic clams and zebra mussels only when the river temperature is above 60 degrees F. TVAN monitoring has shown that veligers are present at river temperatures as low as 46 degrees F.

Previously, spawning was believed to stop at 55 degrees F. For that reason, the 2003 request to TDEC, asked for continuous Towerbrom treatment when the river temperature was >55 degrees F until such time as non-oxidizing biocide was administered. With current data proving present of veRgers at river temperatures as low as 45 degrees F, the ability to use continuous Towerbrom for a period long enough to protect the system from infestation whenever veligers are detected is necessary. The 24-hour application of continuous Towerbrom treatment following nonoxidizing biocide treatments is necessary to have a synergistic effect for mollusk eradication in the systems. Likewise the number of treatments must be Increased In order to limit the size of clams to 118 inch. Shells larger than 1/8 inch could cause failure of critical components required for safe shutdown.

Growth data obtained indicates that a clam can reach 1/4 inch in 8 to 12 weeks. Again.

the ability to control the size of these mollusks is necessary to ensure safe shutdown capability. The same treatment program Is also being used at TVAN's Watts Bar plant in order to ensure safe shutdown capability."

From "An Overview of Raw Water Chemical Additives", included in the letter of March 7, 2005 requesting authorization to implement changes to the raw water treatment plan at the Sequoyah Nuclear Plant (SQN):

"To control macro invertebrates and microbiologically induced corrosion, routine raw water treatments with oxidizing biocide (chlorination) are necessary for:

Stephanie A. Howard Page 5 of 10

1. SON plans to treat two to five days per week during cool weather periods and five to seven days per week during warm weather periods for four to twelve hours per day.

2. SQN plans to treat twenty-four hours per day for approximately 90 days per year and/or when veligers are present.

3. Shorter (24-72 hour) periods of continuous oxidizing biocide treatment will also be required following treatments with the non-oxidizing biocide."

Sodium dichloroisocyanurnate is acutely toxic to D. magna with reported EC50 in the range of 0.093 mg/l to 0.36 mg/I and LC50 of 0.15 mg/I. The sodium bromide is less toxic with D. magna LC50s in the range of 1.3 to 20,000 mg/I. TVA reported data for the Towerbrom 960 mixture, which shows D. magna 48 hr LC50 of 2.43 mg/I and P.

promelas 48 hr LC50 of 0.679 mg/I.

The active ingredients in Towerbrom 960 produce 57% free halogen (chlorine and bromine) in solution. TVA is proposing to control the effluent concentration of Towerbrom-960 by controlling effluent Total Residual Oxidants to 0.10 mg/I in the plant effluent (TROs is defined for purposes of this plan to include residual chlorine and bromine and is to be quantified using the Total Residual Chlorine (TRC] test). Water quality criteria for TRC are 0.019 mg/I as the CMC and 0.011 mg/I as the CCC.

Although the 0.1 mg/I effluent limit will exceed the CMC, it is recognized that TRC reacts and dissipates rapidly between the point of measurement and the point of discharge at the receiving stream. Therefore it is anticipated that an effluent limit of 0.10 mg/I for TRC will comply with water quality criteria.

Based on the data available, the conditions for approval of use of this chemical shall be strictly adhered to and are: (1)the maximum concentration of TROs (including chlorine and bromine) shall not exceed 0.10 mg/I in Outfall 101, (2) the total quantity of active ingredient use shall not exceed 1425 lbs/day, (3) discharge limits compliance will be determined by mass balance calculation, (4) increased periods of application is approved based on described items 1. through 3. above (from the March 7, 2005 request letter's "An Overview of Raw Water Chemical Additives"), (5) oxidizing biocide treatments using Towerbrom 960 shall not be conducted simultaneous per system train with non-oxidizing biocide chemical treatments.

Chemical Name: NALCO H-130M Primary Ingredient: Didecyidimethylammonium Chloride CAS No.: 7173-51-5 This chemical is a non-oxidizing biocide used to control mollusks. The primary ingredient, didecyldimethylammonium chloride, is a specific biocide in the family of quaternary ammonium compounds. These compounds are generally structured to contain four organic radicals attached to a nitrogen molecule. Ethanol may be added to enhance solubility.

Stephanie A. Howard Page 6 of 10 TVA is proposing to increase the use of H-130M and to provide detoxification treatment using Nalco Coagulant Aid 35 active ingredient: Quartz, crystalline silica. (See separate discussion below).

Nalco H-130M is acutely toxic to D.magna in the range of 0.019 mg/I to >1.0 mg/A based on data from the EPA EcoTox database. The Nalco MSDS reports D.magna acute toxicity at 0.19 mg/A and TVA reports chronic toxicity for C. dubia at 0.139 mg/I and for P.

promelas at 0.104 mg/I. Based on these data, an acute criteria (CMC) of 0.05 mg/I and a chronic criteria (CCC) of 0.01 mg/A are established for this compound.

Treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for H-130M will occur. TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may use a colorimetric method for detection of quaternary ammonium compounds suitable for field use to a detectable limit (MDL) of 0.05 mg/I for operational use. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

The conditions for approval of the use of this compound are (1) the concentration of the active ingredients in the plant effluents shall not exceed 0.05 mg/l, (2) when treatment is underway, routine sampling of the effluents shall-be undertaken once each four hours during daylight hours and once during nighttime hours, (or a composite sampler may be used), and the grab samples shall be analyzed for quaternary ammonium compounds using methylene chloride extraction, and (3) the total use of Nalco H-130M shall not exceed 855 lbs/day of active ingredients, and (4) treatment using sodium bentonite shall be applied to Outfalls 101 and 110 any time that calculations show that an exceedance of condition (1) or (3) may occur. TVA-SQN will use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/I, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

Chemical Name: Lonza Barquat 4250-Z, a.k.a. Nalco H-150M Primary Ingredient: N-alkyl (C14 60%, C16 30%, C12 5%, Cie 5%)-N, N-dimethyl-N-Benzylammonium Chloride CAS No.: 68391-01-5 Secondary Ingredient: N-Dodecyl-N,N-dimethyl-N-ethylbenzylammonium CAS No.: 27479-28-3 Chloride This chemical is a "second" generation quaternary ammonium compound used as a hard surface disinfectant and/or water treatment to provide biocidal action against a broad

Stephanie A. Howard

• Page 70f 10 spectrum of microbial organisms such as: bacteria, funji, viruses, and algae. This product is new to this program and has not been previously approved for use. TVA stated in their request for approval to use that 'Toxicity testing of Barquat is (was) currently underway (3/1/05) at Environmental Testing Solutions, Inc., Asheville, NC."

Testing was completed on, or about March 15 2005. Completed test results were presented in a report to the division March 30, 2005.

Barquat 4250-Z is acutely toxic to C. dubia in the range of 48-hour LC50 of 0.053 mg/I to 24-hour LC50 of 0.083 mg/I based on data from the recently completed toxicity testing.

The toxicity tests also reports acute toxicity for P. promelas between 0.283 mg/I for a 96-hour LC50 to 0.386 mg/I for a 24-hour LC50. Based on these data, an acute criteria (CMC) of 0.05 mg/I and a chronic criteria (CCC) of 0.01 mg/i are established for this compound.

Treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for Lonza Barquat 4250-Z, a.k.a. Nalco H-150M will occur. TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/l, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may use a colorimetric method for detection of quaternary ammonium compounds suitable for field use to a detectable limit (MDL) of 0.05 mg/l for operational use. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

The conditions for approval of the use of this compound are (1)the concentration of the active ingredients in the plant effluents shall not exceed 0.05 mg/A, (2)the effluents shall be sampled and analyzed for quaternary ammonium compounds once each 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during daylight hours and once per nighttime hours, (or a composite sampler may be used), in periods when treatment is underway, (3) the total use of Barquat 4250-Z (or Nalco H-150M) shall not exceed 855 lbs/day of active ingredients, and (4) treatment using sodium bentonite shall be applied to Outfalls 101 and 110 any time that calculations show that an exceedance of condition (1) or (3) may occur, (5) TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/l, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

Stephanie A. Howard Page 8 of 10 Chemical Name: Betz Dearborn Spectrus CT1300 Primary Ingredient: (C12-C16) Dimethylbenzylammonium Chloride CAS No.: 68424-85-1 Secondary Ingredient: Ethyl Alcohol CAS No. 64-17-5 This chemical is a non-oxidizing biocide used for mollusk control. It contains a primary ingredient, (C12-C16) dimethylbenzylammonium chloride (50%), which is a quaternary ammonium compound. A secondary ingredient is ethyl -alcohol. This product is approved by the Division with the condition that the concentration of the active ingredients does not exceed 0.05 mg/I in the plant effluents. TVA is requesting that the number of injections and durations be adjusted, but that the current maximum allowable discharge concentration of 0.05 mg/L remains unchanged. Under these conditions, detoxification of the chemicals will be undertaken using sodium bentonite (see discussion below).

Dimethylbenzyl ammonium chloride has been found to be acutely toxic to D. magna at concentrations ranging from .00028 to .09 mg/l and to P. promelas in concentrations ranging from 0.23 to 1.8 mg/I based on limited data in the EPA EcoTox database. The Betz Dearborn MSDS reports acute toxicity for D. magna of 0.16 mg/I and P. promelas of 2.9 mg/I. TVA reports chronic toxicity to C. dubia of 0.18 mg/I and to P. promelas of 0.36 mgA. Based on these data, a CMC of 0.050 mg/I and a CCC of 0.010 mgA are selected to protect the stream.

Treatment of Ouffalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for Betz Dearborn Spectrus CT1300 will occur. TVA-SQN will also use grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mgA, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may use a colorimetric method for detection of quaternary ammonium compounds suitable for field use to a detectable limit (MDL) of 0.05 mg/I for operational use. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

The use of Betz Dearborn Spectrus .CT1300 is approved for use with the following conditions (1) the concentration of the quaternary ammonium compounds in the chemical shall not exceed 0.05 mgA, (2) the total use of all active ingredients in Spectrus CT1300 shall not exceed 855 lbs/day, (3) treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of condition (1) and (2) may occur, (4) when treatment is underway, routine sampling of the effluents shall be undertaken once each four hours during daylight hours and once during nighttime hours, (or a composite sampler may be used), and the grab samples shall be analyzed for quaternary ammonium compounds with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mgA, in conjunction with those calculations to demonstrate protection of the receiving stream. TVA may send samples to Nalco or other qualified laboratories for comparative sample analysis.

Stephanie A. Howard Page 9 of 10 Chemical Name: Nalco Coagulant Aid-35 Active Ingredient: Quartz, crystalline silica (aluminum silicate)

CAS No.: 14808-60-7 This chemical is sodium bentonite clay, which is composed primarily of sodium and aluminum silicates. The clay is used to detoxify (adsorb and bind) the toxic constituents in H-130M, Barquat 4250-Z, (also known as H-150M), and Spectrus CT1300. This treatment proposal is new and has not been approved in the past. Treatment is to occur approximately 24 times per year for about a 3.5-5.5-day period, for a maximum period of 132 days per year. Special trailers have been constructed to house the chemical feed equipment to be used during the treatment operation. Both Outfalls 101 and 110 will be treated as needed. Proposed feed rate is up to 8,520 lbs/day and proposed maximum concentration in the effluents is 10 mg/l.

The sodium and aluminum silicate clays are generally non-toxic and should not pose a problem for the receiving stream. Nalco Coagulant Aid-35 is approved for use with the conditions (1) the maximum concentration in the effluents is less than10 mg/I based on mass balance calculations, (2) the total use of sodium bentonite shall not exceed 8,520 lbs/day, and (3) treatment of Outfalls 101 and 110 with sodium bentonite shall be undertaken any time mass balance calculations indicate that an exceedance of the effluent concentration limits for Nalco H-130M, Barquat 4250-Z, or Betz Dearborn Spectrus CT1300 will occur. TVA-SQN will also use daily grab samples analyzed with a low-level detection test method (using methylene chloride extraction), which has an MDL of 0.02 mg/l, in conjunction with those calculations to demonstrate protection of the receiving stream.

General Requirements In addition to the chemical specific requirements above, the approval of the use of these chemicals is also conditioned upon the following:

1. Oxidizing and non-oxidizing biocides are not to be used at the same time, in each system Train, (e.g., ERCW Train A, Train B, or RCW),

2. Whole effluent toxicity testing (biomonitoring) of Outfall 101 shall be undertaken once per year when oxidizing biocides are being used and once per year when non-oxidizing biocides are being used,

3. Whole effluent toxicity testing (biomonitoring) of Outfall 110 shall be undertaken once per year when oxidizing biocides are being used and once per year when non-oxidizing biocides are being used,

4. Whole effluent toxicity testing performed under requirements of the NPDES permit may be coordinated with the requirements of (2) and (3) above.

5. The sampling and test procedures .used for biomonitoring shall be the same as those described in the NPDES permit, analysis of the samples shall be performed the same regardless of how the sample is collected, e.g., if composite sample collection is used the test method for the sample shall be the same as if the sample was collected by grab sample.

6. The acceptable methods for detection of TRO shall be the same as those specified in the NPDES permit for TRC,

Stephanie A. Howard Page 10 of 10

7. Annually, a report shall be submitted to the Division presenting the biomonitoring data for tests conducted during treatments, a summary of all analytical results (daily maximum, daily average, number of samples), the approximate duration in hours of each chemical used, quantity in pounds of each chemical used, and any minor changes that have occurred to the plan. The report shall be submitted to the Enforcement and Compliance Section in Nashville and to the Chattanooga field office by February 15 of the year following the reporting year. Significant changes to the plan must be submitted for Division for approval prior to their initiation. Minor changes (e.g. chemical names or vendor changes of essentially the same chemical) do not require pre-approval, but shall be indicated in the annual report or when the plan is revised,

8. In order to compare reliability of the mass-balance calculations with the methylene chloride extraction method, SQN shall compare both methods used for the analyses of the effluent and report to the Division. This is especially important during the first six treatments using detoxification. When the division includes "...other qualified laboratories..." the intent is that a laboratory will be selected based on its ability to accurately run the specified test. TVA should base their selection of the laboratory on the highest of industry standards. The results of these comparisons will be submitted in the first annual report to TDEC on February 15, 2006, and

9. TVA-SQN is required to maintain all records on file of sampling and analytical data, toxicity test results, records of quantities fed per day of each chemical, and mass balance calculations. These records shall be maintained on site for a period of at least three years.

If you have any questions or comments, please don't hesitate to contact me at (615) 532-1178, or at edward.volk~state.tn.us.

Sincerely, Edward M. Polk, Jr., P.E.

Manager, Permit Section Water Pollution Control EMP/prm Attachments Cc: Saya A. Qualls, P.E., WPC-Chief Engineer Pamala Myers, Permit Section Terry Whalen, Chattanooga EFO

Table 1 TVA Sequaoyah Nuclear Plant Raw Water Treatment Plant Chemicals Toxicity Data from EPA EcoTox Database suprper Name and Aquatic Speces Ccncentration. ul Reference I CAS No.

Ct.emfcal Name Mtr1n I Alefraae Max No.

Na co Towertrorn 960 14413 Primary active Ingredlent 344 I 3-Oicrhlcro-t.3.5-triazire-2.4.8 (11H3H1.5H)trione, 1 293789 143 Sodium salt. 32a00 344 90%. active ingredient in Towerbrom 960 Rawnbow trout Lc5o 290 14413 Raritow trout 1050 130 9CC 344

- t-.-----t I'-

vacrnia mnacra I:L;o 5. 7L 290 Secondary active ingredient Dac*nria maria ECSO 7.219.000 SodiLrn bromide 7647156 NOEC IO%active uigredent in Towertrom 960 Oacthna magra I Oaonnia manna ECSO I 20.8CC 30 400 20-061 oactnia manna EC50 _ l _23.000 _ Ii 5_575 Dacrinia manna EC5d _ _ l 23.0G0 T ce1o6 I Cacmna magma ECSt 5d-0 T _ l 14.1.0 3949 CDa a manna lC50 _ _ T 5C0.000 T i 5718 Ge_nia manra tCSO II .C.000 _____ I 10600 Oaornia manna LC50 T ____ 49794_

Oachnia ma qna 1C50 105CO.C0 Io l L 5675 Dachnma manna LC50 I0 CCCCC0 20.0C0 CCO 7054 Oacrnia manna 1C50 8.900.0C0 10203 Da Insa marra LCSO <38 76 6320 Oachmita manna LC0O 7394 7508 49794 Gachnia maqna OEC 19000 20C61 Gap amaqna LOEC 19 000 44S4 Dachma macna LOEC 30CO 470CC0 5857 Oansa maqna NOEC 2500 . 12372 aOrtna magna NOEC 3.100.000 7.80o.oro 10600 Oassamalta NOEC _ _ 7500 20061 Oacna maqna NOEC 9.000 T 8s77 Oachmia ma na NOEC 78G0 16.C00 10600

_OEC Naiinamannae30CO 19.C00 T 5857 Sud S. LCS0 c32 330 407 8363

_uq _ LC50_ > .000.093 344 tntand stvers.Cea LC50 s0.. 410 6230 Gcl-en shiner LC50 236 2S8 353 1 6230 Nalco H1-130 M Cemocachss a dstva LC50 69 682 178860 Oacasua manna EC50 52 98C.O 5333 Active Ingredient Vana man EC50 14 120 3t4.

N-Decyl-NN.dimeTryl-I-ecana nium choride 7173515 macra 1050 LCe50ia 64 >1000 5333 Zebra maqna 1C50 23 37 4-3 18386 rmas 4C 4150 470 500 17880 P.melas LC50 290 330 510 18386 Channte stuseon LC50 60- 710 10 20400 Oocssumn strmco LC50_1 39 _ 1C0 M8156 Ooc9ss Shrfimp _tC5Q 52 69 84 344 VloqK"i cysrer LC5O_ t7 95212 Ol 0 3"4 Shet minnow tC50 10ea t70 950 170 344 Zebra mussel LCS0_ 30 _ C0=0 14C,64 Wtfa- LC50 42C0 65C0 17880 Scuct LC50 90 1Ito 120 193866 Channel Caflisth LC50 69 71 730 344 Blueglill LCS0 350 590 8'10 344 3-HcmedrWarttack LC50 4850 6 120 7730 4175 Rainbow Trout LC50 373 773 20361 Rainbow Trout I LC50 970 i 1240 4 4.

Nalco esodetergent 73551 10117 Ettene Oxide 75218 Propylene oidde 75569 LCSO I 170.0010 W.mosoutotsh I LC50 I I 141.COO . 840t l 1eu0-qtl LC50 i 1 215.000 lIl _

iJ

Table 1 continued SWier Name ard CAS No Aftatic Species Erdront' Rele C leffal NarM _ _n Averace kix No etz Oeawon Spec CT13CO Oarana mara EC50 3.6 corn 5.9 com 7.5 com 344 P. nroeretas *C50 .77 c 3cm .90 ctrn 34.

Primary Actie Ingedert 8rcwn Itead LCC50 1.48 cmrn 1.59 corn 1.70 cern 344 Gddish LCSO 1.16com 1.43ccm 1.91 cm 344 (12-16) A;ky dnedl benar amaiLrn chloide 68424851 &mamltt. tbass LC50 1.29 Kcm 137por 1.45 porn 3!4 OCamrte rne ism LCSO .88 corn 58 comr 1.09 corn 3S4 Green surfist LC5O 2.04 ccm 2.25 ccm 2.43 Cem 344 tjueitl LCSO 2.36 cem 2.71 ccm 3.03 ocm 344 Redear suwtish LC50 0.56 ccm .74 ocrn .8 corm 34 Largerru bass I050corn t.07 t. t3 Cor 120 orm 344

. rcect tass LC50 10400 141C0 19100 24D8 Ratew LCSO 2.19 orm 2.45 McM 2.74 pom 344 64175 tDcotria nara LC50 >1CCCOOO 1151 Cochnia rraca POEC 4m530 14533 ett'4 alchdo (Ettanol) C. dortria Ciba LC50 72000CO 88C4CC0 12XOOM 212 Cara LCSO 8140 547 Nac PCL401 _

Prmary Acth Ingredert . Ra3tow tVcWt LC50 490 com Ingedents not provided Irom NtOS WrOMraton semirted NWA Dacelia rracra LC50 280 ccm

. BL LG'O >SOO5 cOr __rn Nalco Coagriant A4c35 rinmary Acme inredert Rairiow f0T LC50 t120 14405 OCtrCr-cystalrine Oia 148086O7 ed4teaA cea cran LCSO _ _40 poM 19974

-~ "-*'- vC...

i. ... ,,, CtoreOta'5.cA r.r rm1 Cbnoerntrorr. -ml CASNo. Aqa-tc Species Er6Pcirt _l_9 r.__

Nalro PCL-227 P. proneas Nr4EC 625 625 1.250 PFirnayActe ikeCiersd__ LOEC 1.250 1250 2.500

__ _ __ _ 1 5SO _ _ _ _ _ _ 1.853 Soiuxn sdLate 7631490-5 LC25 iM530 Satiuponphcsphate 68915-31-1 LC0I 1.336 ' ',_ _

.,_ '. 48-tr C. ciba NOEC 625 313 1.250 ptassin* 0Cs="a.e 7778-77-0 _ LCEC 1.250 625 2.500 Opotassiun pophate 7758-11.4 EC5O ___-._, 1.765 EC2S :_-'_._. 1.397 EC1O .,__.,__. 1.042 LWnza 6arquat 4250Z ...

Primary Actrve krediert 691-0 I-S P. pronre'as ECSs .3255 Ccm .364N pcrm .422S prm 4-A~kyl (C12-18) -N Ndmet-Nnbensjam md 27479-28-3 P. croiretas EC50m 205.4 pcm 3168 mom 64.449 porn N-Ocdecy N- Ndmet A'eium dcotie 27479-29-4 P. Proretas EC50z 0.313 Pcmrn

,NTerradecyf44. N-drN earn n dbide . . 0 Natco H15ihl'. . err LCW.# 0.263 ppmn (Nbte: Cis prodct teas the sane denical characserlsics as P. KrOrelas 0.0 tcrm rwoEC tona Bargiat 4250-2.) P. proelas NOEC 0. I crm C. ttia LCSO .-. . . 0.053 nor

.NOEC -

C. dba 3 Brood ____ o 02 cem C. _ _iba 3 Brood _ O0c _

• SwbazLes Ctegyy Jutsocabn ard tTes g Rsaonale. BernbiaeseCoas e Ston, yrrelc Orgmic C errc LlerAxtesAocator. Certber 2001 Data povided fromTVAandAScO tesbiN performedMarch 5-12. 2005.

Data prvded from TVA ard Ewirnr4rertal Testivv Sdoko Inc bbora'lory report Test 6idraons vary Irum 12lns to 96 hmn 2 Data souWW i TVAor a sactueW.

Sdxaopts for end pdr&s for Bawot 4250-Z are fo best data at 724'r. 46-hr. ard 96 les: at 9$'. FUxial Umits.

Some data dclriated form TVA VWN raw wter treatmert plan.

TABLE 2 Maximun Instream Concentratlon of Raw Water Treatrnent Crirical versus Calculated Water Cuality Critera NVA Sequoyah Nuclear Plant

%M e KxWDaly Wrtm Max crc. AC" tued. ACe Irged.

ActNe fgedient trederl Pve kged. Stream Actrve kred. Acte Chroric Cae CCC7 t

Ownical (or Ikgdert df Cen) in Dsdwate Fno., lstreamr Toxb;t/ Trict (12 Acute) I(V110 Ate)

C ten' ts NW tnt - WA to WI J 1 NtaO PaC-401 MirICcc CCer 28 SO' 148 1892 93.74 798 OCx 209CC 79 i-NalcoPCL.2 22 raycCccOrner 8.8% 76C 189 48.14 1.853.0CC s2e__00 185.30C Phsrtate 32.30. 228C 1890 144.42 Xalco 73551 E1i ge 04 20.C0e _ 189 3.1 200.OOC 28.OC tCr0C 28.CD Nltco Towerrrm 960 Scdtn D0ihormo arae MO.O 14s25 189 9a2e 1lSt 75 t So'xkn itonw*e 10.t0' 1425 1893 902f 60tseC t 30.CC 6.0CC TRFO 5M.70- 1425 1893 S026 19 II Sarquat 4250tZ a9cydometty bentzl 28.93' 855 1892 54.16 303 15t

-ammni ~rideI anq dimetrnyieteyt-V - 25.t0s 855 1892 54.16 agrreniumn drei NalcoHt13CM t , tN*4e y1 50.0t 8 1892 54.16 110 104 50 10.C

__canamirki dJrise o .

Bet=Dearbon- (C12.16)ra 8 diry4tbr benzy4 50.921 855 18S0 54.t6 1CC 104 10.C Specdus CT 1300 araxTum1 rtde NaicO Coaruant Aid 35 Alu m 10t _ 1892 750, 74 1 Data cbtakied tren LbIOS, aenkIa vedr. or TVA.

2 IVA data Iron Ftaw Water C1eil uA etcn Guice, Tables 2 ad 3.

3 Caventradercat based on mass balarce Lsir rrinknrui stream flow a3r asstiktq zro bacsrguctd cxcentraton instear. Values shc itt tbd tave 8e poterrtal to jated exceed ire CMZC arYrdoWe CCC.

4 Ccentra:it selected based on best prelessioral Pui~wt using data ftrct re EPA ECOTOX datbase, toxicity hrtman bor tetMSOS Ior te d*ieical. or cta preseried ty S COaeic loxidty data Ircn MSOS cr TVA data 6 CMZC is p-rsbed cnteria for TRC and alunirnr. For 6ter acfve irgredients, CL)Z calculated to be 112d re acrle toxicy in acccrdnce with EPA p oeC res.

7 CCC value isequiJ to the measured Crcnirc toxibty value or110 of actle tOxicity value (4erfe measured d'Jrkc toxicity data is atseri.)

8 Becarse the sorce d ctra aluninun is clay, a riaturaly oecurrg mateaf hi tOeTeryessee VaI'e,. and because the alurni'irn s cate is nct sduble. We CtC ard CCC are nct cesidered applicaZte to this materiaL 9 tiUnTisrearn now is tie 1010 of 3491 IN0 rrirx s tiheddiarge lkOw )( h acowts as tre intake vcdure).

Table 3 Maximum Anticipated Discharge Concentrations Versus CMC Max Daiy Avg. Plant Calc. Max. Discharge A Max Anticipated Active Ingredient Active Ingred. Discharge Concentraion2 Act. Ingred. CMC Chemical (or Ingredient et Concern) Y Active Discharge' 101 + 110' Chemical Active Ingred. Disch. Conc.

Inrgredient lbs MGOD ucl tcl tA ucA Nalco PCL-401 Anonic Cooolvmer 10O00O. t 1480 1598 111 111 200 399+0CC Nalco PCL-222 Aniionic Ccoolvmer 50.00%. 760 1598 57 29 2001 925.500 Phosohate 50O0.8 2280 1598 171 8a Naico 73551 Ethtene[Prooolvene oxide 100.00% 50 1598 4 4 2000 1i00.0c Nalco Towertbrom 960 Sodium Dichborcisocvanurate 96.00%. 1425 1598 107 103 100 TRC 7.

Sodium Bromide 10 00% sse 1598 = 100 TRC 30 CCc TRO 54.70% 1425 1598 107 100 TRC 19 Barquat4250.Z alk dmethyl benzy1 2500% 855 1598 64 16 so isol

• ammonium chloride alkyl imetyletlybenz. 2500%- 855 1598 64 1c ammonium chloride .

Nalco H-13CNM N-decyl-. N-dimethyl-l - 5000%. 855 1598 64 32 50 SE decanaminium chliodde Betz*0ear~om- (C12-16) alkldimethylbenza 50+00% a5s 1598 64 32 50 so Spectrus CT 1300 ammonium chloride __ _ _ __ _ _

Na!coCoaculantAid3S Aluminum 10.60 8520 1S98 639 68 10600 750 I Average flow reported In June 2003 NPOES permit application 2 Concentration value assumes no treatment for TRO or detoxificaton ol quaternary ammonium compounds 3 The maximum anticipated concentration presented by TVA in the Raw Water Chemical Additives table in the Raw Waer Treatment Plan 4 TVA data from Raw Water Chemical Application Guide. Tables 2 and 3.