Text

Tennessee Valley Authority (TVA) - Sequoyah Nuclear Plant (SQN) - NPDES Permit No. TN0026450 - Application for Renewal. Part 2 of 3
	ML13127A004
Person / Time
Site:	Sequoyah
Issue date:	05/02/2013
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation, State of TN, Div of Water Pollution Control
References
	TN0026450
	Download: ML13127A004 (98)
	v • d • e

Please print or type in the unshaded areas only

,iill-in areas are stnared for elite tlye. Iae 12 characters/inch).

Form Aooroved. OMB No. 2040-0086. Aoromval exoires 5-31-92.

FORM U.S. ENVIRONMENTAL PROTECTION AGENCY S

TIIIIIIIIII It/A C GENERAL INFORMATIONFT 5

4 0

O O

D G N R LIF R

A INT N

5 6

4 0

0 2

0 5

0 4

D Consolidated Permits Program (Head the "General Instructions" before starting.)

12 13 114 115 LABEL ITEMS NGENERILAL INSTRUCINS If a preprinted label has been provided, affix in the designated space. Review the information care-fully; if any of it is incorrect, cross through it and enter the correct data in the appropriate fill-in area below. Also, if any of the preprinted data is absent (the area to the left of the label space lists the information that should appear), please provide it in the proper fill-in area(s) below. It the label is complete and correct, you need not complete Items 1, ///, V, and VI (except VI-B which must be completed regardless). Complete all items it no label has been provided. Refer to the instructions for detailed item descriptions and for the legal authorizations under which this data is collected.

II. POLLUTANT CHARACTERISTICS INSTRUCTIONS: Complete A through J to determinei e EPA. if you answer yes to any questions, you must submit this form and the supplemental form listed in the parenthesis following the question. Mark "X" in the box in the third column if the supplemental form is attached. If you answer "no" to each question, you need not submit any of these forms. You may answer "no" if your activity is excluded from permit requirements; see Section C of the instructions. See also, Section D of the instructions for definitions of bold-faced terms.

MARKX MARK 'X' SPECIFIC QUESTIONS YES NO FORM SPECIFIC QUESTIONS Y

FORM ATTACHEDATTAcHED1 A.

is tnis acility apu icy owned treatment works oes or wthis aci f el er existing orpropose which results in a discharge to waters of the U.S.?

x include a concentrated animal feeding operation or X

(FORM 2A) aquatic animal production facility which results in 16 17 18 a discharge to waters of the U.S.? (FORM 2B) 19 2

21 C. is tis a facility which currently results in discharges I

is a propose acil o

0er an ose escn e to waters of the U.S. other than those described in in A or B above) which will result in a discharge to X

A or B above? (FORM 2C) 2 23 24 waters of the U.S.? (FORM 2D) 25 26 27 E.

oes or will this facility treat, store, or dispose of F. Do you or will you inject at this facility industrial or hazardous wastes? (FORM 3)

X municipal effluent below the lowermost stratum con-X taining, within one quarter mile of the well bore, 28 29__

30 underground sources of drinking water? (FORM 4) 31 32 33 G. Do you or will you inject at this facility any produced H. Do you or will you inject at this facility fluids for special water or other fluids which are brought to the sur-processes such as mining of sulfur by the Frasch face in connection with conventional oil or natural X

process, solution mining of minerals, in situ combus-X gas production, inject fluids used for enhanced tion of fossil fuel, or recovery of geothermal energy?

recovery of oil or natural gas, or inject fluids for (FORM 4) storage of liquid hydrocarbons? (FORM 4) 34 35 36 38 39 is tnhis racility a proposed stationary source whicn Is J. I snis facility a proposed stationary source wnicn Is one of the 28 industrial categories listed in the in-NOT one of the 28 industrial categories listed in the structions and which will potentially emit 100 tons x

instructions and which will potentially emit 250 tons X

per year of any air pollutant regulated under the per year of any air pollutant regulated under the Clean Clean Air Act and may affect or be located in an Air Act and may affect or be located in an attainment attainment area? (FORM 5) 42 area? (FORM 5) 43 44 45 Ill. NAME OF FACILITY I

1 1

SKIP T

V A S

E Q U O Y

A H

NUCL EAR P LANT 151 162 30 6

IV. FACILITY CONTACT A. PAOE A I B.

HONEarea coe &no.

I II I

I I

I v ~-T FACU' R. LN IO S

1 1;,

N,1 1501 4A 4-49551 5

VI. FACILTY LOCATION C. CITY OR TOWN D.

STATE E. ZIP F CO E

F C UN Y OD 41S00. D!DY DA IS T N 37 37 9

1511 401 41421 147 1

5 EPA FormIT 3L0-OCATIONINU NP(~.

EPA Form 3510-1 ("-9)

UONTIINUE ON PAGE1: 2

tiiMTIk*I I1flr ~~IEZ~l OIre.

4 VII. SIC CODES (4-dio. in order of priority)

A. FIRST B. SECOND 7

(specify) c(specify) 4# 9, 1 '1 ELECTRIC SERVICES

(

1l16 19 C. THIRD D. FOURTH

'J (sPecilrl)'

(specify)

.. Speify 7

165-9 6

19 VIII. OPERATOR INFORMATION A. NAME

____________B_________

Is the name listed as I. I I

I i

I.

I I

I f

I I

1 I

I I

I Item VIII-A also the 4TEN'N ES S EE VA' E Y A. U T HORI T V or IS C-'A ES r-~

16 65is C. STATUS OF OPERATOR (Enler the appropriate letter into teanswer box. ifPOther', specl.)

D. PHONE (are code &no.l F

FEDERAL M = PUBLIC (other than federal or state)

(specify) c_

II S

= STATE 0

ý OTHER (specify)

F 41 21 JIjjL:3 P = PRIVATE 6

5 11-181 119 21 E. STREET OR P.O. BOX I I I

I I

I III I

I I

-TI I

I I

-T I

I-P. o.

B - 0X 2

0 0 0, O

P S 4

A

-S Q N 26 55, F. CITY OR TOWN G. STATE H. ZIP CODE IX. INDIAN LAND SII I I IIs the facility located on Indian lands?

BS 0 D D

D A

I S Y T

N 3

73793B,*

7,,

YES NO 1516 401 41 42 147 51I 52 X. EXISTING ENVIRONMENTAL PERMITS A. NPDES (Discharges to Surface Water)

D. PSD (Air Emissions fro Prpsd Sources)

S'TI I

I Operating Permit, Cooling Tower. Unit 1 p0 0

2 6 4

5 0

4150-30600701-01C (see next page for other air permits) 1511o11718 3011617118 3

B. UIC (Under, round Iniection ofTF/uidsI E. OTHErR (specifP, 9

DM L331050021 SONInertLandfillPermit C. RCRA sl E. OTHER s ",

c~~ ~ 7 1 r iul~a I I

-C TI I

I _r I

(spectr)

SR ITN5 60 4 0

0 5

0 41 T1 NJ R1 01 51 01 0 1 5 Multi-Sector General Permit (stormwater) 15 161 17118 301 6718 30 Xl. MAP Aittach to this application a topographic map of the area extending to at least one mile beyond property boundaries. The map must show the outline of the facility. the location of each of its existing and proposed intake and discharge structures, each of its hazardous waste treatment, storage, or disposal facilities, and each well where it injects fluids underground. Include all springs. nvers and other surface water bodies in the map area. See instructions for precise requirements.

XII. NATURE OF BUSINESS provide a bieftd*scr*plion)

Sequoyah Nuclear Plant (SQN) produces electric power by thermonuclear fission.

Kill. CERTIFICATION (see instructions I certify under penalty of law that I have personally examined and am familiar with the information submitted n this application and all attachments and that. based on my inquiry of those persons immediately responsible for obtaining the information contained in the application, I believe that the information is true, accurate and complete. lam aware that there are significant'Tnalties for submitting false information, including the possibility of fine an im 1isonment.

4

(

tDATE SIGNED Site Vice President. Sequoyah Nuclear Plant

"/

a***rmrT

-~e~ t-90)

Form I - General Section X - Existing Environmental Permits Chattanoo-ga-Hamilton County Air Pollution Control Bureau 4150-30600701-03C 4150-30700804-06C 4150-10200501-08C 4150-30703099-09C 4150-30900203-IOC 4150-20200102-11 C Operating Permit, Cooling Tower, Unit 2 Operating Permit, Insulation Saw A and Saw B Operating Permit, Auxiliary Boilers A and B Operating Permit, Carpenter Shop Operating Permit, Abrasive Blasting Operation Operating Permit, Emergency Generators 1A, 1 B, 2A, 2B and Blackout Generators 1 and 2

44 0C IMP107 m

~;j u~g

.71 Forebay 1110 3/4 Cho 350~ 12 3-

~4~f J

I H

JAJ xl J

0 0.75 mi TVA Sequoyah Nuclear Plant NPDES Permit No. TN0026450 Hamilton County April 2013

EPA I.D. NUMBER (copy from Item 1 of Form 1)

TN5640020504 Form Approved.

OMB No. 2040-0086.

AoDroval exDires 8-31-98.

Please print or type in the unshaded areas only.

FORM U.S. ENVIRONMENTAL PROTECTION AGENCY 2C E PA APPLICATION FOR PERMIT TO DISCHARGE WASTEWATER EXISTING MANUFACTURING, 2C EPA COMMERCIAL, MINING AND SILVICULTURAL'OPERATIONS NPDES Consolidated Permits Program I. OUTFALL.LOCATION For each ouffall, listthe latitude and'16ngi-tude 6f its '6ti6 f6tht ne s5

.attf5's6cohnds ad thhaime ofrtlIe receiviIg water.

A.'OUTFALL B. LATITUDE C. LONGITUDE NUMBER

1. DEG.

2. MIN.

3. SEC.

1. DEG,

2. MIN.

3. SEC.

D. RECEIVING WATER (name)

(list) 101 35 12 30 85 5

15 Tennessee River 101E 35 13 15 85 5

45 Tennessee River IMP 103 35 8

15 85 8

0 SQN Diffuser Pond IMP 107 35 8

30 85 8

0 SON Low Volume Waste Treatment Pond 110 35 13 30 85 5

15 Intake Forebay 116 35 13 30 85 5

15 Tennessee River 117 35 13 30 85 5

0.

Tennessee River 118 35 13 30 85 5

15 Intake Forebay II. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES, A.'

Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wastewater t tthe.effielunt '.and treatment units labeled to correspond to the more detailed descriptions in Item B. Construct a water balance on the line drawing by showing average flows between intakes, operations, treatment units, and outfalls. If a water balance cannot be determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount of any sources of water and any collection or treatment measures.

B.

For each outfall, provide a description of: (1) All operations contributing wastewater to the effluent, including process wastewater, sanitary, wastewater, cooling water, and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received, by the wastewater. Continue on additional sheets if necessary.

1. OUT-

2. OPERATION(S) CONTRIBUTING FLOW

3. TREATMENT FALL NO (list)

a. OPERATION (list)

b. AVERAGE FLOW

a. DESCRIPTION

b. LIST CODES FROM (include units)

TABLE 2C-1 101 Discharges from Diffuser Pond include:

1490.854 MGD Discharge to surface water 4

A Sedimentation 1

U (1) Low Volume Waste Treatment Pond (via (1.230 MGD) pH adjustment/ neutralization 2

K Intemal Monitoring Point 103):

(

0

)

a t

r t2 (a) Discharge from metal cleaning waste ponds (IMP 107)

(b)

Turbine building sump (2)

CCW Discharge Channel:

(1447.014 MGD)

(a) Raw cooling water system Disinfection (other) 2 H

(b) Diesel fuel recover trench; high pressure fire water, potable water (c) Condenser Circulating system (d)

Stormwater Runoff (3)

Cooling tower blowdown basin (40.436 MGD)

(a) Essential Raw Cooling Water system Disinfection (other) 2 H

(b)

Cooling towers (closed/helper mode) stormwater runoff (c)

Liquid rad waste treatment system Ion exchange 2

J (d) Steam Generator Blowdown Multi-media filtration 1

Q (4) Yard drainage pond:

(2.125 MGD)

Sedimentation (settling) 1 U

(a) Construction/Demo landfill stormwater (b)

Switchyard runoff (c) Various building heat loads (d)

Yard drainage system (5)

Net Storm Water (Runoff, precipitation, less evaporation)

(0.049 MGD) 101 E Discharges from Diffuser Pond during 0MGD Discharge to surface water 4

A emergency conditions only.

OFFICIAL USE ONLY (effluent guidelines sub-categories)

EPA Form 3510-2C (8-90)

PAGE la OF 4 CONTINUE ON PAGE Ilb

EPA I.D. NUMBER (copy from Item I of Form 1)

I TN5640020504 Form Approved.

OMB No. 2040-0086.

Approval expires 8-31-98.

Please print or type in the unshaded areas only.

FORM U s. ENVIRONMENTAL PROTECTION AGENCY A

APPLICATION FORPERMIT TO DISCHARGE WASTEWATER EXISTING MANUFACTURING, COMMERCIAL, MI'NING AND SILVICULTURAL O.PER.ATIONS NPDES Consolidated Permits Program I. OUTFALL LOCATION For each 6utfall, list the lafitucde and 1o-nhit-ude&6f f71V Iai5rtd na~t.lhg*

6 orfd f*l*-re* erif'Cig*water'.

A. OUTFALL B. LATITUDE C. LONGITUD'E NUMBER

1. DEG.

2. MIN.

3. SEC.

1.'DEG.

2. MIN.

3: SEC.

D. RECEIVINGWATER (name)

See Page la II. FLOWS, SOURCES OF POLLUTION, AND TREATMENT TECHNOLOGIES.

C.

Attach a line drawing.showing the water flow through the facility..l.dicate sourcesof intakewýitbr, operations contributin wastewateF'to t*leieffluent,:and tretnrit Units labeled to. correspond to the more detailed descriptions in Item B.. Construct a water balance on ihe'line drawing by showing averpge~flows'between iria.as, operations, treatment units, and outfalls. If a water balance cannot be, determined (e.g., for certain mining activities), provide a pictorial description of the nature and amount oflany sources of water and any collection or treatment measures.

D.

For each outfall, provide a description" of: (1) All operations contributing wastewater.tp-the effluent,, including process wastewater, sbnita*W wastewte'r,-coliing water,.and storm water runoff; (2) The average flow contributed byeach operation; and (3) The treatment received by the wastewater. Continue on-additinta ;;shgets if necessay..

1. OUT-

2. OPERATION(S) CONTRIBUTING FLOW

3. TREATMENT FALL NO (list)

a. OPERATION (list)

b. AVERAGE FLOW

a. DESCRIPTION

b. LIST CODES FROM (include units)

TABLE 2C'1k IMP Discharges from Low Volume Waste Treatment 1.230 MGD Sedimentation (Settling) 1 U

103 Pond (LVWTP):

120MD Sdmnain(etig pH adjustment I neutralization 2

K (1) Discharges from metal cleaning waste (0.0022 MGD) ponds (IMP 107)

(2) Turbine Building Sump:

(1.047 MGD)

(a) Miscellaneous Low Volume Wastewaters (b) Turbine building floor and equipment pH adjustment I neutralization 2

K drains (c)

Condensate demin. regeneration waste (d)

Secondary system leaks and draindown (e) Steam Generator blowdown (f)

Component Cooling System wastewater (g) Miscellaneous equipment cooling (h)

Ice condenser waste Sedimentation (settling) 1 U

(i)

Alum sludge ponds (WTP)

Landfill 5

Q (3)

Neutral waste sump (WTP)

(0.177 MGD)

(4)

Net Storm Water (Runoff, precipitation, less evaporation)

(0.004 MGD)

IMP Discharges from Metal Cleaning Waste Ponds:

0.0022 MGD Sedimentation (Settling) 1 U

107 pH adjustment / neutralization 2

K (1)

Metal cleaning waste (0.000 MGD)**

Chemical precipitation 2

C (2)

Net Storm Water (Runoff, precipitation, less evaporation)

(0.0022 MGD)

Chemical oxidation 2

B Flocculation 1

G

- Influent lines to MCWP are disconnected Last MCWP discharge occurred on 5/31/2006 OFFICIAL USE ONLY (effluent guidelines sub-categories)

EPA Form 3510-2C (8-90)

PAGE I b OF 4 CONTINUE ON PAGE 1c

EPA I.D. NUMBER (copy from Item I of Form 1)

ITN5640020504 Form Approved.

OMB No. 2040-0086.

Approval expires 8-31-98.

Please print or type in the unshaded areas only.

FORM, ST.EN

.OMEN-TAAL.PRO T ECTI AQENCY,..

2C EPA

~~~APPLICA~OfRPR k~, IqSTqNq

N*DES.

psotshdatedP,;,F.,

t nrmts Program...,

For1eacdioutfa!llist the d a

longtud f sith e

,7 L--TFALL B. LATITUDE

.C. LONGITUDE.

OVN*

.*)R; DI

I.E

"*2;I;

'S..

?

RECEIMINGVATý,E..*li..

(is~)

1.

1. DEG

2. MI 3 SE 1

2. MIN.'

3 SEC.

D R WATER,(na..)

See Page la 4

4 4

+

4 4

4 II. FLOWS, SOURCES OF POLLUTION,,AND TREATMENT TECHNOI!

1 E.

Attah a-line drawing showing the waterflow througthe fity.

qlndicsteeS;Ur.cs.Ofn umtak nwae O

sn t

a labeledtocorrespond to.thermore detailed om,,

C thene drawi.g by showng averageVflws b treatment-units, andoualls. If a water balance canndt be determ ed (e g.' for certain mining actvMties), provide a pictorial description ofthe nature and amount of'iy sources of water and any collection or treatment measures.

F.

For each outfall, provide a description of: (1) All operations contributing wastewater to the-effluent; including process wastewater, sanitary-wastewater, cooling water,i and stormrwaterrunoff, (2) The average flow contributed by each operation; and (3) Th4etratmeqrt receivedbd the wastewater Contnue dditior sheets if necessars

1. OUT-

2. OPERATION(S) CONITRIBTNG FLO'W E

FALL. NO (list)

a. OPERATION (list)

§....VERA-'uFLOW'a*PDSCR-PTI!ON bIST'CODES FROM 110 Discharges include wastewater from:

0.058 MGD Discharge to surface waters 4

A (1)

ERCW system 0 MGD (2)

Cooling towers (closed cycle) 0 MGD (3)

Liquid rad waste treatment system 0 MGD (4)

Net Storm Water (Runoff, precipitation, (0.058 MGD) less evaporation)

MGD)

Recycle cooling water during closed mode operation is discharged through Outfall 110. Outfall 110 has been inactive for approximately 18 years, but remains in the event the plant goes into closed mode.

116 CCW Intake Trash sluice 0.006 MGD Discharge to surface waters 4

A 117 Essential Raw Cooling Water screen and 0.014 MGD Discharge to surface waters 4

A strainer backwash 118 Dredge Pond 0 MGD Discharge to surface waters 4

A Sedimentation (settling) 1 U

Filtration 1

Q Pond is not in service at this time. Therefore outfall 118 is inactive. Only stormwater from surrounding vegetated area discharges. No industrial activity in area. If in service, the pond would provide sedimentation duhng dredge activities and filtration for lower depth waste waters.

OFFICIAL USE ONLY (effluent guidelines.sub-categories)

EPA Form 3510-2C (8-90)

PAGE Ic OF 4 CONTINUE ON PAGE 2

CONTINUED FROM PAGE Ic CONTINUED FROM PAGE lc "

C. Except for storm runoff, leaks, or spills, are any of the discharges described in Items II-A or B intermittent or seasonal?

0 YES (complete the followina tableJ

[I NO (qo to Section III)

1. OUTFALL 2.-OPERATION(s)

3. FREQUENCY

4. FLOW M I, NUMBER' CONTRIBUTING FLOW

a. FLOW RATE

b. TOTAL vOLUME

a. DAYS

.b. MONTHS (in mgd)

.(specify with u.un) c1.

(list)

PER WEEK PER*YEAR (si DU.ION (specify (specify (in days) average),

average)

1. LONG TERM

2. MAXIMUM

1. LONG TERM,

2. MAXIMUM (in days)

A`ERAGE DAILY AVERAGE DAILY IMP 107 110 116 117 1.18 Metal cleaning waste waters Cooling Tower blowdown basin CCW Intake Trash Sluice ERCW Traveling Screen and ERCW Strainer Backwash ERCW Dredge Pond (a)

(b)1 4

3 (c)

(a)

(b) 12 12 12 (c)

(a)

(b) 0.0060 0.0100 0.0040 (c)

(a)

(b) 0.0450 0.0216 0.0096 (c)

(a)

(b) 0.0060 MG 0.0100 MG 0.0040 MG (c)

(a)

(b) 0.0450 MG 0.0216 MG 0.0096 MG (c)

(a)

(b)

<1

<1 (c)

(a)

(b)

(c)

Last MCWP discharge occurred on 5/31/2006. Influent lines are cut and capped. Stormwater flows only are discharged from pond.

Cooling Tower blowdown basin discharges recycled cooling water through outfall 110 while the plant is in closed mode. The plant has not entered closed mode for approximately 18 years. Outfall 110 remains inactive until closed mode operation is necessary, which will result in a discharge flow of approximately 1487.4276 MGD.

No dredging operations conducted during current permit cycle. Pond is vegetated and no industrial activity in the area.

I11. PRODUCTION.

A. Does an effluent guideline limitation promuigated~by.E underSeci6 4oeClean WaferAct apply to youracilt9' 0 YES (complete Item Ill-B)

[I NO (go to.Section IV),

B;. Are the limitations in the applicable effluent guideline expressed in terms of production (or other measure ofoperation)?

F-YES (complete Item Ill-C) 0 NO (go to Section IV)

C.. If you answered "yes" to Item Ill-B, list the quantity which represents an actual measurement of your level of produ'tior,;*expressed*ir;.n the terms and units used in the applicable effluent guideline, and indicate the affected.outfalls.

1. AVERAGE DAILY PRODUCTION..

2. AFFECTED

a. QUANTITY PER DAY

b. UNITS OF MEASURE

c. OPERATION, PRODUCT, MATERIAL, ETC.

OUTFALLS (specify)

(list outfall numbers)

IV. IMPROVEMENTS A. Are 'you now required by any Federal, State or'F66&YU t*c` Vt6 gra*`

ree tro io o wastewater treatment equipment or practices or anyother environmental programs which may-affect the discharges desri6bea inrth'is application?

This includes, but is not limited to, permit conditions, administrative or enforcement orders, enforcement compliance schedulealetters, stipulations, court orders, and grant or loan conditions.

[I YES (complete the following table) 0 NO (go to Item IV-B)

2. AFFECTED OUTFALLS 4 FINAL COM-

1. IDENTIFICATION OF CONDITION,

3. BRIEF DESCRIPTION OF PROJECT

,I.LIANCEODATE AGREEMENT, ETC.

a. NO.

b. SOURCE OFDISCHARGE

a. RE-

'b.,PRO-QUIRED JECTED B.

UOP IONAL: You may attach additional sheets describing any additional water pollution control programs (or other environmental projects which may affect your discharges) you now have underway or which you plan; Indicate whether each program is now underway or planned, and indicate your actual or planned.schedules for construction.

E] MARK "X" IF DESCRIPTION OFADDITIONAL CONTROL PROGRAMS IS ATTACHED EPA Form 3510-2C (Rev. 2-85)

PAGE 2 OF 4 CONTINUE ON PAGE 3

EPA I.D. NUMBER (copy from Item I of Form 1)

TN5640020504 CONTINUED FROM PAGE 2 V. INTAK~E AND EFFLUENT CHARACTERISTICS A, B, &0: se..instructions.before~proceeding - compjete-nte

ýstWr 6

- An ae`h ufar.nM p`eqvs06 ;

NOTE: Tables V-A, V-B, and V-C are included on separate shefets-numbered V-1 through V-9.

D; Use the space below-to list any of the pollutants listed in Table 2c-3 of the instructions, which you know or have reason to.*bele*ieve is discharged or may be discharged from any outfall. For every pollutant you list, briefly describe the reasons you believe it to be-presenltand 'report'any analyticai-data in your possession.

I I

1. POLLUTANT

2. SOURCE

1. POLLUTANT

2. SOURCE See site Biocide Corrosion Treatment Plan (B/CTP).

Dimethylamine (The use of dimethylamine will not result in detectible quantities at Outfall 101)

Steam Generator Layup VI. POTENTIAL DISCHARGES NOT COVERED BY ANALYSIS Is any pollutant listed in Item V-C a substance or a component of asuanc-wgic,-you 'curenly use~or man osi H

e!Wct, Orbyproduct.?*...

El YES (list all such pollutants below) 0 NO (go to Item VI-B)

EPA FORM 3510-2C (8-90)

PAGE 3 OF 4 CONTINUE ON PAGE 4

CONTIN~UED FROMU. PAGE~l I I3 11,*l/l IVII. BIOLOGICAL TOXICITY TESTING DATA Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on any of your discharges or on receiving water In relation to youi discharge within the last 3 years?

0 YES (identify the test(s) and describe their purposes below)

[I NO (go to Section VIll)

Per the requirements of the SON NPDES Permit No. TN0026450, IC25 toxicity testing has been conducted on discharges from Outfall 101 once per year when oxidizing biocides are being used and once per year when nonmoxidizing biocides are being used. Results are routinely submitted with the appropriate Discharge Monitoring Reports.

VIII. CONTRACT ANALYSIS INFORMATION Were any of the analyses reported in Item V performed by a contract laboratory or consulting firm?

0 YES (list the name, address, and telephone number of, end pollutants 0 NO (go to Section IX) analyzed by, each such laboratory or firm below)

C. TELEPHONE D. POLLUTANTS ANALYZED A. NAME B. ADDRESS (area code & no.)

(list)

GEL Laboratories LLC PO Box 30712 (843) 556-8171 All pollutants except for field 2040 Savage Road parameters (temperature, flow, Charleston. SC 29407 pH, sulfite, and total residual chlorine)

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

A. NAME & OFFICIAL TITLE (type orprint)

B. PHONE NO. (area code & no.)

John T. Carirvin.She Yice President, Sequoyah Nuclear Plant (423) 843-7001 C. SIGNATUR

0.

AEJ D

DAE7N EPA Form3CjC(;0 0)ý I /

PAGE 4 OF 4

PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY. You may report some or all of EPA I.D. NUMBER (copy from Item 1 of Form 1) this information on separate sheets (use the same format) instead of completing these pages.

TN5640020504 SEE INSTRUCTIONS.

V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Form 2-C) 1 PART A - You must provide the results of at least one analysis for even pollutant in this table. Coinlete one tablefbreach° outfall. See instructions for additional details.

2. EFFLUENT

3. UNITS 4: INTAKE,,optionaI)

1. POLLUTANT

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE (specify if blank)

a. LONG TERM (ifavailable)

(if available)

d. NO. OF AVERAGE VALUE

b. NO. OF (1)

(2) MASS (1)

(2) MASS ANALYSES

a. CONCEN-

b. MASS (1)

(2) MASS ANALYSES CONCENTRATION CONCENTRATION CONCENTRATION TRATION CONCENTRATION

a. Biochemical Oxygen Demand

<2.00 1

mg/L

<2.00 1

B.OD)

b. Chemical Oxygen Demand 25.8 1

mg/L 23.4 1

(COO)

c. Total Organic Carbon (TOC) 2.87 1

mg/L 2.84 1

d. Total Suspended Solids (TSS) 4.67 1

mg/L 2.64 1

B. Ammonia (as N) 0.129 1

1 mg/L 0.144 1

VALUE VALUE VALUE VALUE

f. Flow 1770 1527 762 MGD 1616 1

q. Temperature VALUE VALUE VALUE VALUE (winter) 34.4 26.5 394

°C

h. Temperature VALUE VALUE VALUE VALUE (summer) 43.2 36.7 354 0C 25.8 IpHMINIMUM MAXIMUM8 MINIMUM MAXIMUM I. pH7.68 4

STANDARD UNITS P'ART B -

Mark "X" in column 2-a for each pollutant you know or have reason to believe is present. Mark X in column 2-b for each pollutant you believe to be absent. If you mark column 2a for any pollutant which is limited.

either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant. For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements.

2. MARK 'X'

3. EFFLUENT

4. UNITS

5. INTAKE(optional)

1. POLLUT-

a. BE-

b. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM ANT AND LIEVED LIEVED (if available)

(if available)

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE

b. NO. OF CAS NO.

PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1)

(2) MASS ANAL-(if available)

SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES CONCENTRATION YSES

a. Bromide (24959-6-9)

X

<0.200 1

mg/L

<0.200

b. Chlorine, Total Residual X

<0.07 1

mg/L

<0.05

c. Color X

20.0 1

PCU 15.0

d. Fecal Coliform X

B.. Fluoride (16984-48-8)

X

<0.100 1

mg/L

<0.100.

f. Nitrate-Nitrite (as N)

X 0.167 1

mg/L 0.127 EPA Form 3510-2C (8-90)

Page V-1 CONTINUE ON PAGE V-2

II lM V-IS UUN I INUIW I-KUM FAjl V-1

2. MARK X

3. EFFLUENT

4. UNITS

5. INTAKE (optional)

1. POLLUT-

a. BE-

b. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM -

b. NO. OF ANT AND LIEVED LIEVED iffavailable*

ifavallable j

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-CAS NO.

PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1)

(2) MASS YSES (if available)

SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES CONCENTRATION

g. Nitrogen, Total Organic X

0.247 1

mg/L 0.314 1

(as N)

I

h. Oil and Grease X

<4.00 1

mg/L

<3.95 1

I. Phosphorus (as P), Total X

<0.050 1

mg/L

<0.050 1

(7723-14-0)

i. Radioactivity (1) Alpha, Total X*

(2) Beta, Total X*

(3) Radium, Total X*

(4) Radium 226, Total X*

k. Sulfate (asS6 4)

X 12.9 1

mg/L 12.9 1

614808-7M~)_________

L Sulfide (asS) x

<0.100 1

mg/L

<0.100 1

m Sulfite (as So4 )

x

<2.0 1

mg/L

<2.0 1

(14265-45-3)

n. Surfactants x

<0.050 1

mg/L

<0.050 1

o. Aluminum.

Total X

0.050 1

mg/L

<0.050 1

(7429-90-51

p. Barium, Total X

0.0279 1

mg/L 0.0280 1

(7440-39-3)

q. Boron, Total X

0.0281 1

mg/L 0.0178 1

(7440-42-8)

r. Cobalt, Total X

<0.001 1

mg/L

<0.001 1

(744048-4)

s. Ironjotal (7439-b9-6)

X 0.131 1

mglL 0.0919 1

t. Magraesium, Total

. X 6.36 1

mg/L 6.18 1

I74s3995~4)_________________

u. Molybdenum, Total-.

X 0.000564 1

mg/L 0.000584 1

j[7439-98I7)

v. Maifigandse, Total X

0.0630 1

mg/L 0.0395 1

(7439-96-5)

w. Tin' Total (74ý40-31-5)

X

<0.005 1

mg/L

<0.005 1

x. Titanium, Total X

<0.005 1

mg/L

<0.005 1

lly occurnng ra~ioaTiveTI-EPA Form 35110-2C Page V-2 CONTINUE ON PAGE V-3

EPA I.D. NUMBER (copy from Item 1 of Form 1)

OUTFALL NUMBER TN5640020504 101 CONTINUED FROM PAGE 3 OF FORM 2-C PART C -

If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GCIMS fractions you must test for. Mark "X" in column 2-a for all such GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2-a (secondary industries, nonprocess wastewater-outfalls, and nonrequired GC/MS fractions), mark "XW in column 2-b for each pollutant you know or have reason to believe is present. Mark "X in column 2-c for each pollutant you believe is absent: If you mark colutn 2a for any pollutant, you must provide the results of at least one analysis for that pollutant, If you mark column 2b for any pollutant, you must provide the results of at least one analysis for that pollutant if you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4 dinitrophenol, or 2-methyl-4, 6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have, reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise for pollutants for which you 'mark column 2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully.

Complete one table (all 7 pages) for each outfall. See instructions for additional details and reqtuirements.

1. POLLUTANT

2. MARK X'

3. EFFLUENT

4. UNITS

5. INTAKE (optional AND CAS

a. TEST-b. BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE.

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED (if available)

(if available

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-PRE-AB-(1)

(2) MASS (1)

(2) MASS (I)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES QUIRED SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES

. TRATION METALS, CYANIDE, AND TOTAL PHENOLS IM. Antimony, Total (7440-36-0)

X

<0.002 1

mg/L

<0.002 1

2M. Arsenic, Total (7440-38-2)

X

<0.005 1

mg/L

<0.005 1

3M. Beryllium, Total, (7440-41-7)

X

<0.0005 1

mg/L

<0.0005 1

4M. Cadmium, Total (7440-43-9)

X

<0.0001 1

mg/L

<0.0001 1

5M. Chromium, Total (7440-47-3)

X

<0.003 1

mg/L

<0.003 1

6M. Copper, Total (7440-50-8)

X 0.00109 1

mg/L

<0.001 1

7M. Lead, Total (7439-92-1)

X

<0.002 1

mg/L

<0.002 1

8M. Mercury, Total (7439-97-6)

X 0.00000278 1

mg/L 0.00000169 1

9M. Nickel, Total (7440-02-0)

X

<0.002 1

mg/L

<0.002 1

10M. Selenium, Total (7782-49-2)

X

<0.005 1

mg/L

<0.005 I1M. Silver, Total (7440-22-4)

X

<0.001 1

mg/L

<0.001 1

12M. Thallium, Tta l.(7440-28-0)

X

<0.0005 1

mg/L

<0.0005 1

13M. Zinc,.Total (74-40"6-6)

X

<0.010 1

mg/L

<0.010 1

14M. Cvyaide, Total (57-1275)

X

<0.005 1

mg/L

<0.005 1

15%M

Phenols, Total X

<0.007 1

mg/L

<0.005 1

DIOXIN 2,3,7,8-Tetr&T IDESCRIBE RESULTS chlorodibenIZ0-P X

Di6xin (1764-01-6)

EP om31O-C(-0iax OTNU NPG -

EPA Form 3510-2C (8-90)

Page V-3 CONTINUE ON PAGE V-4

CONTINUED FROM PAGE V-3

1. POLLUTANT

2. MARK 1

3. EFFLUENT

4. UNITS S_ INTAKE (potiona l AND CAS

a. TEST-b. BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED ILIEVED

"_(if available 0ifavailable)

d. NO. OF a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-PRE-lAB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES QUIRED jSENT SENT CONCENTRA ITION CONCENTRATION CONCENTRATION YSES TRATION GClMS FRACTION - VOLATILE COMPOUNDS IV. Acrolein (107-02-8)

X

<0.005 1

mg/L

<0.005 1

2V. Acrylonitrile (107-13-1)

X

<0.005 1

mg/L

<0.005 1

3V. Benzene (71-43-2)

X

<0.001 1

mg/L

<0.001 1

4V. Bis (Chlom-.

methyl) Ether X*

(542-88-1) 5V. Bromoform (75-25-2) x

<0.001 1

mg/L

<0.001 1

6V. Carbon Tetrachloride X

<0.001 1

mg/L

<0.001 1

(56-23-5) 7V. Chlorobenzene (108-90-7)

X

<0.001 1

mg/L

<0.001 1

BV. Chlorodi-bromomethane X

<0.001 1

mg/L

<0.001 1

(124.48-1) 9V. Chloroethane (75-00-3)

X

<0.001 1

mg/L

<0.001 1

1OV. 2-Chloro-ethilvinyl Ether X

<0.005 1

mg/L

<0.005 1

(110-75-8) 11V. Chloroform (67-66-3)

X

<0.001 1

mg/L

<0.001 1

12V. Dichloro-bromomethane X

<0.001 1

mg/L

<0.001 1

(75-27-4) 13V. Dichloro-difluoromet6ane X*

<0.001 1

mg/L

<0.001 1

14V. 1,1-Dichloro-ethane (75-34-3)

X

<0.001 1

mg/L

<0.001 1

15V. 1,2-Dichloro-ethane (107-06-2)

X

<0.001 1

mg/L

<0.001 1

16V. 1,1-Dichloro-ethylene(75-35-4)

X

<0.001 1

mg/L

<0o001 1

17V. 1,2-Dichloro*-

propane (78"87-5)

X

<0.001 1

mg/L

<0.001 1

18V. 1,3-Dichloro-propylene (542-75-6)

X

<0.002 1

mg/L

<0.002 1

19V. Ethylbenzene (106-414)

X

<0.001 1

mg/L

<0.001 1

20V.. Methyl Bromide (74-83-9)

X

<0.001 1

mg/L

<0.001 1

21V. Methyl Chloride (74-87-3)

X

<0.001 1

mg/L

<0.001 1

SNOTE: Bis (h o-me

)

y

=an~ic oro-clfuoromettan were removed as

'requirements frrom-4 H Part 123 reE i

EPA Form 3510-2C (8-90)

Page V-4 CONTINUE ON PAGE V-5

EPA I.D. NUMBER (copy from Item I of Form 1)

OUTFALL NUMBER I

TN5640020504 101 I

GUN I INUI=

I-HUM IJAUE V-4

1. POLLUTANT

2. MARK X

3. EFFLUENT

4. Ul ITS 5 INTAKE (onti-n

_1 AND CAS

a. TEST-b. BE-1c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED iffavailable)

(if available

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES

_ QUIRED SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION Q-CIMS FRACTION -VC:

binsL tePl D/n

t/nUnd) 22V. M1thylene Chlorde (75-09-2)

X

<0.002 1

mg/L

<0.002 1

23V. 1,1,2,2-Tetra-chloroethane X

<0.001 1

mg/L

<0.001 1

(79-34-51 24V. Tetrachloro-ethylene (127-18-4)

X

<0.001 1

mg/L

<0.001 1

25V. Toluene (108-88-3)

X

<0.001 1

mg/L

<0.001 1

26V. 1,2-Trans-Dichloroethylene X

<0.001 1

mg/L

<0.001 1

f156-60-5) 27V. 1,1,1-Tri-chloroethane X

<0.001 1

mg/L

<0.001 1

(71-55-6B 1

28V. 1;1,2-Tri-chloroethane X

<0.001 1

mg/L

<0.001 1

(79-0o-5) 29V. Trichloro-ethylene (79-01-6)

X

<0.001 1

mg/L

<0.001 1

30V. Trichloro-fluoromethane X.

<0.001 1

mg/L

<0.001 1

f75-69-4) 31V. Vinyl Chloride (75-01-4)

X

<0.001 1

mg/L

<0.001 1

GCIMS FRACTION - ACID COMPOUNDS 1A. 2-Chloroiheho (95-57-8)

X

<0.010 1

mg/L

<0.010 1

2A. 2,4-Dichloro-phenol (120-83-2)

X

<0.010 1

mg/L

<0.010 1

3A. 2,4-Dimethyl-phenol (105-67-9)

X

<0.010 1

mg/L

<0.010 1

4A. 4,6-Dinitro-O-Cresol (534-52-1)

X

<0.010 1

mg/L

<0.010 1

5A. 2,4-Dinitro-phenol (51-28-5)

X

<0.020 1

mg/L

<0.020 1

6A. 2-Nitrophenol (88-75-5)

X

<0.010 1

mg/L

<0.010 1

7A. 4-Nitmphenol (100-0247)

X

<0.010 1

mg/L

<0.010 1

8A. P-Chloro-M Cresol (59-50-7)

X

<0.010 1

mg/L

<0.010 1

9A. Pentachloro-phenol (87-86-5)

X

<0.010 1

mg/L

<0.010 1

10A. Phenol (108-95-2)

X

<0.010 1

mg/L

<0.010 1

1 IA. 2,4,6-Trichloro-phenol (88-06-2)

X

<0.010 1

mg/L

<0.010 1

-NUTE: I ricflrT u~T re was remove as rquireme R Par 12 by

-S 6A

-n -9 EPA Form 3510-2C (8-90)

Page V-5 CONTINUE ON PAGE V-6

CONTINUED FROM PAGE V-5

1. POLLUTANT

2. MARK X

3. EFFLUENT

4. UNITS

5. INTAKE (optionl

)

AND CAS

a. TEST-b. BE-jc. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED (if available (ifavailable)

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

-IRE-PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES OUIRED ISENT SENT I CONCENTRATION CONCENTRATION CONCENTRATION

- YSES TRATION GCIMS FRACTION - BASEINEUTRAL COMPOUNDS 1B. Acenaphthene (83-32ý9)

X 2B. Acenaphtylene (208-96-8)

X 3B. Anthracene (120-12-7)

X 4*. Benzidine (92-87-5)

X 5B. Benzo (a)

Anthracene.

X (56-5.5-3) 6B. Benzo (al Pyrene (50-32-8)

X 7B. 3,4-Benzo-fluoranthene X

(205-99L2) 8B. Benzo (qhi)

Perylene.

X (191-24-2) 9B. Benzo (k)

Fluoranthene X

(207-08-9) 108. Bis2-Chloro-ethoxyj Methane X

',111-91-1) 11P. Bis (2-Chirm-ethyl) Ether X

(111-44-4) 128. Bis (2-Chlora-isopropyl) Ether X

(1 02-60-1 )

138. Bis (2-Ethyl-he*yl) Phthalate X

(117-81-7) 14B. 4-Bromo-phenyl Phenyl X

Ether (101-55-3).

158. Butyl Benzyl Phthalate (85-68-7)

X 168. :2Chloroa naphthal6ne' X

17B. 4-Chloro-pheny) henry.l X

Ether

=7005-72-3)

(18-0.9 Cxy~n 19B. Dibenzo (b.h" Anthratene X

208*.B,2-Dich(oro-benzene (95-50-1)

X

<0.001 1

mg/L

<0.001 1

21B. 1,3-Dichloro-berzene (541-73-1)

X

<0.001 1

mg/L

<0.001 1

EPA~~~~~

~

Fom31-C 89)Pg V

OTNE NPG EPA Form 3510-2C (8-90)

Page V-6 CONTINUE ON PAGE V-7

EPA I.D. NUMBER (rcnvfmm Item 1 nf Form 1)

OUTFALL NUMBER ITN5640020504 1101 1,POLLUTAN T-

.2. MARK 1X'

3. EFFLUENT

4. UNITS

5. INTAKE (option 1)

AND CAS

a. TEST-

b. BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30.DAY VALUE

c. LONG TERM AVRG, VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED I (if available (ifevailable

d. NO. OF a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-'

PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES QUIRED _SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION C

TION B,E/NEI TRAL CWMPOU D___ontinue

22.

1i,4-Dichioro-benzene (106-46-7)

X

<0.001 1

mg/L

<0.001 1

23B. 3,3'-Dichloro-benzidine X

(91-94-1) 24B. Diethyl Phthalate X

(84-66-2) 25B. Dimethyl Phthalate X

(131-11-3) 26B. Di-N-Butyl Phthalate X

(84-74-2) 27B. 2.4-Diniro-toluene (121-14-2)

X 28B..2,6-Dinitro-toluene (606-20-2)

X 29B. Di-N-Octyl Phthalate X

(117-84-0) 30B..1.2-Diphenyl-hydrazine (asAzo-X 31B. Fluoranthene (206-44-0).

X 32B. Fluorene (86-73-7)

X 33B. Hexachlorobenzene (118-74-1)

X 34B. Hexa-chlorobutadiene X

(87-68-3) 35B. Hexachloro-cyclopentadiene X

(77-47-4) 36B. Hexachloro-ethane (67-72-1)

X 378 Indeno (1,.2,3-cd) Pyrene X

(193ý39-5)_

38B. lsophorone (78-59-1)

X 39B. Naphthalene (91720-3)

X 40B. Nitrobenzene (98-9563).

X 41&B.N-Nitro-sadimethylamine X

4(62-75N9).

42B. N-N~itrosodi-Pr pylamn Xt

'62-64-71 x

EPA Form 3510-2C (8-90)

Page V-7 CONTINUE ON PAGE V-8

1. POLLUTANT

2. MARK'X 1

3. EFFLUENT

4. UNITS

5. INTAKE (otiont L

AND CAS

a. TEST-b. BE-c BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED (if available (ifavailable)

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-PRE AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN (2) MASS YSES

, UREDSENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION I

GCIMS FRACTION - B SE/NEU 'RAL CC MPOUNI S (continued) 43B. N-Nitro-sodiphenylamine X

(86-30-6) 44B. Phenanthrene (85-01-8)

X 45B. Pyrene (129-00-0)

X 46B. 1,2,4 - Tri-Xhlorobenzene X

<0.001 1

mg/L

<0.001 (120-82-1)

GCIMS FRACTION - PESTICIDES WP. Aldrin (309-00-2)

X 2P. a-BHC (319-84-6)

X 3P. -

-BHC (319-85--7)

X 4P. v-BHC (58-89-9)

X 5P. 6-BHC (319-86-8)

X 6P. Chlordane (57-74-9)

X 7P. 4,4'-DDT (50-29-3)

X 8P. 4,4'-DDE (72-55-9)

X 9)P. 4,4'-DDD (72-54-8)

X 10P. Dieldrin (60-57-1)

X l1P. d-Endosulfan (115-29-7)

X 12p. R-Endosulfan (1.15-129-7)'

X 13P. Endosulfan*

Sulfate X

(1031-07-8).,

14P. Ehdrin 72k-20-8)

X 15P..,Ehdin Ahdehyde X

(7_42193-4 )-

16Pý, eptachlor

76 8

)

X EP' om3102 89)PgeV8CNIU NPG EPA Form 3510-2C (8-90)

Page V-8 CONTINUE ON PAGE V-9

EPA I.D. NUMBER (coov from Item 1 of Form 1; OUTFALL NUMBER TN5640020504 101 I

CONTINUFn FRnM PAr.F V-B

1. POLLUTANT

2. MARK X

3. EFFLUENT

4. UIIITS

5. INTAKE (optiona )

AND CAS

a. TEST-b.

BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONGTERM

a. LONG TERM

b. NO. OF NUMBER ING ILIEVED ILIEVED (ifavailable)

(if available

d. NO. OF AVERAGE VALUE AVERAGE VALUE ANAL-(ifavailable)

RE-

'IPRE-AB (1)

(2) MASS (1)

(2) MASS ANAL-

a. CONCEN-

b. MASS (1) CONCEN-(2) MASS YSES QUIRED SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES" TRATION

. TRATION

-CIMS FRACTION ESTICI ES (continued) 17B. Heptachlor Epoxida X

(1024-57-3) 18P. PCB-1242 (53469-21-9)

X 19P. PCB-1254 (11097-69-1)

X 20P. PCB-1221 (11104-28-2)

X 21P. PCB--1232 (11141-16-5)

X 22P. PCB-1248 (12672-29-6)

X 23P. PCB,-1260 (11096-82-5)

X 24P. PCB-1016 (12674-11-2)

X 25P. Toxaphene (8001-35-2)

X EPA Form 3510-2C (8-90)

Page V-9

PLEASE PRINT OR TYPE IN THE UNSHADED AREAS ONLY. You may report some or all of EPA I.D. NUMBER (copy from Item 1 of Form 1) this information on separate sheets (use the same format) instead of completing these pages.

TN5640020504 SEE INSTRUCTIONS.

V. INTAKE AND EFFLUENT CHARACTERISTICS (continued from page 3 of Form 2-C)

PART A - You must provide the results of at least one analysis for every pollutant in this table. Cornlete one table foe each outfall. See instructions for additiIdetails.

2. EFFL UENT

3. UNITS

4. INTAKE (optional)

1. POLLUTANT

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE (specify if blank)

a. LONG TERM (if available)

(if available)

d. NO. OF AVERAGE VALUE

b. NO. OF (t)

(2) MASS (1)

(2) MASS ANALYSES

a. CONCEN-

b. MASS (1)

(2) MASS ANALYSES CONCENTRATION CONCENTRATION CONCENTRATION TRATION CONCENTRATION

a. Biochemical Oxygen Demand

. 2.91 1

mg/L

<2.00 1

(BO)D

b. Chemical Oxygen Demand.

28.3 1

mlg/L 23.4 1

(COD)

c. Total Orqanic Carbon (TOC) 4.73 1

mg/L 2.84 1

d. Total Suspended Solids (TSS) 16.0*

<9.1 54 mg/L 2.64 1

e. Ammonia (as N) 0.170 1

mg/L 0.144 1

VALUE VALUE VALUE VALUE

f. Flow 2.06 1.06 762 MGD 1616 1

q. Temperature VALUE VALUE VALUE VALUE (winter)

h. Temperature VALUE VALUE VALUE VALUE (summer) 34.8 4C 25.8 MINIMM AXIMUM MINIMUM MAXIMUM I. pH 6.73 8.35 72 STANDARD UNITS PAK 11:1 -

Mark "X" in column 2-a for each pollutant you know or have reason to believe is present. Mark WX" in column 2-b for each pollutant you believe to be absent. If you mark column 2a for any pollutant which is limited -

either directly, or indirectly but expressly, in an effluent limitations guideline, you must provide the results of at least one analysis for that pollutant. For other pollutants for which you mark column 2a, you must provide quantitative data or an explanation of their presence in your discharge. Complete one table for each outfall. See the instructions for additional details and requirements.

2. MARK W

1

3. EFFLUENT

4. UNITS

5. INTAKE (optional)

1. POLLUT-

a. BE-

b. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

. LONG TERM AVRG. VALUE

a. LONG TERM ANT AND LIEVED LIEVED (if available)

(ifavailable)

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE

b. NO. OF CAS NO.

PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION I1)

(2) MASS ANAL-(if available)

SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES CONCENTRATION YSES

a. Bromide (24959-67-9)

X

<0;20 1

mg/L

<0.200

b. Chlorine;,

Total Residual X

<0.06 1

mg/L

<0.05

c. Color X

40.0 1

PCU 15.0

d. Fecal Coliformn X

e: Fluoride (16g84-8)

X 0.104 1

mg/L

<0.100 1

f.Nitrate-Nitrite (as N)

X 0.301 1

mg/L 0.127 1

- value based on histoncal i 55 oata irom routIne grab samples collecteo as requireo by me permirt ano does not incluoe me composite sample result o1 7.2u mg/L I S:).

EPA Form 3510-2C (8-90)

Page V-11 CONTINUE ON PAGE V-2

ITEM V-B CONTINUED FROM PAGE V-1

2. MARK X

3. EFFLUENT

4. UNITS

5. INTAKE (optional)

1. POLLUT-a: BE-

b. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF ANT AND LIEVED LIEVED (ifavailea (ifavaidab/eL

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-CAS NO.

PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1)

(2) MASS YSES (if available)

SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES CONCENTRATION

g. Nitrogen, Total Organic X

0.740 1

mg/L 0.314 1

(as N)

h. Oil and Grease X

17.0

<5.7 55 mg/L

<3.95 1

I. Phosphorus (as P), Total X

0.0696 1

mg/L

<0.050 (7723-14-01

. Radioactivity (1) Alpha, Total X*

(2) Beta, Total X*

13) Radium, Total X*

14) Radium 226, Total X*

k. Sulfate (as SO4 )

X 23.7 1

mg/L 12.9 (14808-79-8)

I. Sufide as'S)

X

<0.100 1

mg/L

<0.100 m Sulfite (as SO4)

X 2.0 1

mg/L

<2.0 (14265-45-3)

n. Surfactants X

<0.050 1

mg/L

<0.050

o. Aluminum, 1

Total X

0.0968 1

mg/L

<0.050 (7429-90-5)

p. Barium, Total X

0.0312 1

mg/L 0.0280 1

f7440-39-3) qj. Boron, Total X

0.0287 1

mg/L 0.0178 1

(7440-42-8)

r. Cobalt, Total X

<0.001 1

mg/L

<0.001 1

(7440-48-4)

s. IronTotal (7439-89-6)

X 0.221 1

mg/L 0.0919 1

t. Magnesium, Total X

6.33 1

mg/L 6.18 1

L7439-95-4)

u. Molybdenum, Total X

0.00092 1

mg/L 0.000584 1

(7439-98-7)

v. Manganese, Total X

0.0966 1

mg/L 0.0395 1

(7439-9675)

w. Tin, Total (7440-3.1-5)

X

<0.005 1

mg/L

<0.005 1

x. Titanium, Total X

<0.005 1

mg/L

<0.005 1

Believed absent other than naturally occurring radioactive materials.

EPA Form 3510-2C Page V-2 CONTINUE ON PAGE V-3

EPA I.D. NUMBER (copy from Item 1 ofForm 1)

OUTFALL NUMBER I

TN5640020504 103 I

CONTINUED FROM PAGE 3 OF FORM 2-C PART C -

If you are a primary industry and this outfall contains process wastewater, refer to Table 2c-2 in the instructions to determine which of the GC/MS fractions you must test for. Mark WX in column 2-a for all such GC/MS fractions that apply to your industry and for ALL toxic metals, cyanides, and total phenols. If you are not required to mark column 2-a "(secondary.industries, nonprocess wastewaterou.aflls, and nonrequired GCIMS fractions), mark WX" in column 2-b for each pollutant you know or have reason to believe is present. Mark "X" in column 2-c for each pollutant you believe is absent. If you mark column 2a for any pollutant, you must provide the results of at least one analysis for that pollutant. If you mark column 2b for any pollutant, you must provide the results of at least one analysis for that pollutant if.you know or have reason to believe it will be discharged in concentrations of 10 ppb or greater. If you mark column 2b for acrolein, acrylonitrile, 2,4 dinitrophenol, or 2-methyl-4,.6 dinitrophenol, you must provide the results of at least one analysis for each of these pollutants which you know or have reason to believe that you discharge in concentrations of 100 ppb or greater. Otherwise for pollutants for which you mark column 2b, you must either submit at least one analysis or briefly describe the reasons the pollutant is expected to be discharged. Note that there are 7 pages to this part; please review each carefully.

Complete one table (al/ 7 pages) for each outfall. See instructions for additional details and requirements.

1. POLLUTANT

2. MARK X

3. EFFLUENT

4. UNITS

5. INTAKE (optional)

AND CAS

a. TEST-b. BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED (if available) iffavailable

d. NO. OF a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES

_QUIRED SENT jSENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION -

METALS, CYANIDE, AND TOTAL PHENOLS 1M. Antimony, Total (7440-36-0)

X

<0.002 1

mg/L

<0.002 2M. Arsenic, Total (7440-38-2)

X

<0.005 1

mg/L

<0.005 3M. Beryllium, Total. (7440-41-7)

X

<0.0005 1

mg/L

<0.0005 1

4M. Cadmium, Total (7440-43-9)

X

<0.0001 1

mg/L

<0.0001 1

5M. Chromium, Total (7440-47-3)

X

<0.003 1

mg/L

<0.003 1

6M. Copper, Total (7440-50-8)

X 0.00224 1

mg/L

<0.001 1

7M. Lead, Total (7439-92-1)

X

<0.002 1

mg/L

<0.002 8M. Mercury, Total (7439-97-6)

X 0.00000103 1

mg/L 0.00000169 1

9M. Nickel, Total (7440-02-0)

X

<0.002 1

mg/L

<0.002 1

10M. Selenium, Total (7782-49-2)

X

<0.005 1

mg/L

<0.005 1

11M. Silver, Total (7440-22-4)

X

<0.001 1

mg/L

<0.001 12M. Thallium.

Total (7440-28-0)

X

<0.0005 1

mg/L

<0.0005 13M. Zinc, Total (7440-66-6)

X

<0.010 1

ng/L

<0.010 1

14M.'C*yanide, Total (57-12-5)

X

<0.005 1

mg/L

<0.005 1

15M. Phenols, fotal X

<0.005 1

mg/L

<0.005 DIOXIN

-r I

X IDESCRIBE RESULTS ch16rodiberizo-P X

D~ibxin (1764"-01-6)

EPA Form 3510-2C (8-90)

Page V-3 CONTINUE ON PAGE V-4

CONTINUED FROM PAGE V-3

1. POLLUTANT

2. MARK 'X'

3. EFFLUENT

4. UNITS 5 INTAKE (nntionM AND CAS

a. TEST-

b. BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED (if available (ifavallable)

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-'

(if available)

RE-PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES QUIRED _SENT SE§T CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION GClMS FRACTION - VOLATILE COMPOUNDS 1V. Acrolein (107-02-8)

X

<0.005 1

mg/L

<0.005 1

2V. Acrylonitrile (107-13-1)

X

<0.005 1

mg/L

<0.005 1

WV. Benzene (71-43-2)

X

<0.001 1

mg/L

<0.001 1

4V. Bis (Chloro-methyl) Ether X

(542-88-11 5V. Bromoform (75-25-2)

X

<0.001 1

mg/L

<0.001 1

6V. Carbon Tetrachlodde X

<0.001 1

mg/L

<0.001 1

(56-23-5) 7V: Chlorobenzene (108-90-7)

X

<0.001 1

mg/L

<0.001 1

8V. Chlorodi-bromcriiethane X

<0.001 1

mg/L

<0.001 1

(124-48*1

9V. Chloroethane

(.75-00-3)

X

<0.001 1

mg/L

<0.001 1

1OV. 27Chloro-ethylvinyl Ether X

<0.005 1

mg/L

<0.005 1

(110-75")8_

11V; Chloroform (67-68-3)

X

<0.001 1

mg/L

<0.001 1

12V. Dichloro-bromomethane X

<0.001 1

mg/L

<0.001 1

(75-27-41 13V. Dichloro-difluoromethane X*

<0.001 1

mg/L

<0.001 1

(75-71-8)-

14V. 1,1-Dichloro-ethane'(75-34-3)

X

<0.001 1

mg/L

<0.001 1

15V. 1,2-Dichloro-ethane (107-06-2)

X

<0.001 1

mg/L.

<0.001 1

16V. 1,1 -Dichloro-ethylene (75-35-4)

X

<0.001 1

mg/L

<0.001 1

17V., 12.Dichloro-propane (78-87-5)

X

<0.001 mg/L

<01001 18V. 1, 3-Dichloro-propyloe (542-75-6)

X

<0.002 1

mg/L

<0.002 1

19V: Ethy!benzene (100-41-4)

X

<0.001 1

mg/L

<0.001 1

20V. moth~xd promide:(74-83-9)

X

<0.001 1

mg/L

<0.001 1

21V. Methyl Chloride (74-87-3)

X

<0.001 1

mg/L

<0.001 1

NU IL:s (l

Ethera

~ic iuorom e a were removed as requiremei B

y 1, I EPA Foffn 3510-2C (8-90)

Page V-4 CONTINUE ON PAGE V-5

Lr-FMAI.U.

rNUMULK copyfrommuem. oftinm1 I

TN5640020504 OUUIIALL NUMULK 1

103 GUN I INUkI-I-OM pIAUh V-4

1. POLLUTANT

2. MARK X

3. EFFLUENT

4. UNITS S. INTAKE (nntipn 1I AND CAS

a. TEST-c BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING ILIEVED ILIEVED (if available-(iffavailablel

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE.

IPRE-AB-

[

(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES QUIRED jSENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION

CUM FTACTION -VS -_TILF___MP____i_____

__tn 22V. Methylene Chlorde (75-09-2)

X

<0.002 1

mg/L

<0.002 1

23V. 1,1.2,2-Tetra-chloroethane x

<0.001 I

mg/L

<0.0011 (79-34-51 24V. Tetrachloro-ethylene (127-18-4)

X

<0.001 1

mg/L

<0.001 1

12.loluefle 1(108-88-3) x

<0.001

-1 mg/L

<0.001 1

26V. 1,2-Trans-Dichloroethylene X

<0.001 1

mg/L

<0.001 1

(156-60-51 27V. 1,1,1-Tri-chltroethane X

<0,001 1

mg/L

<0.001 1

(71-55-61 28V. 1,ý.1,2-Tn-chloroethane X

<0.001 1

mg/L

<0.001 1

(79-00-51.

29V. Trichloro-ethylene (79-01-6)

X

<0.001 1

mg/L

<0.001 1

30V. Trichloro-fluoromethane X"

<0.001 1

mg/L

<0.001 1

(75-69-4) 31V. Vinyl.

0 Chloride;(75-01-4)

X

<0.001 1

mg/L

<0.001 1

GC/MS FRACTION -ACID COMPOUNDS 1A. 2-Chlorophenb (95-57-8) x

<0.010 1

mg/L

<0.010 1

2A, 2.4-Dichloro-phenol (120-83-2)

X

<0.010 1

mg/L

<0.010 1

3A. 2,4-Dimethyl-phenol (105-67-9)

X

<0.010 1

mg/L

<0.010 1

4A. 4.6-Dinitro-O-Cresol (534-52-1)

X

<0.010 1

mg/L

<0.010 1

5A. 2.4-Dinitro-phenol. (51128-5)

X

<0.020 1

mg/L

<0.020 1

6A 2-Nitrophenol (88-75-5)

X

<0.010 1

mglL

<0.010 1

7A. 4-Nitrophenol (100-02L7),

X

<0.010 1

mg/L

<0.010 1

8A. P-Chlorbo-M ctesol (59-504-)

X

<0.010 1

mg/L

<0.010 1

9A. Pentachloro-phenol 7(87i8&5)

X

<0.010 1

mg/L

<0.010 1

10ý Phenol (108-95-2) -

X

<0.010 1

mg/L

<0.010 1

11Ak 2.4.5-Tdichloro-phenol (08-06-.2)

X

<0.010 1

mg/L

<0.010 1

1 1127R9.

TT!M

-r-,

E: Incrilorolluorbism"a removW as a requirement m -

Crm 143 by -

E EPA Form 3510-2C (8-90)

Page V-5 CONTINUE ON PAGE V-6

CONTINUED FROM PAGE V-5

1. POLLUTANT

2. MARK 'X'

3. EFFLUENT

4. UNITS INTAKE (otion'al)

AND. CAS

a. TEST-, b. BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM.

b. NO. OF NUMBER ING LIEVED LIEVED (ifavailable)

(if available)

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(ifavailable)

RE-PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES QUIRED SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION GCIMS FRACTION -BASEINEUITRAL COMPOUNDS lB. Acenaphthene (83-32-9)

X 2B. Acenaphtylene (208-96-8)

X 3B. Anthracene (120-12-7)

X 4B. Benzidine (92-87-5)

X 5B. Benzo (a)

Anthracene X

(56-55-3) 6B. Banzo (a)

Pyrene (50-32-8)

X 7B' 3,4-Benzo-fluoranthene X

(2065-99-21) 8B. Be nzb (qhi)

Perylene X

(191-24-2) 9B. Benzo (k)

Fluoranthene X

(267-08-9).

-I 10B. Bis (2-Chlarn-ethoxy) Methane X

(111-91-11 118. Bis.(2Chloro-ethyl) Ether X

(11 1-44-4) 12B. Ris (2-Chlom-isopropyl) Ether X

(102-60-1 13B. Bi.s (2-Ethyl-hexyl) Phthalate X

(1117-84

-_7) 14B. 4-Bromo-phenyl Phenyl X

Ether (101-55-3) 15B. Butyl Benzyl Phthalate (85-68-7)

X 16B. 2-Chloro-naplih.rne X

1-7B..4-:Chldrb-phe'nyl Phen`ýI X

Eth6r-(70'0572-3) 19B.Dibenfo-(a.h)

Anthracene X

(53,70-3), ý-:.-,-

I-20B:. 1",2-PDidhtoro-benzene(50-*-*.)

X

<0.001 1

mg/L

<0.001 1

21 B:. 13-Dichlorb0-benzene(54 i1i214)

X

<0.001 1

mg/L

<0.001 EPA Form 31 -

(

EPA Form 3510-2C (8-90)

Page V-6 CONTINUE ON PAGE V-7

EPA I.D. NUMBER (copy from Item I of Form 1)

OUTFALL NUMBER I

TN5640020504 1

103

';QNTINUJED FROM1 PAGE-V,-

.PO LTANT 2._MARK_____

3. EFFLUENT 1

4. UI ITS

5. INTAKE (option 1)

AND CAS Ia TEST-b. BE-c, BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING LIEVED LIEVED (if available)

(if eveiaeble

d. NO. OF a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-PRE-AB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES QUIRED SENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION GCIMS FRACTION - R TRAL C, )MPOU] IDS [continued) 22B 1.4-Dichloro-benzene (106-46-7)

X

<0.001 mg/L

<0.001 1

23B. 3,3'-Dichloro-benzidine X

(91-94-1) 24B. Diethyl Phthalate X

(84-66-2) 25B: Dimethyl Phthalate X

(131-4 1-3) 26B. Di-N-Butyl Phthalate X

(84J74-2) 27B. 2;4-Dinitro-toluene (121-14-2)

X 28B 2,6-Dinitro-toluene (606-20-2)

X 298: Di-N-Octyl Phthalate X

(117-84-0) 30B: 1,2-Diphenyl-hydi'azine (as Azo-X h ananp) (192--RR-7 31B. Fluoranthene (2064")

X 32B. Fluorene (86-73-7)

X 33B..Hexachtorobenzene (118-74-1)

X 34B. Hexa-chlorobutadiene X

(87-68-3i 35B-Hexachloro-cyclopentadiene X

'77-47-41 368. Hexachlom-etihne, (67-72-1)

X 37B. Indeno, (I,2?,3-cd),,Pyrene X

(1.93__39-_5._________________

389-.sophoron6 (76-59-1) -

X 39B-. Naphthalene (91-20-3)

X 408: Nitrobenzene (98-95-3).

X 41*B; N-Nito.-

soclimt*hyliarne X

42B. N-Nitr~tdi:P Proylýamine X

11621-64-7)

EPA Form 3510-2C (8-90)

Page V-7 CONTINUE ON PAGE V-8

1. POLLUTANT 2.&MARK__X'_

3. EFFLUENT

4. UNITS

5. INTAKE (ontioni l)

AND CAS EST-BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER ING IEVED LIEVED (if available (if availablei

d. NO. OF

a. CONCEN-

b. MASS AVERAGE VALUE ANAL-(if available)

RE-PRE-JAB-(1)

(2) MASS (1)

(2) MASS ANAL-TRATION (1) CONCEN-(2) MASS YSES I jUIRED JSENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION GCIMS FRACTION - B SE/NEU' "RAL CC M

_S

[continued) 43B. N-Nitro-sodiphenylamine X

(86-30-6) 1 44B. Phenanthrene (85-01-8)

X 45B. Pyrene (129-00-0)

X 46B. 1,2,4-Tri-chlorobenzene X

<0.001 1

mg/L

<0.001 I

(120-82-1) 1 GCIMS FRACTION - PESTICIDES 1P. Alddn (309-00-2)

X 2P. ac-BHC (319-84-6)

X 3P. R ýBHC (319-85-7)

X 4P. v BHC (58-89-9)

X 5P. 8-BHC (3,19-86-8)

X 6P. Chlordane (57-74-9)

X 7P. 4,4'-DDT (50-29-3)

X 81'. 4.4'-DDE (72-55-9)

X 9P..4,4'-DDD (72-54-8)

X 10P. Dieldrin (60-57-1)

X 1!fP. a-Endosulfan (115-*297):

x 12P.' AI-Erdosulfan 13P. Enddsulfan Spulfa te

-X (10 31-07-81

41.

=4:End~rir (72-20-.8)

X 15P'. Endrin Aldehýde X

(7421-93-4 )

16P*,.Heptachlor (76M44-8)

X EPA Form 3510-2C (8-90)

Page V-8 CONTINUE ON PAGE V-9

EPA I.D. NUMBER (copy from Item 1 of Form 1; OUTFALL NUMBER

-.- TN5640020504 I103 CONTINUED FROM PAGE V-8 1.......

16 POLLUTANT

_2.

MARK'X'

3. EFFLUENT

4.

INTAKE (opotion 1)

AND CAS

a. TEST-

b. BE-

c. BE-

a. MAXIMUM DAILY VALUE

b. MAXIMUM 30 DAY VALUE

c. LONG TERM AVRG. VALUE

a. LONG TERM

b. NO. OF NUMBER-IING

_IEVED LIEVED (ffavailable)

(if available

d. NO. OF AVERAGE, VALUE AVERAGE VALUE ANAL-(if available) iRE-IPRE-JAB-.

(1)

(2) MASS (1)

(2) MASS ANAL-

a. CONCEN-

b. MASS (1) CONCEN-(2) MASS YSES JOUIRED ISENT SENT CONCENTRATION CONCENTRATION CONCENTRATION YSES TRATION TRATION

~CIMS FRACTION -ESTICI ES (con

__nued) 17B."Heptach10r Epokide X

(1024-57-3) 18P. PCB-1242 (53469-21-9)

X 19P. PCB-1254 (11097-69-1)

X 20P. PCB-1221 (11104-28-2)

X 21P. PCB-1232 (11141-16-5)

X 22P.. PCB-1248 (12672-29-6)

X 23P. PCB-1260 (1109§6-82-5)

X 24P. PCB-101'6 (120"4-11-2)

X 25P. Toxaphene (8001-35-2)

X EPA Form 3510-2C (8-90)

Page V-9

Tennessee River 0.006 Outfall 116 42.320 0.014TOutfall 117 Outfall 118 RaCond.irclagWator ERCW Screen &

CCW Trash Sluice Intake Forebay

[IN Dredg He'I P

re ERCW Intake 1447.871 L..

pot"_

Rawtete Outfall 110 1447.014 Treatment Condenser Cooling D

CCW Discharge Water (CCW)

Channel (DC)

Intake F0.024 VCooling Water Circulating~

~

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oln Twr Units 1 & 2 1447.865oos t-Helper Mode cCs Wastewaters 0

Codnser 1005Cold Water ClsdoePiraSytlWae Circulating System Return Channel Coln oe

~Bldwdown Basin SeamrGneto 0.030 (CTB) 1 Slowdown DC ERCW System 0050 38.000 Condensate Deorin.

Raw Cooling Water 37.12n

[ Rad*&acbve FleerDraOm]

Liquid Radwaste System

w.

v and Sump Treatment System West VaheVaut Room (LRW) 0004 Laundry, Shower. and LOW Volume Waste IChemical Draft Treatment Pond Diffuser Pond (DP)

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@ Cooling Tower Basin n

Negligible flw Tennessee Valley Authority 0

Liquid Radwaste Treatment System 0,

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@ Turbine Building Sump

-N Chemical Additive Wastewater Flow Schematic Lw olue ast Teaten P

nd (

Net Stormwater Flow (runoff, NPDES Permit No. TN0026450 LwVlmWatTramnPodprecipitation, less evaporation)

April 2013 Yar D ischarg Pond All flows shown in million gallons per day (MGD)

Tennessee Department of Environment and Conservation Division of Water Pollution Control 401 Church Street, 6h Floor L & C Annex Nashville, TN 37243-1534 Phone: (615)532-0625 PERMIT CONTACT INFORMATION Please complete all sections. If one person serves multiple functions, please repeat this information in each section.

PERMIT NUMBER:

TN0026450 DATE:

April 2013 PERMITTED FACILITY: TVA Sequoyah Nuclear Plant COUNTY:

Hamilton F,.

A" P,..M""ONT.CT w

(The permit signatory authority, e.g. responsible corporate officer, principle executive officer or ranking elected official)

Official

Contact:

John T. Carlin Title or Position: Site Vice President Mailing Address:

Sequoyah Acess Road, PO Box 2000 City:

Soddy Daisy state: TN zip: 37379 Phone number(s):

(423) 843-7001 E-mail:

jtcarlin@tva.gov

ýERMT BILLLING '-ADDRESS (whiere invdicesshuldrbe sent):

Billing

Contact:

Brad M. Love Title or Position: Environmental Scientist Mailing Address:

Sequoyah Acess Road, PO Box 2000 City:

Soddy Daisy State: TN Zip: 37379 Phone number(s):

(423) 843-6714 E-mail: bmlove@tva.gov ACIUY' LOGATTIpN(actu Allcatioji of pqrnut site'and;lo'icl contact fr site activltr:

Facility Location

Contact:

Brad M. Love Title or Position: Environmental Scientist Facility Location (physical street address):

Seqouyah Access Road City:

Soddy Daisy State: TN zip: 37379 Phone number(s):

(423) 843-6714 E-mail: bmlove@tva.gov Alternate Contact (if desired):,

Title or Position:

Mailing Address:

City:

State:

Zip:

Phone number(s):

E-mail:

FACHI2E.ITREPORTING, icharge*Monitoing Reprt.(DMR) or:*other repor'ing):

Y.I.

Cognizant Official authorized for permit reporting:

Title or Position:

Facility Location (physical street address):

City:

State:

Zip:

Phone number(s):

E-mail:

Fax number for reporting:

Does the facility have interest in starting U Yes No*

electronic DMR reporting?*

CN-1090 (rev. 04-2007)

RDAs 2352 AND 2366

TENNESSEE VALLEY AUTHORITY (TVA) - SEQUOYAH NUCLEAR PLANT (SQN) -

NPDES PERMIT NO. TN0026450 - WET REASONABLE POTENTIAL Current Whole Effluent Toxicity (WET) Requirements:

Ouffall 101 -

7-day or 3-brood IC25 Hard Trigger = 43.2%

[IWC = 43.2% effluent (2.3 TUc)]

Monitoring Frequency Governed by B/CTP:

1/year when oxidizing biocides used 1 /year when non-oxidizing biocides used Proposed WET Requirements:

Outfall 101 -

7-day or 3-brood I025 Hard Trigger = 42.8%

[IWC = 42.8% effluent (2.3 TUc)]

Monitoring Frequency Governed by B/CTP:

1/year when oxidizing biocides used 1/year when non-oxidizing biocides used

Background:

The current permit, effective March 1, 2011, requires chronic toxicity biomonitoring at a frequency governed by the B/CTP and with a monitoring limit (IC25 -> 43.2%) that serves as a hard trigger for accelerated biomonitoring. Previous to the issuance of the current permit, Outfall 101 demonstrated No Reasonable Potential for excursions above the ambient water quality chronic (CCC) criterion using historical effluent data. This demonstration of No Reasonable Potential has been maintained throughout the current permit cycle as evidenced in the accompanying historical effluent data for the last 20 studies.

Based on guidance in EPA's Technical Support Document (TSD) for Water Quality-based Toxics Control (EPAI505/2-90-001), a permit limit is not required when No Reasonable Potential exists for excursions above the CCC. In this situation, the TSD recommends that biomonitoring be conducted at a frequency of once every 5 years as part of the permit renewal process.

Proposed Changes:

1. TVA requests that the current permit's requirement for the B/CTP to govern the frequency of biomonitoring remain (i.e., once per year when oxidizing biocides are used, and once per year when non-oxidizing biocides are used).

2. TVA requests that the current monitoring limit be replaced with an IC25 = 42.8%,

which is based on revised effluent flow, and is consistent with the TSD guidance for effluents demonstrating No Reasonable Potential. Toxicity at the instream wastewater concentration (IWC) would serve only as a hard trigger for accelerated biomonitoring, as stated in the current permit.

3. TVA requests changes to the Serial Dilutions table as follows:

Page 22 of 28, table following paragraph 3:

Serial Dilutions for Whole Effluent Toxicity (WET) Testing 100%

(100+ML)I2 Monitoring Limit 0.5 X ML 0.25 X ML Control Eflet(ML)

I 0"X LI

'5 M

ICntl

% effluent 100 71.4 42.8 1

21.4 10.7 0

4. TVA also requests that all other text in Section E of the permit remain unchanged.

Dilution and Instream Waste Concentration Calculations Outfall 101:

Average Discharge = 1491 MGD Tennessee River 1Q10 = 3483 MGD Dilution Factor (DF):

DF= Qs 3483 = 2.34 Qw 1491 Instream Wastewater Concentration (IWC): IWC= w =1491 x 100= 42.8%

Qs 3483 Reasonable Potential Determination:

The last 20 studies for Outfall 101 were used for determining Reasonable Potential, with all studies resulting in no observed toxicity (<1.0 TUc) and a coefficient of variation equal to zero. This outcome demonstrates that no Reasonable Potential for excursions above the CCC exists, based on data obtained from testing conducted under the current operating conditions.

Historical data for the last 20 studies follows, and is followed thereafter with documentation of chemical additions which occurred during sampling for toxicity tests for Outfall 101.

2

SQN Documentation:

Summary of SQN Outfall 101 WET Biomonitoring Results **

Test Date Test Species

64. Feb 8-15, 2005

65. Jun 7-14, 2005

66. Jul 19-26, 2005

67. Nov 1-8, 2005

68. Nov 16-23, 2005

69. Nov 14-21,2006

70. Nov 28 - Dec 5, 2006

71. May 30- Jun 6,2007

72. Dec 4-11,2007

73. Apr 15-22, 2008

74. Oct 28-Nov 4, 2008

75. Feb 10-17,2009

76. May 12-19, 2009

77. Nov 17-24, 2009

78. May 11-18, 2010

79. Nov 2-9, 2010

80. May 3-10, 2011

81. Nov 8-15, 2011

82. May 8-15, 2012

83. Aug 12-17,2012 Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Acute Results (96-h Survival)

% Survival Study in Toxicity Undiluted Units Sample (TUa) 100

<1.0 93 100

<1.0 100 100 100

<1.0 100 100

<1.0 98 100

<1.0 100 100

<1.0 98 100 100

<1.0 100 100

<1.0 100 93 100

<1.0 98 100

<1.0 100 100

<1.0 98 100

<1.0 100 100

<1.0 98 100

<1.0 100 100

<1.0 100 Chronic Results Study Toxicity Units (TUc)

<1.0

<1.0 n

40 20 20 Maximum 100

<1.0

<1.0 Minimum 93

<o.0

<1.0 Mean 99

<1.0

<1.0 CV 0.02 0.00 0.00

- Last 20 studies only were included for determining RP.

Shaded area includes data collected under the current permit.

3

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004 - August 17, 2012 Date Sodium.'. Towerbrom PCL-222 PCL-401 CL-363 Cuprostat-.,14:0M7 Nalco Hf-'50M Hypo.*hhiorite mg/L mg/L mg/L

,mgL PF mg/L mg/ ioud 73551 ing/L mg/L TRC Phosphate Copolymer DMA Azole 1

mg/L Quat TkR_

EO/PO i.

11/07/2004

<0.0187 0:000 0.014 11/08/2004

<0.0192 0.047 0.030 11/09/2004

<0.0233 0.048 0.016 0.041 11/10/2004

<0.0149 P.047 0.016 0.04-.1 11/11/2004

<0.0149 0.049 0.017 0*043:

11/1 2/2004.:

<0.0253 0.48:,

0.017 0.O42,.

02/06/2005

<0.0042 90.28 0.010 02/07/2005

<0.0116 0L.028, 0.010 0.007 02/08/2005

<0.0080 0.028 0.010 02/09/2005 0.0199 0.028 0.010 02/10/2005

<0.0042 0.028 0.010 02/11/20051, 0.0155 0.028.

0.010 0.007 06/05/2005

.0.0063 06/06/2005 0.0043 0.037 06/07/2005 0.0103 0.037 06/08/2005 0.0295 0.037 06/09/2005 0.0129 06/10/20051 0.0184-07/17/2005 0.0109 0.026 0.009 07/18/2005 0.0150

'0.026 0.009 0.036 07/19/2005 0.0163 0.026 0.009 0.036 07/20/2005 0.0209 0.026, 0.009 0.014 0.036 07/21/2005 0.0242 0.026 0.009 07/22/2005 0.0238

.0.054 0.018 0.014 10/30/2005 0.0068 10/31/2005 0.0112 11/01/2005 0.0104 0.035 11/02/2005 0.0104 "0-0.036 11/03/2005 0.0117 0.036 11/04/2005 1 0.0165 0.035 11/14/2005, 0.0274 11/15/2005 0.0256 11/16/2005 0.0234 11/17/2005 0.0231 11/18/2005 0.0200 11/19/2005 1 0.0116 4

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004 - August 17, 2012 Date Sodium.

Towerbrom PCL-222 PCL-401 CL-363 Cuprostat-H-130M Nalco H-MSW Hypoch T

PDite mgiL mg/L mg/L mg/L PF mg/L mg/L Quat 73551 150M 101 mgy L TRC Phosphate Copolymer DMAD Azole mg/L mg/L mg/L TRC EO/PO Quat Phosphate 11/12/2006 0.0055 11/13/2006 0.0068 0.037 11/14/2006.

0.0143 0.037 11/15/2006 0.0068 0.037 11/16/2006 0.0267 0.037 11/17/2006 0.0222 11/26/2006 0.0188 11/27/2006 0.0138 11/28/2006 0.0120 11/29/2006 0.0288 11/30/2006 0.0376 12/01/2006 0.0187 05/28/07 0.015 05/29/07 0.036 0.015 05/30/07 0.0084 0.017 0.036 0.015 05/31/07 0.0103 0.036 0.015 06/01/07 0.0164 0.017 0.036 0.015 06/02/07 0.0305 0.015 12/02/07 0.0241 12/03/07 0.0128 12/04/07 0.0238 12/05/07 0.0158 12/06/07 0.0162 12/07/07 0.0175 04/13/08 0.0039 04/14/08 0.0124 04/15/08 0.0229 04/16/08 0.0143 04/17/08 0.0120 04/18/08 0.0149 10/26/08 0.0260 10/27/08 0.0151 0.017 10/28/08 0.0172 0.041 10/29/08 0.0154 "--

0.018 0.041 0.030 10/30/08 0.041 0.030 10/31/08 0.0086 1 0.041 0.030 5

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004 - August 17, 2012 Date Sodimu

. Towerbrom.PCL-222 PCL-401 Cuprostat-

1.

Nalco S*'Sp~c:us H.5OM MSW Hypoh!'rite mg/L mg/L mg/L 3'63 PF mg/L

,"rnigb/,

73551

".Cx1y1":".0 iK mg/L 101 mg/*b' TRC Phosphate Copolymer :'WI' Azole V

,i' mg/L

.u:.iL at, mg/L

TRC, j_____M..D

> EO/PO

.Q

.*1at r,

Phosphate 02/08/09 0.0197 0.017 02/09/09 0.0237 0.017

.4 -:

02/10/09 0.0104 0.021 02/11/09 0.0155 5-

-0.017 7

02/12/09 0.0106

' : 0.017 02/13/09 05/10/09 0.0129

-6, 05/11/09 0.0415

,.0446 05/12/09 0.0053

"V "...

396 05/13/09 0.0049 0-

.0- "

,396,'

05/14/09

<0.0141 0X0397:

05/15/09

<0.0160 11/15/09 0.025 11/16/09.

0.0152 11/17/09 '

0.0255 11/18/09 0.0306 11/19/09 0.0204 11/20/09 0.0093 05/09/10 7~Y 0.0192 05/10/10 0.0055 05/11/10 0.0100" 3

05/12/10 0,-

0.0171 03 05/13/10 0.0041 0

'03" 05/14/10 '

0.0099

,0} 9 6

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004 - August 17, 2012 Date Sodium Towerbrom PCL-PCL-401 CL-363 Cuprostat-H-130M Nalco Spectrus H-150M MSW Floguard Hypochlorite mg/L 222 mg/L mg/L PF mg/L mg/L 73551 CTI300 mg[L 101.

MS6236 mg/L TRC mg/L Copolymer DMAD Azole Quat mg/L mg/L Quat mg/L mg/L TRC Phos-EO/PO Quat Phosphate Phosphate phate 10/31/10 11/01/10 0.0122 11/02/10 0.0112 11/03/10 0.0163 11/04/10 0.0107 11/05/10 0.0132 05/01/2011 05/02/2011

-0.04 05/03/2011 0.04 05/04/2011 0.0155 0.04 05/05/2011 0.0179

-0.04 05/06/2011 0.0089 11/06/2011 0.0168 11/07/2011 0.0225 11/08/2011 0.0141 11/09/2011 0.0239 11/10/2011 0.0242 11/11/2011 0.0231 05/06/2012 05/07/2012 05/08/2012 0.041 05/09/2012 0.0145 0.041 05/10/2012 0.0298 0.041 05/11/2012 0.0174 08/12/2012 0.029 08/13/2012 0.0256 0.028 0.037 0.029 08/14/2012 0.0209 0.037 0.029 08/15/2012 0.0279 0.028 0.029 08/16/2012 0.0076 0.029 08/17/2012 0.0446 0.032 7

R-Al Study Plan for Evaluation of the TVA Sequoyah Nuclear Plant Discharge in Support of an Alternate Thermal Limit Soddy Daisy, Hamilton County, Tennessee Tennessee Valley Authority June 8, 2011

TABLE OF CONTENTS EX ECU TIV E SU M M A RY.............................................................................................

iii 1.0 IN T R O D U C T IO N.................................................................................................

1 1.1 Facility Inform ation.....................................................................................

1 1.2 R egulatory B asis...........................................................................................

1 1.2.1 Applicable Thermal Criteria..................................................................

1 1.2.2 Permitted Conditions.............................................................................

2 1.2.3 Criteria for Alternate Thermal Limits Under §316(a)...........................

2 1.2.4 Mixing Zone Requirements in Tennessee Rule 1200-4-3-0.5................ 4 1.3 Study Plan Organization.............................................................................

5 2.0 STUDY BACKGROUND...............................................................................

5 2.1 Sequoyah Nuclear Plant..............................................................................

5 2.2 Description of the Receiving Waterbody...................................................

5 2.3 Previous §316(a) Demonstration Study.........................

6 2.4 Contem porary Studies..................................................................................

7 3.0 STUDY PLAN..................

........................... 8 3.1 Study T im ing...............................................................................................

.. 8 3.2 Study Scope...............................................................................................

8 Task 1 - Evaluate Plant Operating Conditions....................................................

8 Task 2 - Thermal Plume Monitoring and Mapping............................................

9 Task 3 - Establishment of Biological Sampling Stations...................................

10 Task 4 - Shoreline and River Bottom Habitat Characterization........................

10 Task 5 - Supporting Water Quality Measurements................................................

11 Task 6 - Biological Evaluations.........................................................................

11 Task 7 -Water Supply and Recreational Use Support Evaluation.....................

14 3.3 Data Contribution to the Analysis/Demonstration.....................................

14 3.3.1 Traditional Analyses...........................................................................

14 3.3.2 Supporting Multi-metric Bioassessment...............................................

15 3.3.4 Reasonable Potential Evaluation..........................................................

16 3.4 R eporting.................................................................................................

.. 16 3.5 Study Schedule Summary...........................................................................

16 4.0 LITERATURE CITED...................................................................................

18 i

LIST OF FIGURES Figure 1. Vicinity map for Sequoyah Nuclear plant depicting Chickamauga and Watts Bar Dam locations and water supply intakes downstream of the plant thermal discharge 2 0 Figure 2. Site map for Sequoyah Nuclear plant showing condenser cooling water intake structure, skimmer wall, and NPDES-permitted discharge Outfall No. 101.............. 21 Figure 3. Biological monitoring zone downstream of Sequoyah Nuclear plant........ 22 Figure 4. Biological monitoring zone upstream of Sequoyah Nuclear plant thermal d isch arg e.........................................................................................................................

2 3 Figure 5. Anticipated transects to be established for conduct of the integrative multi-metric aquatic shoreline habitat assessment...............................................................

24 ii

EXECUTIVE

SUMMARY

This document sets forth a revised Study Plan, which the Tennessee Valley Authority (TVA) plans to implement for the purpose of evaluating the Sequoyah Nuclear Plant (SQN) thermal discharge in support of compliance with the National Pollutant Discharge Elimination System (NPDES) permit for the facility and continuance of the associated Alternate Thermal Limit (ATL) for Outfall 101 as authorized under Section 316(a) of Clean Water Act and Tennessee Department of Environment and Conservation rules.

As required by the NPDES permit, the Study Plan was first submitted to the Tennessee Department of Environment and Conservation (TDEC) on December 20, 2010 and subject to review by TDEC and the U. S. Environmental Protection Agency (EPA),

Region 4. Comments and suggested revisions were provided to TVA by TDEC in a meeting held on April 7, 2011 and have been incorporated herein.

The Study Plan provides regulatory background for the work; information about SQN operations; a brief description of the receiving waterbody; a summary of previous

§316(a) and more recent monitoring studies conducted at the plant; and a detailed Scope of Work proposing the collection of new data to evaluate the potential impact of the Sequoyah Nuclear thermal discharge on the aquatic life and other classified uses of the Tennessee River/Chickamauga Reservoir in the vicinity of the plant. Specifically, studies are proposed to:

1. Collect the temperature data needed to delineate and map the spatial boundaries of the thermal discharge plume;

2. Characterize the aquatic and wildlife habitat in the study area;

3.

Sample the fish, macroinvertebrate, and plankton communities;

4. Survey potentially affected wildlife;

5. Evaluate maintenance of a balanced indigenous population (BIP) by performing traditional and multi-metric analyses of collected data, as appropriate; and

6. Evaluate the reasonable potential for impairment of non-aquatic life uses of the receiving waterbody as they relate to the thermal discharge.

Field sampling activities are scheduled to begin in the summer and autumn of 2011.

Resultant information will be used to support renewal of the facility's NPDES permit set to expire October 31, 2013.

iii

1.0 INTRODUCTION

This document sets forth a revised Study Plan, which the Tennessee Valley Authority (TVA) plans to implement for the purpose of evaluating the Sequoyah Nuclear Plant (SQN) thermal discharge in support of compliance with the National Pollutant Discharge Elimination System (NPDES) permit for the facility (NPDES Permit No.: TN0026450). The Study Plan includes a review and discussion of applicable regulatory requirements for the thermal discharge and presents specific work elements for the re-verification of the existing Alternate Thermal Limit (ATL) for Outfall 101 in accordance with Clean Water Act (CWA) Section (§) 316(a). As required by the NPDES permit, the Study Plan was first submitted to the Tennessee Department of Environment and Conservation (TDEC) on December 20, 2010 and subject to review by TDEC and the U. S. Environmental Protection Agency (EPA), Region 4. Comments and suggested revisions were provided to TVA by TDEC in a meeting held on April 7, 2011 and have been incorporated herein.

1.1 Facility Information Unit I and 2 were placed in operation in 1981 and 1982, respectively. Both units can produce more than 2,400 megawatts of electricity. SQN is located on the right descending bank of the Tennessee River (Chickamauga Reservoir) near Chattanooga, Tennessee (Figure 1). The facility withdraws cooling water from Chickamauga Reservoir via an intake channel and skimmer wall at river mile (TRM) 484.8. The cooling water intake structure (supporting six circulator pumps) provides the units a nominal flow of 1.11 x 106 gallons per minute (gpm) or 1,602 million gallons per day (mgd). The facility employs a once-through (open cycle) condenser cooling water system and can also operate with cooling towers in helper mode. The plant discharges heated effluent to Chickamauga Reservoir via Outfall 101 located at TRM 483.6 as authorized by the NPDES permit (Figure 2).

1.2 Regulatory Basis 1.2.1 Applicable Thermal Criteria TDEC has specified "use classifications" for the state's surface waters and developed temperature criteria intended to support those uses (TDEC Rule 1200-4-4 and 1200-4-3-.03, respectively). The Tennessee River at the location of SQN has been classified for the following uses: Municipal, Industrial, and Domestic Water Supply, Industrial Water Supply, Fish and Aquatic Life, Recreation, Irrigation, Livestock Watering and Wildlife, and Navigation. Except for Irrigation and Livestock Watering and Wildlife (qualitative criteria), temperature criteria relevant to warm-water conditions of the Tennessee River at SQN specify that:

"The maximum water temperature change shall not exceed 3°C [5.4'F] relative to an upstream control point. The temperature of the water shall not exceed 30.5C [86.9°F] and the maximum 1

rate of change shall not exceed 2°C [3.60F] per hour. The temperature of impoundments where stratification occurs will be measured at a depth of 5 feet, or mid-depth whichever is less, and the temperature in flowing streams shall be measured at mid-depth. "[Rule 1200-4-3-.03]

The SQN plant's "once-through" cooling water system design utilizing cooling towers in helper mode provides for the most thermodynamically efficient method of generating electricity and as a result produces a heated discharge. As such, the thermal discharge typically exceeds TDEC's established temperature criteria, therefore, multiport diffusers with mixing zone are used to adequately mix the thermal effluent to meet the state water quality standard at the end of the mixing zone. In such cases, the TDEC rules specific to the Fish and Aquatic Life use classification provide that:

"A successful demonstration as determined by the state conducted for thermal discharge limitations under Section 316(a) of the Clean Water Act, (33 U.S.C. §1326), shall constitute compliance... [with the temperature criteria]."

TVA has previously made such successful demonstration for the SQN thermal discharge in support of mixing zone criteria as further discussed below.

1.2.2 Permitted Conditions Currently permitted thermal discharge limitations* for SQN specify that the daily maximum temperature is not to exceed 30.5°C (86.91F) at the end of the mixing zone (Page 1 of.28),

NPDES permit TN0026450). This mixing zone criteria are based on a previous demonstration by TVA, in accordance with CWA §316(a) and TDEC Rule 1200-4-3-.03 noted above, that a balanced indigenous population (BIP) of fish, shellfish, and wildlife is supported in the Tennessee River potentially affected by the thermal discharge. The mixing zone criteria, as supported by the biological studies, also encompass other components of the TDEC temperature criteria, specifically the change in temperature from ambient/upstream conditions and rate of change in temperature. SQN has maintained a good compliance record with its mixing zone criteria throughout each NPDES permit term since first authorized in the late-1980s; ongoing biological monitoring has consistently demonstrated the mixing zone criteria are protective of aquatic communities in the river near the facility.

1.2.3 Criteria for Alternate Thermal Limits Under §316(a)

/

The regulatory provisions that implementCWA §316(a) provide limited guidance on precisely what the demonstration study must contain to be considered adequate and do not identify precise criteria against which to measure whether a "balanced and indigenous" aquatic community is protected and maintained. Instead, the regulations provide broad guidelines.

Under the broad regulatory guidelines, the discharger must show that the ATL desired, "considering the cumulative impact of its thermal discharge together with all other significant impacts on the species affected," will "assure the protection and propagation of a balanced, indigenous community of shellfish, fish and wildlife in and on the body of water into which the 2

discharge is to be made (40 CFR §125.73). Critical to the demonstration is the meaning of the term "balanced indigenous community". The rules provide the following definition:

"The term "balanced indigenous community" is synonymous with the term balanced, indigenous population (i.e., BIP) in the Act and means a biotic community typically characterized by diversity, the capacity to sustain itself through cyclic seasonal changes, presence of necessary food chain species and by a lack of domination by pollution tolerant species.

Such a community may include historically non-native species introduced in connection with a program of wildlife management and species whose presence or abundance results from substantial, irreversible environmental modifications" (40 CFR § 125.73).

Pursuant to this regulatory definition, a successful demonstration must show that under the desired ATL, and in light of the cumulative impact of the thermal discharge together with all other significant impacts on the species affected, the following characteristics, which are indicative of a BIP, will continue to exist: (1) diversity, (2) the capacity of the community to sustain itself through cyclic seasonal changes, (3) presence of necessary food chain species, and (4) a lack of domination by pollution tolerant species.

There are several methodologies a discharger may pursue in making a §316(a) demonstration.

Under the regulations, new dischargers must use predictive methods (e.g., laboratory studies, literature surveys, or modeling) to estimate an appropriate ATL that will assure the protection and propagation of a balanced, indigenous community prior to commencing the thermal discharge. However, existing dischargers, such as SQN, need not use predictive methods. For such dischargers, §316(a) demonstrations may be based upon the "absence of prior appreciable harm" to a balanced, indigenous community (see 40 CFR § 125.73(c)(1)(i) and (ii)).

Such demonstrations must show either that:

i)

No appreciable harm has resulted from the thermal component of the discharge taking into account the interaction of such thermal component with other pollutants and the additive effect of other thermal sources to a balanced, indigenous community of shellfish, fish, and wildlife in and on the body of water into which the discharge has been made; or ii)

Despite the occurrence of such previous harm, the desired alternative effluent limitations (or appropriate modifications thereof) will nevertheless assure the protection and propagation of a balanced, indigenous community of shellfish, fish, and wildlife in and on the body of water into which the discharge is made.

Furthermore, in determining whether or not prior appreciable harm has occurred, the regulations provide that the permitting agency consider the length of time during which the applicant has been discharging and the nature of the discharge.

The regulations do not define "prior appreciable harm." However, using the definition of "balanced, indigenous community," mixing zone criteria are generally granted under either of the following circumstances:

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1.

When a discharger shows that the characteristics of a BIP (i.e., diversity, the capacity to sustain itself through cyclic seasonal changes, presence of necessary food chain species, and a lack of domination by pollution tolerant species) exist.

Stated another way, the existence of such characteristics essentially prove that the aquatic community has not been appreciably harmed; or

2.

Despite any evidence of previous harm, the characteristics of a BIP, as stated above, will nevertheless be protected and assured under the alternate limit.

1.2.4 Mixing Zone Requirements in Tennessee Rule 1200-4-3-0.5 As noted above, §316(a) pertains to the Fish and Aquatic Life use classification and provides NPDES-permitted facilities a regulatory compliant means of demonstrating that promulgated temperature criteria may be more stringent than necessary to support a BIP. In such cases, less stringent thermal criteria (i.e., ATLs) are justified. However, other use classifications such as Domestic Water Supply and Recreation must be protected as well. Compliance with TDEC temperature criteria for these uses is typically determined after the discharge has had the opportunity to mix with the receiving water; that is, an allowable mixing zone is determined.

TDEC rules define the mixing zone as:

"That section of a flowing stream or impounded waters in the immediate vicinity of an outfall where an effluent becomes dispersed and mixed." [1200-4-3-.04(8)]

The rules [1200-4-3-.05(2)] further provide that mixing zones are to be restricted in area and length and not:

1.

prevent the free passage of fish or cause aquatic life mortality in the receiving waters;

2.

contain materials in concentrations that exceed acute criteria beyond the zone immediately surrounding the outfall;

3.

result in offensive conditions;

4.

produce undesirable aquatic life or result in dominance of a nuisance species;

5.

endanger the public health or welfare; or

6.

adversely affect the reasonable and necessary uses of the area;

7.

create a condition of chronic toxicity beyond the edge of the mixing zone;

8.

adversely affect nursery and spawning areas; or

9.

adversely affect species with special state or federal status.

While TVA's proposed §316(a) demonstration study plan fully examines the effects of the thermal discharge on the aquatic life components of the mixing zone requirements, the potential effects to other non-aquatic life use classifications (items 3, 5, and 6 above) are generally not evaluated. Therefore, this plan has been revised herein to incorporate and/or collect additional 4

information needed to address the reasonable potential for impairment of other non-aquatic life uses in the Tennessee River near the facility.

1.3 Study Plan Organization This Study Plan is organized into the following sections:

1.

Introductory information, including regulatory basis and rationale for the study;

2.

Background information, including a summary of the findings of the previous

§316(a) investigation and subsequent biological monitoring; and,

3.

The proposed design and implementation schedule for the SQN §316(a) demonstration Study Plan.

2.0 STUDY BACKGROUND 2.1 Sequoyah Nuclear Plant The SQN facility is operated to produce base-load electric power throughout the year. When operating at design (nameplate) capacity (2,400 MW), the units requires approximately 1,602 million gallons per day of condenser cooling water. Waste heat increases the temperature of the cooling water by approximately 16.4°C (29.5°F) before it is discharged into the river. The actual condenser flow, and hence the AT, may vary somewhat with the circulating water pump head and the condenser efficiency.

2.2 Description of the Receiving Waterbody Sequoyah Nuclear is located on the right descending bank of Chickamauga Reservoir (TRM 484.5) approximately 18 miles northeast of Chattanooga, Tennessee, and 7 miles southwest of Soddy-Daisy, Tennessee (Figure 1). Chickamauga Reservoir was impounded in 1940 and at full pool covers approximately 36,240 acres.

The topography of the reservoir in the vicinity of the discharge outlet consists of a shallow overbank area on the plant side which extends from TRM 484 downstream to TRM 481.8 and varies in depth from 2 to 20 ft and from 500 to 3,100 ft in width. This shallow area is bordered by a main river channel which is about 900 feet (ft) wide and approximately 60 ft deep. Along this reach there are several small, shallow embayments.

The Tennessee River flow in the vicinity of SQN is controlled by releases from Watts Bar and Chickamauga Dams, and to a lesser extent Hiwassee River. SQN is situated on Chickamauga Reservoir approximately 54.5 river miles downstream from Watts Bar Dam and 13.5 river miles upstream from Chickamauga Dam.

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2.3 Previous §316(a) Demonstration Study TVA conducted comprehensive §316(a) demonstration-related studies of the SQN thermal effluent in the mid-1980s to support establishment of the current mixing zone criteria for the plant discharge (TVA, 1989). The minimum average daily flow for the Tennessee River near SQN at the time of the early studies was 6,000 cfs.

The mid-1980s studies included extensive sampling of the aquatic community including:

" Phytoplankton,

" Periphyton,

Aquatic macrophytes,

Zooplankton,

Benthic macroinvertebrates; and

Fish populations.

Hydrothermal, water quality and other parameters also were evaluated.

Major findings of these studies included:

Average dissolved concentration in the water column was similar immediately upstream and downstream of SQN.

Analysis of the data indicate that the assemblages of phytoplankton, zooplankton, and macroinvertebrates were diverse and, in general, relatively abundant.

Dominance of blue-green algae was similar upstream and downstream of SQN.

The phytoplankton and zooplankton communities were found to be similar, or if different, not impacted by SQN operation, at all stations during 20 of the 27 survey months when the plant was in operation.

Species richness in the benthic macroinvertebrate communities during pre-operational and operational monitoring was similar.

" No changes were documented in the aquatic macrophyte community that reflected effects of the thermal effluent.

Fish species occurrence and abundance data indicated insignificant impacts. Avoidances of the plume could not be detected for any species of fish. One study found that sauger (Sander canadensis) were not concentrated in the thermal plume during winter months nor inhibited from movement past SQN. Results of gonadal inspections indicate that the heated discharge did not adversely affect fish reproduction.

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Other fisheries studies indicated that the thermal discharge resulted in no discernible increase in parasitism.

" No mortalities of threadfin shad due to cold shock following shutdown of SQN were observed or reported, and none are anticipated to occur in the future.

2.4 Contemporary Studies Monitoring of the thermal effects of the SQN discharge on the aquatic community of the receiving waterbody has been more recently conducted by TVA after an agreement was reached with TDEC in 2001. TVA's "Vital Signs" monitoring program also provides useful information for evaluating reservoir-wide effects. Monitoring has included sampling of the fish and macroinvertebrate communities and associated collection of temperature and other water quality parameters. Results of the permit monitoring work and TVA's ongoing Vital Signs monitoring (TVA, 2011) have consistently demonstrated that fish and macroinvertebrate assemblages of Chickamauga Reservoir within and downstream of the SQN thermal discharge are similar to those of upstream locations, as well as to established mainstem reservoir reference conditions for the area.

Results of the above studies notwithstanding, TVA plans to implement this Study Plan for the purpose of further evaluating the SQN thermal discharge to support continuance of the ATL for the facilitydischarge in accordance with CWA §316(a) and TDEC Rule 1200-4-3-.03(e).

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3.0 STUDY PLAN This §316(a) demonstration Study Plan is informed by communications with TDEC and EPA, the study design of the previous demonstration study, and TVA's ongoing river/reservoir biological monitoring programs.

3.1 Study Timing As reasonably practicable, TVA sampling crews will coordinate with SQN facility operations staff to schedule field studies to coincide with representative conditions of maximum generation for the time period to be sampled as dictated by seasonal power demand. The additional field studies will be conducted during the period of critical environmental (thermal) conditions in summer (mid-July - August) when plant operations and ambient reservoir temperatures are at expected seasonal maximums. Summer monitoring will be conducted once during the SQN permit cycle. Data collection during this period will focus on characterization/delineation of the thermal plume and biological field investigations inclusive of thermally affected and unaffected areas. TVA will also conduct monitoring in autumn (October - mid-December) as has been occurring in previous study years.

3.2 Study Scope The following tasks will be conducted for the SQN §316(a) demonstration Study:

Task 1 - Evaluate Plant Operating Conditions During the course of the study, SQN operational data will be recorded, compiled, and analyzed to assist in the interpretation of thermal plume characteristics and biological community information. Available historical operational data will also be compiled and analyzed to evaluate and identify any material changes in SQN operations over the most recent 5-year period that might affect the thermal plume characteristics. Parameters to be recorded during the proposed study and evaluated historically include, but are not limited to:

Cooling water intake flow and water temperature;

" Discharge flow and water temperature; and

Power generation statistics.

The data will be presented in tabular and graphical formats to describe SQN operational conditions during the current study.

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Task 2 - Thermal Plume Monitoring and Mapping Physical measurements will be taken to characterize and map the SQN thermal plume concurrent with biological field sampling during the sampling events. In this manner, it is expected that the plume will be characterized under representative thermal maxima and seasonally-expected low flow conditions. Measurements will be collected during periods of high power production from SQN, as reasonably practicable, to capture maximum extent of the thermal plume under existing river flow/reservoir elevation conditions. This effort will allow general delineation of the "Primary Study Area" per the EPA (1977) draft guidance defined as the: "entire geographic area bounded annually by the locus of the 2'C above ambient surface isotherms as these isotherms are distributed throughout an annual period"); ensure placement of the biological sampling locations within thermally influenced areas; and inform the evaluation of potential impacts on recreation and water supply uses.

However, it is important to emphasize that the >2°C isopleth boundary is not a bright line; it is dynamic, changing geometrically in response to changes in ambient river flows and temperatures and SQN operations. As such, samples collected outside of, but generally proximate to the Primary Study Area boundary should not be discounted as non-thermally influenced. Every effort will be made to collect biological samples in thermally affected areas as guided by the Primary Study Area definition.

Field activities will include measurement of surface to bottom temperature profiles along transects across the plume. One transect will be located proximate to the thermal discharge point; subsequent downstream transects will be concentrated in the near field area of the plume where the change in plume temperature is expected to be most rapid. The distance between transects in the remainder of the Primary Study Area will increase with distance downstream or away from the discharge point. The farthest downstream transect will be just outside of the Primary Study Area. A transect upstream of the discharge that is not affected by the thermal plume will be included for determining ambient temperature conditions. The total number of transects needed to fully characterize and delineate the plume will be determined in the field.

Temperature profile measurement (surface to bottom) points along a given transect will begin at or near the shoreline from which the discharge.originates and continue across the plume until ambient background temperature conditions (based on surface (0.1 meters (m)/0.3 ft depth) measurements) or the far shore is reached. The number of measurement points along transects will generally be proportional to the width of the plume and the magnitude of the temperature change across a given transect. The distances between transects and measurement points will depend on the size of the discharge plume.

The temperature measurement instrument (Hydrolab or equivalent) will be calibrated to a thermometer whose calibration is traceable to the National Institute of Standards and Technology.

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Temperature data will be compiled and analyzed to present the horizontal and vertical dimensions of the SQN thermal plume using spatial analysis techniques to yield plume cross-sections, which can be used to demonstrate the existence of a zone of passage under and/or around the plume.

Task 3 - Establishment of Biological Sampling Stations Water temperature data from Task 2 will define the relationships between the biological sampling zone and thermally affected areas as informed by the EPA (1977) draft guidance, which identifies the Primary Study Area as having water temperatures of >2'C (3.6°F) above ambient temperature. The thermally affected sampling location will be referred to as the "downstream zone;" the non-thermally-affected sampling location will be referred to as the "upstream zone." If it is determined, based on the plume temperature measurements/mapping that the currently used biological sampling zone downstream of SQN is not fully within the EPA guidance-defined Primary Study Area, that sampling zone will be re-established within the EPA Primary Study Area.

Figure 3 depicts the downstream biological sampling zone; Figure 4 includes the location of the ambient biological sampling zone upstream of SQN.

Task 4 - Shoreline and River Bottom Habitat Characterization Informed by the results of Tasks 2 and 3, habitat characterization will be conducted at each selected sampling location to evaluate potential for bias in the results due to habitat differences between the thermally affected area and the ambient sampling locations, and to support interpretation of the biological data. Eight line-of-sight transects will be established across the width of Chickamauga Reservoir downstream and upstream of SQN to assess the quality of shoreline habitat (Figure 5). An integrative multi-metric index (Shoreline Aquatic Habitat Index or SAHI), including several habitat parameters important to resident fish species, will be usedto measure the existing fish habitat quality. Using the SAHI, individual metrics are scored through comparison of observed conditions with reference conditions and assigned a corresponding value.

River bottom habitat characterization for both the upstream and downstream study zones will consist of eight transects each collected perpendicular to the shoreline.

Each transect will evaluate substrate by collecting 10 equally spaced Ponar dredge samples across the width of the reservoir. Each sample will be visually estimated to define substrate and then sieved to define percent makeup of substrate.

At each sample location, depth, and sediment type encountered will be recorded. Sediment categories include bedrock, boulder, cobble, gravel, sand, fines, and detritus. Each site will be assigned one of three habitat categories to reduce the amount of assessment variability. Habitat categories are as follows: A) areas with presence of large substrates such as cobble and boulders, B) areas dominated by sand or fine substrates and C) areas with apresence of a mixture of both A and B (small and large) habitat types.

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Task 5 - Supporting Water Quality Measurements In addition to the thermal plume measurements, additional water quality profiles will be collected as necessary in conjunction with the field studies to: (i) support interpretation of the biological data; and (ii) evaluate potential impacts to water supply and recreational uses. Using a Hydrolab, or equivalent unit, three water column profiles at one-meter increments will be collected near the left descending bank, right descending bank and mid-channel at the upstream and downstream ends of each sample zone, and other areas as needed (e.g., at water supply intakes). Each profile collected will include temperature, dissolved oxygen concentration, pH, and conductivity.

Task 6 - Biological Evaluations The biological evaluations will focus on major representative species of the aquatic and wildlife community that could potentially be affected by the SQN thermal discharge. Sampling will be conducted during the summer months (mid-July - August) once during the SQN permit cycle to evaluate "worst case" conditions. Autumn monitoring (October - mid-December) will be conducted as a measure of potential manifested effects to the aquatic community from summer-long exposure to the thermal discharge and other stressors (basis for existing multi-metric assessments).

The biological communities to be sampled and collection methodologies are provided in the following sections.

Reservoir Fish Community Monitoring Informed by the habitat characterization and temperature measurements, the fish community will be sampled during sample events at two locations: downstream within the thermal influence of the power plant (Figure 3); and upstream and beyond thermal influence of SQN (centered at TRM 489.5) (Figure 4). Sampling will be conducted by boat electrofishing and gill netting (Hubert 1996; Reynolds, 1996).

The electrofishing methodology is based on existing monitoring programs and consists of 15 shoreline-oriented boat electrofishing runs in the upstream sampling zone and 15 shoreline runs in the downstream zone. Each run is 300 m (984 ft) long and electrofishing is conducted for a duration of approximately 15 minutes each. The total near-shore linear area sampled will be approximately 4,500 m (15,000 ft) per zone (Jennings, et al., 1995; Hickman and McDonough, 1996; McDonough and Hickman, 1999). Should the size of the SQN thermal plume (i.e.,

Primary Study Area) be too small to allow collection of all replicate electrofishing runs, the needed remaining replicate runs will be conducted as close as practicable to the Primary Study Area and be identified in the data analyses. As indicated previously, the >20C isopleth boundary that defines the Primary Study Area is not a rigid boundary; rather, its geometry changes in response to ambient river flows and temperatures and SQN operations (discharge flow). As such, samples collected outside of, but generally proximate to the Primary Study Area boundary should not be discounted as non-thermally influenced.

.II

Experimental gill nets (so called because of their use for research as opposed to commercial fishing) are used as an additional gear type to collect fish from deeper habitats not effectively sampled by electrofishing. Each experimental gill net consists of five-6.1 m (20 ft) panels for a total length of 30.5 m (100 ft). The distinguishing characteristic of experimental gill nets is mesh size that varies between panels. For this application, each net has panels with mesh sizes of 2.5 (I inch (in)), 5.1 (2 in), 7.6 (3 in), 10.2 (4 in), and 12.7 (5 in) centimeters (cm). Experimental gill nets are typically set perpendicular to river flow extending from near-shore to the main channel of the reservoir. Ten overnight experimental gill net sets will be used at each area.

Fish collected will be identified by species, counted, and examined for anomalies (such as disease, deformities, or hybridization).

Reservoir Benthic Macroinvertebrate Community Monitoring Benthic macroinvertebrates will be sampled with benthic grab samplers at ten equally-spaced points along the upstream (ambient) and downstream (mid-plume) sampling zones (Figures 3 and 4). A Ponarg sampler (area per sample 0.06 m2) will be used for most samples. When heavier substrates are encountered, a Peterson sampler (area per, sample 0.11 M2) will be used.

Bottom sediments will be washed on a 533 micron (gt) screen; organisms will~be picked from the screen and from any remaining substrate. Organisms will be sent to an independent laboratory for identification to the lowest practicable taxonomic level.

Reservoir Plankton Community Monitoring At the request of TDEC, phytoplankton samples will be obtained from a photic zone1 composite water sample collected at two locations each in the main channel area of the downstream sampling zone (Primary Study Area: mid-plume and plume downstream boundary; see Figure 3) and the upstream zone (Figure 4). This will be accomplished by lowering the intake end of a peristaltic pump sample tube to the bottom of the photic zone; and with the pump activated, slowly retrieving the sample tubing at a constant rate until the reservoir surface is reached. The phytoplankton data will be used to compare potential algal community response to thermal influence based on high-level taxonomy (i.e., Chrysophyta, Chlorophyta, Cyanophyta).

Zooplankton samples will be collected with a plankton net (300 millimeter (1 ft) diameter with 153 gt mesh) towed at two locations each in the main channel area of the downstream sampling zone (Primary Study Area: mid-plume and plume downstream boundary) and the upstream zone (Figures 3 and 4). Tows will consist of a vertical pull (tow) of the entire water column from 2 m off the bottom to the surface of the reservoir. Comparative analysis of zooplankton data from the two locations will be used to evaluate potential thermal influence on community structure.

For the purposes of this study, the photic zone is defined as twice the Secchi disk transparency depth or 4 meters, whichever is greater.

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Plankton sampling will be conducted once during the sampling events utilizing established TVA procedures. Among other criteria, these procedures specify replicate sampling, proper sample preservation, and data processing requirements.

Wildlife Community Evaluation The wildlife community will be evaluated via implementation of visual encounter (observational) wildlife survey methodology and supported through review of the available literature, and communications with natural resource agency contacts. The effort will focus on the more water dependent species of the herpetofaunal, avian, and mammalian communities.

These activities will assist in identifying the wildlife species expected for the ecoregion, establish the presence/absence of a BIP of wildlife in the study area, and support evaluation of potential direct effects of temperature on sensitive life stages and any indirect effects such as increased predation.

A review of available resources to identify any threatened or endangered species potentially occurring in the study area will also be conducted.

For the visual encounter surveys, two permanent transects will be established both upstream and downstream of the SQN thermal effluent. The midpoint of the upstream transect will be positioned at TRM 489.5 and span a distance of 2,100 m within this transect. The downstream transect will be located in the field based on sampling event and likewise span a distance 2,100

m. The beginning and ending point of each transect will be marked with GPS for relocation.

Transects will be positioned approximately 30 m offshore and parallel to the shoreline occurring on both right and left descending banks. Basic inventories will be conducted to provide a representative sampling of wildlife present during summer (mid-July - August) and late autumn-early winter (October - December).

Each transect will be surveyed by steadily traversing the length by boat and simultaneously recording observations of wildlife. Sampling frame of each transect will generally follow the strip or belt transect concept with all individuals enumerated that crossed the center-line of each transect landward to an area that included the shoreline and riparian zone (i.e., belt width generally averages 60 m where vision is not obscured).

Information recorded will include wildlife identification (to the lowest taxonomic trophic level) that is observed visually and/or audibly and a direct count of individuals observed per trophic level. If flocks of a species or mixed flock of a group of species are observed, an estimate of the number of individuals present will be generated. Time will be recorded at the starting and ending point of each transect to provide a general measure of effort expended.

However, times may vary among transects primarily due to the difficulty in approaching some wildlife species without inadvertently flushing them from basking or perching sites.

To compensate for the variation of effort expended per transect, observations will be standardized to numbers per minute or numbers per hectare in preparation for analysis.

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The principal objective and purpose behind the wildlife surveys are to provide a preliminary set of observations to verify trophic levels of birds, mammals, amphibians and reptiles present that might be affected by thermal effects of the power plant (i.e., the ATL). If trophic levels are not represented, further investigation will be used to target specific species and/or species groups (guilds) that will determine the cause.

Task 7 -Water Supply and Recreational Use Support Evaluation Water temperature data collected as part of the thermal mapping (Task 2) and collection of supporting water quality information (Task 5) will be used to evaluate potential thermal impacts to water supply and recreational uses in the vicinity of SQN. Locations of any public water supply intakes and/or established public recreational areas will be determined and their position(s) mapped relative to the SQN thermal plume. We are aware of one domestic water supply intake located within approximately 10 river miles downstream of the SQN thermal discharge (Figure 1). The existence of any relevant water temperature data collected by the owners of these water supply intake(s) will be determined; and if available, requested to augment the field-collected data. As necessary (limited or no available owner-supplied temperature data),

direct measurements of water temperature may also be conducted specifically at these locations to evaluate potential thermal effects of the SQN discharge.

3.3 Data Contribution to the Analysis/Demonstration The analysis of fish, macroinvertebrate, and plankton community data will include traditional analyses whereby community attributes for the thermally affected areas will be compared to the non-thermally affected ambient location. For the purposes of the demonstration (within river/reservoir comparisons), the composition of fish and macroinvertebrate assemblages collected at the upstream station, uninfluenced by the SQN thermal discharge, is expected to set the baseline for evaluating the presence of a BIP in the downstream thermally influenced area. In that regard, a BIP is the expected determination for the thermally uninfluenced area.

3.3.1 Traditional Analyses As applicable, biological community data will be compiled into tables providing a listing of species collected and their status with regard to expected occurrence in the ecoregion. Reference materials such as: "The Fishes of Tennessee" (Etnier and Starnes, 1993); similarly applicable publications; and best professional judgment by experienced aquatic biologists will be used for this determination. The dataset will be further evaluated with regard to the following:

" Life stages represented,

" Food chain species present (e.g., predator and prey species),

" Thermally-tolerant or -sensitive species present (based on Yoder et al., 2006),

" Representative Important Species (commercially and/or recreationally); and

Other community attributes (fish and macroinvertebrates) 14

To evaluate similarity with the downstream thermally influenced area, traditional species diversity indices will be used. Diversity indices provide important information about community composition and take the relative abundances of different species into account as well as species richness (i.e., number of individual species). Two diversity indices will be calculated for each sample location; such as: the Shannon-Weiner diversity index (H') (Levinton, 1982) and Simpson's Index of Diversity (D,) (Simpson, 1949). Of the many biological diversity indices, these two indices are the most commonly reported in the scientific literature and will be evaluated for use in determining if community structure is similar between the thermally influenced and non-thermally influenced sampling locations. Other methods/indices for evaluating similarity between sampling sites will also be considered.

Based on the BIP baseline for the thermally uninfluenced ambient (upstream) location, comparative statistical analysis of the diversity indices and/or other measures of biological community status such as: species richness, relative abundance, pollution tolerance, trophic guilds, indigenousness, and thermal sensitivity (each pending sufficient sample size) will be used to confirm the presence/absence of a BIP in the thermally'influenced study area.

3.3.2 Supporting Multi-metric Bioassessment Upon review of the species listings and establishment that the fish and macroinvertebrate populations are appropriate to the aquatic systems of the ecoregion, sample data also will be analyzed using TVA's Reservoir Fish Assemblage Index (RFAI) methodology (McDonough and Hickman 1999) and Reservoir Benthic Index to further evaluate if the SQN thermal discharge has materially changed ecological conditions in the receiving water body (Tennessee River -

Chickamauga Reservoir).

Reservoir Fish Assemblage Index The RFAI uses 12 fish assemblage metrics from four general categories: Species Richness and Composition (8 metrics); Trophic Composition (two metrics); Abundance (one metric); and Fish Health (absence of anomalies) (one metric). Individual species can be utilized for more than one metric.

Each metric is assigned a score based on "expected" fish assemblage characteristics in the absence of human-induced impacts other than impoundment of the reservoir. Individual metric scores for a sampling area (i.e., upstream or downstream) will be summed to obtain the RFAI score for each sample location and comparatively analyzed. The maximum RFAI score is 60.

Ecological health ratings (12-21 "Very Poor", 22-31 "Poor", 32-40 "Fair", 41-50 "Good", or 51-60 "Excellent") are then applied to scores.

Based on statistical analysis of multiple RFAI datasets, RFAI scores between sites (e.g.,

downstream vs. upstream) will need to differ by 6 points or more to be considered to have different fish assemblages based on documented variability in the sampling methodology.

15

Regardless of the scores, a metric-by-metric examination will be conducted; this review will be helpful in evaluating potential metric-specific impacts that may be thermally related.

Reservoir Benthic Macroinvertebrate Index The RBI is similarly calculated as the RFAI except that it uses seven metrics specific to the macroinvertebrate assemblage. Each metric is assigned a score based on reference conditions and then summed to produce an overall RBI score for each sample site. The maximum RBI score is

35. Ecological health ratings (7-12 "Very Poor", 13-18 "Poor", 19-23 "Fair", 24-29 "Good", or 30-35 "Excellent") will then be applied to scores.

Based on statistical analysis of multiple RBI datasets, RBI scores between sites (e.g.,

downstream vs. upstream) that differ by 4 points or more will be considered to have different macroinvertebrate assemblages. A metric-by-metric examination will also be conducted, regardless of the scores, to evaluate potential thermally-related impacts on specific metrics.

3.3.4 Reasonable Potential Evaluation Based on existing information and temperature data collected/obtained during the study, the reasonable potential for the thermal discharge to impair current and future water supply and recreational (water contact) uses will be evaluated. The measured temperatures at the water supply intake location and location of any named recreational areas or areas where recreational users are known to congregate within the thermally influenced area (if any), will form the basis for determining reasonable potential for use impairment. Should reasonable, potential be indicated, TVA will discuss with TDEC; and as necessary, submit a revised scope of work (study design) for this task (Task 7) proposing additional data collections and/or analysis to focus the evaluation.

3.4 Reporting A final Project Report will be prepared providing a description of the study design, data collection methods, SQN operational data, thermal plume mapping results, water quality monitoring data, and aquatic and wildlife community information. Raw data and associated field collection parameters will be appended to the report.

Results and conclusions regarding the §316(a) demonstration (maintenance of a BIP) and support of other use classifications (recreation and water supply) will be presented.

3.5 Study Schedule Summary Field sampling will be conducted during summer (mid-July - August) once during the SQN permit cycle and autumn (October - mid-December); each event will include sampling of the Primary Study Area/downstream zone and upstream/ambient zone.

16

TVA will provide TDEC with an interim progress report of the summer 2011 sampling results in spring of 2012. Final report will be completed and submitted with the SQN NPDES permit renewal package.

17

4.0 LITERATURE CITED EPA 1977. Draft Interagency 316(a) technical guidance manual and guide for thermal effects sections of nuclear facilities environmental impact statements. U.S. Environmental Protection Agency and U.S. Nuclear Regulatory Commission. U.S. Environmental Protection Agency, Office of Water Enforcement, Permits Division, Industrial Permits Branch, Washington, D.C.

Etnier, D.A. & Starnes, W.C. 1993. The Fishes of Tennessee. University of Tennessee Press, Knoxville, TN, 681 pp.

Hickman, G.D. and T.A. McDonough. 1996. Assessing the Reservoir Fish Assemblage Index-A potential measure of reservoir quality. In: D. DeVries (Ed.) Reservoir symposium-Multidimensional approaches to reservoir fisheries management. Reservoir Committee, Southern Division, American Fisheries Society, Bethesda, MD. pp 85-97.

Hubert, W. A. 1996. Passive capture techniques, entanglementgears. Pages 160-165 in B. R.

Murphy and D. W. Willis, editors. Fisheries techniques, 2nd edition. American Fisheries Society, Bethesda, MD.

Jennings, M. J., L. S. Fore, and J. R. Karr. 1995. Biological monitoring of fish assemblages in Tennessee Valley reservoirs, Regulated Rivers: Research and Management, Vol. 11, pages 263-274.

Levinton, J.S. 1982. Marine Ecology. Prentice-Hall, Inc. Englewood Cliffs, NJ McDonough, T.A. and G.D. Hickman. 1999. Reservoir Fish Assemblage Index development: A tool for assessing ecological health in Tennessee Valley Authority impoundments. In:

Assessing the sustainability and biological integrity of water resources using fish communities. Simon, T. (Ed.) CRC Press, Boca Raton, FL. pp 523-540.

Reynolds, J.B. 1996. Electrofishing. Pages 221-251 in B. R. Murphy and D. W. Willis, editors.

Fisheries techniques, 2nd edition. American Fisheries Society, Bethesda, MD.

Simpson, E.H. (1949) Measurement of diversity. Nature 163:688 see http://www. wku.edu/-smithch/biogeoý/SIMP 1 949.htm TVA 2011. Biological Monitoring of the Tennessee River Near Sequoyah Nuclear Plant Discharge Autumn 2010. Tennessee Valley Authority, Knoxville, TN.

TVA 1989. A Predictive 316(a) Demonstration for an Alternative Winter Thermal Discharge Limit for Sequoyah Nuclear Plant, Chickamauga Reservoir, Tennessee. Tennessee Valley Authority, Chattanooga, TN Yoder, C.O., B.J. Armitage, and E.T. Rankin. 2006. Re-evaluation of the technical justification for existing Ohio River mainstem temperature criteria. Midwest Biodiversity Institute, Columbus, OH.

18

FIGURES 19

Figure 1. Vicinity map for Sequoyah Nuclear plant depicting Chickamauga and Watts Bar Dam locations and water supply intakes downstream of the plant thermal discharge 20

Figure

2. Site map for Sequoyah Nuclear plant showing condenser cooling water intake Figure 2. Site map for Sequoyah Nuclear plant showing condenser cooling water intake structure, skimmer wall, and NPDES-permitted discharge Outfall No. 101 21

M Biomonitoring Stations Downstream of Sequoyah Nuclear Plant

+

Electrofishing Stations o

Gill Netting Stations Benthic Macroinverteb rate Transects 0

Phytoplankton Monitoring Stations k

Il Mile SC Figure 3. Biological monitoring zone downstream of Sequoyah Nuclear plant 22

FIVAI Study Plan for Evaluation of the TVA Sequoyah Nuclear Plant Discharge in Support of an Alternate Thermal Limit Soddy Daisy, Hamilton County, Tennessee Tennessee Valley Authority June 8, 2011

TABLE OF CONTENTS EXECUTIVE

SUMMARY

iii

1.0 INTRODUCTION

I 1.1 Facility Information.....................................................................................

1 1.2 Regulatory Basis..........................................................................................

1 1.2.1 Applicable Thermal Criteria.......................................................................

1 1.2.2 Permitted Conditions............................................................................

2 1.2.3 Criteria for Alternate Thermal Limits Under §316(a)...........................

2 1.2.4 M ixing Zone Requirements in Tennessee Rule 1200-4-3-0.5................ 4 1.3 Study Plan Organization.............................................................................

5 2.0 STUDY BACKGROUND................................................................................

5 2.1 Sequoyah Nuclear Plant...............................................................................

5 2.2 Description of the Receiving W aterbody.....................................................

5 2.3 Previous §316(a) Demonstration Study........................................................

6 2.4 Contemporary Studies..................................................................................

7 3.0 STUDY PLAN..................................................................................................

8 3.1 Study Timing...............................................................................................

8 3.2 Study Scope................................................................................................

8 Task 1 - Evaluate Plant Operating Conditions...................................................

8 Task 2 - Thermal Plume Monitoring and Mapping............................................

9 Task 3 - Establishment of Biological Sampling Stations..................................

10 Task 4 - Shoreline and River Bottom Habitat Characterization........................

10 Task 5 - Supporting W ater Quality Measurements................................................

11 Task 6 - Biological Evaluations.............................................................................

11 Task 7 -W ater Supply and Recreational Use Support Evaluation.....................

14 3.3 Data Contribution to the Analysis/Demonstration....................................

14 3.3.1 Traditional Analyses..............................................................................

14 3.3.2 Supporting Multi-metric Bioassessment...............................................

15 3.3.4 Reasonable Potential Evaluation..........................................................

16 3.4 Reporting...................................................................................................

16 3.5 Study Schedule Summary...........................................................................

16 4.0 LITERATURE CITED.....................................................................................

18 i

LIST OF FIGURES Figure 1. Vicinity map for Sequoyah Nuclear plant depicting Chickamauga and Watts Bar Dam locations and water supply intakes downstream of the plant thermal discharge 2 0 Figure 2. Site map for Sequoyah Nuclear plant showing condenser cooling water intake structure, skimmer wall, and NPDES-permitted discharge Outfall No. 101.............. 21 Figure 3. Biological monitoring zone downstream of Sequoyah Nuclear plant........ 22 Figure 4. Biological monitoring zone upstream of Sequoyah Nuclear plant thermal d isch arg e.........................................................................................................................

23 Figure 5. Anticipated transects to be established for conduct of the integrative multi-metric aquatic shoreline habitat assessment...............................................................

24 ii

EXECUTIVE

SUMMARY

This document sets forth a revised Study Plan, which the Tennessee Valley Authority (TVA) plans to implement for the purpose of evaluating the Sequoyah Nuclear Plant (SQN) thermal discharge in support of compliance with the National Pollutant Discharge Elimination System (NPDES) permit for the facility and continuance of the associated Alternate Thermal Limit (ATL) for Outfall 101 as authorized under Section 316(a) of Clean Water Act and Tennessee Department of Environment and Conservation rules.

As required by the NPDES permit, the Study Plan was first submitted to the Tennessee Department of Environment and Conservation (TDEC) on December 20, 2010 and subject to review by TDEC and the U. S. Environmental Protection Agency (EPA),

Region 4. Comments and suggested revisions were provided to TVA by TDEC in a meeting held on April 7, 2011 and have been incorporated herein.

The Study Plan provides regulatory background for the work; information about SQN operations; a brief description of the receiving waterbody; a summary of previous

§316(a) and more recent monitoring studies conducted at the plant; and a detailed Scope of Work proposing the collection of new data to evaluate the potential impact of the Sequoyah Nuclear thermal discharge on the aquatic life and other classified uses of the Tennessee River/Chickamauga Reservoir in the vicinity of the plant. Specifically, studies are proposed to:

1. Collect the temperature data needed to delineate and map the spatial boundaries of the thermal discharge plume;

2. Characterize the aquatic and wildlife habitat in the study area;

3.

Sample the fish, macroinvertebrate, and plankton communities;

4. Survey potentially affected wildlife;

5. Evaluate maintenance of a balanced indigenous population (BIP) by performing traditional and multi-metric analyses of collected data, as appropriate; and

6. Evaluate the reasonable potential for impairment of non-aquatic life uses of the receiving waterbody as they relate to the thermal discharge.

Field sampling activities are scheduled to begin in the summer and autumn of 2011.

Resultant information will be used to support renewal of the facility's NPDES permit set to expire October 31, 2013.

iii

1.0 INTRODUCTION

This document sets forth a revised Study Plan, which the Tennessee Valley Authority (TVA) plans to implement for the purpose of evaluating the Sequoyah Nuclear Plant (SQN) thermal discharge in support of compliance with the National Pollutant Discharge Elimination System (NPDES) permit for the facility (NPDES Permit No.: TN0026450). The Study Plan includes a review and discussion of applicable regulatory requirements for the thermal discharge and presents specific work elements for the re-verification of the existing Alternate Thermal Limit (ATL) for Outfall 101 in accordance with Clean Water Act (CWA) Section (§) 316(a). As required by the NPDES permit, the Study Plan was first submitted to the Tennessee Department of Environment and Conservation (TDEC) on December 20, 2010 and subject to review by TDEC and the U. S. Environmental Protection Agency (EPA), Region 4. Comments and suggested revisions were provided to TVA by TDEC in a meeting held on April 7, 2011 and have been incorporated herein.

1.1 Facility Information Unit 1 and 2 were placed in operation in 1981 and 1982, respectively. Both units can produce more than 2,400 megawatts of electricity. SQN is located on the right descending bank of the Tennessee River (Chickamauga Reservoir) near Chattanooga, Tennessee (Figure 1). The facility.

withdraws cooling water from Chickamauga Reservoir via an intake channel and skimmer wall at river mile (TRM) 484.8. The cooling water intake structure (supporting six circulator pumps) provides the units a nominal flow of 1.11 x 106 gallons per minute (gpm) or 1,602 million gallons per day (mgd). The facility employs a once-through (open cycle) condenser cooling water system and can also operate with cooling towers in helper mode. The plant discharges heated effluent to Chickamauga Reservoir via Outfall 101 located at TRM 483.6 as authorized by the NPDES permit (Figure 2).

1.2 Regulatory Basis 1.2.1 Applicable Thermal Criteria TDEC has specified "use classifications" for the state's surface waters and developed temperature criteria intended to support those uses (TDEC Rule 1200-4-4 and 1200-4-3-.03, respectively). The Tennessee River at the location of SQN has been classified for the following uses: Municipal, Industrial, and Domestic Water Supply, Industrial Water Supply, Fish and Aquatic Life, Recreation, Irrigation, Livestock Watering and Wildlife, and Navigation. Except for Irrigation and Livestock Watering and Wildlife (qualitative criteria), temperature criteria relevant to warm-water conditions of the Tennessee River at SQN specify that:

"The maximum water temperature change shall not exceed 3°C [5.4°F] relative to an upstream control point. The temperature of the water shall not exceed 30.5°C [86.9°F] and the maximum I

rate of change shall not exceed 2'C [3.6°F] per hour. The temperature of impoundments where stratification occurs will be measured at a depth of 5 feet, or mid-depth whichever is less, and the temperature in flowing streams shall be measured at mid-depth." [Rule 1200-4-3-.03]

The SQN plant's "once-through" cooling water system design utilizing cooling towers in helper mode provides for the most thermodynamically efficient method of generating electricity and as a result produces a heated discharge. As such, the thermal discharge typically exceeds TDEC's established temperature criteria, therefore, multiport diffusers with mixing zone are used to adequately mix the thermal effluent to meet the state water quality standard at the end of the mixing zone. In such cases, the TDEC rules specific to the Fish and Aquatic Life use classification provide that:

"A successful demonstration as determined by the state conducted for thermal discharge limitations under Section 316(a) of the Clean Water Act, (33 U.S.C. §1326), shall constitute compliance... [with the temperature criteria]."

TVA has previously made such successful demonstration for the SQN thermal discharge in support of mixing zone criteria as further discussed below.

1.2.2 Permitted Conditions Currently permitted thermal discharge limitations for SQN specify that the daily maximum temperature is not to exceed 30.5'C (86.9°F) at the end of the mixing zone (Page 1 of 28),

NPDES permit TN0026450). This mixing zone criteria are based on a previous demonstration by TVA, in accordance with CWA §316(a) and TDEC Rule 1200-4-3-.03 noted above, that a balanced indigenous population (BIP) of fish, shellfish, and wildlife is supported in the Tennessee River potentially affected by the thermal discharge. The mixing zone criteria, as supported by the biological studies, also encompass other components of the TDEC temperature criteria, specifically the change in temperature from ambient/upstream conditions and rate of change in temperature. SQN has maintained a good compliance record with its mixing zone criteria throughout each NPDES permit term since first authorized in the late-1980s; ongoing biological monitoring has consistently demonstrated the mixing zone criteria are protective of aquatic communities in the river near the facility.

1.2.3 Criteria for Alternate Thermal Limits Under §316(a)

The regulatory provisions that implement CWA §316(a) provide limited guidance on precisely what the demonstration study must contain to be considered adequate and do not identify precise criteria against which to measure whether a "balanced and indigenous" aquatic community is protected and maintained. Instead, the regulations provide broad guidelines.

Under the broad regulatory guidelines, the discharger must show that the ATL desired, "considering the cumulative impact of its thermal discharge together with all other significant impacts on the species affected," will "assure the protection and propagation of a balanced, indigenous community of shellfish, fish and wildlife in and on the body of water into which the 2

discharge is to be made (40 CFR § 125.73). Critical to the demonstration is the meaning of the term "balanced indigenous community". The rules provide the following definition:

"The term "balanced indigenous community" is synonymous with the term balanced, indigenous population (i.e., BIP) in the Act and means a biotic community typically characterized by diversity, the capacity. to sustain itself through cyclic seasonal changes, presence of necessary food chain species and by a lack of domination by pollution tolerant species.

Such a community may include historically non-native species introduced in connection with a program of wildlife management and species whose presence or abundance results from substantial, irreversible environmental modifications" (40 CFR § 125.73).

Pursuant to this regulatory definition, a successful demonstration must show that under -the desired ATL, and in light of the cumulative impact of the thermal discharge together with all other significant impacts on the species affected, the following characteristics, which are indicative of a BIP, will continue to exist: (1) diversity, (2) the capacity of the community to sustain itself through cyclic seasonal changes, (3) presence of necessary food chain species, and (4) a lack of domination by pollution tolerant species.

There are several methodologies a discharger may pursue in making a §316(a) demonstration.

Under the regulations, new dischargers must use predictive methods (e.g., laboratory studies, literature surveys, or modeling) to estimate an appropriate ATL that will assure the protection and propagation of a balanced, indigenous community prior to commencing the thermal discharge. However, existing dischargers, such as SQN, need not use predictive methods. For such dischargers, §316(a) demonstrations may be based upon the "absence of prior appreciable harm" to a balanced, indigenous community (see 40 CFR §125.73(c)(1)(i) and (ii)).

Such demonstrations must show either that:

i)

No appreciable harm has resulted from the thermal component of the discharge taking into account the interaction of such thermal component with other pollutants and the additive effect of other thermal sources to a balanced, indigenous community of shellfish, fish, and wildlife in and on the body of water into which the discharge has been made; or ii)

Despite the occurrence of such previous harm, the desired alternative effluent limitations (or appropriate modifications thereof) will nevertheless assure the protection and propagation of a balanced, indigenous community of shellfish, fish, and wildlife in and on the body of water into which the discharge is made.

Furthermore, in determining whether or not prior appreciable harm has occurred, the regulations provide that the permitting agency consider the length of time during which the applicant has been discharging and the nature of the discharge.

The regulations do not define "prior appreciable harm." However, using the definition of "balanced, indigenous community," mixing zone criteria are generally granted under either of the following circumstances:

3

1.

When a discharger shows that the characteristics of a BIP (i.e., diversity, the capacity to sustain itself through cyclic seasonal changes, presence of necessary food chain species, and a lack of domination by pollution tolerant species) exist.

Stated another way, the existence of such characteristics essentially prove that the aquatic community has not been appreciably harmed; or

2.

Despite any evidence of previous harm, the characteristics of a BIP, as stated above, will nevertheless be protected and assured under the alternate limit.

1.2.4 Mixing Zone Requirements in Tennessee Rule 1200-4-3-0.5 As noted above, §316(a) pertains to the Fish and Aquatic Life use classification and provides NPDES-permitted facilities a regulatory compliant means of demonstrating that promulgated temperature criteria may be more stringent than necessary to support a BIP. In such cases, less stringent thermal criteria (i.e., ATLs) are justified. However, other use classifications such as Domestic Water Supply and Recreation must be protected as well. Compliance with TDEC temperature criteria for these uses is typically determined after the discharge has had the opportunity to mix with the receiving water; that is, an allowable mixing zone is determined.

TDEC rules define the mixing zone as:

"That section of a flowing stream or impounded waters in the immediate vicinity of an outfall where an effluent becomes dispersed and mixed." [ 1200-4-3-.04(8)]

The rules [1200-4-3-.05(2)] further provide that mixing zones are to be restricted in area and length and not:

1.

prevent the free passage of fish or cause aquatic life mortality in the receiving waters;

2.

contain materials in concentrations that exceed acute criteria beyond the zone immediately surrounding the outfall;

3.

result in offensive conditions;

4.

produce undesirable aquatic life or result in dominance of a nuisance species;

5.

endanger the public health or welfare; or

6.

adversely affect the reasonable and necessary uses of the area;

7.

create a condition of chronic toxicity beyond the edge of the mixing zone;

8.

adversely affect nursery and spawning areas; or

9.

adversely affect species with special state or federal status.

While TVA's proposed §316(a) demonstration study plan fully examines the effects of the thermal discharge on the aquatic life components of the mixing zone requirements, the potential effects to other non-aquatic life use classifications (items 3, 5, and 6 above) are generally not evaluated. Therefore, this plan has been revised herein to incorporate and/or collect additional 4

information needed to address the reasonable potential for impairment of other non-aquatic life uses in the Tennessee River near the facility.

1.3 Study Plan Organization This Study Plan is organized into the following sections:

1.

Introductory information, including regulatory basis and rationale for the study;

2.

Background information, including a summary of the findings of the previous

§316(a) investigation and subsequent biological monitoring; and,

3.

The proposed design and implementation schedule for the SQN §316(a) demonstration Study Plan.

2.0 STUDY BACKGROUND 2.1 Sequoyah Nuclear Plant The SQN facility is operated to produce base-load electric power throughout the year. When operating at design (nameplate) capacity (2,400 MW), the units requires approximately 1,602 million gallons per day of condenser cooling water. Waste heat increases the temperature of the cooling water by approximately 16.4°C (29.5°F) before it is discharged into the river. The actual condenser flow, and hence the AT, may vary somewhat with the circulating water pump head and the condenser efficiency.

2.2 Description of the Receiving Waterbody Sequoyah Nuclear is located on the right descending bank of Chickamauga Reservoir (TRM 484.5) approximately 18 miles northeast of Chattanooga, Tennessee, and 7 miles southwest of Soddy-Daisy, Tennessee (Figure 1). Chickamauga Reservoir was impounded in 1940 and at full pool covers approximately 36,240 acres.

The topography of the reservoir in the vicinity of the discharge outlet consists of a shallow overbank area on the plant side which extends from TRM 484 downstream to TRM 481.8 and varies in depth from 2 to 20 ft and from 500 to 3,100 ft in width. This shallow area is bordered by a main river channel which is about 900 feet (ft) wide and approximately 60 ft deep. Along this reach there are several small, shallow embayments.

The Tennessee River flow in the vicinity of SQN is controlled by releases from Watts Bar and Chickamauga Dams, and to a lesser extent Hiwassee River. SQN is situated on Chickamauga Reservoir approximately 54.5 river miles downstream from Watts Bar Dam and 13.5 river miles upstream from Chickamauga Dam.

5

2.3 Previous §316(a) Demonstration Study TVA conducted comprehensive §316(a) demonstration-related studies of the SQN thermal effluent in the mid-1980s to support establishment of the current mixing zone criteria for the plant discharge (TVA, 1989). The minimum average daily flow for the Tennessee River near SQN at the time of the early studies was 6,000 cfs.

The mid-1980s studies included extensive sampling of the aquatic community including:

" Phytoplankton,

" Periphyton,

Aquatic macrophytes,

" Zooplankton,

" Benthic macroinvertebrates; and

" Fish populations.

Hydrothermal, water quality and other parameters also were evaluated.

Major findings of these studies included:

Average dissolved concentration in the water column was similar immediately upstream and downstream of SQN.

Analysis of the data indicate that the assemblages of phytoplankton, zooplankton, and macroinvertebrates were diverse and, in general, relatively abundant.

Dominance of blue-green algae was similar upstream and downstream of SQN.

" The phytoplankton and zooplankton communities were found to be similar, or if different, not impacted by SQN operation, at all stations during 20 of the 27 survey months when the plant was in operation.

Species richness in the benthic macroinvertebrate communities during pre-operational and operational monitoring was similar.

" No changes were documented in the aquatic macrophyte community that reflected effects of the thermal effluent.

" Fish species occurrence and abundance data indicated insignificant impacts. Avoidances of the plume could not be detected for any species of fish. One study found that sauger (Sander canadensis) were not concentrated in the thermal plume during winter months nor inhibited from movement past SQN. Results of gonadal inspections indicate that the heated discharge did not adversely affect fish reproduction.

6

Other fisheries studies indicated that the thermal discharge resulted in no discernible increase in parasitism.

" No mortalities of threadfin shad due to cold shock following shutdown of SQN were observed or reported, and none are anticipated to occur in the future.

2.4 Contemporary Studies Monitoring of the thermal effects of the SQN discharge on the aquatic community of the receiving waterbody has been more recently conducted by TVA after an agreement was reached with TDEC in 2001. TVA's "Vital Signs" monitoring program also provides useful information for evaluating reservoir-wide effects. Monitoring has included sampling of the fish and macroinvertebrate communities and associated collection of temperature and other water quality parameters. Results of the permit monitoring work and TVA's ongoing Vital Signs monitoring (TVA, 2011) have consistently demonstrated that fish and macroinvertebrate assemblages of Chickamauga Reservoir within and downstream of the SQN thermal discharge are similar to

-those of upstream locations, as well as to established mainstem reservoir reference conditions for the area.

Results of the above studies notwithstanding, TVA plans to implement this Study Plan for the purpose of further evaluating the SQN thermal discharge to support continuance of the ATL for the facility discharge in accordance with CWA §316(a) and TDEC Rule 1200-4-3-.03(e).

7

3.0 STUDY PLAN This §316(a) demonstration Study Plan is informed by communications with TDEC and EPA, the study design of the previous demonstration study, and TVA's ongoing river/reservoir biological monitoring programs.

3.1 Study Timing As reasonably practicable, TVA sampling crews will coordinate with SQN facility operations staff to schedule field studies to coincide with representative conditions of maximum generation for the time period to be sampled as dictated by seasonal power demand. The additional field studies will be conducted during the period of critical environmental (thermal) conditions in summer (mid-July - August) when plant operations and ambient reservoir temperatures are at expected seasonal maximums. Summer monitoring will be conducted once during the SQN permit cycle. Data collection during this period will focus on characterization/delineation of the thermal plume and biological field investigations inclusive of thermally affected and unaffected areas. TVA will also conduct monitoring in autumn (October - mid-December) as has been occurring in previous study years.

3.2 Study Scope The following tasks will be conducted for the SQN §316(a) demonstration Study:

Task 1 - Evaluate Plant Operating Conditions During the course of the study, SQN operational data will be recorded, compiled, and analyzed to assist in the interpretation of thermal plume characteristics and biological community information. Available historical operational data will also be compiled and analyzed to evaluate and identify any material changes in SQN operations over the most recent 5-year period that might affect the thermal plume characteristics. Parameters to be recorded during the proposed study and evaluated historically include, but are not limited to:

" Cooling water intake flow and water temperature;

Discharge flow and water temperature; and

" Power generation statistics.

The data will be presented in tabular and graphical formats to describe SQN operational conditions during the current study.

8

Task 2 - Thermal Plume Monitoring and Mapping Physical measurements will be taken to characterize and map the SQN thermal plume concurrent with biological field sampling during the sampling events. In this manner, it is expected that the plume will be characterized under representative thermal maxima and seasonally-expected low flow conditions. Measurements will be collected during periods of high power production from SQN, as reasonably practicable, to capture maximum extent of the thermal plume under existing river flow/reservoir elevation conditions. This effort will allow general delineation of the "Primary Study Area" per the EPA (1977) draft guidance defined as the: "entire geographic area bounded annually by the locus of the 2°C above ambient sutface isotherms as these isotherms are distributed throughout an annual period"); ensure placement of the biological sampling locations within thermally influenced areas; and inform the evaluation of potential impacts on recreation and water supply uses.

However, it is important to emphasize that the >2°C isopleth boundary is not a bright line; it is dynamic, changing geometrically in response to changes in ambient river flows and temperatures and SQN operations. As such, samples collected outside of, but generally proximate to the Primary Study Area boundary should not be discounted as non-thermally influenced. Every effort will be made to collect biological samples in thermally affected areas as guided by the Primary Study Area definition.

Field activities will include measurement of surface to bottom temperature profiles along transects across the plume. One transect will be located proximate to the thermal discharge point; subsequent downstream transects will be concentrated in the near field area of the plume where the change in plume temperature is expected to be most rapid. The distance between transects in the remainder of the Primary Study Area will increase with distance downstream or away from the discharge point. The farthest downstream transect will be just outside of the Primary Study Area. A transect upstream of the discharge that is not affected by the thermal plume will be included for determining ambient temperature conditions. The total number of transects needed to fully characterize and delineate the plume will be determined in the field.

Temperature profile measurement (surface to bottom) points along a given transect will begin at or near the shoreline from which the discharge originates and continue across the plume until ambient background temperature conditions (based on surface (0.1 meters (m)/0.3 ft depth) measurements) or the far shore is reached. The number of measurement points along transects will generally be proportional to the width of the plume and the magnitude of the temperature change across a given transect. The distances between transects and measurement points will depend on the size of the discharge plume.

The temperature measurement instrument (Hydrolab or equivalent) will be calibrated to a thermometer whose calibration is traceable to the National Institute of Standards and Technology.

9

Temperature data will be compiled and analyzed to present the horizontal and vertical dimensions of the SQN thermal plume using spatial analysis techniques to yield plume cross-sections, which can be used to demonstrate the existence of a zone of passage under and/or around the plume.

Task 3 - Establishment of Biological Sampling Stations Water temperature data from Task 2 will define the relationships between the biological sampling zone and thermally affected areas as informed by the EPA (1977) draft guidance, which identifies the Primary Study Area as having water temperatures of >2°C (3.60F) above ambient temperature. The thermally affected sampling location will be referred to as the "downstream zone;" the non-thermally-affected sampling location will be referred to as the "upstream zone." If it is determined, based on the plume temperature measurements/mapping that the currently used biological sampling zone downstream of SQN is not fully within the EPA guidance-defined Primary Study Area, that sampling zone will be re-established within the EPA Primary Study Area.

Figure 3 depicts the downstream biological sampling zone; Figure 4 includes the location of the ambient biological sampling zone upstream of SQN.

Task 4 - Shoreline and River Bottom Habitat Characterization Informed by the results of Tasks 2 and 3, habitat characterization will be conducted at each selected sampling location to evaluate potential for bias in the results due to habitat differences between the thermally affected area and the ambient sampling locations, and to support interpretation of the biological data. Eight line-of-sight transects will be established across the width of Chickamauga Reservoir downstream and upstream of SQN to assess the quality of shoreline habitat (Figure 5). An integrative multi-metric index (Shoreline Aquatic Habitat Index or SAHI), including several habitat parameters important to resident fish species, will be used to measure the existing fish habitat quality. Using the SAHI, individual metrics are scored through comparison of observed conditions with reference conditions and assigned a corresponding value.

River bottom habitat characterization for both the upstream and downstream study zones will consist of eight transects each collected perpendicular to the shoreline.

Each transect will evaluate substrate by collecting 10 equally spaced Ponare dredge samples across the width of the reservoir. Each sample will be visually estimated to define substrate and then sieved to define percent makeup of substrate.

At each sample location, depth, and sediment type encountered will be recorded. Sediment categories include bedrock, boulder, cobble, gravel, sand, fines, and detritus. Each site will be assigned one of three habitat categories to reduce the amount of assessment variability. Habitat categories are as follows: A) areas with presence of large substrates such as cobble and boulders, B) areas dominated by sand or fine substrates and C) areas with a presence of a mixture of both A and B (small and large) habitat types.

10

Task 5 - Supporting Water Quality Measurements In addition to the thermal plume measurements, additional water quality profiles will be collected as necessary in conjunction with the field studies to: (i) support interpretation of the biological data; and (ii) evaluate potential impacts to water supply and recreational uses. Using a Hydrolab, or equivalent unit, three water column profiles at one-meter increments will be collected near the left descending bank, right descending bank and mid-channel at the upstream and downstream ends of each sample zone, and other areas as needed (e.g., at water supply intakes). Each profile collected will include temperature, dissolved oxygen concentration, pH, and conductivity.

Task 6 - Biological Evaluations The biological evaluations will focus on major representative species of the aquatic and wildlife community that could potentially be affected by the SQN thermal discharge. Sampling will be conducted during the summer months (mid-July - August) once during the SQN permit cycle to evaluate "worst case" conditions. Autumn monitoring (October - mid-December) will be conducted as a measure of potential manifested effects to the aquatic community from summer-long exposure to the thermal discharge and other stressors (basis for existing multi-metric assessments).

The biological communities to be sampled and collection methodologies are provided in the following sections.

Reservoir Fish Community Monitoring Informed by the habitat characterization and temperature measurements, the fish community will be sampled during sample events-at two locations: downstream within the thermal influence of the power plant (Figure 3); and upstream and beyond thermal influence of SQN (centered at TRM 489.5) (Figure 4). Sampling will be conducted by boat electrofishing and gill netting (Hubert 1996; Reynolds, 1996).

The electrofishing methodology is based on existing monitoring programs and consists of 15 shoreline-oriented boat electrofishing runs in the upstream sampling zone and 15 shoreline runs in the downstream zone. Each run is 300 m (984 ft) long and electrofishing is conducted for a duration of approximately 15 minutes each. The total near-shore linear area sampled will be approximately 4,500 m (15,000 ft) per zone (Jennings, et al., 1995; Hickman and McDonough, 1996; McDonough and Hickman, 1999). Should the size of the SQN thermal plume (i.e.,

Primary Study Area) be too small to allow collection of all replicate electrofishing runs, the needed remaining replicate runs will be conducted as close as practicable to the Primary Study Area and be identified in the data analyses. As indicated previously, the >2°C isopleth boundary that defines the Primary Study Area is not a rigid boundary; rather, its geometry changes in response to ambient river flows and temperatures and SQN operations (discharge flow). As such, samples collected outside of, but generally proximate to the Primary Study Area boundary should not be discounted as non-thermally influenced.

11

Experimental gill nets (so called because of their use for research as opposed to commercial fishing) are used as an additional gear type to collect fish from deeper habitats not effectively sampled by electrofishing. Each experimental gill net consists of five-6.1 m (20 ft) panels for a total length of 30.5 m (100 ft). The distinguishing characteristic of experimental gill nets is mesh size that varies between panels. For this application, each net has panels with mesh sizes of 2.5 (1 inch (in)), 5.1 (2 in), 7.6 (3 in), 10.2 (4 in), and 12.7 (5 in) centimeters (cm). Experimental gill nets are typically set perpendicular to river flow extending from near-shore to the main channel of the reservoir. Ten overnight experimental gill net sets will be used at each area.

Fish collected will be identified by species, counted, and examined for anomalies (such as disease, deformities, or hybridization).

Reservoir Benthic Macroin vertebrate Community Monitoring Benthic macroinvertebrates will be sampled with benthic grab samplers at ten equally-spaced points along the upstream (ambient) and downstream (mid-plume) sampling zones (Figures 3 and 4). A Ponar sampler (area per sample 0.06 mE) will be used for most samples. When heavier substrates are encountered, a Peterson sampler (area per sample 0. 11 mE 2 ) will be used.

Bottom sediments will be washed on a 533 micron (pt) screen; organisms will be picked from the screen and from any remaining substrate. Organisms will be sent to an independent laboratory for identification to the lowest practicable taxonomic level.

Reservoir Plankton Community Monitoring At the request of TDEC, phytoplankton samples will be obtained from a photic zone1 composite water sample collected at two locations each in the main channel area of the downstream sampling zone (Primary Study Area: mid-plume and plume downstream boundary; see Figure 3) and the upstream zone (Figure 4). This will be accomplished by lowering the intake end of a peristaltic pump sample tube to the bottom of the photic zone; and with the pump activated, slowly retrieving the sample tubing at a constant rate until the reservoir surface is reached. The phytoplankton data will be used to compare potential algal community response to thermal influence based on high-level taxonomy (i.e., Chrysophyta, Chlorophyta, Cyanophyta).

Zooplankton samples will be collected with a plankton net (300 millimeter (1 ft) diameter with 153 jt mesh) towed at two locations each in the main channel area of the downstream sampling zone (Primary Study Area: mid-plume and plume downstream boundary) and the upstream zone (Figures 3 and 4). Tows will consist of a vertical pull (tow) of the entire water column from 2 m off the bottom to the surface of the reservoir. Comparative analysis of zooplankton data from the two locations will be used to evaluate potential thermal influence on community structure.

For the purposes of this study, the photic zone is defined as twice the Secchi disk transparency depth or 4 meters, whichever is greater.

12

Plankton sampling will be conducted once during the sampling events utilizing established TVA procedures. Among other criteria, these procedures specify replicate sampling, proper sample preservation, and data processing requirements.

Wildlife Community Evaluation The wildlife community will be evaluated via implementation of visual encounter (observational) wildlife survey methodology and supported through review of the available literature, and communications with natural resource agency contacts. The effort will focus on the more water dependent species of the herpetofaunal, avian, and mammalian communities.

These activities will assist in identifying the wildlife species expected for the ecoregion, establish the presence/absence of a BIP of wildlife in the study area, and support evaluation of potential direct effects of temperature on sensitive life stages and any indirect effects such as increased predation.

A review of available resources to identify any threatened or endangered species potentially occurring in the study area will also be conducted.

For the visual encounter surveys, two permanent transects will be established both upstream and downstream of the SQN thermal effluent. The midpoint of the. upstream transect will be positioned at TRM 489.5 and span a distance of 2,100 m within this transect. The downstream transect will be located in the field based on sampling event and likewise span a distance 2,100

m. The beginning and ending point of each transect will be marked with GPS for relocation.

Transects will be positioned approximately 30 m offshore and parallel to the shoreline occurring on both right and left descending banks. Basic inventories will be conducted to provide a representative sampling of wildlife present during summer (mid-July - August) and late autumn-early winter (October - December).

Each transect will be surveyed by steadily traversing the length by boat and simultaneously recording observations of wildlife. Sampling frame of each transect will generally follow the strip or belt transect concept with all individuals enumerated that crossed the center-line of each transect landward to an area that included the shoreline and riparian zone (i.e., belt width generally averages 60 m where vision is not obscured).

Information recorded will include wildlife identification (to the lowest taxonomic trophic level) that is observed visually and/or

.audibly and a direct count of individuals observed per trophic level. If flocks of a species or mixed flock of a group of species are observed, an estimate of the number of individuals present will be generated. Time will be recorded at the starting and ending point of each transect to provide a general measure of effort expended.

However, times may vary among transects primarily due to the difficulty in approaching some wildlife species without inadvertently flushing them from basking or perching sites.

To compensate for the variation of effort expended per transect, observations will be standardized to numbers per minute or numbers per hectare in preparation for analysis.

I 13

The principal objective and purpose behind the wildlife surveys are to provide a preliminary set of observations to verify trophic levels of birds, mammals, amphibians and reptiles present that might be affected by thermal effects of the power plant (i.e., the ATL). If trophic levels are not represented, further investigation will be used to target specific species and/or species groups (guilds) that will determine the cause.

Task 7 -Water Supply and Recreational Use Support Evaluation Water temperature data collected as part of the thermal mapping (Task 2) and collection of supporting water quality information (Task 5) will be used to evaluate potential thermal impacts to water supply and recreational uses in the vicinity of SQN. Locations of any public water supply intakes and/or established public recreational areas will be determined and their position(s) mapped relative to the SQN thermal plume. We are aware of one domestic water supply intake located within approximately 10 river miles downstream of the SQN thermal discharge (Figure 1). The existence of any relevant water temperature data collected by the owners of these water supply intake(s) will be determined; and if available, requested to augment the field-collected data. As necessary (limited or no available owner-supplied temperature data),

direct measurements of water temperature may also be conducted specifically at these locations to evaluate potential thermal effects of the SQN discharge.

3.3 Data Contribution to the Analysis/Demonstration The analysis of fish, macroinvertebrate, and plankton community data will include traditional analyses whereby community attributes for the thermally affected areas will be compared to the non-thermally affected ambient location. For the purposes of the demonstration (within river/reservoir comparisons), the composition of fish and macroinvertebrate assemblages collected at the upstream station, uninfluenced by the SQN thermal discharge, is expected to set the baseline for evaluating the presence of a BIP in the downstream thermally influenced area. In that regard, a BIP is the expected determination for the thermally uninfluenced area.

3.3.1 Traditional Analyses As applicable, biological community data will be compiled into tables providing a listing of species collected and their status with regard to expected occurrence in the ecoregion. Reference materials such as: "The Fishes of Tennessee" (Etnier and Stames, 1993); similarly applicable publications; and best professional judgment by experienced aquatic biologists will be used for this determination. The dataset will be further evaluated with regard to the following:

Life stages represented,

" Food chain species present (e.g., predator and prey species),

Thermally-tolerant or -sensitive species present (based on Yoder et al., 2006),

" Representative Important Species (commercially and/orrecreationally); and

" Other community attributes (fish and macroinvertebrates) 14

To evaluate similarity with the downstream thermally influenced area, traditional species diversity indices will be used. Diversity indices provide important information about community composition and take the relative abundances of different species into account as well as species richness (i.e., number of individual species). Two diversity indices will be calculated for each sample location; such as: the Shannon-Weiner diversity index (H') (Levinton, 1982) and Simpson's Index of Diversity (Ds) (Simpson, 1949). Of the many biological diversity indices, these two indices are the most commonly reported in the scientific literature and will be evaluated for use in determining if community structure is similar between the thermally influenced and non-thermally influenced sampling locations. Other methods/indices for evaluating similarity between sampling sites will also be considered.

Based on the BIP baseline for the thermally uninfluenced ambient (upstream) location, comparative statistical analysis of the diversity indices and/or other measures of biological community status such as: species richness, relative abundance, pollution tolerance, trophic guilds, indigenousness, and thermal sensitivity (each pending sufficient sample size) will be used to confirm the presence/absence of a BIP in the thermally influenced study area.

3.3.2 Supporting Multi-metric Bioassessment Upon review of the species listings and establishment that the fish and macroinvertebrate populations are appropriate to the aquatic systems of the ecoregion, sample data also will be analyzed using TVA's Reservoir Fish Assemblage Index (RFAI) methodology (McDonough and Hickman 1999) and Reservoir Benthic Index to further evaluate if the SQN thermal discharge has materially changed ecological conditions in the receiving water body (Tennessee River -

Chickamauga Reservoir).

Reservoir Fish Assemblage Index The RFAI uses 12 fish assemblage metrics from four general categories: Species Richness and Composition (8 metrics); Trophic Composition (two metrics); Abundance (one metric); and Fish Health (absence of anomalies) (one metric). Individual species can be utilized for more than one metric.

Each metric is assigned a score based on "expected" fish assemblage characteristics in the absence of human-induced impacts other than impoundment of the reservoir. Individual metric scores for a sampling area (i.e., upstream or downstream) will be summed to obtain the RFAI score for each sample location and comparatively analyzed. The maximum RFAI score is 60.

Ecological health ratings (12-21 "Very Poor", 22-31 "Poor", 32-40 "Fair", 41-50 "Good", or 51-60 "Excellent"') are then applied to scores.

Based on statistical analysis of multiple RFAI datasets, RFAI scores between sites (e.g.,

downstream vs. upstream) will need to differ by 6 points or more to be considered to have different fish assemblages based on documented variability in the sampling methodology.

15

Regardless of the scores, a metric-by-metric examination will be conducted; this review will be helpful in evaluating potential metric-specific impacts that may be thermally related.

Reservoir Benthic Macroinvertebrate Index The RBI is similarly calculated as the RFAI except that it uses seven metrics specific to the macroinvertebrate assemblage. Each metric is assigned a score based on reference conditions and then summed to produce an overall RBI score for each sample site. The maximum RBI score is

35. Ecological health ratings (7-12 "Very Poor", 13-18 "Poor", 19-23 "Fair", 24-29 "Good", or 30-35 "Excellent") will then be applied to scores.

Based on statistical analysis of multiple RBI datasets, RBI scores between sites (e.g.,

downstream vs. upstream) that differ by 4 points or more will be considered to have different macroinvertebrate assemblages. A metric-by-metric examination will also be conducted, regardless of the scores, to evaluate potential thermally-related impacts on specific metrics.

3.3.4 Reasonable Potential Evaluation Based on existing information and temperature data collected/obtained during the study, the reasonable potential for the thermal discharge to impair current and future water supply and recreational (water contact) uses will be evaluated, The measured temperatures at the water supply intake location and location of any named recreational areas or areas where recreational users are known to congregate within the thermally influenced area (if any), will form the basis for determining reasonable potential for use impairment. Should reasonable potential be indicated, TVA will discuss with TDEC; and as necessary, submit a revised scope of work (study design) for this task (Task 7) proposing additional data collections and/or analysis to focus the evaluation.

3.4 Reporting A final Project Report will be prepared providing a description of the study design, data collection methods, SQN operational data, thermal plume mapping results, water quality monitoring data, and aquatic and wildlife community information. Raw data and associated field collection parameters will be appended to the report.

Results and conclusions regarding the §316(a) demonstration (maintenance of a BIP) and support of other use classifications (recreation and water supply) will be presented.

3.5 Study Schedule Summary Field sampling will be conducted during summer (mid-July - August) once during the SQN permit cycle and autumn (October - mid-December); each event will include sampling of the Primary Study Area/downstream zone and upstream/ambient zone.

16

TVA will provide TDEC with an interim progress report of the summer 2011 sampling results in spring of 2012. Final report will be completed and submitted with the SQN NPDES permit renewal package.

17

4.0 LITERATURE CITED EPA 1977. Draft Interagency 316(a) technical guidance manual and guide for thermal effects sections of nuclear facilities environmental impact statements. U.S. Environmental Protection Agency and U.S. Nuclear Regulatory Commission. U.S. Environmental Protection Agency, Office of Water Enforcement, Permits Division, Industrial Permits Branch, Washington, D.C.

Etnier, D.A. & Starnes, W.C. 1993. The Fishes of Tennessee. University of Tennessee Press, Knoxville, TN, 681 pp.

Hickman, G.D. and T.A. McDonough. 1996. Assessing the Reservoir Fish Assemblage Index-A potential measure of reservoir quality. In: D. DeVries (Ed.) Reservoir symposium-Multidimensional approaches to reservoir fisheries management. Reservoir Committee, Southern Division, American Fisheries Society, Bethesda, MD. pp 85-97.

Hubert, W. A. 1996. Passive capture techniques, entanglement gears. Pages 160-165 in B. R.

Murphy and D. W. Willis, editors. Fisheries techniques, 2nd edition. American Fisheries Society, Bethesda, MD.

Jennings, M. J., L. S. Fore, and J. R. Karr. 1995. Biological monitoring of fish assemblages in Tennessee Valley reservoirs, Regulated Rivers: Research and Management, Vol. 11, pages 263-274.

Levinton, J.S. 1982. Marine Ecology. Prentice-Hall, Inc. Englewood Cliffs, NJ McDonough, T.A. and G.D. Hickman. 1999. Reservoir Fish Assemblage Index development: A tool for assessing ecological health in Tennessee Valley Authority impoundments. In:

Assessing the sustainability and biological integrity of water resources using fish communities. Simon, T. (Ed.) CRC Press, Boca Raton, FL. pp 523-540.

Reynolds, J.B. 1996. Electrofishing. Pages 221-251 in B. R. Murphy and D. W. Willis, editors.

Fisheries techniques, 2nd edition. American Fisheries Society, Bethesda, MD.

Simpson, E.H. (1949) Measurement of diversity. Nature 163:688 see http ://www. wku.edu/-smithch/biogeog/SIMP 1949.htm TVA 2011. Biological Monitoring of the Tennessee River Near Sequoyah Nuclear Plant Discharge Autumn 2010. Tennessee Valley Authority, Knoxville, TN.

TVA 1989. A Predictive 316(a) Demonstration for an Alternative Winter Thermal Discharge Limit for Sequoyah Nuclear Plant, Chickamauga Reservoir, Tennessee. Tennessee Valley Authority, Chattanooga, TN Yoder, C.O., B.J. Armitage, and E.T. Rankin. 2006. Re-evaluation of the technical justification for existing Ohio River mainstem temperature criteria. Midwest Biodiversity Institute, Columbus, OH.

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FIGURES 19

Watts Bar Dam TRM r29 qJ SQN CCW Discharge TRM 483 6 Eastside Utility District Intake TRM T73 0

2 4

8M ite s Chickamauga Dam TRM 470 9 k*tAL

/

GO Figure 1. Vicinity map for Sequoyah Nuclear plant depicting Chickamauga and Watts Bar Dam locations and water supply intakes downstream of the plant thermal discharge 20

CCW Discharge to Multiport Diffuser on River Bottom A

Ky "IV-0 0 25 05 Figure

2. Site map for Sequoyah Nuclear plant showing condenser cooling water intake MIIs~ ~

Figure 2. Site map for Sequoyah Nuclear plant showing condenser cooling water intake structure, skimmer wall, and NPDES-permitted discharge Outfall No. 101 21

I Biomonitoring Stations Downstream of Sequoyah Nuclear Plant Electrofishing Stations O

Gill Netting Stations

-Benthic Macroinvertebrate Transects Phytoplankton Monitoring Stations U

IV1III, Figure 3. Biological monitoring zone downstream of Sequoyah Nuclear plant 22

Biomonitoring Stations Upstream of Sequoyah Nuclear Plant 0

Electrofishing Stations Gill Netting Stations Benthic Macroinvertebrate Transects Phytoplankton Monitoring Stations U

I IMMiles CCW Discharge SC Figure 4. Biological monitoring zone upstream of Sequoyah Nuclear plant thermal discharge 23

Transects for Shoreline Aquatic Habitat Index (SAHI)

Upstream and Downstream of Sequoyah Nuclear Plant CCW Discharge Figure 5. Anticipated transects to be established for conduct of the integrative multi-metric aquatic shoreline habitat assessment 24

TENNESSEE VALLEY AUTHORITY (TVA) - SEQUOYAH NUCLEAR PLANT (SQN) -

NPDES PERMIT NO. TN0026450 - WET REASONABLE POTENTIAL Current Whole Effluent Toxicity (WET) Requirements:

Ouffall 101 -

7-day or 3-brood IC25 Hard Trigger 43.2%

[IWC = 43.2% effluent (2.3 TUc)]

Monitoring Frequency Governed by B/CTP:

1/year when oxidizing biocides used 1/year when non-oxidizing biocides used Proposed WET Requirements:

Ouffall 101 -

7-day or 3-brood IC25 Hard Trigger = 42.8%

[IWC = 42.8% effluent (2.3 TUc)]

Monitoring Frequency Governed by B/CTP:

1/year when oxidizing biocides used 1/year when non-oxidizing biocides used

Background:

The current permit, effective March 1, 2011, requires chronic toxicity biomonitoring at a frequency governed by the B/CTP and with a monitoring limit (IC 25 > 43.2%) that serves as a hard trigger for accelerated biomonitoring. Previous to the issuance of the current permit, Outfall 101 demonstrated No Reasonable Potential for excursions above the ambient water quality chronic (CCC) criterion using historical effluent data. This demonstration of No Reasonable Potential has been maintained throughout the current permit cycle as evidenced in the accompanying historical effluent data for the last 20 studies.

Based on guidance in EPA's Technical Support Document (TSD) for Water Quality-based Toxics Control (EPA/505/2-90-001), a permit limit is not required when No Reasonable Potential exists for excursions above the CCC. In this situation, the TSD recommends that biomonitoring be conducted at a frequency of once every 5 years as part of the permit renewal process.

Proposed Changes:

1. TVA requests that the current permit's requirement for the B/CTP to govern the frequency of biomonitoring remain (i.e., once per year when oxidizing biocides are used, and once per year when non-oxidizing biocides are used).

2. TVA requests that the current monitoring limit be replaced with an IC25 = 42.8%,

which is based on revised effluent flow, and is consistent with the TSD guidance for effluents demonstrating No Reasonable Potential. Toxicity at the instream wastewater concentration (IWC) would serve only as a hard trigger for accelerated biomonitoring, as stated in the current permit.

3. TVA requests changes to the Serial Dilutions table as follows:

Page 22 of 28, table following paragraph 3:

Serial Dilutions for Whole Effluent Toxicity (WET) Testing 100%

(100+ML)2Monitoring Limit 0.5 X ML 0.25 X ML Control Effluent (ML)+MLI2 (MI

% effluent 100 71.4 42.8 21.4 10.7 0

4. TVA also requests that all other text in Section E of the permit remain unchanged.

Dilution and Instream Waste Concentration Calculations Outfall 101:

Average Discharge = 1491 MGD Tennessee River 1Q10 = 3483 MGD Dilution Factor (DF):

DF- =Qs

- 3483 2.34 Qw 1491 Qw1491 Instream Wastewater Concentration (IWC): IWC= 2w =-1 x 100 =42.8%

Qs 3483 Reasonable Potential Determination:

The last 20 studies for Outfall 101 were used for determining Reasonable Potential, with all studies resulting in no observed toxicity (<1.0 TUc) and a coefficient of variation equal to zero. This outcome demonstrates that no Reasonable Potential for excursions above the CCC exists, based on data obtained from testing conducted under the current operating conditions.

Historical data for the last 20 studies follows, and is followed thereafter with documentation of chemical additions which occurred during sampling for toxicity tests for Outfall 101.

2

SQN Documentation:

Summary of SQN Outfall 101 WET Biomonitoring Results **

Test Date Test Species

64. Feb 8-15, 2005

65. Jun 7-14, 2005

66. Jul 19-26, 2005

67. Nov 1-8, 2005

68. Nov 16-23, 2005

69. Nov 14-21,2006

70. Nov 28 - Dec 5, 2006

71. May 30-Jun 6, 2007

72. Dec 4-11,2007

73. Apr 15-22, 2008

74. Oct28-Nov 4, 2008

75. Feb 10-17, 2009

76. May 12-19, 2009

77. Nov 17-24, 2009

78. May 11-18, 2010

79. Nov 2-9, 2010

80. May 3-10, 2011

81. Nov 8-15,2011

82. May 8-15, 2012

83. Aug 12-17,2012 Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas

.Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Ceriodaphnia dubia Pimephales promelas Cer/odaphnia dub/a Pimephales promelas Acute Results (96-h Survival)

% Survival Study in Toxicity Undiluted Units Sample (TUa) 100

<1.0 93 100 100

<1.0 100 100

<1.0 100

<1.0 100 100 100

<1.0 98 100 100

<1.0 100 100

<1.0 93 100

<1.0 98 100

<1.0 100 100

<1.0 98 100

<1.0 100 100

<1.0 98 100

<1.0 100 100

<1.0 100 Chronic Results Study Toxicity Units (TUc)

<1.0

<1.0 n

40 20 20 Maximum 100

<1.0

<1.0 Minimum 93

<1.0

<1.0 Mean 99

<1.0

<1.0 CV 0.02 0.00 0.00

- Last 20 studies only were included for determining RP.

Shaded area includes data collected under the current permit.

3

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004-August 17, 2012 Date Sodium Towerbrom PCL-222 PCL-401 CL-363 Cuprostat-H-130M Nalco H-150M Hypochlorite mg/L mg/L mg/L mg/L PF mg/L mg/L Quat 73551 mg/L mg/L TRC Phosphate Copolymer DMAD Azole mg/L Quat TRC EO/PO 11/07/2004

<0.0187 0.000 0.014 11/08/2004

<0.0192 0.047 0.030 11/09/2004

<0.0233 0.048 0.016 0.041 11/10/2004

<0.0149 0.047 0.016 0.041 11/11/2004

<0.0149 0.049 0.017 0.043 11/12/2004

<0.0253 0.048 0.017 0.042 02/06/2005

<0.0042 0.028 0.010 02/07/2005

<0.0116 0.028 0.010 0.007 02/08/2005

<0.0080 0.028 0.010 02/09/2005 0.0199 0.028 0.010 02/10/2005

<0.0042 0.028 0.010 02/11/2005 0.0155 0.028 0.010 0.007 06/05/2005 0.0063 06/06/2005 0.0043 0.037 06/07/2005 0.0103 0.037 06/08/2005 0.0295 0.037 06/09/2005 0.0129 06/10/2005 0.0184 07/17/2005 0.0109 0.026 0.009 07/18/2005 0.0150 0.026 0.009 0.036 07/19/2005 0.0163 0.026 0.009 0.036 07/20/2005 0.0209 0.026 0.009 0.014 0.036 07/21/2005 0.0242 0.026 0.009 07/22/2005 0.0238 0.054 0.018 0.014 10/30/2005 0.0068 10/31/2005 0.0112 11/01/2005 0.0104 0.035 11/02/2005 0.0104 0.036 11/03/2005 0.0117 0.036 11/04/2005 0.0165 0,035 11/14/2005 0.0274 11/15/2005 0.0256 11/16/2005 0.0234 11/17/2005 0.0231 11/18/2005 0.0200 11/19/2005 0.0116 4

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004 - August 17, 2012 Date Sodium Towerbrom PCL-222 PCL-401 CL-363 Cuprostat-H-130M Nalco H-MSW Hypochloritc mg/L mg/L mg/L mg/L PF mg/L mg/L Quat 73551 150M 101 mg/L TRC m

Phosphate Copolymer DMAD Azole mg/L mg/L mg/L TRC EO/PO Quat Phosphate 11/12/2006 0.0055 11/13/2006 0.0068 0.037 11/14/2006 0.0143 0.037 11/15/2006 0.0068 0.037 11/16/2006 0.0267 0.037 11/17/2006 0.0222 11/26/2006 0.0188 11/27/2006 0.0138 11/28/2006 0.0120 11/29/2006 0.0288 11/30/2006 0.0376 12/01/2006 0.0187 05/28/07 0.015 05/29/07 0.036 0.015 05/30/07 0.0084 0.017 0.036 0.015 05/31/07 0.0103 0.036 0.015 06/01/07 0.0164 0.017 0.036 0.015 06/02/07 0.0305 0.015 12/02/07 0.0241 12/03/07 0.0128 12/04/07 0.0238 12/05/07 0.0158 12/06/07 0.0162 12/07/07 0.0175 04/13/08 0.0039 04/14/08 0.0124 04/15/08 0.0229 04/16/08 0.0143 04/17/08 0.0120 04/18/08 0.0149 10/26/08 0.0260 10/27/08 0.0151 0.017 10/28/08 0.0172 0.041 10/29/08 0.0154 0.018 0.041 0.030 10/30/08 0.041 0.030 10/31/08 0.0086 0.041 0.030 5

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004 - August 17, 2012 Date Sodium Towerbrom PCL-222 PCL-401 CL-Cuprostat-H-130M Nalco Spectrus H-150M MSW Hypochlorite mg/L mg/L mg/L 363 PF mg/L mg/L 73551 CT1300 mg/L 101 mg/L TRC Phosphate Copolymer mg/L Azole Quat mg/L mg/L Quat mg/L TRC DMAD EO/PO Quat Phosphate 02/08/09 0.0197 0.017 02/09/09 0.0237 0.017 02/10/09 0.0104 0.021 02/11/09 0.0155 0.017 02/12/09 0.0106 0.017 02/13/09 05/10/09 0.0129 05/11/09 0.0415 0.0446 05/12/09 0.0053 0.0396 05/13/09 0.0049 0.0396 05/14/09

<0.0141 0.0397 05/15/09

<0.0160 11/15/09 0.025 11/16/09 0.0152 11/17/09 0.0255 11/18/09 0.0306 11/19/09 0.0204 11/20/09 0.0093 05/09/10 0.0192 05/10/10 0.0055 05/11/10 0.0100 0.039 05/12/10 0.0171 0.039 05/13/10 0.0041 0.039 05/14/10 0a0099 0.039 6

Sequoyah Nuclear Plant Diffuser (Outfall 101) Discharge Concentrations of Chemicals Used to Control Microbiologically Induced Corrosion and Mollusks, During Toxicity Test Sampling November 7, 2004 - August 17, 2012 Date Sodium Towerbrom PCL-PCL-401 CL-363 Cuprostat-H-130M Nalco Spectrus H-150M MSW Floguard Hypochlorite mg/L 222 mg/L mg/L PF mg/L mg/L 73551 CT1300 mg/L 101 MS6236 mg/L TRC mg/L Copolymer DMAD Azole Quat mg/L mg/L Quat mg/L mg/L TRC Phos-EO/PO Quat Phosphate Phosphate phate 10/31/10 11/01/10 0.0122 11/02/10 0.0112 11/03/10 0.0163 11/04/10 0.0107 11/05/10 0.0132 05/01/2011 05/02/2011 0.04 05/03/2011 0.04 05/04/2011 0.0155 0.04 05/05/2011 0.0179 0.04 05/06/2011 0.0089 11/06/2011 0.0168 11/07/2011 0.0225 11/08/2011 0.0141 11/09/2011 0.0239 11/10/2011 0.0242 11/11/2011 0.0231 05/06/2012 05/07/2012 05/08/2012 0.041 05/09/2012 0.0145 0.041 05/10/2012 0.0298 0.041 05/11/2012 0.0174 08/12/2012 0.029 08/13/2012 0.0256 0.028 0.037 0.029 08/14/2012 0.0209 0.037 0.029 08/15/2012 0.0279 0.028 0.029 08/16/2012 0.0076 0.029 08/17/2012 0.0446 0.032 7

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