ML14106A019

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NPDES Permit No. TN0026450 - Discharge Monitoring Report (DMR) for March 2014
ML14106A019
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 04/11/2014
From: Simmons P
Tennessee Valley Authority
To: Morgan C
Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation
References
Download: ML14106A019 (9)
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Tennessee Valley Authority, Post Office Box 2000. Soddy Daisy, Tennessee 37384-2000 April 11,2014 Ms. Christina Morgan Tennessee Department of Environment and Conservation Division of Water Resources William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 11th Floor Nashville, Tennessee 37243

Dear Ms. Morgan:

TENNESSEE VALLEY AUTHORITY (TVA) - SEQUOYAH NUCLEAR PLANT (SQN) - NPDES PERMIT NO. TN0026450 - DISCHARGE MONITORING REPORT (DMR) FOR MARCH 2014 Enclosed is the March 2014 Discharge Monitoring Report for Sequoyah Nuclear Plant, an Attachment describing a suspected false positive analysis for an Oil and Grease sample during the monitoring period, and a letter from the contract laboratory discussing their findings from the QA/QC investigation. There were no exceedances during the monitoring period. If you have any questions or need additional information, please contact Spencer Whittier by email at sdwhittier@tva.gov or by phone at (423) 843-6714.

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

Sincerely, Paul R. Simmons Plant Manager Signatory Authority for:

John T. Carlin Site Vice President Sequoyah Nuclear Plant Enclosures cc (Enclosures):

Chattanooga Environmental Field Office U.S. Nuclear Regulatory Commission Division of Water Pollution Control Attn: Document Control Desk State Office Building, Suite 550 Washington, DC 20555 540 McCallie Avenue Chattanooga, Tennessee 37402-2013

PERMITTEE NAME/ADDRESS (Include Facility Name/Location if Different) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR Form Approved.

DISCHARGE MONITORING REPORT (DMR)

Name TVA - SEQUOYAH NUCLEAR PLANT (SUBR 01) OMB No. 2040-0004 Address P.O. BOX 2000 IqNTEROFFICE OPS-5N-SQN) TN06450 101 G F-FINAL SODDY-- D.ASY TN 37384 PERMITNUMBERJ NUMBER DIFFUSER DISCHARGE Facility TVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY MON ITORING PERIOD EFFLUENT YEAR IMQ I DAY I YEAR I MO DAY NO DISCHARGE ATTN: Spencer Whittier From[ 14 1 03 To t31 NOTE: Read instructions before completinq this form.

PARAMETER QUANTITY OR LOADING QUALITY OR CONCENTRATION NO. FREQUENCY SAMPLE EX OF TYPE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS ANALYSIS AVERAGE TEMPERATURE, WATER DEG. SAMPLE ** 27.6 04 0 31 / 31 RCORDR CENTIGRADE MEASUREMENT 00010 1 0 PERMIT

  • Req. Mon. DEG.C. CONTI CALCTD EFFLUENT GROSS REQUIREMENT .... " 'NUOUS DA MAX TEMPERATURE, WATER DEG. SAMPLE 15.1 04 0 31 / 31 MODELD CENTIGRADE MEASUREMENT 00010 Z 0 PERMIT '. "******** ********
  • 30.5 DEG. C. CONTI CALCTD INSTREAM MONITORING REQUIREMENTDAILY MX NUOUS TEMP. DIFF. BETWEEN SAMP. & SAMPLE * ** 4 04 0 31/ 31 CALCTD UPSTRM DEG.C MEASUREMENT 00016 1 1 .PERMIT  : ...... "* 5 DEG. C. CONTI CALCTD EFFLUENT GROSS REQUIREMENT< . ..... . . !". . " ... DAILY MX NUOUS FLOW, IN CONDUIT OR THRU SAMPLE 1706 03 0 31 / 31 RCORDR TREATMENT PLANT MEASUREMENT 50050 1. 0 PERMIT Req. Mon. MGD CONTI RCORDR EFFLUENT GROSS REQUIREMENT DAILY MAX NUOUS CHLORINE, TOTAL RESIDUAL SAMPLE ** 0.021 0.036 19 0 11/31 GRAB MEASUREMENT 50060 1 0 PERMIT

':REQUIREMENT ,: " *0.1 " 0.1 MG/L FIVE PER CALCTD EFFLUENT GROSS RUEN , , " . MO AVG DAILY MAX WEEK TEMPERATURE - C, RATE OF SAMPLE 0 62 0 31/ 31 CALCTD CHANGE MEASUREMENT 82234 1 0 PERMIT 2 DEG ****** CONTI CALCTD EFFLUENT GROSS REQUIREMENT  : D DAILY MX C/HR NUOUS SAMPLE MEASUREMENT

..PERMIT REQUIREMENT..,_.._ ,. _._"_ . .,.-_ __* __""_ ._ "

NAME/TITLE PRINCIPAL EXECUTIVE OFFICER 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 Ihat qualified Paul R. Simmons personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,

( SeuoaPlnMaae Sequoyah Plant Manager accurate, and complete. I am aware that there are significant penalties for submitting false SIGNATURE OF PRINCIPAL EXECUTIVE information, including the possibility of fine and imprisonment for knowing violations. OFFICER OR AUTHORIZED AGENT TYPED OR PRINTED COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

No closed mode operation. The following injections occurred: 1. Floguard MS6236 (max calc. conc. was 0.03 mg/L--limit 0.2 mg/L) 2. Biodetergent 73551 (max calc. conc. was 0.040 mg/L--limit 2.0 mg/L)

EPA Form 3320-1 (REV 3/99) Previouseditions maybe used Page I of I

PERMITTEE NAME/ADDRESS (Include FacilityName/Location if Different) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR Form Approved.

TVA - SEQUOYAH NUCLEAR PLANT DISCHARGE MONITORING REPORT (DMR)

Name (SUBR 01) 0MB No. 2040-0*004 Address P.O. BOX 2000

_-NTEROIFFICE OPS-5N-SQN) TN0026450 101 T F - FINAL SODDY - DAISY, TN 37384 PERMIT NUMBER DISCHARGE NUMBER BIOMONITORING FOR OUTFALL 101 Facility. TVA - SEQUOYAH NUCLEAR PLANT MONITORING PEROEFFLUENT Location HAMILTON COUNTY MO! A YAIM 0

DAY

      • NO DISCHARGE Z ATTN: Spencer Whittier F NOTE: Read instructions before completing this form.

PARAMETER QUANTITY OR LOADING QUALITY OR CONCENTRATION NO. FREQUENCY SAMPLE

____ EX OF TYPE AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS ANALYSIS IC25 STATRE 7DAY CHR SAMPLE MEASUREMENT Monitoring ** ** * * *

  • 23 CERIODAPHNIA Not Required *w *
  • w~

TRP3B 1 0 PERMIT. 413.2 j. ******** PERCENT SEMI COMPOS REQUIREMENT.

EFFLUENT GROSS MINIMUM. ANNUAL

  • W**** **r IC25 STATRE 7DAY CHR SAMPLE * *W**** ** *** **
  • Monitoring MEASUREMENT 23 PIMEPHALES i...

Not Required TRP6C 1 0 PERMIT.'. 4312 * * ** * **

  • PERCENT SEMI E COMPOS REQUIREMENT EFFLUENT GROSS MIMINUM ANNUAL SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT

'REQUIREMENT SAMPLE MEASUREMENT PERMIT REQUIREMENTA SAMPLE MEASUREMENT REQUIREMENT PERMIT . * * .. ',..  :..

  • SAMPLE MEASUREMENT PERMIT

'REQUIREMENT NAME/TITLE PRINCIPAL EXECUTIVE OFFICER I Certify under penalty of law that this document and all attachments were prepared under my TELEPHONE DATE -

direction or supervision in accordance with a system designed to assure that qualified I Paul R. Simmons 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 Sequoyah Plant Manager the information, the information submitted is, to the best of my knowledge and belief, true. uoyahPlant_,__ anager_423 843-6502 14 04 11 Sequoyah Plant Manager accurate, and complete. I am aware that there are significant penalties for submitting false SIGNATURE OF PRINCIPAL EXECUTIVE

-information, including the possibility of fine and imprisorenent for knowing violations. OFFICER OR AUTHORIZED AGENT AREA NUMBER TYPED OR PRINTED YEAR MO DAY I I CODEJ COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

Toxicity was not sampled in March 2014.

EPA Form 3320-1 (REV 3/99) Previous editions may be used Page 1 of 1

PERMITTEE NAME/ADDRESS (Include Facility Name/Location if Different) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR Form Approved.

Name TVA - SEQUOYAH NUCLEAR PLANT DISCHARGE MONITORING REPORT (DMR)

(SUBR 01) UIVID r04. 2U4U-UUU0 Address P.O. BOX 2000

-.. 1.NTEROFFICE OPS-5N-SQ.N)_ TIENUMB640 103DG F - FINAL SODDY - DAISY, TN 37384 PERMlITi NUMBER RG UBý LOW VOL. WASTE TREATMENT POND Facility. TVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY MONITORINr. PERIOD I EFFLUENT YEAR I MO DY L 4YEAR MO NO DISCHARGE ATTN: Spencer Whittier From L 14T03L 01 Tol 14,1031 31i N NOTE: Read instructions before completinq this form.

PARAMETER QUANTITY OR LOADING QUALITY OR CONCENTRATION NO. FREQUENCY SAMPLE EX OF TYPE ANALYSIS AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS PH SAMPLE **8 12 0 16/31 GRAB MEASUREMENT 00400 1 0 PERMIT " **** *** ** 6 9 SU THREE/ GRAB EFFLUENT GROSS REQUIREMENT MINIMUM MAXIMUM WEEK SOLIDS, TOTAL SUSPENDED SAMPLE ** 13 13 19 0 2 / 31 GRAB MEASUREMENT 00530 1 0 PERMIT . ** .30 .100 MGIL TWICE/ GRAB EFFLUENT GROSS REQUIREMENT . M VA XMONTH OIL AND GREASE SAMPLE ***<1 <1 19 0 2/31 GRAB MEASUREMENT 00556 1 0 PERMIT ** 15 20 MG/L TWICE/ GRAB EFFLUENT GROSS REQUIREMENT MO AVG ;DAILY MX MONTH FLOW, IN CONDUIT OR THRU SAMPLE 0966 1.052 03 31 / 31 RCORDR TREATMENT PLANT MEASUREMENT 50050 1 0 PERMIT Req. Mon. Req. Mon MGD SEE RCORDR EFFLUENT GROSS REQUIREMENT MOAVG DAILY MX PERMIT SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT REQUIREMENT NAME/TITLE PRINCIPAL EXECUTIVE OFFICER I Certify under penalty of law that this document and all attachments were prepared under my DATE d-irection or supervision in accordance with a system designed to assure that qualified el* TELEPHONE Paul R. Simmons personnel properly gather and evaluate the information submitted. Based on my inquiry ofthe 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, C Squoyah Plant Manager 423 843-6502 14 04 11 Sequoyah Plant Manager accurate, and complete. I am aware that there are significant penalties for submitting false SIGNATURE OF PRINCIPAL EXECUTIVE -

information, including the possibility of fine and imprisonment for knowing violations. OFFICER OR AUTHORIZED AGENT AREA NUMBER YEARI MO DAY TYPED OR PRINTED CODE COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

Page 1 of 1 EPA Form (REV 3199) 3320-1 (REV EPA Form 3320-1 3199) editions may Previous editions Previous may bebe used used Page I of 1

PERMITTEE NAME/ADDRESS (Include Facility.Name/Locationif Different) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR Form Approved.

DISCHARGE MONITORING REPORT (DMR)

Name TVA - SEQUOYAH NUCLEAR PLANT (SUBR 01) OMB No. 2040-0004 Address P.O. BOX 2000

.(PINTEROFFICE OPS-5N-SQ,N) S TNO026450 OG F-FINAL SODDY- DAISY TN 37384 PERMIT NUMBER jI DISCHARGE NU R RECYCLED COOLING WATER Facjiy TA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY MONITORING PERIOD EFFLUENT YEAR 0 DRY DA M** NO DISCHARGE [x.

ATTN: Spencer Whittier From[ 14 03 01 1 To I 03 1 31 I 1" ......

NU IT: R(ead instructions before comoletinq this form.

PARAMETER QUANTITY OR LOADING QUALITY OR CONCENTRATION NO. FREQUENCY SAMPLE EX OF TYPE AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS TEMPERATURE, WATER DEG. SAMPLE 0 4*

CENTIGRADE MEASUREMENT 04 00010 1 0 PERMIT * * ** REPORT DEG C CONTIN CALCTD EFFLUENT GROSS VALUE REQUIREMENT DAILY MX UOUS TEMPERATURE, WATER DEG. SAMPLE

  • MEASUREMENT 04 CENTIGRADE 00010 Z 0 PERMIT..* * ** DE*********

C CONTIN CALCTD

,REQUIREMENT", ~, "" . " 3C INSTREAMMONITORING *.,.DAILY MX UOUS TEMP. DIFF. BETWEEN SAMP. & SAMPLE 04 UPSTRM DEG.C MEASUREMENT 04 00016 1 0 PERMIT * "* 5 DEG C CONTIN CALCTD EFFLUENT GROSS VALUE REQUIREMENT DAILY. MX UOUS FLOW, IN CONDUIT OR THRU SAMPLE ******** 03* **

TREATMENT PLANT MEASUREMENT 50050 1 0 PERMIT . Req. Mon. MGD ******* . "

  • CONTIN RCORDR EFFLUENT GROSS VALUE REQUIREMENT .* ,,, ..... D DAILY L MX. " ' ' i..

' " .. . ,. ,,. t UOUS uous CHLORINE, TOTAL RESIDUAL SAMPLE ******** ******19 ** ********

MEASUREMENT 50060 1 0 REQUREMET**

PERMIT <.********. ******** 0.1 01, MGIL Five per CALCTD EFFLUENT GROSS VALUE . MO AVG DAILY MX Week TEMPERATURE - C, RATE OF SAMPLE 04******* *04*********

CHANGE MEASUREMENT 82234 1 0 PERMIT .: ******** 2 DEG C . ******* " CONTIN CALCTD EFFLUENT GROSS VALUE REQUIREMENT .M, UUS SAMPLE MEASUREMENT PERMIT REQUIREMENT NAMETITLE PRINCIPAL EXECUTIVE OFFICER I Certify under penalty of law that this document and all attachments were prepared under my TELEPHONE DATE direction or supervision in accordance with a system designed to assure that qualified Paul R. Simmons personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering Uoyah Ia 423- 2 4 4 the information, the information submitted is, to the best of my knowledge and belief, true, _423 _1 843-6502_14_04_

Sequoyah Plant Manager accurate, and complete. I am aware that there are significant penalties forsubmitting false SIGNATURE OF PRINCIPAL EXECUTIVE information, including the possibility of fine and imprisonment for knowing violations. OFFICER OR AUTHORIZED AGENT AARI MO D TYPED OR PRINTED _ CODE COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

No Discharge this Period EPA Form 3320-1 (REV 3199) Previous editions may be used Page 1 of 1

PERMITTEE NAME/ADDRESS (Include Facility Name/Location if Different) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR Form Approved.

DISCHARGE MONITORING REPORT (DMR)

Name TVA - SEQUOYAH NUCLEAR PLANT (SUBR 01) OMB No. 2040-0004 Address P.O. BOX 2000

- .(INTEROFFCE OPS-5 N-SQN) TN0026450 PERMIT NUMBER I 110 T DISCHARGE NUMBER!

F - FINAL SODDY - DAISY, TN_37394 RECYCLED COOLING WATER Fac -IVA - SEQUOYAH NUCLEAR PLANT T

Location HAMILTON COUNTY - MONITORING PERIOD I EFFLUENT ATTN: Spencer Whittier From! 14 1 03 1 01 1 To!1 14 03 31 Frm TiDAYoi ARI MO ... NO DISCHARGE Fj **

NOTE: Read instructions before completinq this form.

PARAMETER QUANTITY OR LOADING QUALITY OR CONCENTRATION NO. FREQUENCY SAMPLE EX OF TYPE MAXIMUM UNITS MINIMUM. AVERAGE MAXIMUM UNITS ANALYSIS AVERAGE IC25 STATRE 7DAY CHR SAMPLE **

MEASUREMENT 23 CERIODAPHNIA TRP3B 1 0 0 PERMIT

  • 43.2 * *PERCENT SEMI COMPOS EFFLUENT GROSS VALUE REQUIREMENT MINIMUM ANNUAL IC25 STATRE 7DAY CHR SAMPLE ***23 PIMEPHALES MEASUREMENT TRP6C 1 0 0 PERMIT. .43.2 PERCENT SEMI COMPOS EFFLUENT GROSS VALUE REQUIMINIMUM _MINIMUM ANNUAL SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT REQUIREMENT NAME/TITLE PRINCIPAL EXECUTIVE OFFICER 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 Paul R. Simmons personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persQns who manage the system, or those persons directly responsible for gathering Sequoyah Plant Manager the information, the information submitted is, to the best of my knowledge and belief, true, I_ -_-__-_- __...... .

Sequoyah Plant Manager accurate, and complete. I am aware that there are significant penalties fto submitting false SIGNATURE OF PRINCIPAL EXECUT)VI TYPED ORPRIN__

___information, including the possibility of fine and imprisonment for knowing violations. OFFICER OR AUTHORIZED AGENT

  • TYPED OR PRINTED COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

No Discharge this Period EPA Form 3320-1 (REV 3/99) Previouseditions may be used Page 1 of 1

PERMITTEE NAME/ADDRESS (Include FacilityName/Location if Different) NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR Form Approved.

DISCHARGE MONITORING REPORT (DMR) (SUBR 01) OMB No. 2040-0004 Name TVA - SEQUOYAH NUCLEAR PLANT Address P.O. BOX 2000

- - _NTER.QFF_.CE L OPS-ON-SN_). TN0026450 118 F-FINAL SODDY - DAISY TN 37384 PERMIT NUMBER IDISCHARGENUMBER VWASTEWATER & STORM WATER Facility TVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY MONITORING PERIOD I EFFLUENT I YEARI MO I DAY NO DISCHARGE F ATTN: Spencer Whittier NOTE: Read instructions before completinq this form.

PARAMETER QUANTITY OR LOADING 1 QUALITY OR CONCENTRATION IEX NO. FREQUENCY OF SAMPLE TYPE AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS ANALYSIS OXYGEN, DISSOLVED (DO) SAMPLE 19**

MEASUREMENT 00300 1 0 ' PERMIT 2 MGIL TWICE/ GRAB EFFLUENT GROSS REQUIREMENT MINIMUM WEEK SOLIDS, TOTAL SUSPENDED SAMPLE MEASUREMENT 19 00530 1 0 PERMIT

  • 100 MG/L TWICE/ GRAB EFFLUENT GROSS REQUIREMENTDAILY MX WEEK SOLIDS, SETTLEABLE SAMPLE 25 MEASUREMENT 25 00545 1 0 PERMIT * .*
  • MULL ONCE/ GRAB EFFLUENT GROSS REQUIREMENT . .DOTH MN.

FLOW, IN CONDUIT OR THRU SAMPLE 03**

TREATMENT PLANT MEASUREMENT 03 50050 1 0 PERMIT. Req. Mon. Req. Mon. MGD **ONCE/ ESTIMA EFFLUENT GROSS REQUIREMENT MO AVG DAILY MX BATCH SAMPLE MEASUREMENT PERMIT REQUIREMENT SAMPLE MEASUREMENT PERMIT .

REQUIREMENT ":.:"":

SAMPLE MEASUREMENT PERMIT REQUIREMENT, NAME/TITLE PRINCIPAL EXECUTIVE OFFICER I Certify under penalty of law that this document and all attachments were prepared under my ,,r TELEPHONE DATE direction or supervision in accordance with a system designed to assure that qualified Paul R. Simmons personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, Orthose persons directly responsible for gathering Sequoyah Plant Manager the information, the information submitted is, to the best of my knowledge and belief, true, SequoyahPlantManager _ 423 843-6502 14 04 11 Sequoyah Plant Manager accurate, and complete. I am aware that there are significant penalties forsubmitting false SIGNATURE OF PRINCIPAL EXECUTIVE information, including the possibility of fine and imprisonment for knowing violations. OFFICER OR AUTHORIZED AGENT AREA NUMBER YEAR MO DAY TYPED OR PRINTED tCD COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

During this reporting period, there has been no flow from the Dredge Pond other than that resulting from rainfall. No Discharge this Period EPA Form 3320-1 (REV 3199) Previous editions may be used Page 1 of 1

Attachment 1 TVA - Sequoyah Nuclear Plant NPDES Permit No. TN0026450 Event Description On March 3, 2014 SQN collected Oil and Grease (O&G) samples at Internal Monitoring Point (IMP) 103 for routine compliance. During sample collection there was no visual observation of an oil sheen or floating scum or solids resulting from the discharge. The contract laboratory issued the lab report for the referenced sample and the O&G content was 38.9 mg/L.

TVA has an internal policy of collecting split samples for compliance parameters so that in the event of laboratory error or mishandling of samples a backup is available for analysis. SQN shipped the split O&G sample collected at the same time on March 3, 2014 to an independent contract laboratory who reported the O&G content as less than 1.4 mg/L.

TVA requested the contract laboratory reporting 38.9 mg/L perform a QA/QC investigation of the sample analysis; however, an obvious error was not readily identified and there was insufficient sample for reanalysis. False positive results from O&G analysis by Method 1664 may be obtained when contaminants are introduced to the weigh pan during analysis. Sodium sulfate granules or incomplete evaporation of solvents or oils from highly contaminated samples can contribute to weight determinations and lead to false positive results. The laboratory determined based on historical O&G samples from SQN and the split sample results by the independent laboratory that the result of 38.9 mg/L is suspected to be biased high from possible laboratory error.

TVA believes the reported O&G value of 38.9 mg/L from the March 3, 2014 sample is erroneous based on historical O&G trends, the fact that there was no visual observation of an oil sheen or floating scum or solids in IMP 103 discharge at the time of sample collection, and the QA/QC investigation performed by the laboratory. The contract laboratory has provided TVA a letter in response to the investigation and the incident was entered into the laboratory's corrective action database for documentation and tracking. The letter has also been included with this DMR report for your reference.

Based on the findings discussed above, TVA did not include the O&G sample result of 38.9 mg/L in the March 2014 DMR. The laboratory report and associated documentation of visual observations of the discharge and the QA/QC investigation will be maintained on file at SQN for future reference.

Pace Analytical Services, Inc.

    • 9800 Kincey Avenue, Suite 1.00 ace Analytical Huntersvhlle, NC 28078 Phone: 704.875.9092 Fax: 704.875.9091 March 19, 2014 Spencer Whittier Tennessee Valley Authority PO Box 2000 Sequoyah Access Rd Soddy Daisy, TN 37379 RE: Project: NPDES Monthly Samples O&G 3/3 Pace Project ID: 92191889 This letter is in regard to the results for Oil and Grease Method 1664 analysis.

Oil and Grease by 1664 is a gravimetric method that determines the amount of oil and grease by a weight determination. False positive results may be obtained when contaminants are introduced to the weigh pan during analysis. Sodium Sulfate granules, incomplete evaporation of solvents or oils from highly contaminated samples can contribute to weight determinations and lead to false positive results. The laboratory takes corrective action when false high results are suspected by reanalyzing the sample.

The results for sample 92191889001 were investigated by the laboratory upon client request.

The sample was unable to be reanalyzed due to in sufficient sample volume. An error was unable to be identified. However, based on historical data and split sample results from an independent laboratory by the client, the results are suspected to be biased high from possible laboratory error.

This incident has been recorded in the laboratory's corrective action database for documentation and tracking. The information is used to develop continuous improvement plans and departmental training to avoid similar errors.

If you have any further questions or need additional information, please contact Lorri Patton or myself at 704-875-9092.

Sincerely, Cheryl Johnson Quality Manager

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