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)


Text

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 prepared under my direction or supervision in accordance with a system designed to assure that qualified 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, 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.

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)

Name TVA - SEQUOYAH NUCLEAR PLANT Address P.O. BOX 2000 IqNTEROFFICE OPS-5N-SQN)

SODDY-- D.ASY TN 37384 Facility TVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY ATTN: Spencer Whittier NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)

MAJOR DISCHARGE MONITORING REPORT (DMR)

(SUBR 01)

TN06450 101 G F-FINAL PERMITNUMBERJ NUMBER DIFFUSER DISCHARGE MON ITORING PERIOD EFFLUENT Form Approved.

OMB No. 2040-0004 YEAR IMQ I DAY I

YEAR I MO DAY From[ 14 1 03 To t31 NO DISCHARGE NOTE: Read instructions before completinq this form.

PARAMETER QUANTITY OR LOADING QUALITY OR CONCENTRATION NO.

FREQUENCY SAMPLE EX OF TYPE AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS ANALYSIS 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 DA MAX

'NUOUS 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

  • 0.1 0.1 MG/L FIVE PER CALCTD

':REQUIREMENT EFFLUENT GROSS RUEN MO AVG DAILY MAX WEEK TEMPERATURE - C, RATE OF SAMPLE 0

62 0

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0 PERMIT 2

DEG CONTI CALCTD EFFLUENT GROSS REQUIREMENT D

C/HR DAILY MX NUOUS SAMPLE MEASUREMENT

..PERMIT REQUIREMENT..

NAME/TITLE PRINCIPAL EXECUTIVE OFFICER Paul R. Simmons Sequoyah Plant Manager TYPED OR PRINTED 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 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, 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.

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SeuoaPlnMaae SIGNATURE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT 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)

Previous editions maybe used Page I of I

PERMITTEE NAME/ADDRESS (Include Facility Name/Location if Different)

Name TVA - SEQUOYAH NUCLEAR PLANT Address P.O. BOX 2000

_-NTEROIFFICE OPS-5N-SQN)

SODDY - DAISY, TN 37384 Facility.

TVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY ATTN: Spencer Whittier F

NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR Form Approved.

DISCHARGE MONITORING REPORT (DMR)

(SUBR 01) 0MB No. 2040-0*

TN0026450 101 T F - FINAL PERMIT NUMBER DISCHARGE NUMBER BIOMONITORING FOR OUTFALL 101 MONITORING PEROEFFLUENT MO!

A YAIM DAY 0

      • NO DISCHARGE Z NOTE: Read instructions before completing this form.

004 PARAMETER IC25 STATRE 7DAY CHR CERIODAPHNIA TRP3B 1

0 EFFLUENT GROSS IC25 STATRE 7DAY CHR PIMEPHALES TRP6C 1

0 EFFLUENT GROSS SAMPLE MEASUREMENT PERMIT.

REQUIREMENT.

QUANTITY OR LOADING QUALITY OR CONCENTRATION AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM Monitoring Not Required 413.2 MINIMUM.

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'REQUIREMENT NAME/TITLE PRINCIPAL EXECUTIVE OFFICER I Certify under penalty of law that this document and all attachments were prepared under my TELEPHONE direction or supervision in accordance with a system designed to assure that qualified 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 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 I

I CODEJ COMMENTS AND EXPLANATION OF ANY VIOLATIONS (Reference all attachments here)

Toxicity was not sampled in March 2014.

I DATE 14 04 11 YEAR MO DAY 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)

Name TVA - SEQUOYAH NUCLEAR PLANT Address P.O. BOX 2000

-.. 1.NTEROFFICE OPS-5N-SQ.N)_

SODDY - DAISY, TN 37384 Facility.

TVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY ATTN: Spencer Whittier NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)

MAJOR DISCHARGE MONITORING REPORT (DMR)

Form Approved.

(SUBR 01)

UIVID r TIENUMB640 103DG F - FINAL PERMlITi NUMBER RG UBý LOW VOL. WASTE TREATMENT POND

04. 2U4U-UUU0 MONITORINr. PERIOD I

EFFLUENT YEAR I MO DY From L 14T03L 01 L

4YEAR MO NO DISCHARGE Tol 14,1031 31i N

NOTE: Read instructions before completinq this form.

PARAMETER QUANTITY OR LOADING QUALITY OR CONCENTRATION NO.

EX FREQUENCY SAMPLE 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 d-irection 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 the information, the information submitted is, to the best of my knowledge and belief, true, Sequoyah Plant Manager 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.

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

TELEPHONE C

Squoyah Plant Manager 423 843-6502 SIGNATURE OF PRINCIPAL EXECUTIVE OFFICER OR AUTHORIZED AGENT AREA NUMBER CODE DATE 14 04 11 YEARI MO DAY EPA Form 3320-1 (REV 3199)

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

Previous editions may be used Page I of 1

PERMITTEE NAME/ADDRESS (Include Facility.Name/Location if Different)

Name TVA - SEQUOYAH NUCLEAR PLANT Address P.O. BOX 2000

.(PINTEROFFICE OPS-5N-SQ, N)

SODDY-DAISY TN 37384 Facjiy TA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY ATTN: Spencer Whittier NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) MAJOR DISCHARGE MONITORING REPORT (DMR)

(SUBR 01)

S TNO026450 OG F-FINAL PERMIT NUMBER jI DISCHARGE NU R

RECYCLED COOLING WATER MONITORING PERIOD EFFLUENT YEAR 0

DA DRY M**

NO DISCHARGE [x.

From[ 14 03 01 1 To I

03 1 31 Form Approved.

OMB No. 2040-0004 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 CENTIGRADE MEASUREMENT 04 00010 Z

0 PERMIT..*

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,REQUIREMENT",

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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 L UOUS DAILY MX.

i..

t uous CHLORINE, TOTAL RESIDUAL SAMPLE

            • 19 MEASUREMENT 50060 1

0 PERMIT REQUREMET**

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,

_423 843-6502_14_04_

_1 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 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)

Name TVA - SEQUOYAH NUCLEAR PLANT Address P.O. BOX 2000

-.(INTEROFFCE OPS-5 N-SQN)

SODDY - DAISY, TN_ 37394 Fac T

-IVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY ATTN: Spencer Whittier NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)

DISCHARGE MONITORING REPORT (DMR)

TN0026450 I

110 T PERMIT NUMBER DISCHARGE NUMBER!

MONITORING PERIOD I

Frm ARI MO TiDAYoi From! 14 1 03 1 01 1 To!1 14 03 31 MAJOR Form Approved.

(SUBR 01)

OMB No. 2040-0004 F - FINAL RECYCLED COOLING WATER EFFLUENT

... NO DISCHARGE Fj NOTE: Read instructions before completinq 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 CERIODAPHNIA MEASUREMENT 23 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)

Previous editions may be used Page 1 of 1

PERMITTEE NAME/ADDRESS (Include Facility Name/Location if Different)

Name TVA - SEQUOYAH NUCLEAR PLANT Address P.O. BOX 2000 L

_NTER.QFF_.CE OPS-ON-SN_).

SODDY - DAISY TN 37384 Facility TVA - SEQUOYAH NUCLEAR PLANT Location HAMILTON COUNTY ATTN: Spencer Whittier NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)

MAJOR Form Approved.

DISCHARGE MONITORING REPORT (DMR)

(SUBR 01)

OMB No. 2040-0004 TN0026450 118 F-FINAL PERMIT NUMBER IDISCHARGENUMBER VWASTEWATER & STORM WATER MONITORING PERIOD I

EFFLUENT I YEARI MO I DAY NO DISCHARGE F

NOTE: Read instructions before completinq this form.

PARAMETER QUANTITY OR LOADING 1

QUALITY OR CONCENTRATION NO.

FREQUENCY SAMPLE IEX OF TYPE AVERAGE MAXIMUM UNITS MINIMUM AVERAGE MAXIMUM UNITS ANALYSIS OXYGEN, DISSOLVED (DO)

SAMPLE 9**

1 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 MN.

..DOTH 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, 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, SequoyahPlantManager 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 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 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 r eanalyzing 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