ML22014A121

Tennessee Valley Authority, Watts Bar, National Pollutant Discharge Elimination System Permit No. TN0020168 - Comments on Draft NPDES Permit

ML22014A121
Person / Time
Site:	Watts Bar
Issue date:	01/06/2022
From:	Pearman P Tennessee Valley Authority
To:	Janjic V Office of Nuclear Reactor Regulation, State of TN, Dept of Environment & Conservation
References
Download: ML22014A121 (5)

Text

TENNESSEE VALLEY l AUTHOR ITY

1101 Mar ket Street, BR 2C, Chattanooga, Tennessee 37402

Sent Via Electronic Transmittal

January 6, 2022

Mr. Vojin Janjic (Vojin.Janjic@tn.gov)

Manager, Water-Based Systems Division of Water Resources Tennessee Department of Environment and Conservation William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 11th Floor Nashville, Tennessee 37243

Dear Mr. Janjic:

TENNESSEE VALLEY AUTHORITY (TVA) -WATTS BAR NUCLEAR PLANT (WBN)

NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT NO.

TN0020168 - COMMENTS ON DRAFT NPDES PERMIT

TVA has reviewed the subject draft permit dated December 8, 2021, and offers the following comments for your consideration :

1. Page 1, Section 1.1., second paragraph: TVA posits Virtual Outfall V001 be included in this paragraph, as it is an outfall where discharge shall be limited and monitored as specified on page 7, Section 1.1. 1.

2. Page 3, Section 1. 1.1., OSN 101 & OSN 102 Note (6): TVA requests chromium and zinc be added with the following language: Priority Pollutants, other than chromium and zinc,

will not be discharged in cooling tower blowdown in amounts that are detectable by analytical methods in 40 CFF Part 136. Monitoring for the priority pollutants, including chromium and zinc, will not be required unless it has been added to industrial processes and will be present in the discharge effluent. This request also applies to the applicable parts in the Rationale.

3. Page 3, Section 1.1.1., OSN 101 & OSN 102 last note: TVA requests this note to be corrected with the following language : See Part 3.2 for biomonitoring test and reporting requirements.

4. Pages 6 and 7, Section 1.1.1., Note (5) : TVA requests chromium and zinc be added with the following language : Priority Pollutants, other than chromium and zinc, will not be discharged in cooling tower blowdown in amounts that are detectable by analytical methods in 40 CFF Part 136. Monitoring for the priority pollutants, including chromium and zinc, will not be required unless it has been added to industrial processes and will Mr. Vojin Janjic Page 2 January 6, 2022

be present in the discharge effluent. This request also applies to the applicable parts in the Rationale.

5. Page 9, Section 1. 1.2., first paragraph: TVA requests chromium be added with the following language: Priority Pollutants contained in chemicals added for cooling tower maintenance except for chromium (if approved for use) and zinc, shall not be discharged in cooling tower blowdown in amounts that are detectable by analytical methods in 40 CFR Part 136. This request also applies to the applicable parts in the Rationale.

6. Page 9, Section 1.1.2., third paragraph: TV A requests zinc be added with the following language : The limit of 0.2 mg/L will apply to this permit. Priority Pollutants, with the exception of chromium and zinc, will not be discharged in cooling tower blowdown in amounts that are detectable by analytical methods in 40 CFR Part 136. Monitoring for the priority pollutants, including chromium and zinc, will not be required unless it has been added to industrial processes and will be present in the discharge effluent. This request also applies to the applicable parts in the Rationale.

7. Page 10, Section 1.1.2., Outfall OSN 113: Historical data collected and submitted by TVA between 2005 and 2021 has demonstrated a history of compliance for the passive mixing zone; therefore, TV A requests revising in-stream temperature surveys to a biennial (once per two years) frequency. (See Passive Mixing Zone Compliance Survey data submitted to the Division' s Chattanooga Environmental Field Office between 2005 and 2017, and data submitted in NetDMR from 2017 to 2021.)

8. Page 12, Section 1.2.1.: TVA requests language consistent with Sequoyah Nuclear Plant NPDES permit No. TN0026450 regarding the frequency of flow measu rement device calibrations. TVA requests the following language : Appropriate flow measurement devices and methods consistent with accepted scientific practices shall be selected and used to ensure the accuracy and reliability of measurements of the volume of monitored discharges. The devices shall be installed, calibrated (biennially at a minimum) and maintained to ensure that the accuracy of the measurements is consistent with accepted capability of that type of device. Monitoring devices selected shall be capable of measuring flows with a maximum deviation of less than plus or minus 10% from the true discharge rates throughout the range of expected discharge volumes.

9. Page 30, Section 3.2., third paragraph : In order to provide consistency with Sequoyah Nuclear Plant NPDES permit No. TN0026450, TVA requests that Biomonitoring Requirements in this paragraph be revised as follows: The toxicity tests specified herein for Outfalls OSN 101, 102, and 113 shall be conducted according to the Biocide/Corrosion Treatment Plan (BICTP). As outlined in the BICTP, WET testing shall be performed twice per year at each outfall: once per year when oxidizing biocides are being used, and once per year when non-oxidizing biocides are being used. In months when WET testing is performed, the permittee shall indicate under which conditions WET testing was performed on Discharge Monitoring Reports. In order to effectively track WET monitoring, monthly reporting shall continue. For monitoring periods when Mr. Vojin Janjic Page 3 January 6, 2022

WET testing is not required by the BICTP, the permittee shall report "Monitoring not required" (NOD/ = 9) for that month in NetDMR.

10. Page 31, Section 3.3.: TV A requests language consistent with other NOPES permits regarding the replacement of signs be added with the following language : Existing signage using the former name of the Division as " Water Pollution Control" can be used until the signs need replacement, at which time the new name should be added.

11. Page 32, Section 3.4.: TVA requests the phrase "Thermal Variance" be deleted from the section title. WBN ' s thermal limits ensure compliance with state water quality criteria at the edge of a defined mixing zone. WBN does not have, nor is it requesting, a thermal variance, therefore this section is misleading. TVA requests this section to be revised to reflect the operational conditions at WBN.

12. Page 44, Section 5. 1.: The requirements of Section 5.1. are governed by a separate NPDES Permit (Tennessee Storm Water Multi-Sector General permit for Industrial Activities). TVA requests adding language as follows: Stormwaterconcems associated with this facility are covered in the general permit and will therefore not be addressed in detail in this permit.

13. Rationale, Pages R 14-R 15, Section 5.1. 7.: WBN no longer has PCB transformers on site and PCBs will not be present in the discharge effluent. Therefore, TVA requests to remove the requirement to monitor for PCBs.

14. Rationale, Page R31, Section 5.6.2., top of page states that: TRC concentrations from Outfalls OSN101/OSN 102, and OSN 113 are to be measured separately with individual concentrations and calculated "(summed up)" to get a total concentration at Outfall V001. TVA requests that the language be corrected to state that a flow weighted average is calculated for Outfall V001, as shown in the diagram and equation on page R31.

15. Rationale, Page R31, Section 6.1.1., first sentence: WBN does not have a thermal variance; the language provided in this sentence of the draft permit appears to apply to Sequoyah Nuclear Plant, and not WBN. TVA requests the narrative be corrected and revised to reflect the operational conditions at WBN and be consistent with section 1. 1.2.

of the permit (pages 9-12).

Mr. Vojin Janjic Page4 January 6, 2022

TVA also requests a 30-day period between the issuance date and the effective date of the reissued permit to facilitate internal distribution of the permit. If you have questions or need additional information, please call Crystal Bishop at (423) 314-3820 in Chattanooga or by email at clbishopO@tva.gov.

Sincerely,

Paul Pearman Senior Manager Water Permits, Compliance, and Monitoring Mr. Vojin Janj ic Page 5 January 6, 2022

cc (Electronic Distribution):

Mr. Michael Bascom (Michael.Bascom@tn.gov)

Environmental Protection Specialist.

Division of Water Resources Chattanooga Environmental Field Office Tennessee Department of Environment and Conservation 1301 Riverfront Pkwy, Suite 206 Chattanooga, Tennessee 37402

Ms. Jennifer Innes (Jennifer.lnnes@tn.gov)

Environmental Program Manager Division of Water Resources Chattanooga Environmental Field Office Tennessee Department of Environment and Conservation 1301 Riverfront Pkwy, Suite 206 Chattanooga,Tennessee37402

Ms. Shannon McClellan (Shannon.McClellan@tn.gov)

Environmental Protection Specialist 11 Tennessee Department of Environment and Conservation William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 11th Floor Nashville, Tennessee 37243

Water Permits (Water. Permits@tn.gov)

Division of Water Resources Tennessee Department of Environment and Conservation William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 12th Floor Nashville, Tennessee 37243

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555