TENNESSEE DEPARTMENT OF ENVIRONMENT AND CONSERVATION
 

DIVISION OF WATER POLLUTION CONTROL
 

401 CHURCH STREET
 

L & C ANNEX 6TH FLOOR
 

NASHVILLE TN 37243
 

Mr. Kevin Cook, RG CHMM DEC 29 2011 

Environmental Superintendent 

Nyrstar Clarksville, Inc. 

PO Box 1104 

Clarksville, Th 37041 

Subject"	 Minor Modification NPDES Permit No, TN0029t57 

Nyrstar Clarksville, Inc. 

Clarksville, Montgomery County. Tennessee 

Dear Mr. Cook: 

In nceordance with the provisions of "The Tennessee Water Quality Control Act" (Tennessee Code Annotated, 

Sections 6'l-3-101 through 69-3-120) the above referenced NPDES Permit is hereby modified by the Division 

of Water Pollution Control. The continuance and/or reissuance of this NPDES Pennir IS contingent upon your 

meeting the conditions and requirements as staled therein. 

Pursuant to the pennittecs request the division made minor modifications to the permit's Attachments 2 and 3. 

These changes are discussed in the permit'5 Second Addendum to Rationale. 

Please be advised that a petition for permit appeal may be filed, pursuant to T.CA. Section 69-3-105, 

subsection {i}, by the permit applicant or by any aggrieved person who participated in the public comment 

period or gave testimony at a formal public hearing whose appeal is based upon any of the issues that were 

prov idcd to the conutussroner in writing during the public comment period or in testimony at a formal public 

hearing on the permit application. Additionally, for those pennits for which the department gives public notice 

of a draft permit, any permit applicant or aggrieved persou may base a permit appeal on any material change to 

conditions in the final pcnnit from those in the draft. unless the material change has been subject to additional 

opportunity for public comment. Any petition for pcrmn appeal under this subsection (i) shall be filed with the 

board within thirty (30) days after public notice of the commissioner's decision to issue or deny the permit. 

If you have questions. please contact the Nashville Environmental Field Office at 1-888-891-TDEC; or, at this 

office. please contact Mr. Gary Davis at (615) 532-0649 or by E-mail at GW)'.D'1l·is@/II.g01'. 

Sin -crcly. 

in Janjic 

anager, Permit Section 

Division of Water Pollution Control 

P\\H_, 

Fnclo'L1r~

cc:	 Permit Section File 

Nash, ille Environmental Field Office (M il.:eThomIOrli8:m.gov) 

'-h Connie A. Kagey, NPDES Permit Section, ErA Region IV. Kagey.Connie@epamail.epn.go\' 

Mr. lhomas H Green. Jr. P.E. Senior Project Manager, ErtSafc Inc.. tgreen@;en~afe.eom

Craig Jetson. General Manager. .1'0 HO.\ llfH. CI~r~,,\ illc. TN 37040 

STATE OF TENNESSEE
 

NPDES PERMIT 

~~ MODIFIED
 

No. TN0029157
 

Authorization to discharge under the
 

National Pollutant Discharge Elimination System (NPDES)
 

Issued By
 

Tennessee Department of Environment and Conservation
 

Division of Water Pollution Control
 

401 Church Street
 

6th Floor, L & C Annex
 

Nashville, Tennessee 37243-1534
 

Under authority of the Tennessee Water Quality Control Act of 1977 (T.e.A. 69-3-101 et seq.) and the 

delegation of authority from the United States Environmental Protection Agency under the Federal Water 

Pollution Control Act, as amended by the Clean Water Act at 1977 (33 U.SC 1251, et seq.) 

Discharger:	 Nyrstar Clarksville, Inc. 

is authorized to discharge:	 treated process water, sanitary wastewater, stormwater and cooling water 

through Outfall 001, demineralized regeneration water, water plant 

overflow and filter backwash through Outfall 002, stormwater runoff and 

cooling water through Outtalls SW3 and SW4 and stormwater runoff 

though Oulfalls SW5 and SW6 

from a facility located:	 in Clarksville, Montgomery County, Tennessee 

\0 receiving waters named:	 Cumberland River at mile 122 (Outfall 001), unnamed tributary to 

Cumberland River at mile 122.6 (Outfall 002), unnamed tributary to the 

Cumberland River at mile 121.1 (Oulfalls SW3 & SW5) and unnamed 

tributary to the Cumberland River at mile 122.6 (Oulfall SW4 & SW6) 

in accordance with effluent limitations, monitoring requirements and other conditions set forth herein. 

This permit shall become effective on: January 1, 2012 

This permit shall expire on: November 30,2015 

Issuance date: November 30, 2011 

Pau E Davis, Director 

Divi . n of Water Pollution Control 

CN-07S9 ROAs 2352 and 2366 
(This pagelettblankintelllionally) 
TABLE OF CONTENTS
 

Page 

PART I 1
 

A. EFFLUENT LIMITAllONS AND MONITORING REQUIREMENTS 1
 

B. MONITORING PROCEDURES 5
 

1. Represenlalive Sampling . _. .5
 

2. Sampling Frequency. ,............ . 5
 

3. Test Procedures .. 5
 

4. Recording of Results. ..,.." , 6
 

5. Records Retention 6
 

C. DEFINITIONS 6
 

D. ACRONYMS AND ABBREVIATIONS 9
 

E. REPORTING 10
 

1. Monitoring Results .. . 10
 

2. Additional Manitoring by Permittee.. " 11
 

3. Falsifying Results and/or Reports . 11
 

4. Outlier Data . , ,.. ..,..,........ .. 11
 

F. SCHEDULE OFCOMPLIANCE 11
 

PART II 12
 

A. GENERAL PROVISIONS ,., ,.•, 12
 

1. Duty to Reapply................ " 12
 

2. Right of Enrry " ,........... . 12
 

3. Availability of Reports " ,... ., , ,... .. . 12
 

4. Proper Operotion and Maintenance _ 12
 

5. Treatment Facility Failure......... .. ,.... 13
 

6. Property Righls 13
 

7. Severability............................ .. , ,........................................ 13
 

B. Other Information. 13
 

B. CHANGES AFFECTING THE PERMIT ,.,., 13
 

1. Planned Changes . 13
 

2. Permit Modificatian, Revocatian, or termtnatton.. ' ,..................................................... ...13
 

3. Change of Ownership............. , , 14
 

4. Change of MoilingAddress....................... . 15
 

C. NONCOMPLIANCE 15
 

1. Effect of Noncompliance .. 15
 

2. Reporting of Noncomononce.. . .. . 15
 

3, Sanitary Sewer Overflow....... . 16
 

4. Upset.... .. 16
 

5. Adverse Impoct....... 17
 

6. Bypass. . 17
 

7. Washout . .. 18
 

D.lIABILITIES 18
 

1. Civil onaCriminol Liability........ .. 18
 

2. Liability Under Stale [ow " , , , 18
 

PART III , , 19
 

A. TOXIC POLLUTANTS 19
 

B. REOPENER CLAUSE 19
 

C. PLACEMENT OFSiGNS 20
 
D. ANTIDEGRADATION 21
 

E. WASTEWATER TREATMENT FACILITIES INTEGRITY EVALUATION 21
 

F. PRIORITY POLLUTANTS , 21
 

G .CERTIFIED OPERATOR , ,.., , ,•••,.. 21
 

PART IV - BEST MANAGEMENT PRACTICES (BMP) PLAN 22
 

A, BMP GENERAL CONDITIONS ,., 22
 

B. BMP GENERAL REQUIREMENTS 22
 

C. BMP DOCUMENTATiON , , , 24
 

D. BMP PLAN MODIFICATION 24
 

E. BMP MODifiCATION FOR INEFFECTiVENESS 24
 

F. BMP COMPLIANCE SCHEDULE 26
 

PART V -STORMWATER POLLUTION PREVENTION PLAN (SWPPP) , 2S 

A. POLLUTANT SOURCES AND PATHWAyS 2S 

B. STORMWATER CONTROLS , 2S 

C. FACILITY INSPECTION 26
 

D. SPILL PREVENTION CONTROL AND COUNTERMEASURES ,.,.,., 26
 

E. PLANREVIEW UPDATE 26
 

F. PLANIMPLEMENTATION , 26
 

G. PLAN AVAILABILITY ,.,•••••, , , 27
 

H. PLAN MODIFICATION 27
 

I. MONITORINGPLAN ,•••••, 27
 

J. SARAmLE III, SECTION 313, PRIORITY CHEMICALS 27
 

K. SUPPLEMENTALSTORMWATER POLLUTION PREVENTION PLAN ISWPPP) REQUIREMENTS 29
 

ADDENDUM TO RATiONALE •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••AD-l
 

RATIONALE
 

R2, CURRENT PERMrr STATUS , ,., ,••• R-l
 

APPENDICES
 

ATIACHMENT 1 - WASTEWATER TREATMENT FACIUTY INTEGRITY EVALUATION 30
 

ATIACHMENT 2 - CHRONIC BIOMONrrORING IC2S TESTING PROCEDURE 31
 

ATIACHMENT 3 -SUPPLEMENTALSTORMWATER POLLUTION PREVENTION PLAN (SWPPP) REQUiREMENTS.•... 33
 

RI. D'SCHARGER ,., R-l
 

R3. PERMIT RENEWAL CONSiDERATIONS , ,•..•.......•.•....••••••• R·2
 

R4. PERMITIEE'S OUTfALLS, TREATMENT SYSTEMS ,AND RECEIVING STREAMS R·2
 

RS. CURRENT PERMIT LIMITSAND MONITORINGREQUIREMENTS R-3
 

R6. DiSCHARGE MONITORINGREPORT (DMRI AND INSPECTION RESULTS - R-3
 

R7. TECHNOLOGY BASED EfFLUENT LIMITATIONS R-3
 

RS. WATER QUALITYCONSIDERATIONS R-4
 

R9. NEW PERMIT UMITATIONSAND MONITORING REQUiREMENTS ,R-4
 

RIO.ANTIDEGRADATION CONSiDERATIONS ,R-9
 

Rl1. BMP AND SWPPP REQUIREMENTS ,R-1D
 

R12. WASTEWATER TREATMENT SYSTEM INTfGRrTYEVALUATION R·l0
 

R13.PERMIT DURATION , R·ll
 

R-l. PERMITIEE'S DISCHARGES, TREATMENT SYSTEMS, AND RECEIVING STREAMS R-12
 

R-2. CURRENT PERMIT LIMITSAND MONITORINGREQUIREMENTS R-1S
 

R-3. DISCHARGE MONITORING REPORT(DMR) RESULTS R-17
 

R-4. APPLICABLE EFflUENT UMITATIONSGUIDEUNES R-21
 

R-S. WATER QUALITY CONSIDERATIONS R-24
 

R-6. NEW PERMIT LIMITSAND MONITORINGREQUiREMENTS R-34
 

GMDa 

TNClQ2Q157 [)(X'; 
Nyrstar Clarksville, Inc. 

NPDES Permit TN00291 57 

Page 1 

PART I 

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 

Nyrstar Clarksville, Inc. is authorized to discharge treated process water, sanitary 

wastewater, stormwater and cooling water through Outfall 001, demineralized regeneration 

water. water plant overflow and filter backwash through Outfall 002, stormwater runoff and 

cooling water through Outtalls SW3 and SW4 and stormwater runoff though Outtalls SW5 and 

SW6 to Cumberland River at mile 122 (Outfall 001), unnamed tributary to Cumberland River at 

mile 122.6 (Outtall 002), unnamed tributary to the Cumberland River at mile 121.1 (Outlalls 

SW3 & SW5) and unnamed tributary to the Cumberland River at mile 122.6 (Outtalls SW4 & 

SW6). 

These discharges shall be limited and monitored by the permittee as specified below: 

Description: External Outfall, Number: 001, Monitoring: Effluenl Gross, Season: All Year 

Parameter Qualifier Value .Y.!ll! Sample Type Frequency Statistical Base 

Arsenic, total (as As) <=; 34.45 Ibid Composite Semiannual Daily Maximum 

Arsenic, totat (as As) <= 17.12 Ibid Composite Semiannual Monthly 

Average 

Cadmium. total (as 

Cd) 2.28 Ibid Composite Twice Per Month Monthly Average 

Cadmium, total (as 

Cd) 5.29 Ibid Composite Twice Per Month Daily Maximum 

Chloride Report Ibid Composite Weekly Monlhiy 

Average 

Chloride Report Ibid Composite Weekly Daily Maximum 

Conductivity Report umho/cm Composite Weekly Daily Maximum 

Conductivity Report umhc'crn Composite Weekly Monthly 

Average 

Copper. total (as Cu) <= 33.87 Ibid Composite Quarter1y Daily Maximum 

Copper. lotal (as Cu) <=; 17.43 Ibid Composite Quarterly Monthly 

Average 

Flow Report Mgalld Recorder Continuous Daily Maximum 

Flow Report Mgal/d Recorder Continuous Monthly 

Average 

Fluoride Report Ibid Composite Monthly Daily Maximum 

Fluoride Report Ibid Composite Monthly Montnly 

Average 

Lead, total (as Pb) <=; 7.41 Ibid Composite Quarterly Daily Maximum 

Lead, tota' (as Pb) <=; 3.72 Ibid Composite Quarterly Monthly 

Average 

Selenium, toter (as Se) <=; 216 Ibid Composite Semiannual Daily Maximum 

Selenium, toter (as Se) <'" 24.9 Ibid Composite Semiannual Monthly 

Average 

Total Suspended <=; 4,555 Ibid Composite Once Every 2 Daily Maximum 
- -- ----

Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 2 

Description: External Outfall, Number: 001, Monitoring: Effluent Gross, Season: All Year . .. 

Parameter QU811fler :tIllLl Sample Tvpe Freauency Statistical Base . _~------~. -----­

l!!!!l 

Solids (TSSl Months
 

Total Suspended Once Every 2 Monthly
 <= 2,459 Ibid Composite Solids (TSSl Months Average 

Zinc, total (as Zn) <= 27.0 Ibid Composite Weekly Daily Maximum 

Monthly Zinc, total (as Zn) <= 12.0 Ibid Composite Weekly Average
 

pH >= 6.0 5U Grab (al Weekly Minimum
 

pH <= 9.0 5U Grab (a) Weekly Maximum
 

(a) pH analyses shall be performed within fifteen (15) minutes of sample collection. 

Description: Internal Outfall, Number: 01A, Monitoring: Effluent Gross, Season: All Year -~-_. ---­ ---------_.-.. Parameter Qualifier .. lI!Li1 Sample Type Frequency Statistical Base 

Chloride Report IbId Grab Weekly Daily Maximum 

Chloride Report IbId Grab Weekly Monthly Average 

Conductivity Report umholcm Grab Weekly Monthly Average 

Conductivity Report umholcm Grab Weekly Daily Maximum 

Flow Report Mgal/d Recorder Continuous Daily Maximum 

Flow Report Mgal/d Recorder Continuous Monthly Average 

Fluoride Report IbId Grab Weekly Daily Maximum 

Fluoride Report IbId Grab Weekly Monthly Average 

Total Suspended Solids 

(T55) Report Ibid Grab Weekly Daily Maximum 

Total Suspended Solids 

(T55) Report IbId Grab Weekly Monthly Average 

pH Report 5U Grab (a) Weekly Daily Maximum 

pH Report SU Grab (a) Weekly Monthly Average 

(a) pH analyses shall be performed within fjfteen (15) minutes of sample collection. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 3 

Description; External Outfall, Number: 002, Monitoring: Effluent Gross, Season: All Year 

Statistical Parameter Qualifier Sample Type Frequency Base 

Chlorine, total residual Daily <= 0.019 mg/L Grab (a) Weekly (TRC) Maximum 

Monthly Flow Report Mgalld Recorder Continuous Average 

Daily Flow Report Mgalld Recorder Conlinuous Maximum 

Daily Settleable Solids <= 0.5 mUL Grab Weekly Maximum
 

Total Suspended Solids Daily
 <= 40 mg/L Grab Weekly (TSS) Maximum
 

pH >= 6.0 SU Grab (b) Weekly Minimum
 

pH <= 90 SU Grab (b) Weekly Maximum
 

(a) The acceptable methods for analysis 01 TRC are any methods specified in Title 40 CFR, Part 136 as amended. 

The method detection level (MDL) for TRC shall not exceed 0.05 mgll unless the permittee demonstrates that its 

MDL is higher. The permittee shall retain the documentation that justifies the higher MDL and have it available for 

review upon request. In cases where the permit limit is less that the MDL, the reporting of TRG at less than the MDL 

shall be interpreted to consuune compliance with the permit limit. The compliance point for total residual chlorine is 

at the confluence orme discharge and the receiving stream. 

(b) pH and TRC analyses shall be performed within fifteen (15) minutes of sample collection. 

Numerical values shown below for the Outfall SW3, SW4 and SWS discharges are 

Benchmark/Cutoff Values and not effluent limitations. 

Description: External Outfall, Number: SW3, Monitoring: Effluent Gross, Season: All Year 

Parameter Qualifier Unit Sample Type Frequency Statistical Base

Cadmium. total (as <= 0.0159 mg/L Grab Quarterly Daily Maximum Gd)
 

Copper, total (as
 <= 0.0636 mg/L Grab Quarterly Daily Maximum Go) 

Flow Report Mgal/d Estimate Quarterly Monthly Average
 

Flow Report Mgalid Estimate Quarterly Daily Maximum
 

Lead. total (as Pb) <= 0.156 mg/L Grab Quarterly Daily Maximum
 

Total Suspended
 <= 150 mg/L Grab Quarterly Daily Maximum Solids (TSS)
 

Zinc. total (as Zn) <= 0.395 mg/L Grab Quarterly Daily Maximum
 

pH >= 5.0 SU Grab Quarterly Minimum
 

pH <= 9.0 SU Grab Quarterly Maximum
 
---

Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 4 

Description: External Outfall, Number: SW4, Monitoring: Effluent Gross. Season: All Year -~-----_...__.._.- ---~._--_._._._ ,,_. 

Parameter Qualifier _yalue YDl! Sample TyRe Frequency Statistical Base

Cadmium, total (as <= 0.0159 mgIL Grab Ouarter1y Daily Maximum
 

Cd)
 

Copper, total (as <= 0.0636 mgIL Grab Ouartenv Daily Maximum 

Co)
 

Flow Report Mgal/d Estimate Quarterly Monthly Average
 

Flow	 Report Mgal/d Estimate Quarterly Daily Mallimum 

Lead, total (as Pb} <= 0.156 mg/L Grab Quarterly Daily Maximum
 

Total Suspended
 <= '50 mgIL Grab Quarterly Daily Maximum Solids (T55)
 

Zinc, total (as Zn) <= 0.395 mgIL Grab Quarterly Daily Maximum
 

pH >= 5.0 SU Grab Quarterly Minimum
 

pH <= 9.0 SU Grab Quarterly Maximum
 

Description: External Outfall, Number: SW5, Monitoring: effluent Gross, Season: All Year .~~~~~-~.~- --_._-~~~-

Parameter Qua!ifjer y!!!!!. _Unit Sample Type Freauency Statistical Base 

Cadmium, total (as <= 0.0159 mg/L Grab Quarterly Daily Maximum Cd) 

Copper, total (as <= 0.0636 mgIL Grab Quarterly Daily Maximum Co) 

Flow Report Mgalld Estimate Quarterly Monlhly Average
 

Flow Report Mgalld Estimate Quarterly Daily Maximum
 

Lead, total (as Pb) <= 0.156 mg/L Grab Quarterly Daily Maximum
 

Tolal Suspended <= '50 mg/L Grab Quarterly Daily Maximum Solids (T55)
 

Zinc, total (as Zn) <= 0.395 mg/L Grab Quarterly Daily Maximum
 

pH >= 5.0 SU Grab Quarterly Minimum
 

pH <. 9.0 SU Grab Quarterly Maximum
 

The following criteria must be used for monitoring the Outfall SW3, SW4 and SW5 discharges: 

a) pH analyses shall be pertormed within fifteen (15) minutes of sample collection. 

b) The permittee must comply with the permit's Part V.K. requirements. 

Additional monitoring requirements and conditions applicable to the permittee's 

discharges include: 

•	 There shall be no distinctly visible floaling solids, scum, foam, oily slick, or the 

formation of slimes, bottom deposits or sludge banks of such size or character 

that may be detrimental to fish and aquatic life. 
Nyrstar Clarksville, Inc. 

NPDES PermitTN0029157 

Page 5 

•	 The wastewater discharge shall not contain pollutants in quantities that will be 

hazardous or otherwise detrimental to humans, livestock, wildlife, plant life, or 

fish and aquatic life in the receiving stream. 

Sludge or any other material removed by any treatment works must be disposed of in a 

manner, which prevents its entrance into or pollution of any surface or subsurface waters. 

Additionally. the disposal of such sludge or other material must be in compliance with the 

Tennessee Solid Waste Disposal Act, TCA 68-31-101 et sea. and the Tennessee Hazardous 

Waste Management Act, TCA 68-46-101 et seg. 

B,	 MONITORING PROCEDURES 

1.	 Representative Sampling 

Samples and measurements taken in compliance with the monitoring requirements 

specified herein shall be representative of the volume and nature of the monitored discharge, 

and shall be taken after treatment and prior to mixing with uncontaminated stormwater runoff or 

the receiving stream. 

2.	 Sampling Frequency 

The permittee should mark the 'No Discharge' box on the Discharge Monitoring Report 

form only if a permitted outfall does not discharge at any time during the monitoring period. If 

the outfall discharges effluent at any time durinq the monitoring period, the permittee must 

provide at least one sampling result from the effluent of that outfall. 

3.	 Test Procedures 

Where the permit requires sampling and monitoring of a particular effluent 

characterislic(s) at a frequency of less than once per day or daily, the permittee is precluded 

from marking the "No Discharge" block on the Discharge Monitoring Report if there has been 

any discharge from that particular outfall during the period which coincides with the required 

monitoring frequency, i.e, if the required monitoring frequency is once per month or t/rnonth, 

the monitoring period is one rnonlh, and if the discharge occurs during only one day in that 

period then the permittee must sample on that day and report the results of analyses 

accordingly. 

a.	 Test procedures for the analysis of pollutants shall conform to regulations 

published pursuant 10 Section 304 (h) of the Clean Water Act (the "Act"), as 

amended, under which such procedures may be required. 

b.	 Unless otherwise noted in the permit. all pollutant parameters shall be 

determined according to methods prescribed in Title 40, CFR Part 136, as 

amended, promulgated pursuant to Section 304 (h) of the Act. 

In instances where permit limits established through implementation of applicable water 

criteria are below analytical capabilities. compliance with those limits will be determined using 

the detection limits described in the TN Rules, Chapter 1200-4-3-.05(8). 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 6 

4. Recording of Results 

For each measurement or sample taken pursuant to the requirements of this permit, the 

permittee shall record the following information: 

a. The exact place, date and time of sampling; 

b. The exacl person(s) collecting samples; 

c. The dates and times the analyses were performed; 

d. The person(s) or laboratory who performed the analyses; 

e. The analytical techniques or methods used, and; 

f. The results of all required analyses. 

5. Records Retention 

All records and information resulting from the monitoring activities required by this 

permit including all records of analyses performed and calibration and maintenance of 

instrumentation shall be retained for a minimum of three (3) years, or longer, if requested by the 

Division of Water Pollution Control. 

c. DEFINITIONS 

For the purpose of this permit, Annually is defined as a monitoring frequency of once 

every twelve (12) months beginning with the date of issuance of this permit so long as the 

following set of measurements for a given 12 month period are made approximately 12 months 

subsequent to that time. 

A bypass is defined as the intentional diversion of waste streams from any portion of a 

treatment facility. 

A calendar day is defined as the 24-hour period from midnight to midnight or any other 

24-hour period that reasonably approximates the midnight to midnight time period. 

For the purposes of this permit, a Composite Sample for non-stormwater discharges is 

a composite sample of at least 24 grab samples collected at regular intervals over a period of 

24·hours. 

The Daily Maximum Amount, is a limitation measured in pounds per day (Ib/day), on 

the total amount of any pollutant in the discharge by weight during any calendar day. 

The Dally Maximum Concentration is a limitation on the average concentration, in 

milligrams per liter (mg/L), of the discharge during any calendar day. When a proportional-toflow composite sampling device is used, the daily concentration is the concentration of that 24· 

hour composite; when other sampling means are used, the daily concentration is the arithmetic 

mean of the concentrations of equal volume samples collected during any calendar day or 

sampling period. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 7 

Degradation means the alteration of the properties of waters by the addition of 

pollutants or removal of habitat. 

De Minimis - Alterations, other than Ihose resulting in the condition of pollution or new 

domestic wastewater discharges, that represent either a small magnitude or a short duration 

shall be considered a de minimis impact and will not be considered degradation for purposes of 

implementing the antidegradation policy. Discharges other than domestic wastewater will be 

considered de minimis if they are temporary or use less than five percent of the available 

assimilative capacity for the substance being discharged. If more than one activity has been 

authorized in a segment and the total of the impacts uses no more than ten percent of the 

assimilative capacity, available habitat, or 7010 low flow, they are presumed to be de minimis. 

Where total impacts use more than ten percent of the assimilative capacity, available habitat, or 

7010 low flow they may be treated as de minimis provided that the division finds on a scientific 

basis that the additional degradation has an insignificant effect on the resource and that no 

single activity is allowed to consume more than five percent of the assimilative capacity, 

available habitat or 7010 low flow. 

Discharge or "discharge of a pollutant" refers to the addition of pollutants to waters from 

a source. 

Dry Weather Flow shall be construed to represent discharges consisting of process 

and/or non-process wastewater only. 

An ecoregion is a relatively homogeneous area defined by similarity of climate, 

landform, soil, potential natural vegetation, hydrology, or other ecologically relevant variables. 

The geometric mean of any set of values is the nih root of the product of the individual 

values where "n" is equal 10 the number of individual values. The geometric mean is equivalent 

to the antilog of the arithmetic mean of the logarithms of the individual values. For the 

purposes of calculating the geometric mean, values of zero (0) shall be considered to be one 

(1 ). 

A Grab Sample, for the purposes of this permit, is defined as a single effluent sample of 

at least 100 milliliters (sample volumes <100 milliliters are allowed when specified per standard 

methods, latesl edition) collected at a randomly selected time over a period not exceeding 15 

minutes. The sample(s) shall be collected at the period(s) most representative of the total 

discharge. 

The Instantaneous Concentration is a limitation on the concentration, in milligrams per 

liter (mg/L), of any pollutant contained in the discharge determined from a grab sample taken at 

any point in time. 

The monthly average amount, shall be determined by the summation of all the 

measured daily discharges by weight divided by the number of days during the calendar month 

when the measurements were made. 

The monthly average concentration, other than for E. coli bacteria, is the arithmetic 

mean of all the composite or grab samples collected in a one-calendar month period. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 8 

A one week period (or calendar-wee", is defined as the period from Sunday through 

Saturday. For reporting purposes, a calendar week that contains a change of month shall be 

considered part of the latter month. 

Pollutant means sewage, industrial wastes, or other wastes. 

A Qualifying Storm Event is one which is greater than 0.1 inches and that occurs after 

a period of at least 72 hours after any previous storm event with rainfall of 0.1 inches or greater. 

For the purpose of this permit, a Quarter is defined as anyone of the following three 

month periods: January 1 through March 31, April 1 through June 3D, July 1 through 

September 3D, or October 1 through December 31. 

A rainfall event is defined as any occurrence of rain, preceded by 10 hours without 

precipitation that results in an accumulation of 0.01 inches or more. Instances of rainfall 

occurring within 10 hours of each other will be considered a single rainfall event. 

A rationale (or "fact sheet") is a document that is prepared when drafting an NPDES 

permit or permit action. It provides the technical, regulatory and administrative basis for an 

agency's permit decision. 

A reference site means least impacted waters within an ecoreqion that have been 

monitored to establish a baseline to which alterations of other waters can be compared. 

A reference condition is a parameter-specific set of data from regional reference sites 

that establish the statistical range of values for that particular substance at least-impacted 

streams. 

For the purpose ot this permit, Semi-annually means the same as "once every six 

months." Measurements of the eftluent characteristics concentrations may be made anytime 

during a 6 month period beginning from the issuance date of this permit so long as the second 

set of measurements for a given 12 month period are made approximately 6 months 

subsequent to that time, if feasible. 

A subecoregion is a smaller, more homogenous area that has been delineated within 

an ecoregion. 

Upset means an exceptional incident in which there is unintentional and temporary 

noncompliance with technology-based effluent limitations because of factors beyond the 

reasonable control of the permittee. An upset does not include noncompliance to the extent 

caused by operational error, improperly designed treatment facilities, inadequate treatment 

facilities, lack ot preventive maintenance, or careless or improper operation. 

The term, washout is applicable to activated sludge plants and is defined as loss of 

mixed liquor suspended solids (MLSS) of 30.00% or more from the aeration basin(s). 

Waters means any and all water, public or private, on or beneath the surface of the 

ground, which are contained within, flow through, or border upon Tennessee or any portion 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 9 

thereof except those bodies of water confined to and retained within the limits of private 

property in sIngle ownership which do not combine or eHect a junction with natural surface or 

underground waters. 

The weekly average amount, shall be determined by the summation of all the 

measured daily discharges by weight divided by the number of days during the calendar week 

when the measurements were made. 

The weekly average concentration, is the arithmetic mean of all the composite 

samples collected in a one-week period. The permittee must report the highest weekly average 

in the one-month period. 

Wet Weather Flow shall be construed 10 represent stormwater runoff which, in 

combination with all process and/or non-process wastewater discharges, as applicable, is 

discharged during a qualifying storm event. 

D. ACRONYMS AND ABBREVIATIONS 

1010 -1-day minimum, 10-year recurrence interval
 

3005 - 30-day minimum, 5-year recurrence interval
 

7010 -7-day minimum, 10-year recurrence interval
 

BAT - best available technology economically achievable
 

BCT - best conventional pollutant control technology
 

BOL - below detection level
 

B005 - five day biochemical oxygen demand
 

BPT - best practicable control technology currently available
 

CB005 - five day carbonaceous biochemical oxygen demand
 

CEI - compliance evaluation inspection
 

CFR - code of federal regulations
 

CFS - cubic feet per second
 

CFU - colony forming units
 

CIU - categorical industrial user
 

CSO - combined sewer overflow
 

DMR - discharge monitoring report
 

D.O. - dissolved oxygen 

E. coli - Escherichia coli 

EFO - environmental field office 

LB (Ib) - pound 

IC?5 - inhibition concentration causing 25% reduction in survival, reproduction and 

growth of the test organisms 

IU - industrial user 

IWS - industrial waste survey 

LC50- acute test causing 50%, lethality 

MDL - method detection level 

MGD - million gallons per day 

MG/L(mg/l) - milligrams per liter 

ML - minimum level of quantification 

ml - milliliter 
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NPDES Permit TN0029157 

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MLSS - mixed liquor suspended solids
 

MOR - monthly operating report
 

NODI - no discharge
 

NOEC - no observed effect concentration
 

NPDES - national pollutant discharge elimination system
 

PL - permit limit
 

POlW - publicly owned treatment works
 

RDL - required detection limit
 

SAR - semi-annual [pretreatment program) report
 

SIU - significant industrial user
 

SSO - sanitary sewer overflow
 

STP - sewage treatment plant
 

TCA - Tennessee code annotated
 

TDEC - Tennessee Department of Environment and Conservation
 

TIEfTRE - toxicity identification evaluationltoxicity reduction evaluation
 

TMDL - total maximum daily load
 

TRC - total residual chlorine
 

TSS - total suspended solids
 

WQBEL - water quality based effluent limit
 

E. REPORTING 

1. Monitoring Results 

Monitoring results shall be recorded monthly and submitted monthly using Discharge 

Monitoring Report (DMR) forms supplied by the Division of Water Pollution ControL Submittals 

shall be postmarked no later than 15 days atter the completion of the reporting period. A 

completed DMR with an original signature shall be submitted to the following address: 

TENNESSEE DEPT. OF ENVIRONMENT & CONSERVATION
 

DIVISION OF WATER POLLUTION CONTROL
 

ENFORCEMENT & COMPLIANCE SECTION
 

L & C ANNEX 6TH FLOOR
 

401 CHURCH STREET
 

NASHVILLE TN 37243
 

A copy should be retained for the permittee's tiles. In addition, any communication 

regarding compliance with the conditions of this permit must be sent to the two offices listed 

above. 

The first DMR is due on the 15th of the month following permit effectiveness. 

DMRs and any other information or report must be signed and certified by a responsible 

corporate officer as defined in 40 CFR 122.22, a general partner or proprietor, or a principal 

municipal executive officer or ranking elected official, or his duly authorized representative. 

Such authorization must be submitted in writing and must explain the duties and responsibilities 

01 the authorized representative. 

The electronic submission of DMR data will be accepted only it formally approved 

beforehand by the division. For purposes of determining compliance with this permit, data 
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NPDES Permit TN0029157 

Page 11 

approved by the division to be submitted electronically is legally equivalent to data submitted on 

signed and certified DMR forms. The permittee's electronic DMR submittal must also include 

as an attachment its Monthly Operating Report (MOR). 

2. Additional Monitoring by Permittee 

If the permittee monitors any pollutant specifically limited by this permit more frequently 

than required at the location(s) designated, using approved analytical methods as specified 

herein, the results of such monitoring shall be included in the calculation and reporting of the 

values required in the DMR form. Such increased frequency shall also be indicated on the form. 

3. Falsifying Results and/or Reports 

Knowinqly making any false statement on any report required by this permit or falsifying 

any result may result in the imposition of criminal penalties as provided for in Section 309 of the 

Federal Water Pollution Control Act, as amended, and in Section 69-3-115 of the Tennessee 

Water Quality Control Act. 

4. Outlier Data 

Outlier data include analytical results that are probably false. The validity of results is 

based on operational knowledge and a properly implemented quality assurance program. False 

results may include laboratory artifacts, potential sample lampering, broken or suspect sample 

containers, sample contamination or similar demonstrated quality control flaw. 

Outlier data are identified through a property implemented quality assurance program, 

and according to ASTM standards (e.g. Grubbs Test, 'h' and 'k' statistics). Furthermore, outliers 

should be verified, corrected, or removed, based on further inquiries into the matter. If an outlier 

was verified (through repeated testing and/or analysis), it should remain in the preliminary data 

set. If an outlier resulted from a transcription or similar clerical error, it should be corrected and 

subsequently reported. 

Therefore. only if an outlier was associated with problems in the collection or analysis of 

the samples and as such does not conform with the Guidelines Establishing Test Procedures 

for the Analysis of Pollutants (40 CFR §136), il Can be removed from the data set and not 

reported on the Discharge Monitoring Report forms (DMRs). Otherwise, all results (including 

monitoring of pollutants more frequently than required at the location(s) designated, using 

approved analytical methods as specified in the permit) should be included in the calculation 

and reporting of the values required in the DMR form. You are encouraged to use "comment" 

section of the DMR form (or attach additional pages), in order to explain any potential outliers or 

dubious results. 

F. SCHEDULE OF COMPLIANCE 

Full compliance and operational levels shall be attained from the effective date of this 

permit. 
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NPDES Permit TN0029157 

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PART II 

A.	 GENERAL PROVISIONS 

1.	 Duty 10 Reapply 

Permittee is not authorized to discharge atter the expiration date 01 this permit. In order 

to receive authorization to discharge beyond the expiration date, the permittee shall submit 

such information and forms as are required to the Director of Water Pollution Control (the 

"Director") no later than 180 days prior to the expiration date. Such applications must be 

properly signed and certified. 

2.	 Right 01Enlry 

The permittee shall allow the Director, the Regional Administrator of the U.S. 

Environmental Protection Agency, or their authorized representatives, upon the presentation of 

credentials: 

a.	 To enter upon the permittee's premises where an effluent source is located or 

where records are required to be kept under the terms and conditions of this 

permit, and at reasonable times to copy these records; 

b.	 To inspect at reasonable times any monitoring equipment or method or any 

collection, treatment, pollution management, or discharge facilities required 

under this permit; and 

c.	 To sample at reasonable times any discharge of pollutants. 

3.	 Availability 01 Reports 

Except 10r data determined to be confidential under Section 308 of the Federal Water 

Pollution Control Act, as amended, all reports prepared in accordance with the terms of this 

permit shall be available for public inspection at the oHices of the Division of Water Pollution 

Control. As required by the Federal Act. eHluentdata shall not be considered confidential. 

4.	 Proper Operation and Maintenance 

a.	 The permrtlee shall at all times properly operate and maintain all facilities and 

systems (and related appurtenances) for collection and treatment which are 

installed or used by the permittee to achieve compliance with the terms and 

conditions of this permit. Proper operation and maintenance also includes 

adequate laboratory and process controls and appropriate quality assurance 

procedures. This provision requires the operation of backup or auxiliary facilities 

or similar systems, which are installed by a permittee only when the operation is 

necessary to achieve compliance with the conditions of the permit. Backup 

continuous pH and flow monitoring equipment are not required. 
Nyrstar Clarksville, Inc. 

NPDES PermitTN0029157 

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b.	 DIlution water shall not be added to comply with effluent requirements to achieve 

BCT, BPT, BAT and or other technoloqy-based effluent limitations such as those 

in State of Tennessee Rule 1200-4-5-.09. 

5.	 Treatment Facility Failure 

The permittee, in order to maintain compliance with this permit, shall control production, 

all discharges, or both, upon reduction, loss, or failure of the treatment facility, until the facility is 

restored or an alternative method of treatment is provided. This requirement applies in such 

situations as the reduction, loss, or failure of the primary source of power. 

6.	 Property Rights 

The issuance of this permit does not convey any property rights in either real or 

personal property. or any exclusive privileges, nor does it authorize any injury to private 

property or any invasion of personal rights, nor any infringement of Federal. State, or local laws 

or regulations. 

7.	 Severability 

The provisions of this permit are severable. If any provision of this permit due to any 

circumstance, is held invalid, then the application or such provision to other circumstances and 

to the remainder of this permit shall not be affected thereby. 

8.	 Other Information 

If the permitlee becomes aware that he failed to submit any relevant facts in a permit 

application, or submitted incorrect information in a permit application or in any report to the 

Director, then he shall promptly submit such facts or information. 

B.	 CHANGES AFFECTING THE PERMIT 

1.	 Planned Changes 

The permittee shall give notice to the Director as soon as possible of any planned 

physical alterations or additions to the permitted facility. Notice is required only when: 

a.	 The alteration or addition to a permitted facility may meet one of the criteria for 

determining whether a facility is a new source in 40 CFR 122.29(b); or 

b.	 The alteration or addition could significantly change the nature or increase the 

quantity of pollutants discharged. This notification applies to pollutants which are 

subject neither to effluent limitations in the permit, nor to notification 

requirements under 40 CFR 122.42(a)(1). 

2.	 Permit Modification, Revocation, Or Termination 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

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a.	 This permit may be modified, revoked and reissued, or terminated for cause as 

described in 40 CFR 122.62 and 122.64, Federal Register, Volume 49, No. 1BB 

(Wednesday, September 26, 1964), as amended. 

b.	 The permittee shall furnish to the Director, within a reasonable time, any 

information which the Director may request to determine whether cause exists 

for modifying, revoking and reissuing, or terminating this permit, or to determine 

compliance with this permit. The permittee shall also furnish to the Director, upon 

request, copies of records required to be kept by this permit. 

c.	 If any applicable effluent standard or prohibition (including any schedule of 

compliance specified in such effluent standard or prohibition) is established for 

any toxic pollutant under Section 307(a) of the Federal Water Pollution Control 

Act, as amended, the Director shall modify or revoke and reissue the permit to 

conform to the prohibition or to the effluent standard, providing that the effluent 

standard is more stringent than the limitation in the permit on the toxic pollutant. 

The permittee shall comply with these effluent standards or prohibitions within 

the time provided in the regulations that establish these standards or 

prohibitions, even if the permit has not yet been modified or revoked and 

reissued to incorporate the requirement. 

d.	 The filing of a request by the permittee for a modification, revocation, 

reissuance, termination, or notification of planned changes or anticipated 

noncompliance does not halt any permit condition. 

3.	 Change 01 Ownership 

This permit may be transferred to another party (provided there are neither modifications 

to the facility or its operations, nor any other changes which might affect the permit limits and 

conditions contained in the permit) by the permittee if: 

a.	 The permittee notifies the Director of the proposed transfer at least 30 days in 

advance of the proposed transfer date; 

b.	 The notice includes a written agreement between the existing and new 

permittees containing a specified date for transfer of permit responsibility, 

coverage, and liability between them; and 

c.	 The Director, within 30 days, does not notify the current permittee and the new 

permittee of his intent to modify, revoke or reissue, or terminate the permit and 

to require that a new application be filed rather than agreeing to the transfer of 

the permit. 

Pursuant to the requirements of 40 CFR 122.61, concerning transfer of ownership, the 

permittee must provide the following information to the division in their formal notice of intent to 

transfer ownership: 1) the NPDES permit number of the subject permit; 2) the effective date of 

the proposed transfer; 3) the name and address of the transferor: 4) the name and address of 

the transferee; 5) the names of the responsible parties for both the transferor and transferee; 6) 

a statement that the transferee assumes responsibility for the subject NPDES permit; 7) a 

statement that the transferor relinquishes responsibility for the subject NPDES permit; 8) the 

signatures of the responsible parties for both the transferor and transferee pursuant to the 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 15 

requirements of 40 CFR 122.22(a), "Signatories to permit applications"; and, 9) a statement 

regarding any proposed modifications to the facility, its operations, or any other changes which 

might affect the permit limits and conditions contained in the permit. 

4.	 Change or Mailing Address 

The permittee shall promptly provide to the Director written notice of any change of 

mailing address. In the absence of such notice the original address of the permittee will be 

assumed to be correct. 

C.	 NONCOMPLIANCE 

1.	 Effect of Noncompliance 

All discharges shall be consistent with the terms and conditions of this permit. Any 

permit noncompliance constitutes a violation of applicable State and Federal laws and is 

grounds for enforcement action, permit termination, permit modification. or denial of permit 

reissuance. 

2.	 Reporting or Noncompliance 

a.	 24·Hour Reporting 

In the case of any noncompliance which could cause a threat to public drinking 

supplies, or any other discharge which could constitute a threat to human health or the 

environment, the required notice of non-compliance shall be provided to the Division of 

Waler Pollution Control in the appropriate regional Field Office within 24-hours from the 

time the permittee becomes aware of the circumstances. (The regional Field Office 

should be contacted for names and phone numbers of environmental response 

personnel). 

A written submission must be provided within five calendar days of the time the 

permittee becomes aware of the circumstances, unless this requirement is waived by 

the Director on a case-by-case basis. The permittee shall provide the Director with the 

following information: 

i.	 A description of the discharge and cause of noncompliance; 

II.	 The period of noncompliance, including exact dates and times or. jf not 

corrected, the anticipated time the noncompliance is expected to 

continue: and 

iii.	 The steps being taken to reduce, eliminate, and prevent recurrence of the 

noncomplying discharge. 

b.	 Scheduled Reporting 

For instances of noncompliance which are not reported under subparagraph 2.a. 

above, the permittee shall report the noncompliance on the Discharge Monitoring 

Report. The report shall contain all information concerning the steps taken, or planned, 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 16 

to reduce, eliminate, and prevent recurrence of the violation and the anticipated time the 

violation is expected to continue. 

3.	 Sanitary Sewer Overflow 

a.	 "Sanitary sewer Overl/ow" means the discharge to land or water of wastes 

from any portion of the collection, transmission, or treatment system other than 

through permitted outfalls. 

b.	 Sanitary Sewer Overllows are prohibited. 

c.	 The permittee shall operate the collection system so as to avoid sanitary sewer 

overllows. No new or additional flows shall be added upstream of any point in the 

collection system, which experiences chronic sanitary sewer overllows (greater 

than 5 events per year) or would otherwise overload any portion of the system. 

d.	 Unless there is specific enforcement action to the contrary, the permittee is 

relieved 01 this requirement after: 1) an authorized representative of the 

Commissioner of the Department of Environment and Conservation has 

approved an engineering report and construction plans and specifications 

prepared in accordance with accepted engineering practices for correction of the 

problem; 2) the correction work is underway: and 3) the cumulative, peak-design, 

flows potentially added from new connections and line extensions upstream of 

any chronic overllow point are less than or proportional to the amount of inflow 

and infiltration removal documented upstream of that point. The inflow and 

infiltration reduction must be measured by the permittee using practices that are 

customary in the environmental engineering field and reported in an attachment 

to a Monthly Operating Report submitted to the regional TDEC Field Office. The 

data measurement period shall be sufficient to account for seasonal rainfall 

patterns and seasonal groundwater table elevations. 

e.	 In the event that more than five (5) sanitary sewer overflows have occurred from 

a single point in the collection system for reasons that may not warrant the selfimposed moratorium or completion of the actions identified in this paragraph, the 

permittee may request a meeting with the Division of Water Pollution Control 

field office staff to petition for a waiver based on mitigating evidence. 

4.	 Upset 

a.	 "Upser means an exceptional incident in which there is unintentional and 

temporary noncompliance with technology-based effluent limitations because of 

factors beyond the reasonable control of the permittee. An upset does not 

include noncompliance to the extent caused by operational error, improperly 

designed treatment facilities, inadequate treatment facilities, lack of preventive 

maintenance, or careless or improper operation. 

b.	 An upset shall constitute an affirmative defense to an action brought for 

noncompliance with such technology-based permit effluent limitations if the 

permittee demonstrates, through properly signed, contemporaneous operating 

logs. or other relevant evidence that: 
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NPDES Permit TN0029157 

Page 17 

I.	 An upset occurred and that the permittee can identify the cause(s) 01 the 

upset; 

II.	 The permitted facility was at the time being operated in a prudent and 

workman-like manner and in compliance with proper operation and 

maintenance procedures; 

III.	 The permittee submitted information required under "Reporting of 

Noncompliance" within 24-hours of becoming aware of the upset (if this 

information is provided orally, a written submission must be provided 

within five days); and 

iv.	 The permittee complied with any remedial measures required under 

"Adverse Impact." 

5.	 Adverse Impact 

The permittee shall take all reasonable steps to minimize any adverse impact to the 

waters of Tennessee resulting from noncompliance with this permit, including such accelerated 

or additional monitoring as necessary to determine the nature and impact of the noncomplying 

discharge. It shall not be a defense for the permittee in an enforcement action that it would 

have been necessary to halt or reduce the permitted activity in order to maintain compliance 

with the conditions of this permit. 

6.	 Bypass 

a.	 "Bypass" is the intentional diversion of wastewater away from any portion of a 

treatment facility. "Severe property damage" means substantial physical damage 

to property, damage to the treatment facilities, which would cause them to 

become inoperable, or substantial and permanent loss of natural resources 

which can reasonably be expected to occur in the absence of a bypass. Severe 

property damage does not mean economic loss caused by delays in production. 

b.	 Bypasses are prohibited unless the following 3 conditions are met: 

i.	 The bypass is unavoidable to prevent loss of life, personal injury, or 

severe property damage: 

il.	 There are not feasible alternatives to bypass, such as the use of auxiliary 

treatment facilities, retention of untreated wastes, or maintenance during 

normal periods of equipment down-time. This condition is not satisfied if 

adequate back-up equipment should have been installed in the exercise 

of reasonable engineering judgment to prevent a bypass, which occurred 

during normal periods of equipment down-time or preventative 

maintenance; 

Ill.	 The permittee submits notice of an unanticipated bypass to the Division 

of Water Pollution Control in the appropriate environmental assistance 

center within 24-hours of becoming aware of the bypass (if this 

information is provided orally, a written submission must be provided 

within five days). When the need for the bypass is foreseeable, prior 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 18 

notification shall be submitted to the Director, if possible, at least 10 days 

before the date of the bypass. 

c.	 Bypasses not exceeding limitations are allowed only if the bypass is necessary 

for essential maintenance to assure efficient operation. All other bypasses are 

prohibited. Allowable bypasses not exceeding limitations are not subject to the 

reporting requirements of 6.b.iii, above. 

7.	 Washout 

a.	 For domestic wastewater plants only, a 'washout' shall be defined as loss of 

Mixed Uquor Suspended Solids (MLSS) of 30.00% or more. This refers to the 

MLSS in the aeration basin(s) only. This does not include MLSS decrease due to 

solids wasting to the sludge disposal system. A washout can be caused by 

improper operation or from peak flows due to infiltration and inflow. 

b.	 A washout is prohibited. If a washout occurs the permittee must report the 

incident to the Division of Water Pollution Control in the appropriate regional 

Field Office within 24-hours by telephone. A written submission must be provided 

within 5 days. The washout must be noted on the discharge monitoring report. 

Each day of a washout is a separate violation. 

D.	 LIABILITIES 

1.	 Civil and Criminal Liability 

Except as provided in permit conditions for MBypassing,- "Overflow," and "Upset," 

nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties 

for noncompliance. Notwithstanding this permit, the permittee shall remain liable for any 

damages sustained by the State of Tennessee, including but not limited to fish kills and losses 

of aquatic life and/or wildlife, as a result of the discharge of wastewater to any surface or 

subsurface waters. Additionally, notwithstanding this Permit, it shall be the responsibility of the 

permittee to conduct its wastewater treatment and/or discharge activities in a manner such that 

public or private nuisances or health hazards will not be created. 

2.	 Liability Under Slale Law 

Nothing in this pennit shall be construed to preclude the institution of any legal action or 

relieve the permittee from any responsibilities, liabilities, or penalties established pursuant to 

any applicable State law or the Federal Water Pollution Control Act, as amended. 
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NPOES Permit TN0029157 

Page 19 

PART III 

OTHER REQUIREMENTS
 

A. TOXIC POLLUTANTS
 

The permittee shall notify the Division of Water Pollution Control as soon as it knows or 

has reason to believe: 

1.	 That any activity has occurred or will occur which would result in the discharge 

on a routine or frequent basis, of any toxic suostancets) (listed at 40 CFR 122, 

Appendix D, Table II and 111) which is not limited in the permit, if that discharge 

will exceed the highest of the following "notification levels": 

a.	 One hundred micrograms per liter (100 ugll); 

b.	 Two hundred micrograms per liter (200 ugll) for acrolein and acrylonitrile; 

five hundred micrograms per liter (500 ugll) for 2,4-dinrtrophenol and for 

2-methyl-4,6-dinitrophenol: and one milligram per liter (1 mg/L) for 

antimony; 

c.	 Five (5) times the maximum concentration value reported tor that 

pollutant(s) in the permit application in accordance with 122.21 (g)(7); or 

d.	 The level established by the Director in accordance with 122.44(f). 

2.	 That any activity has occurred or will occur which would result in any discharge, 

on a non-routine or infrequent basis, of a toxic pollutant which is not limited in the 

permit. if that discharge will exceed the highest of the following "notification 

levels": 

a.	 Five hundred micrograms per liter (500 ugll); 

b.	 One milligram per liter (1 mg/L) for antimony; 

c.	 Ten (10) times the maximum concentration value reported for that 

pollutant in the permit application In accordance with 122.21(g)(7); or 

d.	 The level established by the Director in accordance with 122.44(f). 

B.	 REOPENER CLAUSE 

If an applicable standard or limitation is promulgated under Sections 301(b)(2)(C) and 

(0), 304(6)(2), and 307(a)(2) and that effluent standard or limitation is more stringent than any 

effluent limitation in the permit or controls a pollutant not limited in the permit, the permit shall 

be promptly modified or revoked and reissued to conform to that effluent standard or limitation. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN00291 57 

Page 20 

If warranted to protect water quality, the division may reopen the permit for modification 

based on the washwater characteristics from the permittee's new Crude Zinc Oxide facility 

Form 2C submittal with IC25 test results. Also, permit modification may be warranted based on 

results from the permittee's wastewater treatment facilities integrity evaluation. Any permit 

modification will be subject to applicable public participation procedures. 

The permittee must notify the division if during the term of the permit the Outfall SW6 discharge 

becomes subject to stormwater runoff from active industrial activity, and the division may 

reopen the permit to add monitoring/BMP upgrade requirements pursuant to applicable 

benchmark/cutoff values. During the permit term, the permittee may request that the division 

reopen the permit to include revised benchmark/cutoff values that are specific to its operation 

given its unique on-site activities, based on justification information provided by the permittee. 

C. PLACEMENT OF SIGNS 

Within sixty (60) days of the effective date of this permit, the permittee shall place and 

maintain a sign(s) at each outfall and any bypass/ovetilow point in the collection system. For 

the purposes of this requirement, any bypass/ovetilow point that has discharged five (5) or 

more times in the last year must be so posted. The sign(s) should be clearly visible to the public 

from the bank and the receiving stream or from the nearest public property/right-of-way, if 

applicable. The minimum sign size should be two feet by two feet (2' x 2') with one inch (1") 

letters. The sign should be made of durable material and have a white background with black 

letters. 

The sign(s) are to provide notice to the public as to the nature of the discharge and, in 

the case of the permitted outfalls, that the discharge is regulated by the Tennessee Department 

of Environment and Conservation, Division of Water Pollution Control. The following is given as 

an example of the minimal amount of information that must be included on the sign: 

TREATED INDUSTRIAL WASTEWATER OUTFALL 001 

Nyrstar Clarksville, Inc. 

(Permittee's Phone Number) 

NPDES Permit NO. 1)10029157 

TENNESSEE DIVISION OF WATER POLLUTION CONTROL 

1-888-891-8332 ENVIRONMENTAL FIELD OFFICE - Nashville 

INDUSTRIAL WASTEWATER OUTFALL 002 

Nyrstar Clarksville, Inc. 

(Permittee's Phone Number) 

NPDES Permit NO. 1)10029157 

TENNESSEE DIVISION OF WATER POLLUTION CON11l0L 

1-888-891-8332 ENVIRONMENTAL FIELD OFFICE - Nashville 

INDUS11llAL NON-PROCESS WASTEWATER AND STORMWATER RUNOFF 

OUTFALLSW3 

Nyrstar Clarksville, Inc. 

(Permittee's Phone Number) 

NPDES Pennit NO. 1)10029157 

TENNESSEE DIVISION OF WATER POLLUTION CONTROL 

1-888-891-8332 ENVIRONMENTAL FIELD OFFICE - Nashville 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 21 

The same sign format as Outfall SW3 should be used lor Outfall SW4. 

INDUSTRIAL STORMWATER RUNOFF OUTFALL SW5 

Nyrstar Clarksville, Inc.
 

(Permittee's Phone Number)
 

NPDES Permit NO. TNOO29157
 

TENNESSEE DIVISION OF WATER POLLUTION CONTROL
 

1-888-891-8332 ENVIRONMENTAL FIELD OFFICE - Nashville
 

The same sign format as Outfall SW5 should be used lor Outfall SW6. 

D. ANTIDEGRADATION 

Pursuant to the Rules of the Tennessee Department of Environment and Conservation, 

Chapter 1200-4-3-.06, titled 'Tennessee Antidegradation Statement," and in consideration of 

the Department's directive in attaining the greatest degree of effluent reduction achievable in 

municipal, industrial, and other wastes, the permittee shall further be required, pursuant to Ihe 

terms and conditions of this permit, to comply with Ihe effluent limitations and schedules of 

compliance required to implement applicable water quality standards, to comply with a State 

Water Quality Plan or other State or Federal laws or regulations, or where practicable, to 

comply with a standard permitting no discharge of pollutants. 

E. WASTEWATER TREATMENT FACILITIES INTEGRITY EVALUATION 

The wastewater treatment facilities integrity evaluation permit requirements are 

presented in Attachment 1. 

F. PRIORITY POLLUTANTS 

Within two (2) years from the permit's effective date, the permittee shall submit to the 

division of Water Pollution Control a completed Application Form 2C - Wastewater Discharge 

Information, Consolidated Permits Program (EPA Form 3510-2C) for the washwater from Ihe 

permittee's recently constructed Crude Zinc Oxide facility. The submittal must also include the 

IC25 testing results, pursuant to the procedure presented in Attachment 2, 

G. CERTIFIED OPERATOR 

The wastewater treatment facilities shall be operated under the supervision of a 

wastewater system certified operator and the collection system operated under the supervision 

of a Collection System certified operator in accordance with the Water Environmental Health 

Act of 1984. 
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NPDES Permit TN0029157 

Page 22 

PART IV 

BEST MANAGEMENT PRACTICES CONDITIONS 

The permittee may consolidate the elements presented in Part IV (Best Management 

Practices Conditions) and Part V (Stormwater Pollution Prevention Plan) into a single 

BMP/SWPPP document as an overall control program for its facility. 

A.	 BMP GENERAL CONDITIONS 

For purposes of this part, the terms "pollutant" or "pollutants" refer to any substance 

listed as toxic under Section 307(a)(l) of the Clean Water Act, oil, as defined in Section 

311(a)(l) of the Act, and any substance listed as hazardous under Section 311 of the Act. The 

permittee shall develop and implement a Best Management Practices (BMP) plan which 

prevents, or minimizes the potential for, the release of pollutants (including oil and grease) from 

ancillary activities, including material storage areas; plant site runoff; in-plant transfer, process 

and material handling areas; loading and unloading operations, and sludge and waste disposal 

areas, to the waters of the State of Tennessee through plant site runoff; spillage or leaks; 

sludge or waste disposal; or drainage from raw material storage. 

B.	 BMP GENERAL REQUIREMENTS 

The BMP program shall: 

1.	 Be documented in narrative form, and shall include any necessary plot plans, 

drawings, or maps; 

2.	 Establish specific objectives for the control of toxic and hazardous pollutants: 

a.	 Each facility component or system shall be examined for its potential for 

causing a release of significant amounts of toxic or hazardous pollutants 

to waters of the State of Tennessee due to equipment failure, improper 

operation, natural phenomena such as rain or snowfall, etc.; 

b.	 Where experience indicates a reasonable potential for equipment failure 

(e.g., a tank overflow or leakage), natural condition (e.g., precipitation), or 

other circumstances to result in significant amounts of toxic or hazardous 

pollutants reaching surface waters, the plan should include a prediction of 

the direction, rate of flow, and total quantity of toxic or hazardous 

pollutants which could be discharged from the facility as a result of each 

condition or circumstance; 

3.	 Establish specific best management practices to meet the objectives identified 

under section B.2. contained herein, addressing each component or system 

capable of causing a release of significant amounts of toxic or hazardous 

pollutants to the waters of the State of Tennessee; 

4.	 The BMP program: 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 23 

a.	 May reflect requirements for Spill Prevention Control and 

Countermeasure (SPCC) plans under section 311 of the Act and Title 40 

CFR part 112, and may incorporate any part of such plans into the BMP 

program by reference; 

b.	 Shall assure the proper management of solid and hazardous waste in 

accordance with regulations promulgated under the Solid Waste Disposal 

Act, as amended by the Resource Conservation and Recovery Act of 

1976 (RCRA) (40 U.S.C. §6901, et. seg.). Management practices 

required under RCRA regulations shall be expressly incorporated inlo the 

BMP program; and, 

c.	 Shall address the following points for the ancillary activities listed in 

section A.l.: 

i.	 Statement of policy: 

Ii.	 Spill Control Committee: responsible for BMP program 

implementation and subsequent review and updating; 

iii.	 Material inventory: identification of all sources and quantities of toxic 

and hazardous substances handled or produced, including plant 

drawings and plot plans, materials flow diagrams, physical, chemical, 

toxicological, and health information on toxic and hazardous 

substances, and investigation and evaluation of new materials: 

iv.	 Material compatibility: evaluation of process changes or revisions for 

materials compatibility, review of properties of chemicals handled and 

materials of construction, evaluation of means of chemical disposal 

and incompatibility, cleansing of vessels and transfer lines, and use of 

proper coatings and cathodic protection on buried pipelines if 

required; 

v.	 Employee training: meetings to be held at frequent intervals, spill 

drills, adequate job training, transmission of information on past spills 

and causes, informing employees of BMP program components, 

training in cleanup procedures, and review and interface with safety 

program; 

vi.	 Reporting and notification procedures: maintenance of records of 

spills through formal reports for internal review, notification as 

required by law to governmental and environmental agencies in the 

event of a spill, and procedures for notifying the appropriate plant 

personnel; 

vii. Visual inspections:	 routine inspections with visual observations of 

storage facilities, transfer pipelines, and loading and unloading areas, 

detailed inspections of pipes, pumps, valves, fittings, tank corrosion, 

tank support and foundation deterioration, etc.; 

viii. Preventive maintenance:	 identification of equipment and systems to 

which the preventive maintenance program should apply, periodic 

inspection and testing of such equipment and systems, appropriate 

adjustment, repair, or replacement of parts, and maintenance of 

preventive maintenance records; 

ix. Good housekeeping:	 neat and orderly storage of chemicals, prompt 

removal of small spillage, regular garbage pickup, maintenance of dry 

and clean floors, proper pathways and walkways, minimum 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 24 

accumulation of liquid and solid chemicals on the ground or floor in a 

building, and stimulation of employee interest in good housekeeping; 

x.	 Security: plant patrols, fencing, good lighting, traffic control, 

controlled access where appropriate, visitor passes, locked 

entrances, locks on drain valves and pumps for chemical storage 

tanks, and television monitoring. 

Note: Additional technical information on BMPs and the elements of a BMP program is 

contained in EPA publications entitled "Guidance Manual for Developing Best Management 

Practices (BMP)" (EPA 833-B-93-004) and "Storrnwater Management for Industrial Activities: 

Developing Pollution Prevention Plans and Best Management Practices" (EPA 832-R-92-006). 

C.	 BMP DOCUMENTATION 

The permittee shall maintain the BMP plan at the facility and shall make the plan 

available to the permit issuing authority upon request. 

D.	 BMP PLAN MODIFICATION 

The permittee shall amend the BMP plan whenever there is a change in the facility or 

change in the operation of the facility, which materially increases the potential for the ancillary 

activities to result in a discharge of significant amounts of pollutants. 

E.	 BMP MODIFICATION FOR INEFFECTIVENESS 

If the BMP plan proves to be ineffective in achieving the general objective at preventing 

the release of significant amounts of pollutants to surface waters and the specific objectives 

and requirements under section B, the permit shall be subject to modification pursuant to 40 

CFR 122.62 or 122.63 to incorporate revised BMP requirements. Any such permit modification 

shall be SUbject to review in accordance with the procedures for permit appeals set forfh in 

accordance with 69·3-110, Tennessee Code Annotated. 

F.	 BMP COMPLIANCE SCHEDULE 

Unless the permittee is otherwtse authorized by the division in writing, the BMP Plan 

shall be completed as follows: 

1.	 The plan shall be developed and available for review within 90 days after permit's 

effective date. 

2.	 The permittee shall begin implementation of the BMP Plan as soon as possible, but not 

later than 120 days after permit coverage. Where new construction is necessary to 

implement the management plan, a construction schedule shall be included. 

Construction shall be completed as soon as possible. 

3.	 The permittee shall fully complete the approved BMP Plan, incluoinq all necessary 

construction, and be in full compliance with the Act, within six months fOllowing initial 

implementation of the Plan. 
Nyrstar Clarksville, Inc. 

NPOES Permit TN0029t57 

Page 25 

PART V 

STORMWATER POLLUTION PREVENTION PLAN (SWPPP) 

The permittee may consolidate the elements presented in Part IV Best Management 

Practices Conditions (BMP) and Part V Stormwater Pollution Prevention Plan (SWPPP) into a 

single BMP/SWPPP document as an overall control program for its facility. 

The permittee must develop, document and maintain a stormwater pollution prevention 

plan (SWPPP) pursuant to the requirements as set forth in the Tennessee Multi-Sector General 

Permit (TMSP) for Industrial Activities. The plan shall be signed by either a principal executive 

officer of a corporation, the owner or proprietor of a sale proprietorship, or a partner or general 

partner of a partnership. 

The SWPPP as developed and implemented shall be site specific to the permitted 

facility with regard to the general terms and conditions outlined in the TMSP and, at a minimum, 

shall contain the following items: 

A. POLLUTANT SOURCES AND PATHWAYS 

1. A site map outlining the individual stormwater drainage areas, existing structural control 

measures, surface water bodies, and sinkholes 

2. A narrative description of significant materials (40 CFR 122.26) that are currently or in 

the past have been treated, stored, or disposed outside; materials management practices; 

existing structural and non-structural control measures to reduce pollutants; and a description 

of any stormwater treatment 

3. A list of significant spills and leaks of toxic or hazardous pollutants at the facility that 

have taken place after the effective date of the permit 

4. A prediction of direction of flow and the possible pollutants associated with each area of 

the plant that generates stormwater 

5. A record of available sampling data describing pollutants in stormwater discharges 

B. STORMWATER MANAGEMENT CONTROLS 

1. Formulate a pollution prevention team with named individuals who will develop the 

stormwater prevention plan and assist plant manager in its implementation. 

2. Inventory types of materials handled and associated potential of release to stormwater. 

Evaluate the following for potential pollutant contribution: loading and unloading operations, 

outdoor storage and manufacturing activities, dust or particulate generating processes, and onsite waste disposal practices. Consider toxicity of chemicals, quantity of chemicals, and history 

of leaks or spills of toxic or hazardous pollutants. 

3, Design a preventive maintenance program including inspection and maintenance of 

stormwater management devices and testing plant equipment and systems to uncover 

conditions, which could cause failures. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 26 

4. Maintain a clean, orderly facility. 

5. Establish prevention and response procedures. Identify potential spill areas and 

drainage points. Specify material handling procedures and storage requirements. Identify spin 

cleanup procedures and provide to responsible personnel. Make available to responsible 

personnel the necessary equipment to implement cleanup at all times when the facility is in 

operation. 

6. Include in the plan a narrative of traditional stormwater management practices, i.e., 

other than those that control the source of pollutants. 

7. Identify areas of potentially high soil erosion and measures to limit erosion. 

8. Train' employees at all levels of responsibility in the components of the stormwater 

prevention plan. 

9. Identify qualified personnel to inspect equipment, plant areas, and material handling 

areas. Develop a tracking system to ensure corrective action and maintain records of 

inspections. 

10. Designate a person in the plan who will keep records of spills or other discharges, 

inspections and maintenance activities, and information describing the quality and quantity of 

stormwater discharges. 

11. Identify any non-stormwater discharges, and their sourcots). associated with the 

stormwater outtalls. In the event non-storrnwater discharges are discovered in combination with 

the stormwater discharges, the permittee must submit the appropriate EPA form(s) for the 

characterization of these non-stormwater discharges as warranted. 

C. FACILITY INSPECTION 

Responsible personts) named in the plan will inspect the facility at least semi-annually 

for the accuracy of the plan and maps, adequate measures to reduce pollutants in stormwater 

runoff, and the need for additional controls. Records of these inspections will be maintained for 

a period of three years. 

D. SPILL PREVENTION CONmOL AND COUNTERMEASURES 

Stormwater management programs may reflect requirements for spill prevention control 

and countermeasures (SPCC) plans under section 311 ot the CWA. 

E. PLAN REVIEW AND UPDATE 

The plan will be reviewed and updated, jf necessary, by the facility at least annually. The 

plan and all records will be retained for at least three years after expiration of this permit. 

F. PLAN IMPLEMENTATION 

The plan should be developed and available for review within 30 days after permit 

coverage. Facilities should implement the management practices as soon as possible, but not 

later than one year after permit coverage. Where new construction is necessary to implement 

the management plan, a construction schedule should be included. Construction should be 

completed as soon as possible. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 27 

G. PLAN AVAILABILITY 

The discharger shall maintain the plan on site, or at a nearby office. Copies of the plan 

will be submitted to the Division of Water Pollution Control within ten business days of any 

request. 

H. PLAN MODIFICATION 

The plan will be modified as required by the Director of the Division of Water Pollution 

Control. 

I. MONITORING PLAN 

The stormwater discharges will be monitored as required in Part l. Section A., Effluent 

Limits and MonItoring Requirements, applicable to stormwater outtaus. For each outfall 

monitored, the surtace area and type of cover. for example, roof, pavement, grassy areas, 

gravel, will be identified. 

J. SARA TITLE III, SECTION 313 PRIORITY CHEMICALS 

The SWPPP shall include the following for those facilities subject to reporting 

requirements under SARA Title 111, Seclion 313 for chemicals that are classified as Section 313 

waler priority chemicals: 

1. tn areas where Section 313 priority chemicals are stored, processed or otherwise 

handled, appropriate containment, drainage control and/or diversionary structures will be 

provided. AI a minimum, one of the following preventive systems or its equivalent will be used: 

a. Curbing, culverting, gutters, sewers or other forms of drainage control 

b. Roofs, covers or other forms or protection to prevent storage piles from 

exposure to stormwater and wind 

2. The plan will include a discussion of measures taken to conform with the following 

applicable guidelines: 

a. In liquid storage areas where stormwater comes into contact with any equipment 

tank container, or other vessel used for Section 313 water priority chemicals, 

i. the tank or container must be compatible with Section 313 water priority 

chemical which it stores and 

ii. the liquid storage areas shall be operated to minimize discharge of 

Section 313 chemicals. 

b. Material storage areas for Section 313 water priority chemicals, other than 

liquids, will incorporate features that will minimize the discharge of Section 313 

chemicals by reducing stormwater contact. 

c. Truck and rail car loading and unloading areas for Section 313 liquid chemicals 

will be operated to minimize discharges of chemicals. Appropriate measures may 

include placement and maintenance of drip pans tor use when making and breaking 

hose connections; a spill contingency plan; and/or other equivalent measures. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 28 

d. In plant areas where Section 313 chemicals are transferred, processed or 

handled, piping, processing equipment, and materials handling equipment will be 

operated so as to minimize discharges of chemicals. Piping and equipment must be 

compatible with chemicals handled. Additional protection, including covers and guards 

to prevent exposure to wind, pressure relief vents, and overhangs or door skirts to 

enclose trailer ends at truck loading docks, will be implemented. Visual inspections or 

leak tests will be conducted on overhead piping that conveys Section 313 chemicals. 

e. For discharges from areas covered by parts 2a, 2b, 2c, or 2d, 

l, the drainage should be restrained by manually-operated valves or other 

positive means to prevent the discharge of a spill or excessive leakage, 

ll. a flapper-type drain valves can not be used for drainage of containment 

units, 

III. the final discharge of in-facility storm sewers should be equipped with a 

diversion system that could, in the event of an uncontrolled spill of a Section 313 

chemical, return the spilled material to the facility, and 

tv. the records of the frequency and estimated volume (in gallons) of 

discharges from containment areas will be maintained. 

1. Facility site runoff other than from areas covered by parts za, ze, zc, and 2d 

from which runoff could contain Section 313 chemicals will incorporate the necessary 

drainage or other control features to prevent discharge of spilled or improperly disposed 

material and to ensure the reduction of pollutants in runoff or leachate. 

g. All areas of the facility will be inspected at specific intervals for leaks or 

conditions that could lead to discharges of Section 313 water priority chemicals or direct 

contact of storrnwater with raw materials, intermediate materials, waste materials or 

products. Inspection intervals shall be specified in the plan and shall be based on design 

and operations experience. Corrective action will be taken promptly when a leak or 

condition, which could cause significant releases of a chemical is discovered. If 

corrective action can't be taken immediately, the unit or process will be shut down until 

the situation is corrected. When a leak or spill has occurred, the contaminated 

material(s) must be promptly removed and disposed in accordance with Federal, State, 

and local requirements and as described in the plan. 

h. Facilities will have the necessary security systems to prevent accidental or 

intentionally entry, which could cause a discharge. 

Facility employees and contract personnel that work in areas where SARA title 

III, Section 313 water priority chemicals are used or stored will be trained in and 

informed of preventive measures at the facility. Employee training shall be conducted at 

least once per year in the pollution control laws and regulations and in the stormwater 

prevention plan. The plan shall designate a person who is accountable for spill 

prevention at the facility and who will set up the necessary spill emergency procedures 

and reporting requirements. 

L 
Nyrstar Clarksville, Inc. 

NPDES PermitTN0029157 

Page 29 

j. The SWPPP for a facility subject to SARA Title Ill, Section 313 requirements will 

be reviewed and certified by a responsible corporate officer. The responsible corporate 

officer will certify the plan every three years thereafter, or as soon as practical, after 

significant modifications are made to the facility. Certification will in no way relieve the 

owner or operator of a facility covered by the plan of their duty to prepare and fully 

implement such plan. 

3. "Section 313 water priority chemicals" means the following chemicals or chemical 

categories: 

a. listed at 40 CFR 372.65 pursuant to Section 313 of Title III of the Superfund 

Amendments and Reauthorization Act (SARA) of 1986, also titled the Emergency 

Planning and Community Right-to-Know Act of 1986; 

b. present at or above threshold levels at a facility subject to SARA Title III, Section 

313 reporting requirements; and 

c. meeting at least one of the following criteria: 

i. listed in Appendix 0 of 40 CFR 122 on either Table II (organic priority 

pollutants), Table III (certain metals, cyanides, and phenols) or Table V (certain 

toxic pollutants and hazardous substances); 

Ii. listed as a hazardous substance pursuant to section 311(b)(2)(A) of the 

CWA at 40 CFR 116.4; or 

III. designated as pollutants for which EPA has published acute or chronic 

toxicity criteria. 

K. STORMWATER SUPPLEMENTAL SWPPP REQUIREMENTS 

The permittee must complete the Supplemental SWPPP Requirements as presented in 

Attachment 3. 

GMDa 

TNOO29157 DOC 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 30 

ATTACHMENT 1 

WASTEWATER TREAThlENT FACILITIES INTEGRITY EVALUATION 

Within eighteen months from the permit's effective date the permittee shall submit to 

TDEC's Nashville Central and Environmental Field Offices (Division of Solid Waste 

Management and Division of Water Pollution Control - Permit Section) a report which 

addresses the structural integrity of any earthen basins associated with its wastewater 

treatment facilities including any waterborne wastes and sludqe storage/disposal units that are 

constructed of earthen material. 

The structural integrity evaluation shall be completed by a professional engineer 

licensed in the State of Tennessee, an environmental management professional, or other 

expert who is qualified by education and/or experience to perform and/or oversee such 

evaluations. The report shall document that the permittee has evaluated the unit's structural 

integrity and shall include the permittee's planned structural integrity improvements, if 

warranted. The report shall also address measures implemented and planned by the permittee 

as appropriate to reduce the chances that said wastewater treatment facilities/units failure 

would result in an uncontrolled discharge to the receiving stream(s) under normal conditions. 

Structural integrity evaluations of earthen basins and/or surface impoundments 

performed for compliance with other requtatory programs (e.g., Hazardous Waste Management 

under 1200-1-11, Solid Waste Management under 1200-1-7, or the Safe Dams Act) satisfy the 

provisions of this permit requirement. 
Nyrstar Clarksville, Inc. 

NPDES Permit TN0029157 

Page 31 

ATTACHMENT 2 

CHRONIC BIOMONITORING IC25 TESllNG PROCEDURE 

Pursuant to the IC25 testing requirements presented in Part III.F., the permittee must 

complete chronic biomonitoring based on the 3-Brood Water Fleas (Ceriodaphnia dubia) 

survival and reproduction test) and the 7-Day Fathead Minnows (Pimephales promelas) larval 

survival and growth test using the Crude Zinc Oxide washwater samples. 

The measured endpoint for toxicity will be the inhibition concentration causing 25% 

reduction in survival. reproduction and growth (IC2s) of the test organisms. The IC25 shall be 

determined based on a 25% reduction as compared to the controls, and as derived from linear 

~nterpolation. The average reproduction and growth responses will be determined based on the 

number of Ceriodaphnia dubia or Pimephafes promelas larvae used to initiate the test. 

This testing must be conducted and its results reported based on appropriate replicates 

of a total of five serial dilutions and a control, using the percent effluent dilutions as presented in 

the following table: 

100 

Treated Effluent Serial Dilutions for Chronic 

Whole Effluent ToxicilV (WEn Testina 

% Effluent 

I 50 I 25 I 12.5 I 6.25 I a 

The dilution/control water used will be moderately hard water as described in ShortTerm Methods for Estimatina the ChrOniC Toxicity of Effluents and Receiving Water to 

Freshwater Organisms, EPA-821-R-02-013 (or the most current edition). A chronic standard 

reference toxicant quality assurance test shall be conducted with each species used in the 

toxicity tests. Additionally, the analysis of this multi-concentration test shall include review of 

the concentration-response relationship to ensure that calculated test resurts are interpreted 

appropriately. 

Testing must be conducted using a minimum of three 24-hour flow-proportionate 

composite samples of final effluent collected on days 1, 3 and 5. If, in any control more than 

20% of the test organisms die in 7 days, the test (with 100% dilution water) is considered a test 

control failure and invalid, and the test shall be repealed. Furthermore, if the results do not 

meet the acceptability criteria in Short-Term Methods for Estimating the Chronic Toxicity of 

Effluents and Receiving Water to Freshwater Oraanisms, EPA-821-R-02-013 (or the most 

current edition). or if the required concentration-response review fails to yield a valid 

relationship per gUidance contained in Method Guidance and Recommendations for Whole 

Effluent Toxicity (WET) Testina, EPA-821-B-00-004 (or the most current edition), that test shall 

be repeated. Any test initiated but terminated before completion must also be reported along 

with a complete explanation for the termination. 

In the event of a test control failure, the permittee shall start a follow-up test within 2 

weeks and submit results from a follow-up test within 30 days from obtaining initial WET testing 

results. The follow-up test must be conducted using the same serial dilutions as presented in 

the above serial dilution table. 

Test procedures, quality assurance practices, determinations of effluent 

survival/reproduction and survival/growth values, and report formats will be made in accordance 
Nyrstar Clarksville, Inc. 

NPDES Permit TN00291 57 

Page 32 

with Short-Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Water 

to Freshwater Organisms, EPA-821-R-02-013, or the most current edition. 

Results of all tests, reference toxicant information, copies of raw data sheets, statistical 

analysis and chemical analyses shall be compiled in a report. The report will be written in 

accordance with Short-Term Methods for Estimating the Chronic Toxicity of Effluents and 

Receiving Water to Freshwater Organisms, EPA-821-R-02-013, or the most current edition. 

Three copies of the IC25 biomonitoring reports (including follow-up reports) must be 

included in the permittee's Form 2C submittal per Part III.F. 
Nyrstar Clarksville, Inc. 

NPDES PermitTNQQ29157 

Page 33 

ATTACHMENT 3 

SUPPLEMENTAL STORMWATER POLLUTION PREVENTION PLAN (SWPPP) 

REQUIREMENTS 

The division acknowledges that the benchmark/cutoff values shown in Part 1.A may not provide 

the best datum for judging stormwater contaminant BMP enhancements needed, given the onsne activities and stormwater controls already implemented. However, until more specific 

stormwater benchmark/cutoff values have been established, the permittee must use the 

discharge values included in Part 1.A as the basis for investigating/making further stormwater 

BMP improvements. As such, the permit requires (he permittee to review/update its SWPPP at 

least annually. Unless otherwise documented in (he SWPPP as a plan-of-action/with schedule, 

the division requires the permittee to make BMP enhancements tor reducing stormwater 

contaminants within 120 days trom submitting the stormwater outfall DMR results for those 

contaminants exceeding the Part 1.A values. The permittee must document these SWPPP 

reviews/upgrades, BMP enhancements, and make such documentation available for division 

review during site inspections. The division may request that the permittee submit a copy of the 

documentation to the Nashville Environmental Field Office. During the permit term, the 

permittee may request that the division reopen the permit to include revised benchmark/cutoff 

values that are specific to its operation given its unique on-site activities, based on justification 

information provided by the permittee. 

Generally, the division considers the "first-flush" sample to be the most accurate representation 

of the maximum daily value for various pollutants in the stormwater runoff. Furthermore. 

storm water sampling requires the analysis of grab samples collected within the first 30 minutes 

(or as soon thereafter as practical. but not to exceed one hour) of when the runoff or snowmelt 

begins discharging, and the discharger must submit with the monitoring report a description of 

why a grab sample during the first 30 minutes was impracticable. Every effort should be made 

to collect a "first-flush" sample representative of the daily maximum values for sampled 

parameters.. If stormwater discharges associated with industrial activity commingle with 

process or nonprocess water, then where practicable permittees must attempt to sample the 

stormwater discharge before it mixes with the non-storm water discharge. 

A minimum of one grab sample shall be taken. All such samples shall be collected from the 

discharge resulting from a storm event that is greater than 0.1 inches in magnitude and that 

occurs at least 72 hours from the previously measurable (greater than 0.1 inch rainfall) storm 

event. The required 72-hour storm event interval is waived where the preceding measurable 

storm event did not result in a measurable discharge from the facility. The required 72·hour 

storm event interval may also be waived where the permittee documents that less than a 72­

hour interval is representative for local storm events during the season when sampling is being 

conducted 
Nyrstar Clarksville, Inc.(Second Addendum to Rationale)
 

NPDES Permit TN0029157
 

Page SAD-'
 

SECOND ADDENDUM TO RATIONALE 

Nyrstar Clarksville. Inc.
 

NPDES PERMIT NO. nl0029157
 

Clarksville. Montgomery County. Tennessee
 

Permit Writer: Mr. Gary Davis 

Pursuant to a December 20. 2011 permittee request the division has made the permit's minor 

modifications presented in this "Second Addendum to Rationale. The division's responses are 

provided in italic/bold font. 

Permittee's Requested Permit Attachment 2 Modifications 

"The language in Attachment 2 - Chronic Biomonitoring IC25 Testing Procedure is taken from 

permits in which there is an enforceable IC25 limit; therefore some aspects are not appropriate 

for Form 2C informational testing. Specifically: 

•	 In the fourth paragraph (after the table), note that results should be submitted with the 

Form 2C, not ''with the discharge monitoring report". 

•	 In the fifth paragraph, the requirement that repeat testing be completed "within two 

weeks" should be deleted in two sentences. 

•	 In the sixth paragraph, the last sentence ("The follow-up test shall not negate an initial 

failed test.") should be deleted: 

Division's Response For The Requested Permit Attachment 2 Modifications 

The division agrees with the request and the changes were made. 

Permittee's Requested Permit Attachment 3 Modifications 

The permittee requested that the permit Attachment 3's first three paragraphs be replaced with 

the following requirements: 

"The division acknowledges that the benchmark/cutoff values shown in Part 1.A may not 

provide the best datum for judging stormwater contaminant BMP enhancement needs, given 

the permittee's on-slte activities. As such, the division will work with the permittee during the 

next NPDES permit renewal cycle to develop benchmark/cutoff values that are specific to its 

operation given its unique on-site activities. Toward that end, the permittee must review its 

SWPPP and stormwater analytical results annually and make appropriate BMP enhancements 

tor reducing slormwater contaminants. The permittee must document these reviews and BMP 

enhancements, and make such documentation available for review during site inspections or at 

other appropriate times. In developing site specific benchmark/cutoff values during the next 

NPDES permit renewal cycle, the division may choose to compare stormwater analytical data 

from the preceding permit cycle to historical stormwater analytical data to evaluate 
Nyrstar Clarksville. Inc.(Second Addendum to Rationale) 

NPDES Permit TN0029157 

Page SAD·2 

effectiveness of BM? enhancements and adequacy of the data for use in developing sitespecific benchmark/cutoff values for inclusion in future permits." 

Division's Response For The Requested Permit Attachment 3 Modifications 

Pursuant to the permittee's request/additional information provided. the permit's 

Attachment 3 first three paragraphs were revised and consolidated per the clarifications 

provided subsequently. 

Prior to Clarifications: 

"If the permittee's discharge value(s) exceed the above new permit's benchmark/cutoff 

values presented in Part 1.A, the division requires that the permittee complete 

investigations to determine the reason(s) the higher value(s) occurred and make as 

needed BMP improvements for the relevant parameter(s). The permittee must 

document/make effectiveness assessments for such BMP improvements. As a 

supplemental SWPPP requirement, the permittee must develop. and regularly update a 

Stormwater Report for its facility. 

The division acknowledges that the benchmark/cutoff values shown in Part 1.A may not 

provide the best datum for judging stormwater contaminant BMP enhancement needs, 

given the permittee's on-site activities. The new permit requires the permittee to submit 

its first written Stormwater Report to the Nashville Environmental Field Office within 18 

months from the permit's effective date with subsequent submittals on an annual basis. 

The Stormwater Report should include the stormwater results and actions taken, as 

warranted. 

The Stormwater Report should note how the permittee proceeded within 30 days from 

the time stormwater monitoring DMR results were submitted to the division to develop a 

plan of action to determine the pollutant source/cause of the exceedance and potential 

remedies for reductions. Furthermore, within 60 days from the time stormwater 

monitoring DMR results were submitted, the permittee must review and as applicable 

make modifications to its SWPPP for reducing stormwater contaminants to less than the 

monitoring benchmark/cutoff values for its facility." 

After Clarifications and Consolidation: 

"The division acknowledges that the benchmark/cutoff values shown in Part 1.A may not 

provide the best datum for judging stormwater contaminant BMP enhancements needed, 

given the on-site activities and stormwater controls already implemented. However, 

until more specific stormwater benchmark/cutoff values have been established, the 

permittee must use the discharge values included in Part 1.A as the basis for 

investigating/making further stormwater BMP improvements. As such, the permit 

requires the permittee to review/update its SWPPP at least annually. Unless otherwise 

documented in the SWPPP as a plan-of-actionlWith schedule, the division requires the 

permittee to make BMP enhancements for reducing stormwater contaminants within 120 

days from submitting the stormwater outfall DMR results for those contaminants 

exceeding the Part 1.A values. The perminee must document these SWPPP 
Nyrstar Clarksville, Inc.(Second Addendum to Rationale) 

NPDES Permit TN0029157 

Page SAD-3 

reviews/upgrades, BMP enhancements, and make such documentation available for 

division review during site inspections. The division may request that the permittee 

submit a copy of the documentation to the Nashville Environmental Field Office. During 

the permit term, the permittee may request that the division reopen the permit to include 

revised benchmark/cutoff values that are specific to its operation given its unique onsite activities, based on justification information prOVided by the permittee. " 

The Reopener Clause (Part III.B) was revised to include this last sentence. The division 

does not want the permittee to be forced into continually having to make BMP 

evaluations/enhancements/documentation, if further stormwater controls are not 

warranted, nor technically/economically realistic. 
Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES Permit TN0029t57 

Page AD-1 

ADDENDUM TO RATIONALE 

Nyrstar Clarksville. Inc. 

NPDES PERMIT NO. TN0029157
 

Clarksville. Montgomery County, Tennessee
 

Permit Writer: Mr. Gary Davis 

Draft permit written comments were submitted by the permittee and EPA. This "Addendum to 

Rationale" provides these comments along with the division's responses (presented in bold 

italics font), and as such augments the draft permit's "Rationale" and allows the new permit to 

be finalized, 

Permittee's No.1 Comment 

On page 12. does the draft permit require thai both a hard cop.,. and an electronic: cop.,. of our Monthly ocerattng 

Report be submitted tu the ~iShville Environmellt;tl Field Office, or will only an electmntc cccv suttrce? We are 

submitting our monthly ~I'OES reports via ~etDMf{, which atlowa for etect-cnk documents to be attached. Will 

attar-ring our MORs to our monlhlv NelOMR subrnrrta' 1ati1fv this reaUlremenO 

Division's Response to Permittee's No.1 Comment 

The division agrees with the permittee attaching its MaR to the monthly NetDMR 

submittet, with all electronic reporting. However, since the Nashville Environmental 

Field Office is not setup for NetDMR subminals, the NetDMR with attached MaR must be 

sUbmitted to the atvtsion's Compliance and Enforcement Office in Nashville. 

As such, the permittee will not be required to submit the MaR (hard copy or 

electronic) to the Nashville Environmental Field Office. Therefore, the following 

sentence was added to the permit, "The permiNee's electronic DMR submittal must also 

include as an attachment its Monthly Operating Report (MaR)." 

For finalizing the permit the following provision included in the draft permit was 

deleted from Part I.E.1: "The permittee shall also submit a copy of its Monthly Operating 

Report (MOR) 10 Ihe division's Nashville Environmenlal Field Office (NEFO). An 

electronic MaR SUbmittal must aJso be provided to the NEFO." "A copy of the 

completed and signed DMR shall be mailed to the Nashville Environmental Field Office 

(EFO) al Ihe following address: 

TENNESSEE DEPT. OF ENVIRONMENT & CONSERVATION 

DIVISION OF WATER POLLUTION CONTROL 

NASHVILLE ENVIRONMENTAL FIELD OFFICE 

711 R.S. GASS BOULEVARD 

NASHVILLE TN 37243" 
Nyrstar Clarksville. Inc. (Addendum to Rationale) 

NPDES Permit TN00291 57 

Page AD-2 

Permittee's No.2 Comment 

Page 23 includes what appears to be standard municipal wastewater treatment plant permit language requiring 

wastewater treatment facl\lties tc be operated under the supervision of a wastewater system certified operateand the ccnecucn svstem operated under the supervf5lon of a ccnectron system cernaed operator. This language 

W3i" not in pre\lious versions of OUf NPDES permit, and our's is ob\liously not II muniLipal svstem. I believe thts 

language should be removed. 

Division's Response to Permittee's NO.2 Comment 

The deparlment requires operator and collection system certifications when the 

permittee's WWTP also trest« sanitary sewage. Since the permittee treats its sanitary 

sewage with its on-site treatment system, appropriate certifications are required. 

However, the division does not specify specific certification reqUirements in NPDES 

permits. To determine appropriate certifications, the division suggests that the perminee 

may want to get Information from the Fleming Training Center 

http://www.tn.gov/environmentHlemingi. 

Permittee's No.3 Comment 

Page U Jncfuees Janguaae requiring our SWPPP to be certified by a PE everv a years. We ink that the
 

:-ecertif![ilticn requirement be changed to I!wry five yean 10coincide with the NPDES permit renewal recycle and
 

the SPCC Plan review requirements.
 

Division's Response to Permittee's No.3 Comment 

The new permit's SWPPP must be certified every 3 years by a permittee's responsible 

corporate officer rather than a professional engineer. The division does not have 

regUlatory authority for the permittse's SPCC plan. 

EPA's NO.1 Comment 

The development of the permit limits for outfall 001 for the following parameters is not 

adequately explained for the following pollutants: arsenic, cadmium, copper, lead, 

selenium, zinc, and total suspended solids (TSS). 

The draft permit shows calculation of limits using effluent limitation guidelines (ELGs) in the 

table on page R-22, but the calculations from the tables on page R-23 a(e difficult to follow. It is 

unclear how the total loadings were established (even with a new table provided by the permit 

writer. Gary Davis). It is unclear what relationship the zinc probability plot in appendix A-3 has 

to do with these calculations and how the statistical (95%ile and 99%ile) method is used. It is 

suggested that a better rationale be provided so one may more easily interpret these tables on 

page R-22. 

Division's Response to EPA's No.1 Comment 

The permittee's physicaVchemical "Metals Recovery Treatment System" (shown in 

Appendix AD-1, Figure AD-1), treats all the plant's wastestreams, except for the recently 

;nstalled Crude Zinc Oxide wash water. Even the dilute wastestreams become 
Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES PermitTN0029157 

Page AD-3 

contaminated since they are comingled with the highly contaminated wastestreams prior 

to treatment and Outfall 001 discharge. As depicted in Figure AD-1, the permittee's 

Metals Recovery Treatment System processes numerous contaminated wastestreams 

associated with ELG and Non-ELG sources. 

Based on the flows presented in Table AD-1A, only 16% of the Outfall 001 discharge is 

due to manufacturing subiect to ELGs. Since all plant wastestreams are 

combined/treated in the permittee's Metals Recovery Treatment System, the Outfall 001 

discharge allocations must be determined based on the ELG and Non-ELG sources. The 

Best Professional Judgment (BPJ) regulatory process must be used to determine 

discharge allocations for Non-ELG wastestreams. The resulting OutfaJl 001 techn%gy~

based effluent limits (TBELs) being the mass loading aJlocations for ELG + Non-ELG 

related plant activities. 

Based on the division's further review of the current permit's rationale, permit renewal 

application information, DMR results, and an on-site evaluation, it was evident that most 

of the OutfaJl 001 contaminant loading allocations relate to Non-ELG wastestreams 

sources. To translate this finding into discharge limits the division calculated aJlocations 

based on the permittee's primary/limiting/controlling discharge parameter, zinc. (The 

permittee considers zinc control to be the most limiting/difficult wastewater contaminant 

to treat for achieving the current permit's discharge limits.) As explained in the Rationale 

(p. R-23), since the permittee uses zinc control as the primary basis for operating its 

physicaVchemical WWTP, the Outfall 001 DMR zinc results probability plot included in 

Appendix R-3, provided performance-based discharge values, [monthly average zinc 

limit =::; 95%tiIe 12.7 Ib/day value (based on DMR monthly averages) and daily maximum 

zinc limit =::; 99%tile 27.0 Ib/day value (based on DMR daily maximum values)]. These 

values represent the technology-based total mass loading allocations (sum from ELG 

and Non-ELG sources) for the facility. 

To determine the mass loading discharge allocations for the Non-ELG wastestreams the 

division assumed that it has two portions tt" portion having treatability "Like ELG" 

sources and 2'dportion "Not Like-ELG"). It was easy to calculate the "Like-ELG" portion 

by calculating the ELG concentration and using the Non-ELG flow to determine mass 

loadings. Since it more complex to explain the "Not Like-ELG" allocation, Table AD-1A 

was developed with detailed example calculations for the monthly average zinc loading 

determination. The daily maximum was determined using the same approach. The 

TBELs for the other discharge parameters was based on the same approach assuming 

the zinc "Like ELG""100INot Like-ELG" value was applicable. The division realizes that 

some BPJ determination adjustments could be warranted for the next permit renewal. 

Using this approach the TBELs presented in Table AD-1B were determined. 

EPA's No.2 Comment 

The rationale for allowing backsliding of the parameters listed above has not been 

adequately documented. 

The limits for outfall 001 are less stringent than the previous permit. It is recommended that 

adequate justification be included for the increase of limits. 
Nyrstar Clarksville, Inc. {Addendum to Rationale) 

NPDES Permit TN0029157 

Page AD-4 

Division's Response to EPA's No.2 Comment 

An antibacksliding exception can occur if the permittee's facility is sUbject to a material 

and substantial alteration. For example, this antibacksliding exception can be applied 

when the discharge limits are increased due to changes in production and/or the 

industry is subject to corrections due to production-based ELGslBPJ determinations. 

Also, an antibacksliding exception exists for renewals involving technical errors! 

misunderstanding related to developing the discharge limits for prior permits. 

The receiving stream is fully supporting its designated uses and the new permit's 

discharge values are consistent with retaining instream water quality requirements. The 

new discharge limits were based on additional site infonnation, furlher division insight 

regarding the permittee's WWTP's operation/perlormance and a revised BPJ 

determination (using the Building Blocks approach instead of the Combined 

Wastestream Formula). In its permit renewal application the permittee noted that as of 

2010 it had re-acquirec/ and is in the process of reopening mines in Tennessee, and is 

installing a crude zinc oxide washing process for providing a supplemental raw material 

source. 

EPA's NO.3 Comment 

The Company had calculated proposed limitations and included this information in the 

application; yet larger loading limits (as calculated by the State) have been included in 

the permit (for outfall 001); justification for this has not been given. 

In the application package submitted by the Nyrstar in May 2010, there were calculations which 

the Company proposed which are contain slightly elevated loading limits tor outfall 001 for 

pollutants in the previous permit. The calculations provided by the Company were easy to 

interpret. The loadings calculated by the Company were more stringent than those proposed in 

the draft permit. It is unclear why the larger proposed draft limits were established, instead of 

those presented by the applicant. 

For example -for monthly average amounts (in pounds per day) 

Pollutant 

Arsenic 

Cadmium 

CODDer 

Lead 

Selenium 

Zinc 

TSS 

Previous permit 

limit 

13.77 

1.76 

14.10 

2.93 

11.02 

10.68 

1876 

Proposed limits by 

Company as shown with 

aoolication (Table 3\ 

Draft permit limit 

I 

13.97 17.12

1.77 2.28 

14.21 17.43 

2.95 3.72 

11.02 24.9 

10.76 12.0 

1943.65 2459 ----.J 
Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES Permit TN0029157 

Page AD-5 

Division's Response to EPA's No.3 Comment 

As explained in the division's response to EPA comments Nos. 1 and 2, the new 

discharge limits were based on additional site information. further division insight 

regarding the permittee's WWTP's operation/perlonnance. and a revised BPJ 

determination. The new permit's technology-based discharge allocations were 

developed using the "Building Blocks" approach instead of the "Combined Wastestream 

Formula". The "Combined Wastestream Formula" is used for pretreatment discharge 

allocation determinations. Also, the current pennit's technology-based discharge 

allocations and the permittee's proposed technology-based were formulated using prior 

division criteria (Rule 120CJ.4-5-.03 for "Unregulated, Non-Process Related 

Wastestreams") Which is no longer applicable. The technology-based limits must be 

developed per Rule 1200-4-5-.09 which involves ELG + BPJ (for applicable Non-ELG 

plant processes). The new permit discharge selenium limits were based on the 

division's water quality reasonable potential evaluation involving an increased low-flow 

determination. as shown in the Rationale (pp. R·30 and R-32). 

EPA's No.4 Comment 

The use of a 90% stream allocation instead of 50% stream allocation that was used in the 

water quality based calculations has not been adequately justified. 

The current method that the State uses in the calculation of reasonable potential procedures 

(RPA) Includes a margin of safety. Generally a 90% margin of safety is used for "wadeable" 

streams and 50% is used tor "non- wadeable streams." The Cumberland River would be 

classified as "non-wadeable" yet the margin of safety used is 90%. Based on April 26, 2011. 

correspondence from the Company, it was requested that 90% allocation be retained. The 

Company noted that use of the 50% margin of safety would ultimately have the effect of 

reducing the metals, particularly cadmium and selenium and would cause undue hardship to 

Nyrstar is more stringent limits were included in the permit (including the possibility of plant 

closure). Such undue hardship should not be considered an appropriate rationale to retain the 

margin of safety at 901;>/0. The rationale in the permit notes on page R·2. Section R3.2.b., that 

"(T]he 90% receiving stream water quality allocation from the permittee's current permit has 

been retained." The last sentence of this seclion states: "Since water quality allocation are 

related to the types and number of dischargers, the specific allocation will be defined with each 

permit renewal." The rationale does not provide adequate justification as to why a 90% 

allocation should be allowed for this particular discharge and the EPA recommends that 

justification be provided. 

As a side-note, the Company had noted that there was only one sampling point for selenium 

and the default value used in the RPA made selenium very restrictive. The Company and the 

State should explore doing multiple in-stream sampling of metals (especially selenium) above 

the discharge to provide better data for the next issuance of the permit. 

Division's Response to EPA's No.4 Comment 

The reasonable potential procedures are not promulgated regulation, therefore the 

division has flexibility regarding the discharge allocation for treated effluent 
Nyrslar Clarksville. Inc. (Addendum to Rationale) 

NPDES Permit TN0029157 

Page AD-6 

contaminants. Since the Crude Zinc Oxide (CZO) is B new process facility, the division 

requires per the new permit's Part III.F., that the CZO washwater contaminant loadings 

must be characterized per Form 2C and IC25 testing. Based on this additional 

wBshwater characterization Information the division may reopen the permit to require 

supplementa' WQBEL determination information, which could involve requirements that 

the permittee identify metals of concern in the Cumberland River upstream of the 

Clarksville STP (TNOO20656) and permittee's discharges. 

EPA's No.5 Comment 

It is noted that stormwater is being limited for cadmium, copper, lead, zinc, and TSS for 

outfalls SW3, SW4, and SW5, but no reasonable potential analysis has been included to 

ensure these are the appropriate limits for these outfalls; this justification should be 

included. 

The EPA appreciates the fact that limitations are being placed on these stormwater discharges 

that had no limits in the previous permit, but recommends that justification be included that 

water quality will be adequately protected with the limits as given. 

Division's Response to EPA's No.5 Comment 

The numerical values for the stormwater Outfall SW3, SW4 and SWS discharges are 

actuallY benchmark/cutoff values and not effluent limitations. As such, reasonable 

potential analyses are not warranted for the permit renewal; however, as described in 

the Rationale p. R-4 [If" the permittee's discharge exceeds the above new permit's 

benchmark concentration the division requires that the permittee complete 

investigations to determine the reason(s) the higher value(s) occurred and make as 

needed BMP improvements for the relevant parameter(s). The permittee must 

document/make effectiveness assessments for such BMP improvements. "J. This 

approach provides a mechanism for the permittee to make stormwater quality 

improvements. The new pennit was finalized to include the draft permit's intended 

reqUirements for conditions where the stonnwater benchmark/cutoff values are exceed 

by adding the Anachment 3 clarifications pursuant to the newly referenced Part V. K. 

The new permit's Anachment 3 includes the following provisions: "If the perminee's 

discharge value(s) exceed the above new permit's benchmark/cutoff values presented in 

Part 1.A. the division requires that the permittee complete investigations to determine 

the reason(s) the higher value(s) occurred and make as needed BMP improvements for 

the relevant parameter(s). The permittee must document/make effectiveness 

assessments for such BMP improvements. As a supplemental SWPPP reqUirement, the 

permtttee must develop, and regularly update a Stormwater Report for its facility. 

The division acknowledges that the benchmark/cutoff values shown in Part 1.A may not 

provide the best datum for judging stonnwater contaminant BMP enhancement needs, 

given the permittee's on-site activities. The new permit reqUires the perminee to submit 

its first wrinen Stormwater Report to the Nashville Environmental Field Office within 18 

months from the permit's effective date with subsequent submittals on an annual basis. 
Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES Permit TN0029157 

Page AD-7 

The Stormwater Report should include the stormwater results and actions taken, as 

warranted. 

The Stormwater Report should note how the permiNee proceeded within 30 days from 

the time stormwater monitoring DMR results were submitted to the division to develop a 

plan of action to determine the pollutant source/cause of the exoeeaenc« and potential 

remedies for reductions. Furthermore, within 60 days from the time stormwater 

monitoring DMR results were submitted, the permiNee must review and as applicable 

make modifications to its SWPPP for reducing stormwater contaminants to less than the 

monitoring benchmark/cutoff values for its facility." 

The new permit's Attachment 3, provides stormwater monitoring clarifications. 

EPA's No.6 Comment 

The draft permit does not include monitoring for a stormwater outfall, SW6, but 

pollutants are being discharged from this site. This outfall needs to include monitoring 

<at the very least). 

The previous permit contained monitoring requirements for flow, pH, T55, total cadmium, total 

copper, total lead, and total zinc. The draft permit contains no monitoring, although it does 

acknowledge the outfall 5W6 on the cover page. The applicant has also noted the existence of 

outfall 5W6. The rationale should present documenlation that RPA has been done, and if no 

water quality limits are needed, then monitoring of pollutants as previously done should be 

included (at a minimum on an annual basis). 

Division's Response to EPA's No.6 Comment 

The DMR results for the permittee's stormwater outfall discharges are provided in the 

Rationale p. R-20. The division is aware that some Outfall SW6 parameters exceed the 

cutoff concentrations (maybe due to historical activity or fugitive emissions); however, 

since the permittee has indicated that the Outfall SW6 hasn't had industrial actiVity for 

the past several years the new permit has been finalized without monitoring 

requirements. As such, the following provision was added to the reopener clause Part 

JIJ.B "The permittee must notify the division if during the term of the permit the Outfall 

SW6 discharge becomes SUbject to runotf from active industrial ectivitv, and the division 

may reopen the permit to add monitoring/BMP upgrade requirements pursuant to 

benchmark/cutoff values." Updated Outfall SW6 stormwater characterization data wiJJ be 

provided to the division with the permiNee's next Form 2F permit renewal submittal, at 

which time the division wiJJ decide if Outfall SW6 monitoring is warranted. 

For the new permit, the division wants the permittee to focus on the OutfaJl SW3, SW4 

and SW5 discharges wherein the stormwater contaminants are much higher than the 

benchmark/cutoff values and further evaluations are warranted. 

EPA's No.7 Comment 

It is recommended that outfall 001 contain whole effluent toxicity (WEn testing. 
Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES Permit TN0029157 

Page AD·S 

To ensure that the effluent is not toxic from the synergistic effects of the various metals being 

discharged to the Cumberland River, and due to the new crude zinc oxide washing facility that 

has been installed, it is recommended that WET testing be included in the permit (at a minimal 

frequency of one per year for the life of the permit). 

Division's Response to EPA'$ No.7 Comment 

The permittee's current permit Rationale p. R-11 indicates "Since the calculated dilution 

factor is greater than 500: 1 for this facility discharge and its receiving stream, 

biomonitoring will not be required during this permit cycle... This provision is applicable 

for the new permit. Also, as beckground information the permittee had conducted 

biomonitoring Outfall 001 discharge evaluations in 1999 with the following results: 96 hr 

LC50 acute = 96% Ceriodaphnia dubia and >100 % for Pimephales promelas, and IC25 

chronic = 14% for Ceriodaphnia dubia and 54% for Pimephales promelas. Based on the 

Appendix R·l (p. R-12) Outfall 001 discharge and receiving stream flow data the instream 

waste concentration OWC) is 0.04%. Therefore, even with changes in manufacturing and 

WWTP upgrades, the division does not expect WET water quality problems associated 

with the Outfall 001 discharge. 

Since no WET results exist for the washwater from the new crude zinc oxide washing 

operation, the permittee must include the IC25 testing results with its Form 2C 

application submittal pursuant to the new permit's Part III.F. The new permit's Part III.F. 

includes the following requirement: "The submittal must also include the IC25 testing 

results, pursuant to the procedure presented in Attachment 2." The new permit's 

Attachment 2 includes the requirements for completing the IC25 testing. 

EPA's No.8 Comment 

Additional justification should be included for the "de minimus" antidegradation 

determination for chloride and fluoride from the new process (crude zinc oxide washing 

facility). 

The table as found in appendix R-5 shows the "de minimus" calculations for chlorides and 

fluorides due to the new process, but the rationale lacks a narrative of why this is considered 

"de minimus" in light of Tennessee's regulations. 

Division's Response fa EPA's No. B Comment 

From the permit's Rationale (p. R·10) "As shown in Appendix R-5 and discussed 

in Section RB, the additional chloride and fluoride loadings in the washwater from the 

permittee's newly-installed Crude Zinc Oxide (CZO) facility presents a de minimis 

impact, since these parameters use less than five percent of the receiving stream's 

available assimilative capacity. OJ Tennessee's antidegradation (per Chapter 1200.4·3·.06.) 

and new permit's Part I.C. Definitions, "De Minimis - Alterations, other than those 

resulting in the condition of pollution or new domestic wastewater discharges, that 

represent either a small magnitude or a short duration shall be considered a de minimis 

impact and will not be considered degradation for purposes of implementing the 

antidegradation policy. Discharges other than domestic wastewater will be considered 
Nyrslar Clarksville, Inc. (Addendum to Rationale) 

NPDES Permit TN0029157 

Page AD-9 

de minimiS if they are temporary or use less than five percent of the available 

assimilative capacity for the substance being discharged. If more than one activity has 

been authorized in a segment and the total of the impacts uses no more than ten percent 

of the assimilative capacity, available habitat, or 7010 low flow, they are presumed to be 

de minimis. Where total impacts use more than ten percent of the assimilative capacity. 

Bvailable habitat, or 7010 low flow they may be treated as de minimis provided that the 

division finds on a scientific basis that the additional degradation has an insignificant 

effect on the resource and that no single actiVity is alloWed to consume more than five 

percent of the assimilative capacity. available habitat or 7010 low flow." Note, 

underlined portion of de minimis definition added for clarification regarding the 

division's "de minimis" determination. 
Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES Permit TN0029157 

Page AD·10 

APPENDIX AD·' 

Fiaure AD·1 

.1-I 

, r -'1---' 

RECEIVED 

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- -

Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES Permit TNDD29157 

Page AD-11 

Table AD-1A 

TECHNOLOGY-BASEO OUTFALL 001 ZINC OlSC~ARGE ALLOCATlONS 

EFFLUENT MonUl Avera _ 

CHARACTERISTIC ELG Wastestreams Non-ELG Wastestreams Total Allocation 

LoadlOg Fk'" CDOC 'ow BPJ Basis a Loading 

,EL:;) IELGI fELG) (Non-ELG) Like-ELG b Not LI'K<:·ELG tc rotar (95 %tlle VaIU8) 

It>cla~1 1m, d ImnJL [mod (Ib'clavl 1b.(1avl tb'oev (Ibid.:!y\ 

ll1'lC(T, 1.478 00727 " 03832 77BS 2.734 10 522 12.0 

EFFLUENT Oaily Mbimum 

CHARACTERISTIC ELG Wastntreams Non-ELG Process W8stutreams lotaIAII~~

, oadll'lg "ow Gone Flow L_ BPJ BaSIS a Loadings

,~ELGI IElGi (ElG) (t~ofl.ElC,tLl'K,".HG b No! LI~e-ElG (e) Total (99 %!Ile Value) 

I (It)'d8.v\ tmcoi met !m')ljj' IIbditv) lb-cIaV (lb'rjaVI Ib,'clay)

Zlt';C(T) 3,590 007Z7 '59 (11832 18.917 44. 23410 

-	

21.0 

0 ,~) , errrvrtee use s lITlC treatment performance as onrnarv ba ,1"- for operating VWVTP 

W) carcoateo USingc:...'~ concemauon ami Non·I::LG wastcaneems now 

iCi '':'';',\'TP zmc Ireillmer,l oerrorroarce veloes for calUILaI,rlg "Like E;"03'& "Not "KE ELG" asocenors 

')c,1° o lor MonthIy Averago'> 

:') 8 "e Ior Oa,l; Maximum 

'~he above oerceraeces useoto cecueie "I~ol ;"1~e·ELG allocations lor clher Oonen 001 parameters i 

,,0110'	 Be-a r'roressrorai Judgment IBPJ) mass loadlrlg allocations developed (on~\derlrlg permittee's prccess 

~nc)wled9€ wastesaeam cnaractensncs eoo lreatmenl system pencrrnance ilS felaled to rocreesec flow from 

ocn.Et.c wa-resnearns i1f\(lude raTlllan) 

IMonthly Average Example:
 

'BEL ncr- ten.scale trealabltity TesU~S 95%(ile value - __-,'"'e.Ollb lInc;oaybased on DMR results
 

AIIQ\:,nCJll nom E~G :;: 1 478 Ib zmoday 

Aucceuon Irorr'LlkeELG :: f--_-f7~7~8~8 Ib zmooav 

Tali'll-= 

~==.~.~"~'~Ib zmouev 

AII0ca::0n rrorut.ot L1ke-cLG' 

7738 Ib zmcoav for "Like ELG" 

\-_-c"",7J.4 bzmc'cavftx "Not llke-ELG'" 

Tolal = 10.522 Ib zmrdaj lor Non ELG

2734"10077BB 

35.1 "0 
Nyrstar Clarksville, Inc. (Addendum to Rationale)
 

NPDES Permit TN0029157
 

Page AD-12
 

Table AD-1B 

TECHNOlOGY-SASED OUlFAllOO1 DISCHARGE ALLOCAl1ONS 

EFFLUENT Mon1h1y Averlot

CHARACTERISTIC ELG Was1estl'eams Non..ElG W,steltreams Total Allocation

Loading Flow Cone FkJw BPJ Basis a Loading

Like tLG Ib Not Like-ELG c Total I~";;G) IllJIdavl lmadl ImaiLl h'da It",.,) IJlda' (l\da~

ARSENIC 2109
 00727 35
 03832 11113
 390 15014
 1712


CADMIUM 0281 00727 05 03832 1.461 052 2000
 228


COPPER 2147
 00727 35
 03832 11.313 397 15285
 1743
 

LEAD 0.458 00727 08 03832 2413 085 3261
 372


SELENUM n 30171
 0.0727 497
 03832 158980 5581
 214790
 245


~NC 1.478 0.0727 24
 03832 17M 2734 10522
 120


TSS 303 00727 499
 03832 1596 560 2156 2459


EFFLUENT Daily Muinum

CHARACTERISTIC ElG Wastestreams Non..ElG Procea Wastestreams Total Allocation

Loa.,,", Row Cone Row BPJ Basis/a LcedHJ;l5

(NooHG) Like ELG bl NOILlke-ELG/c Total 

Illbida' lmad) Iml I
 lmadl lIb/davl Ib!dav\ lbIdav) I"dayl

ARSENIC :n 4 :080 00727 76
 03832 24133 573 29866
 34 4~,

CADMIUMm 0703 00727 12 03832 3704 068 4584
 529
 

COPPERm 4504
 00727 74
 03832 23733 564 29370
 3387


LEAD 0985 00727 i e 03832 5190 123 6423
 741


SELENIUM m 60342
 00727 995 03332 317961
 75521-- 393484 454
 

nNC 3590
 00727 59
 03832 18917 449 23410
 270
 

TSS 606 00727 999 03832 3192 756 3950 4555
 

(al Penmee uses lineueauren petomarce aspnmarv baSIS for operannq IfII\VTP 

(b) CalaJlaled lISlng ELG corcemanct and Noo-ElG easesreams flow 

(c)	 "Not Like-ELG~ allocaborrs oeterrmed assuming that !he follovring zinc perCl?llIagl?S ("Nollike-ElG" '1OOrUe ElG") are applicable.
 

35 1 %for Mo~ A~age
 

238 %lorDaily MaxmllJn
 

Note	 Best Professional Judgment (BPJ) mass loading allocahons developed COflSlderrrrg penntee's process 

knoWledge. wastestream ceacetscs ardlIea~ system pertorrrarce as related 10 mcreasec flow from 

rKIll-ELG wastesnearrs (irdl.de rainal) 

The draft. perrm's ElGs"Cone cacuanors meWed a1ypO, "934" msead of "834" Above cakuanons correcteo 
Nyrstar Clarksville, Inc. (Addendum to Rationale) 

NPDES PermitTN0029157 

Page AD-13 

APPENDIX AD·2
 

SUPPLEMENTAL SWPPP REQUIREMENTS (FROM PERMIT'S ATTACHMENT 3)
 

If the permittee's discharge value(s) exceed the above new permit's benchmark/cutoff values 

presented In Part 1.A, the division requires that the permittee complete investigations to 

determine the reason(s) the higher valuers) occurred and make as needed BMP improvements 

for the relevant parameter(s). The permittee must document/make effectiveness assessments 

for such BMP improvements. As a supplemental SWPPP requirement, the permittee must 

develop, and regularly update a Stormwater Report for its facility. 

The division acknowledges that the benchmark/cutoff values shown in Part 1.A may not provide 

the best datum for judging storm water contaminant BMP enhancement needs, given the 

permittee's on-site activities. The new permit requires the permittee to submit its first written 

Storm water Report to the Nashville Environmental Field Office within 18 months from the 

permit's effective date with subsequent submittals on an annual basis. The Stormwater Report 

should include the stormwater results and actions taken. as warranted. 

The Stormwater Report should note how the permittee proceeded within 30 days from the time 

stormwater monitoring DMR results were submitted to the division to develop a plan of action to 

determine the pollutant source/cause of the exceedance and potential remedies for reductions. 

Furthermore, within 60 days from the time stormwater monitoring DMR results were submitted, 

the permittee must review and as applicable make modifications to its SWPPP for reducing 

storm water contaminants to Jess than the monitoring benchmark/cutoff values for its facility. 

Generally, the division considers the "first-flush" sample to be the most accurate representation 

of the maximum daily value for various pollutants in the stormwater runoff. Furthermore, 

stormwater sampling requires the analysis of grab samples collected within the first 30 minutes 

(or as soon thereafter as practical, but not to exceed one hour) of when the runoff or snowmelt 

begins discharging, and the discharger must submit with the monitoring report a description of 

why a grab sample during the first 30 minutes was impracticable. Every effort should be made 

to collect a "first-flush" sample representative of the daily maximum values for sampled 

parameters. If stormwater discharges associated with industrial activity commingle with 

process or nonprocess water. then where practicable permittees must attempt to sample the 

stormwater discharge before it mixes with the non-stormwater discharge. 

A minimum of one grab sample shall be taken. All such samples shall be collected from the 

discharge resulting from a storm event that is greater than 0.1 inches in magnitude and that 

occurs at least 72 hours from the previously measurable (greater than 0.1 inch rainfall) storm 

event. The required 72-hour storm event Interval is waived where the preceding measurable 

storm event did not result in a measurable discharge from the facility. The required 72-hour 

storm event interval may also be waived where the permittee documents that less than a 72­

hour interval is representative for local storm events during the season when sampling is being 

conducted 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-1 

RATIONALE 

Nyrstar Clarksville, Inc. 

NPDES PERMIT NO. TN0029157 

Clarksville. Montgomery County. Tennessee 

Permit Writer: Mr. Gary Davis 

R1. DISCHARGER 

Nyrstar Clarksville, Inc.
 

1800 Zinc Plant Road
 

Clarksville, Montgomery County, Tennessee 

Site Longitude: -87.416667 Site Latitude: 36.530556 

Official Contact Person: 

Mr. Kevin Cook 

Environmental Superintendent 

(931) 552-4200 

Nature of Business: 

Production of zinc metal from the beneficiation of zinc 

concentrate ore and oxide washing by 

hydrometallurglcal processes; production of coproduct cadmium metal, sulfuric acid and 

metalluraically yaluable by-products. 

SIC Code(s): 1031 

Industrial Classification: Primary 

Discharaer Ratina: Maior 

PRIMARY INDUSTRY CATEGORY means any indust'Y cateqory listed In the 

NRDC Settlement Agreement (Natural Resources Defense Council v. Train, 8 

ERC 2120 [DD.C. 1976], modified 12 ERC 1833IDD.C. 1979]). 

R2. CURRENT PERMIT STATUS 

Effective: June 1, 2006
 

Expired: November 30, 2010 (a)
 

Application for renewal received May 28, 2010
 

(a) Administratively extended with complete permit renewal 

application. 

Watershed Scheduling 

Environmental Field Office: Nashville 

Outfall 001 LongitUde: -87.41602 latitude: 36.51781
 

Hydrocode:5130205 Watershed Group: 5
 

Watershed Identification: Cumberland-lower-Barkley Lake
 

Tarael Relssuance Year: 2015
 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-2 

R3.	 PERMIT RENEWAL CONSIDERATIONS 

1.	 The permittee requested in its permit renewal application that the new permit be 

developed excluding monitoring requirements 10r Outfall SW6, since no industrial 

activity has occurred 10r several years and low discharge contaminant concentrations 

have been monitored. As noted in Section R6 the division concurs with the permittee's 

request and Outfall SW6 monitoring requirements will be included in future permits if 

warranted based on subsequent permit renewal Form 2F results. 

2.	 The new permit includes the following additional requirements: 

a.	 As described in Section R12, a wastewater treatment earthen basins integrity 

evaluation is included as a new permit requirement. 

b.	 The 90%, receiving stream water quality allocation from the permittee's current 

permit has been retained for the new permit. However, based on division policy 

for non-wadeable receiving streams the division frequently uses an allocation up 

to 50% of the water quality criteria for individual dischargers. Since water quality 

allocations are related to the types and number of dischargers, the specific 

allocation will be defined with each permit renewal. 

c.	 Applicable technology-based Outfall 001 discharge mass loadings for process 

wastestreams were determined based on relevant EPA Effluent Limitations 

Guidelines (ELGs). For process and dilute wastestreams nol subject to ELGs, 

Best Professional Judgment (BPJ) assessments were completed to determine 

applicable Outfall 001 discharge mass loading allocations pursuant to the criteria 

presented in Section R7 and Appendix R-4. The new permit requires the 

permittee to also submit its Monthly Operating Reports (MOR), which will be 

useful for BPJ determinations lor subsequent permit renewals. 

e.	 As noted in Section R9, updated TMSP "Cutoff/Benchmark" discharge values 

were included in the new permit. The Cutoff/Benchmark" discharge values are to 

be used for determining the effectiveness of BMPs and are not actually 

discharge permit limits. 

f.	 The permittee's new crude zinc oxide (ClO) washing facility discharge's 

contaminant loadings were determined based on BPJ evaluations, which 

translated to a de minimis water quality impact on the receiving stream. This is 

discussed in Sections RS, R9, R10 and Appendix R-5. The new ClO facility 

resulted in additional Outfall 001 treated effluent monitoring parameters (total 

dissolved solids, conductivity, chlorides, and fluorides) being included in the new 

permit. Also, the new permit includes monitoring requirements for the CZO 

washwater, using a new monitoring location (Internal Outfall 01A). 

R4.	 PERMITTEE'S OUTFALLS, TREATMENT SYSTEM, AND RECEIVING STREAMS 

The permittee discharges treated process wastewater, sanitary wastewater, stormwater 

and cooling water through Outfall 001 to the Cumberland River at mile 1.22. I~ternal Outfall 0.1 A 

results will be used for monitoring the CZO washwater. Demineralized reqeneration 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN00291 57 

Page R-3 

wastewater, water plant overflow and filter backwash is discharged via Outfall 002 to an 

unnamed tributary to Cumberland River at mile 122.6. Stormwater runoff subject to industrial 

activity and cooling water discharges through Outfalls SW3 and SW5 to the Cumberland River 

at mile 121.1 via an unnamed tributary. Stormwater runoff from Outfalls SW4 and SW5 drains 

to an unnamed tributary then to the Cumberland River at mile 122.6. Appendix R-1 presents 

the permittee's discharges. receiving streams information, and a schematic diagram of the 

permittee's physical/chemical wastewater treatment plant. The permittee recently installed 

crude zinc oxide wash facility includes pH adjustment, precipitation, polymer addition and 

sedimentation control systems. 

RS. CURRENT PERMIT LIMITS AND MONITORING REQUIREMENTS 

Appendix R-2 presents the permittee's current permit discharge requirements. 

R6. DISCHARGE MONITORING REPORT (DMR) AND INSPECTION RESULTS 

The permittee's Discharge Monitoring Report (DMR) results for the current permit are 

provided in Appendix R-3. These results demonstrate that the permittee did not have any 

appreciable difficulty in achieving its current permit's treated effluent discharge limits 

monitoriing requirements. 

The permittee indicated that the Outfall SW6 discharge no longer receives stormwater 

subject to industrial activity and requests that no monitoring be required for the new permit. As 

shown in Appendix R-3, the Outfall SW6 discharge contaminants (which might be from past 

activities or fugitive emissions) are much lower concentrations than those for Outfall SW5. As 

such, Outfall SW6 monitoring pursuant to the new permit will not be required. However, the 

permittee must include a completed Form 2F for Outfall SW6 with its next permit application. 

Division personnel from the Nashville Environmental Field Office performed a recent 

Compliance Evaluation Inspection (CEI) for the Nyrstar Clarksville, Inc. facility on February 15, 

2011. The inspection report noted minor deficiencies. 

R7. TECHNOLOGY- BASED EFFLUENT LIMITATIONS 

Technology-based effluent limitations are applicable to wastestreams subject to the 

federal Effluent Limitation Guidelines (ELGs) and for those which ELGs do not exist, the 

division uses Best Professional Judgment (BPJ) for treatment performance-based discharge 

allocations. As presented in Appendix R-4, this approach was used for developing the new 

permit's technology-based discharge requirements/allocations. The October 4, 2000 document 

"Chronology of Effluent Limitation Guidelines for Metallurgical Acid Plants", developed as 

background information for permit renewals is available in the permit file. 

The permittee's SIC code is 1031 (Lead and Zinc Ores). Process wastewater 

discharged through Outfall 001 is regulated by 40 CFR Part 421 - Nonferrous Metals 

Manufacturing Point Source Category and applicable ELGs and mass loadings discharge 

allocations for various wastewater contaminants subject to Subpart H - Primary Zinc 

SUbcategory and SUbpart I - Metallurgical Acid Plants, are provided in Appendix R-4. 

Appendix R-4 also presents the BPJ rationale for technology-based discharge 

allocations for the permittee's non-ELG wastestreams. The BPJ determinations were based on 

contaminants considered present and were derived from process knowledge, treatment 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES PermitTN0029157 

Page R-4 

performance results/treatability information, and the permittee's primary treatment focus on zinc 

control. 

RB. WATER QUALITY CONSIDERATIONS 

Appendix R-5 presents water quality evaluations/calculations for determining discharge 

permit requirements based on the division's reasonable potential approach. The water quality 

calculations provided in Appendix R-5 are specifically focused on water quality requirements 

related to heavy metals and toxic organics. 

The water quality calculations for the permittee's washwater trorn its recently-installed 

Crude Zinc Oxide (CZO) washing facility are also presented in Appendix R-5. The permittee 

has indicated to the division that its washwater discharge presents a de minimis loading on the 

receiving stream (as evident by calculations provided in Appendix R-5). The permittee is 

currently investigating testing several CZO source materials to determine which ones are 

acceptable for its manufacturing purposes. As such, the new permit's reopener clause has 

provisions for modttication if warranted based on CZO washwater characteristics. 

R9. NEW PERMIT LIMITS AND MONITORING REQUIREMENTS 

The proposed new permit limits have been established by determining a technologybased limit and evaluating if that limit protects the receiving stream's water quality. If the 

technology-based limit would cause water quality violationts) the new permit includes the more 

stringent water quality-based discharge limit. The technology-based limits were determined 

from EPA effluent limitations guidelines as applicable; or from State of Tennessee maximum 

effluent limits for effluent limited segments per Rule 1200A-5-.0B; or by way of operational 

and/or treatability data pursuant to BPJs. Furthermore. effluent limitations in this permit must 

comply with any approved Total Maximum Daily Load (TMDL) studies. Appendix R-B lists all 

proposed effluent limitations and monitoring requirements to be included in the new permit. 

Note that In general, the term "anti-backsliding" refers to statutory provisions that prohibits as 

applicable, the renewal, reissuance, or modification of an existing NPDES permit that contains 

effluents limits, permit conditions, or standards that are less stringent than those established in 

the current permit. 

The rationale for including discharge parameter limits and monitoring requirements in 

the new permit for the permittee's various outtalls are presented SUbsequently, pursuant to the 

followings outtalls: 

• Outfall 001 

• Internal Outfall 01A 

• Outtal' 002 

• Outtalls SW3. and SW4. and Outtall SW5 

Outfall 001 Discharge Parameters 

Flow - Outlall 001 
Nyrstar Clarksville, Inc. (Rationale) 

NPOES Permit TN0029157 

Page R-5 

Flow monitoring allows the mass loadings for discharged contaminants to be calculated. 

Flow must be reported in Million Gallons per Day (MGO) and monitored continuously using a 

recorder. 

pH - Durtall 001 

According to the State of Tennessee Water Quality Standards [Chapter 1200-4-3-.03(3) 

(b)1, the pH for the protection of Fish and Aquatic Life for large rivers shall lie within the range of 

6.5 to 9,0 and shall not fluctuate more than 1.0 unit in this range over a period of 24 hours. 

Based on the size of the discharge and the available buffering capacity, a discharge pH of 6.0~

9.0 is considered to comply with the standard. The sample type will be grab, measured at a 

frequency of once per week (1/week). 

Total Suspended Solids (TSSI - Durtall 001 

Total Suspended Solids (TSS) is a general indicator of the wastewater quality and will be 

limited in the new permit. The new permit includes technology-based TSS discharge limitations 

(monthly average and daily maximum amount limits of 2,459 Ib/day and 4,555 Ib/day, 

respectively) 

The State of Tennessee Water Quality Standards tor the protection of Fish & Aquatic 

Lite [Chapter 1200-4-3-.03(3) (c)] state there shall be no distinctly visible solids, scum, toam, 

oily slick, or the formation of slimes, bottom deposits or sludge banks of such size or character 

that may be detrimental to fish and aquatic life in the receiving stream. 

Considering the nature of wastewater collection and discharge system the sample type 

will be composite, measured at a frequency of once every two months (1/2 months). 

Heavv Metals - Curtail 001 

The new permit includes discharge mass loading monthly average and daily maximum 

limits for arsenic, cadmium, copper, lead, selenium, and zinc. The discharge limits for arsenic, 

cadmium, copper, lead and zinc were determined based technology-based effluent limitations. 

The selenium discharge limits were based on water quality criteria. 

Escherichia coli IE. call) - DuHall 001 

Although sanitary wastestreams are included in the permittee's Outfall 001 discharge as 

noted in the current permit, E. coli limitations/monitoring are not warranted, because the division 

considers the acidic value and hydraunc retention time afforded by the permittee's treatment 

pond(s) to be adequate for disinfection. 
Nyrstar Clarksvilte, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-B 

LC50 and IC25 - Outfall 001 

Since the receiving stream to Outfall 001 discharge flow ratio is greater than 500: 1, the 

division has determined that biomonitoring limitations/monitoring will not be required during this 

permit cycle. 

Conductivity, Total Dissolved Solids, Chlorides and Fluorides - Outfall 001 

The new permit includes weekly treated wastewater monitoring based on composited 

samples for conductivity, total dissolved solids, and chlorides. The Outfall 001 effluent fluorides 

must be monitored on a monthly basis. 

Internal Outfall 01A Parameters 

The follOWing Internal Outfall 01A monitoring requirements were included in the new 

permit due the permittee's recently-installed crude zinc oxide (CZO) washing system and the 

division's need to collect its washwater characteristics to insure that applicable discharge 

requirements are included in the permit. 

Flow -Internal Outfall 01A 

The permittee must measure and report its CZO washwater flow (in units MGD). Flow 

values will be used to calculate contaminant loadings trorn the washwater. 

pH - Internal Outfall 01A 

The CZO washwatar pH must be monitored and reported based on grab samples. 

Total Suspended Solids jTSS\ -Internal Outfall 01A 

Wee~ly, grab Internal Outfall 01A washwater samples must be monitored for TSS. 

Conductivity, Total Dissolved Solids. Chlorides and Fluorides -Internal Outfall 01A 

The new permit includes weekly monitoring requirements based on grab samples for the 

Internal Outfall 01A parameters conductivity, total dissolved solids, chlorides and fluorides. 

Outfall 002 Discharge Parameters 

Flow - Outfall 002 

Flow monitoring allows the mass loadings for discharged contaminants to be calculated. 

Flow must be reported in Million Gallons per Day (MGD) and monitored at the time of sample 

collection. 

pH - Outfall 002 

According to the State of Tennessee Water Quality Standards [Chapter 1200-4-3-.03(3) 

(b)], the pH for the prolection of Fish and Aquatic Life shaune within the range of 6.0 to 9.0 and 

shall not fluctuate more than 1.0 unit in this range over a period of 24-hours. The sample type 

will be grab measured at a frequency of once per week (l/week). 
Nyrstar Clarksville. Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-7 

Total Suspended Solids (TSSl - Outlall 002 

The water quality narrative TSS criteria noted above for Outfall 001, also applies to the 

Outlall 002 discharge. 

Total Suspended Solids is a general indicator of the quality of a wastewater and will be 

limited in this permit. The State of Tennessee Rule 1200·4~5. which held effluent limitations for 

industrial wastewater treatment plants, was revised in July 2004 and this limit was removed. 

However, the daily maximum concentration for TSS of 40 mg/I will be retained from the current 

permit to comply with the "anti-backsliding" statutory provision. 

Considering the nature of wastewater collection and discharge system, the sample type 

will be grab measured at a frequency of once per week (1/week). 

Settleable Solids - Qutlall 002 

The current permit limit for Settleable Solids of 0.5 mill daily maximum concentration will 

be retained in the new permit to comply with the "anti-backsliding" statutory provision. 

Considering the nature of wastewater collection and discharge system, the sample type will be 

grab measured at a frequency of once per week (1/week). 

Total Residual Chlorine - Outlall 002 

The daily maximum limit of 0.019 mg/I for Total Residual Chlorine (TRC) will be retained 

in the new permit. The new limit is based on the TN Water Quality Standards applied to a low 

flow stream condition of 0.0 MGO. The background concentration of TRC is assumed to be 0.0 

mglL. 

The acceptable methods for analysis of TRC are any methods specified in Title 40 CFR, 

Part 136 as amended. The method detection level (MDL) for TRC shall not exceed 0.05 mgll 

unless the permittee demonstrates that its MOL is higher. The permittee shall retain the 

documentation that justifies the higher MOL and have it available for review upon request. In 

cases where the permit limit is less that the MOL, the reporting of TRC at less than the MOL 

shall be interpreted to constitute compliance with the permit limit. Please note that any TRC 

detected at or above the MOL will constitute a violation of the permit. 

The sample type will be grab measured at a frequency of once per week (1Jweek), and 

the compliance point for total residual chlorine is at the confluence of the discharge and the 

receiving stream. 

Outfalls SW3, SW4, and SW5 Discharge Parameters 

This facility is one which has stormwater runoff associated with industrial activity, as 

defined in 40 CFR 122.26 (b)(14). Effluent monitoring requirements for outfalls designated as 

SW3, SW4, and SW5 where developed and are applicable to wet weather discharges from the 

permittee's facility. 

For the new permit's stormwater runoff benchmark/cut-off parameters to be monitored 

and reported were determined by comparing the permittee's discharge OMR data, the permit 

renewal application Form 2F results, and the following updated Tennessee Stormwater MultiSector General Permit for Industrial Activities (TMSP) criteria. 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-8 

Parameters of Concern Cut-Off Concentration [mg/L] 

Cadmium (TJ 0.0159 

Total Susoended Solids rTSSI 150 

coooer tt) 0.0636 

Lead 'J 0.156 

pH (range) 5.0 - 9.0 

Total Recoverable Zinc 0.395 

Note: Sample values are from the Tennessee Stormwater Meltt-Sectcr General
 

Permit for Industrial Activities, Rationale, Pari Ill, Table Ill-A: Parameter Benchmark
 

Values.
 

Consistent with the permittee's current permit "benchmark/cut-oH concentrations" will be 

used 10 evaluate the effectiveness of the permittee's stormwater BMPs for the facility. If the 

permittee's discharge exceeds the above new permit's benchmark concentration the division 

requires that the permittee complete investigations to determine the reason(s) the higher 

valuers) occurred and make as needed BMP improvements for the relevant pararneterts). The 

permittee must documenVmake effectiveness assessments for such BMP improvements. A 

wide array of improved/enhanced BMPs exist for making stormwater runoH quality 

improvements. BMP upgrades may be applicable to the permittee's stormwater controls (new 

permit Part IV BMP Plan andlor Part V SWPPP). 

There are no effluent guidelines for stormwater dischar:ges from the Nyrstar Clarksville, 

Inc. facility, The permittee's current permit did not have effluent limitations for the facility's 

stormwater runoH, and all parameters were monitored on a "Report" only basis. Similarly, the 

new permit will not establish effluent limitations, but will require reporting of effluent 

characteristics for the Outfalls SW3, SW4, and SW5 discharges due to stormwater runoff. 

In order to assist the permittee in the evaluation of the effectiveness of the SWPPP, 

benchmark values developed for the Tennessee Stormwater Multi-Sector General Permit for 

Industrial Activities are provided herein for comparison. These benchmark values (cut-off 

concentrations) were developed by the EPA and the State of Tennessee and are based on data 

submitted by similar industries for the development of the multi-sector general stormwater 

permit. The cut-off concentrations are target values and should not be construed to represent 

permit limits. 

The division recognizes thai a "first-flush" sample would be the most accurate 

representation of the maximum daily value for various pollutants in the stormwater runoff. 

Furthermore, stormwater sampling requirements included in the TMSP require analysis of grab 

samples collected within the first 30 minutes (or as soon thereafter as practical, but not to 

exceed one hour) of when the runoH or snowmelt begins discharging. Every effort should be 

made to collect a "first-flush" sample representative of the daily maximum values for sampled 

parameters. 

Flow Outfalls SW3, SW4, and SW5 

Flow monitoring allows the mass loadings for discharged contaminants to be calculated. 

Flow must be reported in Million Gallons per Day (MGD) and monitored at the time of sample 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN00291S7 

Page R-9 

collection. In general, the division does not establish flow benchmark values for individual 

permits, unless based on the specific site conditions/inspection results it is obvious that the 

stormwater runoff is hydraulically adversely impacting the receiving stream characteristics and 

BMPs (e.g., velocity dissipation structures) are warranted. Flow monitoring is being retained 

from the current permit. 

TSS Outfalls SW3. SW4. and SWS 

The receiving stream water quality narrative requirements for stormwater TSS control is 

basically the same as that noted above for Outtalls 001 and 002. However, stormwater runoff 

typically results in higher TSS concentrations due to soils erosion. For large diversified 

industrial facilities, higher TSS concentrations in stormwaters might indicate the need for 

increased in-plant housekeeping, including dust controls. The current permit includes 200 mg/L 

as the TSS benchmark value, which was based on the prior TMSP. However, the new permit 

includes a 150 mglL TSS value, based on the division's most recent TMSP. 

pH Outfalls SW3. SW4. and SWS 

The basic rationale for pH monitoring is the same as that noted above for the 

permittee's Outfall 001 and 002 discharges. The pH benchmark/cutoff monitoring requirements 

from the current permit (5.0 - 9.0 s.u.) will be retained for the new permit. Monitoring the 

stormwater pH can also provide valuable information regarding locating on-site leaks or spill. 

Heaw Metals - Outlalls SW3. SW4. and SWS 

The stormwater discharges from Outfalls SW3, SW4 and SW5 must be monitored for 

the heavy metals, cadmium, copper, lead, and zinc based on grab samples. 

R10. ANTIDEGRADATION CONSIDERATIONS 

Tennessee's Antidegradation Statement is found in the Rules of the Tennessee 

Department of Environment and Conservation, Chapter 1200-4-3-.06. It is the purpose of 

Tennessee's standards to fully protect existing uses of all surface waters as established under 

the Act. 

Stream determinations for this permit action are associated with the waterbody segment 

identified by the division as segment ID# TNOS 13020S01S_2000. 

The division has made a determination of the receiving waters associated with the 

subject discharge(s) and has found the receiving stream to be available conditions waters. 

Available conditions exist where water quality is better than the applicable criterion for a specific 

parameter. The applicant has demonstrated to the department that reasonable alternatives to 

new or increased degradation to the available conditions waters are not feasible. 

The department has maintained, and shall continue to assess, the water quality of the 

stream to assure that the water quality is adequate to protect the existing uses of the stream 

fully, and to assure that there shall be achieved the highest statutory and regulatory 

requirements for all new and existing point sources and all cost-effective and reasonable best 

management practices for nonpoint source control. 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R·10 

The following approved TMDL has been issued for several receiving streams within the 

Cumberland - Lower Barkley Lake watershed. 

Parameter TMDl Approval Date 

E. coli December 26, 2007 

This TMDL's provisions are not applicable to the permittee's dischargers because the 

plant's discharges do not drain to the specific receiving stream segments noted in the TMDL. 

Also, as noted in Section R9, E. coli is not a discharge parameter of concern. 

As shown in Appendix R-5 and discussed in Section Ra, the additional chloride and 

fluoride loadings in the washwater from the permittee's newly-installed Crude Zinc Oxide (CZO) 

facility presents a de minimis impact, since these parameters use less than five percent of the 

receiving stream's available assimilative capacity. 

Rll. BMP AND SWPPP CONTROL PROGRAMS 

The division does not want/require redundant control plans. As such, the new permit 

allows the permittee to develop a single comprehensive BMP/SWPPP control plan, by 

consolidating elements presented in the new permit's Part's IV (BMP) and V (SWPPP). The 

division considers the receiving stream water quality proteclion afforded by a BMP/SWPPP 

program to be warranted lor the permittee's large industrial complex, The permittee's new 

permit does not include specific monitoring requirements/limits for all contaminants which might 

be expected in the permittee raw wastewater intermittently due to leaks/spills and/or from 

stormwater runoff, for which the permittee's treatment system is not expected to remove 

because of characteristics/loading, Thus, the division requires the permittee to implement, as 

an integral part of its wastewater control system a BMP/SWPPP program, which includes 

housekeeping measures to better handle the contaminants which would otherwise flow to the 

permittee's wastewater treatment plant. 

The division considers that the new permit BMP/SWPPP program requirements can be 

achieved by the perrruttee using its reasonably available materials/plans, which can be updated 

based upon site conditions/operational needs, Therefore, the finalized permit includes the 

following introductory statement in Parts IV and V: 

'The permittee may consolidate the elements presented in Part IV (Best Management 

Practices Conditions) and Part V (Stormwater Pollution Prevention Plan) into a single 

BMP/SWPPP document as an overall control program for its facility" 

R12. WASTEWATER TREATMENT SYSTEM INTEGRITY EVALUATION 

The permittee must within eighteen months from the permit's effective date submit to 

TDEC's Nashville Central and Environmental Field Offices (Division of Solid Waste 

Management) and Division of Water Pollution Control - Permit Section) a report which 

addresses the structural integrity of any earthen basins associated WIth its wastewater 

treatment facilities and any waterborne waste and sludge storage/disposal units that are 

constructed of earthen fill. 

Upon submittal of the structural integrity assessment and based on recommendations 

and/or qualifiers provided in the report, TDEC and the permittee will determine what, if any, 
Nyrstar Clarksville, Inc. (Rationale) 

NPOES Permit TN0029157 

Page R-l 1 

improvements will be required. Based on the potential for harm to human health as described, 

additional site specific evaluations may be required. 

Requirements to include permit provisions deemed necessary to protect waters of the 

state, are based on T.C.A. § 69·3·108. It is expected that the permittee's structural integrity 

submittals will be reviewed by the division's Water Pollution Control and Solid Waste 

Management personnel. Although it has not been determined at this time, the division may 

request additional evaluation input from its outside consultants and/or the U.S. EPA. 

R13. PERMIT DURATION 

The proposed limitations meet the requirements of Section 301(b)(2)(A), (C), (0), (El, 

and (F) of the Clean Water Act as amended. It is the intent of the division to organize the future 

issuance and expiration of this particular permit such that other permits located in the same 

watershed and group within the State of Tennessee will be set for issuance and expiration at 

the same time. In order to meet the target reissuance date for the Cumberland-Lower-Barkley 

Lake watershed and following the directives for the Watershed Management Program initiated 

in January, 1996, the new permit will expire in 2015. 
----

Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-12 

APPENDIX R-l 

PERMITTEE'S DISCHARGES, RECEIVING STREAMS, AND WASTEWATER TREATMENT 

SYSTEM 

OUHlIlLOOl 

LOIJGITOOE lATITUOE
 

,'V'1",};; J'i ;1Te1
 

"''' Flo...... and W".te'!!",,'" 'iour~e.

'''''::d OO',ot C",m, 

~",,...,c"" p'oe, '(-'0"'''''01«
 

Ch Ano<!e.Ci'thGde 'Nash
 

ee:; HJ"3~ 8:~
 

Ca~ 1'0'''' Cort'CllDUS Cool!
 

Co~~nU3l" ~e~~"
 

OtrtIall 

ELG Wastesu"am. 

'-25 

'09 

': 0) 

I: l,' 

000 

, so 

51.1)4 

PlOee.. Re'ated Wasoostreams 

': 

S, 3,' 

':' so 

2, SC 

~~ 00 

2li8.5J 

Non_HG Was«>sITeam;

,I" 

0' 

) ,-", ,- cC, 

-fi: 

.; 0(, 

'" "' oem 

430,59 

Treatment: 

0.013 m tt.s .. • 

<':('0,1", '·'_'o;!".,ol",
 

'Gas '='e"~,"o
 

0013"
 

Cel:Ho_,,"
 

f.I.lal, "'~o -,.'"
 

0,181 m • 62.A , ~~","

e,,':~' Blc',dOI 

Au;P;",,: 

,Cent-a ~"t

'U.I"', R",,,"_,,,,,, 

'>:.ad~

;C"eoto;d t·, c, sc'" OO:_nd 

0,16ll m,. n.~ ,

0,62\1 m • 100.0 , 

Chemical precipitation, mixing, !!.edimentation, coagulation, jloccujation, anti neulralization, 

OIJTFALL 001 RECEIVli'lG STREAM 

(umbe,I""d Rive, "I mile 122 

STREAM LOW tete 

i "'" HOWIMGOI 1.696 1.101 I

RECEIVIItG STREAM OESIGNATED USES 

.'.Q ,>< REUlEA"'l(IIj "~~T;':;j,

X x "';'c ';~'·.'G."lON

x x 

'IS" , ,"",',', J01"S~-C

X X X 

'iCL'S 

OUTFAll 002 RECEIVING STREAM 

OUTFALL 002 

lDNGITUW: • LATITUDE 

T-2l-16 36-3'-'11 

I 

I 

I 

unnamed tributtlly to !he ClIIlIbertand River at mile 122.6 

STREAM lOW 1010 300' 

FlOW(MGOI 00 :' 0 

Uon-ElG Flows andWa$le$l1eam SOUfc.ef 

'6 DemlnHailLe' R<=generale Waler RECEMIfG STREAM OESIGttATED USES 

';,2 ',"; ate- P'3l1~ C',eI11JIi'fI~er B1Kkl'lash 

". 0,110 m d 

'~" I ~,) LFE 

x ~;:lVIno~

X 

"--""",,no'. 

x ~"iU,

X 

oces-r 

Treatment: Neutraljzation and sedimentation nus"'<l4' !J~'1GATI(llj
Nyrstar Clarksville, Inc. (Rationale)
 

NPDES Permit TN0029157
 

Page R-13
 

OUTFALL SM ~ECEIVING STREAM 

LONGITUDE LATITUDE DISCHARGE ROUTE 

-67-2J-16 36-~B unnamed triboJllll'y 10ttle Cumberland Rwr ;1\ mrle 121 1 

flOW DISCHARGE STREAM LOW 1010 1010 3005 

(MGD) SOURCE FLOW CFS 00 00 00 

veees StomrwiltPl I'Jncrltand Gooh ••• MGO 00 00 00 

ST~£AM USE CLASSIFICATIONS ATER QUALl 

,~e RfCHtAfI;ltl I<Raj.. ToJll ,>'i~"i CQIIi'S"-": 

X X x X 

IlIDUS'lU>L r'AVIGATl.:'tI 

Varies TOTAL DlSCHARGl 

Treatment collection and en to wastewater nearmeot 31 % of the runoff 

OUTFAll SW. RECEIVING STREAM 

LONGITUDE LATITUDE DISCHARGE ROUTE 

..1j7·2~·20 36-31-12" unnamell tnbutilf"l til tile Cumberland Rr,ef at m'l~ 1:'26 

flOW DlSCHARG£ STRE.Alol LOW 1010 1010 3005 

(MGD) SOURCE FlOW rcrs 00 00 00 

Vanes Stormwater runoff and co,", ••• MGO 00 o.c Q 0 

STREAM USf CLASSlFIC.A TIONS ATER QUALl 

"e RfC.REATCtI JffiG'o TO/, L"'!~' [)OVESTtC 

X X x X 

~""""- MVIGAIDN 

Varies TOTAL DISCHARGe 

Treatment None 

OUTFALL SW5 

LOHGITUDE LATITUDE 

-87-25-00 36-31-15 

D: DISCItARGE STRE~Cl~ 1Ql0 1010 

(MGOf SOURCE now CFS 00 00 00 """ 

Vanes Slomtwatef lunoff MGO 00 00 00 

STREAM USf CLASSlfK:ATIONS MER QUALl 

F;St; RfC~E"71O~ 1R'l/.::"'-TK'~ c'·, ;", ccees-« 

x X X X 

t«luS"Ri4l ~"'VIG"'T(J1l

Varies TOTAL DISCHARGE 

Treatment- None 

OUTFAll SM RECEIVING STREAM 

LONGITUDE LATITUDE OISCHARGE ROUTE 

.B7-ZS-00 36-31-30 unnamed tnbuliJl"! to lhe Cumt.eriand Ri'ief at mile 122 6 

FLOW DlSCHARG£ STR~~ct~ 1Q10 1010 3QQ' 

~MGOI SOURCE now CFS 00 00 00 

Va"es Stoonwaler runoff MGO 00 00 00 

~TRt:AM USf CLASSIFICATIONS WATER QUALl 

f!S~ l'lfCRt:ATKl~ MG"TOll LI',~':' C'OM,o;;--,: 

X X X X 

t£>uSTl'Ac rio>.V1GAmN 

Varies TOTAL DISCHARGE 

Treatment None 

IlfCEIVING STRfAM 

DISCHARGE ROUTE 

unnamed Inl>ulw} I~ too l"umbeftand RMlI at m,le 121 1
 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-14 

WWTP - Schematic Diagram 

o 

,---~~

r:

t 

" 

i

-r=---i

. 

L d.o.-+---H 

.,,- ----8 

'9f2m 

(38 

~~)

~D I 

, --- --~
-- -- --

-- -- --

Nyrstar Clarksville, Inc (Rationale) 

NPDES Permit TN0029157 

Page R-15 

APPENDIX R·2 

CURRENT PERMIT LIMITS AND MONITORING REQUIREMENTS 

PEIMTUr.t1S 

C1IIFPUOO1 

flR)l :e;.e; W§TEWA'THI 

............LJIIIT_
 MCHICRN> 

MClmLY 

-

IEURIHNIS 

"". 

10.88 1MAlek 

1876 1I2fvt:ffu; 

1MAlek Q:t> 

MlY 

.................CXH:. ..... _. _CXH:. -_. _. ........ --..rot...,. .....". . ...,,' cmi.-u:us 

ARSB«: -- 1all -- 29.8 9<m-<n1.D 

CAlM.... 1.76 -- 4.40 2Mnh 

ca'l'<R -- 14.10 -- 29.52 lIQater 

lEAD ~'" fi28 1IQa1e< 

sam.... -- 11.a:' ffi.34 SaTi-<rn..aI 

2INC 25.:<> 

TSS -- -- 372l 

....... F9'rn 6.0·9.0'" 

• ROoIv'S"al1 be n:.p:ltOO in Mllial<1II1cr"6 PerDery (MD) 

- '"""-"'" be ""'ooml"""""'" (15) rnn..<es ct..,-pe"'""",,­

I .....,.lN1S I 

0Jl1'IU"" _1JMIIlJItNi 

-

M:NllR£ 

IoDIDt.Y ....Y -.......ns
 

.cccoc """arc """MM MIM<T. !W\ftE

QfWLIBlSliC ( ( f1QlY. nB:

Rl>N l!;g.. ccmccs .... aO-90 1M!>« 

""""

"'" 

ror"-SlIlI'ENBlSWIll{1llS 40.0 1M!>« "'" 

SEI11.B&.E 05"" 1M!>« "'" ~~,eatJAL 001. 1M!>« "'" . A:w9"ulte rq:n1Ed il Mien G*J'8 pe-CDj~. . ~<rd lFC~9"uI te Wlti1 fiIlEErl (1~ I'I"i'l1es agrpe a:Je:::titn

- Tt"e1J'l'l'f1i'He ITlthxts fereesss d lFC<re <Df ITEtto:Is il Tille 4Ja:FI. Pat 133aserecer lte Il'Btu:IcblDi:n ea 

tr lFCstaI rrr 6IlE6:l QC5rrg1i.d:ss ee pmilIeed::r1 U B1<Dstht itsM:Lis I'i;t'a". lte staI rEt:i1lted:usrH'tfi:n 

tta. jlSife; tre t1oj'u M:La-d ree it ferre.iEwLp:nreaes. Incases hl parrit imI 

islessIta:set.n... eerq:xrti"g d TFCctlessltB1lte Ml...!hlII00i1a'ptta:lIoCIl"l'illl.Je UJ I f:Ia u:: Wlh lte perm liTiL 

1l'e c:crrpiln::e IX*t b'tai'Jll'I!lllIclR d'bft is allhto::riluen:ed 1tv~1n:l1'e~veIEn. 
--

Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-16 

PERMT U'"'" 

CJJTFAllS SW3 and SW/I
 

stcern water RIroff, steam Producecl caoensate and"'scalanecus Non-Process water
 _v EFFllENTUMTAlIONS MllNlURlNC

DOIlV REOlIREMENl' 

EFfl.lENT AVG.CONC AVG AMlloT.

otARACTBlISlIC FRQNC\'. n .. 

FlOW 1/OJarter Estimate

pH 1/OJarter Om"

TOTAL SUSPENDED SOUOS(TSS 1/OJarter Ocab

CADNlIJv'I, TOTAL 1I0Jarter Gcab 

COPPER,TOTAL 1JOJarter Gcab

MAX.<DNC MAX.AMl\ET. M'iRMNT. "'W'LE 

I.... .... MGO • (~ MGO • 

- -

--

-- ""'" 

lEAD, TOTAL 1/0Jarter Gcab 

ZINC, TOTAL 1/0Jarter Gcab 

Flow shall be reooted in ~1Iicr1 Gallons per Day (r-IGD). 

•• pH analysesshall be perfcme:::l v.ilhin nflOO1 (15) rrinutes of sarrpe ccaectco. 

The perrrittee shall provoe Itle I1':I.le and duralioo (In f-ours) 01 the ~lftyif"'J slam ~(s) sarrped; rainfall rreasurements exestimates 

(in Irdles) of the stern eveot that generated the serrpled nron the duralioo belY.eoo Itle storm ewnt serrped am the en:J of the 

pecocs rreascrebe (g-ealer than0.1 irdl raJnlall) stern event. ero an esereie ollhe total'odllTE! of the discharge seooeo. F\oN shaJl 

be rernrted In Milo-. Galkns per Day (M:iD). 

I 

_V 

EFFUJ!N1' AVG.<DNC 

otARACTBlISlIC 

FlOW 

pH 

roTAL. SUSPENDED SOUDS{TSS -

CArMUM, TOTAL -­ COPPER,TOTAL -­

lEAD, TOTAl.. 

ZINC, TOTAL 

. RO\'Ishall be reccteo in Mllim Gallons pee Day (M3Dl .. pH analyses shall be perrorreo v.ilhin Hfleffl (15) rrinules of sarrpe colectco. 

The pernnee shall provide!he I1':I.le and duratOl (in hours)of the ~lif;''lOg srom event(s)S<lIl"Ped; rainfaJl rreasuereus exestimates 

(In Irdles) of !he storm eveuuet generated!he sarrpled I1J"Off; !he durahcn1:leMeen!he storm event serrped ard!he em 01 !he 

prENioJs rreasoratse (greaterthan0.1 irdl ramlall)SICfTTl event; arc anestimateof the lDIaI ',Oll.lre of !he disdlarge sarrped F\oN shall 

be rep::lf1ed in Mlhcn Gallcns per Day (M:iO) 

PERMT U,"", I 

OUTFALL SV1/5 andSV'I'i stoon _ RuOOff 

AVGAMNT. 

j ,,"
 MGO ' 

EFR.lENTUMTATKItS MllNlURlNC 

DOIlV REQUREr.en5 

MAX.<DNC :\tiJt'\I!'H. So\.'l.tI'I...L 

( FRQNC\'. 1'\:'ft: 

MGO ' Seni-annuall Estimate 

Seni-annuaJl "'''' 

""'" - Seni-annuaJly ereo 

Seni-annuall 

Seni-annuall 

"''''

Sem-annuall 

"''''

Seni-annually 

"''''

"'''' 
APPENDIX A·3 

DISCHARGE MONITORING REPORT (DMR) RESULTS 

Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page A-17 

TNOOZ9161 DMR Summa outran 001 

., rss Ca<lmi"", line AI...nie Seienillm C""'.. Lead 

-­ _._~

OmlD OM.. Mil'") ""'" fAA... rn~ ,,., otJ., "'. OM., I.IA''!} DM'" I,ll,,?,] OM., '.I~'~"I,DM"" r"J Ibid•. .'. '" da" 'IO'd• '!t"3a" Ib. ., ". a ' Itr'd ' 

\i.G .. un ,m ,." .. 10.~ "» an ,.. lUl2 U.J.t ,.", ,,~ H3 s.a 

s r .. ,,,,. "'~ 01>614 141&5'.l ~.~ 7n6'.l ""0­ 11001: IJOOI- uou 

s.e " 04'.lt1 'ill" 51'1m s 221f>l 

ez ea 413t11 413417 0%27 1 UW,.8 6~W.) a~O'Ji" c 162.1­ J 324~

e t "' 111!ll.1 12nw 77?IH5 a -\45t2 

az " "",. 484JOii oeess U 9148 s Mt21 B!J4542 

ar " "'" 0416<1 .~m 9 )"~27 , 

"' a.a 23.324 2J.:124 o 1'J1io8 c BlI6l1 104006 t259-l'.l N{)C~: "'". uoo. ~IClOI

.. es 08105 O~Ul '.l11~ 11 02111 

"' " TJ '.l704 13 9'().l 06321 o '-I72J a 293!i3 ':147745 

s t ar c 7UJ 0) /6%'.1 714134 8472i>1 

az a t 4$ 1152 4511,2 c 70f-; G84Ml 912/01 117n2 

s , as t "'" 1HV6 101S27 113474 

er a r 302878 ~"n '"'' 1 5~3J7 7STI31 '.I912\}3 sec­ """ flODt- NODIs t " Q 811 1.202&5 I 411~) 1091U 

a t e.a 17 :.34S 17~34S ueeas 0_ 8.24_79 10().l1] 

r a " 1 0248 1 08406 15m' s 51~91

• as J~ 11.\.6 467146 '~M 1 0!i107 74·\33B B8J'141 

25 '" o 91S7 101626 622346 IlJ,~ --'-­ S2a 00. I.QI 65~ 101 ~59 ,"" """ 9 694a= 11 ~lB~ ~OO 9 !lODI_ """" uoo 

oJ7 ee 06636 080092 9 1146:1 1] 07>, 

f~Ol- IJOOI 9 1,0D:~'J 110[,­

762 B59 623b84 ,,­ 075&9 o"." 7 08291 800>71 

nODI • ,'IODt=e n('O!-9,'JODI 

S 0'0 '" 30 san 611755 1 4932 t 1612'l 11 95J) 2t MM 1,001­ 110m IIODI­ tjODI_ 

az ee 1 3--10, I >810' ~J<)128 10 7'191 

" e r "" ~" '" '" 80)5 995 

a a as "" oa5 9111 '" ",l'j oa 0; 05 

" es 3] 26 3, 82 '" 1 ;8 ',0 n 1441 i -.­

" "' "' 1I8~ '" 13 22 

"' "" "" '" 1 :'7 7:<1 '"' OW 1.1 033 oJ3 o.IS o"; ", J12 

as 019 '" ." !n 8 3 er "" 598, '" 133 ,~ 6 r: 

as as 103 147 '" ,~ (12' .c2' o'-1 )~

"' as '" '" 0" ." '1» .~as er 1 G5 '" 5 71 B17 

ea as 3118 31 19 '" '" 89 p­ ." C' \ 1 r.z 12 Q3 nr ,. 05 " ea "' .~ .., ... sz .. " 21 !12 2102 0'" ... .,. .. '"

" ,n '" e 10 01 cJ; 'HI ." 053 

U .. aeta ~" '''' '" .~ IJ OJ 

es ea t ra '" .~ 1105 

., es .. .. '" ,~ " .~ '" ." 033 ii :I~ '0ss oas 059 059

.. as ,~ '% ,% 11 Ot 

" aa az sa no, r c '" ,,~ 1453

.. es r a t ,7 1~ 81 1J 91 O.~~5 hi 0300 J 5, 

" " ,.", ",n , " .... <0'" 

" .. '" 

". .. ." " .. sas ... '" '" 559 ,~ 00. 011 c /S ,~ ." ." 069 1 "i 

e as '" '" n • 1073 e, a.s "" 10 S8 ." 1.07 ? 21 s s 

" as ... '" 1033 ,,~ .~ ,~ o~9 J ;,g 

r s as '" ~, ." 0" .~ ." " a s c ,~ 'n 6&7 928

.. .. 70 3 '03 ." 1 0fJ--' 8.91 1131 (jis ld~ ''" 0.'2(; 0" "n o ~5 OJ, 

U .. ,~ 125 '"~ 1609 

" .. ,,~ "129 liS ,;; 965 "n .. " ." ,~ 81 tl ;,'6 O)n on Ohl ",! 

" .. " ... '" 1.5) 9 52 \0 ('/ '.0 ,.. "". ,.m '-" 'M 1UI ,,~ 13.11 ". 11.02 "" 14,\0 1!1.~1 ,... '" "' .. 638 ~, ,,, '" '7/ 1" 20 '" on ... 0"(' on o1:' 053 oE2 

" " 175 175 ,~ Ole ". 1 1: 007 '" '" o~& oJ 11> ,' o35 « [ ~,

" .. '" ,~ 1 78 1S~ 11 "0 "' 10 o 18 ... 121l 1.'0 oJ g9 " S" o3'j i (, ~<;

0 • • • , , , • 0 • 0 • , , • 0 

" " " " ,6 " 06 ; , , , " " " " 

M,,""'fndlng "­

~iil= , 

Pe ....lllimlt 

Vl(lI'2(lO(; 06ll8' Bta 

1I:llf100li 0.6<193 .,,,"" 05973 

""

om 

"""'" om .. 100112006 "'" 0.907 

11IlQ/2OO6 ,,~ 0.804 

t2l3tf2llill6 06878 o a77 

1n1120117 06176 '" """"" '0531 c 7aJ 

313112007 ,v5~1. 0) ';;2 

."."." 1055:'6 Q 3'2 

Y.l112OO1 e 61~ o 763 

""""" D~bB

713112001 oi2U oess '''' 813112001 0591, om 

"""'" o ~lU 0 762 

1Dn1QOOl o 5~13 o~

11t1ll'1OO1 06421 c BT2 

WJll201'11 n655~ VB 

lIJH1OO8 06481 "~ '''''''''' "'''''''' """"'" 0595£ ern

,"''''''' """"" o 6'.1'l4 OM 

713112llO8 DlOla cw' .,,"'"' • 00' a 191 

"""'" 0.49~ Q 61, 

10I3112OO1l O.OJI osse 

''''''''"' 0574 .. 12f}112008 aSH 

1131f2009 0511 "" .~, "' 85 

"""'" .% 0.845 

"''''''" 0518 a 753 

"""'" OS13 0.119 .,,,"" V17 1003 

""""" 1l.548 085? 

113112009 0627 ,,~

"'""., ".. a.81ot 

"""'" osea csea 

101311Xl1l§ 0658 085'.1 ,,~ ". o '.1:'1 

1Lf.W1OO9 072& 0852 

1131rnllt 0.&63 o~,

""""" 0814 

3131/2010 0761 Q "" 929 

"""''' u62~ c !'I02 

51311201t 0357 1 102 

"""''' 0811 ,,~

T/31f2ll10 ,%, 1 089 

lIl3112010 o613 0"" 

"""''' 0702 0914 

~!!2010 oSi-I e ess 

111)QJ1(J10 OM" U 95 

1ZI31l2ll1U uo9~ 0.818 

lfJ1f](1l1 0599 0.9U5 

"""'"' tl IJ! 08% 

3r.I112011 '''" 0911 

"""'" .. OM' 

l'efmit Iimk •

'w, ..., oao:;. 

Min,mum 0495 0615 

Maximum 0.901 ; 102 

Excee:Jances "' ,~

c_ ;0 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R·18 

. • 

1 I ," 

H' ...l" IL . ...::c 

i' ~"

,........ - , -, j 

.. 

-­ --, 

'II +. r i ""] -I -~

" ".t' 'c..j..:::.! i-t .• cl· .-'" -. 

,"C' ~, ----l­

+ ..-

.. T ...C·" .. 

.! t 

I 

.. 

rt: 

1, 

I 

.. , 

. i= =f . '. 

• • , I ,:=:==j. 

III W I

" ,! I II I--=:J 

, t· 

-'-H 

I -­ , 

• 

• 

" '(:­

• 

. 

, 

! ,;'- t 

, '.1" 

_.~~'- I 

, , 

. ' , 

.r-c: 1 

i _. 

. , 

.i ... . 

t!' • t 

t:·, -- i.:-t: ; 

,I" . _.. t, 

--, ! 

u: ':-~Ti_:'; I' , ' .,,, - , 

-n 1': 

I I' 1 ' r. j 

.' 

! I "1­

I~

.1, ,

, , 

_.. ~-

,. 

'I' I 

--I, I n 

. ,~.

"±·,Ir;, I' "I..il, T 'C ·f .. 

L ... .; 

,: . 

'r'i

, , 

.-' 

= 

" ,~,

,~

Outfall 001 Treated Effluent Zinc Loadings - Probability Plots (Monthly Average and Daily 

Maximum Loadings) 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

TNOO29167 DMR Sumrnarv Outfall 002 

Month Flo_ 

MA~ DM~ Dmm OMax OM.' ~, 'su ,,' Re rt Re art ••• 9.0 40.0 

""

o 171 0217 67 7 19

•• '.7 8 

0 1591 0= 65 72 6 

01543 0_21 • 8 7.2 9 

01266 o 18'9 7 1 8 5 

0125 0.197 73 8.3 5 

01272 0181 76 8' 7 

01483 0.234- 7 8 3 6 

01729 0285 76 8A 7 

o 1836 0239 77 8 1 6 

o 1715 0217 7 7 8 5 10 

0_ 16 o 195 7 7 87 9 

01626 0207 7. 7 8 6 

01625 0186 74 7.7 8 

o 1533 o 191 73 81 9 

o 1552 0_191 7 7 5 11 

00996 0219 6 7 5 12 

00908 0122 722 833 7 

o 1189 a 211 76 823 8 

0.1167 0214 754 798 9 

NODI NODI R NODI NODI NODI R 

NODI tJOot R NODI· NODl NODI R 

01232 0258 737 8" 10 

NODI NODI R NODI NODI NODI R 

014-72 027 744 789 11 

0.1596 0297 7 31 756 7 

0.14-2 0182 75 76 10 

0.127 0155 75 76 5 

0_128 0235 75 7 9 6 

0_125 0157 75 82 5 

0.129 0219 7.2 79 8 

1/3112009 o 109 0.202 7.6 7 8 6 

2/28/2009 008 0125 73 7 6 6 

pH TSS Settleable Solids

Ending 

DM<O>t 

,. ,'" 

PennIt Ihnk 0.5

6130n006 0

7/31l2OO6 0

8/31/2006­ 0
 

913012006
 0
 

1013112006
 0 

11f3.0/2006 0
 

1213112006
 0 

1/31/2007 0

212812007 0

0
 

4130'2001
 

3131/2007 

0 

513112007 0 

6130/2007 0 

0 

8131/2007 

~~2007 0
 

9/3012007
 0
 

'1013112007
 0
 

11/3GI2OO7
 0
 

12/3112007
 0
 

1/31J2003
 0
 

2129FZOO8
 NODI R 

3/3112008 NODI 

4/30/2008 0 "
 

513112008
 NODI R 

6/3012008 0
 

7/3112008
 0 

813112008 0 1 

9J30n008 0 1 

10/31/2008 o 1
 

11130/2008
 01 

12/3112008 o 1 

o 1 

o 1 

3/31/2009 o 106 0163 66 85 10 o 1
 

4/3012009
 0099 0_129 7. 83 10 o 1 ~/31/2009 0099 0177 7 76 o 1
 

.,3W2009
 

5 

0088 NODI 9 73 73 21 001
 

7/3112009
 0108 0182 7 2 73 14 o 1
 

8/3112009
 0089 0133 72 72 6 o 1
 

913012009
 o 103 0145 73 77 3 o 1
 

1013112009
 o , 7.1 o 1
 

1113012009
 

0184 785 3 

0097 0266 73 75 

•

8 o 1
 

12/31'2009
 o 118 0203 7 5 78 o , 

1/31/2010 a 107 o 193 7.7 78 o 1 •

2128/2010 0128 0208 78 7 9 3 O. t 

313112010 0123 0222 78 8 7 5 01 

4130/2010 012 o 159 76 76 2 o 1
 

5131/2010
 o 132 0217 7 J 7 5 5 o 1 

6130I2010 o 124 026-2 7 5 79 2 o 1 

7/3112010 o 13 0185 7 5 78 9 o 1
 

8'3112010
 c 106 0148 7 1 7 2 21 o 1
 

9/30'2010
 o 114 0.172 72 75 

•

6

5 

o 1
 

10131/2010
 0107 7 3 o 1
 

1113012010
 

o 191 76 

o 105 0165 7 5 7 7 o 1
 

12/3112010
 0102 o 138 7 6 82 

•

4 o 1 

1l3112011 0.108 o 129 76 79 o 1
 

2f28J2011
 0124­ 0196 75 6 1 o 1 •

313112011 o 121 0186 78 9 8 o , 

413Ol2011 o 166 0236 7. 7 7 6 o 1
 

Pennlt 'bnit
 Re .... Re art 6.0 9.0 40.c 0.' 

Avera o 13 020 7.3 7 9 74 o 06 

r>.1inimum 008 o '2 6 ..0 6 7 20 000

1\.1aximum 018 000 7 8 9 0 21 o 10 

Exceedanc@s NA NA 0 c 0 0

Count 55 54 56 56 56 56 

Page R·19 

TRC 

DMa>t 

0.019 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

NODI 

NODI 

"

R 

0 

r·JOOI R 

0 

0 

tJODI 9 

NODI B 

NODI B 

NODI B 

NODI B 

NODI B

NODI B
 

NOO\,.--B
 

NODI B
 

NODI B
 

NODI B
 

NODI B
 

NODI B
 

0.14 

tJODI B 

NODI B 

!'JODI B 

!'JODI B 

NODI B 

NODI B 

NODI B 

NODI B 

NODI B 

I,JODI B 

NODI B 

NODI B 

NODI B 

NODI B 

NODI B 

NODI B 

NODI B 

NODI B 

tiOOI B 

0.019 

001 

000 

o ,. 

1 

24 
Nyrstar Clarksville. Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-20 

TN00291 57OMR Summary Outfalls SWJ and SW4 

1.l0"1~ Ending Outfall SW3 Outfall SW4 

01 

266 

t a.. 

1a5 

,Q7S 

1 ,4 

i s 

Re 011 

I ~~

01 

.I 15 

rjA 

15 

0.156 

fJODi C 

nt 

O5a 

Q 1 

teeo 

Q',L1>: 

r" II 

R. 

liODI 9 

13 j~

u39 

3 02 

415 

04' 

IJODI-9 

NODI 9 

, , 

oO~

J O£ 

1 29 

,~

E 

0.0Ii36 

a05 

"" ""

or 

129 

o37 

012 

R. rt 

eeo-c 

0" 

,] 

R on 

1i0C; 9 

Ola 

cus 

031 

"

0.05 

NOOl-9 

NODi=9 

" 

3~ 1 

~11

18 9 

295 

3&1 

263 

Re crt 

4' 

I) ..: 

295 

1.' 

Re crt 

~JODi-9

16 

1j ;; 

51 

14 9 

!IODI~9

11001-9 

0' 

I'J0DI_C 1, e 

O.(l1~

017 

oJ~

025 

u31 

J 1: 

0;' 

Q 29 

Re ort 

O. t, 1 

oOS 

W 

II;'. 

NODI C 

o31 

"'

005 

TSS CadmIU"-' 

16 

1~

2J{l 

m 

231 

m 

as 

R. rt 

130 

60 

m 

f4A 

16 

100 

"

NODI-': 

ta 

"

6 

prl 

" «r 

" W•. 

16 

6.D-9,0 

O",tnl[lm,n OM<lll OM.x 

~R 'on 

rJODI., NODI 9 

19 081 

19 0 ze 

62 (I Z 

252 ou 

195 021 

NODI=9 UODI-~

~IODI 9 NODI~9

! 6 

,, 

12 

69 

76 

6 

7 92 

, 

flA 

Fio-.. 

, on , 

C! HJ 

o\l~

o:'~

r"" 

om 

oO'~

0026 

oO:,J 

0148 

uIIi' 

'J ~aJ

II0ui 

~n

oc~9

C 0~5

rm ~ul

A crt A ort 

11')01911001-9 

(1072 68 

')062 71 

C-es 3 

o, , 

0172 6.88 

II({li.9IiOOI-9 

IIODI-4110[11 9 

'"

UOCI=C 

,' 

Nt< 

ts 

0.156 

0" 

I ,,2 

o'5 

! J7 

, 02 

2 02 

{l1? 

Re on 

202 

010 

! OJ 

: IIDel c 

145 

o, 

1 ~8

16 C~9

368 "2 

588 213 

"q 1:' 

110['1_' 1100i 

154 3 2.1 

38 .j : es 

J75 ~'Q~

OM~l( OIAa. DMa; 

ma.L I L' me-L 

Re rt R Oft Re IIf1 

11001 _1-1(0 IIOL'I 

99 16: ~SJ

121 0::'.1 1 a 

5183 7306 

96 ~F 569 

;'12 OJS 068 

~IODI 11001 3 r1001-9 

W'OI ,fiC,r,1 W'DI~q

.132 199 

59.1 229 

187 0 1 

R& ort ae rt 

65 2 &i 

16 I) 10 

432 199 

I':' f1;" 

1~ ~~

039, o.ece 

58 069 

20~ 117 

105 1 07 

lJ6 0<15 

1 8-l~. J P 

2% 1IJj 

:u 0 S1 

AI! art 

~8~ 1 ;;1 

3.lO O-W 

l[\jS ~13

IlA NA 

16 16 

200 0.0159 

[1M,). O"-ia" 

'm m ·'L 

R rt Ae ort 

11001 9 11001"9 

7S 2 5B 

'J~ 247 

213 1J.1 

__ 806 1~.7

)4 1}?~

~m(>I-9 IlO[:I,=.! 

NODi tIOO,-~

67 0 .w 

1100l-C NOO!-C 

113 1 ts 

94 1 51 

313 189 

ILL. 

16 

6,0.9.0 

Re ort 

6 8 

, S 

'i IJ 

-; 2 

'" 

,. rt 

n1!Z 

r 'X' 

o }Z~ I 

'ill 

c:a 

(, [,3 I 

o.;.o! 

0032 

o256 

"322 

uoc-c :,['1::;< 

C~8: )" 

o09:. ' 1 

Fie" I rei 

GI,1J:< 1 [>r,." CrT"" 

,m' C' ',L' 

Re {Itt Re n 

IICOI s 'I:~'[',.c, .­ nu" ~.

~':~2 e­ II'~~I-~ 11~;1l1-"

1;({)1-9 W'CI-~

., 

9130,'2009 

11,31,?OO9 

3;31~1)11)

~:3iiit'{l10

Klll/;OIQ 

121]1,'2010 

;).'31:2011 

Permit limi! 

h.:,­

r.h:rruCf' 

MJmrLJ'" 

Exce~da"c~<:

Count 

CutoffVoJlt't5 

Permit limit 

6:30,'lOOli 

913Oi2006 

12131'2006 

ff11!2~7

6:30.'2007 

9i3012oo7 

12:]112001 

313112008 

6i3O'2008 

913012008 

12J31flOO8 

3,'31/2009 

&i3Qi2009 

TN0029157 DMRSummary Outfall. SW5 and SW6 

"'gn\~ Ending Outfall SWS 

,0 I 

100057 

'"" DMax 

rm .Lt 

He ort 

11001-9 

rJODI-9 

fJOOI-9 

r'IODl-9 

1..001 9 

01 

NOOI-C 

01 

!,'GDI'::­

Q 05 

CilPP;Of 

OMax 

1m .'L 

Ae 011 

1,0Di 9 

I,ODl-9 

NOOl-9 

fJODl-9 

11001-9 

J O~

Dl.lax 

:m ,1'

,. 

'1001-9 

~JODI-9

':001-9 

I-DDI-9 

:,,)0, 9 

c' :<1 

'K'D;-C 

Re on 

o(W : 0 3'>

Q or: 

G05 

fl'

, e.etss 

(1002 

oOS 

Re oft 

mh~

1m t 

Ail 011 

nco-« 

r~OD'-9

~IOOi-9

fIOO'-'1 

r-IQO'-,' 

005 

tJODI-C 

005 

TSS Cadrmurn Zinc 

DMax 

, 

12 

,. 

10 

, 

NA " 

4 

100 

m o_ 

R.... 

r~ODI-9

lJODl-9 

rlOOI-9 

!lOOI-9 

IJODi 9

, 

IlOOI-C 

16 

:::1,10;' Irrmn-Drmn 

'''' o: su R He rt 

rIOCI-9 ~jODI-~

uoo 911001-9 

r:,:,[J1-91l<.'DI-~

riOOI_4 rJ0CH 

rir,['1 9 I)(-'01 

1 031 8 

W\Ot~ ucor-c 

(lliS 70 

0722 749 

o~7.j c 1 

Re Re 

c851 72 

(1m s a 

10}1 76 

UA I,M 

, , 

1M E.O.9.0 

0; 

0.1~

014 

" 

OJ,J 

R. on 

o16 

Q 10 

o~j

"' 

o27 

oOS 

07£ 

II:" 

5 

O.06Jii 

o:'0& 

o73 

Re on 

o2 

a3 

174 

!{A. 

; 

0.395 

R 

.mct: ,rr, t­ ,"'­ L 

Re I>l1 Re Or! Re 

11'.:'81­ roc :' !jOOI-9 

110['1· IIC}Di-:' fJOOI 9 

Ij,')[:I-" 110[11 11001-9 

Il')CI­ IJODI-~ I-JOOI-9 

"

76 

14S 

169 

m 

,. 

IJOQIIJODI~

IJODI. 

tlODI014 

04' 

0.05 

cH3 

09' 

R. 

OM 

005 

0" 

'" 5 

a.Ol¥.! 

990 

120 

R. on 

20 

"

120 

,~

100 

He on 

11001-9 

1,001-9 

r'JODj 

rIOOI-9 

, "

rt 

s 

8 0 

'" s 

6.0.9.0 

7 7 

C-·.,-.;" Drmo 

8 

R. on 

"" He 011 

110[>1-9 

I!OCI-~

'Ked 9 

rJC'DI s 

R~ 011 

1,iD\ 

cDot 

2399 

~jA

5

,. 

2 39,' 

(068" 

'" ,j 

Ile Qrt 

>,'CI-9 

',']CI c, 

U[I 4 

\C'DI~?

6;30J7U10 

n~l:201{1

P",on" limit 

;.:~,

':,;.ri'''~~T'

·.'a'·~'uM

E"CMc30d, 

Count 

Cutoff Values 

Permit limi! 

6i30i200G 

1213112006 

613012007 

12/31:2007 

6<WJ]OO8 

12.'31!2{l{lll 

613(lilOO9 

~009

Outfall SW6 

o13 

I) F.2 

liA 

0.395 

ne 011 

004 

00' 

005

,,.


,
 

0,",-" 

Re crt 

01 

01 

I~,
 

e.ree 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-21 

APPENDIX R·4
 

APPLICABLE EFFLUENT LIMITATION GUIDELINES (ELGs)
 

Actual Production Rates (al 

Plant Nea 

Cell House 

Cast House 

Cadmium Plant 

Metalluraical Acid Plant 

Concentrate Preleached 

Production (01 

(Short Ton5l00yl 

398.18 

377.14 

108 

475.16 

00 

(a) Production values are maximum long-term (12 month) dally average for 

period January 2006 through December 2009, based on operatrn<J days 
--

Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-22 

Effluent Limitationl GUideline. Ma•• loading Dilcharge AUocltiont for NontelToul Metsll Manu'acluring. 

Primary linc SUbcategory 

F~A C,u'dellfle, II Actual ~_ BPT Lrrmtatron BAT Limitation .:'::::::;­

we steweror Sourr.- :f'Milm~ter Production lal ~,l[mlhl' -Aver-eClf' Oalr. Maximum M Avera e Dal~' Maximum

H,·n~<d~· , ,Ih.mdl',," lb. d~,d.", iH··,,'.,., I~ ,Il>'d~ ,lb.. m,lh"" Ih !b,da'<) l",m~"'Q" It ilc'cia' 

Arseorc 1M ! NA NA NA NA 

Sut,par1 H I"J Cildmmlll JQ/l18 o OJ" ooee oceo 0068 

::;8{\rOIV'E' :','"E"1 Cooper ,98 U:" 0'''' 0210 0553 0440

.vavre-...·<[8r Lead J9818 oose I 1)045: 0121 0091' 

SelenllJrr, NA I ! NA NA NJ'. NA 

Lin, 398 18 0182 0145 0.441 oJ:-.1

- T:=;s "AI ­ - NA "A IVI NA

,Ars",nlC j NA NA NA Subpartl~it'l Cacrruum -j9E< 1,,, '" '" - 0060 0119 

"':."lhade ~"(1 Aoooe Cooper ace 18 0458 00"·1 0313':. n9131 0765

0150 

'-/Va"h'Naslcl>'<ller Lead sse 18 oD98 0076 Q <'10 o 167 

Selenium 'JA NA NA, NA NA I 

398 1'3 0315 01)10 

TSS 

IZinC 0.251 07613 

NA NA l'IA NA iArsetuc 

I" ... ­

NA NA NA NA NA 

Subpart H Ig! Cadmium 0014 I) 011 oCi27 

Casunc r.omart 

;'77 141 I 0036

Copper ;77 q • 0110 023<' 0175 003J I C0~)ilng t.eed J71 14 l 0024 I) 0:'1 0038 C'0~~ 5eler1IUm M NA IV< 'lA i Z'nc. 377 14 0076 o 0~,7 0135 0140 

'-55 NA NA NA r.A 

A(~enle NA NA IIA '''' NA SuLJ~Hrt H (11' ", 0<94 0001'''' [cadmium 1 2JJ. : ° 003

Cad-n.urn 1 .' PI~rll Copper 00 - 3765 0008 7899 1 ° 017 ';";'..ste.vare- Lead 1 08 0802 0002 1728 0004

I

seeruum NA IIA NA NA NA 

Z,n, 108 2592 n 006 I) 295 I) [1'4 

TSS 

- IIA .­ - NA NA NA NA

'A(wnlc NO NA 1'1.-,\ NA NA 

Sccoao 'i ib) Caomnm f\ Of, 0072 ° GOO i n180 0000

PreLcdLIl of Zinc Copper o o(}('){J , f>CJ o'55IJ 1 153 0000 

CQnCenl'"t'e~ lead oU(I o117 0000 I 0252 0000

seiemor» IIA I NA NA NA NA 

IZme , (100 0378 lJ 000 I) 919 0000 

iTSS NA NA IV< '" i 4,rsenr<:; 377 1,..1, 080 0.603 "0 1.207 '" NA NA 

Summary lor IIC'ldmium 3771-'11 3017 8.00 6 n.,4 0.087 0.218 

Primary lint 1Copper 

- ~17 U­ NA rJA ­ 0.656 1.398 

377 1-'1­

",

NAi 

Category '" ILead NA! IlA 0. 142 1 '·F, NA 0.306

S",~nlulll J!7 1-'1­ 400 302 800 60.3 (.J,t'lf

line 377 14 40 I) :'C' 2 800 602, 0.4691 - 1-114 '''' 

TS5 377 14 ,~10 'J 158.4 420 ° 316.8 NA NA

Alsenlc 47:, 16 NA NA NA IIA 1 ':>8J. 1.505 ."5:;'0 3.374 

Sl>b~,aI11 ,'C<ldmru,n (. 1i' 1 47'> 1" I) <'04 I) 511 1 009 U086 018 0.194 0.486 

Me-lallurg'cal Ac."J !Copper ·H~, 1~ 200 1 ':){11 '-.(10 4752 1 5S8 1.481 :J ':03'1 3.107

P'<l~i~ Lead 47<; 16 (179 07':.1 >sO 1 711 0:'U2 0.316 , o 71::' 0.679 

ISeleflium 475 16 NA 'jA NA NA ~A: NA NA

47~.16 0\,10 ""I 3 so '" 3421 2_476 

475113 

1 on I 1.020 2.305 

1~.2 0 144.4 3D40 288.9 NA NA ~<A

, c~ f--- - rss '" 

I-­ l,Aroel1lC 2.109 4.580 

Combined Totsl Caorrsen 0_281 0.703

Man Limitalionl (b) Copper 2.147 4.504

Lead 0.985 '458 

Selenium 30.2 60.3

Zinc 1.478 3.590

TSS 302.8 605.7 , , ,~J P"rS,Ja1t to pr Jdu,III,n -rate-s shewn above 

,D' Lomb.ned IIIT1Its are ew swn of the subr <11t'9'-~ry nmoauons ot either BPT or 13AT uowever. lor MelahurglO: at ACid Plams 

2>A;- was i.l",.(1 ueca«,e BPT enoreooa, «o.careo lowpr v;;llJe" tor r-adrroum anc one 

r'olf; f.'(,5IWlng(ni ELG values she.....n In Mid 1011\ 
Nyrstar Clarksville. Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-23 

TECHNOLQGY-BASED OUTFAll 001 DISCHARGE ALLOCA11ONS 

EFFLUENT Monthly Average

CHARAClERtSllC ElG WastestlUrm Non-ELG Wastestreaml Total Aloeation

LoadIng F",. C"" Total Flow BPJ BaSIs al Loading

~lG(b erNon-ElG 'c Total

I llbid'" 'm.tI lmodl ",,,,,.1 llb/dav\ "lbidav) IIbfd'" ''''''''' ARSENIC 2.'09 00727 31 03832 9.923 509 15014 1112

CADMIUM 0.281 00727 04 03832 1 322 068 2 [100 228

COPPER 2147 00727 32 0.3832 10102 518 15285 17 43

LEAD ITI 0458 0.0721 0] 03832 2.155 111 3261 372

30171 110727 444 03832 141.959 7283 214790 2~~,

~E~~M ~NC 1478 0.0727 22 03832 6954 3568 10522 120

TSS 303 00727 44Q 03832 1425 731 2.1,56 2459

EFFLUENT DewMaximum 

CHARACTERISTIC ELG Walteltreams Non.ElG Proceu Wastestreaml lotal Allocation 

loadings Fo. Cone Total Flow BPJ BaSIS Ia loadlr'lgs

loerElG b Ioer NOfl.-ElG Ie) Tolal .__ 

{Ibidav ImOOi lmaill ImOO' lJI""v) ~/""v' (\t)!dai IIb,d",

ARSENICm 4580 00727 67 03832 21 556 832 29866 3445 

CADMIUM 0703 0.0727 10 03832 3 JOB 128 4.564 529 

COPPER 4504 0.0727 66 03832 21192 818 29.370 3387 

LEAD m 0985 0.0727 15 03832 4635 1.79 6423 741 

SELENIUM 60 342 00727 888 0.3832 283918 10957 393484 454 

ZINC (f) 3590 00727 53 03832 16891 652 23410 270 

TSS 600 0.0727 892 03832 2.850 1100 3950 4.555

(a) Permnee uses ZJOC treatment pertormerce as primary baSIS loroperating WNfP 

(b) Calculated llSlng ElG corceraanon and Non-ELG wastestreams lbw 

((l Calcuateo using thefollowing WoNTP 1J11C ueanren pertcnrance veues for ELG.lNoo-ElG eaocanons
 

51 3 %lorMO!l1tJIy AverEi!)E!
 

386 %forOalN Maxllflirn
 

Note	 Best Professronai JudgmertllBPJj mass loalilng anocanons oeveooed constoenrc pemmee's process
 

knowledge. wesesnearn ctaractensics. and neaurem svstem pertormance as reateo \0Increased flow from
 

ooo-ElG wastesueems (Include fall1alj
 

Since the permittee must operate its WWTP with a primary focus on achieving its 

effluent zinc discharge requirements, the treated effluent Outtall 001 zinc probability plots 

shown in Appendix R·3 were completed to establish applicable technology-based treatment. 

From the probability plots the following BPJ technoloqy-based Outfall 001 treated effluent zinc 

loadings were determined and used to develop the above summary: 

95 %tile Monthly Average Zn Loading Value = 12.0 Ib/day::: new permit monthly average
 

99 %tile Daily Maximum Zn Loading value e 27.0 Ib/day::: new permit daily maximum
 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES PermitTN0029157 

Page R-24 

APPENDIX R-S 

WATER QUALITY CONSIDERATIONS 

The following procedure is used to calculate the allowable instream concentrations for passthrough guidelines and permit limitations. 

a.	 The most recent background conditions of the receiving stream segment are compiled. 

This information includes: 

•	 1010 of receiving stream (1,696 MGD, USGS)
 

30Q5 of receiving stream (2,302 MGD, USGS)
 

• Calcium hardness (124 mg/I) 

• Total suspended solids (16 mg/l) 

• Background metals concentrations (upstream or Y2 water quality)
 

•
 Other dischargers impacting this segment (none)
 

Downstream water supplies, if applicable
 

b.	 The chronic water quality criteria are converted from total recoverable metal at lab 

conditions to dissolved lab conditions tor the following metals: cadmium, copper, trivalent 

chromium, lead, nickel and zinc. Then translators are used to convert the dissolved lab 

conditions to total recoverable metal at ambient conditions. 

c.	 The acute water quality criteria are converted from totat recoverable metal at lab conditions 

to dissolved lab conditions for the following metals: cadmium, copper, trivalent chromium, 

lead, nickel, zinc and silver. Then translators are used to convert the dissolved lab 

conditions to total recoverable metal at ambient conditions for the following metals: 

cadmium, copper, lead, nickel and silver. 

d.	 The resulting allowable trivalent and hexavalent chromium concentrations are compared 

with the effluent values characterized as total chromium on permit applications. If reported 

total chromium exceeds an allowable trivalent or hexavalent chromium value, then the 

calculated value wiJl be applied in the permit for that form of chromium unless additional 

eHluent characterization is received to demonstrate reasonable potential does not exist to 

violate the applicable state water quality criteria for chromium. 

e.	 A standard mass balance equation determines the total allowable concentration (permit 

limit) for each pollutant. This equation also includes a percent stream allocation of no more 

than 90%. 

The following formulas are used to evaluate water quality protection: 

Cm::	 QsCs + QwCw 

os s cw 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-25 

where: 

em .: resulling in-stream concentration after mixing
 

Cw = concentration of pollutant in wastewater
 

Cs = stream background concentration
 

Ow = wastewater flow
 

Os = stream low flow
 

to protect water qualffy: 

Cw s IS.l [Cm IQs + Qwl - QsCsl 

Qw 

where (SA) ;s the percent "Stream Allocation". 

Calculations for this permit have been done using a standardized spreadsheet, titled "Water 

Quality Based Effluent Calculafions." Division policy dictates the following procedures in 

establishing these permit limits: 

1.	 The critical low flow values are determined using USGS data: 

Fish and Aquatic Life Protection 

7Q10 - Low flow under natural conditions 

1010 - Regulated low flow conditions 

Other than Fish and Aquatic Lite Protection 

30Q5 - Low flow under natural conditions 

2.	 Fish & Aquatic Life water quality criteria for certain Metals are developed through 

application of hardness dependent equations. These criteria are combined with 

dissolved fraction methodologies in order to formulate the final effluent concentrations. 

3.	 For criteria that are hardness dependent, chronic and acute concentrations are based 

on a Hardness of 25 mg/L and Total Suspended Solids (TSS) of 10 mg/L unless 

STORET or Water Supply intake data SUbstantiate a different value. Minimum and 

maximum limits on the hardness value used tor water quality calculations are 25 mg/L 

and 400 mg/L respectively. The minimum limit on the TSS value used for water quality 

calculations is 10 mglL. 

4.	 Background concentrations are determined from the division database, results of 

sampling obtained from the permittee, and/or obtained from nearby stream sampling 

data. If this background data is not sufficient, one-half of the chronic 'In-stream 

Allowable" water quality criteria for fish and aquatic life is used. If the measured 

background concentration is greater than the chronic "In-stream Allowable" water quality 

criteria, then the measured background concentration is used in lieu of the chronic "lnstream Allowable" water quality criteria for the purpose of calculating the appropriate 

effluent limitation (Cw). Under these circumstances, and in the event the "stream 

allocation" is less than 100%, the calculated chronic effluent limitation for fish and 

aquatic life should be equal to the chronic "In-stream Allowable" water quality criteria. 

These guidelines should be strictly followed where the industria! source water is not the 

receiving stream. Where the industrial source water is the receiving stream, and the 

measured background concentration is greater than the chronic "In-stream Allowable" 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES PermitTN0029157 

Page R-26 

water quality criteria, consideration may be given as to the degree to which the 

permittee should be required to meet the requirements of the water quality criteria in 

view of the nature and characteristics of the receiving stream. 

The spreadsheet has fifteen (15) data columns, all of which may not be applicable to any 

particular characteristic constituent of the discharge. A description of each column is as 

follows: 

Column 1: The "Stream Background" concentrations of the effluent characteristics. 

Column 2: The "Chronic" Fish and Aquatic Lile Water Quality criteria. For cadmium, 

copper, trivalent chromium, lead, nickel, and zinc, this value represents the 

criteria for the dissolved form at laboratory conditions. The Criteria 

Continuous Concentration (CCG) is calculated using the equation: 

GGG = (exp ( me [ In (stream hardness)] + be) ) (GGF) 

CCF = Chronic Conversion Factor 

This equation and the appropriate coefficients for each metal are from 

Tennessee Rule 1200-4-3-.03 and the EPA guidance contained in The 

Metals Translator: Guidance For Calculating A Total Recoverable Permit 

Limit From a Dissolved Criterion (EPA 823-6~96-007, June 1996). Values for 

other metals are in the total form and are not hardness dependent; no 

chronic criterion exists for silver. Published criteria are used for non-metal 

parameters. 

Column 3:	 The "Acute" Fish and Aquatic Life Water Quality criteria. For cadmium, 

copper, trivalent chromium, lead, nickel, silver, and zinc, this value 

represents the criteria for the dissolved form at laboratory conditions. The 

Criteria Maximum Concentration (CMC) is calculated using the equation: 

GMG = (exp { m, [ In (stream hardness)] + b,) ) (AGF) 

ACF = Acute Conversion Factor 

Thts equation and the appropriate coefficients for each metal are from 

Tennessee Rule 1200-4-3-.03 and the EPA guidance contained in The 

Metals Translator: Guidance For Calculating A Total Recoverable Permit 

Limit From a Dissolved Criterion (EPA 823-6-96-007, June 1996). Values for 

other metals are in the total form and are not hardness dependent. 

Published criteria are used for non-metal parameters. 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-27 

Column 4:	 The "Fraction Dissolved" converts the value for dissolved metal at laboratory 

conditions (columns 2 & 3) to total recoverable metal at in-stream ambient 

conditions (columns 5 & 6). This factor is calculated using the linear partition 

coefficients found in The Metals Translator; Guidance For Calculating A Total 

Recoverable Permit Limit From a Dissolved Criterion (EPA 823·8-96-007, 

June 1996) and the equation: 

1 

c"., 1 + ( [Kp.,1 [55""'] [lO~ll

ss = in-stream suspended solids concentration [mgJ1J 

Linear partition coefficients for streams are used for unregulated (7Q10) 

recelvlnq waters, and linear partition coefficients for lakes are used for 

regulated (1Q10) receiving waters. For those parameters not in the 

dissolved form in columns 2 & 3 (and all non-metal parameters), a Translator 

of 1 is used. 

Column 5: The "Chronic" Fish and Aquatic Lite Water Quality criteria at in-stream 

ambient conditions. This criteria is calculated by dividing the value in column 

2 by the value in column 4. 

Column 6: The "Acute" Fish and Aquatic Life Water Quality criteria at in-stream ambient 

conditions. This criteria is calculated by dividing the value in column 3 by the 

value in column 4. 

Column 7: The "Chronic" Calculated Effluent Concentration for the protection of fish and 

aquatic life. This is the chronic limit. 

Column 8: The'Acute" Calculated Effluent Concentration for the protection of fish and 

aquatic life. This is the acute limit. 

Column 9: The In-Stream Water Quality criteria for the protection of Human Health 

associated with the stream use classification of Organism Consumption 

(Recreation). 

Column 10: The In-Stream Water Quality criteria for the protection of Human Health 

associated with the stream use classification of Water and Organism 

Consumption. These criteria are only to be applied when the stream use 

classification for the receiving stream includes both "Recreation~ and 

"Domestic Water Supply." 

Column 11: The In-Stream Water Quality criteria for the protection of Human Health 

associated with the stream use classification of Domestic Water Supply. 

Column 12: The Calculated 

Consumption. 

Effluent Concentration associated with Organism 

Column 13: The Calculated Effluent Concentration associated with Water and Organism 

Consumption. 
Nyrstar Clarksville. Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-28 

Column 14:	 The Calculated Effluent Concentration associated with Domestic Water 

Supply. 

The calculated chronic water quality effluent concentrations from Column 7 should be 

compared, individually, to the values calculated in Columns 12, 13, and 14 in order to 

determine the most stringent chronic permit limitations. The calculated acute water quality 

effluent concentrations from Column 8 should then be compared, individually, to values 

equal to two (2) times the values presented in Columns 12, 13, and 14 in order to determine 

the most stringent acute permit limitations. These water quality based limits should then be 

compared to any technology based (CFR or Tennessee "Rules") effluent limitations, and/or 

any previous permit limitations. for final determination of the permit limits. 
Nyrstar Clarksville, Inc, (Rationale) 

NPDES Permit TN0029157 

Page R·29 

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Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-30 

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NPDES Permit TN0029157 

Page R-31 

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Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-32 

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&17 S67 1[I 021 8n' 

"....., H?38' S6 1,;"J : 0'88 3322:71 m'26~ 01(29 4W[' H,lO ~,\I' EO W ~21 19I' ~! 9 3i9!34 I OT m JJI 

Silver" 2' tlA H,:7 WI' \1Il, ~6:,; NA :~', NA hI\. fiA hA ~,A. i1A C' 212:; ) , 275 '!,:,i 02~ .. ,,' 10

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l,Iercury,iW' E'-,~ cr:.1, 1~LJ( ,100(1 ,~I77C, 1m 108 197 "" --",," ,,' "" 

Zinc' 3:, 1~1;:,~:I~Or"~5 01e9 1293:£9" 12B~8:" 1782T 17t,i9 NA I;A fl.'< NA NA ~A 1£ O~: 15911 77IJ' !Ijr)' 

C9 32 ou~ 0" o8? '" '.
 ChromiumJJ I 1B39j 37~:27 H,r,7 11"':,~8gi l'g':~91 nOO2 '69,1~rt" I r~A t~~r" h'A I,:~ flA NA 1S27 I'!~' 1.'34 j
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I 10 I) 11) I I~:' '9;, 19:) I '734 1734 Ii) 02' 

I I'JA ~,A I ~n I ,',A 2164 21(' 0'1 '" QOn I 255 

DenQI~, WI,I) for "f'I(r !--",n 1~c~I,( Ue C"le'la are eusessec as afJf1('j,)n )1 rOio! lIarMe" TN' ~Ish \ A,qua~t Life (Pieri, for It]o' T~I JI;> .r,'" i:&SSUM>C '"'1'1 at ate.:ury (oMir.oos 

Tile Ir_ W2~1' dlo:lfd~le rrrena and (d":c~l!!'L'J .'Iluerl con,el1lallDnS dl,; In !r<; ;0liIl :ecOll":fl~ lanT 

n ),',1: Q:lena ";Ithese J:m:r"eler, se c 'h~ lolallorTl': 

~orE Wl\el Quail~ ,nlella fO' ,tream use :IiIS);llr~~~~ tt"P.! 1I1an Fish gAqLAl1( Life are based on te 3OQ~ !D\IlI 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-33 

Crude Zinc Oxide ICZO) Washwater's Receiving Stream Impact 

Outtall 001 Flow o62 mgd 

Receieinq Stream Flow 

1010 1,696 mgd 

3005 2,302 mod 

CZO Washwater Characteristics 

Flow (333% of Outfall 001) 021 mgd 

Chlorides 7,762 Ib1day 

Fluorides 195 Ibldav 

Limiting Recerenq Stream Available Capacity @ 1.696 mgd 

Chlorides 

Acute critena" 660 mgIL 12,164,390 Iblday 

Chronic cnteria "230 mgIL 4,415,696 Iblday 

Fluondes (drinkinq water "40 mail) 76.795 Ibldav 

Washwater's Percentage Usage ofReceiving Stream's Available Capacity 

Chlorides 

Acute criteria 860 mgll 006 % 

Chronic criteria = 230 mgIL 018 % 

Fluorides 025 % 
Nyrstar Clarksville. Inc. (Rationale) 

NPDES Permit TN0029157 

Page R·34 

APPENDIX R·6 

NEW PERMIT LIMITS AND MONITORING REQUIREMENTS 

Discharge Allocation Comparisons 

DETERMINAllON OF DISCHARGE L1MITAllONS
 

Outfall 001
 

Monthly Averaae 

ELG!BPJ water Quality New 

EFFLUENT Perrmt 

I 

CHARACTERISllC lib/day] lib/day] lib/day] 

TSS 2.459 (a) 2,459 

Cadmium (T) 228 104 2.28 

Copper In 17 43 605 17.43 

Lead In 372 85 3.72 

Zinc In 120 15,029 12.0 

Arsenic In 1712 173 17.12 J 

Selenium 245 249 24.9 

Dailv Maximum 

EFFLUENT 

ELGBPJ Water Quality New 

Permit 

CHARACTERISllC lib/day] lib/day] lib/day] 

TsS 

Cadmium In 

4555 

529 

(a) 

86.6 

4,555 

5.29 

Copper IT) 

Lead In 

3387 

741 

950 

865 

33.87 

7.41 

Zinc In 270 15.895 27.0 

Arsenic (T) 

Selenium 

344:, 

~54

173 

216 

34.45 

216 . (a) Narrative critena only.
 

(bj Pursuant to water quality reasonable potential calculations
 

provided in Appendix R5 

Note: Controlling values shown above as shaded cells. 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-35 

New Permit Discharge Limits and Monitoring Requirements 

I PERMIT UIIITS I 

I 

OUTFALL 001 

TREATED PROCESS WASTEWATER 

EFFLUEHT LIMITATIONS MONITORING 

UONTIllY DAILY REQUIREMENTS 

EFFLUENT AVG.COIIC. A\IG,AUIf, lIAX. COliC. lIAX.AIIIT. MSRMIfT. SAMPU 

CHARACTERISTIC rmgl) _I 1mg,4J -I fRQIICY. TYPE 

Flow Reoort MGDI Reoort MGDl Continuous Recorder 

Chloride, Total -- Reoort -- Reoort 1Week Composite 

Fluoride, Total -­ Report -­ Report IlMonth Cornposns 

Arsenic, Total -­ 17 12 -­ 34 45 Semi-annual Comoosite 

Cadmium, Total -­ 2.28 -­ 529 2IMonth Cornocsite 

CODDer, Tot.1 1743 JlB7 1/Quarter Ccmocsrta 

Lead, Total -­ 372 -­ 741 11Quartet Composite 

Selenium, Total -­ 20 -­ 216 Semi-annual Composite 

Zinc, Total -­ 120 .­ 270 1/VVeek Comoosrte 

TSS 2459 -­ 4555 ti2Months Composite 

Conductivity (umhos/em RepOrt -­ Report -­ 1rWeek Composite 

HIs.u.) Renee 6 0 ·90 (al tWeek Grab 

a) pH anelvses shall beDe!formed within fifteen (15) minutes ofsamoe collection 
--

--

--

Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-36 

I PERMIT REQUIREMENTS I 

INTERNAL OUTFALL OIA 

CRUOE ZINC OXIDE WASHWATER 

EFFLUENT LIMITATIONS MONITORING 

MOHTHLY RfQUIREMENTS 

EFFLUENT 

DAILY 

AVG.COMC. AVG.AMNT. IW.C<lIC. MAX. _I AMIIT. MSRMNT. SAIIPLE

CHARACTERI snc I_I (lb/dayJ (mgIIl FRQNCY. TYP<

Recorder 

Chloride. Total 

Flow fMGDl Re n Re ort Continuous 

.. Grab 

Fluoride. Total 

Report Report 1NJeek 

.. 1,Week Grab 

TSS 

Reoort Reoort 

Report VNeek Grab 

Conductivity tumbosrcm 

Reoort .. Report Vlveek Grab 

H[s.u.] 1'1 ~rt

Reoort 1/Week Grab 

13) pH anal ses shall be performed within fifteen 1151 minutes of samole couecuon 

Reoort 

C PERII'flIllTS I 

EFFLUENT 

CHARACTERISTIC 

flow 

pH Is.u.1 

mlCO~C . 

(qn 

,T0~1 Suspended SolidllTSSI 

.Seltleab~ Solidslml'l) 

.. To~1 Res~ual Chlorin~TRCllbl

.. .. 40 .. 

.. .. 05 .. 

, .­ o019[a, .. 

OUTFAll 002 

EFflUENT lJITA110NS 

1ION1IILY DAILY 

AVG.CO~c. .l\'G. A.\l)1. 1lI1.\ID1. 

(lltn lI'ay) 

Report IMGDI 

llbiilll 

Report [MGD) 

Ra'9€dQ.90 (al 

MONITORING
 

REQUIREMENTS
 

lISR.\N. 

IRQ~n.
 

CDnMuou~
 

1Week 

1Vieek 

1iWeek 

1~NEek

tt\lPU 

mE 

Recarder 

Grab i 

Gra~

Grab 

Grab I 

,ai pH 3~C me ilnai,5~S shall te ~!ormed \i'~hln fift€p ,:151 mmjl.tS of 5a'Jll~ col~tJon

it! ~he c<ceptatle metriC*. for analrslS QITR.C ~re any 'Tletr1OdS ~pet;,lfr<:o:J 1'1 Trtle 40 CFR Par113{) as amemed Ire rnelhoo deteclJon ievei 

I,IOLI for TRC snal, 1): met'iliJ ilS mg'l unless lrte perrnilte€ dfmdlstra1t5 na ~.s MOL IS hgrer Trte perml!lee shall re(alfl Ire 

t':Jinema1.10r lba /JStff5 re h~her MOLand lave aI"31,;a~e lor reView upon rE<:1~L ip cases ~tlere the perm~ limit 

Siess ·.~3t 'te ~JDL :he repor1ng or me ajess lnan !II€' fJ D shall be Interpreltllio cOlSl~ule cOf11\l~ance wllh :he perrnd I,'md 

The complianet point forlotall1Sidual chlorine is.n the confluence of !hi discharve and the recei'ving stream, 
Nyrstar Clarksville, Inc. (Rationale) 

NPDES Permit TN0029157 

Page R-37 

PERIITBENCHllARKlCUTOFF DtSCHARGE VALUES
 

OUTFAlLS SW3.ndSw.t
 

StllrmWlttr Runoff, Steam Condenutt Ind MiscelllnltOltI Non-PrClCeN Wltlr
 

, EFFlUENTBENC_UTOFFVALUES _TORING

IIOIIMY DALY REQUIlEJIENTS 

EFFLUENT 

CHARACTERlSllC 

AVe;. CO:«:. 

,.;;n 

AVG. Am'T. 

"""'" 

MAX. CONe. 1ll.-u'AMNT. ._'" I _I """"'"T. 

J1lQ~cY.

IA.'EPU 

nl'[ 

Flow Report (MGDI Reporl (MGD) 1ouaner Esnrrate 

pH (s.u.) tal 50-90 50·90 t'uuaner Grab 

Total Suspended Solid~ (TSS) .. - 150 - 1Quarter Grab 

Cadmium, Total - 00159 - 1!Qual1er Oreb 

Copper,Total .. 00036 - tqraner Grab 

lead, Total .. 0150 .. t-Ouarter Grab 

Zinc, Total 0395 , ouster Grall 

PERIIIT BENCHIIARKICUTOFF DtSCHARGE VALUES
 

OUTFALL SW5
 

Siormwate, Runoff
 

efFLUENT BENCHIIARKICUTOFF VALUES _l1lRIIlG

IIOII1HLY REQUIREllENTS 

I EFFLUENT 

DALY 

AVG. cosc, I A\'G. AWt'T. MAX.COSC. :H..U- AlL'\T. M5R.IDT. mlPU , ,....
 CHARAClERISTIC JRQ~C\". n ... ,-'" _I 

Flow Report (MGD)

""­

Report (MGDl Sem,-annuaMy Esnrnate 

pH (s.U.lII) 50 90 Sem-amejv Grab 

Total Sus ndad Solids TSS 150 5em·i1ntlwlIv Grab 

cadmium Total .. 00159 Serl1l·annualt\' Grab 

~Total .' 0,063& Serl1l-annualv Grab 

lead, Total - 0150 SemI-amualy Grab 

,Zinc, Total 0.395 Grab 

pH enaeses sI'lill beperformed WIthin fifteen (15) ml!'lUles ofsample collection 

5em.aooually 

"I 

Nore 

The petmnee ;,hall provide jnedate and IiJrabon (inhours) ofthe QlJahlYlllq stem evenusysampleo rainfall measurements or 

esneeres (in mcresjctme s100n event thai generated the sampled nncn ne duration between the scm event sample-d and 

the end of!he prevous measurable (grealer ltlan01rnell ramlall) storm event and an estimate (Ifme lotal volume otme 

di~arge sampled Flow shall be reported inMillon Gallons per Day (MGD) 

GI,lOa 

HI0029157.doc