STATE OF TENNESSEE 

DEPARTMENT OF ENVIRONMENT AND CONSERVATION 

DIVISION OF WATER POLLUTION CONTROL 

401 CHURCH STREET 

L & C ANNEX 6TH FLOOR 

NASHVILLE TN 37243 

Mr. J. Scott Hambrick 

Plant Manager 

TVA - Bull Run Fossil Plant (BRF) 

1265 Edgemore Rd. 

BRF 1A-CTT 

Clinton, TN 37716 

Subject: Modification to NPDES Permit No. TN0005410 

TVA Bull Run Fossil Plant (BRF) 

Clinton, Anderson County, Tennessee 

Dear Mr. Hambrick: 

Enclosed please find a draft copy of the modified NPDES Permit No. TN0000078 which the Division of 

Water Pollution Control (the "Division") proposes to issue. This draft copy is furnished to you solely for 

your review of its provisions. No wastewater discharges are authorized by this modified permit. The 

issuance of an official modified permit is contingent upon your meeting all of the requirements of the 

Tennessee Water Quality Control Act and the Rules and Regulations of the Tennessee Water Quality 

Control Board. 

Also enclosed is a copy of the public notice that announces our intent to issue this permit. The notice 

affords the public an opportunity to review the draft permit and, if necessary, request a public hearing 

on this issuance process. If you disagree with the provisions and requirements contained in the draft 

permit, you have twenty-five (25) days from the date of this correspondence to notify the division of 

your objections. If your objections cannot be resolved, you may appeal this permit upon issuance. 

This appeal should be filed in accordance with Section 69-3-110 of the Tennessee Code Annotated. 

If you have questions, please contact the division at the local Environmental Field Office at 1-888-891-

TDEC; or, at this office, please contact Bob Alexander at (615) 532-0659 or by E-mail at 

robertalexander@tn.gov. 
cc: DWPC, Permit & Enforcement Sections & Knoxville Environmental Field Office 

Ms. Lindy Johnson, TVA, Ipjohnson@tva.gov 

Ms. Connie A. Kagey, Kagey.Connie@epamail.epa.gov 

Mr. Scott Gollwitzer, scott@appvoices.org 

Mr. Aaron Isherwood, aaron.isherwood@sierraclub.org 

Ms. Kimberly Wilson, lcwilson@environmentalintegrity.org 

Attorney Adam Kron, akron@defenders.org 

Ms. Stephanie Matheny, stephanie@tewn.org 

Mr. Axel Ringe, onyxfarm@bellsouth.net 

Ms. Abigail Dillen, adillen@earthjustice.org 

Mr. John McFadden, john mcfadden@attnet 

Ms. Dana Wright, dana@tcwn.org 
STATE OF TENNESSEE 

No. TN0005410 

MINOR MODIFICATION 

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.C.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 of 

1977 (33 U.S.C. 1251, et seq.) 

Discharger: TVA - Bull Run Fossil Plant (BRE) 

is authorized to discharge: dry fly ash wash down sump, FD fan cooling water, stack yard sump (pulverizer equipment cooling water, 

boiler bay floor drain), boiler bilge sump (boiler bay floor drainage), non-chemical metal cleaning wastes (boiler fireside washing, air 

pre-heater washes, precipitator area sump, ducts washing), ash hopper, economizer, pyrite hopper (ash sluice water), hydroveyors (fly 

ash pumps), precipitator wash down sump (fly ash sump, water from RO treatment), ash pond / gypsum stacking (dewatering facility, 

flue gas desulfurization (FGD) wastewater system, FGD detention basin / sump, FGD area runoff / drainage, coal yard drainage basin / 

sump (fly ash stacking area, coal storage area, yard building dust collector sluice, floor drains, roof drains and sumps, coal tower and 

rail hopper floor / roof drains, utility building roof / floor drains), main station sump (condenser pit sump inflow, equipment cooling water 

and leakage, service bay floor drainage, emergency overflow from demineralizer sump, leakage from boiler make-up water and water 

treatment plant, unwatering sump outside powerhouse pumps 1 and 2, yard runoff, electrical yard runoff, back parking lot runoff, roof 

drains, ash sluice line low point sump), yard drainage basin sump (demineralizer sump (demineralizer system drains), condensate 

polisher wastes, reject water treatment plant, stack yard sump (equipment cooling water, floor washing wastes), ammonia facility 

retention pond, ash sluice line low point sump (yard runoff, back parking lot runoff, electrical yard runoff, runoff coal yard pumping 

basin (coal storage area, fly ash storage area), runoff from ash stacking area, treated metal cleaning waste water (Internal Monitoring 

Point 005), and direct precipitation on ash pond through Outfall 001; main condenser cooling water (COW), miscellaneous 

equipment cooling and lubricating water, and roof drains through Outfall 002; intake screen backwash plus intake building sump, 

discharged to Clinch River via Outfall 004 to cooling water channel 

from a facility located: in Clinton, Anderson County, Tennessee 
(This page intentionally left blank.) 
TABLE OF CONTENTS 

Page 

PART! 1 

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 1 

B. MONITORING PROCEDURES 6 

1. Representative Sampling 6 

2. Sampling Frequency 6 

3. Test Procedures 6 

4. Recording of Results 6 

5. Records Retention 7 

C. REPORTING 7 

1. Monitoring Results 7 

2. Additional Monitoring by Permittee 7 

3. Falsifying Results and/or Reports 7 

4. Outlier Data 8 

D. SCHEDULE OF COMPLIANCE 8 

PART 9 

GENERAL PROVISIONS 9 

A. GENERAL PROVISIONS 9 

1. Duty to Reapply 9 

2. Right of Entry 9 

3. Availability of Reports 9 

4. Proper Operation and Maintenance 9 

5. Treatment Facility Failure 10 

6. Property Rights 10 

7. Severability 10 

8. Other Information 10 

B. CHANGES AFFECTING THE PERMIT 10 

1. Planned Changes 10 

2. Permit Modification, Revocation, or Termination 10 

3. Change of Ownership 11 

4. Change of Mailing Address 12 

C. NONCOMPLIANCE 12 

1. Effect of Noncompliance 12 

2. Reporting of Noncompliance 12 

3. Upset 13 

4. Adverse Impact 13 

5. Bypass 13 
PART III 16 

OTHER REQUIREMENTS 16 

A. ASH POND CLOSURE PLAN 16 

B. DIKE INSPECTIONS MODIFIED MAY 13, 2011 16 

C. TOXIC POLLUTANTS 18 

D. HEAVY METALS MONITORING 18 

E. REOPENER CLAUSE 19 

E. PLACEMENT OF PUBLIC NOTIFICATION SIGNS 19 

F. ANTIDEGRADATION 19 

G. MACROINVERTEBRATE CONTROL MEASURES - BIOCIDE/CORROSION TREATMENT PLAN (B/CTP) 22 

H. RE-ROUTING FLOWS FOR MAINTENANCE PURPOSES 23 

I. FACILITY INTAKE WATER QuALITy MONITORING REQUIREMENTS 23 

J. ALTERNATE THERMAL LIMITATION, SECTION 316(A) OF THE CWA 23 

K. COOLING WATER INTAKE STRUCTURES - PHASE II, SECTION 316(B) OF THE CWA 23 

L. AMMONIA NITROGEN, TOTAL 23 

M. EMERGENCY RESPONSE PLAN 24 

PART IV 25 

BEST MANAGEMENT PRACTICES 25 

PART V 25 

STORM WATER POLLUTION PREVENTION PLAN 25 

PART VI 26 

Definitions and Acronyms 26 

DEFINITIONS 26 

ACRONYMNS AND ABBREVIATIONS 28 

RATIONALE FOR MODIFICATION, MAY 2011 1 

NOTICE OF DETERMINATION August 2010 1 

Comments on Draft Permit and TDEC Responses 1 

BEST PROFESSIONAL JUDGMENT ANALYSIS 17 

Conclusion — Permit Writer's Best Professional Judgment 34 

Attachment 1 41 

BEST MANAGEMENT PRACTICES 41 

RATIONALE, JANUARY 2010 1 

I. DISCHARGER 1 

II. PERMIT STATUS 1 

III. FACILITY DISCHARGES AND RECEIVING WATERS 2 

IVAPPLICABLE EFFLUENT LIMITATIONS GUIDELINES 3 
H. RE-ROUTING FLOWS FOR MAINTENANCE PURPOSES 7 

I. HEAVY METALS MONITORING 8 

J. PROCEDURES FOR WATER QUALITY BASED EFFLUENT STANDARDS 

K. EFFLUENT REQUIREMENTS FOR OUTFALL 001, ASH POND 8 

1. BIOMONITORING REQUIREMENTS, CHRONIC 8 

2. AMMONIA NITROGEN 9 

3. OUTFALL 001 ASH POND DISCHARGE OF METALS 12 

4. OUTFALL 001 - PH 15 

1. BIOMONITORING REQUIREMENTS, CHRONIC 15 

M. OUTFALL 004 16 

N. INTERNAL MONITORING POINT 005 16 

0. USE OF TREATED EFFLUENT FOR DUST CONTROL ON ROADS 17 

P. 316(h) -COMPLIANCE WITH SECTION 316, CLEAN WATER ACT 17 

1. 316(A) POTENTIAL THERMAL EFFECTS ON A BALANCED INDIGENOUS POPULATION OF AQUATIC LIFE 17 

2. 316 (B) - COOLING WATER INTAKE STRUCTURE-316(B) 18 

APPENDIX 1. 20 

FACILITY DISCHARGES AND RECEIVING WATERS 20 

APPENDIX 2 23 

APPENDIX 3 28 

PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS 28 

APPENDIX 3 (CONTINUED) 29 

PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS 29 

APPENDIX 3 (CONTINUED) 30 

PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS 30 

APPENDIX 4 31 

HISTORICAL MONITORING AND INSPECTION 31 

OUTFALL 001 - - 2005 - 09 31 

APPENDIX 4 32 

HISTORICAL MONITORING AND INSPECTION 32 

APPENDIX 4 33 

HISTORICAL MONITORING AND INSPECTION 33 

APPENDIX 5A 34 

PROCEDURES FOR DETERMINING WATER QUALITY BASED EFFLUENT LIMITS 34 

APPENDIX 5B 38 

DETERMINING ASH POND FREE WATER VOLUME 38 
APPENDIX 6 41 

NEW PERMIT LIMITS 41 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 1 of 29 

PART I 

EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 

TVA-Bull Run Fossil Plant (BRF) is authorized to discharge: 

Outfall 001: ash pond effluent consisting of dry fly ash wash down sump, FD fan cooling 

water, stack yard sump (pulverizer equipment cooling water, boiler bay floor drain), boiler bilge 

sump (boiler bay floor drainage), non-chemical metal cleaning wastes (boiler fireside washing, 

air pre-heater washes, precipitator area sump, ducts washing), ash hopper, economizer, pyrite 

hopper (ash sluice water), hydroveyors (fly ash pumps), precipitator wash down sump (fly ash 

sump, water from RO treatment), ash pond / gypsum stacking (dewatering facility, flue gas 

desulfurization (FGD) wastewater system, FGD detention basin / sump, FGD area runoff / 

drainage, coal yard drainage basin I sump (fly ash stacking area, coal storage area, yard 

building dust collector sluice, floor drains, roof drains and sumps, coal tower and rail hopper 

floor / roof drains, utility building roof / floor drains), main station sump (condenser pit sump 

inflow, equipment cooling water and leakage, service bay floor drainage, emergency overflow 

from demineralizer sump, leakage from boiler make-up water and water treatment plant, 

unwatering sump outside powerhouse pumps 1 and 2, yard runoff, electrical yard runoff, back 

parking lot runoff, roof drains, ash sluice line low point sump), yard drainage basin sump 

(demineralizer sump (demineralizer system drains), condensate polisher wastes, reject water 

treatment plant, stack yard sump (equipment cooling water, floor washing wastes), ammonia 

facility retention pond, ash sluice line low point sump (yard runoff, back parking lot runoff, 

electrical yard runoff, runoff coal yard pumping basin (coal storage area, fly ash storage area), 

runoff from ash stacking area, treated metal cleaning waste water (Internal Monitoring Point 

005), and direct precipitation on ash pond through Outfall 001pond 

Outfall 002: Main condenser cooling water (CCW), miscellaneous equipment cooling and 

lubricating water, and roof drains through Outfall 002. 

Outfall 004: intake screen backwash plus intake building sump, discharged to Clinch River via 

Outfall 004 to cooling water channel 

Internal Monitoring Point 005: Via Outfall 001 - Metal Cleaning waste pond, boiler chemical 

cleaning, air preheater washing through Outfall 001. 

These discharges shall be limited and monitored by the permittee as specified below: 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 2 of 29 

PERMIT LIMITS 

OUT FAL L 001 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT AVG. CONC. AVG. AMNT MAX CONC. MAX AMNT MS RMNT. SAMPLE 

CHARACTERISTIC (mg/1) (lb/day) (mgin (lb/day) ERQ NC Y. TYPE 

FLOW Report (MGD) * Report (MGD) * 1/Week Instantaneous 

pH ** Range 6.0 - 9.0 1NVeek Grab 

OIL & GREASE 12.0 -- 16.0 -- 1/Month Grab 

TOTAL SUSPENDED SOLIDS (TSS) 26.0 -- 84.0 -- 1/Month Grab 

NITROGEN, AMMONIA TOTAL (Plant 

Intake) -- -- Report Report 1/Month Grab 

NITROGEN, AMMONIA TOTAL 

(Effluent) 

.. -- Report Report 1/Month Grab 

NITROGEN, AMMONIA TOTAL (Net 

Discharge) -- -- Report   Report 1/Month Calculated 

ALUMINUM, TOTAL -- -- Report .... 1/Month Grab 

ANTIMONY, TOTAL -- -- Report -- 1/Month Grab 

ARSENIC, TOTAL — — Report -- 1/Month Grab 

BARIUM, TOTAL -- -- Report -- 1/Month Grab 

BERYLLIUM, TOTAL -- - Report -- i 1/Month Grab 

CADMIUM, TOTAL -- -- Report -- 1/Month Grab 

CHROMIUM, TOTAL -- -- Report -- 1/Month Grab 

COPPER,TOTAL -- -- Report -- 1/Month Grab 

IRON,TOTAL -- -- Report -- 1/Month Grab 

LEAD, TOTAL -- -- Report -- 1/Month Grab 

MERCURY, TOTAL -- -- Report -- 1/Month Grab 

NICKEL, TOTAL -- -- Report -- 1/Month Grab 

SELENIUM, TOTAL -- -- Report -- 1/Month Grab 

SILVER, TOTAL -- -- Report -- 1/Month Grab 

THALLIUM, TOTAL -- -- Report -- 1/Month Grab 

ZINC, TOTAL -- -- Report -- 1/Month Grab 

CYANIDE, TOTAL -- -- Report -- 1/Month Grab 

1C25 Report (serial dilutions) Once/permi Grab ** * 

Note: The permittee shall take reasonable steps to prevent discharge of cenospheres other than in trace amounts from the 

outfall. 

Flow shall be reported in Million Gallons per Day (MGD). 

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

** See Part III for methodology. 

**** If a calculated value for net addition of ammonia as nitrogen exceeds an action concentration value of 10 mg/Lthe 
TVA-Bulk Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 3 of 29 

PERMIT LIMITS 

OUTFALL 002 

EFFLUENT LIMITATIONS I MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. AM NT. MAX. CONC. MAX. AMNT. MSRMNT. 

FRONCY. 

SAMPLE 

(111 41A) (Ibiday) (moll) (1b/day) TYPE 

FLOW 

TIAN 

Report (MGD) Report (MGD) 1 /Day Estimate 1 

TEMPERATURE, Intake Report -- Report -- 1 / Day Grab 

TEMPERATURE, Effluent .. 3t1°C (88°F) 1 / Day Calculated 2 

TOTAL RESIDUAL OXIDANT 

(reported as chlorine) 3 

0.011 -- 0.019 -- 1 /Week 4 Grab 

TIME OF OXIDANT ADDITION 

(minute/day/unit) -- 120 5 1 / Day Log Records 

IC25 Survival, Reproduction, & Growth in 100% Effluent Once 6 Composite 6 

1 Flow shall be estimated from pump logs and reported in Million Gallons per Day (MGD). 

2. Intake temperature is measured hourlyand reported as the average of the hourly measurements for each day. The daily mak m urn discharge temperature 

shall be calculated for the cooling channel based on the 24-hour average intake temperature, 24-hour average unit load, and the 24-hour average flow through 

Outfall 002 

3 Total Residual Oxidant (IRO) monitoring shall be applicable when bromine or any other oxidants are added. The acceptable methods for analysis of TRO 

are any methods specified in 40 CFR, Part 136. 

4. Except for periods of macroinverlebrate control when mdclant addition is required (see Permit - Part Ill), samples shall be taken once at the beginning of the 

period of chlorination for one unit and once every 15 minutes thereafter. At the end of the period of chlorination, one sample shall be taken. Sampling for these 

midants is not required when there is no chlorine/bromine added during that day. 

5. Application of a oxidant (Prom Ina/chlorine) beyond the 120 minutes per day will be allowed to facilitate nuisance macroinvertebrate control according to the Plan 

for such activities described in Permit- Part III 

6 See Part III for methodology. Toxicity tests shall be periormaed only if biocides are added to the cooling water. 

sheen and the permitee 

waters in a way that 

Ii 

OUTFALL 004 

Intake Screen Backwash Water Plus Intake Building Sump 

No numerical limitations or monitoring requirements. The discharge shall not have a visible oil 

shall take reasonable steps to prevent the return of materials collected on the screens to the receiving 

causes an unattractive condition on the recieving waters. 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 4 of 29 

,_.._ 

OUTFALL 005 

Metal c leaning wastes 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. AMT. MAX CO NC. MAX AND7 T. P4SRMNT. 

FRQ NCY. 

SAMPI.E 

(.14A) (112klity) (me) abida y) TYPE 

FLOW Report MGD) * Report MGD)' 1/Batch Estimate** 

Total Suspended Solids 30.0 -- 100.0 -- Grab 

Oland Grease 15.0 20.0 -- Grab 

COPPER,TOTAL 1.0 — 1.0 -- — Grab 

IRON, TOTAL 1.0 — 1.0 -- Grab 

now shalt be reported in Million Gallons per Day (MGD). 

" Flaw shall be estimated tam pump logs. 

— Samples shall be taken at the beginning and end of a discharge event ton each batch treated. 

Modification, May 2011 

During the process of closure of the Chemical Pond, TVA Bull Run Fossil Plant is authorized to 

discharge rain water from the Chemical Pond into the Ash Pond (Outfall 001)without 

requirements to monitor the discharge at the Chemical Pond (IMP005). TVA will put in place a 

procedure to ensure that no wastewater will be discharged into the Chemical Pond. 

In accordance with the Closure Plan for the Chemical Pond, TVA will decant or dewater the 

chemical pond wastewater, and will monitor the discharge from the Ash Pond (Outfall 001) for 

constituents listed under IMP005 discharge at the Ash Pond Discharge (Outfall 001). 

Monitoring will include sampling prior to decanting / dewatering the Chemical Pond, at least 

once per day during the decanting I dewatering of the Chemical Pond, and once 24-hours after 

the decanting has concluded. TVA will monitor for Total Suspended Solids (TSS), Oil and 

Grease (O&G), Total Copper, and Total Iron at Outfall 001. 

Multiple decanting / dewatering events may be necessary during closure to prevent water from 

accumulating in the pond. TVA will monitor each decanting / dewatering event as described 

above. 

PERMIT LIMITS 

RAW WATER INTAKE MONITORING 

The permittee shall continue to monitor facility intake water for the following effluent characteristics (in mg/I): 

Hardness (as CaCO3), TSS, Aluminum, Antimony, Arsenic, Cadmium, Chromium, Copper, Iron, Lead, 

Manganese, Mercury, Nickel, Selenium, Silver, Zinc, and Cyanide. All metals shall be reported as Total 

Recoverable Metal. All samples reported as "Below Detection Level" shall be analyzed to the Required 

Detection Level (RDL) specified in Tennessee General Water Quality Criteria, Chapter 1200-4-3-.05(8), except 

for Mercury which shall be analyzed by EPA Method 1631 or 245.7. Samples shall be taken annually with at 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 5 of 29 

b. There shall be no distinctly visible floating scum, oil or other matter contained in the 

wastewater discharge. The wastewater discharge shall not cause an objectionable 

color contrast in the receiving stream. 

c. 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. The discharge activity shall not cause or 

contribute to violations of water quality criteria as stated in the TDEC Rules, Chapter 

1200-4-3-.03. Under no circumstances may discharges exceed numeric water 

quality criteria for aquatic and human life as stated in State of Tennessee Rule 

1200-4-3. 

d. 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 

seq. and the Tennessee Hazardous Waste Management Act, TCA 68-46-101 et 

seq. 

e. The intake screen backwash discharged through Outfall 004 shall not contain 

materials other than those naturally occurring in the intake water. The discharge 

shall not have visible oil/petroleum sheen. 

f. For the batch discharges from Outfall (IMP) 005: monitoring and reporting of 

measurements of FLOW, the "Monthly Avg." shall be the total flow volume during the 

reporting period divided by the number of calendar days in that period. The "Daily 

Max." shall be the total flow volume for the day with the greatest amount of 

discharge during the reporting period. Example: 3 discharges of 15,000 gallons/day 

and 1 discharge of 20,000 gallons/day during a 1-month period results in a Monthly 

Avg. of 65,000 gallons/30 days, or 2,166 gallons/day (to be reported as 0.002166 

MGD). The Daily Maximum to be reported for this example is 20,000 gallons/day or 

0.020 MGD. 

g. 40 CFR Part 423.12 (b) (2) (BPT) and Part 423.13 (a) (BAT) specify, "There shall be 

no discharge of polychlorinated biphenyl compounds such as those commonly used 

for transformer fluid." 

h. Total residual oxidant (TRO) monitoring shall be applicable when bromine or any 

other oxidants are added. The acceptable methods for analysis of TRO are any 

methods specified in Title 40 CFR, Part 136 as amended. 

i. For Outfall 001 monitoring and reporting for thallium, the renewed permit will require 

reporting of Thallium using Method 200.8 to obtain 12 monthly data points. At the 
May 2011 

B. MONITORING PROCEDURES 

1. Representative Sampling 

TVA-Bull Run Fossil Plant 

MODIFICATION to NPDES Permit TN0005410 

Page 6 of 29 

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 

storm water runoff or the receiving stream. 

2. Sampling Frequency 

Where the permit requires sampling and monitoring of a particular effluent 

characteristic(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 1/month, the monitoring period is one month, 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 

3. Test Procedures 

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

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

amended, under which such procedures may be required. Analyses of total 

mercury will use either EPA Method 245.7 or Method 1631. 

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. 

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 exact person(s) collecting samples; 

c. The dates and times the analyses were performed; 

d

The person(s) or laboratory who performed the analyses; 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 7 of 29 

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. 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 or 

comparable forms provided by the permittee. Submittals shall be postmarked no later than 15 

days after the completion of the reporting period. The top two copies of each report are to be 

submitted. A copy should be retained for the permittee's files. DMRs and any communication 

regarding compliance with the conditions of this permit must be sent to: 

TENNESSEE DEPT. OF ENVIRONMENT & CONSERVATION 

DIVISION OF WATER POLLUTION CONTROL 

COMPLIANCE REVIEW SECTION 

401 CHURCH STREET, 

NASHVILLE TN 37243-1534 

The first DMR is due to be postmarked by the fifteenth 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 of 

the authorized representative. 

The electronic submission of DMRs will be accepted only if approved in writing by the 

division. For purposes of determining compliance with this permit, data submitted electronically 

is legally equivalent to data submitted on signed and certified DMR forms. 

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. 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 8 of 29 

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 tampering, broken or suspect sample 

containers, sample contamination or similar demonstrated quality control flaw. 

Outlier data are identified through a properly 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), it 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. 

D. SCHEDULE OF COMPLIANCE 

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

permit. 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 9 of 29 

PART 11 

GENERAL PROVISIONS 

A. GENERAL PROVISIONS 

1. Duty to Reapply 

Permittee is not authorized to discharge after the expiration date of 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 of Entry 

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 of Reports 

Except for 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 offices of the Division of Water Pollution 

Control. As required by the Federal Act, effluent data shall not be considered confidential. 

4. Proper Operation and Maintenance 

a. The permittee 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 permitProper operation and maintenance also includes 
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b. Dilution water shall not be added to comply with effluent requirements to achieve 

BCT, BPT, BAT and or other technology-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 of such provision to other circumstances and 

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

8. Other Information 

If the permittee 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 permitnor to notification 
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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 of 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) 

ffS ) 
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4. Change of 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 of 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 

Water 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, if not 

corrected, the anticipated time the noncompliance is expected to 

continue; and 

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

noncomplying discharge. 

b. Scheduled Reporting 
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3. Upset 

a. "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 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: 

i. An upset occurred and that the permittee can identify the cause(s) of 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." 

4. 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. 

5. 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 
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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; 

iii. 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 

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. 

6. Washout 

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

Mixed Liquor 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 "Bypassing," "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 
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2. Liability Under State Law 

Nothing in this permit 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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PART III 

OTHER REQUIREMENTS 

A. ASH POND CLOSURE PLAN 

The permittee shall submit an Ash Pond Closure Plan describing the steps to be taken 

to prevent contamination of surface waters from the inactive site. Within 90 days after the 

permit effective date, the permittee shall define closure actions to be implemented in 

conjunction with conversion from wet ash to dry ash handling and discontinued operation of 

existing ash ponds. 

The permittee will provide quarterly updates on progress toward dry ash 

conversions and ash pond closure with the Discharge Monitoring Reports submitted for 

March, June, September, and December. The report must address, at a minimum, the 

estimated future date for complete closure and elimination of ash pond discharges as well as 

updated information on planning, design, and construction milestones for each upcoming 

quarter. 

B. DIKE INSPECTIONS MODIFIED MAY 13, 2011 

(1) The Bull Run Fossil ash pond shall be inspected in accordance with TVA's Reservoir 

Operations Dam Safety Program criteria and processes. This program is directed by 

TVA's Dam Safety Governance Program and is in accordance with the 'Federal 

Guidelines for Dam Safety' developed by the Federal Emergency Management Agency 

(FEMA 93). This document directs TVA to perform inspections scheduled on specific 

intervals and with qualified personnel. The dikes will also be visually inspected daily 

during operations by site personnel or designee that are trained in dam safety procedures 

by TVA's Dam Safety Governance Program. Impoundments shall be inspected annually 

by a state-registered professional engineer trained and experienced in dam safety 

inspection procedures. Special inspections by qualified personnel shall be done within 24 

hours after intense, large or extended rain events (i.e., 10-year storm or equaling or 

exceeding the design requirements for managing storm water) or as soon as safely 

practicable after a significant seismic event approaching or exceeding the design event. 

The reason for this is to validate structural integrity of the structure following an event that 

could test the design assumptions. 

(2) Daily inspections shall, at a minimum, include observations of dams, dikes and toe areas 

for erosion, cracks or bulges, subsidence, seepage, wet or soft soil, changes in 

geometry, the depth and elevation of the impounded water, sediment or slurry, freeboard, 

changes in vegetation such as overly lush, obstructive vegetation and trees, outlet 

controls, drains and any other changes which may indicate a potential compromise to 

impoundment integrity. TVA must prepare a checklist in accordance with proper TVA 

Dam Safety Governance Program requirements with review and written concurrence from 
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May 2011 MODIFICATION to NPDES Permit TN0005410 

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findings of each inspection along with the specific qualifications of the inspector shall be 

summarized and documented in the annual report. The permittee shall submit the first annual 

report no later than 18 months after the effective date of the permit. 

(4) Remediation Measures. Within 24 hours of discovering changes that indicate a potential 

compromise to the structural integrity of the impoundment, the permittee shall begin 

procedures to remediate the problem. Changes such as significant increases in seepage or 

seepage carrying sediment may be signs of imminent impoundment failure and should be 

addressed immediately. 

Other issues which may have long term impacts on integrity, such as trees growing on the 

embankment (especially large, dead or tilting trees, with special concern for those at the toes 

of or within the saturated zones of embankment structures), or vegetation-blocking overflows 

or spillways, shall be removed according to approved geotechnical engineering practices and 

instructions. 

2. Reporting and Recordkeeping Requirements for Impoundments 

(1) Imminent impoundment failure conditions should be reported immediately to TDEC and the 

Anderson County Emergency Management Agency, who will report to TEMA. 

(2) Within 24 hours of discovering a change in the impoundment that indicates a potential 

compromise to the structural integrity of the dike (e.g., significant changes in seeps, boils, 

bulges, or cracks), the permittee must make contact with division personnel describing the 

findings of the inspection, corrective measures taken or proposed (if known), and expected 

outcomes. TVA must keep current a list of division personnel complete with after-hours 

contact information and must speak directly to someone on this list within the 24 hour period. 

Failure to notify the division within 24 hours will be a violation of this permit. In addition, the 

permittee must submit a follow-up report within 5 days summarizing the incident, corrective 

actions taken and outcomes. Additional reports pertaining to the event may be required by 

the Director. 

(3) The permittee shall submit an annual report to the division summarizing findings of all 

monitoring activities and measurements, inspections, and remediation measures pertaining to 

the structural integrity, design, construction, and operation and maintenance of all 

impoundments. 

(4) The permittee shall maintain records of all impoundment inspection and maintenance 

activities, including corrective actions made in response to inspections and all other activities 

undertaken to repair or maintain the impoundment. The permittee shall also maintain records 

of any measurements and evaluation of safety factors. All records shall be kept on site and 

made available to State or Federal inspectors upon request. 
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(6) Permit Re-opener Requirement 

The Director may re-open this permit to incorporate more stringent requirements or any 

applicable standards pertaining to the operation and maintenance of coal combustion waste 

impoundments. 

C. 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 substance(s) (listed at 40 CFR 122, Appendix D, Table II 

and III) 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 ug/l); 

b. Two hundred micrograms per liter (200 ug/I) for acrolein and acrylonitrile; five 

hundred micrograms per liter (500 ug/I) for 2,4-dinitrophenol and for 2-methyl4,6-dinitrophenol; and one milligram per liter (1 mg/L) for antimony; 

c. Five (5) times the maximum concentration value reported for 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 ugA); 

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). 
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concentrations are maintained and shall submit the report to the Division with the monthly DMR 

once per year. 

E. REOPENER CLAUSE 

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

(D), 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. 

E. PLACEMENT OF PUBLIC NOTIFICATION 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/overflow point in the collection system. For 

the purposes of this requirement, any bypass/overflow 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 ### 

TVA Bull Run Fossil Plant (BRF) 

(Permittee's Phone Number) 

NPDES Permit NO, TN0005410 

TENNESSEE DIVISION OF WATER POLLUTION CONTROL 

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

F. 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 the 

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

compliance required to implement applicable water quality standards, to comply with a State 
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The permittee shall conduct a 3-Brood Ceriodaphnia dubia Survival and Reproduction 

Test and a 7-Day Fathead Minnow (Pimephales promelas) Larval Survival and Growth Test on 

the same samples of final effluent from Outfall 001 once durincithe permit period during the 

permit period and Outfall 002 annually (only when biocides are used). 

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

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

determined based on a 25% reduction as compared to the controls. The average reproduction 

and growth responses will be determined based on the number of Ceriodaphnia dubia or 

Pimephales promelas larvae used to initiate the test. A separate statistical analysis based on 

survival information is not required. 

Test shall 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 tables: 

Outfall 001 

Serial Dilutions for Whole Effluent Toxicity (WET) Testing 

4 X 

IWC 

2 X 

IWC 

Instream 

Wastewater 

Concentration 

(IWC) 

0.5 X 

IWC 

0.25 X 

IWC Control 

% effluent 

58.9 29.4 14.7 7.4 I 3.7 0 

Outfall 002 

Serial Dilutions for Whole Effluent Toxicity (WET) Testing 

Permit Limit 

(P L) 0.50 X PL 0.25 X PL 0.125 X PL 0.0625 X PL Control 

% effluent 

100 50 25 12.5 6.25 0 

The dilution/control water used will be a moderately hard water as described in ShortTerm Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to 

Freshwater Organisms, EPA-821-R-02-013 (or the most current edition). Results from a chronic 
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samples run concurrently with the effluent test are also shown to be toxic enough to represent a 

test failure (100 percent samples statistically less than controls using t-tests and minnow growth 

or daphnid reproduction is 25 percent less than controls), the test will be repeated and no 

permit violation will be issued. Effluent toxicity demonstrated by the tests specified herein which 

is not shown to be related to ambient conditions constitutes a violation of this permit. 

All tests will be conducted using a minimum of three 24-hour flow-proportionate 

composite samples of final effluent (e.g., collected on days 1, 3 and 5). If, in any control more 

than 20% of the test organisms die in 7 days, the test (control and effluent) is considered invalid 

and the test shall be repeated within 30 days of the date the initial test is invalidated. 

Furthermore, if the results do not meet the acceptability criteria as defined in Methods for 

Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine 

Organisms, EPA-821-R-02-013 (or the most current edition), or if the required concentrationresponse review fails to yield a valid relationship per guidance contained in Method Guidance 

and Recommendations for Whole Effluent Toxicity (WET) Testing, 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. 

For Outfall 001, the toxicity tests specified herein shall be conducted once during 

the final 18 months of the new permit term and the results of these tests submitted with 

the next permit application. The toxicity tests at Outfall 002 specified herein shall 

commence no later than 90 days from biocide application. If no biocides are added, 

Outfall 002 discharges consist of raw river water to which no chemicals are added. Future 

requirements may be added as a Biocide / Chemical Treatment Plan (B/CTP) is developed 

In the event of a test failure, the permittee must 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 corresponding table(s) above. The follow-up test will not negate an initial failed test. In 

addition, the failure of a follow-up test will constitute a separate permit violation which 

must also be reported. 

In the event of 2 consecutive test failures or 3 test failures within a 12 month period for 

the same outfall, the permittee must initiate a Toxicity Identification Evaluation/Toxicity 

Reduction Evaluation (TIE/TRE) study within 30 days and so notify the division by letter. This 

notification shall include a schedule of activities for the initial investigation of that outfall. During 

the term of the TIE/TRE study, the frequency of biomonitoring shall be once every three 

months. Additionally, the permittee shall submit progress reports once every three months 

throughout the term of the TIE/TRE study. The toxicity must be reduced to allowable limits for 

that outfall within 2 years of initiation of the TIE/TRE study. Subsequent to the results obtained 

from the TIE/TRE studies, the permittee may request an extension of the TIE/TRE study period 

if necessary to conduct further analyses. The final determination of any extension period will be 

made at the discretion of the division. 
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Test procedures, quality assurance practices, determinations of effluent 

survival/reproduction and survival/growth values, and report formats will be made in accordance 

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

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

Two copies of biomonitoring reports (including follow-up reports) shall be submitted to 

the division. One copy of the report shall be submitted along with the discharge monitoring 

report (DMR). The second copy shall be submitted to the local Division of Water Pollution 

Control office address: 

Environmental Field Office- Knoxville 

Division of Water Pollution Control 

3711 Middlebrook Pike, Suite 220 

Knoxville, TN 37921-8332 

G. MACROINVERTEBRATE CONTROL MEASURES - BIOCIDE/CORROSION 

TREATMENT PLAN (B/CTP) 

Previous permits addressed "toxic chemicals", biocide(s), and slimicide(s) use at the site 

for process and non-process flows in a Best Management Plan (BMP) program. A new 

program for managing the use of these products shall be developed under a Biocide/Corrosion 

Treatment Plan (B/CTP). This plan is similar to other major-classed TVA facilities in Tennessee. 

The B/CTP shall describe chemical applications and macroinvertebrate controls; include 

all material feed rates, and proposed monitoring schedule(s) to verify that effluent limitations 

are being met and water quality is being protected. The permittee shall conduct treatments of 

intake or process waters under this permit using biocides, dispersants, surfactants, corrosion 

inhibiting chemicals, or detoxification chemicals in accordance with conditions approved and 

specified in the previous permit for a period of no more that 8-months after the effective date of 

the permit to allow time for TVA to create the B/CTP and also allow time for the division to 

review and approve the B/CTP. At that later date, Whole Effluent Toxicity testing (WET) 

frequency and results reporting will be governed by the B/CTP. 

The permittee shall maintain the [new] B/CTP plan at the facility and make the plan 

available to the permit issuing authority upon request. The permittee shall amend the B/CTP 

plan whenever there is a change in the application of the chemical additives or change in the 

tif thfilittht tillithttil fthtiititlt i
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H. RE-ROUTING FLOWS FOR MAINTENANCE PURPOSES 

The permittee shall be allowed to re-route flows past normal monitoring points as a 

temporary measure for maintenance activities. However, such re-routing must be done in such 

a way that permit limitations are still being met in the receiving waters and compliance with 

permit limitations is monitored and reported on the DMR's for the re-routed flows. The receiving 

waters must be the same for the re-routed flows as for the normal discharges. 

I. FACILITY INTAKE WATER QUALITY MONITORING REQUIREMENTS 

The permittee shall annually monitor the facility intake water for the following effluent 

characteristics (in mg/1): Hardness (as CaCO3), TSS, Aluminum, Antimony, Arsenic, Cadmium, 

Chromium, Copper, Iron, Lead, Manganese, Mercury, Nickel, Selenium, Silver, Zinc, and 

Cyanide. All metals shall be reported as Total Recoverable Metal. All samples reported as 

"Below Detection Level" shall be analyzed to the Required Detection Level (RDL) 

specified in Tennessee General Water Quality Criteria, Chapter 1200-4-3-.05(8) except for 

Mercury which shall be analyzed by EPA Method 1631 or 245.7. Two copies of the 

monitoring results shall be submitted with the Discharge Monitoring Report in the month 

following sample collection. 

J. ALTERNATE THERMAL LIMITATION, SECTION 316(A) OF THE CWA 

316(a) alternate thermal variance remains in effect for the duration of the permit cycle. 

For more detail, refer to the rationale portion of this permit and Title 40, Code of Federal 

Regulations, §125.73 "Criteria and standards for the determination of iterative effluent 

limitations under section 316(a)". 

Within 60 days of the permit effective date, the permittee shall prepare and submit for 

review by the Division and EPA Region 4 a study plan which outlines how the permittee will 

conduct assessments that will generate information sufficient to support a determination of 

whether the Bull Run Plant's alternative thermal limit under Section 316(a) can be continued in 

its next NPDES permit. The proposed study plan shall be designed to supplement information 

previously provided by the permittee. The permittee shall implement provisions of the plan 

within 60 days of its approval by the Division. 

K. COOLING WATER INTAKE STRUCTURES - PHASE II, SECTION 316(B) OF THE 

CWA 

316(b) limitations for this facility are determined to be in compliance based on best 

professional judgment in accordance with 40 CFR 401.14 and 122.43. This permit may be 

reopened to address compliance with the Rule (316(b)) requirements upon reissuance of a new 

rule or final guidance by the U.S. Environmental Protection Agency (U.S. EPA). 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 24 of 29 

operation of the equipment, which involves injection of ammonia nitrogen into the process, has 

been underway prior to the previous permit. 

Wastewater volume of 18.7 MGD discharged from Outfall 001 in this application is only 

marginally different from the previous permit of 17 MGD. Although the potential exists for 

effluent discharged from this outfall to contain increased amounts of ammonia nitrogen, 

reported concentrations of intake and effluent do not show substantial differences of 0.1 mg/I 

and 0.2 mg/I, respectively. 

To assess the potential for ammonia toxicity in the receiving stream, TDEC uses a 

spreadsheet calculation which considers stream pH and temperature, as shown below. These 

calculations indicate the allowable effluent concentration of 11 mg/I would be required to protect 

water quality. Accordingly, the renewed permit shall continue monitoring only at Outfall 001 for 

ammonia. 

Monitoring, on a report basis, will include inflow (sampled at the skimmer wall or at a 

comparable location) and effluent from Outfall 001. The net discharge will be calculated and 

reported. If a calculated value for net addition of ammonia as nitrogen exceeds an action 

concentration value of 0.45 mg/L, the permittee shall investigate source(s) of ammonia, and 

proceed with a corrective action(s), if necessary. Furthermore, EFO - Knoxville shall be notified 

within 24 hours from the time the permittee receives results indicating that an action value of 

1.0 mg/L was exceeded. Monitoring will be performed on a monthly basis, using grab samples. 

M. EMERGENCY RESPONSE PLAN 

For purposes of this NPDES permit, TVA Bull Run Fossil Plant must develop an Emergency 

Response Plan which addresses the TDEC Advisory Board Lessons Learned, 2009: 

"a preparedness plan that consider[s] a boundary for potentially affected topographic 

features based on mud flow and wave propagation to develop requirements for CCW 

storage that will minimize any life threatening effects due to failure." 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 25 of 29 

PART IV 

BEST MANAGEMENT PRACTICES 

Best Management Practices (BMPs) are incorporated as permit conditions to specifically 

address controls on toxic metals in ash pond discharges. These controls can be site-specific 

to BRF operations and practices to address the circumstances of individual fossil plants. Each 

practice must be developed and measured to document the relationship between operations 

and effluent metals concentrations. 

BMPs should be established based on guidance shown in Attachment 1 with submission 

of a BMP Plan for division review within 90 days following the permit Effective Date. 

PART V 

STORM WATER POLLUTION PREVENTION PLAN 

Storm water runoff at the BRF plant that is not discharged through Outfalls 001 and 002 

via the ash pond is authorized under the Tennessee Storm Water Multi-Sector General Permit 

for Industrial Activities (TMSP), Permit Number TNR053185. The Plant shall maintain the 

existing approved storm water pollution prevention plan (SWPPP) pursuant to the requirements 

as set forth in the Tennessee Multi-Sector General Permit for Industrial Activities, Sector 0: 

"Storm Water Discharges Associated With Industrial Activity From Steam Electric Power 

Generating Facilities", and Sector L: "Storm Water Discharges Associated With Industrial 

Activity From Landfills and Land Application Sites." 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 26 of 29 

PART VI 

Definitions and Acronyms 

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. 

A "composite sample", in general is a sample collected continuously over a period of 24-hours at a 

rate proportional to the flow. Composite sample should be a combination of at least 8 sample aliquots 

of at least 100 milliliters, collected at periodic intervals during the operating hours of a facility over a 24-

hour period. 

The "daily maximum amount", is a limitation measured in pounds per day (1b/clay), on the total 

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

The "daily maximum concentration" is a limitation on the average concentration in units of mass per 

volume (e.g. milligrams per liter), 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. 

"Degradation" means the alteration of the properties of waters by the addition of pollutants or removal 

of habitat. 

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

A "dry weather overflow" is a type of sanitary sewer overflow and is defined as one day or any portion 

of a day in which unpermitted discharge of wastewater from the collection or treatment system other 

than through the permitted outfall occurs and is not directly related to a rainfall event. Discharges from 

more than one point within a 24-hour period shall be counted as separate overflows. 

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 nthroot of the product of the individual values where 

"n" is equal to 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). 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 27 of 29 

The "instantaneous maximum concentration" is a limitation on the concentration, in milligrams per 

liter, of any pollutant contained in the wastewater discharge determined from a grab sample taken from 

the discharge at any point in time. 

The "instantaneous minimum concentration" is the minimum allowable concentration, in milligrams 

per liter, of a pollutant parameter contained in the wastewater discharge determined from a grab 

sample taken from the discharge at any point in time. 

The "monthly average amount', is a discharge limitation measured in pounds per day (lb/day), is the 

total amount of any pollutant in the discharge by weight during a calendar month divided by the number 

of days in the month that the production or commercial facility was operating. Where less than daily 

sampling is required by a permit, 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. For the purpose of this definition, a frequency of 2/Month 

is representative of 2 separate daily samples, each sample having been collected on a separate day 

during the monitoring period. 

The "monthly average concentration", other than for E. coil bacteria, is a limitation on the discharge 

concentration, in milligrams per liter (mg/L), and is the arithmetic mean of all daily concentrations 

determined in a one calendar month period. For the purpose of this definition, a frequency of 2/Month 

is representative of 2 separate daily samples, each sample having been collected on a separate day 

during the monitoring period. 

A "one week period' (or "calendar-week') 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 "quarter" is defined as any one of the following three-month periods: January 1 through March 31, 

April 1 through June 30, July 1 through September 30, and/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 ecoregion 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. 

A "sanitary sewer overflow (SSO)" is defined as an unpermitted discharge of wastewater from the 

collection or treatment system other than through the permitted outfall. 

For the purpose of this permit, "semi-annually" means the same as "once every six months." 

Measurements of the effluent characteristics concentrations may be made anytime during a 6 month 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 28 of 29 

become inoperable, or substantial and permanent loss of natural resources which can reasonably be 

expected to occur in the absence of a bypass or SSO. Severe property damage does not mean 

economic loss caused by delays in production. 

"Sewerage system" means the conduits, sewers, and all devices and appurtenances by means of 

which sewage and other waste is collected, pumped, treated, or disposed. 

A "subecoregiori' 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 of 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 thereof except those bodies of 

water confined to and retained within the limits of private property in single ownership which do not 

combine or effect 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 to represent storm water runoff which, in combination with all 

process and/or non-process wastewater discharges, as applicable, is discharged during a qualifying 

storm event. 

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. 

ACRONYMNS AND ABBREVIATIONS 

1Q10 — 1-day minimum, 10-year recurrence interval 

30020 — 30-day minimum, 20-year recurrence interval 

7Q10 — 7-day minimum, 10-year recurrence interval 

BAT — best available technology economically achievable 

BCT — best conventional pollutant control technology 

BDL — below detection level 

BOD5— five day biochemical oxygen demand 

BPT — best practicable control technology currently available 
TVA-Bull Run Fossil Plant 

May 2011 MODIFICATION to NPDES Permit TN0005410 

Page 29 of 29 

CSO — combined sewer overflow 

CWA — Clean Water Act 

DMR — discharge monitoring report 

D.O. — dissolved oxygen 

E. coil — Escherichia coil 

EFO — environmental field office 

LB(Ib) - pound 

IC25 — 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/1) — milligrams per liter 

ML — minimum level of quantification 

ml — milliliter 

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 

POTW — 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 

TIETTRE — toxicity identification evaluation/toxicity reduction evaluation 

TMDL — total maximum daily load 
TVA-Bull Run Fossil Plant 

May 2011 Rationale - MODIFICATION to NPDES Permit TN0005410 

Page R- 1 of R-1 

RATIONALE FOR MODIFICATION, MAY 2011 

TVA - Bull Run Fossil Plant (BRF) 

NPDES PERMIT NO. TN0005410 

Bull Run, Anderson County, Tennessee 

Permit Writer: Mr. Bob Alexander 

1. Revision to Dike Inspection Language 

Minor revisions are made to clarify training and recordkeeping procedures by facility 

personnel in relation to the TVA Dam Safety Program. Specifically, the revisions require use of 

a checklist for inspections which is based upon the TVA Dam Safety Program. 

2. TVA requests Adding notation to Outfall 004 description to include building sump added to 

intake screen backwash: 

TDEC concurs, since this does not change the permit approach that the backwash should not 

contain anything that is not already present in the river and found in the intake. 

3. Clarification of Outfall 005 Chemical Pond Monitoring Provisions during Pond Closure: 

The NPDES Permit issued in September 2010 required submission of an Ash Pond Closure 

Plan, received in January 2011. Closure of the Chemical Pond, Outfall 005 is one of the first 

closure projects to be addressed. TVA has proposed monitoring provisions for the ash pond 

discharge at Outfall 001 which will include the dewatering of the chemical pond. These 

provisions include the same metals — copper and iron — plus TSS, Oil and Grease as required 

by EPA effluent guidelines. 

TDEC concurs with the proposed monitoring at Outfall 001 during the Chemical Pond closure. 

4. Deleting the Ash Pond Free Water Volume (FWV) requirement from Outfall 001: 

Since the permit provision is based on a 1985 EPA memorandum which preceded the Effluent 

Guidelines of 1988, the inclusion of an FWV requirement is subject to the permit writer's 

discretion. The BRF permit stipulates an effluent TSS concentration based upon the ELGs and 

it remains in effect. The several BMPs used by TVA to maintain compliance with effluent TSS 

are working. 

Because TVA has committed to dry ash conversion at BRF and other plants, the operation and 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 1 of NOD - 41 

NOTICE OF DETERMINATION August 2010 

With Record of 

Comments on Draft Permit and TDEC Responses 

National Pollutant Discharge Elimination System 

TVA Bull Run Fossil Plant, Clinton, TN 

NPDES Permit No. TN0005410 

August 30, 2010 

I. Summary 

On August 25, 2007, the Tennessee Valley Authority (TVA) submitted an application for an 

NPDES Permit for the discharge of effluent from the combined bottom ash- gypsum settling pond 

at the Bull Run Fossil Plant (BRF) in Clinton, TN. The TN Department of Environment and 

Conservation (TDEC), Division of Water Pollution Control (the division) published a draft permit 

TN0005410 for the facility on January 25, 2010. Also, the division issued a public notice on the 

availability of the draft permit for public review and for a public hearing to be held in Oak Ridge, 

TN. The hearing was held on March 2, 2010, and was followed by a comment period through April 

12, 2010. 

This Notice of Determination addresses comments presented at the hearing and submitted during 

the public notice period. It also presents TDEC's decision regarding the permit and rationale for 

that decision. 

Comments are shown below with TDECs response and proposed permit changes, as applicable. 

Written comments are, for the most part, shown verbatim. Lengthy comments have been 

paraphrased from multiple-page comments which included background and spreadsheets of data. 

The full length documents are available for review on request. Verbal comments from the April 10, 

2010 public hearing are paraphrased. Comments are shown in plain text with responses shown 

in bold text. 

II. TVA Coal Byproduct Process Conversion 

TDEC recognizes that the TVA's Board of Directors decided on August 20th, 2009, to convert wet 

fly-ash and bottom ash handling systems to dry-ash handling systems at six of TVA's eleven coalburning plants. The decision also included converting gypsum dewatering facilities and closing 

ash and gypsum ponds. Pending development of new measures based on the TVA Board 

decision, the NPDES permit provisions will remain in effect. BRF is one of the six facilities 

scheduled for the conversion. 

Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 2 of NOD - 41 

Ill. Administrative Record 

The permit rationale (or fact sheet) dated January, 2010, sets forth the division's basis for permit 

conditions to be applied for the issuance of the Tennessee NPDES permit for the facility 

discharges. The permit authorizes point source discharges to waters of the State of Tennessee 

from the facility. 

On January 25, 2010, the division issued Public Hearing Notice PH10-03, which announced a 

public hearing, conducted on Tuesday, March 2, 2010, at 6 p.m. (EDT). 

On January 25, 2010, the division issued Public Notice #MMIX-002, which announced its intent to 

issue the permit. The draft permit was made available in an electronic format on the division's web 

site at http://www.state.tn.usienvironment/wpc/wpcppo/. The NPDES permit was drafted in 

accordance with the provisions of the Federal Water Pollution Control Act, the Tennessee Water 

Quality Control Act, and other applicable standards and regulations. At the request of 

Environmental Integrity Project and other groups, the division received comments through April 12, 

2010. This Notice of Determination (NOD) serves as the division's response to questions, 

comments and issues that were raised at the hearing and/or submitted during the subsequent 

comment period. 

IV. Facility Description 

BRF discharges approximately 19 MGD from a retention pond into the Clinch River at mile 46.3 via 

the plant discharge channel. BRF discharges consist of ash transport water, chemical and nonchemical metal cleaning wastewaters, coal pile runoff, low volume wastes, storm water runoff, 

miscellaneous equipment cooling and lubricating water from Outfall 001 and Outfall 006 

(emergency overflow), main condenser cooling water, miscellaneous equipment cooling and 

lubricating water and sewage treatment plant effluent from Outfall 002, intake screen backwash 

water through Out-fall 004, and metal cleaning waste water through Outfall 005 to Clinch River at 

mile 48.0. Discharged wastewater originates from the process of generation of electric power from 

a fossil-fueled steam-electric plant. The plant has one coal-fired unit with a generating capacity of 

950 megawatts. 

V. Permit History 

Permit was last modified in November, 2007, and expired on March 30, 2008 with an 

administrative extension for current coverage of daily operations at the Bull Run Fossil Plant. 

VI. Public Review Comments and Responses 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 3 of NOD - 41 

Comment 1: 

Permit title page and page 1 of 25 descriptions of Outfalls: the description of Outfalls on the title 

page and on page 1 of 25 should match the flow diagram included with the permit application. 

RESPONSE: 

Revisions were made in the permit. 

Comment 2: 

Revised monitoring frequencies were requested based on the reported concentrations being 

much lower than calculated effluent concentrations deemed necessary to protect water quality. 

Requested revisions include: 

• arsenic, low level mercury, and thallium be reduced from monthly to quarterly; 

• cadmium, chromium, copper, lead, nickel, selenium, silver, and zinc be reduced from 

monthly to annually; 

• IC25 be changed from annually to once during the permit term. 

RESPONSE: TDEC will retain proposed monthly monitoring frequency for toxic metals for 

a period of twelve (12) months in order to establish a data record previously not available. 

TDEC and TVA will re-evaluate the monitoring frequency at the end of this 12-month period 

upon permittee's request. Considering existing toxicity data, the division agrees that Whole 

Effluent Toxicity testing can be changed from annually to once during the period. This will 

match the language in Part Ill, E. Biomonitoring Requirements and in the Rationale Part I, 

Section 1. Biomonitoring Requirements. 

Comment 3: 

Page 15 of 25, B. Dike Inspections: Section.2.(b) of the permit should be revised to be more 

specific as to the circumstances in which the division should expect written notifications. The 

following language was suggested to be consistent with the agreed to language in the Johnsonville 

NPDES Permit (TN0005444): 

"Within 5 days of discovering a change in the impoundment that could reasonably be 

expected to indicate a compromise of the structural integrity of the dike (e.g., 

significant changes in seeps, boils, bulges, or cracks), the permittee must notify the 

division in writing describing the findings of the inspection, corrective measures 

taken, and expected outcomes. Failure to do so will be a violation of this permit." 

RESPONSE: Suggested language was included in the final permit. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 4 of NOD - 41 

Comment 4: 

Page 17 of 25, E. Biomonitoring Requirements, Chronic: the following language (shown as bold 

and underlined) should be used for clarification of toxicity sampling requirements: 

Permittee shall conduct a 3-Brood Ceriodaphnia dubia Survival and Reproduction Test and 

a 7-Day Fathead Minnow (Pimephales promelas) Larval Survival and Growth Test on the 

same samples of the final effluent from Outfall 001 once during the permit period and 

Outfall 002 annually (only when biocides are used). 

RESPONSE: Suggested language was included in the final permit. 

Comment 5: 

The following serial dilutions used in toxicity testing were suggested (Outfalls 001 and 002): 

Serial Dilutions for Whole Effluent Toxicity (WET) Testing at Outfall 001 

4 X 

IWC 

2 X 

IWC 

instream 

Wastewater 

Concentration 

(IWC) 

0.5 X 

IWC 

0.25 X 

IWC 

Control 

% effluent 

58.9 29.4 14.7 7.4 3.7 0 

Serial Dilutions for Whole Effluent Toxicity (WET) Testing at Outfall 002 

Permit Limit 

(PL) 0.50 X PL 0.25 X PL 0.125 X PL 

Control 

0.0625 X PL 

% effluent 

100 50 25 12.5 6.25 0 

In addition, following changes on Page 18 of 25, E. Biomonitoring Requirements, Chronic were 

requested (changes are shown as bold and underlined): 

Furthermore, if the results do not meet the acceptability criteria as defined in 

Short-Term Methods for Estimating the Chronic toxicity of Effluents and Receiving 

Waters to Freshwater Organisms, 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) Testing, EPA-821-B-00-004 (or the most current 

edition)that test shall be repeated
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 5 of NOD - 41 

added, Outfall 002 discharges consist of raw river water to which no chemicals are 

added. Future requirements may be added as a Biocide / Chemical Treatment Plan 

(B/CTP) is developed. 

RESPONSE: Suggested changes and language were included in the final permit. 

Comment 6: 

Page 20 of 25, J. Ash Pond Volume Requirements: Free Water Volume (FWV) requirement of 

40.5 MG should remain unchanged from the previous permit. Based on TVA's Free Water 

Volume reports submitted on November 30, 2009, the FWV was 86.2 MG 

RESPONSE: FWV in the proposed permit was listed as 40.5 MGD. Therefore, no permit 

revision is required as a result of this comment. 

Comment 7: 

Additional corrections to the Rationale for biomonitoring language were suggested. 

RESPONSE: Since the January 2010 Rationale is not a legally binding document, changes 

are not made. in the terms of the permit regarding biomonitoring, the monitoring 

provisions have been updated as stated above in Response to Comment 5. 

Comment 8: 

Page R-12 of R-43, 2. Ammonia Nitrogen — The table on this page should be modified to East 

Tennessee temperatures instead of West Tennessee temperatures in the calculations. 

RESPONSE: The commenter may be correct that different temperature value could be used 

in calculations. However, since monitoring requirement in the proposed and final permit 

are on report basis only, no changes or corrections are necessary. 

Comment 9: 

Comments were received on the issue of Thallium limits, laboratory analyses, and Detection 

Limits. Factors to be considered in finalizing the permit requirements and limits should include the 

following factors: 

• Background concentration of Thallium in the Clinch River is <1 ug/l, per EPA Method 

279.1. 

• TN WQC for Drinking Water Supply is 2.0 ugh and for Fish & Aquatic Life/Water & 

Organisms is 024 ug/I
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 6 of NOD - 41 

RESPONSE: 

While the Water and Organisms Criteria Thallium limit listed in TDEC Chapter 1200-4-3 is 

0.24 pg/L, we acknowledge the current EPA approved analytical methods do not measure 

down to that concentration. 

Since TVA data has been reported as "Less-Than" values, there is no basis for determining 

compliance against the WQC. Because of the availability of a more sensitive method, i.e., 

not using the ICP-MS Method 200.8. Accordingly, the renewed permit will require reporting 

of Thallium using this method to obtain 12 monthly data points. 

At the end of 12 months reporting, TVA and TDEC will reevaluate the need for further 

monitoring or a permit limit. 

Comment 10: Additional details should be included in the study plan for documentation of thermal 

effects under Section 316(a) of Clean Water Act. TDEC should seek to reduce or eliminate 

detrimental impact of thermal effects by establishing grounds for a thermal variance, or discarding 

the thermal variance in favor of thermal pollution limits and monitoring requirements that are 

protective of the Clinch River. 

RESPONSE: The permit will extend the thermal variance, with the condition that TVA will 

revise the reservoir monitoring approach acceptable to both TDEC and EPA Region 4 

during this permit cycle. The objective of the study plan will be to generate information 

sufficient to support a determination of whether the BRF alternative thermal limit under 

Section 316 (a) can be continued in the next NPDES permit. For this permit cycle, the RFAI 

data compiled by TVA upstream and downstream of BRF demonstrate that a balanced 

indigenous population is being maintained in the receiving water body. 

Comment 11: TDEC Must Establish Technology-Based Effluent Limits in the Bull Run Fossil Plant 

NPDES Permit. While EPA's forthcoming ELGs will address the full suite of pollutants discharged 

by coal-fired power plants, the new rules will not be finalized for several years. In the interim, the 

Clean Water Act requires that TDEC use its best professional judgment to set BAT-based TBELs 

to limit pollution and protect the Clinch River. Specifically, EPA has identified 27 pollutants to 

analyze in CCW wastewaters, including: 

aluminum, antimony, arsenic, barium, beryllium, boron, cadmium, calcium, 

chromium, cobalt, copper, iron, lead, magnesium, manganese, mercury, 

molybdenum, nickel, selenium, silver, sodium, thallium, tin, titanium, vanadium, 

yttrium, and zinc. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 7 of NOD - 41 

The BPJ analysis addresses the process of setting numeric effluent limits for metals in the 

renewed permit, as well as EPA's ongoing process for publishing revised Effluent 

Limitations Guidelines (ELGs) and TVA's process of converting to dry ash handling. 

The regulation of BRF's waste streams was addressed by the 1982 Steam Electric Power 

Generating ELGs which are the basis for the technology-based effluent limitations in BRF's 

draft NPDES permit. The ELGs do not include metals, other than for chemical metal 

cleaning wastes. EPA regulations give permit writers broad discretion to determine 

whether and when to develop additional limits for waste streams or pollutants not covered 

by ELGs applicable to an industry category. 

The Clean Water Act does not require TDEC either to conduct a Best Available Technology 

(BAT) analysis or to impose BAT limits where TDEC has reasonably concluded, as in the 

case of BRF, that the pollutants will not be discharged at levels likely to cause toxic effects. 

In addition, EPA's 2009 study report on the Steam Electric Generating Point Source 

Category is a preliminary characterization of steam electric plant wastewaters and 

potentially available technologies. It is not determinative on the issue of BAT limits. 

Comment 12: TDEC Must Establish Water Quality-Based Effluent Limits in the Bull Run Fossil 

Plant NPDES Permit. In addition to setting WQBELs in the Bull Run Fossil Plant NPDES permit, 

TDEC should consider adding the Tennessee River to the state's 303(d) listing of impaired waters 

for mercury, iron, cyanide, antimony, manganese, and aluminum, as levels of these pollutants 

already exceed the protective WQC set by Tennessee and/or EPA near the Bull Run Fossil Plant. 

RESPONSE: 

An updated spreadsheet of reasonable potential calculations is attached to this NOD 

addressing all 27 pollutants listed in the comment 11. The reasonable potential 

calculations indicate instream concentrations of pollutants discharged from Outfall 001 do 

not exceed TN WQC. Therefore, no WQBEL are warranted. 

As EIP itself acknowledges, TDEC should set water quality based effluent limitations 

("WQBELs") only "jiff the discharge of pollutants from BRF could cause or contribute to a 

violation of water quality standards in the Clinch River." EIP Comments, p. 3 (emphasis 

added). TDEC has determined that discharges of metals from BRF have no reasonable 

potential to cause or contribute to an in-stream excursion above Tennessee water quality 

criteria. 

As shown on the spreadsheet of BRF Intake data (shown later in the BPJ Analysis), 

background concentrations of metals do not exceed TN WQC. 

[NThhlliid dhdill 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 8 of NOD - 41 

Comment 13: 

TVA reports that the background concentration of mercury in the Clinch River as 0.2 pgIL—a level 

that exceeds Tennessee WQC for recreational waters (0.051 pg/L and 0.05 lig/L) by an order of 

magnitude. However, TDEC did not use this value in the Bull Run permit, and instead conducted 

water quality based effluent calculations using a mercury value of 0.1 Ng/L— half of the actual 

amount detected and reported by TVA. TDEC must correct and re-calculate mercury 

concentrations in the final permit for Bull Run Fossil Plant. 

RESPONSE: 

The background concentration for mercury in the draft permit was based on analytical data 

available at the time. The mercury data were for analyses at detection levels which, while 

meeting TDEC's required detection levels, were greater than the applicable water quality 

criteria. More recently, samples of the BRF intake, ash pond discharge, and condenser 

cooling water discharge have been collected and analyzed by low level methods. The 

resulting values were 0.0025 lag/L, 0.012 pg/L and 0.003 pg/L respectively, all more than 4 -

10 times below TDEC's most stringent Water Quality Criterion (WQC) for this parameter 

(0.05 pg/L for recreational uses). 

Comment 14: 

In TDEC's reasonable potential analysis, it must examine whether the discharge of CCW 

pollutants will cause, have the reasonable potential to cause, or contribute to an excursion above 

water quality standards. If TDEC finds such potential, it can rely on its narrative criteria for water 

quality, as required by Clean Water Act regulations, or use EPA WQC to provide sound scientific 

rationale to establish water quality-based effluent limits for discharges of CCW pollutants from Bull 

Run Fossil Plant to the Clinch River. 

RESPONSE: 

See above response to Comment 12 for revised reasonable potential calculations. 

Comment 15: 

Commenters urge TDEC to use its authority to put enforceable terms, deadlines and conditions in 

this draft permit to ensure that TVA does indeed close the wet CCW disposal areas at the Bull Run 

Fossil Plant. Specifically, TDEC should require remedial actions, or impose increased monitoring 

to ensure safe closure. 

RESPONSE: 

TDEC authority under the Water Quality Control Act (TWQCA) addresses the characteristics 

of ash pond discharges and also addresses the placement of materials having the potential 

to impact state watersThis is the basis for the dike integrity inspection requirement in the 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 9 of NOD - 41 

A requirement for quarterly updates on the dry ash conversion and ash pond closure 

processes is included in the final permit as follows: 

The permittee will provide quarterly updates on progress toward dry ash 

conversions and ash pond closure with the Discharge Monitoring Reports 

submitted for March, June, September, and December. The report must 

address, at a minimum, the estimated future date for complete closure and 

elimination of ash pond discharges as well as updated information on planning, 

design, and construction milestones for each quarter. 

Comment 16: TDEC Should Correct and Revise Permit Condition D [Intake Screen Backwash]: 

The intake screen backwash discharged through Outfall 002 should not contain 

pollutants other than those previously present in the intake water. The discharge 

should not have a visible oil sheen. 

RESPONSE: Revision is made in the final permit. 

Comment 17: TDEC Should Add a Permit Condition to Protect Water Quality 

The discharge activity shall not cause or contribute to violations of water quality criteria as 

stated in the TDEC Rules, Chapter 1200-4-3-.03. Under no circumstances may discharges 

exceed numeric water quality criteria for aquatic and human life as stated in Tennessee 

Water Quality Criteria, Tenn. Comp. R. & Regs 1200-4-3. 

RESPONSE: Part I.A.b. of the permit ("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.") already 

addresses this point. 

Comment 18: Commenters request that TDEC change the language in Permit Condition B(3) 

(Dike Inspections) to state: 

"the Director will re-open this permit to incorporate more stringent requirements or any 

applicable standards pertaining to the operation and maintenance of coal combustion 

waste impoundments." 

RESPONSE: The division will reopen the permit if terms and conditions of the current 

permit are not deemed protective of the applicable water quality standards. The proposed 

change does not enhance or limit director's ability to proceed with re-opening of the 

permit. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 10 of NOD - 41 

❑ All reports and analyses for TVA wet storage facilities, dry storage facilities and landfills 

should be submitted to TDEC, including reports prepared by consultants and relevant to 

permits (such as stability or geotechnical reports, and inspection reports and 

recommendations); 

❑ Calculations and Reports must be signed and sealed by a Registered Professional 

Engineer, registered in the State of Tennessee; 

❑ Through the permitting process, TVA should prepare a detailed inspection regimen for 

each phase of operation, construction or closure, and inspections must be conducted by 

Registered Professional Engineers that have qualified training and experience; 

❑ TDEC should develop criteria for impoundments and use criteria in permit Approval. 

RESPONSE: 

TDEC already expanded the oversight of coal combustion waste facilities in Tennessee. 

Expanded oversight includes Divisions of Water Pollution Control, Solid Waste 

Management, Air Pollution and Water Supply. Most of the recommendations listed in this 

comment above were incorporated through our expanded oversight activities, and some as 

a part of this NPDES permit. Specifically, this final permit contains dike inspection 

reporting requirements, updated information on the progress of dry ash conversion and 

ash pond closure. 

Comment 20: TDEC should require TVA to implement the National Incident Management System 

("NIMS"), required by Homeland Security Presidential Directive (HSPD -5) and recommended by 

the TDEC Advisory Committee on the Kingston Disaster, to improve communications with other 

agencies in the event of an emergency. Any emergency plan for the Bull Run plant developed by 

TVA in conjunction with the NIMS should be included in this condition or otherwise as a permit 

requirement. 

RESPONSE: 

The division, under the TN Water Quality Control Act, lacks direct authority to require TVA 

to implement NIMS, as this is a Presidential Directive affecting all government agencies. 

However, early this year, TVA management initiated a reorganization of the emergency 

response program and notified TDEC and the TN Emergency Management Agency of their 

plans to comply with NIMS. TVA is currently staffing the program, and developing 

procedures for submission to Congress and the public with a tentative completion date of 

August 2010. No new information is available to TDEC on the current status as of this 

writing. 

Based on past experience and knowledge of the risk levels of BRF ash pond dikes, the 

requirement for an Emergency Response Plan to address potential water quality 

emergencies is reasonableFor purposes of this NPDES permitTVA Bull Run Fossil Plant 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 11 of NOD - 41 

Under the TN Water Quality Control Act, TDEC can require TVA to submit information, such 

as this Plan necessary to protect public health and the environment: 

[See TCA 69-3-107. Duties and authority of the commissioner (10) Require 

the submission of such plans, specifications, technical reports, and other 

information as deemed necessary (emphasis added) to carry out the provisions 

of this part or to carry out the rules and regulations adopted pursuant to this part.] 

Comment 21: TDEC Should Investigate Two Recent CCW Spills at Bull Run and Require TVA to 

Take Remedial Action. 

RESPONSE: The division is continuing to investigate referenced incidents. Upon 

completion of our investigation and consultation with other agencies, appropriate 

enforcement action(s) may be taken, if necessary. 

Comment 22: TDEC Should Investigate Selenium Discharges at Bull Run Fossil Plant. In this 

permit cycle, TDEC should ensure that selenium levels are properly controlled in effluent from Bull 

Run Fossil Plant. Treatment technologies and methods of reducing selenium levels in CCW 

effluent should be utilized if necessary. 

RESPONSE: The enclosed reasonable potential analysis indicates the chronic and acute 

selenium concentrations protective of instream designated uses are 19 and 89 ug/L, 

respectively. Actual effluent concentration range as reported in the permit application is 7 

to 15 ug/L. Therefore, although effluent limitation is not required, we've included a 

monitoring requirement in the final permit. 

Comment 23: TDEC Must Prevent Backsliding in the Bull Run Permit and Require Manganese 

and Chromium Monitoring in the Final Permit at Outfall 001. TDEC removed pollutants and 

pollutant monitoring requirements, perhaps inadvertently, for manganese and chromium in the 

effluent limitations chart for Outfall 001. To avoid backsliding, TDEC should continue to require 

that Bull Run Fossil Plant control its discharge of manganese and chromium. At a minimum, 

TDEC should require monthly monitoring for both pollutants, but TDEC may find, after performing 

reasonable potential analysis for manganese and chromium, that effluent limits are also 

necessary. 

RESPONSE: Monitoring requirements for chromium are included in the final permit. 

Although TN has no WQC for manganese, the EPA recommended WQC is used in the RPA 

spreadsheet for manganese of 50 and 100 ug/l for chronic and acute toxicityrespectively
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 12 of NOD - 41 

including antimony, barium, beryllium, boron, calcium, chromium, cobalt, magnesium, manganese, 

molybdenum, tin, titanium, vanadium, yttrium, and zinc at Outfall 001. 

RESPONSE: 

As described in the Response to Comment 12, an updated spreadsheet of reasonable 

potential calculations is attached to this NOD addressing all 27 pollutants listed above. The 

RP calculations indicate mixed concentrations of Outfall 001 and the receiving stream do 

not exceed TN WQC. 

The renewed permit requires monitoring for metals on a monthly basis for those 

parameters for which TN has established a WQ criterion. 

Comment 25: TDEC Must Place Effluent Limits and Monitoring Requirements for once-through 

cooling water (OTCW) in the NPDES Permit for Bull Run Fossil Plant at Outfall 002. Clean Water 

Act regulations set effluent limits for Free Available Chlorine and Total Residual Chlorine in 

OTCW. TDEC should require Bull Run Fossil Plant to use the best practicable control technology 

currently available ("BPT") to limit the discharge of free available chlorine ("FAC") from OTCW 

units. These BPT effluent limits apply to an individual generating unit at the discharge point of the 

individual generating unit, prior to combination with the OTCW from other units. 

RESPONSE: 

As stated in the Draft Permit, TVA BRF no longer uses chlorine for biocide control of 

OTCW, but uses bromine or other oxidizers. Biocide addition does not occur routinely, in 

fact DMR reports for 2008-9 show that no biocides were employed. Monitoring is required 

in the final permit at Outfall 002 per the parameter Total Residual Oxidants to measure 

these oxidizing compounds in a technique similar to chlorine. Permit limitations for use of 

these oxidizers are equivalent to those for the use of chlorine. 

Comment 26: Given the large flow rate of discharges from Bull Run Outfall 002 and the possibility 

that overall pollutant mass discharge could be significant, TDEC should set effluent limits and 

monitoring requirements in the draft NPDES permit for Bull Run Outfall 002. 

RESPONSE: 

Outfall 002 should only discharge compounds found in the Clinch River, plus heated water 

and any biocides used for maintenance purposes. The permit limits, in addition to 

temperature, include total residual oxidants and effluent toxicity to address potential 

impacts on water quality. Other than heat, TDEC has no records to date of significant 

pollutant loadings from Outfall 002 that would warrant effluent limitations. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 13 of NOD - 41 

TDEC should examine TVA's ability to reduce thermal pollution at Bull Run, and examine the 

overall impacts of cooling waters on aquatic life near Bull Run. Specifically, TDEC should require 

TVA to provide a plan for reducing thermal pollution, and to address the concerns raised in EPA's 

letter of June 30, 2009 before TDEC issues the final NPDES permit for Bull Run Fossil Plant. 

RESPONSE: 

The division agrees with commenter's concerns regarding potential effects of thermal 

discharge on a balanced and indigenous population of fish and other aquatic organisms at 

this location. TVA's extensive studies to date will be further expanded under EPA's 

guidance during this permit cycle. EPA Region IV has indicated that additional aquatic data 

should be collected during the five-year duration of the subject permit to facilitate the 

Section 316(a) determination in the "next NPDES permit." (Permit 1111.) The renewed 

permit retains the alternative thermal limit as existing data demonstrate the maintenance of 

a balanced indigenous population ("BIP") in the receiving waterbody. TVA will be required 

to submit a study plan outlining proposed assessments to support continuance of the ATL. 

The plan will be designed to supplement existing information previously provided by TVA. 

EPA has agreed to this approach and will participate in the review of the plan and the 

resulting data. 

Comment 28: TDEC should require TVA to monitor for TSS and oil and grease in addition to flow, 

pH, total copper and total iron. TVA must demonstrate compliance with Metal Cleaning Waste 

ELGs at Internal Outfall 005. 

RESPONSE: In EPA rules at 40 CFR 423.12, ELGs for BPT of Metal Cleaning Wastes require 

limitations of TSS, O&G, Copper and Iron. ELGs for BAT at 423.13 require limitations for 

copper and iron. In the renewed permit, these limits are set for TSS, O&G, Copper and Iron 

with compliance measured at Internal Monitoring Point 005 (referenced as Outfall 005 in the 

above comment). The corresponding changes are incorporated in the final permit (see table 

below). 

I 

OUTFALL 005 

Metal Cleaning wastes 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. ANENT. MAX. CONC. MAX. A_VLNT. MSRNINT. 

FRO NCI'. 

SAMPLE 

(.13/0 iihk1 TYPE .30 OW) (1b/dAy) 

FLOW Report (MGD) • Report (MGD)* 1/Batch EstImateTotal Suspended Solids 30.0 - 100.0 - Grab 

Oil and Grease 15

0 

200 Grab 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 14 of NOD - 41 

RESPONSE: In-stream monitorincLhas been conducted twice yearly immediately 

downstream of the BRF site at the West Knox Utility District water intake since 1995 as 

required by previous permits. Metals concentrations in the mixing zone continue to comply 

with TN WQC for the Drinking Water Supply use classification at Rule 1200-4-3. For CY2006 

thru June 2010, these data are discussed below: 

• For Arsenic was reported three times with a value above the detection limit. Arsenic 

was reported as 0.0015 mg/L in the May 2007 sample (detection limit is 0.0010 mg/L) 

and again in November 2007 and May 2008. All other Arsenic analyses were 

reported Below Detection Limit. 

• Both Chromium and Lead values were all below detection limit except for May 2007 

sample. Chromium was reported as 0.0015 mg/L (detection limit is 0.0010 mg/L) and 

Lead was reported as 0.0011 mg/L (detection limit is 0.0010 mg/L). 

• Selenium was reported two times with a value above the detection limit. Selenium 

was reported as 0.0017 mg/L in the May 2007 sample (detection limit is 0.0010 mg/L) 

and again in November 2007. All other Selenium analyses were reported Below 

Detection Limit. 

• Cadmium and Mercury analyses were reported Below Detection Limit (mercury 

levels reported using low-level tests are discussed in Response to Comment 13 

above). 

The final permit will retain the requirement for semi-annual instream monitoring at the West 

Knox UD intake. 

Comment 30: The RP analysis should include all the metals on page V-3 of the permit 

application. 

RESPONSE: All the metals are assessed in the updated RP Analyses shown on page NOD 

—15. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 15 of NOD - 41 

Comment 31: Concerns for ash pond operation and future closure should address 

potential for groundwater contamination. 

RESPONSE: 

Groundwater monitoring at the ash disposal sites is required by the TDEC Div. of 

Solid Waste Management (DSWM). DSWM records indicate that ongoing groundwater 

monitoring at BRF has detected metals at levels below MCLs for, among others, arsenic, 

cadmium, and silver. Assessment Monitoring was downgraded from Phase III to Phase II 

which consists of sampling groundwater semi-annually.1 

TVA has not developed quantitative estimates of BRF ash pond groundwater 

seepage rates or contaminant loadings to Melton Hill Lake. No estimates of groundwater 

loadings are available for comparison to the ash pond discharge. In other ash pond 

locations, this groundwater seepage rate has been found to be a potentially insignificant 

factor in affecting surface water as compared to the ash pond discharge to the Lake of 20 

MGD. 

Since it's not feasible to measure the potential groundwater effect in the depths of 

the Lake, assessment of the aquatic community remains the only viable option. TVA has 

compiled data on Reservoir Fish Assemblage Index (RFAI) in Melton Hill Lake, upstream 

and downstream of BRF, every other year since 20012. These data demonstrate a balanced, 

indigenous population has been maintained in the vicinity of the plant. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 16 of NOD - 41 

WATER QUALITY BASED EFFLUENT CALCULATIONS 

OUTFALL 001 

Hardness 

as CaCO3 

Stream 

Allocation 

Stream [ Stream 

(1Q10) (30Q5) 

Waste 

Flow 

Susp. 

Solids 

Hardness data: 145 mg,1 

Clinch FM 66 

TDC-C A ebiere Sta Ik160] RAW] 8420] 

157.7 169.3 18.89 9 145 50 

67 1 8 

Fish & Aquatic LifeIWQ Cntena (1010) 

1 2 1 3 4 

5 roam t

Bckgmd. 

Conc."' 

Fish/Aqua. Lite 

WO Criteria 

Effluent 

Fraction 

Dissolved 

Outfall 

In-Stream Allowable Calc. Effluent Comb 001 

EFFLUENT Chronic Acute Chronic Chronic Cono'n 

CHARACTERISTIC 

Acute ACUte 

[ug71] [ugh] [Fraction]. rug/l] 

Aluminum 530 1867 

Antimony 1.33 6.5 

Arsenic 2 150 340 150 340 693 1581 129 

Barium 26 177 

Beryllium 1 2.7 

Boron 200 1297 

Cadmium * 0.2 0.318 2.88 0.194 1.64 14.85 7 69 0.32 

Calcium 

Chromium Ill 772.4 36.9 0.084 9177 439 42893 2046 21.67 

Chromium IV * 5 11 16 11.00 16.00 31 54 NA 

Cobalt 4 4.0 

Copper* 16 12.30 19.07 0.220 56.0 86.8 195 339 6.0 

Iron 423 347 

Lead * 2 3.76 98.55 0.152 24.72 634 107 2957 3 

Magnesium 4067 4733 

Manganese 46.3 50 SOO 1.0 50.00 100 40 274 12.0 

Mercury, (T)** 0.005 0.770 1.4 0.77 1.40 4 7 0.17 

Molybdenum 15 56 

Nickel * 1 71.2 641.2 0.210 339 3054 1581 14270 3 

Selenium 1.3 14 

Silver ' 

5 20 1.0 5 20 18 88 

3.5 6.095 1.0 6.09 14 3.53 

Sodium 

Thallium 1.7 2.0 

Tin 40 40.0 

Titanium 23.3 28.3 

Vanadium 

Yttrium 

Znt • 30 160.54 160.54 0.13 1246.54 1246.54 5701 5701 26.7 

Cyanide (T)** NA 

Chlorine (T. Rea) 

2.6 5.2 22.0 1.0 5.2 22.0 13 92 

0.0 11.0 19.0 1.0 11.0 19.0 103 178 NA 

10 11 I 12 13 14 

In Stream Criteria Cato. Effluent Concentration 001 

Human Health Water QualityY Cate a (300511 Outfall 

EFFLUENT atertarganis OWS Organisms iter/Organis DWS amen 

CHARACTERISTIC 

Organisms 

[ugh] [ug/I] lugid [ugl] Lug/11 ugti 

Aluminum 520 

Antimony 5.6 5.6 6.0 22 22 24 5.3 

Arsenic 10.0 10.0 10.0 41 41 41 34 

Barium 2000 9846 157 

Beryllium 4.0 15 4 

Boron 307 

Cadmium • 5.0 24 0.39 

Calcium N/A 

Chromium Ill * 100.0 494 3 

Chromium IV • 

Cobalt 4.33 

Copper* 5.2 

Iron 303 

Lead • 5.0 16 2 

Magnesium 10533 

Manganese 50 100 41.6 291 53.3 

Mercury, (T)** 0.051 0.050 2.0 0.2 0.2 10 0.17 

Molybdenum 60 

Nickel * 4600 610 100 22909 3034 494 8 

Selenium 50.0 243 12 

Silver 0.53 

Sodium N/A 

Thallium 0.47 0.24 2.0 -5.3 -6.4 2 1.8 

Nn 49.7 

Titanium 20.3 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 17 of NOD - 41 

BEST PROFESSIONAL JUDGMENT ANALYSIS 

Prepared by Robert Alexander 

CONTENTS OF THIS ANALYSIS: 

A. 1982 Steam Electric Power Effluent Limitations Guidelines 

B. 2009 EPA Steam Electric Power GeneratinPoint Source Category: Final Detailed Study 

Report (EPA 821-R-09-008) 

C. 2010 USEPA Rulemaking Process for ELGs for Coal-Fired Plants 

D. USEPA MEMORANDUM — NPDES Permitting at Steam Electric Fossil Plants, dated 7 

June 2010 

E. TVA Proposed Conversion of Wet Ash Handling to Dry Storage 

F. TDEC Procedures for Establishing Effluent Limits 

G. Comments on other fossil plant Draft NPDES Permits 

H. Conclusion - Permit Writer's Best Professional Judgment 

A. 1982 STEAM ELECTRIC POWER EFFLUENT LIMITATIONS GUIDELINES (ELGS) 

EPA first issued effluent guidelines for the Steam Electric Power Generating Point Source Category 

(i.e., the Steam Electric effluent guidelines) in 1974 with subsequent revisions in 1977 and 1982. 

Steam Electric effluent guidelines are codified at 40 CFR Part 4233and include limitations for the 

following waste streams (emphasis added): 

o Once-through cooling water; 

o Cooling tower blowdown; 

o Fly ash transport water; 

o Bottom ash transport water; 

o Metal cleaning wastes; 

o Coal pile runoff; and 

o Low-volume waste sources, including but not limited to wastewaters from: 

■ wet scrubber air pollution control systems [Flue Gas Desulfurization, or FGD systems], 

■ ion exchange water treatment systems, 

■ water treatment evaporator blowdown, 

■ laboratory and sampling streams, 

■ boiler blowdown, 

■ floor drains, 

■ cooling tower basin cleaning wastesand 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 18 of NOD - 41 

1982 EPA ELG Background Information: 

In the 1982 development document for ELGs, EPA addressed4: 

o waste streams listed in the part 1 above, and the four factors known to affect effluent 

characteristics: 

■ type of coal burned 

■ combustion process used 

■ plant site characteristics, and 

■ intake water quality. 

o Priority pollutants, mainly inorganics (metals) 

o Treatment and control technologies used in the 1970's and early 1980's. 

Regarding effluents from coal ash ponds, the significant points from the 1982 ELGs are: 

o Numeric limitations were established for Total Suspended Solids (TSS), Oil and Grease 

(O&G), and pH. 

o For fly ash transport water, no numeric limits for metals were established. 

■ "EPA determined at proposal that the available data regarding the degree of toxic 

pollutant reduction to be achieved beyond the BPT were too limited to support national 

limitations."5 

■ "The Agency considered requiring a zero discharge option for existing sources but 

rejected it because the high cost of retrofitting does not justify the additional pollutant 

reductions beyond BPT."8 

• The 1974 requirement for zero discharge of fly ash transport water was remanded in 

1976. 

■ "Many existing plants are achieving zero discharge [for fly ash sluice water] and new 

plants are at least as capable of implementing dry fly ash systems."' 

o For bottom ash transport water, no numerical limits for metals were established. 

■ "EPA did not propose BAT limitations for the priority pollutants. 

■ Analysis of available wastewater sampling data did not indicate that a quantifiable 

reduction of toxic pollutants would be achieved beyond the BPT level of control."8 

• 1974 BAT contains the same TSS, O&G, pH and PCB limits as BPT, plus a recycle 

requirement of 12.5 cycles of bottom ash recycle water. 

o For low volume wastes [i.e. FGD wastewater]., no numerical limits for metals were 

established. 

• In 1982, EPA examined whether to prescribe numerical limits for metals such as arsenic, 

mercury, selenium, etc., but declined to do so because these substances were determined 

to be "present in amounts too small to be effectively reduced by technologies known to 

the administrator." 47 Fed. Reg. 52,290, 52,303-04 (Nov. 19, 1982). 
Table II-1 

TECHUOLOC/ES EVALUATED AS CAPABLE OF ACUIEVIUG LIMITATIONS 

BAT: 

Standards of 

Performance: 

Pretreatment 

Standards: 

Pretreatment 

Standards: 

Wastestreams Existing Sources New Sources Existing Sources New Sources 

Once-Through Chlorine Minimize-Chlorine MiniCooling Water tion-Dechlorina-mizationLion Dechlorination 

Cooling Tower Use of alternative Use of alter- Use of alternative Use of 

BlowdoWo chemicals native chew..- 

.Gals/chemical 

precipitation 

chemicals alternative 

chemicals 

Bottom Ash Sedimentation 

Transport( 

Water 

Fly Ash Dry transport Dry transTransport 

Water 

and disposal port and 

disposal 

Chemical Chemical Chemical Precipi- Chemical 

Metal Clekz 

ing Wastes 

Precipitation Precipitation tation Prscipitation 

non-chemical Reserved for Reserved for Reserved for Reserved for 

Cleaning future con- future con- future con- future conWastes sideration sideration sideration sideration 

Low Vo vino 

Waste 

Sedimentation Sedimentation Sedimentation 

{includes 

boiler 

Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 19 of NOD - 41 

o Best Available Technologies (BAT) evaluated as capable of achieving limitations are not 

listed for Bottom Ash or Fly Ash sluice water or Low-Volume Wastes, as shown in Table II1 below9: 

o Treated Fly Ash Pond effluent concentrations of only five metals were compared with 

discharges from various industrial processes as shown below: 

Treatment Process 

Effluent Parameter (mg/I) 

Arsenic Copper Nickel Selenium Zinc 

Physical-Chemical 

byvarious industrial 

segments 0.02 to 0.1 0.1 to 7.8 0.09 to 1.9 0.02 to 0.08 0.1 to 6 

ASH POND 

EFFLUENT 

Lime Softening 1 10 to 23 0

5 to 6 3 to 52 <2 to31 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 20 of NOD - 41 

o For bottom ash discharges, no data is shown for effluent metals concentrations. 

o Wet fly ash handling/disposal had higher estimated costs than dry fly ash handling for new 

plants in 1979 dollars. 

SUMMARY OF 1982 ELGs 

■ ELGs cover pH, PCBs, Total Suspended Solids, and Oil and Grease. 

■ EPA considered setting numerical limits for metals, but found inadequate data from 

which to set such numerical limits for toxic metals and low volume wastes (including 

FGD wastewater). 

B. 2009 EPA STUDY REPORT 

In October 2009, EPA published a summary report with two purposes: 

■ To review discharges from steam electric facilities, and 

■ To determine whether ELGs should be revised. 

The report focused primarily on ash ponds and wastewater from FGD air pollution controls. 

The report: 

o Includes data on wastewater characteristics from coal fired power plants; 

o Identifies the wastewater treatment technologies reviewed: 

FGD wastewater treatment technologies 

• Settling ponds 

• Chemical precipitation (hydroxide and/or sulfide) 

• Biological treatment 

■ Constructed wetlands 

■ Vapor-compression evaporation 

• Zero discharge 

Fly and bottom ash sluice water treatment 

■ Settling ponds 

• Re-use of wastewater 

o Presents an overview of the industry profile and predicted future trends in the use of 

air pollution controls; and 

o Describes environmental impacts that have been linked to coal combustion 

wastewater. 

EPA developed the study using 30 pre-selected plants with 9 owners and obtained data from 

existing sources and a questionaire, and site visits with EPA sampling. TVA plants at Widows 

Creek FGD system and Paradise, KY were included in the study. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 21 of NOD - 41 

o Ash pond effluent concentrations identify toxic metals at: 

• Bottom ash pond — Homer City, PA; 

1. Combined bottom and fly ash pond — Widows Creek, AL 

2. Fly ash ponds — Mitchell, WV and Cardinal, OH 

o Effluent metals data is presented as total metals and dissolved metals per EPA Method 

200.8, low-level metals by various methods, and conventional parameters (COD, NH3, 

Chlorides, HEM, TDS/TSS).1° 

o Case Studies are shown: 

1. Reuse of FGD wastewater in WV, OH, and NC 

2. Reuse of fly ash and bottom ash wastewater in KY and PA 

o EPA has determined the Study Report does not contain adequate data on treatment 

technologies and effluent concentrations to enable setting numerical effluent limits for 

toxic metals." 

C. 2010 USEPA RULEMAKING PROCESS FOR ELGS FOR COAL-FIRED PLANTS 

EPA is currently drafting revised ELGs for coal-fired plants and issued a proposed Information 

Collection Request (ICR) questionaire on March 9, 2010.12 

o ICR was distributed in mid-2010 to selected fossil plants. 

o Responses from fossil plants are due 90 days after receipt absent an extension. 

o EPA analyses of the data will follow, with draft ELGs planned for 2012. 

o Final ELGs are planned to be issued in 2014. 

For detailed information and to see the questionaire, see Fact Sheet: Request for Comment on 

Questionnaire for the Steam Electric Power Generating Effluent Guidelines (February 2010). A 

relevant excerpt is quoted below: 

"Approximately 734 fossil- or nuclear-fueled steam electric plants will be required to 

complete Parts A and I of the questionnaire. This total includes approximately 495 coalfired, 9 petroleum coke-fired, 20 oil-fired, 168 gas-fired, 20 nuclear power plants, and 22 

combination power plants. [...] One or more of these subpopulations will also be required 

to fill out certain additional detailed sections (for some sections of the questionnaire, the 

coal-fired respondents will be reduced to a subset of approximately 94 plants). 

EPA has determined that the data obtained through the Steam Electric ICR is necessary for 

EPA to review and revise the ELGs for the steam electric industry. The ICR will obtain 

information about steam electric power generating industry operations for use in 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 22 of NOD - 41 

pollutant discharges associated with this industry. These data will be used to perform 

detailed technical and economic analyses that will support EPA's potential development 

of numerical limitations or best management practices for wastewaters generated by steam 

electric plants [emphasis added] 

Key points of EPA Information Collection Request (ICR): 

o At this writing, it is unclear whether or how much data will be available from TVA 

fossil plants depending on TVA plants being selected in the representative samples for 

detailed wastewater technology. All eleven of TVA's coal-fired electricity generating 

plants received the ICR questionaire. 

o EPA will solicit data from ten coal plants having combined FGD/ash ponds for which 

EPA desires detailed data. 

o EPA estimates that the total burden to the 393 coal-fired electric power plants for 

responding to the questionnaire will be approximately 200 hours per plant, for a total 

estimated effort of $4MM. 

o Adequacy of Existing Data 

• EPA has concluded the 2009 Study lacks specific information to set ELGs: 

"EPA compiled certain information through a recently-completed study [2009 

Study Report] of the steam electric power generating industry and through public 

sources of information, but was not able to obtain the detailed plant-level and 

generator-level data that will be collected through this questionnaire."I4 

• Although a similar data collection under the Clean Air Act is ongoing, "it will not 

collect information about the wastewaters generated from this equipment, nor 

will it collect information regarding related operating practices that affect the 

wastewater pollutant characteristics and generation rate." 

o Cost Data 

• Data on costs of achieving effluent reduction are not available from existing data 

sources [including the 2009 Study]: 

"EPA determined that the information available for regulated utilities are 

generally not sufficiently detailed and complete to support the plant level 

economic/financial impact analyses that will be conducted for the effluent 

guidelines rulemaking." 

• Sources of cost data needed for ELG development include: 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 23 of NOD - 41 

• Edison Electric Institute (EEI) 

• Depending on the data requested, EPA asks for plants to provide cost information 

for systems installed since 1985 or 1990. Relatively few plants have installed 

treatment systems since then, therefore EPA has selected these dates to obtain the 

data necessary to evaluate potential technology options. 

o Parts A thru D and I will be submitted to all coal-fired plants, with Parts E, F, and G 

submitted to selected facilities of interest. 

D. USEPA MEMORANDUM — NPDES PERMITTING OF WASTEWATER 

DISCHARGES from Flue Gas Desulfurization (FGD) and Coal Combustion Residuals 

(CCR) Impoundments at Steam Electric Fossil Plants, dated 7 June 2010. 

EPA Office of Wastewater Management issued this Memorandum to EPA Regions as interim guidance 

to assist permitting authorities in establishing permit requirements for steam electric plants, primarily for 

FGD discharges. At BRF, both the CCR stream (i.e., sluiced bottom ash) and the FGD discharges flow 

into a 30-acre settling pond. EPA's the guidance has been considered in this BPJ analysis. 

E. TVA PROPOSED CONVERSION OF WET ASH HANDLING TO DRY STORAGE 

TVA plans to eliminate all wet ash and gypsum storage in the TVA system and convert its 11 

operating coal-fired power plants to dry storage. As stated in the Draft NPDES permit , the 

TVA Board decided in July 2009 to convert wet ash to dry ash handling.15 

o Program Details (TN-only) 

• Wet fly-ash will be converted to dry storage at Allen, Gallatin, Bull Run, and 

Kingston. 

• Wet bottom-ash will be converted to dry storage at all eleven TVA fossil plants. 

• Gypsum dewatering processes will be installed at Bull Run and Kingston. 

• New ash disposal facilities will be developed to handle future plant operations. 

• Eighteen existing ash and gypsum ponds will be closed and capped according to 

EPA guidelines for all of TVA area. 

• High risk storage facilities will be converted first at Bull Run and Cumberland. 

• TVA expects the conversion program to cost $1.5 to $2 billion and take 8-10 years to 

complete. 

• Additional disposal facilities are planned for future plant operations. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 24 of NOD - 41 

o Conversions Planned for Each TVA Fossil Plant: 

• Allen (near Memphis, TN; 3 units; 990 MW) 

• Wet fly ash to dry storage 

• Wet bottom ash to dry storage 

• Bull Run (near Oak Ridge, TN; 1 unit; 950 MW) 

• Gypsum dewatering 

• Wet bottom ash to dry storage 

• Cumberland (northwest of Nashville, TN; 2 units; 2,600 MW) 

• Wet bottom ash to dry storage 

• Gallatin (northeast of Nashville; 4 units; 1,255 MW) 

• Wet fly ash to dry storage 

• Wet bottom ash to dry storage 

• John Sevier (near Rogersville, TN; 4 units; 800 MW) 

• Wet bottom ash to dry storage 

• Kingston (near Kingston, TN; 9 units; 1,700 MW) 

• Wet fly ash to dry storage [Scheduled for completion in 2011] 

• Wet bottom ash to dry storage 

• Gypsum dewatering 

The most recent information regarding conversion at BRF indicates: 

• Wet bottom ash to dry storage completion in 2012 

• Gypsum dewatering completion in 2013. 

F. COMMENTS ON THE DRAFT PERMIT(S) 

The Draft NPDES Permit for the TVA Bull Run Fossil Plant establishes effluent limits for 

parameters listed in the 1982 ELGs and previous permits: pH, Total Suspended Solids, and Oil 

and Grease. In addition, the draft permit required monitoring of toxic metals: 

OUTFALL 001 EFFLUENT LIMITATIONS MONITORING REQUIREMENTS 

MONTHLY DAILY 

EFFLUENT 

CHARACTERISTIC 

AVG. 

CONC. 

AVG. 

AMT. 

MAX. 

CONC. 

MAX. 

AMT. MSRMNT. 

FRQNCY. 

SAMPLE 

(uWL) (lb/day) (ug/L) (lb/day) TYPE 

Arsenic (T) N/A N/A report N/A Monthly Grab 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 25 of NOD - 41 

Zinc (T) N/A N/A report N/A Monthly Grab 

The renewed permit will add the following metals to the monitoring requirement — the permit 

will thus require monitoring for all metals which are listed in current TN Water Quality 

Criteria: 

Antimony, Barium, Beryllium, Chromium, and Silver 

Commenters on the draft permit have stated that TDEC must establish Technology-Based 

Effluent Limits for toxic metals:17 

"Where EPA has not yet promulgated ELGs for particular pollutants discharged by a 

given point source category, the CWA requires TDEC to stand in the shoes of EPA 

and use its best professional judgment ("BPJ") to set case-by-case TBELs for these 

pollutants in NPDES permits. 

In addition to the TBELs required at Outfall 001 and discussed above, commenters 

request that TDEC establish numeric effluent limits for the pollutants listed in the 

NPDES permit for Outfall 001, including aluminum, arsenic, cadmium, copper, iron, 

lead, mercury, nickel, selenium, silver, thallium, and cyanide. In addition, TDEC 

should require monitoring and effluent limits for the additional pollutants EPA 

identified in CCW wastewaters, including antimony, barium, beryllium, boron, 

calcium, chromium, cobalt, magnesium, manganese, molybdenum, tin, titanium, 

vanadium, yttrium, and zinc at Outfall 001 and 011. [...] 

Using the wealth of data available from EPA and power plants in Tennessee, TDEC 

can and must use its best professional judgment to set BAT-based numeric effluent 

limits for heavy metals, such as the 27 pollutants listed above, present in CCW 

wastewaters." 

This portion of the Notice of Determination specifically addresses this comment. Responses to 

other comments received during the public review process are addressed separately. 

G. TDEC PROCEDURES TO DEVELOP ASH POND EFFLUENT LIMITS 

1) OVERVIEW 

TDEC rules require use of Best Professional Judgment (BPJ) when federal ELGs are not 

applicable: 

For industrial discharges without applicable federal effluent guidelines, best professional 

judgment should be employed to determine appropriate effluent limitations and standards.I8 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 26 of NOD - 41 

Technology-based treatment requirements may be imposed through one of the following three 

methods: [...] On a case-by-case basis under section 402(a)(1) of the Act, to the extent that 

EPA promulgated effluent limitation are inapplicable.19 

Again, federal ELGs are both existing and applicable to waste streams in question. Under 40 

CFR 125.3 and Section 402(a)(1) of the CWA, to the extent that ELGs are inapplicable, the 

permit writer must consider: 

(1) the appropriate technology for the category class of point sources of which the 

applicant is a member, based on all available information, and 

(2) any unique factors relating to the applicant. 

2) POLLUTANTS ADDRESSED BY PUBLISHED EFFLUENT GUIDELINES 

Prior to establishing BPJ-based limits for a pollutant not regulated in an effluent guideline, the 

permit writer should ensure that the pollutant was not considered by EPA while developing the 

ELGs. That is, BPJ-based effluent limits are not required for pollutants that were considered by 

EPA for regulation under the effluent guidelines, but for which EPA determined that no ELG 

was necessary. 

In developing the 1982 ELGs, EPA considered but did not establish numeric ELG's for toxic 

metals due to lack of available data. In 2005, EPA after reviewing TRI and NPDES data, has 

decided to revisit ELGs from power plants. EPA is currently drafting revised ELGs for coalfired plants and issued a proposed Information Collection Request (ICR) questionnaire on 

March 9, 2010. Responses to the ICR will be analyzed by EPA, with draft ELGs planned for 

2012. Final ELGs are planned to be proposed in 2014. 

3) SECTION 304(B) FACTORS TO BE CONSIDERED IN SETTING BPJ LEvirrs20 

Factor 1. Age of equipment and facilities involved 

Bull Run Fossil Plant (BRF) began operation in 1967 with one boiler, known as one of the 

largest and most efficient in the US. BRF capacity is reported at 870 megawatts burning up 

to 7300 tons of coal per day. The ash pond treats sluice water for both bottom ash and 

gyspum wastewater from the Flue Gas Desulfurization system (since 2009). 

The fly ash handling system at BRF was converted to a dry fly ash handling system. 

Prior to thisall fly ash and bottom ash was sluiced to the ash pond complexSince 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 27 of NOD - 41 

Dry fly ash that is not marketed can be conditioned with water and loaded into dump 

trucks for transport to the fly ash disposal or utilization areas. The maximum active 

area of exposed dry fly ash will be 10 acres or less (Robinson 2000). As stacking 

areas become inactive, they will be closed with an interim cover. The dry fly ash 

stack is graded to a 1% to 2% slope at the end of each day to limit ponding and 

encourage sheet flow runoff. Runoff from the dry fly ash stacking area drains to a 

sedimentation pond where it evaporates or overflows into the coal storage yard pond 

which is manually pumped to the ash pond as needed (Ross 2000).22 

Although BRF collects most of the fly ash dry, it retains the capability to sluice fly 

ash to the ash pond complex. Fly ash is sluiced during unit start-up and during 

operational problems that compromise the reliability of the dry fly ash collection 

system. In recent years, BRF has sluiced as much as 70,000 tons of fly ash annually 

to the ash pond. BRF recently utilized all of the fly ash produced at the plant for 

development of the Lost Ridge Industrial Park 

Bottom ash collects in the bottom of the boiler and is periodically washed from the 

boiler bottoms with jets of water and sluiced to a bottom ash dewatering area within 

the ash pond complex. The bottom ash is removed from this area with pan scrapers 

and then carried to stacking areas within the ash pond complex.23 

The age of BRF combustion equipment is a factor that may be affecting coal ash 

wastewater. However, data does not exist as to specific effects. 

The age of the TVA ash pond impoundments is not a significant factor in examining 

effluent quality — newer or older impoundments can produce the same settling performance. 

The age of ash transport equipment and process is very relevant — ash sluicing practices and 

equipment are unchanged for almost 50 years. During this permit term, it is likely that 

TVA will replace BRF equipment and processes with conversion to dry bottom ash 

handling and gypsum dewatering. 

Although the 1982 ELGs established the dry fly ash technology under New Source 

Performance Standards (NSPS), this rule is not applicable to wet ash treatment process used 

at BRF. As noted in the EPA 2009 Study Report, development of future fly ash handling 

will be based on dry transport: 

Mlihbid dbh hdlih
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 28 of NOD - 41 

generating wet fly ash transport water tend to be older units, while dry ash handling 

systems tend to be operated on newer units.24 

Notwithstanding the fact that BRF is an older unit (pre-1982), the fly ash system has 

already been converted from wet to dry, and TVA plans to convert the handling of bottom 

ash and gypsum from wet to dry systems. 

Factor 2: Process employed 

BRF ash disposal involves sluicing bottom ash into a 30-acre ash pond flowing into a 

stilling pond and discharge of final effluent to Melton Hill Lake at Clinch River mile 48. 

FGD scrubber wastewater is mixed with sluiced bottom ash. Fly ash originates from 

operation of electrostatic precipitators and is transported to the dry ash stacking area: 

BRF is expected to burn between 2.0 and 2.2 million tons of coal annually through 

at least 2014. The coal averages 9.59% ash, therefore, total ash production will 

range from approximately 191,000 to 210,000 tons of ash per year.25 

The type of process used at BRF or any fossil plant is a unique combination of factors which 

create wastewater characteristics specific to each plant. Dominant factors affecting coal ash 

wastewater are: 

• type and mixture of coal burned, 

• coal handling practices such as washing and pulverizing, 

• intake water quality, 

• type of boiler, and 

• waste stream source (bottom ash, fly ash, gypsum, etc.) 

Toxic metal constituents in coal ash are identified in the 1982 ELGs showing variations in 

coal ash composition based on anthracite, bituminous, subbutiminous, and lignite coal 

sources.

26 

For example, a description of fuel source at BRF is stated below: 

Prior to year 2000, Bull Run burned low sulfur coal from eastern Kentucky and 

Tennessee. To reduce sulfur emissions Bull Run switched to an even lower-sulfur 

coal from eastern Kentucky in January 2000.27 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 29 of NOD - 41 

Factor 3: Engineering aspects of application of various control techniques 

Settling is the predominant control technologies for fly ash sluice water. 

Table 5-6 shows that 95 percent of the plants in the combined data set that handle any 

amount of fly ash wet send the fly ash transport water to settling ponds. Sixty-five percent 

of the fly ash ponds from the combined data set receive both fly ash and bottom ash. Only 

one of the fly ash ponds included in the combined data set is completely segregated (i.e., it 

receives only fly ash wastewater). 28 

The control technology for bottom ash sluice water involves dewatering bins, settling, or 

both. 

The plants within EPA's combined data set that operate wet bottom ash handling systems 

send their bottom ash transport water to dewatering bins, settling ponds, or both. EPA has 

observed that most bottom ash settling ponds also receive other plant wastewaters. In 

response to the data request, no plants reported operating segregated bottom ash ponds. 

Table 5-7 shows that 90 percent of the plants in the combined data set that handle the 

bottom ash with a wet system transfer the bottom ash transport water to a settling pond for 

treatment. Only 18 percent of the plants are operating dewatering bins prior to the settling 

pond. As shown in Table 5-7, there are more plants that keep their bottom ash transport 

and fly ash transport waters segregated than not.29 

At BRF, wastewater treatment is performed in a 30-acre settling pond and stilling pond for 

the combined flow from bottom ash processes, FGD wastewater, metal cleaning wastes, 

coal yard runoff, and other minor sources. By their nature, settling ponds are designed for 

gravity separation of ash solids with discharge of supernatant to surface waters. While ash 

ponds are not designed to treat dissolved metals from sluiced ash or other wastewater 

sources, they are very effective in removing metals that are present in the waste stream in 

particulate form. 

USING EFFLUENT DATA TO EVALUATE CONTROL TECHNOLOGY 

Availability of effluent data on wastewater treatment performance for ash ponds is 

described in Section 2 above, describing EPA's national effort to revise ELGs. Pending 

completion in 2011-12 of EPA's data collection, two sources30are currently available to 

TDEC regarding effluent concentrations of toxic metals from ash ponds — (1) EPA's 2009 

SdRd (2) Al ffldfTVA'i
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 30 of NOD - 41 

EPA 2009 Study Report 

The most representative data from the 2009 EPA Study Report are effluent metals 

concentrations from the combined ash settling pond at TVA Widows Creek - summarized 

in Table 5-9 for: 

aluminum, antimony, arsenic, barium, beryllium, boron, cadmium, calcium, chromium, 

cobalt, copper, iron, lead, magnesium, manganese, mercury, molybdenum, nickel, selenium, 

sodium, thallium, titanium, vanadium, yttrium, and zinc. 

Table 5-9 is copied later in this document - note that this table does not include silver and 

tin. 

TVA Ash Pond Effluent Data 

TVA has provided effluent concentrations from BRF as shown on the following page. Data 

is presented from permit renewal applications submitted in 1998, 2003, and 2007 - each 

entry is based on analysis of one (1) sample. 

Comparison of these data indicates a wide range of effluent concentrations. Concentrations 

of arsenic, for example, are described below: 

• BRF permit application data ranges from 11 — 53 ug/l. 

• EPA data ranges from Non-Detect at 10 ug/1 to 150 ugh per Table 5-9. 
Units are in 

lig/L 

I3RF 001 BRF Intake 

Form 2C Form 2C Form 2C Form 2C Form 2C Form 2C 

Parameter SYM 1998 SYM 2003 SYM 2007 MEAN SYM 1998 sym 2003 SYM 2007 MEAN 

1 Aluminum 770 390 400 520 190 < 50 350 197 

2 Antimony 5 < 1 9.9 5.3 < 1 6.1 < 1 2.70 

3 Arsenic 38 53 11 34 < 1 < 1 < 1 1.0 

4 Barium 100 110 290 166.7 20 40 36 32.0 

5 Beryllium < 1 < 1 < 10 4.0 < 1 < 1 < 1 1.0 

6 Boron < 500 < 200 220 306.7 < 500 < 200 < 200 300 

7 Cadmium 0.4 < 0.1 0.68 0.4 < 0.1 < 0.1 < 0.5 0.23 

8 Calcium N/A N/A N/A N/A N/A N/A N/A N/A 

9 Chromium 3 4.1 1.5 2.9 < 1 < 1 < 1 1.0 

10 Cobalt 2 < 1 < 10 4.3 < 1 < 1 < 10 4.00 

11 Copper 7 3.6 5 5.2 < 1 ' 3 3 2.33 

12 Iron 520 260 130 303.3 260 230 2200 897 

13 Lead 2 < 1 2 1.7 2 < 1 1.6 1.53 

14 Magnesium 9600 10000 12000 10533.3 9400 10000 12000 10467 

15 Manganese 54 37 60 50.3 42 60 93 65 

16 Mercury 't < 0.2 < 0.1 < 0.2 0.2 < 0.2 < 0.1 < 0.2 0.17 

17 Molybdenum 50 43 87 60 < 20 < 20 7.8 15.9 

18 Nickel 8 7 8.5 7.8 < 1 < 1 13 5.0 

19 Selenium 7 13 15 11.7 < 1 < 1 < 1 1.0 

20 Silver t < 1 < 0.1 < 0.5 0.5 < 1 < 0.1 < 0.5 0.53 

21 Sodium N/A N/A N/A N/A N/A N/A N/A N/A 

22 Thallium T < 2 < 2 1.4 1.8 < 2 < 2 < 1 1.67 

23 Tin < 50 < 50 49 49.7 < 50 < 50 52 50.7 

24 Titanium 28 14 19 20.3 < 5 < 5 < 10 6.67 

25 Vanadium N/A N/A N/A N/A N/A N/A N/A N/A 

26 Yttrium N/A N/A N/A N/A N/A N/A N/A N/A 

27 Zinc 8 < 10 20 12.7 < 6 < 10 22 12.7 

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Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 32 of NOD - 41 

Using Ash Pond Effluent Data from Similar Facilities 

Comparison of data shown in the EPA 2009 Study report between Widows Creek and BRF 

is difficult at best, and illustrates how fuel, facility, and operational characteristics result in 

wide variations in effluent metals concentrations. These characteristics are mentioned 

above, and include: 

■ type of coal burned, 

■ low-sulfur blend of coal, 

■ combustion process used, 

■ plant site characteristics, and 

■ intake water quality. 

In fact, the following table illustrates a variability of coal combustion management practices 

at TVA's fossil plants: 

Plant Fly Ash Bottom Ash FGD wastewater 

JSF Dry Sluice water No FGD 

BRF Dry Sluice water Piped to ash pond 

KIF Sluice water Sluice water Separate Gypsum 

Disposal Area 

JOF Sluice water Sluice water No FGD 

CUF Sluice water Sluice water Piped to ash pond 

GAF Sluice water Sluice water No FGD 

ALF Sluice water Sluice water No FGD 

Statistical Variability of Ash Pond Effluent Concentrations 

Ash pond effluent characteristics vary over time. Variations occur due to a number of 

factors, including changes in production cycles, variation in responses of ash ponds to 

influent changes, and, to a degree, seasonal changes in temperature and sunlight. NPDES 

permit procedures, including EPA rules at 40 CFR 122.44(d)(1), require TDEC to use a 

procedure that accounts for effluent variability. 

When developing a BPJ limit, permit writers can use an approach consistent with EPA's 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 33 of NOD - 41 

distribution of 4-day averages divided by the mean of the monthly averages. A modified 

delta-lognormal distribution can be fit to concentration data. 

Variability factors can then be computed for a facility distribution. The modified deltalognormal distribution models the data as a mixture of non-detect observations and 

measured values. This distribution is often selected because the data for most analytes 

consists of a mixture of measured values and non-detects. The modified delta-lognormal 

distribution assumes that all non-detects have a value equal to the detection limit and that the 

detected values follow a lognormal distribution. 31 

Factor 4: Process Changes 

As discussed above, TVA is underway with planning and design to convert all wet ash and 

gypsum storage to dry storage. The conversion from wet sluicing of fly ash to dry stacking 

has already been achieved, and plans are underway to make wet to dry conversions for 

bottom ash and gypsum. Major reduction in wastewater flow through the ash pond is 

predicted from these projects. For example, the Kingston dry fly ash handling project will 

reduce ash pond effluent flow by approximately 80%, from 40 to 15 MGD. 

Based on public statements made by TVA regarding conversion to dry ash to eliminate ash 

sluice water, this process change negates the need for consideration of additional controls, 

since no additional technology could be installed sooner than the dry ash conversion 

systems. 

Factor 5: Non-water quality environmental impact including energy 

requirements 

There is little or no information in current publications providing an insight for comparison 

of non-water environmental impacts of various technologies. Lack of information presents 

itself as an obstacle for the division in order to impose or even suggest BPJ-derived 

technology-based limitations on any facility in Tennessee. Given that this aspect of analysis 

cannot assist us in selecting an optimal treatment technologies for coal ash wastewater, nonenvironmental impacts cannot be identified (or used in a decision-making process) pending 

EPA's publication of revised ELGs, expected in 2013. 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 34 of NOD - 41 

may limit the division's ability to require, at this time, one technology solution over 

another. 

A distinction must be made between existing and new sources. It is likely that retrofitting 

technology solutions on aging fossil plants may be a cost-prohibitive option. A much more 

detailed financial analysis, beyond the scope of BPJ-based limits, and expected as a part of 

ELG development, would be necessary in order to make such decision. 

Considering the imminent promulgation of new/modified ELGs for this industry, it is our 

opinion that mandating a technology change at this time could have long-lasting negative 

effects. The reasons are as following: there is no definitive guidance (or an indication) what 

will be the technology of choice in the final ELGs. Such discrepancy in decision-making 

may have an consequence of imposing a BPJ technology based limit ultimately not deemed 

to be a BAT. Associated cost with such inconsistent application of technology-based 

solutions could be enormous and a waste of public resources. 

Furthermore, one of the most important aspects of ELGs is to "level the playing field" on a 

national basis. Establishing potentially different BPJ technology-based limits at various 

states in the region (or even nation-wide) would be counterproductive, and would go 

against the intent of the rule. 

Conclusion — Permit Writer's Best Professional Judgment 

For the permit term of 2010 — 2013 (watershed cycle year), the NPDES permit for TVA Bull 

Run Fossil Plant should incorporate non-numeric Best Management Practices to control 

concentrations of toxic metals as described herein. Consistent with 40 CFR 122.44(k)(3), the 

BMP approach is appropriate because establishment of numeric limits is infeasible pending 

EPA publication of revised Effluent Limitations Guidelines. Furthermore, during this permit 

term, TVA will be converting the BRF process to dry ash handling with major reductions of 

pollutant loading and developing plans for pond closure. 

More detailed conclusions are presented below: 

A. Establishment of numeric limits for toxic metals is infeasible for the following 

reasons: 

1. Limited data - Effluent data for toxic metals consists of only three 
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 35 of NOD - 41 

4. The EPA 2009 Study report does not provide enough effluent 

characterization of available technologies to enable establishing numeric 

effluent metals limits. 

B. Cost data is not available to determine economic achievability pending 

publication by EPA of revised ELGs. 

C. Non-water quality environmental impacts, such as energy requirements or 

handling/disposal of dry ash conversion can not be identified, pending 

publication by EPA of revised ELGs. 

D. NPDES permits for TVA fossil plant ash pond discharges shall include permit 

conditions requiring Best Management Practices (BMPs) since establishment of 

justifiable numeric effluent limitations is currently infeasible. 

1. Effluent guidelines are not available to prescribe numeric effluent limits for 

toxic metal discharges from TVA ash ponds nor to guarantee water quality 

sufficient for the protection of indigenous aquatic life. Clean Water Act rules 

provide for pollution controls supplemental to effluent limitations guidelines, 

known as Best Management Practices, or BMPs. 

In addition to the conditions established under 122.43(a), each NPDES 

permit shall include conditions meeting the following requirements when 

applicable. 

(k) Best management practices (BMPs) to control or abate the discharge of 

pollutants when: 

(1) Authorized under section 304(e) of the CWA for the control of toxic 

pollutants and hazardous substances from ancillary industrial activities; (2) 

Authorized under section 402(p) of the CWA for the control of storm water 

discharges; 

(3) Numeric effluent limitations are infeasible; or 

(4) The practices are reasonably necessary to achieve effluent limitations and 

standards or to carry out the purposes and intent of the CWA.32(emphasis 

added) 

2. BMPs may be incorporated as permit conditions to specifically address controls 

titlih d dih
Notice of Determination 

NPDES Permit - TVA Bull Run Fossil Plant 

Page NOD - 36 of NOD - 41 

■ BMPs should be established based on guidance shown in Attachment 1 

with submission of a BMP Plan for division review within 60 days 

following the permit Effective Date. 

3. Uses of BMPs are a fundamental part of major NPDES permitting programs for 

CAFO, stormwater, and construction stormwater controls. 

4. Development of BMPs will closely correspond to, and incorporate best practices from TVA ash 

pond closure projects following conversion to dry bottom handling and gypsum dewatering 

efforts. The BMP Plan submitted within 60 days following the effective date of this permit shall 

be amended as necessary to incorporate features of the dry bottom ash and dry gypsum handling 

projects implemented in the future. The amended plan must be submitted for division review at 

least 60 days prior to operation of the converted system. 
Table 54. Ash FoHd Effluen C. centrations 

An to 

. 

Unit 

Homer CitT - 

Effluent from Bolton 

.Ash Fond ' 

Widows Creek - 

Effluent from 

Combined A.* Pond ' 

liatchell - Effluent 

from. Ily-Ash Pond ' 

_ 

Cantina-Effluent 

from. fly Ash Pond Lb: 

:Routine 1,:fetah .- Total 

Abtrwrtfun. 7 00.7 ligt 323 1:,0 +0 404 344 

.43abarmy 200.7 P&L rD (20.0) 1,7D (20_0) 24.6 71.1 

Ara 200.7 Pgi- ND (100) 36.2 150 77.6 

3;_num. 200.7 ligi• 101 227 133 1d5 

3aeryiliinx, 200.7 ligl- I,ID (5.00) ND (5 .00) ND (5.00) NJD (5 CO) 

.3,roa 200.7 ligl- 396 2..210 2,350. 1„:.:>0 

e. 200.7 1.1.1,..1. 'I,ID (5,00) ID (500) .1NTD (5.00) I,D (3 CO:: 

Cad= 200.7 LI g:L 113f,000 56,500 115,000 5S,400 

Caxmium. 200. • lig1T- 111(10_0) 13.5 15„9 ND (100) 

Cabal: 200.7 lIPL. ND (50_0) I,D (50.0) ND (50.0) ND 0.0) 

C'o p pe: 200.7 lig" 1D(10..0) 1,0) (10..0) ND (10.0) ND (10_0 

Loa 200.7 1.10- 355 114 ND (100) ND (100) 

_ea. d. 200.7 lig.1 ID (50_0) I,,D (500) ND (50.0) 1,17 (500) 

Magesium 200.7 lig" 31,SZO .5.660 21000 17.900 

3.-fanganese- 200.7 pg:L 12S I,I) (15_0) ND (15.0) 64.7 

Iiaraci 245.1 Pg.L ND (0.200) Is•TD (0.200) N.D (0_20D) ND (0.200) 

....1.1.c17...bdatuiz 200.7 Figl. 19:7 143 3S 361 

'Mae] 200.7 lig:L. ID (50..0) ND (50.0}o ND (50.0) ND (50.0) 

S4:4Fri ium 200.7 PO- 6_02 16.2 l77 44.5 

Sodium 200.7 ligl 21.300 526,000 70,800 

Tbaltittre. 200.7 1ig°1- ND (110) ND (10.0) ND (10.0) I,D (10.0) 

1-Lrtiitial 2 - 1.1g.1- 1.-7D (10.0) 14.5 ND (10.0) 12.16 

Vaaathi.nr. 200.- lIg1- ND (20.0) 66.5 1 10 104 

77:rtitilla. 1. 00.7 1.1g1_ ND (5.00) ID (5.,X.) ND (5.00) ND (5..401 

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TVA-Bull Run Fossil Plant) 

NPDES Permit TN0005410 

Page NOD - 38 of NOD — 42 

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Anilre Method 

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Unit 

Hamer cityEffluent from Bottom 

Ash Pond -1- 

viadaws -creak - 

Effluent from 

Combined Ash Pond ' 

Mitchel-Effluent 

from. Ely Ash Pond fr 

_ 

C2rdin21- Effluent 

from Ely Ash Pend "" fr. 

Low-Level Metals - Total 

_korimony 1638 PPL 1,09 4.39 23.8 21.9 

_Arsenic 1638 ligl- 6.51. 34.9 142 69.3. 

C.admitnn 163S ligl- .ND (0.500) ND (0.500) 1.32 1.14 

Cammium. 1638 l'gl- ND (4.00) 13,5 L 204 4.&I L 

Copp& 163S ligl- 1...3 -.7 

- . 1.49 5.47 2.93 

Lead. 163S 1,1g1- ND (0.250) 0.490 0_5E0 0.420 

Iferctny 163.1E itgl_ 0,00511 0.00157 U. 212 0.00125 

1:licke1 1638 itg-L 10..7 1-7D (5...X) 1 L0 10.7 

Selenium 1635 141 3.74 17.1 191 45,3 

!]itm 1635 ligt 1,32: 1.46 1.72 2.84 

Zinc 1638 141- 24.2 ND (1.50) 101 5.98 

Low-Level Metals - s41 'ed 

Antimony 1638 ligl- 0.990 4.45 1-7;:-.; 22.4 

_ArseMc 1638 itgL 500 29.0 131 68.9 

Cadr_inu.n . - 1638 itgL ND (0.500) ND (0.500) 1.17 1.11 

Can,_rn WEL 1638 itgt ND (4.00) 12.6 L 16.0 4.49 L 

Hexavaleni C.-am mi.= 1636 pg-i_ 3.01 14.7 17,4 3.96 

Copper 1638 itg-L 2,0a 1.7123 (L00) 4.54 '7'.2'7 

_ 1638 itgL ND (0.230) ND (0.250) ED (0.250) ND (0.250) 

Merany 1631E itg-L 0.00141 ND (0.000500) ND (0./.,`' 00) ND (0. 3) 

'Nick e3 1638 it•gt 104 ND (5.00) 9.57 10.61 

Selenium 1638 pg:L 5,16 15.15 161 45.0 

TI:cillitira 1638 pgL 1.31 1.49 1.42 2.87 

Zinc 1638 lig-L 15.0 141) (2_50) 9.51 4.15 
Table ' h Pond Effluent C oncentrations 

Anatre Method 

. 

Unit 

Homer CityEffluent from Beitant 

Ailk Pond' 

Vildorm: Creek - 

Effluent from 

Combined Ash Pond' 

hatchell - Effluent 

from Ely,-.Ash Pond ` 

_ 

Cardinal-Effluent 

from. Fly Ash Pond ''''' 

Cla Isicaik; 

Ammonia As Nirogen c.,17.-.,-1 7 1 /4.P; 4500._ ..iF mg.. 0.340 0160 0J50 0.205 

-...,:iitateNir:tte r_.70 7-N l';02-11',, 35,3.2 ilk..7.°L 37.0 0.23D 0_730 4.73 7 

Total Kje Wahl Niuogeu iTf... -. ThZ.) 4500-N,C 1 1_36 3.39 ND (0..100) q: 7.15 _ 

3iochemic al Crrygen'De-1mnd (E0D) 5210B mgd_ ND (2_00) 400: 2.00 ND (_CO) 

Chloride 4500-CL-C ingt. 90.0 20.0- 240 60.0 

He.vme .E:ccramble li.titu - -ial TIENI) 166-1A....,_ ,1-:D (_5_00) 6.00 ND t5.00) 10.0 

Silica Gel Treated HEM. (S&T-HEM) 1664A ingl NA ND ' M) NA ND (4.00) 

Suite D51640. ing.L 1,290 S0.7 1,110 494 

Tow_l DiEsolved Solids (IDS) 2540:C mg1 1.250 281 2,050 673 

Tool Phosphom 365.3 mg-T_ 1,09 0.2:70 E 0..200 0.0870 

Total Suspended Solids (FSS) '254 D xL 5_00: 11`.0 E 15.0 6.00 

Source: [ERG. 200S1; ERG. 200£m; ERG., 20081: ERG, 2008o] 

Note: EPA used several aualrical aallyn, for metals dart, ' the sampling pro-gram. For the purposes of sampling -program, EPA desipiated some of 

the asalyacal methods as 'routine' angi. some of :hem. as. lo3,,'-3e1.-el."' EPA designated all of the methods that require. the use of riPan hfinrkVarly 

collection. techniques :EPA Method 1669 sample collection techniques) as "lotv-le_17methods_ Note that although. not required by the yrillytical method 

E3A used c]ean bands.'tiry collection Sechniques for 01mi-1e-1e1 and raarin.e metals samplea... 

- The concentradom raw-eyed lave been rounded to three sipificant figures. 

- The ash goad effment resultsi-: .plesen.t.the avenge of the &sh pond effluent imd the duplicate of the 3 th pond effluent anolyrical measurements 

- A-verase rend: in.cludes at least one non-detect (Calculation uses the report limit for non-detected result* 

E - Sample an outside holdnic nine 

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NA -Not analy-md. 

:1'7D -fart detected 1:-nimber inparenthesis is the report lireat). The sampling episode reports for each of the individual plmrirs comnins additional samplinz 

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TVA-Bull Run Fossil Plant) 

NPDES Permit TN0005410 

Page NOD - 41 of NOD — 42 

Attachment 1 

BEST MANAGEMENT PRACTICES 1 

GENERAL CONDITIONS 

For purposes of this part, the terms "pollutant" or "pollutants" refer to any substance listed as toxic under Section 

307(a)(1) of the Clean Water Act, oil, as defined in Section 311(a)(1) 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. 

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: 

a. May reflect requirements for Spill Prevention Control and Countetuteasure (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. seq.). Management practices required under 
TVA-Bull Run Fossil Plant) 

NPDES Permit TN0005410 

Page NOD - 42 of NOD — 42 

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 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. 

The permittee shall maintain the BMP plan at the facility and shall make the plan available to the permit issuing 

authority upon request. 

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. 

MODIFICATION FOR INEFFECTIVENESS 
TVA-Bull Run Fossil Plant) 

NPDES Permit TN0005410 

Page NOD - 43 of NOD - 42 

Final Determination: 

DETERMINATION 

It is the determination of the division that NPDES Permit No.TN0005410 be issued to the 

Tennessee Valley Authority's Bull Run Fossil Plant. 

Vojin Janjic Manager, Permit Section Date 

TN Division of Water Pollution Control 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-1 of R-43 

RATIONALE, JANUARY 2010 

TVA Bull Run Fossil Plant (BRF) 

NPDES PERMIT NO. TN0005410 

Bull Run, Anderson County, Tennessee 

Permit Writer: Mr. Bob Alexander 

I. DISCHARGER 

TVA - Bull Run Fossil Plant (BRF) 

Oak Ridge, Anderson County, Tennessee 

Facility-Plant Manager: Mr. J. Scott Hambrick 

865-945-7212 

Corporate Contact: Ms. Lindy P. Johnson 

Manager of water Permitting and Compliance-TVA 

(423) 751-3361 

Nature of Business: 

Fossil fueled steam-electric power generating plant. 

SIC Code(s): 4911 

Industrial Classification: Primary 

Discharger Rating: Major 

II. PERMIT STATUS 

Issued November 30, 2007 

Last modified November 30, 2007 

Expired March 30, 2008 

Application for renewal received August 25, 2007 

Watershed Scheduling 

Environmental Field Office: Knoxville 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-2 of R-43 

III. FACILITY DISCHARGES AND RECEIVING WATERS 

TVA - Bull Run Fossil Plant (BRF) discharges ash transport water, chemical and nonchemical metal cleaning wastewaters, coal pile runoff, low volume wastes, storm water runoff, 

miscellaneous equipment cooling and lubricating water from Outfall 001 and Outfall 006 

(emergency overflow), main condenser cooling water, miscellaneous equipment cooling and 

lubricating water and sewage treatment plant effluent from Outfall 002, intake screen backwash 

water through Outfall 004, and metal cleaning waste water through Outfall 005 to Clinch River 

at mile 48.0. Discharged wastewater originates from the process of generation of electric power 

from a fossil-fueled steam-electric plant. The plant has one coal-fired unit with a generating 

capacity of 950 megawatts. 

The discharge at Outfall 001 from the ash pond Consists of dry fly ash wash down 

sump, FD fan cooling water, stack yard sump (pulverizer equipment cooling water, boiler bay 

floor drain), boiler bilge sump (boiler bay floor drainage), non-chemical metal cleaning wastes 

(boiler fireside washing, air pre-heater washes, precipitator area sump, ducts washing), ash 

hopper, economizer, pyrite hopper (ash sluice water), hydroveyors (fly ash pumps), precipitator 

wash down sump (fly ash sump, water from RO treatment), ash pond / gypsum stacking 

(dewatering facility, flue gas desulfurization (FGD) wastewater system, FGD detention basin / 

sump, FGD area runoff / drainage, coal yard drainage basin / sump (fly ash stacking area, coal 

storage area, yard building dust collector sluice, floor drains, roof drains and sumps, coal tower 

and rail hopper floor / roof drains, utility building roof I floor drains), main station sump 

(condenser pit sump inflow, equipment cooling water and leakage, service bay floor drainage, 

emergency overflow from demineralizer sump, leakage from boiler make-up water and water 

treatment plant, unwatering sump outside powerhouse pumps 1 and 2, yard runoff, electrical 

yard runoff, back parking lot runoff, roof drains, ash sluice line low point sump), yard drainage 

basin sump (demineralizer sump (demineralizer system drains), condensate polisher wastes, 

reject water treatment plant, stack yard sump (equipment cooling water, floor washing wastes), 

ammonia facility retention pond, ash sluice line low point sump (yard runoff, back parking lot 

runoff, electrical yard runoff, runoff coal yard pumping basin (coal storage area, fly ash storage 

area), runoff from ash stacking area, treated metal cleaning waste water (Internal Monitoring 

Point 005), and direct precipitation on ash pond through Outfall 001; main condenser cooling 

water (CCW), miscellaneous equipment cooling and lubricating water, and roof drains through 

Outfall 002; intake screen backwash, discharged to Clinch River via Outfall 004 to cooling 

water channel.. 

Treatment in the ash pond of Flue Gas Desulfurization wastewater has been in 

operation since 2007-8. 

The discharge at Outfall 002 consists of main condenser cooling water (CCW), 

miscellaneous equipment cooling and lubricating water, and roof drains. 

The discharge at Outfall 004 is a comparatively minor waste stream from an intake 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-3 of R-43 

The only storm water discharges associated with industrial activity authorized by this 

permit are those discharged through Outfall 001. Storm water runoff discharges from the 

facility not specifically authorized in this permit are covered under the Tennessee Storm Water 

Multi-Sector General Permit for Industrial Activities, Permit Number TNR053185. 

Appendix 1 summarizes facility discharges and the receiving stream information for 

Outfalls 001, 002, 004, and IMP 005. 

IV. APPLICABLE EFFLUENT LIMITATIONS GUIDELINES 

Wastewater discharged from Outfall °Oland 002 is subject to the effluent limitation 

guidelines contained in 40 CFR, Part 423 for the Steam Electric Power Generating Point 

Source Category. The Best Practicable Control Technology (BPT) and Best Available 

Technology Economically Achievable (BAT) limitations for several effluent characteristics are 

given in sections §423.12 and §423.13, respectively for the following waste streams: fly ash and 

bottom ash transport water, metal cleaning wastes, once through cooling water (main 

condensers), cooling tower blow down, coal pile runoff, and low volume waste sources. Low 

volume waste sources are defined in §423.11(b) as "...wastewater from all sources except 

those for which specific limitations are otherwise established..." 

Of particular importance are §423.12(b)(12) and §423.13(h) which state that when 

regulated waste streams are combined for treatment or discharge, the quantity of each pollutant 

or pollutant property controlled in §423.12 and §423.13 attributable to each controlled waste 

source shall not exceed the specified limitation for that waste source. These sections were 

interpreted in consideration of a U.S.EPA Memorandum dated August 22, 1985, titled 

"Guidance for NPDES Permits Issued to Steam Electric Power Plants." Because multiple waste 

streams of certain CFR limited discharges are combined and treated in the facility ash pond 

prior to discharge through Outfall 001, the effluent limits set forth in this permit for Outfall 001 

are established in accordance with the methods described in the guidance. 

Appendix 2 lists the applicable effluent limitations guidelines specified in §423.12 and 

§423.13. 

V. PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS 

Appendix 3 lists the permit limitations and monitoring requirements as defined in the 

previous permit. 

VI. HISTORICAL MONITORING AND INSPECTION 

During the previous permit term, TVA - Bull Run Fossil Plant (BRF) did not have any 

ibldiffiliifflliiilid ihiiA 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-4 of R-43 

operation and maintenance of the equipment used in determining compliance with the permit. 

The following items were reports as the result of that inspection: 

A. There were no operational problems observed at the time of the inspection, however, 

there were some procedural issues discussed with site personnel at the time of the 

inspection. 

B. A copy of the permit was available for review. All documents, laboratory reports, and 

monitoring reports were available for review and appear to be in line with the 

requirements of the permit. TMSP monitoring for 2008 was also available for review 

and appeared to be satisfactory. TVA reported iron as having exceeded the cut off 

value given in the TMSP. However, the excess was not substantial. This was found at 

outfalls F11 and F16. TVA has taken action to mitigate the problem. 

C. At the time of our inspection, we reviewed the DMR and MOR reports for the past twelve 

months and found no deficiencies or violations of permit limits. TVA Bull Run plant has 

successfully completed their DMR, QA study 28 and reported on August 29, 2008. On 

the day of the inspection, the plant appeared in compliance and operational. The 

effluent being discharged had no visible signs of solids, oil sheen, scum, or foam in the 

receiving stream from the outfall. 

D. TVA Bull Run Steam Plant had bio-monitoring testing completed in June 25, 2008, by an 

outside contractor. The results were available for review and it appeared to be complete 

and satisfactory. 

E. On November 25, 2008, TVA completed a calculation on the ash pond volume and 

freeboard as required by the permit. Based on the calculation, the ash pond has a 

sufficient volume and freeboard to handle additional water in case of emergency before 

the dam overtops. 

F. On June 9, 2008, TVA also performed a complete stability inspection of the ash pond 

and evaluated the structure's integrity and stability. The inspection finding appeared to 

be satisfactory. 

VII. NEW PERMIT LIMITS AND MONITORING REQUIREMENTS 

The new permit limits are determined by using Best Professional Judgment (BPJ) 

through a comparison of any applicable EPA effluent guidelines or State of Tennessee 

maximum limits per Rule 1200-4-5-.03(2) with the previous permit limits and operational and/or 

treatability data. The more restrictive requirement from this comparison is checked against the 

appropriate water quality criteria. The most restrictive limit is used as the new permit limit. 

Monitoring of flow will be required at all outfalls. Flow shall be reported in Million Gallons per 

Day (MGD) and monitored at the time of sample collection. Monitoring of flow quantifies the 

load of pollutants to the stream. 

Appendix 5 lists all effluent limitations and monitoring requirements included in the new 

permitAppendix 5 also provides formulas and detailed procedures for Water Quality Based 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-5 of R-43 

dewatering facilities and closing ash and gypsum ponds. This renewed permit contains in Part 

III the provision for a Closure Plan for the existing ash ponds. 

B. DIKE INSPECTIONS 

1. Inspection Procedures 

a. The Bull Run ash pond shall be inspected in accordance with TVA's 

Reservoir Operations Dam Safety Program criteria and processes. This 

program is in accordance with the 'Federal Guidelines for Dam Safety' 

developed by the Federal Emergency Management Agency (FEMA 93). This 

document directs TVA to perform inspections scheduled on specific intervals 

and with qualified personnel. The dikes will also be visually inspected daily 

during operations by site personnel or designee. Impoundments shall be 

inspected annually by a qualified TVA engineer under the direction of a 

State-registered professional engineer. Special inspections by qualified 

personnel shall be done immediately after intense, large or extended rain 

events (i.e., 10-year storm or equaling or exceeding the design requirements 

for managing storm water) or within 24 hours after a significant seismic event 

approaching or exceeding the design event. The reason for this is to validate 

structural integrity of the structure following an event that could test the 

design assumptions. 

b. (Inspections shall, at a minimum, include observations of dams, dikes and 

toe areas for erosion, cracks or bulges, subsidence, seepage, wet or soft 

soil, changes in geometry, the depth and elevation of the impounded water, 

sediment or slurry, freeboard, changes in vegetation such as overly lush, 

obstructive vegetation and trees, and any other changes which may indicate 

a potential compromise to impoundment integrity. The findings of each 

inspection shall be documented in a written inspection report. 

c. Remediation Measures. Within 24 hours of discovering changes that indicate 

a potential compromise to the structural integrity of the impoundment, the 

permittee shall begin procedures to remediate the problem. Changes such as 

significant increases in seepage or seepage carrying sediment may be signs 

of imminent impoundment failure and should be addressed immediately. 

d. Other issues which may have long term impacts on integrity, such as trees 

growing on the embankment (especially large, dead or tilting trees, with 

special concern for those at the toes of or within the saturated zones of 

embankment structures), or vegetation-blocking overflows or spillways, shall 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-6 of R-43 

b. Within 5 days of discovering any changes in the impoundment that indicate a 

potential compromise to the structural integrity of the dike (e.g., significant 

changes in seeps, boils, bulges, or cracks), the permittee must notify the 

division in writing describing the findings of the inspection, corrective 

measures taken, and expected outcomes. Failure to do so will be a violation 

of this permit. 

c. The permittee shall submit an annual report to the division summarizing 

findings of all monitoring activities, inspections, and remediation measures 

pertaining to the structural integrity, design, construction, and operation and 

maintenance of all impoundments. 

d. The permittee shall maintain records of all impoundment inspection and 

maintenance activities, including corrective actions made in response to 

inspections and all other activities undertaken to repair or maintain the 

impoundment. All records shall be kept on site and made available to State 

or Federal inspectors upon request. 

e. All pertinent impoundment permits, design, construction, operation, and 

maintenance information, including but not limited to: plans, geotechnical and 

structural integrity studies, copies of permits, associated certifications by 

qualified, State-registered professional engineer, and regulatory approvals, 

shall be kept on site and made available to State or Federal inspectors upon 

request. 

3. Permit Re-opener Requirement 

The Director may re-open this permit to incorporate more stringent requirements or any 

applicable standards pertaining to the operation and maintenance of coal combustion 

waste impoundments. 

C. ASH POND VOLUME 

Beginning on the effective date of this permit, the permittee shall provide and maintain a 

minimum free water volume in the ash pond of 16.226 40.5 million gallons.as-eaTeulated4R 

Appendix 5. As needed, the permittee shall remove settled material from the pond, or 

otherwise enlarge the available storage capacity in order to maintain the required minimum 

volume. The permittee shall certify annually that the required volume is maintained and shall 

submit the report to the Division with the monthly DMR once per year. Certification shall be 

based upon physical surveys conducted every two years and estimates of ash volumes 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-7 of R-43 

In order to complete the work, TVA will temporarily lower the FWV water level in the ash 

pond by four feet and gradually raise it to normal levels upon completion. In approving the 

request, TDEC required the Total Suspended Solids monitoring at Outfall 001 be increased 

from monthly to weekly. 

F. USE OF TOXIC CHEMICALS 

The permittee shall practice due diligence in evaluating any material that could 

potentially be discharged via the NPDES outfalls. The permittee shall evaluate the following: 

1. Name and general composition of the chemical, 

2. Frequency of use, 

3. Quantities to be used, 

4. Proposed discharge concentrations, 

5. Existing 96-hour LC50 toxicity data (including laboratory reports if available) for 

available aquatic species, 

6. Product data sheet, and 

7. Product label or copy of the product label. 

Discharge of any product registered under the Federal Insecticide, Fungicide, and 

Rodenticide Act to any waste stream which may ultimately be released to lakes, rivers, streams, 

or other surface waters of the State is prohibited unless authorized in writing by the Division. 

This requirement is not applicable to products used for lawn and agricultural purposes. This 

requirement is also not applicable to herbicides used in accordance with labeled instructions 

and any applicable State permit. Discharge of chlorine from the use of chlorine gas, sodium 

hypochlorite, or other similar compounds for disinfection in plant potable and service water 

systems and in sewage treatment is authorized as are similar compounds in once-through 

cooling water. 

G. MACROINVERTEBRATE CONTROL MEASURES 

The permittee shall submit a plan to the Division if biocides are to be used for 

macroinvertebrate control at the site. If this is implemented at this facility, the permittee will 

submit a plan to the Division describing the macroinvertebrate controls to be utilized, material 

feed rates, and proposed monitoring schedule to verify that effluent limitations are being met 

and water quality is being protected. Use of biocides may warrant modification of this permit to 

include additional monitoring or permit limitations. 

H. RE-ROUTING FLOWS FOR MAINTENANCE PURPOSES 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-8 of R-43 

I. HEAVY METALS MONITORING 

The permittee shall monitor heavy metals at the West Knox District Intake on semiannual basis to ensure this source will not exceed Drinking Water Standards. Heavy metals 

shall not be discharged in concentrations which cause intake concentrations in the West Knox 

Utility District Intake to exceed the following limitations at any time: 

Arsenic : 0.05 mg/I Lead : .0.015 mg/I 

Cadmium : 0.005 mg/I Mercury : 0.002 mg/I 

Chromium : 0.1 mg/I Selenium : 0.05 mg/I 

The permittee shall certify annually that the required intake concentrations are maintained and 

shall submit the report to the Division with the monthly DMR once per year. 

J. PROCEDURES FOR WATER QUALITY BASED EFFLUENT STANDARDS 

The procedure used to calculate the allowable instream concentrations for permit 

limitations is shown in Appendix 5. Should monitoring for a particular pollutant indicate that the 

pollutant is not present (i.e., consistently below detection level), then the division may drop the 

monitoring requirements in the reissued permit. 

Procedures for calculations consider background conditions, chronic and acute water 

quality criteria, and critical low streamflow in a spreadsheet which calculates a mass balance. 

The calculated chronic water quality effluent concentrations required for Fish and 

Aquatic Life are compared to the Human Health criteria in order to determine the most stringent 

chronic 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, as shown in Appendix 5. 

K. EFFLUENT REQUIREMENTS FOR OUTFALL 001, ASH POND 

1. BIOMONITORING REQUIREMENTS, CHRONIC 

Based on the results of biomonitoring for the effluent discharged through Outfall 001 in 

the period of 1994-2006 (see permit application), the division has determined that reasonable 

potential to exceed narrative water quality standards has not been demonstrated. Therefore, 

the whole effluent toxicity (WET) limitation at Outfall 001 will not be required in the proposed 

permitHoweverin accordance with EPA recommendations in the Technical Support 
Stream Is Source of Effluent 

Outfall 001 

Strea 

Flow 

Wastewater 

Flow 

Tota 

Flow 

[MGD] [MGD] [MGD] 

129.3 19.037 129.3 

DF 6.8 

IC25 › 

IWC 14.7 

...•••••- 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-9 of R-43 

2. AMMONIA NITROGEN 

Selective Non-Catalytic Reduction (SNCR) equipment is used at BRF to lower nitrogen 

oxide stack emissions, as mandated by the Tennessee Air Quality Board. Installation and 

operation of the equipment, which involves injection of ammonia nitrogen into the process, has 

been underway prior to the previous permit. 

Wastewater volume of 4-977 18.7 MGD discharged from Outfall 001 in the renewal 

application is only marginally different from the previous permit of 17 MGD. Although the 

potential exists for effluent discharged from this outfall to contain increased amounts of 

ammonia nitrogen, reported concentrations of intake and effluent do not show substantial 

differences of 0.1 mg/l and 0.2 mg/I, respectively — see next page. 

To assess the potential for ammonia toxicity in the receiving stream, TDEC uses a 

spreadsheet calculation which considers stream pH and temperature, as shown below. These 

calculations indicate the allowable effluent concentration of 11 mg/I would be required to protect 

water quality. Accordingly, the renewed permit shall continue monitoring only at Outfall 001 for 

ammonia. 

Monitoring, on a report basis, will include inflow (sampled at the skimmer wall or at a 

comparable location) and effluent from Outfall 001. The net discharge will be calculated and 
Bull Run Fossil 

5 Ili SN001 and Plant-intake- Nitrogen,AmmeniaTotal 

5/20006 5/2/2007 5/2/2008 5/2/2009 

Plant intz ke 

-D5N001 

3 ! 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-10 of R-43 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-11 of R-43 

Ammonia as Nitrogen Calculations 

The State utilizes the EPA document, 1999 Update to Ambient Water Quality Criteria for Ammonia and 

assumed temperatures of 25°C and 15°C and stream pH of 8 to derive an allowable instream protection value. 

A mass balance with plant and stream flows and this allowable value determines the monthly average permit limit. 

Seasonal limits may also be allowed due to ambient temperature variations between the summer and winter seasons. 

East TN- 25°C, 15°C A pH value of 7.8 (instead of historically used 7.5) was chosen for two 

Middle TN- 27°C, 17°C reasons: 1.) ambient monitoring in east TN showed that a pH often 

West TN- 30°C, 20°C exceeds 7.5, and is up to 7.8 is the 10-year mean 

2.) this assumption is more conservative. 

Winter Summer 

Temp (°C)= 15 Temp (°C)= 25 

pH° 7.8 pH= 7.8 

Min (2.85, 1.45°10^ 2.76 Min (2.85, 1.45°10^ 1.45 

0.028°(25-T)) 2.85 0.028125-T)) 2.85 

2.76 1.45 

CCC= 3.09 CCC= 1.62 

CCC - Contionuous Chronic Criterion Allowable instream NH3 concentration [mg/1] 

where: 129 Critial Low Flow [MGD] (7010 value) 

0.1 Background Ammonnia Concentration [mg/L] 

18.9 WWTP Design Flow or long-term average flow [MGD] 

Therefore, the Allowable Effluent Concentrations and corresponding Amounts in winter and summer are: 

Winter Summer 

Concentration [mg/L] 23.46 Concentration fmg/L] 11.987 

Amount [lb/day] 3697.8 Amount [lb/day] 1889.5 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-12 of R-43 

3. OUTFALL 001 - ASH POND DISCHARGE OF METALS 

40 CFR, §122.44(d)(1)(iii) states that effluent limits must be specified for an individual 

pollutant when it is determined that "a discharge causes, has the reasonable potential to cause, 

or contributes to an in-stream excursion above the allowable ambient concentration of a State 

numeric criteria within a State water quality standard for an individual pollutant". The permit 

application indicates that a number of metals are believed to be present in the ash pond 

discharge. For each of these metals a comparison was made of the effluent concentration as 

reported on DMRs and the permit application, with calculated limits based on State of 

Tennessee water quality criteria (APPENDIX 5d) or maximum limits per Rule 1200-4-5-.10 

Spreadsheet calculations are shown below utilizing the procedures described earlier for 

determining water quality-based effluent limits. Specific factors used in these calculations 

include: 

• stream background concentrations per the TVA permit application reported 

values from Bull Run intake monitoring, and 

• hardness value of 145 mg/I from the TDEC upstream ambient monitoring station 

at mile 66 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-13 of R-43 

1 

‘; 

FACILITY: 

PERMIT #: 

TVA - Buil Run Fossil Plant 

TN0005410 

Stream 

(1010) 

Stream 

(3005) 

Waste 

Flow 

Ttl. Susp. 

Solids 

Hardness 

(as CaCO3) 

Stream 

Allocation 

[MOD] [MGDI [MGD] [mgill [m0/1] 1%1 

129.300 424.600 19.037 10 145 90 

1 2 1 3 4 5 6 1 7 1 8 

Stream 

Bckgmd. 

Conc." 

Fish/Aqua. Life 

Water Quality Criteria 

Effluent 

Fraction 

Dissolved 

Fish & Aquatic Life Water Quality Criteria (1010) 

In-Stream Allowable Calc. Effluent Concentration 

EFFLUENT 

CHARACTERISTIC 

Chronic Acute Chronic Acute Chronic Acute 

11-18/11 [ugrI] [ug/I] [Fraction] [ug/I] Iughll lug/I1 [ugh] 

Arsenic 2.50 150 340 1.000 150.00 340.00 1036.6 2369.1 

Cadmium * 2.50 1.357 5.537 0.193 7.04 28.72 34.1 186.2 

Copper * 3.00 15.59 24.15 0.218 71.54 110.80 483.3 758.7 

Lead * 1.60 3.76 96.55 0.143 26.22 672.87 174.1 4708.9 

Silver * 2.50 NA 6.537 0.850 NA 7.69 NA 38.6 

Nickel * 13.00 215.25 1938.20 0.206 1046.14 9419.74 7256.9 65979.6 

Mercury, (T) *** 0.006 0.700 1.400 1.000 ' 0.700 1.400 4.87 9.8 

Chromium (T)*"* 0.50 74.00 570.00 1.000 74.000 570.000 515.9 3994.3 

Selenium ***** 0.50 5.00 20.00 1.000 5.000 20.000 32.0 137.2 

The Fish & Aquatic Life 

and calculated effluent 

In cases where the 

watershed. 

than toxicity. 

2C 

30Q5 flow. 

r 9 10 11 12 1 13 14 

Human Health Wate Quality Criteria (3005) 

In-Stream Criteria Ca[c. Effluent Concentration 

EFFLUENT 

CHARACTERISTIC 

Organisms VatelOrganisnff DWS Organisms %later/Organism: DWS 

[uWI] [ugll] [ugri] [ug/l] [ug/I] [ug/I] 

Arsenic 10.0 10.0 10.0 46.3 159.6 159.6 

Cadmium * NA NA 5.0 NA NA 54.7 

Copper* NA N/A NA NA NA NA 

Lead * NA NA 5.0 NA NA 72.8 

Silver " NA NA 100.0 NA NA 2047.2 

Nickel" 4600.0 610.0 100.0 96217.3 12532.9 1836.4 

Mercury, (T) *** 0.051 0.05 2.0 0.949 0.928 41.8 

Chromium (T)**" NA NA 100.0 NA NA 2087.3 

Selenium NA NA 5.0 NA NA 104.9 

* Denotes metals for which Fish & Aquatic Life Criteria are expressed as a function of total hardness. 

criteria for this metal are in the dissolved form at laboratory conditions. The in-stream allowable criteria 

concentrations are in the total recoverable form. 

** Stream background concentrations are taken from Outfall 002 intake sample on the permit application. 

background concentration was reported as less than a value, one halt of the value was used. 

A background level of 0.006 ug/L based on reference stream monitoring by DOE in the Lower Clinch 

*** The chronic criterion for mercury is not converted to dissolved, since it is based on fish tissue data rather 

  The criteria for this parameter are in the total recoverable form. 

** **" Stream background concentration for selenium is half of the intake value of <0.001 mg/I reported on Form 

and for arsenic is half of the intake value of <.005 mg/I. 

NOTE: Water Quality criteria for stream use classifications other than Fish & Aquatic Life are based on the 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-14 of R-43 

The comparison table shown below illustrates the relationship between calculated 

effluent requirements for metals, TN water quality criteria, and reported concentrations from 

Outfall 001 on Discharge Monitoring Reports. 

DETERMINATION OF MONITORING REQUIREMENTS BY 

COMPARISON OF APPLICABLE EFFLUENT LIMITATIONS 

TVA- Bull Run Fossil Plant 

Outten 001 

RDL * 

DMR Summary** Application Sample Tennessee 

WQC 

Water 

Long Term Quality*** 

Average 

Daily 

Maximum 

Daily 

EFFLUENT Maximum 

CHARACTERISTIC [mg/1] I [mg/I] [mg/I] [mg/I] [mg/I] [mg/I] 

Cadmium (T) 0.001 0.0004 0.0005 0.0007 0.002 0.06 

Chromium (T) 0.001 0.002 0.004 0.0015 0.57 2.09 

Copper (T) 0.001 0.0044 0.0057 0.0050 0.013 0.758 

Lead (T) 0.001 0.0010 0.0020 0.0020 0.065 0.07 

Mercury, (T) 0.0002 0.0002 0.0002 <0.0002 0.00005 0.0009 

Silver (T) 0.001 0.0004 0.0010 <0.0005 0.003 0.038 

Nickel 0.01 NR NR 0.0085 0.47 1.836 

Arsenic 0.001 NR NR 0.011 0.34 0.16 

Selenium (T) 0.002 0.0120 0.0280 0.015 0.02 0.1050 

* Required Detection Level per State of Tennessee Rule 1200-4-3-.05(8) 

** Data reported 2005 - 09. 

*** Most stringent applicable water quality based limit. 

These data illustrate two things: 

(1) the effluent concentrations necessary to protect water quality in the Clinch River 

downstream of Outfall 001 as shown in the spreadsheet on the preceding page, and 

(2) reported effluent concentrations comply with the required water quality based limits. 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-15 of R-43 

The division has determined that additional monitoring of toxic metals is required in the 

renewed permit for the Ash Pond discharge. Monitoring frequencies for metals are established 

as monthly and additional monitoring will be conducted and reported as shown below: 

OUTFALL 001 EFFLUENT LIMITATIONS MONITORING 

REQUIREMENTS 

MONTHLY DAILY 

EFFLUENT 

CHARACTERISTIC 

AVG. 

CONC. 

AVG. 

AMT. 

MAX. 

CONC. 

MAX. 

' AMT. MSRMNT. 1 

FRQNCY. 

SAMPLE 

TYPE (ug/L) (lb/day) (ug/L) (lb/day) 

Arsenic (T) N/A N/A report N/A Monthly Grab 

Cadmium (T) N/A N/A report N/A Monthly Grab 

Copper (T) N/A N/A report N/A Monthly Grab 

Lead (T) N/A N/A report N/A Monthly Grab 

Mercury (T) N/A N/A report N/A Monthly Grab 

Nickel (T) N/A N/A report N/A Monthly Grab 

Selenium (T) N/A N/A report N/A Monthly Grab 

Thallium (T) N/A N/A report N/A Monthly Grab 

Zinc (T) N/A N/A report N/A Monthly Grab 

4. OUTFALL 001 - PH 

A pH range limit of 6.0 to 9.0 will be retained for the discharge from Outfall 001. This 

ensures the protection of water quality per certain Tennessee water quality criteria and, 

likewise, follow the federal guidelines promulgated by the EPA in 40 CFR §423.12(b)(1) which 

states "The pH of all discharges, except for once through cooling water, shall be in the range of 

6.0 to 9.0." The pH monitoring frequency at Outfall 001 will be retained from the previous 

permit at once per week, and collected by a grab sample. 

L. OUTFALL 002 

The effluent discharged through Outfall 002 is primarily composed of "once through 

cooling water" from the main condensers (approximately 546.4 MGD), which is subject to the 

effluent limitations guidelines contained in §423.12(b)(6) and §423.13(b). 

1. BIOMONITORING REQUIREMENTS, CHRONIC 

Based on the dilution factor and insufficient receiving stream flow for mixing, there is a 

concern for toxicity effects of the discharge on the receiving stream. Biomonitoring will provide 

information relative to the toxicity of the discharge. Calculation of toxicity limits is as follows: 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-16 of R-43 

129.3 

DF = = 0.24 

546.44 

Since the calculated dilution factor is less than 100:1, and assuming immediate and 

complete mixing, protection of the stream from chronic effects requires: 

1WC < 1.0 X IC25; or, 

INHIBITION CONCENTRATION, 25% › IWC 

Where IWC is lnstream Waste Concentration and is calculated using the following formula: 

Qw 

IWC = X 100 = lnstream Waste Concentration 

Qs 

546.44 

IWC = X 100 = 422.6 (i.e. 100%) 

129.3 

Therefore, WET testing will be required on 100% effluent. The toxicity tests specified 

herein shall be conducted annually and begin no later than ninety (90) days from the 

commencement date of biocide addition. Toxicity tests shall be conducted only if biocides are 

added to the once through cooling water. The details regarding biomonitoring methodology can 

be found in Part Ill of the permit. 

M. OUTFALL 004 

Intake screen backwash water (approximately 567 mgd) may be discharged 

through Outfall 004 without limitations or monitoring requirements. The discharge shall not 

have a visible oil sheen and reasonable steps shall be taken to prevent the return of unsightly 

materials to the receiving waters. 

N. INTERNAL MONITORING POINT 005 

Treated chemical and non-chemical metal cleaning wastes are discharged from 

Internal Monitoring Point 005, which discharges its effluent via the ash pond Outfall 001 to 

Clinch River mile 48.0. Due to the additional treatment and dilution provided by the ash pond, 

compliance with some of the requirements of 40 CFR §423.12(b)(5) and §423.13(e) for facility 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-17 of R-43 

discharges through IMP005 only when metal cleaning operations or other process wastewater 

generating activities occur. 

0. USE OF TREATED EFFLUENT FOR DUST CONTROL ON ROADS 

TVA's September 24, 2007, permit renewal application requested authorization to use 

treated ash pond (Outfall 001) and/or ash dredge cell (future Outfall 011) wastewater for 

watering plant roadways for control of dusting and as a beneficial use of the water that would be 

discharged to the receiving stream. TVA requests inclusion of this authorization in the permit. 

The division disagrees with this practice, as it can contribute to long-term release in 

offsite particulate dust containing metals. We recommend TVA consider other dust control 

options in consultation with the TDEC Division of Air Pollution Control. Accordingly, the division 

is not approving this request. 

P. 316(A) — COMPLIANCE WITH SECTION 316, CLEAN WATER ACT 

1. 316(A) POTENTIAL THERMAL EFFECTS ON A BALANCED INDIGENOUS 

POPULATION OF AQUATIC LIFE 

Section 316(a) of the Clean Water Act allows point-source discharges of heated water 

to exceed State water quality thermal criteria based on demonstrating maintenance of 

"Balanced Indigenous Populations" (BIP) of aquatic life. Bull Run Fossil is operating under a 

316(a) alternate thermal variance that has been administratively continued with each permit 

renewal based on studies conducted in the mid 1970's. The requirement for conducting 316(a) 

studies in TN comes from EPA Region IV guidance to the States requiring future variance 

requests be granted on new data generated to show aquatic communities meet the BIP 

standard. 

In 2001, TDEC approved the TVA program for Reservoir Fish Assemblies Index (RFAI) 

studies to support the continuation of thermal variances. RFAI data is collected at upstream 

and downstream stations in Melton Hill Lake on the Clinch River every two years. With the 

application, TVA submitted data from 2001, 03, and 05 supporting their request for continuation 

of the 316(a) variance from the previous permit. 

With the permit renewal application of September 2007, TVA described ecological 

conditions near Bull Run Fossil Plant as monitored at three locations under their Vital Signs 

(VS) program. In addition to the fish community, environmental indicators are measured in the 

VS program for dissolved oxygen, chlorophyll, sediment quality, and benthic macro-invertebrate 

community. 

TDEC hid hRFAI fih idf2001200d idifid 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-18 of R-43 

Extensive interagency discussions between TVA, TDEC, and EPA Region 4 have 

occurred regarding future studies to demonstrate BIP. EPA Region 4 has requested additional 

information prior to their approval of TDEC renewal of any NPDES permits for fossil plants, in 

order to evaluate the thermal component and protection and propagation of a BIP. EPA and 

TVA have agree to revise the existing TVA process for reservoir monitoring in accordance with 

the following terms: 

Within 60 days of the permit effective date, the permittee shall prepare and submit for 

review by the Division a study plan which outlines how the permittee will conduct 

assessments that will generate information sufficient to support a determination of 

whether the Bull Run Plant's alternative thermal limit under Section 316(a) can be 

continued in its next NPDES permit. The proposed study plan shall be designed to 

supplement information previously provided by the permittee. The permittee shall 

implement provisions of the plan within 60 days of its approval by the Division 

In the renewed permit, TDEC will extend the thermal variance, with the condition that 

TVA will revise the reservoir monitoring approach acceptable to TDEC and EPA Region 4. 

2. 316 (B) - COOLING WATER INTAKE STRUCTURE-316(B) 

316(b) limitations for this facility are determined to be in compliance based on best 

professional judgment in accordance with 40 CFR 401.14 and 122.43. This permit may be 

reopened to address compliance with 316(b) requirements upon issuance of a new rule or fina 

guidance by EPA. 

This permit, TN0005410, had been previously issued by EPA under the federal NPDES 

permit program. In those previous permits the facility was deemed to be in compliance with the 

Clean Water Act Regulations, Establishing Requirements for Cooling Water Intake Structures 

at Phase II Existing Facilities. This regulation is also referred to as the "316(b) rule". Previous 

and current compliance with the rule have been and continue to be based on best professional 

judgment (BPJ) in accordance with Title 40 CFR 401.14 and 122.43. 

In 2007, during review of the draft permit addressing TVA's request for permit 

modification of the 316(b) language, EPA Region 4 suggested the division add language to the 

rationale of the permit to better detail the events supporting this modification. As it is still 

relevant to this permit renewal, we have included background information regarding the 2007 

recent Court actions relating to the 316(b) rule: 

On February 16, 2004, EPA took final action on regulations governing cooling water 

intake structures at certain existing power producing facilities under section 316(b) of 

the Clean Water Act (Phase II rule). 69 FR 41576 (July 9, 2004). The final Phase II rule 

applies to existing facilities that are point sources that, as their primary activity, both 

generate and transmit electric power or generate electric power for sale to another entity 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-19 of R-43 

These performance standards were determined to reflect the Best Technology Available 

(BTA) for minimizing adverse environmental impacts at facilities covered by the Phase 11 

rule. 

These regulations were challenged by industry and environmental stakeholders. On 

judicial review, the Second Circuit decision (Riverkeeper, Inc. v. EPA, 475 F.3d 83, (2d 

Cir., 2007)) remanded several provisions of the Phase ll rule on various grounds. The 

provisions remanded to EPA include: 

• EPA's determination of the BTA under section 316(b); 

• The rule's performance standard ranges; 

• The cost-cost and cost-benefit compliance alternatives; 

• The Technology Installation and Operation Plan provision; 

• The restoration provision; and 

• The "independent supplier" provision. 

With several significant provisions of the Phase II rule affected by the decision, and with 

the need to provide timely direction to Stakeholders about the continuing application of 

the Phase II rule, EPA's Assistant Administrator for Water issued a memorandum on 

March 20, 2007, which announced EPA's intention to suspend the Phase II rule. This 

memorandum also discussed the anticipated issuance of [this] Federal Register 

suspension document. 

The formal suspension of the rule was published in the Federal Register: July 9, 2007 

(Volume 72, Number 130)][Rules and Regulations][Page 37107-371091, and is available from 

the Federal Register Online via GPO Access [wais.access.gpo.godDOC1D:frO9N07-31. 

Upon notice of the suspension of this rule, TVA requested to modify and remove only 

the suspended 316(b) requirements previously issued in this and seven (7) other TVA NPDES 

permits. The division agreed with the TVA request and modified only those requirements 

specifically suspended by the EPA, specifically the CDS report. All other permit requirements 

remained in place as enforceable compliance items as previously permitted and were deemed 

to remain in compliance with the remainder of the Clean Water Act based on BTA and best 

professional judgment (BPJ). 

In January, 2008, TVA submitted biological monitoring data collected in 

accordance with the permittee's Proposal for Information Collection (PIC) plan as 

developed under the 316(b) requirements prior to their suspension by EPA on March 20, 

2007. This and other information will be used to support evaluation of Best Technology 

Available during permit reissuance in subsequent years. 
OUTFALL 001 

LONGITUDE 

84-09-15 

LATITUDE 

36-00-00 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-20 of R-43 

APPENDIX 1 

FACILITY DISCHARGES AND RECEIVING WATERS 

FLOW DISCHARGE 

(MGD) SOURCE 

Discharge from Asti pond: 

1.6430 Boiler bilge sump 

3.1900 Hydroveyers (ash collection) 

1.4290 Precipitator washdown sump 

0.0052 MCW Chemical treatment pond (IMP 005) 

0.0011 Dry 0y ash washdown sump 

1.1920 FD tan cooling water 

1.1170 Stack yard sump (equipment cooling water) 

0.0290 Stack yard sump (floor drainage) 

6.8480 Ash sluice water 

0.0042 Fly ash silo area sump 

0.0780 Demineralizer sump 

0.1365 Coal yard drainage basin/sump (fly ash stacking area) 

0.1550 Coal yard drainage basinIsump (coal storage area) 

0.9716 Coal yard drainage basin/sump (floor/roof drains) 

-0.0970 Coal yard drainage basin/sump (evaporation) 

0.0141 Ash sluice line low point sump (yard runoff) 

0.0247 Ash sluice line low point sump (electrical yard runoff) 

0.0177 Ash sluice line low point sump (back parking lot runoff) 

1.0380 Main station sump (equipment cooling water & leakage 

0.0140 Main station sump (service bay floor drainage) 

0.0680 Main station sump (plant leakage - boilers) 

0.0041 Main station sump (roof drains) 

0.0142 Unwatering sumps (yard runoff) 

0.5003 Precipitation 

0.1180 Evaporation 

0.7570 FGD Flows, including runoff 

19.0367 TOTAL DISCHARGE 

Treatment: Settling (1U), Neutralization (2K). 

RECEIVING STREAM 

DISCHARGE ROUTE 

Outfall 001 discharges into Clinch River mile 48.0 

STREAM LOW 

FLOW (CFS) * 

701 1010 3002 

290. 200.0 657.0 

(MGD) 1 187.4 129.3 424.6 

STREAM USE CLASSIFICATIONS (WATER QUALITY) 

RSH FEOREATION IRRIGATION LW&W DOMESTIC 

X X X X X 

INDUSTRIAL NAVIGATION 

x x 

Reference: Flow Duration and Low Flows of Tennessee Streams th rough 1992 by George S. Law and Jess D. 

Weaver. Water Resources Investigations Report 95-4293 prepared by the U.S. Geological Survey in 

Cooperation with the Tennessee Department of Environment and Conservation and the Tennessee Valley 

Authority. Nashville, Tennessee, 1996, p. 51. Station number 03533000: flow regulated by Norris Dam. 
OUTFALL 002 

LONGITUDE 

84-09-30 

LATITUDE 

36-01-00 

FLOW DISCHARGE 

(MGD) SOURCE 

Condenser cooling water discharges: 

0.0040 Roof drains 

17.8550 Equipment cooling water 

539.9420 Condenser cooling water 

0.0270 Intake screen backwash (Outfall 004) 

-11.3880 Withdrawal for ash disposal 

546.4400 TOTAL DISCHARGE 

RECEIVING STREAM 

DISCHARGE ROUTE 

duffel! 002 discharges into Clinch River mile 48.0 

STREAM LOW 7010 1Q10 3002 

FLOW (CFS) * 290.0 200.0 NA 

(MGD) I 187.4 129.3 NA 

STREAM USE CLASSIFICATIONS (WATER QUALITY) 

FISH RECREATION IRRIGATION UMW DOMESTIC 

x x x x x 

INDUSTRIAL NAVIGATION 

X X 

Treatment Discharge to surface water via condenser cooling water discharge canal (4A). 

Reference: Flow Duration and Low Flows of Tennessee Streams through 1992 by George S. Law and Jess D. 

Weaver. Water Resources Investigations Report 95-4293 prepared by the U.S. Geological Survey in 

Cooperation with the Tennessee Department of Environment and Conservation and the Tennessee Valley 

Authority. Nashville, Tennessee, 1996, p. 51. Station number 03533000:flow regulated by Norris Dam. 

OUTFALL 004 

LONGITUDE 

84-09-30 

LATITUDE 

36-01-00 

FLOW DISCHARGE 

(MOD) SOURCE 

Raw river water 

0.0900 Backwash intake water (approximate) 

0.0900 TOTAL DISCHARGE 

RECEIVING STREAM 

DISCHARGE ROUTE 

Outfali 004 discharges into Clinch River mile 48.0 via CCWC 

STREAM LOW 

FLOW (CFS)* 

7010 1Q10 3002 

290.0 200.0 NA 

(MGD) 187.4 129.3 NA 

STREAM USE CLASSIFICATIONS (WATER QUALITY) - - 

FISH RECREATION IRRIGATION LW&W DOMESTIC 

x x x x x 

INDUSTRIA L NAVIGATION 

x x 

Reference: Flow Du ration and Low Flows of Tennessee Streams through 1992 by George S. Law and Jess D. 

WeaverWater Resources Investigations Report 954293 prepared by the USGeological Survey in R 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-21 of R-43 

APPENDIX 1 (continued) 
OUTFALL 005 

LONGITUDE 

84.09-45 

LATITUDE 

36-01-45 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-22 of R-43 

APPENDIX 1 (continued) 

FLOW DISCHARGE 

(MGD) SOURCE 

to 001 

0.0606 Boiler chemical cleaning 

0.0040 Air preheater washer 

0.0041 Precipitation 

-0.0035 Evaporation 

0.0052 I TOTAL DISCHARGE 

RECEIVING STREAM 

DISCHARGE ROUTE 

Outfall 005 discharges into Clinch River mile 48.0 (via Outfall 001) 

STREAM LOW 7010 1Q10 3002 

FLOW (CFS) * 290.0 200.0 NA 

(MGD) r 187.4 I 129.3 NA 

STREAM USE CLASSIFICATIONS (WATER QUALITY) 

RS H RE-CREATION IRRIGATION LW&W DOMESTIC 

x x x x x 

INDUSTRIAL NAVIGATION 

X X 

Treatment in a 8.65 acre pond: pH adjustment, aeration 2B), chemical precipitation of metals (2C), settling (1 U), and 

neutralization (in ash pond)(2K) 

Reference: Flow Duration and Low Flows of Tennessee Streams through 1992 by George S. Law and Jess D. 

Weaver. Water Resources Investigations Report 95-4293 prepared by the U.S. Geological Survey in 

Cooperation with the Tennessee Department of Environment and Conservation and the Tennessee Valley 

Authority. Nashville, Tennessee, 1996, p. 51. Station number 03533000: flow regulated by Norris Dam. 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-23 of R-43 

APPENDIX 2 

APPLICABLE EFFLUENT LIMITATIONS GUIDELINES from Title 40, CFR Part 

§423.12 Effluent limitations guidelines representing the degree of effluent reduction 

attainable by the application of the best practicable control technology currently 

available (BPT). 

b) Any existing point source subject to this subpart must achieve the following effluent limitations 

representing the degree of effluent reduction by the application of the best practicable control 

technology currently available (BPT): 

(1) The pH of all discharges, except once through cooling water, shall be within the range of 6.0-

9.0. 

(2) There shall be no discharge of polychlorinated biphenyl compounds such as those commonly 

used for transformer fluid. 

(3) The quantity of pollutants discharged from low volume'waste sources shall not exceed the 

quantity determined by multiplying the flow of low volume waste sources times the concentration 

lised in the following table: 

Pollutant or pollutant 

property 

BPT effluent limitations 

Maximum for any 1 

day (mg/1) 

Average of daily values for 30 consecutive 

days shall not exceed (mg/1) 

TSS 100.0 30.0 

Oil and grease 20.0 15.0 

(4) The quantity of pollutants discharged in fly ash and bottom ash transport water shall not 

exceed the quantity determined by multiplying the flow of fly ash and bottom ash transport water 

times the concentration listed in the following table: 

Pollutant or pollutant 

property 

BPT effluent limitations 

Maximum for any 1 

day (mg/1) 

Average of daily values for 30 consecutive 

days shall not exceed (mg/1) 

TSS 100.0 30.0f 

Oil and grease 20.0 15.01 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-24 of R-43 

5) The quantity of pollutants discharged in metal cleaning wastes shall not exceed the quantity 

determined by multiplying the flow of metal cleaning wastes times the concentration listed in the 

following table: 

Pollutant or pollutant 

property 

BPT effluent limitations 

Maximum for any 1 

day (mg/1) 

Average of daily values for 30 consecutive 

days shall not exceed (mg/1) 

TSS 100.0 30.0 

Oil and grease 20.0 15.0 

Copper, total 1.0 1.0 

Iron, total 1.0 1.0 

(6) The quantity of pollutants discharged in once through cooling water shall not exceed the 

quantity determined by multiplying the flow of once through cooling water sources times the 

concentration listed in the following table: 

Pollutant or pollutant 

property 

BPT effluent limitations 

Maximum concentration 

(mg/1) 

Average concentration 

(mg/I) 

Free available chlorine 0.5 0.2 

(7) The quantity of pollutants discharged in cooling tower blowdown shall not exceed the quantity 

determined by multiplying the flow of cooling tower blowdown sources times the concentration listed 

in the following table: 

Pollutant or pollutant 

property 

BPT effluent limitations 

Maximum concentration Average concentration 

(mg/1) (mg/1) 

Free available chlorine 0.5 0.2 

(8) Neither free available chlorine nor total residual chlorine may be discharged from any unit for 

more than two hours in any one day and not more than one unit in any plant may discharge free 

available or total residual chlorine at any one time unless the utility can demonstrate to the Regional 

Administrator or State, if the State has NPDES permit issuing authority, that the units in a particular 

location cannot operate at or below this level or chlorination. 
BAT Effluent Limitations 

Pollutant or pollutant property Maximum concentration (mg/I) 

Total residual chlorine 0.20 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-25 of R-43 

(10) Any untreated overflow from facilities designed, constructed, and operated to treat the volume 

of coal pile runoff which is associated with a 10 year, 24 hour rainfall event shall not be subject to 

the limitations in paragraph (b)(9) of this section. 

(11) At the permitting authority's discretion, the quantity of pollutant allowed to be discharged may 

be expressed as a concentration limitation instead of the mass based limitations specified in 

paragraphs (b)(3) through (7) of this section. Concentration limitations shall be those concentrations 

specified in this section. 

(12) In the event that waste streams from various sources are combined for treatment or discharge, 

the quantity of each pollutant or pollutant property controlled in paragraphs (b)(1) through (11) of this 

section attributable to each controlled waste source shall not exceed the specified limitations for that 

waste source. 

[47 FR 52304, Nov. 19, 1982, as amended at 48 FR 31404, July 8, 1983] 

§423.13 Effluent limitations guidelines representing the degree of effluent reduction 

attainable by the application of the best available technology economically achievable 

(BAT). 

Except as provided in 40 CFR 125.30 through 125.32, any existing point source subject to this part 

must achieve the following effluent limitations representing the degree of effluent reduction 

attainable by the application of the best available technology economically achievable (BAT). 

(a) There shall be no discharge of polychlorinated biphenyl compounds such as those commonly 

used for transformer fluid. 

(b)(1) For any plant with a total rated electric generating capacity of 25 or more megawatts, the 

quantity of pollutants discharged in once through cooling water from each discharge point shall 

not exceed the quantity determined by multiplying the flow of once through cooling water from each 

discharge point times the concentration listed in the following table: 

(2) Total residual chlorine may not be discharged from any single generating unit for more than two 

hours per day unless the discharger demonstrates to the permitting authority that discharge for more 

than two hours is required for macroinvertebrate control. Simultaneous multi-unit chlorination is 

permitted. 

(c)(1) For any plant with a total rated generating capacity of less than 25 megawattsthe quantity of 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-26 of R-43 

Pollutant or pollutant 

property 

BAT effluent limitations 

Maximum concentration 

(mg/I) 

Average concentration 

(mg/I) 

Free available chlorine 0.5 0.2 

(2) Neither free available chlorine nor total residual chlorine may be discharged from any unit for 

more than two hours in any one day and not more than one unit in any plant may discharge free 

available or total residual chlorine at any one time unless the utility can demonstrate to the Regional 

Administrator or State, if the State has NPDES permit issuing authority, that the units in a particular 

location cannot operate at or below this level of chlorination. 

(d)(1) The quantity of pollutants discharged in cooling tower blowdown shall not exceed the 

quantity determined by multiplying the flow of cooling tower blowdown times the concentration listed 

below: 

Pollutant or pollutant property 

BAT effluent limitations 

Maximum 

concentration 

(mg/I) Average concentration (mg/I) 

Free available chlorine 0.5 0.2 

Pollutant or pollutant property 

Maximum for any 

1 day -(mg/1) 

Average of daily values for 30 

consecutive days shall not 

exceed =(mg/1) 

The 126 priority pollutants (Appendix A) 

contained in chemicals added for cooling 

tower maintenance, except: 

(1) (1) 

Chromium, total 0.2 0.2 

Zinc, total 1.0 1.0 

1No detectable amount. 

(2) Neither free available chlorine nor total residual chlorine may be discharged from any unit for 

more than two hours in any one day and not more than one unit in any plant may discharge free 

available or total residual chlorine at any one time unless the utility can demonstrate to the Regional 

Administrator or State, if the State has NPDES permit issuing authority, that the units in a particular 

location cannot operate at or below this level of chlorination. 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-27 of R-43 

pollutant property Maximum for any 1 

day (mg/I) 

Average of daily values for 30 consecutive 

days shall not exceed -(mg/I) 

Copper, total 1.0 1.0 

Iron, total 1.0 1.0 

(f) [Reserved—Nonchemical Metal Cleaning Wastes]. 

(g) At the permitting authority's discretion, the quantity of pollutant allowed to be discharged may be 

expressed as a concentration limitation instead of the mass based limitations specified in 

paragraphs (b) through (e) of this section. Concentration limitations shall be those concentrations 

specified in this section. 

(h) In the event that waste streams from various sources are combined for treatment or discharge, 

the quantity of each pollutant or pollutant property controlled in paragraphs (a) through (g) of this 

section attributable to each controlled waste source shall not exceed the specified limitation for that 

waste source. 

(The information collection requirements contained in paragraphs (c)(2) and (d)(2) were approved 

by the Office of Management and Budget under control number 2040-0040. The information 

collection requirements contained in paragrdph (d)(3) were approved under control number 2040-

0033.) 

[47 FR 52304, Nov. 19, 1982, as amended at 48 FR 31404, July 8, 1983] 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-28 of R-43 

APPENDIX 3 

PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS 

PERMIT LIMITS 

OUTFALLS 001 

1--- EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. AMNT. MAX, CONC, MAX. AMNT. MSRMNT. 

FRQNCY. 

SAMPLE 

TYPE (mP,A) (ibiday) OW) (lb/day) 

FLOW Report (MGD) Report (MGD) * 1/Week Instantaneous 

pH ** Flange 6.0 - 9.0 1/Week Grab 

OIL & GREASE 12.0 -- 16.0 -- 1/Month Grab 

TOTAL SUSPENDED SOLIDS (TSS) 26.0 -- 84.0 -- 1/Month Grab 

NITROGEN, AMMONIA TOTAL (Plant 

Intake) -- -- Report Report 2/Month Grab 

NITROGEN, AMMONIA TOTAL 

(Effluent) 

- - L Report Report 2/Month Grab 

NITROGEN, AMMONIA TOTAL (Net 

Discharge) 

-- -- Report "*— Report 2/Month Calculated 

COPPER,TOTAL -- -- Report -- 1/Year Grab 

LEAD, TOTAL -- -- Report -- 1/Year Grab 

MERCURY, TOTAL -- -- Report -- 1/Year Grab 

SELENIUM, TOTAL -- -- Report -- 1/Year Grab 

CADMIUM, TOTAL -- -- Report -- 1/Year Grab 

CHROMIUM, TOTAL -- -- Report -- 1/Year Grab 

IRON, TOTAL -- -- Report -- 1/Year Grab 

MANGANESE, TOTAL -- -- Report -- 1/Year Grab 

SILVER, TOTAL -- -- Report -- 1/Year Grab 

IC25 Survival, Reproduction, & Growth in 100% Effluent Annually Grab *** 

Note: The permittee shall take reasonable steps to prevent discharge of cenospheres other than in trace amounts from the outfall. 

* Flow shall be reported in Million Gallons pe Day (MGD). 

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

*** See Part Ill for methodology. 

-- If a calculated value for net addition of ammonia as nitrogen exceeds an action concentration value of 1.0 mg/L, the permittee should 

investigate source(s) of ammonia, and proceed with a corrective action(s), if necessary. Furthermore, EFO - Knoxville shall be notified 

within 24 hours from the time the permittee receives results indicating that an action value of 1.0 rrig/L was exceeded. 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-29 of R-43 

APPENDIX 3 (CONTINUED) 

PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS 

1 

shall 

Outten 

of TRC 

that its MDL 

In cases 

period 

Plan 

PERMIT LIMITS 

OUTFALL 002 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY W DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. AMNT. MAX. CONC. MAX. AMNT. MSRMNT. SAMPLE 

TYPE (mS11) (1131clay) (rrign) (Ib/day) FRONCY. 

FLOW Report (MGD) Report (MGD) 1 / Day Estimate' 

TEMPERATURE, Intake Report -- Report -- 1 / Day Grab 

TEMPERATURE, Effluent - 31.1°C (88°F) 1 / Day Calculated 2 

TOTAL RESIDUAL OXIDANT 

(reported as chlorine) 3 

0.011 -- 0.019 -- 1 / Week 4 Grab 

TIME OF CHLORINE ADDITION 

(minute/day/unit) -- 120 5 1 / Day Log Records 

IC25 Survival, Reproduction, & Growth in 100% Effluent Once 6 Composite 6 

1 Flow shall be estimated from pump logs and reported in Million Gallons per Day (MGD). 

2 Intake temperature is measured hourly and reported as the average of the hourly measurements for each day. The daily maximum discharge temperature 

be calculated for the cooling channel based on the 24-hour average intake temperature, 24-hour average unit load, and the 24-hour average flow through 

002. 

3 Total Residual Chlorine (TRC) monitoring shall be applicable when chlorine, bromine, or any other oxidants are added. The acceptable methods for analysis 

are any methods specified in 40 CFR, Part 136. The method detection level (MDL) for TRC shall not exceed 0.05 mg/I unless the permittee demonstrates 

is higher. The permittee shall retain the documentation that justifies the higher MDL, and shall have that documentation available for review upon request. 

where the permit limit is less than the MDL, the reporting of TRC at less than the MDL shall be interpreted to constitute compliance with the permit limit. 

4 Except for periods of macroinvertebrate control when oxidant addition is required (see Permit - Part Ill), samples shall be taken once at the beginning of the 

of chlorination for one unit and once every 15 minutes thereafter. At the end of the period of chlorination, one sample shall be taken. Sampling for these oxidants 

is not required when there is no chlorine/bromine added during that day. 

5 Application of a oxidant (bromine/chlorine) beyond the 120 minutes per day will be allowed to facilitate nuisance macroinvertebrate control according to the 

for such activities described in Permit - Part Ili. 

6 See Part Ill for methodology. Toxicity tests shall be performaed only if biocides are added to the cooling water. 

PERMIT LIMITS 

OUTFALL 004 

Intake Screen Backwash Water 

No numerical limitations or monitoring requirements. The discharge shall not have a visible oil sheen and the permitee 

hll kblhf illld hhiiih
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-30 of R-43 

APPENDIX 3 (CONTINUED) 

PREVIOUS PERMIT LIMITS AND MONITORING REQUIREMENTS 

PERMIT LIMITS I 

INTERNAL MONITORING POINT 005 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. ANNT. MAX. CONC. MAX. ANENT. MSRMNT. 

FRQNCY. 

SAMPLE 

(mg/I) (]b/day) TYPE (mWI) (]b/day) 

FLOW Report (MGD) * Report (MGD) * 1/Batch Estimate* 

IRON, TOTAL 1.0 -- 1.0 -- 

*. Grab 

COPPER,TOTAL 1.0 -- 1.0 -- ** Grab 

Flow shall be reported in Million Gallons per Day (MGD), and shall be estimated based on elevation change. 

Samples shall be taken at the beginning and end of a discharge event for each batch treated. 
0.0 

5/2/2005 

30 

25 . 

20 

15 ---

10 

S/2/2006 5/2/2007 5(2/2008 5/2/2009 

Oil & Grease, mgIL 

OUTFALL 001 - - 2005 - 09 

10.0 

9.0 

8.0 

7.0 

6.0 

5.0 

4..0 

0 

2.0 

1.0 

-4—T5S 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-31 of R-43 

APPENDIX 4 

HISTORICAL MONITORING AND INSPECTION 
Oil and Grease, mg/I 

0.4 

0.35 

0.3 

0.25 — 

0.2 

0.15 

0.1 

0.05 

0 

10.0 

9.0 

8.0 

7.0 

6.0 

5. 

4.0 

3.0 

2.0 

1.0 

0.0 

5/2/2005 

Grease— 

5/2/2006 5/2/2007 5/2/2008 5/2/2009 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-32 of R-43 

APPENDIX 4 

HISTORICAL MONITORING AND INSPECTION 

OUTFALL 001 - - 2005 - 09 
0.03 

0.025 

0.04 

- Se 

0.035 

1\ t v I 

t, 

--Ak 

4 

A ft, 

v 

1 t., 

I t, 

,0 *, 

0.02 

0.01 

0.005 

0 

Hg 

Ph 

Cu 

Cr 

- Cd 

TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-33 of R-43 

APPENDIX 4 

HISTORICAL MONITORING AND INSPECTION 

OUTFALL 001 - - 2005 - 09 

eeee e eegeeeee ,Yry eeee cF3 41, $1. 

ti0 0 0 0 0„I:, 1N, t,,,,, 

Various Metals 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-34 of R-43 

APPENDIX 5a 

PROCEDURES FOR DETERMINING WATER QUALITY BASED 

EFFLUENT LIMITS 

The following formulas are used to evaluate water quality protection: 

Cm = 0sCs + QwCw 

Qs + Qw 

where: 

Cm = resulting in-stream concentration after mixing 

Cw = concentration of pollutant in wastewater 

Cs ,- stream background concentration 

Ow = wastewater flow 

Qs = stream low flow 

to protect water quality: 

Cw 5 ja,) [Cm (Qs + Ow) - QsCs1 

Qw 

where (SA) is the percent "Stream Allocation". 

Calculations for this permit have been done using a standardized worksheet, titled 

"Water Quality Based Effluent Calculations." 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 

7010 - Low flow under natural conditions 

1010 - Regulated low flow conditions 

Other than Fish and Aquatic Life Protection 

3002 - 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/I and Total Suspended Solids (TSS) of 10 mg/I unless STORET or 

WtSlitkdtbttitdifft lMiid iliitth
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-35 of R-43 

APPENDIX 5a (Continued) 

concentration is used in lieu of the chronic "In-stream 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 industrial 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" 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 fourteen (14) 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 Life Water Quality criteria. For Cadmium, 

Copper, Lead, Nickel, and Zinc, this value represents the criteria for the 

dissolved form at laboratory conditions. The Criteria Continuous Concentration 

(CCC) is calculated using the equation: 

CCC = (exp me[ In (stream hardness) ] bc}) (CCF) 

CCF = Chronic Conversion Factor 

Column 3: 

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-B-96-007, June 1996). Values for other metals are 

in the total form and are not hardness dependent; no chronic criteria exists for 

silver. Published criteria are used for non-metal parameters. 

The "Acute" Fish and Aquatic Life Water Quality criteria. For Cadmium, Copper, 

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: 

CMC = (exp mA [ In (stream hardness) ] + bA }) (ACF) 

ACF = Acute Conversion Factor 

This equation and the appropriate coefficients for each metal are from 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-36 of R-43 

APPENDIX 5a (Continued) 

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-B-96-007, June 

1996) and the equation: 

Cdiss 1 

Ctotal 1 + [Kim] [ss 1+a)] [10-6] 

ss = in-stream suspended solids concentration [mg/I] 

Linear partition coefficients for streams are used for unregulated (7010) 

receiving waters, and linear partition coefficients for lakes are used for regulated 

(1010) 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 Life 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: 

Column 8: 

Column 9: 

The "Chronic" Calculated Effluent Concentration for the protection of fish and 

aquatic life. This is the chronic limit. 

The "Acute" Calculated Effluent Concentration for the protection of fish and 

aquatic life. This is the acute limit. 

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 

itd ith thtlifitif DtiWtSl
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-37 of R-43 

APPENDIX 5a (Continued) 

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. 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-38 of R-43 

APPENDIX 5b 

Determining Ash Pond Free Water Volume 

Tennessee Valley Authority - Bull Run Fossil Plant 

Ash Pond Required Free Volume Calculations 

Dry Weather Volume 

Source [MGDI 

Wet Weather Volume 

Boiler Bay Bilge Sump 1.643 Ash ponds & metal waste treatment ponds 55 acres 

Hydroveyers (ash collection) 3.1900 Coal Yard Drainage Basin 140.5 acres 

MCW Treatment Pond 0.0052 

Stack Yard Sump 11460 Total drainage area providing runoff 195.5 acres 

Ash Collection Tanks 9.5520 to the ash pond (includes ash pond) 

Coal Yard Drainage Basin Surrp 1.1660 

Ash Sluice Line Low Point Sump 0.0565 10 year - 24 hour storm event 5.1 inches 

Main Station Sump 1.1240 

Unw ater Sump 0.0142 Wet Weather Volume 27,072,300 gallons 

FGD Detention Sump 0.0270 

Rim Ditch Discharge 0.7300 Dry Weather Volume 19,153,900 gallons 

Precipitation 0.5000 

Total Required Volume 46,226,200 gallons 

Total - Dry Weather Volume 19.1539 

* Not used in calculations since metal cleaning wastes and 

ash transport water do not normally occur simultaneously. 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-39 of R-43 

APPENDIX 5c 

Water Quality Based Effluent Calculations 

FACILITY: 

PERMIT #: 

TVA - Bull Run Fossil Plant 

TN0005410 

Stream 

(1Q10) 

Stream 

(30Q5) 

Waste 

Flow 

T1I. Susp. 

Solids 

Hardness 

(as CaCO3) 

Stream 

Allocation 

IMOD] [MOD] [MOD] [mg/1] [mg/1] IN 

129.300 424.600 19.037 10 145 90 

1 2 3 4 5 [ 6 I 7 8 

Stream 

Bckgrnd. 

Com.- 

Fish/Aqua. Lite 

Water Quality Criteria 

Effluent 

Fraction 

Dissolved 

Fish & Aquatic Life Water Quality Criteria (1010) 

In-Stream Allowable Calc. Effluent Concentration 

EFFLUENT 

CHARACTERISTIC 

Chronic Acute Chronic Acute Chronic Acute 

[ug/1] [ug/11 [ug/I] [Fraction] [ug/I] ILIgill lug/I] [ug/I] 

Arsenic 2.50 150 340 1.000 150.00 340.00 1036.6 2369.1 

Cadmium * 2.50 1.357 5.537 0.193 7.04 28.72 34.1 186.2 

Copper* 3.00 15.59 24.15 0.218 71.54 110.80 483.3 758.7 

Lead * 1.60 3.76 96.55 0.143 26.22 672.87 174.1 4708.9 

Silver * 2.50 NA 6.537 0.850 NA 7.69 NA 38.6 

Nickel * 13.00 215.25 1938.20 0.206 1046.14 9419.74 7256.9 65979.6 

Mercury, (T) *** 0.10 0.700 1.400 1.000 R 0.700 1.400 4.30 9.2 

Chromium (T)**** 0.50 74.00 570.00 1.000 74.000 570.000 515.9 3994.3 

Selenium ""*"" 0.50 5.00 20.00 1.000 5.000 20.000 32.0 137.2 

The Fish & Aquatic Life 

and calculated effluent 

In cases where the 

than toxicity. 

9 10 11 12 I 13 74 

Human Health Wate Quality Criteria (3005) 

In-Stream Criteria Cale. Effluent Concentration 

EFFLUENT 

CHARACTERISTIC 

Organisms Voter/Organism DWS Organisms Vater/Organis m: DWS 

Iug/11 [ugll] [41] [ug/I] [ug/I] [ug/1] 

Arsenic 10.0 10.0 10.0 46.3 159.6 159.6 

Cadmium * NA NA 5.0 NA NA 54.7 

Copper* NA WA NA NA NA NA 

Lead * NA NA 5.0 NA NA 72.8 

Silver * NA NA 100.0 NA NA 2047.2 

Nickel * 4600.0 610.0 100.0 96217.3 12532.9 1836.4 

Mercury, (T) *** 0.051 0.05 2.0 -0.938 -0.959 39.9 

Chromium (T)*"" NA NA 100.0 NA NA 2087.3 

Selenium NA NA 5.0 NA NA 104.9 

* Denotes metals for which Fish & Aquatic Life Criteria are expressed as a function of total hardness. 

criteria for this metal are in the dissolved form at laboratory conditions. The in-stream allowable criteria 

concentrations are in the total recoverable form. 

11,1e Stream background concentrations are taken from Outfall 002 intake sample on the permit application. 

background concentration was reported as less than a value, one half of the value was used. 

The chronic criterion for mercury is not converted to dissolved, since it is based on fish tissue data rather 

"""* Th

itifthitithttl blf
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-40 of R-43 

APPENDIX 5d 

Comparison of Effluent Limits 

COMPARISON 

DETERMINATION OF 

TVA- Bull 

OF APPLICABLE 

MONITORING 

Run Fossil 

Outfall 001 

EFFLUENT 

REQUIREMENTS BY 

LIMITATIONS 

Plant 

RDL * 

' DMR Summary** Application Sample Tennessee 

Rules 

Water 

Long Term Quality*** 

Average 

Daily 

Maximum 

Daily 

EFFLUENT Maximum 

CHARACTERISTIC [mg/I] [mg/I] [mg/I] [INA] [mg/1] [mg/I] 

Cadmium (T) 0.001 0.0004 0.0005 0.0007 0.002 0.06 

Chromium (T) 0.001 0.002 0.004 0.0015 0.57 2.09 

Copper (T) 0.001 0.0044 0.0057 0.0050 0.013 0.758 

Iron (T) -- 0.25 0.34 0.200 

Lead (T) 0.001 0.0010 0.0020 0.0020 0.065 0.07 

Manganese (T) -- 0.046 0.078 0.060 NA 

Mercury, (T) 0.0002 0.002 0.002 <0.0002 0.00005 -0.0009 

Silver (T) 0.001 0.0004 0.0010 <0.0005 0.003 0.038 

Nickel 0.01 0.0085 0.47 1.836 

Arsenic 0.001 0.011 0.34 0.16 

Selenium (T) 0.002 0.0120 0.0280 0.015 0.02 0.1050 

* Required Detection Level per State of Tennessee Rule 1200-4-3-.05(8) 

** Data reported 2005 - 09. 

*** Most stringent applicable water quality based limit. 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-41 of R-43 

APPENDIX 6 

New Permit Limits 

OUTFALL 001 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT AVG. CONC. AVG. AMNT. MAX CONC. MAX. AMNI MS RMNT. SAMPLE 

CHARACTERISTIC (mg/1) (lb/day) (mg.fl) (lb/day) FRQ NCY. TYPE 

FLOW Report (MGD)* Report (MGD) * 1/Week Instantaneous 

pH — Range 6.0 - 9.0 1/VVeek Grab 

OIL & GREASE 12.0 -- 16.0 -- 1/Month Grab 

TOTAL SUSPENDED SOLIDS (TSS) 26.0 -- 84.0 -- 1/Month Grab 

NITROGEN, AMMONIA TOTAL (Plant 

Intake) 

. -- Report Report 1/Month Grab 

NITROGEN, AMMONIA TOTAL -- -- Report Report 1/Month Grab 

NITROGEN, AMMONIA TOTAL (Net 

Discharge) -- -- Report **** Report 1/Month Calculated 

ARSENIC, TOTAL -- -- Report -- 1/Month Grab 

CADMIUM, TOTAL -- -- Report -- 1/Month Grab 

COPPER,TOTAL -- -- Report -- 1/Month Grab 

LEAD, TOTAL -- -- Report -- 1/Month Grab 

MERCURY, TOTAL -- -- Report -- 1/Month Grab 

NICKEL, TOTAL — -- Report — 1/Month Grab 

SELENIUM, TOTAL -- -- Report -- 1/Month Grab 

THALLIUM, TOTAL -- -- Report -- 1/Month Grab 

ZINC, TOTAL -- -- Report -- 1/Month Grab 

IRON, TOTAL -- -- Report -- 1/Month Grab 

SILVER, TOTAL -- -- Report -- 1/Year Grab 

IC25 Survival, Reproduction, & Growth in 100% Effluent Annually Grab*** 

Note: The permittee shall take reasonable steps to prevent discharge of cenospheres other than in trace amounts from the outf 

* Flow shall be reported in Million Gallons per Day (MGD). 

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

*** See Part III for methodology. 

**** If a calculated value for net addition of ammonia as nitrogen exceeds an action concentration value of 1.0 mg/L, the 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-42 of R-43 

APPENDIX 6b 

New Permit Limits 

[CONTINUED) 

PERMIT LIMITS 

OUTFALL 002 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. AM NT. MAX CONC. MAX AM NT. MSPNI NT. 

FRONCY. 

SAMPLE 

(n41 TYPE ) Ob/day) (mgII) (Ibiday) 

FLOW Report (MGD) Report (MGD) 1 / Day Estimate 1 

TEMPERATURE, Intake Report -- Report -- 1 /Day Grab 

TEMPERATURE, Effluent -- 31.1°C (88°F) 1 /Day Calculated 2 

TOTAL RESIDUAL OXIDANT 

(reported as chlorine) 3 

0.011 -- 0.019 -- 1 / Week 4 Grab 

In take temperature is measured hourly and reported 

discharge temperature shall be c alculated to r th ec 

— unit load, and th e 24-hour average llowthrough Outfall 

Ie2b 

as the average of the hourly measurements 

poling c hannel based on the 24-hour average 

OP. 

I Survival, Reproduction, & 

for each day. The 

intake temperature 

urowth in 11)0% 

daily maximum 

24-hour av erage 1 / Day Log Records 

ettruent Once 6 Composite 6 

1 Flow shall be estimated from pump logs and reported in Million Gallons per Day (MOD). 

; Except for pea ods of rnacrol nvertebrate c ontrol when orddant addition Is required (see Permit - Part III), s ampless hall be taken once at the 

beginning of the period of chlorination for one unit and once every lb minutes thereafter. At the end of th e period of chlorination, a nesarnple shall 

be taken. Sampling for these oAdants is not required when there is no c h lori ne/bromine added during th al day. 

, Application of a oxidant (brombek Hoene) beyond th e 120 minutes perday will be allowed to faciftatenuisance mac roinvertebrate contr ol 

ac co Wino to the Plan for such acliviti es described n Permit - Part III. The acceptable methods for analysis of TR 

are any mernous specmeu in Cu urm, ran I JO. Ine memou uetecuon ievei sur 1114-• snail net exceec u.uo mgr I unless the permittee demonstrates that its 

is higher. The permittee shall retain the documentation that justifies the higher MDL, and shall have that documentation available for review upon request. In cas 

where the permit limit is less than the MDL, the reporting of -FRC at less than the MDL shall be interpreted to constitute compliance with the permit limit. 

4 

5 

6 See Part Ill for methodology. Toxicity tests shall be performaecl only if biocides are added to the cooling water. 

OUTFALL 004 

Intake Screen Backwash Water 

No numerical limitations or monitoring requirements. The discharge shall not have a visible oil sheen and the permitee 
TVA-Bull Run Fossil Plant (Rationale) 

NPDES Permit TN0005410 

Page R-43 of R-43 

APPENDIX 6c 

New Permit Limits 

(Continued) 

PERMIT LIMITS 

INTERNAL MONITORING POINT 005 

EFFLUENT LIMITATIONS MONITORING 

MONTHLY DAILY REQUIREMENTS 

EFFLUENT 

CHARACTERISTIC 

AVG. CONC. AVG. ANENT. EMAX. CONC. MAK AMNT. MS RNENT. 

FRQNC Y. 

SAMPLE 

(Flgn) (lb/day) (mg/l) (lb/day) TYPE 

FLOW Report (MGD) * Report (MGD) * 1/Batch Estimate* 

IRON, TOTAL 1.0 -- 1.0 -- 

.. Grab 

COPPER,TOTAL 1.0 -- 1.0 -- 

** Grab 

Flow shall be reported in Million Gallons per Day (MGD), and shall be estimated based on elevation change. 

The permittee will be required to monitor discharges through IMP005 only when metal cleaning operations or other process 

wastewater generating activities occur.