NC0027341_Draft Permit Comments_20180605

TVA
Tennessee Valley Authority, 1101 Market Street,BR4A,Chattanooga,Tennessee 37402
May 31, 2018
Mr. Derek Denard RECEIVE®1®ERI®WR
Environmental Specialist ��� ® 5 2018
North Carolina Department of Environmental Quality
Division of Water Resources Water Resources
Compliance and Expedited Permitting Unit permitting Section
1617 Mail Service Center
Raleigh, North Carolina 27699-01617
Dear Mr. Denard:
TENNESSEE VALLEY AUTHORITY (WA) - FONTANA HYDRO (FNH) - NPDES PERMIT
NO. NC0027341 - DRAFT RENEWAL PERMIT COMMENTS
TVA has reviewed the draft permit public notice dated May 2, 2018, and we offer the following
comments to the Division for consideration:
1. For Outfalls 001, 002, and 006, on pages 3, 4, and 6 respectively, TVA suggests
updating the first part of Footnote 5 to read: "In lieu of monitoring and reporting pH and
O&G".
2. For Outfalls 003, 004 &005, on page 5, WA requests removal of pH monitoring. FNH
does not implement any chemical treatment of cooling water and WA does not believe
the once-thru cooling process alters the pH from ambient river conditions.
3. Under Section A.(6.), TVA requests the ability to submit a copy of signed original
DMRs. TVA will also be submitting DMRs electronically which requires the signatory
official certify the DMR electronically. As a result, WA believes submitting a copy of a
signed original DMR is acceptable.
4. TVA submits DMRs to the Division on a quarterly basis and believes the first paragraph
on page 8 under Section A.(6.) in the draft permit should be updated to indicate the first
DMR is due on the last day of the month following the quarterly period in which the
renewal permit is issued.
5. TVA requests a 30-day period between the issuance date and the effective date of the
reissued permit to allow adequate time for internal distribution and implementation of
permit changes.
If you have questions or need additional information, please contact Brad Love at
[phone] or by email at [e-mail].
Sincerely,
Terry Cheek
Senior Manager
Water Permits, Compliance, and Monitoring