Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 1

National Pollutant Discharge Elimination System (NPDES) Permit P rogram



### F A C T S H E E T

Regarding an NPDES Permit To Discharge to Waters of the State of Ohi o for the FirstEnergy Generation Corp. - Bayshore Station

Public Notice No.: 10-03-034 OEPA Permit No.: 2IB00000*RD Public Notice Date: March 15, 2010 Application No.: (OH #) OH0002925 Comment Period Ends: April 15, 2010

Name and Address of Facility Where Name and Address of Applicant: Discharge Occurs:

First Energy FirstEnergy Generation Corp. - Bayshore Station 76 South Main Street 4701 Bayshore Road Akron, Ohio 44308 Oregon, Ohio 43616 Lucas County

Receiving Water: Driftmeyer Ditch Subsequent

Maumee Bay Stream Network: Lake Erie



### Introduction

Development of a Fact Sheet for NPDES permits is required by Title 40 of the Co de of Federal Regulations, Section 124.8 and 124.56. This document fulfills the requirements established in those regulations by providing the information necessary to inform the public of actions proposed by t he Ohio Environmental Protection Agency, as well as the methods by which the public can participat e in the process of finalizing

those actions.

This Fact Sheet is prepared in order to document the technical basis and risk management decisions that are considered in the determination of water quality based NPDES Permit eff luent limitations. The technical basis for the Fact Sheet may consist of evaluations of promulgated effl uent guidelines and other treatmenttechnology based standards, existing effluent quality, instream biological, chemical and physical conditions, and the allocations of pollutants to meet Ohio Water Quality Standards . This Fact Sheet details the discretionary decision-making process empowered to the director by the Clea n Water Act and Ohio Water Pollution Control Law (ORC 6111). Decisions to award variances to Water Qua lity Standards or promulgated effluent guidelines for economic or technological reasons w ill also be justified in the Fact Sheet where necessary.

Effluent limits based on available treatment technologies are require d by Section 301(b) of the Clean Water Act. Many of these have already been established by U.S. EPA in the effluen t guideline regulations (a.k.a. categorical regulations) for industry categories in 40 CFR Parts 405-499. T echnology-based regulations for publicly-owned treatment works are listed in the Secondary Treatment Re gulations (40 CFR Part 133). If regulations have not been established for a category of dischargers, th e director may establish technologybased limits based on best professional judgment (BPJ).Page 2 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010

Ohio EPA reviews the need for water-quality-based limits on a pollutant-by-pol lutant basis. Wasteload allocations are used to develop these limits based on the pollutants that have been detected in the discharge, and the receiving water’s assimilative capacity. The assimilati ve capacity depends on the flow in the water receiving the discharge, and the concentration of the pollutant upstream . The greater the upstream flow, and the lower the upstream concentration, the greater the assimilative capacity is. Assimilative capacity may represent dilution (as in allocations for metals), or it may also incorpora te the break-down of pollutants in the receiving water (as in allocations for oxygen-demanding materials)

.

The need for water-quality-based limits is determined by comparing the was teload allocation for a pollutant to a measure of the effluent quality. The measure of effluent quality is c alled PEQ - Projected Effluent Quality. This is a statistical measure of the average and maximu m effluent values for a pollutant. As with any statistical method, the more data that exists for a given pollutant, t he more likely that PEQ will match the actual observed data. If there is a small data set for a given pollutant, the highest measured value is multiplied by a statistical factor to obtain a PEQ; for example if only one sample exists, the factor is 6.2, for two samples - 3.8, for three samples - 3.0. The factors continue to decline as samples sizes increase. These factors are intended to account for effluent variability, but if the polluta nt concentrations are fairly constant, these factors may make PEQ appear larger than it would be shown to be if more sample results existed.



### Summary of Proposed Permit Conditions

Monitoring requirements for water temperature, total residual oxidant s (TRO), flow rate, total residual chlorine (TRC), and chlorination/bromination duration is proposed to continue a t outfall 001. In addition, limits for TRO, TRC, and chlorination/bromination duration are also proposed t o remain in the permit. Monitoring requirements for copper have been added, and monitoring for silver and zinc has been removed.

At outfall 002, monitoring requirements for total suspended solids (TSS), fl ow rate, and pH as well as limits for pH are proposed to continue from the existing permit.

For outfall 003, monitoring requirements are proposed to continue from the existing permit for TSS, oil and grease, selenium, thallium, silver, zinc, lead, copper, flow rate, mercury , aluminum, and pH. Limits are proposed to continue for TSS, oil and grease, and pH. Monitoring for barium and cadmi um has been added to the draft permit. Based upon an application submitted by First Energy, the permit includes a variancebased limit for mercury at outfall 003 for the average criterion. In addi tion, annual toxicity testing and beryllium monitoring have been removed from the permit for this outfall. Par ts IV, V, and VI have been included with the permit to address stormwater issues at the facility

.

This permit renewal is proposed for a term of approximately four and one-half years , expiring on January 31, 2015 . This schedule will allow the Bayshore Station permit to be on a simila r schedule with the other

facilities within the same watershed basin.Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 3 

### Table of Contents

Introduction .......................................................................................................................................... Page 1

Summary of Proposed Permit Conditions ..................................................................................................... 2

Table of Contents .......................................................................................................................................... 3

Procedures for Participation in the Formulation of Final Determinati ons .................................................... 5

Location of Discharge/Receiving Water Use Classification ......................................................................... 6

Facility Description ....................................................................................................................................... 7

Discharges from the Bayshore Station .......................................................................................................... 7

Assessment of Impact on Receiving Waters ................................................................................................. 9

Impingement and Entrainment .................................................................................................................... 10

Development of Water Quality-Based Effluent Limits .............................................................................. 11

Parameter Selection ...........................

................................................... ................................................... ................ 11

Wasteload Allocation ..........................

................................................... ................................................... .............. 12 Dissolved Metal Translator for Copper .........

................................................... ................................................... .... 12

Reasonable Potential ..........................

................................................... ................................................... ................ 12 Whole Effluent Toxicity WLA ...................

................................................... ................................................... ....... 13

Effluent Limits / Hazard Management Decisions ....................................................................................... 13

Impingement/Entrainment Reductions ....................................................................................................... 16

Whole Effluent Toxicity Reasonable Potential ........................................................................................... 16

List of Figures

Figure 1. Location of the Bayshore Station. .......................................................................................... 6

Figure 2. Wastewater Flow Diagram ..................................................................................................... 8

Figure 3. Western Basin of Lake Erie Water Quality Assessment (2010 I ntegrated Report) ............. 10

Figure 4. Temperature: Intake vs. Outfall 001 (2007 – 2009) ............................................................. 11Page 4 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 

### Table of Contents (continued)

List of Tables

Table 1. Description of Bayshore Station Outfalls .................................................................................. 7

Table 2. Flows for Outfalls 001 and 003 ................................................................................................. 9

Table 3. Concentration of Chemicals Found in Effluent and Intake ..................................................... 17

Table 4. Effluent Characterization and Decision Criteria: Januar y 2006 – November 2009 ................ 19

Table 5. Effluent Data for Bayshore Power Plant ................................................................................. 22

Table 6. Water Quality Criteria in the Study Area ................................................................................ 23

Table 7. Instream Conditions and Discharger Flow .............................................................................. 24

Table 8. Summary of Effluent Limits to Maintain Applicable Water Quality Criteria ......................... 26

Table 9-xxx. Parameter Assessment

Table 9-001. for Outfall 001 ........................................................................................ 27

Table 9-003. for Outfall 003 ........................................................................................ 28

Table 10-xxx. Final Effluent Limits and Monitoring Requirements

Table 10-001. ...for Outfall 001 ............................................................................... 29

Table 10-002. ...for Outfall 002 ............................................................................... 29

Table 10-003. ...for Outfall 003 ............................................................................... 30

Attachment A. Federal Effluent Guidelines Applicable to the Bayshore Sta tion ...................................... 31Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 5



### Procedures for Participation in the Formulation of Final Determinat ions

The draft action shall be issued as a final action unless the Director re vises the draft after consideration of the record of a public meeting or written comments, or upon disapproval by the Administ rator of the U.S. Environmental Protection Agency.

Within thirty days of the date of the Public Notice, any person may request or petition for a public meeting for presentation of evidence, statements or opinions. The purpose of the public m eeting is to obtain additional evidence. Statements concerning the issues raised by the part y requesting the meeting are invited. Evidence may be presented by the applicant, the state, and other parties, and f ollowing presentation of such evidence other interested persons may present testimony of facts or s tatements of opinion.

Requests for public meetings shall be in writing and shall state the acti on of the Director objected to, the questions to be considered, and the reasons the action is contested. Such request s should be addressed to:

Legal Records Section Ohio Environmental Protection Agency

Lazarus Government Center

P.O. Box 1049 Columbus, Ohio 43216-1049

Interested persons are invited to submit written comments upon the discharg e permit. Comments should be submitted in person or by mail no later than 30 days after the date of this Publi c Notice. Deliver or mail all

comments to:

Ohio Environmental Protection Agency

Attention: Division of Surface Water Permits and Compliance Section

Lazarus Government Center

P.O. Box 1049 Columbus, Ohio 43216-1049

The OEPA permit number and Public Notice numbers should appear on each page of any subm itted comments. All comments received no later than 30 days after the date of the P ublic Notice will be

considered.

Citizens may conduct file reviews regarding specific companies or si tes. Appointments are necessary to conduct file reviews because requests to review files have increased dr amatically in recent years. The first 250 pages copied are free. For requests to copy more than 250 pages, there is a five -cent charge for each page copied. Payment is required by check or money order, made payable to Treasurer State of Ohio.

For additional information about this fact sheet or the draft permi t, contact Naajy Abdullah [phone: (419)
373-3017; email: 

### naajy.abdullah@epa.state.oh.us ] in Ohio EPA’s Northwest District Office or Mike McCullough [phone: (614) 644-4824; email: 

### mike.mccullough@epa.state.oh.us ] in Ohio EPA’s Central

Office.Page 6 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010



### Location of Discharge/Receiving Water Use Classification

The FirstEnergy Generation Corporation Bayshore Station (or the Bayshor e Station) discharges directly to Maumee Bay through outfalls 001 and 003. Outfall 002 discharges into Driftmeyer Di tch which flows into Maumee Bay. Maumee Bay flows into Lake Erie. The approximate location o f the Bayshore Station is shown in the center of Figure 1.

This segment of Maumee Bay is described by Ohio EPA River Code: 24-100; USEPA R iver Reach #: NA; County: Lucas; Ecoregion: Huron-Erie Lake Plain (HELP). The Maumee Ba y is presently designated for the following uses: exceptional warmwater habitat (EWH), state resour ce water (SRW), agricultural water supply, public water supply, industrial water supply, and bathing waters.

Use designations define the goals and expectations for a waterbody. These goa ls are set for aquatic life protection, recreation use and water supply use, and are defined in the Ohio Wate r Quality Standards, or the Ohio Administrative Code (OAC 3745-1-07). The use designations for individual waterbodies are listed in rules -08 through -32 of the OAC. Once the goals are set, numeric water quality standa rds are developed to protect these uses; higher quality uses typically have more protectiv e water quality criteria.

Use designations for aquatic life protection include habitats for co ldwater fish and macroinvertebrates, warmwater aquatic life and waters with exceptional communities of warmwater organisms. These uses all meet the goals of the federal Clean Water Act. Ohio Water Quality Sta ndards (WQS) also include aquatic Figure 1. Location of Bayshore StationFactsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 7

life use designations for waterbodies which can not meet the Clean Water A ct goals because of humancaused conditions that can not be remedied without causing fundamental chang es to land use and widespread economic impact. The dredging and clearing of some small streams to support agricultural or urban drainage is the most common of these conditions. These streams are given Modified Warmwa ter or Limited Resource Water designations.

Recreation uses are defined by the depth of the waterbody and the potential f or wading or swimming. Uses are defined for bathing waters, swimming/canoeing (Primary Contact) and w ading only (Secondary Contact - generally waters too shallow for swimming or canoeing). Water supply uses are defined by the actual or potential use of the waterbody. Public Water Supply designations apply near existing water intakes so that

waters are safe to drink with standard treatment. Most other waters are de signated for agricultural and industrial water supply.



### Facility Description

The Bayshore Station is a coal-fired steam-electric generating sta tion, owned by the First Energy Generation Corporation. This facility is involved in the generation, transmission, and distribution of electric power. The daily production rate is approximately 620 megawatts of electricity.

The Bayshore Station’s processes generate wastewaters which are re gulated by the federal effluent guidelines (FEGs) listed in 40 CRF Part 423, Steam Electric Power Genera ting Point Source Category. The process operations at this facility are also defined by the standard indus trial classification (SIC) category

4911 - Electric Services.



### Discharges from the Bayshore Station

Outfall 001 discharges directly to Lake Erie at the rate of approxim ately 679 million gallons per day (MGD). The wastewater flowing from this outfall consists primarily of the onc e-through condenser cooling water. Some stormwater also is discharged through this outfall. (See Table 1.)

Table 1. Description of Bayshore Station Outfalls

Outfall

# Type of Wastewater Treatment System Used Discharge

Point Ave. Discharge

(in MGD)*

001 Condenser cooling water discharge, stormwater none Maumee Bay 679

002 Fly ash sluice, coal pile runoff - Sedimentation

- Neutralization Driftmeyer

Ditch 0.095

003 Bottom ash sluice, boiler blowdown, metal cleaning, demineralization regeneration - Sedimentation

- Neutralization

- Slow sand filtration Maumee Bay 1.43

*Flow rates are based upon the NPDES permit renewal application.Page 8 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010

Outfall 002 is designed to discharge wastewater from a fly ash pond into Driftmeyer Ditch which

flows less than a mile before emptying into Maumee Bay. The wastewater from the pond includes fly ash sluice and runoff from a coal pile. Previous to March 2008,

this outfall has not discharged any

wastewater for several years. However, more than 130 discharges were reported from March through June of 2008.

Wastewater flowing into a bottom ash pond consists of bottom ash sluice, boiler blowdown, metal cleaning agents, and wash water resulting from regenerating ion exchange media used in purifying

boiler water. Since acids

are used in the metal cleaning process and in regenerating the ion exchange media, the

wastewater from these processes is neutralized

before it is sent to the bottom ash pond. The wastewater in the bottom ash pond is treated by settling and neut ralization. The sanitary wastewaters from the plant are discharged to a local publicly- operated treatment works (POTW).

The Bayshore Station obtains the majority of its water from an intake i n Maumee Bay (approximately 749 MGD). This water is used for various purposes including once-through cooling w ater, and sluice water for transporting the bottom ash from the boilers to the ash ponds. The City of Oreg on provides potable water for the Bayshore Station for the sanitary system and to replenish boiler water. (See Figure 2 for a schematic of the wastewater flow and treatment systems at the Bayshore Station.)

The wastewater discharge flow rates during the past five years for outf alls 001 and 003 are shown in Table 2 on the following page. Reported flow rates for outfall 001 have remained consta nt throughout the most recent four-year period. In addition, the 50 th and 95 th percentile discharge amounts from outfall 003 have been relatively consistent, however, the maximum flows appear to have decre ased somewhat for this outfall within the last two to three years. Figure 2. Wastewater Flow DiagramFactsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 9

From January 2006 through November 2009, the Bayshore Station has reported only three sample results which were numeric violations of permit limits. At outfall 003, limits fo r total suspended solids were exceeded twice, and the pH maximum limit was exceeded one time.



### Assessment of Impact on Receiving

Waters

Recent biological data for Lake Erie is not available to assess the water quality impact of permitted discharges from the Bayshore Station. Figure 3 on page 10 shows the assessment of water quality based upon information in the draft

version of Ohio EPA’s 2010 Integrated Report

.

The impacts of the thermal discharge from the Bayshore Station have been

somewhat controversial for a number of years. Concerns have been expressed regarding the size of the thermal plume, and its impact on recreational activities in Maumee Bay. Ohio EPA conducted an assessment of these iss ues in 2004, and developed a document entitled, “Thermal Discharge from the Toledo Edison Bayshore Power P lant: An Update” which discussed the assessment. (Contact Ohio EPA for a copy of this document.) In summa ry, the assessment concluded the following:

• The Bayshore Station discharge does exceed water quality standards for t emperature within the thermal plume near the facility, however, the facility’s impacts on a quatic life and designated uses of Maumee Bay do not justify restricting the size of the thermal mixing zone a t this time.

• Depending upon wind patterns and other factors, the thermal plume sometimes exte nds to the south shore of Maumee Bay and/or more than a mile beyond the end of the Confined Disposal Faci lity (CDF).

• The thermal discharge restricts recreational activities in ce rtain areas of the Bay.

The pattern of discharge temperatures at outfall 001 has remained consis tent during the past four years. (See Figure 4 on page 11.) However, the reported temperature values seem to have dec reased slightly in 2009 in conjunction with somewhat lower generated power and water usage at the fac ility. Both the 50 th and 95 th
percentile temperature values decreased during both summer and winter mont hs, with a maximum summer discharge temperature of 94.1o F. The reported temperatures at the i ntake station for Bayshore also decreased slightly in 2009. Consistent with the 2005 through 2008 time period, the temper ature at outfall 001 remains approximately 9 to 10o F higher than the intake temperature.

Ohio EPA has also had concerns that the heated effluent from the Bayshore Sta tion may be causing (or contributing to) “... undesirable aquatic life or result in a dominance of nuisance species...” w ithin the mixing zone of the cooling water discharge. (See rule 3745-2-08 of the Ohio Administr ative Code.) In order to address this concern, the existing NPDES permit required First Energ y to conduct a two-year survey of the benthic community within the thermal mixing zone, and determine the types and di stribution of benthic macroinvertebrates and plants. The final report shows that the density of som e species (e.g., Asiatic clams) is higher near the discharge, while the density for some species (zebra and quagga mussels) is lower. Even Table 2. Flows for Outfalls 001 and 003

Year Flow in MGD

50 th Percentile 95 th Percentile Maximum Outfall 001

2006 745.9 745.9 745.9

2007 745.9 745.9 745.9

2008 745.9 745.9 745.9

2009 653.7 745.9 745.9

Overall 745.9 745.9 745.9 Outfall 003

2006 1.2 2.065 5.3

2007 1.1 2.0 3.1

2008 1.2 1.8 2.3

2009 1.25 2.02 2.27

Overall 1.2 1.99 5.3Page 10 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010

though there are some concerns regarding this study,

Ohio EPA believes that the

available evidence does not support restricting the size of the thermal mixing zone at this

time.



### Impingement and

Entrainment

In order to fulfill requirements under federal regulations adopted in 2004 associated with large, existing power plants 1 , the Bayshore Station conducted sampling in 2005 and 2006 at their cooling water intake structure (CWIS) to

determine the number of fish impinged on the screens and entrained through the facility. Based upon this study, First Energy estimated annual impingement to be more than 46 million fish, with the majority of the fish identified as emerald shiner and gizzard

shad. The annual estimates for

entrainment were approximately: 209 million fish eggs; 2,247 million fish larvae; and 14 million juvenile fish. In order to put these impingement/entrainment (I&E) estimates into persepctive, it is likely that the Bayshore Station impinges and

entrains more fish than all the other power plants in Ohio combined. Finally, the Bayshore Station does not currently employ any technologies t hat are typically considered effective for reducing impingement and entrainment mortality.

1 These regulations, which were adopted to implement Section 316(b) of the Clean Water Act, were suspen ded by U.S. EPA in 2007 after a federal court overturned signif icant provisions. States have been directed by U.S . EPA to use best professional judgement (BPJ) to implement the requi rements of Section 316(b) in the absence of federal regulations. 

## Assessment Unit Name: Lake Erie Western
Basin Shoreline (including Maumee Bay and Sandusky Bay)

Monitoring Scheduled: 2012
TMDL Scheduled: 2015



### Aquatic Life Use Assessment Reporting Category: 5x Sampling Years: 2000, 2001, 2002
Total Shoreline Miles: 119.9
Shoreline Miles Monitored: 33.1
Sites Monitored: 10 Sites Full Attainment: 0 (0%) Sites Partial Attainment: 0 (0%) Sites Non Attainment: 10 (100%)

Causes of Impairment :

• nutrients

• siltation

• organic enrichment/DO

• exotic species

Sources of Impairment :

• municipal point sources

• combined sewer overflows

• non-irrigated crop production

Comments: No nearshore Lake Erie monitoring by the Ohio EPA has
occurred since 2002.



### Recreation Use Assessment
Reporting Category: 5



### Public Drinking Water Supply Assessment Reporting Category: 1
Nirtate Watch List: No
Pesticide Watch List: No



### Fish Tissue Assessment Reporting Category: 5x

Figure 3. Western Basin of Lake Erie Water Quality Assessment (2010 Integrated Report)Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 11



### Development of Water Quality-Based

Effluent Limits

Determining appropriate

effluent concentrations is a multiple-step process in which parameters are identified as likely to be discharged by a facility, evaluated with respect to Ohio water quality criteria, and examined to

determine the likelihood that the existing effluent

could violate the

calculated limits. Although the locations

of the external outfalls

001 and 003 for the Bayshore Station are relatively near one another, the discharges have not been modeled interactively; given the met hodology which must be used to develop waste load allocations for a lake discharger, considering these outfalls to be interactive would not change the parameter assessment results. (See the section below ent itled, “Waste Load Allocation”.)

Parameter Selection

Effluent data for the Bayshore Station were used to determine what para meters should undergo wasteload

allocation. The sources of effluent data are as follows:

Self-monitoring data (Discharge Monitoring Reports) January 2006 - November 2009 NPDES permit renewal application 2008

The effluent data were checked for outliers and six were removed for parame ters monitored at outfall 003: four sample results were eliminated for selenium due to a reported method det ection level which appears to be incorrect; a value of 102 ug/l was eliminated for lead; and a value of 53.1 ug/l was eliminated for mercury. The remaining data was evaluated statistically, and Project ed Effluent Quality (PEQ) values were calculated for each pollutant. PEQ avg values represent the 95 th percentile of monthly average data, and PEQ

max values represent the 95 th percentile of all data points. The average and maximum projected ef fluent quality (PEQ) values are presented in Table 5. For a summary of the s creening results, refer to the parameter groupings on pages 27 and 28.

PEQ values are used according to Ohio rules to compare to applicable WQS and a llowable WLA values for each pollutant evaluated. Initially, PEQ values are compared to the applic able average and maximum WQS. If both PEQ values are less than 25 percent of the applicable WQS, the par ameter does not have the reasonable potential to cause or contribute to exceedances of WQS, and no wa steload allocation is done for that parameter. If either the PEQ avg or PEQ

max is greater than 25 percent of the applicable WQS, a wasteload Figure 4. Temperature: Intake vs. Outfall 001 (20 07 – 2009)Page 12 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010

allocation is conducted to determine whether the parameter exhibits re asonable potential (and needs to be limited) or if monitoring is required.

Wasteload Allocation

For those parameters that require a wasteload allocation (WLA), the r esults are based on the uses assigned to the receiving waterbody in OAC 3745-1. Dischargers are allocated pollutant loadings/concentrations based on the Ohio Water Quality Standards (WQS - OAC 3745-1). Most pollutants are al located by a massbalance method because they do not degrade in the receiving water. Waste load allocations for average criteria using this method are done using the following general equation for dir ect dischargers to Lake Erie: Discharger WLA = (11 x WQS) - (10 x background concentration).

For direct dischargers to lakes, the waste load allocations for maximum criteria (or Outside Mixing Zone Maximum, OMZM) are set equal to the Inside Mixing Zone Maximum criteria. The values for the OMZM are left blank in Table 8 to indicate that any limits based upon a maximum WLA ar e actually represented by the Inside Mixing Zone Maximum criteria. The wasteload allocation value s in Table 8 would allow the Bayshore Station to maintain all applicable water quality criteria. Al locations cannot exceed the Inside Mixing Zone Maximum criteria.

The data used in the WLA are listed in Tables 6 and 7. The wasteload alloca tion results to maintain all applicable criteria are presented in Table 8.

Dissolved Metal Translator for Copper

A dissolved metals translator (DMT) is the factor used to convert a dissolved metal aquatic life criterion to an effective total recoverable aquatic life criterion with whi ch a total recoverable aquatic life allocation can be calculated as required in the NPDES permit process. Currently, a DMT is based on site- or area-specific field data; each field data sample consists of a total recoverable mea surement paired with a dissolved metal measurement. For Maumee Bay, there were 18 such paired samples availabl e applicable to copper. To account for the limited quantity of data, the DMT for each of these metal s was determined as the lower end of the 95% confidence interval (1-tail) about the geometric mean of the t otal recoverable-to-dissolved ratios of the sample pairs. Each DMT is metal-specific and is applied by multipl ying the dissolved criteria by the DMT, resulting in total effective recoverable criteria which can b e used in the wasteload allocation procedures.

In some cases, it is possible that the use of a DMT may result in instr eam concentrations of metals that may increase the risk of non-attainment of the aquatic life use designation. Th is was evaluated for the Bayshore Station. The application of the dissolved metal translator resulted in ef fective total recoverable criteria for copper that was higher than the total recoverable criteria listed in O AC 3745-1. The available data suggests that Maumee Bay near the Bayshore Station is not attaining its designat ed use, however this assessment is based upon data that is more than ten years old and it is likely that impa irment is not related to the presence of metals such as copper in the waterbody. In addition, the Bayshore Station has n ot requested any increase in permitted load. Therefore, the facility can receive permit limits that maintain all numeric criteria, up to their most recently calculated wasteload allocation, without undergoing any further review to ensure that the limits for the metals will protect the aquatic life and other uses.

Reasonable Potential

After appropriate effluent limits are calculated by wasteload a llocation, the lowest most restrictive average

and maximum values are selected from Table 8 and are referred to as Prel iminary Effluent Limits (PEL avgFactsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 13

and PEL

max respectively). The reasonable potential of the discharger to excee d the wasteload allocation (PEL values) is determined by comparing the PEQ avg (Table 5) to the PEL avg and the PEQ

max to the PEL

max for each parameter. Based on this comparison, each parameter is placed i n a defined “group”. Parameters that do not have a water quality standard (WQS) or do not require a WLA based on the initial screening are assigned to either group 1 or 2. Parameters are assigned to group 3, 4, or 5 depending on how c lose the PEQ value is to the allocated value or PEL. The groupings listed in Tables 9-001 and 9-003 reflect the reasonable potential hazard assessment done according to WLA procedures.

Whole Effluent Toxicity WLA

Whole effluent toxicity or “WET” is the total toxic effect of an efflue nt on aquatic life measured directly with a toxicity test. Acute WET measures short term effects of the effluent while chronic WET measures longer term and potentially more subtle effects of the effluent.

Water Quality Standards for WET are expressed in Ohio’s narrative “f ree from” WQS rule (OAC 3745-1- 04(D)). These “free froms” are translated into toxicity units (TUs) by the associated WQS Implementation Rule (OAC 3745-2-09). Wasteload allocations can then be calculated using TU s as if they were water quality criteria.

The wasteload allocation calculations for WET are similar to those for aquatic life criteria - using the chronic toxicity unit (TU

c ) and 7Q10 flow for the average and the acute toxicity unit (TU

a ) and 1Q10 flow for the maximum for flowing streams. 

### However, i n accordance with the Rule 3745-2-09 of the OAC, the AET for acute toxicity is set equal to 1.0 TU

a for lake dischargers. For the Bayshore Station, the wasteload

allocations are 1.0 TU

a and 11.0 TU

c for both outfall 001 and outfall 003.



### Effluent Limits/Hazard Management Decisions

The final effluent limits are determined by evaluating the groupings in conjunc tion with other applicable rules and regulations. Tables 10-001, 10-002, and 10-003 show the draft NPDES permit lim its for the Bayshore Station.

Federal and State laws/regulation require that dischargers meet bot h treatment-technology-based limits and any more stringent standards needed to comply with state WQS. Permit li mits are based on the more restrictive of the two. Treatment-technology-based limits for the B ayshore Station, found in 40 CFR Part 423, Steam Electric Power Generating Point Source Category, are based on the milligrams of pollutant allowed to be discharged per liter. (See Attachment A for technology-base d limits applicable to the Bayshore Station.)

The limits and monitoring requirements for each outfall are discussed in de tail below and the corresponding “Final Effluent Limits” table is referenced.

Outfall 001: Table 10-001

The Ohio EPA risk assessment (Table 9-001) places total residual chlorine and silver in Group 5, and recommends limits to protect water quality. However, the maximum daily li mit of 0.038 mg/l for chlorine has not been included in the permit since the Bayshore Station re stricts the use of chlorine at this outfall to less than two hours per day. (See the discussion below.)Page 14 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010

Silver has also been placed into Group 5 for outfall 001. An analysis conducted i n 2008 compared

the silver concentration of intake water to the concentration in the dis charge at outfall 001 from July 2006 through April 2008. This analysis showed that the discharge concentrations wer e very similar to the intake water concentrations. For this permit renewal, Ohio EPA ha s determined that the presence of silver in the discharge is due to its presence in the intak e water. Monitoring for silver at outfall 001 has been removed from the permit.

The Ohio EPA risk assessment places copper in Group 4. This placement as wel l as the data in Tables 4 and 5 indicate that copper should not pose an environmental hazard and limi ts are not necessary to protect water quality. Monitoring for Group 4 parameters is r equired in accordance with the Ohio Administrative Code, and has been included at outfall 001.

Monitoring for water temperature, total residual oxidants, flow r ate, total residual chlorine, and duration of chlorination/bromination have been continued in the draft permit . Since the discharge from this outfall is non-contact cooling water, it is important to monitor the temperature of the

wastewater as it enters Lake Erie. Total residual chlorine inc ludes a limit of 0.2 milligrams per liter (mg/l), which allows chlorination at this outfall for not more than two hours e ach day, and is based upon the Federal Effluent Guidelines for steam-electric power plants. The limit of 0.05 mg/l for total residual oxidants, which is based upon best professional judgement rega rding the relative toxicity of bromine, allows the Bayshore Station to discharge bromine, or bromine and chlori ne compounds for not more than two hours per day.

Several additional parameters with water quality criteria (barium, boron, fluoride, manganese, and nitrate+nitrite) were detected in the effluent from outfall 001, but were no t allocated since the concentration of the pollutant was less than 110 percent of its concentrati on in the intake water. 2 This

determination has been made in accordance with Rule 3745-2-06 of the Ohio Administr ative Code, and has been based upon the data reported in the NPDES permit renewal application.

Outfall 002: Table 10-002

In the event that this outfall may be used during the next permit period cycle, tot al suspended solids, flow rate, and pH must be monitored when a discharge occurs. These parameter s have been monitored under the existing permit, and are required for inclusion in accordance with t he Federal Effluent Guidelines. Monitoring for mercury has been added to the requirements for thi s outfall since mercury is a common pollutant found in discharges from fly ash ponds.

Outfall 003: Table 10-003

Loadings at outfall 003 have been determined in the permit by continuing to use a des ign flow rate of 2.3 MGD from the bottom ash pond. Average flow rates are less than 2.3 MGD, however, th is higher flow rate allows the facility to operate at increased throughput levels wh ich does occur at occasion. (See Table 2.)

Silver . The Ohio EPA risk assessment places silver in Group 5. This placeme nt as well as the data in Tables 4 and 5 indicate that limits are necessary to protect water quali ty. Since only two values of silver were reported above the daily maximum limit of 5.7 ug/l, the draft permit doe s not include a compliance schedule for meeting this limit. However, Part II of the permit includes a requirement that First Energy

2 A threshold of 110 percent has been used in order to allow for possible sampling and/or analytical er ror.Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 15

use an analytical method for silver analysis with a method detection le vel (MDL) no greater than 1.9 ug/l so that monitoring data can be appropriately used to compare with the waste load allocation of 5.7 ug/l.

Mercury . The risk assessment also places mercury in Group 5 after November 15, 2010 3 , as 43 out of 44 samples were greater than the average water quality criterion of 1.3 na nograms per liter (ng/l) since January 2006. Based on the results of low-level mercury monitoring, the permit tee has determined that its discharge at outfall 003 cannot meet the average water quality-ba sed effluent limit (WQBEL) of 1.3 ng/l, and has applied for coverage under the general mercury variance, Rule 3745-33-07(D)(10) of the Ohio Administrative Code. However, the permittee believes that the pl ant will be able to achieve an annual average mercury effluent concentration of 12 ng/l. The variance appl ication also demonstrated to the satisfaction of Ohio EPA that there is no readily apparent means of complying with the WQBEL without constructing prohibitively expensive end-of-pipe controls for mercu ry. Based on these factors, the permittee is eligible for coverage under the general mercury variance.

Ohio EPA has reviewed the mercury variance application and has determined t hat it meets the requirements of the Ohio Administrative Code. Items F and G in Part II of the dr aft NPDES permit list the provisions of the mercury variance, and include the following requirement s:

• A variance-based monthly average effluent limit of 11 ng/l, which was dev eloped from sampling data submitted by the permittee;

• A requirement that the permittee make reasonable progress to meet t he water-quality-based effluent limit for mercury by implementing the plan of study, which has been developed as par t of the Pollutant Minimization Program (PMP);

• Low-level mercury monitoring (U.S. EPA Method 1631) of the plant’s influent and e ffluent;

• A requirement that the annual average mercury effluent concentration is less than or equal to 12 ng/l as specified in the plan of study;

• A summary of the elements of the plan of study;

• A requirement to submit an annual report on implementation of the PMP; and

• A requirement for submittal of a certification stating that all per mit conditions related to implementing the plan of study and the PMP have been satisfied, and whether or not compliance with the monthly average water quality-based effluent limit for mercury has been achieved.

Part II, Item J. of the permit also includes a list of the information w hich must be submitted with the next permit renewal application to evaluate renewal of the mercury v ariance.

Barium, Cadmium, and Thallium . The Ohio EPA risk assessment places barium, cadmium, and thallium in group 4. This placement as well as the data in Tables 4 and 5 indic ate that these pollutants should not pose environmental hazards and limits are not necessary to protect w ater quality. Monitoring for Group 4 parameters is required in accordance with the Ohio Administrat ive Code and has been included in the draft permit.

3 In November 2010, the use of mixing zones to deter mine the waste load allocation for bioaccumulative chemicals of concern (BCCs) will no longer be allowed. This mea ns that limits for BCCs after November 2010 must me et water quality standards with no allowances for dilution. Since mercury is considered a BCC, discharges must comply with water quality standards at that time.Page 16 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010

Aluminum, Copper, Lead, Selenium, and Zinc . The Ohio EPA risk assessment places aluminum, copper, lead, selenium, and zinc in group 3. This placement as well as the data in T ables 4 and 5 indicate that these pollutants should not pose environmental hazards and limits a re not necessary to protect water quality. Monitoring has been included to ensure that concentr ations for these pollutants remain below levels of concern. A number of other parameters have been placed i n Groups 2 and 3, but Ohio EPA has determined that monitoring for these parameters is not warra nted at this time.

Total Suspended Solids, Oil & Grease, and pH . The limits and monitoring requirements for the remaining parameters have been continued from the existing permit. The limi ts for total suspended solids and oil and grease are based upon the Federal Effluent Guidelines, 40 CFR 423.12(b) (4). The limits for pH are based upon Ohio water quality standards.



### Impingement/Entrainment Reductions

The permit includes a compliance schedule which requires First Energy to ev aluate alternatives to reduce fish impingement and entrainment (I/E) at the Bayshore Station. No later than July 2011, the permittee must select an alternative designed to reduce I/E by 80 percent and 60 percen t, respectively, from a calculation baseline. Construction of improvements to reduce I/E must be compl eted no later than October 2014. The permit also requires sampling to be conducted at the cooli ng water intake structure to determine the effectiveness of the I/E reduction implementation.



### Whole Effluent Toxicity Reasonable Potential

During the term of the existing permit, the Bayshore Station reported two te st results at outfall 003 for Ceriodaphnia dubia and fathead minnows which indicated no evidence of acute toxicity. Based upon these findings, Ohio EPA believes that biomonitoring at outfall 003 is not w arranted at this time and has been removed from the draft permit.Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 17

Table 3. Concentrations of Chemicals Found in Effluent and Int ake

2008 Permit Application Renewal Form 2C

--- ---------------------------------Effluent---------- --------- Parameter No. of Sam ples Average* Maximum

Outfall 001

Aluminum (ug/l) 1 3240. Arsenic (ug/l) 1 16. Barium (ug/l) 1 49. Boron (ug/l) 1 56. Copper (ug/l) 1 4. Cyanide, Total (mg/l) 4 0.01 Fluoride (mg/l) 1 0.3 Iron (ug/l) 1 1950. Magnesium (mg/l) 1 19.59 Manganese (ug/l) 1 50. Molybdenum (ug/l) 1 11. Nitrate-Nitrite as N (mg/l) 1 2.68 Nitrogen, Total Organic as N (mg/l) 1 1.32 Phosphorus (mg/l) 1 0.22 Sulfate (mg/l) 1 48.4 Titanium (mg/l) 1 103.

Outfall 002

Aluminum (ug/l) 1 984. Antimony (ug/l) 1 8. Arsenic (ug/l) 1 29. Barium (ug/l) 1 74. Boron (ug/l) 1 1116. Fluoride (mg/l) 1 0.3 Iron (ug/l) 1 38. Magnesium (mg/l) 1 27.27 Manganese (ug/l) 1 60. Nitrate-Nitrite as N (mg/l) 1 0.14 Nitrogen, Total Organic as N (mg/l) 1 0.28 Phosphorus (mg/l) 1 0.26 Sulfate (mg/l) 1 373. Titanium (ug/l) 1 54.

Outfall 003

Aluminum (ug/l) 1 4010. Antimony (ug/l) 1 5. Arsenic (ug/l) 1 16. Barium (ug/l) 1 199. Boron (ug/l) 1 186. Chromium (ug/l) 1 6. Copper (ug/l) 1 5.Page 18 Factsheet for Bayshore Station NPDES Permit Renewal, March 2010 Table 3. Concentrations of Chemicals Found in Effluent and Intak e (continued)

2008 Permit Application Renewal Form 2C

--------------------------Effluent----------------- ----------- Parameter No. of Sam ples Average* Maximum

Outfall 003 (continued)

Fluoride (mg/l) 1 0.3 Iron (ug/l) 1 1680. Magnesium (mg/l) 1 17.59 Manganese (ug/l) 1 40. Nitrate-Nitrite as N (mg/l) 1 2.88 Nitrogen, Total Organic as N (mg/l) 1 0.62 Phosphorus (mg/l) 1 0.16 Sulfate (mg/l) 1 66.9 Titanium (ug/l) 1 112.

Outfall 800

Aluminum (ug/l) 1 1520. Antimony (ug/l) 1 5. Arsenic (ug/l) 1 3. Barium (ug/l) 1 45. Boron (ug/l) 1 65. Copper (ug/l) 1 2. Fluoride (mg/l) 1 0.3 Iron (ug/l) 1 1670. Magnesium (mg/l) 1 18.72 Manganese (ug/l) 1 50. Nitrate-Nitrite as N (mg/l) 1 2.57 Nitrogen, Total Organic as N (mg/l) 1 0.98 Phosphorus (mg/l) 1 0.21 Sulfate (mg/l) 1 49.1 Titanium (ug/l) 1 74.Factsheet for Bayshore Station NPDES Permit Renewal, March 2010 Page 19Table 4. Effluent Characterization and Decision Criteria: January 2006 – November 2009Summary of analytical results for Outfalls 001, 002, 003, 601, and 800. All values areinμg/l unless otherwise indicated. ND = below detection (detectionlimit); NA = not analyzed. Decision Criteria: PEQavg= monthly averages; PEQmax= daily maximum analytical results.Current PermitLimitsPercentilesDecision CriteriaParameterSeasonUnits30 dayDaily# Obs.50th95thData Range# Obs.PEQavePEQmaxOutfall 001Water Temperature Annual C Monitor only 1371 15.7 31.8 5.7-34.5 1037 24.178 41.658Dissolved Oxygen Summer mg/l Monitor only 23 9.2 10.1 5.7-10.4 15 10.337 12.421Dissolved Oxygen Winter mg/l Monitor only 22 9.9 10.7 8.4-18 10 10.747 11.387Dissolved Oxygen Summer kg/day 23 24000 27600 16100-28200Dissolved Oxygen Winter kg/day 22 27700 30200 14000-50800Silver, Total Recoverable Annual ug/l Monitor only28 0 5.54 0-7 28 7.3048 10.985Silver, Total Recoverable Annual kg/day 28 0 15 0-19.8Zinc, Total Recoverable Annual ug/l Monitor only 299.1 43.1 0-59.2 29 41.745 70.403Zinc, Total Recoverable Annual kg/day 29 22.6 111 0-167Flow Rate Summer MGD 705 746 746 377-746Flow Rate Winter MGD 666 746 746 281-746Flow Rate Annual MGD Monitor only 1371 746 746 281-746Chlorine, Total Residual Annual mg/l -- 0.2 561 0.03 0.1 0-0.19 561 0.055808 0.12171Chlorine, Total Residual Annual kg/day 561 63.8 2540-536Chlorination/Bromination Duration Annual Minutes --120 833 0 90 0-90Outfall 002Total Suspended Solids Annual mg/l Monitor only 13010.5 90.2 0-270 130 62.024 133.97Total Suspended Solids Annual kg/day 130 4.52 71.20-161Flow Rate Summer MGD 53 0.07 0.184 0.01-0.19Flow Rate Winter MGD 81 0.15 0.39 0.02-0.4Page 20 Factsheet for Bayshore Station NPDES PermitRenewal, March 2010Table 4. Effluent Characterization and Decision Criteria: January 2006 – November 2009Summary of analytical results for Outfalls 001, 002, 003, 601, and 800. All values areinμg/l unless otherwise indicated. ND = below detection (detectionlimit); NA = not analyzed. Decision Criteria: PEQavg= monthly averages; PEQmax= daily maximum analytical results.Current PermitLimitsPercentilesDecision CriteriaParameterSeasonUnits30 dayDaily# Obs.50th95thData Range# Obs.PEQavePEQmaxFlow Rate Annual MGD Monitor only 134 0.11 0.39 0.01-0.4pH, Maximum Annual S.U. Monitor only 130 7.36 7.946.6-8.26pH, Minimum Annual S.U. Monitor only 129 7.36 7.946.6-8.26Outfall 003Total Suspended Solids Annual mg/l 30 100 429 4 42.6 0-95 429 35.819 59.148Total Suspended Solids Annual kg/day 261 871 429 15.1 235 0-611Oil and Grease, Total Annual mg/l 15 20 47 0 0 0-047 -- --Oil and Grease, Total Annual kg/day 131 174 47 0 00-0Selenium, Total Recoverable Annual ug/l Monitor only 194 0 17.4 0-125 190 24.869 26.442Selenium, Total Recoverable Annual kg/day 194 0 0.101 0-0.628Thallium, Total Recoverable Annual ug/l Monitor only 43 0 0 0-34.6 43 27.78 38.06Thallium, Total Recoverable Annual kg/day 43 0 0 0-0.134Beryllium, Total Recoverable Annual ug/l Monitor only 10 0 2.42 0-4.4 8 6.103 8.36Beryllium, Total Recoverable Annual kg/day 10 0 0.00916 0-0.0167Silver, Total Recoverable Annual ug/l Monitor only190 0 6.41 0-31.8 190 6.5706 8.7069Silver, Total Recoverable Annual kg/day 190 0 0.0309 0-0.165Zinc, Total Recoverable Annual ug/l Monitor only 194 10 47.7 0-176 194 40.229 60.096Zinc, Total Recoverable Annual kg/day 194 0.0325 0.259 0-0.855Aluminum, Total Recoverable Annual ug/l Monitor only 20 3310 12600 974-21000 20 11067 18914Aluminum, Total Recoverable Annual kg/day 20 16.2 87.6 3.07-89.8Cadmium, Total Recoverable Annual ug/l 6 0 3.23 0-4.3 6 6.592 9.03Cadmium, Total Recoverable Annual kg/day 6 0 0.01220-0.0163Lead, Total Recoverable Annual ug/l Monitor only 194 0 8.21 0-102 193 6.4811 9.7915Factsheet for Bayshore Station NPDES Permit Renewal, March 2010 Page 21Table 4. Effluent Characterization and Decision Criteria: January 2006 – November 2009Summary of analytical results for Outfalls 001, 002, 003, 601, and 800. All values areinμg/l unless otherwise indicated. ND = below detection (detectionlimit); NA = not analyzed. Decision Criteria: PEQavg= monthly averages; PEQmax= daily maximum analytical results.Current PermitLimitsPercentilesDecision CriteriaParameterSeasonUnits30 dayDaily# Obs.50th95thData Range# Obs.PEQavePEQmaxLead, Total Recoverable Annual kg/day 194 0 0.04610-0.309Copper, Total Recoverable Annual ug/l Monitor only193 6.6 19.4 0-34.4 193 16.459 24.696Copper, Total Recoverable Annual kg/day 193 0.02540.101 0-0.202Flow Rate Summer MGD 679 1.3 2 0-3.5Flow Rate Winter MGD 585 1.1 1.9 0.1-5.3Flow Rate Annual MGD Monitor only 1264 1.2 1.99 0-5.3Mercury, Total (Low Level) Annual ng/l 1.3 1700 454.7 16.7 1.04-53.1 44 11.026 17.242Mercury, Total (Low Level) Annual kg/day 0.000011 0.015 451.95E054.79E-050.00000339-0.000261Acute Toxicity, Ceriodaphniadubia Annual TUa Monitor only 2 0 0 0-0Acute Toxicity, Pimephalespromelas Annual TUa Monitor only 2 0 0 0-0pH, Maximum Annual S.U. Not more than 9.0 940 8.338.8 6.5-9.36pH, Minimum Annual S.U. Not less than 6.5 939 8.328.8 6.5-9.36Outfall 601Mercury, Total (Low Level) Annual ng/l Monitor only28 18.6 95.1 1.34-114 28 120.87 198.18Outfall 800Water Temperature Annual C Monitor only 1371 10.7 27.9 0-33.4Total Suspended Solids Annual mg/l Monitor only 95058 227 1-814Page 22 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010



### Table 5. Effluent Data for the Bayshore Power Plant

Number of Number > PEQ PEQ

Parameter Units Samples MDL Average Maximum

Outfall 001
Arsenic – TR * ug/l 1 1 72.416 99.2
Chlorine - TRes mg/l 561 507 0.0558 0.122
Copper – TR * ug/l 1 1 18.104 24.8
Iron – TR * ug/l 1 1 8825.7 12090
Molybdenum * ug/l 1 1 49.786 68.2
Silver ug/l 28 9 6.132 8.4
Titanium * ug/l 1 1 466.178 638.6
Zinc - TR ug/l 29 19 41.745 70.403

Outfall 003 Aluminum ug/l 20 20 11067 18914 Antimony * ug/l 1 1 22.63 31

Arsenic – TR * ug/l 1 1 72.416 99.2 Barium * ug/l 1 1 900.674 1233.8 Beryllium ug/l 8 1 6.1028 8.36

Boron * ug/l 1 1 841.836 1153.2

Cadmium - TR ug/l 6 1 6.5919 9.03 Chromium – TR* ug/l 1 1 27.156 37.2 Copper - TR ug/l 193 145 16.459 24.696

Fluoride * mg/l 1 1 1.3578 1.86

Iron - TR* ug/l 1 1 7603.68 10416 Lead - TR ug/l 193 87 6.4811 9.7915 Magnesium * mg/l 1 1 79.61234 109.058 Manganese – TR * ug/l 1 1 181.04 248 Mercury - TR ng/l 44 44 11.026 17.242 Nitrate-N + Nitrite-N * mg/l 1 1 13.03488 17.856 Phosphorus * mg/l 1 1 0.72416 0.992

Selenium - TR ug/l 190 7 24.869 26.442

Silver ug/l 190 60 6.5706 8.7069 Sulfates * mg/l 1 1 302.7894 414.78 Thallium ug/l 43 2 27.7838 38.06

Titanium * ug/l 1 1 506.912 694.4

Zinc - TR ug/l 194 115 40.229 60.096

* The dataset for this parameter is based upon the NPDES permit renewal application.Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 23



### Table 6. Water Quality Criteria in the Study Area

Outside Mixing Zone Criteria Inside
Average Maximum Mixing

Human Agri- Aquatic Aquatic Zone

Parameter Units Wildlife Health culture Life Life Maximum

Aluminum ug/l -- 4500 -- -- -- -- Arsenic - TR ug/l -- 580 100 150 340 680 Antimony ug/l -- 780 -- 190 900 1800 Barium ug/l -- 160000 -- 220 2000 4000 Beryllium ug/l -- 130c 100 19 160 320 Boron ug/l -- 200000 -- 950 8500 17000 Cadmium - TR ug/l -- 730 50 3.2 6.6 13 Chlorine - TRes mg/l -- -- -- 0.011 0.019 0.038 Chromium - TR ug/l -- 14000 100 110 2400 4800 Copper – TR ug/l -- 64000 500 12 19 38
Copper – TR 1 ug/l -- 64000 500 25 38 77 Fluoride mg/l -- -- 2 -- -- -- Iron - TR ug/l -- -- 5000 -- -- --
Lead - TR ug/l -- -- 100 9.9 190 380 Magnesium mg/l -- -- -- -- -- -- Manganese - TR ug/l -- 61000 -- -- -- -- Mercury - TR ng/l 1.3 3.1 10000 910 1700 3400
Molybdenum ug/l -- 10000 -- 20000 190000 370000 Nitrate-N + Nitrite-N mg/l -- -- 100 -- -- -- Phosphorus mg/l -- -- -- -- -- -- Selenium - TR ug/l -- 3100 50 5 -- -- Silver ug/l -- 11000 -- 1.3 2.9 5.7 Sulfates mg/l -- -- -- -- -- -- Thallium ug/l -- 3.7 -- 17 79 160 Titanium ug/l -- -- -- -- -- -- Zinc - TR ug/l -- 35000 25000 160 160 320

1 Water quality criteria which is applicable to out fall 003. Aquatic life criteria is based upon a di ssolved metal translator (DMT). See Table 7 for value of DMT.Page 24 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010



### Table 7. Instream Conditions and Discharger Flow

Parameter Units Season Value Basis

Hardness mg/l annual 140 50 th percentile statewide value *

Bayshore Power Plant flow

Outfall 001 cfs annual 1154 DMR data, 50th percentile value

Outfall 003 cfs annual 3.56 Previous WLA

Background Water Quality

Arsenic - TR ug/l 0 No representative data available.

Chlorine - TRes mg/l 0 No representative data available.

Copper - TR ug/l 5 n=2867; 1597<MDL *

Iron - TR ug/l 650 n=3018; 15<MDL *

Molybdenum ug/l 0 No representative data available.

Silver ug/l 0 No representative data available.

Titanium ug/l 0 No representative data available.

Zinc - TR ug/l 15 n=2284; 1117<MDL *

Aluminum ug/l 330 n=640; 146<MDL *

Antimony ug/l 0 No representative data available.

Arsenic - TR ug/l 0 No representative data available.

Barium ug/l 68 n=1728; 0<MDL **

Beryllium ug/l 0 No representative data available.

Boron ug/l 0 No representative data available.

Cadmium - TR ug/l 0.25 n=1696; 1365<MDL *

Chromium - TR ug/l 15 n=1641; 1388<MDL *

Copper - TR ug/l 5 n=2867; 1597<MDL *

Fluoride mg/l 0 No representative data available.

Iron - TR ug/l 650 n=3018; 15<MDL *

Lead - TR ug/l 2 n=2814; 1458<MDL *

Magnesium mg/l 22.5 n=2604; 3<MDL *Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 25



### Table 7. Instream Conditions and Discharger Flow

Parameter Units Season Value Basis

Manganese - TR ug/l 0 No representative data available.

Mercury - TR ng/l 0 No representative data available.

Nitrate-N + Nitrite-N mg/l 0.73 n=5852; 515<MDL *

Phosphorus mg/l 0.06 n=5820; 1769<MDL *

Selenium - TR ug/l 0 No representative data available.

Silver ug/l 0 No representative data available.

Sulfates mg/l 0 No representative data available.

Thallium ug/l 0 No representative data available.

Titanium ug/l 0 No representative data available.

Zinc - TR ug/l 15 n=2284; 1117<MDL *

Dissolved Metal Translator

Copper 2.08 First Energy study (2008)

* “BWQR” means Background Water Quality Report, sa mples taken through February 1988, and the value sh own represents the statewide 50 th percentile estimate.

** The background value for this parameter is base d upon the statewide 50 th percentile for reference sites sampled in Ohio from 1999 through 2003.Page 26 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010



### Table 8. Summary of Effluent Limits to Maintain Applicable WQ Criteria

Outside Mixing Zone Criteria Inside
Average

Maximum Mixing

Human Agri- Aquatic Aquatic Zone

Parameter Units Wildlife Health culture Life Life Maximum

Outfall 001
Arsenic - TR ug/l -- 6380 3 1100 3 1650 3 -- 680 Chlorine - TRes mg/l -- -- -- 0.12 3 -- 0.038 Copper - TR ug/l -- 703950 3 5450 3 82 3 -- 38 Iron - TR ug/l -- -- 48500 -- -- -- Molybdenum ug/l -- 110000 -- 220000 -- 370000
Silver ug/l -- 121000 3 -- 14 3 -- 5.7
Titanium ug/l -- -- -- -- -- -- Zinc - TR ug/l -- 384850 3 274850 3 1610 3 -- 320

Outfall 003
Aluminum ug/l -- 46200 -- -- -- -- Antimony ug/l -- 8580 3 -- 2090 3 -- 1800 Arsenic - TR ug/l -- 6380 3 1100 3 1650 3 -- 680 Barium ug/l -- 1759320 3 -- 1740 -- 4000 Beryllium ug/l -- 1430 3 1100 3 209 -- 320 Boron ug/l -- 2200000 3 -- 10450 -- 17000 Cadmium - TR ug/l -- 8028 3 548 3 33 3 -- 13 Chromium - TR ug/l -- 153850 3 950 1060 -- 4800 Copper - TR ug/l -- 703950 3 5450 3 225 3 -- 77 Fluoride mg/l -- -- 22 -- -- -- Iron - TR ug/l -- -- 48500 -- -- --
Lead - TR ug/l -- -- 1080 3 89 -- 380 Magnesium mg/l -- -- -- -- -- --
Manganese - TR ug/l -- 671000 -- -- -- --
Mercury - TR 1 ng/l 14 34 110000 3 10010 3 -- 3400
Mercury - TR 2 ng/l 1.3 3.1 10000 3 910 -- 3400 Nitrate-N + Nitrite-N mg/l -- -- 1093 -- -- --
Phosphorus mg/l -- -- -- -- -- -- Selenium - TR ug/l -- 34100 550 55 -- --
Silver ug/l -- 121000 3 -- 14 3 -- 5.7
Sulfates mg/l -- -- -- -- -- -- Thallium ug/l -- 41 -- 187 3 -- 160
Titanium ug/l -- -- -- -- -- -- Zinc - TR ug/l -- 384850 3 274850 3 1610 3 -- 320

1 These wasteload allocations are in effect until November 1, 2010, when mixing zones can no longer be used for developing wasteload allocations for bioaccumulativ e chemicals of concern such as mercury.

2 These wasteload allocations are in effect after November 1, 2010, when mixing zones can no longer be used for developing wasteload allocations for bioaccumulativ e chemicals of concern such as mercury.

3 Wasteload allocations can not exceed the inside m ixing zone maximum.Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 27



### Table 9-001. Parameter Assessment for Outfall 001

Group 1: Due to a lack of criteria, the following parameters could not be evaluat ed at this time.

Titanium

Group 2: PEQ < 25 percent of WQS or all data below minimum detection limit.

WLA not required. No limit recommended; monitoring optional.

Molybdenum

Group 3: PEQ

max < 50 percent of maximum PEL and PEQ avg < 50 percent of average PEL.

No limit recommended; monitoring optional.

Arsenic - TR Iron - TR Zinc - TR

Group 4: PEQ

max >= 50 percent, but < 100 percent of the maximum PEL or

PEQ avg >= 50 percent, but < 100 percent of the average PEL. Monitoring is appropriate.

Copper - TR

Group 5: Maximum PEQ >= 100 percent of the maximum PEL or average PEQ >= 100

percent of the average PEL, or either the average or maximum PEQ is be tween 75
and 100 percent of the PEL and certain conditions that increase the risk to t he
environment are present. Limit recommended.

Limits to Protect Numeric Water Quality Criteria

Recommended Effluent Limits

Parameter Units Period Average Maximum

Chlorine - TRes mg/l -- 0.038 Silver ug/l -- 5.7Page 28 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010



### Table 9-003. Parameter Assessment for Outfall 003

Group 1: Due to a lack of criteria, the following parameters could not be evaluat ed at this time.

Magnesium Phosphorus Sulfates

Titanium

Group 2: PEQ < 25 percent of WQS or all data below minimum detection limit.

WLA not required. No limit recommended; monitoring optional.

Antimony Manganese - TR Nitrate-N + Nitrite-N

Group 3: PEQ

max < 50 percent of maximum PEL and PEQ avg < 50 percent of average PEL.

No limit recommended; monitoring optional.

Aluminum Arsenic - TR Beryllium Boron Chromium - TR Copper - TR

Fluoride Iron - TR Lead - TR

Selenium - TR Zinc - TR

Group 4: PEQ

max >= 50 percent, but < 100 percent of the maximum PEL or

PEQ avg >= 50 percent, but < 100 percent of the average PEL. Monitoring is appropriate.

Barium Cadmium - TR Mercury - TR 1

Thallium

Group 5: Maximum PEQ >= 100 percent of the maximum PEL or average PEQ >= 100

percent of the average PEL, or either the average or maximum PEQ is be tween 75
and 100 percent of the PEL and certain conditions that increase the risk to t he
environment are present. Limit recommended.

Limits to Protect Numeric Water Quality Criteria

Recommended Effluent Limits

Parameter Units Period Average Maximum

Mercury - TR 2 ng/l 1.3 3400 Silver ug/l -- 5.7

1 This grouping is in effect until November 1, 2010, when mixing zones can no longer be used for developing wasteload allocations for bioaccumulativ e chemicals of concern such as mercury.

2 This grouping is in effect after November 1, 2010, when mixing zones can no longer be used for developing wasteload allocations for bioaccumulativ e chemicals of concern such as mercury.Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 29

Table 10-001. Final Effluent Limits and Monitoring Requirements f or Outfall 001

Effluent Limits Concentration Loading (kg/day) a 30 Day Daily 30 Day Daily Parameter Units Average Maximum Average Maximum Basis b

Water Temperature E C - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/M c Dissolved Oxygen mg/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/M c Copper, Tot. Rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - WLA Oxidants, Tot. Res. mg/l -- 0.05 -- -- EP/M c

Flow MGD - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/M c Chlorine, Total Residual mg/l -- 0.2 -- -- EP

Chlorination/Bromination

minutes -- 120 -- -- EP

a Loadings based upon an effluent flow rate of 746 MG D.

b,c See page 29 for definition of terms and explanat ion of monitoring requirements.

Table 10-002. Final Effluent Limits and Monitoring Requirements for Outfall 002

Effluent Limits Concentration Loading (kg/day) a 30 Day Daily 30 Day Daily Parameter Units Average Maximum Average Maximum Basis b

Suspended Solids mg/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - M c /EP

Flow rate MGD - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - M c Mercury, Tot. Rec. ng/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - BPJ pH S.U. - - - - - - - - - - - 6.5 to 9.0 - - - - - - - - - - - - - - - - -WQS

b,c See page 29 for definition of terms and explanat ion of monitoring requirements.Page 30 Factsheet for Bayshore Station NPDES Permit Renewal , March 2010

Table 10-003. Final Effluent Limits and Monitoring Requirements for Outfall 003

Effluent Limits Concentration Loading (kg/day) a 30 Day Daily 30 Day Daily Parameter Units Average Maximum Average Maximum Basis b

Suspended Solids mg/l 30 100 261 871 EP/BPT Oil and Grease mg/l 15 20 131 174 EP/BPT Selenium, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/WLA Barium, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - WLA Thallium, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/WLA Silver, tot. rec. μ g/l -- 5.7 -- 0.050 RP Zinc, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/WLA Aluminum, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/RP Lead, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - EP/WLA Cadmium, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - WLA Copper, tot. rec. μ g/l - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - WLA

Flow MGD - - - - - - - - - - - - Monitor - - - - - - - - - - - - - - - M c Mercury, tot. rec. ng/l 11. 1700 0.000096 0.015 MVAR/EP pH S.U. - - - - - - - - - - - - - 6.5 to 9.0 - - - - - - - - - - - - - EP/WQS

a Loadings based upon an effluent flow rate of 2.3 MG D.

b Definitions: ABS = Antibacksliding Rule (OAC 3745-33-05(E) and 40 C FR Part 122.44(l));

AD = Antidegradation (OAC 3745-1-05);

BAT = Best Available Technology economically achievabl e, Federal Effluent Guidelines, 40 CFR Part 414;
BPJ = Best Professional Judgment;

BPT = Best Practicable control Technology currently av ailable, Federal Effluent Guidelines, 40 CFR, Part 414;

EP = Existing Permit;

M = Division of Surface Water Guidance #2, “National Pollutant Discharge Elimination System: Determination of Sampling Frequency Formula for Industrial Waste Discharges” recommends m onitoring for this

parameter;
MVAR = Mercury Variance-based limit [OAC 3745-33-07(D)( 10)];

PD = Plant Design Criteria;

RP = Reasonable Potential for exceeding water qualit y standards, and requiring water quality-based effluent limit s and monitoring requirements in NPDES permits (3745-33-07(A) );

WET = Whole Effluent Toxicity (OAC 3745-33-07(B)) ;

WLA = Wasteload Allocation procedures (OAC 3745-2);

WLA/IMZM = Wasteload Allocation limited by Inside Mixing Zo ne Maximum; WQS = Ohio Water Quality Standards (OAC 3745-1).

c Monitoring of flow and other indicator parameters is specified to assist in the evaluation of effluen t quality and treatment plant performance.Factsheet for Bayshore Station NPDES Permit Renewal , March 2010 Page 31



### Attachment A. Federal Effluent Guidelines Applicable to the Bays hore Station

40 CFR, Part 423 Steam Electric Power Generating Point Source Cat egory

Section 423.12(b)(3) Low Volume Waste Sources

Best Practicable Control Technology Available (BPT) ------------------- (mg/l) ---------------------

--- Parameter Daily Maximum 30-Day Average Total Suspended Solids 100.0 30.0

Oil & Grease 20.0 15.0

Section 423.12(b)(4) Fly Ash and Bottom Ash Transport Water

Best Practicable Control Technology Available (BPT) ------------------- (mg/l) ---------------------

--- Parameter Daily Maximum 30-Day Average Total Suspended Solids 100.0 30.0

Oil & Grease 20.0 15.0

Section 423.13(b) Once-through Cooling Water

Best Available Technology Economically Achievable (BPT) ------------------- (mg/l) ---------------------

--- Parameter Daily Maximum 30-Day Average

Total Residual Chlorine 0.20 --