per_Fncv.rtf 

CHRIS CHRISTIE DEPARTMENT OF ENVIRONMENTAL PROTECTION BOB MARTIN 

Governor Mail Code – 401-02B Commissioner 

Water Pollution Management Element 

Bureau of Surface Water Permitting 

KIM GUADAGNO P.O. Box 420 

Lt. Governor Trenton, NJ 08625-0420 

 Phone: (609) 292-4860 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

 7010 1870 0001 4760 7838 

June 17, 2013 

James Maiz, Senior Vice President 

RC Cape May Holdings LLC 

900 N Shore Rd 

Beesleys Point, NJ 08223 

Re: Final Consolidated Renewal Permit Action 

 Categories: B -Industrial Wastewater 

 RF -Stormwater 

 NJPDES Permit No. NJ0005444 

 B L ENGLAND GENERATING STATION 

 Upper Twp, Cape May County 

Dear Mr. Maiz: 

Enclosed is a final New Jersey Pollutant Discharge Elimination System (NJPDES) permit action identified above 

which has been issued in accordance with N.J.A.C. 7:14A. This permit action authorizes discharge activities 

applicable to the Industrial Wastewater and Stormwater categories. The permit authorizes the intake of Great Egg 

Harbor Bay water as well as the discharge of pollutants through several outfalls to Great Egg Harbor Bay, classified as 

SE-1. There are several discharges from this facility including: cooling tower blowdown (DSN 001A), stormwater 

(DSNs 003A, 006A and 007A), intake screen backwash (DSN 008A), condenser cooling water discharges (DSNs 

009A and 010A), wastewater treatment plant effluent (DSN 013A), and effluent from the flue gas desulfurization 

system (DSN 014A – internal point). 

The draft permit proposed to authorize treated effluent from the Continuous Sequential Batch Reactor (CSBR) (DSN 

015A – internal point), however, at the permittee’s request the discharge of sanitary effluent from the CSBR has been 

removed in this final permit. Accordingly, requirements for DSN 015A in Part III are not included in this final permit. 

Note that removal of this internal monitoring point in the final permit is consistent with N.J.A.C. 7:14A-16.5(a)6. 

In this final permit action, the following change was made from the draft permit: 

• Dissolved oxygen monitoring was added on a once per month basis to DSNs 001A, 009A and 010A, as well as 

the intake to DSN 010A. 

The Department received one set of comments from a third party on the draft action during the public comment period. 

A summary of these comments, the Department's responses, and an explanation of any changes from the draft action 

have been included in the Response to Comments document attached hereto as per N.J.A.C. 7:14A-15.16. 

Any requests for an adjudicatory hearing by the third party that commented on the draft action shall be submitted in 

writing by certified mail, or by other means which provide verification of the date of delivery to the Department, 
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within 30 days of receipt of this Consolidated Renewal Permit Action in accordance with N.J.A.C. 7:14A-17.2. The 

adjudicatory hearing request must be accompanied by a completed Adjudicatory Hearing Request Form. 

As per N.J.A.C. 7:14A-4.2(e)3, any person planning to continue discharging after the expiration date of an existing 

NJPDES permit shall file an application for renewal at least 180 calendar days prior to the expiration of the existing 

permit. 

All monitoring shall be conducted in accordance with 1) the Department's "Field Sampling Procedures Manual" 

applicable at the time of sampling (N.J.A.C. 7:14A-6.5(b)4), and/or 2) the method approved by the Department in Part 

IV of the permit. The Field Sampling Procedures Manual is available at http://www.nj.gov/dep/srp/guidance/fspm/. 

As a result of this permit action, your monitoring report forms have been changed. Enclosed with this permit are the 

new monitoring report forms (MRFs). Beginning the effective date of the permit, please use the new MRFs. 

Questions regarding the new forms shall be directed to this Bureau for further clarification. 

For your convenience, a schedule of submittal requirements has been included with this permit package.

Questions or comments regarding the final action should be addressed to Heather Genievich at (609) 292-4860. 

Sincerely, 

Pilar Patterson, Chief 

Bureau of Surface Water Permitting 

Enclosures 

cc: Permit Distribution List 

Masterfile #: 267113; PI #: 46087
FACILITY SUBMITTALS

B L ENGLAND GENERATING STATION, Beesleys Point Permit No. NJ0005444

PER050003 Consolidated Renewal Permit Action

1. GDR - General Discharge Requirements 

Task Description Actual

Due Date

Submit a Complete Permit Renewal Application 02/01/2018

2. B - Industrial Wastewater

Task Description Actual

Due Date

Submit an Acute Whole Effluent Toxicity Test Report 08/26/2014

Submit an Acute Whole Effluent Toxicity Test Report 08/26/2015

Submit an Acute Whole Effluent Toxicity Test Report 08/26/2016

Submit an Acute Whole Effluent Toxicity Test Report 08/26/2017

3. RF - Stormwater

Task Description Actual

Due Date

Annual Report 09/01/2014

Submit the Generic Certification Form Certifying That The Annual Inspection Was Conducted 09/01/2014

Submit the SPPP 02/01/2015

Annual Report 09/01/2015

Submit the Generic Certification Form Certifying That The Annual Inspection Was Conducted 09/01/2015

Annual Report 09/01/2016

Submit the Generic Certification Form Certifying That The Annual Inspection Was Conducted 09/01/2016

Annual Report 09/01/2017

Submit the Generic Certification Form Certifying That The Annual Inspection Was Conducted 09/01/2017

Facility Submittals Page 1 of 1
B L ENGLAND GENERATING STATION NJPDES Permit Number: NJ0005444 

Consolidated Renewal Permit Action Program Interest Number: 46087 

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Table of Contents 

This permit package contains the items listed below: 

 

1. Cover Letter 

 

2. Facility Submittals 

 

3. Table of Contents 

 

4. Response to Comments 

 

5. NJPDES Permit Authorization Page 

 

6. Part I – General Requirements: NJPDES 

 

7. Part II – General Requirements: Discharge Categories 

 

8. Part III – Limits and Monitoring Requirements 

9. Part IV – Specific Requirements: Narrative 

 

10. Attachment 1 – Contents of the Stormwater Pollution Prevention Plan 

 

 

 
 Response to Comments 

 Page 1 of 40 

 Permit No. NJ0005444 

New Jersey Department of Environmental Protection 

Division of Water Quality 

Bureau of Surface Water Permitting 

RESPONSE TO COMMENTS 

Comments were received on the New Jersey Pollutant Discharge Elimination System (NJPDES) 

draft Surface Water Renewal Permit Action No. NJ0005444 issued on March 28, 2013. The 

comment period began on March 26, 2013 and the Public Notice was published in the Press of 

Atlantic City as well as the DEP Bulletin. The public comment period ended on April 29, 

2013. 

 

The Department received the following submission: 

1. Reed W. Super and Edan Rotenberg of Super Law Group, LLC with Aaron Kleinbaum and 

Alice R. Baker of Eastern Environmental Law Center in a letter and e-mails dated April 26, 

2013. These two law groups submitted comments in one document on behalf of the Sierra 

Club, American Littoral Society, New Jersey Environmental Federation, and Clean Ocean 

Action. 

A summary of the timely and significant comments received, the New Jersey Department of 

Environmental Protection's (NJDEP) responses to these comments, and an explanation of any 

changes from the draft action have been included below. 

Comment 1 

Section 316(b) of the Clean Water Act (the Act) requires that the “location, design, construction, 

and capacity of cooling water intake structures reflect the best technology available (BTA) for 

minimizing adverse environmental impact.” The adverse environmental impacts of B.L. 

England’s once-through cooling system are significant where the Act requires that these impacts 

be minimized through this NJPDES permit renewal, not at some indefinite future point. Yet the 

NJDEP avoids making any real decisions or requiring any serious improvements to the cooling 

water system. 

In the Draft Permit the NJDEP concludes that B.L. England will minimize the adverse 

environmental impact of its cooling water system by submitting a study that analyzes the 

feasibility of reducing impingement mortality through improved screens with fish buckets and an 

improved fish return system. This is very far from the kind of determination about the BTA 

required by federal law. This “BTA Determination” does not discuss or address entrainment at 

all, nor does it require B.L. England to take any action that might actually reduce the number of 

fish killed. NJDEP should have considered a range of options that address both impingement 

and entrainment, and then determined which technology is the best available for minimizing the 

adverse environmental impacts of B.L. England’s cooling water system. Then, NJDEP should 

require that this technology be installed as soon as reasonably possible. 

 
 Response to Comments 

 Page 2 of 40 

 Permit No. NJ0005444 

The best technology to address B.L. England’s fish kills and thermal pollution is a closed-cycle 

cooling system like the one that is in use at Unit 3. Using the upcoming repowering as a chance 

to install a closed-cycle cooling system for the balance of the plant will reduce B.L. England’s 

water withdrawals and environmental impacts by 90%, at a cost which is not wholly 

disproportionate to the benefits, and without disrupting B.L. England’s electricity generating 

operations. Hence, it is an available technology. 

Response 1 

The Department disagrees with the commentor’s assertion that the Section 316(b) determination 

is inconsistent with federal law. While the commentor is correct in that NJDEP is requiring a 

study of improvements to the screen system and fish return to minimize impingement effects, 

NJDEP did not limit its Section 316(b) decision to impingement reductions alone. The 

cornerstone of the 2013 draft permit is the fact that the repowered facility will withdraw lesser 

volumes of water. As noted on page 1 of the 2013 Fact Sheet: 

... The permittee is proposing major changes to the Station that will result in environmental 

benefits in the vicinity of the Station and to the receiving waterbody due to reductions in 

intake volume, discharge volume, and air emissions. 

Further, on page 20: 

...The Department contends that it is reasonable to assume that a reduction in water 

withdrawal will have a directly proportional reduction in impingement and entrainment 

mortality. As a result, the reduction in flow after repowering of approximately 43% will 

have a significant reduction in impingement and entrainment mortalities. 

By way of background, Section 316(b) of the 1972 Clean Water Act regulates cooling water 

intake structures and their effects and states that: 

Any standards established pursuant to section 301 or section 306 of this Act and applicable to 

a point source shall require that the location, design, construction, and capacity of cooling 

water intake structures reflect the BTA for minimizing adverse environmental impact. 

The construction of BL England predates the enactment of the Clean Water Act since Units 1 and 

2 came on line in 1961 and 1962, respectively, and Unit 3 came on line in 1964. Although the 

Clean Water Act was issued in 1972, final EPA regulations for existing plants such as BLE are 

still not in effect but are due to be finalized by June 27, 2013 

(http://water.epa.gov/lawsregs/lawsguidance/cwa/316b/). In the interim, states are required 

to issue Section 316(b) determinations in accordance with Best Professional Judgment (BPJ). 

Because the required analysis for a BTA determination is not currently set forth in regulation, 

states and permitting authorities must glean information from the procedural history and draft 

regulation that came after the Clean Water Act Statute. In sum, NJDEP maintains that this BTA 

determination is legally appropriate and considers the necessary elements. 
 Response to Comments 

 Page 3 of 40 

 Permit No. NJ0005444 

Comment 2 

NJDEP’s BTA determination process was compromised by NJDEP’s failure to demand 

information about cooling towers. B.L. England was required to submit a Proposal for 

Information Collection (PIC) in 2005 and a Comprehensive Demonstration Study (CDS - also 

called a “316(b) Report”) in 2008, as per the then effective federal rules. However, the PIC 

excluded all consideration of cooling towers from the analysis and instead examined a set of ten 

technology options that involved various modifications to the existing screens, the fish return 

system, relocation of the intake, or addition of a net barrier. While none of these technologies 

approach the impingement and entrainment reductions achievable through closed-cycle cooling, 

the NJDEP accepted this deficient PIC. 

 

Between 2005 and the proposed submission of a 316(b) Report in 2008, EPA withdrew its Phase 

II regulations in light of a ruling from the Second Circuit Court of Appeals. Given the change in 

regulatory background, NJDEP sent a letter to the permittee in December 2007 and stated that 

any renewal application must contain a complete analysis of the suite of intake protection 

technologies that are available to address impingement and entrainment by June 30, 2008. 

Given that B.L. England already operates one natural draft cooling tower, it is indisputable that 

cooling towers must be considered as part of a complete analysis. But NJDEP made no effort to 

correct the gap in the record. Instead, in its 2007 letter, NJDEP actually waived a requirement 

that the forthcoming CDS should include “technology and compliance assessment information” 

and “information to support site-specific determination of BTA for minimizing adverse 

environmental impact.” The February 2008 316(b) Report did not include any analysis of 

closed-cycle cooling, nor did the permittee’s 2009 permit renewal application. 

 

After receiving the 316(b) Report in 2008 and the renewal permit application in 2009, NJDEP 

took another four years to issue this Draft Permit. This extended delay provided NJDEP ample 

time to correct the deficient record in its possession. 

Response 2 

To properly understand the timeline of events, it is important to provide information detailing the 

evolvement of the EPA Section 316(b) regulations and then compare the Section 316(b) reports 

from the permittee against that timeline. EPA issued final regulations for Phase II facilities 

effective September 7, 2004 to guide implementation of the Section 316(b) statute under the 

1972 Clean Water Act. These Phase II regulations were specific to power generating facilities 

that met certain eligibility criteria such as B.L. England. As noted in this comment, the Section 

316(b) Phase II regulations required submission of a PIC followed by a CDS. The PIC is 

essentially a workplan to describe what data will be collected for the purposes of the CDS. The 

Phase II rule stated that the CDS must be submitted by January 7, 2008 as specified at 40 CFR 

Part 125.95(a)(2)(ii). 

The Phase II regulations were appealed by multiple parties. In Riverkeeper, Inc., v. EPA, No. 

04-6692, (2d Cir. January 25, 2007) the Second U.S. Circuit Court of Appeals issued its decision 
 Response to Comments 

 Page 4 of 40 

 Permit No. NJ0005444 

in the litigation over the Phase II regulation. The court’s decision remanded several provisions 

of the Rule on various grounds including, but not limited to the following:

• 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 and; 

• The restoration provisions. 

EPA then suspended the Phase II Section 316(b) regulations as articulated in the July 9, 2007 

Federal Register. EPA directed States and permitting authorities to issue permits in accordance 

with BPJ pursuant to 40 CFR 401.14 until the final rule is released which is expected on June 27, 

2013. 

With respect to the Administrative Record for BL England, NJDEP issued a final renewal permit 

on January 11, 2005. Because the Phase II regulations were then in effect, the renewal permit 

required submission of a PIC and a CDS. The necessary elements of the PIC as described in the 

EPA Rule at 40 CFR 125.95(b)(1) (now remanded) were as follows: 

(1) Proposal For Information Collection. You must submit to the Director for review and 

comment a description of the information you will use to support your Study. The 

Proposal for Information must be submitted prior to the start of information collection 

activities, but you may initiate such activities prior to receiving comment from the 

Director. The proposal must include: 

(i) A description of the proposed and/or implemented technologies, operational measures, 

and/or restoration measures to be evaluated in the Study; 

(ii) A list and description of any historical studies characterizing impingement mortality 

and entrainment and/or the physical and biological conditions in the vicinity of the 

cooling water intake structures and their relevance to this proposed Study. If you 

propose to use existing data, you must demonstrate the extent to which the data are 

representative of current conditions and that the data were collected using appropriate 

quality assurance/quality control procedures; 

(iii) A summary of any past or ongoing consultations with appropriate Federal, State, and 

Tribal fish and wildlife agencies that are relevant to this Study and a copy of written 

comments received as a result of such consultations; and 

(iv) A sampling plan for any new field studies you propose to conduct in order to ensure 

that you have sufficient data to develop a scientifically valid estimate of impingement 

mortality and entrainment at your site. The sampling plan must document all methods 

and quality assurance/quality control procedures for sampling and data analysis. The 

sampling and data analysis methods you propose must be appropriate for a quantitative 

survey and include consideration of the methods used in other studies performed in the 
 Response to Comments 

 Page 5 of 40 

 Permit No. NJ0005444 

source waterbody. The sampling plan must include a description of the study area 

(including the area of influent of the cooling water intake structure(s)), and provide a 

taxonomic identification of the sampled or evaluated biological assemblages (including 

all life stages of fish and shellfish). 

As noted by the commentor, BL England specified in its PIC that closed cycle cooling was 

already in place for Unit 3 but also provided a list of ten design and construction technologies for 

the once through cooling system as per 40 CFR 125.95(b)(1)(i) above. However, the objective 

of the PIC is to describe what studies will be evaluated and does not specify that certain intake 

protection technologies, such as closed cycle cooling, must be evaluated. On January 4, 2006, 

the NJDEP approved the PIC as it was consistent with the scope of the rule at 40 CFR 

125.95(b)(1)(i) and addressed all necessary components. In sum, NJDEP found the PIC to be 

fully compliant with the then effective Phase II Section 316(b) regulations. 

Based on the remand of the Phase II Section 316(b) regulations, EPA directed states and 

permitting authorities to proceed at their discretion with respect to the CDS requirements. The 

NJDEP carefully considered the court decision and affected sections of the rule in determining 

what was useful and appropriate within the context of the CDS for all affected facilities. As a 

result, the NJDEP determined that the Source Waterbody Flow Information and the Impingement 

Mortality and/or Entrainment Characterization Study (40 CFR 125.95(b)(2) through (3)) were 

still appropriate and required to be submitted. However, given the remand of the Phase II rule 

and uncertainty as to any future study requirements, NJDEP waived the study requirements for 

technology and compliance assessment information; a restoration plan; information to support 

site-specific determination of BTA (BTA) for minimizing adverse environmental impact and a 

verification monitoring plan. Specifically, compliance assessment information was no longer 

appropriate as the numerical standards for impingement and entrainment were remanded. This 

determination was appropriate given the Second Circuit Court’s position on the technology and 

restoration portion of the rule and was within NJDEP’s authority at 40 CFR 401.14. 

NJDEP disagrees with the commentor’s assertion that the 2009 permit renewal application did 

not contain the necessary Section 316(b) information. Rather, the 2009 renewal application 

referred to the voluminous 2008 CDS study which contained an analysis of intake protection 

technologies despite the uncertainty associated with the pending Section 316(b) rule. Upon 

renewal of the permit in 2013, NJDEP utilized the information available which had been updated 

to include the repowering scenario. In preparing the renewal permit, NJDEP determined that 

operation of the existing cooling tower as well as the significant reduction in water withdrawals 

would significantly reduce impingement and entrainment losses. It is NJDEP’s position that this 

flow reduction is more stringent than the requirements of the proposed rule as described further 

in Response 5. In addition, NJDEP determined that the suite of intake protection technologies 

evaluated was sufficient given the site-specific information regarding the plant and the language 

contained in the pending EPA rule. 

Comment 3 

B.L. England’s cooling water intakes have significant adverse impacts that include killing 
 Response to Comments 

 Page 6 of 40 

 Permit No. NJ0005444 

billions of organisms per year. To quantify impingement and entrainment, B.L. England’s 

owners conducted impingement and entrainment mortality studies in 1998-1999 and again in 

2005-06, using similar methodologies each time. In 1988-89, sampling found 80 species 

impinged and 134 species entrained. In 2005-06, at least 60 species were impinged and 132 

species entrained. The mean annual density of organisms impinged and entrained was nearly 

constant across time. However, the total number of organisms killed dropped by about a third in 

recent data, from around 3 billion organisms in 1988-89 (3.05 billion), down to around 2 billion 

organisms (1.92 billion) in 2005-06. But since the density of entrained organisms did not 

change more than a fraction of a percent, the difference in the number of organisms killed can 

only be attributable to a reduced intake flow used in extrapolating the 2005-06 sampling out to 

annual numbers. 

For the next few years, the plant’s design intake flow will remain 294.3 MGD. After 

repowering, B.L. England will continue to withdraw 167.6 MGD of cooling water unless NJDEP 

requires a move to closed-cycle cooling. Since there are no enforceable flow or generating 

capacity limitations written into the Draft Permit, NJDEP’s BTA determination must be based on 

avoiding the harm that would occur at these design flows. Even at a flow of 167.6 MGD, B.L. 

England will withdraw 600,000 cubic meters of water from Great Egg Harbor Bay daily, or more 

than 231 million cubic meters of water every year resulting in the killing of billions of organisms 

a year. 

 

Response 3 

Repowering this existing facility will result in the operation of two units - one with a cooling 

tower and the other at significantly reduced water withdrawal volumes. NJDEP maintains that 

these technologies will significantly reduce impingement and entrainment losses and that these 

reductions are in line with the proposed EPA 316(b) rule as described in Responses 1 and 2. 

NJDEP recognizes that there are impacts resulting from cooling water intakes. The Draft 2013 

permit contains numerous charts and information regarding historical and current impingement 

and entrainment data. As noted by the commentor, aquatic organisms are present at certain 

densities in intake water. By reducing the amount of water withdrawn, there is a commensurate 

reduction in impingement and entrainment losses as described in Response 1. Entrainment 

impacts are linked to the amount of water passing through the intake structure because the eggs 

and larvae of some aquatic species are free-floating and may be drawn with the flow of cooling 

water into an intake structure. Impingement impacts are also related to intake flow since swim 

speeds of affected species as well as intake velocity are factors in predicting rates of 

impingement based on the ability of juvenile and adult life stages of species to avoid 

impingement. The Section 316(b) statute requires that these impacts be minimized through 

intake protection technologies. NJDEP maintains that the most effective way to reduce 

impingement and entrainment is through a reduction in water withdrawal. 

While the commentor is correct in that this permit does not specify flow limits, this permit does 

require monitoring of intake flow volume. 
 Response to Comments 

 Page 7 of 40 

 Permit No. NJ0005444 

Comment 4

NJDEP’s failure to consider the use of cooling towers at B.L. England is arbitrary, capricious, 

unreasonable, and violates the express requirement of Section 316(b). First, the absence of any 

cooling tower analysis is inconsistent with NJDEP’s recent BTA determination process at other 

power plants. NJDEP changed its practice for B.L. England without explanation and did not 

look at whether cooling towers are technically or economically feasible. Second, the failure to 

consider closed-cycle cooling contradicts the approach laid out in the draft 1977 EPA guidance 

document that NJDEP claims to rely upon in making BTA determinations such as in the 2005 

B.L. England renewal permit. In the 1977 EPA guidance document, EPA stated that 

closed-cycle cooling is not the inevitable outcome of every BPJ-based BTA determination, but 

rather the appropriate technology is best determined after a careful evaluation of the specific 

aspects at each site. As noted in the 1977 EPA guidance document: 

Where environmental impact from entrainment must be minimized reliance must be placed 

primarily on flow reduction and intake relocation as remedial measures: Reducing cooling 

water flow is generally an effective means for minimizing potential entrainment impact. In 

fact, this may be the only feasible means to reduce impact of entrainment . . . Reduction of 

flow is accomplished primarily by an increase in condenser temperature rise or through 

recirculating cooling systems. 

 

In its 2005 Fact Sheet NJDEP characterized the B.L. England intake as being located in a shallow 

estuarine environment. NJDEP has stated in other permit actions that these environments tend 

to have greater ecological impacts since these areas are usually more biologically productive. 

As per the above EPA document, this is the type of scenario in which entrainment must be 

minimized and cooling towers must be considered. Further, the need to evaluate the use of 

cooling towers in connection with this repowering is all the more obvious at a site like B.L. 

England since one natural draft cooling tower has already been in use for decades, proving that 

cooling tower technology is available and feasible at this site. 

 

Finally, NJDEP’s failure to consider the use of a cooling tower for the new Unit 4 contradicts 

EPA’s latest guidance on BTA Determinations namely the 2011 proposed regulation. While 

NJDEP refers to these draft regulations in the process of reaching its BPJ based BTA 

Determination, NJDEP missed the fact that it would be required to evaluate the use of cooling 

towers at every existing facility in the state as per 40 C.F.R. § 122.21(r)(10)(i)(A). 

Response 4 

With respect to the claim that the BTA analysis is inappropriate, NJDEP maintains that it 

included a site-specific BTA determination in the Draft 2013 permit that is consistent with 

Section 316(b) as described in Response 1. To further elaborate, NJDEP is not requiring the 

facility to install cooling towers for Unit 4 for the following site-specific reasons: 

• BL England already operates a closed cycle cooling system at Unit 3. 
 Response to Comments 

 Page 8 of 40 

 Permit No. NJ0005444 

• B.L. England is significantly reducing its water withdrawal for once-through cooling by 

43% with a commensurate reduction in impingement and entrainment; 

• There is no final EPA regulation requiring cooling towers at existing facilities. 

• The proposed EPA regulation requires “study” of entrainment controls which could 

include closed-cycle cooling for plants that have an actual intake flow of 125 MGD. 

Most importantly, NJDEP does not agree that the Section 316(b) statute requires NJDEP to 

require closed cycle cooling nor does NJDEP agree that the final regulation will mandate closed 

cycle cooling for existing facilities. As stated on page 22207 of the April 20, 2011 Federal 

Register for the proposed Section 316(b) regulation: 

...EPA has determined that closed cycle cooling is not the “BTA” for this proposal. After 

considering all of the relevant factors, EPA proposes that it should not establish a uniform 

BTA entrainment standard based on closed-cycle cooling for existing facilities other than for 

new units. Instead...EPA is proposing that the permitting authority should establish BTA 

entrainment mortality controls on a site-specific basis.. 

As stated on page 22283 of the proposed rule: 

§125.93 (c) BTA standards for entrainment mortality for existing facilities. The Director 

must establish BTA standards for entrainment mortality on a case-by case basis. These 

standards must reflect the Director’s determination of the maximum reduction in entrainment 

mortality warranted after consideration of all factors relevant for determining the BTA at 

each facility, including the factors specified in § 125.98. 

And on page 22288 of the proposed rule: 

§ 125.98 (e) Site-specific entrainment mortality controls. The Director must establish 

case-by-case BTA standards for entrainment mortality for any facility subject to such 

requirements after reviewing the information submitted under 40 CFR 122.21(r) and § 

125.95...The Director may reject an otherwise available technology as BTA standards for 

entrainment mortality if the social costs of compliance are not justified by the social 

benefits... If all technologies considered have social costs not justified by the social benefit, 

or have unacceptable adverse impacts that cannot be mitigated, the Director may determine 

that no additional control requirements are necessary beyond what the facility is already 

doing. 

In sum, NJDEP maintains that the Section 316(b) determination is legally appropriate. Please 

refer to Response 6 for a more detailed discussion of BTA analysis at other NJ power plants and 

site-specific considerations. 

Regarding use of the 1977 EPA guidance document in NJDEP’s BPJ determination, NJDEP 

maintains that more recent documents are more relevant to the current NJPDES renewal. For 

example, it is more appropriate to look to the 2011 proposed rule as an indicator of the 

requirements of the 2013 final rule in developing the BL England permit conditions. 
 Response to Comments 

 Page 9 of 40 

 Permit No. NJ0005444 

Nevertheless, contrary to the commentor’s contention, NJDEP maintains that the 1977 guidance 

document excerpt quoted here is consistent with the 2013 permit determination since the 1977 

guidance document points to the benefits of flow reduction technology which is the cornerstone 

of the 2013 draft NJPDES decision. 

With respect to the third part of this comment, NJDEP agrees that estuaries are biologically 

productive and that entrainment effects must be minimized. This further supports the approach 

of reducing water withdrawals as BL England is proposing to do under repowered plant 

conditions. 

Finally, NJDEP agrees with the contention that EPA’s proposed text at 40 C.F.R. § 

122.21(r)(10)(i)(A) requires consideration of cooling towers where all eligible New Jersey 

facilities, including B.L. England, will be required to comply with the proposed rule 

requirements upon finalization. This text reads as follows: 

The owner or operator of the facility must submit an engineering study of the technical 

feasibility and incremental costs of candidate entrainment mortality control technologies. . . 

At a minimum, the owner or operator of the facility must conduct a study to evaluate the 

technical feasibility of closed-cycle recirculating systems (cooling towers). . . 

However, note that this is a proposed rule that sets forth these study requirements. The rule 

must be finalized before the permittee is required to comply with the conditions of the rule. It 

would not be appropriate for NJDEP to pre-judge the outcome of a study for which the 

requirements have not yet been finalized and therefore technically not even yet required. 

Comment 5 

A proper BPJ analysis of closed-cycle cooling towers would have found it to be the BTA. In the 

2006 NJPDES permit for the PSEG Mercer power plant, NJDEP concluded that “closed cycle 

cooling is considered by NJDEP to be the best technology” for protecting fish at intakes, and the 

question remaining for NJDEP henceforth would be whether the technology is “available” at a 

particular site. No other technology approaches the environmental effectiveness of closed-cycle 

cooling. In its Technical Development Document for the proposed rule, EPA has looked at 

every technology from strobe lights and bubble curtains to wedgewire screens, but found many of 

them to be of questionable effectiveness and feasibility. Of those technologies that EPA selected 

for further study, it found that the next most effective technologies to closed-cycle cooling only 

reduce mortality from impingement, but can do little or nothing to reduce entrainment of early 

life stage organisms such as free floating larvae and eggs. Without reducing intake volume, 

EPA estimates that, on average, the next best alternatives to closed-cycle cooling can only reduce 

fish kills by about 31%. 

 

NJDEP argues that a 43% reduction in cooling water intake caused by the shutdown of Unit 1 is 

a significant gain. NJDEP has not explained why a 43% reduction is acceptable and consistent 

with use of the BTA when a 90% reduction is readily achievable through closed-cycle cooling. 

 
 Response to Comments 

 Page 10 of 40 

 Permit No. NJ0005444 

Response 5 

NJDEP agrees that there are limited technologies to address entrainment. The best way to 

address entrainment is through flow reduction as described in Response 1. An important 

consideration in NJDEP’s determination for BL England is the fact that impingement and 

entrainment reductions will be realized as soon as 2016. Specifically, Unit 3 will continue to 

operate with closed cycle cooling. Unit 4 will operate at a 43% reduction as compared to the 

current once-through cooling system. In comparison, the proposed rule at 122.21(r)(2) through 

(12) requires the study and submission of numerous application components including the 

following: 

• Source water physical data 

• Cooling water intake structure data 

• Source water baseline biological characterization data 

• Cooling water system data 

• Proposed impingement mortality reduction plan 

• Performance studies 

• Operational status 

• Entrainment characterization study (peer reviewed) 

• Comprehensive technical feasibility and cost evaluation study 

• Benefits valuation study 

• Non-water quality and other environmental impacts study 

The range of due dates for these inherently complex study components ranges from 3 years to 7.5 

years from the finalization of the rule. It is possible that applicants will conclude that additional 

entrainment reduction technologies are not justified. These studies will then need to be 

reviewed and evaluated by the permitting agency and could result in additional entrainment 

reduction technologies where a compliance schedule could be required. In contrast, the 

entrainment reduction benefits at BL England based on the water withdrawal reductions will be 

realized as soon as 2016. 

It is important to note that NJDEP has included requirements to ensure that impingement benefits 

are realized sooner than the rule. As noted in this comment and in the March 28, 2011 EPA 

Technical Development Document that was prepared as part of the rule, the benefits of modified 

Ristroph traveling screens are well proven. NJDEP agrees that modified Ristroph screens are 

beneficial as noted in the 2013 draft permit: 

The Department has repeatedly gone on record through its comments on EPA’s rule making 

effort as well as through individual permit actions that Ristroph traveling screens are a 

proven and effective technology to minimize impingement mortality. Constant rotation and 

screen washes serve to reduce impingement mortality by assisting organisms into the fish 

return system, which should discharge below the tide level. Modified Ristroph traveling 

screens are particularly effective in reducing impingement mortality for blue crab, a species 

which has the highest impingement rate at BLE. 
 Response to Comments 

 Page 11 of 40 

 Permit No. NJ0005444 

Yet while modified Ristroph screens are a proven and effective technology, EPA has stated that 

technologies used to meet the impingement requirements of the final rule upon adoption would 

have to be implemented as soon as possible but within eight years at the latest. In contrast, 

NJDEP is requiring an expedited schedule for study of impingement screens. As stated in the 

2013 draft permit: 

The permittee shall submit the Impingement Alternatives Analysis on or before EDP + 15 

months. The permittee shall submit these technical findings to the Department as indicated in 

Part IV. Upon receipt of this information, the Department will evaluate the findings in 

concert with the final EPA regulations and will reopen the permit to incorporate permit 

conditions pursuant to N.J.A.C. 7:14A-16.4. 

In sum, NJDEP maintains that its 2013 draft permit determination addresses both impingement 

and entrainment in a proactive manner. 

Comment 6 

NJDEP has already determined that closed-cycle cooling is the BTA at the Oyster Creek power 

station. Although Oyster Creek is a larger power station (645 MW) that withdraws almost twice 

the amount of cooling water, it is also located in an estuary on the New Jersey Shore. And based 

on sampling conducted from 2005 to 2007, entrainment at Oyster Creek appears to be lower than 

at B.L. England. At Oyster Creek, NJDEP evaluated a wide array of alternative control 

technologies and determined that BTA for the facility was closed-cycle cooling. NJDEP 

focused on the fact that closed-cycle cooling reduces water intake usage significantly, thereby 

decreasing impingement and entrainment effects; and is one of the few technologies able to do 

so. 

B.L. England is substantially similar to other facilities for which EPA and other permitting 

agencies have required installation of closed-cycle cooling. U.S. EPA Region 1 required 

installation of cooling towers at the Brayton Point power plant in Fall River, Massachusetts 

which is also located on a shallow estuarine bay and withdraws copious amounts of cooling 

water. The New York Department of Environmental Conservation (NY DEC) recently deemed 

closed-cycle cooling to be BTA for the E.F. Barrett power station (362 MW) where the receiving 

water supports a finfish community similar to that in Great Egg Harbor Bay with lower levels of 

entrainment. NY DEC evaluated a wide array of alternative control technologies. DEC based 

its determination that cooling towers were BTA on several factors and noted that the technology 

would significantly reduce the number of eggs and larvae entrained and impinged “more than any 

other technology or operational measure available to reduce aquatic impacts.” NY DEC also 

noted the ancillary benefits in abating thermal discharge issues at E.F. Barrett. 

Response 6 

It is difficult to compare Section 316(b) determinations across the nation for a variety of reasons. 

First, there are many site-specific factors that must be taken into account in defining available 

intake protection technologies such as remaining useful plant life, air emissions, space 
 Response to Comments 

 Page 12 of 40 

 Permit No. NJ0005444 

constraints, etc. Secondly, Section 316(b) determinations have occurred over time at various 

stages in the Section 316(b) rule evolution. Third, while some permitting agencies may be 

requiring closed-cycle cooling, many of these decisions were never finalized or are pending in 

court. NJDEP has provided background information on all of the plants cited in this comment. 

With respect to NJDEP’s BTA determination regarding the Oyster Creek Generating Station in 

Forked River, NJ, the currently effective NJPDES permit was issued in 2011 and states the 

following: 

Pursuant to the December 9, 2010 Administrative Consent Order (“ACO”), Exelon is legally 

required to Terminate Operations, as that term is defined in the December 9, 2010 ACO, no 

later than December 31, 2019. As a direct result of this requirement, the Department has 

determined that closed cycle cooling is not the BTA given the length of time that would be 

required to retrofit from the existing once-through cooling system to a closed-cycle cooling 

system and the limited life span of the facility after implementation of the closed-cycle 

cooling system. The facility has physical limitations which constrain the location and types of 

closed-cycle cooling systems that could be installed. As stated in the January 7, 2010 draft 

permit, the length of time required to design, permit, and construct closed-cycle cooling 

technology at the facility would likely be at least seven years and would involve significant 

costs. 

As noted above, the rationale for this decision was based on the site-specific information 

regarding the facility. There were also a number of other environmental impacts associated with 

cooling towers as cited in NJDEP’s 2011 Oyster Creek determination which are as follows: 

• The height and visual obtrusion of the towers 

• The impingement and entrainment impacts relating to the withdrawal of water for cooling 

tower make-up water 

• The effects of the cooling tower blowdown on marine biota and populations 

• Tower vapor plume effects due to size, frequency, or trajectory, including icing and fogging 

effects 

• Impacts to traffic visibility on nearby roads and highways 

• Salt drift from the towers on the nearby community 

• Noise impacts on neighbors 

• Impacts of particulate emissions on air quality including potential impact on soils, vegetation 

and visibility. 

NJDEP is also aware of the Dominion Brayton Point Power Station in Somerset, Massachusetts 

where US EPA Region 1 required the retrofit of the existing cooling water system with cooling 

towers. The Brayton Point facility is a coal-fired facility that generates a total of 1538 MW 

making it New England’s largest fossil-fueled generating facility. However, the ultimate 

requirement to install cooling towers occurred after decades of technical review and eventual 

court action. Also, a major issue associated with the once-through system stemmed from the 

notable and well documented thermal impacts of the plant on the winter flounder population in 

Mount Hope Bay. NJDEP maintains that this is a very separate situation from BL England. 
 Response to Comments 

 Page 13 of 40 

 Permit No. NJ0005444 

Regarding the E.F. Barrett plant in New York, please note that this decision is out in draft form. 

Given the intricacies and uncertainties of the pending rule, it is possible that this determination 

could change especially in light of finalization of the Section 316(b) regulation. This is also true 

of the Indian Point, Merrimack and Mirant Canal decisions by other permitting authorities. 

In contrast, finalization of this permit for BL England will result in a 43% reduction in intake 

volume where those benefits will be realized as soon as 2016. 

Comment 7 

Although it has no legal obligation to do so, NJDEP typically compares the costs and benefits of 

different technologies in its BTA determination to ensure that the costs of the technology selected 

as the best available are not wholly disproportionate to the benefits gained by its implementation. 

In 2010, Robert Johnston, who is a professor of economics at Clark University, provided an 

economic analysis of the benefits of reducing impingement and entrainment. Professor Johnston 

explained that “[a]ll evidence indicates that economic benefits from impingement and 

entrainment (I&E) reductions are significant.” But he also warned NJDEP that the evidence can 

be difficult to collect simply by looking at conventional economic data since the economic 

benefits of saving fish and other organisms “are non-market economic benefits that are (1) 

unrelated to the direct use of affected species in markets, and (2) only measurable using 

non-market valuation methods capable of estimating both use and nonuse values. As a result, 

reliance on market data alone to estimate benefits of I&E reductions will lead to gross 

underestimates of total benefits.” 

In the past, at power plants such as the Mercer Generating Station, NJDEP has based its wholly 

disproportionate analysis on deeply flawed cost-benefit studies provided by power plant owners 

that looked at market data for commercially fished species and zeroed-out the value of all 

non-commercial species of fish. Thus, NJDEP has grossly underestimated the total benefits of 

reducing impingement and entrainment. 

 

This problem is not unique to New Jersey. For many years, EPA had recognized that the 

benefits of protecting fish, shellfish and other aquatic organisms from destruction by cooling 

water intake structures were significant, but had no way to quantify these benefits. So in late 

2011, U.S. EPA conducted a national stated-preference study to address cost-benefit analyses for 

cooling water intake regulation where the initial results were released in the summer of 2012. 

The results of EPA’s study were clear in that the monetized benefits of closed-cycle cooling 

greatly exceed its costs by a large margin across the United States. EPA estimated the net 

present cost of different technologies for reducing impingement and entrainment of fish and 

compared them to the net present value that Americans are willing to pay for the environmental 

benefits of these technologies. The results of the comparison indicate that the net environmental 

benefits from modernized cooling systems will be at least $5 - $7 billion annually, even under a 

series of highly conservative and unrealistic assumptions. Other estimates conclude that the 

benefits are more likely in the range of $13 to $18 billion. 

 
 Response to Comments 

 Page 14 of 40 

 Permit No. NJ0005444 

EPA’s survey design was methodologically rigorous and vetted by outside experts and 

government economists. NJDEP should look to EPA’s research and conclude that the benefits 

of a closed cycle cooling system are substantial and are not wholly disproportionate to the costs; 

thus a closed cycle cooling system is the BTA at B.L. England. 

Response 7 

 

The commentor is correct in that NJDEP has historically issued findings with respect to costs and 

benefits as part of its BTA determination. The "wholly disproportionate" standard originated 

from case law along with the precedent that NJDEP carries the burden in proving that the costs of 

an intake protection technology are not wholly disproportionate to the environmental benefits. 

See, e.g., In re Central Hudson Gas and Electric Corporation, et al., Opinion No. 63, July 29, 

1977, 1977 WL 28250, *8 (E.P.A.G.C.), In The Matter of Public Service Company Of New 

Hampshire, et al. (Seabrook Station, Units 1 and 2) National Pollutant Discharge Elimination 

System Permit, 1978 WL 21140, 1 E.A.D. 455 (E.P.A., Aug 04, 1978) (No. APPLICATION NH 

00203, 76-7). NJDEP also agrees that cost/benefit studies are typically prepared by the 

permittee. NJDEP then reviews these studies against applicable laws and guidance that are 

available at that time. Given the absence of a Section 316(b) regulation for such a long period, 

NJDEP has had to rely on relevant case law. 

Regardless of past practice, the 2011 proposed rule sets a new playing field. Specifically, the 

proposed 2011 rule continues with a requirement for a permittee of BL England’s size to submit 

a cost evaluation study as well as a benefits evaluation study which is due within 7.5 years from 

rule finalization. NJDEP did voice concerns on the difficulty of using societal costs and benefits 

in a site-specific BTA determination. As noted in NJDEP’s August 17, 2011 comments on the 

draft rule: 

 

NJDEP supports the decision of entrainment to be left to the states as well as the 

consideration of the following factors specified in 125.98(e) namely: (1) numbers and types 

of organisms entrained; (2) entrainment impacts on the waterbody; (4) thermal discharge 

impacts, (5) impacts on the reliability of energy delivery within the immediate area; (6) 

impact of changes in particulate emissions or other pollutants associated with entrainment 

technologies, (7) land availability; (8) remaining useful plant life; and (9) impacts on water 

consumption. 

However, NJDEP does not support item (3), namely the consideration of quantified and 

qualitative social benefits and social costs of available entrainment technologies including 

ecological benefits and benefits to any threatened or endangered species. Under the 

proposed rule States can require an available technology (e.g. cooling towers) if the social 

costs of compliance are justified by the social benefits. Social costs encompass a long list of 

factors including non-water quality costs such as changes to energy consumption, estimates 

of air emissions, noise, etc. whereas social benefits include non-market benefits such as a 

household’s “willingness to pay” for the protection of fish based on a sense of altruism. 

Evaluating costs and benefits at the “social level” is inherently complex, subjective and 

almost impossible to quantify particularly with respect to non-market values. 
 Response to Comments 

 Page 15 of 40 

 Permit No. NJ0005444 

In fact, as part of its effort on the rule-making, EPA is developing a stated preference survey 

to estimate total willingness to pay for improvements to fishery resources affected by 

impingement and entrainment mortality from in-scope 316(b) facilities. However, EPA did 

not have sufficient time to fully develop and implement this survey for the proposed 

regulation which serves to illustrate the complexity in defining social benefits. By 

incorporating such an ambiguous and complex test for requiring entrainment technologies, 

EPA has made the state’s ability to require any entrainment technology nearly impossible. 

We also note that having to prove that the social costs are justified by the social benefits is a 

step backward from the currently utilized wholly disproportionate standard found in relevant 

case law. 

 

NJDEP is unclear as to the commentor's suggestion that NJDEP base its decision on EPA's 

national stated-preference study. This survey is relevant to the rule-making effort and in 

evaluating societal costs and benefits as part of the rule. This is not the same as a site-specific 

BTA determination in which NJDEP is evaluating costs and benefits. In addition, as noted in 

Response 3, it is not appropriate to pre-judge the results of an analysis which has not yet been 

formalized and required in a final rule. This issue should be revisited upon finalization of the 

rule. 

Comment 8 

A proper BPJ analysis would have found closed-cycle cooling to be BTA at B.L. England. Such 

analysis assumes, as NJDEP did, that B.L. England is categorized as an existing facility under 

EPA’s proposed regulations for existing facilities rather than a “new facility” under EPA’s Phase 

I regulations for cooling water intake structures. In addition, there are two further reasons 

supporting closed-cycle cooling at B.L. England that differentiate it from other existing facilities. 

 

First, regardless of how it may be categorized under the federal regulations, Unit 4 is effectively a 

new unit and NJDEP should regulate it as such. The repowering project provides an opportunity 

to upgrade the balance of the plant surrounding Unit 4 and, because its operating life will be 

extended, the investment in Unit 4 can be amortized over a considerable lifespan. In the federal 

rulemaking docket, EPA’s technical staff wrote a draft regulation that would have treated a 

repowered facility like B.L. England as a new unit, meaning it would be required to reduce 

impingement and entrainment to levels commensurate with a closed-cycle cooling system. A 

few months before proposal, EPA submitted a draft of its proposed rule to the Office of 

Management and Budget (OMB) for interagency review. EPA released a “redlined” version of 

its proposed rule which reflected OMB’s suggestions and recommendations. EPA asserted that 

repowered units should be treated like any other new unit since repowerings provide the ideal 

opportunity to design and construct the new units without many of the additional expenses 

associated with retrofitting an existing unit to closed-cycle. Based on EPA’s reasoning in that 

internal version of the proposed rule, NJDEP should require closed-cycle cooling. The facilities 

for which NJDEP and other permitting agencies have required installation of closed-cycle 

cooling (e.g. Oyster Creek, Brayton Point, Indian Point, Merrimack and Mirant Canal) are all 

existing facilities. Accordingly, the case for closed-cycle cooling as BTA is even stronger at B.L. 
 Response to Comments 

 Page 16 of 40 

 Permit No. NJ0005444 

England since the above noted existing facilities all must be retrofit after being in operation for many 

years. 

 

Second, the Proposed Rule’s definition of “new unit at an existing facility,” may not hold up in court 

if finalized. EPA’s rationale for why repowerings are akin to new units and new facilities was 

deleted from the proposed regulation at the insistence of the OMB. Because OMB does not have 

technical expertise relevant to evaluating the similarity of repowerings, retrofits and new 

construction its technical decisions about repowerings merit no deference. If EPA’s proposed 

definition of “new unit at an existing facility” is restored to the definition originally developed by 

EPA in 2011, B.L. England’s repowering will be categorized as a “new unit at an existing facility,” 

which would require application of a categorical standard requiring closed-cycle cooling. 

Response 8 

NJDEP appreciates the commentor’s support of NJDEP’s determination that BL England is 

subject to the proposed rules as an existing facility rather than the Phase I final regulations for 

new facilities. As noted in the 2013 Fact Sheet, NJDEP evaluated whether the federal Section 

316(b) regulations under “Phase I” (40 CFR Part 125, Subpart I) were applicable to this facility. 

Phase I regulations are applicable to new facilities and were published in the Federal Register 

Notice dated December 18, 2001 

(http://www.epa.gov/fedrgstr/EPA-WATER/2001/December/Day-18/w28968.htm). As per 40 

CFR § 125.83 the Department determined that BL England is not a “new facility” based on the 

following: 

• BL England is not proposing a greenfield or stand-alone facility but rather is a 

repowered version of an existing facility. 

• The existing cooling water intake structure is being utilized for the repowered units. 

• The design capacity of the existing cooling water intake structure is being decreased 

due to less water use. 

NJDEP also evaluated whether or not Unit 4 met the definition of a “new unit” in the proposed 

rule. New units are required to reduce impingement and entrainment at a level commensurate 

with closed-cycle cooling as per 40 CFR § 125.93(d) of the proposed rule. On page 22282, new 

unit is defined as follows: 

New unit means any addition of an operating unit at an existing facility where the 

construction begins after [effective date of the final rule], including but not limited to a new 

unit added to a new or existing facility for the same general industrial operation, but that does 

not otherwise meet the definition of a new facility at § 125.83. New unit includes any 

additional unit where that unit is not subject to the requirements of Subpart I. For purposes of 

this subpart, new unit refers to newly built units added to increase capacity at the facility and 

does not include any rebuilt, repowered or replacement unit, including any units where the 

generation capacity of the new unit is equal to or greater than the unit it replaces. 

BL England is NOT a new unit since it is repowering its plant. Also BL England is not eligible 

under the Phase I rule at 40 CFR Part 125, Subpart I. As described in the 2013 Fact Sheet: 
 Response to Comments 

 Page 17 of 40 

 Permit No. NJ0005444 

After the repowering project is complete, the power generating capacity of the station will 

increase from 447 MW to 584 MW, which is an increase of 131 MW or approximately 30%. 

While overall energy generating capacity will increase, nitrogen oxide and sulfur dioxide 

emissions will significantly decrease. As noted above, by the date of the repowering on May 

1, 2016, operations from Units 1 and 2 will have ceased. Unit 1 will be retired and Unit 2 will 

cease operations as a coal-fired unit. Unit 3 which now runs on #6 oil will convert to natural 

gas. Unit 4 will consist of a new combined cycle combustion turbine which runs on natural 

gas with a Heat Recovery Steam Generation (HRSG) unit, but will utilize the existing steam 

turbine that was formerly associated with Unit 2. The former Unit 2 steam turbine is 

associated with the circulating cooling water.

In sum, repowering BL England does not qualify as a “new unit” under the proposed rule. 

With respect to the second part of this comment, the commentor is suggesting that NJDEP not 

use the proposed rule definition of new unit and instead rely on an internal version of the rule 

submitted to OMB that is available as part of the docket. In this internal version of the rule, the 

regulatory framework treated “new units” in a different fashion where repowered units would be 

treated as “new units”. NJDEP cannot use an internal version of the rule since internal 

documents are not valid for the purposes of NJDEP in rendering a decision. Instead, NJDEP must 

rely on the proposed rule as drafted. 

The commentor also contends that NJDEP should not utilize the proposed version of the rule 

which changed from this internal version based on input by OMB. The commentor supports this 

suggestion by asserting that OMB does not have technical expertise on issues relating to 

repowering. Again, NJDEP maintains that it would also be legally inappropriate for NJDEP to 

speculate on the appropriateness of input as part of the rule-making process and instead must rely 

on the official proposed version of the draft rule. 

Finally, the commentor is contending that NJDEP abandon this “new unit at an existing facility” 

definition based on the possibility that the proposed rule may not hold up in court upon finalization 

or because OMB does not have appropriate expertise. This is also not legally appropriate or 

defensible. 

Comment 9 

The segment of the Great Egg Harbor Bay into which B.L. England discharges its waste heat is 

impaired for dissolved oxygen. The water quality standard for dissolved oxygen in Great Egg 

Harbor is 5 mg/L averaged over 24 hours, and no less than 4.0 mg/L at any time. The two 

nearest water quality monitoring stations in NJDEP’s Marine Water Monitoring Program are 

Station 2902A and Station 2720B where together these stations give a good indication of the 

water quality in Great Egg Harbor Bay near B.L. England. Further, water quality monitoring 

conducted at Station 2720B shows that this portion of Great Egg Harbor Bay has experienced 

algal blooms and brown tides in the past, most recently an algal bloom in July 2012. Most 

summers, the portion of the Harbor nearest to B.L. England fails to meet this standard. 

 
 Response to Comments 

 Page 18 of 40 

 Permit No. NJ0005444 

The discharge of heat from B.L. England’s once through cooling system contributes to these 

water quality violations. Dissolved oxygen concentrations in water are inversely correlated to 

temperature where hotter water contains less oxygen and colder water holds more oxygen. By 

raising the water temperature, B.L. England reduces its dissolved oxygen concentration. With 

the addition of nutrients and other oxygen demanding substances in the water, the dissolved 

oxygen concentration is far lower. In summertime, average water temperatures in Great Egg 

Harbor Bay typically range from 20-27 degrees Celsius. During summer, when dissolved 

oxygen concentrations are lowest, B.L. England is authorized to discharge water from Great Egg 

Harbor Bay up to a maximum temperature of 38.3 degrees Celsius. This temperature increase 

reduces the maximum oxygen concentration in the discharged water by a quarter, before 

accounting for oxygen demanding substances. 

Response 9 

The commentor is correct in that the receiving waterbody is considered "impaired" for DO. A 

DO impairment is typical for many of the other monitoring stations near the Atlantic Ocean. In 

fact, according to the 2010 303(d) List of Water Quality Limited Waters ("303(d) Report") which 

is part of the “New Jersey Integrated Water Quality Monitoring and Assessment Report,” the 

entire Atlantic coastline from Sandy Hook to Cape May is impaired for DO. 

The commentor is correct in that NJDEP monitors various water quality stations for a number of 

parameters including DO. NJDEP has evaluated the data from the two monitoring stations 

referenced in this comment. Station 2902A is approximately 6336 feet upstream of the facility at 

the mouth of the Tuckahoe River. While the Great Egg Harbor Bay where BL England 

discharges is tidal, this station may be more indicative of the water quality draining from the 

Tuckahoe River given that it is located at the mouth of the Tuckahoe River. The individual DO 

data points from Station 2902A are as follows: 
 Response to Comments 

 Page 19 of 40 

 Permit No. NJ0005444 

Station 2720B is approximately 3942 feet from the facility and is located downstream. The 

individual DO data points from Station 2902 are as follows: 

In reviewing these charts, most individual data points are well above the instantaneous minimum 

value of 4.0 mg/L and average values are above the 5.0 mg/L average. In addition, there are 

many other confounding factors that also contribute to dissolved oxygen levels in a waterbody 

such as non-point pollution effects, other dischargers, weather, etc. While point source 

discharges are regulated through NJPDES permits, these other non-point sources are not directly 

regulated. 

The Department does not agree that the Great Egg Harbor Bay is experiencing objectionable 

algal densities and nuisance aquatic vegetation. With respect to the contention regarding an 

algal bloom in July 2012 at Station 2720B, data downloaded from the NJDEP Bureau of Marine 

Water Monitoring website states the following: 

Date Time Water Temp. (oC) Chlorophyll 

(μg/L) 

Dominant Species Toxic 

Species* 

7/12/12 10:42am 26.5 2.10 Sparse algal 

concentrations 

None Present 

7/18/12 9:56am 28.2 7.99 Thalassiosira sp. (200 

cells/mL) 

None Present 
 Response to Comments 

 Page 20 of 40 

 Permit No. NJ0005444 

 

Comments from the July 19, 2012 Report: The waters of Great Egg have low levels of 

Thalassiosira sp (200 cells/mL). No toxic species were detected. 

 

The Department does not agree that the fact that algae is present is equivalent to an algal bloom. 

Finally, with respect to the contention that BL England is contributing to the DO impairment, 

there currently is no discharge data to prove this contention. It would be inappropriate to 

assume that DO levels from BL England are the cause of the impairment given this lack of 

discharge data as well as the many other contributing factors to DO levels. It would also be 

inappropriate to deny BL England a NJPDES permit based on this assumption. Additional 

information regarding the appropriateness of discharge requirements for DO at the surface water 

outfalls is included in Response 11. 

Please refer to Response 10 regarding discharge requirements for DO at the surface water 

outfalls. 

Comment 10 

Under N.J.A.C. 7:14A-13.5(a), the Department must establish water quality based effluent limits 

to protect water quality. But NJDEP has not set any limits on the dissolved oxygen content of 

the cooling water, on the organic matter released at DSNs 008A, 009A, and 010A, or on any 

other parameter to address the discharge of heat and nutrients from these outfalls. 

 

The absence of water quality based effluent limits is surprising given that NJDEP has set 

dissolved oxygen limits at DSN 013A; namely a 24-hour average limitation of 5.0 mg/L and an 

instantaneous minimum limitation of 4.0 mg/L. These effluent limits are equivalent to the water 

quality criteria for dissolved oxygen that apply to saline estuaries pursuant to N.J.A.C. 

7:9B-1.14(d). By requiring that the discharge meets the in-stream water quality criteria at the 

point of discharge, NJDEP ensures that the discharge from DSN 013A does not cause or 

contribute to a violation of water quality standards. Yet the discharge from DSN 013A is 

presently 0.69 MGD, and will drop to just 0.22 MGD after repowering. In comparison, the 294 

MGD of heated, nutrient-laden discharge from the cooling water system is hundreds of times 

larger and likely to have a far more significant impact, especially in the summertime, even at 167 

MGD later. NJDEP must establish heat and dissolved oxygen effluent limits for DSN009A and 

DSN010A that require the discharge to immediately meet a 24-hour average limitation of 5.0 

mg/L and an instantaneous minimum limitation of 4.0 mg/L. 

 

In the Fact Sheet, NJDEP places substantial emphasis on the possibility that “the repowered 

operating conditions and closure of Unit 1 will result in a significant [cooling water] discharge 

flow reduction.” But the anticipated changes to the discharge from the planned repowering are 

legally irrelevant to NJDEP’s renewal of this NJPDES permit today because they take place in 

the future. While NJDEP considers them to be likely, its legal obligation is to write a permit 

that adequately controls the discharge that exists today. 
 Response to Comments 

 Page 21 of 40 

 Permit No. NJ0005444 

Response 10 

Generally, DO is a parameter that is included in wastewater discharges, not in cooling water 

discharges. According to the State of Michigan 

(http://www.michigan.gov/documents/deq/wb-npdes): 

Dissolved oxygen limits are commonly placed in permits for discharges which have the 

potential to exert an oxygen demand. These types of discharges include effluent from 

wastewater treatment plants, food processing and manufacturing operations and landfills. 

Dissolved oxygen limits are not necessary for all permits, such as discharges of clear 

non-contact cooling water, where levels of dissolved oxygen are expected to be high. 

DO limits or monitoring requirements are not applied to cooling water discharges at other 

NJPDES permits for power plants. Similarly, DO is not specified as a discharge requirement in 

the Federal Effluent Limitation Guidelines for the Steam Electric Power Generating Point Source 

Category at 40 CFR 423 nor in the Steam Electric Power Generating Point Source Category: 

Final Detailed Study Report (EPA-821-R-09-008, DCN 06390, October 2009). Finally, a direct 

DO permit limitation has not been applied to any of the NPDES permits referenced in the 

comments submission in other states, namely Indian Point, Mirant Canal, E.F. Barrett and 

Merrimack. 

Nonetheless, the Department recognizes the commentor's concern in that DO levels can be 

related to heat. The Department maintains that BL England is regulated for temperature in a 

holistic fashion by use of an effluent temperature limit, a temperature differential limit and an 

overall heat limit. Therefore, as a conservative and proactive measure, the Department is adding 

a DO monitoring requirement to the cooling water outfalls, namely DSN 001A, 009A and 010A, 

as well as to the intake at DSN 010A. This will allow the Department to track both the intake 

and effluent to assess any contributions from the heated discharge. Part IV also contains a 

reopener clause at Part IV F.2. that would allow NJDEP to incorporate DO limits through a 

major permit modification if deemed necessary based on submitted data. The incorporation of 

more frequent monitoring in a final permit action is allowable under N.J.A.C. 7:14A-16.5. 

This change affects Tables III-A-1, III-E-1, and III-F-1 where DO monitoring has been included. 

Comment 11 

The dead, rotting organisms that are entrained and killed by the cooling system are discharged at 

DSNs 009A and 010A thereby contributing to the dissolved oxygen impairments in Great Egg 

Harbor Bay. Also, dead fish are sprayed off the screens and discharged at DSN 008A. The 

discharge of all these dead organisms adversely effects dissolved oxygen levels and is equivalent 

to dumping several tons of fertilizer into Great Egg Harbor Bay every year. 

 

As explained above, the area of Great Egg Harbor Bay adjacent to B.L. England has experienced 

algal blooms and is unsuitable for its designated uses due to dissolved oxygen levels. NJDEP 

has identified “agriculture” – i.e. nutrient runoff – as one cause of this impairment. Therefore 
 Response to Comments 

 Page 22 of 40 

 Permit No. NJ0005444 

the uncontrolled discharge of nutrients from DSNs 008A, 009A, and 010A causes or contributes 

to violation of both the dissolved oxygen and nutrient water quality standards and must be 

subject to effluent limits. 

Response 11 

 

NJDEP cannot place limitations on the amount of detritus and dead organisms that are released 

through a discharge. Rather, the appropriate regulatory mechanism is the federal Section 316(b) 

regulations as described in Responses 1 through 8. The approach to Section 316(b) is not to 

directly limit the amount of dead organisms and detritus that can be discharged but rather to 

require the installation of intake protection technologies to minimize impingement and 

entrainment losses. For example, the proposed rule requires an impingement mortality standard. 

As stated in Response 5, this permit requires an expedited study of modified Ristroph traveling 

screens with fish buckets where the screens are continuously rotated with a dual pressure spray 

wash and fish are then returned via a non-abrasive fish return system. These measures are 

expected to decrease impingement mortality, which will in turn reduce the quantity of dead 

organisms that are returned to the waterbody. Screens can address impingement mortality; for 

example, even with the simplified screen system at the current intake structure, blue crabs show 

median survivability of 92.7% in recent impingement data. With respect to entrainment, many 

early life stage organisms can survive entrainment where survivability varies from species to 

species and is often dependent on life stage. Nonetheless, permitting agencies frequently 

assume 100% entrainment mortality in evaluating entrainment technologies since it is difficult to 

quantify entrainment mortality for each species and life stage. This analysis will be part of any 

review of an entrainment mortality study as required under the proposed Section 316(b) 

regulations upon finalization. 

The Department agrees that the SWQS address nutrients at N.J.A.C. 7:14A-1.14(d), namely 

phosphorus and nitrogen. As noted in this comment, this citation states the following: 

Except as due to natural conditions, nutrients shall not be allowed in concentrations that 

render the waters unsuitable for the existing or designated uses due to objectionable algal 

densities, nuisance aquatic vegetation, diurnal fluctuations in dissolved oxygen or pH 

indicative of excessive photosynthetic activity, detrimental changes to the composition of 

aquatic ecosystems, or other indicators of use impairment caused by nutrients. 

The commentor is implying that this requirement must be applied directly to the discharge. 

However, because the SWQS set standards for the stream, this requirement applies to the 

waterbody and not the direct discharge. The purpose of the SWQS is to set standards for the 

waterbody whereas the NJPDES permit sets standards for the discharges in order to ensure that 

the SWQS are attained. While it is true that NJDEP sometimes applies SWQS as end-of-pipe 

effluent limitations for facilities on impaired waterbodies, this is only when there is a 

demonstrated link showing that the discharge contributes to this impairment. The permittee’s 

discharge data must show cause or the reasonable potential to cause a violation of the SWQS in 

order for NJDEP to calculate and apply a WQBEL for phosphorus or nitrate. B.L. England does 

not add phosphorus or nitrate in the discharges from the cooling towers and the screen backwash. 
 Response to Comments 

 Page 23 of 40 

 Permit No. NJ0005444 

Also, it is difficult to apply a narrative criteria such as that cited above at end-of-pipe. 

 

Finally, the Department does not agree that impinged or entrained organisms can be equated to 

"agriculture". 

Comment 12 

Instead of establishing water quality based effluent limitations, NJDEP is proposing to renew 

B.L. England’s alternative heat limits set under the Clean Water Act section 316(a) variance 

provision. NJDEP explained that its intent to renew the variance is based primarily on the fact 

that the overall discharge of heat from B.L. England is decreasing yet this analysis is flawed in 

several ways. 

First, it is unreasonable for NJDEP to rely directly on there being less heat discharged presently 

than was discharged when the 316(a) variance was last renewed in 2005 since Great Egg Harbor 

Bay was not yet listed as impaired for dissolved oxygen. The relevant question is whether the 

alternative heat limit proposed for the period before and after the repowering is acceptable in 

light of the impairment. Because an alternative heat limit would cause or contribute to 

exceedances of water quality standards, it is not acceptable. 

 

Second, the proposed 316(a) variance determination places significant emphasis on the plant’s 

total heat load dropping with the removal of Unit 1 but NJDEP is allowing B.L. England to 

increase the temperature of the discharge in summertime by several degrees in order to run 

supplementary burners (duct burners). NJDEP believes that the reduced overall heat load will 

shrink the outer zone of the thermal plume, the 1.5 degree isotherm, by around 30% yet the “zone 

of initial dilution” will increase in both size and temperature. Thus, the repowered plant will 

actually expand the area of Great Egg Harbor Bay that is unfit for aquatic life. 

Finally, the proposed variance is unlawful since the permittee’s burden of proof is to demonstrate 

that the alternative limit will assure protection of a balanced indigenous population of shellfish, 

fish and wildlife considering the cumulative impact of its thermal discharge together with all 

other significant impacts on the species affected. Neither B.L. England’s request for a variance 

nor NJDEP’s proposed variance determination discuss the cumulative impact of increased heat, 

nutrients, and low dissolved oxygen levels on the health of Great Egg Harbor Bay and its 

denizens. 

 

Response 12 

By way of background, Section 316(a) of the Federal Clean Water Act regulates the thermal 

component of surface water discharges. Specifically, Section 316(a) authorizes variances from 

thermal SWQS where it is shown that the alternative limit proposed will “assure the protection 

and propagation of a balanced, indigenous population of shellfish, fish, and wildlife” in the 

receiving water. Section 316(a) of the Federal Clean Water Act states, in part: 
 Response to Comments 

 Page 24 of 40 

 Permit No. NJ0005444 

....the Administrator (or if appropriate, the State) may impose an effluent limitation under 

such sections for such plant, with respect to the thermal component of such discharge 

(taking into account the interaction of such thermal component with other pollutants), that 

will assure the protection and propagation of a balanced, indigenous population of 

shellfish, fish and wildlife in and on that body of water. 

In other words, the Department can deviate from the SWQS expressed for point sources and for 

heat dissipation dimensions provided that the conditions of Section 316(a) of the Clean Water 

Act are met. As stated at N.J.A.C. 7:9B-1.5(c).8.i., a Section 316(a) determination would 

override the SWQS thermal criteria. 

8. Temperature criteria at N.J.A.C. 7:9B-1.14(d) apply unless an alternative effluent 

limitation is approved in accordance with Section 316(a) of the Clean Water Act, 33 

U.S.C. 1326(a). 

Federal regulations at 40 CFR Part 125 125.70 – 125.73 (Subpart H – Criteria for Determining 

Alternative Effluent Limitations Under Section 316(a) of the Act) serve to guide implementation 

of Section 316(a) of the Clean Water Act. The Department used these regulations in 

establishing the Section 316(a) determination in the 2013 Draft Permit. 

Regarding the DO impairment for Great Egg Harbor Bay, the Department does not agree that 

there is any evidence that BL England is contributing to the DO impairment through its 

discharges as noted at length in Responses 10, 11 and 12. Again, DO is not generally a 

regulatory requirement for cooling water discharges and the fact that the predominant discharges 

are comprised of cooling water does not change from current plant conditions to repowered plant 

conditions. Therefore, the issue of the waterbody being impaired for DO before or after 2005 is 

moot. 

Secondly, while it is true that areas of the zone of initial dilution (ZID) may have greater 

temperatures during certain intermittent conditions, the Department does not agree that the 

overall plume will be increased under the repowered plant conditions. As stated in the 2013 

Fact Sheet: 

...After repowering, the once-through cooling water discharge will be discharged through 

DSN 010 and the cooling tower blowdown will continue to be discharged through DSN 

001. The once-through cooling water discharge through DSN 009 will be eliminated. 

The size and characteristics of the thermal plume during current conditions as well as 

after repowering are dependent on the thermal characteristics of the cooling water 

discharge, the station’s net generation over several days, the hydrodynamics of the bay 

and meteorological conditions. Simplified thermal modeling results show a net 

reduction in the overall area of the plume from approximately 26 to 32% for the 

repowered plant condition as compared to the existing plant configuration. 

And with respect to the operation of supplementary burners and any effect on the plume, the 

following is stated: 
 Response to Comments 

 Page 25 of 40 

 Permit No. NJ0005444 

...While the current heat loading limitations for the Station have been retained from the 

existing permit, the overall thermal contribution from the Station will decrease from the 

existing plant configuration based on the elimination of any heat loading from DSN 009A 

after repowering. In addition, the effluent temperature and temperature differential 

limitations for DSN 010A for September through May have been retained from the 

existing permit. However, with respect to the period from June through August for DSN 

010A, the Department is imposing a temperature differential limit of 11.0 degrees Celsius 

as a daily maximum and an effluent temperature limit of 40.5 degrees Celsius as a daily 

maximum. This change is necessary since higher temperatures will be realized as a 

result of the use of the duct burners as well as the use of the steam turbine bypass. This 

operating scenario will not be continuous because the use of the duct burners is limited by 

the Title V Air Permit and the steam turbine bypass only operates for a few hours during 

each plant startup, shutdown or infrequent turbine transients. While temperatures within 

the ZID may at times be greater as compared to the current plant configuration, the ZID 

occupies very small areas within GEHB and is expected to have minimal effect on 

aquatic organisms in GEHB beyond the effects considered in prior Section 316(a) 

assessments. 

Based on the above and the shutdown of Unit 1, the overall plume will decrease under repowered 

plant conditions. Operation of duct burners occurs very infrequently and for very short periods 

of time. As a result, NJDEP does not agree with the contention that the repowered plant will 

actually expand the area of Great Egg Harbor Bay that is unfit for aquatic life nor does the 

Department agree that Great Egg Harbor Bay is unfit for aquatic life. As evidenced by the 

impingement and entrainment data presented in the 2013 Draft Permit, many organisms are 

present in the area of the intake. Note that the 2010 303(d) list does not specify any other 

impairments for Great Egg Harbor Bay with the exception of DO. 

Finally, NJDEP maintains that the applicant has met the burden of proof with respect to a Section 

316(a) variance including cumulative impacts. As stated in the 2013 Fact Sheet: 

In evaluating the renewal of the section 316(a) variance, the Department considered the 

current application, applicable state and federal regulations, and applicable guidance 

documents. The Department recognizes that the applicant’s burden with regard to the 

renewal of a thermal variance is “to support the continuation of the variance” and does 

not require the same level of proof as an application for an initial variance in accordance 

with 40 CFR 125.72(c). 

One of the factors that the Department considered regarding this request is whether or not 

operating characteristics have changed. Specifically, the Department evaluated existing 

discharge monitoring report data with respect to flow, temperature and heat as well as 

modeling estimates. The Department also reviewed available information with respect 

to the balanced indigenous community and the effects of the plume on such. 

Based on this information, the Department concluded the following: 
 Response to Comments 

 Page 26 of 40 

 Permit No. NJ0005444 

With respect to recent and current plant operations, the Department recognizes that the 

Station’s operations and the resulting physical thermal plume have been below the design 

flow for DSNs 001A, 009A and 010A. While the current heat loading limitations for the 

Station have been retained from the existing permit, the overall thermal contribution from 

the Station will decrease from the existing plant configuration based on the elimination of 

any heat loading from DSN 009A after repowering. In addition, the effluent temperature 

and temperature differential limitations for DSN 010A for September through May have 

been retained from the existing permit. However, with respect to the period from June 

through August for DSN 010A, the Department is imposing a temperature differential 

limit of 11.0 degrees Celsius as a daily maximum and an effluent temperature limit of 

40.5 degrees Celsius as a daily maximum... 

Based on the regulations at 40 CFR Part 125.73(c), the Department has determined that a 

variance under Section 316(a) is warranted in accordance with Section 316(a) of the 

Clean Water Act. This variance is based on the Department’s findings that: (1) the 

operating conditions for years 2008 through 2010 are below the bounds of the operating 

conditions at the time of the last 2005 variance; (2) the repowered operating conditions 

and closure of Unit 1 will result in a significant discharge flow reduction; and (3) the 

overall heat loading limits from the station have been retained. As a result, the 

Department has determined that a thermal discharge at the Station, in accordance with the 

proposed temperature and heat limitations, is expected to assure the protection and 

propagation of the balanced indigenous population. 

In sum, the Department maintains that the Section 316(a) analysis is appropriate and based on 

relevant laws and guidance. 

Comment 13 

In this permit renewal, NJDEP plans to weaken the existing heat limits to accommodate the 

permittee’s desire to install duct burners at B.L. England in order to avoid a dropoff in summertime 

generating capacity without having to pay to upgrade the condenser cooling system. Specifically, 

the Department will raise the summertime (June to August) temperature differential limit at DSN 

010A from 8.8 to11 degrees Celsius as a daily maximum and the maximum temperature effluent 

limit at DSN 010A from 38.3 to 40.5 degrees Celsius. 

Relaxation of this heat effluent limit clearly violates New Jersey’s anti-backsliding rules at N.J.A.C. 

7:14A-13.19. Based on this language, the increase in the temperature of the discharge is illegal 

unless an exemption under Section 402(o) applies yet none of the exceptions described therein apply 

at B.L. England. The provision NJDEP cites to justify less stringent effluent limitations stipulates 

that “material and substantial alterations or additions to the permitted facility occurred after permit

issuance which justify the application of a less stringent effluent limitation.” Neither of these 

conditions have been met. First, although a repowering is contemplated by 2016, no material or 

substantial alterations have occurred at B.L. England yet. Until the repowering is completed, in 

2016, the exception cited by NJDEP cannot possibly apply. Second, even if the proposed 

repowering occurs as planned, NJDEP has not explained why a less stringent effluent limitation for 
 Response to Comments 

 Page 27 of 40 

 Permit No. NJ0005444 

the discharge of heat would be justified and why a greater loss of habitat is justified. As explained 

above, although the reduced volume of the discharge will shrink the overall size of the thermal 

plume, the increased heat of the discharge will expand the zone at the core of the plume that is 

totally uninhabitable, thus destroying more habitat than the current plume. 

Finally, even if the exception cited by NJDEP did apply, Section 402(o) also provides that “in no 

event may such a permit to discharge into waters be renewed, reissued, or modified to contain a less 

stringent effluent limitation if the implementation of such limitation would result in a violation of a 

water quality standard . . . .” 33 U.S.C. § 1342(o)(3). Since the less stringent effluent limitation 

contemplated by NJDEP would result in violation of the dissolved oxygen water quality standard in 

Great Egg Harbor Bay, there is simply no way that NJDEP can authorize B.L. England to backslide 

by discharging water at a higher temperature than at present. 

 

Response 13 

First and foremost, because the overall heat loading from the Station will decrease, it is 

questionable that antibacksliding is even triggered. Nonetheless, to address the increase in 

effluent temperature and temperature differential limits at DSN 010 during June through August, 

the Department conservatively evaluated the requirements referenced in N.J.A.C. 7:14A-13.19 in 

the 2013 Fact Sheet as well as in this response below. The antibacksliding citation at N.J.A.C. 

7:14A-13.19 states the following: 

Except as provided for under Section 402(o) of the Federal Act (33 U.S.C. §1342(o)), when a 

permit is modified, renewed or reissued, all effluent limitations or standards shall be at least 

as stringent as the final and effective effluent limitations or standards in the previous permit. 

And Section 402(o)(2) of the Federal Clean Water Act states the following with respect to 

anti-backsliding and its exceptions: 

(o) Anti-backsliding 

(1) General prohibition 

In the case of effluent limitations established on the basis of subsection (a)(1)(B) of this 

section, a permit may not be renewed, reissued, or modified on the basis of effluent 

guidelines promulgated under section 1314(b) of this title subsequent to the original issuance 

of such permit, to contain effluent limitations which are less stringent than the comparable 

effluent limitations in the previous permit. In the case of effluent limitations established on 

the basis of section 1311(b)(1)(C) or section 1313(d) or (e) of this title, a permit may not be 

renewed, reissued, or modified to contain effluent limitations which are less stringent than 

the comparable effluent limitations in the previous permit except in compliance with section 

1313(d)(4) of this title. 

(2) Exceptions 

A permit with respect to which paragraph (1) applies may be renewed, reissued, or modified 

to contain a less stringent effluent limitation applicable to a pollutant if— 

(A) material and substantial alterations or additions to the permitted facility occurred after 

permit issuance which justify the application of a less stringent effluent limitation... 
 Response to Comments 

 Page 28 of 40 

 Permit No. NJ0005444 

The commentor is correct in that NJDEP cited that the repowering project qualifies as a material 

and substantial alteration or addition to the permitted facility pursuant to Section 402(o) of the 

Federal Clean Water Act. Contrary to the commentor’s contention, the Department does not 

agree that Section 402(o) requires the permittee to complete the material and substantial 

alteration before requesting higher limits. Rather, the material and substantial alteration would 

have occurred after the issuance of the “previous permit”, as referenced in Section 402(o)1, 

which in this case refers to the 2005 NJPDES renewal. Secondly, NJDEP maintains that it 

explained that higher limits were necessary due to changes at the plant that will result in 

intermittent higher temperatures due to operation of the duct burners. Excerpts of this scenario 

from the 2013 Fact Sheet are summarized in Response 12. 

As noted in detail in Responses 9 and 10, the Department maintains that there is no evidence that 

the non-contact cooling water discharges at BL England do not result in violation of the water 

quality standards. 

Comment 14 

The variance request and variance determination are silent with respect to climate change. With a 

major repowering proposed, whatever cooling system is built now will operate for at least another 40 

or 50 years. In the long run, the failure to consider climate change is not in B.L. England’s interests, 

because if the plant is reliant on a once-through cooling system, increasing temperatures in Great 

Egg Harbor Bay may limit the repowered plant’s ability to run when intake water temperatures are 

hot. During recent heat waves, some U.S. power plants have already had to reduce or curtail 

operations to comply with thermal discharge regulations such as the Millstone nuclear plant in 

Connecticut. Higher global temperatures will only increase the frequency with which such 

compliance issues will arise in northern states. In the future, power plants with once-through 

cooling systems will need to adapt their cooling systems to ensure usable capacity since they will be 

faced with higher summertime intake temperatures due to an increased frequency of low flows, 

higher overall river temperatures, and higher peak summer temperatures. 

Response 14 

At this time there are no regulatory criteria to consider climate change as part of Section 316(a). In 

fact, one could argue that climate change considerations would result in higher temperature limits, 

temperature differential limits and heat limitations. Instead, NJDEP is maintaining its heat limits, 

temperature differential limits and effluent temperature limits from the previous permit with the 

exception of the period of June through August for DSN 010A. 

Comment 15 

In some cases, a closed-cycle cooling system is needed in order to comply with state water quality 

standards, irrespective of whether the Act’s technology-based provisions also require use of the 

technology. At least four power plants – the McDonough and Yates plants in Georgia, and the 

Canadys and Wateree plants in South Carolina have converted to closed-cycle cooling primarily to 

reduce thermal discharges that ran afoul of state water quality standards. As at those plants, the 

thermal pollution and the nutrients discharged by B.L. England’s once-through cooling system cause 
 Response to Comments 

 Page 29 of 40 

 Permit No. NJ0005444 

sufficient environmental harm to warrant a conversion to closed-cycle cooling. 

Response 15 

As described in further detail in Response 6, it is not appropriate to compare the site-specific 

information of various national plants. This is based on variation in a number of factors including 

receiving waterbody characteristics, discharge characteristics, plant characteristics, environmental 

characteristics, intake water availability, etc. Also, as noted at length in Responses 12 and 13, 

NJDEP maintains that its Section 316(a) determination is in accordance with applicable regulations 

and guidance. Finally, the Department does not agree that there is any evidence of documented 

harm as a result of BL England's discharges. 

Comment 16 

 

NJDEP should have consulted with the U.S. Fish and Wildlife Service and with the National Oceanic 

and Atmospheric Administration (NOAA) in determining whether the thermal pollution discharged 

from B.L. England is allowable and whether a 316(a) variance should be granted. Both federal 

agencies have voiced general concern about the discharge of thermal pollution in marine estuaries. 

Also, both agencies have a strong interest and understanding of the ecological health of Great Egg 

Harbor Bay, have supported NJDEP’s conservation and research efforts, and have consulted with 

NJDEP on other NJDPES permitting processes. If NJDEP has not already done so, it should now 

consult with US. Fish and Wildlife Service and with the National Oceanic and Atmospheric 

Administration prior to issuance of the final permit to learn more about the short and long term 

impacts of this permit. 

Response 16 

NJDEP has forwarded the draft permit action to NOAA and the US Fish and Wildlife Service. In 

addition, the related air permit, namely the Federal Prevention of Significant Deterioration (PSD) 

construction permit, was forwarded to the US Fish and Wildlife Service as part of its recent public 

comment period which began on February 6, 2013. No comments were received on the PSD permit. 

Comment 17 

NJDEP failed to gather adequate effluent data then uses this as an excuse for not conducting a 

reasonable potential analysis before issuing the NJPDES permit. NJDEP then proposes lax 

schedules for gathering the missing data and does not include reopener provisions in the permit 

specifying that the permit shall be reopened immediately once the missing data are collected. 

Commenters have observed this pattern in both the Mercer Generating Station and Hudson 

Generating Station NJPDES permits and believe that it likely occurs at other facilities as well. 

NJDEP must ensure that every NJPDES permit contains effluent limitations for all pollutants that 

have the reasonable potential to cause or contribute to violations of water quality standards by 

conducting a reasonable potential analysis. But, the Department claims that it cannot determine 

whether an existing discharge has the reasonable potential to cause or contribute to a violation of 

water quality standards unless it has ten water quality samples. Thus, NJDEP concluded that it 

lacks sufficient data to conduct a reasonable potential analysis as follows: 
 Response to Comments 

 Page 30 of 40 

 Permit No. NJ0005444 

 

• At DSN 001A (cooling tower blowdown), including for copper, even though in the four 

existing water quality samples from this outfall copper was detected in three samples and the 

highest measurement was 15 times greater than the state water quality standard. 

 

• At DSN 003A (stormwater outfall), because the Department has only four water quality 

samples. To remedy this deficiency, NJDEP is ordering once-annual sampling. But this 

means that in five years, when the Draft Permit is finalized and expires, NJDEP still will not 

have the ten samples it needs to issue a lawful renewal permit; and the oldest of its nine 

samples will be more than six years out of date. 

• At DSNs 009A and 010A (once-through cooling water). Although arsenic and the toxic 

plasticizer BPA have been detected at values exceeding state water quality standards, “at this 

time, insufficient data exist to determine the need for WQBELs.” 

• At DSN 013A (wastewater treatment plant), because there are only five samples, including 

the data submitted with B.L. England’s Permit Renewal application. NJDEP is not 

conducting a reasonable potential analysis or setting water quality based effluent limits even 

though it detected arsenic and selenium in four of five samples, with at least one arsenic 

sample at concentrations nearly 300 times higher than the state water quality standard. 

• At DSN 014A (flue gas desulfurization wastewater), where NJDEP not only concluded that, 

“at this time, insufficient data exist for most of these parameters to determine the need for 

WQBELs,” but that it need not even collect such data because the FGD scrubber likely will 

shut down in 2016, when the repowering is completed. 

NJDEP had other options for handling this situation such as it could have relied on the four or 

five samples available for each outfall, particularly where a sample is above state water quality 

standards. At a minimum, NJDEP should include: 

 

• A copper effluent limit at DSN 001A, where copper was detected in three samples and 

the highest measurement was 15 times greater than the state water quality standard; 

• An effluent limit at DSN 008A that relates to a parameter such as total organic carbon or 

biological oxygen demand and addresses the impact that pressure-spraying dead and 

decomposing fish off the plant’s intake screens has on dissolved oxygen concentrations; 

• Arsenic, heat, dissolved oxygen, and nutrient effluent limits at DSNs 009A and 010A; 

and 

• An arsenic effluent limit at DSN 013A (wastewater treatment plant). 

Finally, NJDEP should conduct (or require B.L. England to conduct) a program of rapid testing 

over the next few months to adequately characterize all of the discharges at B.L. England for 

which it claims to lack sufficient data, and should then issue a final permit that includes water 

quality based effluent limits. 
 Response to Comments 

 Page 31 of 40 

 Permit No. NJ0005444 

Response 17 

The commentor is correct in that it is the Department’s policy to have sufficient available data 

before a proper water quality based effluent limit cause and reasonable potential analysis can be 

conducted. This policy is routinely applied to all NJPDES permits throughout the state. The 

Department does not agree that this practice is “illegal” since there is no state regulation which 

stipulates how many data points must be utilized in conducting such an analysis. Rather, it is 

within the permitting authority’s discretion where the permitting authority maintains that 

sufficient representative data must be available to conduct a proper statistical analysis. 

Additionally, the U.S. EPA Technical Support Document recommends in Section 3.3 that eight 

to 12 samples be obtained for parameters of concern. Contrary to the commentor’s assertion, 

NJDEP did include a reopener clause in the draft permit to allow the inclusion of effluent limits 

if warranted as described in detail in Response 18. With respect to the commentor’s contention 

that commenters noted this pattern in the Mercer and Hudson NJPDES permits, it is unclear as to 

which commenters are being referred to since the only parties that commented on those permits 

were the permittee. 

Toxic pollutants are not commonly the focus of non-contact cooling water discharges since 

generally the primary pollutant is heat. Current federal steam electric guidelines at 40 CFR Part 

423 do not specify metals limits for the types of wastestreams authorized at BL England. 

And given the conversion from coal to natural gas, it is expected that the process wastewater 

discharge at BL England will only become cleaner. Also, the internal monitoring point 

designated as DSN 014, which is the flue gas desulfurization scrubber, will be eliminated. After 

that time the only wastewater components that will enter the treatment system for DSN 013 will 

be wastewater from floor drains, deionizer filters, filter backwash, demineralizer wastewater and 

boiler blowdown. 

As noted in the 2013 Fact Sheet, the Department did evaluate available toxic data at all 

discharges. NJDEP had required extensive priority pollutant sampling at most outfalls where 

the vast majority of results were non-detectable values. The following is a response to the 

commentor’s specific assertions on each outfall: 

• At DSN 001A four data points are available for copper, with three of these values 

detectable (4 ug/L; 23.4 ug/L; and 45.2 ug/L) and one non-detectable value (<10 ug/L). 

It is Department policy that a pollutant must be consistently detected in the effluent 

before a WQBEL analysis is conducted for that pollutant. Four data points are not 

sufficient for determining a site-specific coefficient of variation and subsequent WQBEL. 

However, monitoring for copper is increased to semiannual in the final permit so there 

will be 10 data values available upon permit renewal. Note that copper limits are not 

established in any other NJPDES permits for cooling tower blowdown across the state. 

• Outfall DSN 003A previously consisted of slag pond overflow but now consists of 

stormwater only. Current data is not likely representative of stormwater data after 

repowering based on the change in fuel source from coal to natural gas. Also, metals are 
 Response to Comments 

 Page 32 of 40 

 Permit No. NJ0005444 

not typically present in stormwater yet the Department is requiring an annual metals scan 

as a conservative measure. 

• Intake screen backwash occurs at DSN 008A. Rinsing organisms from the screen is not 

viewed as an addition of pollutants due to the fact that these organisms are being returned 

to the same body of water from which they were withdrawn and the permittee is not 

adding any pollutants to the water. This policy is consistently applied to all power plants 

across the state. Again, losses of organisms are addressed via Section 316(b) of the 

Clean Water Act as described further in Responses 5 and 11.

• The toxics data from DSNs 009A and 010A is limited to one round of sampling which 

was submitted with the 2009 application, with the exception of Selenium for which there 

are four data values. The commentor has requested a WQBEL for Arsenic at these 

outfalls; however, one data value does not provide a sufficient basis for instituting a new 

WQBEL. Monitoring has been increased to semiannual for Arsenic and Boron. 

Semiannual monitoring will provide sufficient data for conducting WQBEL analyses 

upon renewal. Toxics are not generally present in once-through cooling water 

discharges. 

• At DSN 013A, five data values are available for Arsenic. Results are as follows: 169 

ug/L; <6 ug/L; 4 ug/L; 36.2 ug/L and 15.1 ug/L. Since this amount of data is not 

sufficient for calculating a WQBEL, the monitoring frequency is increased to semiannual 

and the need for a WQBEL will be reevaluated upon permit renewal. Also, WQBELs 

are imposed for several toxics at the internal monitoring point DSN 014A. Again, 

effluent quality at DSN 013A is expected to improve with the repowering since DSN 

014A will be eliminated. 

• At DSN 014A, WQBELs for chromium, iron, nickel and zinc are carried forward from 

the existing permit with a weekly monitoring frequency. Monitoring was also increased 

for the six parameters that were detected in the application data even though the majority 

of those detected parameters were orders of magnitude below the SWQS as described in 

the 2013 Fact Sheet. This outfall will cease discharging by May 2016 per the Air 

Program’s Administrative Consent Order since coal burning will have ceased by that 

date. 

 

NJDEP maintains that it used appropriate judgment in establishing effluent limits and/or 

increased monitoring frequencies for those wastestreams that have the potential to contain toxic 

pollutants or where existing data warranted additional monitoring. Regarding the suggestion 

that additional data be collected at an expedited schedule, it is unclear what purpose this would 

serve since several discharges will significantly change and/or not occur during the extended 

construction period and after repowering is complete. 

 

Comment 18 

The state regulations at N.J.A.C. 7:14A-13.8(a)(2) require that a permit developed without 
 Response to Comments 

 Page 33 of 40 

 Permit No. NJ0005444 

adequate effluent samples “shall include a reopener clause.” The requirement to collect 

sampling data and improve upon a deficient reasonable potential analysis is one of DEP’s basic 

water quality policies at N.J.A.C. 7:14A-13.5(l). But this Draft Permit does not contain a 

reopener provision that would allow NJDEP to include the missing effluent limits as soon as 

possible, although it does contain specific provisions related to the BTA determination, 

petroleum hydrocarbons in cooling tower blowdown, and new biocides. Further, NJDEP cannot 

justify setting a sampling schedule that will take five or more years to provide ten data points 

since the Act requires compliance with water quality standards at all times. 

Response 18 

As discussed in Response 17 the Department maintains that the sampling requirements for toxics 

in this permit are appropriate and do not cause or contribute to an excursion above the SWQS. 

Contrary to the commentor’s contention, the 2013 Draft Permit does contain a reopener clause. 

As per Part IV F.2. of the Draft Permit: 

The Department may modify or revoke and reissue any permit to incorporate 1) any 

applicable effluent standard or any effluent limitation, including any effluent standards or 

effluent limitations to control the discharge of toxic pollutants or pollutant parameters such as 

acute or chronic whole effluent toxicity and chemical specific toxic parameters, 2) toxicity 

reduction requirements, or 3) the implementation of a TMDL or watershed management plan 

adopted in accordance with N.J.A.C. 7:15-7. 

In sum, the Department can reopen the permit at any time if effluent data demonstrates the need 

for additional limits or requirements. Also, the Department can require more frequent 

monitoring through issuance of a minor permit modification pursuant to N.J.A.C. 7:14A-16.5. 

Comment 19 

NJDEP could have characterized effluents by using data from similar discharges at other power 

plants. For example, with respect to DSNs 013A and 014A, which receive effluent 

contaminated with coal combustion waste, DEP can rely on recent guidance sent from EPA to 

NPDES permit writers namely the June 7, 2010 memorandum from EPA Director James A. 

Hanlon regarding Wastewater Discharges from Flue Gas Desulfurization (FGD) and Coal 

Combustion Residuals Impoundments at Steam Electric Power Plants. This memo cites that 

metals have the potential to be present in coal combustion waste effluent. As an alternative, 

NJDEP could have sought the data it required during the four years that lapsed between B.L. 

England’s submission of a permit renewal application and NJDEP’s issuance of this NJPDES 

permit. Or NJDEP could simply have rejected B.L. England’s permit renewal application as 

incomplete and insufficient and demanded more data when it was filed in 2009. 

Presumably, NJDEP’s insistence on gathering ten data points before conducting a reasonable 

potential analysis is based on N.J. ADMIN. CODE § 7:14A-13.8(a). But relying on existing 

effluent quality, though preferable to other methods, is not the only way to conduct a reasonable 

potential analysis. 
 Response to Comments 

 Page 34 of 40 

 Permit No. NJ0005444 

Response 19 

While NJDEP recognizes that the above referenced memo may apply to FGD systems as 40 CFR 

423 is being redrafted, NJDEP does not agree that information in this memo regarding coal 

combustion waste is applicable to BL England. Coal combustion residuals, commonly known 

as coal ash, are byproducts of the combustion of coal at power plants and are generally disposed 

of in liquid form at large surface impoundments and in solid form at landfills. As noted in the 

June 7, 2010 memo: 

The purpose of this memorandum is to provide you with interim guidance to assist 

National Pollutant Discharge Elimination System (NPDES) permitting authorities to 

establish appropriate permit requirements for wastewater discharges from Flue Gas 

Desulfurization (FGD) systems and coal combustion residual (CCR) impoundments at 

Steam Electric Power Plants. 

Because wastewater is not generated from coal combustion and because a coal combustion 

residual impoundment does not exist at BL England, guidance regarding coal combustion waste 

is not applicable. 

Regarding guidance for FGD systems, the memo does cite that arsenic, mercury, and selenium 

have the potential to be present in FGD wastewater. These parameters have and continue to be 

regulated in the NJPDES permit despite the fact that applicable effluent limitation guidelines do 

not specify limits for these parameters. A complete description of regulation of these and other 

toxic metals is included below in Response 20. 

NJDEP recognizes that N.J.A.C. 7:14A-13.8 describes the need for ten data points for a proper 

statistical analysis. However, this paragraph is intended for limits derived based on existing 

effluent quality and not water quality based effluent limits. 

Comment 20 

 

The Draft Permit sets inadequate technology based effluent limits at DSN 013A and DSN 014A 

which should be revised to reflect Best Available Technology for coal plants. The effluent 

passing through these outfalls contain a number of toxic metals including arsenic, selenium, and 

chromium. 

EPA has not yet established effluent limitation guidelines for steam electric power generators 

that address the metals and other toxic pollutants found in coal combustion waste. The agency 

has announced its intention to revise the existing effluent limitation guidelines for power plants 

to address coal combustion waste pollutants, but this will take several more years. EPA last 

promulgated ELGs for the steam electric power generation industry in 1982. Since then, EPA 

has learned that the power sector is a significant discharger of toxic pollutants and the toxicity of 

these discharges is primarily driven by metals associated with coal combustion waste. EPA has 
 Response to Comments 

 Page 35 of 40 

 Permit No. NJ0005444 

also made clear that the existing effluent limitation guidelines fail to control metals in coal 

combustion waste discharges. Thus, in 2009, EPA issued guidance for permit writers in which 

EPA restated its position that in the absence of an effluent guideline for those coal combustion 

waste pollutants, the Clean Water Act requires permitting authorities to conduct the “BPJ” 

analysis discussed above on a case-by-case basis for those pollutants in each permit. 

In setting BAT effluent limits, NJDEP should look to the performance of other plants in the 

industry. The Merrimack power plant in New Hampshire uses a more effective treatment 

system that begins with a conventional chemical precipitation system but then adds on an 

advanced biological treatment system specifically to treat dissolved coal combustion waste 

metals like selenium. A comparison is as follows: 

 

Comparison of FGD Wastewater Effluent Limits 

 at Merrimack and B.L. England 

Pollutant 

(μg/L) 

Merrimack B.L. England 

Monthly 

Average 

Daily 

Maximum 

Effluent Data 

(MOAV/DAMX)

Monthly 

Average 

Daily 

Maximum 

Arsenic 8 15 169 Report Report 

Cadmium Report 50 not sampled no limit no limit 

Chromium Report 10 4/10 Report 200 

Copper 8 16 5,300/48,000 Report 8,700 

Lead Report 100 not sampled no limit no limit 

Selenium 10 19 40 Report Report 

Zinc 12 15 30/130 Report 1000 

Because plants like Merrimack are meeting these limits, they are achievable and the technology 

leading to them is available at B.L. England. And other plants are surpassing even this level of 

achievement and eliminating all FGD wastewater discharge either through the use of 

vapor-compression evaporation systems or by fully recycling wastewater. 

 

NJDEP cannot claim that improved treatment technologies as not “available” for DSNs 013A 

and 014A because some of the discharges routed through these outfalls will cease if the 

repowering is completed. Moreover, the wastewater treatment plant will not shut down as it will 

continue to operate even if the FGD scrubber is disconnected upon repowering. If NJDEP is 

concerned about the remaining life of the treatment plant in light of the repowering, the 

Department can set a compliance schedule for meeting more stringent effluent limits that take 

effect on the planned date of the repowering. Thus, B.L. England can choose to meet the 

effluent limit by repowering and eliminating the discharge, or in the alternative, by installing 

more advanced pollution controls. The attainment of zero discharge at some plants suggests that 

the best available technology standards is in fact zero meaning the complete elimination of all 

discharge. 

Response 20 

As noted previously, DSN 014 consists of approximately 0.03 MGD of FGD wastewater which 
 Response to Comments 

 Page 36 of 40 

 Permit No. NJ0005444 

is diverted to the on-site wastewater treatment plant. Other wastestreams that are routed to the 

on-site wastewater treatment plant include water from floor drains, deionizer water filters 

wastewater, charcoal filter backwash, demineralizer water, boiler blowdown and stormwater 

from the coal pile. Treatment consists of oil coalescence, equalization, polymer addition, two 

stage pH adjustment, flocculation, clarification, filtration and neutralization. As described 

above in Response 19, guidance regarding coal combustion waste does not apply to BL England. 

With respect to the FGD wastestream (DSN 014A), the Department maintains that the limits set 

in the 2013 Draft Permit are adequate and appropriate. 

Many toxic pollutants are limited at DSN 013A and/or at DSN 014A. The information 

presented in this comment that compares the FGD wastewater at B.L. England to Merrimack 

does not match the data contained in the 2013 Draft Permit for this same outfall. A complete 

list of metals data and effluent limits at DSNs 013A and 014A for the parameters described in 

this comment are as follows: 

DSN 013A – Wastewater Treatment Plant 

PARAMETER UNITS AVERAGING 

PERIOD 

WASTEWATER 

DATA 

(3/2005-9/2012) 

FINAL 

LIMITS 

MONITORING 

FREQUENCY 

SAMPLE TYPE 

Total Recoverable 

Chromium 

mg/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

0.004 

0.01 

4/38 

90% 

MR 

0.2 

1/Quarter 4-Hour Composite 

Total Recoverable 

Zinc 

mg/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

0.03 

0.13 

15/28 

65% 

MR 

1.0 

1/Quarter 4-Hour Composite 

Total Recoverable 

Copper 

mg/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

5.3 

48 

25/62 

71% 

MR 

8.7 

1/Quarter 4-Hour Composite 

Total Recoverable 

Nickel 

mg/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

0.011 

0.04 

9/35 

76% 

MR 

1.0 

1/Quarter 4-Hour Composite 

Arsenic, Total 

Recoverable 

μg/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected

62.7 

169 

3/1 

25% 

MR 

MR 

1/6 Months 4-Hour Composite 

Selenium, Total 

Recoverable 

μg/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected

20.4 

40 

4/1 

20% 

MR 

MR 

1/6 Months 4-Hour Composite 
 Response to Comments 

 Page 37 of 40 

 Permit No. NJ0005444 

DSN 014 – FGD Wastestream that is Diverted to Wastewater Treatment Plant 

Discharge will be eliminated upon repowering 

PARAMETER UNITS AVERAGING 

PERIOD 

WASTEWATER 

DATA 

(3/2005-9/2012) 

FINAL 

LIMITS 

MONITORING 

FREQUENCY 

SAMPLE TYPE 

Total Recoverable 

Arsenic 

ug/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

26.11 

112 

27/37 

58% 

830 

1700 

1/Week 4-Hour Composite 

Total Recoverable 

Copper 

ug/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

65.95 

500 

13/52 

80% 

1700 

3500 

1/Week 4-Hour Composite 

Total Recoverable 

Mercury 

ug/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

0.22 

1.6 

12/53 

82% 

49 

98 

1/Week 4-Hour Composite 

Total Recoverable 

Selenium 

ug/L Monthly Avg. 

Daily Max. 

# detect/# non-detect 

% not detected 

40 

50 

2/2 

50% 

MR 

MR 

1/6 Months 4-Hour Composite 

A summary as to how each of the parameters referenced in the above table is regulated is as 

follows: 

Arsenic – Arsenic is limited at the internal monitoring point DSN 014A and monitored at 

DSN 013A. Arsenic was NOT detected 58% of the time at DSN 014A. 

Cadmium – Application data for Cadmium showed it was not detected at outfalls DSN 013A 

or DSN 014A. Regardless, cadmium is required to be monitored annually at DSN 013A. 

The EPA memo dated June 7, 2010 for FGD wastestreams does not recognize cadmium as a 

wastewater component. 

Chromium – Chromium is limited at the internal monitoring point DSN 014A and 

monitored at DSN 013A. Chromium was NOT detected 90% of the time at DSN 014A. 

The EPA memo dated June 7, 2010 for FGD wastestreams does not recognize chromium as a 

wastewater component. 

Copper – Copper is limited at the internal monitoring point DSN 014A as well as at DSN 

013A. Copper is NOT detected 71% of the time at DSN 013A and NOT detected 80% of 

the time at DSN 014A. The EPA memo dated June 7, 2010 for FGD wastestreams does not 

recognize copper as a wastewater component. 

Lead – Application data for Lead showed it was NOT detected at outfalls DSN 013A or DSN 

014A. Regardless, lead is required to be monitored annually at DSN 013A. The EPA 

memo dated June 7, 2010 for FGD wastestreams does not recognize lead as a wastewater 

component. 
 Response to Comments 

 Page 38 of 40 

 Permit No. NJ0005444 

Mercury – Application data for Mercury showed it was not detected at outfalls DSN 013A or 

DSN 014A. Mercury is not detected 82% of the time at DSN 014A. Mercury limits are 

applied at DSN 014A with weekly monitoring and annual monitoring is required at DSN 

013A. 

Selenium – Available data for Selenium showed it was detected in four of four samples at 

DSN 013A (12.6 ug/L; 5 ug/L; 24.3 ug/L and 40 ug/L) and in two of four samples at DSN 

014 (29.7 ug/L and 50 ug/L). All results are below the NJSWQS of 71 ug/L. Selenium is 

required to be monitored semi-annually at DSN 013A and at DSN 014A. 

Zinc – Zinc is limited at the internal monitoring point DSN 014A where it was NOT detected 

65% of the time. Zinc was also not detected in the application data for DSN 013A and 

014A. Regardless, zinc is required to be monitored annually at DSN 013A. The EPA 

memo dated June 7, 2010 for FGD wastestreams does not recognize zinc as a wastewater 

component. 

In sum, the Department maintains that the effluent limits at DSNs 013A and 014A are 

appropriate and protective. 

With respect to the suggestion that DSN 014 be required to have a “zero discharge,” because this 

discharge will be eliminated, this condition is being met. The remaining wastewater at DSN 013A 

will continue to be extensively treated and the effluent will be monitored. 

Comment 21 

New Jersey’s antidegradation policy at N.J.A.C. 7:9B-1.5 states that existing uses of a waterbody 

shall be maintained and protected. Also, designated uses shall be maintained or, as soon as 

technically and economically feasible, be attained wherever these uses are not precluded by 

natural conditions. Further, at a minimum, even the most polluted waterbodies “shall be 

protected from any measurable changes (including calculable or predicted changes) to the 

existing water quality.” And under no circumstances can “water quality-based effluent 

limitations established to implement the water quality standards (which includes the 

antidegradation policies)” ever provide for effluent limits less stringent than required by federal 

law. 

The Draft Permit violates the antidegradation policy in several ways. First, the failure to set 

water quality based effluent limits violates the state’s antidegradation policy because NJDEP has 

not analyzed whether the permit renewal will cause any measurable changes to the existing water 

quality. Increasing the temperature of the discharge at DSN010A in a manner that makes a 

larger portion of Great Egg Harbor Bay inimical to indigenous species violates the 

antidegradation policy for the same reasons. Most of all, the Draft Permit’s failure to require 

closed cycle cooling and the proposed 316(a) variance together allow B.L. England to continue 

discharging high volumes of heat and nutrients into an oxygen-impaired waterbody,. The 

designated uses of Great Egg Harbor Bay are not being attained for DO. NJDEP must conduct 

an antidegradation review and include in the administrative record a determination as to how the 
 Response to Comments 

 Page 39 of 40 

 Permit No. NJ0005444 

permit comports with New Jersey’s antidegradation policy. 

Response 21 

This permit is consistent with NJDEP’s antidegradation policy because all permit limitations and 

conditions are equal to or more stringent than those contained in the existing permit with the 

exception of temperature differential and effluent temperature at DSN 010A during June through 

August. The basis for the changes in these limits is discussed at length in Response 13. 

Please refer to Responses 9 and 10 regarding DO, Responses 17 and 20 regarding WQBELs and 

Responses 1 through 8 regarding closed-cycle cooling. 

Comment 22 

The commentor requests that a public hearing be convened on this issue. The commentor also 

requests a meeting with Chief Patterson and staff of the Bureau of Surface Water Permitting. 

Response 22 

NJDEP denied the request for a public hearing in a letter dated June 3, 2013 addressed to Reed 

W. Super of Super Law Group, LLC from Chief Pilar Patterson of the Bureau of Surface Water 

Permitting. As described in this letter, the regulatory criteria for holding a public hearing is set 

forth in the NJPDES Regulations at N.J.A.C. 7:14A-15.11. Pursuant to N.J.A.C. 

7:14A-15.11(b): 

A request for a public hearing shall be in writing and shall state the nature of the 

significant and relevant issues proposed to be raised in the hearing and why these issues 

cannot be adequately expressed other than at a public hearing. 

N.J.A.C. 7:14A-15.12(a) further clarifies the criteria for holding public hearings by stating: 

The Department shall hold a public hearing if there is or may be a significant degree of 

public interest in favor of holding a public hearing. The Department may hold a public 

hearing if it determines that a hearing is likely to clarify one or more legal and/or factual 

issues on a draft permit and that oral testimony is essential to adequately express all 

issues and concerns. 

The April 26, 2013 submission is the only set of comments that were received on the NJPDES 

permit. Additionally, NJDEP did not receive any public comments on the associated air permit 

for the facility, namely the Significant Modification to the Title V Operating Permit. The public 

comment period for the air permit began on February 6, 2013 and ended on March 6, 2013. As 

a result, the Department has determined that there is not a “significant degree of public interest” 

in the NJPDES permit. In addition, as required by N.J.A.C. 7:14A-15.12(a), there was no 
 Response to Comments 

 Page 40 of 40 

 Permit No. NJ0005444 

justification in the submittal as to why a public hearing was necessary and why written comments 

would not be sufficient in addressing the group’s concerns. 

Additionally, NJDEP participated in a conference call on June 13, 2013 with some of the 

commenters including Edan Rotenberg of Super Law Group, Alice Baker of the Eastern 

Environmental Law Center, and Edward Lloyd and Susan Kraham of the Environmental Law 

Clinic at Columbia University School of Law. Participants from NJDEP included Pilar 

Patterson and Susan Rosenwinkel of the Bureau of Surface Water Permitting; Assistant Director 

Janice Brogle and Director Michele Putnam of the Division of Water Quality; and Helene 

Chudzik of the Division of Law. The purpose of the call was to offer an opportunity for the 

commenters to describe their concerns.
per_fcp.rtf 

New Jersey Department of Environmental Protection 

NEW JERSEY POLLUTANT 

DISCHARGE ELIMINATION SYSTEM 

The New Jersey Department of Environmental Protection hereby grants you a NJPDES permit for the facility/activity named in this document. This permit 

is the regulatory mechanism used by the Department to help ensure your discharge will not harm the environment. By complying with the terms and 

conditions specified, you are assuming an important role in protecting New Jersey’s valuable water resources. Your acceptance of this permit is an 

agreement to conform with all of its provisions when constructing, installing, modifying, or operating any facility for the collection, treatment, or discharge 

of pollutants to waters of the state. If you have any questions about this document, please feel free to contact the Department representative listed in the 

permit cover letter. Your cooperation in helping us protect and safeguard our state’s environment is appreciated. 

Permit Number: NJ0005444 

Final: Consolidated Renewal Permit Action

 

Permittee: 

RC Cape May Holdings LLC

900 N Shore Rd 

Beesleys Point, NJ 08223 

 

Property Owner: Location Of Activity: 

RC Cape May Holdings LLC 

c/o Rockland Capital Energy 

2204 Timberlock Pl - Ste 190

Investments

The Woodlands, TX 77380 

B L England Generating Station

900 N Shore Rd

Upper Township, NJ 

Cape May County

Authorization(s) Covered Under This Approval Issuance Date Effective Date Expiration Date 

B -Industrial Wastewater 

RF -Stormwater 

06/17/2013 08/01/2013 07/31/2018 

 

By Authority of: 

Commissioner's Office ________________________________ 

 DEP AUTHORIZATION 

 Pilar Patterson, Chief 

Bureau of Surface Water Permitting 

Division of Water Quality 

(Terms, conditions and provisions attached hereto) 

Division of Water Quality 
GENERAL REQUIREMENTS Page 1 of 1

 

B L ENGLAND GENERATING STATION Permit No. NJ0005444 

Beesleys Point Consolidated Permit 

Consolidated Renewal Permit Action 

 

PART I

GENERAL REQUIREMENTS: 

NJPDES 

A. General Requirements of all NJPDES Permits 

1. Requirements Incorporated by Reference 

a. The permittee shall comply with all conditions set forth in this permit and with all the applicable 

requirements incorporated into this permit by reference. The permittee is required to comply with 

the regulations, including those cited in paragraphs b. through e. following, which are in effect as 

of the effective date of the final permit. 

b. General Conditions 

Penalties for Violations N.J.A.C. 7:14-8.1 et seq. 

Incorporation by Reference N.J.A.C. 7:14A-2.3 

Toxic Pollutants N.J.A.C. 7:14A-6.2(a)4i 

Duty to Comply N.J.A.C. 7:14A-6.2(a)1 & 4 

Duty to Mitigate N.J.A.C. 7:14A-6.2(a)5 & 11 

Inspection and Entry N.J.A.C. 7:14A-2.11(e) 

Enforcement Action N.J.A.C. 7:14A-2.9 

Duty to Reapply N.J.A.C. 7:14A-4.2(e)3 

Signatory Requirements for Applications and Reports N.J.A.C. 7:14A-4.9 

Effect of Permit/Other Laws N.J.A.C. 7:14A-6.2(a)6 & 7 & 2.9(c) 

Severability N.J.A.C. 7:14A-2.2 

Administrative Continuation of Permits N.J.A.C. 7:14A-2.8 

Permit Actions N.J.A.C. 7:14A-2.7(c) 

Reopener Clause N.J.A.C. 7:14A-6.2(a)10 

Permit Duration and Renewal N.J.A.C. 7:14A-2.7(a) & (b) 

Consolidation of Permit Process N.J.A.C. 7:14A-15.5 

Confidentiality N.J.A.C. 7:14A-18.2 & 2.11(g) 

Fee Schedule N.J.A.C. 7:14A-3.1 

Treatment Works Approval N.J.A.C. 7:14A-22 & 23 

c. Operation And Maintenance 

Need to Halt or Reduce not a Defense N.J.A.C. 7:14A-2.9(b) 

Proper Operation and Maintenance N.J.A.C. 7:14A-6.12 

d. Monitoring And Records 

Monitoring N.J.A.C. 7:14A-6.5 

Recordkeeping N.J.A.C. 7:14A-6.6 

Signatory Requirements for Monitoring Reports N.J.A.C. 7:14A-6.9 

e. Reporting Requirements 

Planned Changes N.J.A.C. 7:14A-6.7 

Reporting of Monitoring Results N.J.A.C. 7:14A-6.8 

Noncompliance Reporting N.J.A.C. 7:14A-6.10 & 6.8(h) 

 Hotline/Two Hour & Twenty-four Hour Reporting N.J.A.C. 7:14A-6.10(c) & (d) 

 Written Reporting N.J.A.C. 7:14A-6.10(e) &(f) & 6.8(h) 

Duty to Provide Information N.J.A.C. 7:14A-2.11, 6.2(a)14 & 18.1 

Schedules of Compliance N.J.A.C. 7:14A-6.4 

Transfer N.J.A.C. 7:14A-6.2(a)8 & 16.2 
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

PART II

GENERAL REQUIREMENTS:

DISCHARGE CATEGORIES

A. Additional Requirements Incorporated By Reference

1. Requirements for Discharges to Surface Waters

a. In addition to conditions in Part I of this permit, the conditions in this section are applicable to

activities at the permitted location and are incorporated by reference. The permittee is required to

comply with the regulations which are in effect as of the effective date of the final permit.

i. Surface Water Quality Standards N.J.A.C. 7:9B-1

ii. Water Quality Management Planning Regulations N.J.A.C. 7:15

B. General Conditions

1. Scope

a. The issuance of this permit shall not be considered as a waiver of any applicable federal, state, and

local rules, regulations and ordinances.

2. Permit Renewal Requirement

a. Permit conditions remain in effect and enforceable until and unless the permit is modified, renewed

or revoked by the Department.

b. Submit a complete permit renewal application: 180 days before the Expiration Date.

3. Notification of Non-Compliance

a. The permittee shall notify the Department of all non-compliance when required in accordance

with N.J.A.C. 7:14A-6.10 by contacting the DEP HOTLINE at 1-877-WARNDEP

(1-877-927-6337).

b. The permittee shall submit a written report as required by N.J.A.C. 7:14A-6.10 within five days.

4. Notification of Changes

a. The permittee shall give written notification to the Department of any planned physical or

operational alterations or additions to the permitted facility when the alteration is expected to result

in a significant change in the permittee's discharge and/or residuals use or disposal practices

including the cessation of discharge in accordance with N.J.A.C. 7:14A-6.7.

b. Prior to any change in ownership, the current permittee shall comply with the requirements of

N.J.A.C. 7:14A-16.2, pertaining to the notification of change in ownership.

5. Access to Information

General Discharge Requirements Page 1 of 5
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

a. The permittee shall allow an authorized representative of the Department, upon the presentation of

credentials, to enter upon a person's premises, for purposes of inspection, and to access / copy any

records that must be kept under the conditions of this permit.

6. Stormwater Discharge Authorization

a. The permittee shall discharge stormwater to surface waters and/or ground waters of the State only

as authorized herein and consistent with the terms and conditions of this permit. This permit does

not authorize any unpermitted discharge of domestic wastewater, non-contact cooling water,

leachate, or process water, unless otherwise stated in Part IV of the Permit.

7. Other Discharges

a. If, during or after the preparation of the SPPP, it is discovered that the facility generates and

discharges to surface waters and/or ground water any domestic wastewater, non-contact cooling

water, or process waste water (including leachate and cooling water), not authorized by this permit

or any other NJPDES permit, the permittee shall discontinue such discharges and apply for the

appropriate NJPDES DSW permit in accordance with the NJPDES rules at N.J.A.C. 7:14A.

8. Operator Certification

a. For stormwater only discharges pursuant to N.J.A.C. 7:10A-1.10, the facility operator is exempt

from the operator certification requirements unless otherwise required by this permit .

9. Monitoring Locations

a. All samples shall be taken at the monitoring points specified in Part III of this permit and, unless

otherwise specified, before the effluent joins or is diluted by any other waste stream, body of water

or substance. Sampling points shall not be changed without notification to and the approval of the

Department.

10. Stormwater/Intermittent Discharges

a. The permittee is required to ensure that samples and measurements taken for the purposes of

monitoring are representative of the monitored activity pursuant to N.J.A.C. 7:14A-6.5(a). This

includes any regulated intermittent activity or discharge. Therefore, although a discharge may

occur on an intermittent basis, it does not exempt the permittee from complying with the conditions

of the permit. For example, if a permittee has a monthly monitoring and reporting requirement and

the discharge occurs three separate times during the month, the permittee should obtain a sample

during at least one of the discharge events occurring during the monitoring period.

i. The permittee should check "No Discharge this monitoring period" on the monitoring report

transmittal sheet only if there are no discharge events during the entire reporting period.

11. Removed Substances/Residuals

a. This permit does not authorize discharge of solids, sludge, filter backwash or other pollutants

removed in the course of treatment or control to the waters of the State unless specifically

authorized in this permit. All solids, sludge, filter backwash, or other pollutants removed from, or

resulting from the treatment or control of discharges must be disposed of in accordance with all

applicable Federal, State, Local and other appropriate agency requirements.

12. Outfall Tagging and Monitoring Location Tagging

a. All permittees with discharges that flow through an outfall with a Discharge Serial Number (DSN),

shall identify the outfall with an outfall tag or posted sign. The outfall tag or posted sign shall be:

i. legible from twenty-five (25) feet, with a minimum of one (1) inch lettering;

General Discharge Requirements Page 2 of 5
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

ii. visible to the public from the land and water (if applicable)

iii. located as near to the end of the outfall as possible;

iv. made of durable, weather resistant material; and

v. maintained on a regular basis, such as cleaned and inspected to ensure that the tag is properly

attached.

b. The outfall tag shall display, at minimum, the following information:

i. the name of the facility where the discharge originates;

ii. the NJPDES permit number;

iii. the Department Hotline phone number; and

iv. the DSN for that particular outfall.

c. If the monitoring locations are different than the outfall locations, monitoring locations shall also

be identified with a tag or posted sign. The tag or posted sign shall be:

i. legible;

ii. made of durable, weather resistant material; and

iii. maintained on a regular basis, such as cleaned and inspected to ensure that the tag is properly

attached.

d. The monitoring location tag shall display, at minimum, the following information:

i. the DSN.

13. Operator Certification

a. Pursuant to N.J.A.C. 7:10A-1.1 et seq. every wastewater system not exempt pursuant to N.J.A.C.

7:10A-1.1(b) requires a licensed operator. The operator of a system shall meet the Department's

requirements pursuant to N.J.A.C. 7:10A-1.1 and any amendments. The name of the proposed

operator, where required shall be submitted to the Department at the address below, in order that

his/her qualifications may be determined prior to initiating operation of the treatment works.

i. Notifcations shall be submitted to:

NJDEP

Examination and Licensing Unit

P.O. Box 420 Mail Code 401-04E

Trenton, New Jersey 08625-0420

(609)777-1012.

b. The permittee shall notify the Department of any changes in licensed operator within two weeks of

the change.

14. Operation Restrictions

a. The operation of a waste treatment or disposal facility shall at no time create: (a) a discharge,

except as authorized by the Department in the manner and location specified in Part III of this

permit; (b) any discharge to the waters of the state or any standing or ponded condtion for water or

waste, except as specifically authorized by a valid NJPDES permit.

General Discharge Requirements Page 3 of 5
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

15. Residuals Management

a. The permittee shall comply with land-based sludge management criteria and shall conform with the

requirements for the management of residuals and grit and screenings under N.J.A.C.

7:14A-6.15(a), which includes:

i. Standards for the Use or Disposal of Residual, N.J.A.C. 7:14A-20;

ii. Section 405 of the Federal Act governing the disposal of sludge from treatment works treating

domestic sewage;

iii. The Solid Waste Management Act, N.J.S.A. 13:1E-1 et seq., and the Solid Waste Management

Rules, N.J.A.C. 7:26;

iv. The Sludge Quality Assurance Regulations, N.J.A.C. 7:14C;

v. The Statewide Sludge Management Plan promulgated pursuant to the Water Quality Planning

Act, N.J.S.A. 58:11A-1 et seq., and the Solid Waste Management Act, N.J.S.A. 13:1E-1 et seq.;

and

vi. The provisions concerning disposal of sewage sludge and septage in sanitary landfills set forth at

N.J.S.A. 13:1E-42 and the Statewide Sludge Management Plan.

vii. Residual that is disposed in a municipal solid waste landfill unit shall meet the requirements in

40 CFR Part 258 and/or N.J.A.C. 7:26 concerning the quality of residual disposed in a municipal

solid waste landfill unit. (That is, passes the Toxicity Characteristic Leaching Procedure and

does not contain "free liquids" as defined at N.J.A.C. 7:14A-1.2.)

b. If any applicable standard for residual use or disposal is promulgated under section 405(d)of the

Federal Act and Sections 4 and 6 of the State Act and that standard is more stringent than any

limitation on the pollutant or practice in the permit, the Department may modify or revoke and

reissue the permit to conform to the standard for residual use or disposal.

c. The permittee shall make provisions for storage, or some other approved alternative management

strategy, for anticipated downtimes at a primary residual management alternative. The permittee

shall not be permitted to store residual beyond the capacity of the structural treatment and storage

components of the treatment works. N.J.A.C. 7:14A-20.8(a) and N.J.A.C. 7:26 provide for the

temporary storage of residuals for periods not exceeding six months, provided such storage does

not cause pollutants to enter surface or ground waters of the State. The storage of residual for

more than six months is not authorized under this permit. However, this prohibition does not apply

to residual that remains on the land for longer than six months when the person who prepares the

residual demonstrates that the land on which the residual remains is not a surface disposal site or

landfill. The demonstration shall explain why residual must remain on the land for longer than six

months prior to final use or disposal, discuss the approximate time period during which the

residual shall be used or disposed and provide documentation of ultimate residual management

arrangements. Said demonstration shall be in writing, be kept on file by the person who prepares

residual, and submitted to the Department upon request.

d. The permittee shall comply with the appropriate adopted District Solid Waste or Sludge

Management Plan (which by definition in N.J.A.C. 7:14A-1.2 includes Generator Sludge

Management Plans), unless otherwise specifically exempted by the Department.

e. The preparer must notify and provide information necessary to comply with the N.J.A.C. 7:14A-20

land application requirements to the person who applies bulk residual to the land. This shall

include, but not be limited to, the applicable recordkeeping requirements and certification

statements of 40 CFR 503.17 as referenced at N.J.A.C 7:14A-20.7(j).

General Discharge Requirements Page 4 of 5
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

f. The preparer who provides biosolids to another person who further prepares the biosolids for

application to the land must provide this person with notification and information necessary to

comply with the N.J.A.C. 7:14A-20 land application requirements.

g. Any person who prepares bulk residual in New Jersey that is applied to land in a State other than

New Jersey shall comply with the requirement at N.J.A.C. 7:14A-20.7(b)1.ix to submit to the

Department written proof of compliance with or satisfaction of all applicable statutes, regulations,

and guidelines of the state in which land application will occur.

General Discharge Requirements Page 5 of 5
PER

B L ENGLAND GENERATING STATION, Beesleys Point

PART III

LIMITS AND MONITORING REQUIREMENTS

001A SW Outfall DSN 001A Great Egg Harbor Bay B - Industrial Wastewa

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

Effluent samples for DSN 001A shall be taken at the sampling station located at the boiler blowdown pipe prior to discharge via DSN 00Cooling tower blowdown

Location DescriptionContributing Waste Types

Surface Water DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

Monitoring for Chromium is only required if cooling tower additives that contain Chromium are used during the month specified on the cooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MGD C

*****

Effluent REPORT REPORT 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

MGD C

*****

Intake From REPORT REPORT 

Stream

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

*****

Effluent 6.0 9.0 SU 

Gross Value

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Intake From REPORT REPORT SU 

Stream

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Effluent REPORT REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Solids, Total Suspended

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

Monitoring for Chromium is only required if cooling tower additives that contain Chromium are used during the month specified on the cooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent Net 30 100 MG/L 

Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Solids, Total Suspended

*****

Intake From REPORT REPORT MG/L 

Stream

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Solids, Total Suspended

*****

Effluent REPORT %EFFL 

Gross Value

QL *** *** *** *** ***

Minimum

 ***** ***** Report Per ***** *****

 January thru December

 LC50 Statre 96hr Acu Mysid Bahia

*****

Effluent 0.2 0.5 MG/L 

Gross Value

RQL *** *** *** 0.1 0.1

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chlorine Produced Oxidants

*****

Effluent REPORT REPORT DEG.C C

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Intake From REPORT REPORT DEG.C C

Stream

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Effluent REPORT REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Minimum Minimum

 ***** ***** Instant Daily Avg *****

 January thru December

 Oxygen, Dissolved (DO)

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

Monitoring for Chromium is only required if cooling tower additives that contain Chromium are used during the month specified on the cooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Carbon, Tot Organic (TOC)

MBTU/HR 

*****

Effluent REPORT 50 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Net Rate of Addition of Heat

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** 10 10

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Selenium, Total Recoverable

*****

Effluent REPORT REPORT MG/L 

Gross Value

RQL *** *** *** 0.01 0.01

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chromium, Total (as Cr)

*****

Effluent Net REPORT 0.2 MG/L 

Value

RQL *** *** *** 0.01 0.01

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chromium, Total (as Cr)

*****

Intake From REPORT REPORT MG/L 

Stream

RQL *** *** *** 0.01 0.01

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chromium, Total (as Cr)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** 10 10

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Nickel, Total Recoverable

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

Monitoring for Chromium is only required if cooling tower additives that contain Chromium are used during the month specified on the cooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT REPORT MG/L 

Gross Value

RQL *** *** *** 0.03 0.03

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Zinc, Total Recoverable

*****

Effluent Net REPORT 1 MG/L 

Value

RQL *** *** *** 0.03 0.03

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Zinc, Total Recoverable

*****

Intake From REPORT REPORT MG/L 

Stream

RQL *** *** *** 0.03 0.03

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Zinc, Total Recoverable

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** 10 10

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Copper, Total Recoverable

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Manganese, Total REPORT UG/L Grab 

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 40

 Cyanide, Total

 (as CN)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 8

 Arsenic, Total

 Recoverable (as As)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Thallium, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Beryllium, Total

 Recoverable (as Be)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Barium, Total

 Recoverable (as Ba)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 2

 Silver,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 4

 Cadmium,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Lead,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Antimony, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 1

 Mercury

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Acenaphthylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 Acenaphthene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Anthracene Effluent Gross Value

 Benzo(b)fluoranthene REPORT UG/L Grab 

 (3,4-benzo)

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 20

 Benzo(k)fluoranthene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Benzo(a)pyrene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Bis(2-chloroethyl)

 ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 26.5

 Bis(2-chloroethoxy)

 methane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Bis (2-chloroiso-

 propyl) ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Butyl benzyl

 phthalate

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Chrysene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Diethyl phthalate Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Dimethyl phthalate Effluent Gross Value

 1,2-Diphenyl- REPORT UG/L Grab 

 hydrazine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Fluoranthene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Fluorene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Hexachlorocyclo-

 pentadiene

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Hexachloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Indeno(1,2,3-cd)-

 pyrene

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 10

 Isophorone Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 N-nitrosodi-n-

 propylamine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 N-nitrosodiphenyl-

 amine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 N-nitrosodimethyl-

 amine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Nitrobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Phenanthrene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Pyrene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Benzo(ghi)perylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Benzo(a)anthracene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 1,2-Dichlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 1,2,4-Trichloro-

 benzene

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Dibenzo(a,h)

 anthracene

Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 1,3-Dichlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 1,4-Dichlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 2-Chloronaphthalene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Di-n-octyl Phthalate Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 10

 2,4-Dinitrotoluene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 2,6-Dinitrotoluene Effluent Gross Value

REPORT UG/L Grab 

RQL = 60

 3,3'-Dichloro-

 benzidine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 4-Bromophenyl phenyl

 ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 8

 Naphthalene Effluent Gross Value

REPORT UG/L Grab 

RQL = 30

 Bis(2-ethylhexyl)

 phthalate

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Di-n-butyl phthalate Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Benzidine Effluent Gross Value

 Malathion Effluent Gross Value REPORT UG/L Grab 

 Demeton Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 10

 Hexachlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Hexachlorobutadiene Effluent Gross Value

 Mirex Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 7

 1,3-Dichloropropene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 1,2,4,5-Tetrachloro- REPORT UG/L Grab 

 benzene

Effluent Gross Value

 N-nitrosodiethyl- REPORT UG/L Grab 

 amine

Effluent Gross Value

 N-nitrosopyrrolidine Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 6

 Carbon Tetrachloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 3

 1,2-Dichloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 8

 Bromoform Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Chloroform Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Toluene Effluent Gross Value

REPORT UG/L Grab 

RQL = 7

 Benzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Acrolein Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Acrylonitrile Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Chlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Chlorodibromomethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Ethylbenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 Methyl Bromide Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 10

 Methyl Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Methylene Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 Tetrachloroethylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Trichlorofluoro-

 methane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 23.5

 1,1-Dichloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1-Dichloroethylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1,1-Trichloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1,2-Trichloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 1,1,2,2-Tetrachloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 1,2-Dichloropropane Effluent Gross Value

REPORT UG/L Grab 

RQL = 4

 1,2-trans-Dichloro-

 ethylene

Effluent Gross Value

 2-Chloroethyl REPORT UG/L Grab 

 Vinyl Ether (Mixed)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Bromodichloromethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Vinyl Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Trichloroethylene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Methoxychlor Effluent Gross Value REPORT UG/L Grab 

 N-Nitrosodi- REPORT UG/L Grab 

 n-butylamine

Effluent Gross Value

 Chloroethane Effluent Gross Value REPORT UG/L Grab 

 Parachloro-m- REPORT UG/L Grab 

 cresol

Effluent Gross Value

 Parathion Effluent Gross Value REPORT UG/L Grab 

 Phenols Effluent Gross Value REPORT UG/L Grab 

 2,4,5-Trichloro- REPORT UG/L Grab 

 phenol

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.02

 Delta BHC,

 Total (ug/l)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.08

 Endosulfan Sulfate Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Beta Endosulfan Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.02

 Alpha Endosulfan Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.1

 Endrin Aldehyde Effluent Gross Value

 PCB-1016 REPORT UG/L Grab 

 (Arochlor 1016)

Effluent Gross Value

 2,3,7,8-Tetrachloro- REPORT UG/L Grab 

 dibenzo-p-dioxin

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.06

 4,4'-DDT(p,p'-DDT) Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 0.04

 4,4'-DDD(p,p'-DDD) Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 4,4'-DDE(p,p'-DDE) Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Aldrin Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.02

 Alpha BHC Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Beta BHC Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.03

 Gamma BHC (lindane), Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.2

 Chlordane Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.03

 Dieldrin Effluent Gross Value

 Endosulfans, Total REPORT UG/L Grab 

 (alpha and beta)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Endrin Effluent Gross Value

REPORT UG/L Grab 

RQL = 1

 Toxaphene Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.02

 Heptachlor Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.4

 Heptachlor Epoxide Effluent Gross Value

 PCB-1221 REPORT UG/L Grab 

 (Arochlor 1221)

Effluent Gross Value

 PCB-1232 REPORT UG/L Grab 

 (Arochlor 1232)

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 PCB-1242 REPORT UG/L Grab 

 (Arochlor 1242)

Effluent Gross Value

 PCB-1248 REPORT UG/L Grab 

 (Arochlor 1248)

Effluent Gross Value

 PCB-1254 REPORT UG/L Grab 

 (Arochlor 1254)

Effluent Gross Value

 PCB-1260 REPORT UG/L Grab 

 (Arochlor 1260)

Effluent Gross Value

 Polychlorinated REPORT UG/L Grab 

 Biphenyls (PCBs)

Effluent Gross Value

 Chlorpyrifos Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 20

 2-Chlorophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 18

 2-Nitrophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 2,4-Dichlorophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 13.5

 2,4-Dimethylphenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 40

 2,4-Dinitrophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 2,4,6-Trichloro-

 phenol

Effluent Gross Value

REPORT UG/L Grab 

RQL = 21

 4-Chlorophenyl

 phenyl ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 12

 4-Nitrophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 60

 4,6-Dinitro-o-cresol Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 10

 Phenol

 Single Compound

Effluent Gross Value

REPORT UG/L Grab 

RQL = 30

 Pentachlorophenol Effluent Gross Value

 Pentachlorobenzene Effluent Gross Value REPORT UG/L Grab 

 Guthion Effluent Gross Value REPORT UG/L Grab 

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

003A SW Outfall DSN 003A Great Egg Harbor Bay RF - Stormwater

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

Effluent samples for DSN 003A shall be taken via a grab sample prior to discharge.Storm Water Runoff

Location DescriptionContributing Waste Types

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - B - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MGD 

*****

Effluent REPORT REPORT 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

*****

Effluent 6.0 9.0 SU 2

Gross Value

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Effluent 30 100 MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Solids, Total Suspended

*****

Effluent 10 15 MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Petroleum Hydrocarbons

*****

Effluent REPORT REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Carbon, Tot Organic (TOC)

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - B - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT 0.136 UG/L 1

Gross Value

RQL *** *** *** 8 8

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Arsenic, Total Recoverable (as As)

*****

Effluent 0.75 1.5 MG/L 

Gross Value

RQL *** *** *** 0.01 0.01

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Nickel, Total Recoverable

*****

Effluent 0.5 1.0 MG/L 

Gross Value

RQL *** *** *** 0.03 0.03

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Zinc, Total Recoverable

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - B - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Manganese, Total REPORT UG/L Grab 

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 40

 Cyanide, Total

 (as CN)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Selenium, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Thallium, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Beryllium, Total

 Recoverable (as Be)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Barium, Total

 Recoverable (as Ba)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 2

 Silver,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 4

 Cadmium,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Lead,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Chromium,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Copper,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Antimony, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 1

 Mercury

 Total Recoverable

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - B - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Phenols Effluent Gross Value REPORT UG/L Grab 

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

006A Stormwater Great Egg Harbor Bay RF - Stormwater

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

Effluent samples for DSN 006A shall be taken via a grab sample prior to discharge.Storm Water Runoff

Location DescriptionContributing Waste Types

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - C - 1: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Date of Storm Event Effluent Gross Value REPORT MM/DD/YY Calculated 

 Time Storm REPORT STD TIME Calculated 

 Event Began

Effluent Gross Value

 Storm Event Duration Effluent Gross Value REPORT # HOURS Calculated 

 Hours Since Last REPORT # HOURS Calculated 

 Storm Event

Effluent Gross Value

 Time of Sample REPORT STD TIME Calculated 

 Collection

Effluent Gross Value

 Rainfall Amount at REPORT # INCHES Calculated 

 Time of Sampling

Effluent Gross Value

 pH Effluent Gross Value REPORT SU Grab 

 Solids, Total REPORT MG/L Grab 

 Suspended

Effluent Gross Value

 Oil and Grease Effluent Gross Value REPORT MG/L Grab 

 Petrol Hydrocarbons, REPORT MG/L Grab-3 

 Total Recoverable

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - C - 1: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Oxygen Demand,Chem. REPORT MG/L Grab 

 (High Level) (COD)

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

007A Stormwater Great Egg Harbor Bay RF - Stormwater

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

There are no monitoring requirements for this discharge.Storm Water Runoff

Location DescriptionContributing Waste TypesRequirements have not been defined for this Monitored Location.

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

009A SW Outfall DSN 009A Great Egg Harbor Bay B - Industrial Wastewa

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

Effluent samples for DSN 009A shall be taken at the sampling station for DSN 009A which is before mixing with DSN 010A in the dischSteam Elec Cooling Water

Location DescriptionContributing Waste Types

Surface Water DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

The heat limits for DSN 009A and 010A shall apply to the sum of the heat contributions from both outfalls.

PHASE: PHASE Start Date: PHASE End Date:

Table III - E - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MGD C

*****

Effluent REPORT REPORT 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

MGD C

*****

Intake From REPORT REPORT 

Stream

QL *** *** *** *** ***

Average Average

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

*****

Effluent 6.0 9.0 SU 

Gross Value

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Intake From REPORT REPORT SU 

Stream

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Effluent REPORT 0.2 MG/L 

Gross Value

MDL *** *** *** 0.1 0.1

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chlorine Produced Oxidants

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

The heat limits for DSN 009A and 010A shall apply to the sum of the heat contributions from both outfalls.

PHASE: PHASE Start Date: PHASE End Date:

Table III - E - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT 38.3 DEG.C C

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Intake From REPORT REPORT DEG.C C

Stream

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Effluent REPORT REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Minimum Minimum

 ***** ***** Instant Daily Avg *****

 January thru December

 Oxygen, Dissolved (DO)

MBTU/HR 

*****

Effluent REPORT 1530 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Net Rate of Addition of Heat

*****

Effluent Net REPORT 8.8 DEG.C 

Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 June thru August

 Temp. Difference, Summer (oC)

*****

Effluent Net REPORT 19.3 DEG.C 

Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 September thru May

 Temp. Difference, Winter (oC)

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

010A SW Outfall DSN 010A Great Egg Harbor Bay B - Industrial Wastewa

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

Effluent samples for DSN 010A shall be taken at the sampling station for DSN 010A which is before mixing with DSN 009A in the dischSteam Elec Cooling Water

Location DescriptionContributing Waste Types

Consolidated DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

The heat limits for DSN 009A and 010A shall apply to the sum of the heat contributions from both outfalls. The final phase applies und

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 1: Consolidated DMR Limits and Monitoring Requirements

1-Initial 08/ PHASE Start Date: 01/2013 07/31/2016 PHASE End Date:

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MGD C

*****

Effluent REPORT REPORT 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

MGD C

*****

Intake From REPORT REPORT 

Stream

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

*****

Effluent 6 9 SU 

Gross Value

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Intake From REPORT REPORT SU 

Stream

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Effluent REPORT 0.2 MG/L 

Gross Value

MDL *** *** *** 0.1 0.1

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chlorine Produced Oxidants

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

The heat limits for DSN 009A and 010A shall apply to the sum of the heat contributions from both outfalls. The final phase applies und

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 1: Consolidated DMR Limits and Monitoring Requirements

1-Initial 08/ PHASE Start Date: 01/2013 07/31/2016 PHASE End Date:

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT 38.3 DEG.C C

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Intake From REPORT REPORT DEG.C C

Stream

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Effluent REPORT REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Minimum Minimum

 ***** ***** Instant Daily Avg *****

 January thru December

 Oxygen, Dissolved (DO)

*****

Intake From REPORT REPORT MG/L 

Stream

QL *** *** *** *** ***

Minimum Minimum

 ***** ***** Instant Daily Avg *****

 January thru December

 Oxygen, Dissolved (DO)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Boron, Total (as B)

MBTU/HR 

*****

Effluent REPORT 1530 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Net Rate of Addition of Heat

*****

Effluent Net REPORT 8.8 DEG.C 

Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 June thru August

 Temp. Difference, Summer (oC)

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

The heat limits for DSN 009A and 010A shall apply to the sum of the heat contributions from both outfalls. The final phase applies und

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 1: Consolidated DMR Limits and Monitoring Requirements

1-Initial 08/ PHASE Start Date: 01/2013 07/31/2016 PHASE End Date:

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent Net REPORT 19.3 DEG.C 

Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 September thru May

 Temp. Difference, Winter (oC)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Arsenic, Total Recoverable (as As)

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 2: Consolidated DMR Limits and Monitoring Requirements

2-Final (Repowered) 08/01/2016

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MGD C

*****

Effluent REPORT REPORT 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

MGD C

*****

Intake From REPORT REPORT 

Stream

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

*****

Effluent 6 9 SU 

Gross Value

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

The heat limits for DSN 009A and 010A shall apply to the sum of the heat contributions from both outfalls. The final phase applies und

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 2: Consolidated DMR Limits and Monitoring Requirements

2-Final (Repowered) 08/01/2016

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Intake From REPORT REPORT SU 

Stream

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Effluent REPORT 0.2 MG/L 

Gross Value

MDL *** *** *** 0.1 0.1

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chlorine Produced Oxidants

*****

Effluent REPORT 40.5 DEG.C C

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Intake From REPORT REPORT DEG.C C

Stream

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Effluent REPORT REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Minimum Minimum

 ***** ***** Instant Daily Avg *****

 January thru December

 Oxygen, Dissolved (DO)

*****

Intake From REPORT REPORT MG/L 

Stream

QL *** *** *** *** ***

Minimum Minimum

 ***** ***** Instant Daily Avg *****

 January thru December

 Oxygen, Dissolved (DO)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Boron, Total (as B)

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated DMR Reporting Requirements:

Comments:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

The heat limits for DSN 009A and 010A shall apply to the sum of the heat contributions from both outfalls. The final phase applies und

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 2: Consolidated DMR Limits and Monitoring Requirements

2-Final (Repowered) 08/01/2016

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MBTU/HR 

*****

Effluent REPORT 1530 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Net Rate of Addition of Heat

*****

Effluent Net REPORT 11.0 DEG.C 

Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 June thru August

 Temp. Difference, Summer (oC)

*****

Effluent Net REPORT 19.3 DEG.C 

Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 September thru May

 Temp. Difference, Winter (oC)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Arsenic, Total Recoverable (as As)

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Manganese, Total REPORT UG/L Grab 

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 40

 Cyanide, Total

 (as CN)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Selenium, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Thallium, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Beryllium, Total

 Recoverable (as Be)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Barium, Total

 Recoverable (as Ba)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Nickel,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 2

 Silver,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 30

 Zinc,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 4

 Cadmium,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Lead,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Chromium,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Copper,

 Total Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Antimony, Total

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 1

 Mercury

 Total Recoverable

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 10

 Acenaphthylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 Acenaphthene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Anthracene Effluent Gross Value

 Benzo(b)fluoranthene REPORT UG/L Grab 

 (3,4-benzo)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Benzo(k)fluoranthene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Benzo(a)pyrene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Bis(2-chloroethyl)

 ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 26.5

 Bis(2-chloroethoxy)

 methane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Bis (2-chloroiso-

 propyl) ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Butyl benzyl

 phthalate

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Chrysene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Diethyl phthalate Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Dimethyl phthalate Effluent Gross Value

 1,2-Diphenyl- REPORT UG/L Grab 

 hydrazine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Fluoranthene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 10

 Fluorene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Hexachlorocyclo-

 pentadiene

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Hexachloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Indeno(1,2,3-cd)-

 pyrene

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Isophorone Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 N-nitrosodi-n-

 propylamine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 N-nitrosodiphenyl-

 amine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 N-nitrosodimethyl-

 amine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Nitrobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Phenanthrene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Pyrene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Benzo(ghi)perylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Benzo(a)anthracene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 1,2-Dichlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 1,2,4-Trichloro-

 benzene

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 20

 Dibenzo(a,h)

 anthracene

Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 1,3-Dichlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 1,4-Dichlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 2-Chloronaphthalene Effluent Gross Value

 Di-n-octyl Phthalate Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 10

 2,4-Dinitrotoluene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 2,6-Dinitrotoluene Effluent Gross Value

REPORT UG/L Grab 

RQL = 60

 3,3'-Dichloro-

 benzidine

Effluent Gross Value

REPORT UG/L Grab 

RQL = 9.5

 4-Bromophenyl phenyl

 ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 8

 Naphthalene Effluent Gross Value

REPORT UG/L Grab 

RQL = 30

 Bis(2-ethylhexyl)

 phthalate

Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 Di-n-butyl phthalate Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Benzidine Effluent Gross Value

 Malathion Effluent Gross Value REPORT UG/L Grab 

 Demeton Effluent Gross Value REPORT UG/L Grab 

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 10

 Hexachlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Hexachlorobutadiene Effluent Gross Value

 Mirex Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 7

 1,3-Dichloropropene Effluent Gross Value

 1,2,4,5-Tetrachloro- REPORT UG/L Grab 

 benzene

Effluent Gross Value

 N-nitrosodiethyl- REPORT UG/L Grab 

 amine

Effluent Gross Value

 N-nitrosopyrrolidine Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 6

 Carbon Tetrachloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 3

 1,2-Dichloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 8

 Bromoform Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Chloroform Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Toluene Effluent Gross Value

REPORT UG/L Grab 

RQL = 7

 Benzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Acrolein Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Acrylonitrile Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 6

 Chlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Chlorodibromomethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Ethylbenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 Methyl Bromide Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Methyl Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Methylene Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 Tetrachloroethylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Trichlorofluoro-

 methane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 23.5

 1,1-Dichloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1-Dichloroethylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1,1-Trichloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1,2-Trichloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 1,1,2,2-Tetrachloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 1,2-Dichloropropane Effluent Gross Value

REPORT UG/L Grab 

RQL = 4

 1,2-trans-Dichloro-

 ethylene

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 2-Chloroethyl REPORT UG/L Grab 

 Vinyl Ether (Mixed)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Bromodichloromethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Vinyl Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Trichloroethylene Effluent Gross Value

 Methoxychlor Effluent Gross Value REPORT UG/L Grab 

 N-Nitrosodi- REPORT UG/L Grab 

 n-butylamine

Effluent Gross Value

 Chloroethane Effluent Gross Value REPORT UG/L Grab 

 Parachloro-m- REPORT UG/L Grab 

 cresol

Effluent Gross Value

 Parathion Effluent Gross Value REPORT UG/L Grab 

 Phenols Effluent Gross Value REPORT UG/L Grab 

 2,4,5-Trichloro- REPORT UG/L Grab 

 phenol

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.02

 Delta BHC,

 Total (ug/l)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.08

 Endosulfan Sulfate Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Beta Endosulfan Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.02

 Alpha Endosulfan Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 0.1

 Endrin Aldehyde Effluent Gross Value

 PCB-1016 REPORT UG/L Grab 

 (Arochlor 1016)

Effluent Gross Value

 2,3,7,8-Tetrachloro- REPORT UG/L Grab 

 dibenzo-p-dioxin

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.06

 4,4'-DDT(p,p'-DDT) Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 4,4'-DDD(p,p'-DDD) Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 4,4'-DDE(p,p'-DDE) Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Aldrin Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.02

 Alpha BHC Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Beta BHC Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.03

 Gamma BHC (lindane), Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.2

 Chlordane Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.03

 Dieldrin Effluent Gross Value

 Endosulfans, Total REPORT UG/L Grab 

 (alpha and beta)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.04

 Endrin Effluent Gross Value

REPORT UG/L Grab 

RQL = 1

 Toxaphene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 0.02

 Heptachlor Effluent Gross Value

REPORT UG/L Grab 

RQL = 0.4

 Heptachlor Epoxide Effluent Gross Value

 PCB-1221 REPORT UG/L Grab 

 (Arochlor 1221)

Effluent Gross Value

 PCB-1232 REPORT UG/L Grab 

 (Arochlor 1232)

Effluent Gross Value

 PCB-1242 REPORT UG/L Grab 

 (Arochlor 1242)

Effluent Gross Value

 PCB-1248 REPORT UG/L Grab 

 (Arochlor 1248)

Effluent Gross Value

 PCB-1254 REPORT UG/L Grab 

 (Arochlor 1254)

Effluent Gross Value

 PCB-1260 REPORT UG/L Grab 

 (Arochlor 1260)

Effluent Gross Value

 Polychlorinated REPORT UG/L Grab 

 Biphenyls (PCBs)

Effluent Gross Value

 Chlorpyrifos Effluent Gross Value REPORT UG/L Grab 

REPORT UG/L Grab 

RQL = 20

 2-Chlorophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 18

 2-Nitrophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 2,4-Dichlorophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 13.5

 2,4-Dimethylphenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 40

 2,4-Dinitrophenol Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 20

 2,4,6-Trichloro-

 phenol

Effluent Gross Value

REPORT UG/L Grab 

RQL = 21

 4-Chlorophenyl

 phenyl ether

Effluent Gross Value

REPORT UG/L Grab 

RQL = 12

 4-Nitrophenol Effluent Gross Value

REPORT UG/L Grab 

RQL = 60

 4,6-Dinitro-o-cresol Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Phenol

 Single Compound

Effluent Gross Value

REPORT UG/L Grab 

RQL = 30

 Pentachlorophenol Effluent Gross Value

 Pentachlorobenzene Effluent Gross Value REPORT UG/L Grab 

 Guthion Effluent Gross Value REPORT UG/L Grab 

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

013A SW Outfall DSN 013A Great Egg Harbor Bay B - Industrial Wastewa

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

Effluent samples for DSN 013A shall be taken at the sampling station for DSN 013A which is after the last stage of treatment prior to disthe pipe identified as DSN 013A.Process Water

Location DescriptionContributing Waste Types

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MGD C

*****

Effluent REPORT REPORT 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

*****

Effluent 6.0 9.0 SU C

Gross Value

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

*****

Effluent 30 100 MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Solids, Total Suspended

*****

Effluent REPORT %EFFL 

Gross Value

 AL *** *** 50 *** ***

Minimum

 ***** ***** Report Per ***** *****

 January thru December

 LC50 Statre 96hr Acu Mysid Bahia

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent 4.0 5.0 MG/L 

Gross Value

QL *** *** *** *** ***

Minimum Minimum

 ***** ***** Instant Daily Avg *****

 January thru December

 Oxygen, Dissolved (DO)

*****

Effluent 10 15 MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Petroleum Hydrocarbons

Effluent REPORT REPORT KG/DAY 21 REPORT MG/L 

Gross Value

QL *** *** *** *** ***

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 Carbon, Tot Organic (TOC)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** *** 8

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Selenium, Total Recoverable

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** *** 10

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Arsenic, Total (as As)

*****

Effluent REPORT 1.0 MG/L 1

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Iron, Total (as Fe)

*****

Effluent REPORT 1.0 MG/L 1

Gross Value

RQL *** *** *** *** 0.01

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Nickel, Total Recoverable

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT 1.0 MG/L 1

Gross Value

RQL *** *** *** *** 0.03

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Zinc, Total Recoverable

*****

Effluent REPORT 0.2 MG/L 1

Gross Value

RQL *** *** *** *** 0.01

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Chromium, Total Recoverable

*****

Effluent REPORT 8.7 UG/L 

Gross Value

RQL *** *** *** *** 10

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Copper, Total Recoverable

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Manganese, Total REPORT UG/L 4 Hour Composite 

 Recoverable

Effluent Gross Value

REPORT UG/L Grab 

RQL = 40

 Cyanide, Total

 (as CN)

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Thallium, Total

 Recoverable

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Beryllium, Total

 Recoverable (as Be)

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Barium, Total

 Recoverable (as Ba)

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 2

 Silver,

 Total Recoverable

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 4

 Cadmium,

 Total Recoverable

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Lead,

 Total Recoverable

Effluent Gross Value

 Chromium, Hexavalent REPORT UG/L 4 Hour Composite 

 Dissolved (as Cr)

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Antimony, Total

 Recoverable

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 1

 Mercury

 Total Recoverable

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Acenaphthylene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 9.5

 Acenaphthene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Anthracene Effluent Gross Value

 Benzo(b)fluoranthene REPORT UG/L 4 Hour Composite 

 (3,4-benzo)

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L 4 Hour Composite 

RQL = 20

 Benzo(k)fluoranthene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Benzo(a)pyrene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Bis(2-chloroethyl)

 ether

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 26.5

 Bis(2-chloroethoxy)

 methane

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Bis (2-chloroiso-

 propyl) ether

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Butyl benzyl

 phthalate

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Chrysene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Diethyl phthalate Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Dimethyl phthalate Effluent Gross Value

 1,2-Diphenyl- REPORT UG/L 4 Hour Composite 

 hydrazine

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Fluoranthene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Fluorene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Hexachlorocyclo-

 pentadiene

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Hexachloroethane Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Indeno(1,2,3-cd)-

 pyrene

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L 4 Hour Composite 

RQL = 10

 Isophorone Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 N-nitrosodi-n-

 propylamine

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 N-nitrosodiphenyl-

 amine

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 N-nitrosodimethyl-

 amine

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Nitrobenzene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Phenanthrene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Pyrene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Benzo(ghi)perylene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Benzo(a)anthracene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 1,2-Dichlorobenzene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 1,2,4-Trichloro-

 benzene

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Dibenzo(a,h)

 anthracene

Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 1,3-Dichlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 20

 1,4-Dichlorobenzene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 9.5

 2-Chloronaphthalene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Di-n-octyl Phthalate Effluent Gross Value REPORT UG/L 4 Hour Composite 

REPORT UG/L 4 Hour Composite 

RQL = 10

 2,4-Dinitrotoluene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 9.5

 2,6-Dinitrotoluene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 60

 3,3'-Dichloro-

 benzidine

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 9.5

 4-Bromophenyl phenyl

 ether

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 8

 Naphthalene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 30

 Bis(2-ethylhexyl)

 phthalate

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 Di-n-butyl phthalate Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 50

 Benzidine Effluent Gross Value

 Malathion Effluent Gross Value REPORT UG/L 4 Hour Composite 

 Demeton Effluent Gross Value REPORT UG/L 4 Hour Composite 

REPORT UG/L 4 Hour Composite 

RQL = 10

 Hexachlorobenzene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 Hexachlorobutadiene Effluent Gross Value

 Mirex Effluent Gross Value REPORT UG/L 4 Hour Composite 

REPORT UG/L Grab 

RQL = 7

 1,3-Dichloropropene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 1,2,4,5-Tetrachloro- REPORT UG/L 4 Hour Composite 

 benzene

Effluent Gross Value

 N-nitrosodiethyl- REPORT UG/L 4 Hour Composite 

 amine

Effluent Gross Value

 N-nitrosopyrrolidine Effluent Gross Value REPORT UG/L 4 Hour Composite 

REPORT UG/L Grab 

RQL = 6

 Carbon Tetrachloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 3

 1,2-Dichloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 8

 Bromoform Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Chloroform Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Toluene Effluent Gross Value

REPORT UG/L Grab 

RQL = 7

 Benzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Acrolein Effluent Gross Value

REPORT UG/L Grab 

RQL = 50

 Acrylonitrile Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Chlorobenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Chlorodibromomethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Ethylbenzene Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 Methyl Bromide Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L Grab 

RQL = 10

 Methyl Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 Methylene Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 9

 Tetrachloroethylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Trichlorofluoro-

 methane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 23.5

 1,1-Dichloroethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1-Dichloroethylene Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1,1-Trichloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 6

 1,1,2-Trichloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 1,1,2,2-Tetrachloro-

 ethane

Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 1,2-Dichloropropane Effluent Gross Value

REPORT UG/L Grab 

RQL = 4

 1,2-trans-Dichloro-

 ethylene

Effluent Gross Value

 2-Chloroethyl REPORT UG/L Grab 

 Vinyl Ether (Mixed)

Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Bromodichloromethane Effluent Gross Value

REPORT UG/L Grab 

RQL = 10

 Vinyl Chloride Effluent Gross Value

REPORT UG/L Grab 

RQL = 5

 Trichloroethylene Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Methoxychlor Effluent Gross Value REPORT UG/L 4 Hour Composite 

 N-Nitrosodi- REPORT UG/L 4 Hour Composite 

 n-butylamine

Effluent Gross Value

 Chloroethane Effluent Gross Value REPORT UG/L Grab 

 Parachloro-m- REPORT UG/L 4 Hour Composite 

 cresol

Effluent Gross Value

 Parathion Effluent Gross Value REPORT UG/L 4 Hour Composite 

 Phenols Effluent Gross Value REPORT UG/L Grab 

 2,4,5-Trichloro- REPORT UG/L 4 Hour Composite 

 phenol

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.02

 Delta BHC,

 Total (ug/l)

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.08

 Endosulfan Sulfate Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.04

 Beta Endosulfan Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.02

 Alpha Endosulfan Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.1

 Endrin Aldehyde Effluent Gross Value

 PCB-1016 REPORT UG/L 4 Hour Composite 

 (Arochlor 1016)

Effluent Gross Value

 2,3,7,8-Tetrachloro- REPORT UG/L 4 Hour Composite 

 dibenzo-p-dioxin

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.06

 4,4'-DDT(p,p'-DDT) Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L 4 Hour Composite 

RQL = 0.04

 4,4'-DDD(p,p'-DDD) Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.04

 4,4'-DDE(p,p'-DDE) Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.04

 Aldrin Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.02

 Alpha BHC Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.04

 Beta BHC Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.03

 Gamma BHC (lindane), Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.2

 Chlordane Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.03

 Dieldrin Effluent Gross Value

 Endosulfans, Total REPORT UG/L 4 Hour Composite 

 (alpha and beta)

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.04

 Endrin Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 1

 Toxaphene Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.02

 Heptachlor Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 0.4

 Heptachlor Epoxide Effluent Gross Value

 PCB-1221 REPORT UG/L 4 Hour Composite 

 (Arochlor 1221)

Effluent Gross Value

 PCB-1232 REPORT UG/L 4 Hour Composite 

 (Arochlor 1232)

Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 PCB-1242 REPORT UG/L 4 Hour Composite 

 (Arochlor 1242)

Effluent Gross Value

 PCB-1248 REPORT UG/L 4 Hour Composite 

 (Arochlor 1248)

Effluent Gross Value

 PCB-1254 REPORT UG/L 4 Hour Composite 

 (Arochlor 1254)

Effluent Gross Value

 PCB-1260 REPORT UG/L 4 Hour Composite 

 (Arochlor 1260)

Effluent Gross Value

 Polychlorinated REPORT UG/L 4 Hour Composite 

 Biphenyls (PCBs)

Effluent Gross Value

 Chlorpyrifos Effluent Gross Value REPORT UG/L 4 Hour Composite 

REPORT UG/L 4 Hour Composite 

RQL = 20

 2-Chlorophenol Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 18

 2-Nitrophenol Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 10

 2,4-Dichlorophenol Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 13.5

 2,4-Dimethylphenol Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 40

 2,4-Dinitrophenol Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 20

 2,4,6-Trichloro-

 phenol

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 21

 4-Chlorophenyl

 phenyl ether

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 12

 4-Nitrophenol Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 60

 4,6-Dinitro-o-cresol Effluent Gross Value

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Consolidated WCR - Annual Reporting Requirements:

Submit an Annual WCR: within twenty-five days after the end of every 12 month monitoring period beginning from the effective date of 

PHASE: PHASE Start Date: PHASE End Date:

Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

REPORT UG/L 4 Hour Composite 

RQL = 10

 Phenol

 Single Compound

Effluent Gross Value

REPORT UG/L 4 Hour Composite 

RQL = 30

 Pentachlorophenol Effluent Gross Value

 Pentachlorobenzene Effluent Gross Value REPORT UG/L 4 Hour Composite 

 Guthion Effluent Gross Value REPORT UG/L 4 Hour Composite 

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

014A SW Outfall DSN 014A Great Egg Harbor Bay B - Industrial Wastewa

MONITORED LOCATION: RECEIVING LOCATION: DISCHARGE CATEGORY

Effluent samples for DSN 014A shall be taken at the sampling station for DSN 014A (located in the scrubber/wastewater treatment buildparameters with the exception of whole effluent toxicity (WET). Samples for WET shall be taken at the discharge canal for DSN 010A a014A discharges into it.Process Water

Location DescriptionContributing Waste Types

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - H - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

MGD C

*****

Effluent REPORT REPORT 

Gross Value

QL *** *** *** *** ***

Average Maximum

Monthly Daily ***** ***** *****

 January thru December

 Flow, In Conduit or Thru Treatment Plant

Effluent REPORT REPORT KG/DAY REPORT REPORT MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 BOD, 5-Day (20 oC)

*****

Effluent 6.0 9.0 SU 

Gross Value

QL *** *** *** *** ***

Minimum Maximum

 ***** ***** Daily ***** Daily

 January thru December

 pH

Effluent 8.18 27.25 KG/DAY 30 100 MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 Solids, Total Suspended

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - H - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT %EFFL 

Gross Value

 AL *** *** 50 *** ***

Minimum

 ***** ***** Report Per ***** *****

 January thru December

 LC50 Statre 96hr Acu Mysid Bahia

*****

Effluent REPORT REPORT DEG.C 

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Temperature, oC

*****

Effluent 10 15 MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Petroleum Hydrocarbons

Effluent REPORT REPORT KG/DAY REPORT REPORT MG/L 2

Gross Value

QL *** *** *** *** ***

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 Carbon, Tot Organic (TOC)

Effluent 1.1 2.1 KG/DAY 3900 7900 UG/L 

Gross Value

QL *** *** *** *** ***

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 Sulfide, Total (as S)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Sulfate, Total (as SO4)

*****

Effluent REPORT REPORT MG/L 1/

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Iron, Total Recoverable

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - H - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

QL *** *** *** *** ***

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Boron, Total (as B)

Effluent 0.23 0.45 KG/DAY 830 1700 UG/L 

Gross Value

RQL *** *** *** 8 8

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 Arsenic, Total Recoverable (as As)

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** 10 10

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Selenium, Total Recoverable

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** 30 30

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Zinc, Total Recoverable

Effluent 0.47 0.95 KG/DAY 1700 3500 UG/L 

Gross Value

RQL *** *** *** 10 10

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 Copper, Total Recoverable

Effluent 0.013 0.027 KG/DAY 49 98 UG/L 

Gross Value

RQL *** *** *** 1 1

Average Maximum Average Maximum

Monthly Daily ***** Monthly Daily

 January thru December

 Mercury Total Recoverable

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Surface Water DMR Reporting Requirements:

Submit a Monthly DMR: Within twenty-five days after the end of every month beginning from the effective date of the permit (EDP)..

PHASE: PHASE Start Date: PHASE End Date:

Table III - H - 1: Surface Water DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Effluent REPORT REPORT UG/L 1/

Gross Value

RQL *** *** *** 30 30

Average Maximum

 ***** ***** ***** Monthly Daily

 January thru December

 Bis(2-ethylhexyl) phthalate

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

SI6A Belt Filter Press B - Industrial Wastewater

MONITORED LOCATION: DISCHARGE CATEGORY(IES):

Annually, a representative sample of the belt filter pressed sludge generated from wastewater treatment shall be analyzed pursuant to the Assurance Regulations (SQAR, N.J.A.C. 7:14C) each year sludge is removed for ultimate management.Ind Residual-Other

Location DescriptionContributing Waste Types

Residuals DMR Reporting Requirements:

Submit an Annual DMR: due 60 calendar days after the end of each calendar year.

PHASE: PHASE Start Date: PHASE End Date:

Table III - I - 1: Residuals DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Industrial REPORT %TS 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Solids, Total

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Nitrate Nitrogen, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Nitrogen, Kjeldahl Total, Dry Wt

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Potassium Dry Weight

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Residuals DMR Reporting Requirements:

Submit an Annual DMR: due 60 calendar days after the end of each calendar year.

PHASE: PHASE Start Date: PHASE End Date:

Table III - I - 1: Residuals DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Nitrogen, Ammonia Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Calcium Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Molybdenum Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Phosphorus Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Arsenic, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Selenium, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Copper, Dry Weight

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Residuals DMR Reporting Requirements:

Submit an Annual DMR: due 60 calendar days after the end of each calendar year.

PHASE: PHASE Start Date: PHASE End Date:

Table III - I - 1: Residuals DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Beryllium Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Cadmium, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Zinc, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Lead, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Nickel, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Mercury, Dry Weight

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Chromium, Dry Weight

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Residuals DMR Reporting Requirements:

Submit an Annual DMR: due 60 calendar days after the end of each calendar year.

PHASE: PHASE Start Date: PHASE End Date:

Table III - I - 1: Residuals DMR Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Limit Units Sample Point Limit Units Limit Limit Limit Limit Units F

F

*****

Industrial REPORT MG/KG 

Residuals

QL *** *** *** *** ***

Average

 ***** ***** ***** Monthly *****

 January thru December

 Iron, Dry Weight

Residuals WCR - Annual Reporting Requirements:

Submit an Annual WCR: due 60 calendar days after the end of each calendar year.

PHASE: PHASE Start Date: PHASE End Date:

Table III - I - 3: Residuals WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Amt Sludge Rmvd, REPORT WCY/YR Calculated 

 Wet Cubic Yards

Industrial Residuals

 Amt Sludge Rmvd, REPORT WMT/YR Calculated 

 Wet Metric Tons

Industrial Residuals

 Amt Sludge Rmvd, REPORT GAL/YEAR Calculated 

 Gallons

Industrial Residuals

 Total Amount of REPORT DMT/YR Calculated 

 Sludge Removed

Industrial Residuals

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Residuals WCR - Annual Reporting Requirements:

Submit an Annual WCR: due 60 calendar days after the end of each calendar year.

PHASE: PHASE Start Date: PHASE End Date:

Table III - I - 3: Residuals WCR - Annual Limits and Monitoring Requirements

Final 08/01/2013

Parameter Sample Point Compliance Quantity Units Sample Type 

 Solids, Total Industrial Residuals REPORT %TS Composite 

Limits And Monitoring Requirements 
PER

B L ENGLAND GENERATING STATION, Beesleys Point

Residuals Transfer Reporting Requirements:

Submit an Annual RTR: due 60 calendar days after the end of each calendar year.

Limits And Monitoring Requirements 
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

PART IV

SPECIFIC REQUIREMENTS: NARRATIVE

Notes and Definitions

1. Stormwater Notes

a. The following notes refer to the monitoring requirements contained in the tables located in Part III

of the permit.

i. No visible sheen. The parameter Petroleum Hydrocarbons shall be analyzed in accordance with

N.J.A.C. 7:14A-12.8 et seq.

ii. The term "Daily Min." means to report minimum value obtained (usually only applied to pH).

iii. The term "Average" means to report the average value of the results.

iv. The term "Daily Max." means to report the analytical result which yielded the highest

concentration.

v. "NL" means not limited, but monitoring and reporting is required.

vi. Reporting of analytical results shall follow the procedures described in the Department's

"Discharge Monitoring Report Instruction Manual" (latest revision).

vii. Grab samples shall be collected at the designated sampling points and shall be collected as soon

as practicable within 30 minutes and no later than 45 minutes after the start of the stormwater

discharge (ASWD). For sampling, follow guidelines in, "NJDEP Field Sampling Procedures

Manual", latest edition.

viii. Grab -3 is a multi-grab sample that shall be collected at the sampling points as follows: the first

grab sample shall be collected (in accordance with "NJDEP Field Sampling Procedures Manual",

latest edition) within 30 minutes (or as soon thereafter as practicable) after stormwater discharge

(ASWD); the second grab between 30 and 45 minutes ASWD (or as soon thereafter as

practicable); and the third grab between 45 and 60 minutes ASWD (or as soon thereafter as

practicable).

ix. pH values that are measured below lower pH limit are not in violation if they are not lower than

the measured pH of the precipitation collected on site during the storm event. To qualify for this

exception, pH of that precipitation must be reported on the monitoring report form as "Rain" pH.

x. A "discernible, confined and discrete conveyance" includes, but is not limited to, a pipe, ditch or

channel. Examples of such conveyances include storm sewer pipes, drainage ditches, spillways,

gullies, swales, gutters, curbs and streets.

2. Stormwater Definitions

a. Unless otherwise stated in this permit, the definitions set forth at N.J.A.C. 7:14A-1.2 and

Discharge Monitoring Report (DMR) Instruction Manual are incorporated into this permit.

i. "Annual monitoring" means monitoring conducted at a minimum frequency of once every

calendar year, beginning with the Effective Date of the Permit unless there is a different period

specified in the permit.

Notes and Definitions Page 1 of 24
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

ii. "Composite Sample" means a combination of individual (or continuously taken) samples

(aliquots) of at least 100 milliliters, collected at periodic intervals over a specified time period.

The composite can be either time proportional or flow proportional; either the time interval

between each aliquot or the volume of each aliquot should be proportional to either the flow at

the time of sampling or the total flow since the collection of the previous aliquot. Aliquots may

be collected manually or automatically. For intermittent discharges less than 4 hours duration,

aliquots shall be taken at intervals not to exceed 15 minutes. For intermittent discharges of 4

hours or more duration, aliquots shall be taken at intervals not to exceed 30 minutes.

iii. "EDP" means Effective Date of the Permit.

iv. "EDPM" means the Effective Date of the Permit Modification".

v. "mg/L" means milligrams per liter.

vi. "Outfall" shall mean (a) a point within the facility at which stormwater associated with the

facility's industrial activity enters a surface water body from a discernible, confined and discrete

conveyance; or (b) a point at which stormwater associated with the facility's industrial activity

enters a surface water body from a discernible, confined and discrete conveyance for transport as

stormwater to an offsite surface water body.

vii. "Process wastewater" means any water which, during manufacturing or processing, comes into

direct contact with or results from the production or use of any raw material, intermediate

product, finished product, byproduct, or waste product. Process wastewater includes, but is not

limited to, "leachate" and cooling water other than " non-contact cooling water". (Please note

that for the purposes of this NJPDES permit, the stormwater discharges regulated by this permit

are not process wastewater)

viii. "Monthly Monitoring" means monitoring conducted at a minimum frequency of once every

month, beginning with the EDP unless there is a different period specified.

ix. "Quarterly Monitoring "means monitoring conducted at a minimum frequency of once every

three calendar months, beginning with the EDP unless there is a different period specified in the

permit.

x. "Semiannual Monitoring" means monitoring conducted at a minimum frequency of once every

six calendar months, beginning with the EDP unless there is a different period specified in the

permit.

xi. "Weekly Monitoring" means monitoring conducted at a minimum of once every seven calendar

day period, beginning with the EDP unless there is a different period specified.

xii. "Separate Storm Sewer" means a conveyance or system of conveyances (including roads with

drainage systems, streets, catch basins, gutters, ditches, man-made channels, or storm drains): 1.

Designed or used for collecting or conveying stormwater; 2. Which is not part of a combined

sewer system; and 3. Which is not part of a publicly owned treatment works (POTW)

xiii. "Seven Day" or "Weekly Average Value" means the greatest sum of all daily discharges

measured during any seven consecutive days, divided by the number of daily discharges

measured during that period. Results may be expressed in loading (g/day or kg/d) and/or

concentration (ug/L or mg/L). Only data collected within a single calendar month may be used

in the calculation of a seven day or weekly average value for that month.

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PER050003 Consolidated Renewal Permit Action

xiv. "Source materials" means any materials or machinery located at the facility and directly or

indirectly related to process or other industrial activities which could be a source of pollutants in

a stormwater discharge associated with industrial activity that is subject to N.J.A.C. 7:14A-11.5.

Source materials include, but are not limited to: raw materials; intermediate products; final

products; waste materials; by-products; industrial machinery and fuels; and lubricants, solvents,

and detergents that are related to process or other industrial activities. Material or machinery

that are not exposed to stormwater or that are not located at the facility are not "source

materials".

xv. "Stormwater" means stormwater runoff, snow melt runoff, surface runoff and drainage

xvi. "ug/L " means micrograms per liter.

xvii. "Multiple Grab Composite" or " Multi-Grab" means a combination of individual samples

(aliquots) collected at a specified frequency over a specified time period. Each aliquot must be

collected in a glass vial with a septum cap and iced until delivered for analysis. An air space

should remain in the vial. Each aliquot shall be analyzed individually. The recorded value will

be the flow proportioned average of the individual analyses for the specific time period.

xviii."Maximum Value" means the highest value measured during the monitoring period.

xix. "Minimum Value" means the lowest value measured during the monitoring period.

xx. "DMR" means a Discharge Monitoring Report form prepared by the Department.

xxi. "WCR" means a Wastewater Characterization Report form prepared by the Department.

Notes and Definitions Page 3 of 24
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

Industrial Wastewater

A. MONITORING REQUIREMENTS

1. Standard Monitoring Requirements

a. Each analysis required by this permit shall be performed by a New Jersey Certified Laboratory that

is certified to perform that analysis.

b. The Permittee shall perform all water/wastewater analyses in accordance with the analytical test

procedures specified in 40 CFR 136 unless other test procedures have been approved by the

Department in writing or as otherwise specified in the permit.

c. The permittee shall utilize analytical methods that will ensure compliance with the Quantification

Levels (QLs) listed in PART III. QLs include, but are not limited to, Recommended

Quantification Levels (RQLs) and Method Detection Levels (MDLs). If the permittee and/or

contract laboratory determines that the QLs achieved for any pollutant(s) generally will not be as

sensitive as the QLs specified in PART III, the permittee must submit a justification of such to the

Bureau of Surface Water Permitting. For limited parameters with no QL specified, the sample

analysis shall use a detection level at least as sensitive as the effluent limit.

d. All sampling shall be conducted in accordance with the Department's Field Sampling Procedures

Manual, or an alternate method approved by the Department in writing.

e. All monitoring shall be conducted as specified in Part III.

f. All sample frequencies expressed in Part III are minimum requirements. Any additional samples

taken consistent with the monitoring and reporting requirements contained herein shall be reported

on the Monitoring Report Forms.

g. Annual and semi-annual wastewater testing shall be conducted in a different quarter of each year

so that tests are conducted in each of the four permit quarters of the permit cycle. Testing may be

conducted during any month of the permit quarters.

h. Monitoring for Wastewater Characterization Report parameters shall be conducted concurrently

with the Whole Effluent Toxicity (WET) monitoring, when feasible.

i. Any influent and effluent sampling for toxic pollutant analyses shall be collected concurrently.

j. The permittee shall perform all residual analyses in accordance with the analytical test procedures

specified in 40 CFR 503.8 and the Sludge Quality Assurance Regulations (N.J.A.C. 7:14C) unless

other test procedures have been approved by the Department in writing or as otherwise specified in

the permit.

k. DSN 001A - Flow is calculated based on the position of the control valve. The valve should be

installed, calibrated and maintined to ensure that the instrumentation maintains accurate and

precise measurements. DSN 009A and 010A - Flow shall be calculated based on the operating

mode of the pumps. DSN 013A and 014A - Flow shall be metered.

l. The net amount of heat per unit time shall be calculated by multiplying heat capacity, discharge

flow, and discharge-intake temperature difference. The heat limits for DSN 009A and 010A shall

apply to the sum of the heat contributions from both outfalls.

m. Chlorine Produced Oxidants samples shall be taken once during each two hour period of

bromination.

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PER050003 Consolidated Renewal Permit Action

Industrial Wastewater

n. Net limitations shall be calculated by using the following formula: [(gross effluent

concentration)*(gross effluent flow) - (intake concentration)*(intake flow)] / [gross effluent flow].

Individual intake and effluent flow values for that day shall be utilized in the above calculation.

B. RECORDKEEPING

1. Standard Recordkeeping Requirements

a. The permittee shall retain records of all monitoring information, including 1) all calibration and

maintenance records and all original strip chart recordings for continuous monitoring

instrumentation (if applicable), 2) copies of all reports required by this NJPDES permit, 3) all data

used to complete the application for a NJPDES permit, and 4) monitoring information required by

the permit related to the permittee's residual use and/or disposal practices, for a period of at least 5

years, or longer as required by N.J.A.C. 7:14A-20, from the date of the sample, measurement,

report, application or record.

b. Records of monitoring information shall include 1) the date, locations, and time of sampling or

measurements, 2) the individual(s) who performed the sampling or measurements, 3) the date(s)

the analyses were performed, 4) the individual(s) who performed the analyses, 5) the analytical

techniques or methods used, and 6) the results of such analyses.

C. REPORTING

1. Standard Reporting Requirements

a. The permittee shall submit all required monitoring results to the Department on the forms provided

to them. The Monitoring Report Forms (MRFs) may be provided to the permittee in either a paper

format or in an electronic file format. Unless otherwise noted, all requirements below pertain to

both paper and electronic formats.

b. Any MRFs in paper format shall be submitted to the following addresses:

i. NJDEP

Division of Water Quality

Administrative Section

Mail Code 401-02B P.O. Box 420

Trenton, New Jersey 08625-0420.

ii. (if requested by the Water Compliance and Enforcement Bureau)

NJDEP: Southern Bureau of Water Compliance and Enforcement

One Port Center

2 Riverside Drive, Suite 201

Camden, New Jersey 08103

c. Any electronic data submission shall be in accordance with the guidelines and provisions outlined

in the Department's Electronic Data Interchange (EDI) agreement with the permittee. Paper copies

must be available for on-site inspection by DEP personnel or provided to the DEP upon written

request.

d. All monitoring report forms shall be certified by the highest ranking official having day-to-day

managerial and operational responsibilities for the discharging facility.

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

e. The highest ranking official may delegate responsibility to certify the monitoring report forms in

his or her absence. Authorizations for other individuals to sign shall be made in accordance with

N.J.A.C. 7:14A-4.9(b).

f. Monitoring results shall be submitted in accordance with the current Discharge Monitoring Report

Manual and any updates thereof.

g. If monitoring for a parameter is not required in a monitoring period, the permittee must report

"CODE=N" for that parameter.

h. If there are no discharge events during an entire monitoring period, the permittee must notify the

Department when submitting the monitoring results. This is accomplished by placing a check

mark in the "No Discharge this monitoring period" box on the paper or electronic version of the

monitoring report submittal form.

D. SUBMITTALS

1. Standard Submittal Requirements

a. The permittee shall amend the Operation & Maintenance Manual whenever there is a change in the

treatment works design, construction, operations or maintenance which substantially changes the

treatment works operations and maintenance procedures.

E. FACILITY MANAGEMENT

1. Discharge Requirements

a. The permittee shall discharge at the location(s) specified in PART III of this permit.

b. The permittee shall not discharge foam or cause foaming of the receiving water that: 1) Forms

objectionable deposits on the receiving water, 2) Forms floating masses producing a nuisance, or

3) Interferes with a designated use of the waterbody.

c. The permittee's discharge shall not produce objectionable color or odor in the receiving stream.

d. The discharge shall not exhibit a visible sheen.

e. When quantification levels (QL) and effluent limits are both specified for a given parameter in Part

III, and the QL is less stringent than the effluent limit, effluent compliance will be determined by

comparing the reported value against the QL.

f. The Permittee is authorized to use the following corrosion inhibitors, biocides, or other cooling

water additives: Trisodium Phosphate, Hydrated Lime, Sulfuric Acid, Cleartreat, Di-Sodium

Phosphate, Bromine and Spectrus OX1200. Use of additional additives requires Departmental

approval. The permittee shall submit any request to add or modify additives that are not already

approved at least 180 days prior to anticipated use.

2. Applicability of Discharge Limitations and Effective Dates

a. Surface Water Discharge Monitoring Report (DMR) Form Requirements

i. The final effluent limitations and monitoring conditions contained in PART III for all outfalls

apply for the full term of this permit action, with the exception of outfall DSN 010A. The initial

effluent limitations and monitoring conditions for DSN 010A begin on the effective date of the

permit, and the final effluent limitations and monitoring conditions apply when BLE completes

the repowering project.

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PER050003 Consolidated Renewal Permit Action

b. Wastewater Characterization Report (WCR) Form Requirements

i. The final effluent monitoring conditions contained in PART III for all outfalls apply for the full

term of this permit action.

3. Operation, Maintenance and Emergency conditions

a. The permittee shall operate and maintain treatment works and facilities which are installed or used

by the permittee to achieve compliance with the terms and conditions of this permit as specified in

the Operation & Maintenance Manual.

b. The permittee shall develop emergency procedures to ensure effective operation of the treatment

works under emergency conditions in accordance with NJAC 7:14A-6.12(d).

4. Toxicity Testing Requirements - Acute Whole Effluent Toxicity (DSNs 001A, 013A and 014A)

a. The permittee shall conduct toxicity tests on its wastewater discharge in accordance with the

provisions in this section. Such testing will determine if appropriately selected effluent

concentrations adversely affect the test species.

b. Acute toxicity tests shall be conducted using the test species and method identified in Part III of

this permit.

c. Part III of this permit contains an Action Level (AL) for acute Whole Effluent Toxicity. Toxicity

Reduction and Implementation Requirements may be triggered based on exceedences of this

Action Level. See Toxicity Reduction and Implementation Requirements section below for more

details.

d. Any test that does not meet the specifications of N.J.A.C. 7:18, laboratory certification regulations,

must be repeated within 30 days of the completion of the initial test. The repeat test shall not

replace subsequent testing required in Part III.

e. The permittee shall resubmit an Acute Methodology Questionnaire within 60 days of any change in

laboratory.

f. Submit an acute whole effluent toxicity test report: within twenty-five days after the end of every

12 month monitoring period beginning from the effective date of the permit (EDP). The permittee

shall submit toxicity test results on appropriate forms.

g. Test reports shall be submitted to:

i. New Jersey Department of Environmental Protection

Mail Code 401-02B

Division of Water Quality

Bureau of Surface Water Permitting

401 East State Street

P.O. Box 420

Trenton, New Jersey 08625-0420.

5. Toxicity Reduction Implementation Requirements (TRIR)

a. The permittee shall initiate a tiered toxicity investigation if two out of six consecutive WET tests

demonstrate that the effluent does not comply or will not comply with the toxicity limit or action

level specified in Part III of this permit.

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PER050003 Consolidated Renewal Permit Action

i. If the exceedence of the toxicity limit or action level is directly caused by a documented facility

upset, or other unusual event which has been identified and appropriately remedied by the

permittee, the toxicity test data collected during the event may be eliminated when determining

the need for initiating a TRIR upon written Department approval.

b. The permittee shall begin toxicity characterization within 30 days of the end of the monitoring

period when the second toxicity test exceeds the toxicity limits or action levels in Part III. The

monitoring frequency for toxicity testing shall be increased to monthly. Up to 12 additional tests

may be required.

i. The permittee may return to the toxicity testing frequency specified in Part III if four consecutive

toxicity tests conducted during the Toxicity Characterization do not exceed the toxicity limit or

action level.

ii. If two out of any six consecutive, acceptable tests again exceed the toxicity limit or action level

in Part III, the permittee shall repeat the Toxicity Reduction Implementation Requirements.

c. The permittee shall initiate a preliminary toxicity identification (PTI) upon the third exceedence of

the toxicity limit or action level specified in Part III during toxicity characterization.

i. The permittee may return to the monitoring frequency specified in PART III while conducting

the PTI. If more frequent WET testing is performed during the PTI, the permittee shall submit

all biomonitoring reports to the DEP and report the results for the most sensitive species on the

DMR.

ii. As appropriate, the PTI shall include:

 (1) treatment plant performance evaluation,

 (2) pretreatment program information,

 (3) evaluation of ammonia and chlorine produced oxidants levels and their

 effect on the toxicity of the discharge,

 (4) evaluation of chemical use and processes at the facility, and

 (5) an evaluation of incidental facility procedures such as floor washing,

 and chemical spill disposal which may contribute to effluent toxicity.

iii. If the permittee demonstrates that the cause of toxicity is the chlorine added for disinfection or

the ammonia concentration in the effluent and the chlorine and/or ammonia concentrations are

below the established water quality based effluent limitation for chlorine and/or ammonia, the

permittee shall identify the procedures to be used in future toxicity tests to account for chlorine

and/or ammonia toxicity in their preliminary toxicity identification report.

iv. The permittee shall submit a Preliminary Toxicity Identification Notification within 15 months of

triggering TRIR. This notification shall include a determination that the permittee intends to

demonstrate compliance OR plans to initiate a CTI.

d. The permittee must demonstrate compliance with the WET limitation or action level in four

consecutive WET tests to satisfy the requirements of the Toxicity Reduction Investigation

Requirements. After successful completion, the permittee may return to the WET monitoring

frequency specified in PART III.

e. The permittee shall initiate a Comprehensive Toxicity Investigation (CTI) if the PTI does not

identify the cause of toxicity and a demonstration of consistent compliance with the toxicity limit

or action level in Part III can not be made.

i. The permittee shall develop a project study plan identifying the party or parties responsible for

conducting the comprehensive evaluation, establish a schedule for completing the study, and a

description of the technical approach to be utilized.

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PER050003 Consolidated Renewal Permit Action

ii. If the permittee determines that the PTI has failed to demonstrate consistent compliance with the

toxicity limit or action level in Part III , a Comprehensive Toxicity Investigation Workplan must

be prepared and submitted within 90 days.

iii. The permittee shall summarize the data collected and the actions taken in CTI Quarterly Reports.

The reports shall be submitted within 30 calendar days after the end of each quarter.

iv. The permittee shall submit a Final CTI Report 90 calendar days after the last quarterly report.

The final CTI report shall include the corrective actions identified to reduce toxicity and a

schedule for implementing these corrective actions.

f. Upon receipt of written approval from the Department of the corrective action schedule, the

permittee shall implement those corrective actions consistent with that schedule.

i. The permittee shall satisfy the requirements of the Toxicity Reduction Implementation

Requirements and return to the original toxicity monitoring frequency after corrective actions are

implemented and the permittee demonstrates consistent compliance with the toxicity limit or

action level in Part III in four consecutive toxicity tests.

ii. If the implemented corrective measures do not result in consistent compliance with the toxicity

limit or action level in Part III, the permittee shall submit a plan for resuming the CTI.

iii. Documents regarding Toxicity Investigations shall be sent to the following:

New Jersey Department of Environmental Protection

Division of Water Quality

Bureau of Surface Water Permitting

Mail Code 401-02B P.O. Box 420

Trenton, New Jersey 08625-0420.

F. CONDITIONS FOR MODIFICATION

1. Notification requirements

a. The permittee may request a minor modification for a reduction in monitoring frequency for a

non-limited parameter when four consecutive test results of "not detected" have occurred using the

specified QL.

2. Causes for modification

a. The Department may modify or revoke and reissue any permit to incorporate 1) any applicable

effluent standard or any effluent limitation, including any effluent standards or effluent limitations

to control the discharge of toxic pollutants or pollutant parameters such as acute or chronic whole

effluent toxicity and chemical specific toxic parameters, 2) toxicity reduction requirements, or 3)

the implementation of a TMDL or watershed management plan adopted in accordance with

N.J.A.C. 7:15-7.

b. The permittee may request a minor modification to eliminate the monitoring requirements

associated with a discharge authorized by this permit when the discharge ceases due to changes at

the facility.

G. Custom Requirement

1. Specific Sampling Requirements

a. Chlorine Produced Oxidants (CPO).

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PER050003 Consolidated Renewal Permit Action

i. 001A, 009A and 010A - CPO may not be discharged from any operating unit for more than two

hours in any one day, and not more than one unit in the plant may discharge chlorine at any one

time, consistent with 40 CFR Part 423.

b. Total Petroleum Hydrocarbons for DSNs 009A and 010A - Petroleum hydrocarbons limits of 10

mg/L as a monthly average and 15 mg/L as a daily maximum are applicable to these outfalls

although routine monitoring and reporting is not required at this time.

c. Chromium Monitoring at DSN 001A - Monitoring is only required if cooling tower additives that

contain these chemicals are used during the month specified on the monitoring report form. If

cooling tower additives containing these chemicals are not used during that month then the

permittee shall report "Code = N.".

d. Effluent pH (for DSNs 001A, 009A and 010A) - If the pH at the intake is outside the range of 6 to

9 standard units, a discharge outside the range of 6.0 to 9.0 standard units shall be permitted

provided that: a) if the intake value is greater than 9 s.u. then the discharge value may not exceed

the intake value, and b) if the intake value is less than 6.0 s.u. then the discharge value may not be

less than the intake value.

e. DSN 008A - The discharge of screen washwater from DSN 008A shall not cause an exceedance of

the New Jersey Surface Water Quality Standards, N.J.A.C. 7:9B-1.1 et seq.

f. Continuous Temperature - When continuous temperature monitoring is in use, compliance with

effluent limitations for temperature shall be based, except as otherwise provided by the provisions

hereof, on an average of all corresponding temperature values (influent and effluent temperature

values) available for the corresponding calendar day. Continuous temperature monitoring is

required at all times when non-contact cooling water is being discharged from outfalls 009 and

010, but is not required during periods where a malfunction of continuous temperature monitoring

equipment has occurred. As used herein, "malfunction" means an infrequent, unintentional and not

reasonably preventable failure of continuous temperature monitoring equipment. "Malfunction"

does not include a failure caused by improper or inadequate maintenance of continuous

temperature monitoring equipment or careless or improper operational practices with respect to

such equipment. Where such a malfunction has occurred, the permittee shall within 24 hours

verbally communicate the following information to the Department via the DEP Hotline:.

i. the cause of the malfunction or the steps the permittee will take to determine such cause;.

ii. the anticipated duration of the malfunction; and.

iii. the steps the permittee is taking to prevent reoccurrence of the malfunction.

2. Impingement Alternatives Analysis and Section 316(b) Determination

a. Since the Section 316(b) final regulations are not due out until June 2013, the Department is

requiring the permittee to submit an Impingement Alternative Analysis to assess technologies to

minimize impingement mortality at the plant's intake. The purpose of this study is for the

permittee to evaluate and analyze a potential alternative for reducing impingement mortality with a

focus on improved screens and fish return.

b. The Impingement Alternatives Analysis shall address the following factors at the intake:.

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

i. Replacement of the existing screens with Ristroph screens having a dual spraywash system

(high-and-low-pressure). The screens shall have fish lifting buckets to hold the fish in water as

they are lifted to the low-pressure spraywash removal system. The screen size shall be optimized

to minimize impingement mortality and the wire mesh shall have a smooth face. These screens

shall be operated continuously exclusive of periods of maintenance or operational requirements.

ii. Installation of a fish return system for the intake structure that is designed and constructed in

consideration of the following factors: 1) using a fiberglass composite or a similar non-abrasive

material that will be added to the full length of the interior surface of the trough of the fish return;

2) a trough with a rounded shape that will reduce abrasion and obstructions to fish; 3) designed

to have sufficient capacity, flow volume and water level to facilitate safe return of impinged

organisms to the Great Egg Harbor; and 4) designed so that the fish return conveyance terminus

is submerged at all tidal stages on a year-round basis.

iii. Inclusion of scoping cost estimates for alternatives and a project implementation schedule.

c. In consideration of the regulatory and technical information available at this time, the Department

hereby determines that conduct of an Impingement Alternatives Analysis to assess the installation

of modified Ristroph traveling screens as well as a fish return system at the Cooling Water Intake

Structure constitutes best technology available based on best professional judgement in accordance

with Section 316(b) of the Clean Water Act.

d. Upon receipt of the Impingement Alternatives Analysis, the Department will evaluate the findings

in concert with the final EPA regulations and will reopen the permit to incorporate permit

conditions pursuant to N.J.A.C. 7:14A-16.4.

e. The permittee shall submit the Impingement Alternative Analysis on or before EDP + 15 months to

the following address:

New Jersey Department of Environmental Protection

Mail Code 401-02B

Division of Water Quality

Bureau of Surface Water Permitting

401 East State Street

P.O. Box 420

Trenton, NJ 08625-0420.

3. Submissions as part of any NJPDES Renewal Application - Section 316(a) Special Condition

a. If upon renewal, the permittee wants the Section 316(a) variance to be continued, the request for

the variance along with a basis for its continuance must be submitted at the time of the application

for the renewal permit in accordance with 40 CFR 125.73(c). The Department's Section 316(a)

Determination shall include, but not be limited to:.

i. a review of whether the nature of the thermal discharge or the aquatic population associated with

the Station have changed;.

ii. whether the existing permit conditions have assured the protection and propagation of a balanced

indigenous population;.

iii. whether the best scientific methods to assess the effect of the permittee's cooling system have

changed; and.

iv. whether the technical knowledge of stresses caused by the cooling system has changed.

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PER050003 Consolidated Renewal Permit Action

4. Thermal Modeling Study

a. Repowering the Station will result in changes to the thermal plume. After the Station completes

repowering on May 1, 2016, the permittee shall complete a thermal plume characterization study

utilizing the Cornell Mixing Zone Expert System (CORMIX) software and other appropriate

far-field modeling as necessary. The study shall be submitted to the Department by April 30,

2017.

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

Stormwater

A. Permit Overview

1. Summary of Stormwater Permit Requirements

a. The permittee shall develop, implement, update and maintain a Stormwater Pollution Prevention

Plan (SPPP), which includes a Drainage Control Plan (DCP) (see Part IV.B).

b. The permittee shall develop, implement, update and maintain site specific best management

practices (BMPs) to achieve the design criteria and effluent limitations as specified in the permit

(see Part IV.C).

c. The permittee shall be responsible for supervising and managing the operation and maintenance of

the facility, which includes routine inspections of the facility (see Part IV.D).

d. The permittee shall conduct stormwater monitoring in accordance with the permit (see Part IV.E).

e. The permittee shall summarize facility inspections in written reports and submit reports and

certifications to ensure compliance with this permit (see Part IV.F).

f. The permittee shall retain records of all monitoring information, maintenance records, and copies

of all reports (including the SPPP and soil erosion and sediment control plans) required by this

permit (see Part IV.G).

B. Stormwater Pollution Prevention Plan

1. SPPP Minimum Requirements

a. The SPPP shall address all stormwater discharges associated with industrial activity, including

source materials, at the facility.

b. The facility shall gain drainage control of the stormwater runoff from all areas of industrial

activity, including source materials, in accordance with section B.4 below.

c. The permittee shall include a DCP as a section within the SPPP.

d. The SPPP shall identify the BMPs that are in place to eliminate, reduce, or minimize exposure of

industrial activity and source materials to stormwater discharging to surface or ground water.

e. The SPPP shall demonstrate that upon implementation the stormwater discharges associated with

industrial activity meet the permit conditions contained in this permit.

f. The SPPP shall address, but is not limited to, the following outside areas:

i. outside vehicle/equipment fueling, maintenance and washing areas, and fuel storage (e.g., diesel

fuel);

ii. outside areas used for waste management/handling or storage of equipment (e.g., dumpsters,

scrap metal, vehicle parts, drums, and garbage);

iii. pavement and access roads needing repairs and unpaved surfaces with the potential to erode and

discharge solids (soils and/or sediments) to surface waters;

iv. catch basins, trench drains and roof drains discharging to surface waters;

v. loading docks;

vi. spills/leaks/non-stormwater discharges of fluid products, raw material, vehicle coolants,

lubricants and other chemicals;

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PER050003 Consolidated Renewal Permit Action

Stormwater

vii. above ground storage tanks; and

viii. other areas/activities with stormwater discharges to surface water associated with industrial

activity as defined by the federal rules (40 CFR 122.26 (b) (14)) and contained by reference in

the state rules.

g. The SPPP shall identify BMPs to stablize surface soils and reduce sediment transport, using BMPs

outlined in the Standards for Soil Erosion and Sediment Control in New Jersey where appropriate,

in accordance with the Soil Erosion and Sediment Control Act N.J.S.A. 4:24-39 et seq.

h. The SPPP shall identify production and non-production areas that have a high potential for soil

erosion or a known soil erosion problem. Appropriate vegetative, structural, or stabilization

measures shall be selected to limit erosion and sediment transport in these areas.

i. The SPPP shall be prepared, implemented, and maintained in accordance with good engineering

practices and shall include, at a minimum, all of the items and information identified in Part IV. B,

C and Attachment 1: "Contents of the Stormwater Pollution Prevention Plan".

j. The original SPPP shall be retained at the facility for use by the facility and inspection by the

Department.

2. BMP Design Criteria

a. For monitoring only requirements, BMPs shall be designed, implemented and maintained to

achieve the following design criteria upon implementation of the SPPP:

i. COD <= 120 mg/L

ii. TSS <= 100 mg/L

iii. pH = 6.0 - 9.0 S.U.

iv. Oil and Grease <= 15 mg/L

b. If the monitoring results exceed the design criteria (or are outside the range for pH, if applicable),

the permittee shall:

i. evaluate potential sources for the specific parameter that did not comply with the design criteria;

ii. identify BMPs (e.g., source control, operational control, stormwater treatment) by which the

permittee can further reduce stormwater contamination;

iii. evaluate whether any improvements or changes to the SPPP are warranted to reduce and control

this parameter concentration;

iv. update the SPPP with any improvements or changes; and

v. summarize the results in the annual report in accordance with Part IV.F, including remedial

actions taken.

c. If the permittee fails to design, implement and maintain the BMPs identified in the SPPP to meet

the design criteria, or to make significant progress toward meeting the design criteria, the

Department may modify the permit in accordance with N.J.A.C. 7:14A-16.4(b)11.

3. Drainage Control

a. Drainage Control shall be established in all areas of industrial activity. In areas of industrial

activity that cannot be diverted to a permitted outfall, the permittee shall do one of the following:

Stormwater Page 14 of 24
B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

i. convert the area(s) to "no discharge" area(s) and manage stormwater collected in the area(s) as

industrial wastewater; or

ii. eliminate industrial activity in these areas.

b. To establish drainage control, a facility shall:

i. ensure all "stormwater associated with industrial activity" as defined in N.J.A.C. 7:14A-1.2, is

discharged through a regulated outfall(s) to surface water and/or a ground water discharge

location;

ii. create a representative monitoring point for each regulated outfall(s) to surface water and/or a

ground water discharge location; and

iii. separate the discharge of stormwater not associated with industrial activity (e.g. rooftop runoff,

employee parking, open space) from regulated discharges, where practicable.

c. Outfall Stabilization

i. The permittee shall design, implement and maintain BMPs to prevent downstream erosion and

sedimentation caused by stormwater, and/or process wastewater runoff at the outfall(s).

ii. At a minimum, the BMPs shall meet the most recent technical standards listed in Standards for

Soil Erosion and Sediment Control in New Jersey, Engineering Standards Section titled Standard

for Off-Site Stability.

iii. Where erosion at the outfall structure occurs the permittee shall restore the eroded areas to its

previous condition.

4. Drainage Control Plan

a. The facility shall develop, implement and/or maintain a DCP containing the following:

i. a written narrative; and

ii. a Drainage Control Map.

b. The DCP shall be certified by a New Jersey licensed Professional Engineer.

c. Elevations for the Drainage Control Map shall be measured by a New Jersey licensed surveyor.

d. The written narrative shall describe how the facility will establish drainage control and shall

include the following:

i. facility name;

ii. NJPDES permit number (NJ0005444) and Program Interest I.D. number;.

iii. an alpha-numeric discharge serial number (e.g., DSN001A, DSN002A, DSN003A) for each

surface water monitoring point(s);

iv. an alpha-numeric identifier (e.g. I01I, I02I, I03I) for each ground water monitoring point(s);

v. the latitude and longitude for each monitoring point(s);

vi. the name of all receiving water bodies (for discharges to surface water) and assigned New Jersey

Surface Water Quality Standards' classifications;

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

vii. the name of the receiving aquifer (for discharges to ground water) and assigned New Jersey

Ground Water Quality Standards' classification; and

viii. a description of any proposed stormwater treatment.

e. Unless otherwise specified by the Department the Drainage Control Map shall be an appropriate

engineering scale, which is legible and clearly depicts the following information when applicable:

i. site boundary;

ii. title block containing tax block and lot number;

iii. north directional arrow;

iv. date prepared and subsequent revisions;

v. final grading of drainage areas, including elevations and flow arrows showing the drainage to

regulated outfalls;

vi. location of flow diversion structures, treatment units (i.e. lined and unlined basins);

vii. location of surface water outfalls (regulated and unregulated) and discharge structures;

viii. location of ground water discharge point(s) and discharge structure;

ix. receiving waters and their location;

x. areas of industrial activity (i.e. Maintenance, fueling, equipment cleaning and storage);

xi. access roads;

xii. existing buildings and other structures; and

xiii. employee and customer parking.

5. Modification of SPPP to include the DCP

a. An existing facility with a SPPP shall modify the plan to include the Drainage Control

requirements outlined in Part IV.B.

b. The modified SPPP that includes the DCP shall be implemented in accordance with the permit and

certified on a form provided by the Department.

c. The deadline for the preparation and implementation of the SPPP to include the DCP and

submittals are contained in Part IV.F of the permit.

6. Continuation of SPPP

a. The SPPP shall be updated and maintained in accordance with the permit and recertified on a form

provided by the Department in accordance with the schedule in Part IV.F.

C. Site Specific Best Management Practices

1. Coal Pile Area

a. Implement and maintain measures that prevent dust emissions from coal handling areas (including

storage area).

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

b. The dike surrounding the coal pile must be tall enough to control the spill of coal particles.

c. Coal particles outside the diked areas shall be minimized to the best extent practicable. These

particles shall be removed from these areas upon discovery.

d. The discharge of coal particles to the Great Egg Harbor Bay shall be minimized to the furthest

extent practicable.

2. Delivery Vehicles

a. Implement and maintain measures that prevent or minimize the contamination of stormwater runoff

from delivery vehicles arriving at the plant site.

b. The permittee shall have procedures to inspect delivery vehicles to ensure the overall integrity of

the body and container.

c. The permittee shall have procudres to deal with leakage/ spillage from delivery vehicles or

contaniers.

3. Ash Loading and Unloading Areas

a. Implement and maintain measures to reduce and control the tracking of ash/ residue from the ash

loading areas.

i. Clear the ash building floor and adjacent roadways of spillage, debris and excess water before

departure of each loaded vehicle.

b. Develop and maintain procedures to reduce ash residue that may be tracked onto access roads

traveled by residue handling vehicles, and reduce ash residue on exit roads leading into and out of

residue handling areas.

4. Fueling and Spill Prevention Planning

a. Implement and maintain measures to ensure the potential of spills or leakage of any liquid are

minimized or eliminated.

b. Any spills shall be cleaned up properly immediately after discovery.

5. Outdoor Maintenance, Fabrication, and Assembly

a. Implement and maintain inspection protocols following any maintenance, fabrication , and

assembly procedures occurring outdoors.

b. Any waste oils, dust, sandblast residue, steel shavings, etc. shall be cleaned up and properly

disposed of in accordance with all applicable State, Federal, and local requirements.

6. Scrap Metal

a. Scrap metal exposed to stormwater must be free of residual materials (i.e., oils, tar, fine particles)

and deterioration due to oxidation.

b. The permittee shall have in place a program for the periodic removal of scrap metal material.

c. Scrap metal that is not free of residual materials or is deteriorating must be removed or stored in a

watertight container and covered.

7. BMP - Vehicle/ Equipment Washing

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

a. The discharge of wash waters to surface water are strictly prohibited. Designate and clearly mark

equipment-cleaning areas.

b. Cleaning of aircraft, ground vehicles and equipment shall be carried out indoors and drain to

sanitary sewer when ever practicable.

c. Outdoor cleaning management practices shall be conducted in such a manner as to prevent the

discharge of wash water to surface water.

d. This should include the following management practices, or equivalent measures:

i. Section off portions of stormwater sewer system for the equipment cleaning drainage area. Pump

the wash water from the sectioned off stormwater sewer system for recycling, discharge to

sanitary sewer, or proper disposal by a licensed waste hauler.

ii. Construct a pad and dike. Pump wash water to be recycled, discharged to sanitary sewer, or

properly disposed of by a waste hauler. Maintain and clean dike area of residuals.

iii. Place impermeable tarps in a diked area. Vacuum or pump wash water and remove tarp after

use.

8. BMP - Vehicle/ Equipment Maintenance

a. Designate and clearly mark areas for equipment maintenance.

b. Establish standard operating procedures that prevent or minimize the contamination of stormwater

runoff from all areas used for aircraft, ground vehicle, and equipment maintenance.

c. This shall include, but is not limited to, the following management practices, or equivalent

measures:

i. Performing maintenance indoors when practicable.

ii. Maintaining and organizing inventory of materials used in maintenance areas.

iii. Draining all parts containing fluids prior to maintenance and/or disposal.

iv. Prevent the practice of hosing down the apron or hanger floor. The use of dry cleanup methods,

and/or collecting the stormwater runoff from the maintenance area and providing treatment or

recycling should be considered.

9. BMP - Discharge of Stormwater from Secondary Containment (version #1)

a. The following BMP shall be implemented for discharging stormwater from secondary containment

areas at the facility. The facility is only authorized to discharge stormwater.

i. The stormwater in the containment area shall not come into contact with the contents of the

wastewater storage tank(s).

ii. The discharge pipe/outfall from the containment area shall have a valve and that valve shall

remain closed at all times except when discharging stormwater.

iii. A visual inspection of the tank shall be performed to insure the tank's physical integrity; which

must be completed on a routine basis and an inspection log maintained.

iv. Regular maintenance of the wastewater tank must be performed (e.g. painting, repair) to insure

the tank's integrity.

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PER050003 Consolidated Renewal Permit Action

v. A visual inspection of the stormwater is to be performed prior to the onset of a discharge to

insure that the stormwater has not been contaminated by the contents of the tank or by other

materials.

vi. Alternative means for disposing the stormwater must be established for stormwater that has or is

suspected to have been contaminated by the contents of the tank or by other materials.

10. BMP - Bulk Transfer Of Liquids

a. In areas where liquid materials are transferred in bulk from truck or rail cars, the permittee shall

take appropriate measures to minimize contact of transferred material with precipitation.

i. Hose connection points at storage containers shall be inside containment areas.

ii. Drip pans must be used in areas that are not in a containment area where spillage may occur (e.g.

hose reels, connection points with rail cars or trucks).

iii. All loading and unloading racks must be surrounded by curbs to contain accidental spills. Install

a canopy over a loading rack.

iv. In order to prevent discharge of spills or leaks where precipitation is contained, contained areas

should be restrained by valves or other equivalent means.

11. Salavaged Equipment and Spare Parts

a. Dismanteled equipment that is being used for is salvageable parts and is exposed to stormwater

shall be free of residual materials (i.e., oils, lubricants, tar, fine particles) and deterioration due to

oxidation.

b. Salvageable equipment that is not free of residual materials or is deteriorating must be removed or

stored in a water tight container and covered.

D. Operations and Maintenance

1. Facility and BMP Operation and Maintenance

a. The permittee shall be responsible for supervising and managing the operation and maintenance of

this facility. This requires implementing BMPs that must be installed or used by the permittee to

achieve compliance with the SPPP. Proper operation and maintenance also requires the operation

of backup or auxiliary facilities or similar systems when necessary to achieve compliance with the

conditions of the permit.

b. The operation and maintenance activities shall be verified through the certification and annual

reporting requirements of Part IV.F.

c. Frequent and thorough inspections, at a frequency of at least quarterly, are necessary to ensure

adequate functioning of control measures. Inspections are recommended to be conducted during

dry periods as well as storm events.

i. Inspections during dry periods allow facilities to identify and address any problems prior to a

storm event, thereby minimizing the chance for stormwater contamination.

ii. Inspections during significant storm events ensure that measures are functioning as originally

intended and provide an opportunity for facilities to observe what materials and/or activities are

exposed to stormwater.

2. Soil Erosion Sediment Control Plan

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

a. For construction activities disturbing one (1) acre or more of total land area, authorization shall be

obtained under either a modification to this permit or under NJPDES Permit No. NJ0088323

(Construction Activity Stormwater General Permit), for stormwater from such construction

activities that would be discharged to surface waters.

b. Land disturbances that may result in a stormwater discharge authorized by this permit, shall be

executed only in accordance with a soil erosion and sediment control plan certified pursuant to

N.J.S.A. 4:24-43, or requirements for soil erosion and sediment control established in or pursuant

to a municipal ordinance in accordance with N.J.S.A. 4:24-48, whichever is applicable.

c. A copy of this plan shall be retained by the permittee for a period of at least five (5) years after the

completion of construction.

E. Monitoring

1. Criteria for monitoring a valid storm event

a. The criteria for a valid storm event is any precipitation that produces a stormwater discharge

including discharges from snow melt events.

i. The permittee shall monitor its stormwater discharge during a valid storm event from the outfalls

designated in the DCP.

ii. For stormwater that accumulates during a storm event in a containment area impoundment or

other device that controls the discharge, the facility shall monitor its stormwater at the time of the

discharge.

iii. A wet basin must be monitored whenever there is a discharge.

b. Sampling a Snowmelt Event

i. If the snowmelt results in a discharge, the permittee may collect a sample of the snow melt as

part of the site monitoring requirements.

ii. Snowmelt samples must be representative of the area of industrial activity. Samples may not be

collected from snow stockpiles from non-industrial areas of the facility.

iii. The permittee shall only sample one snow melt event per calendar year.

2. Monitoring Locations

a. Samples shall be taken in compliance with the specified monitoring locations in Part III.

b. Monitoring locations shall not be changed without notification to and the approval from the

Department.

c. Monitoring locations shall be included on the DCP map as detailed in Part IV.B.

3. Monitoring Schedule

a. Samples shall be collected in accordance with the sampling frequency established by the

Department in Part III.

4. Collection and Analysis of Samples

a. Stormwater samples shall be collected within 30 minutes of the stormwater discharge or as soon

thereafter as practicable.

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action

b. The facility can collect their own sample.

c. Samples shall be analyzed by a New Jersey certified laboratory (N.J.A.C 7:18).

d. All samples shall be analyzed in accordance with approved U.S. Environmental Protection Agency

(EPA) methods contained in 40 CFR Part 136, unless otherwise specified in the footnotes in Part

IV.A.

e. The permittee may take samples and have analysis made by a New Jersey Certified laboratory on

additional occasions to those specified in this permit. If so, the maximum values of all analytical

results taken during the sampling period shall be reported. In addition, if an average value is

required to be reported, all sample results shall be used when calculating the average. However,

for pH, both minimum and maximum values are reported.

f. If only one analysis for a given parameter is made during any monitoring period specified in this

permit, the result of such analysis shall be construed as the maximum value for that parameter, for

said monitoring period.

F. Inspections, Reports and Submissions

1. Stormwater Monitoring Report Forms (MRFs)

a. Sampling results shall be summarized and reported in accordance with the requirements contained

in Part III of this permit on the appropriate monitoring report forms mailed separately by the

Bureau of Permit Management.

b. If the permittee finds that the pre-printed MRFs they receive from the Department contain errors

from the monitoring and reporting requirements contained in Part III, the permittee should contact

the Bureau of Nonpoint Pollution Control at (609) 633-7021.

c. The permittee is required to monitor its stormwater discharge and submit appropriate MRFs to the

Department in accordance with conditions of permit even if pre-printed MRFs contain errors.

d. The permittee shall make hand corrections to the MRFs if corrected forms are not received prior to

the monitoring report due date.

2. Reporting Storm Event Information

a. In order for the Department to better assess the monitoring results provided by the permittee, the

Department requires that storm event information is recorded and reported along with monitoring

results.

b. The permittee shall record and submit the following storm event information on the appropriate

MRFs provided by the Department:

i. date of storm event;

ii. time storm event began;

iii. storm event duration;

iv. time of sample collection;

v. rainfall amount at time of sampling (an estimate of the inches of rainfall or snowfall, which can

be based upon such data as recorded by a local weather monitoring station(s) or an onsite

maintained monitoring station);

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PER050003 Consolidated Renewal Permit Action

vi. date of sample collection;

vii. type of storm event (rain or snowmelt); and

viii. pH of rain (optional).

3. Reporting "No Discharge"

a. If a discharge does not occur during a particular reporting period, the permittee should check "No

Discharge this monitoring period" on the MRF transmittal sheet for each discharge monitoring

location which had "no discharge"

b. The Department shall compare all reports of "No Discharge" against information provided by

Premium AccuWeather services (https://wwwl.accuweather.com/premium_login.php) to determine

if a discharge has occurred.

4. MRF Submittals

a. Unless otherwise specified or directed, signed copies of required MRFs shall be submitted

postmarked no later than the 25th day of the calendar month following the completed monitoring

period to the address given below:

i. New Jersey Department of Environmental Protection

Mail Code 401-02B

Office of Permit Management

P.O. Box 420 - 401 E. State St.

Trenton, New Jersey 08625-0420

Attn. Monitoring Reports

b. Submitting MRFs

i. The permittee shall continue to submit MRFs in accordance with the schedule established in the

previous permit cycle.

c. The permittee may also participate in electronic reporting of the MRFs via NJ Online with the

Electronic Discharge Interchange (EDI) system. Follow the directions in the NJPDES Monitoring

Report Form Manual to participate.

5. SPPP Modification Submittal Requirements

a. A SPPP shall be modified to include a DCP in accordance with the submittal schedule below:

i. Copies of the SPPP including the DCP shall be submitted to the Department's Southern Bureau

of Water Compliance and Enforcement and the Bureau of Nonpoint Pollution Control.

ii. Submit the SPPP: within 18 months from the effective date of the permit (EDP).

iii. The implementation of the modified SPPP to include the DCP shall be certified through the

annual recertification in accordance with Part IV.F below.

iv. This certification form is available on the Department website at

http://www.state.nj.us/dep/dwq/forms.htm#stormforms

6. Annual Inspections, Reports, and Recertifications

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PER050003 Consolidated Renewal Permit Action

a. The permittee shall conduct annual inspections of the facility in accordance with N.J.A.C.

7:14A-24.9(a) to assess all areas contributing to the stormwater discharge authorized by this

permit, to evaluate whether the SPPP complies with and is implemented in accordance with this

permit, and whether additional measures are needed to meet the conditions of this permit.

b. The permittee shall prepare an annual report.

c. The annual report shall be completed prior to the annual recertification submission date.

d. The annual report shall be retained by the permittee in accordance with Part IV.G for a period of at

least five (5) years.

e. Submit an Annual Report: by September 1 of each year beginning from the effective date of the

permit (EDP).

f. The annual report shall be submitted with the annual recertification. This certification form is

available on the Department website at http://www.state.nj.us/dep/dwq/forms.htm#stormforms.

g. The annual report shall summarize the findings of the annual inspection in accordance with a.

above, including:

i. The date of the inspection; and

ii. Name(s) and title of the inspector(s).

h. The annual report shall include a summary comparing the MRF data with the design criteria. This

summary shall include:

i. An explanation of two (2) or more exceedances of the design criteria for the same parameter;

ii. Changes and/or upgrades to BMPs to meet design criteria, and

iii. A discussion of the effectiveness of the BMP changes and/or upgrades.

i. The permittee shall annually certify on a form provided by the Department that the facility has

completed their annual report as specified above and is in compliance with the SPPP and this

permit.

i. Submit the Generic Certification Form certifying that the annual inspection was conducted: by

September 1 of each year beginning from the effective date of the permit (EDP).

ii. Any incident of non-compliance shall be identified in the certification. This shall include the

steps being taken to remedy the non-compliance, and to prevent such incidents from recurring.

G. Record Keeping

1. Record Keeping Requirements

a. The permittee shall retain records of all monitoring information, maintenance records, and copies

of all reports required by this permit for a period of at least five (5) years.

2. SPPP Record Keeping Requirements

a. The SPPP shall be signed by the permittee, and the original shall be retained at the facility for use

by the facility and inspection by the Department.

b. The SPPP shall be made available, upon request, to a representative of the Department and to the

owner and operator of any municipal separate storm sewer receiving the stormwater discharge.

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PER050003 Consolidated Renewal Permit Action

c. The SPPP shall be made available to the public upon request, except as noted below.

d. The facility may claim any portion of the SPPP as confidential in accordance with the provisions

set forth in N.J.A.C. 7:14A-18.2.

3. Soil Erosion and Sediment Control Plan Record Keeping

a. If the permittee is required to implement a Soil Erosion and Sediment Control Plan as a result of

construction activities or land disturbance greater than or equal to one (1) acre, a copy of the plan

shall be retained by the permittee for a period of at least five (5) years after the completion of

construction.

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B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

PER050003 Consolidated Renewal Permit Action
ATTACHMENT 1: 

CONTENTS OF THE 

STORMWATER 

POLLUTION PREVENTION PLAN 

 

 
Table of Contents

I. Stormwater Pollution Prevention Plan ......................................................................... 1 

II. Stormwater Pollution Prevention Team ..................................................................... 1 

III. Description of Existing Environmental Management Plans ..................................... 1 

IV. Site Assessment ........................................................................................................ 2 

A. Inventory Requirements ................................................................................. 2 

 1. List Source Materials ................................................................................. 2 

 2. List Sources of Water ................................................................................ 2 

 3. List Permits ............................................................................................... 2 

B. Drainage Control Plan & Mapping Requirements ......................................... 2 

V. Best Management Practices (BMP) Selection and Plan Design........................2,3 

A. Pollution Prevention ....................................................................................... 3 

 1. Diverting Stormwater ................................................................................. 3 

 2. Good Housekeeping .................................................................................. 3 

 3. Spill Prevention and Response .................................................................. 4 

 4. Site Stabilization and Dust Control ........................................................... 4 

 5. Erosion Control at the Outfalls................................................4,5 

 6. Preventative Maintenance ......................................................................... 5 

 7. Engineered Treatment Systems ................................................................. 5 

VI. Implementation Schedule..................................................................5,6 

VII. General Plan Requirements ..................................................................................... 6 

A. Certification of Stormwater Pollution Prevention Plan...........................6 

 1. The SPPP .................................................................................................. 6 

B. Required Signatures for SPPP and Certifications...............................6,7 

C. Plan Location and Public Access ................................................................... 7 

 1. SPPP Records ............................................................................................ 7 

 2. Make Available to Public .......................................................................... 7 

 3. Submit Copy of SPPP ............................................................................... 7 

 4. Inspections and Annual Reports...............................................7,8 

VIII. Special Requirements ............................................................................................. 8 

A. Facilities Subject to Emergency Planning and Community Right-to-Know 

Statute.................................................................................................................. 8 

B. Facilities with SPCC Plans, DPCC Plans, or DCR Plans .............................. 8 

C. Facilities Undergoing Construction Activities ............................................... 8 

i 
1 

I. Stormwater Pollution Prevention Plan 

The following outline provides the key elements of an acceptable Stormwater Pollution 

Prevention Plan (SPPP). The purpose of the SPPP is to meet the following objectives: 

A. identify potential sources of pollution and source materials onsite which may 

reasonably be expected to affect the quality of stormwater discharges associated with 

industrial activity; 

B. establish drainage control; 

C. describe and ensure that practices are implemented to eliminate and/or reduce 

pollutants from source materials in stormwater discharges associated with industrial 

activity to meet design criteria and effluent limitations; and 

D. ensure continued compliance with the terms and conditions of this permit. 

II. Stormwater Pollution Prevention Team 

The permittee shall form and identify a Stormwater Pollution Prevention Team in the SPPP. 

The team is responsible for developing, implementing and maintaining the SPPP in 

accordance with good engineering practices. The SPPP shall identify names of those 

individuals and their titles within the facility’s organization who are members of the team. 

The SPPP shall clearly identify the team leader who has the authority to make decisions and 

give directives to effectively implement the plan. The plan shall clearly identify the 

responsibilities of each team member. The activities and responsibilities of the team shall 

address all aspects of the facility's SPPP which are provided below. 

III. Description of Existing Environmental Management Plans 

The SPPP team shall evaluate the facility's existing environmental management plans and 

programs for consistency with this permit and determine which provisions, if any, from these 

other plans can be incorporated by reference into the SPPP. 

Examples of plans which may be referred to when applicable to the site include: Discharge 

Prevention Containment and Countermeasure (DPCC), Discharge Cleanup and Removal 

(DCR), Preparedness Prevention and Contingency Plan (PPCP, 40 CFR Parts 264 and 265), 

the Spill Prevention Control and Countermeasures (SPCC) requirements (40 CFR Part 112), 

the National Pollutant Discharge Elimination System Toxic Organic Management Plan 

(NPDESTOMP, 40 CFR Parts 413, 433, and 469), and the Occupational Safety and Health 

Administration (OSHA) Emergency Action Plan (29 CFR Part 1910). A copy of any plans 

referred to in the SPPP should be kept on-site with the SPPP. 
2 

IV. Site Assessment 

The Site Assessment shall describe the physical facility and the potential pollutant sources 

(materials, activities and areas) which may be reasonably expected to affect the quality of 

stormwater discharges. The key elements of the site assessment shall include, at a 

minimum, the following requirements: 

A. Inventory Requirements 

Each facility must develop and update annually, as appropriate, an inventory which includes, 

at a minimum, the following: 

1. List Source Materials 

Make list of source materials that have been used, loaded/unloaded, stored, treated, spilled, 

leaked and/or disposed onsite in a manner to allow exposure to stormwater; and 

2. List Sources of Water 

Make list of any domestic wastewater, non-contact cooling water, or process waste water 

(see definitions in Part IV of permit), that is generated at the facility and discharged through 

separate storm sewers (see definition in Part IV of permit) to surface waters. 

3. List Permits 

Make list of any current NJPDES (New Jersey Pollutant Discharge Elimination System) 

permits or permit application that the facility may have for such discharges. 

B. Drainage Control Plan Narrative & Mapping Requirements 

Refer to Part IV Section B, Drainage Control Plan, of this permit. 

V. Best Management Practices (BMP) Selection and Description 

The SPPP shall describe the BMPs used to prevent or minimize pollution from source 

materials and areas of industrial activity. The permittee shall evaluate the information from 

the site assessment phase of this plan to identify potential and existing sources of stormwater 

contaminated by source material. All non-stormwater discharges to surface water and/or 

groundwater must be eliminated or permitted. The permittee shall design, implement 

and maintain BMPs to meet design criteria and effluent limits specified in this permit. 

Based upon the site assessment performed, the permittee shall develop BMPs that will 

effectively eliminate or reduce pollutant loadings in stormwater discharges from the facility 
3 

 in accordance with the following sections. The evaluation and selection of the BMPs shall 

address each area, and/or activity where source materials are exposed to stormwater 

discharging to surface water. 

A. Pollution Prevention 

All contact of source materials and industrial activities with stormwater shall be prevented 

and/or minimized. Each BMP that is used to minimize and/or prevent such contact shall be 

identified and discussed in the SPPP. 

1. Diverting Stormwater 

Approved diversion of contaminated stormwater to either a domestic or industrial 

wastewater treatment plant may also be considered when choosing an appropriate BMP 

where feasible. (Diversion to groundwater may require additional Department approval, or 

modification to this permit. Contact the Bureau of Nonpoint Pollution Control if a discharge 

to groundwater is being considered.) 

2. Good Housekeeping 

The SPPP must include a good housekeeping program to help maintain a clean and orderly 

work place. For certain activities or areas, contact of source materials with stormwater may 

be prevented and/or minimized merely by using good housekeeping methods. The following 

are some simple procedures that a facility can consider incorporating into an effective good 

housekeeping program: 

• conduct cleanup immediately after discovery of leaks and spills; 

• implement careful material storage practices; 

• improve operation and maintenance of industrial machinery and processes; 

• maintain up-to-date material inventory; 

• maintain well organized work areas; 

• provide regular pickup and disposal of waste materials; 

• maintain dry and clean floors and ground surfaces by using brooms, shovels, vacuum 

cleaners, or cleaning machines; and 

• train employees about good housekeeping practices. 
4 

3. Spill Prevention and Response 

Specific spill prevention and response procedures shall be developed. The procedures shall 

include material handling, storage and equipment operation and maintenance requirements 

used to prevent and/or eliminate spills and/or leaks. A valid SPCC or DPCC shall satisfy this 

requirement provided the plan includes spill prevention/cleanup for all site chemicals, 

wastewater and raw materials. 

The permittee shall develop and implement a Spill Prevention Plan. At a minimum, the Plan 

shall include: 

- Spill Response Coordinator 

- Procedures for preventing and/or cleaning up spills 

- List of available spill cleanup materials, including brooms, shovels, absorbents, 

heavy equipment, containers, etc. (The list should include normal level of inventory 

that will be kept onsite). 

- Description of employee training, including: 

• Location of spill cleanup materials, containers and equipment 

• Procedures for preventing and/or cleaning up spills 

• Company Spill Response Coordinator (the coordinator can be listed by Title, 

such as, Plant Manager) 

• List of emergency phone numbers 

- Description of routine inspections for spills, leaks, damage to containment and 

spill structures. Inspections are recommended to be done weekly. 

- Routine inventory of spill cleanup materials and equipment. 

4. Site Stabilization and Dust Control 

The SPPP shall include standards for site stabilization and dust control designed to prevent 

transport of particulate and sediment from areas devoid of vegetation and to prevent 

downstream soil erosion caused by routine operations and uncontrolled stormwater runoff. 

At a minimum the standards shall meet the technical standards found in the Standards for 

Soil and Erosion and Sediment Control in New Jersey and shall include: 

- traffic control to prevent or minimize disturbance of unstabilized areas and to 

prevent disturbance of vegetative covers and/or other dust control mechanisms 

- entrance/exit stabilization to prevent or minimize transport of sediment and dust 

outside the site property line 

- dust control to prevent or minimize movement of dust and sediment from 

exposed soil areas 

5. Erosion Control at the Outfalls 

The permittee shall inventory all outfall structures that are used to convey and discharge 

stormwater. Stormwater velocity at the outfalls shall be controlled to prevent 

downstream erosion and/or degradation and ensure stabilization. 
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- All work shall be accomplished in accordance with applicable State, Federal, and 

local approvals. 

- The permittee shall design, implement and maintain BMPs to prevent 

downstream erosion and sedimentation caused by stormwater, mine dewatering 

and/or process wastewater runoff at the outfall(s). 

- At a minimum, the BMPs shall meet the most recent technical standards listed in 

Standards for Soil Erosion and Sediment Control in New Jersey, Engineering 

Standards Section titled Standard for Off-Site Stability. 

- The permittee shall repair and maintain the erosion controls and shall restore the 

eroded areas to its previous condition. 

- The permittee shall include a narrative of stormwater runoff control and list of 

BMPs in the site SPPP. 

6. Preventative Maintenance 

The SPPP shall include a Preventative Maintenance Program to include timely and regular 

inspections and maintenance of stormwater management devices (e.g., cleaning oil/water 

separators, catch basins, drip pans, catch basins, detention basins, covers, treatment units) 

and routine inspections of facility equipment and operations to detect faulty equipment. 

Equipment (such as tanks, piping, containers, and drums) should be checked regularly for 

signs of deterioration. 

7. Engineered Treatment Systems 

If the permittee implements specific BMPs to minimize or eliminate specific pollutants and 

discovers that the BMPs continue to be ineffective, then the permittee will need to consider 

an engineered treatment system. Treatment systems may require additional permitting from 

NJDEP. 

Stormwater treatment systems that are verified by NJCAT (http://www.njcat.org/) and 

certified by NJDEP maybe considered to meet permit requirements. But site specific 

applications needs to be evaluated before installing any system. The permittee should 

contact the Department’s permitting case manager prior to purchasing and installing an 

engineered treatment system. 

VI. Implementation Schedule 

The SPPP shall include an implementation schedule for all structural and non-structural 

BMP's including a schedule(s) for removal, coverage, minimization of exposure of source 

material to stormwater, and/or stormwater diversion or treatment. The schedule shall meet 

the deadlines established in the permit in accordance with Part IV. 
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Upon completion of the initial SPPP, those BMP's (e.g., spill response, good housekeeping) 

that may readily be implemented as specified in Part IV of the permit, shall be done so 

within 30 days, if not already practiced. 

VII. General Plan Requirements 

This section provides additional requirements on the administrative requirements related to 

finalizing your SPPP. It covers (1) required certifications, (2) required signatures, and (3) 

requirements for plan location and access 

A. Certification of Stormwater Pollution Prevention Plan 

1. The SPPP 

The SPPP preparation, implementation, and annual recertification shall be certified in 

accordance with Part IV on the appropriate form provided by the Department. 

B. Required Signatures for SPPP and Certifications 

The SPPP and Certifications shall be signed as follows: 

For a corporation: A president, secretary, treasurer or vice-president of the corporation in 

charge of a principal business function, or any other person who performs similar policy or 

decision making functions for the corporation; or the manager of one or more 

manufacturing, production, or operating facilities, provided: 

(1) The manager is authorized to make management decisions that govern the operation 

of the regulated facility, including having the explicit or implicit duty of recommending 

major capital investment, initiating and directing comprehensive measures to assure long 

term compliance with environmental laws and regulations, and ensuring that the necessary 

systems are established or actions taken to gather complete and accurate information for 

permit application requirements; or 

(2) The authority to sign documents has been assigned or delegated to the manager in 

accordance with corporate procedures. 

For a partnership or sole proprietorship: A general partner or the proprietor 

For a government agency: A ranking elected official; or the chief executive officer of the 

agency; or a senior executive officer having responsibility for the overall operations of a 

principal geographic unit of the agency (e.g., Regional Administrator); or duly authorized 

representative as defined in N.J.A.C. 7:14A - 4.9 (b).
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Whenever there are two or more permittees for the facility, all of those permittees shall 

jointly submit this Certification, unless permittees received authorization on different dates 

and this Certification is therefore due from them at different dates. 

C. Plan Location and Public Access 

1. SPPP Records 

The SPPP and inspection and preventative maintenance records or logs shall be maintained 

on site at all times. These documents must be made available, upon request, to a 

representative of the Department and to the owner and operator of any municipal separate 

storm sewer receiving the stormwater discharge. 

2. Make Available to the Public 

The SPPP shall be made available to the public upon request. The facility may claim any 

portion of the SPPP as confidential in accordance with the provisions set forth in N.J.A.C. 

7:14A-18.2. 

3. Submit a Copy of the SPPP 

A copy of the SPPP shall be submitted to the appropriate Regional Bureau of Water 

Compliance and Enforcement and to the Bureau of Nonpoint Pollution Control. Revisions 

made to the facility's SPPP shall be submitted also 

4. Inspections and Annual Reports 

- Regular Inspections 

The SPPP shall establish a schedule for regular inspections as required in Part IV 

Section F of the permit. Regular inspections shall include inspections of the 

facility's equipment, exposed source materials and industrial areas to ensure that 

all elements of the SPPP are in place and working properly. Inspections shall be 

conducted by qualified, trained plant personnel. Records of these inspections 

shall be kept onsite with the SPPP. At a minimum, these inspection records shall 

consist of the following: 

• date of inspection; 

• location of and problem(s) identified; 

• steps taken to correct problem(s) and prevent recurrence; and 

• inspector's name and title. 

In addition these inspection records shall record any incidents such as leaks or 

accidental discharges, and any failures or breakdowns of structural BMPs. 

- Annual Inspections 
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Conduct annual inspections as required in Part IV Section F of the permit. The 

annual inspections are necessary to evaluate the implementation of the SPPP for 

preparation of the annual report and annual certifications. 

- Annual Reports 

The SPPP shall include a method to routinely and continually evaluate the SPPP 

for effectiveness, any flaws that may have developed, and maintenance that may 

be required. The routine evaluation must include, but not be limited to: 

• Regular and annual inspections 

• Inspection logs and records 

• Internal reporting 

• Plan revisions to correct any flaws detected in the SPPP or to reflect 

changes/additions at the facility 

• Logs of preventative maintenance performed at the facility. 

VIII. Special Requirements 

A. Facilities Subject to Emergency Planning and Community Right-to-Know 

Statute 

For facilities subject to the Emergency Planning and Community Right-to-Know Act 

(EPCRA) Section 313, the SPPP shall include, or cite the location of, any spill reports 

prepared under that Act. 

B. Facilities with SPCC Plans, DPCC Plans, or DCR Plans 

The SPPP shall include, or cite the location(s) of, any Spill Prevention Control and 

Countermeasure Plan (SPCC Plan) prepared under 40 CFR 112 and section 311 of the Clean 

Water Act, 33 U.S.C.§1321; and any discharge prevention, containment and countermeasure 

plan (DPCC plan) and discharge cleanup and removal plan (DCR plan) prepared under 

N.J.A.C. 7:1E. 

C. Facilities Undergoing Construction Activities 

Whenever construction activities are undertaken at the facility, the SPPP shall be amended, 

if necessary, so that the SPPP continues to be accurate and to meet the requirements of Part I 

of this permit.