# 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 categ ories. The permit authorizes the intake of Great Egg

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

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

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

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

system (DSN 014A – internal point).

The draft permit proposed to authorize treated effluent fr om 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. Accordingl y, 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 m onth 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 part y 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,

# per_Fncv.rtf 

# within 30 days of receipt of this Consolidated Renewa l 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 fo rms have been changed. Enclosed with this permit are the

new monitoring report forms (MRFs). Beginning the effe ctive 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 shou ld 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

ftoc_dsw.rtf 

# 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 St ormwater Pollution Prevention Plan

# Response to Comments

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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 Pollu tant Discharge Elimina tion System (NJPDES)

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

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

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

2013.

The Department received the following submission:

1. Reed W. Super and Edan Rotenberg of S uper 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 beha lf of the Sierra

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

Action.

A summary of the timely and significant comme nts 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 th e “location, design, construction,

and capacity of cooling water inta ke 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 re quiring 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 thr ough improved screens with fish buckets and an

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

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

all, nor does it require B.L. Engl and to take any action that mig ht actually reduce the number of

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

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

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

require that this technology be inst alled as soon as reasonably possible.

# Response to Comments

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Permit No. NJ0005444



# The best technology to address B. L. England’s fish kills and ther mal 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 envir onmental 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 Sec tion 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) decisi on to impingement reductions alone. The

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

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

... The permittee is proposing major changes to th e Station that will re sult in environmental

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

intake volume, discharge volume, and air emissions.

Further, on page 20:

...The Department cont ends that it is reasonable to a ssume that a reduction in water

withdrawal will have a dir ectly proportional reduc tion 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 regu lates cooling water

intake structures and their effects and states that:

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

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

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

The construction of BL England predates the enac tment 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 regu lations 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) determin ations in accordance with Best Professional Judgment (BPJ).

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

states and permitting authorities must glean info rmation 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

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# Comment 2

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

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

Information Collection (PIC) in 2005 and a Comp rehensive Demonstrati on Study (CDS - also

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

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

technology options that involved va rious modifications to the exis ting screens, the fish return

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

approach the impingement and en trainment reductions achievable th rough 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 Ci rcuit 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 availabl e 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. Inst ead, in its 2007 letter, NJDEP actually waived a requirement

that the forthcoming CDS should include “tec hnology and compliance a ssessment information”

and “information to support site-specific de termination 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 per mittee’s 2009 permit renewa l application.

After receiving the 316(b) Re port in 2008 and the renewal pe rmit application in 2009, NJDEP

took another four years to issue this Draft Pe rmit. This extended de lay 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 in formation detailing the

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

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

effective September 7, 2004 to gu ide implementation of the S ection 316(b) statute under the

1972 Clean Water Act. These Phase II regulations were specific to pow er 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 s ubmitted 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. Ci rcuit Court of Appeals issued its decision

# Response to Comments

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# in the litigation over the Phase II regulation. Th e court’s decision rema nded several provisions

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

• EPA’s determination of th e 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 Administra tive Record for BL England, NJDE P issued a fina l renewal permit

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

required submission of a PIC and a CDS. The nece ssary 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 pr ior 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 imp lemented 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 biol ogical conditions in the vicinity of the

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

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

representative of current cond itions and that the data were collected using appropriate

quality assurance/quality control procedures;

(iii) A summary of any past or ongoing consu ltations 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 pr opose must be appropria te for a quantitative

survey and include considerati on of the methods used in ot her studies performed in the

# Response to Comments

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

(including the area of influent of the coolin g water intake structur e(s)), and provide a

taxonomic identification of the sampled or ev aluated biological a ssemblages (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 cons truction technologies for

the once through cooling system as per 40 CF R 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 consiste nt with the scope of the rule at 40 CFR

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

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

Based on the remand of the Phase II Section 316( b) regulations, EPA di rected 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 contex t of the CDS for all affected facilities. As a

result, the NJDEP determined that the Source Wa terbody Flow Information and the Impingement

Mortality and/or Entrainment Characterization Study (40 CF R 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 require ments, NJDEP waived the study requirements for

technology and compliance assessm ent information; a restorati on 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 st andards for impingement and entr ainment were remanded. This

determination was appr opriate given the Sec ond Circuit Court’s position on the technology and

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

NJDEP disagrees with the commentor’s asserti on that the 2009 permit re newal application did

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

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

technologies despite the uncertain ty associated with the pendi ng Section 316(b) rule. Upon

renewal of the permit in 2013, NJ DEP utilized the information av ailable 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 require ments of the proposed rule as described further

in Response 5 . In addition, NJDEP determined that th e suite of intake pr otection 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

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# 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 k illed 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 th e 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 extra polating the 2005-06 sampling out to

annual numbers.

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

repowering, B.L. England will continue to w ithdraw 167.6 MGD of coo ling 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 o ccur at these design flows. Ev en at a flow of 167.6 MGD, B.L.

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

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

a year.

Response 3

Repowering this existing facility will result in th e 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 impin gement 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 resultin g 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 comment or, aquatic organisms ar e present at certain

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

reduction in impingement and entr ainment 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-floatin g 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 requi res that these impacts be minimized through

intake protection technol ogies. NJDEP maintains that th e most effective way to reduce

impingement and entrainment is throug h 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

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# Comment 4

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

unreasonable, and violates the expr ess requirement of S ection 316(b). First, the absence of any

cooling tower analysis is inconsistent with NJ DEP’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 ma king 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 outco me of every BPJ-based BTA determination, but

rather the appropriate t echnology is best deter mined after a careful ev aluation 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 reme dial 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 temperat ure 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 impact s 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 availabl e 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 f act that it would be required to evaluate the use of cooling

towers at every existing facility in the st ate 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

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# • B.L. England is significantly reducing its wa ter 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 st ated on page 22207 of the April 20, 2011 Federal

Register for the proposed Section 316(b) regulation:

...EPA has determined that closed cycle coolin g 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 info rmation 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 technolog ies considered have social costs not justified by the social benefit,

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

that no additional control requi rements are necessary beyond wh at the facility is already

doing.

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

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

site-specific considerations.

Regarding use of the 1977 EPA guidance docum ent 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

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

document excerpt quoted here is consistent with the 2013 permit dete rmination 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 e ffects must be minimized. This further supports the approach

of reducing water withdrawals as BL Engl and 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 considera tion of cooling towers wher e all eligible New Jersey

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

requirements upon finalization. Th is 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 morta lity control technologies. . .

At a minimum, the owner or operator of the f acility 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 per mittee 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 tec hnically not even yet required.

Comment 5

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

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

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

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

particular site. No other tec hnology approaches the environmenta l effectiveness of closed-cycle

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

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

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

for further study, it found that the next most eff ective technologies to cl osed-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 larv ae 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 wa ter 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

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# 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 r ealized 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 co mparison, the proposed rule at 122.21(r)(2) through

(12) requires the study and submission of num erous 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 co mplex 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 justif ied. 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 sche dule 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 re quirements 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 we ll 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 ac tions that Ristroph traveling screens are a

proven and effective technolog y to minimize impingement mort ality. 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.

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# Yet while modified Ristroph scr eens are a proven and effective t echnology, EPA has stated that

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

have to be implemented as soon as possible but w ithin 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, th e Department will eval uate 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 pe rmit determinati on 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, entrainm ent at Oyster Creek appears to be lower than

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

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

focused on the fact that closed-cycle cooling re duces 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 installa tion 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 copi ous amounts of cooling

water. The New York Department of Envir onmental 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 t echnologies. DEC based

its determination that cooling to wers were BTA on several factor s and noted that the technology

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

other technology or operational measure available to reduce a quatic 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) determina tions across the nation for a variety of reasons.

First, there are many site-specifi c factors that must be taken in to account in defining available

intake protection tec hnologies such as remaining useful plant life, air emissions, space

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

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

requiring closed-cycle cooling, many of these d ecisions were never finaliz ed 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 NJ PDES 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 in stalled. 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 l east seven years and woul d involve significant

costs.

As noted above, the rationale for this decisi on 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 bl owdown 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 gene rates a total of 1538 MW

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

requirement to install cooling towers occurred af ter 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 ther mal impacts of the plant on the winter flounder population in

Mount Hope Bay. NJDEP maintains that this is a very separate situa tion from BL England.

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# 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) regulati on. 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 w ill 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 de termination to ensure that the costs of the technology selected

as the best available are not who lly 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 en trainment. Professor Johnston

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

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

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

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

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

non-market valuation methods cap able 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 tota l benefits.”

In the past, at power plants such as the Mer cer Generating Station, NJDE P has based its wholly

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

that looked at market data fo r commercially fished species a nd zeroed-out the value of all

non-commercial species of fish. Thus, NJDEP ha s grossly underestimated th e total benefits of

reducing impingement and entrainment.

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

benefits of protecting fish, sh ellfish and other aqua tic organisms from destruction by cooling

water intake structures were sign ificant, but had no way to quantif y these benefits. So in late

2011, U.S. EPA conducted a national st ated-preference study to addr ess cost-benefit analyses for

cooling water intake re gulation 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 acr oss the United States. EPA estimated the net

present cost of different technologies for reduc ing 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 i ndicate that the net environmental

benefits from modernized coolin g 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.

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# EPA’s survey design was methodologically ri gorous 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 histor ically issued findings with respect to costs and

benefits as part of its BTA de termination. The "wholly dispr oportionate" 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 di sproportionate to the e nvironmental benefits.

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

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

Hampshire, et al. (Seabrook Station, Units 1 a nd 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/ben efit 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, th e 2011 proposed rule sets a new pl aying 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 ev aluation 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 specifi ed in 125.98(e) namely: (1) numbers and types

of organisms entrained; (2) entrainment imp acts 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 availab ility; (8) remaining useful plan t life; and (9) impacts on water

consumption.

However, NJDEP does not support item (3), na mely the considerati on of quantified and

qualitative social benefits and so cial costs of available entr ainment technologies including

ecological benefits and benef its 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. wh ereas social benefits include non-market benefits such as a

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

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

almost impossible to quantif y particularly with respect to non-market values.

# Response to Comments

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# In fact, as part of its effort on the rule-makin g, 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 a nd 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 an y 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 standa rd found in relevant

case law.

NJDEP is unclear as to the commentor's sugge stion 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 NJDE P is evaluating costs and benef its. 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 revisite d upon finalization of the

rule.

Comment 8

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

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

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

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

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

First, regardless of how it may be categorized unde r 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 lif espan. In the federal

rulemaking docket, EPA’s techni cal staff wrote a draft regulati on 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 dr aft 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 sugges tions and recommendations. EPA asserted that

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

opportunity to design and constr uct 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 shoul d 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 BT A is even stronger at B.L.

# Response to Comments

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# England since the above noted existing facilities all must be retrofit after be ing 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 insi stence of the OMB. Because OMB does not have

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

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

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

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

which would require app lication 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 whethe r 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 fac ilities 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 i ndustrial operation, but that does

not otherwise meet the definiti on 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 re placement 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:

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# 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 a nd 2 will have ceased. Unit 1 w ill be retired and Unit 2 will

cease operations as a coal-fired unit. Unit 3 whic h now runs on #6 oil w ill 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 Engla nd does not qualify as a “new un it” under the proposed rule.

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

use the proposed rule definition of new unit and in stead 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 di fferent fashion where repowered units would be

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

documents are not valid for the purposes of NJDE P in rendering a decisi on. Instead, NJDEP must

rely on the proposed rule as drafted.



# The commentor also contends that NJDEP shoul d 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 appropriate ness of input as part of the rule-m aking process and instead must rely

on the official proposed version of the draft rule.

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

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

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

defensible.



# Comment 9

The segment of the Great Egg Harbor Bay into wh ich 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, a nd 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 th ese 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.

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# 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 oxyg en and colder water holds more oxygen. By

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

the addition of nutrients and other oxygen dema nding 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 temp erature 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 mon itoring 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. NJDE P has evaluated the data from the two monitoring stations

referenced in this comment. Station 2902A is a pproximately 6336 feet upstr eam 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:

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# 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 th e 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 disc hargers, weather, etc. While point source

discharges are regulated throug h 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 nuisan ce 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. ( o 

# C) 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 Thal assiosira sp. (200

cells/mL) None Present

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# Comments from the July 19, 2012 Report: The wate rs 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 alg ae 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 da ta to prove this contention. It would be in appropriate to

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

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

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

information regarding the appropriateness of di scharge 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 wa ter 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 rel eased at DSNs 008A, 009A, and 010A, or on any

other parameter to a ddress the discharge of heat a nd 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 equi valent 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 th e discharge from DSN 013A does not cause or

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

presently 0.69 MGD, and will drop to just 0.22 M GD 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 significan t impact, especially in the summertime, even at 167

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

DSN010A that require the discharge to imme diately 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 em phasis 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 re newal of this NJPDES permit t oday 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 di scharge that exists today.

# Response to Comments

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# 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 manufactur ing operations and landfills.

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

non-contact cooling water, wher e 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 Elect ric Power Generating Po int 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 I ndian Point, Mirant Canal, E.F. Barrett and

Merrimack.

Nonetheless, the Department recognizes the co mmentor'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 w ill allow the Department to track both the intake

and effluent to assess any contri butions 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 d eemed necessary based on submitte d data. The incorporation of

more frequent monitoring in a final permit action is allo wable 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 o ff the screens and discharged at DSN 008A. The

discharge of all these dead organisms adversely e ffects dissolved oxygen le vels 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

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# the uncontrolled discharge of nutrients from DS Ns 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 detr itus and dead organisms that are released

through a discharge. Rather, th e appropriate regulatory mechanis m 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 de tritus that can be discharged but rather to

require the installation of intake protection technologie s to minimize impingement and

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

As stated in Response 5 , this permit requires an expedited st udy 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-abrasi ve 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 imp ingement 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 tec hnologies since it is difficult to

quantify entrainment mortality for each species and lif e 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 addre ss 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 sh all not be allowed in concentrations that

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

densities, nuisance aqua tic vegetation, diurnal fluctuations in dissolved oxygen or pH

indicative of excessive photosyn thetic activity, detr imental 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 pur pose of the SWQS is to set standards for the

waterbody whereas the NJPDES per mit sets standards for the discharg es 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 facilitie s 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 fro m the cooling towers and the screen backwash.

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# 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 entraine d organisms can be equated to

"agriculture".

Comment 12

Instead of establishing wate r quality based efflue nt limitations, NJDEP is proposing to renew

B.L. England’s alternative h eat limits set under the Clean Wate r Act section 316(a) variance

provision. NJDEP explained that its intent to re new the variance is base d 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 direc tly on there being less heat discharged presently

than was discharged when the 316(a) variance wa s last renewed in 2005 si nce 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 befo re and after the repowering is acceptable in

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

exceedances of water quality standards, it is not acceptable.

Second, the proposed 316(a) varian ce determination places signif icant 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 be lieves that the reduced overall heat load will

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

of initial dilution” will increase in both size a nd 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 th e permittee’s burden of pr oof is to demonstrate

that the alternative limit will assu re protection of a balanced i ndigenous 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 de termination discuss the cumula tive 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 Fe deral Clean Water Act regulates the thermal

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

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

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

receiving water. Section 316(a) of the Federal Clean Water Ac t states, in part:

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# ....the Administrator (or if a ppropriate, the State) may im pose 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 th ermal component with ot her pollutants), that

will assure the protection and propagation of a balan ced, indigenous population of

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

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

heat dissipation dimensions provided that the c onditions 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 Sec tion 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) deter mination 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 coolin g 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 water body 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 in termittent conditions, the Depar tment does not agree that the

overall plume will be increased under the repower ed 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 c ontinue to be discharged through DSN

001. The once-through cooling water discha rge 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 plum e from approximately 26 to 32% for the

repowered plant condition as compared to the existing plant configuration.

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

following is stated:

# Response to Comments

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# ...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 e limination of any heat loading from DSN 009A

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

limitations for DSN 010A for September thr ough 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 temperat ure differential limit of 11.0 degrees Celsius

as a daily maximum and an effluent temper ature 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 becau se the use of the duct burners is limited by

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

each plant startup, shutdown or infrequent turbin e 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 a nd is expected to have minimal effect on

aquatic organisms in GEHB beyond the eff ects 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 duc t burners occurs very infrequen tly 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 Ba y that is unfit for a quatic life nor does the

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

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

present in the area of the intake. Note th at 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 me t 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 regulati ons, and applicable guidance

documents. The Department recognizes that the applicant’s burden with regard to the

renewal of a thermal variance is “to suppor t the continuation of the variance” and does

not require the same le vel of proof as an application for an initial variance in accordance

with 40 CFR 125.72(c).

One of the factors that the Department consider ed 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 Depa rtment concluded the following:

# Response to Comments

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# 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 th e 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 repowerin g. In addition, the effluent temperature

and temperature differential limitations for DSN 010A for Se ptember 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 max imum 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 base d 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 vari ance; (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 dete rmined 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 Sec tion 316(a) analysis is appropriate and based on

relevant laws and guidance.

Comment 13

In this permit renewal, NJDEP plans to weak en 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 upg rade the condenser coolin g 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 ma ximum and the maximum temperature effluent

limit at DSN 010A from 38.3 to 40.5 degrees Celsius.

Relaxation of this heat effluent limit clearly violat es 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 ex ceptions described therein apply

at B.L. England. The provision NJDEP cites to ju stify 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 e ffluent limitation.” Neither of these

conditions have been met. First, although a re powering is contemplated by 2016, no material or

substantial alterations have occurred at B.L. En gland yet. Until the repowering is completed, in

2016, the exception cited by NJDEP cannot possibl y apply. Second, even if the proposed

repowering occurs as planned, NJDEP has not expl ained why a less stringent effluent limitation for

# Response to Comments

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# 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 discha rge will shrink the overall size of the thermal

plume, the increased heat of the discharge will e xpand the zone at the core of the plume that is

totally uninhabitable, thus destroying mo re 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 m odified 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 temper ature differential limits at DSN 010 during June through August,

the Department conservatively ev aluated the requirement s referenced in N.J.A.C. 7:14A-13.19 in

the 2013 Fact Sheet as well as in this response be low. 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 limit ations or standards in the previous permit.



# And Section 402(o)(2) of the Federal Clean Wate r Act states the following with respect to

anti-backsliding and its exceptions:

(o) Anti-backsliding

(1) General prohibition

In the case of effluent limitations establishe d 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 th is title subsequent to the original issuance

of such permit, to contain e ffluent 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 prev ious permit except in compliance with section

1313(d)(4) of this title.

(2) Exceptions

A permit with respect to which paragraph (1) a pplies may be renewed, re issued, or modified

to contain a less stringent effluent limit ation applicable to a pollutant if—

(A) material and substantial alterations or a dditions to the permitted facility occurred after

permit issuance which justify the applicat ion of a less stringent effluent limitation...

# Response to Comments

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# The commentor is correct in that NJDEP cited that the repowering project qualifies as a material

and substantial alte ration or addition to the permitted facility pur suant to Section 402(o) of the

Federal Clean Water Act. Contrary to the commentor’s contention, th e Department does not

agree that Section 402(o) requires the permittee to complete the mate rial and substantial

alteration before requesting higher limits. Rather, the material and substantial alteration would

have occurred after the issuance of the “previ ous permit”, as referen ced in Section 402(o)1,

which in this case refers to the 2005 NJPDES renewal. Secondly, NJ DEP 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 s ilent 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 regu lations such as the Mill stone 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 pl ants with once-through

cooling systems will need to adapt their cooling syst ems 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 cons ider climate change as part of Section 316(a). In

fact, one could argue that climate change consid erations would result in higher temperature limits,

temperature differential limits and heat limitations. Instead, NJDEP is maintaining its heat limits,

temperature differential limits and effluent temper ature 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 n eeded in order to comply with state water quality

standards, irrespective of whethe r the Act’s technology-based provis ions 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 Sout h Carolina have converted to cl osed-cycle cooling primarily to

reduce thermal discharges that ran afoul of state water quality standa rds. As at those plants, the

thermal pollution and the nutrients discharged by B.L. England’s once-through cooling system cause

# Response to Comments

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Permit No. NJ0005444



# sufficient environmental harm to warrant a conversion to closed-cycle cooling.

Response 15

As described in fu rther detail in Response 6 , it is not appropriate to compare the site-specific

information of various national plan ts. This is based on variation in a number of factors including

receiving waterbody characteristics, discharge char acteristics, 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) determina tion 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 a nd 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 di scharge of thermal pollution in marine estuaries.

Also, both agencies have a strong interest and understanding of th e ecological health of Great Egg

Harbor Bay, have supporte d NJDEP’s conservation and research efforts, and have consulted with

NJDEP on other NJDPES permittin g processes. If NJ DEP 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 per mit 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 th e NJPDES permit. NJDEP then proposes lax

schedules for gathering the missing data and does not in clude reopener provisi ons in the permit

specifying that the permit shall be reopened i mmediately once the missing data are collected.

Commenters have observed this pattern in bot h the Mercer Generatin g 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 cont ains effluent limitations for all pollutants that

have the reasonable potential to cause or contribut e 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 qua lity samples. Thus, NJDEP concluded that it

lacks sufficient data to conduct a reasonabl e potential analysis as follows:

# Response to Comments

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# • At DSN 001A (cooling tower blowdown), includi ng for copper, even though in the four

existing water quality samples from this outfall copper was det ected 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 de ficiency, 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 coolin g 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 setti ng water quality based effluent limits even

though it detected arsenic and sele nium in four of five samples, with at least one arsenic

sample at concentrations nearly 300 time s higher than the state water quality standard

.

• At DSN 014A (flue gas desulfurization wastew ater), 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 situati on such as it could have relied on the four or

five samples available for each out fall, particularly where a samp le is above state water quality

standards. At a minimum, NJDEP should include:

• A copper effluent limit at DSN 001A, where c opper 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 th at relates to a parameter su ch as total organic carbon or

biological oxygen demand a nd addresses the impact that pressure-spraying dead and

decomposing fish off the plant’s intake screen s has on dissolved oxygen concentrations;

• Arsenic, heat, dissolved oxygen, and nutri ent 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. En gland to conduct) a prog ram of rapid testing

over the next few months to adequately character ize all of the discharges at B.L. England for

which it claims to lack sufficient data, and shoul d then issue a final permit that includes water

quality based effluent limits.

# Response to Comments

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# 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 routin ely applied to all NJPDES per mits 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 wh ere the permitting authority maintains that

sufficient representative data mu st be available to conduct a proper statistical analysis.

Additionally, the U.S. EPA Technical Support Do cument recommends in Section 3.3 that eight

to 12 samples be obtained for pa rameters 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 desc ribed 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 desu lfurization scrubber, w ill 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 availabl e toxic data at all

discharges. NJDEP had required extensive prior ity pollutant sampling at most outfalls where

the vast majority of results we re 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 th at pollutant. Four data points are not

sufficient for determining a site -specific coefficient of varia tion and subsequent WQBEL.

However, monitoring for copper is increased to semiannual in the final permit so there

will be 10 data values ava ilable upon permit renewal. No te 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 likel y representative of stormwater data after

repowering based on the change in fuel source fro m coal to natural gas. Also, metals are

# Response to Comments

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Permit No. NJ0005444



# not typically present in stormwater yet the De partment 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 organism s are addressed via S ection 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 pr ovide 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 mon itoring frequency is in creased to semiannual

and the need for a WQBEL will be reeval uated upon permit renewa l. Also, WQBELs

are imposed for several toxics at the in ternal 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, ni ckel 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 magn itude below the SWQS as described in

the 2013 Fact Sheet. This outfall will ceas e discharging by May 2016 per the Air

Program’s Administrative Cons ent 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 pe rmit developed without

# Response to Comments

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Permit No. NJ0005444



# adequate efflue nt samples “ shall include a reopener clause .” The requirement to collect

sampling data and improve upon a de ficient reasonable potential anal ysis 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 in clude the missing effluent limits as soon as

possible, although it does contain specific pr ovisions related to th e BTA determination,

petroleum hydrocarbons in cooling tower blowdow n, 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 appropr iate and do not cause or contribute to an excursion above the SWQS.

Contrary to the commentor’s contention, the 2013 Draft Permit does contai n a reopener clause.

As per Part IV F.2. of the Draft Permit:

The Department may modify or revoke and reissue any pe rmit 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 ch emical specific toxic parameters, 2) toxicity

reduction requirements, or 3) the implementation of a TMDL or watershed ma nagement 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 Desulfuriza tion (FGD) and Coal

Combustion Residuals Impoundments at Steam Elect ric 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 da ta it required during the four y ears that lapsed between B.L.

England’s submission of a permit renewal appli cation 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 wh en it was filed in 2009.

Presumably, NJDEP’s insistence on gathering te n data points before conducting a reasonable

potential analysis is based on N.J. ADMIN. C ODE § 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

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Permit No. NJ0005444



# Response 19

While NJDEP recognizes that the above referen ced 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 Engl and. Coal combustion residuals, commonly known

as coal ash, are byproducts of the combustion of co al at power plants and are generally disposed

of in liquid form at large surf ace impoundments and in solid form at landfills. As noted in the

June 7, 2010 memo:

The purpose of this memorandum is to provi de 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 co al combustion and because a coal combustion

residual impoundment does not exist at BL Engla nd, guidance regarding coal combustion waste

is not applicable.

Regarding guidance for FGD systems, the memo doe s 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 descri bes 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 inadequa te technology based effluent limits at DSN 013A and DSN 014A

which should be revised to refl ect Best Available Technology fo r 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 othe r toxic pollutants found in coal combustion waste. The agency

has announced its intention to revise the existin g 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 indus try in 1982. Since then, EPA

has learned that the power sector is a significant discharger of toxic polluta nts and the toxicity of

these discharges is primarily driven by metals associated with coal combustion waste. EPA has

# Response to Comments

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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 requi res 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 c onventional 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 thes e limits, they are achievable and the technology

leading to them is available at B.L. England. A nd other plants are surpassing even this level of

achievement and eliminating all FGD wastewater discharge either through the use of

vapor-compression evaporati on systems or by fully recycling wastewater.

NJDEP cannot claim that improve d treatment technologies as not “available” for DSNs 013A

and 014A because some of the discharges r outed 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 lif e 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 discharg e at some plants suggests that

the best available technology sta ndards is in fact zero meaning the complete e limination of all

discharge.

Response 20

As noted previously, DSN 014 consists of a pproximately 0.03 MGD of FGD wastewater which

# Response to Comments

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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 o il coalescence, equalization, polymer addition, two

stage pH adjustment, flocculati on, clarification, filtr ation and neutraliza tion. As described

above in Response 19, guidance regarding coal co mbustion waste does not apply to BL England.

With respect to the FGD wastes tream (DSN 014A), the Department maintains that the limits set

in the 2013 Draft Permit are ad equate and a ppropriate.

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 a nd effluent limits at DSNs 013A and 014A for the parameters described in

this comment are as follows:

DSN 013A – Wastewat er 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

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Permit No. NJ0005444



# DSN 014 – FGD Wastestream that is Div erted to Wastewat er 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 refe renced in the above tabl e is regulated is as

follows:

Arsenic – Arsenic is limited at the internal mon itoring point DSN 014A and monitored at

DSN 013A. Arsenic was NOT detect ed 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 require d to be monitored annually at DSN 013A.

The EPA memo dated June 7, 2010 for FGD wa stestreams 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 wast estreams does not recognize chromium as a

wastewater component.

Copper – Copper is limited at the internal monito ring 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 date d 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 outfa lls 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

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Permit No. NJ0005444



# Mercury – Application data for Merc ury showed it was not detect ed 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 be low the NJSWQS of 71 ug/L. Selenium is

required to be monitore d semi-annually at DSN 013A and at DSN 014A.

Zinc – Zinc is limited at the internal monitori ng 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 main tains that the effluent limits at DSNs 013A and 014A are

appropriate a nd protective.

With respect to the suggestion that DSN 014 be re quired to have a “zero discharge,” because this

discharge will be eliminated, this condition is being met. The re maining 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 protecte d. Also, designated uses shall be maintained or, as soon as

technically and economically feasible, be attain ed wherever these uses are not precluded by

natural conditions. Further, at a minimum, ev en 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 “wat er 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 efflue nt limits violates the state’s antid egradation 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 disc harge at DSN010A in a manner that makes a

larger portion of Great Egg Harbor Bay in imical to indigenous sp ecies 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) vari ance together allow B.L. England to continue

discharging high volumes of h eat 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

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Permit No. NJ0005444



# permit comports with New Jersey’s antidegradation policy.

Response 21

This permit is consistent with NJDEP’s antidegradation policy because all per mit limitations and

conditions are equal to or more stringent than those contained in the existing permit with the

exception of temperature differen tial 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 Bur eau 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 P ilar Patterson of the Bureau of Surface Water

Permitting. As described in this letter, the regulatory criteria fo r 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 crite ria 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. Th e Department may hold a public

hearing if it determines that a hearing is likel y 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 an y public comments on the associated air permit

for the facility, namely the Significant Modificati on to the Title V Operating Permit. The public

comment period for the air permit began on Fe bruary 6, 2013 and ende d 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 re quired by N.J.A.C. 7:14A-15.12(a), there was no

# Response to Comments

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Permit No. NJ0005444



# justification in the submittal as to why a public hearing was necessary and why written comments

would not be sufficient in a ddressing the group’s concerns.

Additionally, NJDEP participated in a conf erence call on June 13, 2013 with some of the

commenters including Edan Rotenberg of S uper Law Group, Alice Baker of the Eastern

Environmental Law Center, and Edward Lloyd and Susan Kraham of the Environmental Law

Clinic at Columbia Univers ity School of Law. Particip ants from NJDEP included Pilar

Patterson and Susan Rosenw inkel of the Bureau of Surface Wa ter 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



# N EW 

# J ERSEY 

# P OLLUTANT



# D ISCHARGE 

# E LIMINATION 

# S YSTEM

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 wi th the terms and

conditions specified, you are assuming an important role in protecting New Jersey’s valuable water resources. Your acceptance o f this permit is an

agreement to conform with all of its provisions when constructing, installing, modifying, or operating any facility for the col lection, 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

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# PART II

GENERAL REQUIREMENTS:

DISCHARGE CATEGORIES

A. Additional Requirements Incorporated By Reference

1. Requirements for Discha rges 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 discha rge 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

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# 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 fac ility generates and

discharges to surface waters and/or ground water any domestic wastewater, non-contact cooling

water, or process waste water (including leachate an d 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 even ts 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 contro l 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 discharg es 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;

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# 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 ope rator 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

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# 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

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# 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 Jers ey 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 5Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointPART IIILIMITS AND MONITORING REQUIREMENTSGreat Egg Harbor BayB - Industrial Wastewater001A SW Outfall DSN 001ADISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION:Effluent samples for DSN 001A shall be taken at the sampling station located at the boiler blowdown pipe prior to discharge viaDSN 001A.Cooling tower blowdownLocation DescriptionContributing Waste TypesSurface 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 monitoring report form. Ifcooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."PHASE Start Date:PHASE End Date:PHASE:Table III - A - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMGDContinuous*****CalculatedREPORTREPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment PlantMGDContinuous*****CalculatedREPORTREPORTIntake FromStreamQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment Plant*****2/Week9.0SUGrab6.0EffluentGross ValueQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****2/WeekREPORTSUGrabREPORTIntake FromStreamQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****1/MonthREPORTREPORTMG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberSolids, TotalSuspendedLimits And Monitoring RequirementsPage 1 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 monitoring report form. Ifcooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."PHASE Start Date:PHASE End Date:PHASE:Table III - A - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/Month30100MG/LCalculatedEffluent NetValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberSolids, TotalSuspended*****1/MonthREPORTREPORTMG/LGrabIntake FromStreamQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberSolids, TotalSuspended*****1/Year%EFFLCompositeREPORTEffluentGross ValueQL***************MinimumReport Per********************January thru DecemberLC50 Statre 96hr AcuMysid Bahia*****3/Week0.20.5MG/LGrabEffluentGross ValueRQL*********0.10.1AverageMaximum*****MonthlyDaily**********January thru DecemberChlorine ProducedOxidants*****ContinuousREPORTREPORTDEG.CMeteredEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****ContinuousREPORTREPORTDEG.CMeteredIntake FromStreamQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****1/MonthREPORTMG/LGrabREPORTEffluentGross ValueQL***************MinimumMinimumInstantDaily Avg***************January thru DecemberOxygen, Dissolved(DO)Limits And Monitoring RequirementsPage 2 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 monitoring report form. Ifcooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."PHASE Start Date:PHASE End Date:PHASE:Table III - A - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/MonthREPORTREPORTMG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberCarbon, Tot Organic(TOC)MBTU/HR1/Day*****Calculated50REPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberNet Rate of Additionof Heat*****1/6 MonthsREPORTREPORTUG/LGrabEffluentGross ValueRQL*********1010AverageMaximum*****MonthlyDaily**********January thru DecemberSelenium, TotalRecoverable*****1/MonthREPORTREPORTMG/LGrabEffluentGross ValueRQL*********0.010.01AverageMaximum*****MonthlyDaily**********January thru DecemberChromium, Total(as Cr)*****1/MonthREPORT0.2MG/LGrabEffluent NetValueRQL*********0.010.01AverageMaximum*****MonthlyDaily**********January thru DecemberChromium, Total(as Cr)*****1/MonthREPORTREPORTMG/LGrabIntake FromStreamRQL*********0.010.01AverageMaximum*****MonthlyDaily**********January thru DecemberChromium, Total(as Cr)*****1/6 MonthsREPORTREPORTUG/LGrabEffluentGross ValueRQL*********1010AverageMaximum*****MonthlyDaily**********January thru DecemberNickel,Total RecoverableLimits And Monitoring RequirementsPage 3 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 monitoring report form. Ifcooling tower additives containing Chromium are not used during that month then the permittee shall report "CODE=N."PHASE Start Date:PHASE End Date:PHASE:Table III - A - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/MonthREPORTREPORTMG/LGrabEffluentGross ValueRQL*********0.030.03AverageMaximum*****MonthlyDaily**********January thru DecemberZinc,Total Recoverable*****1/MonthREPORT1MG/LGrabEffluent NetValueRQL*********0.030.03AverageMaximum*****MonthlyDaily**********January thru DecemberZinc,Total Recoverable*****1/MonthREPORTREPORTMG/LGrabIntake FromStreamRQL*********0.030.03AverageMaximum*****MonthlyDaily**********January thru DecemberZinc,Total Recoverable*****1/6 MonthsREPORTREPORTUG/LGrabEffluentGross ValueRQL*********1010AverageMaximum*****MonthlyDaily**********January thru DecemberCopper,Total RecoverableLimits And Monitoring RequirementsPage 4 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabManganese, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 40Cyanide, Total(as CN)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 8Arsenic, TotalRecoverable (as As)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Thallium, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Beryllium, TotalRecoverable (as Be)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Barium, TotalRecoverable (as Ba)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 2Silver,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 4Cadmium,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Lead,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Antimony, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 1MercuryTotal RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10AcenaphthyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.5AcenaphtheneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10AnthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabBenzo(b)fluoranthene(3,4-benzo)Effluent Gross ValueLimits And Monitoring RequirementsPage 5 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 20Benzo(k)fluorantheneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Benzo(a)pyreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Bis(2-chloroethyl)etherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 26.5Bis(2-chloroethoxy)methaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Bis (2-chloroiso-propyl) etherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Butyl benzylphthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20ChryseneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Diethyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Dimethyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrab1,2-Diphenyl-hydrazineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10FluorantheneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10FluoreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Hexachlorocyclo-pentadieneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10HexachloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Indeno(1,2,3-cd)-pyreneEffluent Gross ValueLimits And Monitoring RequirementsPage 6 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 10IsophoroneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20N-nitrosodi-n-propylamineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20N-nitrosodiphenyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20N-nitrosodimethyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10NitrobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10PhenanthreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20PyreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Benzo(ghi)peryleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Benzo(a)anthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 91,2-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 101,2,4-Trichloro-benzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Dibenzo(a,h)anthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 91,3-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 201,4-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.52-ChloronaphthaleneEffluent Gross ValueLimits And Monitoring RequirementsPage 7 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabDi-n-octyl PhthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 102,4-DinitrotolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.52,6-DinitrotolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 603,3'-Dichloro-benzidineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.54-Bromophenyl phenyletherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 8NaphthaleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 30Bis(2-ethylhexyl)phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Di-n-butyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50BenzidineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabMalathionEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabDemetonEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10HexachlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10HexachlorobutadieneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabMirexEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 71,3-DichloropropeneEffluent Gross ValueLimits And Monitoring RequirementsPage 8 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrab1,2,4,5-Tetrachloro-benzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabN-nitrosodiethyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabN-nitrosopyrrolidineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6Carbon TetrachlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 31,2-DichloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 8BromoformEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5ChloroformEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6TolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 7BenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50AcroleinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50AcrylonitrileEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6ChlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6ChlorodibromomethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6EthylbenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9Methyl BromideEffluent Gross ValueLimits And Monitoring RequirementsPage 9 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 10Methyl ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6Methylene ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9TetrachloroethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5Trichlorofluoro-methaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 23.51,1-DichloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1-DichloroethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1,1-Trichloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1,2-Trichloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 101,1,2,2-Tetrachloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 51,2-DichloropropaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 41,2-trans-Dichloro-ethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrab2-ChloroethylVinyl Ether (Mixed)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5BromodichloromethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Vinyl ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5TrichloroethyleneEffluent Gross ValueLimits And Monitoring RequirementsPage 10 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabMethoxychlorEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabN-Nitrosodi-n-butylamineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabChloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabParachloro-m-cresolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabParathionEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPhenolsEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrab2,4,5-Trichloro-phenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.02Delta BHC,Total (ug/l)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.08Endosulfan SulfateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04Beta EndosulfanEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.02Alpha EndosulfanEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.1Endrin AldehydeEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1016(Arochlor 1016)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrab2,3,7,8-Tetrachloro-dibenzo-p-dioxinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.064,4'-DDT(p,p'-DDT)Effluent Gross ValueLimits And Monitoring RequirementsPage 11 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 0.044,4'-DDD(p,p'-DDD)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.044,4'-DDE(p,p'-DDE)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04AldrinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.02Alpha BHCEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04Beta BHCEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.03Gamma BHC (lindane),Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.2ChlordaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.03DieldrinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabEndosulfans, Total(alpha and beta)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04EndrinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 1ToxapheneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.02HeptachlorEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.4Heptachlor EpoxideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1221(Arochlor 1221)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1232(Arochlor 1232)Effluent Gross ValueLimits And Monitoring RequirementsPage 12 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabPCB-1242(Arochlor 1242)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1248(Arochlor 1248)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1254(Arochlor 1254)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1260(Arochlor 1260)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPolychlorinatedBiphenyls (PCBs)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabChlorpyrifosEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 202-ChlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 182-NitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 102,4-DichlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 13.52,4-DimethylphenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 402,4-DinitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 202,4,6-Trichloro-phenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 214-Chlorophenylphenyl etherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 124-NitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 604,6-Dinitro-o-cresolEffluent Gross ValueLimits And Monitoring RequirementsPage 13 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - A - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 10PhenolSingle CompoundEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 30PentachlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPentachlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabGuthionEffluent Gross ValueLimits And Monitoring RequirementsPage 14 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointGreat Egg Harbor BayRF - Stormwater003A SW Outfall DSN 003ADISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION:Effluent samples for DSN 003A shall be taken via a grab sample prior to discharge.Storm Water RunoffLocation DescriptionContributing Waste TypesSurface 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 Start Date:PHASE End Date:PHASE:Table III - B - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMGD1/Month*****CalculatedREPORTREPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment Plant*****2/Month9.0SUGrab6.0EffluentGross ValueQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****2/Month30100MG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberSolids, TotalSuspended*****2/Month1015MG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberPetroleumHydrocarbons*****1/MonthREPORTREPORTMG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberCarbon, Tot Organic(TOC)Limits And Monitoring RequirementsPage 15 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 Start Date:PHASE End Date:PHASE:Table III - B - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/QuarterREPORT0.136UG/LGrabEffluentGross ValueRQL*********88AverageMaximum*****MonthlyDaily**********January thru DecemberArsenic, TotalRecoverable (as As)*****6/Year0.751.5MG/LGrabEffluentGross ValueRQL*********0.010.01AverageMaximum*****MonthlyDaily**********January thru DecemberNickel,Total Recoverable*****6/Year0.51.0MG/LGrabEffluentGross ValueRQL*********0.030.03AverageMaximum*****MonthlyDaily**********January thru DecemberZinc,Total RecoverableLimits And Monitoring RequirementsPage 16 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - B - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabManganese, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 40Cyanide, Total(as CN)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Selenium, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Thallium, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Beryllium, TotalRecoverable (as Be)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Barium, TotalRecoverable (as Ba)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 2Silver,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 4Cadmium,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Lead,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Chromium,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Copper,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Antimony, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 1MercuryTotal RecoverableEffluent Gross ValueLimits And Monitoring RequirementsPage 17 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - B - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabPhenolsEffluent Gross ValueLimits And Monitoring RequirementsPage 18 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointGreat Egg Harbor BayRF - Stormwater006A StormwaterDISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION:Effluent samples for DSN 006A shall be taken via a grab sample prior to discharge.Storm Water RunoffLocation DescriptionContributing Waste TypesConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - C - 1: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberMM/DD/YYREPORTCalculatedDate of Storm EventEffluent Gross ValueJanuary thru DecemberSTD TIMEREPORTCalculatedTime StormEvent BeganEffluent Gross ValueJanuary thru December# HOURSREPORTCalculatedStorm Event DurationEffluent Gross ValueJanuary thru December# HOURSREPORTCalculatedHours Since LastStorm EventEffluent Gross ValueJanuary thru DecemberSTD TIMEREPORTCalculatedTime of SampleCollectionEffluent Gross ValueJanuary thru December# INCHESREPORTCalculatedRainfall Amount atTime of SamplingEffluent Gross ValueJanuary thru DecemberSUREPORTGrabpHEffluent Gross ValueJanuary thru DecemberMG/LREPORTGrabSolids, TotalSuspendedEffluent Gross ValueJanuary thru DecemberMG/LREPORTGrabOil and GreaseEffluent Gross ValueJanuary thru DecemberMG/LREPORTGrab-3Petrol Hydrocarbons,Total RecoverableEffluent Gross ValueLimits And Monitoring RequirementsPage 19 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - C - 1: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberMG/LREPORTGrabOxygen Demand,Chem.(High Level) (COD)Effluent Gross ValueLimits And Monitoring RequirementsPage 20 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointGreat Egg Harbor BayRF - Stormwater007A StormwaterDISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION:There are no monitoring requirements for this discharge.Storm Water RunoffLocation DescriptionContributing Waste TypesRequirements have not been defined for this Monitored Location.Limits And Monitoring RequirementsPage 21 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointGreat Egg Harbor BayB - Industrial Wastewater009A SW Outfall DSN 009ADISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION:Effluent samples for DSN 009A shall be taken at the sampling station for DSN 009A which is before mixing with DSN 010A in the discharge canal.Steam Elec Cooling WaterLocation DescriptionContributing Waste TypesSurface 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 Start Date:PHASE End Date:PHASE:Table III - E - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMGDContinuous*****CalculatedREPORTREPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment PlantMGDContinuous*****CalculatedREPORTREPORTIntake FromStreamQL***************AverageAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment Plant*****3/Week9.0SUGrab6.0EffluentGross ValueQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****3/WeekREPORTSUGrabREPORTIntake FromStreamQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****3/WeekREPORT0.2MG/LGrabEffluentGross ValueMDL*********0.10.1AverageMaximum*****MonthlyDaily**********January thru DecemberChlorine ProducedOxidantsLimits And Monitoring RequirementsPage 22 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 Start Date:PHASE End Date:PHASE:Table III - E - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****ContinuousREPORT38.3DEG.CMeteredEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****ContinuousREPORTREPORTDEG.CMeteredIntake FromStreamQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****1/MonthREPORTMG/LGrabREPORTEffluentGross ValueQL***************MinimumMinimumInstantDaily Avg***************January thru DecemberOxygen, Dissolved(DO)MBTU/HR1/Day*****Calculated1530REPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberNet Rate of Additionof Heat*****1/DayREPORT8.8DEG.CCalculatedEffluent NetValueQL***************AverageMaximum*****MonthlyDaily**********June thru AugustTemp. Difference,Summer (oC)*****1/DayREPORT19.3DEG.CCalculatedEffluent NetValueQL***************AverageMaximum*****MonthlyDaily**********September thru MayTemp. Difference,Winter (oC)Limits And Monitoring RequirementsPage 23 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointGreat Egg Harbor BayB - Industrial Wastewater010A SW Outfall DSN 010ADISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION:Effluent samples for DSN 010A shall be taken at the sampling station for DSN 010A which is before mixing with DSN 009A in the discharge canal.Steam Elec Cooling WaterLocation DescriptionContributing Waste TypesConsolidated 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 under repowered conditions.PHASE Start Date:PHASE End Date:PHASE:Table III - F - 1: Consolidated DMR Limits and Monitoring Requirements1-Initial 08/01/2013 07/31/2016PHASE Start Date:PHASE End Date:ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMGDContinuous*****CalculatedREPORTREPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment PlantMGDContinuous*****CalculatedREPORTREPORTIntake FromStreamQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment Plant*****3/Week9SUGrab6EffluentGross ValueQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****3/WeekREPORTSUGrabREPORTIntake FromStreamQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****3/WeekREPORT0.2MG/LGrabEffluentGross ValueMDL*********0.10.1AverageMaximum*****MonthlyDaily**********January thru DecemberChlorine ProducedOxidantsLimits And Monitoring RequirementsPage 24 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 under repowered conditions.PHASE Start Date:PHASE End Date:PHASE:Table III - F - 1: Consolidated DMR Limits and Monitoring Requirements1-Initial 08/01/2013 07/31/2016PHASE Start Date:PHASE End Date:ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****ContinuousREPORT38.3DEG.CMeteredEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****ContinuousREPORTREPORTDEG.CMeteredIntake FromStreamQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****1/MonthREPORTMG/LGrabREPORTEffluentGross ValueQL***************MinimumMinimumInstantDaily Avg***************January thru DecemberOxygen, Dissolved(DO)*****1/MonthREPORTMG/LGrabREPORTIntake FromStreamQL***************MinimumMinimumInstantDaily Avg***************January thru DecemberOxygen, Dissolved(DO)*****1/6 MonthsREPORTREPORTUG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberBoron, Total(as B)MBTU/HR1/Day*****Calculated1530REPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberNet Rate of Additionof Heat*****1/DayREPORT8.8DEG.CCalculatedEffluent NetValueQL***************AverageMaximum*****MonthlyDaily**********June thru AugustTemp. Difference,Summer (oC)Limits And Monitoring RequirementsPage 25 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 under repowered conditions.PHASE Start Date:PHASE End Date:PHASE:Table III - F - 1: Consolidated DMR Limits and Monitoring Requirements1-Initial 08/01/2013 07/31/2016PHASE Start Date:PHASE End Date:ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/DayREPORT19.3DEG.CCalculatedEffluent NetValueQL***************AverageMaximum*****MonthlyDaily**********September thru MayTemp. Difference,Winter (oC)*****1/6 MonthsREPORTREPORTUG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberArsenic, TotalRecoverable (as As)PHASE Start Date:PHASE End Date:PHASE:Table III - F - 2: Consolidated DMR Limits and Monitoring Requirements2-Final (Repowered) 08/01/2016ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMGDContinuous*****CalculatedREPORTREPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment PlantMGDContinuous*****CalculatedREPORTREPORTIntake FromStreamQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment Plant*****3/Week9SUGrab6EffluentGross ValueQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpHLimits And Monitoring RequirementsPage 26 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 under repowered conditions.PHASE Start Date:PHASE End Date:PHASE:Table III - F - 2: Consolidated DMR Limits and Monitoring Requirements2-Final (Repowered) 08/01/2016ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****3/WeekREPORTSUGrabREPORTIntake FromStreamQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****3/WeekREPORT0.2MG/LGrabEffluentGross ValueMDL*********0.10.1AverageMaximum*****MonthlyDaily**********January thru DecemberChlorine ProducedOxidants*****ContinuousREPORT40.5DEG.CMeteredEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****ContinuousREPORTREPORTDEG.CMeteredIntake FromStreamQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****1/MonthREPORTMG/LGrabREPORTEffluentGross ValueQL***************MinimumMinimumInstantDaily Avg***************January thru DecemberOxygen, Dissolved(DO)*****1/MonthREPORTMG/LGrabREPORTIntake FromStreamQL***************MinimumMinimumInstantDaily Avg***************January thru DecemberOxygen, Dissolved(DO)*****1/6 MonthsREPORTREPORTUG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberBoron, Total(as B)Limits And Monitoring RequirementsPage 27 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 under repowered conditions.PHASE Start Date:PHASE End Date:PHASE:Table III - F - 2: Consolidated DMR Limits and Monitoring Requirements2-Final (Repowered) 08/01/2016ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMBTU/HR1/Day*****Calculated1530REPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberNet Rate of Additionof Heat*****1/DayREPORT11.0DEG.CCalculatedEffluent NetValueQL***************AverageMaximum*****MonthlyDaily**********June thru AugustTemp. Difference,Summer (oC)*****1/DayREPORT19.3DEG.CCalculatedEffluent NetValueQL***************AverageMaximum*****MonthlyDaily**********September thru MayTemp. Difference,Winter (oC)*****1/6 MonthsREPORTREPORTUG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberArsenic, TotalRecoverable (as As)Limits And Monitoring RequirementsPage 28 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabManganese, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 40Cyanide, Total(as CN)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Selenium, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Thallium, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Beryllium, TotalRecoverable (as Be)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Barium, TotalRecoverable (as Ba)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Nickel,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 2Silver,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 30Zinc,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 4Cadmium,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Lead,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Chromium,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Copper,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Antimony, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 1MercuryTotal RecoverableEffluent Gross ValueLimits And Monitoring RequirementsPage 29 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 10AcenaphthyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.5AcenaphtheneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10AnthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabBenzo(b)fluoranthene(3,4-benzo)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Benzo(k)fluorantheneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Benzo(a)pyreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Bis(2-chloroethyl)etherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 26.5Bis(2-chloroethoxy)methaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Bis (2-chloroiso-propyl) etherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Butyl benzylphthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20ChryseneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Diethyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Dimethyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrab1,2-Diphenyl-hydrazineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10FluorantheneEffluent Gross ValueLimits And Monitoring RequirementsPage 30 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 10FluoreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Hexachlorocyclo-pentadieneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10HexachloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Indeno(1,2,3-cd)-pyreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10IsophoroneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20N-nitrosodi-n-propylamineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20N-nitrosodiphenyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20N-nitrosodimethyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10NitrobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10PhenanthreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20PyreneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Benzo(ghi)peryleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Benzo(a)anthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 91,2-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 101,2,4-Trichloro-benzeneEffluent Gross ValueLimits And Monitoring RequirementsPage 31 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 20Dibenzo(a,h)anthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 91,3-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 201,4-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.52-ChloronaphthaleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabDi-n-octyl PhthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 102,4-DinitrotolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.52,6-DinitrotolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 603,3'-Dichloro-benzidineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9.54-Bromophenyl phenyletherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 8NaphthaleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 30Bis(2-ethylhexyl)phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 20Di-n-butyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50BenzidineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabMalathionEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabDemetonEffluent Gross ValueLimits And Monitoring RequirementsPage 32 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 10HexachlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10HexachlorobutadieneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabMirexEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 71,3-DichloropropeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrab1,2,4,5-Tetrachloro-benzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabN-nitrosodiethyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabN-nitrosopyrrolidineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6Carbon TetrachlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 31,2-DichloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 8BromoformEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5ChloroformEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6TolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 7BenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50AcroleinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50AcrylonitrileEffluent Gross ValueLimits And Monitoring RequirementsPage 33 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 6ChlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6ChlorodibromomethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6EthylbenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9Methyl BromideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Methyl ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6Methylene ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9TetrachloroethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5Trichlorofluoro-methaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 23.51,1-DichloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1-DichloroethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1,1-Trichloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1,2-Trichloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 101,1,2,2-Tetrachloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 51,2-DichloropropaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 41,2-trans-Dichloro-ethyleneEffluent Gross ValueLimits And Monitoring RequirementsPage 34 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrab2-ChloroethylVinyl Ether (Mixed)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5BromodichloromethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Vinyl ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5TrichloroethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabMethoxychlorEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabN-Nitrosodi-n-butylamineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabChloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabParachloro-m-cresolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabParathionEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPhenolsEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrab2,4,5-Trichloro-phenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.02Delta BHC,Total (ug/l)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.08Endosulfan SulfateEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04Beta EndosulfanEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.02Alpha EndosulfanEffluent Gross ValueLimits And Monitoring RequirementsPage 35 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 0.1Endrin AldehydeEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1016(Arochlor 1016)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrab2,3,7,8-Tetrachloro-dibenzo-p-dioxinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.064,4'-DDT(p,p'-DDT)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.044,4'-DDD(p,p'-DDD)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.044,4'-DDE(p,p'-DDE)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04AldrinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.02Alpha BHCEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04Beta BHCEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.03Gamma BHC (lindane),Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.2ChlordaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.03DieldrinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabEndosulfans, Total(alpha and beta)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.04EndrinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 1ToxapheneEffluent Gross ValueLimits And Monitoring RequirementsPage 36 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 0.02HeptachlorEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 0.4Heptachlor EpoxideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1221(Arochlor 1221)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1232(Arochlor 1232)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1242(Arochlor 1242)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1248(Arochlor 1248)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1254(Arochlor 1254)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPCB-1260(Arochlor 1260)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPolychlorinatedBiphenyls (PCBs)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabChlorpyrifosEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 202-ChlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 182-NitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 102,4-DichlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 13.52,4-DimethylphenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 402,4-DinitrophenolEffluent Gross ValueLimits And Monitoring RequirementsPage 37 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - F - 3: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 202,4,6-Trichloro-phenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 214-Chlorophenylphenyl etherEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 124-NitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 604,6-Dinitro-o-cresolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10PhenolSingle CompoundEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 30PentachlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPentachlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabGuthionEffluent Gross ValueLimits And Monitoring RequirementsPage 38 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointGreat Egg Harbor BayB - Industrial Wastewater013A SW Outfall DSN 013ADISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION: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 discharge throughthe pipe identified as DSN 013A.Process WaterLocation DescriptionContributing Waste TypesSurface 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 Start Date:PHASE End Date:PHASE:Table III - G - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMGDContinuous*****MeteredREPORTREPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment Plant*****Continuous9.0SUMetered6.0EffluentGross ValueQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpH*****2/Month30100MG/L4 Hour CompositeEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberSolids, TotalSuspended*****1/Year%EFFLCompositeREPORTEffluentGross ValueAL******50******MinimumReport Per********************January thru DecemberLC50 Statre 96hr AcuMysid BahiaLimits And Monitoring RequirementsPage 39 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 Start Date:PHASE End Date:PHASE:Table III - G - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/Month5.0MG/LGrab4.0EffluentGross ValueQL***************MinimumMinimumInstantDaily Avg***************January thru DecemberOxygen, Dissolved(DO)*****2/Month1015MG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberPetroleumHydrocarbonsKG/DAY1/Month21REPORTMG/LGrabREPORTREPORTEffluentGross ValueQL***************MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberCarbon, Tot Organic(TOC)*****1/6 MonthsREPORTREPORTUG/L4 Hour CompositeEffluentGross ValueRQL************8AverageMaximum*****MonthlyDaily**********January thru DecemberSelenium, TotalRecoverable*****1/6 MonthsREPORTREPORTUG/L4 Hour CompositeEffluentGross ValueRQL************10AverageMaximum*****MonthlyDaily**********January thru DecemberArsenic, Total(as As)*****1/QuarterREPORT1.0MG/L4 Hour CompositeEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberIron, Total(as Fe)*****1/QuarterREPORT1.0MG/L4 Hour CompositeEffluentGross ValueRQL************0.01AverageMaximum*****MonthlyDaily**********January thru DecemberNickel,Total RecoverableLimits And Monitoring RequirementsPage 40 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 Start Date:PHASE End Date:PHASE:Table III - G - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/QuarterREPORT1.0MG/L4 Hour CompositeEffluentGross ValueRQL************0.03AverageMaximum*****MonthlyDaily**********January thru DecemberZinc,Total Recoverable*****1/QuarterREPORT0.2MG/L4 Hour CompositeEffluentGross ValueRQL************0.01AverageMaximum*****MonthlyDaily**********January thru DecemberChromium,Total Recoverable*****1/MonthREPORT8.7UG/L4 Hour CompositeEffluentGross ValueRQL************10AverageMaximum*****MonthlyDaily**********January thru DecemberCopper,Total RecoverableLimits And Monitoring RequirementsPage 41 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositeManganese, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 40Cyanide, Total(as CN)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Thallium, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Beryllium, TotalRecoverable (as Be)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Barium, TotalRecoverable (as Ba)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 2Silver,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 4Cadmium,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Lead,Total RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeChromium, HexavalentDissolved (as Cr)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Antimony, TotalRecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 1MercuryTotal RecoverableEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10AcenaphthyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 9.5AcenaphtheneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10AnthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeBenzo(b)fluoranthene(3,4-benzo)Effluent Gross ValueLimits And Monitoring RequirementsPage 42 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Benzo(k)fluorantheneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Benzo(a)pyreneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Bis(2-chloroethyl)etherEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 26.5Bis(2-chloroethoxy)methaneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Bis (2-chloroiso-propyl) etherEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Butyl benzylphthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20ChryseneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Diethyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Dimethyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour Composite1,2-Diphenyl-hydrazineEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10FluorantheneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10FluoreneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Hexachlorocyclo-pentadieneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10HexachloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Indeno(1,2,3-cd)-pyreneEffluent Gross ValueLimits And Monitoring RequirementsPage 43 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10IsophoroneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20N-nitrosodi-n-propylamineEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20N-nitrosodiphenyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20N-nitrosodimethyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10NitrobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10PhenanthreneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20PyreneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Benzo(ghi)peryleneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10Benzo(a)anthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 91,2-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 101,2,4-Trichloro-benzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Dibenzo(a,h)anthraceneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 91,3-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 201,4-DichlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 9.52-ChloronaphthaleneEffluent Gross ValueLimits And Monitoring RequirementsPage 44 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositeDi-n-octyl PhthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 102,4-DinitrotolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 9.52,6-DinitrotolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 603,3'-Dichloro-benzidineEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 9.54-Bromophenyl phenyletherEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 8NaphthaleneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 30Bis(2-ethylhexyl)phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 20Di-n-butyl phthalateEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 50BenzidineEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeMalathionEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeDemetonEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10HexachlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10HexachlorobutadieneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeMirexEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 71,3-DichloropropeneEffluent Gross ValueLimits And Monitoring RequirementsPage 45 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour Composite1,2,4,5-Tetrachloro-benzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeN-nitrosodiethyl-amineEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeN-nitrosopyrrolidineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6Carbon TetrachlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 31,2-DichloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 8BromoformEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5ChloroformEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6TolueneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 7BenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50AcroleinEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 50AcrylonitrileEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6ChlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6ChlorodibromomethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6EthylbenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9Methyl BromideEffluent Gross ValueLimits And Monitoring RequirementsPage 46 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORTGrabRQL = 10Methyl ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 6Methylene ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 9TetrachloroethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5Trichlorofluoro-methaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 23.51,1-DichloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1-DichloroethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1,1-Trichloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 61,1,2-Trichloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 101,1,2,2-Tetrachloro-ethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 51,2-DichloropropaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 41,2-trans-Dichloro-ethyleneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrab2-ChloroethylVinyl Ether (Mixed)Effluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5BromodichloromethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 10Vinyl ChlorideEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabRQL = 5TrichloroethyleneEffluent Gross ValueLimits And Monitoring RequirementsPage 47 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositeMethoxychlorEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeN-Nitrosodi-n-butylamineEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabChloroethaneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeParachloro-m-cresolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeParathionEffluent Gross ValueJanuary thru DecemberUG/LREPORTGrabPhenolsEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour Composite2,4,5-Trichloro-phenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.02Delta BHC,Total (ug/l)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.08Endosulfan SulfateEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.04Beta EndosulfanEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.02Alpha EndosulfanEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.1Endrin AldehydeEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePCB-1016(Arochlor 1016)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour Composite2,3,7,8-Tetrachloro-dibenzo-p-dioxinEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.064,4'-DDT(p,p'-DDT)Effluent Gross ValueLimits And Monitoring RequirementsPage 48 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.044,4'-DDD(p,p'-DDD)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.044,4'-DDE(p,p'-DDE)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.04AldrinEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.02Alpha BHCEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.04Beta BHCEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.03Gamma BHC (lindane),Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.2ChlordaneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.03DieldrinEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeEndosulfans, Total(alpha and beta)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.04EndrinEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 1ToxapheneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.02HeptachlorEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 0.4Heptachlor EpoxideEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePCB-1221(Arochlor 1221)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePCB-1232(Arochlor 1232)Effluent Gross ValueLimits And Monitoring RequirementsPage 49 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositePCB-1242(Arochlor 1242)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePCB-1248(Arochlor 1248)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePCB-1254(Arochlor 1254)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePCB-1260(Arochlor 1260)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePolychlorinatedBiphenyls (PCBs)Effluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeChlorpyrifosEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 202-ChlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 182-NitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 102,4-DichlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 13.52,4-DimethylphenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 402,4-DinitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 202,4,6-Trichloro-phenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 214-Chlorophenylphenyl etherEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 124-NitrophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 604,6-Dinitro-o-cresolEffluent Gross ValueLimits And Monitoring RequirementsPage 50 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointConsolidated 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 the permit (EDP).PHASE Start Date:PHASE End Date:PHASE:Table III - G - 2: Consolidated WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 10PhenolSingle CompoundEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeRQL = 30PentachlorophenolEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositePentachlorobenzeneEffluent Gross ValueJanuary thru DecemberUG/LREPORT4 Hour CompositeGuthionEffluent Gross ValueLimits And Monitoring RequirementsPage 51 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointGreat Egg Harbor BayB - Industrial Wastewater014A SW Outfall DSN 014ADISCHARGE CATEGORY(IES):RECEIVING LOCATION:MONITORED LOCATION:Effluent samples for DSN 014A shall be taken at the sampling station for DSN 014A (located in the scrubber/wastewater treatmentbuilding) for allparameters with the exception of whole effluent toxicity (WET). Samples for WET shall be taken at the discharge canal for DSN010A after DSN014A discharges into it.Process WaterLocation DescriptionContributing Waste TypesSurface 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 Start Date:PHASE End Date:PHASE:Table III - H - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit UnitsMGDContinuous*****MeteredREPORTREPORTEffluentGross ValueQL***************MaximumAverage***************DailyMonthlyJanuary thru DecemberFlow, In Conduit orThru Treatment PlantKG/DAY2/MonthREPORTREPORTMG/L4 Hour CompositeREPORTREPORTEffluentGross ValueQL***************MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberBOD, 5-Day (20 oC)*****1/Day9.0SUGrab6.0EffluentGross ValueQL***************MinimumMaximumDaily*****Daily**********January thru DecemberpHKG/DAY2/Month30100MG/L4 Hour Composite27.258.18EffluentGross ValueQL***************MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberSolids, TotalSuspendedLimits And Monitoring RequirementsPage 52 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 Start Date:PHASE End Date:PHASE:Table III - H - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/Year%EFFLCompositeREPORTEffluentGross ValueAL******50******MinimumReport Per********************January thru DecemberLC50 Statre 96hr AcuMysid Bahia*****1/DayREPORTREPORTDEG.CGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberTemperature,oC*****2/Month1015MG/LGrabEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberPetroleumHydrocarbonsKG/DAY2/MonthREPORTREPORTMG/L4 Hour CompositeREPORTREPORTEffluentGross ValueQL***************MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberCarbon, Tot Organic(TOC)KG/DAY1/Week39007900UG/L4 Hour Composite2.11.1EffluentGross ValueQL***************MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberSulfide, Total(as S)*****1/6 MonthsREPORTREPORTUG/L4 Hour CompositeEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberSulfate, Total(as SO4)*****1/6 MonthsREPORTREPORTMG/L4 Hour CompositeEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberIron, TotalRecoverableLimits And Monitoring RequirementsPage 53 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 Start Date:PHASE End Date:PHASE:Table III - H - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/6 MonthsREPORTREPORTUG/L4 Hour CompositeEffluentGross ValueQL***************AverageMaximum*****MonthlyDaily**********January thru DecemberBoron, Total(as B)KG/DAY1/Week8301700UG/L4 Hour Composite0.450.23EffluentGross ValueRQL*********88MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberArsenic, TotalRecoverable (as As)*****1/6 MonthsREPORTREPORTUG/L4 Hour CompositeEffluentGross ValueRQL*********1010AverageMaximum*****MonthlyDaily**********January thru DecemberSelenium, TotalRecoverable*****1/6 MonthsREPORTREPORTUG/L4 Hour CompositeEffluentGross ValueRQL*********3030AverageMaximum*****MonthlyDaily**********January thru DecemberZinc,Total RecoverableKG/DAY1/Week17003500UG/L4 Hour Composite0.950.47EffluentGross ValueRQL*********1010MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberCopper,Total RecoverableKG/DAY1/Week4998UG/L4 Hour Composite0.0270.013EffluentGross ValueRQL*********11MaximumAverageAverageMaximum*****MonthlyDailyDailyMonthlyJanuary thru DecemberMercuryTotal RecoverableLimits And Monitoring RequirementsPage 54 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSurface 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 Start Date:PHASE End Date:PHASE:Table III - H - 1: Surface Water DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/6 MonthsREPORTREPORTUG/L4 Hour CompositeEffluentGross ValueRQL*********3030AverageMaximum*****MonthlyDaily**********January thru DecemberBis(2-ethylhexyl)phthalateLimits And Monitoring RequirementsPage 55 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointSI6A Belt Filter Press B - Industrial WastewaterMONITORED LOCATION:DISCHARGE CATEGORY(IES):Annually, a representative sample of the belt filter pressed sludge generated from wastewater treatment shall be analyzed pursuant to the Sludge QualityAssurance Regulations (SQAR, N.J.A.C. 7:14C) each year sludge is removed for ultimate management.Ind Residual-OtherLocation DescriptionContributing Waste TypesResiduals DMR Reporting Requirements:Submit an Annual DMR: due 60 calendar daysafter the end ofeach calendar year.PHASE Start Date:PHASE End Date:PHASE:Table III - I - 1: Residuals DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/YearREPORT%TSCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberSolids, Total*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberNitrate Nitrogen,Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberNitrogen, KjeldahlTotal, Dry Wt*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberPotassiumDry WeightLimits And Monitoring RequirementsPage 56 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointResiduals DMR Reporting Requirements:Submit an Annual DMR: due 60 calendar daysafter the end ofeach calendar year.PHASE Start Date:PHASE End Date:PHASE:Table III - I - 1: Residuals DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberNitrogen, AmmoniaDry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberCalciumDry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberMolybdenumDry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberPhosphorusDry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberArsenic, Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberSelenium, Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberCopper, Dry WeightLimits And Monitoring RequirementsPage 57 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointResiduals DMR Reporting Requirements:Submit an Annual DMR: due 60 calendar daysafter the end ofeach calendar year.PHASE Start Date:PHASE End Date:PHASE:Table III - I - 1: Residuals DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberBerylliumDry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberCadmium, Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberZinc, Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberLead, Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberNickel, Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberMercury, Dry Weight*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberChromium, Dry WeightLimits And Monitoring RequirementsPage 58 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointResiduals DMR Reporting Requirements:Submit an Annual DMR: due 60 calendar daysafter the end ofeach calendar year.PHASE Start Date:PHASE End Date:PHASE:Table III - I - 1: Residuals DMR Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample TypeFrequencyLimitLimitLimitLimitSample Point Limit UnitsSample TypeFrequencyUnitsSample Point Limit Units*****1/YearREPORTMG/KGCompositeIndustrialResidualsQL***************Average*****Monthly***************January thru DecemberIron, Dry WeightResiduals WCR - Annual Reporting Requirements:Submit an Annual WCR: due 60 calendar daysafter the end ofeach calendar year.PHASE Start Date:PHASE End Date:PHASE:Table III - I - 3: Residuals WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru DecemberWCY/YRREPORTCalculatedAmt Sludge Rmvd,Wet Cubic YardsIndustrial ResidualsJanuary thru DecemberWMT/YRREPORTCalculatedAmt Sludge Rmvd,Wet Metric TonsIndustrial ResidualsJanuary thru DecemberGAL/YEARREPORTCalculatedAmt Sludge Rmvd,GallonsIndustrial ResidualsJanuary thru DecemberDMT/YRREPORTCalculatedTotal Amount ofSludge RemovedIndustrial ResidualsLimits And Monitoring RequirementsPage 59 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointResiduals WCR - Annual Reporting Requirements:Submit an Annual WCR: due 60 calendar daysafter the end ofeach calendar year.PHASE Start Date:PHASE End Date:PHASE:Table III - I - 3: Residuals WCR - Annual Limits and Monitoring RequirementsFinal 08/01/2013ParameterSample Type Monitoring PeriodUnitsSample Point Compliance QuantityJanuary thru December%TSREPORTCompositeSolids, TotalIndustrial ResidualsLimits And Monitoring RequirementsPage 60 of 61Permit No. NJ0005444PER050003 Consolidated Renewal Permit ActionB L ENGLAND GENERATING STATION, Beesleys PointResiduals Transfer Reporting Requirements:Submit an Annual RTR: due 60 calendar daysafter the end ofeach calendar year.Limits And Monitoring RequirementsPage 61 of 61

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

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# 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 Hy drocarbons 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 designate d 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 w ith "NJDEP Field Sampling Procedures Manual",

latest edition) within 30 minutes (or as soon ther eafter 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 precipitatio n 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.

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# ii. "Composite Sample" means a combination of individual (or continuously taken) samples

(aliquots) of at least 100 millilite rs, collected at periodic interv als 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 aliquo t 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, th e 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 coll ected 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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# 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.

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# 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 w ith 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 Repor t parameters shall be conducted concurrently

with the Whole Effluent Toxicity (WET) monitoring, when feasible.

i. Any influent and effluent sampling for toxic pollu tant 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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# 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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# e. The highest ranking official may delegate responsibility to certify the monitoring report forms in

his or her absence. Authorizations for other in dividuals 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 resu lts. 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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# B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

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# 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 a nd 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 Implemen tation 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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# B L ENGLAND GENERATING STATION, Beesleys Point Permit No.NJ0005444

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# 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 toxi city 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 Ch aracterization do not exceed the toxicity limit or

action level.

ii. If two out of any six consecutive, acceptable test s 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 th e chlorine and/or ammonia concentrations are

below the established water quality based effluent limitation for chlorine and/or ammonia, the

permittee shall identify the procedur es to be used in future toxi city 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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# 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 rei ssue any permit to incor porate 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 para meters, 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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# 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 ha s 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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# 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 th e interior surface of the tr ough 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 in formation 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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# 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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# 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 monitori ng 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 stor mwater 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 unp aved 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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# 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 Sedi ment 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 erosio n and sediment transport in these areas.

i. The SPPP shall be pr epared, 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 fac ility 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:

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# i. convert the area(s) to "no discharge" area(s) an d 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 associat ed with industrial activity (e.g. rooftop runoff,

employee parking, open space) from regul ated 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 numbe r (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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# 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 S PPP 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 update d 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 du st emissions from coal handling areas (including

storage area).

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# 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 mi nimized to the best extent practicable. These

particles shall be removed from these areas upon discovery.

d. The discharge of coal particles to the Great E gg 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 deliv ery 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 sh avings, 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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# 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 prev ent 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 Contai nment (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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# 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 contamin ated 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 containe rs 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. Insp ections 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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# 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 an d 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 perm ittee 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 preci pitation 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 stor m 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. 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 cont ained 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 lo cal weather monitoring station(s) or an onsite

maintained monitoring station);

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# 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 subm ittal schedule below:

i. Copies of the SPPP including the DCP shall be subm itted 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 thro ugh 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, Report s, and Recertifications

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# a. The permittee shall conduct annual inspections of the facility in acco rdance 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 th e SPPP complies with and is impl emented 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 comp leted prior to the annual recertification submission date.

d. The annual report shall be retained by the permitt ee 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 y ear beginning from the effective date of the

permit (EDP).

f. The annual report shall be submitted with the a nnual 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 inspectio n 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 prov ided by the Department that the facility has

completed their annual report as specified above and is in compliance with the S PPP 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 perm ittee, 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.

Stormwater Page 23 of 24

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

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 S PPP 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.

Stormwater Page 24 of 24

# 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 (B MP) 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. Preventa tive Maintenance ......................................................................... 5

7. Engineered Treatment Systems ................................................................. 5

VI. Implementation Schedule..................................................................5,6

VII. General Plan Requirements ..................................................................................... 6

A. Certification of Stormwat er 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. Sub mit 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 elemen ts 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 ac tivities 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), Disc harge Cleanup and Removal

(DCR), Preparedness Prevention and Contingency Plan (PPC P, 40 CFR Parts 264 and 265),

the Spill Prevention Control and Countermeasur es (SPCC) requirement s (40 CFR Part 112),

the National Pollutant Discharge Elimination System Toxic Organic Management Plan

(NPDESTOMP, 40 CFR Parts 413, 433, and 469), a nd the Occupational Sa fety and Health

Administration (OSHA) Emergenc y 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 a ppropriate, an invent ory 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 manne r to allow exposure to stormwater; and

**2. List Sources of Water**

Make list of any domestic wast ewater, non-contact cooling wate r, or process waste water

(see definitions in Part IV of permit), that is generated at the facility and discharged through

separate storm sewers (see de finition in Part IV of pe rmit) 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 Na rrative & Mappi**  **ng 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 industria l activity. The permittee shall evaluate the information from

the site assessment phase of this plan to iden tify 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 sha ll develop BMPs that will

effectively eliminate or reduce pollutant loadings in stormwater discharges from the facility

# 3 in accordance with the following sections. Th e 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 activitie s 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 conta minated stormwater to eith er a domestic or industrial

wastewater treatment plant may also be c onsidered when choosin g an appropriate BMP

where feasible. (Diversion to groundwater may require additional Depa rtment approval, or

modification to this permit. Contact the Bur eau 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, cont act 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 di scovery of leaks and spills;

• 

# implement careful material storage practices;

• 

# improve operation and main tenance of industrial m achinery and processes;

• 

# maintain up-to-date material inventory;

• 

# maintain well organized work areas;

• 

# provide regular pickup and dis posal of waste materials;

• 

# maintain dry and clean floors and ground su rfaces by using brooms, shovels, vacuum

cleaners, or cleaning machines; and

• 

# train employees about g ood housekeeping practices.

# 4 **3. Spill Prevention and Response**

Specific spill prevention and response procedures shall be developed. The procedures shall

include material handling, st orage and equipment operation and maintenan ce 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/clea nup 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 material s, 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 ar e recommended to be done weekly.

- Routine inventory of spill clea nup materials and equipment.

**4. Site Stabilizati on 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 opera tions 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 di sturbance 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 a ll outfall structures that are used to convey and discharge

stormwater. Stormwater velocity at the outfalls shall be controlled to prevent

downstream erosion and/or degrad ation and ensure stabilization.

# 5 - 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 cau sed 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 Sta ndard 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 ba sins, 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 ev aluated 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 trea tment. The schedule shall meet

the deadlines established in the permit in accordance with Part IV.

# 6 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 pe rmit, 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, imp lementation, and annua l recertification sha ll 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 busine ss function, or any other person who performs similar policy or

decision making functions for the corpora tion; or the manager of one or more

manufacturing, production, or ope rating facilities, provided:

(1) The manager is authorized to make manage ment 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).

# 7 Whenever there are two or more permittees fo r the facility, all of those permittees shall

jointly submit this Certifica tion, unless permittees received au thorization 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 mu st be made availabl e, upon request, to a

representative of the Department and to the owner and operator of an y 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 confidentia l 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 materi als and industrial areas to ensure that

all elements of the SPPP are in pl ace and working properly. Inspections shall be

conducted by qualified, trained plant personnel. R ecords 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

# 8 Conduct annual inspections as required in Part IV Secti on F of the permit. The

annual inspections are necessary to eval uate the implementa tion of the SPPP for

preparation of the annual re port and annual certifications.

- Annual Reports

The SPPP shall include a method to routinely and continually evaluate the SPPP

for effectiveness, any flaws that may ha ve developed, and ma intenance that may

be required. The routine evaluation must include, but not be limited to:

• 

# Regular and annua l 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 Communi**  **ty 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 Pl an) prepared under 40 CFR 112 and section 311 of the Clean

Water Act, 33 U.S.C.§1321; and any discharge prevention, containmen t and countermeasure

plan (DPCC plan) and discharge cleanup a nd 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 th e SPPP continues to be accurate and to meet th e requirements of Part I

of this permit.