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BAY SHORE POWER PLANTINTAKE AND THERMAL DISCHARGE NPDES COMPLIANCE OPTION EVALUATION1.0 INTRODUCTIONUnder contract EP-C-05-046, Tetra Tech was tasked by USEPA’s Office of Wastewater Management andEPA Region 5 to evaluate data and documentation submitted by FirstEnergy in support of Ohio EPA’songoing efforts to develop appropriate NPDES permit conditions for FirstEnergy’s Bay Shore PowerPlant (BSPP) located near Oregon, OH. This effort focuses on impacts that may occur from cooling waterwithdrawal in the Maumee River estuary and elevated temperature waste discharges to Maumee Bay—two distinct, but related, aspects of the NPDES program.Section 316(b) of the Clean Water Act (CWA) requires facilities to employ the best technology available(BTA) to minimize adverse environmental impact (AEI) from cooling water intakes. Ohio EPA iscurrently in the process of reviewing BSPP’s current cooling water intake structure (CWIS) operationagainst the technology-based standard in the statute and will incorporate any necessary changes orimprovements into a compliance schedule that will be part of the renewed NPDES permit for the facility.The Ohio Administrative Code (OAC) establishes numeric water quality criteria for thermal discharges tostate waters as well as narrative criteria that are designed to protect the designated uses of the receivingwater (OAC Rule 3745-1-07). Mixing zones are permitted for thermal discharges but the discharger mustdemonstrate that certain conditions are met in order to ensure compliance with all applicable criteria aremet (OAC Rule 3745-2-08). Through existing NPDES permit requirements, Ohio EPA has directed BSPPto conduct studies and collect additional data describing the facility’s thermal discharge in order todetermine if the mixing zone’s size should be restricted or whether additional measures must be taken toensure compliance with the appropriate water quality standards.1.1SCOPE OF WORK AND TASK ORDER SUMMARYTasks 1-4 direct Tetra Tech to review the facility’s Proposal for Information Collection (PIC), allimpingement mortality and entrainment (IM/E) sampling data and supporting documentation, and all datarelated to the thermal discharge, including the 2003 Thermal Mixing Zone Study.Task 5 and its subtasks address Section 316(b) requirements and direct Tetra Tech to a) determine if IM/Eestimates are reasonable and representative; b) determine if proposals (if available) for reducing IM/E areadequate and appropriate; c) recommend a level of IM/E reduction representing BTA for this facility; andd) recommend improvements and/or operational changes at the facility that will meet BTA.1Task 6 directs Tetra Tech to develop recommendations, conclusions, and/or suggestions regarding thepossible impact of the thermal discharge and the need to and justification for restricting the size of thethermal mixing zone.1BSPP did not submit detailed information regarding any proposed technologies or operational measures designed to reduceIM/E, except brief mentions of five technology categories proposed for further study in its Proposal for Information Collection(PIC). The PIC does not discuss the evaluation methods to be used or any data already collected or conclusions reached. As such,Tetra Tech did not conduct any determination under Task 5.b.1
FEB 27, 20091.2FINAL REPORTREPORT BASIS AND ORGANIZATIONTetra Tech prepared this final report based on data collected and evaluated by BSPP and its contractors,as well as additional information gathered from other state resource agencies and provided by Ohio EPA.Tetra Tech did not collect any biological or temperature data as part of this effort nor was Tetra Techinvolved in the process that evaluated BSPP’s proposed study plans prior to those activities. Allbiological and temperature data specific to BSPP and discussed in this report were collected at thefacility’s direction with oversight by Ohio EPA and should be cited accordingly. Tetra Tech reviewed theadequacy of all available information and provided a summary to Ohio EPA by memoranda datedSeptember 30, 2008 and December 12, 2008.This final report evaluates the potential efficacy of several technology-based compliance options and theirapplicability at BSPP in the event Ohio EPA determines additional measures are necessary to complywith existing regulations. Options are reviewed according to accepted criteria used by Tetra Tech, USEPA and industry organizations such as EPRI when conducting the same type of evaluation at otherfacilities nationwide. Similar accepted practices are used in those instances where option cost estimatesare also developed, although any estimate must be further refined with more detailed facility informationif the option is selected for implementation.The remainder of this report is organized as follows: Section 2 provides a brief overview of the BSPP facility, its operations and cooling waterwithdrawals.Section 3 discusses the various state and federal regulatory programs that address cooling waterwithdrawal and thermal discharge impacts.Section 4 summarizes data submitted by BSPP and describes how any identified deficienciesaffect the final analysis.Section 5 presents the screening criteria used for this report and analysis results for several widelyused technology-based options.Section 6 provides further detail and cost estimates for an evaporative cooling tower retrofit atBSPP.Appendix A contains a summary table of all options considered.Appendix B provides additional detail on the methods used to develop performance and costestimates for an evaporative cooling tower retrofit.Bay Shore Power Plant Technology Option Analysis2
FEB 27, 2009FINAL REPORT2.0 FACILITY BACKGROUND AND DESCRIPTIONThe Bay Shore Power Station is located on the south shore of Lake Erie near the confluence of theMaumee River and Maumee Bay near the city of Oregon (Figure 1). The facility operates fourconventional steam boiler generating units with a combined nameplate rating of 631 MWe. Unit 1 has acirculating fluidized bed boiler while units 2-4 have either wall or vertical dry bottom boilers. Unit 1 wasretrofitted in 2000 to consume petroleum coke generated at the nearby BP refinery. The remaining threeunits consume coal (Unit 1 is capable of burning coal if necessary) (EIA 2007). All four units areoperated with once through cooling systems, wherein cooling water is withdrawn from a source, passedthrough a surface condenser to remove waste heat, and discharged to a receiving water.BSPP operates as a baseload facility, which means it generates electricity for delivery to the grid more orless continuously for extended periods in order to meet minimum electrical demand. Baseload facilitiesmay be inactive for normal maintenance periods or when electrical demand is low but generally operateyear-round. Figure 2 shows the 3-year (2005-2007) monthly and cumulative average gross load for eachunit expressed as a percentage of each unit’s nameplate capacity. The facility-wide average gross load forthe time period is 83% of BSPP’s total capacity (USEPA 2007).Figure 1. Facility LocationBay Shore Power Plant Technology Option Analysis3
FEB 27, 2009FINAL REPORT120%Unit 1Unit 3Unit 2Unit 4Capacity pOctNovDec3-yearAvgFigure 2. 2005-2007 Average Gross LoadBSPP operates one common CWIS to provide cooling water to each unit. Water is withdrawn from theMaumee River estuary via an intake canal extending 3,700 feet southeast to the facility, where the canaldivides to nine individual intake bays. Each bay consists of bar racks that prevent larger debris fromentering the cooling system and a vertical traveling screen fitted with 3/8-inch mesh panels to screensmaller debris. Screen #4 operates only 15 minutes per day while screen #7 operates for 30 minutesduring each 12-hour shift (Kinetrics 2008). Operating information for the other screens is not availablebut presumed to include periodic rotations to remove accumulated items. Screens are washed during arotation cycle with a high pressure (50 psi) spray that removes any impinged debris, including fish, whichis then discharged to a common sluiceway that empties into Maumee Bay (Figure 3). The design throughscreen velocity is estimated at 2.58 fps (FirstEnergy 2004).Each unit is served by two circulating water pumps, each with the capacity of 64,000 gpm, or 92 mgd, fora facility total of 512,000 gpm, or 737 mgd.2, 3 Cooling water is drawn through a single pass surfacecondenser fitted with 90-10 copper-nickel tubes and combined with other in-plant wastes before finaldischarge to Maumee Bay through one of three permitted outfalls. This section of Maumee Bay is2Information submitted in the PIC lists the combined intake capacity at 810 mgd while other reports identify maximum intakevolumes of 745 mgd. The difference between the reported circulating pump capacity and actual withdrawal rates (see Kinetrics2008, Table 4.1) may reflect additional volumes from service water or condensate pumps used for purposes indirectly related tosteam condensation. Tetra Tech notes that the surface condenser capacity (128,000 gpm) is equal to each unit’s total circulatingpump capacity3Information provided by BSPP describing the surface condensers (“Knowledge Requirement Answers for Circulating WaterSystems”) does not specify the corresponding generating unit or whether all units share the same pump and condenserspecifications. Without additional information, Tetra Tech assumed the specifications were applicable to all units.Bay Shore Power Plant Technology Option Analysis4
FEB 27, 2009FINAL REPORTcurrently designated for the following uses: exceptional warm water habitat (EWH), state resource water(SRW), agricultural supply water, public water supply, industrial water supply, and bathing waters.4Figure 3. Intake and Discharge Locations3.0 FEDERAL AND STATE REGULATORY REQUIREMENTS3.1COOLING WATER WITHDRAWALSCWA Section 316(b) establishes a statutory requirement that CWIS location, design, capacity andconstruction reflect the best technology available for minimizing adverse environmental impact.Authority for implementing Section 316(b) resides with EPA and is addressed through the issuance ofNational Pollutant Discharge Elimination System (NPDES) permits. States may assume thisresponsibility if they implement an approved permitting program. Ohio was granted this authority in1974.In 1976 USEPA published a final rule implementing Section 316(b). Following a lawsuit filed by a groupof utility companies, the Court of Appeals for the Fourth Circuit remanded the rule citing EPA’s failure tocomply with the Administrative Procedures Act by not properly publicizing the rule’s supportingdocumentation. USEPA later withdrew most of the final rule, although a draft guidance documentdeveloped during the rulemaking—Guidance for Evaluating the Adverse Impact of Cooling Water IntakeStructures on the Aquatic Environment: Section 316(b) [“1977 USEPA Guidance”]—was released andserved as the basis for implementing Section 316(b) using best professional judgment (BPJ).After entering into a consent decree with plaintiffs who challenged the lack of national technology-basedstandards, USEPA began developing section 316(b) implementing regulations in three phases. The PhaseI rule, applicable to new steam electric facilities—was issued in 2001. The Phase II rule was adopted in4NPDES Fact Sheet OEPA Permit 21B00000*QD.Bay Shore Power Plant Technology Option Analysis5
FEB 27, 2009FINAL REPORT2004 and was to apply to most existing steam electric facilities, including BSPP. Following a courtchallenge, however, USEPA effectively suspended the Phase II rule on March 20, 2007 and directedpermitting authorities to continue implementing section 316(b) statutory requirements on a BPJ basis(Grumbles 2007).BSPP’s previous permit was developed and issued during the interim period between the adoption of thePhase II rule in 2004 and its suspension in 2007. At the time, Phase II compliance was based on a multiyear process that involved the collection and submittal of various source water and biologicalcharacterization data, which might include new IM/E sampling efforts, as well as a plan of study forevaluating proposed compliance methods. The first step, the Proposal for Information Collection (PIC),would serve as an outline and study plan for any activities the facility would conduct prior to a finaldetermination of BTA and the different methods it proposes to evaluate as possible compliance options.The facility would then prepare a Comprehensive Demonstration Study (CDS) that evaluated the efficacyof any existing IM/E reduction measures and any additional measures that would be necessary to complywith the Phase II performance standards. BSPP submitted its PIC in 2004 and conducted impingementsampling, survival studies, and entrainment sampling over a 15-month period during 2005 and 2006. Afinal CDS was not prepared in light of USEPA’s suspension of the Phase II rule.3.1.1 DETERMINING ADVERSE ENVIRONMENTAL IMPACTIn 1978 Ohio EPA published Guidelines for the Submittal of Demonstrations Pursuant to Sections 316(a)and 316(b) of the Clean Water Act and Chapter 3745-1 of the Ohio Administrative Code [“Ohio 316Guidelines”] that outlined policy procedures and objectives addressing both thermal and intake impacts.Specific to IM/E, the document states that the “primary objective of any 316(b) evaluation should be todetermine if an existing or proposed cooling water intake structure minimizes adverse environmentalimpact” (OEPA 1978, p. 45).Similar to the approach in the 1977 USEPA Guidance, Ohio EPA defines AEI as “damage that occurswhenever there is entrainment or impingement of aquatic organisms as a result of the operation of aCWIS” (OEPA 1978, p. 36) and provides guidance for determining whether the damage is acceptable byconsidering1. the number of organisms entrained and impinged.2. the percentage of each representative species lost due to entrainment and impingement damage.3. the magnitude of damage to endangered species, or to commercially, recreationally, orecologically valuable species.4. whether the observed IM/E damage contributes to community unbalance.Ultimately, IM/E impacts are considered unacceptable “if the maintenance of existing balancedcommunities or the recovery of perturbed or unbalanced communities are impaired or prohibited, or themagnitude of damage to endangered, commercial, sport, and/or ecologically valuable species interfereswith an existing or planned use of the source water body” (OEPA 1978, p. 37).3.1.2 QUALIFYING AND QUANTIFYING INTAKE DAMAGEFurthermore, the Ohio 316 Guidelines provide instruction on what factors should be considered whenattempting to quantify the level of impact that may be occurring and place it within the appropriateBay Shore Power Plant Technology Option Analysis6
FEB 27, 2009FINAL REPORTcontext. Facilities that withdraw cooling water from surface waters are classified as either high risk or lowrisk based on several possible characteristics, including the source water designation and intake capacity.BSPP, which withdraws water from the Maumee River estuary, is automatically considered a “high risk”facility regardless of its intake capacity because it is located on a Lake Erie estuary (OEPA 1978, p. 38no. 4).A facility’s risk classification does not equate to more or less stringent criteria for determining BTA.Rather, the guidelines direct Ohio EPA and the facility to a conduct all data collection and analyses usingan increasing level of preciseness and sophistication that corresponds to a facility’s level of risk.Specifically, “the precision with which [intake damage] assessments and evaluations are made shouldincrease proportionally with risk” (OEPA 1978, p. 47) and should1. Estimate the numbers (with accompanying confidence limits) of fishes impinged and eggs andlarvae entrained (by species) during each year of sampling.2. Estimate the percent of each representative fish species population lost due to entrainment andimpingement mortality (applicable to high risk intakes).3. Evaluate the significance of the estimated losses to the representative fish species populations andexisting fisheries in the source water body.3.2THERMAL DISCHARGESBSPP is classified as point source discharge (and subject to NPDES permitting requirements) with athermal component to its discharge. As such, BSPP is subject to both technology- and water quality-basedeffluent limitations pursuant to CWA Sections 301 and 306, including those established for temperature.OAC Rule 3745-1-07 contains water quality standards and numeric criteria for temperature applicable todischarges to Maumee Bay, while OAC Rule 3745-1-04 contains general narrative criteria prohibiting, toevery extent practical and possible, discharges that cause nuisance conditions in surface waters, includingmixing zones. OAC Rule 3745-2-08(c) lists various sizing and demonstration requirements for thepurpose of establishing a mixing zone, subject to Ohio EPA’s review.Ohio EPA’s Section 316 Guidelines provide further information for establishing the appropriate thermaleffluent limitation and determining the mixing zone’s size. When a thermal mixing zone applies to afacility’s discharge, temperature limitations are expressed in terms of the net plant heat rejection rate(BTU/hr) rather than through an areal or volumetric description. For an existing thermal mixing zone, thereview process evaluates the effects that the zone’s total size has on the populations and communities ofthe receiving water body (OEPA 1978, p.28) and is based on1. Site-specific biological, chemical, and physical information provided by the applicant.2. Temperature standards or other temperature criteria applicable to the receiving water body.3. Demonstration that the mixing zone will assure protection and propagation of a balancedindigenous community.The current permit for BSPP (21B00000*QD) was issued on June 29, 2007 and expired on January 31,2009. Permit conditions require FirstEnergy to conduct a thermal mixing zone benthic survey tosupplement information provided in the 2003 Thermal Mixing Zone study. The survey includes samplingfor 2 years from 2008 through 2009. The most recent progress report, including a summary of thesampling results, was submitted to OEPA on December 31, 2008.Bay Shore Power Plant Technology Option Analysis7
FEB 27, 2009FINAL REPORT4.0 DATA SUMMARY, PERFORMANCE AND LIMITATIONSThe studies and data submitted by BSPP in support of thermal mixing zone and cooling water intakeimpacts reflect ongoing permit compliance efforts dating back several years, with study plans for IM/Esampling and thermal plume modeling having been previously approved by Ohio EPA. BSPP hassubmitted interim reports updating Ohio EPA staff on its activities and preliminary data thus allowing forcontinued input from staff on the direction of future activities.Tetra Tech conducted an initial review of the information set and submitted its initial findings to OhioEPA on 9/30/2008, which were then forwarded to FirstEnergy with a request to provide additionalinformation. Tetra Tech reviewed FirstEnergy’s response and additional data provided by Ohio EPA andsubmitted a follow up review on 12/18/2008. These memoranda provide a more detailed discussion ofTetra Tech’s review.Tetra Tech identified several critical missing elements to various reports, particularly the 2003 ThermalMixing Zone Study, and suggested additional data for collection to augment any final BAT/BTAdeterminations made for BSPP.5 A brief summary and a discussion of how any deficiencies affect theoverall analysis is provided below.4.1IMPINGEMENT AND ENTRAINMENTTetra Tech reviewed data provided by BSPP from its 2005-2006 sampling effort. These data provide thebasis for BSPP’s estimates of the annual numbers of fish impinged on the facility’s intake screens and thenumbe
1 BAY SHORE POWER PLANT INTAKE AND THERMAL DISCHARGE NPDES COMPLIANCE OPTION EVALUATION 1.0 INTRODUCTION Under contract EP-C-05-046, Tetra Tech was tasked by USEPA’s Office of Wastewater Management and EPA Region 5 to evaluate data and documentation submitted by First
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