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Septehiber \&&7
            Profile Of The
            Fossil Fuel Electric Power
            Generation Industry
          «c *
NOTEBOOKS
            EFA Office Of Compliance Sector Notebook Project

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               WASHINGTON, D.C. 20460
                                          f8 1997
                                                                         THE ADMINISTRATOR

Message from the Administrator

Since EPA's founding over 25 years ago, our nation has made tremendous progress in protecting
public health and our environment while promoting economic prosperity. Businesses as large as
iron and steel plants and those as small as the dry cleaner on the corner have worked with EPA to
find ways to operate cleaner, cheaper and smarter.  As a result, we no longer have rivers catching
fire. Our skies are clearer. American environmental technology and expertise are in demand
around the world.

The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.

The Environmental Protection Agency has undertaken its Sector Notebook Project to compile,
for major industries, information about environmental problems and solutions, case studies and
tips about complying with regulations. We called on industry leaders, state regulators, and EPA
staff with many years of experience in these industries and with their unique environmental issues.
Together with an extensive series covering other industries, the notebook you hold in your hand is
the result.

These notebooks will help business managers to understand better their regulatory requirements,
and learn more  about how others in their industry have achieved regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful  information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.

I encourage you to use this notebook to evaluate and improve the way that we together achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — in industry after industry, community  after community ~
environmental protection and economic prosperity go haj^in hand.
                                                Carol M. Browner
            R«cycl*d/R*cyclib!« • Printed with Vegetable OH Based Inks on 100% Recycled Paper (40% Postconsumer)

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Fossil Fuel Electric Power Generation
Sector Notebook Project
                                                                 EPA/310-R-97-007
              EPA Office of Compliance Sector Notebook Project

     Profile of the Fossil Fuel Electric Power Generation Industry
                                  September 1997
                                Office of Compliance
                    Office of Enforcement and Compliance Assurance
                        U.S. Environmental Protection Agency
                             401 M St., SW (MC 2223-A)
                               Washington, DC 20460
                            For sale by the U.S. Government Printing Office
                     Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
                                ISBN 0-16-049399-4
Sector Notebook Project
        September 1997

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Fossil Fuel Electric Power Generation
Sector Notebook Project
This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors. The documents were developed under contract by Abt Associates
(Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-
Allen & Hamilton, Inc. (McLean, VA). This publication may be purchased from the
Superintendent of Documents, U.S. Government Printing Office. A listing of available Sector
Notebooks and document numbers is included at the end of this document.

All telephone orders should be directed to:

       Superintendent of Documents
       U.S. Government Printing Office
       Washington, DC 20402
       (202)512-1800
       FAX (202) 512-2250
       8:00 a.m. to 4:30 p.m., EST, M-F
Using the form provided at the end of this document, all mail orders should be directed to:

       U.S. Government Printing Office
       P.O. Box 371954
       Pittsburgh, PA  15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and
academic libraries, Federal, State, and local governments, and the media from EPA's National
Center for Environmental Publications and Information at (800) 490-9198. For further
information, and for answers to questions pertaining to these documents, please refer to the
contact names and numbers provided within this volume.
Electronic versions of all Sector Notebooks are available via Internet on the Enviro$en$e World
Wide Web. Downloading procedures are described in Appendix A of this document.
Cover photograph courtesy of Arizona Electric Power Cooperative, Inc.
Sector Notebook Project
        September 1997

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 Fossil Fuel Electric Power Generation
                                                   Sector Notebook Project
                               Sector Notebook Contacts
 The Sector Notebooks were developed by the EPA's Office of Compliance. Questions relating
 to the Sector Notebook Project can be directed to:

 Seth Heminway, Coordinator, Sector Notebook Project
 US EPA Office of Compliance
 401 M St., SW (2223-A)
 Washington, DC 20460
 (202) 564-7017

 Questions and comments regarding the individual documents can be directed to the appropriate
 specialists listed below.
Document Number
EPA/310-R
EPA/310-R
EPA/310-R
EPA/310-R
EPA/310-R
EPA/310-R
EPA/310-R
EPA/310-R
EPA/310-R-
EPA/310-R
EPA/310-R
EPA/310-R
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R
EPA/310-R-
EPA/310-R-

EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R-
EPA/310-R-
-95-001.
-95-002.
-95-003.
-95-004.
-95-005.
-95-006.
-95-007.
-95-008.
-95-009.
-95-010.
-95-011.
-95-012.
-95-013.
-95-014.
-95-015.
•95-016.
-95-017.
-95-018.

•97-001.
•97-002.
•97-003.
•97-004.
•97-005.
•97-006.
97-007.
•97-008.
97-009.
97-010.
           Industry

Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Ind.
Transportation Equip. Cleaning Ind.

Air Transportation Industry
Ground Transportation Industry
Water Transportation Industry
Metal Casting Industry
Pharmaceuticals Industry
Plastic Resin and Manmade Fiber Ind.
Fossil Fuel Elec. Power Generation Ind.
Shipbuilding and Repair Industry
Textile Industry
Sector Notebook Data Refresh, 1997
   Contact

Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Anthony Raia
Anthony Raia
Jane Engert
Anthony Raia
Walter DeRieux
Tom Ripp
Ginger Gotiiffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop

Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
Phone (202)

   564-7073
   564-7007
   564-7021
   564-7067
   564-7027
   564-7017
   564-7013
   564-6045
   564-6045
   564-5021
   564-6045
   564-7067
   564-7003
   564-7072
   564-7016
   564-7027
   564-7013
   564-7057

   564-7057
   564-7057
   564-7057
   564-5021
   564-7071
   564-7074
   564-7028
   564-6045
   564-7022
   564-7017
Sector Notebook Project
                                                           September 1997

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Fossil Fuel Electric Power Generation
Sector Notebook Project
                          [This page intentionally left blank.]
 Sector Notebook Project
         September 1997

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Fossil Fuel Electric Power Generation
Sector Notebook Project
      FOSSIL FUEL ELECTRIC POWER GENERATION INDUSTRY
                               (SIC 4911, 493)
                           TABLE OF CONTENTS

LIST OF TABLES	iv

LIST OF FIGURES	vi

LIST OF ABBREVIATIONS AND ACRONYMS	  vii

I.     INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	1
      A. Summary of the Sector Notebook Project	1
      B. Additional Information	2

II.    INTRODUCTION TO THE FOSSIL FUEL ELECTRIC POWER GENERATION
      INDUSTRY	3
      A. Introduction, Background, and Scope of the Notebook	3
      B. Characterization of the Fossil Fuel Electric Power Generation Industry	4
            1. Product Characterization	5
            2. Industry Size and Geographic Distribution of the Fossil Fuel Electric Power
                  Generation Industry	5
            3. Industry Size and Geographic Distribution of Traditional Utilities	7
            4. Industry Size and Geographic Distribution of Nonutilities  	13
            5. Economic Trends  	;	19

III.    INDUSTRIAL PROCESS DESCRIPTION  	23
      A. Industrial Processes in the Fossil Fuel Electric Generation Industry	23
            1. Steam Turbine Generation	23
            2. Internal Combustion Generation	32
            3. Gas Turbine Generation 	33
            4. Combined-Cycle Generation  	34
            5. Cogeneration	 35
            6. Supporting Operations  	36
      B. Raw Material Inputs and Pollution Outputs  	38
            1. Fossil Fuels and Other Raw Material Inputs	38
            2. Pollutant Outputs  	40
Sector Notebook Project
       September 1997

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Fossil Fuel Electric Power Generation
                   Sector Notebook Project
IV.   WASTE RELEASE PROFILE  	47
      A. Available Solid Waste Release Data for the Fossil Fuel Electric Power Generation
             Industry	47
      B.  Available Water Release Information for the Fossil Fuel Electric Power
             Generation Industry	51
      C. Available Air Emissions Data for the Fossil Fuel Electric Power Generation
                   Industry 	53
             1. Annual Emissions Estimated by the Department of Energy,
                   Energy Information Administration 	53
             2. AIRS Database Annual Estimated Releases for the Electric
                   Power Generation Industry 	54
             3. Hazardous Air Pollutant Emissions Estimates for Fossil Fuel Electric Utility
                   Steam Generating Units	56

V.    POLLUTION PREVENTION OPPORTUNITIES	71
      A. Pollution Prevention Technologies in the DOE Clean Coal Technology
             Demonstration Program	72
             1. Emerging Technologies  	72
             2. Coal Processing for Clean Fuels	76
      B. Other Pollution Prevention Technologies 	77
      C. Other Pollution Prevention and Waste Minimization Opportunities	79
             1. Process  or Equipment Modification Options  	79
             2. Inventory Management and Preventative Maintenance for
                   Waste Minimization	85
             3. Potential Waste Segregation and Separation Options	86
             4. Recycling Options	87
             5. Facility  Maintenance Wastes 	89
             6. Storm Water Management Practices	92
             7. Training and Supervision Options 	94
             8. Demand-Side Management Programs  	94

VI.   SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS .... 95
      A. General Description of Major Statutes 	95
      B. Industry-Specific Requirements  	106
      C. Pending and Proposed Regulatory Requirements 	116

VH.   COMPLIANCE AND ENFORCEMENT HISTORY	 119
      A. Fossil Fuel Electric Power Generation Industry Compliance History	 123
      B. Comparison of Enforcement Activity Between Selected Industries	 125
      C. Review of Major Legal Actions	 130
             1. Review  of Major Cases	 130
             2. Supplemental Environmental Projects  	131
Sector Notebook Project
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September 1997

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Fossil Fuel Electric Power Generation
                                                 Sector Notebook Project
VIII.  COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES	133
      A. Sector-Related Environmental Programs and Activities	133
      B. EPA Voluntary Programs	134
      C. Trade Association/Industry Sponsored Activity 	137
            1. Environmental Programs	138
            2. Summary of Trade Associations	138
IX.
CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/
BIBLIOGRAPHY	
                                                                        143
APPENDIX A - INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK  	 A-l
Sector Notebook Project
                               m
September 1997

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Fossil Fuel Electric Power Generation
                    Sector Notebook Project
                                LIST OF TABLES

Table 1:      Comparison of Utility and Nonutility Electric Power Generation (1995)	6
Table 2:      Revenues From Major Utility Generators (1995)  	9
Table 3:      Top Ten Investor-Owned Utilities Ranked by Revenue From Sales to
             Ultimate Consumers (1995)	9
Table 4:      Top Ten Publicly Owned Generator Utilities Ranked by Megawatt Sales
             to Ultimate Consumers (1994)	10
Table 5:      Existing Capacity of All U.S. Utilities by Prime Mover (fossil fuels,
             renewable fuels, and other fuels) (1995)	12
Table 6:      Fossil-Fueled Utility Capacity by Prime Mover (1995) 	.12
Table 7:      Utility Generating Capability and Net Generation by Energy Source (1995) ... 13
Table 8:      Major SIC Codes and Industrial Categories Where Nonutility Power
             Generation Activities Are Found	16
Table 9 :     Existing Capacity of Nonutilities by Prime Mover (1995) 	18
Table 10:     Nonutility Capacity by Fossil Fuel Energy Source (1995)	18
Table 11:     1995 Nonutility Net Generation by Primary Fossil Fuel Energy Source and
             Type of Producer (thousand megawatthours)  	19
Table 12:     Characteristics of Various Types of Stokers	26
Table 13:     Summary of Typical Waste Streams and Pollutants Generated at Fossil
             Fuel Electric Power Generation Facilities Based on Fuel Type  	43
Table 14:     Generation and Disposition of Utility Fly and Bottom Ash, 1994 (thousand
             short tons)	48
Table 15:     Generation and Disposition of Utility FGD  Sludge, 1994 (thousand short
             tons)	49
Table 16:     Estimated Nonutility Generation of Coal Ash, 1990	50
Table 17:     List of Pollutants Reported in 1992 PCS Data from Steam Electric Facilities .. 52
Table 18:     Estimated 1995 Emissions From Fossil Fuel Steam Electric Generating
             Units  at Electric Utilities by Fuel Type (thousand short tons)	53
Table 19:     Criteria Pollutant Releases (short tons/year)	55
Table 20:     Estimated Releases of TRI Chemicals	58
Table 21:     Median Emission Factors Determined From Test Report Data, and Total
             1990 and 2010 HAP Emissions, Projected With the Emission Factor
             Program for Inorganic HAPs From Coal-Fired Units	61
Table 22:     Median Emission Factors Determined From Test Report Data, and Total
             1990 and 2010 HAP Emissions, Projected With the Emission Factor Program
             for Inorganic HAPs From Oil-Fired Units	62
Table 23:     Median Emission Factors Determined From Test Report Data, and Total
             1990 and 2010 HAP Emissions, Projected With the Emission Factor Program
             for Inorganic HAPs From Gas-Fired Units	 63
Table 24:     Median Emission Factors From Test Report Data, and Total 1990 and 2010
             HAP Emissions, Projected With the Emission Factor Program for Organic
             HAPs From Coal-Fired Units  	64
Sector Notebook Project
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September 1997

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Fossil Fuel Electric Power Generation
Sector Notebook Project
Table 25:     Median Emission Factors from Test Report Data, and Total 1990 and 2010
             HAP Emissions, Projected with the Emission Factor Program for Organic
             HAPs from Oil Fired Units  	68
Table 26:     Median Emission Factors From Test Report Data, and Total 1990 and 2010
             HAP Emissions, Projected With the Emission Factor Program for Organic
             HAPs From Gas-Fired Units	70
Table 27:     Summaries of Clean Coal Technologies Under DOE's Clean Coal
             Technology Demonstration Program	73
Table 28:     Pollution Prevention Opportunities for Reducing Cooling Tower Emissions ... 81
Table 29:     Pollution Prevention Options for Fireside Washes 	82
Table 30:     Pollution Prevention Options for Boiler Cleaning Wastes  	85
Table 31:     Inventory Management and Preventative Maintenance Waste Minimization
             Opportunities	87
Table 32:     Current and Potential Uses for Fly Ash	88
Table 33:     Pollution Prevention Opportunities For Facility Maintenance Wastes	91
Table 34:     Common Pollution Prevention Practices for Managing Runoff at Coal
             Storage and Handling Areas 	92
Table 35:     Storm Water Pollution Prevention Opportunities at Fossil Fuel Electric
             Power Generation Facilities  	93
Table 36:     New Source Performance Standards	109
Table 37:     Waste Streams and Pollutants Regulated Under National Effluent Limitation
             Guidelines for the Steam Electric Generating Point Source Category 	113
Table 38:     Five-Year Enforcement and Compliance Summary for the Fossil Fuel
             Electric Power Generation Industry	124
Table 39:     One-Year Enforcement and Compliance Summary for Selected Industries  ... 126
Table 40:     Five-Year Enforcement and Compliance Summary for Selected Industries  ... 127
Table 41:     Five-Year Inspection and Enforcement Summary by Statute for Selected
             Industries	128
Table 42:     One-Year Inspection and Enforcement Summary by Statute for Selected
             Industries	129
Table 43:     List of Power Plants That Participated in the Environmental Leadership
             Program For 1995 and 1996  	135
Sector Notebook Project
        September 1997

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Fossil Fuel Electric Power Generation
                     Sector Notebook Project
                                 LIST OF FIGURES

Figure 1:  Total Utility and Nonutility Electric Power Net Generation Based on Fuels (1995)  . 7
Figure 2:  Total Utility Electricity Sales to Ultimate Consumers  	8
Figure 3:  Geographic Distribution of U.S. Utility Electric Power Net Generation	11
Figure 4:  Nonutility Capacity by Type of Producer	15
Figure 5:  Geographic Distribution of U.S. Nonutility Electric Power Net Generation	17
Figure 6:  Steam Turbine Generation	25
Figure 7:  Stoker Coal Feeder	27
Figure 8:  Typical Cyclone Coal Burners	28
Figure 9:  Tangential Firing Pattern	29
Figure 10: Flow Pattern of Horizontal Firing	30
Figure 11: Flow Pattern of Arch Firing	31
Figure 12: Typical Bubbling Fluidized-Bed Boiler	32
Figure 13: Simple Gas Turbine Cycle	33
Figure 14: Combined Cycle with Heat Recovery	34
Figure 15: Cogeneration Plant Schematic	36
Figure 16: Waste Streams Generated at a Typical Fossil Fuel Electric Power Generation
          Plant	44
Sector Notebook Project
VI
September 1997

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Fossil Fuel Electric Power Generation
                    Sector Notebook Project
               LIST OF ABBREVIATIONS AND ACRONYMS

ACAA   American Coal Ash Association
AEE     Association of Energy Engineers
AEPCO  Arizona Electric Power Cooperative
AFS     AIRS Facility Subsystem (CAA database)
AIRS    Aerometric Information Retrieval System (CAA database)
APPA    American Public Power Association
ANL     Argonne National Laboratory
B ACT    Best Available Control Technology
BIFs     Boilers and Industrial Furnaces (RCRA)
BOD     Biochemical Oxygen Demand
BPJ      Best Professional Judgment
BTU     British Thermal Unit
CAA     Clean Air Act
CAAA   Clean Air Act Amendments of 1990
CaCl2    Calcium Chloride
C API    Clean Air Power Initiative
CCGT    Combined-Cycle Gas Turbine
CCP     Coal Combustion Product
CCT     Clean Coal Technology Demonstration Project (DOE)
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERCLIS CERCLA Information System
CEQ     Council for Environmental Quality
CFC     Chlorofluorocarbon
CHIEFs  Clearing House of Inventory Emissions Factors
CO      Carbon Monoxide
CO2      Carbon Dioxide
COD     Chemical Oxygen Demand
CP&L    Carolina Power and Light
CSI      Common Sense Initiative
CWA    Clean Water Act
D&B     Dun and Bradstreet Marketing Index
DOE     Department of Energy
DSA     Dimensionally stable
DSM     Demand Side Management
EA      Environmental Assessment
EDS     Effluent Data Statistics System
EEI      Edison Electric Institute
EIA      Energy Information Administration (DOE)
EIS      Environmental Impact Statement
ELP     Environmental Leadership Program
EMS     Environmental Management System
Sector Notebook Project
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September 1997

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Fossil Fuel Electric Power Generation
                    Sector Notebook Project
EPA     U.S. Environmental Protection Agency
EPACT  Energy Policy Act of 1992
EPCRA  Emergency Planning and Community Right-to-Know Act
EPRI     Electric Power Research Institute
EPSA    Electric Power Supply Association
EWG     Exempt Wholesale Generators
FAC     Free Available Chlorine
FBC     Fluidized Bed Combustion
FERC    Federal Energy Regulatory Commission
FGD     Flue Gas Desulfurization
FIFRA   Federal Insecticide, Fungicide, and Rodenticide Act
FINDS   Facility Indexing System
FONSI   Finding of No Significant Impact
HAPs    Hazardous Air Pollutants (CAA)
HCFC    Hydrochloroflourocarbon
HSDB    Hazardous Substances Data Bank
HSWA   Hazardous and Solid Waste Amendments of 1984
IDEA    Integrated Data for Enforcement Analysis
ICCR    Industrial Combustion Coordinated Rulemaking
IGCC    Integrated Coal Gasification Combined-cycle
IPP      Independent Power Producer
KW     Kilowatt
LAER    Lowest Achievable Emissions P.ate
LDR     Land Disposal Restrictions (RCRA)
LEPC    Local Emergency Planning Committee
MACT   Maximum Achievable Control Technology (CAA)
MCL     Maximum Contaminant Level
MCLG   Maximum Contaminant Level Goal
MEK     Methyl Ethyl Ketone
MSDS    Material Safety Data Sheet
MW     Megawatt
NAAQS  National Ambient Air Quality Standards (CAA)
NAFCOG North American Fuel Cell Owner Group
NAFTA  North American Free Trade Agreement
NAICS   North American Industry Classification System
NCDB   National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP     National Oil and Hazardous Substances Pollution Contingency Plan
NEPA    National Environmental Policy Act
NERC    North American Reliability Council
NEIC    National Enforcement Investigation Center
NESHAP National Emission Standards for Hazardous Air Pollutants
NGFC    Natural Gas Fuel Cell
NMHC   Non-Methane Hydrocarbon
NO2     Nitrogen Dioxide
NOV     Notice of Violation
Sector Notebook Project
vm
September 1997

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Fossil Fuel Electric Power Generation
                    Sector Notebook Project
NOX      Nitrogen Oxide
NPDES   National Pollutant Discharge Elimination System (CWA)
NPL      National Priorities List
NRECA   National Rural Electric Cooperative Association
NRC      National Response Center
NSR      New Source Review
NSPS     New Source Performance Standards (CAA)
OAR      Office of Air and Radiation
OAQPS   Office of Air Quality Planning and Standards
OEC A    Office of Enforcement and Compliance Assurance
OIT      Office of Industrial Technology (DOE)
OPA      Oil Pollution Act
OPPTS   Office of Prevention, Pesticides, and Toxic Substances
OSHA    Occupational Safety and Health Administration
OSW     Office of Solid Waste
OSWER   Office of Solid Waste and Emergency Response
OTAG    Ozone Transport Assessment Group
OW      Office of Water
P2        Pollution Prevention
PAH      Polycyclic Aromatic Hydrocarbon
Pb        Lead
PCB      Polychlorinated Biphenyl
PCS      Permit Compliance System (CWA Database)
PEPCO   Potomac Electric Power Company
PETC     Pittsburgh Energy Technology Center
PM       Particulate Matter
PMN      Premanufacture Notice
POTW    Publicly Owned Treatment Works
PSD      Prevention of Significant Deterioration (CAA)
PSES     Pretreatment Standards for Existing Sources
PSNS     Pretreatment Standards for New Sources
PSE&G   Public Service Electric and Gas
PT        Total Particulate Emissions
PUHCA   Public Utility Holding Company Act
PURPA   Public Utility Regulatory Policies Act
QF        Qualifying Facility (PURPA)
RACT    Reasonably Achievable Control Technology
RCRA    Resource Conservation and Recovery Act
RCRIS    RCRA Information System
RDF      Refuse Derived Fuel
SARA    Superfund Amendments and Reauthorization Act
SDWA   Safe Drinking Water Act
SEP      Supplementary Environmental Project
SERC     State Emergency Response Commission
SIC      Standard Industrial Classification
Sector Notebook Project
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September 1997

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Fossil Fuel Electric Power Generation
                    Sector Notebook Project
SIP       State Implementation Plan (CAA)
SO2       Sulfur Dioxide
SOX       Sulfur Oxides
TCRIS    Toxic Chemical Release Inventory System
TDSS     Total Dissolved Suspended Solids
TOC      Total Organic Carbon
TRC      Total Residual Chlorine
TRI       Toxic Release Inventory
TRIS      Toxic Release Inventory System
TSCA     Toxic Substances Control Act
TSDF     Treatment, Storage, or Disposal Facility (RCRA)
TSS       Total Suspended Solids
UARG    Utility Air Regulatory Group
UIC       Underground Injection Control (SDWA)
UST      Underground Storage Tanks (RCRA)
USWAG  Utility Solid Waste Activities Group
UWAG   Utility Water Act Group
VOC      Volatile Organic Compound
Sector Notebook Project
x
September 1997

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Fossil Fuel Electric Power Generation
Section I. Intro, to the Sector Notebook Project
            FOSSIL FUEL ELECTRIC POWER GENERATION INDUSTRY
                                    (SIC 4911,493)

I.         INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

LA.      Summary of the Sector Notebook Project

                    Integrated environmental policies based upon comprehensive analysis of air,
                    water, and land pollution are a logical supplement to traditional single-media
                    approaches to environmental protection.  Environmental regulatory agencies
                    are beginning to embrace comprehensive, multi-statute solutions to facility
                    permitting,  enforcement and compliance assurance, education/outreach,
                    research, and regulatory development issues. The central concepts driving
                    the new policy direction are that pollutant releases to each environmental
                    medium (i.e., air, water, and land) affect each other and that environmental
                    strategies must actively identify and address these inter-relationships by
                    designing policies for the "whole" facility.  One way to achieve  a whole
                    facility focus is  to design environmental policies for similar industrial
                    facilities.  By doing so, environmental concerns that are common to the
                    manufacturing of similar products can be addressed in a comprehensive
                    manner.  Recognition of the need to develop the industrial "sector-based"
                    approach within the U.S. Environmental Protection Agency (EPA) Office of
                    Compliance led to the creation of this document.

                    The  Sector Notebook Project was originally initiated by the Office  of
                    Compliance within the Office of Enforcement and Compliance Assurance
                    (OECA) to provide its staff and managers with summary information for 18
                    specific industrial  sectors. As other EPA offices,  states, the regulated
                    community, environmental groups, and the public became interested in this
                    project, the scope of the original project was expanded to its current form.
                    The  ability to design comprehensive,  common sense  environmental
                    protection measures for specific industries depends on knowledge of several
                    interrelated topics. For the purposes of this project, the key elements chosen
                    for inclusion are general industry information (economic and geographic); a
                    description of industrial processes; pollution outputs; pollution prevention
                    opportunities; Federal statutory and regulatory  framework;  compliance
                    history; and a description of partnerships that have been formed between
                    regulatory agencies, the regulated community, and the public.

                    For any given industry, each topic listed above could alone be the subject of
                    a lengthy volume. However,  in order to produce a manageable document,
                    however, this project focuses on providing summary information for  each
                    topic.  This format provides the reader with a synopsis of each issue and
                    references where more in-depth information is available. Text within  each
                    profile was researched from a variety of sources and was usually condensed
Sector Notebook Project
 1
September 1997

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Fossil Fuel Electric Power Generation
                                Section I. Intro, to the Sector Notebook Project
I.E.
          from more detailed sources pertaining to specific topics.  This approach
          allows for a wide coverage of activities that can be further explored based
          upon the citations and references listed at the end of this profile. To check
          the information included, each notebook went through an external review
          process. The Office of Compliance appreciates the efforts of all those who
          participated in this process who enabled the development of more complete,
          accurate,  and up-to-date summaries.  Many of those who reviewed this
          notebook are listed as contacts in Section DC and may be sources of additional
          information.  The individuals and groups  on this list do  not  necessarily
          concur with all statements within this notebook.

Additional Information

Providing Comments

          The OECA Office of Compliance plans  to periodically review and update the
          notebooks and will make  these updates available both in hard copy and
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          would like to provide additional information, please send a hard copy and
          computer disk to the EPA Office of Compliance, Sector Notebook Project
          (2223-A), 401 M Street, SW, Washington, DC 20460. Comments can also
          be uploaded to the Enviro$en$e World Wide Web for general access to all
          users of the system. Follow instructions in Appendix A for accessing this
          system.  Once you have logged in, procedures for uploading text are available
          from the on-line Enviro$en$e Help System.

Adapting Notebooks to Particular Needs

          The scope of the industry sector described in this notebook approximates the
          national occurrence of facility types within the sector.  In many instances,
          industries within specific  geographic  regions or states may have unique
          characteristics that are not fully captured in these profiles.  The Office of
          Compliance encourages state  and  local environmental agencies and other
          groups to supplement or repackage the information included in this notebook
          to include more specific industrial and regulatory information that may be
          available.  Additionally, interested states may want to supplement the
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          also want to develop the  "Pollution Prevention"  section  in more detail.
          Please contact the appropriate specialist listed on the opening page of this
          notebook if your office is interested in assisting us in further development of
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          interested hi assisting hi the development of new notebooks for sectors not
          covered in the original 18, please contact the Office of Compliance at (202)
          564-2395.
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 Fossil Fuel Electric Power Generation
Section II. Introduction to the Industry
 II.        INTRODUCTION TO THE FOSSIL FUEL ELECTRIC POWER GENERATION
           INDUSTRY

                      This Sector Notebook addresses the fossil fuel  electric power generation
                      industry, which comprises the majority of the total electric power generation
                      industry. This subset of the industry includes only facilities that use either
                      coal, petroleum, or gas as the energy source to generate electricity and does
                      not include facilities that use nuclear or renewable (e.g., wood, solar) energy
                      sources exclusively. However, this subset would include power generation
                      activities at facilities that use both fossil fuels and another energy source. In
                      addition, the scope of this profile is further limited to address only those
                      facilities that generate electricity either as a primary activity or as an ancillary
                      activity.  The profile does not include facilities and activities associated with
                      the transmission and distribution of electricity.

 II.A      Introduction, Background, and Scope of the Notebook

                      Fossil fuel electric power generation facilities are classified under Standard
                      Industrial Classification (SIC) code 49,  which includes  establishments
                      engaged in electric, gas, and sanitary services.  These facilities can be further
                      classified under the following three- and four-digit SIC codes from the
                      Standard Industrial  Classification (SIC)   Manual  of the  Office  of
                      Management and Budget.

                      •   SIC 4911 - Electric Services: Establishments that are  engaged in the
                         generation, transmission, and/or distribution of electric energy for sale.

                      •   SIC 493 - Combination Electric and Gas, and Other Utility Services:
                         Establishments providing electric or gas services in combination with
                         other services. Establishments are classified here only if one service does
                        not constitute at least 95 percent of revenues.

                     It  should be noted that  these  SIC codes  do  not make  the necessary
                     distinctions  between fuels used and generation versus transmission and
                     distribution activities. Data available to characterize the fossil fuel electric
                     power generation industry that use these  SIC codes also may not distinguish
                     between these categories of facilities. Where these categories of facilities
                     and/or activities cannot be distinguished in the available data, it will be so
                     noted within the profile.

                     Fossil fuel electric power generation facilities are also classified under a new
                     system called the North American Industry Classification System (NAICS),
                     which replaced the existing SIC codes in January  1997.   The NAICS
                     classification code for fossil fuel electric power generation is 221112.
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Fossil Fuel Electric Power Generation
Section II. Introduction to the Industry
                     Power generation facilities and activities exist in association with both
                     traditional utilities or nonutility power producers. Traditional utilities are the
                     regulated industry that produces and provides electricity for public use. Prior
                     to 1980, nonutilities consisted of industrial manufacturers that produced
                     electricity for their own use. Currently, nonutilities not  only consist of
                     industrial  manufacturers, but also other industrial  groups that  provide
                     electricity and other services for their own use and/or for sale to others.
                     These categories are discussed further below.

                     This section provides background information on  the size, geographic
                     distribution, electricity production, sales, and economic condition of the
                     fossil fuel electric power generation industry. The type of facilities described
                     within  the document are also  described in terms  of their SIC codes.
                     Additionally, this section lists the largest companies in terms of sales.

H.B      Characterization of the Fossil Fuel Electric Power Generation Industry

                     The U.S. Department of Energy's (DOE) Energy Information Administration
                     (EIA) collects, evaluates, and disseminates information on the fossil fuel
                     electric power generation industry. This information is published annually.
                     In addition, industry trade associations collect information.

                     Available statistics  on the fossil fuel electric power generation  industry
                     typically characterize the industry in terms of capacity, generating capability,
                     net generation, and revenues. These terms are defined as follows:

                     •  Capacity is the amount of electric power delivered or required for which
                        a generator, turbine, or system has been rated by the manufacturer.

                     •  Capability is the maximum load that a generating unit can be expected
                        to carry under specified conditions for a given period of time without
                        exceeding approved limits of temperature or stress. The net capability of
                        a generating unit is always less than the rated capacity.

                     •  Net generation is the total amount of electricity generated minus the
                        electricity used by the facility itself.

                     •  Revenue is the total amount of money received by a firm from sales of
                        its products and/or services, gains from the sales or exchange assets,
                        interest and dividends earned on investments, and other increases in the
                        owner's equity except those arising from capital adjustments.

                     The following  sections  briefly summarize  information available to
                     characterize the industry.
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Fossil Fuel Electric Power Generation
Section II. Introduction to the Industry
           II.B.1     Product Characterization

                     The product in fossil fuel electric power generation is electricity.  Ancillary
                     activities associated with the generation of electricity may generate other
                     products, however. For example, cogeneration systems produce electricity,
                     as well as another form of usable energy (i.e., steam or heat).  In addition,
                     utilities with SIC code 493 may produce other products, such as gas. These
                     other products are beyond the scope of this profile.

           II.B.2     Industry Size and Geographic Distribution of the Fossil Fuel Electric
                     Power Generation Industry

                     In general, the power generation industry comprises both traditional and
                     nontraditional electric-producing companies.  They are called "utility" and
                     "nonutility" power producers,  respectively.  A  key difference between
                     utilities and nonutilities is that utilities own generation, transmission, and
                     distribution functions. Thus, utilities are "vertically" oriented.  Nonutilities,
                     on the other hand, generally own only generation capabilities. Often, the
                     nonutilities must rely on utilities to sell the electricity they produce.

                     A utility power producer is generally defined as any person, corporation,
                     municipality, State political subdivision or agency, irrigation project, Federal
                     power administration, or other legal entity that is primarily engaged in the
                     retail or wholesale sale, exchange, and/or transmission of electric energy. In
                     1995, there were 3,199 utilities in the United States; however, only 700 of
                     these utilities generated electric power. The remainder were electric utilities
                     that purchased wholesale power from others for the purpose of distribution
                     over their lines to the ultimate consumer.  The 700 utilities that  generated
                     power had a total of 3,094 power plants or stations.1

                     A nonutility  power producer is  defined  as  any person,  corporation,
                     municipality, State political subdivision or agency, Federal agency, or other
                     legal entity that either (1) produces electric energy at a qualifying facility
                     (QF)a as defined under the Public Utility Regulatory Policies Act  (PURPA)
                     or (2) produces electric energy but is primarily engaged in business activities
                     other than the sale of electricity. In 1995, there were 4,190 nonutility power-
                     generating facilities. Generation by nonutility power producers accounted for
                     approximately 12 percent of the total U.S. electric generation.  Fifty-six
                     percent of the electricity generated  by nonutilities was  sold to  electric
                     utilities.2
a To receive status as a QF under PURPA, a facility must meet certain ownership, thermal output size, and
efficiency criteria established by the Federal Energy Regulatory Commission (FERC). QFs are guaranteed that
electric utilities will purchase their output at a reasonable price.
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Fossil Fuel Electric Power Generation
Section II. Introduction to the Industry
                     Table 1 provides electric power generation statistics for the year 1995 that
                     allows comparison between electric power generation by both utilities and
                     nonutilities based on the fuels used.
Table 1: Comparison of Utility and Nonutility Electric Power Generation (1995)
Energy
Source
Fossil
Nuclear
Hydroelectric*
Renewable
and other"
Total
Utility Generation
(thousand megawatthours)
2,021,064
673,402
293,653
6,409
2,994,528
Nonutility Generation
(thousand megawatthours)***
287,696
	 (t)
14,515
98,295
400,505
Total U.S. Generation
(thousand megawatthours)
2,308,760
673,402
308,168
104,704
3,395,033
" Includes hydroelectric, conventional, and pumped storage.
" Includes geothermal, solar, waste, wind, photovoltaic, and biomass; projects for which there were two primary energy
sources; and projects that did not identify the primary energy source. Nonutility data includes nuclear.
*** Totals may not equal sum of components because of independent rounding.
* Nonutility facilities using nuclear are including under "Renewable and other."
Sources: (a) Electric Power Annual, 1995, Volume I. U.S. Department of Energy, Energy Information Administration,
Washington, DC. July 1996. DOE/EIA-0348(95/1); and (b) 1995 Capacity and Generation of Non-Utility Sources of
Energy. Prepared by the Edison Electric Institute, Washington, DC. November 1996.
                     Based on these numbers and as shown hi Figure 1, fossil fuel electric power
                     generation represented 68 percent of the total U.S. electric power generation
                     industry's total production of electricity in that year (both utility and
                     nonutility combined). Nuclear energy represented 20 percent, renewable
                     energy sources  represented about 12 percent,  and  other energy sources
                     represented less than 1 percent of the electricity production.
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Fossil Fuel Electric Power Generation
Section II. Introduction to the Industry
                           Figure 1: Total Utility and Nonutility Electric Power Net
                                       Generation Based on Fuels (1995)
                                            Renewable  Other
                                              12%     <1%
                                  Nuclear
                                   20%
                                                                      Fossil
                                                                        68%
                     In general, statistics on utility and nonutility electric power production are
                     not aggregated. The following sections provide a more in-depth discussion
                     of the information available to characterize the utility and nonutility electric
                     power generators.

          II.B.3     Industry Size and Geographic Distribution of Traditional Utilities

          Ownership Categories and Revenues

                     Electric utilities are divided into four ownership categories:  investor-owned,
                     publicly owned, cooperative-owned, and Federally owned. These categories
                     are described as follows:

                     •   Investor-owned utilities produce a return for investors. They either
                        distribute profits to stockholders as dividends or reinvest the profits.
                        Investor-owned utilities are regulated entities that are granted a service
                        monopoly  in certain geographic areas  and are obliged to serve all
                        consumers and charge reasonable prices.

                     •   Publicly-owned utilities are non-profit local government agencies (e.g.,
                        municipalities,  counties, States, and public utility districts) that  serve
                        communities and nearby consumers at cost, returning excess funds to the
                        consumer in the form of community  contributions,  economic and
                        efficient facilities, and lower rates.

                     •   Cooperative utilities are owned by their members and are established to
                        provide electricity to those members. Cooperatives typically provide
                        electric service to small rural communities of 1,500 or less.

                     •   Federal electrical utilities do not generate power for profit. The Federal
                        government is primarily a producer and wholesaler of electricity, and
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Fossil Fuel Electric Power Generation
Section II. Introduction to the Industry
                        preference in the purchase of the electricity is given to publicly owned
                        and cooperative electric utilities.

                     In 1995, there were 244 investor-owned, 2,014 publicly owned, 10 Federal,
                     and 931 cooperative utilities.  Figure 2 shows the percentage of 1995 U.S.
                     electricity sales to ultimate consumers based on ownership type. Total sales
                     were 1,013 billion kilowatthours. Only a portion of these utilities own and/or
                     operate fossil fuel electric power generation capacity.

                       Figure 2:  Total Utility Electricity Sales to Ultimate Consumers3
                                    Cooperative  Federal
                                        8%        2%
          Publicly
          Owned
           15%
                                                Investor-
                                                Owned
                                                 75%
                     Among the ownership classes, investor-owned utilities account for more than
                     75 percent of all retail sales and revenues. In 1995, revenues from major
                     utility generators totaled 208 billion dollars.  Table 2 provides the revenues
                     from major utility generators based on ownership category.  Tables 3 and 4
                     list the 1995 top ten investor-owned and publicly owned utilities based on
                     revenues from sales and megawatts sales to ultimate consumers, respectively.
                     It should be noted that these data are for all electric utility activities, not just
                     those that generate electricity.
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Fossil Fuel Electric Power Generation
Section II. Introduction to the Industry
Table 2: Revenues From Major Utility Generators (1995)
Ownership Category
Investor-Owned
Publicly Owned
Cooperative
Federal
Total
Revenue (billion $)
164
26
17
1
208
Source: Electric Power Annual 1995, Volume II. U.S. Department of Energy, Energy Information Administration,
Washington, DC. July 1996. DOE/EIA-0384(95)/2.
Table 3: Top Ten Investor-Owned Utilities Ranked by Revenue From Sales
to Ultimate Consumers (1995)
Utility Name
Southern California Edison Co.
Pacific Gas and Electric Co.
Commonwealth Edison Co.
Texas Utilities Electric Co.
Florida Power & Light Co.
Consolidated Edison Co. - NY, Inc.
Virginia Electric & Power Co.
Georgia Power Co.
Public Service Electric & Gas
Duke Power Co.
Subtotal
Revenue (thousand dollars)
7,575,448
7,569,507
6,634,832
5,450,444
5,325,258
5,005,860
3,979,071
3,972,189
3,886,566
3,843,227
53,242,403
% of Total
4.64
4.63
4.06
3.34
3.26
3.07
2.44
2.43
2.38
2.35
32.61
Source: Financial Statistics of Major U.S. Investor-Owned Electric Utilities - 1995. U.S. Department of Energy, Energy
Information Administration, Washington, DC. December 1996. DOE/EIA-0437/(95)/l.
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Fossil Fuel Electric Power Generation
       Section II. Introduction to the Industry
Table 4: Top Ten Publicly Owned Generator Utilities Ranked by Megawatt Sales
to Ultimate Consumers (1994)
Utility Name
City of Los Angeles (CA)
Salt River Project (AZ)
Power Authority of State of NY
San Antonio Public Service Board (TX)
City of Seattle (WA)
Jacksonville Electric Authority (FL)
Sacramento Municipal Utility District (CA)
South Carolina Public Service Authority
City of Austin (TX)
Omaha Public Power District (NE)
Subtotal
Megawatt Sales
20,430,075
16,058,298
13,212,615
13,027,064
8,874,039
8,817,618
8,458,156
7,423,460
7,308,134
7,066,940
110,676,399
% of Total
8.61
6.77
5.57
5.49
3.74
3.72
3.57
3.13
3.08
2.98
46.65
Source: Financial Statistics of Major U.S. Publicly-Owned Electric Utilities - 1994. U.S. Department of Energy, Energy
Information Administration, Washington, DC. December 1995. DOE/EIA-0437/(94)/2.
           Geographic Distribution of Utilities

                     Fossil fuel electric power generation by utilities occurs across the United
                     States.  Figure 3 provides the total electric power net generation for each
                     State. Higher values for net generation from utilities generally mirror higher
                     population densities and industrial centers. The States with the highest utility
                     net generation included were California, Texas, Illinois, Ohio, Pennsylvania,
                     and Florida. The amount and geographical distribution of capacity by energy
                     source are a function of availability and price of fuels and/or regulations.
                     Energy sources used by utilities generally show a geographical pattern, such
                     as significant coal and  petroleum-fired capacity in the East and gas-fired
                     capacity in the Coastal South.4
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Fossil Fuel Electric Power Generation
        Section II. Introduction to the Industry
      Figure 3:  Geographic Distribution of U.S. Utility Electric Power Net Generation
   Source: Electric Power Annual, 1995,  Volume I and II. U.S. Department of Energy, Energy
   Information Administration, Washington, DC.  July 1996. DOE/EIA-0348(95)/1&2.


          Existing Utility Capacity and Electricity Generation

                     In general, electric power generation utilities use several technologies to
                     generate electric power.  These technologies, known as prime movers, are
                     steam turbines, gas turbines, internal combustion engines, combined-cycle,
                     hydraulic turbines, and others (e.g., geothermal, solar, and wind).  Combined-
                     cycle facilities use a technology in which electricity is produced from
                     otherwise lost heat exiting from one or more gas (combustion) turbines. The
                     exiting heat is routed to a conventional boiler or to  a heat recovery steam
                     generator for utilization by a steam turbine in the production of electricity.
                     This process increases the efficiency of the generating unit.  Table 5 shows
                     the 1995 existing capacity that employs these technologies and the percent
                     of total U.S. utility capacity. Steam turbines are associated with 77 percent
                     of the total U.S. utility capacity.
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Fossil Fuel Electric Power Generation
       Section II. Introduction to the Industry
Table 5: Existing Capacity of All U.S. Utilities by Prime Mover
(fossil fuels, renewable fuels, and other fuels) (1995)
Prime Mover
Steam Turbines*
Gas Turbines
Internal Combustion
Combined-Cycle (gas and steam)
Hydraulic Turbines (hydroelectric)
Others
Total
Generating Capacity
(megawatts)"
579,647
58,329
4,985
14,578
91,114
1,888
750,542
Percent of Total U.S.
Capacity
77
7
>1
2
12
>1
100
* Includes nuclear generators.
" Total may not equal sum of components because of independent rounding.
Source: Inventory of Power Plants in the United States, as of January 1, 1996. U.S. Department of Energy,
Energy Information Administration, Washington, DC. December 1996. DOE/EIA-0095(95).
                    Not all of the existing capacity uses fossil fuels.  Only a subsection of steam
                    turbine,  gas turbine, internal  combustion, and combined-cycle capacity
                    (657,539 megawatts) uses fossil fuels. More than 75 percent of the total
                    existing  capacity is fossil-fueled. Table 6 presents the 1995 capacity that
                    used fossil fuels for each prime mover. In 1995, approximately 86 percent
                    of the fossil-fueled electric power generation capacity was from steam turbine
                    systems.
Table 6: Fossil-Fueled Utility Capacity by Prime Mover (1995)*
Prime Mover
Steam Turbine
Gas Turbine/Internal Combustion
Total
Generating Capacity
(megawatts)
475,860
73,166
549,026
% of Fossil-Fueled Capacity
86
14
100
Includes combined-cycle capacity.
Source: Inventory of Power Plants in the United States, As of January 1, 1996. U.S. Department of Energy,
Energy Information Administration, Washington, DC. December 1996. DOE/EIA-0095(95).
                    Fossil fuel-fired steam electric utilities had the capability to produce 445,627
                    megawatts of electricity, or more than 50 percent of the net generating
                    capability at U.S. electric utilities.  Gas turbine and internal combustion
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Fossil Fuel Electric Power Generation
       Section II. Introduction to the Industry
                     facilities  combined  had the capability to produce 61,424 megawatts of
                     electricity, or 11.5 percent of generating capability at U.S. electric utilities in
                     1995.

                     In 1995, coal was used as the energy source to generate the most electricity
                     in the utility industry, accounting for net generation of 1,652,914 thousand
                     megawatthours of electricity, consuming 829,007 thousand short tons of coal.
                     Gas-fired generators generated 307,306 thousand megawatthours, consuming
                     3,196,507 million cubic feet of gas, and petroleum-fired generators generated
                     60,844 thousand megawatthours of electricity, consuming 102,150 thousand
                     barrels of petroleum (not including petroleum coke). Many utility generators
                     have the flexibility to switch fuel sources in response to market conditions.
                     Table 7 provides the  1995 U.S. utility generating capacity and net generation
                     for each fossil fuel energy source.
Table 7: Utility Generating Capability and Net Generation by Energy Source (1995)
Energy Source
Coal
Gas
Petroleum
Total
Generating Capability
(megawatts)
301,484
135,749
70,043
507, 276
Net Generation
(thousand megawatthours)
1,652,914
307,306
60,844
2,020,822
Source: Electric Power Annual, 1995, Volume 1. U.S. Department of Energy, Energy Information
Administration, Washington, DC. July 1996. DOE/EIA-0348(95/1).
          II.B.4     Industry Size and Geographic Distribution of Nonutilities

          Nonutility Classifications

                     There are three categories of nonutilities:

                     •   Cogeneration is the major technology used among nonutility power
                        producers.  This technology, which is discussed in greater detail in
                        Section III,  is the combined production of electric power and another
                        form of useful energy (e.g.,  heat or steam).  To receive QF status  under
                        PURPA, a cogeneration facility must meet certain operating criteria to
                        "produce electrical energy  and another form of useful thermal energy
                        through the  sequential use of energy." Depending upon the technology
                        used, a facility may also be  required to meet specific efficiency criteria.
                        QFs are guaranteed that electric utilities will purchase their output at the
                        incremental cost that an electric  utility would incur to  produce or
                        purchase an amount of power equivalent to that purchased from QFs.
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Fossil Fuel Electric Power Generation
       Section II. Introduction to the Industry
                        QFs are also guaranteed that electric utilities will provide backup service
                        at prevailing (non-discriminatory) rates.

                        Fossil-fueled  steam  turbine  systems are  used in  most  industrial
                        applications of cogenerating processes, while gas turbine systems are
                        used in most other processes (e.g., commercial). Diesel engine systems
                        are limited in their application to cogeneration because they provide less
                        useable process heat per unit of electric power input.

                     •  Small Power Producers are designated under PURPA regulations based
                        on fuel consumption of a renewable energy  source greater than 75
                        percent.   This means that most nonutility fossil fuel electric  power
                        generators are not likely  to carry this designation.  In limited cases
                        however,  a facility may use fossil fuel in conjunction with a renewable
                        energy source.

                     •  Other Nonutility Generators are facilities not classified in the previous
                        categories that produce electric power for their own use and for  sale to
                        electric utilities.  These facilities include:

                        -   Independent power producers (IPPs)
                        -   Nonqualifying cogenerators
                            Exempt wholesale generators (EWGs)
                            Other commercial and industrial establishments.

                     FERC defines IPPs as producers of electric power other than QFs that are
                     unaffiliated with firanchised utilities in the IPP's market area and that for
                     other reasons lack significant market power.  The IPPs  may lack market
                     power due to siting or access to  transmission.  The EWGs are engaged
                     exclusively in the business of wholesale electric generation and are exempt
                     from corporate organizational restrictions under the Public Utility Holding
                     Company Act of 1935.

                     In 1995, the makeup of the nonutility industry, based on capacity, included
                     76.2 percent cogenerators, 15.8 percent small power producers, and 8 percent
                     other nonutility producers. Figure 4 illustrates the percent capacity of the
                     different classes of nonutility power producers.5
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Fossil Fuel Electric Power Generation
       Section II. Introduction to the Industry
                              Figure 4:  Nonutility Capacity by Type of Producer
                              Small Power
                               Producers
                                 16%
         Other
      Nonutilities
         8%
                                                                    Cogenerators
                                                                        76%
                    Qualified facilities comprised 78 percent of the total nonutility capacity in
                    1995.  Non-qualified facilities were 12.9 percent of the capacity.

                    Nonutility power generation facilities  and activities may  be  found  in
                    association with commercial and industrial facilities. Table 8 lists SIC codes
                    and industries where power generation facilities and activities may be found.

                    In 1995, nonutility  generation capacity within the chemical industry (SIC
                    Code 28) accounted for 21 percent of the nonutility capacity and 23 percent
                    of the total  nonutility generation.   The paper industry (SIC Code 26)
                    accounted for 17 percent of the nonutility capacity and  18 percent of the
                    generation. The coal, oil, and gas mining and refining industries (SIC Codes
                    12, 13, and 29) accounted for 12 percent of the total nonutility capacity and
                    13 percent of the generation.6
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Fossil Fuel Electric Power Generation
                Section II. Introduction to the Industry
               Table 8: Major SIC Codes and Industrial Categories Where Nonutility
                                Power Generation Activities Are Found
      Major SIC Code
Industrial Category
      01,02
      07
      10
      12
      13
      20
      21
      22
      23
      24
      25
      26
      27
      28
      29
      30
      31
      32
      33
      34
      35
      36
      37
      38
      39
      42,45,47,48,49
      53,54,55,58
      60,65
      70,72,80, 82, 83, 84,86,87
      91,92,97
Agricultural Production - Crops, Livestock, and Animals
Agricultural Services
Metal Mining
Coal Mining
Oil and Gas Extraction
Food and Kindred Products
Tobacco Products
Textile Mill Products
Apparel & Other Finished Fabric Products
Lumber and Wood Products (Except Furniture)
Furniture and Fixtures
Paper and Allied Products
Printing, Publishing, and Allied Industries
Chemicals and Allied Products
Petroleum Refining and Related Industries
Rubber and Miscellaneous Plastics Products
Leather and Leather Products
Stone, Clay, Glass, and Concrete Products
Primary Metal Industries
Fabricated Metal Products (Except Machinery)
Industrial and Commercial Machinery/Computer Equipment
Electronic and Other Electrical Equipment
Transportation Equipment
Measuring, Analyzing, and Controlling Instruments
Jewelry, Silverware, and Plated Silver
Transportation, Communications, Electric, Gas, and Sanitary Services
Retail Trade
Finance, Insurance, and Real Estate
Services
Public Administration
      Source: Directory of U.S. Cogeneration, Small Power, and Industrial Power Plants. June 1995.. Giles, Ellen and Fred Yost. Twelfth
      Edition. Utility Data Institute, A Division of McGraw- Hill Company.  UDI-2018-95.                              	
           Geographic Distribution ofNonutilities

                         Fossil fuel electric power generation by nonutilities occurs all across the
                         United States.  Figure 5 provides the total nonutility electric power net
                         generation for  each State.   As with the utilities, higher  values for net
                         generation for nonutilities  generally mirror higher population densities and
                         industrial centers.   The States  with the highest nonutility  net generation
                         included were California, Texas,  Virginia, New York, Florida, and New
                         Jersey.
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Fossil Fuel Electric Power Generation
       Section II. Introduction to the Industry
    Figure 5:  Geographic Distribution of U.S. Nonutility Electric Power Net Generation
Source: Electric Power Annual Volume I and II. July 1995. U.S. Department of Energy, Energy
Information Administration, Washington, DC.  DOE/EIA-0348(95)/1&2.

          Existing Nonutility Capacity and Electricity Generation

                    As in the traditional utilities, nonutilities use steam turbines, gas turbines,
                    internal combustion engines, hydraulic turbines, and combined-cycle systems
                    to generate electricity. Steam turbines accounted for 42 percent of all the
                    capacity and combined-cycle generating  systems accounted for 27 percent.
                    Table  9  provides existing 1995 nonutility generating capacity by prime
                    mover technology.

                    The majority (more than 68 percent) of existing 1995 nonutility capacity is
                    attributed to fossil-fueled electricity production.7 Many facilities are able to
                    switch from one fossil fuel to another if the fuel supply is interrupted or the
                    economics warrant it.  Some facilities are even able to switch from fossil
                    fuels to renewable energy sources, while still others can use combustors that
                    can burn two  or  more different  fuels simultaneously, in  varying
                    combinations, to generate a desired heat output.  Thus, the nonutility industry
                    can be very adaptable, depending upon the type of equipment at a facility and
                    based on economic  conditions.  Table  10 provides the  1995 nonutility
                    capacity associated with each fossil fuel energy source.
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Table 9 : Existing Capacity of Nonutilities by Prime Mover (1995)
Prime Mover
Steam Turbines
Combined-Cycle
Gas Turbines
Internal Combustion
Hydraulic Turbines
Others*
Total
Generating Capacity
(megawatts)
28,192
17,417
12,081
2,018
3,410
3,297
66,415
Percent of Total U.S.
Capacity
42
27
18
3
5
5
100
* Includes nuclear generators.
Source; 1995 Capacity and Generation ofNonutility Sources of Energy. Edison Electric Institute, Washington,
DC. November 1996.
Table 10: Nonutility Capacity by Fossil Fuel Energy Source (1995)
Fossil Fuel
Gas
Coal
Petroleum
Total
Generating Capacity
(megawatts)
33,221
10,324
1,657
45,202
Percent of Total Fossil Fuel
Nonutility Capacity
73
23
4
100
Source: 1995 Capacity and Generation ofNonutility Sources of Energy. Edison Electric Institute, Washington,
DC. November 1996.
                     The majority of the nonutility power producers use fossil fuels to generate
                     electricity. Fossil fuels accounted for more than 287 million megawatthours,
                     which was 72 percent of the total  electricity produced by nonutilities in
                     1995.8

                     Gas was the fossil fuel used to generate the most electricity in the nonutility
                     industry, providing a total of 213 million megawatthours of electricity in
                     1995. Coal was used to produce 70 million megawatthours of electricity,
                     and petroleum was used to produce  4 million megawatthours of electricity.
                     Table 11 provides 1995 nonutility generation by power producer class and
                     energy source.
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Table 11: 1995 Nonutility Net Generation by Primary Fossil Fuel Energy Source and Type
of Producer (thousand megawatthours)
Energy Source
Gas
Coal
Petroleum
Total
Cogenerators
200,080
63,440
3,957
267,477
Small Power
Producers
0
0
0
0
Other Nonutility
Power Producers
13,357
6,740
121
20,218
Total U.S.
Nonutility
Generation
213,437
70,180
4,079
287,696
Source: 1995 Capacity and Generation of Nonutility Sources of Energy. Edison Electric Institute, Washington,
DC. November 1996.
          II.B.5    Economic Trends

          Change in Structure of the Utility Electric Power Industry

                    Utility electric power generation is one of the largest industries that remains
                    regulated in the United States. Change is rapidly occurring in this industry
                    due to the  issuance by the FERC of Orders 888 and 889 (dated April 24,
                    1996), which encourage wholesale competition. Order 888 deals with issues
                    of open access to transmission networks and stranded costs;  Order 889
                    requires utilities to establish systems to share information on the availability
                    of transmission capacity.  To date, many States have initiated activities
                    related to retail competition, and legislative proposals have been introduced
                    into the U.S. Congress on restructuring the electric power industry.

                    With a competitive industry structure eminent, investor-owned utilities have
                    been downsizing  staff and reorganizing their company structures to lower
                    costs. They have lowered costs by taking advantage of lower fuel prices and
                    modifying fuel acquisition procedures. This has resulted in lower operation
                    and maintenance costs. Some large investor-owned utilities have begun to
                    expand their  business investments into such areas as energy service
                    companies; oil and gas exploration, development, and production; foreign
                    ventures; and telecommunications.  Numerous utilities are planning  to
                    improve their position in a competitive market through mergers and
                    acquisitions.  In 1995,  13 investor-owned utilities merged or had mergers
                    pending.9

                    Publicly owned and cooperative utilities are expected to be affected by the
                    posturing  of the  investor-owned companies.   Although they  can sell
                    electricity at a competitive price, increased competition from investor-owned
                    utilities and electricity marketing companies may require them to lower costs.
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                     Many have already begun to reduce staff and engage in other cost-cutting
                     measures.  Mergers are also expected to occur among public utilities,
                     however, not at the same rate as the investor-owned.

                     Stranded costs are a major concern for this industry as they move to a
                     competitive market. Stranded costs are costs that have been incurred by the
                     utilities to serve their consumers but cannot be recovered if the consumers
                     choose other electricity suppliers.  Estimates of stranded costs have been
                     from $10 to $500 billion.   Currently, utilities are  looking  for ways to
                     mitigate  stranded costs, and regulators are looking at alternatives for
                     recovering these costs.10

                     The structure of the electric power industry is undergoing other changes. In
                     the  past, the electric  power  industry has  been  dominated ,by utilities,
                     especially regulated investor-owned utilities.   It is  expected that utility
                     generators will continue to dominate capacity in the United States, increasing
                     from 703 gigawatts in 1995  to 724.4 gigawatts in 2015.   In addition,
                     nonutilities will continue to increase their role in the industry.  Recent
                     legislation has had an effect. For example, PURPA in 1978 has allowed QF
                     status, and the Energy Policy Act of 1992 (EPACT) has removed constraints
                     on utility ownership of significant shares of nonutility producers. In 10 years
                     (1985-1995), the nonutility role in U.S. electric power industry has grown
                     from 4 percent to 11 percent of the total generation.11

                     With the advent of a more competitive market, a new type of firm  called
                     "power marketers" has arisen in the electric power generation industry.
                     Power marketers buy electric energy and transmission and other services
                     from utilities, or other suppliers, and resell the products for profit.  This
                     practice started in the late 1980s, and growth in this market has increased
                     competition in the wholesale market. Nine wholesale marketers existed in
                     1992; 180 existed by the end  of 1995. The growth and success of power
                     marketers signal a potential  for  fundamental change  in  the  wholesale
                     electricity business.

          Projected Growth in the Power Generation Industry

                     Demands for electricity have slowed in recent years due to several factors.
                     These factors include market saturation of electric appliances, improvements
                     in equipment efficiency, utility investments in demand-side management
                     programs, and legislation establishing more stringent  equipment efficiency
                     standards. In the 1960s, electricity demand grew by more than 7 percent a
                     year. By the 1980s, this growth had slowed to only 1 percent per year. A
                     further decline in growth is expected into the next century.12
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                    Despite the slower demand growth, 319 gigawatts of new generating capacity
                    are expected to be needed by 2015. This need is both a result of the demand
                    and because  of the amount of capacity that is expected to be retired.  In
                    particular, approximately 38 percent of the existing nuclear capacity is
                    expected to be retired, in addition to 16 percent of the existing fossil-fueled
                    steam turbine capacity. Of the new capacity needed, 81 percent is projected
                    to be combined-cycle or combustion turbine technology expected to be fueled
                    with natural gas or both oil and gas. Both of these technologies supply peak
                    and intermediate capacity, but combined-cycle units can also be used to meet
                    baseload requirements.

                    Before building new capacity, many utilities are exploring other alternatives
                    to meet the growth demand.  Some of these alternatives are life extension and
                    repowering,  power  imports, demand-side management  programs, and
                    purchase from cogenerators.  Even with these alternatives, a projected 1,063
                    new plants (assuming approximately 300 megawatts capacity per plant) will
                    be  needed by 2015 to meet  the growing  demand  and  to offset  the
                    retirements.13
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 Fossil Fuel Electric Power Generation
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HI.       INDUSTRIAL PROCESS DESCRIPTION

                     This section describes the major industrial processes within the fossil fuel
                     electric power generation industry, including the materials and equipment
                     used and the processes  employed.  The section  is designed  for those
                     interested in gaining a general understanding of the industry and for those
                     interested in the interrelationship between the industrial process and the
                     topics described in subsequent sections of this profile ~ pollutant outputs,
                     pollution prevention opportunities, and Federal regulations.  This section
                     does not attempt to replicate published  engineering information that  is
                     available for this industry. Section IX lists available resource materials and
                     contacts.

                     This section describes commonly used production processes, associated raw
                     materials, the by-products produced or released, and the  materials either
                     recycled or transferred offsite.  This discussion, coupled with schematic
                     drawings of the identified processes, provide a concise description of where
                     wastes may be  produced in the process.  This section also describes the
                     potential fate (via air, water, and soil pathways) of these waste products.

III.A      Industrial Processes in the Fossil Fuel Electric Generation Industry

                     The majority of the electricity generated in the United  States today  is
                     produced by facilities that employ steam turbine systems.14 Other fossil fuel
                     prime movers commonly used include  gas turbines and internal combustion
                     engines. Still other power generation systems employ a combination of the
                     above, such as combined-cycle and cogeneration systems. The numbers of
                     these systems being built are increasing as a result of the demands placed on
                     the industry to provide economic and efficient systems.

                     The type of system employed at a facility is chosen based on the loads, the
                     availability of fuels, and the  energy  requirements  of the electric power
                     generation facility.  At facilities employing these systems, other ancillary
                     processes must be performed to support the generation of electricity. These
                     ancillary processes  may include  such supporting  operations  as  coal
                     processing and pollution control, for example.  The following subsections
                     describe each system and then discuss ancillary processes at the facility.

           III.A.I    Steam Turbine Generation

                     The process of generating electricity  from steam comprises four parts:  a
                     heating subsystem (fuel to produce the steam), a steam subsystem (boiler and
                     steam delivery system), a steam turbine,  and a condenser (for condensation
                     of used steam).  Heat for the system is usually provided by the combustion
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                     of coal, natural gas, or oil.  The fuel is pumped into the boiler's furnace. The
                     boilers generate steam in the pressurized vessel  in small boilers or in the
                     water-wall tube system in modern utility and industrial boilers.  Additional
                     elements within  or  associated with the boiler,  such  as the superheater,
                     reheater, economizer and air heaters, improve the boiler's efficiency.

                     Wastes from the combustion process include exhaust gases and, when coal
                     or oil is used as the boiler fuel, ash.  These wastes  are typically controlled to
                     reduce the levels of pollutants exiting the exhaust stack.  Bottom ash, another
                     byproduct of combustion, also is discharged from the furnace.

                     High temperature, high pressure steam is generated in the  boiler and then
                     enters the steam turbine.  At the other end of the steam turbine is the
                     condenser, which is  maintained at  a low temperature and pressure.  Steam
                     rushing from the high pressure boiler to the low pressure condenser drives the
                     turbine blades, which powers the electric generator. Steam expands as it
                     works; hence, the turbine is wider at the exit end of the steam.   The
                     theoretical thermal efficiency of the unit is dependent on the high pressure
                     and temperature  hi  the boiler and the low temperature and pressure in
                     condenser.  Steam turbines typically have a thermal efficiency of about 35
                     percent, meaning that 35 percent of the heat of combustion is transformed
                     into electricity. The remaining 65 percent of the heat either goes up the stack
                     (typically 10 percent) or  is discharged with the condenser cooling water
                     (typically 55 percent).

                     Low pressure steam exiting the turbine enters the condenser shell and is
                     condensed on the condenser tubes.  The condenser tubes are maintained at a
                     low temperature by the flow of cooling water.  The condenser is necessary for
                     efficient operation by providing a low pressure sink for the exhausted steam.
                     As the steam is cooled to condensate, the condensate is transported by the
                     boiler feedwater system back to the boiler, where it is used again.  Being a •
                     low-volume incompressible liquid, the condensate water can be efficiently
                     pumped back into the high pressure boiler.

                     A constant flow of low-temperature cooling water in the condenser tubes is
                     required to keep the condenser shell (steam side) at proper pressure and to
                     ensure efficient electricity generation.  Through the condensing process, the
                     cooling water is warmed. If the cooling system is an open or a once-through
                     system, this warm water is released back to the source water  body.  In a
                     closed system, the warm water is  cooled by recirculation through cooling
                     towers, lakes, or ponds,  where the heat is released into  the  air  through
                     evaporation and/or sensible heat transfer. If a recirculating cooling system
                     is used, only a small amount of make-up water is required to offset the
                     cooling tower blowdown which must  be discharged periodically to control
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                      the build-up of solids.  Compared to a once-through system, a recirculated
                      system uses about one twentieth the water.15 Figure 6 presents a typical
                      steam generation process.

                      There are several types of coal-fired steam generators. A description of each
                      follows. The classification of these generators is based on the characteristics
                      of the coal fed to the burners and the mode of burning the coal. Coal-fired
                      steam generation systems are designed to use pulverized coal or crushed coal.
                      Before the  coal  is  introduced to the burners,  it must  be processed, as
                      discussed hi Section III.A.6.
                                      Figure 6: Steam Turbine Generation
                        Fuel
                                Steam
                               Generator
                                      s
                                                                              Electrical
                                                                              Generator
                                                  Healer
                               Cooling Water (In)
                               Cooling Water (out)
                          Condenser
                                                  Train
                                    • Exhaust <3as
           Stoker-Fired Furnace
                     Stoker-fired furnaces are designed to feed coal to the combustion zone on a
                     traveling grate.  Stokers can be divided into three general groups, depending
                     on how the coal reaches the grate of the stoker for burning.  The three general
                     types  of stokers  are  (1)  underfeed,  (2)  overfeed, and (3) spreader
                     configurations. Table 12 presents the general characteristics of these three
                     general types of stokers.  Figure 7 presents a schematic of a stoker coal
                     feeder.
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Table 12: Characteristics of Various Types of Stokers
Stoker Type and Subclass
Burning Rate *
(BTU/hr/ftz)
Characteristics
Spreader
Stationary
Traveling grate
Vibrating grate
450,000
750,000
400,000
Capable of burning a wide range of coals, best
in handling fluctuating loads, high fly ash
carry over, low load smoke.
Overfeed
Chain grate and
traveling grate
Vibrating grate
600,000
400,000
Low maintenance but difficult in burning
caking coals.
Low maintenance but difficult in burning
weakly caking coals, smokeless operation.
Underfeed
Single or double
retort
Multiple retort
400,000
Capable of burning caking coals and a wide
range of coals, high maintenance, low fly ash
carry over, suitable for continuous load
operation.
* Maximum amount of British thermal units per hour per square foot of grate hi the stoker.
Source: Coal Handbook, Robert Meyers (Ed.). Marcel Dekker, Inc. New York, NY, 1981 as referenced in
Wastes from the Combustion of Coal by Electric Utility Power Plants. Report to Congress. US. Environmental
Protection Agency, Office of Solid Waste. Washington, DC. February 1988. EPA/530-SW-88-002.
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                                          Figure 7: Stoker Coal Feeder
                                                             ^•"-o
                                                                        •Coal Gate
                            Chilli F««l«
                                                                            Rotor
                                                                            AlrTuyir*
                      Source: Standard Handbook of Power Plant Engineering. Elliot, Thomas C. ed.
                      McGraw-Hill, Inc. New York NY.  1989. Reproduced with permission of the
                      McGraw-Hill Companies.
                     In a cyclone-fired furnace, fuel is fired under intense heat and air is injected
                     tangentially to create a swirling motion as shown in Figure 8. The resulting
                     hot gases exit through the cyclone bore into the cyclone in the furnace.  Ash
                     becomes a molten slag that is collected below the furnace.  Coal is the
                     primary cyclone fuel, but oil and gas are used as startup, auxiliary, and main
                     fuels.
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                     Figure 8:  Typical Cyclone Coal Burners
                            Burner
                  Cyclone
                  Furnace
                          End Views

               Tertiary     Primary Air
                 Air        and Coal,
                                 Side Views
                           Tertiary
                             Air
                                              Orifice-
                                       Scroll Burner    Primary Air and Coal \
Coal Primary
       Air
         \
                                                   Coal
                                       Vortex Burner
                              Primary Ai
"     \
                               Coal
               Primary Air
                           Primary   Coal
                             Air
                   Tertiary Air    ^v
                                              Orifice
                                      Radial Burner
      Source: Steam, Its Generation and Use; 40th Edition. Stultz and Kitto, eds. Babcock
      and Wilcox, Barbeton, OH. 1992. Reproduced with permission from the Babcock and

      Wilcox Co.
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           Tangential-Fired Furnace
                     In a tangential-fired furnace, both air and fuel are projected from the corners
                     of the furnace along lines tangent to a vertical cylinder at the center.  A
                     rotating motion is created, allowing a high degree of mixing. This system
                     provides great flexibility for multiple fuel firing (see Figure 9).16

                                     Figure 9: Tangential Firing Pattern
                                  Main Fuel
                                  Nozzle
                                  Secondary-
                                  Air
                                  Dampers
                              Source: Standard Handbook of Power Plant
                              Engineering. Elliot, Thomas C. ed. McGraw-Hill, Inc.
                              New York, NY.  1989. Reproduced with permission of
                              the McGraw-Hill Companies.
          Horizontal or Wall-Fired Furnace

                     In horizontal or wall-fired systems, pulverized coal and primary air are
                     introduced tangentially to the coal nozzle.  The degree of air swirl and the
                     contour of the burner throat establish a recirculation pattern extending several
                     throat diameters into  the furnace.   The hot products of combustion are
                     directed back toward the nozzle to provide the ignition energy necessary for
                     stable combustion. In this system, burners are located in rows on the front
                     wall (see Figure 10) or both front and rear walls.17
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                                 Figure 10:  Flow Pattern of Horizontal Firing
                                      Air A
                                      AirB
                                      AirC
                                      AirD
                                        Burner B
                                        Burner A
                                        Burner D
                                        Burner C
                            Source: Standard Handbook of Power Plant Engineering. Elliot,
                            Thomas C. ed. McGraw-Hill, Inc. New York, NY. 1989.
                            Reproduced with permission of the McGraw-Hill Companies.
          Arch-Fired Systems
                     Vertical-fired systems are used to fire solid fuels that are difficult to ignite,
                     such as coals with moisture and ash-free  volatile matter of less than 13
                     percent. In this system, the pulverized coal is discharged through a nozzle
                     surrounded by heated combustion air. High-pressure jets are used to prevent
                     fuel-air streams from short circuiting. The firing system produces a looping
                     flame with hot gases discharging at the center (see Figure 11).18
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                                    Figure 11: Flow Pattern of Arch Firing
                                        Upper
                                        Front
                                        (or Rear)
                                        Wall
              High Pressure
              Jet Air
                Primary Air and
                Pulverized Coal
                 Secondary Air
                    Arch
                                                              Tertiary Air
                                                              Admission
                                                           "U"-Shaped
                                                           Vertical
                                                           Pulverized-Coal
                                                           Flame
                                             Furnace Enclosure
                                             (Refractory Lined)
                           Source: Standard Handbook of Power Plant Engineering. Elliot,
                           Thomas C. ed. McGraw-Hill, Inc. New York, NY.  1989.
                           Reproduced with permission of the McGraw-Hill Companies.
          Fluidized-Bed Combustors
                     In fluidized-bed combustors, fuel materials are forced by gas into a state of
                     buoyancy. The gas cushion between the solids allows the particles to move
                     freely, thus flowing like a liquid.  By using this technology, SO2 and NOX
                     emissions are reduced because an SO2 sorbent, such as limestone, can be used
                     efficiently. Also, because the operating temperature is low, the amount of
                     NOX  gases  formed  is  lower than  those  produced  using conventional
                     technology.

                     Fluidized-bed combustors are divided into two  categories: circulating
                     fluidized-beds and bubbling fluidized-beds (see Figure 12). Fluidized-bed
                     combustors can operate at atmospheric pressure or in a pressurized chamber.
                     In the pressurized chamber, operating pressures can be 10 to 20 times the
                     atmospheric pressure. Pressurized fluidized-bed furnaces provide significant
                     gain in overall thermal efficiency over atmospheric fluidized-bed furnances.19
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                               Figure 12:  Typical Bubbling Fluidized-Bed Boiler
                               Secondary
                               Superheater
                              Water-Cooled
                                 Walls
                                Top of Bed

                                 Bubbling
                                   Bed
                                                             Primary Superheater

                                                             Economizer
                                                                     Dust Collector
                        Superheater and
                         Boiling Surface

                                         Distributor
                                           Plate   Windbox
                          Source: Adapted from Steam, Its Generation and Use; 40th Edition.
                          Stultz and Kitto, eds. Babcock and Wilcox, Barbeton, OH. 1992.
                          Reproduced with permission from the Babcock and Will Cox. Co.

                     Fluidized-bed combustion allows for the use of high sulfur coals,  high
                     fouling and slagging fuels, and low British Thermal Unit (BTU) fuels. High
                     ash coals burned hi fluidized-beds require less preparation than hi pulverized
                     coal  combustors.   Additionally, fiuidized-bed  combustors require less
                     maintenance than pulverized coal combustors.

          III.A.2    Internal Combustion Generation

                     Internal combustion generating units, also known as diesel engines, have one
                     or more cylinders in which fuel combustion occurs.  Internal combustion
                     generating units convert the chemical energy of fuels into mechanical energy
                     in a  design similar to an automobile engine.  Attached to the shaft of the
                     generator, the engine provides the mechanical energy to drive the generator
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                    to produce electricity. Internal combustion generating units for power plants
                    are typically designed to operate on either four- or two-stroke cycles.

                    Internal combustion generators are small and range in capacity from 2 to 6
                    megawatts.  They are more efficient than gas turbines.20 In addition, capital
                    costs are low, they are easily transported, and they can generate electricity
                    almost immediately upon startup.  For this  reason, internal combustion
                    generators are often used for small loads and for emergency power.21

          III.A.3   Gas Turbine Generation

                    Gas turbine systems operate in a manner similar to steam turbine systems
                    except that combustion gases are used to turn the turbine blades instead of
                    steam. In addition to the electric generator, the turbine also drives a rotating
                    compressor to pressurize the air, which is then mixed with either gas or liquid
                    fuel in a combustion chamber. The greater the compression, the higher the
                    temperature and the efficiency that can be achieved in a gas turbine.  Exhaust
                    gases are emitted to the atmosphere from the turbine. Unlike a steam turbine
                    system,  gas turbine systems do not  have boilers  or  a steam  supply,
                    condensers, or a waste heat disposal system.  Therefore, capital costs are
                    much lower for a gas turbine system than for a steam system.

                    In electrical power applications, gas turbines are typically used for peaking
                    duty, where rapid startup and short runs are needed.  Most installed simple
                    gas turbines with no controls have only a 20- to 30-percent efficiency. Figure
                    13 presents a schematic of a simple gas turbine system.

                                    Figure 13: Simple Gas Turbine Cycle
                                              Fuel
                                    Compressor
                                        Exhaust
            Turbine
                                                                  Generator
                         Source: Standard Handbook of Power Plant Engineering.  Elliot,
                         Thomas C. ed. McGraw-Hill, Inc. New York, N.Y. 1989.
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          III.A.4   Combined-Cycle Generation

                    Combined-cycle generation is a configuration using both gas turbines and
                    steam generators.  In a combined-cycle gas turbine (CCGT), the hot exhaust
                    gases of a gas turbine are used to provide all, or a portion of, the heat source
                    for the boiler, which produces steam for the steam generator turbine. This
                    combination increases the thermal efficiency over a coal- or oil- fueled steam
                    generator. The system has an efficiency of about 54 percent, and the fuel
                    consumption is approximately 25 percent lower.  Combined-cycle systems
                    may have multiple gas turbines driving one steam turbine (see Figure 14).22

                               Figure 14: Combined Cycle with Heat Recovery
                                                               •Cooling Water {In)
                                                               Cooling Walw (out)
                                                Tnln
                                      ••ExhauatGa*
                    There are four major classifications of combined-cycle facilities:

                    •   Gas Turbine Plus Unfired Steam Generator:  A steam generator is
                        installed at the discharge of a gas turbine to recover the heat in the gas
                        turbine exhaust so as to create steam in the steam generator.  The fuel is
                        fired only hi the gas turbine.
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                     •   Gas Turbine Plus Supplementary-Fired Steam Generator: A portion
                        of the oxygen in the gas turbine exhaust is used to support further
                        combustion in a supplementary firing system in the connecting duct
                        between the gas turbine and the steam generator.

                     •   Gas Turbine Plus Furnace-Fired Steam Generator: This generator is
                        the same as the gas turbine plus supplementary-fired steam generator,
                        except that essentially all of the oxygen from the gas turbine exhaust is
                        used to support further combustion.

                     •   Supercharged Furnace-Fired Steam Generator Plus Gas Turbine:
                        A steam  generator is placed between the air compressor and the gas
                        turbine. The air compressor is used to pressurize the boiler where the fuel
                        is fired. The products of combustion that have been cooled within the
                        boiler are then discharged through a gas turbine.

                     In addition, integrated coal gasification combined-cycle (IGCC) units are
                     combined systems that are in the demonstration stage, but are expected be in
                     commercial operation by the year 2000. In an IGCC system, coal gas is
                     manufactured and cleaned in a "gasifier" under pressure, thereby reducing
                     emissions  and particulates. The coal gas then is combusted in a CCGT
                     generation system.
          III.A.5   Cogeneration
                    Cogeneration is the merging of a system designed to produce electric power
                    and a system used for producing industrial heat and steam. Cogeneration
                    accounted for 75 percent of all nonutility power generation in 1995.23 This
                    system is a more efficient way of using energy inputs and allows the recovery
                    of  otherwise wasted  thermal  energy  for use in an industrial process.
                    Cogeneration technologies are classified as "topping cycle" and "bottoming
                    cycle" systems, depending on whether electrical (topping cycle) or thermal
                    (bottoming cycle) energy is derived first.

                    Most Cogeneration systems use a topping cycle. This is shown as a steam
                    turbine topping system in Figure 15. The process steam shown in Figure 15
                    is condensed as it delivers heat to an industrial process, and the resulting
                    return condensate is returned back to the boiler as shown.

                    Facilities that cogenerate may be eligible for QF status under PURPA. To
                    qualify, the facility must produce electric energy and "another form of useful
                    thermal energy  through  sequential  use of energy," and meet  certain
                    ownership, operating, and efficiency criteria established by FERC (See 18
                    CFR Part 292). In a topping cycle system, the fuel is used to generate power
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Fossil Fuel Electric Power Generation
    Section III. Industrial Process Description
                     with a steam boiler or gas turbine cycle combustor.  The waste heat from the
                     power generation process is then used in an industrial process.24

                                   Figure 15: Cogeneration Plant Schematic
                                 Boiler
                                                                       Generator
                                     Return condensate
                    Source: Standard Handbook of Power Plant Engineering. Elliot, Thomas C. ed.
                    McGraw-Hill, Inc. New York, NY. 1989.  Reproduced with permission of the
                    McGraw-Hill Companies.

           III.A.6    Supporting Operations

                     Many operations  associated with fossil  fuel electric power generation
                     facilities are not directly involved in the production of electricity but serve
                     in a supporting role. This section discusses some of the major supporting
                     processes.

           Coal Processing

                     Fifty-seven percent of coal used in power plants is transported from mines by
                     rail.25 Coal is also transported by truck and barge.  Once coal arrives at the
                     plant, it is unloaded to live storage, dead storage, or directly to the stoker or
                     hopper. Live storage is an enclosed silo or bunker next to conveyors leading
                     to the pulverizer. Dead storage is exposed outdoors and is the backup supply.
                     Coal unloading devices depend on the size and type of plant.  Coal arriving
                     by rail may be unloaded directly into the storage area or to conveyors leading
                     directly to generation units. Coal arriving by barge is unloaded by buckets,
                     which are part of coal towers or unloading bridges.26 Coal shipped by truck
                     generally needs little equipment for unloading.
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                     Precautions must be taken in the transportation and storage of coal.  In
                     transporting coal during warmer months and in dry climates, dust suppression
                    . may be necessary. Dust suppression is typically accomplished through the
                     use of water, oil, or calcium chloride (CaCl2). In winter months, antifreeze
                     chemicals are applied to the coal.  Because coal oxidizes easily in open air,
                     it should be stored in layered piles to minimize air flow. Hot areas should be
                     removed from the pile to prevent fire;  water should not be added to reduce
                     the heat, since the water increases the air flow and, therefore, would increase
                     the oxidation of the coal.

                     Coal may be cleaned and prepared before being either crushed or pulverized.
                     Impurities in coal, such as ash, metals, silica, and sulfur, can cause boiler
                     fouling and slagging. Coal cleaning can be used to reduce sulfur in the coal
                     to meet sulfur dioxide (SO2) emissions regulations.  Cleaning the coal is a
                     costly process that increases its fuel efficiency, yet reduces the size of the
                     particles. Coal cleaning is typically performed at the mine by using gravity
                     concentration, flotation, or dewatering methods. Some smaller stoker plants
                     purchase pre-cleaned, pre-crushed coal.27

                     Coal is transported from the coal bunker or silo to be crushed, ground, and
                     dried further before it is fired in the burner or combustion system.  Many
                     mechanisms can be used to grind the coal  and  prepare  it for firing.
                     Pulverizers, cyclones, and stokers are all used to grind and dry the coal.
                     Increasing the coal's particle surface area and decreasing its moisture content
                     greatly increases its heating capacity. Once prepared, the coal is transported
                     within the system to the combustion system, or boiler. Devices at the bottom
                     of the boilers catch ash and/or slag.
          Air Pollution Control Processes
                     Air pollution control devices found in fossil fuel-fired systems (particularly
                     steam electric power facilities) include particulate removal equipment, sulfur
                     oxide (SOx)  removal equipment,  and nitrogen oxide (NOx) removal
                     equipment. Particulate removal equipment includes electrostatic precipitators,
                     fabric filters,  or mechanical particulate collectors, such as cyclones.  SOX
                     removal equipment includes sorbent injection technologies and wet and dry
                     scrubbers. Both types of scrubbers result in the formation of calcium sulfate
                     and sulfite as waste products.  NOX emission control systems include low
                     NOX burners and selective catalytic or non-catalytic reduction technologies.
                     The  selective catalytic and non-catalytic  reduction technologies convert
                     oxides of nitrogen into nitrogen gas and water.
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          Other Processes to Mitigate Environmental Impacts

                     Control technologies are used at many utility  electric power generation
                     facilities to mitigate the environmental impacts of cooling water intake
                     structures. These technologies may include intake screening systems, passive
                     intake system (physical exclusion devices), or fish diversion and avoidance
                     systems. Technologies used to mitigate thermal pollution include cooling
                     towers, cooling ponds or lakes, and sprinklers. Other control technologies
                     may include recycling and reuse equipment for metals recovery; evaporators;
                     and physical, chemical, and biological wastewater treatment.

III.B     Raw Material Inputs and Pollution Outputs

                     The primary raw material used in fossil fuel electric power generation is the
                     fossil fuel needed as the energy source to drive the prime mover (i.e.,
                     turbine). Fossil fuels employed in the United States predominantly include
                     coal, petroleum, and gas.  Other inputs include water (for cooling and steam
                     generation) and chemicals used for equipment cleaning and maintenance.
                     Pollution outputs include solid waste pollution, wastewater pollution, air
                     pollution, and thermal pollution. The following subsection discusses the
                     major sources of raw materials and the sources of emissions associated with
                     the power generation industry.

          III.B.l    Fossil Fuels and Other Raw Material Inputs

                     The major types of fossil fuels used for electricity generation in the United
                     States are coal, petroleum, gas.  Other fossil fuels used include petroleum
                     coke, refinery gas, coke oven gas, blast furnace gas, and liquefied petroleum
                     gas. These latter fuels are used much less frequently and, therefore, will not
                     be discussed in this notebook.
          Coal
                     Coal is the most abundant fossil fuel in the United States and the most
                     frequently used energy source for U.S. electricity generation. More than one-
                     half of all electricity generated by utilities comes from coal-fired facilities.28
                     Although the use of coal has decreased since the 1970s, some areas of the
                     country use coal almost exclusively.

                     Coals used for electric power generation are very heterogeneous and. vary in
                     content, depending on the location of the mine. The major chemical makeup,
                     which includes carbon, hydrogen, and oxygen, also contains impurities, such
                     as minerals and sulfur.  These impurities are a major concern because they
                     contribute to the pollutants produced during combustion of the coal.
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                     Of all the fossil fuel used for electricity generation, coal requires the most
                     extensive processing, handling, storage, and loading and unloading facilities.
                     Coal firing requires the use of crushers, pulverizers, ash handling equipment,
                     dust control, emissions control equipment, and soot blowers.
           Petroleum
           Gas
                     Petroleum, or crude oil, is the source of various fuel oils used as the energy
                     source for power generation.  As an energy source, petroleum accounts for
                     less than five percent of all electricity receipts in the United States.  However,
                     numerous utilities in the New England  States, New York, Florida, and
                     Hawaii still rely on petroleum as an energy source.29

                     Most petroleum used for power generation is refined prior to use.  Typical
                     fuel oils include fuel oil numbers 4, 5, and 6 (heavy oil) and constitute the
                     majority of all petroleum receipts at electric utilities. Smaller amounts of fuel
                     oil number 2 (light oil) are used typically for startup and flame stabilization
                     of the boilers.30 Other less frequently used sources include topped crude,
                     kerosene, and jet fuel.

                     Fuel oils used for electricity generation require special handling, storage, and
                     loading and unloading facilities. Oil requires ash handling equipment, dust
                     control, emissions control equipment,  soot blowers, and, in some  instances,
                     wanning and heating facilities.
                     Gas is used less than coal as a primary fuel source at power generation
                     utilities.   Gas is widely  used  for  industrial electric power generation,
                     however. Gas is used in those areas of the United States where it is readily
                     accessible or in States in which environmental laws for air emissions are
                     stringent (e.g., California).  Many of the facilities that use gas  also use
                     petroleum in dual-fired generating units. The use of one fuel over the other
                     is based on economics.

                     Natural gas must be treated to  produce commercial fuel.  Natural gas
                     comprises primarily methane and ethane. Natural gas suitable for use as a
                     fuel in power generation facilities must be at least 70-percent methane,
                     60-percent propane, or 25-percent hydrogen.  The fuel may come in either a
                     gaseous or liquid form.31

                     Gas has one advantage over other fuels in that it is a cleaner burning fuel.
                     Therefore,  some electric  utilities  use gas  in  order to  comply with
                     environmental regulations.  Gas used for generating electricity requires
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Fossil Fuel Electric Power Generation
    Section HI. Industrial Process Description
                    relatively little special handling (piping) and may or may not require storage
                    facilities.
          Other Inputs
                    In addition to fossil fuels, electric power generation requires other material
                    inputs. These inputs include (1) water for steam condensation and equipment
                    cooling, (2) lime or limestone, as a sorbent for pollution control equipment,
                    (3) chlorine and/or biocides to prevent biofouling of steam condensers and
                    cooling towers,  (4) chemical solvents,  oils, and lubricants for equipment
                    cleaning and maintenance.
          HI.B.2   Pollutant Outputs
                    Pollutants are generated as byproducts from the burning of fossil fuels to
                    generate electricity.   The combustion process releases highly regulated
                    pollutants, such as NOX, carbon monoxide (CO), particulate matter (PM),
                    SO2, volatile organic compounds (VOCs), organic hydrocarbons, and trace
                    metals, into the air.  Combustion waste, the majority of which is ash waste,
                    is created during combustion processes  using coal or oil for fuel. Non-
                    combustion wastes, such as cooling, process, and storm waters,  that are
                    discharged from  fossil fuel electric power generation facilities have the
                    potential to release pollutants (e.g.,  chlorine, heavy metals, and thermal
                    pollution) into surface waters. The following discussion highlights each of
                    the waste streams created during the generation of fossil fuel electric power.
          Air Emissions
                     Air emissions from the stack gases from coal- and oil-fired boilers include
                     four of six criteria pollutants regulated through the National Ambient Air
                     Quality Standards (NAAQS) under the Clean Air Act (CAA) as amended:
                     NOX, CO, SO2, and PM.  Amounts of SO2 emitted depend largely on the
                     amount of sulfur present in the coal or oil and the method used to generate
                     steam.

                     Other emissions regulated by  the CAA commonly contained in emission
                     gases are total organic carbon (TOC) as methane, non-methane hydrocarbons
                     (NMHC), and VOCs. Traces  of lead, another criteria pollutant,  and other
                     metals and minerals are also found.  These metals are present in the coal and
                     oil. Sulfur is also found in these fuels (more in coal than in oil), and fly ash
                     is the product of sulfur and other mineral materials that do not combust.

                     Fugitive dust from coal piles and fuel handling equipment is another source
                     of participates.  In addition, fugitive emissions of VOCs can arise  from coal
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     Section III. Industrial Process Description
                     piles during low temperature devolatilization.  Thermal rise plumes are also
                     discharged from cooling towers. These plumes contain such pollutants as heat
                     and some trace materials in the water vapor.

                     Compared to a fossil-fueled steam turbine generating system with no air
                     pollution controls, a gas-fired power generation system with no controls
                     emits less tonnage of NOX and SO2 and trace amounts of TOC, particulate
                     matter, and CO.

                     Combined-cycle gas turbines have virtually no SO2 emissions because of the
                     purity of natural gas. Because oil and coal are not used, solid waste is
                     eliminated, and CO2, NOX, and thermal pollution are cut by 60 percent.

                     Cogeneration is considered a pollution prevention technology. Other benefits
                     of cogeneration are reduced fuel consumption and lower air emissions.
                     Because of their smaller size, however, cogeneration systems in the United
                     States tend to have lower stack heights.  Therefore, air emissions to the
                     immediate atmosphere contribute to increased local pollution.

           Combustion Wastes

                     Two principal wastes are associated with the combustion of fossil fuels: ash
                     waste and flue gas desulfurization (FGD) wastes. The quantities of these
                     wastes generated depend upon the fossil fuel burned.

                     Ash waste -Two types of ash are generated during combustion of fossil fuels:
                     bottom ash and fly ash. Ash that collects at the bottom of the boiler is called
                     bottom ash and/or slag. Fly ash is a finer ash material that is borne by the
                     flue gas from the furnace to the end of the boiler. Bottom ashes are collected
                     and discharged from the boiler, economizer, air heaters,  electrostatic
                     precipitator, and fabric filters.  Fly ash is collected in the economizer and air
                     heaters or is collected by the particulate  control equipment.  Coal-fired
                     facilities generate the largest quantity of ash; gas facilities generate so little
                     that separate ash management facilities are not necessary.   Fly and bottom
                     ash may be managed separately or together in landfills or in wet surface
                     impoundments.

                     Ashes differ hi characteristics depending upon the content of the fuel burned.
                     For coal, the chemical composition of ash is a function of the type of coal
                     that is burned, the extent to which the coal is prepared before it is burned, and
                     the operating conditions of the boiler.  These factors are very plant- and coal-
                     specific.  Generally, however, more than 95 percent of ash is made up of
                     silicon, aluminum, iron, and calcium in their oxide forms, with magnesium,
                     potassium, sodium,  and titanium  representing the  remaining  major
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                    constituents. Ash may also contain a wide range of trace constituents in
                    highly variable concentrations. Potential trace constituents include antimony,
                    arsenic, barium, cadmium, chromium, lead, mercury, selenium, strontium,
                    zinc, and other metals.

                    Flue gas desulfurization waste - If coal or oil is the fuel source, the FGD
                    control technologies  result in  the  generation of solid wastes.   Wet
                    lime/limestone scrubbers produce a slurry of ash, unreacted lime, calcium
                    sulfate, and calcium sulfite. Dry scrubber systems produce a mixture of
                    unreacted  sorbent  (e.g., lime,  limestone, sodium carbonates,  calcium
                    carbonates), sulfur salts, and fly ash. Sludges are typically stabilized with fly
                    ash.   Sludges  produced in a  wet  scrubber  may  be disposed of in
                    impoundments  or below-grade landfills, or  they  may be stabilized  and
                    disposed of in landfills. Dry scrubber sludges may be managed dry or wet.
          Non-Combustion Wastes
                    Non-combustion wastes can be categorized into contact and noncontact
                    wastes.  Contact wastes come in contact with combustion wastes and,
                    therefore, contain the same constituents as the combustion wastes. In many
                    cases, these contact wastes are managed with the combustion wastes. Non-
                    contact wastes do not come in contact with ashes or FGD wastes and may be
                    managed separately.   Table 13 summarizes the  typical waste streams,
                    potential pollutants, and ways of managing these pollutants. Figure 16 shows
                    where the waste streams are generated at a typical steam electric power plant.
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Table 13: Summary of Typical Waste Streams and Pollutants Generated at Fossil Fuel Electric
Power Generation Facilities Based on Fuel Type
Fuel Type Wastes/Pollutant
Coal
Oil
Gas
Process wastes
Pollutants
Process wastes
Pollutants
Process wastes
Pollutants
Air Emissions
Flue gas and heat -
thermal rise plume.
SO2, NOX, CO2, CO
(more from small
boilers), VOCs, TOC,
PM, metals, sulfur.
Flue gas and heat -
thermal rise plume.
Low SO2, NOX (as NOX
particulate), CO2 ,
sulfur, and PM
compared to coal.
Metals and TOC.
Flue gas.
Low Nox, and SO2
compared to oil and
coal. Thermal pollution
is 60% less than coal.
Combustion Wastes
Bottom ash, fly ash, and
FGD wastes
desulfurization, and fly
ash.
Heavy metals, ferrous
sulfate, sulfuric acid,
sulfate, CaSO3, and CaO.
Bottom ash and fly ash.
VOCs and heavy metals.
None.
None.
Non-Combustion Wastes
Contact*: ash transport, gas-side boiler
cleaning,* FGD blowdown, coal pile
runoff, pyrite waste, floor drains.
Noncontact: once-through cooling
water,* cooling system blowdown,*
boiler blowdown,* water-side boiler
cleaning,* demineralizer regenerent.*
Chlorine, organic chemicals, metals,
pH, TSS, TDSS, ferrous sulfate,
sulfuric acid, metals, pyrite.
Contact*: ash transport, gas-side boiler
cleaning,* FGD blowdown, floor
drains.
Noncontact: once-through cooling
water,* cooling system blowdown,*
boiler blowdown,* water-side boiler
cleaning,* demineralizer regenerent.*
Chlorine, organic chemicals, metals,
pH, TSS, TDSS, ferrous sulfate,
sulfuric acid, metals.
Contact*: infrequent gas-side boiler
cleaning,* floor drains.
Noncontact: once-through cooling
water,* cooling system blowdown,*
boiler blowdown,* water-side boiler
cleaning,* demineralizer regenerent.*
Chlorine, organic chemicals, metals,
pH, TSS, TDSS, metals.
* Waste streams at facilities with steam turbines. t In contact with combustion wastes.
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    Section III. Industrial Process Description
          Figure 16:  Waste Streams Generated at a Typical Fossil Fuel Electric
                                 Power Generation Plant
                                   Fugitive Oust
                                                                               Flue Gas ,
                                                Note; SOT-Selectlve Catalytic
                                                   Reduction DeNO. System
                                                   FGD-FlueGas
                                                   Desulfurlzatlon System
                           FGD Byproduct
                            Gypsum or
                           Landfill Sludge
                                                                                   Low
                                                                                   Volume
                                                                                   Wastes
 Source: Adapted from Steam, Its Generation and Use, 40th Edition.  Stultz and Kitto, eds.
 Babcock and Wilcox, Barbeton, OH. 1992. Reproduced with permission from the Babcock and
 Wilcox Co.
                     Contact Non-Combustion Wastes

                     Metal and boiler cleaning waste (gas-side) - Gas-side metal and boiler
                     cleaning wastes are produced during maintenance of the gas-side of the
                     boiler, including the  air preheater, economizer,  superheater,  stack, and
                     ancillary equipment. Residues from coal combustion (soot and fly ash) build
                     up on the surfaces of the equipment and must be removed periodically. This
                     buildup is typically removed with plain, pressurized water containing no
                     chemical additives.  Wastewaters are sometimes neutralized and metals
                     precipitated.  At coal plants, the wastewater is most often put into the ash
                     ponds without treatment.

                     Ash transport wastewater - Ash produced from the combustion of coal or
                     oil is typically collected in a sluice water that is then sent to settling ponds for
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     Section III. Industrial Process Description
                     disposal.  The  ash settling pond discharge may contain  dissolved and
                     suspended solids, heavy metals (nickel, iron, vanadium),  organometalic
                     compounds, and magnesium compounds when magnesium oxides are used
                     for corrosion control.

                     Flue gas desulfurization blowdown - Slowdown from FGD systems is
                     discharged when the recycled liquor begins to build up chlorine.  The
                     discharge contains calcium sulfate, calcium chloride, and sodium chloride.
                     Depending upon fly ash carryover, the wastewater may contain metal ions.

                     Coal pile runoff- Open storage of coal allows contact with rain and/or other
                     precipitation.  These storm waters react  with the minerals in the coal to
                     produce a leachate contaminated with ferrous sulfate and sulfuric acid. The
                     lowpH of the leachate reacts with the coal, thereby accelerating dissolution
                     of metals in the coal.

                     Pyrite waste - Coal mills or pulverizers reduce the size of the feed coal going
                     into the boiler.  During this process, various impurities, such as  hard coal,
                     rocks, and pyrites (an iron-based mineral), are mechanically separated from
                     the feed stream. This solid waste is typically collected and fed into the
                     bottom ash transport system and eventually co-disposed with the ash in either
                     a landfill or an impoundment.

                     Floor drains -  Floor and yard drains collect rainfall, seepage, leakage
                     wastewaters from small equipment cleaning operations, process spills, and
                     leaks. As a result, the pollutants found in the wastewaters are variable. The
                     waste streams may contain coal dust,  oil, and detergents.

                     Noncontact. Non-combustion Wastes

                     Once-through cooling water - When a steam turbine is used to drive the
                     electric generator the process is called "steam electric."  Steam electric units
                     require large amounts of cooling water for steam condensation and efficient
                     thermal operation. The cooling water flow rate through the condenser is by
                     far the largest process water flow, normally equating to about 98 percent of
                     the total process water flow for the entire unit, hi a once-through cooling
                     water system, water is usually taken into the plant from surface waters, but
                     sometimes ground  waters or municipal supplies are  used.  The water is
                     passed through the condenser where it absorbs heat and is then discharged to
                     a receiving water. Chlorine, which is added intermittently to the cooling
                     water to control biofouling,  is a pollutant of concern  in cooling  water
                     discharge.  Heat is also a concern.
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                    Cooling tower blowdown - Cooling water is recirculated when the water
                    supply is inadequate to sustain a once-through system or when thermal
                    discharges are regulated or undesirable, ha a system that recirculates cooling
                    water, heat from the water is transferred to  the atmosphere via cooling
                    towers, cooling ponds, or spray facilities.  The recirculated water eventually
                    builds up dissolved solids and suspended matter.  Cooling tower blowdown
                    (a percentage of the recirculated water) is discharged regularly and additional
                    fresh makeup water is treated and added into the recirculating system to
                    relieve this buildup of solids.   Pollutants of concern in cooling tower
                    blowdown discharges include chlorine, organic chemicals, and trace metals
                    from biofouling and corrosion control.

                    Boiler blowdown - Water to make steam may be recirculated and eventually
                    build up impurities in the boiler. This water is periodically purged from the
                    system.  Boiler blowdown is typically alkaline, is low in total dissolved
                    solids, and contains chemical additives used to control scale and corrosion.
                    Blowdown also contains trace amounts of copper, iron, and nickel.

                    Metal and boiler cleaning waste (water-side) - Metal cleaning wastes are
                    produced during cleaning of the boiler tubes, superheater, and condenser
                    located on the water-side or steam-side of the boiler.  Scale and corrosion
                    products build up in the boiler and must be removed with chemical cleaning
                    using an acid or alkaline solution.  The composition of the waste solvents
                    depends  on the construction material of the feedwater system, but largely
                    consists  of iron with lesser amounts of copper, nickel,  zinc, chromium,
                    calcium,  and magnesium. Spent solvents may be treated in numerous ways:
                    (1) neutralization and then discharge, (2) evaporation in other operating
                    boilers onsite, (3) dedicated holding ponds, (4) mixing with rinsate and
                    sending to ash impoundments, or (5) disposal offsite.

                    Demineralizer Regenerant - Boiler systems may require treatment of boiler
                    makeup water prior to use. Ion exchange resins used in the treatment of the
                    water accumulate cations and anions removed from the raw water.  These
                    resins are regenerated using a strong acid, such as sulfuric acid, or a strong
                    base, such as sodium hydroxide.  Regenerant wastes contain dissolved ions
                    removed from the raw wastewater and excess acid or base. Often, the waste
                    is directed into the ash impoundment for disposal or to a settling pond with
                    other liquid wastes prior to discharge.
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Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
IV.        WASTE RELEASE PROFILE

                     This section provides estimates and reported quantities of wastes released
                     from the fossil fuel electric power generation industry. Currently, this
                     information is not available from the Toxics Release Inventory (TRI) under
                     the  Emergency Planning and Community Right-to-Know Act (EPCRA).
                     However, regulations promulgated on May 1,1997, would require facilities
                     that combust coal and/or oil for the purpose of generating power for
                     distribution in commerce to begin reporting in 1999 (for the period from
                     January 1 to December 31, 1998). Because TRI reporting is not currently
                     required, other sources of waste release data have been identified for this
                     profile.

                     This section comprises three subsections. The first section provides available
                     data on releases of solid wastes from fossil fuel electric power generation
                     facilities. The second section provides available data on releases to surface
                     waters.  A third section provides available data on releases of criteria
                     pollutants and hazardous pollutants to the air.

IV.A      Available Solid Waste Release Data for the Fossil Fuel Electric Power Generation
           Industry

                     As described previously, the primary solid waste releases from coal- and oil-
                     fired steam electric facilities are fly ash and bottom ash produced during the
                     combustion process. An increasing number of facilities must condition flue
                     gases to remove sulfur compounds, which results in the generation of another
                     solid waste typically referred to as FGD sludge. The following tables present
                     aggregated ash and FGD sludge generation estimates for utility and nonutility
                     steam electric facilities.

                     Table 14 presents the estimated quantity of fly and bottom ash (combined)
                     for utility boilers in 1994.  Coal ash figures have been derived from 1994
                     DOE, EIA Form EIA-767 utility survey responses. These responses are
                     compiled by the Edison Electric Institute (EEI) hi their Power Statistics
                     Database.32 The oil ash figures  were developed by the Electric Power
                     Research Institute (EPRI) based on utility-provided estimates, as well as
                     extrapolations  based  on oil consumption  and  particulate collection
                     efficiencies for individual plants. Gas-fired facilities are not presented in the
                     table because gas combustion does not generate measurable quantities of
                     particulate ash. In general, coal-fired utilities produce  ash at approximately
                     10 percent of the fuel consumption rate.  This high rate  of production
                     confirms that ash  management  can represent  an important operational
                     consideration at coal plants. In contrast, oil-fired utilities produce much less
                     than 0.1 percent of the total ash produced by the coal-fired facilities. This
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                    figure reflects the low ash content of oil compared with coal, the typically
                    lower requirements for particulate collection devices at coal-fired facilities,
                    the small average particle size of oil ash, and the small contribution that oil
                    currently makes to total U.S. electricity generation.
Table 14: Generation and Disposition of Utility Fly and Bottom Ash, 1994 (thousand short tons)
Fuel Type
Coal*
Coal/Gas
Coal/Nuclear
Coal/Oil
CoatfOil/Gas
Coal/Wood
Subtotal Coal
OH"
Totals
Number
of
Plants
404
32
2
26
2
1
467
73
540
Quantity
Sold
12,122
830
279
368
1
0
13,600
n/a
13,600
Quantity
Removed by
Contractor
8,762
546
0
401
41
0
9,750
n/a
9,750
Quantity
Landfilled
24,849
636
0
303
45
0
25,833
n/a
25,833
Quantity
Ponded
19,929
133
26
470
0
0
20,558
n/a
20,558
Quantity
Used Onsite,
Given Away,
or Disposed
of in Other
Ways
4,014
83
29
180
0
0
4,306
n/a
4,306
Total
Quantity
Collected
for the
Record
Year (1994)
69,676
2,228
334
1,722
87
0
74,047
23
74,070
* Coal ash values provided in EEI Power Statistics Database (1994 Data). Prepared by Utility Data Institute, McGraw-Hill,
Washington, DC. 1995. Plants include only those reporting coal as primary or secondary fuel. Includes 88 facilities
reporting zero waste generation: 26 facilities reported zero fuel consumption and 62 facilities did not exceed the capacity
and/or ash generation reporting thresholds for the DOE EIA 767 Survey.
" Oil ash values are for 1995. Source: Oil Combustion By-Products - Chemical Characteristics and Management
Practices: Draft Report. Electric Power Research Institute, Palo Alto, California. March 1997.
                     Table 14 also indicates the range of management options employed by
                     utilities in managing coal ash. While the figure varies considerable between
                     operators and sites, roughly one-third of all U.S. utility coal ash finds its way
                     to  some type of beneficial use project.  Of the material remaining in
                     traditional disposal environments, the majority is  managed  in  onsite
                     impoundments or  landfills.   These units  vary  in size,  design,  and
                     environmental controls, depending on the age, the State, and the operator.

                     Table 15 presents similar findings for utility FGD sludge generation and
                     management. Again, the data reflect utility responses to the Form EIA-767,
                     as compiled by EEI in the Power Statistics Database. Note that there are no
                     oil-fired utility boilers equipped with FGD scrubbers. The quantity of FGD
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 Fossil Fuel Electric Power Generation
   Section IV. Chemical Releases and Transfers
                     sludge generated at a given plant is a function of the sulfur content of the coal
                     consumed, the total  quantity of coal consumed, the type of scrubber
Table 15: Generation and Disposition of Utility FGD Sludge, 1994 (thousand short tons)
Fuel Type
Coal
Coal/Gas
Coal/Nuclear
Coal/Oil
Coal/Oil/Gas
Coal/Wood
Totals
Number
of
Plants
71
4
0
2
1
0
78
Quantity
Sold
118
106
0
18
0
0
242
Quantity
Removed by
Contractor
759
6
0
5
0
0
770
Quantity
Landfilled
8,286
479
0
55
33
0
8,853
Quantity
Ponded
4,082
0
0
0
0
0
4,082
Quantity
used onsite,
given away,
or disposed
of in other
ways
708
5
0
0
0
0
713
Total
Quantity
Collected
for the
record year
(1994)
13,953
596
0
78
33
0
14,660
Source: EEI Power Statistics Database (1994 Data). Prepared by Utility Data Institute, McGraw-Hill, Washington, DC.
1995.
                     employed, the efficiency of reaction of the scrubber, and other factors. The
                     majority of FGD sludge is managed in onsite landfills or impoundments.

                     Table 16 presents an estimate of the 1990 coal ash generation by nonutility
                     fossil fuel combustors, broken out by major industrial category. Based on
                     EPA Office of Air and Radiation's 1990 Paniculate Inventory Database
                     (Version  3), the ash figures are derived from the estimated 1990 coal
                     consumption and coal ash content for the boiler  population.   The table
                     includes all coal combustors permitted as major sources of criteria pollutants
                     under the CAA and, therefore, includes many combustors that do not produce
                     electricity. The electric generators, however, may be expected to represent the
                     largest of the nonutility combustors and the greatest portion of the fuel usage
                     by that population, such that the estimates shown provide at  least a fair
                     picture of the ability of the population to generate ash.

                     Compared with the utility coal ash estimates presented above, the nonutility
                     universe represents only roughly 5 percent of the total U.S. ash  generation.
                     This fact reflects the generally small boiler size and the small aggregate coal
                     consumption represented by nonutility combustors. Two industry categories,
                     paper and chemicals manufacturing, represent 50 percent of all nonutility
                     coal consumption, with only five industry categories accounting for more
                     than 80 percent of all nonutility coal consumption.
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Fossil Fuel Electric Power Generation
 Section IV. Chemical Releases and Transfers
Table 16: Estimated Nonutility Generation of Coal Ash, 1990
Standard Industrial Classification
2600-2699, Paper and Allied Products
2800-2899, Chemicals and Allied Products
3300-3399, Primary Metals Industries
2000-2099, Food and Kindred Products
4900-4999, Electric, Gas, and Sanitary Services
3700-3799, Transportation Equipment
2200-2299, Textile Mill Products
1400-1499, Mining and Quarrying of Non-Metallic
Minerals, Except Fuels
3800-3899, Measuring, Analyzing, and Controlling
Instruments
3000-3099, Rubber and Miscellaneous Plastic Products
TOTALS (Top Ten Ash Producing SIC Categories)
Percentage of Total Universe
TOTALS (Complete Nonutility universe)
Number of
Facilities
139
116
45
94
29
57
58
7
1
20
566
76
749
Number
of Boilers
243
276
85
151
83
162
101
15
3
37
1,156
79
1,467
Total
Capacity
(MMBTU)
61,348
54,031
20,344
21,391
30,234
14,581
7,272
6,620
1,976
3,779
221,576
89
249,437
Estimated
Ash
Generation
(1,000 tons)
1,189
1,025
500
402
392
125
107
76
66
63
3,945
93
4,263
Source: Nonutility Fossil Fuel Combustion: Sources and Volumes - Revised Draft Report. Prepared for U.S.EPA, Office of
Solid Waste by Science Applications International Corporation, McLean, VA. December 1996.
                     As discussed previously, steam electric facilities may generate a variety of
                     other solid wastes.  These may include boiler and cooling water treatment
                     wastes, coal mill rejects, boiler cleaning wastes, and a variety of smaller
                     waste streams incidental to power generation of ancillary activities.  At coal
                     plants, these waste streams typically are small compared with ash and sludge
                     generation.  At oil- and gas-fired plants, they may represent the largest solid
                     wastes present at the site.  Unfortunately, available data sources  do not
                     provide credible estimates of the total quantity of these materials generated
                     at utility and nonutility steam electric sites.
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 Fossil Fuel Electric Power Generation
   Section IV. Chemical Releases and Transfers
 IV.B      Available Water Release Information for the Fossil Fuel Electric Power Generation
           Industry

                     The EPA Office of Water, Office of Science and Technology, Engineering
                     and Analysis Division, has collected water release data in evaluating the need
                     for revisions to the 1982 Effluent Limitations Guidelines and Standards for
                     the Steam Electric Point Source Category.  The EPA has identified 53
                     chemicals (29 priority and 24 nonconventional) as pollutants of interest in
                     wastewaters discharged from steam electric  power generation facilities.
                     These pollutants were identified in the EPA Permit Compliance System
                     (PCS) database.  The PCS is a computerized information management system
                     maintained by the EPA Office of Enforcement. The PCS contains data on
                     permit conditions, monitoring,  compliance, and  enforcement data  for
                     facilities regulated by the National Pollutant Discharge Elimination System
                     (NPDES) Program. The information contained in the database is generally
                     limited to only those facilities that have been classified as "major" by EPA
                     based on factors such as effluent design flow and physical, chemical, and
                     locational characteristics  of the discharge.  Information  on facilities
                     designated as "minor" is not required to be entered into the PCS database.

                     The data collected included 1992 records of pollutant releases from facilities
                     with primary SIC codes 4911 and 4931. Approximately 512 facilities were
                     identified in PCS as "major" steam electric facilities. Please  note that
                     facilities that use nuclear energy to drive steam turbines are also covered in
                     the universe evaluated under this study. An option in the PCS system called
                     Effluent Data Statistics (EDS) was used to generate the annual loading
                     values. For the  purposes of the effluent guideline study, the EDS-derived
                     data were subjected to numerous refinements in an attempt to overcome
                     limitations in the database.  These  refinements included review of the data by
                    monitored facilities, as arranged by the Utility Water Act Group (UWAG)
                    and the EEL  The industry still contends, however, that the loadings of
                    pollutants in these data are over estimated.33  Therefore actual loadings
                    cannot be provided in this Sector  Notebook.

                    Table 17 provides a list of the pollutants found in the  1992 PCS data for
                    steam electric effluents.
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Fossil Fuel Electric Power Generation
 Section IV. Chemical Releases and Transfers
Table 17: List of Pollutants Reported in 1992 PCS Data from Steam Electric Facilities*
Priority
Pollutant






X


X



X
X
X
X
X
X


X
X

X
X

Pollutant
Iron
Chlorine
Aluminum
Boron
Fluoride
Boric Acid
Zinc
Barium
Magnesium
Copper
Ammonia
Iron Sulfate
Manganese
Chromium, trivalent
Nickel
Lead
Arsenic
Chromium
Selenium
Bromine
Hydrogen Sulfide
Chromium, hexavalent
Cadmium
Vanadium
Cyanide
Phenol
Hydrazine
Priority
Pollutant
X
X


X
X
X
X
X




X
X

X


X
X
X
X
X
X
X

Pollutant
Trichloromethane
Beryllium
Ethylene glycol
Nitrosomorphpline, N-
Mercury
Pentachlorophenol
Silver
Thallium
Antimony
Molybdenum
Benzonitrile
Titanium
Polychlorinated biphenyls, NOS
Dichloromethane
Tetrachloroethane
Dibenzofuran
Toluene
Xylene
Lithium
Benzene
Ethylbenzene
Phenanthrene
Pyrene
PCB-1254
PCB-1260
Chlorophenol, 2-

' Based on estimated data supplied by members (representing 80 facilities) of the electric utility industry.
Source: Preliminary Data Summary for the Steam Electric Point Source Category. U.S. Environmental Protection Agency, Office of
Water, Washington, D. C. July 1996. (EPA-921-R-96-010).
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Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
IV.C     Available Air Emissions Data for the Fossil  Fuel Electric  Power Generation
          Industry

                     Three existing sources of data for estimating the releases to the air from the
                     fossil fuel electric power generation industry were identified. The following
                     sections discuss the available data and associated limitations.

          IV.C.l    Annual Emissions Estimated by  the Department  of Energy, Energy
                     Information Administration

                     Emissions data for traditional utility steam electric facilities that generate 10
                     or more megawatts electricity using fossil fuels are  derived or obtained
                     directly from information collected in an annual survey by the DOE EIA.
                     This survey (Form EIA-767) is a restricted-universe census used to collect
                     boiler-specific data from almost 900  electric utility  power plants.   The
                     emissions are calculated based on fuel consumption data and using emission
                     factors  from the EPA report AP-42, Compilation of Air Pollutant Emission
                     Factors and reduction factors for control equipment, where applicable.  The
                     CO2 emissions are estimated using additional information about fuel quality.
                     Table 18 provides the estimated 1995 emissions for utility fossil fuel steam
                     electric generating units that generate 10 or more megawatts electricity.
Table 18: Estimated 1995 Emissions From Fossil Fuel Steam Electric Generating Units at
Electric Utilities by Fuel Type (thousand short tons)
Fuel
Coal
Gas
Petroleum
Net Generation
(thousand megawatts)
1,652,914
307,306
60,844
SO2
11,248
1
321
NOX
6,508
533
92
C02
1,752,527
161,969
50,878
Source: Electric Power Annual 1995, Volume 2. Energy Information Administration, Department of
Energy, Washington, DC. DOE/EIA-0348(95)/2. December 1996.
                    As indicated in the table, the majority of the emissions from utility fossil fuel
                    steam electric generating units come from coal-burning facilities. This is due
                    in part because there is more coal-fired capacity than other fossil-fueled
                    capacity in use. SO2 emissions are higher in coal-burning facilities due to the
                    higher sulfur content in coals than in other fuels. The average sulfur content
                    in coals ranges from 0.3 percent in the West to approximately 2.5 percent in
                    the East.  Petroleum burned at utility power plants ranges from almost no
                    sulfur to about 3.5 percent. The amount of sulfur contained in natural gas is
                    relatively small.
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Fossil Fuel Electric Power Generation         Section IV. Chemical Releases and Transfers

                    The Form EIA-767 does not collect data for facilities employing internal
                    combustion engines, gas turbines, or combined-cycle systems  or steam
                    electric plants generating less than 10 megawatts electricity.   The EIA
                    conducted a study in 1991 to estimate air emissions from these generating
                    units, using a methodology similar to that used on the larger steam electric
                    facilities.  The study indicated that emissions of SO2, NOX, and CO2 are less
                    than 0.1,1.2, and 1.1 percent, respectively, of total utility air emissions.34

                    The EIA collects similar fuel consumption and quality information for
                    nonutility power producers. However, EIA provides only aggregate statistics
                    on estimated emissions for all fuels (fossil and renewable energy sources) and
                    does not separate out emissions for fossil-fueled facilities.  These statistics
                    are not provided in this document since the capacity  of nonutility generation
                    using nonrenewable energy sources is large.

          IV.C.2   AIRS Database Annual Estimated Releases for the Electric Power
                    Generation Industry

                    The Aerometric Information Retrieval System (AIRS) is an air pollution data
                    delivery system managed by the Technical Support Division in EPA's Office
                    of Air  Quality Planning  and  Standards (OAQPS), located  in  Research
                    Triangle Park, North Carolina.  The AIRS is a national repository of data
                    related to air pollution monitoring and control.  It contains a wide range of
                    information related to stationary sources of air pollution, including the
                    emission of a number of air pollutants that may  be of concern within a
                    particular industry.  States are the primary suppliers of data  to AIRS.  Data
                    are used to support monitoring, planning, tracking, and enforcement related
                    to implementation by EPA staff,  the scientific community, other countries,
                    and the general public.  The  following  criteria pollutant  emissions and
                    estimated TRI pollutant release data for the fossil fuel  electric power
                    generation industry were extracted from this database.

          AIRS Estimated Criteria Pollutant Emissions

                    The AIRS database contains data on criteria pollutants: CO, NOX, particulate
                    matter (PM) of 10 microns or less (PM10), total particulate emissions (PT),
                    SO2, and VOCs. Criteria pollutant releases for the fossil fuel electric power
                    generation industry were accessed using SIC codes 4911 and 4931. It should
                    be noted that  accessing the data using SIC  codes does  not allow the
                    segregation of emissions for facilities that use fossil fuels from facilities that
                    use nuclear,  renewable, or a combination of fuels. Therefore, the annual
                    emissions taken from the AIRS database will overestimate the emissions
                    from the fossil fuel subsector of the power generation industry.  Table 19
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Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
                     presents the criteria pollutant data available for this industry.  Pollutant
                     releases for other industries are also included in the table.
Table 19: Annual Air Pollutant Releases (tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay and Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Electronics and Computers
Motor Vehicles, Bodies, Parts and Accessories
Dry Cleaning
Transportation
Metal Casting
Pharmaceuticals
Plastic Resins and Synthetic Fibers
Textiles
Fossil Fuel ElectricPower Generation
Ship Building and Repair
CO
4,670
25,922
122,061
2,754
566,883
8,755
153,294
112,410
734,630
2,200
105,059
1,386,461
214,243
4,925
356
15,109
102
128,625
116,538
6,586
16,388
8,177
366,208
105
NO2
39,849
22,881
38,042
1,872
358,675
3,542
106,522
187,400
355,852
9,955
340,639
153,607
31,136
11,104
1,501
27,355
184
550,551
11,911
19,088
41,771
34,523
5,986,757
862
PM10
63,541
40,199
20,456
2,502
35,030
405
6,703
14,596
27,497
2,618
192,962
83,938
10,403
1,019
224
1,048
3
2,569
10,995
1,576
2,218
2,028
140,760
638
PT
173,566
128,661
64,650
4,827
111,210
1,198
34,664
16,053
36,141
5,182
662,233
87,939
24,654
2,790
385
3,699
27
5,489
20,973
4,425
7,546
9,479
464,542
943
SO2
17,690
18,000
9,401
1,538
493,313
1,684
194,153
176,115
619,775
21,720
308,534
232,347
253,538
3,169
741
20,378
155
8,417
6,513
21,311
67,546
43,050
13,827,511
3,051
voc
915
4,002
55,983
67,604
127,809
103,018
65,427
180,350
313,982
132,945
34,337
83,882
11,058
86,472
4,866
96,338
7,441
104,824
19,031
37,214
74,138
27,768
57,384
3,967
Source: U.S. EPA Office of Air and Radiation, AIRS Database, 1997.
          AIRS Estimated TRI Pollutant Emissions

                    Data were collected from the AIRS database by the EPA Office of Pollution
                    Prevention and Toxics, Environmental Assistance Division, Toxics Release
                    Inventory Branch in support of the TRI  expansion project  discussed
Sector Notebook Project
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Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
                    previously. The data set that was downloaded included the most recent data
                    available for each facility up to and including 1995 data. The data presented
                    in Table 20 are estimates of TRI releases based on air releases reported in the
                    AIRS Facility Subsystem (AFS) from facilities within SIC codes 4911 and
                    4931. The data contain quantities of directly reported TRI chemicals, as well
                    as quantities of additional TRI chemicals extrapolated from reported releases
                    of PM and VOCs. The PM and VOC releases were matched with chemical
                    profiles contained in the SPECIATE database (Version 1.5). The SPECIATE
                    is a computerized format of the EPA Air Emissions Species Manual and is
                    available for download from the Clearing House of Inventory and Emissions
                    Factors (CHIEFs). The data presented are based only on apportionment of
                    "original" species profiles  hi the SPECIATE  database  ~ those species
                    profiles that were developed specifically for the source of the release where
                    it has been applied. Despite the use of only the highest quality profiles hi the
                    SPECIATE database, these data should  only  be used as a preliminary
                    indication of potential releases and not as actual air releases. These data have
                    been provided for illustrative purposes only and should not be used in
                    comparisons with other release data.

          IV.C.3    Hazardous Air Pollutant Emissions Estimates for Fossil Fuel Electric
                    Utility Steam Generating Units

                    Estimates of  hazardous air pollutant (HAP) emissions from fossil fuel
                    electric utility steam generating units have been developed by OAQPS and
                    are reported hi a report entitled, Study of Hazardous Air Pollutant Emissions
                    from Electric Utility Steam Generating  Units - Interim Final Report
                    (Volumes 1-3).35 These estimates are based on emissions test data from 52
                    units obtained from extensive emission tests by the EPRI, DOE, the Northern
                    States Power Company, and EPA. The testing program covered a wide range
                    of facility types with a variety of control scenarios.  Therefore, the data are
                    considered to be generally representative of fossil fuel utility steam electric
                    generating units as a whole.  This study estimated the average annual
                    emissions for each of 684 power plants. A total of 67 HAPs were identified
                    in the emission testing program as  potentially being emitted from these
                    facilities.

                    It should be noted that the report states that because of the small sample sizes
                    for specific boiler types and control scenarios, there are uncertainties in the
                    data. Therefore, the data for individual plants may either underestimate or
                    overestimate the actual emissions.  According to the report, the average
                    annual emissions estimates will be roughly within a factor of plus or minus
                    three of the actual annual emissions.  However,  it is recognized that the
                    analysis had numerous limitations, such as not including data on potential
                    upsets or unusual operating conditions, and it is possible that the range of
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 Fossil Fuel Electric Power Generation
   Section IV. Chemical Releases and Transfers
                     uncertainty is greater.  Tables 21, 22, and 23 present data on estimated
                     inorganic HAPs from coal-fired, oil-fired, and gas-fired utility steam electric
                     facilities.  Tables 24, 25, and 26 present data on estimated organic HAPs
                     from coal-fired, oil-fired, and gas-fired utility steam electric facilities.
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Fossil Fuel Electric Power Generation
 Section IV. Chemical Releases and Transfers
Table 20: Estimated Releases of TRI Chemicals *
CAS
NO.
71556
79005
95636
106934
95501
107062
106990
541731
106467
112345
124174
111900
111773
111762
1 10805
111159
109S64
90437
101779
75070
107028
79107
107131
7429905
7664417
62533
120127
7440360
7440382
1332214
7440393
56553
71432
218019
50328
100447
7440417
92524
7726956
141322
123728
7440439
Chemical Name
1,1,1-Trichloroethane (Methyl chloroform)
1 , 1 ,2-Trichloroethane
1 ,2,4-Trimethylbenzene
1,2-Dibromoethane (Ethylene dibromide)
1 ,2-DichIorobenzene
1,2-Dichloroe thane (Ethylene dichloride)
1,3-Butadlene
1,3-Dichlorobenzene
1 ,4-Dichlorobenzene
2-(2-Butoxyethoxy)ethanol
2-(2-Butoxyethoxy)ethanoI acetate
2-(2-Ethoxyethoxy)ethanol
2-(2-Methoxyethoxy)ethanol
2-Butoxyethanol
2-Ethoxyethanol
2-Ethoxyethyl acetate
2-Mcthoxyethanol
2-PhcnylphenoI
4,4'-MethyIenedianiIine
Acctaldehyde
Acrolcin
Acrylic acid
Acrylonitrile
Aluminum (fume or dust)
Ammonia
Aniline
Anthracene
Antimony
Arsenic
Asbestos (friable)
Barium
Benz(a)anthracene
Benzene
Bcnzo(a)phenanthrene
Bcnzo(a)pyrene
Benzyl chloride
Beryllium
Biphcnyl
Bromine
Butyl acrylate
Butylaldehyde
Cadmium
Total Releases
(pounds per year)
52,923,638
422,954
264,682
1,820,797
22,292
35,222,942
7,443,883
672
378,018
103,100
0
885,978
0
21,929,191
998,125
111,202
60
8,507
43
2,010,699
1,528,324
3,657
783,041
75,792,629
43,518,590
311,982
139,265
1,789,097
9,329,119
8,123
1,435,995
1,839
149,967,605
1,609
1,381
0
10,997
85,493
949,230
11,240
110,921
13,733,816
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 Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
Table 20 (continued): Estimated Releases of TRI Chemicals *
CAS
NO.
75150
56235
7782505
108907
75456
75003
67663
74873
126998
75729
7440473
7440484
7440508
8001589
1319773
98828
110827
108930
84742
75718
75092
76142
131113
106898
140885
100414
74851
107211
75218
7782414
50000
64186
76131
7647010
78842
67630
7439921
108383
108316
7439965
7439976
67561
Chemical Name
Carbon disulfide
Carbon tetrachloride
Chlorine
Chlorobenzene
Chlorodifluoromethane (HCFC-22)
Chloroethane (Ethyl chloride)
Chloroform
Chloromethane (Methyl chloride)
Chloroprene
Chlorotrifluoromethane (CFC-13)
Chromium
Cobalt
Copper
Creosote
Cresol (mixed isomers)
Cumene
Cyclohexane
Cyclohexanol
Dibutyl phthalate
Dichlorodifluoromethane (CFC-12)
Dichloromethane (Methylene chloride)
Dichlorotetrafluoroethane (CFC-1 14)
Dimethyl phthalate
Epichlorohydrin
Ethyl acrylate
Ethylbenzene
Ethylene
Ethylene glycol
Ethylene oxide
Fluorine
Formaldehyde
Formic acid
Freon 113 [Ethane, l,l,2-trichloro-l,2,2,-trifluoro-]
Hydrochloric acid
Isobutyraldehyde
Isopropyl alcohol (mfg-strong acid process)
Lead
m-Xylene
Maleic anhydride
Manganese
Mercury
Methanol
Total Releases
(Pounds per Year)
27,330,674
81,376
71,501,754
171,894
162,070
31,182,710
13,340
178,484
57,294
9,053
2,632,999
211,262
3,058,579
0
239,994
725,684
96,418,561
6,031
1,248,555
97,414
1,414,455,336
5,847
669,536
66,000
117,509
68,347,539
53,298,159
76,627
541,571
6,068,173
61,211,875
467,279
7,587,241
5,809,931
109,758
32,059,970
72,091,837
32,874,142
324,171
2,969,118
394,924
44 028 966
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Fossil Fuel Electric Power Generation
 Section IV. Chemical Releases and Transfers
Table 20 (continued): Estimated Releases of TRI Chemicals
CAS
NO.
96333
78933
108101
80626
74953
101688
101688
76153
68122
71363
1 10543
91203
7440020
7697372
98953
95476
106423
85018
108952
7723140
85449
123386
115071
75569
78922
7782492
7440224
100425
7664939
75650
127184
7440280
108883
79016
75694
7440622
108054
75014
1330207
7440666
Chemical Name
Methyl acrylate
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Melhylene bromide
Mcthylenebis(phenylisocyanate)(MBI)
Methylenebis(phenylisocyanate) (MDI)
Monochloropentafluoroethane (CFC-115)
N,N-Dimethylformamide
n-Butyl alcohol
n-Hcxane
Naphthalene
Nickel
Nitric acid
Nitrobenzene
o-Xylcne
p-Xyicne
Phcnanthrene
Phenol
Phosphorus (yellow or white)
Phthalic anhydride
Propionaldehyde
Propylene (Propene)
Propylene oxide
sec-Butyl alcohol
Selenium
Silver
Styrcne
Sulfuric acid
Tcrt-Butyl alcohol
TetrachloroethyIene(Perchloroethylene)
Thallium
Toluene
Trichloroethylene
Trichlorofluoromethane (CFC-1 1)
Vanadium (fume or dust)
Vinyl acetate
Vinyl chloride
Xylcne (mixed isomers)
Zinc (fume or dust)
Total Releases
(Pounds per Year)
0
91,926,327
20,020,683
16,208
52,241
130
130
6,199
2,700,310
12,653,277
107,548,181
434,275
7,884,920
214,564
0
41,115,640
2,327,391
84,032
15,017,545
7,980,941
2,491,887
49,400
45,955,707
183,593
990,420
173,886
289,686
28,155,503
1,320,503
4,660
14,623,885
<1
421,985,085
27,838,379
1,315,878
7,256,367
1,011,166
10,200,715
191,013,108
20,353,738
* Data in this table should not be used for comparison with other environmental data from other sources. It is only provided for
illustrative purposes. Please note the limitations of the data explained in the text.
Sector Notebook Project
60
September 1997

-------
Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
Table 21: Median Emission Factors Determined From Test Report Data, and Total 1990 and
2010 HAP Emissions, Projected With the Emission Factor Program for Inorganic HAPs
From Coal-Fired Units *
Coal-Fired Units:
Inorganic HAPs
Antimony
Arsenic
Beryllium
Hydrogen Chloride
Hydrogen Cyanide
(HCN) t
Hydrogen Fluoride
Cadmium
Chromium
Cobalt
Lead
Manganese
Mercury
Nickel
Phosphorous (P)n
Selenium
Number of
Stack
Factors:
PM
Control "
7
21
12
15
All HCN
factors were
combined
14
18
22
10
21
21
20
21
AH P Factors
were
Combined
19
Median
Stack
Factor: PM
Control
(Ib/trillion
Btu)*"
1.4
2.9
0.45
21,000
Number of
Factors: 5
4,200
0.72
8.4
2.7
4.8
15
3.9
8.3
Number of
Factors: 10
62
Number of
Stack
Factors:
PMand
SO2
Control"
4
8
5
9
Median
Factor: 28
Ib/trillion Btu
6
9
10
6
9
9
10
10
Median Stack
Factor: PM
and SO2
Control
(Ib/trillion
Btu)"
0.13
0.9
0.14
1,290

106
1
4
1
5.8
15
3.4
5.2
Median Factor 31 Ib/trillion Btu
9
8
Estimate
d Total
1990
Emission
s (tons)
11
54
6.6
137,000
240
19,500
1.9
70
21
72
180
51
48
270
190
Estimated
Total 2010
Emissions
(tons)
14
62
7.6
150,000
320
25,600
2.3
83
27
83
232
65
57
350
230
* Compounds are listed in the following sequence: inorganic, organic, and dioxin/furan/polycyclic aromatic
hydrocarbons (PAHs). Median emission factors were determined from organic HAP concentrations at the stack,
control device outlet, or boiler outlet when at least one of typically three measured flue gas concentrations was
detected.
** Stack factors for inorganic HAPs were taken from test reports when at least one of typically three measured
flue gas concentrations was detected. These factors were not used to develop the estimated emissions.
*** Since the inorganic emissions were not directly estimated from stack factors, total emissions of inorganic
HAPs projected with the computer program and from median stack factors will vary.
f Nationwide hydrogen cyanide emissions were detected from stack emission factors and not from emission
median factors.
tf Nationwide phosphorous emissions were detected from stack emission factors and not from emission median
factors.
Source: Study of Hazardous Air Pollutant Emission from Electric Utility Steam Generating Units— Interim Final
Report, Volumes 1-3. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Research Triangle Park, NC. EPA-453/R-96-013b. October 1996.
Sector Notebook Project
61
September 1997

-------
Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
Table 22: Median Emission Factors Determined From Test Report Data, and Total 1990 and 2010 HAP
Emissions, Projected With the Emission Factor Program for Inorganic HAPs From Oil-Fired Units *
Oil-Fired Units:
Inorganic HAPs
Arsenic
Beryllium
Cadmium
Chromium
Cobalt
Hydrogen Chloride
Hydrogen Fluoride
Lead
Manganese
Mercury
Nickel
Phosphorous (P)f
Selenium
Number of
Stack
Factors: PM
Control "
2
2
1
4
2
4
3
3
3
3
4
A11P
Factors were
Combined
1
Median
Stack
Factor: PM
Control
Ob/trillion
Btu)'"
0.32
0.33
0.32
3.7
6.1
2900
230
2.6
15
0.24
180
Number of
Factors: 3
1.4
Number of
Stack Factors:
NoPM
Control "
8
4
9
8
3
2
2
8
9
3
9
Median
Stack
Factor: No
PM Control
(Ib/trillion
Btu) *"
5.3
0.21
1.6
5.7
27
2300
140
9
16
0.48
410
Median Factor 1 10 Ib/trillion
Btu
8
3.8
Estimated
Total 1990
Emissions
(tons)
5
0.45
1.7
4.7
20.3
2870
144
10.6
9.5
0.25
389
68
1.7
Estimated
Total 2010
Emissions
(tons)
2.5
0.23
0.87
2.4
10.3
1456
73
5.3
4.8
0.13
197
34
0.84
* Compounds are listed in the following sequence: inorganic, organic, and dioxin/furan/polycyclic aromatic
hydrocarbons (PAHs). Median emission factors were determined from organic HAP concentrations at the
stack, control device outlet, or boiler outlet when at least one of typically three measured flue gas
concentrations was detected.
" Stack factors for inorganic HAPs were taken from test reports when at least one of typically three measured
flue gas concentrations was detected. These factors were not used to develop the estimated emissions.
*"* Since the inorganic emissions were not directly estimated from stack factors, total emissions of inorganic HAPs
projected with the computer program and from median stack factors will vary.
* Nationwide phosphorous emissions were detected from stack emission factors and not from emission median
factors.
Source: Study of Hazardous Air Pollutant Emission from Electric Utility Steam Generating Units— Interim Final
Report Volumes 1-3. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Research Triangle Park, NC. EPA-453/R-96-013b. October 1996.
Sector Notebook Project
62
September 1997

-------
Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
Table 23: Median Emission Factors Determined From Test Report Data, and Total 1990 and 2010
HAP Emissions, Projected With the Emission Factor Program for Inorganic HAPs From Gas-Fired Units *
Gas-Fired Units: Inorganic
HAPs
Arsenic
Cadmium
Chromium
Cobalt
Lead
Manganese
Mercury
Nickel
Phosphorous
Number of Stack
Factors: No PM
Control
2
1
2
1
2
2
2
2
1
Median Stack
Factor: No PM
Control
(Ib/trillion Btu)
0.14
0.044
0.96
0.12
0.37
0.3
<0.38
2.3
2.2
Estimated Total
1990 Emissions
(tons)
0.16
0.054
1.2
0.14
0.44
0.37
0.0016
2.3
1.3
Estimated Total
2010 Emissions
(tons)
0.25
0.086
1.9
0.23
0.68
0.59
0.0024
3.5
2
Compounds are listed in the following sequence: inorganic, organic, and dioxin/furan/polycyclic aromatic
hydrocarbons (PAHs). Median emission factors were determined from organic HAP concentrations at the
stack, control device outlet, or boiler outlet when at least one of typically three measured flue gas
concentrations was detected.
Source: Study of Hazardous Air Pollutant Emission from Electric Utility Steam Generating Units— Interim Final
Report Volumes 1-3. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards.
Research Triangle Park, NC. EPA-453/R-96-013b. October 1996.
Sector Notebook Project
63
September 1997

-------
Fossil Fuel Electric Power Generation
 Section IV. Chemical Releases and Transfers
Table 24: Median Emission Factors From Test Report Data, and Total 1990 and 2010 HAP Emissions,
Projected With the Emission Factor Program for Organic HAPs From Coal-Fired Units
Coal-Fired Units: Organic HAP
1,1,2-Trichlorocthane
2-chloroacctophcnonc
2,4 -Dinitro toluene
Acctaldchydc
Acctophcnone
Acrolcin
Benzene
Benzyl chloride
Bis{2-cthylhcxyl) phthalate
Bromoform
Carbon distil fide
Carbon tetrachloridc
Chlorobcnzcnc
Chloroform
Cumcnc
Dibutyl phthalate
Ethylbcnzcne
Ethylchloridc
Methylchloroform
Ethylcncdichloride
Formaldehyde
Hcxanc
Hcxachlorobcnzcnc
Isophoronc
Methylbromlde
Methylchloridc
McUiylcthylketonc
Methyliodidc
Methylisobutyl kctone
Mcthylmcthacrylate
Methyltcrtbutylcthcr
Mcthylcncchloridc
Number
of
Emission
Factors
l
3
3
12
7
6
20
1
9
1
8
2
2
2
1
5
5
1
4
3
15
2
1
2
6
3
6
1
3
1
1
5
Median
Emission
Factor
(Ib/trillion
Btu)
4.7
0.29
0.015
6.8
0.68
3.3
2.5
0.0056
4.1
6.6
4.3
3.3
3.2
3.2
0.29
2.8
0.40
2.4
3.4
3.1
4.0
0.82
0.079
24
0.88
5.9
8.0
0.40
4.9
1.1
1.4
13
Computer
Program:
1990 Total
Tons
40
2.4
0.13
58
5.8
28
21
0.048
35
57
37
28
27
28
2.5
24
3.5
20
29
27
35
6.9
0.68
200
7.7
51
69
3.4
42
9.3
12
110
Computer
Program:
2010 Total
Tons
53
3.2
0.17
76
7.7
37
28
0.063
46
75
48
37
36
36
3.2
32
4.6
27
38
35
45
9.1
0.89
270
10
67
90
4.5
53
12
16
150
Sector Notebook Project
64
September 1997

-------
Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
Table 24 (continued) : Median Emission Factors From Test Report Data, and Total 1990 and 2010 HAP
Emissions, Projected With the Emission Factor Program for Organic HAPs From Coal-Fired Units
Coal-Fired Units: Organic HAP
n-nitrosodimethylamine
Naphthalene
n,p-cresol
o-cresol
p-cresol
perylene
Pentachlorophenol
Phenol
Phthalicanhydride
Propionaldehyde
Quinoline
Styrene
Tetrachloroethylene(PerchloroethyIene)
Toluene
Trans 1,3-dichloropropene
Trichloroethylene
Vinyl acetate
Vinylidnechloride
Xylene
o-xylene
m,p-xylene
Total TEQ' for 2,3,7,8-tetra-chlorodibenzo-p-dioxin
2,3,7,8-tetrachloride-benzo-p-dioxin
1,2,3,7,8-pentachlorodi-benzo-p-dioxin
1,2,3,4/7,8-hexachlorodi-benzo-p-dioxin
1,2,3,6,7,8-nexachlorodi-benzo-p-dioxin
1,2,3,7,8,9-hexachlorodi-benzo-p-dioxin
1,2,3,4,6,7,8-heptaehlorodi-benzo-p-dioxin
Heptachlorodi-benzo-p-dioxin
Hexachlorodi-benzo-p-dioxin
Octachlorodi-benzo-p-dioxin
Pentachlorodi-benzo-p-dioxin
Number
of
Emission
Factors
l
11
2
3
1
1
1
10
1
4
1
7
5
17
1
1
1
2
2
5
8
-
4
3
4
4
4
9
6
8
6
6
Median
Emission
Factor
(Ib/trillion
Btu)
0.68
0.77
0.68
1.7
0.95
0.075
0.0082
6.1
4.9
10
0.053
3.1
3.1
3.6
4.7
3.1
0.42
9.7
4.7
0.82
1.5
-
1.6 xlO-6
4.3 x 10-*
9.7 x 10*
5.8 x 10-6
7.3 x 10*
5.7 x 10*
l.lxlO"4
2.4 x lO'5
5.8 x 10'5
9.8x10*
Computer
Program:
1990 Total
Tons
5.9
6.6
5.8
14
8.2
0.65
0.070
52
42
89
0.46
27
27
31
40
27
3.5
84
40
6.9
13
1.5 xlO-4
1.4 xlO-5
3.7 x 10'5
8.3 x 10-5
5.0 x lO'5
6.3 x lO'5
4.9 xlO-5
9.2 xlO"4
2.1 x 10-"
5.0 xlO"
8.5 x 10-5
Computer
Program:
2010 Total
Tons
7.7
8.7
7.6
19
11
0.85
0.093
69
56
120
0.61
35
35
41
53
35
4.6
110
53
9.1
17
2.0 x 10-"
1.9 xlO-5
4.8 x 10-5
l.lxlO"4
6.6 x 10-5
8.3 x lO'5
6.5 x lO'5
1.2x10-'
2.7 x 10-4
6.6 x 10"4
l.lxlO-4
Sector Notebook Project
65
September 1997

-------
Fossil Fuel Electric Power Generation
  Section IV. Chemical Releases and Transfers
Table 24 (continued) : Median Emission Factors From Test Report Data, and Total 1990 and 2010 HAP
Emissions, Projected With the Emission Factor Program for Organic HAPs From Coal-Fired Units
Coal-Fired Units: Organic HAP
Tctrach!oridc-bcnzo-p-dioxin
2,3,7,8-tetraehloritIe-benMfuran
1 ,2,3,7,8-pcntachlorodi-benzofuran
2,3,4,7,8-pentachIorodi-benzofuran
1,2,3,4,7,8-hcxachlorodi-benzofuran
1^,3,6,7,8-hcxachlorodi-benzofuran
1 ,2,3,7,8,9-hexachIorodi-bcnzofiiran
2,3,4,6,7,8-hcxachIorodi-benzofuran
1,2,3,4,6,7,8-heptachIorodi-benzofiiran
1,2,3,4,7,8,9-hcptachlorodi-benzoftiran
Heptachlorodi-bcnzofuran
Hcxachlorodi-benzofuran
Octachlorodl-benzofuran
Pcntachlorodi-bcnzofuran
Tctrachloridc-bcnzofuran
1 -methylnaphthalcne
2-chloronaphthalcnc
2-mcthylnaphthalenc
Acenapihenc
Accnapthylene
Anthracene
I3cnz(n)anthraccne
Bcnzo{a)pyrcnc
Bcnzo(e)pyrene
Qenzo(b)fluoranthcnc
Benzo(b+k)fluoranthcne
Bcnzo(k)fluoranthcne
Bcnzo(g,h,i)pcrylcnc
Biphcnyl
Chjyscne
Dibcnzo(a,h)anthacene
Fluoranthcnc
Number
of
Emission
Factors
9
8
5
5
6
5
4
5
8
4
8
8
10
9
10
2
2
6
6
5
4
4
6
1
1
1
1
2
1
4
1
6
Median
Emission
Factor
(Ib/trillion
Btu)
7.1 x 10"6
3.9 x 10"6
2.4 xlO"6
1.0 xlO'5
l.SxlO-5
4.0 x 10-6
8.5 x 10*
1.6xlO-5
2.0 xlO'5
1.7 xlO-1
2.4 x 10-5
1.9 xlO'5
1.7xlO'5
1.8 xlO'5
1.2 xlO'5
0.0085
0.04
0.024
0.008
0.0042
0.0042
0.0021
0.001
0.0012
0.0081
0.0016
0.0036
0.0032
0.34
0.0026
0.0003
0.007
Computer
Program:
1990 Total
Tons
6.1 x 10'5
3.4 x lO'5
2.1 x 10'5
9.0 x 10-5
LlxlO4
3.4x10-'
7.3 x lO'5
1.4 xlO"4
1.7 xlO"4
1.5 xlO'3
2.1 x lO"4
1.6 xlO"1
1.4 xlO"4
1.6 xlO"4
1.0 xlO"4
0.076
0.35
0.2
0.07
0.036
0.036
0.018
0.0088
0.01
0.07
0.014
0.031
0.028
3.1
0.022
0.003
0.06
Computer
Program:
2010 Total
Tons
8.0 x lO'5
4.5 x 10-5
2.8 x 10-5
1.2x10^
1.5 x 10"4
4.5 x 10'5
9.6 xlO'5
1.8 xlO"4
2.2 xlO"1
2.0 x 10-'
2.7 x ID"4
2.1 x 10"4
1.9 xlO"4
2.1 x 10-4
1.3 xlO-4
0.1
0.46
0.26
0.09
0.047
0.047
0.002
0.012
0.014
0.092
0.018
0.04
0.036
4
0.03
0.004
0.082
Sector Notebook Project
66
September 1997

-------
 Fossil Fuel Electric Power Generation
   Section IV. Chemical Releases and Transfers
Table 24 (continued) : Median Emission Factors From Test Report Data, and Total 1990 and 2010 HAP
Emissions, Projected With the Emission Factor Program for Organic HAPs From Coal-Fired Units
Coal-Fired Units: Organic HAP
Fluorene
Indeno(l ,2,3 -c,d)pyrene
Phenanthrene
Pyrene
Number
of
Emission
Factors
5
2
7
4
Median
Emission
Factor
(Ib/trillion
Btu)
0.013
0.0064
0.032
0.009
Computer
Program:
1990 Total
tons
0.11
0.054
0.031
0.081
Computer
Program:
2010 Total
tons
0.15
0.072
0.36
0 103
Toxic equivalent emissions.
Source: Study of Hazardous Air Pollutant Emission from Electric Utility Steam Generating Units-Interim Final Report, Volumes 1-3. U.S.
Environmental Protection Agency, Office of Air Quality Planning and Standards. Research Triangle Park, NC. October 1996. EPA-453/R-
96-013b.
Sector Notebook Project
67
September 1997

-------
Fossil Fuel Electric Power Generation
 Section IV. Chemical Releases and Transfers
Table 25: Median Emission Factors From Test Report Data, and Total 1990 and 2010 HAP
Emissions, Projected With the Emission Factor Program for Organic HAPs From
Oil-Fired Units
Oil-Fircd Units: Organic HAPs

Benzene
Ethylbcnzcne
Formaldehyde
Melhylchloroform
Methylcneehloride
Naphthalene
Phenol
Tctrachlorocthylcne (Perchloroethylene)
Toluene
Vinyl acetate
o-Xylcnc
m,p-Xylcnc
Total TEQ* for 2,3,7,8-tetra-chlorodibenzo-p-dioxin
2,3,7.8-tetrachloride-bcnzo-p-dioxin
1,2,3,7,8-pcntachlorodi-benzo-p-dioxin
1.2,3,4,7,8-hcxachIorodi-bcnzo-p-dioxin
1,2,3,6,7,8-hcxachlorodl-benzo-p-dioxin
1,2,3,7,8,9-hexachIorodi-benzo-p-dioxin
1,2.3,4,6,7,8-hcptachlorodi-benzo-p-dioxin
Hcptach!orodi-bcnzo-p-dioxin
Hcxachlorodi-benzo-p-dioxin
Octachlorodi-bcnzo-p-dioxin
Pentachlorodi-benzo-p-dioxin
Tctfichloridc-benzo-p-dioxin
2,3,7,8-tetrachloride-bcnzofuran
1 ,2.3,7,8-pcntachlorodi-bcnzofuran
2,3,4.7,8-pentachlorodi-benzoftiran
1,2,3,4,7,8-hexachIorodi-benzofuran
1 ,2,3,6,7,8-hcxachlorodl-benzofuran
Number of
Emission
Factors
i
6
2
9
3
2
4
2
1
6
2
1
2
_
1
2
1
2
2
2
2
2
1
2
2
2
2
2
2
2
Median
Emission
Factor
(Ib/trillion
Btu)
8.2
1.4
0.49
30
7.6
32
0.33
24
0.55
8
5.2
0.84
1.4
—
6.5 x 10"6
5.8 x 10*
1.2 xlO-5
5.4 x 10-5
8.3 x 10*
2.0 x 10-5
2.0 x 10-5
8.1 x 10-*
2.3 x 10'5
5.8 xlO"6
5.7 x 10*
4.6 x lO"6
4.3 x 10-*
4.8 x 10*
6.1 x 10*
3.8 xlO*
Computer
Program:
1990 Total
Tons
5
0.88
0.29
19
4.6
20
0.21
15
0.34
4.9
3.2
0.51
0.82
1.1 x 10-5
4.5 x 10*
3.5 x 10*
7.6x10*
3.3 x 106
5.1 x 10*
1.2xlO'3
1.2xlO'5
5.0 x 10*
1.4 xlOJ
3.5 x 10*
3.4 x 10*
2.9x10*
2.6 x 10*
3.0x10*
3.7 x 10*
2.3 x 10*
Computer
Program:
2010 Total
Tons
2.6
0.45
0.15
9.5
2.4
10
0.1
7.5
0.17
2.5
1.6
0.26
0.42
5.4x10*
2.0x10*
1.8x10*
3.9 x 10*
1.7x10*
2.6 x 10*
6.2 x 10*
6.2 x 10*
2.5 x 10*
7.3 x 10*
1.8x10*
1.8 x 10*
1.4x10*
1.3x10*
1.5x10*
1.9x10*
1.2x10*
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  Section IV. Chemical Releases and Transfers
Table 25 (continued): Median Emission Factors From Test Report Data, and Total 1990 and 2010
HAP Emissions, Projected With the Emission Factor Program for Organic HAPs From
Oil-Fired Units
Oil-Fired Units: Organic HAPs
1,2,3,7,8,9-hexachlorodi-benzofiiran

2,3,4,6,7,8-hexachlorodi-benzofuran

1,2,3,4,6,'7,8-heptachIorodi-benzofuran
1,2,3,4,7,8,9-heptachlorodi-benzofuran
Heptachlorodi-benzofuran
Hexachlorodi-benzofuran
Octachlorodi-benzofuran
Pentachlorodi-benzofiiran
Tetrachloride-benzofuran
2-methylnaphthalene
Acenaphthene
Acenaphthylene
Anthracene
Benz(a)anthracene
Benzo(b+k)fluoranthene
Benzo(g,h,i)perylene
Chrysene
Dibenzo(a,h)anthracene
Fluoranthene
Fluorene
Indeno(l ,2,3-c,d)pyrene
Nitrobenzofluoranthene
Nitrochrysene/benzanthracene
Phenanthrene
Pyrene
Number of
Emission
Factors
2
1
1
1
1
2
1
2
2
4
2
1
2
3
2
2
3
2
6
5
2
1
1
9
6
Median
Emission
Factor
(Ib/trillion
Btu)
5.8 xlO*
4.8 x ID"6
9.4 xlO"6
l.OxlO'5
1.5 x 10"6
9.6 x 10-6
1.0 x lO'5
7.3 x 10"6
5.0 xlO-6
0.017
0.38
0.017
0.015
0.03
0.033
0.021
0.021
0.0081
0.016
0.021
0.024
0.015
0.016
0.025
0.037
Computer
Program:
1990 Total
Tons
3.5 xlO"6
3.0 x 10-6
5.7 x 10-*
6.2 x 10^
8.8 x 10-'
5.8 x 10-6
6.2 x 10-6
4.4 xlO"6
3.1 x 10-°
0.01
0.22
0.01
0.0093
0.018
0.02
0.013
0.013
0.005
0.0097
0.013
0.014
0.0092
0.0098
0.015
0.022
Computer
Program: 2010
Total Tons
1.8 xlO-6
1.4 xlO-6
3.0 x 10"6
3.2 x 10"6
4.4 x 10-'
3.0 xlO-6
3.2 xlO*
2.2 x 10-6
1.5 xlO"6
0.0052
0.11
0.0052
0.0047
0.0092
0.01
0.0065
0.0066
0.0025
0.0049
0.0065
0.0073
0.0047
0.005
0.0077
0.011
* Toxic equivalent emissions
Source: Study of Hazardous Air Pollutant Emission from Electric Utility Steam Generating Units-Interim Final Report, Volumes 1-3. U.S.
Environmental Protection Agency, Office of Air Quality Planning and Standards. Research Triangle Park, NC. October 1996. EPA-453/R-96-
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Table 26: Median Emission Factors From Test Report Data, and Total 1990
and 2010 HAP Emissions, Projected With the Emission Factor Program for Organic HAPs From
Gas-Fired Units
Gas-Fired Units: Organic HAPs
Benzene
Formaldehyde
Naphthalene
Toluene
2-methylnaphthalene
Fluoranthcne
Fluorene
1-phenanthrene
Pyrene
Number of
Emission
Factors
1
8
2
2
2
1
1
2
1
Median
Emission
Factor
(Ib/trillion
Btu)
1.4
35.5
0.7
10
0.026
0.0028
0.0026
0.013
0.0049
Computer
Program:
1990 Total
Tons
1.8
55
0.66
13
0.025
0.0034
0.0034
0.016
0.0061
Computer
Program: 2010
Total Tons
2.7
83
1
19
0.038
0.0055
0.0051
0.024
0.0094
Source: Study of Hazardous Air Pollutant Emission from Electric Utility Steam Generating Units-Interim Final Report,
Volumes 1-3. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. Research Triangle Park,
NC. October 1996. EPA-453/R-96-013b.
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Fossil Fuel Electric Power Generation	Section V. Pollution Prevention Opportunities

 V.        POLLUTION PREVENTION OPPORTUNITIES

                     The best way to reduce pollution is to prevent it in the first place.  Some
                     companies have creatively implemented pollution prevention techniques that
                     improve efficiency and increase profits while at the same time minimizing
                     environmental impacts. This can be done in many ways, such as reducing
                     material inputs, re-engineering processes to reuse byproducts, improving
                     management practices, and employing substitution of toxic chemicals.  Some
                     smaller facilities are able to actually get below regulatory thresholds just by
                     reducing pollutant releases through aggressive pollution prevention policies.

                     The Pollution Prevention Act of 1990 established a national policy of
                     managing  waste  through source reduction, which means preventing the
                     generation of waste.  The Pollution  Prevention Act also established as
                     national policy a hierarchy of waste management options for situations in
                     which source reduction cannot be implemented  feasibly.  In the waste
                     management hierarchy, if source reduction is not feasible the next alternative
                     is recycling of wastes, followed by energy recovery, and waste treatment as
                     a last alternative.

                     hi order to encourage these approaches, this section provides both general and
                     company-specific descriptions of some pollution prevention advances that
                     have been implemented within the fossil fuel electric  power generation
                     industry. While the list is not exhaustive, it does provide core information
                     that can be used as the starting point for facilities interested hi beginning their
                     own pollution prevention projects.   This section provides summary
                     information from activities that may be, or are being implemented by this
                     sector.  When possible, information is provided that gives the context in
                     which the technique can be used effectively. Please note that the activities
                     described in this section do not necessarily apply  to all facilities that fall
                     within this sector. Facility-specific conditions must be carefully considered
                     when pollution prevention options are evaluated, and the full impacts of the
                     change must examine how each option affects air, land and water pollutant
                     releases.

                     Coal is considered the primary energy source for power generation now and
                     in the future.  Coal is  relatively abundant and inexpensive.  However,
                     environmental impacts associated with  coal combustion, most notably, acid
                     rain, represent a cost to the environment and human health. This section
                     emphasizes technologies for coal-fired electric power generation plants, but
                     includes pollution prevention practices that apply to  other fossil fuel electric
                     plants as well. Many of the technologies and practices may be employed in
                     existing plants, in the repowering of existing plants, and in the design and
                     construction of new plants.
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V.A      Pollution  Prevention  Technologies  in the  DOE  Clean  Coal Technology
          Demonstration Program

                    The DOE is charged with protecting the Nation's energy interests.  In
                    recognition of the vital role of coal as a sustainable energy source, DOE
                    vigorously researches and promotes ways to reduce the  environmental
                    impacts associated with coal combustion under the Clean Coal Technology
                    Demonstration (CCT) Program. Specific goals of the CCT Program include
                    (1) increasing the efficiency of electricity production and (2) enhancing the
                    efficient  and cost effective  use of U.S.  coal reserves, while ensuring
                    achievement of national and environmental goals.

                    One way in which the CCT Program progresses towards these goals is by
                    building  a portfolio  of advanced, coal-based technology  demonstration
                    projects.  Included in the portfolio are technologies that result in improved
                    efficiency with  fewer  environmental  consequences.  The technologies
                    demonstrated  under the CCT Program include  commercially  viable
                    processes, as well as projects whose commercial  viability is  still being
                    explored.  These technologies may be categorized as (1) power systems, (2)
                    environmental control devices, and (3) clean coal  processing.  Pollution
                    prevention technologies being demonstrated under the CCT Program are
                    included under the categories labeled "power systems" and "clean coal
                    processing." Technologies categorized as "environmental control devices"
                    may not be considered pollution prevention technologies; however, they may
                    enable the recovery of pollutants for subsequent reuse/resale in products.

                    A brief  discussion  of emerging power systems  and coal  processing
                    technologies being demonstrated under the CCT Program is provided below.
                    DOE's Clean Coal Technology Demonstration Program, Program Update
                    1995 (April 1996) provides a more detailed discussion.

          V.A.1    Emerging Technologies

                    Pollution prevention opportunities in advanced coal-fired power systems are
                    realized by the increase in overall efficiency of the combustion  (electricity
                    produced per amount of fuel) resulting in the reduction of environmental
                    pollutants released. Efficiency of a technology is determined by  the portion
                    of energy hi fuel that is converted into electricity.  Thus, the  process of
                    combustion and heat transfers are critical variables. In considering advanced
                    technologies, one must consider the environmental transfer of wastes from
                    one media to another. Unless the transfer represents a more manageable form
                    of the waste, there may be little or no environmental gain.
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  Section V. Pollution Prevention Opportunities
                       A brief description of power system technologies is provided below.  While
                       none of the technologies described are currently commercially viable, they
                       may be in the future. Table 27 summarizes demonstration projects for power
                       system technologies funded by DOE and participating companies.
      Table 27: Summaries of Clean Coal Technologies Under DOE's Clean Coal Technology
     	Demonstration Program
  Demonstration: Pressurized Fluidized-Bed Combustion Combined-cycle. Tidd Proiect-The Ohio Power
  Company
 Status:  Completed on the 70 MW scale, future testing on 340 MW scale planned.
 Size: 55 MW steam turbine, 15 MW gas turbine
 Efficiency; Combustion efficiency of 99.6%. Heat rate efficiency of 33.2percent
 Environmental Benefits: SO2 removal of up to 95%. Resulting NOX emissions ofO. 15-0.33lb/million Btu.

 Demonstration: Inteerated Gasification Combined-cycle Repowerine Project
 Status: Currently still in design stage.
 Size: 65 MW
 Projected Efficiency: Heat efficiency of approximately 43%.
 Environmental Benefits:  Expected CO2 reduction, improved efficiency over coal-fired plant -with flue gas
 desulfurization.

 Demonstration: Indirect Fired Cycle-Repowering. Pennsylvania Electric Co. Warren Station. Unit No. 2
 Status: Currently still in design stage.
 Size: 62.4 MW
 Projected Heat Rate: 9,650 BTU/KWh (31.3% improvement over existing).
 Environmental Benefits:  Eliminates the need for hot gas cleanup systems.

 Demonstration: Coal Diesel Combined-Cycle Project. Arthur D. Little. Inc.
 Status: Currently in design stage.
 Size:  14 MW
 Projected Efficiency: Heat efficiency of approximately 48%.
 Environmental Benefits:  Emissions reductions to levels of50%-70% below NSPS.

 Demonstration: Slagging Combustor. Heavy Clean Coal Project. Alaska Industrial Development and Export
 Authority. Golden Valley Electric Association
 Status: Currently in construction stage.
 Size: 50 MW
 Projected Efficiency: Projected SO2 removal of 90%, NOX emissions/million BTU emissions of less than 0.015
 Ib/million BTU, particulates of 0.0015 Ib/million BTU.
 Environmental Benefits:  SO2, NOX, particulates emissions reductions.
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          Fluidized-Bed Combustion
 Section V. Pollution Prevention Opportunities
                    Fluidized bed  combustion  (FBC)  technology includes three designs:
                    atmospheric, pressurized, and two-stage bubbling bed.  Although FBC
                    technology is not yet widespread in the industry, it allows any kind of fuel to
                    be burned while controlling the emission of SO2 without the use of a flue gas
                    scrubbing device.  In the FBC process, a sorbent, such as crushed limestone,
                    is introduced with pulverized coal in the  combustion chamber.  Air forced
                    into the combustion chamber suspends the coal-limestone mixture. Sulfur,
                    released from the coal, combines with the sorbent to form a solid  waste that
                    is relatively easy to handle and dispose of.   The  advantage of FBC
                    technology is that it creates a turbulent environment conducive to a high rate
                    of combustion and a high rate  of sulfur capture and  allows  for lower
                    operating temperatures than conventional boilers.  Because  operating
                    temperatures are below the threshold of thermally induced NOX formation,
                    NOX emissions are reduced. In addition, the operating temperature tends to
                    be below the ash fusion range for coal, resulting in less wastes  present in
                    fireside wash waters and less frequent cleaning requirements.

          Integrated Gasification Combined-cycle

                    In the IGCC, coal is converted into a gaseous fuel, purified, and combusted
                    in a gas turbine generator to produce electricity. The constituents react to
                    produce a fuel gas.  Heat from the exhaust gas is recovered and used to
                    generate steam, which produces  additional electricity.  Gasification is a
                    process in which coal is introduced to a reducing atmosphere with oxygen or
                    air and steam. In some systems, a limestone sorbent is added to the gasifier
                    for sulfur removal. The environmental advantages of IGCC include:

                    •   High efficiency
                    •   Removal of nitrogen, sulfur,  and particulates prior to the addition of
                        combustion air, thereby lowering the volume of gas requiring treatment
                    •   Sulfur in the gas is in the form of hydrogen sulfide, which is removable
                        to a greater extent than SO2
                    •   NOX removal of more than 90 percent
                    •   Reduced CO2 emissions compared to  traditional coal-fired boilers.

                    Currently, gas cleanup in IGCC requires the gas to be cooled; however, hot
                    gas cleanup systems are being developed that will remove 99.9 percent of the
                    sulfur and result in a saleable sulfur product. The IGCC system is well suited
                    for repowering because it can use the existing steam turbine, electrical
                    generator, and coal-handling facilities in most cases.
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            Indirect-Fired Cycle
  Section V. Pollution Prevention Opportunities
                      An indirect-fired cycle operates  such that coal or biomass combustion
                      products do not come hi direct contact with gas turbine components.  Instead,
                      heated gases pass on the shell side of an air heater.  On the tube side of the
                      air heater, compressed gas is heated and passes through a gas turbine. The
                      environmental advantage is that this eliminates the need for hot gas cleanup
                      since the corrosive and abrasive fuel products do not come into direct contact
                      with the turbines. Heat is recovered from air heater exhaust and is used to
                      produce steam, which powers a steam turbine.  In addition, corrosive gas
                      products do not come into direct contact with the turbine, thereby eliminating
                      the need for hot gas cleanup. Although the technology is still in the design
                      stage, the efficiency is expected to be 20 percent greater than that of a
                      pulverized coal plant. Furthermore, SO2 reductions of 90 percent, as well as
                      reduced NOX and particulate emissions, are expected.

           Integrated Gasification Fuel Cell

                      An integrated gasification fuel cell system consists of a coal gasifier with a
                      gas cleanup system, a fuel cell, an inverter, and a heat recovery system. Coal
                      gas, made through the reaction of steam, oxygen, and limestone, is introduced
                      to a fuel cell  composed of an anode and a cathode and separated by an
                      electrolytic layer.  The fuel cell converts the chemical energy of the gas to
                      direct current electrical energy and generates heat, and an inverter converts
                      direct current to alternating current. A heat recovery system delivers heat to
                      a bottoming steam cycle for further generation of electricity.  Pollution
                      prevention is realized by improved emissions reduction associated with the
                      gas cleanup system and solid waste reduction.

           Coal-Fired Diesel

                     Diesel generators are modified to accept a coal/water slurry as a fuel source.
                     Environmental control systems are typically installed to remove NOX, SO2,
                     and particulates. The advantage of a coal-fired diesel system is that it is well
                     suited to small generators (below 50 megawatts).  In addition, it is estimated
                     to result in emissions  reduction of 50  percent  below New Source
                     Performance Standards.  Similarly, coal-oil mixture technology can replace
                     up to 50 percent of fuel oil with pulverized coal for burning in conventional
                     oil or gas burners.

          Slagging Combustor

                     In a slagging combustor, coal is burned at very high combustion temperatures
                     outside the furnace cavity, and combustion gasses pass into the boiler, where
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                    heat exchange takes place. In a conventional boiler, the ash enters the boiler
                    and collects on boiler tubes, thus decreasing the efficiency of heat exchange.
                    Alternatively, the high temperature of the slagging combustor causes ash to
                    form slag, which is collected in cyclones. The advantage of the slagging
                    combustor is that it prevents a loss in heat exchange efficiency that would
                    occur from ash accumulation on boiler tubes.

          V.A.2    Coal Processing for Clean Fuels

                    Pollution prevention entails removal of the pollutants from coal in the
                    precombustion stage. This is accomplished through coal cleaning, whereby
                    pollutants are removed without altering the solid state of the  coal, or by
                    conversions (gasification or liquefaction), which represent transformations
                    in the state of the coal.

          Coal Cleaning

                    Most coal cleaning occurs at the mouth of the mine. The  cleaning method
                    depends on the size of the coal pieces. Typically, coal is cleaned by pulsing
                    currents of water through a bed of coal in a jig to separate the impurities from
                    the coal.  Coal cleaning can be achieved through physical, biological, or
                    chemical means. Physical cleaning is the most common method and involves
                    the separation of coals to obtain coals with lower ash content.  A lower ash
                     content helps in meeting particulate emissions standards and results in lower
                     operating and maintenance costs associated with ash handling. Coal cleaning
                     can also reduce the trace metal content, thus reducing trace metal content in
                     ashes.  Furthermore, cleaning is effective in removing sulfur from coal.  This
                     is sulfur that may otherwise end up as SO2 emissions.  There is a tradeoff
                     between sulfur reduction and energy recovery.36 It should be noted, however,
                     that a reduction in energy recovery is associated with sulfur removal.

                     A study  cited in   a  report  written by the  Virginia Department of
                     Environmental Quality compared two FBC conceptual plant designs using
                     mine-run coal versus washed coal. The  washed coal facility reduced SO2
                     emissions by more than 50 percent on the basis of equivalent heat input and
                     sulfur removal. The NOX emissions from the washed coal are about one-third
                     lower in comparison to mine-run coal based on equivalent heat input. In
                     addition,  the  washed coal facility was physically  smaller, had lower
                     installation costs, required less storage area for limestone and ash, used less
                     water, and generated less high-volume wastes.
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          Coal Gasification
                                  Section V. Pollution Prevention Opportunities
                     Gasification is the process of converting coal to a gaseous fuel—coal gas—
                     followed by chemical cleaning.  Coal gas has the benefit of burning as
                     cleanly as natural gas. The process entails coal gas reacted with steam and
                     an oxidant in a reducing atmosphere. If air is the oxidant, a low-BTU gas
                     results; if oxygen is the oxidant, a medium-BTU gas results.
          Mild Gasification
V.B
          In mild gasification, coal is heated in a oxygen-free reactor, which produces
          gaseous, solid, and liquid products. The environment in the reactor drives off
          the condensed, volatile hydrocarbons and leaves behind carbon. The benefit
          of mild gasification is that it produces multiple fuels and feedstocks using
          medium temperature treatment of coal.

Coal Liquefaction

          Hydrogen added to coal increases the fuel's ratio of hydrogen to carbon to a
          level similar to that of petroleum-based fuels. Coprocessing is a liquefaction
          process, whereby heavy petroleum residue combined with coal produces a
          liquid fuel. The liquids can be cleaned of sulfur and ash prior to use as a fuel
          and have higher thermal efficiencies (60-70 percent range), high  product
          yield, and potentially marketable byproducts, such as gasoline.

Other Pollution Prevention Technologies

Cogeneration

          Cogeneration is the production of electricity and heat from  a single power
          plant unit.  Because of the  heat recovery aspect, Cogeneration itself is a
          pollution prevention strategy. In Cogeneration, heat that would otherwise be
          released from a steam turbine, gas turbine, or diesel engine is  recaptured and
          used to heat buildings or other industrial processes or to generate additional
          electricity. In fact, whereas the typical efficiency at a fossil fuel electric plant
          is around 33 to 38  percent,  cogenerators can  obtain  up to 80-percent
          efficiency because of the heat recaptured. The heat recovered comes mainly
          from the flue gases.37

          Cogeneration plants were originally industrial applications.  They are still
          used primarily to provide power for industries, hotels, universities,  etc., yet
          they are increasingly being designed for larger capacities and are competing
          with utilities for power production.  Cogeneration plants may be owned by
          an industrial company, supplying its own power,  or they may be owned by
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                     small entrepreneurial companies. Besides size requirements, factors such as
                     type of fuel to burn, methods of recapturing heat, and control of emissions,
                     should be considered when evaluating cogeneration as a power source.

                     DOE's Office of Industrial Technology (OIT) has several projects underway
                     to promote cogeneration, which is a commercially available technology. For
                     example, OIT teamed up with Riegel Textile Corporation to design and test
                     an innovative 4.3 MW high-back-pressure steam cogeneration system using
                     a modified coal-fired boiler.  The turbine exhaust (225 psig at 570 degrees
                     Fahrenheit) is hot enough to be used for process heating and can also be used
                     to drive an existing low-pressure turbine to generate additional electricity.
                     In 1994,17 such systems were in operation.38
          Repowering
                     Repowering is a way in which power generation facilities can improve and
                     increase both the production and efficiency of standard thermal generating
                     facilities. Repowering options include expanding a unit's size or changing
                     the type or quality of the fuel used.  In most cases, it involves partial or
                     complete replacement of the steam supply system and usually a more or less
                     complete retention, refurbishment, and reuse of the turbine/generator. Many
                     of the technologies listed above are appropriate for repowering.
          Fuel Cells
                     Natural gas fuel cell (NGFC) energy systems improve gas utilization and
                     efficiency.   Like batteries,  fuel  cells are based on  the principles of
                     electrochemistry, except that they consume fuel to maintain the chemical
                     reaction. The most common electrochemical reaction in a fuel cell is that of
                     hydrogen with oxygen. The oxygen is usually derived from the air, and the
                     hydrogen is usually obtained by steam-reforming fossil fuel. Natural gas is
                     the most common fuel; however, other fuels can be used: peaked-shaved gas,
                     air-stabilized gas from local production such as landfills, propane, or other
                     fuels with high methane content. Fuel Cells, being electrochemical, are more
                     efficient than combustion systems.  In addition, emissions are reduced from
                     typical gas systems because there is no combustion of fossil fuel.  Although
                     many fuel cells are being researched, developed, and demonstrated around
                     the world, only one system is commercially available at this time. It is a 200
                     kW phosphoric acid fuel cell system.39

                     Because emissions are reduced, State and local air quality regulating agencies
                     have begun to grant and/or consider exemptions from air quality permitting
                     requirements. For example, after extensive emissions  testing, the South
                     Coast Air Quality  Management District has granted NGFC's exemption in
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 Section V. Pollution Prevention Opportunities
                    the Los Angeles area.   Exemptions have also been granted by the Santa
                    Barbara  Air Quality Management District, the Bay Area Air  Quality
                    Management District, and the State of Massachusetts. These exemptions may
                    create economic incentives to install NGFC systems to avoid permitting fees
                    and violation fines, or to take advantage of emissions credits.  A Federal
                    incentive program is being managed by the DOE Morgantown Energy
                    Technology Center to reduce the cost of the fuel cell by $1,000 per kW.40

                    Additional information on this technology may be obtained from the North
                    American Fuel Cell Owner Group (NAFCOG), an independent users group
                    comprised of owners and operators of NGFCs.

V.C      Other Pollution Prevention and Waste Minimization Opportunities

                    In addition to the technologies discussed previously, several other pollution
                    prevention methods can be employed. Some of the methods are common
                    solutions applicable to a wide range of facilities; others are more tailored to
                    site-specific situations. Some of the methods are relatively simple, whereas
                    others require more technological modifications.  This section includes not
                    only physical tasks, but management and training  steps that foster pollution
                    prevention.

          V.C.I    Process or Equipment Modification Options

          Fuel Sources

                    As discussed under  the CCT Program, the initial fuel source may  be
                    examined as a potential pollution prevention opportunity.   Clean coal
                    technologies remove the pollutants prior to the major processes of electrical
                    generation. But on a case-by-case basis, one can also consider the option of
                    using fuels that are naturally lower in pollutants. Low-sulfur coals produce
                    less SO2 emissions, and there is less pollution associated with coal pile
                    runoff. However, a tradeoff exists in that most low-sulfur coal in the United
                    States is "low rank" (i.e.,  it has a higher ash and moisture content). Several
                    operational difficulties stem from switching from high-rank to low-rank coal.
                    Nonetheless, processing techniques to  improve the BTU and remove sulfur
                    from low-rank coals are being developed. For example, SynCoal (Western
                    Energy Company) is  a technology that produces  a fuel with a 0.5 percent
                    sulfur content, a moisture content of greater than 5 percent, a heating value
                    of 11,800 Btu per pound, and ash content of approximately 9 percent.

                    Another related technology that has been researched extensively is co-firing
                    using refuse derived fuel (RDF) pellets and coal in power plants. In 1992,
                    DOE's OIT, in  cooperation with several organizations, operated a power
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                    plant with a mixture of coal and up to 25 percent RDF pellets. The project
                    found that the mixture resulted in reduced acid gas emissions. The CAA
                    amendments of 1990 allow the combustion of up to 30 percent municipal
                    solid waste  hi coal plants.  The results of this project  are facilitating
                    commercialization of the co-combustion technology.
          Cooling Water
                     Cooling water is used hi steam turbine electric power plants and is circulated
                     through the condenser to condense the steam left after the generation of
                     electricity. The resulting condensate can then be pumped back into the high-
                     pressure boiler. Cooling systems may be once-through, where cooling water
                     is discharged into a receiving water body after use, or recirculating, which
                     involves the use of cooling towers, lakes, or ponds.  Scaling of heat exchange
                     equipment and piping occurs from cooling water contact and reduces the
                     efficiency of the equipment. To prevent scaling, chemical additives, such as
                     polyphosphates,  polyester, phosphates, and  polyacrylates, are added to
                     cooling water.  In the past, cooling tower treatment chemicals contained
                     hexavalent chromium.  Recent regulations have restricted the use of chrome-
                     based treatment to reduce the associated public health and  environmental
                     impacts.   As a result, industry has switched to non-chrome treatment
                     chemicals.

                     Corrosion, fostered through aeration of cooling water in cooling towers, is
                     another problem. A number of different chemicals such as zinc, molybdate,
                     silicate, polyphosphate, aromatic azole, carboxylate, and sometimes chromate
                     are added to cooling water for corrosion control. Fouling  and biological
                     growth are  commonly  controlled  through  the addition  of polyester,
                     phosphates, polyacrylates, non-oxidizing biocides, chlorine,  and bromine.

                     Pollution prevention opportunities for cooling water address minimizing
                     chemical additives and conserving water. Table 28 presents a few general
                     pollution prevention recommendations for reducing cooling tower emissions.

                     First and foremost, a facility can determine the optimum chemicals for the
                     prevention of biologic growth and corrosion. In general, chlorinated biocides
                     are less toxic than brominated biocides, and polyphosphate and organo-
                     phosphate inhibitors are less toxic than chromate corrosion inhibitors.
                     Another possible means to reduce the need for chemical additives for control
                     of scaling is magnetic water conditioning.

                     Widespread attention has focused on ozone treatment in lieu of common
                     biocide use.   Ozone  acts to rupture bacterial  cells through oxidation.
                     Reductions in scaling, biofouling,  and overall toxics may be realized from
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                      ozone.  It has been successful mainly in once-through cooling water systems
                      for power plants. Drawbacks in the use of ozone treatment include (1) the
                      potential for corrosion in cooling towers, unless careful dosing is practiced
                      to maintain the oxidation-reduction potential rate and (2) ozone treatments
                      have been shown to exhibit rapid fouling on high temperature surfaces such
                      as would be found in recirculating systems.  In addition, health and safety
                      issues associated with worker exposure to ozone must be considered.
   Table 28: Pollution Prevention Opportunities for Reducing Cooling Tower Emissions
  Pretreat makeup water: Pretreating the makeup water to cooling towers reduces the chemical treatment
  requirements for scale and corrosion control and can increase the number of times cooling water may be recycled
  before blowdown.

  Use inert construction materials:  Polyethylene, titanium, and stainless steel are relatively nonreactive
  compared to carbon steel and require lesser quantities of scale and corrosion inhibitors.

  Install automatic bleed/feed controllers and bypass feeders: By installing this equipment  on the cooling
  towers, facilities have reduced volumes of cooling tower chemicals, as well as energy costs, labor, and water.

  Recirculate the cooling water: When possible, cooling tower water should be recirculated instead of cycling
  once-through the system.

  Use chlorinated biocides: Facilities can use chlorinated biocides instead of brominated biocides to reduce the
  toxicity of biocides.
  Sources: Fact Sheet: Eliminating Hexavalent Chromium from Cooling Towers. City of Los Angeles Board of
  Public Works, Hazardous and Toxic Materials Office. Undated; Fact Sheet: Water and Chemicals Reduction for
  Cooling Towers. North Carolina Department of Environmental Health and Natural Resources, Pollution
  Prevention Program. May 1987; Pollution Prevention/Environmental Impact Reduction Checklist for Coal-Fired
  Power Plants. U.S. Environmental Protection Agency, Office of Federal Activities. Undated.
           Fireside Washes
                      In the combustion of fossil fuels, products of incomplete combustion will rise
                      with gas and collect on boiler tubes and heat transfer units. Fireside wastes
                      consist primarily of bottom ash and damaged refractory brick, which may be
                      contaminated with heavy metals from the ash.  As the buildup increases, the
                      heat exchange efficiency decreases. Periodically, the buildup is removed by
                      applying a large volume of water to the boiler surfaces.  The wash water
                      contains trace metals (nickel, chromium, iron, vanadium, and zinc), calcium,
                      sodium, chlorides, nitrates, sulfates, and organics contained in  suspended
                      soot.  The resulting waste is a wet ash sludge.  This sludge may be co-
                      managed for disposal with large volume combustion waste (fly ash, bottom
                      ash, FGD sludge) or managed separately with other low-volume wastes and
                      treated  through  physical or  chemical  precipitation,  as well as pond
                      evaporation.
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                    Soot blowers use steam, air, or water to clean fireside fouled heat transfer
                    surfaces. The removed soot and ash deposits are either reintroduced into the
                    combustion process, redeposited  for  easier removal,  or captured by
                    particulate control equipment. Sonic horns generate sound waves that cause
                    the heat transfer surface to  vibrate and dislodge  soot and ash.  Manual
                    cleaning includes brushing, sweeping, and vacuuming.

                    Abrasive cleaning methods remove contaminants by blasting a compound at
                    the substrate. Typical blasting compounds are sand, walnut shells, or carbon
                    dioxide pellets. The abrasive cleaning technology field is changing rapidly.
                    New materials that may remove soot and ash without damaging the boiler
                    tubes  and refractory include plastic beads, sodium bicarbonate, and,
                    potentially, liquid CO2.

                    Table 29 provides some examples of pollution prevention opportunities for
                    fireside washes.
Table 29: Pollution Prevention Options for Fireside Washes
Options
Use cleaner fuels
Use alternative cleaning methods
Recycle or reuse fireside wastes
Comments
Natural gas is the cleanest burning fossil fuel, but availability limits
widespread use. Cleaner burning fuel oils and coals are available but
may be cost-prohibitive.
Soot blowers and sonic horns may be used to reduce the need for
washing. Dry ash has higher potential for reuse. Abrasives may be
used but add to waste created.
Lime sludge from treatment may be sold to copper smelters.
Vanadium recovery from fuel oil ash may be feasible. Coal ash can
be used as a substitute for cement in concrete or as structural fill.
Source: Industrial Pollution Prevention Handbook. Freeman, Harry M., ed. McGraw Hill, Inc. 1995.
          Boiler Chemical Cleaning Wastes

                     The purpose of boiler cleaning is to remove scale from the inside (water side)
                     of boiler tubes. The waste generated contains spent cleaning solution and the
                     scaling components: copper, iron, zinc, nickel, magnesium, and chromium.
                     Certain cleaning agents target certain types of boilers and deposits. Boiler
                     cleaning wastewaters may be difficult to treat and, in some cases, fall under
                     the jurisdiction of the Resource Conservation and Recovery Act (RCRA) as
                     a hazardous waste.

                     One way to minimize the volume of boiler cleaning wastes is to optimize the
                     cleaning  frequency.  Specific practices that  help to optimize cleaning
                     frequency include:
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                     •   Maintaining records of operations
                     •   Conducting biweekly chemical analysis to define normal cycle chemistry
                     •   Sampling tubes annually
                     •   Determining the location and/or type of deposits through ultrasonic
                        imaging,  thermocouples,  removable  test  strips,  and  fiberscopic
                        inspections.

                     Controlling the chemistry of the boiler feed water is a significant way to
                     control the rate of scaling. Generally, boiler water is treated through fine
                     filtration, chemical treatment, reverse osmosis, and/or  ion exchange to
                     remove minerals.  Other constituents in the boiler water targeted for removal
                     may include oxygen and carbon dioxide.

                     While most utilities use hydrazine and morpholine in the chemical treatment
                     of boiler feed water,  an elevated oxygen treatment process  has been
                     demonstrated that results hi the  accumulation of a finer-grained, more
                     unified,  magnetite layer that necessitates less frequent cleaning.  To create
                     this condition, oxygen or hydrogen peroxide is added to condensate at a pH
                     of 7 to 7.5, oxygen and ammonia are added at a pH of 8 to 8.5, and ammonia
                     is added at a pH of 9 or greater, until ammonia concentrations of 250 parts
                     per billion are reached.

                     The boiler cleaning frequency may be decreased by reducing the amount of
                     oxygen entering the boiler due to leaks in the system. Leaks can be corrected
                     through inspection and replacement of seals on steam cycle components.
                     Maintenance schedules and monitoring techniques are effective practices in
                     preventing leaks. Furthermore, maintaining high quality performance of the
                     oxygen deaerators will also help to prevent oxygen ingress.

                     Another effective pollution prevention technique is determining the optimum
                     frequency of boiler cleanouts. Utilities should clean the boilers based on the
                     actual deposit thickness instead of according to a predetermined schedule.
                     According to a survey performed by EPRI, one California utility monitors
                     both scale thickness and composition by means of small, retrievable test
                     strips placed inside the boiler. Base unit boilers are now cleaned about once
                     every 72 months, and cycling units are cleaned once every 48 months. Other
                     California utilities report cleaning schedules as often as once every 24
                     months.41

                     On-line  cleaning involves boiler cleaning  while the boiler remains in
                     operation. This can be done by injection of a sodium poly-acrylate additive
                     into the boiler feedwater to a concentration of 400 mg/L.  The most critical
                     outer layer of magnetite is removed, but an inner layer remains. This method
                     requires less cleaning time than traditional boiler cleaning, uses less
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          Fly Ash
                    hazardous chemicals, and results in a more easily handled waste.  The
                    drawbacks of on-line cleaning include the risk of contaminating the steam
                    turbine, less deposits removed, and potentially poor copper removal. Cost
                    savings associated with the use of this technology at a 300-MW unit have
                    been estimated to be $25,000 to $30,000 per year.42

                    Sodium bicarbonate-based blast media can be used in association with
                    specifically designed delivery systems to meet a wide range of cleaning
                    needs,  including general facility  maintenance (e.g., floor cleaning, paint
                    stripping and boiler tube cleaning). Sodium bicarbonate blasting is becoming
                    increasingly common in the electric utility industry.43

                    In areas where water costs are high, utilities may choose to reuse their boiler
                    chemical cleaning wastewater as makeup for  cooling  towers,  fly  ash
                    scrubbers, or flue gas  desulfurization systems.44  Also, depending on the
                    composition of the chemical cleaning sludge, it may be economically feasible
                    to  recycle  the  sludge  for its metal content.  Arizona Electric Power
                    Cooperative (AEPCO),  Incorporated, for example,  uses this  cleaning
                    material, rather than face potentially expensive disposal costs. The EiPA, the
                    Arizona Department of Environmental Quality, the California Department of
                    Toxic  Substances Control,  and the  Occupational Safety  and  Health
                    Administration approved the use of by products from chemical cleaning from
                    AEPCO's boilers.  AEPCO sells the by-product to Pacific Gas & Electric
                    Company for hydrogen sulfide gas abatement at its Geysers Power Plant, a
                    geothermal power generation facility.45

                    Table 30 lists pollution prevention opportunities for boiler cleaning wastes.
                     Fly ash is typically collected in the flue of the combustion  unit and
                     transported to a centralized containment area for treatment and storage. Both
                     wet ash transport and dry collection are commonly practiced.  Some facilities
                     use wet  ash, creating a slurry  as  the  mechanism for transport.  The
                     disadvantage of wet ash transport is that it increases the volume of the ash
                     waste and it must eventually be separated out and treated. In contrast, a dry
                     process control electrostatic precipitator  avoids the added volume due to
                     water and allows the collection of a dry  product  for recycling and/or
                     beneficial reuse.
          Chemical Substitutions
                     Several process modifications described previously have required material
                     substitution (e.g., switching fuels). However, material substitutions are not
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Table 30: Pollution Prevention Options for Boiler Cleaning Wastes
Options
Improve boiler water supply
Control boiler water chemistry
Reduce contaminant ingress
Base cleaning on fouling
Use on-line cleaning
Reuse wastewater
Reuse lime sludge
Control H2S-
Comments
Regenerate ion exchange resins promptly. Install reverse osmosis
equipment ahead of ion exchange systems to reduce mineral loading
and reduce regeneration frequency.
Use hydrazine to control dissolved oxygen and morpholine to
control carbon dioxide.
Improve equipment seals to prevent air and cooling water leaks into
the boiler.
Use coupons to measure scale buildup and schedule cleaning
accordingly.
Sodium polyacrylate injection may be used to remove deposits
without having to shut down boiler. Further research required.
Wastewater may be used for cooling tower makeup or as feedwater
to ash scrubbers and flue gas desulfurization units. Some
pretreatment and/or segregation may be required.
Sludges from lime treatment of chemical cleaning wastes may be
sold to copper smelters for reuse.
Ethylenediamine-tetraacetic acid (EDTA)-based cleaning processes
can produce Fe-EDTA, which is an effective chelating agent for H2S
control.
Source: Adapted from Industrial Pollution Prevention Handbook. Freeman, Harry M., ed. McGraw Hill, Inc. 1995.
          V.C.2
limited  to  major  processes.   Sometimes,  toxic  chemicals  are  used
unnecessarily on a wide-scale basis for  a variety  of operations and
maintenance activities (e.g., cleaning, lubrication). By substituting less toxic
chemicals, a facility can avoid unnecessary risks associated with worker
exposure and the potential for release into the environment.  The first step in
determining the  viability  of material substitutions is to inventory the
chemicals used at the site.  The chemical can be evaluated as to its hazard
potential, its necessity, and possible alternatives. For example, San Diego
Gas and Electric Company determined several different solvents onsite could
be replaced by just a few different solvents.  By eliminating the wide array
of solvents, the company is now able to install a solvent recovery unit, which
will reduce the amount of solvent waste.

Inventory  Management  and  Preventative Maintenance  for Waste
Minimization

Fossil fuel electric power generation facilities, like many industrial facilities,
.use solvents  and other  chemicals for everyday operations.  Everyday
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                     operations  include parts washing,  lubricating,  general cleaning,  and
                     degreasing application during plant and equipment maintenance activities.
                     Often, chemical wastes generated by these operations are made up of out-of-
                     date, necessary, off-specification, and spilled or damaged chemical products.
                     Actual costs for materials used include not  only  the cost of the original
                     product,  but also the costs of disposal.   Inventory management and
                     preventative maintenance are ways these facilities can decrease the amounts
                     of chemical wastes generated in a cost-effective manner.

                     There are two categories of inventory  management including inventory
                     control and material control. Inventory control includes techniques to reduce
                     inventory size, reduce toxic and/or hazardous chemical use, and increase
                     current inventory turnover. Material control includes the proper storage and
                     safer transfer of materials. Proper material control will ensure that materials
                     are used efficiently to reduce waste and preserve the ability to recycle the
                     wastes.

                     Corrective and preventative maintenance can reduce waste generation.  A
                     well run preventative maintenance program will serve to identify the potential
                     for releases and correct problems before material is lost and/or considered a
                     waste. New or updated equipment can use process materials more efficiently,
                     producing less waste.  Table 31 provides examples of inventory management
                     and preventative maintenance waste  minimization techniques that can be
                     used at fossil fuel electric power generation facilities.

           V.C.3     Potential Waste Segregation and Separation Options

                     Fossil fuel electric power generation facilities can reduce their waste disposal
                     costs by carefully segregating their waste streams. In particular, facilities
                     should segregate RCRA nonhazardous  wastes from hazardous wastes to
                     reduce the quantity of waste that must be disposed of as a hazardous waste.
                     For example, facilities should segregate used oil from degreasing solvents
                     because uncontaminated used oil can be recycled or fed into the boiler as a
                     supplemental fuel. Oil contaminated with polychlorinated biphenyls (PCBs)
                     should be segregated from other used oils.  Absorbent material that is not
                     fully saturated with  oils, etc., should be stored separately from saturated
                     material so that it can be reused.  Recycling companies  typically offer a
                     higher price for segregated recyclables (e.g., clean office paper, scrap metal)
                     than mixed waste streams.
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        Table 31: Inventory Management and Preventative Maintenance Waste Minimization
                                               Opportunities
  Inventory Management
  Inventory Control
       Purchase only the quantity of material needed for the job or a set period of time
       Evaluate set expiration date on materials, especially for stable compounds, to determine if they could be extended.
       Search the inventory at other company sites for available stock before ordering additional material
       Purchase material in the proper quantity and the proper container size. If large quantities are needed, purchase in bulk. If the
       material has a short shelf-life or small quantities are needed, purchase in small containers
       If surplus inventories exist, use excess material before new material are ordered
       Contact supplier to determine if surplus materials can be returned.  If not, identify other potential users or markets
       Evaluate whether alternative, non-hazardous substitutes prior to purchase and checked for acceptance at the facility.
  Material Control
       Reduce material loss through improved process operation, increased maintenance and employee training to identify sources of loss
       Handle and manage wastes to allow recycling.
  Maintenance Programs
  Operational and Maintenance Procedures
       Reduce raw material and product loss due to leaks, spills, and off-specification products
       Develop employee training procedures on waste reduction
       Evaluation the need for operational steps and eliminate practices that are unnecessary
       Collect spilled or leaked material for re-use whenever possible
       Consolidate like chemicals and segregate wastes to reduce the number of different waste streams and increase recoverability.
  Preventive Maintenance Programs
      Perform maintenance cost tracking
      Perform scheduled preventive maintenance and monitoring
      Monitor closely "Problem" equipment or processes that are known to generate hazardous waste (e.g., past spills).
  Source: Adapted from "ComEd Operation and Maintenance Manual" and "Pollution Prevention Success" Fact Sheets. Received From
  Edison Electric Institute. July 1997.	
             V.C.4      Recycling Options
                         With the exception of cooling water and used oil, fly ash represents the
                         greatest waste component at fossil fuel plants. For this reason, recycling
                         options for fly ash present a significant opportunity for pollution prevention.
                         Typical uses include incorporating fly ash into construction materials, such
                         as asphalt or cement. However, new uses are being found every day. Table
                         32 lists existing and potential marketable uses for fly ash. More information
                         about the production and use of fly ash and other coal combustion materials
                         can be obtained from the American Coal Ash Association.46
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                        Table 32: Current and Potential Uses for Fly Ash
    Current Uses for Fly Ash
    Flowable fill
    Soil stabilization
    Lightweight aggregate building material
    Roofing materials
    Roofing granules
    Plastics, paint
    Filter cloth precoat for sludge dewatering
    Pipe bedding
    Structural fills
    Concrete and block Portland cement
    Mine reclamation
    Agricultural enhancement
    Road paving: as a sub-base or fill material under a paved road
    Potential Uses for Fly Ash
    Ingredient of golf ball coverings
    Flue gas reactants
    An additive to sewage sludge for use as a soil conditioner
    An alkali reactivity minimizer in concrete aggregate
    The footprint of a structure, a paved parking lot, sidewalk, walkway, or similar structure
                     The Carolina Power and Light (CP&L) is successful in selling 80 to 100
                     percent of the fly ash generated at three coal-fired power plants. The CP&L
                     estimates capital costs to be $1 to $2/ton of fly ash and operation and
                     maintenance costs to be $3 to $4/ton of fly ash. The ash sales revenues have
                     resulted hi reduced disposal costs.  Duke Power has experienced similar
                     success. Duke Power has sold more than 230,000 tons of fly ash and 65,400
                     tons of bottom ash for use hi concrete production. Other markets for the fly
                     ash included plastic manufacturing and asphalt production.  In addition, Duke
                     Power donated 30,000 tons of bottom ash to the State of North Carolina to
                     use as a base in road construction.

                     It should be noted that uses for fly ash vary greatly according to market
                     conditions and transportation costs.  In addition, for most uses, the ash must
                     have a low carbon content. However, available commercial technologies can
                     separate the ash into carbon-rich and carbon-poor fractions.

                     Pollution  prevention associated with  boiler  blowdown was  discussed
                     previously; however, boiler blowdown water may potentially be recycled
                     and used as makeup to cooling tower  waters and flashing blowdown to
                     generate additional steam. This is accomplished through the regeneration of
                     demineralizer waters.
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                      Sulfur is produced .through the cleaning of fuels and ores and the use of clean
                      scrubbers. Recycling options include the following:

                      •   Substituting sulfur for  Portland cement and water to act as a binding
                         agent to produce a durable, acid-resistant concrete
                      •   Using sulfur in  protective coatings  to  improve  the  resistance of
                         conventional building materials to chemical and other stresses; fabric can
                         be impregnated with sulfur and additive materials to produce flexible or
                         rigid lining materials
                      •   Using sulfur as an asphalt extender or as an asphalt replacement to totally
                         eliminate the need for asphalt.

                      The FGD units can produce sulfur, sulfuric acid, gypsum, or some non-
                      saleable sludge material. Select FGD  units can produce saleable materials,
                      as indicated in the following examples:

                      •   Gypsum can be processed into a quality gypsum grade for resale to wall
                         board producers or sold for use in cement manufacturing.
                      •   Sodium sulfate and sulfuric acid can be produced for resale.
                      •   An electron beam scrubbing system can be used to produce ammonium
                         sulfate and ammonium nitrate for sale as a fertilizer supplement.
                      •   A pozzolanic stabilization reaction process can be implemented where
                         lime-based reagent is added to scrubber sludge and fly ash to  create a
                         mineral product suitable for roadway base course.  (Pozzolans are
                         siliceous or siliceous/aluminous materials that, when mixed with lime and
                         water, form cementitious compounds.)

           V.C.5     Facility Maintenance Wastes

                     In addition to the wastes associated with the power production operations,
                     fossil fuel electric power generation facilities also  generate wastes from
                     support operations,  such as facility and equipment maintenance,  storage
                     areas, transportation, and offices.  Pollution prevention techniques can greatly
                     reduce many of these waste streams for relatively little cost.

                     Table 33 highlights several basic pollution prevention options for equipment
                     and facility maintenance. All of the options involve the use of commercially
                     available equipment that is  already in  widespread use.  In addition to the
                     options described in Table 33, common pollution prevention options include:

                     •  Establishing preventive maintenance programs for equipment
                     •  Testing fluids prior to changing them
                     •  Purchasing equipment to enable recycling of antifreeze, solvents, and
                        oil/water mixtures
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                        Purchasing longer lasting/reusable absorbent materials and rags
                        Laundering rags offsite instead of disposing of them
                        Using steam cleaning equipment or sodium bicarbonate blast systems for
                        general facility cleaning
                        Purchasing electric-powered vehicles for onsite use
                        Upgrading bulk storage equipment and spill prevention practices
                        Improving spill containment equipment and equipment for transferring
                        fluids
                        Using low- or no-VOC paints for facility maintenance and restricting
                        color choices
                        Recycling office paper, cardboard, plastics, scrap metals, wood products,
                        etc.
                        Purchasing products with recycled content
                        Finding  alternatives  to replace ozone depleting  substances (e.g.,
                        refrigerants, fire suppression, degreasers)
                        Practicing integrated pest management to reduce the use of pesticides in
                        grounds maintenance operations
                        Using less toxic products for custodial operations.
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Table 33: Pollution Prevention Opportunities For Facility Maintenance Wastes
Options
Comments
Rotating Equipment Maintenance
Use high quality fluids
Routinely monitor fluid condition
Use nonleak equipment
Clean and recycle dirty fluids
Use waste oils as boiler fuel
While costing more initially, high quality fluids may last twice as
long in service.
Waste fluid generation can be reduced by switching to a
replacement schedule based on fluid condition. Low-cost testing
services can provide detailed information.
Use dry disconnect hose couplings, self sealing lock nuts, and
elastomeric flange gaskets to reduce oil leakage. Canned or
magnetically driven pumps, bellow valves, and bellow flanges are
also effective.
Dirty fluids may be cleaned for extended use by small filtration
devices. More complex systems may use centrifugation or vacuum
distillation.
This depends on boiler size, PCB content, and halogen content of
the waste oil. Would not apply to synthetic hydraulic fluids.
Facility Maintenance
Eliminate use of hazardous materials
Replace tricarboxylic acid (TCA) and
chlorofluorocarbons (CFCs) with non-
ODS cleaners
Use high transfer efficiency painting
equipment
Use an enclosed cleaning station
Avoid the removal of leaded paint
Major accomplishments have been made in this area, including
eliminating the use of PCBs, asbestos insulation, chromium-based
cooling water treatment chemicals, and leaded paints.
Petroleum distillate and D-limonene blends are effective cleaners for
electrical equipment. Detergents are good for general purpose
cleaning but must be kept out of yard drains and oil water
separators.
Brushes, rollers, and hand mitts are very efficient but labor-
intensive. Airless spray is common for field use since a source of
clean, dry ah- is not required.
Several air districts mandate the use of enclosed gun cleaners and
prohibit the spraying of cleanup solvent into the air.
Removal of lead-based paint should only be performed when the
paint fails to provide adequate protection. Use wet blasting or
vacuum collective devices to prevent the generation of leaded paint
dust.
Source: Industrial Pollution Prevention Handbook. Freeman, Harry M., ed. McGraw-Hill Inc 1995
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           V.C.6     Storm Water Management Practices

                      An important pollution prevention consideration at fossil fuel electric power
                      generation plants is the management of runoff.  Coal pile runoff is perhaps
                      the most significant.  Coal pile runoff results from precipitation coming into
                      contact with coal storage piles. The most effective way to eliminate coal pile
                      runoff is to store coal indoors.  In many instances, this is not feasible, at
                      which point, pollution prevention turns to managing runoff.  A facility's
                      storm water pollution prevention plan should address storm water controls
                      (e.g., dikes, levies) and the potential for reuse of storm water. Coal-handling
                      areas also represent potential for coal pollutants to contaminate storm water.
                      Table 34 lists practices that can prevent pollutants in coal from contaminating
                      storm water.
           Table 34: Common Pollution Prevention Practices for Managing Runoff at
                               Coal Storage and Handling Areas47	
       Consider rail transport of coal over barge transport, because the potential impacts to water are
       lessened.
       Cover coal off-loading areas, crushers, screens, and conveyors to reduce dust emissions.
       Cover coal storage piles or store in silos to prevent contact with precipitation and to minimize dust.
       Spray coal piles with anionic detergents. This will reduce the acidic content of the pile by reducing
       bacterial oxidation of sulfide minerals.
       Configure a storm water collection system based on slopes, collection ditches, diversions and storage,
       and treatment ponds.
       If settling ponds exist, consider recycling the dredgings.                                  	
                      Some of the practices listed in the table are applicable to fly ash storage and
                      handling areas, as well as coal pile runoff. For example, if dry ash transport
                      is employed, covers will prevent dust and contact with precipitation. Other
                      areas of concern with respect to storm water pollution prevention include fuel
                      and chemical handling and storage areas where there is potential for spills.
                      Table 35 provides some recommended practices that apply to these areas.
                      Ideally, these practices should be addressed in a facility's storm water
                      pollution prevention plan.
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Table 35: Storm Water Pollution Prevention Opportunities at
Fossil Fuel Electric Power Generation Facilities
Areas of Concern
Fuel Oil Unloading Areas
Chemical Unloading/Loading Areas
Miscellaneous Loading/Unloading Areas
Liquid Storage Tanks
Large Bulk Fuel Storage Tanks
Oil-Bearing Equipment Storage Areas
Ash-Loading Areas
Areas Adjacent to Disposal Ponds
Material Storage Areas
Storm Water Pollution Prevention Opportunities
• Use containment curbs to contain spills
• Station personnel familiar with spill prevention and response
procedures at areas during deliveries to ensure quick response for
leaks or spills
• Use spill and overflow protection technologies
• Use containment curbs to contain spills
• Cover area
• Station personnel familiar with spill prevention and response
procedures at areas during deliveries to ensure quick response for
leaks or spills
• Use grading, berming, and curbing to minimize runon
• Locate equipment and vehicles so leaks can be controlled in
existing containment and flow diversion system
• Cover area
• Use dry cleanup methods
• Use containment curbs to contain spills
• Use spill and overflow protection technologies
• Use containment curbs to contain spills
• Use level grades and gravel surfaces to retard flow and limit
spread of spills
• Collect storm water in perimeter ditches
• Establish procedures to reduce or control tracking of ash or
residue from ash loading areas
• Clear ash from building floor and immediately adjacent roadways
of spillage, debris, and excess water before each loaded vehicle
departs
• Reduce ash residue, which can be tracked onto access roads
traveled by residue trucks or residue handling vehicles
• Reduce ash residue on exit roads leading into and out of residue-
handling areas
• Use level grades
• Collect runoff in graded swales or ditches
• Implement erosion protection measures at steep outfall sites
• Provide cover for material
Source: Preamble to NPDES Storm Water Multi-Sector General Permit for Industrial Activities (60 FR 50974 Friday,
September 29, 1995).
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          V.C.7    Training and Supervision Options

                    While the major pollution prevention gains are achieved through process
                    controls and reuse/recycling, many day-to-day common sense practices are
                    relatively easy and inexpensive to incorporate. Through training, these
                    practices can become effective means of pollution prevention.  Examples of
                    proactive employee behavior includes training for careful use and disposal of
                    cleaners and detergents to prevent them from entering floor and yard drains.
                    If these substances do enter the drains, they may interfere with oil/water
                    separators.  Good housekeeping will ensure optimum performance of these
                    treatment units.

          V.C.8    Demand-Side Management Programs

                    In the past, electric utilities have implemented demand-side  management
                    (DSM) programs to achieve two basic objectives: energy efficiency and load
                    management.  Through these  demand-side programs, the utilities have
                    successfully reduced toxic air emissions and achieved cost effectiveness for
                    both the utility and the consumer, mainly by deferring the need to build new
                    power plants.48 The energy efficiency goal has been achieved primarily by
                    reducing the overall consumption of electricity from specific end-use devices
                    and systems by promoting high-efficiency equipment and building design.

                    With the advent of deregulation and restructuring in the utility power
                    generation industry, DSM programs appear to be diminishing.  The industry
                    is reducing DSM spending and experiencing a reduction in the rate of growth
                    on energy savings. Among other factors, the potential for restructuring could
                    affect the utilities interest hi energy savings or may create new types of DSM
                    activities.
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VI.       SUMMARY OF FEDERAL STATUTES AND REGULATIONS

                     This section discusses the Federal regulations that may apply to this sector.
                     The purpose of this section is to highlight and briefly describe, the applicable
                     Federal requirements,  as well  as to provide citations  for more detailed
                     information. This sections includes:

                     •   Section VI. A, a general overview of major statutes
                     •   Section VLB, a list of regulations specific to this industry
                     •   Section VI.C, a list of pending and proposed regulations.

                     The descriptions  within Section VI are intended solely for general
                     information.  Depending upon the nature or scope of the activities at a
                     particular facility, these summaries may or may not necessarily describe all
                     applicable environmental requirements. Moreover, they do not constitute
                     formal interpretations or clarifications of the statutes and regulations.  For
                     further information, readers should consult the Code of Federal Regulations
                     and other state or local regulatory agencies.  This section also provides EPA
                     hotline contacts for each major statute.

VI.A     General Description of Major Statutes

          Resource Conservation and Recovery Act

                     The Resource Conservation And Recovery Act of 1976, which amended the
                     Solid  Waste Disposal Act,  addresses solid (Subtitle D) and hazardous
                     (Subtitle C) waste management activities.  The Hazardous and Solid Waste
                     Amendments (HSWA) of 1984 strengthened RCRA's waste  management
                     provisions and added Subtitle I, which governs underground storage tanks
                     (USTs).

                     Regulations promulgated pursuant to Subtitle  C of RCRA (40 CFR Parts
                     260-299) establish a "cradle-to-grave" system governing hazardous waste
                     from the point of generation to disposal. RCRA hazardous wastes include the
                     specific materials listed in the regulations (listed wastes). Listed wastes are
                     designated with a specific code. Hazardous wastes designated with the code
                     "P" or "U" are commercial chemical products including technical grades,
                     pure forms, off-specification products, sole-active-ingredient products, or
                     spill or container residues of these products. "P" wastes are considered
                     acutely hazardous and are subject to more stringent requirements. Hazardous
                     wastes from specific industries/sources are designated with the code "K" and
                     hazardous wastes from non-specific sources are designated with the code "F."
                     Materials  that exhibit a hazardous waste characteristic (i.e., ignitability,
                     corrosivity, reactivity, or toxicity) are designated with the code "D."
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                    Regulated entities that generate hazardous waste  are  subject to waste
                    accumulation, manifesting, and record keeping standards. Facilities generally
                    must obtain a permit either from EPA or from a State agency that EPA has
                    authorized to implement the permitting program if they store hazardous
                    wastes for more than 90 days before treatment or disposal.  Facilities may
                    treat hazardous wastes stored in less-than-ninety-day tanks or containers
                    without a permit. Subtitle C permits contain general facility standards, such
                    as contingency plans, emergency procedures, record keeping and reporting
                    requirements, financial assurance mechanisms, and unit-specific standards.
                    RCRA also contains provisions (40 CFR Part 264 Subpart S  and §264.101)
                    for conducting  corrective actions that govern the cleanup  of releases of
                    hazardous waste or constituents from solid waste management units at RCRA
                    treatment, storage, and disposal facilities.

                    Although RCRA is a Federal statute, many States implement the RCRA
                    program.  Currently, EPA has delegated authority  to implement  various
                    provisions of RCRA to 47 of the 50 States and two U.S. territories.
                    Delegation has not been given to Alaska, Hawaii, or Iowa.

                    Most RCRA requirements are not industry specific but apply to any company
                    that generates, transports, treats, stores, or disposes of hazardous waste. The
                    following list highlights important RCRA regulatory requirements:

                    •   Identification of solid and hazardous  wastes (40 CFR Part 261) lays
                        out the procedure every generator must follow to determine whether the
                        material in question is considered a hazardous waste or a solid waste or
                        is exempted from regulation.

                    •   Standards  for generators of hazardous waste (40 CFR Part 262)
                        establishes the responsibilities of hazardous waste generators including
                        obtaining an EPA ID number, preparing a manifest, ensuring proper
                        packaging and labeling, meeting standards for waste accumulation units,
                        and fulfilling record keeping and reporting requirements. Providing they
                        meet  additional  requirements  described  in  40  CFR Part 262.34,
                        generators may accumulate hazardous waste for up to 90 days (or 180 or
                        270 days depending on the amount of waste generated and the distance
                        the waste will be transported) without obtaining a Subtitle C permit.

                    •   Land disposal restrictions (LDRs) (40 CFR Part 268) are regulations
                        prohibiting  the  disposal of hazardous  waste on land  without  prior
                        treatment. Under the LDRs program, materials must meet LDR treatment
                        standards prior to placement in a RCRA land disposal unit (landfill, land
                        treatment unit, waste pile, or surface impoundment). Generators of waste
                        subject to the LDRs must provide notification of such to  the designated
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                        treatment, storage, and disposal (TSD) facility to ensure proper treatment
                        prior to disposal.

                     •  Used  oil  management standards  (40  CFR  Part 279)  impose
                        management requirements affecting the storage, transportation, burning,
                        processing, and re-refining of the used oil.  For parties that merely
                        generate used oil, regulations establish storage standards. For a party
                        considered a used oil processor, re-refiner, burner, or marketer (i.e., one
                        who generates and sells off-specification used oil directly to a used oil
                        burner), additional  tracking  and paperwork requirements  must be
                        satisfied.

                     •  RCRA contains  unit-specific standards for all units used to store, treat, or
                        dispose of hazardous waste, including tanks and containers. Tanks and
                        containers used to store hazardous waste with a high volatile organic
                        concentration must meet emission standards under RCRA.  Regulations
                        (40 CFR Part 264-265, Subpart CC) require generators to test the waste
                        to determine the concentration of the waste, to satisfy tank and container
                        emissions  standards, and to inspect and monitor regulated units. These
                        regulations apply to  all facilities that store such waste, including large
                        quantity generators accumulating waste prior to shipment off-site.

                     •   Underground  storage  tanks containing petroleum and hazardous
                        substances are regulated under Subtitle I of RCRA. Subtitle I regulations
                        (40  CFR   Part 280) contain tank design and  release  detection
                        requirements, as well as financial responsibility and corrective action
                        standards  for USTs.    The  UST  program also  includes  upgrade
                        requirements for existing tanks that must be met by December 22, 1998.

                     •   Boilers and industrial furnaces (BIFs) that use or burn fuel containing
                        hazardous waste must comply with design and operating standards.  The
                        BIF regulations  (40  CFR Part 266,  Subpart H) address unit design,
                        provide performance standards, require emissions monitoring, and restrict
                        the type of waste that may be burned.

                     The EPA RCRA, Superfund and EPCRA Hotline, at (800) 424-9346, responds
                     to questions and distributes guidance regarding all RCRA regulations.  The
                     RCRA Hotline  operates -weekdaysfrom 9:00 a.m. to 6:00p.m. ET, excluding
                     Federal holidays.

          Comprehensive Environmental  Response, Compensation,  and Liability Act

                     The Comprehensive  Environmental Response, Compensation, and Liability
                     Act (CERCLA), a 1980 law known commonly as Superfund, authorizes EPA
                     to respond to releases, or threatened releases, of hazardous substances that
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                    may endanger public health, welfare, or the environment.  In addition,
                    CERCLA  enables EPA to force parties responsible for environmental
                    contamination to clean it up or to reimburse the Superfund for response costs
                    (including remediation costs) incurred by EPA. The Superfund Amendments
                    and Reauthorization Act (SARA) of 1986 revised  various sections of
                    CERCLA, extended the taxing authority for the Superfund, and created a
                    free-standing law, SARA Title HI, also known as the Emergency Planning
                    and Community Right-to-Know Act.

                    The CERCLA hazardous substance release reporting regulations (40 CFR
                    Part 302) direct the person hi charge of a facility to report to the National
                    Response Center (NRC) any environmental release of a hazardous substance
                    that equals or exceeds a reportable quantity.  Reportable quantities are listed
                    in 40 CFR §302.4. A release report may trigger a response by EPA or by one
                    or more Federal or State emergency response authorities.

                    The EPA implements hazardous substance responses according to procedures
                    outlined in the National Oil and Hazardous Substances Pollution Contingency
                    Plan (NCP) (40 CFR Part 300). The NCP includes provisions for permanent
                    cleanups, known as remedial actions, and other cleanups referred to as
                    removals.  The  EPA generally takes remedial actions only at sites on the
                    National Priorities List (NPL), which currently includes approximately 1,300
                    sites.   Both EPA and states can act at sites;  however, EPA provides
                    responsible parties the opportunity to conduct removal  and remedial actions
                    and encourages community involvement throughout the Superfund response
                    process.

                    The EPA RCRA, Superfiind and EPCRA Hotline, at (800) 424-9346, answers
                    questions and references guidance pertaining to the Superfund Program.
                    The CERCLA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m. ET,
                    excluding Federal holidays.

          Emergency Planning And Community Right-To-Know Act

                    The Superfund Amendments and Reauthorization Act of  1986 created
                    EPCRA, a statute designed to improve community access to information
                    about chemical hazards and to  facilitate the development of chemical
                    emergency response plans by State and local governments.  The  EPCRA
                    required the establishment  of State  emergency response  commissions
                    (SERCs), which are responsible for coordinating certain emergency response
                    activities and for appointing local emergency planning committees (LEPCs).

                    The EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish
                    four types of reporting obligations for facilities that store or manage specified
                    chemicals:
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                     •   EPCRA §302 requires facilities to notify the SERC and LEPC of the
                        presence of any  extremely  hazardous substance  (the  list  of such
                        substances is in 40 CFR Part 355, Appendices A and B) if it has such
                        substance in excess of the substance's threshold planning quantity and
                        directs the facility to appoint an emergency response coordinator.

                     •   EPCRA §304 requires the facility to notify the SERC and LEPC in the
                        event of a release equaling or exceeding the reportable quantity of a
                        CERCLA hazardous  substance or an  EPCRA extremely hazardous
                        substance.

                     •   EPCRA §311 and §312 require a facility at which a hazardous chemical,
                        as defined by the Occupational Safety and Health Act, is present in an
                        amount exceeding a specified threshold to submit to the SERC, LEPC,
                        and local fire department material safety data sheets (MSDSs) or lists of
                        MSDS's and hazardous chemical inventory forms (also known as Tier I
                        and II forms). This information helps the local government respond in
                        the event of a spill or release of the chemical.

                     •   EPCRA §313 applies to facilities covered in SIC major groups  10
                        (except 1011,1081, and 1094), 12 (except 1241), or 20 through 39; SIC
                        codes 4911,1193, and 4939 (limited to facilities that combust coal and/or
                        oil for the purposes of generating power for distribution in commerce);
                        or 4935 (limited to facilities regulated under RCRA, Subtitle C), or 5169,
                        or 5171, and 7389 (limited to facilities  primarily engaged in solvent
                        recovery services on a contract or fee basis).  These facilities must also
                        have  10 or more employees and manufacture, process, or use specified
                        chemicals in amounts greater than threshold quantities.  Facilities that
                        meet these criteria must submit an annual toxic chemical release report.
                        This  report, commonly  known as the Form R, covers releases and
                        transfers  of toxic chemicals to various facilities and environmental media
                        and allows EPA to compile the national TRI database.

                    All information submitted pursuant to EPCRA regulations  is publicly
                    accessible, unless protected by a trade secret claim.

                    The EPA RCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers
                    questions and distributes guidance regarding the EPCRA regulations. The
                    EPCRA Hotline operates weekdays from  9:00 a.m. to 6:00 p.m. ET,
                    excluding Federal holidays.
          Clean Water Act
                    The primary objective of the Federal Water Pollution Control Act, commonly
                    referred to as the Clean Water Act (CWA), is to restore and maintain the
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                     chemical, physical, and biological integrity of the Nation's surface waters.
                     Pollutants regulated under the CWA include "priority" pollutants, including
                     various toxic pollutants; "conventional"  pollutants, such  as biochemical
                     oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and
                     grease, andpH; and "nonconventional" pollutants, including any pollutant not
                     identified as either conventional or priority.

                     The  CWA regulates both  direct and indirect discharges.  The NPDES
                     Program (CWA §502) controls direct discharges into waters of the U.S.
                     Direct discharges or "point source" discharges are from sources such as pipes
                     and sewers. NPDES permits, issued by either EPA or an authorized State
                     (EPA has authorized 42 States to administer the NPDES Program), contain
                     industry-specific, technology-based limits and may also include additional
                     water quality-based limits, and establish pollutant monitoring requirements.
                     A facility that intends to discharge into the Nation's waters must obtain a
                     permit prior to  initiating its discharge. A permit applicant must provide
                     quantitative analytical data identifying the types of pollutants present in the
                     facility's effluent.  The permit will then set the conditions and effluent
                     limitations on the facility discharges.

                     A NPDES permit may also include discharge limits based on Federal or State
                     water quality criteria or standards that were designed to protect designated
                     uses of surface waters, such as supporting aquatic life or recreation. These
                     standards, unlike the technological standards, generally do not take into
                     account  technological  feasibility or costs.   Water quality  criteria and
                     standards vary  from State to State and site to site, depending on the use
                     classification of the receiving body of water.  Most States follow EPA
                     guidelines, which propose aquatic life and human health criteria for many of
                     the 126 priority pollutants.

                     Storm Water Discharges

                     In 1987, the CWA was amended to require EPA to establish a program to
                     address storm water discharges.  In response, EPA promulgated the NPDES
                     storm  water permit application regulations. These regulations require
                     facilities with the following storm water discharges to apply for a NPDES
                     permit:  (1) a discharge associated with industrialjtGtiyily, (2) a discharge
                     from a large or medium municipal storm sewer system, or (3) a discharge that
                     EPA or the State determines to contribute to a violation of a water quality
                     standard or is a significant contributor of pollutants to waters of the United
                     States.

                     The term "storm water discharge associated  with  industrial activity" is a
                     storm water discharge from 1 of 11 categories of industrial activity defined
                     at 40 CFR 122.26.  Six of the categories are defined by SIC codes, while the
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                     other five are identified through narrative descriptions of the regulated
                     industrial activity.  If the primary SIC code of the facility is one of those
                     identified in the regulations, the facility is subject to the storm water permit
                     application requirements. If any activity at a facility is covered by one of the
                     five narrative categories, storm water discharges from those areas where the
                     activities occur are subject to  storm water discharge permit  application
                     requirements.

                     Those facilities/activities that are subject to storm water discharge permit
                     application requirements are identified in the following list:

                     •   Category I: Facilities subject to storm water effluent guidelines, new
                         source performance standards, or toxic pollutant effluent standards.

                     •   Category ii: Facilities classified as SIC 24-lumber and wood products
                         (except wood kitchen cabinets); SIC code 26-paper and allied products
                         (except paperboard containers and products); SIC code 28-chemicals and
                         allied products  (except  drugs and paints); SIC code 291-petroleum
                         refining; and SIC code 311-leather tanning and finishing; SIC code 32
                         (except 323)-stone, clay, glass, and concrete, 33-primary metals, 3441-
                         fabricated structural metal, and 3 73-ship and boat building and repairing.

                     •   Category iii: Facilities classified as SIC code 10-metal mining; SIC
                         code 12-coal mining; SIC code 13-oil and gas extraction; and SIC code
                         14-nonmetallic mineral mining.

                     •   Category iv: Hazardous waste treatment, storage, or disposal facilities.

                     •   Category v:  Landfills,  land application sites, and  open dumps that
                         receive or have received industrial wastes.

                     •   Category vi: Facilities classified as SIC code 5015-used motor vehicle
                         parts; and SIC code 5093-automotive scrap and waste material recycling
                         facilities.

                     •   Category vii: Steam electric power generating facilities.

                     •   Category  viii:     Facilities  classified  as   SIC  code  40-railroad
                        transportation; SIC code 41-local passenger transportation; SIC code 42-
                        trucking and warehousing (except public warehousing and storage); SIC
                        code 43-U.S. Postal Service; SIC code 44-water transportation; SIC code
                        45-transportation by air; and SIC code 5171-petroleum bulk  storage
                        stations and terminals.

                     •  Category ix: Sewage treatment works.
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                    •   Category x: Construction activities except operations that result in the
                        disturbance of less than five acres of total land area.

                    •   Category xi:  Facilities classified as SIC code 20-food and kindred
                        products;  SIC code  21-tobacco  products; SIC code 22-textile mill
                        products; SIC code 23-apparel related products; SIC code 2434-wood
                        kitchen cabinets manufacturing; SIC code 25-furniture and fixtures; SIC
                        code 265-paperboard containers  and boxes;  SIC code 267-converted
                        paper and paperboard products; SIC code 27-printing, publishing, and
                        allied industries; SIC code 283-drugs; SIC code 285-paints, varnishes,
                        lacquer, enamels, and allied products; SIC code 30-rubber and plastics;
                        SIC code 31-leather and leather products (except leather and tanning and
                        finishing); SIC code  323-glass products; SIC code 34-fabricated metal
                        products (except fabricated structural metal); SIC code 35-industrial and
                        commercial machinery and computer equipment; SIC code 36-electronic
                        and  other electrical equipment and  components; SIC  code 37-
                        transportation equipment (except ship and boat building and repairing);
                        SIC code 38-measuring, analyzing, and controlling instruments; SIC code
                        39-miscellaneous manufacturing  industries; and SIC code 4221-4225-
                        public warehousing and storage.

                    To determine whether a particular facility falls within one of these categories,
                    consult the regulation.

                    Pretreatment Program

                    Another type of discharge that is regulated by the CWA is one that goes to
                     a publicly-owned treatment  works (POTWs). The national pretreatment
                    program  (CWA  §307(b)) controls the indirect discharge of pollutants to
                    POTWs by "industrial users." Facilities regulated under §307(b) must meet
                     certain pretreatment standards.  The goal of the pretreatment program is to
                     protect municipal wastewater treatment plants from damage that may occur
                     when hazardous, toxic, or other wastes are discharged into a sewer system
                     and to protect the quality of sludge generated by these plants. Discharges to
                     a POTW are regulated primarily by the POTW itself, rather than the State or
                     EPA.

                     The EPA has developed technology-based standards for industrial users of
                     POTWs.  Different standards apply to existing and new sources within each
                     category. "Categorical" pretreatment standards applicable to an industry on
                     a nationwide basis are  developed by EPA.  In  addition, another kind of
                     pretreatment standard, "local limits," are developed by the POTW in order to
                     assist the POTW in achieving the effluent limitations in its NPDES permit.
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                    Regardless of whether a State is authorized to implement either the NPDES
                    or the pretreatment program, if it develops its own program, it may enforce
                    requirements more stringent than Federal standards.

                    Spill Prevention. Control and Countermeasure Plans

                    The 1990 Oil Pollution Act requires that facilities that could reasonably be
                    expected to discharge oil hi harmful quantities prepare and implement more
                    rigorous Spill Prevention Control and Countermeasure (SPCC) Plan required
                    under the CWA (40 CFR §112.7). There are also criminal and civil penalties
                    for deliberate or negligent spills of oil. Regulations covering response to oil
                    discharges and contingency plans (40 CFR Part 300), and Facility Response
                    Plans to  oil discharges (40 CFR §112.20) and for  PCB transformers and
                    PCB-containing items were revised and finalized in 1995.

                    EPA's Office of Water, at (202) 260-5700, will direct callers that questions
                    about the CWA to the appropriate EPA office.   EPA also  maintains a
                    bibliographic database  of Office  of Water publications -which can be
                    accessed through the Ground Water and Drinking Water Resource Center,
                    at (202) 260-7786.
          Safe Drinking Water Act
                    The Safe Drinking Water Act (SDWA) mandates  that EPA  establish
                    regulations to protect human health from contaminants in drinking water.
                    The law authorizes EPA to develop national drinking water standards and to
                    create a joint Federal-State system to ensure compliance with these standards.
                    The SDWA also directs EPA to protect underground sources of drinking
                    water by controlling underground injection of liquid wastes.

                    The EPA has developed primary and secondary drinking water standards
                    under its SDWA authority.  The EPA and authorized States enforce the
                    primary  drinking  water  standards,  which  are contaminant-specific
                    concentration limits that apply to certain public drinking water supplies.
                    Primary drinking water standards consist of maximum contaminant level
                    goals  (MCLGs), which are non-enforceable,  health-based goals,  and
                    maximum contaminant levels (MCLs), which are enforceable limits set as
                    close to MCLGs as possible, considering cost and feasibility of attainment.

                    The SDWA Underground Injection Control (UIC) Program (40 CFR Parts
                    144-148) is a permit program that protects underground sources of drinking
                    water by regulating five classes of injection wells. The UIC permits include
                    design, operating, inspection, and monitoring requirements. Wells used to
                    inject hazardous wastes must also comply with RCRA corrective action
                    standards in order to be granted a RCRA permit and must meet applicable
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                    RCRA land disposal restrictions standards.  The UIC permit program is
                    primarily State-enforced, since EPA has authorized all but a few States to
                    administer the program.

                    The SDWA also provides for a Federally-implemented sole source aquifer
                    program, which prohibits Federal funds from being expended on projects that
                    may contaminate the sole or principal source of drinking water for a given
                    area, and for a State-implemented wellhead protection program which is
                    designed to protect drinking water wells and drinking water recharge areas.

                    The EPA Safe Drinking Water Hotline, at (800) 426-4791, answers questions
                    and distributes guidance pertaining to SDWA standards.  The  Hotline
                    operates from 9:00 am. through 5:30 p.m. ET, excluding Federal holidays.
          Toxic Substances Control Act
                    The Toxic Substances Control Act (TSCA) granted EPA authority to create
                    a regulatory framework to collect data on chemicals in order to evaluate,
                    assess, mitigate, and control risks that may be posed by their manufacture,
                    processing, and use. TSCA provides a variety of control methods to prevent
                    chemicals from posing unreasonable risk.

                    The TSCA standards may apply at any point during a chemical's life cycle.
                    Under TSCA §5, EPA has established an inventory of chemical substances.
                    If a chemical is not already on the inventory and has not been excluded by
                    TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to
                    manufacture or import. The PMN must identify the chemical and provide
                    available information on health and environmental effects. If available data
                    are not sufficient to evaluate the  chemical's effects, EPA can impose
                    restrictions pending the development of information on  its health and
                    environmental effects. The EPA can also restrict significant new uses of
                    chemicals based upon factors such as the projected volume and use of the
                    chemical.

                    Under TSCA §6, EPA can ban the manufacture or distribution in commerce
                    of, limit the use of, require labeling for, or place other  restrictions on
                    chemicals that pose unreasonable risks. Among the chemicals EPA regulates
                    under §6 authority are asbestos, CFCs, and PCBs.

                    The EPA TSCA Assistance Information Service, at (202) 554-1404, answers
                    questions and distributes guidance pertaining to TSCA standards.  The
                    Service operates from 8:30 a.m. through 4:30 p.m.  ET, excluding Federal
                    holidays.
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           Clean Air Act
  Section VI. Federal Statutes and Regulations
                     The Clean Air Act and its  amendments, including the Clean Air Act
                     Amendments (CAAA) of 1990, are designed to "protect and enhance the
                     nation's air resources so as to promote the public health and welfare and the
                     productive capacity of the population." The CAA consists of six sections,
                     known, as titles, that direct EPA to establish national standards for ambient
                     air quality and for EPA and the States to implement, maintain, and enforce
                     these standards through a variety of mechanisms.  Under the CAAA, many
                     facilities will be required to obtain permits for the first tune. State and local
                     governments oversee, manage, and enforce many of the requirements of the
                     CAAA.  The CAA regulations appear at 40 CFR Parts 50-99.

                     Pursuant to Title I of the CAA, EPA has established NAAQS to limit levels
                     of criteria pollutants, including carbon monoxide (CO), lead (Pb), NO2, PM,
                     ozone, SO2, and volatile organic compounds (VOCs).  Geographic areas that
                     meet NAAQS for a given pollutant are classified as attainment areas; those
                     that do not meet NAAQS are classified as non-attainment areas.  Under
                     section 110 of the CAA, each State must develop a State Implementation
                     Plan (SIP)  to identify sources of air pollution  and to determine what
                     reductions are  required to  meet Federal air quality standards.  Revised
                     NAAQS for particulates and ozone were proposed in 1996 and may go into
                     effect as early as late 1997.

                     Title I also authorizes EPA  to establish new source performance standards
                     (NSPS), which are nationally uniform emission standards for new stationary
                     sources falling within particular industrial categories. NSPS are based on the
                     pollution control technology available to that category of industrial source.

                     Under Title I, EPA establishes and enforces national emission standards for
                     hazardous air pollutants (NESHAPs), which are nationally uniform standards
                     oriented towards controlling particular HAPs. Title I, section 112(c) of the
                     CAA further directed EPA to develop a list of sources that emit any of 188
                     HAPs and to develop regulations for these categories of sources. To date,
                     EPA has listed 174 categories and developed a schedule for the establishment
                     of emission standards. The emission standards will be developed for both
                     new and existing sources based on maximum achievable control technology
                     (MACT). The  MACT is defined as the control technology achieving the
                     maximum degree of reduction in the emission of the HAPs.

                     Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
                     and planes.  Reformulated gasoline, automobile pollution control devices,
                     and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
                    uses to regulate mobile air emission sources.
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                    Title IV of the CAA establishes a SO2 and NO2 emissions control program
                    designed to reduce the formation of acid rain. Reduction of sulfur dioxide
                    releases will be obtained by granting to certain sources limited emissions
                    allowances, which, beginning hi 1995, will be set below previous levels of
                    SO2 sulfur dioxide releases.  Reduction of nitrogen will be obtained by
                    required reduction of nitrogen oxides from power plants and new cars.

                    Title V of the CAA of 1990 created a permit program for all "major sources"
                    (and certain other sources) regulated under the CAA.  One purpose of the
                    operating permit is to include in a single document  all air emissions
                    requirements that apply to a given facility. States are developing the permit
                    programs in accordance with guidance and regulations from EPA. Once EPA
                    approves a State program that state will issue and monitor permits.

                    Title VI of the CAA is intended to protect stratospheric ozone by phasing out
                    the manufacture of ozone-depleting chemicals and restrict their use and
                    distribution. Production of Class I substances, including 15 kinds of CFCs
                    and chloroform, were phased out (except for essential uses) in 1996.

                    The EPA Clean Air Technology Center, at (919) 541-0800, provides general
                    assistance and information on CAA standards. The Stratospheric Ozone
                    Information Hotline, at (800) 296-1996, provides general information about
                    regulations promulgated under Title VI of the CAA, and the EPA EPCRA
                    Hotline, at (800) 535-0202, answers questions about accidental release
                    prevention under CAA §112(r).  In addition, the Clean Air  Technology
                    Center's website includes recent CAA rules, EPA guidance documents, and
                    updates of EPA activities (http://www.epa.gov/ttn then select Directory and
                    then CATC).
VLB     Industry Specific Requirements
                    Since the 1960s, there has been an increased public awareness that industrial
                    growth, as well as its inherent need for energy produced using fossil fuels, is
                    accompanied by  the  release of potentially  harmful pollutants into  the
                    environment. Hence, the fossil fuel electric power generation industry has
                    become one of  the most highly regulated industries.  In  addressing
                    environmental issues, the industry has moved from providing not only the
                    lowest cost energy, to providing the lowest cost energy with an acceptable
                    impact on the environment. Air pollution control has been of most concern,
                    with a significant percentage of the cost of a power plant going towards the
                    purchase of air pollution control equipment. However, control of hazardous
                    effluent discharges and proper management and disposal of solid wastes have
                    also been key concerns. This section summarizes the current major Federal
                    regulations affecting the fossil fuel electric power generation industry.
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 Fossil Fuel Electric Power Generation	Section VI. Federal Statutes and Regulations

           National Environmental Policy Act

                     The National Environmental Policy Act of 1969 (NEPA) applies to all
                     Federal agencies and to Federal actions that may significantly impact the
                     environment. The NEPA requires that all Federal agencies prepare detailed
                     statements assessing the environmental impact of, and alternatives to, major
                     Federal actions that  may significantly affect the quality of the  human
                     environment.  Implementing regulations are issued by the Council on
                     Environmental  Quality  (CEQ) at  40  CFR  Parts  1500-1508.  NEPA
                     implementing regulations that are most applicable to the fossil fuel electric
                     power generation industry can be found at 40 CFR Part 6 (EPA) and 10 CFR
                     Part 1021 (DOE). Each government agency has issued its own implementing
                     regulations under NEPA. The types of Federal activities associated with
                     fossil fuel electric power generating facilities that may be subject to NEPA
                     requirements include siting, construction, and operations of federally owned
                     facilities, federally issued NPDES, RCRA, and air permits, and federally
                     issued operation licenses.

                     Each Federal activity subject to NEPA must follow certain environmental
                     review procedures. If there is enough information to determine at the outset
                     that the Federal action will cause a significant effect on the environment, then
                     an environmental impact statement (EIS) must be prepared.  If there is
                     insufficient information available, an environmental assessment (EA) must
                     be prepared to assist the agency in determining if the impacts are significant
                     enough to require an EIS. If the assessment shows the impacts not to be
                     significant, the agency must prepare a finding of no significant impact.
                     (FONSI). Further stages of the Federal activity may then be excluded from
                     the NEPA requirements.

          Clean Air Act

                     Numerous existing standards and programs under the Clean Ah- Act may
                     affect the fossil fuel electric power generation industry. These regulations
                     and programs include Title I New Source Performance Standards, Title III
                     National Emissions Standards for Hazardous Air Pollutants, Title IV Acid
                     Rain Program, and Title V Operating Permits Program.  The NAAQS under
                     Title I may affect the industry indirectly through permits.

                     National Ambient Air Quality Standards

                     Regulations for NAAQS do not directly affect the fossil fuel electric power
                     generation industry because they are not applied to sources. Rather, these
                     standards  are applied to the ambient  air in a particular area. Fossil fuel
                     electric power generators  may be indirectly affected by these standards if
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r
             Fossil Fuel Electric Power Generation
 Section VI.  Federal Statutes and Regulations
                                 they are located in or near an area with nonattainment status. In meeting
                                 NAAQS, States develop and implement SIPs that prescribe use of reasonably
                                 available control technologies (RACTs) for major sources. In addition, as
                                 fossil fuel electric power generation facilities are typically one of the largest
                                 emitters of criteria pollutants, they may be targeted for more stringent
                                 controls implemented through operating permits.

                                 The NAAQS currently exist for the following criteria pollutants (40 CFR
                                 Part 50): PM10, SO2, CO, Pb, ozone, andNOx.

                                 On July 16, 1997, new and/or revised standards for particulate matter and
                                 ozone were promulgated. The regulations revise the current primary standard
                                 by adding a new annual PMZS (or PM "fine")  standard set at 15 micrograms
                                 per cubic meter (|J.g/m3) and a new 24-hour PM2 5 standard set at 65 ug/m3.
                                 These regulations revise the current 1-hour primary standard for ground level
                                 ozone by adding an 8-hour standard set at 0.08 ppm (the 1-hour standard will
                                 eventually be phased out).

                                 Among the tools proposed for implementing these new ambient standards is
                                 a trading plan for emissions from utilities. The new standards will require
                                 local controls  in 2004 for ozone  and  2005 for particulate matter, with
                                 compliance by 2007 and 2008, respectively.

                                 A group called the Ozone Transport Assessment Group (OTAG) was formed
                                 between EPA, the Environmental Council of States, and various industry and
                                 environmental groups. The primary objective of OTAG is the collective
                                 assessment of the ozone transport problem and the development of a strategy
                                 for reducing ozone pollution on a regional scale.

                                 New Source Review and New Source Performance Standards

                                 New source review (NSR) requirements in 40 CFR §52.21 (b)(l)(I)(a)-(b)
                                 apply to all new facilities and may apply to expansions of existing facilities
                                 or process modifications.  The NSRs are  typically conducted  by State
                                 agencies in accordance with their SIP. SIPs are the primary tool for meeting
                                 NAAQS and are administered through State and local agencies.

                                 Prevention of significant deterioration (PSD) reviews are performed for areas
                                 meeting NAAQS. Nonattainment reviews are performed for areas violating
                                 the NAAQS. In nonattainment areas, permits may be issued to require new
                                 sources to meet  lowest achievable  emission  rate  (LAER) standards.
                                 Operators of the new sources must procure reductions hi emission of the
                                 same pollutants from other  sources in the nonattainment area in equal  or
                                 greater amounts to the emissions from the new  source.  These "emission
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                    offsets" may be banked and traded through the State agencies. In PSD areas,
                    permits require the best available control technology (BACT), and the
                    operator must conduct continuous air monitoring for one year prior to the
                    startup of the new source to determine the effects that the new emissions may
                    have on air quality.

                    Under NSPS, given at 40 CFR Part 60, EPA sets standards for LAER and
                    BACT for the following subcategories of the fossil fuel electric power
                    generation industry:

                    •   Subpart D:    Standards of Performance for Fossil-Fuel-Fired Steam
                                     Generators for Which Construction Is Commenced After
                                     August 17, 1971

                    •   Subpart Da:   Standards of Performance for Fossil-Fuel-Fired Steam
                                     Generators for Which Construction Is Commenced After
                                     September 18, 1978

                    •   Subpart Db:   Standards of Performance for Industrial-Commercial-
                                     Institutional Steam Generating Units

                    •   Subpart DC:   Standards of Performance for Small Industrial-
                                     Commercial-Institutional Steam Generating Units

                    •   Subpart GG:   Standards of Performance for Stationary Gas Turbines.

                    The standards in each subcategory apply to units  of a specified size and
                    age. Table 36 provides the NSPS.
Table 36: New Source Performance Standards
Emission
SO2
NOX
PM
Opacity
Standards
General standard for various levels of ng/J (Ib/mm Btu) heat input and %
reduction, depending on fuel type and sulfur content (see 40 CFR Subparts D, Da,
Db, and DC).
For gas turbines, no gases in excess of 0.015% by volume (at 15% O2 by volume)
or with sulfur contents in excess of 0.8% by weight shall be burned.
Between 0.2 and 0.8 Ib/mm BTU, depending on category of combustion. For gas
turbines, NOX standards specified hi equation hi 60.332(a)(l) or (2) as directed in
60.332(b), (c), and (d).
Between 0.05 and 0.20 Ib/mm BTU, unless a low nitrogen fuel is used, in which
case compliance is based on results of performance tests.
20%.
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Fossil Fuel Electric Power Generation       Section VI. Federal Statutes and Regulations

                    National Emission Standards for Hazardous Air Pollutants

                    Current regulations at 40 CFR Part 61 provide standards for eight substances
                    identified  as air toxics:  vinyl  chloride,  mercury, beryllium, radon,
                    radionuclides, benzene, asbestos, and arsenic. Under Title III of the CAA,
                    EPA is required to  identify source categories of 188 HAPs or toxic air
                    pollutants and then issue (at 40 CFR  Part 63) MACT standards for each
                    source category according to a prescribed schedule. The standards are to be
                    based on best demonstrated control technologies or  practices  within the
                    regulated industry. Eight years after a MACT is installed on a source, EPA
                    is required to evaluate the risk levels remaining at the facilities and determine
                    whether additional controls are needed to reduce the risk to acceptable levels.
                                                            (
                    The EPA has issued an initial list of categories of major and area sources that
                    will be subject to regulation under Section 112 (57 FR 31576).  The list
                    contains numerous sources from the fossil fuel electric power  generation
                    industry, and standards are currently being developed under the Industrial
                    Combustion Coordinated Rulemaking (see Section VI.C.).

                    Acid Rain Program

                    The 1990 amendments to the CAA added a new provision (Title IV) to
                    control acid deposition. Title IV of the CAAA sets primary goals to reduce
                    annual emissions of both SO2 and NO2.

                    Upwards of 20 million tons of SO2 are emitted annually in the United States.
                    Most of this amount is from the burning of fossil fuels by electric utilities.
                    Because acid rain is a problem, Title  IV requires EPA to reduce  SO2
                    emissions to 10 million tons below the 1980 level. Reduction hi SO2 will be
                    attained in two phases by a marketable emission allowance program (40 CFR
                    Part 73). Phase I, which became effective in January 1995, required 110
                    power plants to reduce their emissions to a level equivalent to the product of
                    an emissions rate of 2.5 pounds (Ibs) of SO2/mmBtu times an average of their
                     1985-1987 fuel use.  Plants that use certain control technologies to meet the
                    Phase I reduction requirements received a 2-year extension of compliance
                    until 1997. The new law also allows for special allocation of 200,000 annual
                    allowances per year, in each of the 5 years of Phase  I, to power plants in
                    Illinois, Indiana, and Ohio.

                    Under the new requirements,  utilities may trade allowances within their
                    systems and/or buy  or sell allowances to and from other affected sources.
                    Phase I facilities  were  allocated allowances based on historic  fuel
                    consumption and a specific emission rate.  One allowance equals the right to
                    emit one ton of SO2.  Affected facilities are required to turn into the EPA one
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Fossil Fuel Electric Power Generation
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                    allowance for each ton emitted in a calendar year. Unused allowances may
                    be sold, traded, or banked by the facilities.  Power plants that do not have
                    sufficient allowances  to cover annual emissions  are subject to fees  and
                    requirements to offset the excess emissions the following year.

                    Power plants that emit less than  1.2 Ibs of SO2/mmBtu are allowed to
                    increase emissions by 20 percent until the year 2000.

                    Phase II of the CAAA SO2 reduction requirement becomes effective January
                    1, 2000, and affects all utilities generating  at least 25 MW of electricity.
                    These requirements require approximately 2,128 electric power utilities to
                    reduce emissions to a level equivalent to the product of an emissions rate of
                    1.2 Ibs of SO2/mmBtu times the average of their 1985-1987 fuel use. SO2
                    emissions from electric utilities will be capped at 8.95 million tons per year.

                    Title IV of the CAAA requires a 2 million ton reduction in NOX emissions
                    from 1980 levels. The EPA has developed regulations to help reduce NOX
                    emissions that may affect the fossil fuel electric power generation industry.
                    As hi the SO2 reduction program, the NOX Emission Reduction Program is
                    being implemented in two phases for two categories of coal-fired electric
                    utility boilers. The NOX program differs from the SO2 program in that it
                    neither "caps" the NOX emissions, nor utilizes an allowance trading system.

                    Phase I  of the program for "Group I" boilers was effective on January 1,
                    1996, and affected dry-bottom wall fired boilers and tangentially fired boilers
                    that are required to meet NOX performance standards (40 CFR Part 76).
                    Regulations for Phase II of the NOX reduction program were promulgated in
                    December 1996.  These rules become effective in the year 2000.  These
                    regulations set lower emission limits for Group 1 boilers.  In addition, the
                    regulation establishes initial NOX emission limitations for Group 2 boilers.
                    Group 2 boilers include boilers applying cell burner technology, cyclone
                    boilers, wet bottom boilers, and other types of coal-fired boilers.

                    Facilities covered by the Acid Rain Program must apply for an Acid Rain
                    Permit. Most utilities must apply for permits in either Phase I or Phase II of
                    the program. Two categories of utility units may be eligible for exemption:
                    small new units burning clean fuels and retired units. Some cogeneration
                    units are not covered under the program.

                    To support the mandated reductions in SO2 and NOX, the 1990 CAAA also
                    required EPA to issue regulations requiring facilities to install continuous
                    emissions monitoring systems (40 CFR Part  75).  Fossil fuel electric power
                    generation units over 25 megawatts and new units under 25 megawatts that
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Fossil Fuel Electric Power Generation
  Section VI.  Federal Statutes and Regulations
                     use fuel with a sulfur content greater than .05 percent by weight are required
                     to measure and report emissions under the Acid Rain Program.

                     Federal/State Operating Permits Programs

                     Title V  of the CAAA requires the development of a comprehensive
                     permitting program to control air emissions from major stationary sources.
                     Major sources include those that emit 100 tons/year or more of VOCs or
                     criteria pollutants, 10 tons/year or more of any single toxic air pollutant, or
                     25 tons/year or more of a combination of toxic air pollutants. This program
                     is modeled after the NPDES program under the CWA and serves to bring
                     together all of the requirements concerning air emissions that apply to
                     affected sources. Like the NPDES program, administration of the operating
                     permit program is also delegated to States with approved programs.

                     This program requires all significant sources of air  emissions to obtain
                     permits.   In general, utility fossil fuel steam electric  power plants are all
                     considered major sources, so they will most likely be required to obtain
                     permits.  Other types of fossil fuel electric power generation facilities, such
                     as those employing small gas turbines, may not be considered a major source
                     and may not be required to apply for a permit. Any operational change that
                     increases emissions above specified limits will most likely necessitate permit
                     modifications.   Permit terms are determined by State  regulations  for
                     delegated programs but may not exceed 5 years.

          Clean Water Act

                     Wastewater discharges from fossil fuel electric power generation facilities
                     released to waters of the United States  are covered under the CWA. Any
                     point source discharge is required to apply for, and obtain, an NPDES permit
                     (40 CFR Part 122). Permits may be issued by EPA or a State, depending
                     upon whether the State has a delegated program. The NPDES permits serve
                     to regulate point source discharges by establishing pollutant limitations  and
                     other special conditions.  Facilities discharging to a POTW may be required
                     to obtain a permit from a POTW that has an approved pretreatment program.

                     Current technology-based effluent limitations guidelines and pretreatment
                     standards for discharges from the steam electric generating point source
                     category were promulgated in 1982 (40 CFR Part 423).  The waste streams
                     covered and parameters limited are summarized in Table 37 below.
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Table 37: Waste Streams and Pollutants Regulated Under National Effluent Limitation
Guidelines for the Steam Electric Generating Point Source Category
Type of Waste Stream
All discharges
Bottom ash transport waters and low volume waste
sources
Chemical boiler metal cleaning wastes
Non-chemical metal cleaning wastes
Fly ash transport water (including economizer ash)
Once-through cooling water
Cooling tower blowdown
Coal pile runoff
BAT Effluent Limitations Guidelines
pH , PCBs
TSS, oil and grease
TSS, oil and grease, iron, and copper
Reserved (low volume wastewater limits apply)
No discharge allowed (based on the availability of dry
disposal methods and the potential for reuse of fly ash
transport water)
Total residual chlorine (TRC) or free available chlorine
(FAC), depending on facility's generating capacity
FAC, chromium, zinc, other 126 priority pollutants where
they are found in chemicals used for cooling tower
maintenance
TSS
                     In general, steam electric facilities built after 1982 are considered new
                     sources and must comply with the 1982 effluent limitations.  Less stringent
                     guidelines may apply for facilities constructed between 1974 and 1982 (see
                     1974 guidelines and standards).  Steam electric generating facilities that have
                     been repowered are considered new sources.

                     Steam electric facilities that discharge to a POTW may be required to meet
                     pretreatment standards for existing sources  (PSES) or for new sources
                     (PSNS).   General pretreatment  standards applying  to  most  industries
                     discharging to a POTW are described in 40 CFR Part 403.  Pretreatment
                     standards applying specifically to the steam electric generating point source
                     category are listed in 40 CFR §§423.16 and 17.

                     Beyond the applicable technology-based effluent limitations described above,
                     permits may also establish technology-based limits for other pollutants based
                     on the application of best professional judgement (BPJ). Permit limits and
                     special conditions  may  also  be established based  on water quality
                     considerations. Thermal limitations are often placed hi permits for steam
                     electric power plants based on Section 316(a) of the CWA and water quality
                     considerations.  Additionally, permits may require the performance of a
                     demonstration study and implementation of control technologies to minimize
                     adverse environmental impacts from cooling water intake structures.

                     Storm water discharges associated with any industrial activity  onsite at a
                     fossil fuel electric power generation facility are covered under the National
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Fossil Fuel Electric Power Generation
  Section VI. Federal Statutes and Regulations
                    Storm Water Program. Steam electric power generating activities are listed
                    as one of the categories of industrial activities subject to the storm water
                    permit application requirements (category vii). The regulations at 40 CFR
                    Part 122.26 require facilities discharging storm water from 1  of the  11
                    categories of industrial activities to apply for a storm water permit if the
                    storm water discharges to waters of the United States. In most permits,
                    facilities are required to develop and implement a storm water pollution
                    prevention plan. However, limitations and other special conditions may be
                    included on a case-by-case basis.  Some permits may include the numeric
                    effluent limitation guideline for coal pile runoff. Storm water discharges
                    associated with other industrial activities  at fossil  fuel electric power
                    generation facilities are typically not subject to numeric limits, however.

          Resource Conservation and Recovery Act

                    The 1980 Solid Waste Disposal Act Amendments conditionally exempted
                    from regulation under Subtitle C large volume wastes, including fly ash
                    waste, bottom ash waste, boiler slag waste, and flue gas emission control
                    waste generated primarily from the combustion of coal or other fossil fuels
                    (RCRA §3001).  Section 8002(n) of RCRA directed EPA to study these
                    wastes.

                    In 1993, EPA issued  a regulatory determination addressing large volume
                    wastes (fly ash, bottom ash, boiler ash, boiler slag, and flue gas emission
                    control wastes) generated  by coal-fired utility power plants, including
                    independent power producers not engaged in any other industrial activity.
                    The regulatory determination stated that these wastes should not be regulated
                    as Subtitle C wastes when they are managed separately from other wastes.
                    A similar determination for other large volume fossil fuel combustion wastes
                    and co-managed wastes was deferred pending  additional studies.

                    Wastes exempt from hazardous waste regulation (currently all wastes from
                    fossil fuel  combustion) are addressed by  Subtitle  D  of RCP.A (for
                    nonhazardous solid wastes). There are currently no Federal nonhazardous
                    waste regulations. As a result, fossil fuel electric power generation waste
                    management is addressed solely by the States, either through their general
                    industrial solid waste programs or through specific programs for fossil fuel
                    combustion wastes. These State programs vary considerably.

                    Subtitle I of RCRA has stringent requirements for underground petroleum
                    and hazardous  substances storage tank (UST) systems with 110-gallon or
                    greater capacity. Any storage of fuels in USTs  onsite at a fossil fuel electric
                    power generation facility would be covered under these regulations at 40
                    CFR Part 280.
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                     Subtitle C of RCRA provides for a comprehensive cradle to grave system of
                     management  for hazardous waste and  includes rules governing waste
                     disposal on land; recycling and generators; and treatment, storage, or disposal
                     facilities  (TSDFs).  Low volume fossil fuel combustion wastes not co-
                     managed  with ash, slag, or flue gas desulfurization wastes and other wastes
                     that are not directly associated with the combustion process are not exempted
                     from hazardous waste regulation. As such, they are hazardous wastes if they
                     are listed as hazardous wastes from non-specific sources (e.g., spent solvents)
                     or if they  exhibit one or more of the RCRA hazardous waste characteristics
                     of toxicity, corrosivity, reactivity, and ignitability.  The identification of
                     specific  listed  wastes  and the definitions of  the  hazardous  waste
                     characteristics are listed in 40 CFR Part 261.

                     Fossil fuel electric power generating plants do not typically generate large
                     quantities of hazardous waste. Furthermore, the requirements and costs of
                     operating an onsite hazardous waste TSDF are extensive.  Therefore, most
                     electric power generating facilities send any generated hazardous waste to
                     offsite RCRA-permitted commercial TSDFs for permanent disposal.

                     Some steam electric power generating plants  co-fire  their boilers  with
                     hazardous wastes (e.g., spent solvents), along with their primary fossil fuel
                     source. Such facilities are subject to RCRA regulation under the BIF Rule
                     (40 CFR Part 266, Subpart H).  The BIF Rule includes operating condition
                     requirements, as well as testing requirements, for air emissions and residuals
                     to ensure  adequate destruction of toxic constituents.

          Emergency Planning and Community Right-to-Know Act

                     In a recent rulemaking (62 FR 23834, May 1,1997), EPA expanded the list
                     of industry groups subject to reporting requirements under Section 313 of
                     EPCRA (61 FR 33587).  The  expanded list of industry groups  includes
                     electric utilities classified hi the following SIC codes: 4911 Electric Services,
                     4931  Electric and Other Services Combined, and 4939 Combination Utilities,
                     Not Elsewhere Classified.  EPCRA Section 313 now requires electric
                     generating facilities that combust coal and/or oil  for  the purpose of
                     generating electricity for distribution in commerce to evaluate their chemical
                     use   and   management   activities to   determine  potential  reporting
                     responsibilities.  Section 313 establishes annual requirements for amounts
                     released and otherwise managed of "section 313 chemicals" (a list of more
                     than 650 chemicals and chemical categories).

                     For each Section 313 chemical or chemical category, covered facilities must
                     report total routine and accidental amounts entering each environmental
                     media, as well as onsite waste management via, and offsite transfers for,
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Fossil Fuel Electric Power Generation
 Section VI. Federal Statutes and Regulations
                    disposal, waste treatment, energy recovery and recycling, and onsite source
                    reduction activities.  This information is submitted on the TRI reporting form
                    called Form R if the facility has met or exceeded certain thresholds. The first
                    period of reporting for this industry will be on or before July 1,1999, for the
                    period from January 1 to December 31, 1998. Reporting will be required
                    annually thereafter.  For additional information on these new TRI reporting
                    requirements, contact the Emergency Planning and Right-to-Know Hotline
                    at (800) 535-0202 (in Virginia and Alaska (703) 412-9877; TDD (800) 553-
                    7672).

VI.C     Pending and Proposed Regulatory Requirements

          Clean Air Act Amendments of 1990

                    Hazardous Air Pollutants

                    In response to requirements under Section 112 of the CAA as well as Section
                    129, EPA is developing a unified set of Federal air emission regulations for
                    industrial combustion sources.  This rulemaking effort is being called the
                    Industrial Combustion Coordinated Rulemaking (ICCR).

                    The ICCR will cover sources from industrial/institutional/commercial boiler,
                    process heaters, industrial/commercial and other solid waste (not including
                    hazardous, medical, or large municipal) incinerators, stationary gas turbines,
                    and stationary internal combustion engines. These sources are not limited to
                    use of fossil fuels and have the potential to emit both HAPs and  criteria
                    pollutants. This rulemaking effort will produce approximately seven separate
                    regulations, six of which are  expected to be finalized by November 2000.
                    For additional information on the ICCR, contact Fred Porter,  U.S. EPA
                    Office of Air and Radiation, at (919) 541-5251.

                    Section 112(n) requires that EPA perform studies to evaluate the health risks
                    associated with emissions of toxic air pollutants from electric utility steam
                    generating units. Electric utility steam generating units are defined as any
                    fossil fuel-fired combustion unit of more than 25 MW electric that serves a
                    generator that produces electricity for sale.  Cogenerators that supply more
                    than one-third of their potential electric output capacity and more than 25
                    MW output  to any utility power distribution system for sale will  also be
                    covered. A  preliminary study has been completed  and was issued as an
                    interim final in October 1996.  Additional studies will be performed, as well
                    as an in-depth study of potential public health concerns due to mercury
                    emissions from utilities.  These findings will be published in a report to
                    Congress at a later date and will include costs and technologies available to
                    control these emissions and recommendations as to whether regulations are
                    needed  for  air toxics emissions from this industry.   For  additional
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Fossil Fuel Electric Power Generation
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                     information on this study, contact Bill Maxwell, U.S. EPA Office of Air and
                     Radiation, at (919) 541-5430.

           Clean Water Act

                     Effluent Limitations Guidelines and Standards and Pretreatment Standards
                     for the Steam Electric Point Source Category

                     The  existing  1982  effluent limitations  guidelines  and standards and
                     pretreatment standards for wastewater discharges from the Steam Electric
                     Point Source Category are currently being reviewed by the Office of Water.
                     A preliminary study has been completed by the Office of Water to evaluate
                     the  guidelines and  standards  based  on current technical  feasibility,
                     environmental factors, economic impacts, and utility to permit writers. The
                     study was performed because the steam electric power generating industrial
                     category is considered as a candidate for possible regulatory revisions in the
                     future. For additional information, contact Joe Daly, U.S. EPA Office  of
                     Water, at (202) 260-7186.

                     Cooling Water Intake Structure Regulations

                     Section 316(b) of the  Clean Water Act requires that "...any  standard
                     established pursuant to Section 301 or 306... and applicable to a point source
                     shall require that the location, design construction, and capacity of cooling
                     water intake structures reflect the best technology available for minimizing
                     adverse environmental impact."  Since fossil fuel electric power generators
                     with steam turbines withdraw by far the greatest quantity of cooling water of
                     any single industrial sector, it is expected that this industry will be the most
                     affected by this requirement. Although some EPA regions and States have
                     developed programs to minimize impacts from cooling water structures, no
                     uniform national standards  or implementing regulations are currently  in
                     force. As set forth in a consent  decree (Cronin v.  Browner), EPA has
                     initiated the information collection activities needed  to develop proposed
                     regulations to address impacts from the intake of cooling water by  1999.
                     Final EPA action is scheduled for the year 2001. For additional information
                     on the Section 316(b) rulemaking effort, contact Deborah Nagle, U.S. EPA
                     Office of Water, at (202) 260-2656.

          Resource Conservation and Recovery Act

                     A regulatory determination on whether large volume wastes at utility oil-
                     fired, nonutility coal- and oil-fired, and fluidized  bed combustion power
                     plants and co-managed large volume wastes at all utility and nonutility coal-
                     and oil-fired electric generation facilities should be considered hazardous
                     wastes under  Subtitle C is  expected to be  finalized in 1998,  pending
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                    additional data collection. For additional information, contact Dennis Ruddy,
                    U.S. EPA Office of Solid Waste, at (703) 308-8430.
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Fossil Fuel Electric Power Generation   Section VII. Compliance and Enforcement History

VII.       COMPLIANCE AND ENFORCEMENT HISTORY

                     Until recently,  EPA has focused much of its attention on measuring
                     compliance with specific environmental statutes. This approach allows the
                     EPA to track compliance with CAA, RCRA, CWA, and other environmental
                     statutes.  Within the last several years, the EPA has begun to supplement
                     single-media  compliance indicators  with  facility-specific, multimedia
                     indicators of compliance, hi doing so, EPA is in a better position to track
                     compliance with all statutes at the facility level and within specific industrial
                     sectors.

                     A major step in building the  capacity to  compile multimedia data for
                     industrial sectors was the creation of EPA's IDEA system. The IDEA has the
                     capacity to  "read into" EPA's single-media databases,  extract compliance
                     records, and match the records to individual facilities. The IDEA system can
                     match air, water, waste, toxics/pesticides/EPCRA, TRI, and enforcement
                     docket records for a given facility and generate a list of historical permit,
                     inspection, and enforcement activity. IDEA also has the capability to analyze
                     data by geographic area and corporate holder. As the capacity to generate
                     multimedia compliance data improves, EPA will make available more in-
                     depth compliance and enforcement information. Additionally, sector-specific
                     measures of success for compliance assistance efforts are being developed.

          Compliance and Enforcement Profile Description

                     Using inspection, violation and enforcement data from the IDEA system, this
                     section provides information  regarding the historical compliance and
                     enforcement activity of this sector. In order to mirror the facility universe
                     reported hi the Toxic Chemical Profile, the data reported within this section
                     consist of records only from the TRI reporting universe.  With this decision,
                     the selection criteria are consistent across sectors with certain exceptions.
                     For the sectors that do not normally report to the TRI program, data have
                     been provided from EPA's Facility Indexing  System (FINDS) which tracks
                     facilities hi all media databases.  Please note, in this section, EPA does not
                     attempt to define the actual number of facilities that fall  within each sector.
                     Instead, the section portrays the records of a subset of facilities within the
                     sector that are well defined within EPA databases.

                     As a check on the relative size of the full sector universe, most notebooks
                     contain an estimated number of facilities within the sector according to the
                     Bureau of Census. For the fossil fuel electric power generation industry,
                     statistics about the industry are collected by the DOE EIA (see Section II).
                     With sectors dominated by small businesses, such as metal finishers and
                     printers,  the reporting universe within EPA databases may be  small in
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Fossil Fuel Electric Power Generation   Section VII. Compliance and Enforcement History

                    comparison to Census data. However, the group selected for inclusion in this
                    data analysis section should be consistent with this sector's general make-up.

                    Following this introduction is a list defining each data column presented
                    within this section.  These values represent a retrospective summary of
                    inspections and enforcement actions, and reflect solely EPA, State, and local
                    compliance assurance activities that have been entered into EPA databases.
                    To identify any changes in trends, the EPA ran two data queries: one for the
                    past five calendar years (April 1,1992, to March 31,1997) and the other for
                    the most recent 12-month period (April 1,1996, to March 31, 1997).  The
                    5-year analysis  gives  an  average level of activity for that period for
                    comparison to the more recent activity.

                    Because most inspections focus on single-media requirements, the data
                    queries presented in this section are taken  from single media databases.
                    These databases do not provide data on whether inspections are state/local or
                    led by EPA. However, the table breaking down the  universe of violations
                    does  give a crude measurement of EPA's and States' efforts within each
                    media program.  The presented data illustrate the variations across EPA
                    regions for certain sectors.3 This variation may be attributable to state/local
                    data  entry variations, specific  geographic  concentrations, proximity to
                    population centers, sensitive  ecosystems, highly toxic chemicals used in
                    production, or historical noncompliance. Hence, the exhibited data do not
                    rank regional performance or necessarily reflect which regions may have the
                    most compliance problems.

                    Compliance and Enforcement Data Definitions

                    Facility Indexing System - This system assigns a common facility number
                    to EPA single-media permit records.  The  FINDS  identification number
                    allows EPA to compile and review all permit, compliance, enforcement, and
                    pollutant release data for any given regulated facility.

                    Integrated Data for Enforcement Analysis  - This data integration system
                    can retrieve  information from the major EPA program  office databases.
                    IDEA uses the FINDS identification number to link separate data records
                    from EPA's databases.  This allows retrieval of records from across media
                    or statutes for any given facility, thus creating a "master list" of records for
                    that facility. Some of the data systems accessible through IDEA are: AIRS
                    (Office of Air and Radiation), PCS (Office of Water), RCRIS (Resource
• EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD,
PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX);
VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); DC (AZ, CA, HI, NV, Pacific Trust Territories); X (AK,
ID, OR, WA).
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Fossil Fuel Electric Power Generation   Section VII. Compliance and Enforcement History

                    Conservation and Recovery Information System, Office of Solid Waste),
                    NCDB (National Compliance Data Base, Office of Prevention, Pesticides,
                    and  Toxic Substances), CERCLIS (Comprehensive Environmental  and
                    Liability Information System,  Superfund),  and TRIS (Toxic  Release
                    Inventory System).  IDEA also contains information from outside sources
                    such as  Dun and Bradstreet and the  Occupational  Safety  and Health
                    Administration (OSHA). Most data queries displayed in Sections IV and VII
                    of this notebook were conducted using IDEA.

                    Data Table Column Heading Definitions

                    Facilities in Search are based on the universe of TRI reporters within the
                    listed SIC  code range.  For industries not covered under TRI reporting
                    requirements (metal mining, nonmetallic mineral mining, electric power
                    generation, ground transportation, water transportation, and dry cleaning), or
                    industries hi which only a very small fraction of facilities report to TRI (e.g.,
                    printing), the notebook uses the FINDS universe for executing data queries.
                    The SIC code range selected for each search is defined by each notebook's
                    selected SIC code coverage described in Section II.

                    Facilities Inspected indicates the level of EPA and state agency inspections
                    for the facilities in this data search. These values show what percentage of
                    the facility universe is inspected in a one-year or five-year period.

                    Number of Inspections measures the total number of inspections conducted
                    in this sector. An inspection event is counted each time it is entered into a
                    single media database.

                    Average Time Between Inspections provides an average length of time,
                    expressed in months, between compliance inspections at a facility within the
                    defined universe.

                    Facilities with One or More Enforcement Actions expresses the number
                    of facilities that were the subject of at least one enforcement action within the
                    defined time period. This category is broken down further into federal and
                    state actions.   Data are obtained for administrative, civil/judicial,  and
                    criminal enforcement  actions.  Administrative actions include Notices of
                    Violation (NOVs).  A facility with multiple enforcement actions is only
                    counted once in this column, e.g., a facility with three enforcement actions
                    counts as one facility.

                    Total Enforcement Actions describes the total number of enforcement
                    actions identified  for an industrial  sector across all environmental statutes.
                    A facility with multiple enforcement actions is counted multiple times, e.g.,
                    a facility with three enforcement actions counts as three.
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Fossil Fuel Electric Power Generation   Section VII. Compliance and Enforcement History

                    State Lead Actions shows what percentage of the total enforcement actions
                    are taken by state and local environmental agencies. Varying levels of use
                    by states of EPA data systems may limit the volume of actions recorded as
                    state  enforcement  activity.  Some states extensively report enforcement
                    activities into EPA data systems, while other states may use their own data
                    systems.

                    Federal Lead Actions shows what percentage of the total enforcement
                    actions are taken by the United States Environmental Protection Agency.
                    This value includes referrals from state agencies.  Many of these actions
                    result from coordinated or joint state/federal efforts.

                    Enforcement to Inspection Rate is a ratio of enforcement actions to
                    inspections, and is presented for comparative purposes only. This ratio is a
                    rough indicator of the relationship between inspections and enforcement. It
                    relates the number of enforcement actions and the number of inspections that
                    occurred within the one-year or five-year period.  This ratio includes the
                    inspections and enforcement actions reported under the CWA, CAA, and
                    RCRA. Inspections and actions from the TSCA/FIFRA/ EPCRA database
                    are not factored into this ratio because most of the actions taken under these
                    programs are not the result of facility inspections. Also, this ratio does not
                    account for enforcement actions arising from non-inspection compliance
                    monitoring activities (e.g., self-reported water discharges) that can result in
                    enforcement action within the CAA, CWA, and RCRA.

                    Facilities with One or More Violations Identified indicates the percentage
                    of inspected facilities having a violation identified in one of the following
                    data categories:   In Violation  or  Significant Violation  Status (CAA);
                    Reportable Noncompliance, Current Year  Noncompliance,  Significant
                    Noncompliance (CWA); Noncompliance and Significant Noncompliance
                    (FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High
                    Priority Violation (RCRA). The values presented for this column reflect the
                    extent of noncompliance within the measured time frame, but do not
                    distinguish between the severity of the noncompliance. Violation stains may
                    be a precursor to an enforcement action, but does not necessarily indicate that
                    an enforcement action will occur.

                    Media Breakdown of Enforcement Actions and Inspections —  four
                    columns identify the proportion of total inspections and enforcement actions
                    within EPA air, water, waste, and TSCA/FIFRA/EPCRA databases.  Each
                    column is  a percentage of either the "Total Inspections," or the  "Total
                    Actions" column.
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 Fossil Fuel Electric Power Generation   Section VII. Compliance and Enforcement History

 VILA     Fossil Fuel Electric Power Generation Industry Compliance History

                     This section examines the historical enforcement and compliance data on the
                     fossil fuel electric power generation sector. As noted earlier, these data were
                     obtained from EPA's IDEA system. The five exhibits within this section
                     provide both a 5-year and a 1 -year review of the data from the sector and also
                     provide data from other sectors for comparison purposes. It should be noted
                     that the data are accessed in the IDEA database system through SIC codes.
                     Therefore,  only  those facilities  whose primary  SIC codes indicate  the
                     potential for power generation activities  can be accessed (see Section II).
                     This means that the data retrieved from IDEA may be more inclusive (e.g.,
                     include transmission and distribution facilities).  Other industry facilities that
                     have associated power generation activities cannot be identified because their
                     primary SIC codes do not indicate power generation.

                     Table 38 provides an overview of the reported compliance and enforcement
                     data for the fossil fuel electric power generations sector over the past 5 years
                     (April 1992 to April 1997).  These data are also broken out by EPA Regions
                     thereby permitting geographical comparisons. A few points evident from the
                     data  are listed below.  As  shown, 3,270 facilities were identified through
                     IDEA with SIC codes that indicate power generation may be occurring (see
                     discussion  above).  Of those,  approximately 66  percent (2,166) were
                     inspected in the last 5 years. Other points of interest include:

                     •   14,210 inspections were conducted over the last 5 years.  Of the 3,166
                        facilities inspected, on average, each received over 6 inspections in the
                        past 5-year period.

                     •   The 14,210 inspections resulted in 403 facilities having enforcement
                        actions taken against them. At those 403 facilities, there were a total of
                        789 enforcement actions; therefore,  each  facility averaged nearly 2
                        enforcement actions over the 5-year period.

                     •   The average enforcement to inspection rate is 0.06, with the rate across
                        the regions ranging from 0.02 to 0.13. There appears to be no correlation
                        between State versus Federal lead on the inspections and the enforcement
                        to inspection rate.
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Fossil Fuel Electric Power Generation  Section VII. Compliance and Enforcement History
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Fossil Fuel Electric Power Generation  Section VII. Compliance and Enforcement History

VII.B     Comparison of Enforcement Activity Between Selected Industries

                     Tables 39 and 40 allow the compliance history of the fossil fuel electric
                     power generation sector to be compared to the other industries covered by the
                     industry sector notebooks. Comparisons between Tables 39 and 40 permit
                     the identification of trends in compliance and enforcement records of the
                     various industries by comparing data covering the last 5 years (April 1992 to
                     April 1997) to that of the past year (April 1996 to April 1997). As shown in
                     the data, the 3,270 fossil fuel electric power generation facilities is the sixth
                     largest  number  of facilities  identified through  IDEA,  with  ground
                     transportation having the most  facilities with  7,786.  However, while
                     approximately 66 percent of the fossil fuel electric power generation facilities
                     have been inspected in the past 5 years, only 41 percent of the ground
                     transportation facilities have been inspected.  Other points  of interest from
                     the 5-year summary include:

                     •  The number of inspections over the past 5 years for fossil fuel electric
                       power generation facilities (14,210)  is more than 3 times the amount
                       conducted in most other sectors.

                     •  The enforcement to inspection rate of 0.06 over the past 5 years is one of
                       the lower rates of the listed sectors.

                     Points of interest from the 1-year summary include:

                     •  The 1,318 fossil fuel electric power generation facilities  inspected in the
                       past year places this sector among the top four sectors for number of
                       facilities inspected.

                     •  The total number of inspections in this sector is 2,430 which compares
                       with the number of inspections performed in the ground transportation
                       and non-metallic mining sectors, but is 1.5 to 17 times more than the
                       other sectors which range from 1,436 down to 141.

                     •  The enforcement to inspection rate of 0.06 is about average among all the
                       sectors, with the lowest being 0.01 (dry cleaning) and the highest being
                       0.23 (petroleum refining).  This is relatively constant  with the 5-year
                       average for the fossil fuel electric power generation sector.

                     Tables 41 and 42 provide a more in-depth comparison between the fossil fuel
                     electric power generation sector  and others  by organizing inspection and
                     enforcement  data  by environmental statute.  As in the previous Tables
                     (Tables 39 and 40), the data cover the last 5 years (Table 41) and the last
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Fossil Fuel Electric Power Generation  Section VII. Compliance and Enforcement History











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Fossil Fuel Electric Power Generation  Section VII. Compliance and Enforcement History

                    one year (Table 42) to facilitate the identification of recent trends.  Points of
                    interest from the 5-year summary include:

                    •  Compared to other sectors, the fossil fuel electric power generation sector
                       has one of the higher percentages of CAA inspections (57%) and one of
                       the lower percentages of RCRA inspections (11%), when measured
                       against the total number of inspections conducted. As a result, it has one
                       of the higher percentages of CAA enforcement actions (59%) and one
                       of the lowest percentages of RCRA enforcement actions (10%), when
                       measured against total enforcement actions.

                    The 1-year inspection and enforcement summary reflects similar numbers to
                    those from the past 5 years. No notable exceptions are apparent.

VH.C     Review of Major Legal Actions

          Major Cases/Supplemental Environmental Projects

                    This section provides summary information about major cases that have
                    affected this sector, and a list of Supplemental Environmental Projects
                    (SEPs).

          VII.C.l   Review of Major Cases

                    As shown in the previous tables, the number of enforcement actions taken
                    over the past  5 years,  when compared to the  number  of inspections
                    conducted, is minimal. Even though there have been 871 total enforcement
                    actions, major cases involving fossil fuel electric power generation facilities
                    are rare. Since 1992, however, there have been at least 13 actions against
                    such facilities.

                    The 13 cases were broken out as follows:

                    •  6 cases under the CAA (asbestos NESHAPs, NOX monitoring violations,
                       and SO2 violations)
                    •  2 cases under the CWA (NPDES permit violation, wetlands)
                    •  2 cases under TSCA (PCBs)
                    •  2 cases under EPCRA (release in excess of reportable quantities)
                    •   1 multimedia case (CWA, EPCRA, and TSCA).

                    The average penalty associated with these cases was just more than $150,000.
                    In addition, two SEPs were associated with the 13 cases. Those are discussed
                    in more detail in the following section.
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 Fossil Fuel Electric Power Generation  Section VII. Compliance and Enforcement History

                     The two most significant cases against fossil fuel electric power generation
                     facilities included CWA violations by Potomac Electric Power Company
                     (PEPCO) and CAA violations by Public Service Electric & Gas (PSE&G).
                     In the PEPCO case, the violations occurred from 1988 to 1993, during which
                     time a site supervisor either pumped or oversaw the pumping of polluted
                     water from holding ponds into an adjacent swamp. PEPCO discovered the
                     illegal discharge  and informed EPA.  The consent decree provides for a
                     penalty of $975,000. Because the violation was self-disclosed, no criminal
                     charges were brought against the company or its officers.

                     In United States v. Public Service Electric & Gas, PSE&G was charged with
                     violating the CAA, specifically the asbestos NESHAP.  While commuting
                     home from work, an off-duty EPA inspector noticed a pile of old pipes laying
                     in a yard. A subsequent inspection of the old gas-cracking operation revealed
                     the NESHAP violations.  The PSE&G was required to pay a civil penalty of
                     $230,000 and complete an extensive worker training and notification
                     program.

          VII.C.2   Supplementary Environmental Projects (SEPs)

                     SEPs are compliance agreements that reduce a facility's non-compliance
                     penalty in return for an environmental project that exceeds the value of the
                     reduction. Often, these projects fund pollution prevention activities that can
                     reduce the future pollutant loadings of a facility. Information on SEP cases
                     can be  accessed via  the  internet at EPA's  Enviro$en$e  website:
                     http://es.inel.gov/sep.

                    As mentioned above, there were two SEPs at fossil fuel electric power
                     generation facilities.  The  SEPs  were negotiated with IBS Utilities,
                    Incorporated, of Cedar Rapids, Iowa, and Consumers Power Company of
                    West Olive, Michigan.

                    The case against IBS  Utilities, Incorporated, was the  first acid rain
                    administrative penalty action in the country.  The complaint alleged IBS
                    failed to  complete timely certification testing of the acid rain continuous
                    emission monitors required for SO2, NOX, CO2, and volumetric flow at
                    several of its generating stations.  As part of the settlement,  IBS agreed to a
                    SEP involving the purchase and permanent surrender by the utility to EPA
                    of 589 SO2 allowances. Each allowance constitutes an authorization to emit
                    during or after a specified calendar year one ton of SO2. The value of the
                    allowances permanently removed from the market was $76,570 at the time
                    of the settlement. IBS was also required to pay a penalty of $25,630 to settle
                    the claims.
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Fossil Fuel Electric Power Generation   Section VII. Compliance and Enforcement History

                    In the Consumers Power Company case, the company agreed to carry out
                    three SEPs at a total estimated cost of $247,742. The projects include (1)
                    converting heat exchangers from ethylene glycol to propylene glycol, which
                    is 300 times less toxic, (2) sending information on EPCRA requirements to
                    an estimated 3,000 facilities in Michigan, and (3) conducting an outreach
                    program on the EPCRA Section 302 notification requirement to rural
                    communities. The company must also certify its compliance with EPCRA.
                    In its complaint, EPA alleged that the company failed to notify authorities
                    about an accidental release of 1,400 pounds of sodium hypochlorite.
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 Fossil Fuel Electric Power Generation    Section VIII. Compliance Activities and Initiatives

 VIII.  COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

                     This section highlights the activities undertaken by this industry sector and
                     public  agencies  to  voluntarily  improve  the  sector's  environmental
                     performance.  These activities include those  initiated independently by
                     industrial trade associations. In this section, the notebook also contains a
                     listing and description of national and regional trade associations.

 VIII.A.   Sector-related Environmental Programs and Activities

           Clean Air Power Initiative

                     The goal of the Clean Air Power Initiative (CAPI) is to improve air pollution
                     control efforts within the electric power generating industry by developing
                     an integrated regulatory strategy for three major pollutants emitted by electric
                     power generators: SO2,  NOX, and air toxics (specifically, mercury). The
                     project was initiated in 1995 by EPA's Assistant Administrator for Air and
                     Radiation. Through the Initiative, EPA hopes to provide the electric power
                     industry with greater regulatory flexibility and cost savings while achieving
                     environmental goals for ozone, fine particles, regional haze, and toxics. The
                     Initiative will use existing CAA authority where possible, although ultimately
                     new congressional authority may be required. The EPA believes focusing on
                     regional reductions of the pollutants and implementing a "cap and trade"
                     approach for some pollutants, such as NOX, SO2, and mercury, would be most
                     effective.  The EPA is meeting with representatives of the power industry,
                     State and local officials, environmental groups, and pollution control  vendors
                     to obtain their views and input for the regulatory framework for the Initiative.
                     (Contact:  Linda  Reidt  Critchfield,  at   (202)  233-9087.    Website:
                     http://www.epa.gov/capi).

          EPA Regional Compliance And Enforcement Activities

                     The EPA Region VIII has focused on enforcement and compliance activities
                     for coal-fired power plants.  This industrial sector was targeted by Region
                     VIII because they have 38 significant operating plants (i.e., generate greater
                     than 25 MW electricity). The region has experienced ongoing compliance
                     issues related to the new Acid Rain Program, impacts from plants  in PSD
                     Class I areas, and impacts in nonattainment areas. The goal of this EPA
                     regional  compliance and enforcement initiative  is  to comprehensively
                     evaluate the compliance status of the facilities.  The region is also evaluating
                     any environmental justice issues due to the location of the facilities. States
                     in Region VIII are participating in the sector initiative by performing annual
                     air program and NPDES permit inspections on a yearly basis.  South Dakota
                     has conducted multimedia inspections at two coal-fired power plants.
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Fossil Fuel Electric Power Generation   Section VIIL Compliance Activities and Initiatives

          Department of Energy Environmental Research Programs

                    The DOE maintains numerous laboratories and field facilities that perform
                    research and development type activities. The following facilities are of
                    interest  to  the fossil  fuel  electric power  generation  industry  and
                    environmental compliance:

                    •   Argonne National Laboratory: The Argonne National Laboratory
                        (ANL) conducts applied research and engineering development in energy
                        and environmental technologies, high performance computing,  and
                        scientific research hi physical and life sciences. The Energy Systems
                        Division of ANL focuses its expertise on  controlling environmental
                        impacts  of industrial energy use.  The  division is committed to a
                        revitalized  competitiveness  in  the  national  economy. (Website:
                        http:\\www.anl.gov).

                    •   Oak Ridge National Laboratory: The Oak Ridge National Laboratory
                        performs research on a broad range of energy-related problems and
                        provides technical information and assistance  on energy  research for
                        State and local governments and the private sector. Areas of research
                        include  waste management, fossil, fuel power generation technology,
                        nuclear  power generation technologies, fusion technology, conservation,
                        and environment. (Website: http:\\www.ornl.gov).

                    •   Federal Energy Technology Center: The Federal Energy Technology
                        Center (FETC), one of the government's principal fossil fuel energy
                        research centers, is responsible for research and development programs
                        in the technical and administration management of fossil energy.  The
                        FETC is part of the Bruceton Research Center, which is the Nation's
                        largest governmental lab devoted to coal research and development.  The
                        center's program responsibilities include clean coal technology,  coal
                        preparation, combustion technology, alternative fuels utilization, flue gas
                        cleanup,  coal  liquefaction,  advanced  research  and  technology
                        development in direct utilization and liquefaction, and solids transport.
                        (Website: http:\\www.fetc.doe.gov).

 VIII.B    EPA Voluntary Programs

           Environmental Leadership Program

                     The Environmental Leadership Program  (ELP)  is  a national  initiative
                     developed by EPA that focuses on improving environmental performance,
                     encouraging voluntary compliance, and building working relationships with
                     stakeholders. EPA initiated a one year pilot program in 1995 by selecting 12
                     projects at industrial facilities and federal installations that demonstrate the
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 Fossil Fuel Electric Power Generation   Section VIII. Compliance Activities and Initiatives

                     principles of the ELP program.  These principles include: environmental
                     management  systems,  multimedia  compliance  assurance,  third-party
                     verification of compliance, public measures of accountability, pollution
                     prevention, community involvement, and mentor programs. In return for
                     participating, pilot participants received public recognition and were given
                     a period  of time to correct any  violations discovered  during  these
                     experimental  projects. Four fossil fuel electric power generation facilities
                     proposals were accepted and are listed in Table 43.  Progress reports and fact
                     sheets from these pilot programs are now available from EPA or off the web.
    Table 43: List of Power Plants That Participated in the Environmental Leadership
                               Program For 1995 and 1996
  1. Arizona Public Service, Deer Valley Facility (Phoenix, AZ)

  2. Duke Power Riverbend Steam Station (Mt. Holly, NC)

  3. Ocean State Power (Burrillville, RI)

  4. Salt River Project (Phoenix, AZ)
                     EPA is making plans to launch its full-scale Environmental Leadership
                     Program in 1997. The full-scale program will be facility-based with a 6-year
                     participation cycle. Facilities that meet certain requirements will be eligible
                     to participate, such as having a community outreach/employee involvement
                     programs and an environmental management system (EMS) in place for 2
                     years.  (Contact: Debby Thomas,  ELP Deputy Director, (202)564-5041.
                     Website: http://es.inel.gov/elp).
          Project XL
                    Project XL was initiated in March 1995 as a part of President Clinton's
                    Reinventing Environmental Regulation initiative.  The projects seek to
                    achieve cost effective environmental benefits by providing participants
                    regulatory flexibility on the condition that they produce greater environmental
                    benefits.  EPA and program participants will negotiate and sign a Final
                    Project Agreement, detailing specific  environmental objectives that the
                    regulated entity shall satisfy.  EPA will provide regulatory flexibility as an
                    incentive  for the  participants'  superior  environmental  performance.
                    Participants are  encouraged to  seek  stakeholder support from local
                    governments,  businesses, and  environmental groups.   EPA  hopes to
                    implement  fifty  pilot projects in four  categories, including  industrial
                    facilities,  communities,  and government facilities regulated  by  EPA.
                    Applications will be accepted on a rolling basis.  For additional information
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                    regarding XL projects, including application procedures and criteria, see the
                    May 23, 1995 Federal Register Notice. (Contact: Fax-on-Demand Hotline
                    202-260-8590, or Christopher Knopes at EPA's Office of Policy, Planning
                    and Evaluation (202)260-9298. Website: Web: http://www.epa.gov/
                    ProjectXL)

          Climate Wise Recognition Program

                    The  Climate Change Action Plan was initiated in response to the U.S.
                    commitment to reduce  greenhouse gas emissions in accordance with the
                    Climate Change Convention of the  1990 Earth Summit.  As part, of the
                    Climate Change Action Plan, the Climate Wise Recognition Program is a
                    partnership initiative run jointly by EPA and DOE. The program is designed
                    to reduce greenhouse gas emissions by encouraging reductions across all
                    sectors of the economy, encouraging participation in the full range of Climate
                    Change Action Plan  initiatives, and fostering  innovation.  Program
                    participants  are required to identify and commit to actions that reduce
                    greenhouse gas emissions. The program, hi turn, gives organizations early
                    recognition for their reduction commitments; provides technical assistance
                    through consulting services, workshops, and guides; and provides access to
                    the program's centralized information system. At EPA, the program is
                    operated by the Air and Energy Policy Division within the Office of Policy
                    Planning  and  Evaluation.   (Contact: Pamela Herman, (202)260-4407.
                    Website: http://www.oit.doe.gov/Access/climate).

          Green Lights Program

                    EPA's Green Lights program was initiated in 1991 and has the goal of
                    preventing pollution by encouraging U.S. institutions to use energy-efficient
                    lighting technologies.   The program saves money for businesses and
                    organizations and creates a cleaner environment by reducing pollutants
                    released into the atmosphere. The program has over 2,345 participants which
                    include major corporations, small and medium sized businesses, federal, state
                    and local  governments, non-profit groups, schools, universities, and health
                    care facilities.  Each participant is required to survey their facilities and
                    upgrade lighting wherever it is profitable. As of March 1997, participants
                    had  lowered their electric bills by $289  million annually.  EPA  provides
                    technical  assistance to the participants through a decision support software
                    package, workshops and manuals, and an information hotline.  EPA's Office
                    of Air and Radiation is responsible for operating the Green Lights Program.
                    (Contact: Green Light/Energy Star Hotline at 1-888-STARYES or Maria
                    Tikoff  Vargar,  EPA Program Director, at  (202)233-9178.  Website:
                    http://www.epa.gov/greenlights.html).
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           WasteWi$e Program

                     The WasteWi$e Program was started in 1994 by EPA's Office of Solid
                     Waste and Emergency  Response.   The program is aimed  at  reducing
                     municipal solid wastes by promoting waste prevention, recycling collection
                     and the manufacturing and purchase of recycled products. As  of 1997, the
                     program had about 500 companies as members, one third of whom are
                     Fortune 1000 corporations. Members agree to identify and implement actions
                     to reduce their solid wastes setting waste reduction goals and providing EPA
                     with yearly progress reports.  To member companies, EPA, in turn, provides
                     technical assistance, publications, networking opportunities, and national and
                     regional recognition. (Contact: WasteWi$e Hotline at 1-800-372-9473 or
                     Joanne  Oxley,  EPA  Program Manager, (703)308-0199.    Website:
                     http://www.epa.gov /epaoswer/non-hw/reduce/wstewise/
                     index.html)
           NICE-
                     The U.S. Department of Energy is administering a grant program called The
                     National Industrial  Competitiveness through Energy, Environment, and
                     Economics (NICE3). By providing grants of up to 45 percent of the total
                     project cost, the program encourages industry to reduce industrial waste at its
                     source and become more energy-efficient and cost-competitive through waste
                     minimization efforts.  Grants are used by industry to design, test, and
                     demonstrate new processes and/or equipment with the potential to reduce
                     pollution and increase  energy efficiency.  The program is open to all
                     industries; however, priority is given to proposals from participants in the
                     forest products, chemicals, petroleum refining, steel, aluminum, metal casting
                     and glass manufacturing sectors. (Contact: Chris Sifri, DOE, (303)275-4723
                     or Eric Hass, DOE, (303)275-4728. Website: http//www.oit.doe.gov/access/
                     nice3).
VIII.C   Trade Association/Industry Sponsored Activity
                    Trade associations, in conjunction with their industry members, sponsor
                    activities that serve to further regulatory compliance initiatives. This section
                    describes a major environmental compliance assistance program being
                    sponsored by the utilities in the fossil fuel electric power generation industry,
                    as well as some of the major trade associations serving the fossil fuel electric
                    power generation industry.
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          VIII.C.l  Environmental Programs

          Climate Challenge Program

                    The Climate Challenge Program is a joint initiative of DOE and the electric
                    utility  industry to reduce greenhouse gas emissions.  Electric utilities
                    voluntarily commit to undertake actions to reduce, avoid, or sequester more
                    than 47 million metric tons of carbon equivalent by the year 2000.  These
                    commitments are formalized hi individual utility participation accords for
                    large utilities, and letters of participation for utilities with less than 50,000
                    customers. Utilities report greenhouse gas emissions data and submit annual
                    reports, which describe their achievements, to DOE.  The Climate Challenge
                    Options Workbook describe more than 50 options for utilities to implement
                    to meet their participation commitments.   The workbook  was jointly
                    developed by the electric power industry and DOE. (Contact: Larry Mansueti,
                    Program Director, Office of Utility Technologies, EE-10, U.S. DOE, 1000
                    Independence Avenue SW, Washington, DC 20585.  Website: http://bejing.
                    dis.anl.gov/ ee-cgi-bin/ccap.pl)

                    The utility industry has also developed a set of initiatives to help utilities
                    meet their commitments. These include:

                    •   EnviroTech  Investment  Fund, which  fund invests  in companies
                        focusing on regenerating energy technologies that  are more energy
                        efficient than those currently in use.

                    •   International Utility Efficiency Projects  that  support  energy
                        development in a way that is environmentally beneficial.

                    •   Utility Forest  Carbon Management Program,  which comprises
                        domestic and  international forestry projects to manage CO2 emissions.

           VIII.C.2 Summary of Trade Associations

                    Trade  associations and professional organizations that serve the fossil fuel
                    electric power generation industry are numerous and varied in their focus.
                    They range from serving  a relatively small portion of the industry (e.g.,
                    independent power producers) to serving the industry as  a whole. This
                    section briefly describes some major trade and professional organizations for
                    this industry.
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                      American Coal Ash Association (ACAA)
                      2760 Eisenhower Avenue, Suite 304
                      Alexandria, VA  22314
                      Phone:(703)317-2400
                      Fax:(703)317-2409
                      Website: http://www.acaa-usa.org
                    Members: 110
                    Staff: 5
                    Contact: Samuel S. Tyson
                    Founded in 1968, ACAA's mission is to advance the management and use of
                    Coal Combustion Products (CCPs) in ways  that are technically sound,
                    commercially competitive, and environmentally safe.
                     American Public Power Association
                     (APPA)
                     2301M Street, NW
                     Washington, DC 20037
                     Phone: (202) 467-2900
                     Fax:(202)467-2910
                     Website: http://www.appa.org/
                    Members: 2,000
                    Staff: 60
                    Contact: Alan H. Richards
                    Founded in 1940, APPA's members include public utility systems, State- and
                    county-owned electric systems, and rural cooperatives. The APPA maintains
                    a library on the electric power industry and publishes a bimonthly magazine.
                    The APPA also conducts research programs, compiles statistics, and offers
                    utility education courses hi electric power. The association holds an annual
                    conference and workshops.
                     Association of Energy Engineers (AEE)
                     4025 Pleasantville Road., Suite 420
                     Atlanta, GA 30340
                     Phone: (770) 447-5083
                     Fax: (770) 446-3969
                     Website: http://www.aeecenter.org/
                  Members: 8,500
                  Staff: 9
                  Contact: Ruth M. Bennett
                    Founded in 1977, the members of the AEE are engineers, architects, and
                    other professionals interested in energy management and cogeneration. The
                    AEE promotes  advancement of the profession  and contributes  to the
                    professional development of its membership.  The AEE provides scholarships
                    for students in energy engineering, supports the National Energy Policy
                    Council, and sponsors the Cogeneration and Competitive Power Institute, a
                    research organization.  The AEE publishes journals  and newsletters and
                    sponsors several technical and managerial congresses each year.
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                     Edison Electric Institute (EEI)
                     701 Pennsylvania Avenue, NW
                     Washington, DC 20004-2696
                     Phone: (202) 508-5000
                     Fax: (202) 508-5360
                     Website: http://www.eei.org/
                 Members: 202
                 Staff: 262
                 Contact: Thomas Kuhn,
                 President
                    Founded in 1933, EEI members are investor-owned electric utility companies
                    operating hi the United States. Some affiliated members are from Canada,
                    Mexico, and Central and South America. The EEI acts as a representative for
                    the shareholder-owned electric power industry on subjects of public interest
                    and provides a medium for the exchange of ideas and information within the
                    electric power industry. The institute maintains a library and database and
                    compiles statistics. The EEI provides educational programs and publishes
                    surveys, which provide statistical and factual information about operation,
                    rates, regulation, and environmental practices.
                     Electric Power Research Institute (EPRI)
                     3412 Hillview Road
                     Palo Alto, CA 94303
                     Phone: (415) 855-2000
                     Fax: (415) 855-2041
                     Website: http://www.epri.com/
                  Members: 700
                  Staff: 500
                  Contact: Kurt Yeager, Exec.
                  Officer
                    The EPRI was founded hi 1972 and serves all sectors of the electric utility
                    industry.  The EPRI mission is to conduct a broad economically and
                    environmentally acceptable  program  of research  and development  in
                    technologies for electric power production, distribution, transmission, and
                    utilization. The EPRI primary research areas are advanced power systems,
                    coal  combustion  systems,   electrical  systems,  energy  analysis,  and
                    environment and energy management and utilization. The institute maintains
                    a library and a database of current and completed research in the electric
                    power industry. The institute also publishes a guide and a journal.
                      Electric Power Supply Association
                      (EPSA)
                      1401 H Street NW, Suite 760
                      Washington, DC 20005
                      Phone: (202) 789-7200
                      Fax: (202) 789-7201
                  Members: 90
                  Staff: 12
                     The EPSA was formed by a merger of two former trade associations: the
                     Electric Generating Association and the National Independent Energy
                     Producers (NIEP).  (The Electric Generation Association was formed by the
                     merger of the Independent Power Producers Working Group  and the
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                     Cogeneration and Independent Power Coalition of America.)  The EPSA
                     mission is to advance the interests of its members: competitive generators,
                     power marketers, and other suppliers.  The EPSA advocates domestic and
                     international policies that will result in a fully competitive electric power
                     supply marketplace.  The EPSA supports the development of a market in
                     which existing commitments, such as independent power contracts,  are
                     honored and in which all customers have a choice of electric suppliers by a
                     certain date.
                      National Rural Electric Cooperative
                      Association (NRECA)
                      4301 Wilson Boulevard
                      Arlington, VA 22203
                      Phone: (703) 907-5500
                      Fax: (703) 907-5521
                      Website: http://www.nreca.org/
                    Members: 1000
                    Staff: 600
                    Contact: Glenn English
                     The NRECA, founded in 1942, represents rural electric cooperatives, public
                     power districts, and public utility districts in 46 States. The NRECA is an
                     advocate for energy and operational issues, as  well  as rural  electric
                     development. The association maintains a library of 20,000 volumes, holds
                     professional conferences,  and publishes a magazine and newsletter. Other
                     activities include legislative representation; energy, regulatory, and legal
                     expertise; industry public relations; management institutes;  training and
                     energy research and development consulting services; insurance and safety
                     programs; wage and salary surveys; and an international program.
                      North American Electric Reliability
                      Council (NERC)
                      Princeton Forrestal Village
                      116-390 Village Boulevard
                      Princeton, NJ 08540-5731
                      Phone: (609) 452-9550
                      Fax:(609) 452-7669
                      Website: http://www.nerc.com/
                    Members: 9 Regional
                    Councils
                    Contact: Michehl R. Gent
                    The NERC is a nonprofit company owned by nine regional councils. The
                    members of the regional councils and one affiliate are individual utilities
                    representing all ownership categories of the electric utility industry, including
                    investor-owned, municipal, rural electric cooperatives, Federal, independent
                    power producers,  power marketers,  and power brokers.  The principal
                    purpose of NERC is to coordinate, promote, and communicate the reliability
                    of North American electric utilities. The organization annually reviews the
                    reliability and adequacy of the bulk electricity systems in North America and
                    maintains several  databases.   In addition, the organization  facilitates
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                    development  of reliability-related planning and  operating criteria  and
                    standards, and publishes reports and reference documents.
                     Utility Air Regulatory Group
                     (UARG)
                     c\o Hunton & Williams
                     1900 K Street NW
                     Washington, DC 20460
                     Phone: (202) 955-1500
                     Fax: (202) 778-2201
           Members: 74
                    The UARG is a voluntary, nonprofit, unincorporated, ad hoc group of 74
                    electric utilities, the EEI, the NRECA, and the APPA. The UARG's purpose
                    is to participate on behalf of its members collectively in Federal air pollution
                    control regulatory activities and in related litigation.
                     Utility Solid Waste Activities
                     Group (USWAG)
                     c\o EEI
                     701 Pennsylvania Ave. NW
                     Washington, DC 20004
                     Phone: (202) 508-5645
                     Fax: (202) 508-5150
           Members: 83
           Contact: Jim Roewer
                    The USWAG is an informal consortium of the EEI, the APP A, the NRECA
                    and approximately  80 electric  utility companies.  Together, USWAG
                    members represent more than 85 percent  of the total electric generating
                    capacity of the United States and service more than 95 percent of the Nation's
                    consumers of electricity.  The mission of USWAG is to help member
                    companies manage all utility wastes and byproducts in a manner that is
                    protective of human health and the environment and is of reasonable cost.
                     Utility Water Act Group
                     (UWAG)
                     c\o Hunton & Williams
                     1900 K Street NW
                     Washington, DC 20460
                     Phone: (202) 955-1500
                     Fax: (202) 778-2201
           Members: 78
           Contact: John (Jack) F. Mackenzie,
           Chair
           Pacific Gas and Electric Co.
           Phone: (415) 973-6901
           Fax: (415) 973-9201
                    The UWAG is an association of 75 individual utilities and three national
                    trade associations of electric utilities~the EEI, the NRECA, and the APPA.
                    The UWAG purpose is to participate on behalf of its members in EPA's
                    rulemakings under the CWA and in litigation arising from those rulemakings.
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 IX.     CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS

 For further information on selected topics within the fossil fuel electric power generation industry
 a list of contacts and publications are provided below.

 Contacts
Name
Rafael Sanchez
Chris Oh
Joe Daly
Organization
EPA/OECA/METD
EPA/OECA/METD
EPA/OST/EAD
Telephone
(202) 564-7028
(202) 564-7004
(202)260-7186
Subject
Compliance assistance
Compliance assistance
Steam Electric Effluent Guidelines
Acknowledgments
The contacts listed below have provided valuable background information and comments during the
development of this document. EPA appreciates this support and acknowledges that the individuals
listed do not necessarily endorse all statements made within this sector notebook.

Joseph Daly - EPA/Office of Water (EPA/OW)
Rafael Sanchez - EPA/Office of Enforcement and Compliance Assurance (EPA/OECA)
Bill Maxwell - EPA/Office of Air Quality Standards and Planning (EPA/OAQSP)
Samuel S. Tyson - American Coal Ash Association (ACAA)
Bill Wemhoff - American Public Power Association (APPA)
Kara M. Downey - Arizona Electric Power Cooperative, Inc.(AEPC)
Ruth M. Bennett - Association of Energy Engineers (AEE)
Alice Meyer - Edison Electric Institute (EEI)
Richard W. Sternberg - National Rural Electric Cooperative Association (NRECA)
Anthony Riai - EPA/Office of Enforcement and Compliance Assurance (EPA/OECA)

General Profile	

1995 Capacity and Generation of Non-Utility Sources of Energy. Prepared by the Edison Electric
Institute, Washington, D.C. November 1996.

Annual Energy Outlook 1997 - With Projections to 2015. U.S. Department of Energy, Energy
Information Administration, Washington, D.C. December 1996. DOE/EIA-0383(97).

Directory of U.S. Cogeneration, Small Power, and Industrial Power Plants. Giles, Ellen, and Fred
Yost.  Twelfth Edition. Utility Data Institute, A Division of McGraw-Hill Company. June 1985.
UDI-2018-95.

Electric Power Annual,  1995, Volume  1.  U.S. Department of Energy,  Energy  Information
Administration, Washington, D.C.  July 1996.  DOE/EIA-0348(95/1).
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Electric Power Annual  1995,  Volume II. U.S.  Department  of Energy, Energy Information
Administration, Washington, D.C. December 1996. DOE/EIA-0348(95)/2.

Federal Technology Alert. U.S. Department of Energy, Washington, D.C. May 1997.

Financial Statistics of Major U.S. Publicly-Owned Electric Utilities -1994. U.S. Department of
Energy, Energy Information Administration, Washington, D.C.  December 1995. DOE/EIA-
0437/(94)/2.

Financial Statistics of Major U.S. Investor-Owned Electric Utilities - 1995. U.S. Department of
Energy, Energy Information Administration, Washington, D.C. December 1996. DOE/EIA-
0437/(95)/l.

Inventory of Power Plants in the United States, As of January 1, 1996. U.S. Department of Energy,
Energy Information Administration, Washington, D.C. December 1996. DOE/EIA-0095(95).

The Changing Structure of the Electric Power Industry: An Update. U.S. Department of Energy,
Energy Information Administration, Washington, D.C.  December 1996. DOE/EIA-0562(96).

The Changing Structure of the Electric Power Industry, 1970-1991. U.S. Department of Energy,
Energy Information Administration, Washington, D.C.  March 1993. DOE/EIA-0562.

Process Descriptions and Chemical Use Profiles	

Clean Power From Fossil Fuels.  Energy and the Environment, the Linacre Lectures 1991 -1992.
Chester, Peter. Bryan Cartledge, ed.  Oxford University Press, Oxford.  1993.

Development Document for Effluent Limitations  Guidelines and Standards and Pretreatment
Standards for the Steam Electric Point Source Category.  U.S. Environmental Protection Agency,
Office of Water, Washington, D.C.  1982. EPA 440/1-82/029.

EM  Guidelines for New Source Fossil Fueled  Steam  Electric Generating Stations.   U.S.
Environmental Protection Agency, Office of Federal Activities by SAIC, Falls Church. VA, 1994.

Electric Power Annual 1995.  Energy Information Administration.  U.S. DOE Office of Coal,
Nuclear, Electric and Alternate Fuels, Washington, D.C. 1996.

Energy, Electric Power and Man. Healy, Timothy J. Boyd & Fraser Co. San Francisco, CA. 1974.

Standard Handbook of Power Plant Engineering. Elliot, Thomas C., ed. McGraw-Hill, Inc., New
York, NY.  1989.

Steam and its Generation  and Use, 40th edition. Stultz and Kitto, eds. Babcock & Wilcox,
Barbeton,OH. 1992.
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 Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units - Interim
 Final Report, Volume L  U.S. Environmental Protection Agency, Office of Air Quality Planning &
 Standards, Research Triangle Park, N.C. 1996. EPA-453/R-96-013a.

 Wastes from the Combustion of Coal by Electric Utility Power Plants.  U.S. Environmental
 Protection Agency, Office of Solid Waste and Emergency Remediation, Washington, D.C. 1988.
 EPA 530-SW-88-002.

 Regulatory Profile	

 Development Document For Effluent Limitations Guidelines and Standards and Pretreatment
 Standards for the Steam Electric Point Source Category. U.S. Environmental Protection Agency,
 Office of Water, Washington, D.C. November, 1982.

 EIA Guidelines for New Source Fossil Fueled Steam Electric Generating Stations.    U.S.
 Environmental Protection Agency, Office of Federal Activities by SAIC, Falls Church, VA, 1994.

 Electricity Generation and Environmental Externalities: Case Studies.  U.S. Department of Energy,
 Assistant Secretary for Fossil Energy, Washington, D.C.. September 1995. DOE/FE-0598

 Standard Handbook of Power Plant Engineering. Elliot, Thomas C., ed. McGraw-Hill, Inc., New
 York, NY. 1989.

 Steam  and its Generation and Use, 40th edition.  Stultz and Kitto, eds.   Babcock & Wilcox,
 Barbeton, OH.  1992.

 Pollution Prevention	

 Case Summaries of Waste Reduction by Industries in the Southeast. Gary Hunt, et al., eds. North
 Carolina Department of Natural Resources and Community Development. July 1989.

 Clean  Coal Technology Demonstration Program, Program Update  1995.  U.S. Department of
 Energy, Assistant Secretary for Fossil Energy, Washington, D.C. April 1996. DOE/FE-0346.

 Coal Combustion Product Production and Use: 1966-1994, Report for Coal Burning Electric
 Utilities in the United States.  American Coal Ash Association, Inc. Alexandria, VA. May 1996.

Enviro$ense,  Fact Sheet: Pollution Prevention: Strategies for  Fossil Fuel  Electric  Power
 Generation. Center for Hazardous Material Research (CHMR). Pittsburg, PA. Online, Available:
http://es.inel.gov.com.  Last updated January 9,1996.

EnviroSense, Cogeneration of Steam and Electric Power: Pollution Prevention Opportunities and
 Options,  Report 49-1, September 1994, Prepared by: Commonwealth of Virginia Department of
Environmental, Quality Office of Pollution Prevention.   Richmond, VA.   Online, Available:
http://es.inel.gov.com, Last updated January 29,1996.
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EnviroSenSe, Pollution Prevention Opportunities in Fossil Fuel Electric Power Generation. October
1990. Online, Available: http://es.inel.gov.techinfo/facts/epa/fosilful.html.

Fact Sheet: Eliminating Hexavalent Chromium from Cooling Towers. City of Los Angeles, Board
of Public Works, Hazardous and Toxic Materials Office.  Undated.

Fact Sheet: Water and Chemicals Reduction for Cooling Towers. North Carolina Department of
Environmental Health and Natural Resources, Pollution Prevention Program. May 1987.

Industrial Pollution Prevention Handbook. Harry M. Freeman, ed. McGraw-Hill Inc. 199:5.

Pollution Prevention/Environmental Impact Reduction Checklist for Coal-Fired Power Plants. U.S.
Environmental Protection Agency, Office of Federal Activities, Washington, D.C. Undated. Online,
Available: http://es.enel.gov./oeca/ofa/pollprev/coal.html.

Preamble to NPDES  Storm Water Multi-sector  General Permit for Industrial Activities (60 FR
50974, Friday, September 29,1995).

Summary of Results from Programs Conducted by the Office Of Industrial Technologies. U.S.
Department of Energy, Office of Energy Efficiency and Renewable Energy, Office of Industrial
Technologies, Washington, D.C. October 1995.

U.S. Electric Utility Demand-Side Management 1994. Energy Information Administration.  Office
of Coal, Nuclear, Electric and Alternate Fuels.  U.S. Department of Energy. Washington, D.C.
December 1995. DOE/EIA-0589(94).
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 Fossil Fuel Electric Power Generation
                                    Endnotes
                                     ENDNOTES

 1.  Inventory of Power Plants in the United States, As of January 1, 1996.  U.S. Department of
 Energy,  Energy Information Administration, Washington, D.C. December  1996. DOE/EIA-
 0095(95).

 2. 1995 Capacity and Generation ofNon-Utility Sources of Energy. Prepared by the Edison Electric
 Institute, Washington, D.C.  November 1996.

 3.  Electric Power Annual 1995,  Volume II.  U.S. Department of Energy, Energy Information
 Administration, Washington, D.C. December 1996. DOE/EIA-0384(95)72.

 4.  Inventory of Power Plants in the United States, As of January 1, 1996. U.S. Department of
 Energy, Energy Information administration, Washington, D.C. December 1996. DOE/EIA-0095(95).

 5.  1995 Capacity and Generation ~of Nonutility Sources of Energy. Edison Electric Institute,
 Washington, D.C. November 1996.

 6.  1995 Capacity and Generation of Nonutility Sources of Energy. Edison Electric Institute,
 Washington, D.C. November 1996.

 7.  1995 Capacity and Generation of Nonutility Sources of Energy. Edison Electric Institute,
 Washington, D.C. November 1996.

 8.  Electric Power Annual 1995,  Volume II. U.S. Department of Energy, Energy Information
 Administration, Washington, D.C. December 1996. DOE/EIA-03 84(95)72.

 9. The Changing Structure of the Electric Power Industry: An Update.  U.S. Department of Energy,
 Energy Information Administration, Washington, D.C.  December 1996.  DOE7EIA-0562(96).

 10. The Changing Structure of the Electric Power Industry: An Update. U.S. Department of Energy,
 Energy Information Administration, Washington, D.C.  December 1996.  DOE/EIA-0562(96).

 11. Annual Energy Outlook 1997 - With Projections to 2015. U.S. Department of Energy, Energy
 Information Administration, Washington, D.C. December 1996. DOE/EIA-0383(97).

 12. Annual Energy Outlook 1997 - With Projections to 2015. U.S. Department of Energy, Energy
 Information Administration, Washington, D.C. December 1996. DOE/EIA-0383(97).

 13. Electric Power Annual 1995, Volume I. U.S. Department of Energy, Energy Information
 Administration, Washington, D.C.  July 1996. DOE/EIA-0348(95)/1.

 14. Energy, Electric Power and Man. Healy, Timothy.  J. Boyd & Fraser Co., San Francisco, CA.
 1974.
Sector Notebook Project
147
September 1997

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Fossil Fuel Electric Power Generation
                                  Endnotes
15. Standard Handbook of Power Plant Engineering.  Elliot, Thomas C. Ed. McGraw-Hill, Inc.
New York, NY. 1989.

16. Standard Handbook of Power Plant Engineering.  Elliot, Thomas C. Ed. McGraw-Hill, Inc.
New York, NY. 1989.

17. Standard Handbook of Power Plant Engineering.  Elliot, Thomas C. Ed. McGraw-Hill, Inc.
New York, NY. 1989.

18. Electric Power Annual 1995, Volumes I and II. U.S. Department of Energy, Energy Information
Administration. Washington, D.C. July and December 1996. DOE/EIA-0348(95)/1&2.

 19. Energy, Electric Power and Man. Healy, Timothy. J. Boyd & Fraser Co., San Francisco, CA.
1974, and Electric Power Annual 1995, Volumes I and II. U.S. Department of Energy, Energy
Information Administration.  Washington, D.C.  July and December 1996.

20. Energy, Electric Power and Man. Healy, Timothy. J. Boyd & Fraser Co., San Francisco, CA.
1974, and Electric Power Annual 1995, Volumes I and II. U.S. Department of Energy, Energy
Information Administration.  Washington, D.C.  July and December 1996.

21. Clean Power From Fossil Fuels.  Chester, Peter, and Bryan Carteledge, eds. Linacre Lectures
1991-1992. Oxford University Press, Oxford, 1974. DOE/EIA-0348(95)/1&2.

22, Electric Power Annual 1995, Volumes I and II. U.S. Department of Energy, Energy Information
Administration. Washington, D.C. July and December 1996. DOE/EIA-0348(95)/1&2.

23.  Steam, Its Generation and Use, 40th Edition. Stultz and Kitto, eds. Babcock & Wilcox,
Barbeton,OH. 1992.

24.  Steam, Its Generation and Use, 40th Edition. Stultz and Kitto, eds. Babcock & Wilcox,
Barbeton,OH. 1992.

25. Standard Handbook of Power Plant Engineering. Elliot, Thomas C. Ed. McGraw-Hill, Inc.
New York, NY. 1989.

26.  Steam, Its Generation and Use, 40th Edition.  Stultz and Kitto, eds.  Babcock & Wilcox,
Barbeton, OH. 1992.

27. Electric Power Annual 1995, Volumes I and II. U.S. Department of Energy, Energy Information
Administration. Washington, D.C. July and December 1996. DOE/EIA-0348(95)/1&2.

28. Electric Power Annual 1995, Volumes I and II. U.S. Department of Energy, Energy Information
Administration. Washington, D.C. July and December 1996. DOE/EIA-0348(95)/1&2.

29. Electric Power Annual 1995, Volumes I and II. U.S. Department of Energy, Energy Information
Administration. Washington, D.C. July and December 1996. DOE/EIA-0348(95)/1&2.
 Sector Notebook Project
148
September 1997

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Fossil Fuel Electric Power Generation
                                    Endnotes
30.  Steam, Its Generation and Use, 40th Edition. Stultz and Kitto, eds.  Babcock & Wilcox,
Barbeton, OH.  1992.

31.  Steam, Its Generation and Use, 40th Edition. Stultz and Kitto, eds.  Babcock & Wilcox,
Barbeton, OH.  1992

32. Power Statistics Database (1994 Data). Edison Electric Institute. Prepared by the Utility Data
Institute, McGraw-Hill, Inc. Washington, D.C. 1995.

33. Personal communication with Joe Daly, EPA Office of Science and Technology, Engineering
and Analysis Division.  March 14,1997.

34.  Electric Power Annual 1995, Volume II. U.S. Department of Energy, Energy Information
Administration, Washington, D.C. December 1996. DOE/EIA-03 84(95)72.

35. Study of Hazardous Air Pollutant Emissions from Electric Utility Steam Generating Units —
Interim Final Report. U.S. EPA Office of Air Quality Planning and Standards, Research Triangle
Park,NC. October 1996. EPA-453/R-96-013a.

36. Enviro$ense, Cogeneration of Steam and Electric Power: Pollution Prevention Opportunities
and Options, Report 49-1. Commonwealth of Virginia, Department of Environmental Quality
Office of Pollution and Prevention. September 1994. Online, Available: http://es.enel.gov.com. Last
updated January 29, 1996.

37. Case Summaries of Waste Reduction by Industries in the Southeast. Gary M. Hunt et. al., eds.
North Carolina Department of Natural Resources and Community Development. July 1989.

38. Summary of Results from Programs Conducted by the Office Of Industrial Technologies.  U.S.
Department of Energy,  Office of Energy Efficiency and Renewable Energy, Office of Industrial
Technologies.  October  1995.

39. Federal Technology Alert. U.S. Department of Energy, Washington, D.C. May 1997.

40. Federal Technology Alert. U.S. Department of Energy, Washington, D.C. May 1997.

41. Industrial?ollution  Prevention Handbook. Freeman, Harry M. Ed. McGraw Hill Inc. 1995.

42. Pollution Prevention/Environmental Impact Reduction Checklist for Coal-Fired Power Plants.
U.S. Environmental Protection Agency, Office of Federal Activities. Undated. Online, Available:
pollprev/coal.html.

43.  Personal Communication.  Leonard Swann, Specialty Products Inc.  Distributor for Armex
Accustrip systems. March 7, 1997.

44. Industrial Pollution Prevention Handbook.  Freeman, Harry M. Ed. McGraw Hill Inc. 1995.
Sector Notebook Project
149
September 1997

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Fossil Fuel Electric Power Generation
                                  Endnotes
45. "Boiler Chemical Cleaning Waste Can Make Money." Electric Co-op Today. May 2,1997.

46. Coal Combustion Product Production and Use: 1966-1994, Report for Coal Burning Electric
Utilities in the United States. American Coal Ash Association, Inc. Alexandria, VA. May 1996.

47. U.S. Electric Utility Demand-Side Management 1994. Office of Coal, Nuclear, Electric and
Alternate Fuels. U.S. Department of Energy, Energy Information Administration.  Washington, D.C.
December 1995. DOE/EIA-0589(94).
Sector Notebook Project
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                               APPENDIX A
      INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK

          Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web.  The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.

ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB

      To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
      Web Browser to the following address:
      http://es.epa.gov/comply/sector/index.html
      or use


      WWW.epa.gOV/OeCa -   then select the button labeled Industry and Gov't
                                    Sectors and select the appropriate sector from the
                                    menu.  The Notebook will be listed.

      Direct technical questions to the Feedback function at the bottom of the web page or to
      Shhonn Taylor at (202) 564-2502
                                  Appendix A

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Sector Notebook Project                  A - 2                           September 1997

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