&EPA
                                            821-B-05-005
               Preliminary Engineering Report:
                 Steam  Electric Detailed Study
                      U.S. Environmental Protection Agency
                                Engineering and Analysis Division
                                           Office of Water
                                 1200 Pennsylvania Avenue, NW
                                      Washington, D.C. 20460
                                            August 2005

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                     ACKNOWLEDGMENT AND DISCLAIMER
             This report was prepared with the technical support of Eastern Research Group,
Inc. under the direction and review of the Office of Science and Technology. Neither the United
States Government nor any of its employees, contractors, subcontractors, or their employees
make any warrant, expressed or implied, or assume any legal liability or responsibility for any
third party's use of, or the results of, such use of any information, apparatus, product, or process
discussed in this report, or represents that its use by such party would not infringe on privately
owned rights.

             The primary contact regarding questions or comments on this document is:

                                 Martha Segall
                                 U.S. EPA Engineering and Analysis Division (4303T)
                                  1200 Pennsylvania Avenue NW
                                 Washington, DC 20460

                                 (202) 566-1041 (telephone)
                                 (202) 566-1053 (fax)
                                 segall.martha@epa.gov

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                               TABLE OF CONTENTS

                                                                                Page

1.0    INTRODUCTION	1-1

2.0    EXISTING EFFLUENT GUIDELINES AND OTHER REGULATIONS	2-1
       2.1    Steam Electric Effluent Guidelines	2-1
       2.2    Cooling Water Intake Structures	2-4
       2.3    Air Regulations 	2-6
       2.4    Resource Conservation and Recovery Act (RCRA)  	2-7

3.0    DATA SOURCES  	3-1
       3.1    Energy Information Administration	3-2
             3.1.1  FormEIA-860 	3-2
             3.1.2  FormEIA-767 	3-3
       3.2    Permit Compliance System 	3-3
       3.3    Toxic Release Inventory (TRI)  	3-6
       3.4    Economic Census	3-7
       3.5    Section 316(b) Cooling Water Intake Structures	3-7
       3.6    Utility Water Act Group  	3-8
       3.7    1996 Preliminary Data Summary for the Steam Electric Point Source Category
             (PDS)	3-9
       3.8    OECA Sector Notebook	3-9

4.0    INDUSTRY PROFILE	4-1
       4.1    Facility Types 	4-1
       4.2    Process Description and Wastewater Sources	4-3
       4.3    Industry Demographics  	4-7
             4.3.1  Overall Steam Electric Industry	4-8
             4.3.2  Utilities	4-12
             4.3.3  Nonindustrial Nonutilities	4-14
             4.3.4  Industrial Nonutilities 	4-17
             4.3.5  Other Fuel  Sources	4-20

5.0    WASTEWATER CHARACTERIZATION	5-1
       5.1    Utilities	5-2
             5.1.1  PCS  	5-2
             5.1.2  TRI	5-12
       5.2    Nonindustrial Nonutilities	5-15
             5.2.1  PCS  	5-15
             5.2.2  TRI	5-20
       5.3    Industrial Nonutilities  	5-24

6.0    ADDITIONAL INFORMATION NEEDS AND NEXT STEPS	6-1
       6.1    Pollution Prevention and Wastewater Treatment Technologies  	6-2
       6.2    UWAG Information	6-3

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                        TABLE OF CONTENTS (Continued)

                                                                               Page

      6.3    Industrial Nonutilities  	6-3
      6.4    Renewable/Recycled Fuel Sources  	6-4
      6.5    Emerging Issues	6-5

7.0   REFERENCES	7-1
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                                   LIST OF TABLES

                                                                                   Page

2-1    Pollutants Regulated by Existing Effluent Limitations Guidelines and Standards .... 2-3

3-2    Steam Electric Facilities Contacted to Verify PCS 2002 Data	3-5

4-1    Wastewater Streams from Steam Electric Facilities  	4-6

4-2    Distribution of PCS Facilities by SIC Code 	4-8

4-3    Distribution of TRI Facilities by SIC Code	4-9

4-4    Number of Steam Electric Facilities, Generating Units, and Capacity, by Facility Type
       Reported to EIA	4-12

4-5    Distribution of Steam Electric Utilities by Size	4-12

4-6    Distribution of Steam Electric Nonindustrial Nonutilities by Size	4-15

4-7    Distribution of Industrial Nonutilities by NAICS Code 	4-17

4-8    Distribution of Steam Electric Industrial Nonutilities by Size 	4-19

4-9    Summary of EIA Data for Other Fuel Sources for All Steam Electric Facilities Reporting
       to EIA 2002 	4-21

5-1    Number of Facilities in the PCS and TRI Databases Matched to the EIA Database  .  . 5-2

5-2    The Top Pollutants Released From 327 Utilities in the PCS Database	5-3

5-3    Pollutants Without TWFs Discharged From 327 Utilities in the PCS Database	5-4

5-4    PCS Discharges From 327 Utilities Distributed by Energy Source  	5-5

5-5    Top Five Pollutants From 327 Utilities by Fuel Source 	5-6

5-6    Pollutant Releases From RE Ginna Nuclear Plant in Ontario, NY	5-6

5-7    Flow Categories	5-7

5-8    TWPE From Utilities by Flow Range	5-8

5-9    Flow Distribution for the Top Five Pollutants Released by Utilities  	5-8

5-10   Distribution of Cooling Systems Used by Utilities	5-9

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                            LIST OF TABLES (Continued)

                                                                                 Page

5-11  Distribution of PCS TWPE From 305 Utilities by Type of Cooling System1	5-10

5-12  PCS Concentration Information From 309 Utilities for Top Pollutants in PCS  	5-11

5-13  Pollutants Released From 235 Utilities in the TRI Database  	5-13

5-14  TRI Discharges From 235 Utilities Distributed by Energy Source	5-14

5-15  Top Five Pollutants From 235 Utilities for Each Fuel Source in the TRI Database .  . 5-15

5-16  The Top Pollutants Released From 163  Steam Electric Nonindustrial Nonutilities in the
      PCS Database	5-16

5-17  Comparison of Capacity Between Utilities and Nonindustrial Nonutilities Reporting in
      the PCS Database	5-17

5-18  Pollutants Without TWFs Released From 163 Nonindustrial Nonutilities in the PCS
      Database	5-17

5-19  PCS Discharges From 163 Nonindustrial Nonutilities Distributed by Energy Source 5-18

5-20  Comparison of TWPE/Facility Between Utilities and Nonindustrial
      Nonutilities Reporting in the PCS Database 	5-19

5-21  Comparison of TWPE/MW Between Utilities and Nonindustrial Nonutilities Reporting in
      the PCS Database	5-20

5-22  Distribution of Cooling Systems Used by Nonindustrial Nonutilities  	5-20

5-23  The Top Pollutants Released From 103  Steam Electric Nonindustrial Nonutilities in the
      TRI Database	5-21

5-24  TRI Discharges From 103 Nonindustrial Nonutilities Distributed by Energy Source  5-22

5-25  Comparison of TWPE Between Utility and Nonindustrial Nonutility Facilities Reporting
      in the TRI Database	5-23

5-26  Comparison of TWPE/MW Between Utility and Nonindustrial Nonutility Facilities
      Reporting in the TRI Database 	5-23

5-27  Industries Represented in the Analysis of 60 Industrial Nonutilities  	5-25
                                          IV

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                             LIST OF TABLES (Continued)

                                                                                   Page

5-28   Top Pollutants Released From 60 Industrial Nonutility Facilities Reporting in the PCS
       Database	5-26

5-29   Distribution of Cooling Systems Used by 60 Industrial Nonutility Facilities	5-27

5-30   Distribution of Energy Sources Used by Industrial Nonutility Facilities 	5-27

6-1    Potential Pollution Prevention Options for Steam Electric Facilities	6-2

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                                   LIST OF FIGURES




                                                                                   Pages




4-1    Steam Electric Process Flow Diagram	4-5




4-2    Distribution of Electricity Production in the Steam Electric Industry, 2002	4-11




4-3    Distribution of Utility Capacity by Energy Source	4-13




4-4    Capacity of Utilities by Fuel Type	4-14




4-5    Distribution of Nonindustrial Nonutility Capacity by Energy Source  	4-16




4-6    Capacity of Nonindustrial Nonutilities by Fuel Type	4-16




4-7    Distribution of Industrial Nonutility Capacity by Energy Source	4-19




4-8    Capacity of Industrial Nonutilities by Fuel Source	4-20
                                           VI

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i.o    INTRODUCTION

       Every other year, Section 304(m) of the Clean Water Act requires EPA to publish a plan
establishing a schedule for the annual review and revision of effluent guidelines required by
Section 304(b). Section 304(m) also requires EPA to take public comment on its plan prior to
issuing a final plan. EPA published the latest biennial plan, the 2004 effluent guidelines program
plan ("2004 Plan"), on September 2, 2004 (69 FR 53705). EPA selected the Steam Electric
Point Source Category (40 CFR 423) for detailed investigation because it ranked second in terms
of toxic and non-conventional toxic-weighted discharges in the 2005 annual review.

       During the development of the 2004 Plan, EPA identified data gaps and issues that may
affect the Agency's estimate of the potential hazards caused by discharges from steam electric
facilities.  To fill these gaps, EPA is currently collecting information on the wastewater
characteristics and treatment technologies used at facilities in the steam  electric point source
category, including electric utilities and nonutilities that use fossil fuels  or nuclear fuel to
generate electricity for distribution in commerce. As part of the detailed study, EPA will also
investigate data on facilities that are not currently regulated under Part 423 but that use a steam
cycle to generate electricity. EPA will evaluate whether the point source category should be
revised to include these facilities.

       This report presents the preliminary results of EPA's evaluation and outlines the
additional data collection that will be conducted for the development of the next biennial plan
("2006 Plan"). The report is organized into the following sections:

       •      Section 2.0 summarizes the existing regulations for this industry;
       •      Section 3.0 discusses the data sources used in this profile;
       •      Section 4.0 presents a profile of the industry;
       •      Section 5.0 discusses wastewater characteristics;
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•      Section 6.0 discusses the additional information needs and next steps in the
       detailed review; and

•      Section 7.0 presents the references used to date for the detailed study.
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2.0    EXISTING EFFLUENT GUIDELINES AND OTHER REGULATIONS


       This section presents a brief overview of existing regulations for steam electric facilities
and is divided into the following sections:


       •      Section 2.1 discusses the current effluent guidelines for the steam electric point
             source category;

       •      Section 2.2 discusses the Cooling Water Intake Structure regulations;

       •      Section 2.3 discusses Clean Air Act requirements; and

       •      Section 2.4 discusses Resource Conservation and Recovery Act requirements
             (RCRA).


2.1    Steam Electric Effluent Guidelines


       The steam electric point source category is currently regulated under 40 CFR 423. EPA
first published effluent guidelines for this category in 1974 with subsequent revisions in 1977
and 1982.  The timeline below describes the history of the effluent guideline:
October 8,1974 (39 FR 36186):
      EPA promulgated effluent limitations based on:

             —     Best practicable control technology currently available (BPT),
             —     Best available control technology economically achievable (BAT),
             —     New Source performance standards (NSPS), and
             —     Pretreatment standards for new sources (PSNS).

      The promulgated regulations addressed thermal and chemical pollution. Amendments
      were issued February 19, 1975 (40 FR 23987) and June 4, 1978 (40 FR 23987). The
      chemical limitations covered the following wastestreams:

             —     Once-through cooling water,
             —     Cooling tower blowdown,
             —     Bottom ash transport water,
             —     Fly ash transport water,
             —     Boiler blowdown,
             —     Low volume wastes,
             —     Metal cleaning wastes, and

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              —    Material storage and construction runoff (including coal pile runoff).

July 16,1976:
       The U.S. Court of Appeals in the Fourth Circuit remanded (1) thermal limitations;1 (2)
       NSPS for fly ash transport water; (3) rainfall run off limitations; and (4) BPT variance
       clause.

March 23,1977 (42 FR 15695):
       EPA promulgated pretreatment standards for existing sources (PSES). PSES covered
       copper in metal cleaning wastes, polychlorinated biphenyls (PCBs), and oil and grease.

November 19,1982 (47 FR 52290):
       EPA revised existing BAT, NSPS, PSES, and PSNS effluent limitations guidelines and
       standards for the steam electric point source category, codified at 40 CFR 423.  The
       regulations modified the existing subcategorization  scheme and reserved effluent
       limitations for four types of waste streams for future rulemaking:

              —    Non-chemical metal cleaning,
              —    Flue gas desulfurization waters,
              —    Thermal discharges, and
              —    Run off from materials storage and construction areas (other than coal
                    storage).

       The 1982 guidelines are summarized in Table 2-1 and are applicable to:

              discharges resulting from the operation of a generating unit by an establishment
       primarily engaged in the generation of electricity for distribution and sale which results
       primarily from a process utilizing fossil-type fuel (coal, oil, or gas) or nuclear fuel in
       conjunction with a thermal cycle employing the steam water system as the
       thermodynamic medium.
'Thermal dischargers may still apply for a variance from stated water quality standards under section 316(a) of the
Clean Water Act.

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      Table 2-1.  Pollutants Regulated by Existing Effluent Limitations Guidelines and
                                            Standards
Wastestream
All Wastestreams
Low Volume Wastes
Fly Ash Handling
Bottom Ash Handling
Chemical Metal
Cleaning
Once Through Cooling
Cooling Tower
Blowdown
Coal Pile Runoff
BPT
pH6-9
PCBs: Zero
discharge
TSS 100/30
Oil and Grease
20/15
TSS 100/30
Oil and Grease
20/15
TSS 100/30
Oil and Grease
20/15
TSS 100/30
Oil and Grease
20/15
Cu 1.0/1.0
Fe 1.0/1.0
FAC 0.5/0.2
FAC 0.5/0.2
TSS 50 max
BAT
PCBs: Zero
discharge
No Limitation
No Limitation
No Limitation
Cu 1.0/1.0
Fe 1.0/1.0
TRC 0.20 max or =
BPTif<25MW
FAC 0.5/0.2
126 Pr. Pol. No.
Detect
Cr 0.2/0.2
ZN 1.0/1.0
No Limitation
NSPS
pH6-9
PCBs: Zero
discharge
= BPT
Zero Discharge
TSS 100/30
Oil and Grease
20/15
TSS 100/30
Oil and Grease
20/15
Cu 1.0/1.0
Fe 1.0/1.0
TRC 0.20 max or =
BPTif<25MW
FAC 0.5/0.2
126 Pr. Pol. No.
Detect
Cr 0.2/0.2
ZN 1.0/1.0
TSS 50 max
PSES & PSNS
PCBs: Zero
discharge
No Limitation
Zero Discharge
(PSNS only)
No limitation in
PSES
No Limitation
Cu 1.0 max
No Limitation
126 Pr. Pol.
No Detect
Cr 0.2 max
Zn 1.0 max
No Limitation
Source: Code of Federal Regulations .
Notes:
- Concentrations are in mg/1. If daily maximum and 30-day average concentrations apply, they are given as
"maximum/average".
- Total Residual Chlorine (TRC) = Free Available Chlorine (FAC) + Combined Residual Chlorine (CRC).
- BCT is reserved for all wastestreams.
- Low Volume Wastes include: clarifier blowdown, makeup water filter backwash, lime softener blowdown, ion
exchange softener regeneration, demineralizer regeneration, powdered resin demineralizer back flush, reverse
osmosis brine, boiler blowdown, evaporator blowdown, laboratory drains, sanitary wastes, and diesel engine cooling
system discharge.
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       Region IV issued a policy guidance letter on December 19, 1989 stating that the steam
electric unit of a facility employing combined-cycle technology is subject to the applicability of
the steam electric effluent guidelines in 40 CFR 423. Region IV made the determination during
a review of proposed new facilities at a Florida Power & Light plant. Because the steam electric
portion of a facility employing combined-cycle technology uses fossil-type fuel in conjunction
with a thermal cycle, Region IV declared that Part 423 applies to the steam electric portion of
these facilities.  The Region IV letter also states that no operational, technological, economic, or
cost factors distinguish the steam electric portion of a combined cycle plant from a stand-alone
steam electric unit. EPA has been following this guidance. (1)

       The current applicability of Part 423 does not include facilities that may be using a
renewable fuel source, such as biomass or wood wastes, to generate steam to produce electricity,
nor does it cover facilities whose primary activity is not the distribution and sale of electricity.
According to information provided in the  1996 Preliminary Data Summary for the Steam
Electric Point Source Category., permits for the effluent wastestreams of an electric power
generating unit which exists as an  ancillary unit of a plant not subject to Part 423 are normally
written by best professional judgement (BPJ) using Part 423 regulations for similar wastestreams
(U.S. EPA, 1996).  EPA does not have information regarding the application of Part 423 limits to
facilities using renewable fuel sources.

2.2    Cooling Water Intake Structures

       Section 316(b) of the Clean Water Act requires EPA to ensure that the location, design,
construction, and capacity of cooling water intake structures reflect the best technology available
to minimize adverse environmental impacts. Such impacts include death or injury to aquatic
organisms by impingement (being pinned against screens or other parts of a cooling water intake
structure) or entrainment (being drawn into cooling water systems and subjected to thermal,
physical, or chemical stresses). In response to section 316(b), EPA developed the regulation in
three phases:
              Phase I, promulgated on December 18, 2001 (66 FR 65256), covers new facilities
              that use cooling water intake structures to withdraw water from waters of the U.S.
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              and that have or require a National Pollutant Discharge Elimination System
              (NPDES) permit.  New facilities subject to the Phase I regulations include those
              that have a design intake flow of greater than two million gallons per day and that
              use at least 25% of the water withdrawn for cooling purposes;

              Phase II, promulgated on July 9, 2004 (69 FR 41576), covers large existing
              electric generating plants that use at least 50 million gallons of water a day from
              waters of the U.S., including existing utilities and nonindustrial nonutilities; and

              Phase III, proposed on November 24, 2004 (69 FR 68444), would cover certain
              existing facilities not covered under Phase II that withdraw cooling water above a
              certain threshold, and new offshore and coastal oil  and gas extraction facilities.
Phase II establishes performance standards and other requirements for cooling water intake

structures at large utility and nonutility power plants.  Phase III proposes similar requirements

that would be applicable to power generating facilities co-located with manufacturing facilities

(industrial nonutilities).  The Phase II regulation applies to facilities that:


       •       Meet the definition of an existing steam electric power generating facility;

       •       Use a cooling water intake structure or structures, or obtain cooling water by a
              contract or arrangement with an independent supplier who has a cooling water
              intake structure;

       •       Withdraw cooling water from waters of the U.S. and use at least 25% for contact
              or non-contact cooling purposes;

       •       Have a National Pollutant Discharge Elimination System (NPDES) permit or are
              required to obtain one; and

       •       Have a design intake flow of 50 MGD  or greater.


The section 316(b) rulemaking focuses on reducing impingement, mortality, and entrainment.

According to the Phase II rule, facilities must choose one of five alternatives for establishing the

best technology available (BTA) to minimize adverse environmental impact. The impacts of the

section 316(b) regulations on wastewater characteristics from steam electric facilities are not yet

known.  (U.S. EPA, section 316(b) Web site)
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2.3    Air Regulations


       Electric utility boilers that fire fossil fuels are subject to numerous regulations under the

Clean Air Act. These regulations include the Clean Air Interstate Rule (CAIR), Clean Air

Visibility Rule (CAVR), Clean Air Mercury Rule (CAMR), Acid Rain Program, New Source

Performance Standards (NSPS), and National Emissions Standards for Hazardous Air Pollutants

(NESHAP). The only regulations with the potential to create new wastewater streams at electric

utilities are those with SO2 emission limits.  Over time, new and revised SO2 regulations are

leading to the greater use of flue gas desulfurization systems (FGD). Wet FGD systems create a

sludge byproduct that must be de-watered for disposal. Each regulation is summarized briefly

below.
              CAIR. Published in 2005, CAIR will regulate SO2 and NOx emissions to help
              states achieve the national ambient air quality standards (NAAQS) for ozone and
              fine particulate matter. The rule permanently caps emissions (tons per year)
              across 28 eastern states and the District of Columbia. The cap for SO2 will take
              effect in 2010 with a lower cap in 2015.  States must meet the caps by
              establishing emission limits or participating in a regional cap and trade program.

              CAVR.  On June 15, 2005, EPA finalized amendments to the July 1999 regional
              haze rule. These amendments apply to the provisions of the regional haze rule that
              require emission controls known as best available retrofit technology, or BART,
              for industrial facilities emitting air pollutants that reduce visibility by causing or
              contributing to  regional haze. The pollutants that reduce visibility include fine
              particulate matter, and compounds which contribute to its formation, including
              SO2 and others. The amendments include final guidelines, known as BART
              guidelines, for states to use in determining which facilities must install  controls
              and the type of controls the facilities must use. States which adopt the CAIR cap
              and trade program for SO2 and NOx are allowed to apply CAIR controls as a
              substitute for controls required under BART because the analysis concluded that
              CAIR controls  are "better than BART" for electric generating units in the states
              subject to CAIR.

              CAMR.  Published in 2005, this rule established a national cap and trade program
              for mercury emissions from power plants. Plants will be able to meet the first
              phase cap in 2010 using the SO2 and NOx controls required to comply with
              CAIR. The second phase cap in 2018 is expected to require the use of mercury-
              specific control technologies.

              Acid Rain. The acid rain program established a national cap and  trade program
              for SO2 emissions from fossil fuel-fired power plants.  Phase I began in 1995 and

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              affected 445, mostly coal-fired electric utility plants located in 21 eastern and
              midwestern states. Phase II, which began in the year 2000, lowered the emission
              caps on the Phase I plants and also capped emissions on all units nation-wide that
              serve generating units > 25 MW fired by coal, oil, or gas.  The program also
              established emission limits for NOx.

              NSPS.  The NSPS limit SO2, particulate matter, NOx, and mercury from new,
              modified, or reconstructed electric utility boilers.  EPA proposed amendments to
              the NSPS in February. The proposed SO2 standard sets a single limit that all fuels
              must achieve regardless of the fuel sulfur content. The SO2 standard for units
              burning high sulfur coals requires approximately a 95% reduction of emissions,
              which requires FGD.  Units burning low sulfur coals can achieve the standard
              with approximately 80% reduction, which can be achieved with a spray dryer.
              Spray dryers do not generate a wastewater stream.  The NOx emission limits
              require the use of selective catalytic reduction or selective non-catalytic
              reduction.  The mercury NSPS emission limits can be met using the same
              technologies used to meet  SO2 and NOx NSPS emission limits. The particulate
              matter NSPS can be met using an electrostatic precipitator or bag house.

              NESHAP.  The NESHAP regulates hazardous air pollutant emissions from
              stationary gas turbines and reciprocating internal combustion engines.  The
              controls to meet these standards will not create wastewater streams.
2.4    Resource Conservation and Recovery Act (RCRA)


       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. This determination stated that

these wastes should not be regulated as Subtitle C wastes. Therefore, no Federal regulations

exist for solid wastes from steam electric facilities;  instead, they are managed by state solid

waste programs or specific programs for fossil fuel  combustion wastes (U.S. EPA, 1997).
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s.o    DATA SOURCES

       This section describes the data sources EPA used, to date, for its detailed study of the
Steam Electric Point Source Category.  EPA used calendar year 2002 data from three primary
data sources: the Department of Energy's Energy Information Administration (EIA), the Permit
Compliance System (PCS), and the Toxic Release Inventory (TRI).1  EPA also reviewed data
from other regulations impacting steam electric sources, and data provided by trade associations.
       The remainder of this section presents information on the following sources as they
pertain to the steam electric industry detailed study:

       •       Section 3.1 discusses EIA data;
       •       Section 3.2 discusses PCS data;
       •       Section 3.3 discusses TRI data;
       •       Section 3.4 discusses data obtained from the 2002 Economic Census;
       •       Section 3.5 discusses data obtained from records supporting EPA's section 316(b)
              Cooling Water Intake Structure Guidelines;
       •       Section 3.6 discusses data provided by the Utilities Water Act Group (UWAG);
       •       Section 3.7 discusses information obtained from the 1996 Preliminary Data
              Summary for the Steam Electric Point Source Category; and
       •       Section 3.8 discusses information obtained from EPA's Office of Enforcement
              and Compliance Assurance (OECA) Profile of the Fossil Fuel Electric Power
              Generation Industry (Sector Notebook).
'Note that the most recent TRI data available when EPA began this study was for calendar year 2002.

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3.1    Energy Information Administration

       The EIA is a statistical agency of the Department of Energy that collects information on
existing electrical generating plants and associated equipment to evaluate the current status and
potential trends in the electric power industry. EPA used information from two of EIA's data
collection forms:
             Form EIA-860, Annual Electric Generator Report (discussed in Section 3.1.1);
             and
             Form EIA-767, Steam Electric Plant Operation and Design Report (discussed in
             Section 3.1.2).
3.1.1   Form EIA-860

       Form EIA-860 collects data for all electric generating plants that have or will have a
nameplate rating of one megawatt or more, and are operating or plan to be operating within five
years of the filing of the report. The data collected in Form EIA-860 are associated only with the
design and operation of the generators at facilities. EPA used the following information from
Form EIA-860 to characterize the steam electric industry:

       •       Company Name;
       •       Facility Name;
              Plant ID (Assigned by EIA);
       •       North American Industry Classification System (NAICS) code;
       •       Generator ID;
       •       Nameplate Capacity - The maximum rated output of a generator;
       •       Prime Mover - The engine, turbine, water wheel, or similar machine that drives an
              electric generator;
       •       Energy Source - The primary source providing the power that is converted to
              electricity through chemical, mechanical, or other means;

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             Month and year of initial operation; and
             Type - A code identifying whether the parent company is a regulated or
             unregulated company.
3.1.2   Form EIA-767

       Form EIA-767 collects information annually from all U.S. plants with a total existing or
planned organic-fueled or combustible renewable steam-electric unit that has a generator
nameplate rating often megawatts or larger.  The data collected in Form EIA-767 is associated
with the operation and design of the entire facility. EPA used Form EIA-767 primarily for
information on the type of cooling system including the following data fields:
       •      Type of system;
       •      Type of towers;
       •      Flow rates; and
       •      Source water.
       One of the limitations of using data from Form EIA-767 is that the cooling system
information is required to be completed only by facilities that have a nameplate capacity larger
than 100 megawatts.  Therefore, some of the facilities that report to EIA-767 do not report any
information about cooling systems.

       EPA will review any additional or updated data from Form EIA-767 during the
development of the final 2006 ELG Plan.

3.2    Permit Compliance System

       OECA maintains PCS which is a computerized management information system,
containing information from Discharge Monitoring Reports (DMR) that facilities provide to their
permitting authority (e.g., states, regions) in accordance with their permit requirements. The
information stored in  PCS consists of the concentration and/or quantity of the parameter
discharged, as well as the flows associated with the various  discharge pipes.  Using this
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information, EPA estimated the annual pounds released for each of the reported parameters.
PCS provides information only for wastewaters discharged directly to receiving streams. The
PCS database contains information for both major and minor sources. EPA only used
information from the major sources because permitting authorities are not required to provide
DMR data to PCS for minor sources.  Consequently, data available for minor sources are limited.
To compute a Toxic-Weighted Pound Equivalent (TWPE) for each parameter reported,  the
estimated mass (in pounds) of the chemical discharged is multiplied by its toxic weighting factor
(TWF). Additional information on the calculation of TWPE and the PCS loading calculations
can be found in the 2005 Screening-Level Analysis Report.

       Chlorine, used by steam electric facilities to control the growth of microorganisms in
cooling water systems (i.e., condenser tubes, cooling towers,  etc), is reported to PCS as either
free available chlorine or total residual chlorine (TRC). Per 40 CFR 423, neither free available
chlorine nor TRC may be discharged from once-through cooling or cooling tower blowdown for
more than two hours in any one day. However, PCS may report pollutant concentrations as
either a daily maximum or average or as a 2-hour maximum or average.  In computing chlorine
releases for the detailed study, EPA assumed chlorine is discharged only 2 hours per day, and
calculated loads using this discharge period rather than the standard 24 hours per day. UWAG
stated that the amount of time a facility discharges chlorine varies from plant to plant and could
only be determined through an industry survey (see DCN 01738 in section 13.2 of the record).

       EPA determined that eight facilities discharged 93% of the TWPE for the steam electric
industry. EPA contacted these facilities to verify their discharges and revised the PCS data to
include the newly collected information.  Table 3-2 shows the facilities contacted and the
explanation of their discharges. Based on these explanations, EPA determined it was appropriate
to revise the 2002 PCS  data for these facilities.  After making the revisions, the TWPE for steam
electric facilities decreased from 22.7 million to 1.6 million.  EPA used the revised loadings for
all analyses discussed in this report. For additional information, see the 2005 Screening-Level
Analysis Report.
                                           3-4

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         Table 3-2. Steam Electric Facilities Contacted to Verify PCS 2002 Data.
Facility
AL Power Co.
(EC Gaston Plant)
Wilsonville, AL
Gulf Power Co.
Pensacola, FL
Duke Energy
South Bay
Chula Vista, CA
FPL Energy
Wyman Station
Yarmouth, ME
Progress Energy
Asheville
Arden, NC
Duke Energy
Marshall
Terrell, NC
Duke Energy
Marshall
Terrell, NC
Gulf Power Co
(Scholz Plant)
Chattahoochee, FL
Duke Energy
(Allen)
Belmont, NC
Duke Energy
(Allen)
Belmont, NC
Duke Energy
(Allen)
Belmont, NC
NPID
AL0003140
FL0002275
CA0001368
ME0000272
NC0000396
NC0004987
NC0004987
FL0002283
NC0004979
NC0004979
NC0004979
Pollutant
Arsenic
Iron
Chlorine
Mercury
Copper
Arsenic
Selenium
Iron
Cadmium
Zinc
Barium
2002 Estimated
Load
(Ibs/yr)
2,016,604
1,010,409,425
4,578,499
18,028
1,552,866
16,880
84,526
109,028,494
19,498
557,712
8,925,808
2002 Revised
Load
(Ibs/yr)
2,016
1,010,409
4,578
0.018
1,553
244
115
109,028
43
1,208
16,607
Explanation for Re-estimated
Discharge Loads1
PCS incorrectly reported the units
as mg/L rather than ng/L.
PCS incorrectly reported the units
as mg/L rather than ng/L.
PCS incorrectly reported the units
as mg/L rather than ng/L.
PCS incorrectly reported the units
as mg/L rather than ng/L.
PCS incorrectly reported the units
as mg/L rather than ng/L.
Two of the four concentrations
were reported correctly as mg/L,
while the other two were
incorrectly reported as mg/L
rather than ng/L.
One of the four concentrations
were reported correctly as mg/L,
while the other three were
incorrectly reported as mg/L
rather than ng/L.
PCS incorrectly reported the units
as mg/L rather than ng/L.
One of the two concentrations
was reported correctly as mg/L,
while the other one was
incorrectly reported as mg/L
rather than ng/L.
One of the two concentrations
was reported correctly as mg/L,
while the other one was
incorrectly reported as mg/L
rather than ng/L.
One of the two concentrations
was reported correctly as mg/L,
while the other one was
incorrectly reported as mg/L
rather than ng/L.
Discharge loads were re-estimated for use in this detailed study.
                                            3-5

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3.3    Toxic Release Inventory (TRI)

       Steam electric facilities are required to complete a TRI Form R or A if the facility meets
the following criteria:
              Facility Identification: The facility is in SIC code 4911, 4931, or 4939 and it
              combusts coal and/or oil for the purpose of generating electric power.
              Number of Employees: Facilities must have 10 or more full-time employees or
              their equivalent.  EPA defines a "full-time equivalent" as a person who works
              2,000 hours in the reporting year.
              Activity Thresholds:  Facilities must conduct an activity threshold analysis for
              every chemical and chemical category  on the current TRI list to determine
              whether it manufactures, processes, or  otherwise uses each chemical at or above
              the appropriate activity threshold.
Facilities provide an estimate of toxic chemical2 releases in pounds per year. Note that TRI does
not collect data for natural gas or nuclear powered steam electric facilities.  However, if the
facility combusts any coal or oil for the purpose of distributing electricity in commerce, the
entire facility (including the non-coal/oil combustion operations) is subject to TRI reporting
requirements.  TRI considers kerosene and petroleum coke as "oil" for reporting purposes. EPA
used the reported releases to compute a TWPE for each chemical reported for reporting year
2002. (U.S. EPA, 2000)

       Unlike PCS, chlorine is reported to TRI as chlorine (C12), not as TRC. The EPCRA
Section 313 Industry Guidance for Electricity Generating Facilities states that no releases to
water of chlorine are typically expected. At a pH above four, chlorine reacts almost completely
with water to form HOC1, Cl", and FT; therefore, no releases of C12 are expected during normal
discharge situations. However,  13 steam electric facilities reported releases of chlorine in TRI.
EPA provided information on the 13 facilities to an industry trade group, UWAG.  UWAG
believes the facilities reported incorrectly and will be submitting Form R corrections to TRI (See
DCN 01738 in section 13.2 of the record).
2Over 600 specific chemicals and chemical categories are associated with TRI reporting.
                                           3-6

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3.4    Economic Census

       The Economic Census provides a detailed portrait of the U.S. economy once every five
years.  The 2002 Economic Census covers nearly all of the U.S. economy in its basic collection
of establishment statistics, and provides the following information by NAICS code:

       •      Number of companies;
       •      Number of establishments;
       •      Number of establishments by size range, based on number of employees; and
       •      Number of employees.

       The Economic Census provides an upper limit of the number of facilities performing
operations that fall under the steam electric category, as the census may overstate the number by
including nonproduction facilities, such as distribution locations.  Also, some of the facilities
included in the census may not use a steam turbine.  For these reasons, EPA used the census data
only as a point of reference in this detailed study.

3.5    Section 316(b) Cooling Water Intake Structures

       For the section 316(b) Cooling Water Intake Structures Rulemaking, EPA conducted a
survey of steam electric utilities, steam electric nonutilities, and other manufacturing facilities
that use cooling water in the following four major manufacturing sectors: Paper and Allied
Products (SIC 26), Chemical and Allied Products (SIC 28), Petroleum and Coal Products (SIC
29), and Primary Metals (SIC 33). The survey requested the following type of information:

       •       General plant information, such as plant name, location, and SIC codes;
       •       Cooling water source and uses;
       •      Design and operational data on cooling water intake structures and cooling water
              systems;
                                          3-7

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              Studies of potential impacts from cooling water intake structures that the facility
              had performed; and
              Financial and economic information about the facility.
       Although the section 316(b) survey was used to create guidelines for cooling water intake
structures, the cooling water system information collected is useful for this review of the steam
electric industry. EPA used the information provided by the section 316(b) survey in the
following analyses:
              Linking EIA facility information to the TRI and PCS discharges;
              Identifying the type of cooling systems used by facilities; and
              Identifying industrial nonutilities.
       EPA will continue to evaluate section 316(b) information as it completes the detailed
study.

3.6    Utility Water Act Group

       UWAG is a trade association that represents the utility electricity producers.  On
February 22, 2005, EPA staff met with representatives of UWAG to discuss the detailed study
and certain data inconsistencies and gaps. UWAG indicated that they would try to provide EPA
additional information on the steam electric industry such as the following aggregated data:
              Information regarding reported chlorine and boron releases;
              Information on wastewater characteristics; and
              Information regarding current technologies used by the industry.
Information provided by UWAG to EPA as of June 27, 2005 has been included in this report,
where appropriate. For more information regarding specific information that has been provided
to EPA, see Docket ID No. OW-2004-0032.
                                           3-8

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3.7    1996 Preliminary Data Summary for the Steam Electric Point Source Category
       (PDS)

       The 1996 Preliminary Data Summary (PDS) was conducted to provide technical support
for possible revision of the 1982 steam electric effluent limitations guidelines and standards.
The 1996 PDS contained information about the process descriptions and the pollutants released
in each of the different types of waste streams. EPA used the 1996 PDS as a guide for the type
of information that would be useful to collect for the industry profile and wastewater
characteristic sections of the detailed study report.  Because the 1996 PDS noted changes that
were starting to occur in the industry, it can be used as a point of comparison to the results of this
detailed study.

3.8    OECA Sector Notebook

       The OECA Sector Notebook, Profile of the Fossil Fuel Electric Power Generation
Industry, contains the following information:

       •       Industry profile using 1995 data;
       •       Industrial  process descriptions;
       •       Chemical  releases and transfers;
       •       Pollution prevention opportunities; and
       •       Regulatory summary.

EPA supplemented data from EIA, PCS, and TRI with background information from the Sector
Notebook (U.S. EPA, 1997).
                                          3-9

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4.0    INDUSTRY PROFILE

       This section describes the steam electric industry in greater detail and is divided into the
following sections:

       •      Section 4.1 discusses the different types of steam electric facilities;
       •      Section 4.2 presents an overview of the steam cycle for electricity generation and
              discusses the waste streams generated; and
       •      Section 4.3 discusses the demographics of the industry using data from EIA.

4.1    Facility Types

       Electric power plants may use various prime movers to generate electricity. DOE's EIA
defines prime mover as the engine, turbine, water wheel, or similar machine that drives an
electric generator; or, a device that converts energy to electricity directly (e.g., photovoltaic solar
and fuel cell(s)) (U.S. DOE EIA Web site). The primary types of prime movers are steam
turbines, gas turbines, internal combustion engines, combined-cycle turbines, hydraulic turbines,
and others.

       Steam electric facilities use a steam/water system as the thermodynamic medium to drive
a turbine. An energy source is required to produce heat for the boiler which generates the steam.
The current applicability of Part 423 covers facilities that use fossil-type fuel (coal, oil, or gas) or
nuclear fuel to produce the steam. However, other fuel sources such as municipal solid wastes or
wood wastes (biomass) may also be used to produce the steam.  For this preliminary report, EPA
focused on facilities that meet the definition of steam electric under Part 423.  A brief discussion
of steam facilities using alternate fuel sources is included in Section 4.3.5. EPA will investigate
these facilities further during the development of the 2006 Effluent Guidelines Program Plan.

       Some electricity generators use combined-cycle units to produce electricity.  These units
use steam turbine technology  to increase the efficiency of the primary gas turbine.  Hot gases
                                           4-1

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from the turbines are transported to a waste heat recovery boiler to generate steam for a second

turbine.


       For the purposes of this detailed study, EPA divided the steam electric industry into the

three facility types:
       1.     Utility: A corporation, person, agency, authority, or other legal entity or
              instrumentality that owns and/or operates facilities for the generation,
              transmission, distribution, or sale of electric energy for use primarily by the
              public. Utilities provide electricity within a designated franchised service area and
              file forms listed in 18 CFR Part 141. Per EIA, facilities that qualify as
              cogenerators or small power producers under the Public Utility Regulatory
              Policies Act are not considered electric utilities.

       2.     Nonindustrial nonutility:  A corporation, person, agency, authority, or other legal
              entity or instrumentality that owns electric generating capacity and is not an
              electric utility. Nonutility power producers include qualifying cogenerators,
              qualifying small power producers, and other nonutility generators (including
              independent power producers) without a designated franchised service area, and
              which do not file forms listed in 18 CFR Part 141.

       3.     Industrial nonutility: Industrial nonutilities are similar to nonindustrial nonutilities
              except their primary purpose is not the distribution and sale of electricity. This
              category includes electric generators that are co-located with other manufacturing
              activities such as chemical manufacturing or pulp making.
In general, utilities and nonindustrial nonutilities are categorized by three SIC codes:
              4911:  Electric Services - Establishments engaged in the generation,
                     transmission, and/or distribution of energy for sale.

              4931:  Electric and other services combined - Establishments primarily engaged
                     in providing electric services in combination with other services when the
                     electric services are the major part of the services, but are less than 95% of
                     the total services.

              4939:  Combination utilities, not elsewhere classified - Establishments primarily
                     engaged in providing combinations of electric, gas, and other services, not
                     elsewhere classified.
                                            4-2

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NAICS codes have replaced SIC codes. The U.S. Census Bureau provides tables showing the
correspondence between NAICS and SIC codes. SIC codes 4911, 4931, and 4939 all fall under
NAICS code 22, Utilities.  The NAICS definition of utilities includes establishments providing
the following utility services: electric power, natural gas, steam supply, water supply, and
sewage removal. Within this sector, the specific activities associated with the utility services
provided vary by establishment.  Services that electric power establishments may provide
include generation, transmission, and distribution.  NAICS  code 22 is further subdivided into the
following codes that apply to steam electric facilities:
       •      221112 - Fossil Fuel Electric Power Generation;
       •      221113 - Nuclear Electric Power Generation; and
       •      221119 - Other Electric Power Generation.
Utilities and nonindustrial nonutilities typically report to EIA under NAICS code 22.  The 2002
Economic Census data uses the more detailed six-digit NAICS code.

       Industrial nonutilities are not categorized in the above SIC and NAICS codes since their
primary purpose is not the distribution and sale of electricity. EPA used the reported SIC and
NAICS codes to identify industrial nonutilities. Section 4.3 discusses the identification of steam
electric facilities in greater detail.

4.2    Process Description and Wastewater Sources

       Steam electric facilities consist of a steam generator (boiler), a steam turbine, and a
condenser. The following description of the steam process reflects facilities using fossil fuel.
Fossil fuels are conveyed into a boiler where they are combusted to generate steam. Boilers may
have superheaters, reheaters, economizers, and air heaters to improve efficiency. The high
temperature, high pressure steam leaves the boiler and enters the turbine generator. As it moves
from the high pressure boiler to the low pressure condenser the steam drives the turbine blades.
During the process, the steam expands, and the now low pressure steam enters the condenser,
where it is condensed by the cooling water flowing through condenser tubes. The condensate
travels back to the boiler where it is reheated for use in the turbine. Figure 4-1  shows a diagram

                                           4-3

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of the steam electric cycle. Table 4-1 lists the wastewater streams produced by the steam electric
cycle.

       A constant flow of cooling water is required to keep the condenser shell at the proper
pressure. The cooling water is warmed during the condensation process. Facilities use either a
once-through or recirculating cooling water system. In once-through cooling water systems, the
cooling water is withdrawn from the source water, flows through the condenser, and is
discharged back to the source water. In a recirculating system, the warmed cooling water is
cooled in cooling towers or cooling ponds and then recirculated to the condenser.  Recirculating
systems require only about 5% of the water that once-through systems use. In recirculating
systems, a small amount of water must be discharged periodically to control the build-up of
solids; then make-up water is added to the system.

       In both once-through and recirculating systems, chemicals may be added to prevent
scaling and biofouling. Chlorination is the most widely used method of biofouling control,
although some facilities use bromine. EPA does not have information on the types and amounts
of chemicals used at steam electric facilities.  According to information from UWAG, if facilities
report discharges  of total residual oxidants, rather than total residual chlorine, the facility is
likely using  bromine. Facilities  using bromine must still use some chlorine to activate the
bromine. UWAG also stated that the steam electric industry is trying to optimize the amount of
chemicals added and the timing  of the addition to reduce costs (see DCN 01738 in section 13.2
of the record).
                                           4-4

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       Two types of ash are produced during the combustion of fossil fuels, bottom ash and fly
ash.  Bottom ash collects at the bottom of the boiler. Fly ash, which is finer than bottom ash, is
transferred by the flue gas to the end of the boiler where it is collected in the economizer, air
heater, or particulate control equipment. Fly ash and bottom ash may be managed separately or
together in landfills or in wet surface impoundments. While natural gas plants generally do not
require ash handling facilities, coal-fired facilities generate the largest quantities of ash and
usually require ash handling facilities. The ash content will depend on the type of coal burned,
how it was prepared before burning, and the  operating conditions of the boiler. According to the
OECA Sector Notebook (U.S. EPA, 1997), more than 95% of the ash consists of silicon,
aluminum, iron, calcium, magnesium, potassium, sodium, and titanium.  Trace constituents
include antimony, arsenic,  barium, cadmium, chromium, lead, mercury, selenium,  strontium,
zinc, and other metals.

       Another source of wastewater from steam electric facilities is coal pile runoff. Rainwater
can dissolve inorganic salts in coal and carry the pollutants into the runoff. Other sources of
wastewater include water treatment discharges, boiler blowdown, maintenance cleaning, and wet
air pollution control devices (flue gas desulfurization) (U.S. EPA, 1997).

              Table 4-1.  Wastewater Streams from Steam Electric Facilities
Process
Cooling Water
Ash Handling
Coal Pile Runoff
Wastewater
Chlorine, iron, copper, nickel, chlorinated organic compounds, temperature,
suspended solids
Generally: SiO2, A12O3, Fe3O3, CaO, MgO, TiO2, SO3, P2O3, and carbon residuals
Possibly: TDS, TSS, sulfate, calcium, chloride, magnesium, nitrate, antimony,
arsenic, cadmium, chromium, copper, cyanide, iron, lead, mercury, nickel,
selenium, silver, thallium, vanadium, and zinc (may cause turbidity)
Generally: Acidity, COD, calcium, magnesium, iron, aluminum, manganese,
silica, chloride, sulfate, TD, TSS, arsenic, chromium, copper, nickel, vanadium,
and zinc
Possibly: antimony, cadmium, beryllium, lead, selenium, thallium, mercury, and
silver
                                          4-6

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                                  Table 4-1 (Continued)
Process
Water Treatment
Boiler Blowdown
Flue Gas Desulfurization
Waste from Wet Scrubbers
Maintenance Cleaning
Miscellaneous
Wastestreams
Wastewater
Clarification: aluminum sulfate, sodium aluminate, ferrous sulfate, ferrous
chloride, and calcium carbonate
Filtration: suspended solids
Ion Exchange: calcium and magnesium salts, iron, copper, zinc, aluminum,
manganese, potassium, soluble sodium, chlorides, sulfates, organics, sulfuric acid,
and sodium hydroxide
Evaporation: salts (type depends on intake water characteristics)
Softening: calcium carbonate, magnesium hydroxide, and sodium salts
Chlorides, sulfates, metals, precipitated solids containing calcium and magnesium
salts, soluble and insoluble corrosion products, and chemical additives
A slurry of ash, unreacted lime, calcium sulfate, and calcium sulfite.
Oil, grease, phosphates, nitrites, suspended solids, dissolved solids, iron, nickel,
chromium, vanadium, zinc, magnesium salts, polynuclear hydrocarbons, acidity,
alkalinity, and oil
Suspended solids, dissolved solids, oil and grease, phosphates, surfactants,
acidity, methylene chloride, phthalates, BOD5, COD, fecal conform, and nitrates
Source: Preliminary Study of the Steam Electric Point Source Category, 1996 and OECA Sector Notebook, 1997.


4.3    Industry Demographics


       EPA performed a preliminary analysis of the demographic information for the year 2002

collected by EIA.


       This section is divided into the following subsections:
              Section 4.3.1 discusses the overall industry;
              Section 4.3.2 discusses utilities;
              Section 4.3.3 discusses nonindustrial nonutilities;
              Section 4.3.4 discusses industrial nonutilities; and
              Section 4.3.5 discusses additional fuel types.
                                            4-7

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4.3.1   Overall Steam Electric Industry

       As stated previously, the steam electric industry comprises facilities that generate
electricity using a steam cycle.  Part 423 regulates steam facilities that use fossil fuel or nuclear
fuel as their energy source. For the purpose of this preliminary report, EPA refers to facilities
using fossil or nuclear fuel to produce electricity through a steam-cycle as 'steam electric'
facilities.  Facilities may be using other sources  of energy to generate steam. Section 4.3.5
provides a brief discussion of these facilities.  EPA will investigate these facilities further during
the development of the 2006 Effluent Guidelines Program Plan.

       EPA reviewed data from PCS, TRI, and EIA to characterize the steam electric industry.
This section describes the facilities included in each data source. EIA provided information on
facility type, capacity, and fuel type while PCS and TRI provided information on wastewater
characteristics.

       EPA extracted all PCS data from major sources in SIC 4911,  SIC 4931, and SIC 4939 for
the preliminary detailed study. In the PCS database, 882 facilities report one of these SIC codes.
Of the 882 facilities,  554  are major dischargers and 328 are minor dischargers. The analyses in
this report use PCS data from the 554 major facilities.  Table 4-2 shows the distribution of the
PCS facilities by SIC code.
                  Table 4-2. Distribution of PCS Facilities by SIC Code
SIC Code
4911
4931
4939
Total
Major
Dischargers
545
9
0
554
Minor
Dischargers
266
42
20
328
Total
811
51
20
882
EPA also extracted TRI data from all facilities in SIC 4911, 4931, and 4939. Of the 692
facilities that report one of these SIC codes in the TRI database, only 376 report wastewater
                                           4-8

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discharges of reportable toxic chemicals, and one facility reports wastewater discharge in SIC
Code 4939.  Because this facility has only one discharge of 1.7 pounds of barium, resulting in a
TWPE of 0.003, EPA did not use this facility's data in this analysis.  Table 4-3 shows the
distribution of the TRI facilities by SIC code. EPA linked the PCS and TRI data to information
from EIA to classify each facility type. Section 5.0 discusses the use of the PCS and TRI data in
greater detail.
                  Table 4-3. Distribution of TRI Facilities by SIC Code
SIC
4911
4931
4939
Total
Total
639
45
8
692
No Reported
Water Discharge
289
20
7
316
Direct Discharge
320
19
1
340
Indirect
Discharge
12
3
0
15
Both Direct and
Indirect Discharge
18
o
J
0
21
       Since Form EIA-860 contained the most detailed information on facility type, energy
source, and capacity, EPA used data from EIA to develop a preliminary demographic profile of
the industry. Form EIA-860 contains records for 16,413 generators from 5,137 facilities for
calendar year 2002. However, these records include data from all facilities that produce
electricity, not specifically steam electric facilities. EPA included just the facilities that used a
steam turbine as the prime mover in the steam electric detailed study.  For this preliminary
report, EPA included the following prime movers from Form EIA-860:

       •      ST - Steam Turbine;
       •      CA - Combined Cycle Steam Part; and
       •      CS - Combined Cycle Single Shaft (combustion turbine and steam turbine share a
              single generator).

As mentioned in Section 2.1, Region IV determined that the steam electric effluent guidelines in
40 CFR 423 are applicable to the steam electric unit of a combined cycle generating plant
because the steam electric portion of the combined cycle uses fossil-type fuel in conjunction with
                                           4-9

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a thermal cycle. Therefore, EPA included data for the prime movers reported as "combined
cycle steam part" in this study.

       Based on the current applicability of 40 CFR 423, EPA included facilities using only
fossil or nuclear fuel in this initial analysis:

       •      BIT - Anthracite Coal, Bituminous Coal;
       •      LIG - Lignite Coal;
       •      SUB - Subbituminous Coal;
             WC - Waste/Other Coal;
             DFO - Distillate Fuel Oil;
             JF - Jet Fuel;
       •      KER - Kerosene;
             RFC - Residual Fuel Oil;
             WO - Oil-Other and Waste Oil, Crude Oil, Liquid Byproducts, Oil Waste,
             Propane (Liquid), Re-Refined Motor Oil, Sludge Oil, Tar Oil);
       •      NG - Natural Gas; and
       •      NUC - Nuclear (Uranium, Plutonium, Thorium).

       Figure 4-2 shows the distribution of the energy sources used in the steam electric
industry. The figure shows that most of the electricity produced by the steam electric facilities is
provided by coal and natural gas. For 2002, Form EIA-860 reporting shows 1,450 steam electric
facilities with a total electric capacity of 631,635 Megawatts.
                                          4-10

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                                                            Total Steam Electric Capacity:
                                                                631,635 Megawatts
                                                                         Source: El A, 2002
     Figure 4-2. Distribution of Electricity Production in the Steam Electric Industry,
                                           2002
       EIA uses the terms "regulated" and "unregulated" entities to correspond to utilities and
nonutilities. Regulated entities sell electricity to the public while unregulated entities do not
have a designated franchised service area. According to information obtained from EIA, the
"type" field reported on Form EIA-860 can be used to separate utilities (regulated) from
nonutilities (unregulated). However, some unregulated facilities may be run by regulated
utilities, and vice-versa.

       EIA reports facilities by NAICS code rather than SIC code. Utilities and nonindustrial
nonutilities are reported under NAICS code 22, while industrial nonutilities are reported under
the NAICS code for their primary industry. EPA used the NAICS code along with the regulated
status to determine the number of facilities, number of generating units, and total capacity for
each type of facility, shown in Table 4-4.
                                           4-11

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    Table 4-4.  Number of Steam Electric Facilities, Generating Units, and Capacity, by
                              Facility Type Reported to EIA
Facility Type
Utilities
Nonindustrial nonutilities
Industrial nonutilities
Total
Number of Facilities
662
480
308
1,450
Number of Generating Units
1,721
857
676
3,254
Total Capacity (MW)
416,361
204,614
10,660
631,635
4.3.2   Utilities

       Utilities provide approximately 66 percent (416,361 Megawatts) of the electricity
produced by steam electric facilities.  Table 4-5 presents the capacity, number of steam electric
facilities, and number of steam electric generating units according to plant capacity. Note that
facilities may have multiple generating units.

                 Table 4-5.  Distribution of Steam Electric Utilities by Size
Plant Capacity
Total Utility
Capacity (MW)
Percent of Utility
Capacity
Number of
Utility Facilities
Percent of Utility
Facilities
Number of
Utility
Generating Units
Percent of Utility
Generating Units
0-50
MW
2,887
1%
109
16%
203
12%
50-100
MW
5,249
1%
70
11%
153
9%
100-200
MW
12,511
3%
85
13%
203
12%
200-300
MW
12,826
3%
52
8%
129
7%
300-400
MW
14,527
3%
41
6%
124
7%
400-500
MW
18,855
5%
42
6%
112
7%
>500
MW
349,506
84%
263
40%
797
46%
Total
416,361
100%
662
100%
1,721
100%
The data in Table 4-5 show that the majority of the utilities, generating units, and capacity is
from the largest size group (>500 megawatts). EPA also divided the utility group by primary
energy source as shown in Figure 4-3. The majority of utility capacity is provided by coal.
                                           4-12

-------
   300
g" 250
          0
                    63%
                                                         Total Existing Capacity:
                                                           416,361 Megawatts
                   Coal
                              Natural Gas
Nuclear
Oil
              Figure 4-3. Distribution of Utility Capacity by Energy Source

Figure 4-4 presents a timeline of cumulative capacity for the utilities reported on the 2002 EIA
forms. The graph shows the cumulative steam electric capacity based on initial year of
operation. While the coal-fired capacity increased rapidly in the 1970s, the utility capacity has
leveled off in recent years.
                                         4-13

-------
       300
                                                                       I Coal
                                                                       I Natural Gas
                                                                       I Nuclear
                                                                       I Oil
             Through Through Through Through Through Through
               1950     1960    1970     1980    1990    2002
                                  Time Period
                     Figure 4-4. Capacity of Utilities by Fuel Type
4.3.3   Nonindustrial Nonutilities

       Nonindustrial nonutilities provide 32% of the total steam electric capacity.  Table 4-6 and
Figures 4-5 and 4-6 present the nonindustrial nonutility distributions in the same manner as the
utilities. Like utilities, most of the capacity is from large (>500 MW) facilities; however,
nonindustrial nonutilities have a greater percentage of facilities and generating units in the
smaller size ranges than utilities.
                                         4-14

-------
        Table 4-6.  Distribution of Steam Electric Nonindustrial Nonutilities by Size

Plant Capacity
Total
Nonindustrial
Nonutility
Capacity (MW)
Percent of
Nonindustrial
Nonutility
Capacity
Number of
Nonindustrial
Nonutility
Facilities
Percent of
Nonindustrial
Nonutility
Facilities
Number of
Nonindustrial
Nonutility
Generating Units
Percent of
Nonindustrial
Nonutility
Generating Units
0-50
MW
2,835



1%



118



25%



144



17%



50-100
MW
4,210



2%



57



12%



64



7%



100-200
MW
9,868



5%



68



14%



98



11%



200-300
MW
12,655



6%



52



11%



76



9%



300-400
MW
12,532



6%



36



8%



67



8%



400-500
MW
8,332



4%



19



4%



45



5%



>500
MW
154,181



75%



130



27%



363



42%




Total
204,613



100%



480



100%



857



100%



Nonindustrial nonutilities also have a larger percentage of capacity than natural gas-fired
generating units. The overall capacity from natural gas for utilities and nonutilities is similar
(70,800 megawatts for utilities and 75,700 megawatts for nonindustrial nonutilities).
                                          4-15

-------
                                              Total Existing Capacity
                                                204,613 Megawatts
              Coal
Natural Gas
Nuclear
Oil
Figure 4-5. Distribution of Nonindustrial Nonutility Capacity by Energy Source
                                                         • Coal
                                                         ^Natural Gas
                                                         M Nuclear
           Through Through Through Through Through Through
            1950   1960    1970   1980    1990   2002
                           Time Period
       Figure 4-6. Capacity of Nonindustrial Nonutilities by Fuel Type
                                 4-16

-------
Figure 4-5 shows that coal-fired nonindustrial nonutility capacity increased through the 1960s
and 1970s. Nonindustrial nonutilities also saw a large increase in natural gas capacity during the
1990s.

4.3.4   Industrial Nonutilities

       The industrial nonutility group contains facilities reporting NAICS codes other than 22,
Utilities. These facilities are not currently regulated under 40 CFR 423.  According to
information provided in the 1996 Preliminary Data Summary for the Steam Electric Point
Source Category, permits for the effluent wastestreams of an electric power generating unit
which exists as an ancillary unit of a plant falling under an effluent guideline other than Part 423
are normally written by best professional judgement (BPJ) using Part 423 regulations for similar
wastestreams.  Table 4-7  lists the industries, the number of facilities represented, and the total
capacity for steam electric industrial nonutilities using fossil or nuclear fuel as reported to EIA.
             Table 4-7.  Distribution of Industrial Nonutilities by NAICS Code
NAICS Code
322
325
311
611
324
331
211
622
92
314
327
336
3122
NAICS Title
Paper Manufacturing
Chemical Manufacturing
Food Manufacturing
Educational Services
Petroleum and Coal Products
Manufacturing
Primary Metal Manufacturing
Oil and Gas Extraction
Hospitals
Public Administration
Textile Product Mills
Nonmetallic Mineral Product
Manufacturing
Transportation Equipment
Manufacturing
Tobacco Manufacturing
Number of Facilities
82
58
44
33
20
12
10
9
5
5
2
3
3
Total Capacity (MW)
2,968
3,147
1,001
456
743
1,158
34
60
57
84
77
93
101
                                           4-17

-------
                                  Table 4-7 (Continued)
NAICS Code
321
333
22132
326
332
481
482
514
521
561
624
814
212
2212
3345
4911
562212
Total
NAICS Title
Wood Product Manufacturing
Machinery Manufacturing
Sewage Treatment Facilities
Plastics and Rubber Products
Manufacturing
Fabricated Metal Product
Manufacturing
Air Transportation
Rail Transportation
Information Services and Data
Processing
Monetary Authorities
Administrative and Support
Services
Social Assistance
Private Households
Mining
Natural Gas Distribution
Navigational, Measuring,
Electromedical, and Control
Instruments Manufacturing
Postal Service
Solid Waste Landfill

Number of Facilities
2
2
2
1
1
1
1
1
1
1
1
1
2
1
1
1
1
308
Total Capacity (MW)
9
24
112
40
10
8
4
0.7
12
2
2
6
66
o
J
205
178
1
10,660
       Table 4-8 and Figures 4-7 and 4-8 present the distribution information for industrial
nonutilities. Table 4-8 shows that industrial nonutilities are much smaller in size than utilities
and nonindustrial nonutilities, which is expected since the steam electric generator is ancillary to
other manufacturing activities.  Industrial nonutilities have a fairly small overall capacity
(10,660 MW). The capacity is fairly equally distributed between coal and natural gas fired
generating units.
                                           4-18

-------
  Table 4-8.  Distribution of Steam Electric Industrial Nonutilities by Size
Plant Capacity
Total Industrial
Nonutility Capacity
(MW)
Percent of Industrial
Nonutility Capacity
Number of Industrial
Nonutility Facilities
Percent of Industrial
Nonutility Facilities
Number of Industrial
Nonutility
Generating Units
Percent of Industrial
Nonutility
Generating Units
0-50
MW
3,257
31%
242
79%
453
67%
50-100
MW
2,950
28%
42
14%
124
18%
100-200
MW
2,145
20%
16
5%
59
9%
200-300
MW
1,195
11%
5
2%
29
4%
300-400
MW
688
6%
2
1%
4
1%
400-500
MW
425
4%
1
0%
7
1%
>500
MW
0
0%
0
0%
0
0%
Total
10,660
100%
308
100%
676
100%
                                                Total Existing Capacity
                                                   10,660 Megawatts
            Coal
Natural Gas
Nuclear
Oil
Figure 4-7. Distribution of Industrial Nonutility Capacity by Energy Source
                                  4-19

-------
                                                                   gCoal
                                                                   ^Natural Gas
       o
                Through Through Through Through Through Through
                 1950    1960    1970    1980    1990    2002
                                  Time Period
              Figure 4-8. Capacity of Industrial Nonutilities by Fuel Source
4.3.5   Other Fuel Sources


       Some facilities that produce electricity using a steam cycle may be using a renewable fuel

rather than fossil or nuclear fuel.  EPA has not reviewed wastewater characteristics for these

facilities, to date. This section provides demographic information for these facilities.


       Facilities reported using the following fuel types with steam cycles in EIA:
             AB - Agricultural Crop;
             MSW - Municipal Solid Waste;
             OBS - Other Biomass Solid;
             TDF - Tire-derived Fuels;
             WDS - Wood/Wood Waste Solids;
             BLQ - Black Liquor;
             WDL - Wood Waste Liquids;
             LFG - Landfill Gas;
             GEO - Geothermal;
                                         4-20

-------
             PC - Petroleum Coke;
             OG - Other Gas;
             BFG - Blast Furnace Gas;
             PUR - Purchased Steam;
             OBG - Other Biomass Gas;
             SUN - Solar; and
             OTH - Other.
Table 4-9 lists the number of facilities, number of generating units, and total capacity for the

renewable fuels.
 Table 4-9. Summary of EIA Data for Other Fuel Sources for All Steam Electric Facilities
                                Reporting to EIA 2002
Facility Type
Steam Cycle - BLQ
Steam Cycle - GEO
Steam Cycle - MSW
Steam Cycle - WDS
Steam Cycle - PC
Steam Cycle - OG
Steam Cycle - BFG
Steam Cycle - OTH
Steam Cycle - SUN
Steam Cycle - AB
Steam Cycle - LFG
Steam Cycle - PUR
Steam Cycle - TDF
Steam Cycle - WDL
Steam Cycle - OBS
Steam Cycle - OBG
Number of Facilities
66
45
81
117
16
24
9
20
9
13
11
4
2
2
2
1
Number of Generating Units
157
200
105
161
19
54
29
29
9
27
12
9
2
3
2
1
Total Capacity (MW)
3,688
2,987
2,900
2,701
1,043
837
826
673
410
345
212
58
57
35
25
18
                                        4-21

-------
s.o    WASTEWATER CHARACTERIZATION

       EPA analyzed the wastewater discharges by the type of facility reporting (utility,
nonindustrial nonutility, or industrial nonutility). In order to classify the PCS and TRI data by
facility type, EPA linked the PCS and TRI databases to the EIA database.  Each of these primary
data sources uses unique identification numbers for facilities. EPA linked the PCS and TRI data
for each facility using EPA's Facility Registration System (FRS).  FRS provides a unique
identification number for facilities and contains relevant information about the facility such as
name, address, owners, and permits held. Both PCS and TRI identification numbers are included
in the FRS system.  EPA linked the PCS and TRI information to the EIA data using information
from EPA's section 316(b) cooling water intake structure regulation development, and also by
matching zip codes and other facility identification information. EPA created a master table that
lists the FRS ID, TRI ID, NDPES number, and EIA ID. This master table allowed information
from each data source to be consolidated by facility. See Docket ID No. OW-2004-0032 for
additional information.

       Table 5-1 shows the number of facilities that are in the  TRI and PCS databases that report
to the SIC codes applicable to the steam electric industry, the number of facilities linked to the
EIA database, and the percent of the TWPE that is represented by the linked facilities. EPA was
not able to categorize all the facilities listed in the table below  as utilities or nonutilities due to
incomplete  information in EIA. For example, EIA does not contain information for facilities in
Puerto Rico and the Virgin Islands and some facility information was incomplete. However,  the
analysis of wastewater characteristics presented in this section represents 96% of the PCS TWPE
and 95% of the TRI TWPE.
                                          5-1

-------
    Table 5-1. Number of Facilities in the PCS and TRI Databases Matched to the EIA
                                         Database
Database
PCS
TRI
Number of
Facilities
Reporting
554 (major
dischargers)
375
Number of
Matched
Utilities
327
235
Number of Matched
Nonindustrial
Nonutilities
163
103
Total Number
of Matched
Facilities
490
338
Percent of
TWPE
Represented
96
95
       The remainder of this section presents the wastewater characteristics for the following
types of steam electric facilities:
              Section 5.1 discusses utilities;
              Section 5.2 discusses non-industrial nonutilities; and
              Section 5.3 discusses industrial nonutilities.
5.1    Utilities


       This section summarizes the wastewater characteristics for utilities. Section 5.1.1

discusses the PCS data and 5.1.2 discusses the TRI data.


5.1.1   PCS


       EPA analyzed data from PCS to identify pollutants discharged from steam electric

utilities.  Of the 554 major facilities reporting to PCS, 327 are utilities. Table 5-2 presents the

top pollutants discharged based on TWPE, along with the number of facilities reporting the

pollutant. The top five pollutants reported are:
       1.      Copper: Copper may be present in cooling water biocides or coal pile runoff.

       2.      Arsenic: Coal pile runoff and ash handling wastes are the most likely source of
              arsenic since arsenic is naturally occurring in coal. All but 1 of the 44 facilities
              that report arsenic discharges are coal facilities. Arsenic discharges are reported
              by facilities in only 14 states, and 29 of the 44 facilities reporting arsenic
                                            5-2

-------
        discharges are in Region IV. Facilities in North Carolina account for 12% of the
        arsenic TWPE.

        Chlorine: Chlorine is used as a biocide and is most likely discharged from cooling
        water streams.  Chlorine is a constituent of coal and therefore may also be present
        in other wastestreams such as coal pile runoff, ash handling streams, and scrubber
        wastes. Chlorine reported in PCS refers to TRC and not C12.

        Boron:  Boron is not regulated by 40 CFR 423  so few facilities report boron
        discharges. Of the 11 facilities that reported boron discharges, 6 use coal as an
        energy  source and 5 use nuclear as an energy source. One facility  accounts for
        67% of the boron discharged, and the top five boron dischargers account for 98%.
        EPA does not currently have information on potential sources of boron in the
        wastewater; however,  UWAG has performed an initial investigation regarding
        the release of boron and will be submitting a summary memorandum to EPA on
        the sources of this pollutant (see DCN 01739 in section 13.2 of the record).

        Aluminum: Aluminum is typically used as a treatment chemical in chemical
        precipitation/clarification systems although the potential source in steam electric
        discharges is not apparent from the PCS data.
Table 5-2.  The Top Pollutants Released From 327 Utilities in the PCS Database
Pollutant
Copper
Arsenic
Chlorine (based on discharging 2 hrs/day)
Boron
Aluminum
Silver
Selenium
Iron
Cadmium
Fluoride
Lead
Mercury
Zinc
Nitrogen, Nitrate Total (as N)
Nickel
Nitrite plus Nitrate Total 1 Det. (as N)
Number of
Facilities Reporting
Pollutant
121
44
136
11
21
6
50
88
22
7
26
25
69
5
25
11
Total Pounds
Estimated to
be Discharged
318,312
47,443
364,978
920,836
1,609,747
5,090
28,229
4,442,293
744
412,707
6,216
97
159,696
807,041
23,422
342,762
Total
TWPE
202,071
191,732
185,833
163,186
104,136
83,836
31,655
24,877
17,209
14,445
13,923
11,360
7,488
4,519
2,551
1,919
Percent of
Total
TWPE
19%
18%
17%
15%
10%
7.9%
3.0%
2.3%
1.6%
1.4%
1.3%
1.1%
0.7%
0.42%
0.24%
0.18%
                                    5-3

-------
                                  Table 5-2 (Continued)
Pollutant
Manganese
Chromium, Hexavalent
Total
Number of
Facilities Reporting
Pollutant
15
6
327
Total Pounds
Estimated to
be Discharged
76,926
2,051
9,568,590
Total
TWPE
1,110
1,060
1,067,569
Percent of
Total
TWPE
0.10%
0.10%
99.6%
Note: Includes only pollutants that have a TWF. Does not include conventional pollutants like BOD5 and TSS.

       In addition to the pollutants listed in Table 5-2, steam electric plants discharge other
pollutants, such as the conventional pollutants, that do not have a toxic weighting factor (TWF).
EPA could not calculate TWPE for these pollutants.  As shown in Table 5-3, utilities discharge
large masses of these pollutants.

 Table 5-3. Pollutants Without TWFs Discharged From 327 Utilities in the PCS Database
PoDutant
Total Suspended Solids
BOD5
Oil & Grease
Total Residual Oxidants*
Number of Facilities
Reporting Pollutant
294
94
280
49
Total Pounds Estimated to be
Discharged
375,870,357
7,611,588
4,886,983
729,338
* According to UWAG, total residual oxidants indicates use of bromine biocides (see DCN 01738 in section 13.2 of
the record).

       Analysis of Pollutants Discharged by Energy Source

       EPA further investigated the pollutant discharges reported in PCS by the energy source
reported in the EIA database.  Table 5-4 shows the number of facilities, the combined capacity,
and the TWPE associated with the reported discharges by energy source.  Table 5-4 was created
using information from the 327 PCS steam electric utilities.  Since facilities may report two or
more energy sources, the total number of facilities reported in Table 5-4 is greater than 327.
                                            5-4

-------
       Table 5-4. PCS Discharges From 327 Utilities Distributed by Energy Source
Category
Coal
Natural Gas
Nuclear
Oil
Number of
Facilities
231
71
38
30
Energy Source
Capacity (MW)
200,650
45,324
56,993
13,262
MW/Facility
869
638
1,500
442
TWP1
(tox-lb/yr)
853,828
72,864
120,125
20,753
TWPE/Facility
3,696
1,026
3,161
692
TWPE/MW
4.26
1.61
2.11
1.56
       For facilities that reported using two or more energy sources, EPA distributed the TWPE
to each energy source based on the percentage of capacity from each energy source. For
example, if 25% of a facility's capacity is from coal and 75% is from natural gas, and the facility
reported releasing 4,000 pounds of chlorine, then EPA assumed 1,000 pounds are associated
with coal and 3,000 pounds are associated with natural gas operations.  Although some
pollutants, especially metals, are more likely to result from the use of certain fuels (e.g.,  coal),
this approximation allowed EPA to evaluate whether certain energy sources contributed  the bulk
of the pollutant loads. Table 5-4 shows that the majority of the utility TWPE is discharged by
coal facilities. Coal facilities account for 65% of the steam electric utility capacity, but 80% of
the TWPE discharged.  Compared to the  other fuel types, coal facilities have additional waste
streams from coal pile runoff and ash handling that add to the loadings for this energy source.

       Table 5-4 also shows TWPE per megawatt, TWPE per facility,  and megawatt per facility
calculated by EPA.  The table shows that coal facilities have the highest TWPE per megawatt,
discharging more than 2.5 times as much as natural gas and oil facilities, and twice as much as
nuclear facilities per megawatt.

       Table 5-5 shows the top five pollutants and their TWPE released from each energy
source and the total TWPE.  Similar pollutants are ranked in the top five for each energy source.
Coal has the highest levels of arsenic compounds, likely due to coal pile runoff or ash handling
since arsenic is naturally occurring in coal. As mentioned previously, cooling water is a
potential source of chlorine.  Copper may be found in cooling water, ash handling, coal pile
runoff, or the low volume wastestreams.
                                           5-5

-------
             Table 5-5.  Top Five Pollutants From 327 Utilities by Fuel Source
Rank
1
2
3
4
5

Coal
Pollutant
Arsenic
Chlorine
Copper
Boron
Aluminum
Total
TWPI
177,205
137,480
130,357
128,690
84,630
853,828
Natural Gas
Pollutant
Copper
Chlorine
Arsenic
Lead
Mercury
Total
TWPE
30,439
24,204
11,866
1,610
1,529
72,864
Nuclear
Pollutant
Copper
Boron
Aluminum
Iron
Chlorine
Total
TWPI
37,824
34,492
19,507
13,202
12,499
120,125
Oil
Pollutant
Chlorine
Copper
Arsenic
Nitrite Plus
Nitrate
Total (as N)
Iron
Total
TWPI
11,649
3,451
2,661
1,028
640
20,753
       According to Tables 5-4 and 5-5, nuclear facilities have a TWPE of 120,125 Ib-eq, which
accounts for 11% of the total utility TWPE.  However, 60% of this discharge is released from
one facility, RE Ginna Nuclear Power Plant in Ontario, NY.  The top five pollutant discharges
from this facility based on TWPE are copper, boron, iron, chlorine, and zinc. The facility
accounts for 80% of the copper TWPE, 66% of the boron TWPE, and 99.9% of the iron TWPE
released from utility facilities using nuclear as an energy source. Table 5-6 compares the
releases from the RE Ginna facility to the releases for all nuclear facilities.  The high TWPE per
facility and TWPE per MW for nuclear facilities are driven by the results from this facility.
       Table 5-6. Pollutant Releases From RE Ginna Nuclear Plant in Ontario, NY
Pollutant
Copper
Boron
Iron
All Releases
RE Ginna Nuclear Plant
30,071
22,721
13,198
71,690
AD Nuclear Facilities
37,824
34,492
13,202
120,125
                                           5-6

-------
       Analysis of Pollutants Discharged by Flow Rate

       PCS does not provide adequate information to determine the process stream (e.g., fly ash
handling) for each reported discharge.  Therefore, EPA divided waste streams into four
categories based on flow, shown in Table 5-7, to help determine the type of streams driving
loads.  Although the flows for these streams varies largely by plant size, EPA is using these
categories only as a screening-level tool to determine the source of the majority of the TWPE.
                               Table 5-7.  Flow Categories
Flow Rate (MGD)
>50
10-50
1-10
<1
Potential Streams
Once-Through Cooling Water
Recirculating Cooling Water
Ash Handling
Miscellaneous, Metal Cleaning Waste
       EPA separated the discharges for each of the top pollutants released by flow category.
EPA did not have concentration and flow information for all 327 facilities in the utility segment.
Some facilities report releases by a mass quantity (rather than concentration and flow), and
therefore, the TWPE from these facilities could not be distributed to one of the flow categories.
However, these facilities account for only 1% of the total TWPE reported by utilities.  Table 5-8
lists the total TWPE for each of the four flow categories.  The table shows that the majority
(52%) of the TWPE released is from streams that are greater than 50 MGD.
                                           5-7

-------
                     Table 5-8. TWPE From Utilities by Flow Range
Flow Range
(MGD)
>50
10-50
1-10
<1
TOTALS
Total Flow
(MGD)
167,375
7,111
2,703
301
177,490
TWPE
549,009
224,908
246,801
36,618
1,057,336
Percent of Total TWPE
52%
21%
23%
4%

Note: Approximately 1 percent of the total TWPE is not included in the flow analysis since some facilities do not
report a flow rate, but do report a discharge by quantity.
       Table 5-9 shows the distribution among the four flow categories for the top five
pollutants.  Arsenic is the only pollutant that does not have the majority of its TWPE associated
with flows that are greater than 50 MGD. The majority of the arsenic TWPE falls in the flow
range of 10 - 50 MGD. Arsenic is a constituent of coal, and is likely to be released from ash
ponds. Although ash handling streams are likely to have a lower flowrate, coalpile runoff may
also be contributing to the arsenic loads and may be a higher flow stream.

       Table 5-9.  Flow Distribution for the Top Five Pollutants Released by Utilities
Flow Range
(MGD)
>50
10-50
1-10
<1
Total
Copper
TWPE
123,630
35,832
38,316
4,293
202,071
Arsenic
TWPE
14,518
115,885
56,805
4,354
191,562
Chlorine
TWPE
181,061
3,715
382
211
185,369
Boron
TWPE
117,858
6,150
37,507
1,670
163,186
Aluminum
TWPE
51,932
29,945
10,176
2,703
94,755
Note: Approximately 1% of the total TWPE is not included in the flow analysis since some facilities do not report a
flow rate, but do report a discharge by quantity.
       Analysis of Pollutants Discharged by Type of Cooling System

       Steam electric power plants use two types of cooling systems: once-through and
recirculating. EPA used information from EIA and the section 316(b) cooling water intake
structure regulation development to categorize cooling system type.  Form EIA-767 and section
316(b) contain information about the type of cooling system in use at 305 of the 327 steam
                                           5-8

-------
electric utilities in PCS.  Table 5-10 shows the number of utilities that use each type of cooling
system. Table 5-11 shows the total TWPE released for all utilities, once-through facilities,
recirculating facilities, and facilities using a combination of once-through and recirculating
cooling systems. Forty facilities reported both a once-through and a recirculating cooling
system. Table 5-11 shows that, for each of the pollutants,  once-through facilities release a
greater amount of pollutant than recirculating facilities.
               Table 5-10.  Distribution of Cooling Systems Used by Utilities
Type of Cooling System
Once Through
Recirculating
Combination
Total
Number of Facilities
195
70
40
305
       Analysis of Effluent Pollutant Concentrations

       EPA used concentration data available in PCS to compute the minimum, average, and
maximum concentration of detected concentrations reported for each of the top pollutants. EPA
also determined the number of non-detects reported.  Table 5-12 shows the distribution of
concentrations for each of the top pollutants along with the method detection limit.
Concentration data were available for 309 of the 327 PCS utilities, which accounts for 97% of
the total PCS TWPE.
                                           5-9

-------
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                                                  5-11

-------
5.1.2   TRI

       EPA developed analyses similar to the PCS data analyses using information from TRI.
However, the two data sets have differences, such as:
              Not all pollutants are reported to both databases - for example, TRO is reported to
              PCS but not TRI;
              Chlorine is reported to TRI as C12 rather than residual chlorine;
              TRI data contains only facilities using coal or oil as energy, as other fuel sources
              aren't required to report unless the facility also uses coal or oil; and
              TRI contains data for both direct and indirect discharges, while PCS contains only
              direct discharges.
The numbers presented in this section of the report for pounds released and TWPE represents the
quantity discharged to receiving streams and accounts for POTW treatment (for indirect
discharges).

       As in the PCS analysis, EPA was not able to link all TRI facilities to information in EIA
to obtain facility information. Of the 375 facilities reporting to TRI, 235 are utilities. Table 5-13
shows the pollutant discharges reported from the 235  utilities in TRI.  Arsenic is the top
pollutant discharged, followed by copper, mercury, lead, and selenium.  Arsenic is reported by
84 out of 235 facilities and accounts for 49% of the total TWPE reported by steam electric
utilities in TRI. All 84 facilities that reported arsenic discharges are coal facilities. Arsenic
discharges are reported by only 17 states, of which 45 of the 84 releases are from Region IV.
                                           5-12

-------
Table 5-13. Pollutants Released From 235 Utilities in the TRI Database
Chemical Name
Arsenic and Arsenic Compounds
Copper and Copper Compounds
Mercury and Mercury Compounds
Lead and Lead Compounds
Selenium and Selenium Compounds
Chlorine
Zinc and Zinc Compounds
Nickel and Nickel Compounds
Manganese and Manganese Compounds
Chromium and Chromium Compounds
Polycyclic Aromatic Compounds
Vanadium and Vanadium Compounds
Thallium and Thallium Compounds
Beryllium and Beryllium Compounds
Cobalt and Cobalt Compounds
Barium and Barium Compounds
Ammonia
Antimony and Antimony Compounds
Nitrate Compounds
Benzo(g,h,i)perylene
Methanol
Sulfuric Acid (1994 and after "Acid Aerosols"
Only)
Hydrochloric Acid (1995 and after "Acid
Aerosols" Only)
Hydrogen Fluoride
Total
Number of
Facilities
Reporting
Chemical
84
143
96
148
21
9
148
119
126
111
3
66
11
15
38
167
18
7
3
4
1
1
1
1
235
Total Pounds
Released
Accounting for
POTW
Removals
73,224
258,030
313
16,272
26,858
22,929
212,630
60,598
379,967
31,561
24
62,811
1,832
1,279
10,389
543,754
48,006
4,111
516,350
18
6,604
5
5
10

Total
TWPE
295,923
163,803
36,654
36,449
30,117
11,675
9,969
6,600
5,484
2,389
2,382
2,198
1,882
1,351
1,187
1,082
72
50
32
5
0.10
0.007
0.00012
0.00006
609,307
Percent of
Total TWPE
49%
27%
6%
6%
5%
2%
1.6%
1.1%
0.9%
0.4%
0.4%
0.4%
0.3%
0.2%
0.2%
0.18%
0.01%
0.01%
0.01%
<0.01%
<0.01%
<0.01%
0.01%
0.01%
100%
                               5-13

-------
       Analysis of Pollutants Discharged by Energy Source

       EPA segmented the TRI discharges by the energy source as in the PCS analysis. Table 5-
14 shows a summary of the total TWPE for each energy source.  Since facilities may report
using two or more energy sources, the total number of facilities reported in Table 5-14 is greater
than 235. For facilities that reported using two or more energy sources in the EIA database, EPA
distributed the TWPE to each energy source based on the percentage of capacity from each
energy source as in the PCS data analysis. As with the PCS data, the majority of the utility
TWPE is released by coal facilities. EPA also computed the TWPE per megawatt (MW), TWPE
per facility, and megawatt per facility.  Table 5-14 shows that coal facilities again have the
highest TWPE per MW. Coal facilities account for most of the capacity, but they also account
for most of the TWPE, and on a TWPE per MW basis, coal facilities are discharging just slightly
more than natural gas facilities, four times as much as oil facilities, and more than eight times as
much as nuclear facilities. As mentioned previously, natural gas and nuclear facilities are not
required to  report under TRI. Facilities report to TRI if any portion of their capacity is generated
from coal or oil. Not enough information is available to determine why the natural gas and
nuclear facilities may be reporting to TRI.
       Table 5-14.  TRI Discharges From 235 Utilities Distributed by Energy Source
Category
Coal
Natural Gas
Nuclear
Oil
Number of
Facilities
220
25
4
18
Energy
Source
Capacity
(MW)
192,560
12,296
7,974
8,578
MW/Facility
875
492
1,994
477
TWPE
(Tox-lb/yr)
567,360
32,849
2,792
6,305
TWPE/Facility
2,579
1,314
698
350
TWPE/MW
2.95
2.67
0.35
0.74
       Table 5-15 shows the top five pollutants, based on TWPE, released from each energy
source and the total TWPE for the energy source.  The top pollutants are mainly metals which
are a constituent of coal and may be released to water in the fly ash handling system or through
coal pile runoff.
                                          5-14

-------
    Table 5-15. Top Five Pollutants From 235 Utilities for Each Fuel Source in the TRI
                                        Database
Rank
1
2
3
4
5

Coal
Pollutant
Arsenic
Copper
Lead
Mercury
Selenium
Total
TWPE
282,479
155,335
35,351
30,560
29,998
567,360
Natural Gas
Pollutant
Arsenic
Chlorine
Copper
Mercury
Lead
Total
TWPE
13,168
8,381
5,220
4,359
674
32,849
Nuclear
Pollutant
Copper
Zinc
Lead
Nickel

Total
TWPE
1,696
952
110
35

2,792
Oil
Pollutant
Mercury
Copper
Polycyclic
Aromatic
Compounds
Chlorine
Lead
Total
TWPE
1,734
1,552
1,468
458
314
6,305
       Summary

       The PCS and TRI analysis shows that copper, arsenic, chlorine, boron, aluminum,
mercury, lead, and selenium rank highest in terms of TWPE released to wastewater for utilities.
The majority of the pollutant loads are from coal facilities.  This result is expected since coal
facilities have additional wastestreams due to coal-pile runoff and ash handling systems. The
initial evaluation of cooling system information shows that utilities using a once-through cooling
water system discharge higher levels of pollutants.

5.2    Nonindustrial Nonutilities

       This section summarizes the wastewater characteristics for nonindustrial nonutilities.
Section 5.2.1 discusses the PCS data and 5.2.2 discusses the TRI data.

5.2.1   PCS

       EPA analyzed data from PCS to identify pollutants discharged from steam electric
nonindustrial nonutilities.  Of the 554 facilities reporting to PCS, 163 are nonindustrial
nonutilities. Table 5-16 presents the top pollutants discharged based on TWPE, along with the
number of facilities reporting the pollutant.
                                          5-15

-------
Table 5-16. The Top Pollutants Released From 163 Steam Electric Nonindustrial
                      Nonutilities in the PCS Database
Pollutant
Boron
Aluminum
Chlorine
Copper
Iron
Lead
Silver
Zinc
Selenium
Chromium, Hexavalent
Cadmium
Mercury
Hydrazine
Nickel
Manganese
Nitrogen, Ammonia
Boric Acid
Arsenic
Sulfate
Nitrogen, Nitrate Total (As N)
Chloride
Chromium
Pcb-1260 (Arochlor 1260)
Nitrogen, Nitrite Total (As N)
Magnesium
Vanadium
Cobalt
Molybdenum
Sodium
Fluoride
Titanium
Beryllium
Barium
Total
Number of
Facilities Reporting
Pollutant
14
24
79
55
62
19
5
49
11
5
9
6
7
27
20
20
1
8
13
6
5
12
2
4
2
7
1
2
1
4
2
4
2

Total Pounds
Estimated to be
Discharged
703,404
1,858,482
184,974
71,321
4,578,911
8,809
1,016
267,254
5,723
6,009
99
4
7,409
3,636
23,405
223,024
519,734
74
48,887,354
35,868
6,511,436
1,918
0
209
75,839
1,349
235
121
2,318,659
339
109
1
408

Total TWPE
124,654
120,227
94,182
45,276
25,642
19,733
16,733
12,530
6,417
3,104
2,295
521
465
396
338
336
312
298
274
201
159
145
81
78
66
47
27
24
13
12
3
1
1
474,591
Percent of
Total TWPE
26%
25%
20%
10%
5%
4%
4%
3%
1.4%
0.7%
0.5%
0.11%
0.10%
0.08%
0.07%
0.07%
0.07%
0.06%
0.06%
0.04%
0.03%
0.03%
0.02%
0.02%
0.01%
0.01%
0.01%
0.01%
<0.01%
<0.01%
<0.01%
0.01%
0.01%

                                  5-16

-------
       As in the analyses of utilities, boron, aluminum, chlorine, and copper ranked in the top
five pollutants discharged based on TWPE. Iron also ranked in the top five for nonindustrial
nonutilities.  Arsenic is the only pollutant that was in the top five for utilities, but not for
nonindustrial nonutilities. The capacity of coal-fired plants is over three times higher for utilities
than nonindustrial nonutilities which may also account for the higher arsenic loads.

       Table 5-17 shows the comparison of capacity between the utility and  the nonindustrial
nonutility facilities.
   Table 5-17.  Comparison of Capacity Between Utilities and Nonindustrial Nonutilities
                             Reporting in the PCS Database
Energy Source
Coal
Natural Gas
Nuclear
Oil
Total
Utility Capacity
(MW)
200,650
45,324
56,993
13,262
316,229
Percent of Total
Utility Capacity
64
14
18
4
100
Nonindustrial
Nonutility Capacity
(MW)
59,426
37,609
35,245
16,428
148,708
Percent of Total
Non-industrial
Nonutility Capacity
40
25
24
11
100
       As with the utilities, some of the pollutants discharged, such as conventional pollutants,
do not have TWFs. Some of these pollutants can have significant discharges, as shown in Table
5-18.
Table 5-18. Pollutants Without TWFs Released From 163 Nonindustrial Nonutilities in the
                                     PCS Database
Pollutant
Total Suspended Solids
Oil & Grease
Total Residual Oxidants
BOD5
Number of Facilities Reporting
Pollutant
139
131
26
65
Total Pounds Estimated to be
Discharged
88,278,176
11,621,147
669,239
21,359
                                          5-17

-------
       Analysis of Pollutants Discharged by Energy Source

       EPA further investigated the pollutant discharges reported in PCS by the energy source
reported in the EIA database. Table 5-19 shows the number of facilities, the combined capacity,
and the TWPE associated with the reported discharges by energy source. Table 5-19 was created
using information from the 163 PCS steam electric nonindustrial nonutilities.  Since facilities
may report two or more energy sources, the total number of facilities reported in Table 5-19 is
greater than  163.
  Table 5-19. PCS Discharges From 163 Nonindustrial Nonutilities Distributed by Energy
                                         Source
Category
Coal
Natural Gas
Nuclear
Oil
Number of
Facilities
80
53
22
33
Energy Source
Capacity (MW)
59,426
37,609
35,245
16,428
MW/Facility
743
710
1,602
498
TWPE
(tox-lb/yr)
184,089
190,001
64,868
35,633
TWPE/Facility
2,301
3,585
2,949
1,080
TWPE/MW
3.10
5.05
1.84
2.17
       For facilities that reported using two or more energy sources, EPA distributed the TWPE
to each energy source based on the percentage of capacity from each energy source.  For
example, if 25% of a facility's capacity is from coal and 75% is from natural gas, and the facility
reported releasing 4,000 pounds of chlorine, then EPA assumed 1,000 pounds are associated
with coal and 3,000 pounds are associated with natural gas operations. Although some
pollutants, especially metals, are more likely to result from the use of certain fuels (e.g., coal),
this approximation allowed EPA to evaluate whether certain energy sources contributed the bulk
of the pollutant loads.  Table 5-19 shows that the natural gas facilities report the highest TWPE.

       Table 5-19 also shows TWPE per megawatt,  TWPE per facility, and megawatt per
facility calculated by EPA. The table shows that natural gas facilities have the highest TWPE
per megawatt, discharging more than twice as much as nuclear and oil facilities, and more than
1.5 times as much as coal facilities per megawatt.
                                          5-18

-------
       Table 5-20 shows the comparison of TWPE per facility between the utilities and
nonutilities. Table 5-20 shows that the natural gas TWPE for nonindustrial nonutilities is 2.5
times larger than for utilities while the number of facilities is lower. The overall TWPE per
facility for nonindustrial nonutilities is more than three times larger than for utilities.  The
difference is driven by one facility, West Texas Utilities Company in Abilene, TX. This facility
reports a discharge of 1,226,638 pounds  of aluminum which is equal to 79,353 Ib-eq. EPA will
contact this facility to verify the reported discharge.
      Table 5-20. Comparison of TWPE/Facility Between Utilities and Nonindustrial
                        Nonutilities Reporting in the PCS Database
Category
Coal
Natural Gas
Nuclear
Oil
Number of
Utility
Facilities
231
71
38
30
Utility
TWPE
853,828
72,864
120,125
20,753
Utility
TWPE/Facility
3,696
1,026
3,161
692
Number of
Nonindustrial
Nonutility
Facilities
80
53
22
33
Nonindustrial
Nonutility
TWPE
184,089
190,001
64,868
35,633
Nonindustrial
Nonutility
TWPE/Facility
2,301
3,585
2,949
1,080
       Due to the greater TWPE and the lower capacity for nonindustrial nonutility natural gas
facilities compared to utility natural gas facilities, the TWPE per megawatt is greater.  Part of
this difference may be attributable to West Texas Utilities; however, even if the TWPE from that
facility was set to zero, the TWPE would still be larger for nonindustrial nonutilities than for
natural gas utilities. Table 5-21 shows the TWPE per megawatt for each of the energy sources
for utility facilities and nonindustrial nonutility facilities.
                                           5-19

-------
 Table 5-21. Comparison of TWPE/MW Between Utilities and Nonindustrial Nonutilities
                             Reporting in the PCS Database
Energy Source
Coal
Natural Gas
Nuclear
Oil
Utility TWPE/MW
4.26
1.61
2.11
1.56
Non-industrial Nonutility
TWPE/MW
3.10
5.05
1.84
2.17
       Analysis of Pollutants Discharged by Cooling System

       Using the section 316(b) and Form EIA-767 information, EPA determined the cooling
system used by 144 of the 163 nonindustrial nonutilities. As with the utilities, the majority of
the TWPE is released by facilities using once-through cooling systems. However, for the
nonindustrial  nonutilities, greater quantities of some pollutants (boron, selenium,  and cadmium)
are released from recirculating systems rather than once-through systems. Table 5-22 shows the
distribution of the 144 facilities by cooling system type. Table 5-22 shows that the majority of
the nonindustrial nonutilities use once-through cooling systems.
      Table 5-22.  Distribution of Cooling Systems Used by Nonindustrial Nonutilities
Type of Cooling System
Once-Through
Recirculating
Combination
Number of Facilities
102
31
11
5.2.2   TRI

       EPA analyzed data from TRI to identify pollutants discharged from steam electric
nonindustrial nonutilities. Of the 375 facilities reporting to TRI, 103 are nonindustrial
nonutilities. Table 5-23 presents the top pollutants discharged based on TWPE, along with the
number of facilities reporting the pollutant.
                                          5-20

-------
Table 5-23. The Top Pollutants Released From 103 Steam Electric Nonindustrial
                      Nonutilities in the TRI Database
Chemical Name
Arsenic and Arsenic Compounds
Lead and Lead Compounds
Copper and Copper Compounds
Mercury and Mercury Compounds
Nickel and Nickel Compounds
Chromium and Chromium Compounds
Zinc and Zinc Compounds
Vanadium and Vanadium Compounds
Selenium and Selenium Compounds
Manganese and Manganese Compounds
Chlorine
Barium and Barium Compounds
Thallium and Thallium Compounds
Ammonia
Polychlorinated Biphenyls
Hexachlorobenzene
Toluene
Cobalt and Cobalt Compounds
Antimony and Antimony Compounds
Beryllium and Beryllium Compounds
Polycyclic Aromatic Compounds
Molybdenum Trioxide
Formic Acid
Benzo(g,h,i)perylene
Hydrogen Fluoride
Total
Number of Facilities
Reporting Chemical
29
76
43
41
41
40
52
28
7
55
2
63
4
22
1
1
2
6
4
1
2
2
1
1
1

Total Pounds
Released
15,395
20,742
30,978
44
44,984
54,413
46,593
59,998
1,862
107,621
1,945
286,663
530
46,871
0.0012
0.02
4,200
132
763
4
0.03
253
13
0.0005
10

Total
TWPE
62,216
46,462
19,665
5,099
4,899
4,119
2,185
2,100
2,088
1,553
990
571
544
71
41
39
24
15
9
4
3
0.2
0.005
0.00014
0.00006
152,697
Percent of
Total TWPE
41%
30%
13%
3%
3%
3%
1.4%
1.4%
1.4%
1.0%
0.6%
0.4%
0.4%
0.05%
0.03%
0.03%
0.02%
0.01%
0.01%
<0.01%
<0.01%
<0.01%
<0.01%
0.01%
0.01%

                                  5-21

-------
       Four of the top five pollutants (arsenic, lead, copper, and mercury) released from
nonindustrial nonutilities were among the top five pollutant released from utility facilities.
Nickel replaced selenium in the top five pollutants list for nonindustrial nonutilities.

       Analysis of Pollutants Discharged by Energy Source

       EPA segmented the TRI discharges by the energy source as in the PCS analysis.  Table 5-
24 shows a summary of the total TWPE for each energy source. Since facilities may report two
or more energy sources, the total number of facilities reported in Table 5-24 is greater than 103.
For facilities that reported using two or more energy sources in the EIA database, EPA
distributed the TWPE to each energy source based on the percentage of capacity from each
energy source as discussed in the PCS data analysis.  Unlike the PCS data, the majority of the
nonindustrial nonutility TWPE is released by coal facilities, 91%, not natural gas. EPA also
computed the TWPE per megawatt, TWPE per facility, and megawatt per facility.  Table 5-24
shows that coal facilities have the highest TWPE per megawatt. Coal facilities account for most
of the capacity, but they also account for most of the TWPE, and on a TWPE per megawatt
basis, coal facilities are discharging almost twice as much as natural gas facilities and four times
as much as oil facilities. Four utility facilities reported a nuclear fuel source, but no
nonindustrial nonutilities reported  a nuclear fuel source. This discrepancy is not surprising,
since nuclear facilities are not required to report to TRI.
  Table 5-24.  TRI Discharges From 103 Nonindustrial Nonutilities Distributed by Energy
                                         Source
Category
Coal
Natural Gas
Oil
Number of
Facilities
90
14
16
Energy
Source
Capacity
56,939
5,484
10,004
MW/Facility
633
392
625
Energy
Source
TWPE
139,615
6,939
6,143
TWPE/Facility
1,551
496
384
TWPE/MW
2.45
1.27
0.61
                                          5-22

-------
       Table 5-25 shows the comparison of TWPE between the two types of facilities.  The
TWPE percentage by fuel source is fairly consistent between the utilities and the nonindustrial
nonutilities.
 Table 5-25. Comparison of TWPE Between Utility and Nonindustrial Nonutility Facilities
                            Reporting in the TRI Database
Category
Coal
Natural Gas
Nuclear
Oil
Utility TWPE
567,360
32,849
2,792
6,305
Percent of Utility
TWPE
93.1
5.4
0.5
1.0
Nonindustrial
Nonutility TWPE
139,615
6,939
-
6,143
Percent of
Nonindustrial
Nonutility TWPE
91.4
4.6
-
4.0
       While the TWPE percentages were consistent, the TWPE per megawatt for each of the
fuel sources was lower for utility facilities as compared to nonindustrial nonutility facilities. For
example, the TWPE per megawatt was 52% lower for utilities than nonindustrial nonutilities
using natural gas as the fuel source.  Table 5-26 shows the comparison of TWPE per megawatt
for the two types of facilities.
   Table 5-26. Comparison of TWPE/MW Between Utility and Nonindustrial Nonutility
                        Facilities Reporting in the TRI Database
Category
Coal
Natural Gas
Nuclear
Oil
Utility TWPE/MW
2.95
2.67
0.35
0.74
Nonindustrial Nonutility
TWPE/MW
2.45
1.27
-
0.61
                                         5-23

-------
       Summary

       The PCS and TRI analysis shows that boron, aluminum, chlorine, copper, iron, arsenic,
mercury, lead, and nickel rank highest in terms of TWPE released to wastewater for
nonindustrial nonutilities.  Arsenic loadings reported to PCS are significantly lower for
nonindustrial nonutilities than for utilities, because the megawatts generated by coal (the major
source of arsenic) is over three times higher for utilities. The PCS data show that the TWPE per
facility is highest for natural gas facilities, while the TRI data show coal facilities have the
highest TWPE per facility. As discussed previously, the high TWPE reported for natural gas
facilities may be due to a single anomalous facility.  EPA will discuss the reported discharge
with the facility, and, if necessary,  investigate the source of their high discharge. The
preliminary results show that utilities and nonutilities have similar wastewater characteristics.

5.3    Industrial Nonutilities

       EPA was able to match 60 of the 308 steam electric industrial nonutilities listed in EIA to
data included in the PCS database.  The industries that these facilities represent are presented in
Table 5-27.
                                           5-24

-------
      Table 5-27. Industries Represented in the Analysis of 60 Industrial Nonutilities
Industry
Pulp, Paper, and Paperboard
Sugar Processing
Petroleum Refining
Organic Chemicals, Plastics, and Synthetic Fibers
Iron and Steel Manufacturing
Vinyl Chloride and Chlor- Alkali
Grain Mills Manufacturing
Nonferrous Metals Manufacturing
Pharmaceutical Manufacturing
Pesticide Chemicals Manufacturing
Fruits and Vegetable Processing
Cement Manufacturing
Inorganic Chemicals
Metal Finishing
Ore Mining and Dressing
Explosives
Sewerage Systems
Number of Facilities
17
8
8
5
5
4
2
2
2
2
1
1
1
1
1
1
1
       Since the industrial nonutilities' primary purpose of operation is something other than
electricity production, many of the chemicals released may not be associated with electricity
production.  Table 5-28 shows the top pollutants, based on TWPE, released from the steam
electric industrial nonutilities. Of the 60 industrial nonutilities, 21 reported releasing chlorine,
which is one of the most frequently reported chemicals from steam electric facilities in the PCS
database.
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 Table 5-28.  Top Pollutants Released From 60 Industrial Nonutility Facilities Reporting in
                                    the PCS Database
Pollutant
Silver
Chlorine
Molybdenum
Sulfide
Nitrogen, Ammonia
Lead
Copper
Nitrogen, Nitrite Total (As N)
Cyanide
Fluoride
Selenium
Aluminum
Arsenic
Nickel
Zinc
Phenol & Phenolics
Mercury
Cadmium
Chloride
Tributyltin
Nitrogen, Nitrate Total (As N)
Boron
Chromium, Hexavalent
Number of
Facilities
3
21
1
7
38
15
19
2
11
3
4
5
4
13
19
12
5
4
6
1
o
J
1
5
Pounds Released
9,990
295,368
717,011
42,674
32,564,941
13,085
44,006
74,432
18,422
358,547
11,136
168,466
2,467
72,970
134,045
187,285
45
216
126,159,200
25
143,050
3,837
1,307
TWPE
164,548
150,390
144,434
119,550
49,022
29,310
27,936
27,788
20,576
12,549
12,487
10,898
9,970
7,947
6,285
5,245
5,238
4,986
3,072
2,242
801
680
675
       Using the section 316(b) and Form EIA-767 information, EPA determined the type of
cooling system used by 22 of the 60 industrial nonutilities. Table 5-29 shows the distribution of
the 22 facilities by cooling system type. The majority of the industrial nonutilities use
recirculating cooling systems; however, with such a small data set, it is difficult to determine if
these results are representative of all industrial nonutilities.
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  Table 5-29. Distribution of Cooling Systems Used by 60 Industrial Nonutility Facilities
Type of Cooling System
Once-Through
Recirculating
Combination
Total
Number of Facilities
6
15
1
22
       Table 5-30 shows the distribution of the 60 facilities by energy source using EIA
information.  Five of the facilities reported using two or more energy sources; therefore, the total
number of facilities reported in Table 5-30 is greater than 60.
    Table 5-30. Distribution of Energy Sources Used by Industrial Nonutility Facilities
Energy Source
Coal
Natural Gas
Nuclear
Oil
Number of Facilities
32
35
0
5
       Due to the limited information on industrial nonutilities, EPA will continue to investigate
this type of facility as it completes the detailed study.
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6.0    ADDITIONAL INFORMATION NEEDS AND NEXT STEPS


       EPA will continue to evaluate steam electric facilities for the development of the 2006
Plan.  EPA will respond to comments on this preliminary report and continue to evaluate the
topics discussed in this report.  Topics requiring further study include:
       •       Arsenic - Arsenic discharges are reported by facilities in 14 states, and 29 of the
              44 facilities reporting are in Region IV. EPA will investigate the reason for the
              increased discharge in this area;

       •       Boron - Boron ranks in the top five pollutants discharged from steam electric
              utilities and nonindustrial nonutilities. EPA will investigate possible sources of
              boron;

       •       Mercury - Mercury ranks in the top five pollutants discharged from natural gas-
              fired utilities and coal- and natural gas-fired nonindustrial nonutilities. EPA will
              investigate the wastestreams that contribute to the mercury load; and

       •       Total Suspended Solids - Steam electric facilities discharge high quantities of
              TSS. EPA will investigate the sources of TSS.


       In addition, EPA will conduct a focused review of topics that were not evaluated as part

of the preliminary study. The additional areas to be investigated are discussed in the following

sections:
       •       Section 6.1 discusses the evaluation of pollution prevention and wastewater
              treatment technologies;

       •       Section 6.2 discusses the review of information provided by UWAG;

       •       Section 6.3 discusses the additional questions on industrial nonutilities;

       •       Section 6.4 discusses the additional questions on generators using renewable or
              recycled fuel; and

       •       Section 6.5 discusses emerging issues.


EPA will review any additional information provided on these topics for the development of the
2006 Plan.
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6.1    Pollution Prevention and Wastewater Treatment Technologies

       EPA will review pollution prevention and wastewater treatment technologies available to
reduce pollutant loadings. When evaluating potential treatment options, EPA will take into
account the preliminary concentration analysis (Table 5-12), which shows that, on average, the
pollutants are present in steam electric wastewaters. EPA will consider the reported
concentration levels when evaluating treatment options.

       In the OECA Sector Notebook (U.S. EPA, 1997), EPA suggested several methods for
reducing pollution from steam electric facilities (summarized in Table 6-1). EPA will
investigate these and other options further during the development of the final detailed study.

       Table 6-1.  Potential Pollution Prevention Options for Steam Electric Facilities
Pollution Prevention Option
Description/Notes
Cooling Water
Optimize chemical use
Chemical substitution
Use inert construction materials
Reduce water use
Facilities should minimize the amount of chemicals added to the
system.
Bromine is more toxic than chlorine. Ozone treatment could be
considered to replace both bromine and chlorine.
Nonreactive construction materials will reduce scale and corrosion.
Recirculating systems should be used instead of once-through systems.
Installing automatic bleed/feed controllers and bypass feeders may also
reduce volumes of chemicals and water required.
Boiler Cleaning (Fire side)
Use cleaner fuels
Use alternate cleaning methods
Natural gas is the cleanest burning fuel. Cleaner coals and oils will
reduce amount of cleaning required.
Soot blowers, sonic horns, brushing, sweeping, or vacuuming used to
replace or augment waster washing will reduce wastewater generated.
Boiler Cleaning (Water side)
Optimize cleaning frequency
Control boiler chemistry
Maintain operating records including normal cycle chemistry to help
determine when cleaning is needed
Controlling chemistry will help reduce scaling
Source: OECA Sector Notebook (U.S. EPA, 1997)

       Steam electric facilities are currently recycling fly ash and bottom ash to minimize the
amount of ash requiring treatment. UWAG provided information on the use of coal combustion
                                          6-2

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product wastes (see DCN 01728 in section 13.2 of the record).  Information for 2003 shows that

fly ash and bottom ash are used in the following applications:
       •      Concrete/Concrete Products/Grout;
       •      Cement/Raw Feed for Clinker;
       •      Flowable Fill;
       •      Structural Fills/Embankments;
       •      Road Base/Sub-base/Pavement;
       •      Soil Modification/Stabilization;
       •      Mineral Filler in Asphalt;
       •      Snow and Ice Control;
       •      Blasting Grit/Roofing Granules;
       •      Mining Applications;
       •      Waste  Stabilization/Agriculture; and
       •      Agriculture.
       EPA will continue to collect information on potential pollution prevention and

wastewater treatment options for this industry.


6.2    UWAG Information


       As mentioned in Section 3.6, UWAG is currently collecting data from their members for

use in EPA's evaluation of this industry. EPA will review the information as it is received from

UWAG and incorporate it into analyses where appropriate.  Since UWAG represents only

utilities, the information collected will only be applicable to this facility type (see DCN 01738 in

section 13.2 of the record).
6.3    Industrial Nonutilities


       Industrial nonutilities are not currently regulated under Part 423 since their primary

purpose is not the generation or distribution of electricity. EPA will investigate these facilities
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further to estimate the potential hazard posed by discharges from the steam electric portion of
these facilities. Additional questions to address include:
              What are the current permit limits for these generating units?  Are permit writers
              applying Part 423 limits to the steam electric portion of these plants?

              Is wastewater from the steam electric plant commingled with other facility
              wastewater before treatment and discharge? Does it affect the pollutant loads and
              potential treatment?

              What type of cooling systems are used by these facilities?  What chemicals are
              they using to control biofouling?

              Does the fact that these facilities are  co-located with other manufacturing
              operations affect pollution prevention and treatment options?
EPA may answer these questions through a targeted permit review and/or through facility site

visits.


6.4    Renewable/Recycled Fuel Sources


       Part 423 currently only applies to facilities using fossil-based or nuclear fuel.  As

mentioned in Section 4.3.5 steam electric facilities may use fuels such as agricultural waste and

biomass to produce steam.  EPA will investigate these facilities to determine if they should be

included in the applicability of Part 423.  Additional questions to address include:
              How are these facilities similar to facilities currently covered by Part 423 in terms
              of pollutant discharge, water use, wastewater flow rates, and plant capacity?

              Do these facilities have any additional sources of wastewater?

              How are these facilities currently permitted? What pollutants are regulated and
              what limits apply?
       EPA may answer these questions through a targeted permit review and/or through facility

site visits.
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6.5    Emerging Issues

       EPA will also review information on emerging technologies that may impact pollutant
loadings, such as Integrated Gasification Combined-Cycle (IGCC). This technology, which may
become used more frequently, involves converting coal into a gaseous fuel which is then purified
and combusted in a gas turbine generator to produce electricity. Heat from the exhaust gas is
recovered and used to generate steam to produce additional electricity.  IGCC plants are more
efficient than traditional steam electric plants. Most of the environmental benefits for this
technology will be related to reducing air emissions. (U.S. EPA, 1997)

       EPA will collect additional information on the prevalence of these types of facilities.
Currently, EPA only has information on one IGCC plant located at the Polk Power Station in
Florida. The 260 MW IGCC plant is considered a zero-discharge facility.  A brine concentration
unit handles all  of the liquid wastes and the effluent is reused in the process.  EPA will
investigate topics related to IGCC plants during the development of the 2006 Plan.
                                              cfm)]
                                          6-5

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7.0   REFERENCES
1.     Kaplan, Charles H., Letter to Regional Permit Branch Chiefs and State Directors.
      "Combined Cycle Electric Generation Plants, Steam Electric Power Generating Point
      Source Category", U.S. EPA Region IV, December 19, 1989.

2.     Tampa Electric Environmental Web site,
      http://www.tampaelectric.com/TEEVPowerPlantsIGCC.cfm

3.     U.S. Department of Energy, Energy Information Administration. www1eja.doe1gov.

4.     U.S. EPA. Cooling Water Intake Structures Section 316(b) Web site,
      http://www.epa.gov/waterscience/316b/index.html.

5.     U.S. EPA. EPCRA Section 313 Industry Guidance Electricity Generating Facilities. EPA
      745-B-00-004, Office of Pollution Prevention and Toxics, February 2000.

6.     U.S. EPA. 2005. PCSLoads2002 vOl Database.

7.     U.S. EPA. Preliminary Data Summary for the Steam Electric Point Source Category.
      EPA-821-Z-96-010, Washington, DC, 1996.

8.     U.S. EPA, Profile of the Fossil Fuel Electric Power Generation Industry. EPA Office of
      Compliance  Sector Notebook Project, EPA/310-R097-007,  September 1997.

9.     U.S. EPA. Screening-Level Analysis Report. Washington. DC. 2005.

10.    U.S. EPA. 2005. TRIReleases2002 v02 Database.
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