&EPA
United States
Environmental Protection
Agency
EPA821-R-07-008
Steam Electric Detailed Study:
Summary Paper for the Preliminary 2008
Effluent Guidelines Plan
October 2007
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TABLE OF CONTENTS
Page
1.0 BACKGROUND 1
1.1 Background of the Study 1
2.0 DATA COLLECTION ACTIVITIES 2
2.1 Facility Inspections 3
2.2 Wastewater Sampling 7
2.3 Data Request 9
2.4 EPA Interactions with the Utility Water Act Group (UWAG) 12
2.4.1 Database of Power Plant Information 13
2.4.2 Wastewater Sampling 13
2.4.3 Data Request 14
2.4.4 NPDES Form 2C 14
2.5 EPA Interactions with the Electric Power Research Institute (EPRI) 15
2.6 Other Data Collection Activities 15
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LIST OF TABLES
Page
Summary of Steam Electric Detailed Study Site Visits 5
Summary of Steam Electric Detailed Study Sampling Program 7
Summary of Analytes of Interest for Sampling Program 9
Preliminary Profile Data of Data Request Recipients 11
LIST OF FIGURES
Page
Geographic Distribution of Coal-fired Steam Electric Plants Included in EPA
Data Collection Activities for Steam Electric Detailed Study 3
Geographic Distribution of Coal-fired Steam Electric Plants Part of EPA Site
Visit and Sampling Program for the Steam Electric Detailed Study 6
Geographic Distribution of Coal-fired Steam Electric Plants That Received the
Data Request for Steam Electric Detailed Study 12
11
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LIST OF ACRONYMS
BODs Biochemical oxygen demand
CFR Code of Federal Regulations
CWA Clean Water Act
DCN Document control number
ELGs Effluent limitations guidelines and standards
EPA Environmental Protection Agency
EPRI Electric Power Research Institute
FGD Flue gas desulfurization
FIEM Hexane extractable material
IGCC Integrated Gasification Combined Cycle
NOx Nitrogen oxides
NPDES National Pollutant Discharge Elimination System
O&M Operating and maintenance
PCS Permit Compliance System
QC Quality control
SCR Selective catalytic reduction
SGT-HEM Silica gel treated hexane extractable material
SNCR Selective non-catalytic reduction
IDS Total dissolved solids
TKN Total Kjeldahl nitrogen
TRI Toxics Release Inventory
TSS Total suspended solids
UWAG Utility Water Act Group
WWT Wastewater treatment
in
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1.0 BACKGROUND
The Environmental Protection Agency (EPA) is conducting a review of
discharges from the steam electric power generating industry as part of its broader review of
effluent limitations guidelines and standards (ELGs) for the 2008 Effluent Guidelines Plan.
Section 304(m) of the Clean Water Act (CWA) requires EPA to develop and publish a biennial
plan that establishes a schedule for the annual review and revision of ELGs required by Section
304(b).
The 2007/2008 study is concentrating primarily on characterizing pollutant
sources believed to contribute the majority of the toxic-weighted pollutant loadings from steam
electric facilities. The study will also evaluate available pollution control technologies/practices
for the pollutants present in these wastestreams. Building upon the results of a prior study EPA
conducted for the 2005/2006 review of ELGs, the current effort is primarily focused on
wastewater discharges from air pollution controls and ash handling operations at coal-fired
power plants. Certain other discharges from steam electric power plants will also be reviewed
during the study. EPA is collecting data using a variety of means, including facility inspections,
wastewater sampling, industry and vendor contacts, and a data request instrument (i.e.,
questionnaire) sent to selected power plant operators.
EPA's Office of Water is coordinating its efforts with ongoing research and
activities being undertaken by other EPA offices, including the Office of Research and
Development, the Office of Solid Waste, and the Office of Air and Radiation (Office of Air
Quality Planning and Standards and the Office of Atmospheric Programs). EPA is also
coordinating certain activities with the Utility Water Act Group (UWAG), an industry trade
association, and has held technical information discussions with the Electric Power Research
Institute (EPRI) and treatment equipment vendors.
1.1 Background of the Study
During EPA's 2005/2006 review of ELGs, EPA determined that the Steam
Electric Power Generating Point Source Category (40 CFRPart 423) discharges relatively high
amounts of toxic-weighted pollutants, in comparison to other industry sectors. In conducting the
detailed study that ended in 2006, EPA initially investigated whether pollutant discharges
reported to the Permit Compliance System (PCS) and Toxics Release Inventory (TRI) for 2002
accurately reflected the current discharges of the industry. EPA also performed an in-depth
analysis of the reported pollutant discharges, and reviewed technology innovation and process
changes. Additionally, EPA evaluated certain electric power and steam generating activities that
are similar to the processes regulated for the Steam Electric Power Generating Point Source
Category, but that are not currently subject to ELGs.
EPA's efforts for the 2006 study focused on the following objectives:
• Identify the key pollutants and sources of those pollutants discharged by the
regulated steam electric industry.
• Identify available pollution control technologies and best management practices
within the industry to address significant pollutant discharges.
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• Evaluate wastewaters from certain activities not currently regulated by ELGs, but
which may be similar in nature to the waste streams regulated by 40 CFR Part
423. EPA examined information for wastewaters from the following types of
activities:
— The combustion/gas turbine portion of combined cycle systems.
— Steam electric facilities where the energy/heat source used to produce the
steam is not a fossil or nuclear fuel.
— Steam supply facilities that generate steam for distribution and sale, but
that do not primarily use that steam to drive a turbine and produce electric
power.
— Facilities providing a combination of electric power (generated by steam)
and other utility services.
— Industrial non-utilities (i.e., steam electric power plants located at
industrial/manufacturing facilities such as paper mills).
EPA determined that the currently available data provide an incomplete picture of
the wastewaters generated by the regulated steam electric industry; however, they do suggest that
several process waste streams are primarily driving the pollutant loads discharged by these
facilities and that control technologies and management practices capable of achieving
significant pollutant reductions are technologically feasible. Therefore, EPA determined that
further review of these discharges during the 2007/2008 ELG planning cycle was warranted. For
more information on the 2005/2006 study, see Interim Detailed Study Report for the Steam
Electric Power Generating Point Source Category (EPA-821-R-06-015; November 2006).
2.0 DATA COLLECTION ACTIVITIES
EPA is focusing efforts for the 2007/2008 Study on certain discharges from coal-
fired power plants. Since EPA's past study efforts indicate that the toxic-weighted loadings are
predominantly driven by the metals present in wastewater discharges, and that the waste streams
contributing the majority of the metals are associated with air pollution controls,1 EPA is
collecting and analyzing data characterizing wastewater pollutants and potential control options
for wet flue gas desulfurization (FGD) wastes and ash handling wastes. EPA is collecting data
through facility inspections, wastewater sampling, a limited survey of selected facilities, and
various secondary data sources. Figure 1 shows the locations of plants where EPA has visited,
collected samples of wastewater, or obtained information via the data request.
1 Other potential sources of metals include coal pile runoff, metal/chemical cleaning wastes, coal washing, and
certain low volume wastes.
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a
•s*
• 9
Legend
n Plants that were visrted by EPA and are not currently scheduled to be sampled
I Plants that have been or are scheduled to be sampled during EPA's detailed study (EPA conducted pre-sampling site visits at each of these plants)
• Plains thai are within (he scope of the data request (and were no! visited or scheduled for sampling)
A Plants that were visited by EPA and are within the scope of the data request
Figure 1. Geographic Distribution of Coal-fired Steam Electric Plants Included in EPA
Data Collection Activities for Steam Electric Detailed Study
2.1 Facility Inspections
EPA is currently conducting a site visit program to gather information on the
types of wastewaters generated by coal-fired steam electric power plants, as well as the methods
of managing these wastewaters to allow for recycle, reuse, or discharge. In particular, EPA has
focused data gathering activities on coal-fired power plants, with particular interest in FGD
wastewater treatment, the management of ash sluice water, and water reuse opportunities.
EPA initially constructed a list of 96 coal-fired steam electric plants believed to
operate wet FGD systems, based on information received from EPA's Office of Air and
Radiation. EPA received and reviewed data from UWAG on approximately 80 of these coal-
fired steam electric plants with wet FGD systems and two additional plants not previously
identified by EPA. The data provided by UWAG included information on air pollution controls
in place, process configurations, and other characteristics of the plants (see Section 2.4 for more
information). In addition, EPA gathered data on another 4 coal-fired steam electric power plants.
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The compiled facility data are believed to represent approximately 80-85 percent of the total
population of coal-fired plants currently operating wet FGD systems.2 The UWAG data were
used in conjunction with information from other sources, including publicly available plant-
specific information and contacts with state and regional permitting authorities, to preliminarily
identify candidate plants for site visits. EPA considered the following characteristics to select
plants for site visits (not listed in any priority order):
• Coal-fired boilers;
• Wet FGD scrubber system, including:
— Type of scrubber,
— Sorbent used,
— Year operation began,
— Chemical additives used,
— Forced oxidation process,
— Water cycling, and
— Solids removal process;
• Type of coal;
• Selective Catalytic Reduction (SCR) and/or Selective Non-Catalytic
Reduction (SNCR) NOx controls;
• Ash handling systems;
• FGD wastewater treatment system;
• Ash treatment system; and
• Advanced mercury air controls.
Using these characteristics, EPA identified plants to contact and obtain more
detailed information about the plants' operations. From the information obtained during these
contacts, EPA selected 12 plants for site visits. Plant conditions, such as type of FGD and
whether target waste streams are segregated or commingled with other wastes, influenced the
plant selection process. See Table 1 for information on the characteristics of plants visited prior
to September 2007. Figure 2 shows the geographic distribution of the plants that were visited.
As of early 2007, EPA had identified 98 plants operating one or more wet FGD systems. The total number of
plants operating wet FGD systems is dynamic; additional plants have started operating FGD systems since the
beginning of the year, or are currently in the process of installing FGD systems. Therefore, the data provided by
UWAG are believed to represent about 80-85 percent of the total population of coal-fired plants currently operating
wet FGD systems.
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Table 1. Summary of Steam Electric Detailed Study Site Visits
Site
A
B
C
D
E
F
G
H
I
J
K
L
Coal Type
Eastern Bituminous
Eastern Bituminous
Eastern Bituminous
Eastern Bituminous
Eastern Bituminous
Subbituminous (Powder
River Basin)
Bituminous (75%), Eastern
Bituminous (25%)
Eastern bituminous,
additionally bums
petroleum coke as a small
percentage (up to 30%)
Eastern Bituminous,
additionally bums
petroleum coke as a small
percentage (typically 1-
2%; 5% maximum)
Eastern Bituminous
Eastern Bituminous
Subbituminous
FGD Type
Chiyoda Jet-Bubbling Reactor,
limestone forced oxidation. No
additives. (1 unit)
Currently being installed
Spray tower, limestone forced
oxidation.3 No additives. (2 units)
Spray tower, limestone forced
oxidation. Dibasic acid additive.
(2 units)
Spray tower, limestone forced
oxidation. Formic acid additive.
(1 unit)
Spray tower, limestone forced
oxidation. No additives. (2 units)
Spray tower, limestone forced
oxidation. No additives. (2 units)
Spray tower, limestone forced
oxidation. Dibasic acid additive. (2
units)
Two scrubbers for 4 units (2 units per
scrubber): (1) spray tower, limestone
forced oxidation, and (2) double loop
spray tower, limestone forced
oxidation. Dibasic acid additive.
Spray tower, limestone forced
oxidation. Formic acid additive. (2
units)
Spray tower, limestone forced
oxidation. No additives. (2 units)
In the process of being installed.
Year FGD
Began
Operation
1992
NA
1977 and 1981
1994 and 1995
2001
2006 and 2007
1992
1984
1985 (double
loop) and
2000 (spray
tower)
1995
NA
NA
SCR/SNCR NOX
Control
No SCR or SNCR
SCRs on 2 units
SCRs on both units
with FGD
No SCR or SNCR
SCRs on 3 units
SCRs on both units
with FGD
SCR on one of the units
with FGD
No SCR or SNCR
SCR on one unit. Will
be installing SCRs on
the other units over the
next three years.
SCR on 1 unit
SCRs on both units
with FGD
SCRs on 3 units
Type of FGD Wastewater Treatment
System
Settling pond
Currently installing a settling pond
Settling Pond
Chemical precipitation (lime addition to pH
8.6, ferric chloride, sodium sulfide,
polymer), followed by biological reactor
Chemical precipitation (lime addition to pH
8.1, ferric chloride, polymer), followed by
biological reactor
Chemical precipitation (lime addition to pH
8.9, organosulfide, ferric chloride, polymer)
Polymer addition only; no pH adjustment
Chemical precipitation (lime addition to pH
8, ferrous chloride, polymer)
Chemical precipitation (lime addition to pH
9.0, ferric chloride, polymer)
Chemical precipitation (lime addition to pH
10.7, ferric chloride, polymer)
Chemical precipitation (lime addition to pH
8.5, ferric chloride, polymer)
In process of being installed
Fly Ash
Handling
(wet/dry)
Wet
Wet
Wet
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Dry
Wet
aThe FGD scrubber is a once-through system in which, the gypsum slurry in the scrubber reaction tank is not recycled back through the scrubber, but rather, is continuously discharged.
NA - Not available.
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.
Legend
Plants that were visited by EPA and are not currently scheduled to be sampled
Plants that have been or are scheduled to be sampled during EPA's detailed study
(EPA conducted pre-sampling site visits at each of these plants)
Figure 2. Geographic Distribution of Coal-fired Steam Electric Plants Part of EPA Site
Visit and Sampling Program for the Steam Electric Detailed Study
During the site visits, EPA collected information on plant operations and types of
wastewater management techniques. EPA also used these visits to assess whether the site was
appropriate for sampling. The objectives of these site visits were to:
• Gather general information about the plant's operations;
• Gather process-specific information;
• Gather information on pollution prevention and wastewater
treatment/operations;
• Gather plant-specific information to develop sampling plans; and
• Select and evaluate potential sampling points.
From these visits, EPA selected six facilities as candidates for wastewater
sampling episodes.
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2.2
Wastewater Sampling
EPA is currently conducting a sampling program to characterize raw wastewaters
generated by coal-fired steam electric power plants, as well as evaluate treatment technologies
and best management practices used to reduce pollutant discharges. EPA developed a "generic"
sampling plan3 to provide general sampling procedures and methods EPA and its contractors will
follow when conducting sampling activities. This document, in combination with plant-specific
sampling plans, serves as a guide to the field sampling crew, and provides a source of procedural
information for plant personnel.
EPA is in the process of collecting and analyzing samples to characterize
wastewater streams generated at six coal-fired steam electric power plants. Specifically, EPA is
characterizing wastewater streams associated with wet FGD systems and ash handling
operations, and evaluating the capability of various types of treatment systems to remove metals
prior to discharge. See Table 2 for information on the plants selected as part of the sampling
program and Figure 2 for the geographic distribution of coal-fired steam electric plants that were
sampled.
Table 2. Summary of Steam Electric Detailed Study Sampling Program
Site
I
E
C
K
L
F
Episode
No.
6547
6548
6549
6550
6551
6546
Date of Sample
Episode
July 2007
August 2007
September 2007
Episode has not yet
occurred
Episode has not yet
occurred
Episode has not yet
occurred
Samples Planned for Collection
FGD
Influent
X
X
X
X
X
In-Process
X
X
X
Effluent
X
X
X
X
X
Ash Pond
Influent
X
(fly + bottom)
X
(fly ash)
Effluent
X
(bottom ash)
X
(fly + bottom)
X
(fly ash + other)
X
(fly ash)
objectives:
Data from the sampling program will be used to support the following study
• Determine the pollutants present in wastewater streams generated by or
associated with air pollution controls (e.g., wet scrubber FGD units,
SCR/SNCRNOx controls, wet ash handling systems);
• Characterize the treatment performance of steam electric wastewater
treatment systems;
Generic Sampling and Analysis Plan for Coal-Fired Steam Electric Power Plants (DCN 04296), dated 6/1/2007.
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• Evaluate the effectiveness of treatment systems at reducing discharges of
metals;
• Characterize the pollutants ultimately discharged to surface water from
steam electric plants; and
• Depending on available information, determine the contribution of the
pollutants from FGD wastewaters and ash handling to the overall pollutant
load discharged from steam electric plants.
The steam electric sampling and analysis program consists of one- to two-day
sampling at selected plants. The sampling activities will characterize the FGD and ash handling
wastewaters, and the performance of the systems used to treat these wastes. EPA has prepared or
is preparing site-specific sampling plans for each location, including discussions of the specific
sample points, the sample collection methods to be used, and the field quality control (QC)
samples to be collected (consisting of bottle blanks, field blanks, equipment blanks, duplicate
samples, and laboratory QC samples used for matrix spike/matrix spike duplicate analyses and
serial dilutions).
Table 3 presents the analytes identified by EPA as analytes of interest for the
wastewater sampling program. The analytes selected for analysis reflect the current
understanding of coal-fired power plant wastewaters, including contributions from coal, scrubber
sorbents, treatment chemicals, and other sources. EPA is also collecting samples that will be
analyzed by EPA's Office of Research and Development for arsenic and selenium speciation.
EPA's sampling program will provide data to perform an engineering assessment
of the design, operation, and performance of treatment systems at steam electric plants.
Specifically, EPA will collect information regarding system design and day-to-day operation.
The sampling will focus on influent, effluent, and in-process streams for FGD and ash handling
wastewater treatment systems.
During each sampling episode, engineering information will be collected with
regard to design and operation of the plant being sampled. For example, information such as
coal usage, plant capacity, wastewater flow rates, sludge generation rates (if applicable), and
retention times in wastewater treatment process stages. Engineering data collection sheets will
be completed for each plant. This information will be used to determine if the specific design or
operational criteria of the steam electric operations affect the wastewater characteristics.
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Table 3. Summary of Analytes of Interest for Sampling Program
Parameter
Method Number
Classical*
Biochemical Oxygen Demand (BODS)
Total Suspended Solids (TSS)
Total Dissolved Solids (TDS)
Sulfate
Chloride
Ammonia as Nitrogen
Nitrate/Nitrite as Nitrogen
Total Kjeldahl Nitrogen (TKN)
Total phosphorus
Hexane Extractable Material (HEM)
Silica Gel Treated Hexane Extractable Material (SGT-HEM)
SM5210B
SM 2540 D
SM 2540 C
ASTMD5 16-90
SM 4500-C1-C
SM 4500— NH3
SM 4500— NO3
SM 4500— NH3
EPA 365.3 (Rev
B,F(18thed.)
-H
BorC,F(18thed.)
1978)
EPA 1664A
EPA 1664A
Metals
Total metals (27 metals: aluminum, antimony, arsenic, barium,
beryllium, boron, cadmium, calcium, chromium, cobalt, copper, iron,
lead, magnesium, manganese, mercury, molybdenum, nickel,
selenium, silver, sodium, thallium, tin, titanium, vanadium, yttrium,
and zinc)
Dissolved metals (27 metals)
Low-level total metals (11 metals: antimony, arsenic cadmium,
chromium, copper, lead, nickel, selenium, silver, thallium, zinc)
Low-level dissolved metals (11 metals)
Low-level total mercury
Low-level dissolved mercury
Hexavalent chromium
Low-level hexavalent chromium
EPA 200.7, 200.
EPA 200.7, 200.
8, 200.9, 245.2
8, 200.9, 245.2
EPA 1638
EPA 1638
EPA 1631
EPA 1631
ASTMD 1687-92
EPA 1636
2.3
Data Request
EPA collected information about coal-fired steam electric plants by means of the
Data Request for the Steam Electric Power Generating Industry 4 ("data request"), issued under
authority of Section 308 of the Clean Water Act.
EPA selected nine companies to receive the data request based on specific
characteristics of plants they operate. Each company operates one or more coal-fired power
plants that were in operation in 2006 and have one or more of the following characteristics: wet
FGD systems (either operating or planned installations) or wet fly ash handling systems. EPA
distributed the data request to these nine power companies in May 2007 and received data
request responses in August and October 2007.
1 Data Request for the Steam Electric Power Generating Industry (DCN 04322), dated 05/07/2007.
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The data requests were divided into two parts: Part A, General Power Company
Information; and Part B, Power Plant Technical Information. Part A requested the following:
company contact information; corporate structure information; and profile information for the
coal-fired steam electric plants that the companies currently operate and that were in operation
during 2006.
EPA requested that the power companies complete Part B of the data request for
each coal-fired steam electric plant they operate that meets the following criteria: was in
operation in calendar year 2006; and operates at least one wet scrubber and/or is currently
constructing/installing (or plans to begin constructing prior to December 31, 2010) at least one
wet scrubber. Part B contains the following seven sections:
• Section 1: General Plant Information;
• Section 2: Steam Electric Power Production;
• Section 3: Fuels Used;
• Section 4: Process Wastewater Generation from Coal-fired Steam Electric
Units;
• Section 5: Wastewater Discharge and Treatment Operations;
• Section 6: Wastewater Treatment Costs; and
• Section 7: Monitoring Data.
Section 1 (General Plant Information) requested plant address and contact
information. Sections 2 and 3 (Steam Electric Power Production; Fuels Used) requested steam
electric power production information and fuels used for each steam electric unit that the plant
operated in 2006.
Section 4 (Process Wastewater Generation from Coal-fired Steam Electric Units)
requested wastewater generation information, including flow rate data, for the following
wastewaters: coal pile runoff; coal pulverizer waste streams; wastewaters from ash handling and
air pollution control systems (FGD, SCR/SNCR, and enhanced mercury air controls); and
cooling water.
Section 5 (Wastewater Discharge and Treatment Operations) requested
information on the operations of each wastewater treatment system at each plant and the
associated wastewater flow rates; flow rates for untreated wastewaters; and a diagram for each
plant including all coal-fired steam electric process operations, wastewater treatment systems,
and treated and untreated flows. Section 6 (Wastewater Treatment Costs) requested operation
and maintenance (O&M) cost data for each wastewater treatment system operated in 2006; and
capital cost data for each FGD wastewater treatment system constructed between January 01,
1997 and December 31, 2006.
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Section 7 (Monitoring Data) requested monitoring data for coal-fired steam
electric wastewater steams that the plant collected for any reason during 2006 that meets certain
sample location and analyte criteria.
In developing the data request, EPA worked with industry trade associations and
other EPA program offices to develop questions that addressed the needs of the detailed study,
while minimizing respondent burden.
Table 4 contains preliminary information about the coal-fired steam electric plants
operated by the data request recipient companies. EPA obtained this information either from the
data request recipients directly (prior to data request completion), or from the plant information
provided by UWAG. As shown in Table 4, EPA received data request information for 30 coal-
fired steam electric plants, all of which are either operating a wet FGD system or are
constructing or planning to begin constructing a wet FGD system by December 31, 2010. Of
these plants, 20 plants operate wet fly ash handling systems and 7 plants operate segregated FGD
wastewater treatment systems. Figure 3 presents the geographic distribution of coal-fired steam
electric plants for which the data request recipients provided information.
Table 4. Preliminary Profile Data of Data Request Recipients
Company
Number
1
2
3
4
5
6
7
8
9
Total
Coal-fired Steam Electric Plants Operated by
Company/Subsidiary
Total3
10
6
16
8
10
3
8
4
2
67
Number
Currently
Operating Wet
FGD Systems3
o
6
i
2
1
1
o
3
2
2
2
17
Number Not Currently
Operating Wet FGD
Systems, But Planning to
Begin Constructing by
12/31/20103
2
1
1
o
J
5
0
1
0
0
13
Plants Covered by the Data Request
Total
5
2
3
4
6
3
3
2
2
30
Number with
Segregated FGD
WWT System
(Operating)11
1
1
1
1
1
0
0
2
Oc
7
Number with
Wet Fly Ash
Systems3
0
1
1
4
6
o
J
3
0
2
20
aData from companies receiving data request.
bData from UWAG plant information; not yet confirmed by review of response to data request.
°Data from initial plant contacts; not yet confirmed by review of response to data request.
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o o
o
•
Legend
O Currently operating one or more wet FGD systems
• Not currently operating wet FGD systems, but planning to begin constructing by 12/31/2010
Figure 3. Geographic Distribution of Coal-fired Steam Electric Plants That Received the
Data Request for Steam Electric Detailed Study
2.4
EPA Interactions with the Utility Water Act Group (UWAG)
The Utility Water Act Group (UWAG) is an association of over 200 individual
electric utilities and four national trade associations of electric utilities: the Edison Electric
Institute, the National Rural Electric Cooperative Association, the American Public Power
Association, and the Nuclear Energy Institute. The individual utility companies operate power
plants and other facilities that generate, transmit, and distribute electricity to residential,
commercial, industrial, and institutional customers. The Edison Electric Institute is the
association of U.S. shareholder-owned electric companies, international affiliates, and industry
associates. The National Rural Electric Cooperative Association is the association of nonprofit
electric cooperatives supplying central station service through generation, transmission, and
distribution of electricity to rural areas of the United States. The American Public Power
Association is the national trade association that represents publicly owned (municipal and state)
electric utilities in 49 states. The Nuclear Energy Institute establishes industry policy on
legislative, regulatory, operational, and technical issues affecting the nuclear energy industry on
behalf of its member companies, which include the companies that own and operate commercial
nuclear power plants in the United States, as well as nuclear plant designers and other
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organizations involved in the nuclear energy industry. UWAG's purpose is to participate on
behalf of its members in EPA's rulemakings under the CWA.
UWAG previously commented on EPA's selection of the steam electric power
generation industry for a detailed study as part of the 2006 Effluent Guidelines Program Plan.
UWAG also provided data during a review of PCS and TRI data to assess national discharge
loadings associated with this industry, as summarized in the Interim Detailed Study Report for
the Steam Electric Power Generating Point Source Category (EPA/821-R-06-015,
November2006). As EPA continued with the detailed study and began formulating approaches
to data collection, EPA held a series of discussions with UWAG to streamline and facilitate the
data collection process. Specifically, EPA communicated with UWAG to collect information on
power plant characteristics to support site visit selection, discuss wastewater sampling
approaches and recommendations, review the data request for clarity, and coordinate data
collection for existing permit data.
2.4.1 Database of Power Plant Information
In preparing for the selection of site visit candidates, EPA assembled available
power plant information from the Department of Energy and EPA's Office of Air and Radiation.
Specifically, EPA was interested in coal-fired power plants that operate wet FGD systems and
have wet ash handling operations. EPA provided UWAG with a list of 96 potential candidates,
which UWAG reviewed and provided information as described in Section 2.1.
In reviewing the information provided by UWAG, EPA determined slightly more
than half of the plants use eastern bituminous coal as the primary source of fuel. Eastern
bituminous coal is generally considered to contribute more pollutants (i.e., metals) to wastewater
streams than other types of coal. Approximately 10 percent of the plants use Powder River
Basin coal, another approximately 10 percent use lignite coal, and still another approximately 10
percent use subbituminous coal. Almost 60 percent of the FGD systems in the dataset use
limestone as the FGD sorbent and approximately half of the plants are using forced oxidation
systems to produce a calcium sulfate byproduct (gypsum), while the other half are producing a
calcium sulfite byproduct. However, a number of relatively old FGD systems are included in the
UWAG data and, based on communications with industry, EPA believes that the majority of
newly-installed FGD systems will be limestone forced oxidation systems that produce a
commercial-grade gypsum byproduct. No plants were identified as using advanced mercury air
controls.
According to the UWAG data, most of the plants (75 percent) do not treat FGD
wastewater prior to commingling it with other waste streams at the plant. Therefore, the most
reported treatment operation was settling, such as a pond system, to treat the FGD wastewater
prior to discharge from the plant. EPA did identify seven plants in the UWAG dataset that
operate a segregated chemical precipitation system for treating FGD wastewater.
2.4.2 Wastewater Sampling
As discussed in Section 2.2, EPA is conducting a wastewater sampling program to
characterize wastewaters generated by coal-fired power plants, and to evaluate treatment
technologies and best management practices available to reduce pollutant discharges. EPA held
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several meetings with UWAGto discuss various approaches to the sampling program, including
identifying representative sample points, providing comment on the generic sampling and
analysis plan, and providing recommendations on laboratory analyses and potential interferences
(particularly with handling high solids influent samples). UWAG participated in the facility pre-
sampling site visits and provided review and comment on site-specific sampling plans. At the
invitation of the plants being sampled, UWAG also collected split samples during EPA's
sampling episodes.
2.4.3 Data Request
As discussed in Section 2.3, EPA developed a data request to collect information
on coal-fired steam electric plants. EPA provided UWAG an opportunity to review the data
request and to recommend changes to improve the clarity of the questions involved. For
example, UWAG provided input on the industry's definitions of scrubber terminology to ensure
that the respondents would understand the questions that EPA included in the request. A copy of
UWAG's comments on the data request are included in the docket.5
2.4.4 NPDES Form 2C
UWAG and EPA are coordinating efforts to compile selected NPDES Form 2C
data from UWAG's member companies. The NPDES Form 2C is an application for a permit to
discharge wastewater that must be completed by existing industrial facilities (including
manufacturing, commercial, mining and silvicultural operations). This form includes facility
information, data on facility outfalls, process flow diagrams, treatment information, and intake
and effluent characteristics. During EPA's development of the "Data Request for the Steam
Electric Power Generating Industry, " UWAG proposed, as an alternative to the Data Request
including a requirement for plants to collect wastewater samples, to gather current Form 2Cs
from its members and summarize relevant data contained on the forms. While this compilation
of Form 2C data will provide less information than could have been collected for any individual
plant if a sampling requirement had been included as part of the Data Request, EPA believes it is
a reasonable alternative that will provide wastewater characteristics for a broader population of
plants than EPA had contemplated, encompassing a greater variety of plant operations and
characteristics and possibly resulting in a better characterization of the waste streams of interest.
In addition, this approach eases the burden that a sampling requirement would have imposed on
plants responding to the Data Request.
The database will focus on the outfalls of coal-fired facilities that receive either
FGD, ash handling, or coal pile runoff waste streams. Other outfalls - such as separate outfalls
for sanitary sewerage, cooling water, landfill runoff, and other miscellaneous purposes - will not
be included in the database. The database will not include Form 2C information for plants that
do not have either a wet FGD or wet fly ash. For example, if a plant has no wet FGD and it is
known that the only wet ash handling at the plant is for bottom ash sluicing, its information will
not be included in the database.
Comments of the Utility Water Act Group (UWAG) on EPA 's Draft Data Request for the Steam Electric
Generating Industry (DCN 04998), dated 03/23/2007.
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2.5 EPA Interactions with the Electric Power Research Institute (EPRI)
EPRI is a research-oriented trade association for the steam electric industry that
focuses on determining solutions to industry issues or problems. EPRI has extensively studied
wastewater discharges from FGD systems, and provided EPA with reports that summarize the
data collected during several of these studies. EPRI provided EPA with the following reports:
• Flue Gas Desulfurization (FGD) Wastewater Characterization: Screening
Study (DCN 04539);
• EPRI Technical Manual: Guidance for Assessing Wastewater Impacts of
FGD Scrubbers (DCN 04537);
• The Fate of Mercury Absorbed in Flue Gas Desulfurization (FGD)
Systems (DCN 04538);
• Update on Enhanced Mercury Capture by Wet FGD: Technical Update
(DCN 04536); and
• PISCES Water Characterization Field Study, Sites A-G (DCNs 05060-
05065).
The EPRI reports have provided EPA with background information regarding the characteristics
of FGD wastewaters and the sampling techniques used to collect the samples.
In addition, EPRI participated in meetings with EPA and provided comments on
EPA's planned data collection activities, including the data request and the sampling program.
EPRI specifically commented on the sample collection techniques, as well as considerations for
the laboratory analysis of FGD and ash handling wastewaters. EPRI also provided comments on
EPA's Generic Sampling and Analysis Plan for Coal-Fired Steam Electric Power Plants.
2.6 Other Data Collection Activities
EPA is also in the process of contacting vendors and conducting literature
searches to collect additional information on wastewater treatment technology options and
wastewater reuse options for particular waste streams. In addition, EPA is collecting general
information on the cost for coal-fired power plants to install FGD systems, wastewaters
associated with Integrated Gasification Combined Cycle (IGCC) power plants, and is continuing
to investigate the source of boron in wastewaters discharged from nuclear facilities.
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