g 

EPA 821-R-09-008 

Steam Electric Power Generatin

Point Source Category: 

Final Detailed Study Report 

October 2009 
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Final Detailed Study Report Contents 

ii 

CONTENTS 

Page 

EXECUTIVE SUMMARY................................................................................................................... xii 

1. INTRODUCTION AND BACKGROUND OF THE STUDY ..........................................................1-1 

2. DATA COLLECTION ACTIVITIES ........................................................................................2-1 

2.1 Site Visits.............................................................................................................2-2

2.2 Wastewater Sampling ........................................................................................2-10 

2.3 Questionnaire (“Data Request”) ........................................................................2-12 

2.4 EPA and State Sources.......................................................................................2-15 

2.4.1 NPDES Permits and Fact Sheets............................................................2-16 

2.4.2 State Groups and Permitting Authorities ...............................................2-16 

2.4.3 1974 and 1982 Technical Development Documents for the Steam 

Electric Power Generating Point Source Category................................2-16 

2.4.4 CWA Section 316(b) - Cooling Water Intake Structures Supporting 

Documentation and Data........................................................................2-17 

2.4.5 Office of Air and Radiation ...................................................................2-17 

2.4.6 Office of Research and Development....................................................2-18 

2.4.7 Office of Solid Waste and Emergency Response ..................................2-18 

2.5 Interactions with the Utility Water Act Group ..................................................2-18 

2.5.1 Database of Power Plant Information....................................................2-19 

2.5.2 Wastewater Sampling ............................................................................2-19 

2.5.3 Data Request ..........................................................................................2-20 

2.5.4 NPDES Form 2C....................................................................................2-20 

2.6 Interactions with the Electric Power Research Institute (EPRI)........................2-20 

2.7 Department of Energy (DOE)............................................................................2-21 

2.8 Other Sources.....................................................................................................2-22 

2.8.1 Wastewater Treatment Equipment Vendors ..........................................2-22 

2.8.2 U.S. Geological Survey (USGS) COALQUAL Database.....................2-22 

2.8.3 Literature and Internet Searches ............................................................2-22 

2.8.4 Environmental Groups and Other Stakeholders ....................................2-22 

3. STEAM ELECTRIC INDUSTRY PROFILE...............................................................................3-1 

3.1 Overview of the Electric Generating Industry.....................................................3-1 

3.1.1 Demographics of the Electric Generating Industry .................................3-3 

3.1.2 Steam Electric Power Generating Industry..............................................3-4 

3.2 Steam Electric Process and Wastewater Sources...............................................3-12 

3.2.1 Fly Ash and Bottom Ash........................................................................3-15 

3.2.2 Flue Gas Desulfurization .......................................................................3-16 

3.2.3 Selective Catalytic Reduction................................................................3-17 

3.2.4 Condenser Cooling.................................................................................3-18 

3.2.5 Low Volume Wastes..............................................................................3-20 

3.2.6 Metal Cleaning.......................................................................................3-21 

3.2.7 Coal Piles ...............................................................................................3-21 

3.2.8 Landfill Leachate and Runoff ................................................................3-23 
Final Detailed Study Report Contents 

CONTENTS (Continued) 

Page 

iii 

3.2.9 Combined Cycle Generating Units ........................................................3-25 

3.2.10 Integrated Gasification Combined Cycle (IGCC)..................................3-26 

3.2.11 Carbon Capture and Storage ..................................................................3-29 

3.3 Effluent Guidelines for the Steam Electric Power Generating Point Source 

Category.............................................................................................................3-32 

4. FLUE GAS DESULFURIZATION SYSTEMS ...........................................................................4-1 

4.1 Coal-Fired FGD System Statistics.......................................................................4-1 

4.1.1 Current Coal-Fired FGD System Profile .................................................4-1 

4.1.2 Projected Use of FGD Systems at Coal-Fired Plants...............................4-4 

4.2 Process Description and Wastewater Generation ................................................4-7 

4.2.1 Forced Oxidation FGD Systems ..............................................................4-7 

4.2.2 Inhibited Oxidation FGD System ..........................................................4-10 

4.2.3 Other Types of FGD Systems................................................................4-13 

4.3 FGD Wastewater Characteristics.......................................................................4-15 

4.4 FGD Wastewater Treatment Technologies........................................................4-26 

4.4.1 Settling Ponds ........................................................................................4-26 

4.4.2 Chemical Precipitation...........................................................................4-27 

4.4.3 Biological Treatment .............................................................................4-30 

4.4.4 Constructed Wetlands ............................................................................4-33 

4.4.5 Vapor-Compression Evaporation System..............................................4-33 

4.4.6 Design/Operating Practices Achieving Zero Discharge ........................4-36 

4.4.7 Other Technologies under Investigation................................................4-40 

4.4.8 Wastewater Treatment System Use in the Coal-Fired Steam 

Electric Industry.....................................................................................4-43 

4.5 Comparison of FGD Wastewater Control Technologies...................................4-50 

4.6 FGD Pollutant Loads Estimates.........................................................................4-68 

4.6.1 FGD Wastewater Treatment Industry Profile........................................4-68 

4.6.2 Calculation of Loads..............................................................................4-69 

4.6.3 Industry Baseline and Treatment Technology Loads ............................4-70 

5. COAL ASH HANDLING SYSTEMS .......................................................................................5-1 

5.1 Fly Ash Handling Operations ..............................................................................5-1 

5.2 Bottom Ash Handling Operations........................................................................5-3 

5.3 Ash Transport Water Characteristics...................................................................5-5 

5.4 Ash Transport Water Treatment Systems..........................................................5-11 

6. ENVIRONMENTAL ASSESSMENT OF COAL COMBUSTION WASTEWATER ...........................6-1 

6.1 Coal Combustion Wastewater Pollutants.............................................................6-2 

6.2 Coal Combustion Wastewater Interactions with the Environment......................6-7 

6.2.1 Discharges to Surface Waters ..................................................................6-8 

6.2.2 Leaching to Groundwater ......................................................................6-11 

6.2.3 Surface Impoundments and Constructed Treatment Wetlands as 

Attractive Nuisances ..............................................................................6-13 
Final Detailed Study Report Contents 

CONTENTS (Continued) 

Page 

iv 

6.3 Types of Environmental Effects ........................................................................6-13 

6.3.1 Lethal Effects.........................................................................................6-14 

6.3.2 Sublethal Effects ....................................................................................6-15 

6.3.3 Population and Community Effects.......................................................6-16 

6.3.4 Human Health Impacts ..........................................................................6-17 

7. PRELIMINARY INVESTIGATION OF OTHER INDUSTRY SEGMENTS ......................................7-1 

7.1 Alternative-Fueled Steam Electric Plants ............................................................7-2 

7.1.1 Demographic Data for Alternative-fueled Steam Electric Plants............7-3 

7.1.2 Alternative-Fueled Steam Electric Fuel Types and Processes.................7-3 

7.1.3 Summary of NPDES Permit Review .......................................................7-9 

7.2 Industrial Non-Utilities ......................................................................................7-10 

7.2.1 Overview of Industrial Non-Utilities.....................................................7-11 

7.2.2 Demographic Data for Fossil-Fueled Industrial Non-Utilities ..............7-12 

7.2.3 Review of Industrial Non-Utility Discharge Permits.............................7-18 

7.2.4 Contacts with Industrial Non-Utilities...................................................7-20 

7.3 Steam and Air Conditioning Supply Plants .......................................................7-21 

7.3.1 Wastewater Discharge Characterization Data .......................................7-23 

7.3.2 NPDES Permit Review..........................................................................7-23 

7.3.3 Contacts with Steam Supply Companies ...............................................7-26 

7.4 Combination Utility Plants ................................................................................7-27 

7.4.1 Wastewater Discharge Characterization Data .......................................7-28 

7.4.2 NPDES Permit Review..........................................................................7-31 

8. REFERENCES .....................................................................................................................8-1 
Final Detailed Study Report List of Tables 

v 

LIST OF TABLES 

Page 

2-1 Summary of the Detailed Study Site Visits ..................................................................... 2-5 

2-2 Summary of the Detailed Study Sampling Program...................................................... 2-10 

2-3 Analytes Included in the Detailed Study Sampling Program ........................................ 2-11 

2-4 Profile of Coal-Fired Power Plants Operated by Data Request Respondents ............... 2-13 

3-1 Distribution of U.S. Electric Generating Plants by NAICS Code in 2002 ...................... 3-4 

3-2 Distribution of Prime Mover Types for Plants Regulated by the Steam Electric 

Power Generating Effluent Guidelines ............................................................................ 3-7 

3-3 Distribution of Fuel Types Used by Steam Electric Generating Units............................ 3-8 

3-4 Types of Fuel Used by Stand-Alone and Combined Cycle Steam Turbines................. 3-10 

3-5 Distribution of Fuel Types for Combined Cycle Units Regulated by the Steam 

Electric Power Generating Effluent Guidelines............................................................. 3-11 

3-6 Distribution by Size of Steam Electric Capacity, Plants, and Electric Generating 

Units Regulated by the Steam Electric Effluent Guidelines.......................................... 3-12 

3-7 Coal Pile Runoff Generation Reported for the EPA Data Request ............................... 3-22 

3-8 Current Effluent Guidelines and Standards for the Steam Electric Power 

Generating Point Source Category................................................................................. 3-33 

4-1 Scrubbed Coal-Fired Steam Electric Power Generation as of June 2008........................ 4-2 

4-2 Characteristics of Coal-Fired Power Plants with Wet FGD Systems.............................. 4-3 

4-3 Projected Future Use of FGD Systems at Coal-Fired Power Plants................................ 4-5 

4-4 FGD Scrubber Purge Flow Rates................................................................................... 4-16 

4-5 Influent to FGD Wastewater Treatment System Concentrations .................................. 4-19 

4-6 FGD Scrubber Purge Self-Monitoring Data .................................................................. 4-25 

4-7 FGD Wastewater Treatment Systems Identified During EPA’s Detailed Study........... 4-44 

4-8 Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment 

Systems .......................................................................................................................... 4-57 

4-9 Monitoring Data: Pollutant Concentrations in Effluent from Settling Ponds................ 4-64 
Final Detailed Study Report List of Tables 

LIST OF TABLES (Continued) 

Page 

vi 

4-10 Monitoring Data: Pollutant Concentrations in Effluent from Chemical 

Precipitation Systems..................................................................................................... 4-65 

4-11 Monitoring Data: Pollutant Concentrations in Effluent from Biological Treatment 

Systems .......................................................................................................................... 4-67 

4-12 Treatment Technology Loads by Model Plant Size....................................................... 4-70 

5-1 Fly Ash Handling Practices at Plants Included in EPA’s Combined Data Set................ 5-3 

5-2 Bottom Ash Handling Practices at Plants Included in EPA’s Combined Data Set ......... 5-5 

5-3 Fly Ash Transport Water Flow Rates .............................................................................. 5-6 

5-4 Bottom Ash Transport Water Flow Rates from EPA Data Request Responses.............. 5-7 

5-5 Ash Pond Influent Concentrations................................................................................... 5-7 

5-6 Fly Ash Transport Wastewater Treatment Systems at Plants Included in EPA’s 

Combined Data Set ........................................................................................................ 5-12 

5-7 Bottom Ash Transport Wastewater Treatment Systems at Plants Included in 

EPA’s Combined Data Set............................................................................................. 5-13 

5-8 Ponds Containing Coal Combustion Residues .............................................................. 5-14 

5-9 Ash Pond Effluent Concentrations................................................................................. 5-17 

6-1 Selected Coal Combustion Wastewater Pollutants.......................................................... 6-3 

6-2 Number of Documented Cases of Environmental Impacts from Coal Combustion 

Wastewater....................................................................................................................... 6-7 

7-1 Summary of Alternative-Fueled Steam Electric Plants, by Fuel/Energy Source 

Type ................................................................................................................................. 7-4 

7-2 Comparison of Available Coal Ash, Municipal Solid Waste Ash, and Wood Ash 

Composition Data ............................................................................................................ 7-5

7-3 Summary of Fossil-Fueled, Steam Electric Industrial Non-Utilities, 

by NAICS Code in 2005................................................................................................ 7-14 

7-4 Distribution of Prime Mover Types Among Fossil-Fueled, 

Steam Electric Industrial Non-Utilities.......................................................................... 7-16 

7-5 Distribution of Fuel Types Among Fossil-Fueled, Steam Electric Industrial NonUtilities........................................................................................................................... 7-17 
Final Detailed Study Report List of Tables 

LIST OF TABLES (Continued) 

Page 

vii 

7-6 Steam and Air-Conditioning Supply Plants Identified in DMRLoads2007

Database......................................................................................................................... 7-24 

7-7 Combination Utilities Identified in DMRLoads2007 Database..................................... 7-29 
Final Detailed Study Report List of Figures 

viii 

LIST OF FIGURES 

Page 

2-1 Locations of Coal-Fired Power Plants Included in EPA Data Collection Activities 

for the Detailed Study ...................................................................................................... 2-2

2-2 Locations of Coal-Fired Power Plants Included in EPA’s Site Visit and Sampling 

Program............................................................................................................................ 2-4 

2-3 Locations of Coal-Fired Power Plants for which Data Request Respondents 

Provided Technical Information .................................................................................... 2-14 

3-1 Types of U.S. Electric Generating Plants ........................................................................ 3-1 

3-2 Steam Electric Process Flow Diagram........................................................................... 3-13 

3-3 Typical Wet FGD System.............................................................................................. 3-16 

3-4 Diagram of a Recirculating Cooling System ................................................................. 3-18 

3-5 Diagram of Landfill Leachate and Landfill Runoff Generation and Collection............ 3-24 

3-6 Combined Cycle Process Flow Diagram ....................................................................... 3-26 

3-7 Wabash River ConocoPhillips E-GasTM Gasification Process ...................................... 3-28 

3-8 AEP’s Chilled Ammonia Process at Mountaineer Power Station ................................. 3-31 

4-1 Wet FGD Systems at Coal-Fired Power Plants (Current and Projected 2020)................ 4-6 

4-2 Typical Process Flow Diagram for a Limestone Forced Oxidation FGD System........... 4-8 

4-3 Process Flow Diagram for a Lime or Limestone Inhibited Oxidation FGD System..... 4-12 

4-4 Distribution of FGD Scrubber Purge Daily Flow Rates ................................................ 4-17 

4-5 Distribution of FGD Scrubber Purge Normalized Daily Flow Rates ............................ 4-17 

4-6 Process Flow Diagram for a Hydroxide and Sulfide Chemical Precipitation 

System............................................................................................................................ 4-29 

4-7 Process Flow Diagram for an Anoxic/Anaerobic Biological Treatment System .......... 4-31 

4-8 Process Flow Diagram for a Vapor-Compression Evaporation System........................ 4-34 

4-9 Distribution of FGD Wastewater Treatment Systems Among Plants Operating 

Wet FGD Systems.......................................................................................................... 4-47 

4-10 Comparison of Distribution of FGD Wastewater Treatment Systems by Type of 

Oxidation System........................................................................................................... 4-48
Final Detailed Study Report List of Figures 

LIST OF FIGURES (Continued) 

Page 

ix 

4-11 Distribution of FGD Wastewater Treatment Systems Among Plants that 

Discharge FGD Wastewater .......................................................................................... 4-49 

4-12A Concentration of Arsenic in FGD Scrubber Purge and Effluent from Chemical 

Precipitation and Biological Treatment Systems at Belews Creek................................ 4-52 

4-13A Concentration of Arsenic in FGD Scrubber Purge and Effluent from Settling Pond 

and Biological Treatment Systems at Roxboro ............................................................. 4-52 

4-12B Concentration of Arsenic in Effluent from Chemical Precipitation and Biological 

Treatment Systems at Belews Creek.............................................................................. 4-52 

4-13B Concentration of Arsenic in Effluent from Settling Pond and Biological Treatment 

Systems at Roxboro ....................................................................................................... 4-52 

4-12C Concentration of Mercury in FGD Scrubber Purge and Effluent from Chemical 

Precipitation and Biological Treatment Systems at Belews Creek................................ 4-53 

4-13C Concentration of Mercury in FGD Scrubber Purge and Effluent from Settling 

Pond and Biological Treatment Systems at Roxboro .................................................... 4-53 

4-12D Concentration of Mercury in Effluent from Chemical Precipitation and Biological 

Treatment Systems at Belews Creek.............................................................................. 4-53 

4-13D Concentration of Mercury in Effluent from Settling Pond and Biological 

Treatment Systems at Roxboro...................................................................................... 4-53 

4-12E Concentration of Selenium in FGD Scrubber Purge and Effluent from Chemical 

Precipitation and Biological Treatment Systems at Belews Creek................................ 4-54 

4-13E Concentration of Selenium in FGD Scrubber Purge and Effluent from Settling 

Pond and Biological Treatment Systems at Roxboro .................................................... 4-54 

4-12F Concentration of Selenium in Effluent from Chemical Precipitation and 

Biological Treatment Systems at Belews Creek............................................................ 4-54 

4-13F Concentration of Selenium in Effluent from Settling Pond and Biological 

Treatment Systems at Roxboro...................................................................................... 4-54 

4-12G Concentration of TDS in FGD Scrubber Purge and Effluent from Chemical 

Precipitation and Biological Treatment Systems at Belews Creek................................ 4-55 

4-13G Concentration of TDS in FGD Scrubber Purge and Effluent from Settling Pond 

and Biological Treatment Systems at Roxboro ............................................................. 4-55 

4-14 Estimated Industry-Level FGD Effluent Discharge Loadings By Treatment 

Scenario.......................................................................................................................... 4-71 
Final Detailed Study Report Acronyms 

x 

ACRONYMS 

AEP American Electric Power 

API American Petroleum Institute 

ASTM American Society for Testing and Materials 

BAT Best available technology economically achievable 

BOD5 Biochemical oxygen demand (5-day) 

BPJ Best Professional Judgment 

BPT Best practicable control technology currently available 

CaCO3 Limestone 

Ca(OH)2 Lime 

CaSO3 Calcium sulfite 

CaSO4 Calcium sulfate 

CaSO4 • 2H2O Gypsum 

CCR Coal combustion residues 

CFR Code of Federal Regulations 

CO Carbon monoxide 

CO2 Carbon dioxide 

COD Chemical oxygen demand 

COS Carbonyl sulfide 

CPO Chlorine-produced oxidants 

CWA Clean Water Act 

CWTS Constructed wetland treatment system 

DBA Dibasic acid (a mixture of glutaric, succinic, and adipic acid) 

DCN Document control number 

DMR Discharge Monitoring Report 

DOE Department of Energy 

DRC Dynamic reaction cell 

EIA Energy Information Administration 

EPA Environmental Protection Agency 

EPRI Electric Power Research Institute 

ESP Electrostatic precipitator 

FGD Flue gas desulfurization 

gpd Gallons per day 

gpm Gallons per minute 

gpy Gallons per year 

H2 Hydrogen 

H2S Hydrogen sulfide 

HEM Hexane Extractable Material 

HEROTM High-efficiency reverse osmosis 

HG-AFS Hydride generation and atomic fluorescence spectrometry 

HRSG Heat recovery steam generator 

ICIS Integrated Compliance Information System 

IGCC Integrated gasification combined cycle 

IPM Integrated Planning Model 

MCL Maximum contaminant level 

MDEA Methyldiethanolamine 

mgd Million gallons per day 
Final Detailed Study Report Acronyms 

xi 

MSW Municipal solid waste 

MW Megawatt 

N2 Nitrogen 

Na2CO3 Sodium carbonate

NAICS Northern American Industry Classification System 

NEEDS National Electric Energy Data System 

NETL National Energy Technology Laboratory 

NH3 Ammonia 

(NH4)2SO4 Ammonium sulfate 

NH4HSO4 Ammonium bisulfate 

NPDES National Pollutant Discharge Elimination System 

NO Nitrogen monoxide 

NO2 Nitrogen dioxide 

NOx Nitrogen oxides 

NSPS New source performance standards 

OAP Office of Atmospheric Programs 

OAQPS Office of Air Quality Planning and Standards 

OAR Office of Air and Radiation 

OECA Office of Enforcement and Compliance Assistance 

ORCR Office of Resource Conservation and Recovery 

ORD Office of Research and Development 

ORSANCO Ohio River Valley Water Sanitation Commission 

OSWER Office of Solid Waste and Emergency Response 

OW Office of Water 

PCS Permit Compliance System 

PPM Parts per million 

PSES Pretreatment standards for existing sources 

PSNS Pretreatment standards for new sources 

SBR Sequencing batch reactor 

SCR Selective catalytic reduction 

SIC Standard Industrial Classification 

SGT-HEM Silica Gel Treated Hexane Extractable Material 

SNCR Selective non-catalytic reduction 

SO2 Sulfur dioxide 

SO3 Sulfur trioxide 

TDS Total dissolved solids 

TKN Total Kjeldahl nitrogen 

TMT Trimercapto-s-triazine 

TRI Toxics Release Inventory 

TRO Total residual oxidants 

TSS Total suspended solids 

TVA Tennessee Valley Authority 

TWF Toxic weighting factor 

TWPE Toxic-weighted pound equivalent 

USGS U.S. Geological Survey 

UWAG Utility Water Act Group 
Final Detailed Study Report Executive Summary 

EXECUTIVE SUMMARY

This report summarizes the information collected and analyzed by the United States 

Environmental Protection Agency (EPA) to review discharges from the steam electric power 

generating industry and to determine whether the current effluent guidelines for this industry 

should be revised. EPA’s detailed study of wastewater discharges and treatment technologies 

associated with this industry evaluated a range of waste streams and processes. However, the 

study ultimately focused largely on discharges associated with coal ash handling operations and 

wastewater from flue gas desulfurization (FGD) air pollution control systems because these 

sources comprise a significant fraction of the pollutants discharged by steam electric power 

plants. In this report, EPA provides an overview of the steam electric power generating industry 

and its wastewater discharges, and the data collection activities and analyses conducted over the 

course of EPA’s detailed study. 

The scope of the study included plants covered by the Steam Electric Power Generating 

effluent guidelines (40 CFR Part 423), which is a subset of the entire electric generating industry. 

The Steam Electric Power Generating effluent guidelines apply to wastewater discharges from 

plants primarily engaged in the generation of electricity for distribution and sale which results 

primarily from the use of nuclear or fossil fuels in conjunction with a steam-water 

thermodynamic cycle. During the study, EPA collected data about the industry by performing the 

following activities: conducting site visits and wastewater sampling episodes at steam electric 

power plants, distributing a questionnaire to collect data from nine companies (30 coal-fired 

power plants), reviewing publicly available sources of data, and coordinating with EPA program 

offices, other government organizations (e.g., state groups and permitting authorities), and 

industry and other stakeholders. 

EPA evaluated several waste streams generated at power plants, including wastewaters 

from wet FGD systems, fly ash and bottom ash handling, coal pile runoff, condenser cooling, 

equipment cleaning, and leachate from landfills and impoundments. Additionally, EPA reviewed 

information on integrated gasification combined cycle (IGCC) and carbon capture technologies. 

Wastewaters from flue gas mercury control systems (i.e., when the dry mercury capture residues 

are transported by a wet fly ash handling system to ash ponds) and regeneration of the catalysts 

used for Selective Catalytic Reduction (SCR) NOx controls were identified as potential new 

waste streams that warrant attention; however, EPA was not able to obtain characterization data 

for these wastes. 

The use of wet FGD systems to control SO2 emissions has increased significantly since 

the effluent guidelines were last revised in 1982 and is projected to increase substantially in the 

next decade as power plants take steps to address federal and state air pollution control 

requirements. FGD wastewaters generally contain significant levels of metals, including 

biaccumulative pollutants such as arsenic, mercury, and selenium. The FGD wastewaters also 

contain significant levels of chloride, total dissolved solids (TDS), total suspended solids (TSS), 

and nutrients. EPA identified and investigated technologies for treating FGD wastewaters, 

including settling ponds, chemical precipitation systems, biological treatment systems (anaerobic 

and aerobic), constructed wetlands, vapor-compression evaporation systems, and other 

technologies under investigation. From information collected during the study, EPA determined 

that settling ponds are the most commonly used treatment system for managing FGD wastewater. 

These ponds can be effective at removing suspended solids and those metals present in the 

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Final Detailed Study Report Executive Summary 

xiii 

particulate phase from FGD wastewater; however, they are not effective at removing dissolved 

metals. Other treatment systems, such as chemical precipitation and certain biological treatment 

systems, are demonstrated to be effective at removing certain dissolved metals from FGD 

wastewater. EPA also identified operating/management practices and treatment technologies that 

are used to reduce the discharge of FGD wastewater, and in some cases, eliminate the discharge 

completely. 

Coal-fired power plants may manage bottom ash and fly ash using either wet or dry 

handling techniques. For wet handling systems, the plants typically sluice the fly ash and/or 

bottom ash to a surface impoundment or settling pond where most of the solids settle out of the 

water. Some plants recycle a portion or all of the settled ash pond effluent, but most plants 

discharge the pond overflow. Untreated ash transport waters contain significant concentrations of 

TSS and metals. The treated effluent from ash ponds generally contains low concentrations of 

TSS; however, metals are still present in the wastewater, predominantly in dissolved form. 

 Most of the newer electric generating units operate dry fly ash handling systems because 

of new source performance standards that require “... no discharge of wastewater pollutants 

from fly ash transport water.” [40 CFR Part 423.15] These dry fly ash handling systems use a 

vacuum or blower to transport the fly ash to a storage silo where it is typically sold for beneficial 

use or landfilled. The dry bottom ash handling process typically consists of collecting the bottom 

ash in a quench water bath and conveying it out of the boiler to a dewatering pile. 

FGD and ash transport wastewaters, as well as other coal combustion wastewaters, 

contain pollutants that can have detrimental impacts to the environment. EPA reviewed publicly 

available data to identify documented cases where environmental impacts were attributable to 

releases from surface impoundments or landfills containing coal combustion residues. EPA 

determined that there are a number of pollutants present in wastewaters generated at coal-fired 

power plants that can impact the environment, including metals (e.g., arsenic, selenium, 

mercury), TDS, and nutrients. The primary routes by which coal combustion wastewater impacts 

the environment are through discharges to surface waters, leaching to ground water, and by 

surface impoundments and constructed wetlands acting as attractive nuisances that increase 

wildlife exposure to the pollutants contained in the systems. EPA found the interaction of coal 

combustion wastewaters with the environment has caused a wide range of environmental effects 

to aquatic life. 

As part of the study, EPA also investigated other electric power and steam generating 

activities that are similar to the processes regulated for the Steam Electric Power Generating 

Point Source Category, but which are not subject to the effluent guidelines. Such activities 

include electric generating units fueled by non-fossil or non-nuclear fuels (e.g., municipal solid 

waste, biomass), electric generating units at industrial facilities (e.g., chemical plants, petroleum 

refineries), plants that produce steam for distribution and/or sale but do not generate electric 

power, and facilities that provide a combination of electric power and other utility services. EPA 

compared the volume and characteristics of wastewaters generated by these activities to the 

plants regulated by the Steam Electric effluent guidelines and determined that these processes 

may generate similar types of wastewaters in terms of pollutants present; however, the volume of 

the wastewaters generated are much smaller than those generated at plants regulated by the 

effluent guidelines. 
Final Detailed Study Report Chapter 1 – Introduction and Background of the Study 

1. INTRODUCTION AND BACKGROUND OF THE STUDY

This report summarizes the information collected and analyzed by the United States 

Environmental Protection Agency (EPA) to review discharges from steam electric power 

generating facilities and to determine whether the current wastewater discharge regulations for 

these operations should be revised. EPA’s review of wastewater discharges and treatment 

technologies evaluated a range of waste streams and processes, but has focused primarily on coal 

ash ponds and wastewater from flue gas desulfurization (FGD) air pollution control systems 

because these sources comprise a significant fraction of the pollutants discharged by steam 

electric power plants. In this report, EPA provides an overview of the steam electric power 

generating industry and its wastewater discharges, and the data collection activities and analyses 

conducted over the course of the study. Much of the information in this report is associated with 

the processes, wastewaters, and pollution controls for fly ash, bottom ash, and FGD wastes. 

The Steam Electric Power Generating effluent limitations guidelines and standards 

(referred to in this report as “effluent guidelines”) apply to a subset of the electric power 

industry, namely those plants “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.” The effluent guidelines are codified in the Code of Federal 

Regulations (CFR) at Title 40, Part 423 (40 CFR Part 423). EPA’s most recent revisions to the 

effluent guidelines for this industry sector were promulgated in 1982 (see 47 Fed. Reg. 52290; 

November 19, 1982). 

EPA is required by section 304 of the Clean Water Act (CWA) to periodically review all 

effluent guidelines to determine whether revisions are warranted. In addition, section 304(m) of 

the CWA requires EPA to develop and publish a biennial plan that establishes a schedule for the 

annual review and revision of national effluent guidelines required by section 304(b) of the 

CWA. EPA last published an Effluent Guidelines Program Plan in 2008 [73 Fed. Reg. 53218; 

September 15, 2008], in which EPA discussed the status of the detailed study of the steam 

electric power generating industry. 

EPA first identified this industry for study during the 2005 annual review of effluent 

guidelines. At that time, publicly available data reported through the National Pollutant 

Discharge Elimination System (NPDES) permit program and the Toxics Release Inventory (TRI) 

indicated that this industry ranked high in discharges of toxic and nonconventional pollutants 

[U.S. EPA, 2005b]. Because of these findings, EPA initiated a more detailed study of this 

category to determine if the effluent guidelines should be revised. 

During the detailed study, EPA investigated whether pollutant discharges reported under 

these programs accurately reflected current discharges for the Steam Electric Power Generating 

Point Source Category, including those associated with recent process and technology changes 

being implemented by the industry. 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 effluent 

guidelines. EPA found that the existing publicly available data were insufficient to fully evaluate 

the industry’s discharges. To fill these data gaps, EPA collected information on wastewater 

characteristics and treatment technologies through site visits, wastewater sampling, a data 

1-1 
Final Detailed Study Report Chapter 1 – Introduction and Background of the Study 

request that was sent to a limited number of companies, and various secondary data sources (see 

Chapter 2 for more detail about data collection activities). 

EPA focused efforts for these data collection activities on certain discharges from coalfired steam electric power plants (referred to in this report as “coal-fired power plants"). 

Specifically, these activities focused on: (1) characterizing the mass and concentrations of 

pollutants in wastewater discharges from coal-fired power plants; (2) identifying the pollutants 

that comprise a significant portion of the category's toxic-weighted pound equivalent (TWPE) 

discharge estimate and the corresponding industrial processes responsible for the release of these 

pollutants; and (3) evaluating process changes and treatment technologies available for reducing 

these pollutant discharges. EPA's review determined that most of the toxic loadings for this 

category are associated with metals and certain other constituents, such as selenium, present in 

wastewater discharges, and that the waste streams contributing the majority of these pollutants 

are associated with ash handling and wet FGD systems. Other potential sources of these 

pollutants include coal pile runoff, metal cleaning wastes, coal washing, leachate from landfills 

and wastewater impoundments, and certain low-volume wastes. 

EPA evaluated pollution prevention practices and reviewed examples of water 

recycle/reuse to identify opportunities to address water quality and water quantity issues. 

Information was compiled for wastewaters generated by emerging technologies such as carbon 

capture/sequestration and coal gasification. 

EPA also assessed available information on plants that are not currently regulated by the 

Steam Electric Power Generating effluent guidelines but that use a steam cycle to generate 

electricity, such as steam electric generating units at industrial facilities and plants that use nonfossil and non-nuclear fuel. Examples of such fuels include wood wastes, landfill methane, and 

municipal solid wastes. 

Throughout the study, EPA’s Office of Water (OW) coordinated efforts with ongoing 

research and activities being undertaken by other EPA offices, including the Office of Research 

and Development (ORD), the Office of Solid Waste and Emergency Response (OSWER), and 

the Office of Air and Radiation (OAR), specifically the Office of Air Quality Planning and 

Standards (OAQPS) and the Office of Atmospheric Programs (OAP). EPA also exchanged 

information with state NPDES permitting authorities about the characteristics of power plant 

wastewater, the availability and implementation of treatment technologies, and water quality 

concerns. 

This report, Steam Electric Power Generating Point Source Category: Final Detailed 

Study Report (EPA-821-R-09-008; DCN 06390), documents the data and information that EPA 

has collected over the course of the detailed study. For additional information about the 

progression of the detailed study since its inception, see the interim reports supporting the 2006 

and 2008 Effluent Guidelines Program Plans: the Interim Detailed Study Report for the Steam 

Electric Power Generating Point Source Category (EPA-821-R-06-015; November 2006) [U.S. 

EPA, 2006e] and the Steam Electric Power Generating Point Source Category: 2007/2008 

Detailed Study Report (EPA-821-R-08-011; DCN 05516) [U.S. EPA, 2008e], respectively. 

1-2 
Final Detailed Study Report Chapter 1 – Introduction and Background of the Study 

1-3 

This report is organized into the following chapters: 

• Chapter 2 discusses the data sources used in the detailed study; 

• Chapter 3 presents a profile of the steam electric power generating industry, 

including demographic data, a discussion of the steam electric process and 

wastewaters generated, and a discussion of the Steam Electric Power Generating 

effluent guidelines; 

• Chapter 4 discusses FGD operations at coal-fired power plants, specifically their 

current use in the industry, their operating characteristics and wastewater 

generation, potential control technologies for FGD wastewater, and EPA’s 

pollutant load estimates associated with the discharge of FGD wastewaters; 

• Chapter 5 discusses ash handling operations at coal-fired power plants, the 

wastewater generated, and ash wastewater treatment; 

• Chapter 6 discusses the environmental effects of coal combustion wastewaters; 

• Chapter 7 discusses plants and processes that are not regulated by the Steam 

Electric Power Generating effluent guidelines, but that use a steam cycle to 

generate electricity; and 

• Chapter 8 presents the references cited in this report. 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

2. DATA COLLECTION ACTIVITIES

EPA collected and evaluated information from various sources in the course of 

conducting the detailed study of the steam electric power generating industry. EPA used these 

data to develop an industry profile, determine wastewater characteristics and potential pollution 

control technologies, review the potential pollutant load reductions and costs associated with 

certain treatment technologies, and review environmental impacts associated with discharges 

from this industry. This section discusses the following data collection activities: 

• Site visits, including the site selection process, characteristics of the sites visited, 

and their locations; 

• Wastewater sampling, including information about and the locations of plants 

sampled, types of samples collected, analytes included in the sampling program, 

and analytical methods used; 

• Industry questionnaire, including the characteristics and location of plants 

responding to the questionnaire, and a description of the data request instrument; 

• Coordination and informal consultations with EPA program offices, EPA regional 

offices, and state permitting agencies, including information collected from 

Agency databases; 

• Interactions with UWAG, including input from and coordination with UWAG on 

sampling, site visits, and other data; 

• Interactions with EPRI, including input from EPRI on EPA’s wastewater 

sampling and questionnaire activities; 

• Use of Department of Energy (DOE) data, including the use of data collected by 

the Energy Information Administration; and 

• Other data sources. 

As described in Chapter 1, EPA focused most efforts for the detailed study on certain 

discharges from coal-fired power plants, including FGD system wastes and ash handling wastes. 

Figure 2-1 shows the locations of coal-fired power plants at which EPA conducted site visits, 

collected samples of wastewater, or obtained technical information via the questionnaire. 

2-1 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

Figure 2-1. Locations of Coal-Fired Power Plants Included in EPA Data Collection 

Activities for the Detailed Study 

2.1 Site Visits

EPA conducted a site visit program to gather information on the types of wastewaters 

generated by coal-fired power plants, and the methods of managing these wastewaters to allow 

for recycle, reuse, or discharge. EPA focused data gathering activities primarily on FGD 

wastewater treatment and management of ash transport water because the FGD and ash transport 

water stream are the primary sources of metal discharges from the industry. EPA conducted 34 

site visits at steam electric power generating plants in 14 states between December 2006 and 

April 2009. 

The purpose of the site visits was to collect information about each site’s electric 

generating processes, wastewater management practices and treatment technologies, and to 

evaluate each plant for potential inclusion in the sampling program. To identify potential 

candidate plants for visits, EPA began by compiling a list of U.S. coal-fired power plants 

believed to operate wet FGD systems, based on information from EPA’s Office of Air and 

Radiation and data provided by the Utility Water Act Group. EPA used the Utility Water Act 

Group data in conjunction with information from other sources, including publicly available 

plant-specific information and state and regional permitting authorities. 

2-2 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

2-3 

From its data collection activities, EPA identified 108 plants that as of June 2008 were 

operating one or more wet FGD systems.1

EPA considered the following characteristics to select plants for site visits (not listed in 

any priority order): 

• Coal-fired boilers; 

• Type of coal; 

• Wet FGD system, including: 

— Type of scrubber, 

— Sorbent used, 

— Year operation began, 

— Chemical additives used, 

— Forced oxidation process, 

— Water cycling, and 

— Solids removal process. 

• FGD wastewater treatment system; 

• Selective catalytic reduction (SCR) and/or selective non-catalytic reduction 

(SNCR) NOx controls; 

• Ash handling systems; 

• Ash treatment system; and 

• Advanced flue gas mercury controls. 

Using these characteristics, EPA identified plants to contact in order to obtain more 

detailed information about their operations. From the information obtained during these contacts, 

EPA selected plants for site visits. Plant conditions, such as type of FGD system and whether 

target waste streams are segregated or commingled with other wastes, influenced the plant 

selection process. 

The specific objectives of these site visits were to: 

• Gather general information about each plant’s operations; 

• Gather information on pollution prevention and wastewater treatment/operations; 

• Gather plant-specific information to develop sampling plans; and 

• Select and evaluate potential sampling points. 

 

1

 See the memorandum in the docket entitled “Development of the Current and Future Industry Profile for the Steam 

Electric Detailed Study,” dated 10/9/2009 [ERG, 2009r] for details on the development of this list. The total number 

of plants operating wet FGD systems is dynamic; additional plants have started operating FGD systems since EPA 

compiled this profile or are currently in the process of installing FGD systems. 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

Based on information obtained during these site visits, EPA selected six plants for 

wastewater sampling episodes, which are discussed further in Section 2.2. 

Table 2-1 presents information on the characteristics of each plant visited during the site 

visit program. The geographic distribution of these plants is illustrated by the map in Figure 2-2. 

Figure 2-2. Locations of Coal-Fired Power Plants Included in EPA’s Site Visit and 

Sampling Program 

2-4 
Final Detailed Study Report Chapter 2 – 

Table 2-1. Summary of the Detailed Study Site Visits 

Plant Name 

Location 

(Reference) 

Month/Year of 

Site Visit Coal Type FGD System a 

Year FGD 

Began 

Operation 

SCR/SNCR 

NOx Control

Type of FGD W

Treatment 

Yates 

Georgia 

[ERG, 2007f] 

December 2006 Eastern Bituminous Jet-bubbling reactor, limestone 

forced oxidation, no additives (1 unit) 

1992 No SCR or 

SNCR 

Settling pond 

Wansley 

Georgia 

[ERG, 2007e]

December 2006 Eastern Bituminous Installation in progress during 

site visit 

NA SCRs on 2 

units 

Visited prior to insettling pond 

Widows Creek 

Alabama 

[ERG, 2007h; ERG, 

2007k] 

December 2006 Eastern Bituminous Spray tower, limestone forced 

oxidation b, no additives (2 

units) 

1977 and 

1981 

SCRs on both units with FGD 

Settling pond 

Conemaugh 

Pennsylvania 

[ERG, 2007l] 

February 2007 Eastern Bituminous Spray tower, limestone forced 

oxidation, dibasic acid additive (2 units) 

1994 and 

1995 

No SCR or SNCR 

Chemical precipitaddition, ferric chsodium sulfide, pofollowed by aerobbatch reactors 

Homer City 

Pennsylvania 

[ERG, 2007i; ERG, 

2007j] 

February 2007 Eastern Bituminous Spray tower, limestone forced 

oxidation, formic acid additive (1 unit) 

2001 SCRs on 3 

units 

Chemical precipitaddition, ferric chpolymer), followebiological reactor 

Pleasant Prairie 

Wisconsin 

[ERG, 2007d] 

April 2007 Subbituminous 

(Powder River Basin) 

Spray tower, limestone forced oxidation, no additives (2 units) 

2006 and 

2007 

SCRs on both units with FGD 

Chemical precipitaddition, organosuchloride, polymer

Bailly 

Indiana 

[Hall, 2007] 

April 2007 Bituminous (75%), 

Eastern Bituminous (25%) 

Spray tower, limestone forced oxidation, no additives (2 units) 

1992 SCR on one 

of the units with FGD 

Polymer addition adjustment 

Seminole 

Florida 

[Jordan, 2007] 

April 2007 Eastern Bituminous, 

also burns petroleum coke as a small percentage (up to 30%) 

Spray tower, limestone forced oxidation, dibasic acid additive (2 units) 

1984 No SCR or 

SNCR 

Chemical precipitaddition, ferrous cpolymer) 

Big Bend 

Florida 

[ERG, 2007b; ERG, 

2007g] 

April 2007 Eastern Bituminous, 

also burns petroleum coke as a small percentage (typically 1-2%; 5% maximum) 

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 

1985 

(double 

loop) and 

2000 

(spray 

tower) 

SCR on one unit; will install SCRs on the other units over the next 3 years 

Chemical precipitaddition, ferric chpolymer) 

2-5 
Final Detailed Study Report Chapter 2 – 

2-6 

Table 2-1. Summary of the Detailed Study Site Visits 

Plant Name 

Location 

(Reference) 

Month/Year of 

Site Visit Coal Type FGD System a 

Year FGD 

Began 

Operation 

SCR/SNCR 

NOx Control

Type of FGD W

Treatment 

Cayuga 

New York 

[Jordan, 2008b] 

May 2007 Eastern Bituminous Spray tower, limestone forced 

oxidation, formic acid additive (2 units) 

1995 SCR on 1 unit Chemical precipit

addition, ferric chpolymer) 

Mitchell 

West Virginia 

[ERG, 2007o] 

May 2007 Eastern Bituminous Spray tower, limestone forced 

oxidation, no additives (2 units) 

NA SCRs on both 

units with FGD 

Chemical precipitaddition, ferric chpolymer) 

Cardinal 

Ohio 

[ERG, 2007n] 

May 2007 Subbituminous Installation in progress during 

site visit 

NA SCRs on 3 

units 

Currently being in

Bruce Mansfield 

Pennsylvania 

[U.S. EPA, 2008d] 

October 2007 Bituminous Venturi scrubber, magnesiumenhanced lime, inhibited 

oxidation (2 units); horizontal spray scrubber, magnesiumenhanced lime, inhibited oxidation (1 unit); additional forced oxidation as separate process for all 3 units 

1976, 

1977, and 

1980 

SCRs on 3 units 

Surface impoundm

Roxboro 

North Carolina 

[Jordan, 2008a] 

March 2008 Eastern Bituminous Tray tower, limestone forced 

oxidation, no additive (2 units operating, 2 more units planned for 2008) 

2007 and 

2008) 

SCRs on 4 units 

Settling pond folloanaerobic/anoxic btreatment system fmetals and nutrien

Belews Creek 

North Carolina 

[ERG, 2008h] 

March 2008 Eastern Bituminous Spray tower, limestone forced 

oxidation (1 unit operating, 1 more unit planned for 2008) 

2008 SCRs on 2 

units 

Chemical precipitfollowed by anaerbiological treatmeremoval of metals followed by a conwetland treatment 

Marshall 

North Carolina 

[ERG, 2008i] 

March 2008 Eastern Bituminous, 

additionally burns a small percentage of South American coal (2%) 

Spray tower, limestone forced oxidation. (3 scrubbers for 4 units) 

2006 and 

2007 

SNCRs on 4 units 

Clarifier followed constructed wetlansystem 

Mount Storm 

West Virginia 

[ERG, 2008p] 

September 2008 Bituminous Spray tower, limestone forced 

oxidation, no additives (3 units) 

1995 and 

2002 

SCRs on 3 units 

No FGD wastewadischarged; FGD landfilled (leachatlandfill treated by ponds and dischar
Final Detailed Study Report Chapter 2 – 

2-7 

Table 2-1. Summary of the Detailed Study Site Visits 

Plant Name 

Location 

(Reference) 

Month/Year of 

Site Visit Coal Type FGD System a 

Year FGD 

Began 

Operation 

SCR/SNCR 

NOx Control

Type of FGD W

Treatment 

Harrison 

West Virginia 

[ERG, 2009c] 

September 2008 Eastern Bituminous Spray tower, magnesiumenhanced lime inhibited 

oxidation (2 units); emulsified sulfur added 

1994 SCRs on 3 

units 

No FGD wastewadischarged; FGD landfilled (leachatportion of FGD lainto settling ponds from unlined portilandfill is transferconstructed wetlansystem and then d

Mountaineer 

West Virginia 

[ERG, 2009u] 

September 2008 Eastern Bituminous Spray tower, limestone forced 

oxidation, no additives (1 unit) 

2007 SCR on 1 unit Chemical precipit

addition, polymerchloride) 

Gavin 

Ohio 

[ERG, 2009b] 

September 2008 Eastern Bituminous Spray tower, magnesiumenhanced lime inhibited 

oxidation (2 units); emulsified sulfur added 

1994 and 

1995 

SCRs on 2 units 

No FGD wastewadischarged; FGD landfilled (leachatlandfill collected iponds and dischar

Deely 

Texas 

[ERG, 2009o] 

October 2008 NA Considering dry and limestoneforced oxidation wet scrubbers 

(2 units) 

Planned 

for 2012 

and 2013 

SCRs planned on 2 units by 2015 

To be determined 

Clover 

Virginia 

[ERG, 2009d] 

October 2008 Eastern Bituminous Spray tower, limestone forced 

oxidation (2 units) 

1995 and 

1996 

SNCRs on both units 

No FGD wastewadischarged; FGD landfilled 

JK Spruce 

Texas 

[ERG, 2009o] 

October 2008 Subbituminous 

(Powder River Basin) 

Spray tower, limestone natural oxidation, no additives (1 unit - but plans to convert to limestone forced oxidation in future); spray tower, limestone forced oxidation, no additives (1 unit planned) 

1992, 2010 SCR on 1 

unit; SCR expected by 2015 on other unit 

Settling pond folloclarifier with poly

Fayette Power 

Project/Sam Seymour 

Texas 

[ERG, 2009p] 

October 2008 Subbituminous 

(Powder River Basin) 

Spray tower, limestone forced oxidation, no additives (1 unit operating, 2 units planned) 

1988 (and 

2 units 

planned for 

2010) 

No SCR No FGD wastewa
Final Detailed Study Report Chapter 2 – 

2-8 

Table 2-1. Summary of the Detailed Study Site Visits 

Plant Name 

Location 

(Reference) 

Month/Year of 

Site Visit Coal Type FGD System a 

Year FGD 

Began 

Operation 

SCR/SNCR 

NOx Control

Type of FGD W

Treatment 

Ghent 

Kentucky 

[ERG, 2009g] 

December 2008 Eastern Bituminous, 

previously would occasionally burn 50/50 mixture of Eastern Bituminous/Powder River Basin in 2 units 

Tray tower, limestone forced oxidation, no additives currently used (DBA capability) (3 units operating, 1 unit planned) 

1994, 2007, 

2008, (and 

1 unit 

planned for 

2009) 

SCRs on 2 units 

Settling pond 

Trimble County 

Kentucky 

[ERG, 2009j] 

December 2008 Eastern Bituminous 

in one unit; 70/30 mixture of Eastern Bituminous/Powder River Basin for planned unit 

Spray tower, limestone forced oxidation, no additives currently used (DBA capability for operating unit) (1 unit operating, 1 unit planned) 

1990 (1 

unit 

planned for 

2010) 

SCRs on 2 units 

No FGD wastewadischarged; FGD stored in a settling completely reuses wastewater in the [Note: configuratitreatment system w2010 to settling pounit begins operat

Cane Run 

Kentucky 

[ERG, 2009h] 

December 2008 Eastern Bituminous Spray tower, lime inhibited 

oxidation (2 units); spray tower, lime inhibited oxidation and sodium carbonate dual-alkali (1 unit); emulsified sulfur added to all three units 

1976, 

1977, and 

1978 

No SCRs Settling pond 

Mill Creek 

Kentucky 

[ERG, 2009i] 

December 2008 Eastern Bituminous Tray tower, limestone forced 

oxidation (4 units) 

1978, 1980, 

1981, and 

1982 

SCRs on 2 units 

Settling pond 

Brandon Shores 

Maryland 

 [ERG, 2009k] 

January 2009 Eastern Bituminous Tray tower, limestone forced 

oxidation (planned for 2 units) 

1 unit 

planned for 

2009 and 

one 

planned for 

2010 

SCRs on 2 units 

Chemical precipitaddition, organosuchloride); aerobic/biological sequencreactors 

Kenneth C Coleman 

Kentucky 

[ERG, 2009m] 

February 2009 Bituminous Tray tower, limestone forced 

oxidation (1 scrubber for 3 units) 

2006 No SCRs Clarifier and filter 
Final Detailed Study Report Chapter 2 – 

2-9 

Table 2-1. Summary of the Detailed Study Site Visits 

Plant Name 

Location 

(Reference) 

Month/Year of 

Site Visit Coal Type FGD System a 

Year FGD 

Began 

Operation 

SCR/SNCR 

NOx Control

Type of FGD W

Treatment 

Gibson 

Indiana 

[ERG, 2009e] 

February 2009 Bituminous Spray tower, limestone forced 

oxidation for 3 units (Units 1, 2, and 3); horizontal flow, limestone forced oxidation for 1 unit (Unit 5); spray tower, limestone inhibited oxidation for 1 unit (emulsified sulfur added) (Unit 4) 

1982, 1995, 

2006, and 

2007 

No information 

No FGD wastewafrom the Unit 4 ansystems. Chemica(ferric chloride antreatment for the Fwastewater from U3. The treated FGD is sent to the coolirecycled for plant plant is constructiinject the treated Fwastewater into ungeological format

Paradise 

Kentucky 

[ERG, 2009l] 

February 2009 Bituminous Spray tower, limestone forced 

oxidation (3 units) 

1982 (2 

units) and 

2006 (1 

unit) 

SCRs on 2 units 

Settling pond 

Wabash River 

Indiana 

[ERG, 2009f; ERG, 

2009v] 

February 2009 Petroleum coke 

(IGCC unit); Bituminous (5 pulverized coal units) 

No FGD systems NA No SCR or 

SNCR 

NA 

Miami Fort 

Ohio 

[ERG, 2009r] 

April 2009 Eastern Bituminous Spray tower, limestone forced 

oxidation (2 units); no additives 

2007 SCRs on 2 

units 

Chemical precipitaddition, organosuchloride, polymer

a – The number of generating units in parentheses is also the number of FGD systems unless otherwise specified. b – The FGD system is a once-through system in which the gypsum slurry in the scrubber reaction tank is not recycled back through thcontinuously discharged. NA – Not available. Note: The table reflects the data collected at the time of each individual site visit and does not reflect changes that have occurred since conducted. 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

2.2 Wastewater Sampling

EPA conducted a sampling program to characterize untreated wastewaters generated by 

coal-fired power plants, as well as to evaluate treatment technologies and best management 

practices for reducing pollutant discharges. EPA developed a “generic” sampling plan [ERG, 

2007c] to provide general sampling procedures and methods that were followed when 

conducting sampling activities. The generic sampling plan, in combination with plant-specific 

sampling plans, served as a guide to the field sampling crew and provided procedural 

information for plant personnel. 

Between July 2007 and October 2008, EPA collected and analyzed samples to 

characterize wastewater streams at six coal-fired power plants. Specifically, EPA characterized 

wastewater streams associated with wet FGD systems and ash handling operations and evaluated 

the capability of various types of treatment systems to remove metals and other pollutants of 

concern prior to discharge. Table 2-2 presents information on the plants selected for the sampling 

program. The plant locations are shown in Figure 2-2. 

Table 2-2. Summary of the Detailed Study Sampling Program 

Type of Samples Collected 

FGD Treatment System Ash Pond 

Plant Name 

Sampling 

Episode 

No. 

Date of 

Sampling 

Episode Influent In-Process Effluent Influent Effluent 

Big Bend 6547 July 2007 9 9

Homer City 6548 August 2007 9 9 9 9

(bottom ash) 

Widows 

Creek 

6549 September 

2007 

9 9 9

(fly + bottom) 

9

(fly + bottom) 

Mitchell 6550 October 

2007 

9 9 9 9

(fly ash + other)

Cardinal 6551 October 

2007 

9

(fly ash) 

9

(fly ash) 

Belews Creek 6557 October 

2008 

9 9 9

The sampling program consisted of one-day or two-day sampling episodes at the six 

selected plants. EPA prepared sampling episode reports for each plant, describing the specific 

sample points, the sample collection methods used, the field quality control samples collected, 

and the laboratory analytical results. The reports for these six episodes are in the docket for the 

Preliminary 2010 Effluent Guidelines Program Plan [ERG, 2008l; ERG, 2008m; ERG, 2008k; 

ERG, 2008n; ERG, 2008o; ERG, 2009q]. 

Table 2-3 lists the analytes for which EPA collected sampling data. The analytes listed 

generally reflect the expected characteristics of coal-fired power plant wastewaters, including 

contributions from coal, scrubber sorbents, treatment chemicals, and other sources. Several 

analytes, such as yttrium, were included in the analyte list because of pre-established laboratory 

contracts and perhaps would not have been individually selected for inclusion. 

2-10 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

Table 2-3. Analytes Included in the Detailed Study Sampling Program 

Parameter 

Method Number 

(Sampling Episodes 6547, 

6548, 6549, 6550, 6551) 

Method Number 

(Sampling Episode 

6557) 

Classicals

Biochemical Oxygen Demand (5-day) (BOD5) SM 5210 B SM 5210 B 

Chemical Oxygen Demand (COD) a SM 5220 C 

Total Suspended Solids (TSS) SM 2540 D SM 2540 D 

Total Dissolved Solids (TDS) SM 2540 C SM 2540 C 

Sulfate ASTM D516-90 EPA 300.0 

Chloride SM 4500–Cl–C EPA 300.0 

Ammonia as Nitrogen SM 4500—NH3 F (18th 

ed.) 

EPA 350.1 

Nitrate/Nitrite as Nitrogen SM 4500-NO3 H b EPA 353.2 

Total Kjeldahl Nitrogen (TKN) SM 4500—N, C EPA 351.2 

Total Phosphorus EPA 365.3 (Rev 1978) EPA 365.2 

Hexane Extractable Material (HEM) EPA 1664A EPA 1664A 

Silica Gel Treated Hexane Extractable Material (SGT-HEM) EPA 1664A EPA 1664A 

Metals 

Total and Dissolved 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, Zinc) 

EPA 200.7 

EPA 245.1 

EPA 245.5 

EPA 200.7 c 

EPA 200.8 c 

EPA 200.8 with DRC d

Low-Level Total and Dissolved Metals (11 Metals: 

Antimony, Arsenic, Cadmium, Chromium, Copper, Lead, 

Nickel, Selenium, Silver, Thallium, Zinc) 

EPA 1638 EPA 1638 

EPA 1638 with DRC e

HG-AFS f 

Low-Level Total and Dissolved Mercury EPA 1631E EPA 1631E 

Hexavalent Chromium ASTM D1687-92 EPA 218.6 

Low-Level Hexavalent Chromium EPA 1636 EPA 1636 

a – COD was analyzed only for Sampling Episode 6557. 

b – EPA Method 353.2 was used for the nitrate/nitrite analysis for Sampling Episode 6548. Standard Method 4500-NO3-

H was used for Sampling Episodes 6549, 6550, and 6551. Nitrate/nitrite was not analyzed in Sampling Episode 6547 

because a laboratory instrument failure delayed analysis until the sample holding time was exceeded. 

c – Molybdenum, tin, titanium, and yttrium were not analyzed by EPA Methods 200.7 or 200.8 for Sampling Episode 

6557. Additionally, mercury was not analyzed by EPA Method 245.1 for Sampling Episode 6557. 

d – Samples were analyzed for arsenic, chromium, iron, manganese, nickel, selenium, vanadium, and zinc using EPA 

Method 200.8 with a dynamic reaction cell (DRC) instrumentation for Sampling Episode 6557. 

e – Samples were analyzed for arsenic, chromium, nickel, selenium, and zinc using EPA Method 1638 with a DRC for 

Sampling Episode 6557. 

f – Samples were analyzed for arsenic and selenium using hydride generation and atomic fluorescence spectrometry 

(HG-AFS) using Frontier Geosciences Method 055 (modified SM 3114) for Sampling Episode 6557. 

During the sampling program, EPA also collected data on the design, operation, and 

performance of treatment systems at steam electric plants, specifically regarding system design 

and day-to-day operation. The sampling activities were focused on influent, effluent, and inprocess streams for FGD and ash handling wastewater treatment systems. During each sampling 

2-11 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

2-12 

episode, EPA collected engineering information regarding the design and operation of the plant 

being sampled, such as coal usage, plant capacity, wastewater flow rates, sludge generation rates, 

and retention times in wastewater treatment process stages. Engineering data collection sheets 

were completed for each plant. 

EPA used data from the sampling program to help identify the pollutants present in 

wastewater streams generated by or associated with wet ash handling systems and SO2/NOx air 

pollution controls (e.g., wet FGD systems, SCR/SNCR). The data were also used to characterize 

the performance of wastewater treatment systems. 

2.3 Questionnaire (“Data Request”)

EPA collected information from a limited number of coal-fired power plants using a 

questionnaire issued under authority of Section 308 of the Clean Water Act (Data Request for 

the Steam Electric Power Generating Industry), referred to in this report as the “data request” 

[U.S. EPA, 2007a]. The data request complemented EPA’s site visit and sampling program by 

obtaining information about wastewater generation rates and management practices for the FGD 

and ash transport water waste streams, other waste streams not sampled by EPA’s sampling 

program (e.g., coal pile runoff), and other power plant information as described below. 

EPA selected nine power companies to receive the data request based on specific 

characteristics of plants they operate. These companies all operate coal-fired plants that have wet 

FGD systems and/or wet fly ash handling systems. Table 2-4 presents a profile of the coal-fired 

power plants operated by the nine selected companies (referred to in this report as “data request 

respondents”). As shown in Table 2-4, the data request respondents operated a total of 67 coalfired power plants and provided technical information for 30 of these coal-fired power plants as 

instructed by Part B of the data request. These 30 coal-fired power plants (i.e., the “data request 

plants”) either operated wet FGD systems as of October 2007, and/or were planning to begin 

constructing wet FGD systems by December 31, 2010. The plants that are most likely to operate 

FGD systems are those that burn eastern bituminous coal, which has relatively high sulfur 

content, so the vast majority of the data request plants are located in the eastern United States. 

Figure 2-3 shows the location of the data request plants. 

EPA distributed the data request to the nine selected power companies in May 2007 and 

received data request responses in August and October 20072

. The data requests were divided 

into two parts: Part A, General Power Company Information; and Part B, Power Plant Technical 

Information. EPA requested that each power company complete Part A of the data request and to 

complete Part B of the data request for each coal-fired power plant they operate that meets the 

following criteria: was in operation in calendar year 2006; and operates at least one wet FGD 

system and/or is currently constructing/installing (or plans to begin constructing prior to 

December 31, 2010) at least one wet FGD system. 

 

2

 EPA received data request responses from each of the nine data request respondents in August 2007. One 

respondent also provided a Part B response for one data request plant in October 2007. 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

Table 2-4. Profile of Coal-Fired Power Plants Operated by Data Request Respondents 

Coal-Fired Power Plants Operated by Data 

Request Respondents 

Plants for which Data Request Respondents 

Provided Technical Information a

Company 

Number 

Total 

No. of 

Plants 

Number 

Currently 

Operating 

Wet FGD 

Systems b 

Number Not Currently 

Operating Wet FGD 

Systems, But Planning 

to Begin Constructing 

by 12/31/2010 b 

Total 

No. of 

Plants 

Number with 

Segregated FGD 

Wastewater 

Treatment System 

(Operating) b

Number with 

Wet Fly Ash 

Systems 

1 10 3 2 5 0 0 

2 6 1 1 2 1 1 

3 16 2 1 3 0 1 

4 8 1 3 4 1 2 

5 10 1 4 6 1 6 

6 3 3 0 3 0 3 

7 8 1 2 3 1 2 

8 4 2 0 2 0 0 

9 2 2 0 2 0 2 

Total 67 16 13 c 30 c 4 17 

Source: [U.S. EPA, 2008a]. 

a – Plants within the scope of Part B of the data request. 

b – Based on information provided in the data request responses, as of October 2007. 

c – EPA received data request technical information for 30 coal-fired power plants. One company initially reported 

plans to install wet FGD systems at one plant by December 31, 2010; however, during follow-up communications, 

the company informed EPA that they subsequently decided not to install wet FGD systems as part of the company’s 

long-term air pollution control strategies. 

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Final Detailed Study Report Chapter 2 – Data Collection Activities 

Source: [U.S. EPA, 2008a]. 

Note: Based on information provided in the data request responses, as of October 2007. 

Figure 2-3. Locations of Coal-Fired Power Plants for which Data Request Respondents 

Provided Technical Information 

Part A requested the following: company contact information; corporate structure 

information; and profile information for the coal-fired power plants that the companies currently 

operate and that were in operation during 2006. Part B requested the following information: 

• General plant information, including address and contact information. 

• Steam electric power production information and fuels used for each steam 

electric unit that the plant operated in 2006. 

• 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. 

• Operation 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. 

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Final Detailed Study Report Chapter 2 – Data Collection Activities 

• Operation and maintenance 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. 

• Monitoring data that the plant collected for any reason during 2006 for coal-fired 

steam electric wastewater streams that meet 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. After distributing the data request to the nine data request 

respondents, EPA provided assistance and clarification regarding the data request questions 

directly via a help line and indirectly via UWAG. 

EPA conducted a technical review of the data request responses to ensure the quality and 

consistency of the data. Following the technical review of each data request response, EPA 

communicated with the data request respondents to resolve questions and/or discrepancies found. 

Once resolved, EPA key-entered the revised data request responses into a database and 

conducted a quality assurance check of the key-entered data [ERG, 2008j]. A database 

containing the responses to the data request is included in the docket for the Final 2008 Effluent 

Guidelines Program Plan. A portion of the information provided by data request respondents was 

claimed as confidential business information. In these cases, EPA has provided sanitized 

versions of the data request responses. 

2.4 EPA and State Sources

Throughout the detailed study, EPA collected information from the Agency’s databases 

and publications and state groups and permitting authorities, including the following, which are 

discussed further in the subsections below: 

• Information on current permitting practices for the steam electric industry from a 

review of selected National Pollutant Discharge Elimination System (NPDES) 

permits and accompanying fact sheets; 

• Input from EPA and state permitting authorities regarding implementation of the 

Steam Electric Power Generating effluent guidelines; 

• Background information on the steam electric industry from documents prepared 

during the development of the Steam Electric Power Generating effluent 

guidelines; 

• Information from a survey of the industry conducted in support of the Clean 

Water Act Section 316(b) Cooling Water Intake Structures rulemaking; 

• Information from EPA’s OAR used to predict impacts from environmental 

policies; 

• Information from EPA’s ORD characterizing coal combustion residues (CCRs) 

and the potential leaching of these CCRs from landfills and surface 

impoundments; 

• Information collected by EPA’s OSWER regarding surface impoundments or 

other similar management units that contain CCRs at power plants. 

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Final Detailed Study Report Chapter 2 – Data Collection Activities 

Other data sources include the Permit Compliance System (PCS) and Toxics Release 

Inventory (TRI) databases, from which EPA obtained initial information on reported pollutant 

releases from the electric generating industry, and the Office of Enforcement and Compliance 

Assistance (OECA) Sector Notebook, Profile of the Fossil Fuel Electric Power Generation 

Industry [U.S. EPA, 1997]. 

EPA’s Office of Water has coordinated its efforts with ongoing research and activities 

being undertaken by other EPA offices, including the Office of Air and Radiation (OAR), the 

Office of Research and Development (ORD), the Office of Solid Waste and Emergency 

Response (OSWER), the Office of Enforcement and Compliance Assurance, and EPA regional 

offices. 

2.4.1 NPDES Permits and Fact Sheets 

The CWA requires direct dischargers (i.e., industrial facilities that discharge process 

wastewaters from any point source into receiving waters) to control their discharges according to 

effluent guidelines and water quality-based effluent limitations included in NPDES permits. 

EPA reviewed selected NPDES permits and, where available, accompanying fact sheets 

to identify the sources of wastewater at steam electric plants and to determine how the 

wastewaters are currently regulated (i.e., effluent limitations for specific parameters and the basis 

for selecting the parameters). As part of the NPDES permit review, EPA contacted state permit 

writers to obtain additional information or clarify permit information. 

2.4.2 State Groups and Permitting Authorities 

Throughout the detailed study, EPA interacted with states and EPA regional permitting 

authorities. When contacting and visiting power plants, EPA coordinated with state and regional 

permit writers. EPA solicited input and suggestions from states and permitting authorities on 

specific power plant characteristics and implementation of the Steam Electric Power Generating 

effluent guidelines. EPA hosted a webcast seminar in December 2008 to review information on 

wastewater discharges from coal-fired power plants for NPDES permitting and pretreatment 

authorities. The webcast provided an update on EPA's review of the current effluent guidelines 

(40 CFR Part 423) and presented information on pollutant characteristics and treatment 

technologies for wastewater from FGD scrubbers. During the webcast, state and interstate 

approaches for managing steam electric power plant wastewaters were shared by representatives 

from Wisconsin, North Carolina, and the Ohio River Valley Water Sanitation Commission 

(ORSANCO). 

2.4.3 1974 and 1982 Technical Development Documents for the Steam Electric Power 

Generating Point Source Category 

The 1974 Development Document for Effluent Limitations Guidelines and New Source 

Performance Standards for the Steam Electric Power Generating Point Source Category

(referred to in this report as “the 1974 Development Document”) [U.S. EPA, 1974] and the 1982 

Development Document for Effluent Limitations Guidelines and Standards and Pretreatment 

Standards for the Steam Electric Point Source Category (referred to in this report as “the 1982 

Development Document”) [U.S. EPA, 1982] present the results of studies of the steam electric 

industry that EPA conducted in developing the Steam Electric Power Generating effluent 

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Final Detailed Study Report Chapter 2 – Data Collection Activities 

guidelines. These development documents contain findings, conclusions, and recommendations 

on control and treatment technology relating to discharges from steam electric power plants. In 

this detailed study, EPA used the information presented in the 1974 and 1982 Development 

Documents for historical background on the Steam Electric Power Generating effluent guidelines 

and for information on sources of pollutants. 

2.4.4 CWA Section 316(b) - Cooling Water Intake Structures Supporting Documentation 

and Data 

For the CWA section 316(b) Cooling Water Intake Structures rulemaking, EPA 

conducted a survey of steam electric utilities and steam electric non-utilities that use cooling 

water, as well as facilities in four other manufacturing sectors: Paper and Allied Products (SIC 

code 26), Chemical and Allied Products (SIC code 28), Petroleum and Coal Products (SIC code 

29), and Primary Metals (SIC code 33). The survey requested the following types of information: 

• General plant information, such as plant name, location, and SIC codes; 

• Cooling water source and use; 

• Design and operational data on cooling water intake structures and cooling water 

systems; 

• Studies of the potential impacts from cooling water intake structures conducted by 

the facility; 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 in the survey was useful for the 

detailed study of the steam electric industry. EPA used the information provided by the Section 

316(b) survey in the following analyses: 

• Linking Energy Information Administration (EIA) facility information to the TRI 

and PCS discharges; 

• Identifying the type of cooling systems used by facilities; and 

• Identifying industrial non-utilities. 

2.4.5 Office of Air and Radiation 

EPA’s Office of Air and Radiation (OAR) develops national programs, technical policies, 

and regulations for controlling air pollution and radiation exposure. EPA used the 2006 

Integrated Planning Model (IPM) database used by OAR to estimate the projected scrubbed 

capacity for the future industry profile [U.S. EPA, 2006]. The IPM was developed by ICF 

Consulting, Inc. and is used to estimate the projected impacts from environmental policies on the 

electric power sector. IPM Version 3.0 projects the electric generating capacity for various “plant 

types” at different run years in the future (i.e., 2010, 2015, 2020, and 2025). EPA used the data 

from run year 2020 as a basis for future industry profile for this study, which EPA used to assess 

future growth of FGD usage in the industry. Additionally, EPA used OAR’s Acid Rain Database 

[ERG, 2007a] and NEEDS 2006 database [U.S. EPA, 2006h] to supplement information 

collected on characteristics of plants within the steam electric industry. 

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Final Detailed Study Report Chapter 2 – Data Collection Activities 

2.4.6 Office of Research and Development 

EPA’s Office of Research and Development is currently evaluating the impact of air 

pollution controls on the characteristics of coal combustion residues (CCRs). Specifically, the 

Office of Research and Development is studying the potential cross-media transfer of mercury 

and other metals from flue gas, fly ash, and other residues collected from coal-fired boiler air 

pollution controls and disposed of in landfills or surface impoundments. The key routes of 

release being studied are leaching into groundwater or subsequent release into surface waters, reemission of mercury, and bioaccumulation. The Office of Research and Development is also 

examining the use of CCRs in asphalt, cement, and wallboard production. 

This research seeks to better understand potential impacts from disposal practices and 

beneficial use of CCRs by taking a holistic approach, evaluating life-cycle environmental 

tradeoffs that compare beneficial use applications with and without using CCRs. The outcome of 

this research will help to identify potential management practices of concern where 

environmental releases may occur, such as the development and application of a leach testing 

framework that evaluates a range of materials and the different factors affecting leaching for the 

varying field conditions in the environment. 

EPA’s Office of Water consulted with the Office of Research and Development on the 

status and findings of current research assessing the potential for CCRs to impact water quality. 

2.4.7 Office of Solid Waste and Emergency Response 

EPA’s Office of Solid Waste and Emergency Response (OSWER) recently issued 

Information Request Letters to electric utilities that have surface impoundments or similar 

management units that contain CCRs. EPA’s OSWER is using the data collected from the 

Information Request Letters to evaluate the threat of releases of pollutants from these 

management units. EPA’s Office of Water used the OSWER data as another source of 

information about the use of ash ponds and FGD ponds at coal-fired power plants. 

The OSWER database contains information collected from plants identified as potentially 

operating ash ponds or FGD ponds, based on data compiled by the Department of Energy’s 

Energy Information Administration (EIA). The EIA data does not include information about 

waste disposal practices for those plants with nameplate electric generating capacity of less than 

100 MW. In addition, due to the nature of EIA’s data collection form, the EIA data may also 

exclude information about the presence of ponds at plants that use the pond as an interim step 

(e.g., to dewater ash or other CCR solids), but final disposition of the CCRs is an on-site landfill 

or off-site disposal/use. In requesting information on CCR surface impoundments and similar 

waste management units, OSWER directed the requests to those plants identified by the EIA data 

as disposing of CCRs in an on-site pond. As such, the OSWER database potentially 

underestimates the total number of ash ponds and FGD ponds nationwide. 

2.5 Interactions with 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, 

2-18 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

transmit, and distribute electricity to residential, commercial, industrial, and institutional 

customers. The Edison Electric Institute is an association of U.S. shareholder-owned electric 

companies, international affiliates, and industry associates. The National Rural Electric 

Cooperative Association is an 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 a national trade association 

representing 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. These members 

include the companies that own and operate commercial nuclear power plants in the United 

States, as well as nuclear plant designers and other 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 commented on EPA’s selection of the steam electric power generating industry 

for a detailed study as part of the 2006 Effluent Guidelines Program Plan and submitted 

comments to EPA regarding the detailed study as part of the Preliminary 2008 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, November 2006) [U.S. EPA, 2006e]. As EPA continued with the detailed 

study and began formulating approaches to data collection, the Agency held a series of 

discussions with UWAG to streamline and facilitate the data collection process. Specifically, 

EPA coordinated with UWAG on collecting information on power plant characteristics to 

support site visit selection, discussing wastewater sampling approaches and recommendations, 

reviewing the data request for clarity, and collecting existing permit data. At the invitation of 

individual plants, UWAG also collected split samples during EPA’s sampling program and 

participated in most site visits. 

2.5.1 Database of Power Plant Information 

UWAG provided EPA with additional power plant information to augment data compiled 

from other data sources described in this chapter. EPA provided UWAG with a list of 96 coalfired power plants believed to be operating wet FGD systems and UWAG provided information 

regarding plant operations at 76 of the plants. UWAG provided information on the operation of 

the wet FGD systems, including the installation year, sorbent usage, additive usage, oxidation 

type, solids handling practices, and wastewater treatment system. UWAG also provided the type 

of bottom and fly ash handling and wastewater treatment systems. 

2.5.2 Wastewater Sampling 

As discussed in Section 2.2, EPA conducted a 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 several meetings with 

UWAG to discuss various approaches to the sampling program, including identifying 

representative sample points, providing comment on the generic sampling plan, and providing 

recommendations on laboratory analyses and potential interferences (particularly with handling 

influent samples with high concentrations of solids). UWAG participated in the plant pre2-19 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

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. EPA met with UWAG to discuss the FGD effluent sampling results and 

during these meetings, compared analytical results and discussed the challenges associated with 

laboratory analyses of FGD wastewaters [ERG, 2008d; ERG, 2009n]. UWAG also provided 

written suggestions to EPA for improving the analytical procedures for the sampling program 

[Hill, 2008]. 

2.5.3 Data Request 

As discussed in Section 2.3, EPA developed a questionnaire (i.e., data request) to collect 

information on coal-fired power 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. After EPA 

distributed the data request to the data request respondents, UWAG requested clarification 

regarding certain data request questions on behalf of its members. Copies of UWAG’s comments 

and questions on the data request are included in the docket for the Preliminary 2010 Effluent 

Guidelines Program Plan [UWAG, 2007]. 

2.5.4 NPDES Form 2C 

UWAG and EPA coordinated efforts to create a database of selected NPDES Form 2C 

data from UWAG’s member companies. The NPDES Form 2C (or an equivalent form used by a 

state permitting authority) 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. 

The NPDES Form 2C database contains information about the outfalls of coal-fired 

power plants that receive FGD, ash handling, or coal pile runoff waste streams. EPA received 

Form 2C data from UWAG for 86 plants in late June 2008. [UWAG, 2008] UWAG did not 

include data on other outfalls, such as separate outfalls for sanitary wastes, cooling water, landfill 

runoff, and other waste streams, in the database. The database does not include Form 2C 

information for plants that have neither a wet FGD system nor wet fly ash handling. For 

example, if a plant has no wet FGD system and the plant’s only wet ash handling is for bottom 

ash sluicing, UWAG did not include its information in the database. EPA reviewed the Form 2C 

data for use in developing the industry profile, in particular for ash wastewater treatment 

operations. 

2.6 Interactions with the Electric Power Research Institute (EPRI)

EPRI is a research-oriented trade association for the steam electric industry. EPRI 

conducts research funded by the steam electric industry and has extensively studied wastewater 

discharges from FGD systems. The trade association provided EPA with the following reports 

that summarize the data collected during several EPRI studies: 

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Final Detailed Study Report Chapter 2 – Data Collection Activities 

2-21 

• Flue Gas Desulfurization (FGD) Wastewater Characterization: Screening Study

[EPRI, 2006a]; 

• EPRI Technical Manual: Guidance for Assessing Wastewater Impacts of FGD 

Scrubbers [EPRI, 2006b]; 

• The Fate of Mercury Absorbed in Flue Gas Desulfurization (FGD) Systems

[EPRI, 2005]; 

• Update on Enhanced Mercury Capture by Wet FGD: Technical Update [EPRI, 

2007b]; and 

• PISCES Water Characterization Field Study, Sites A-G [EPRI, 1997b-2001]. 

The EPRI reports 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 and considerations for 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. A copy of EPRI’s 

comments on the sampling plan is included in the docket for the Preliminary 2010 Effluent 

Guidelines Program Plan [EPRI, 2007c]. 

2.7 Department of Energy (DOE) 

DOE is the department of the United States government responsible for energy policy. In 

the detailed study, EPA used information on electric generating facilities from DOE’s Energy 

Information Administration (EIA) data collection forms. 

EIA is a statistical agency of the DOE that collects information on existing U.S. electric 

generating facilities and associated equipment to evaluate the current status and potential trends 

in the industry. EPA used information from two of EIA’s data collection forms: Form EIA-860, 

Annual Electric Generator Report, and Form EIA-767, Steam Electric Plant Operation and 

Design Report. Form EIA-860 collects information annually for all electric generating facilities 

that have or will have a nameplate capacity3

 of one megawatt (MW) or more and are operating 

or plan to be operating within five years of the filing of the Annual Electric Generator Report. 

The data collected in Form EIA-860 are associated only with the design and operation of 

generators at facilities [U.S. DOE, 2005a]. Form EIA-767 collects information annually from all 

electric generating facilities with a total existing or planned organic-fueled or renewable steam 

electric generating unit that has a nameplate rating of 10 MW or larger. The data collected in 

Form EIA-767 are associated with the operation and design of the entire facility. EPA used Form 

EIA-767 primarily for information on the facilities operating (or planning to operate) FGD 

systems [U.S. DOE, 2005b]. 

the 

 

3

 DOE defines the generator nameplate capacity as the maximum rated output of a generator under specific 

conditions designated by the manufacturer. Generator nameplate capacity is usually indicated in units of kilovoltamperes (kVA) and in kilowatts (kW) on a nameplate physically attached to the generator. More generally, 

generator capacity is the maximum output, commonly expressed in megawatts (MW), that generating equipment can 

supply to system load, adjusted for ambient conditions. 
Final Detailed Study Report Chapter 2 – Data Collection Activities 

2-22 

2.8 Other Sources

EPA obtained additional information on steam electric processes, technologies, 

wastewaters, pollutants, and regulations from sources including wastewater treatment equipment 

vendors, the U.S. Geological Survey (USGS), and literature and Internet searches. In addition, 

EPA considered information provided in public comments during the effluent guidelines 

planning process, as well as other contacts with interested stakeholders. 

2.8.1 Wastewater Treatment Equipment Vendors 

EPA contacted companies that manufacture, distribute, or install various components of 

pollutant removal systems. EPA obtained information about the operation and performance of 

these systems and the type of equipment used for treating FGD wastewaters. 

2.8.2 U.S. Geological Survey (USGS) COALQUAL Database 

Since the middle 1970s, the USGS has maintained a national coal quality database, 

containing data compiled on more than 13,000 coal samples collected by USGS and cooperative 

state geological surveys. The database contains 136 parameters for each sample, including data 

on location and sample description, analytical data from American Society for Testing and 

Materials (ASTM) tests, and USGS tests for major, minor, and trace elements. The COALQUAL 

database [USGS, 1998] contains data for 7,430 coal samples that represent complete-bed 

thicknesses at various locations. EPA generally reviewed data from the COALQUAL database 

when initially studying the industry to determine potential constituents that may be present in 

coal combustion wastes. 

2.8.3 Literature and Internet Searches 

EPA conducted literature and Internet searches to obtain information on various aspects 

of the steam electric process, both for plants regulated by the effluent guidelines and certain 

operations outside the scope of the regulations. The information collection objectives of these 

searches included characterizing wastewaters and pollutants originating from these steam electric 

processes, the environmental impacts of these wastewaters, and applicable regulations. EPA used 

industry journals, reference texts about the industry, and company press releases obtained from 

Internet searches. EPA participated in the 2007 and 2008 International Water Conference and 

reviewed papers presented at these conferences. 

2.8.4 Environmental Groups and Other Stakeholders 

 EPA received information from several environmental groups and other stakeholders as 

part of public comments submitted for the 2006 and 2008 Effluent Guidelines Plans, and in other 

discussions over the course of the detailed study. The public comments and other information 

were reviewed to determine whether they identified new waste streams or pollutant issues that 

warranted investigation beyond that being conducted as part of the study. In general, the 

information highlighted environmental concerns associated with the pollutants present in power 

plant wastewaters, and technological controls for reducing or eliminating pollutant discharges 

from FGD and ash handling systems. 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3. STEAM ELECTRIC INDUSTRY PROFILE

Electric generating plants use various types of prime movers (e.g., combustion turbines, 

steam turbines, diesel engines) to convert mechanical, chemical, and/or fission energy into 

electric energy. Within this population of electric generating plants, there are different types of 

processes employed to produce electricity (e.g., coal-fired power plants, wind turbines) and there 

are different types of companies that operate these electric generating plants (e.g., utilities, 

industrial plants). The Steam Electric Power Generating effluent guidelines apply to only certain 

types of electric generating plants. Figure 3-1 broadly depicts the various types of electric 

generating plants operating in the United States and identifies which are regulated by the Steam 

Electric Power Generating effluent guidelines. 

This chapter provides an overview of the various types of electric generating processes 

operating in the United States and then focuses on the categories of processes regulated by the 

Steam Electric Power Generating effluent guidelines. The chapter also describes the wastewaters 

generated by these processes. 

Electric Generating Plants

Industrial Non-Utilities Electric Generating Industry

(Utilities and Non-Utilities)

Steam Electric 

Power Generation

Non-Steam Electric 

Power Generation

Fossil or Nuclear Steam Electric 

Generating Plants

(Steam Electric Power Generating 

Point Source Category)

Non-Fossil and Non-Nuclear 

Steam Electric Generating Plants

Figure 3-1. Types of U.S. Electric Generating Plants 

3.1 Overview of the Electric Generating Industry

This section describes the types of plants that compose the overall electric generating 

industry. As shown in Figure 3-1, the plants regulated by the Steam Electric Power Generating 

effluent guidelines are only a portion of the electric generating industry. 

3-1 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-2 

In general, the companies generating electrical power are categorized as one of the 

following types: 

1. Utility: Any entity that generates, transmits, and/or distributes electricity and 

recovers the cost of its generation, transmission and/or distribution assets and 

operations, either directly or indirectly, through cost-based rates set by a separate 

regulatory authority (e.g., state Public Service Commission), or is owned by a 

governmental unit or the consumers that the entity serves. According to the 

Energy Information Administration (EIA), plants that qualify as cogenerators or 

small power producers under the Public Utility Regulatory Policies Act are not 

considered electric utilities [U.S. DOE, 2006b]. 

2. Non-industrial non-utility: Any entity that generates, transmits, and/or sells 

electricity, or sells or trades electricity services and products, where costs are not 

established and recovered by regulatory authority. Non-utility power producers 

include, but are not limited to, independent power producers, power marketers 

and aggregators, merchant transmission service providers, self-generation entities, 

and cogeneration firms with Qualifying Facility Status. [U.S. DOE, 2006b]. Like 

utilities, the primary purpose of non-industrial non-utilities is producing electric 

power for distribution and/or sale. 

3. Industrial non-utility: Industrial non-utilities are similar to non-industrial nonutilities except their primary purpose is not the distribution and/or sale of 

electricity. This category includes electric generators that are located at facilities 

such as chemical manufacturing plants or paper mills. Industrial non-utilities 

typically provide most of the electrical power they generate to the industrial 

operation with which they are located, although they may also provide some 

electric power to the grid for distribution and/or sale. 

Industrial non-utilities are generally not included within the scope of the existing Steam 

Electric Power Generating effluent guidelines because they are not primarily engaged in 

producing electricity for distribution and/or sale4

. As described above, these industrial nonutilities typically are industrial plants that are producing, processing, or assembling goods and 

the electricity generated at these plants is an ancillary operation used to dispose of a by-product 

or for cost savings. Industrial non-utilities are discussed in greater detail in Chapter 7 of this 

report. 

Because industrial non-utilities are not included in the applicability of the Steam Electric 

Power Generating effluent guidelines, EPA has excluded them from the discussion of the U.S. 

electric generating industry for the purposes of this report. Therefore, information presented on 

plants comprising the electric generating industry include only the utilities and the non-industrial 

 

4

 The applicability of the Steam Electric Power Generating Point Source Category (40 CFR Part 423.10) states the 

following: “The provisions of this part 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.” 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-3 

non-utilities, which are generally categorized by the following four North American Industry 

Classification System (NAICS) codes5

: 

• 221111 – Hydroelectric Power Generation; 

• 221112 – Fossil Fuel Electric Power Generation; 

• 221113 – Nuclear Electric Power Generation; and 

• 221119 – Other Electric Power Generation. 

Although the transmission and distribution entities are included in the definition of 

utilities and non-industrial non-utilities, they are not included in the Steam Electric Power 

Generating effluent guidelines; therefore, this report only presents information on the plants and 

NAICS codes associated with the generation of electricity. 

As shown in Figure 3-1, the electric generating industry can be further broken down 

based on the type of prime mover used to generate electricity. DOE’s Energy Information 

Administration (EIA) defines a 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 2006a]. Because the Steam Electric Power 

Generating effluent guideline is applicable only to plants generating electricity using a “... 

thermal cycle employing the steam water system as a thermodynamic medium,” EPA 

categorized the prime movers into “steam electric” and “non-steam electric” categories. The 

steam electric generating units include steam turbines and combined cycle systems (see Section 

3.2 for more details on these types of units). The non-steam electric generating units include, but 

are not limited to, combustion turbines, internal combustion engines, fuel cells, and wind 

turbines. 

The final criteria for a plant to meet the Steam Electric Power Generating effluent 

guideline applicability is that they must primarily utilize a fossil-type or nuclear fuel to generate 

the steam used in the turbine. The fossil-type fuels include coal, oil, or gas, and fuels derived 

from coal, oil, or gas such as petroleum coke, residual fuel oil, and distillate fuel oil. Fossil-type 

fuels also include blast furnace gas and the product of gasification processes using fossil-based 

feedstocks such as coal, petroleum coke, and oil. Examples of non-fossil/non-nuclear fuels used 

by some steam electric generating power plants include pulp mill black liquor, municipal solid 

waste, and wood solid waste. 

3.1.1 Demographics of the Electric Generating Industry 

This section presents available demographic data and other information for the electric 

generating industry (i.e., excluding industrial non-utilities). EPA analyzed the available 

demographic information using EIA data for the year 2005 (Form EIA-860 and Form EIA-767) 

[U.S. DOE, 2005a; U.S. DOE, 2005b], and U.S. Census Bureau data collected in the 2002 

Economic Census [USCB, 2002]. EPA used the 2005 EIA data because it is the most recent year 

for which both EIA-860 and EIA-767 data are available, and the 2002 Census data because it is 

the most recent year for which data at the six-digit NAICS code are available. Together, these 

 

5

 Prior to the introduction of NAICS codes, Standard Industrial Classification (SIC) codes were used to classify 

operations. The SIC codes applicable to the Steam Electric Power Generating effluent guidelines are discussed in 

Chapter 7. 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-4 

sources provide the most recent and comprehensive dataset of power plant data available. EPA 

identified electric generating plants in the EIA database as those reporting NAICS code 22 - 

Utilities6

. The 2002 Economic Census data include more specific industry sector information at 

the six-digit NAICS code level. 

According to the Economic Census, there were 2,138 electric generating plants in the 

United States in 2002, 61 percent (1,311 plants) of which are characterized primarily as using 

fossil or nuclear fuel [USCB, 2002]. These data include both steam and non-steam electric 

generation processes. Table 3-1 presents the distribution of plants among each of the electric 

generating NAICS codes. The Economic Census includes all facilities reporting under NAICS 

code 22. As a result, it includes entities categorized by U.S. DOE as utilities and non-industrial 

non-utilities, but does not include industrial non-utilities. 

Table 3-1. Distribution of U.S. Electric Generating Plants by NAICS Code in 2002 

NAICS Code – Description Plants 

221111 – Hydroelectric Power Generation 416 

221112 – Fossil Fuel Electric Power Generation 1,233 

221113 – Nuclear Electric Power Generation 78 

221119 – Other Electric Power Generation (includes conversion of other forms of energy, 

such as solar, wind, or tidal power, into electrical energy) 

411 

22111 – Electric Power Generation (Total) 2,138 

Source: [USCB, 2002]. 

EPA also examined the data on electricity generating plant operations that were reported 

to the EIA in 2005. Form EIA-860 contains records for 16,807 steam and non-steam electric 

generating units having at least one MW of capacity operated at 5,267 plants for calendar year 

2005 [U.S. DOE, 2005a]. These plants include both the electric generating industry and 

industrial non-utilities. 

3.1.2 Steam Electric Power Generating Industry 

EPA used EIA’s Form EIA-860 information on plant type, energy source, and capacity to 

develop a demographic profile of the portion of the electric generating industry regulated by the 

Steam Electric Power Generating effluent guidelines. As mentioned in Section 3.1.1, these 

records include data from all plants that produce electricity, including steam electric plants. EPA 

defined the subset of EIA data for the Steam Electric Power Generating effluent guidelines by 

the reported NAICS code, as well as the type of turbine and the fuel reported to be used to 

generate electricity. 

All electric generating plants (i.e., utilities, non-industrial non-utilities, and industrial 

non-utilities) report information about each of their electric generating units to the EIA in Form 

EIA-860, and each plant identifies a “primary purpose” code for its operations that is analogous 

to their NAICS code. Utilities and non-industrial non-utilities report under the general NAICS 

 

6

 NAICS code 22 – Utilities is defined as establishments providing the following utility services: electric power, 

natural gas, steam supply, water supply, and sewage removal. Excluded from this sector are establishments primarily 

engaged in waste management services [USCB, 2002]. 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

code 22, while industrial non-utilities report under the particular NAICS code for their primary 

manufacturing or service operation. Because utilities and non-industrial non-utilities are 

regulated by the Steam Electric Power Generating effluent guidelines, their EIA data are 

combined in this report. 

3.1.2.1 Definition of the Steam Electric Power Generating Industry 

The Steam Electric Power Generating effluent guidelines apply 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.” (40 CFR 423.10) EPA identified the 

subset of electric generating plants in the EIA database that use steam electric processes as those 

operating at least one prime mover that utilizes steam. The following electric generating unit or 

prime mover types are included in the demographic data for the steam electric industry presented 

in this report: 

• Steam turbine; 

• Combined cycle system – steam turbine portion; 

• Combined cycle system – combustion turbine portion; and 

• Combined cycle system – single shaft (i.e., the steam turbine and combustion 

turbine are used together to drive a single generator). 

The subset of steam electric plants that are regulated by the steam electric effluent 

guidelines use a fossil or nuclear fuel as the primary energy source for the steam electric 

generating unit. In analyzing the EIA data, EPA included plants using the following EIA-defined 

nuclear and fossil (or fossil-derived) fuel types: 

• Anthracite coal, bituminous coal; 

• Lignite coal; 

• Subbituminous coal; 

• Coal synfuel; 

• Waste/other coal; 

• Petroleum coke; 

• Distillate fuel oil; 

• Residual fuel oil; 

• Jet fuel; 

• Kerosene; 

• Oil-other and waste oil (e.g., crude oil, liquid by-products, oil waste, propane 

(liquid), re-refined motor oil, sludge oil, tar oil); 

• Natural gas; 

• Blast furnace gas; 

• Gaseous propane; 

• Other gas; and 

• Nuclear (e.g., uranium, plutonium, thorium). 

Using the criteria for the prime mover type and energy source described above for all 

plants (utilities and non-industrial non-utilities) reporting a primary purpose/NAICS code of 22, 

3-5 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

EPA identified 1,187 steam electric plants regulated under the Steam Electric Power Generating 

effluent guidelines that reported to the EIA in 2005. In analyzing the EIA energy source data for 

the purpose of this report, EPA only identified plants/units that reported one of the above energy 

sources as a “primary” energy source in the 2005 EIA data. These plants operate an estimated 

2,557 stand-alone steam electric generating units or combined cycle systems, which have a total 

generating capacity of 762,386 MW [U.S. DOE, 2005a]. 

3.1.2.2 Demographics of the Steam Electric Power Generating Industry 

Table 3-2 presents the distribution of the types of steam electric prime movers used by 

plants subject to the Steam Electric Power Generating effluent guidelines. The table presents the 

numbers of plants, electric generating units, and capacity for each type of steam electric prime 

mover. The number of electric generating units represents the number of generators/turbines that 

are used to generate electricity and does not necessarily relate to the number of boilers. 

Based on the 2005 EIA data, the majority (74 percent) of the steam electric power 

produced by the plants subject to the effluent guideline is generated using stand-alone steam 

turbines, which are also the most prevalent type of steam electric prime mover used. 

In the 2005 EIA database, an estimated 411 plants regulated by the Steam Electric Power 

Generating effluent guidelines reported operating at least one fossil-fueled combined cycle 

system. Due to the nature of the EIA data, EPA was able to identify the number of combined 

cycle turbines (i.e., prime movers), but could not discern the number of actual combined cycle 

systems. A combined cycle system is comprised of one or more combustion turbines linked to 

one or more steam turbines; these systems often do not have a one-to-one relationship between 

the number of combustion turbines and steam turbines. The total combined cycle system 

generating capacity of 198,660 MW represents 26 percent of the total capacity regulated by the 

steam electric effluent guidelines [U.S. DOE, 2005a]. 

Table 3-3 presents the distribution of fossil and nuclear fuels used to power each type of 

steam electric prime mover. The number of electric generating units represents the number of 

generators/turbines that are used to generate electricity and is not equal to the number of boilers. 

The vast majority (90 percent) of these generating units are fueled by either coal or gas. Coal is 

the primary fuel type for stand-alone steam turbines, while gas is the primary fuel for nearly all 

combined cycle systems. 

3-6 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-7 

Table 3-2. Distribution of Prime Mover Types for Plants Regulated by the Steam Electric 

Power Generating Effluent Guidelines 

Steam Electric Prime Mover 

Number of 

Plants a

Number of 

Electric 

Generating Units

Total Steam or 

Combined Cycle 

Turbine Capacity 

(MW)

Stand-Alone Steam Turbine 818 

(69%) 

1,995 

(78%) 

563,726 

(74%) 

Combined Cycle Systems b: 411 

(35%) 

562 

(22%) 

198,660 

(26%) 

Combined Cycle Steam Turbine c, d 392 512 70,020 

Combined Cycle Single Shaft (steam and 

combustion turbines share a single shaft) 

22 50 9,503 

Combined Cycle Combustion Turbine c, d 390 889 119,137 

Total 1,187 

(100%) 

2,557 e

(100%) 

762,386 

(100%) 

Source: [U.S. DOE, 2005a]. 

a – Because a single plant may operate multiple electric generating units of various types, the number of plants by 

prime mover type is not additive. There are 1,187 plants in the industry that operate at least one steam electric 

generating unit powered by either fossil or nuclear fuel. 

b – Due to the nature of the EIA data, EPA was able to identify the number of combined cycle turbines (i.e., prime 

movers), but could not discern the number of actual combined cycle systems. EPA estimated the number of 

combined cycle systems by adding the number of combined cycle steam turbines and the number of combined cycle 

single shaft turbines. Typically there are multiple combustion turbines to a single steam turbine in a combined cycle 

system; therefore, EPA believes this methodology is a better representation of the number of combined cycle 

systems than simply adding the number of combined cycle combustion and steam turbines. 

c – The 2005 EIA database contains a total of 506 combined cycle steam turbines, with an additional six plants 

reporting at least one combined cycle combustion turbine, but not a combined cycle steam turbine. EPA believes 

that these six plants likely operate a combined cycle steam turbine; therefore, EPA assumed that each of the six 

plants operates one combined cycle steam turbine and counted six additional turbines and six additional plants to the 

numbers identified in the 2005 EIA database for the number of combined cycle steam turbines and combined cycle 

steam turbine plants. 

d – One plant in the 2005 EIA database reported having a combined cycle steam turbine electric generating unit and 

two internal combustion electric generating units. Another plant in the database reported a fossil fuel for its 

combined cycle steam turbine and a non-fossil/non-nuclear fuel for its three combined cycle combustion turbines. 

EPA included the combined cycle steam turbines for these plants in the table, but did not include the internal 

combustion or the combined cycle combustion turbines using fuels not covered by the effluent guidelines. 

e – EPA estimated the total number of electric generating units as the sum of the stand-alone steam turbines and the 

estimated number of combined cycle systems. EPA did not sum the total number of turbines. 
Final Detailed Study Report Chapter 3 – Stea

Table 3-3. Distribution of Fuel Types Used by Steam Electric Generating Units 

Number of Electric Generating Units 

Fossil or Nuclear Fuel a

Stand-Alone 

Steam Turbines 

Combined Cycle Steam 

Turbines b, c 

Combined Cycle 

Single Shaft 

Combined Cycl

Combustion Turbi

Coal: 1,179 2 0 2 

Anthracite Coal, Bituminous Coal 695 2 0 2 Subbituminous Coal 411 0 0 0 Lignite Coal 29 0 0 0 Coal Synfuel 22 0 0 0 Waste/Other Coal 22 0 0 0 

Petroleum Coke 12 0 0 0 Oil: 136 11 0 20 

Residual Fuel Oil 125 2 0 2 Distillate Fuel Oil 11 8 0 16 Waste Oil 0 1 0 2 

Gas: 564 499 50 867 

Natural Gas 559 495 50 866 Blast Furnace Gas 5 0 0 0 Other Gas 0 4 0 1 

Nuclear 104 0 0 0 Total 1,995 512 50 889 

Source: [U.S. DOE, 2005a]. a – No steam electric generating units were reported to use jet fuel, kerosene, or gaseous propane in the 2005 EIA database. b – The 2005 EIA database contains a total of 506 combined cycle steam turbines, with an additional six plants reporting at least one coturbine, but not a combined cycle steam turbine. EPA believes that these six plants likely operate a combined cycle steam turbine; thereeach of the six plants operates one combined cycle steam turbine and counted six additional turbines and six additional plants to the num2005 EIA database for the number of combined cycle steam turbines and combined cycle steam turbine plants. c – One plant in the 2005 EIA database reported having a combined cycle steam turbine electric generating unit and two internal combu

units. Another plant in the database reported a fossil fuel for its combined cycle steam turbine and a non-fossil/non-nuclear fuel for its t

combustion turbines. EPA included the combined cycle steam turbines for these plants in the table, but did not include the internal comcycle combustion turbines using fuels not covered by the effluent guidelines.

d – EPA estimated the total number of electric generating units as the sum of the stand-alone steam turbines and the estimated number osystems. EPA did not sum the total number of turbines. 

3-8 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-9 

Table 3-4 presents the distribution of fossil and nuclear fuels used by plants applicable to 

the Steam Electric Power Generating effluent guideline. The 2005 EIA data demonstrate that 

more than half of the electricity produced by steam turbines is fueled by coal. Natural gas 

accounts for 27 percent of the electricity produced by steam turbines, nuclear for 16 percent, and 

oil for 5 percent of the electricity from steam turbines. Table 3-4 includes only the prime movers 

that are specifically steam-driven turbines (i.e., stand-alone steam turbines, combined cycle 

steam turbines, and combined cycle single shaft). Therefore, the total numbers of plants, electric 

generating units, and capacity presented in Table 3-4 do not match the total numbers presented in 

Table 3-2. EPA included only the steam turbines in Table 3-4 to focus on identifying the fuels 

used to produce electricity using steam. 

Table 3-5 presents the distribution of combined cycle units powered by fossil and nuclear 

fuels. Table 3-5 includes only the prime movers associated with combined cycle units (i.e., 

combined cycle steam turbine, combined cycle single shaft, and combined cycle combustion 

turbine). The stand-alone steam turbines are not included in the table. The 2005 EIA data show 

that natural gas is the predominant fuel source for combined cycle units, accounting for 99 

percent of the total combined cycle capacity. There are a small number of plants that reported 

operating combined cycle units fueled by oil. The two plants that reported coal as the fuel source 

are Integrated Gasification Combined Cycle (IGCC) units. These “coal-fired” combined cycle 

systems are actually powered by syngas generated by a coal gasification process [U.S. DOE, 

2005a]. Section 3.2.10 contains additional information about IGCC systems. 

Table 3-6 presents the steam electric capacity, as well as the number of steam electric 

plants and electric generating units in the industry, distributed by overall plant capacity7

. Table 

3-6 includes the stand-alone steam turbines and all the combined cycle system turbines (i.e., 

combined cycle steam turbine, combined cycle single shaft, and combined cycle combustion 

turbine) in the determination of the number of steam electric plants and steam electric capacity. 

For the number of electric generating units, EPA only included the stand-alone steam turbines, 

the combined cycle steam turbines, and the combined cycle single shaft to estimate the number 

of stand-alone electric generating units and the number of combined cycle systems. According to 

the 2005 EIA data, the largest capacity plants (>500 MW) comprise nearly half of all steam 

electric plants, approximately 60 percent of the electric generating units, and 87 percent of the 

steam electric generating capacity for all plants regulated by the effluent guidelines. Based on the 

2005 EIA data, most steam electric plants are either gas or coal-fired and have a generating 

capacity greater than 500 MWs. 

 

7

 The overall plant capacity includes all electric power generated by the plant, including electricity produced by nonsteam generators and through the use of non-fossil/non-nuclear energy sources. 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-10 

Table 3-4. Types of Fuel Used by Stand-Alone and Combined Cycle Steam Turbines 

Fossil or Nuclear Fuel a Number of Plants b

Number of Electric 

Generating Units 

Total Steam Turbine 

Capacity 

(MW) c

Coal: 488 

(41%) 

1,181 

(46%) 

329,211 

(51%) 

Anthracite Coal, Bituminous Coal 280 697 175,271 

Subbituminous Coal 173 411 130,300 

Lignite Coal 17 29 14,643 

Coal Synfuel 10 22 6,960 

Waste/Other Coal 20 22 2,037 

Petroleum Coke 11 

(0.9%) 

12 

(0.5%) 

778 

(0.1%) 

Oil: 75 

(6.3%) 

147 

(5.7%) 

32,219 

(5.0%) 

Residual Fuel Oil 60 127 30,983 

Distillate Fuel Oil 14 19 1,216 

Waste Oil 1 1 20 

Gas: 619 

(52%) 

1,113 

(44%) 

175,455 

(27%) 

Natural Gas 613 1,104 175,186 

Blast Furnace Gas 2 5 152 

Other Gas 4 4 117 

Nuclear 66 

(5.6%) 

104 

(4.1%) 

105,585 

(16%) 

Total 1,187 

(100%) 

2,557 

(100%) 

643,249 

(100%) 

Source: [U.S. DOE, 2005a]. 

Note: The table includes only the stand-alone steam turbines, combined cycle steam turbines, and combined cycle 

single shaft. The combined cycle combustion turbines are not included in the table. 

a – No steam electric generating units were reported to use jet fuel, kerosene, or gaseous propane in the 2005 EIA 

database. 

b – Because a single plant may operate multiple electric generating units utilizing differing fuel types, the number of 

plants by fuel type is not additive. There are 1,187 plants in the industry that operate at least one stand-alone steam 

turbine, combined cycle steam turbine, or combined cycle single shaft electric generating unit powered by either 

fossil or nuclear fuel. 

c – The total steam electric capacity shown does not equal the sum of the steam electric capacities for each fuel type 

due to rounding errors.
Final Detailed Study Report Chapter 3 – Stea

3-11 

Table 3-5. Distribution of Fuel Types for Combined Cycle Units Regulated by the Steam Electric Power G

Guidelines 

Combined Cycle Steam Turbine 

Combined Cycle Single Shaft (steam 

and combustion turbines share a 

single shaft) 

Combine

Fossil or Nuclear Fuel a

Number of 

Plants b 

Number of 

Electric 

Generating 

Units c 

Total 

Turbine 

Capacity 

(MW) d 

Number of 

Plants b 

Number of 

Electric 

Generating 

Units 

Total 

Turbine 

Capacity 

(MW) c 

Number of 

Plants b 

Coal: 2 2 246 0 0 0 2 

Anthracite Coal, Bituminous Coal 2 2 246 0 0 0 2 

Petroleum Coke 0 0 0 0 0 0 0 Oil: 10 11 399 0 0 0 8 

Residual Fuel Oil 2 2 97 0 0 0 1 Distillate Fuel Oil 7 8 280 0 0 0 6 Waste Oil 1 1 20 0 0 0 1 

Gas: 379 499 69,375 22 50 9,503 380 

Natural Gas 376 495 69,258 22 50 9,503 379 Other Gas 4 4 117 0 0 0 1 

Nuclear 0 0 0 0 0 0 0 Total 392 512 70,020 22 50 9,503 390 

Source: [U.S. DOE, 2005a]. Note: The table includes only the combined cycle steam turbines, combined cycle single shaft, and combined cycle combustion turbine

turbines are not included in this table, but can be found in Table 3-4. 

a – No combined cycle electric generating units were reported to use lignite coal, coal synfuel, subbituminous coal, waste/other coal, je

propane, or blast furnace gas in the 2005 EIA database. b – Because a single plant may operate multiple electric generating units utilizing differing fuel types, the number of plants by fuel type c – The 2005 EIA database contains a total of 506 combined cycle steam turbines, with an additional six plants reporting at least one coturbine, but not a combined cycle steam turbine. EPA believes that these six plants likely operate a combined cycle steam turbine; thereeach of the six plants operates one combined cycle steam turbine and counted six additional turbines and six additional plants to the num2005 EIA database for the number of combined cycle steam turbines and combined cycle steam turbine plants. d – The total capacity shown does not equal the sum of the steam electric capacities for each fuel type due to rounding errors.

e – One plant in the 2005 EIA database reported having a combined cycle steam turbine electric generating unit and two internal combuunits. Another plant in the database reported a fossil fuel for its combined cycle steam turbine and a non-fossil/non-nuclear fuel for its t

combustion turbines. EPA included the combined cycle steam turbines for these plants in the table, but did not include the internal comcycle combustion turbines using fuels not covered by the effluent guidelines.
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

Table 3-6. Distribution by Size of Steam Electric Capacity, Plants, and Electric 

Generating Units Regulated by the Steam Electric Effluent Guidelines 

Overall Plant 

Capacity a

0-50 

MW 

50-100 

MW 

100-200 

MW 

200-300 

MW 

300-400 

MW 

400-500 

MW >500 MW Total 

Total Steam 

Electric Capacity 

(MW) 

3,033 8,225 20,544 21,075 20,604 27,730 661,476 762,386 b 

Percentage of 

Capacity c 

0.4% 1.1% 2.7% 2.8% 2.7% 3.6% 87% 100% 

Number of Plants 112 120 152 91 64 67 581 1,187

Percentage of 

Plants c 

9.4% 10% 13% 7.7% 5.4% 5.6% 49% 100% 

Number of Steam 

Electric Generating 

Units d 

183 210 257 155 131 148 1,473 2,557 

Percentage of 

Steam Electric 

Generating Units c 

7.2% 8.2% 10% 6.1% 5.1% 5.8% 58% 100% 

Source: [U.S. DOE, 2005a]. 

Note: The number of plants, number of steam electric generating units, and total steam electric capacity includes the 

stand-alone steam turbines, combined cycle steam turbines, combined cycle single shaft, and combined cycle 

combustion turbines. 

a – Overall plant capacity includes electricity produced by both steam and non-steam electric generating units, as 

well as through the use of non-fossil/non-nuclear energy sources. 

b – The total steam electric capacity shown does not equal the sum of the steam electric capacities for each size 

category due to rounding errors. 

c – The sum of the percentages for each size category may not equal 100 percent due to rounding errors. 

d – EPA estimated the total number of electric generating units as the sum of the stand-alone steam turbines and the 

estimated number of combined cycle systems. EPA did not sum the total number of turbines. EPA estimated the 

number of combined cycle systems by adding the number of combined cycle steam turbines and the number of 

combined cycle single shaft turbines. 

3.2 Steam Electric Process and Wastewater Sources 

Steam electric plants generate electricity using a process that includes: a steam generator 

(i.e., boiler); a steam turbine/electrical generator; and a condenser. Figure 3-2 illustrates the 

stand-alone steam electric process, in which a combustible fuel is used as the energy source to 

generate steam. The Steam Electric Power Generating effluent guidelines regulate wastewaters 

discharged by those steam electric plants that use fossil-type fuel (e.g., coal, oil, or gas) or 

nuclear fuel to generate the steam. However, other fuel sources such as municipal solid wastes or 

wood wastes may also be used to produce the steam for generating electricity. Section 7.1 of this 

report discusses steam electric processes that use alternative fuel sources. 

3-12 
Final Detailed Study Report Chapter 3 – Stea

Figure 3-2. Steam Electric Process Flow Diagram 

3-13 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-14 

As shown in Figure 3-2, fuels are fed to a boiler where they are combusted to generate 

steam. Boilers and their associated subsystems often include components to improve 

thermodynamic efficiency by boosting steam temperature and preheating intake air using 

superheaters, reheaters, economizers, and air heaters. The hot gases from combustion (i.e., the 

flue gas) leaves the steam generator subsystem and passes through particulate collection and the 

sulfur dioxide scrubbing system (if present), then is emitted through the stack. The hightemperature, high-pressure steam leaves the boiler and enters the turbine generator where it 

drives the turbine blades as it moves from the high-pressure to the low-pressure stages of the 

turbine. The spinning of the turbine blades drives the linked generator, producing electricity. The 

lower-pressure steam leaving the turbine enters the condenser, where it is cooled and condensed 

by the cooling water flowing through heat exchanger (condenser) tubes. The water collected in 

the condenser (condensate) is sent back to the boiler where it is again converted to steam 

[Babcock & Wilcox, 2005]. 

The steam electric process may be used in conjunction with other processes that use a 

portion of the thermal energy produced in the boiler. Cogeneration facilities, also known as 

combined heat and power generators, are facilities that use thermal energy to produce electricity 

and also to produce steam or hot water, typically for use in manufacturing processes or for 

central heating. Cogeneration technologies are classified as either bottoming-cycle or toppingcycle systems. In a typical bottoming-cycle system, high temperature steam is first used in a 

manufacturing process and then the waste heat is used to generate steam to drive a turbine for 

generating electricity. In one of two top-cycling configurations, high-temperature high-pressure 

steam from a boiler is used to drive a turbine to generate electricity, and the waste heat or steam 

exhausted from the turbine is then used as a source of heat for an industrial or commercial 

process, such as space heating or food preparation. In another topping-cycle configuration, a 

combustion turbine or diesel engine burns fuel to spin a shaft connected to a generator to produce 

electricity, and the waste heat from the burning fuel is recaptured in a waste-heat recovery boiler 

for use in direct heating or producing steam for thermal applications [U.S. DOE, 2000b]. Some 

of the industrial non-utilities discussed in Section 7.2 are cogeneration plants, and some of the 

alternative-fueled8

 steam electric plants discussed in Section 7.1 may be cogeneration plants. 

The nuclear-fueled steam electric process is similar to the same steam/water system 

described above. Key differences between the nuclear and non-nuclear systems include fuel 

handling, nuclear fission within the reactor core replaces the boiler as the heat source for 

producing steam, and the air pollution control equipment is not needed for the flue gases. No fuel 

is combusted and no ash is generated in a nuclear-fueled steam electric process. Instead, heat is 

transferred from the reactor core by creating steam in boiling water reactors or creating 

superheated water in pressurized-water reactors. The steam turbine/electric generator and 

condenser portions of the nuclear-fueled steam electric process are the same as those described 

for the stand-alone steam electric process [U.S. DOE, 2006c]. 

The remainder of this section discusses the waste streams generated at steam electric 

plants. This section also discusses the combined cycle system process and emerging technologies 

such as IGCC and carbon capture processes. Chapters 4 and 5 discuss FGD and ash handling 

 

8

 An alternative-fueled plant is defined for the purpose of this report as a plant that is not fueled by fossil or nuclear 

fuel. 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

systems and wastewaters in greater detail, as these wastewaters were the focus of the detailed 

study. 

3.2.1 Fly Ash and Bottom Ash 

Combusting coal and oil in steam electric boilers produces a residue of noncombustible 

fuel constituents, referred to as ash. Depending on the boiler design, as much as 70 to 80 percent 

of the ash from a pulverized coal furnace will consist of very fine particles that are light enough 

to be entrained in the flue gas and carried out of the furnace. This portion of the ash is commonly 

known as fly ash. The remaining 20 to 30 percent of the heavier ash that settles in the furnace or 

dislodged from furnace walls is collected at the bottom of the boiler and is referred to as bottom 

ash. Certain boiler designs, such a cyclone boilers, will produce relatively small amounts of fly 

ash, on the order of 20 to 30 percent, and upwards of 70 to 80 percent bottom ash. 

Some of the fly ash will be collected in hoppers located under the economizer and air 

heaters as the coarser particles drop out of suspension as the flue gas flow changes direction. The 

fly ash particles that remain entrained in the flue gases are carried to the particulate control 

equipment, such as baghouses and electrostatic precipitators, for removal. The captured fly ash is 

collected in hoppers and then either pneumatically transferred as dry ash to silos for temporary 

storage or sluiced with water to a surface impoundment (i.e., ash pond). Dry fly ash stored in the 

silos is periodically transferred, usually by truck, to either a landfill or for use offsite. 

Bottom ash is usually hydraulically conveyed (i.e., sluiced with water) to either an ash 

pond or dewatering bin. In such a system, the hot bottom ash drops to the bottom of the furnace 

where it is quenched in a water-filled hopper. Ash from the hopper is fed into a conveying line 

where it is diluted into slurry and pumped to the ash pond or dewatering storage bin. The ash 

sent to a dewatering bin is separated from the transport water, then sent to a landfill or 

transported offsite. 

An alternative to the hydraulic bottom ash handling system is the mechanical drag 

system. As is the case with the hydraulic systems, the bottom ash first drops to the bottom of the 

furnace where it is quenched in a water bath. The ash is then removed from the furnace using a 

submerged mechanical drag conveyor, which is essentially a parallel pair of chains with 

crossbars attached at regular intervals. Ash conveyed out of the bottom of the furnace is typically 

dumped into a nearby bunker and periodically trucked to landfill or sent offsite. 

At any given facility, either the fly ash or bottom ash, or both, may be handled in a wet or 

dry fashion. If handled wet, the fly ash and bottom ash may be stored in a common ash pond or 

in separate impoundments. Coal-fired power plants typically generate large quantities of both fly 

ash and bottom ash. Oil-fired plants produce less ash than coal-fired plants, and most of the ash 

produced is fly ash. Natural gas-fired plants do not produce ash. The characteristics of ash 

depend to some degree on the type of fuel combusted, how it is prepared prior to combustion, 

and the operating conditions of the boiler. Fly ash and bottom ash transport waters typically 

contain heavy metals, including priority pollutants [U.S. EPA, 1982]. Chapter 5 further discusses 

ash handling operations and wastewater generation at coal-fired power plants. 

3-15 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3.2.2 Flue Gas Desulfurization 

Power plants use FGD scrubber systems to remove SO2 from stack emissions. Typically, 

FGD scrubber systems can remove over 90 percent of the SO2 in the flue gas, and in many cases 

can remove up to or greater than 99 percent. Wet FGD scrubbers are the most common; 

however, dry FGD scrubbers also exist [U.S. EPA, 2003]. Although dry FGD scrubbers use 

water in their operation, they do not generate any wastewaters. 

In wet FGD scrubbers, the flue gas stream comes in contact with a liquid stream 

containing a sorbent, which is used to effect the mass transfer of pollutants from the flue gas to 

the liquid stream. Figure 3-3 presents a simplified diagram of a typical wet FGD system. The 

sorbents typically used for SO2 absorption are lime (Ca(OH)2) or limestone (CaCO3), which react 

with the sulfur in the flue gas to form calcium sulfite (CaSO3). Scrubber systems can be operated 

with varying levels of oxidation. In forced oxidation systems, the CaSO3 is fully oxidized to 

produce gypsum (CaSO4 • 2H2O). Section 4.2 discusses these processes in further detail. 

Figure 3-3. Typical Wet FGD System 

Limestone forced oxidation systems are the most common scrubbers operated in the 

steam electric industry today. Plants that generate gypsum using limestone forced oxidation 

systems can market the gypsum for use in building materials (e.g., wallboard), while plants that 

do not generate gypsum or only partially oxidize the CaSO3 must dispose of their scrubber 

solids, typically in landfills or surface impoundments [U.S. EPA, 2006a]. Plants that are 

producing a saleable product, such as gypsum, may rinse the product cake to reduce the level of 

chlorides in the final product. This wash water may be reused or potentially treated and 

discharged. Both sludge by-products, gypsum and CaSO3, typically require dewatering prior to 

sale, disposal, or processing for reuse. This dewatering process generates a wastewater stream 

that likely needs to be treated before it is discharged or reused. FGD scrubber system 

wastewaters, including the wastewater stream from dewatering and scrubber blowdown, may 

contain significant concentrations of metals, such as arsenic, mercury, and selenium. During the 

scrubbing process, metals and other constituents that were not removed from the flue gas stream 

by the electrostatic precipitators (ESPs) may be transferred to the scrubber blowdown and other 

downstream wastewaters and/or solid products. 

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3-17 

FGD wastewaters are currently regulated by the effluent guidelines as low volume wastes

generated at steam electric plants [40 CFR 423.11(b)]. EPA first identified FGD wastewater as a 

potential wastewater for regulation during the 1982 rulemaking. At that time, EPA concluded 

that the available data were not sufficient for characterizing the pollutant loadings from FGD 

systems and that additional studies would be needed. [U.S. EPA, 1982]. Chapter 4 contains more 

information on FGD systems, FGD wastewater characteristics, and the treatment of FGD 

wastewater. 

3.2.3 Selective Catalytic Reduction 

Selective catalytic reduction (SCR) is a technology used to control nitrogen oxide (NOx) 

emissions in the flue gas from the boiler. Ammonia (NH3) is injected into the flue gas upstream 

of a catalyst, such as vanadium or titanium. The NOx in the flue gas (comprising mainly nitrogen 

monoxide (NO) with lesser amounts of nitrogen dioxide (NO2)) reacts with the NH3 in the 

presence of oxygen and the catalyst to form nitrogen and water: 

4NO + 4NH3 + O2 → 4N2 + 6H2O (3-1) 

 2NO2 + 4NH3 + O2 → 3N2 + 6H2O (3-2) 

In addition to these primary reactions, a fraction of the SO2 in the flue gas may be 

oxidized to sulfur trioxide (SO3), and other side reactions may produce ammonium sulfate 

((NH4)2SO4) and ammonium bisulfate (NH4HSO4) as by-products: 

 SO2 + 1⁄2 O2 → SO3 (3-3) 

 2NH3 + SO3 + H2O → (NH4)2SO4 (3-4) 

 NH3 + SO3 + H2O → NH4HSO4 (3-5) 

These by-products can foul and corrode downstream equipment. The extent to which they 

are formed depends upon various factors within the process, including the sulfur content of the 

coal used in the boiler and the amount of excess NH3 in the system. Unreacted NH3 present in 

the flue gas from the SCR is commonly termed ammonia slip [CCT, 1997]. 

Plants may use different SCR configurations based on the particular operations of the 

system, including placing the SCR upstream of the air heater9

 and other emission control devices 

such as a FGD scrubber and/or particulate controls (e.g., ESP). Although the SCR does not 

produce a waste stream, it can affect the characteristics of fly ash transport water, air heater wash 

water, and FGD wastewater. As previously explained, unreacted NH3 and SO3 by-product can 

create (NH4)2SO4 and NH4HSO4, which can deposit in the air heater and must be removed 

through periodic washes. Ammonia that passes unreacted through the SCR may attach to the 

particulates in the flue gas and be removed from the flue gas in the air pollution control 

equipment (e.g., ESP, baghouse, FGD scrubber). Because ammonia is soluble, if the ash 

collected from the particulate removal device is handled with a wet system (e.g., wet sluicing), 

 

9

 The air preheater utilizes the heat contained in the flue gas to increase the temperature (via heat exchange) of the 

air injected into the boiler for combustion. 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

then the ammonia will likely partition into the wastewater and be discharged from the plant 

[Wright, 2003].

In addition to reducing the ammonia slip, installing an SO3 removal system before the air 

heater may further reduce the amount of (NH4)2SO4 and NH4HSO4 formed and deposited in the 

air heater and, consequently, the amount of NH3 in the air heater wash water [Wright, 2003]. 

3.2.4 Condenser Cooling 

In the steam electric process, a constant flow of cooling water is required to maintain 

steam condensation and a low pressure in the condenser. Steam electric plants typically use 

either once-through cooling water systems or recirculating cooling water systems to condense the 

steam from the process. In once-through cooling water systems, the cooling water is withdrawn 

from a body of water, flows through the condenser, and is discharged back to the body of water. 

A recirculating cooling system recirculates the cooling water required to maintain steam 

condensation and a low pressure in the condenser. After it passes through the condenser, the 

heated water is sent to a cooling tower to lower its temperature. The heated water enters the 

cooling tower at the top and falls down the packing material in the tower. Air flows upward 

through the tower, and as the air contacts the droplets of water, some of the water evaporates. 

The high surface area of the packing material enhances evaporation. As water evaporates, the 

latent heat required to evaporate the water is transferred from the water to the air, cooling the 

water. Fresh water is periodically added to the cooling water system to make up for evaporative 

losses. Additionally, as cooling water evaporates in the cooling tower dissolved minerals present 

in the water remain behind in the system. Over time, these minerals will increase in 

concentration. To prevent these minerals from building up to unacceptable levels, a volume of 

water must be discharged periodically to purge the minerals from the system, which is referred to 

as “cooling tower blowdown.” Figure 3-4 presents a diagram of a recirculating cooling system. 

Figure 3-4. Diagram of a Recirculating Cooling System 

As the cooling water passes through the condenser, microbiological species (e.g., 

bacterial slimes and algae) stick to and begin growing on the condenser tubes. This growth, 

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3-19 

referred to in the industry as biofouling, reduces heat transfer, decreases flow, and accelerates 

corrosion of the condenser. Various macro-organisms, such as mussels, mollusks, and clams, can 

also inhibit condenser performance. Steam electric plants use biocides, such as sodium 

hypochlorite, sodium bromide, or chlorine gas, to control biofouling on the condenser tubes and 

cooling tower packing material. Plants may also use chlorine or other antimicrobials, or other 

methods (e.g., mechanical, thermal) to control macro-organisms. 

Once-through cooling water and cooling tower blowdown may contain the following 

pollutants, often in low concentrations, as a result of chlorination and corrosion and erosion of 

the piping, condenser, and cooling tower materials: chlorine, iron, copper, nickel, aluminum, 

boron, chlorinated organic compounds, suspended solids, brominated compounds, and 

nonoxidizing biocides. Although the pollutants present in cooling water-related wastewaters are 

often at low concentrations, the overall pollutant mass discharge may be significant due to the 

large flow rates of cooling water discharges at steam electric power plants. 

Once-through cooling water is the largest volume wastewater discharge at coal-fired 

power plants. EPA’s data request obtained information on once-through cooling water flows 

from 15 plants. The once-through cooling water flow rates at these plants ranged from 178 to 

1,860 million gallons per day (mgd), with an average discharge rate of 720 mgd. Recirculating 

cooling water systems minimize the amount of water used by steam electric plants. On average, 

recirculating cooling water systems reduce the cooling water flow rate between 92 and 95 

percent compared to once-through cooling systems, depending on the water source [U.S. EPA, 

2001]. According to information obtained through the data request, the average cooling tower 

blowdown flow rate (for 16 coal-fired power plants and 39 recirculating cooling water systems) 

is 37.7 mgd. The recirculating cooling water flow rates for these plants ranged from 0.89 to 512 

mgd. These data generally compare to the cooling water flow rate data presented in the 1996 

Preliminary Data Study and the 1982 Development Document [U.S. EPA, 1996; U.S. EPA, 

1982]10. 

Although recirculating cooling systems reduce the amount of water used by the cooling 

system, they consume more water than once-through cooling systems. Recirculating cooling 

systems use evaporation to remove heat from the cooling water, and the water evaporated is lost 

from the system. In a once-through cooling system, all the water used for cooling is discharged 

from the cooling water system. 

Some plants have implemented dry cooling technology to minimize cooling water usage, 

due in part to water shortages that exist in arid parts of the world. Dry cooling systems transfer 

heat to the atmosphere without water evaporation. There are two types of dry cooling systems for 

power plant applications: direct dry cooling and indirect dry cooling. Direct dry cooling systems 

use air to directly condense steam, whereas indirect dry cooling systems use a closed-cycle water 

cooling system to condense steam, and the heated water is then cooled by air. 

 

10 The 1982 Development Document states that the average flow rate through a once-through cooling system was 

305 mgd and the average blowdown flow rate from a recirculating cooling system was 0.94 mgd, based on industry 

survey data [U.S. EPA, 1982]. The 1996 Preliminary Data Study states that for a 1,150-MW coal-fired power plant, 

the once-through cooling water flow rate is approximately 1,440 mgd and the cooling tower blowdown flow rate 

ranges from 13.6 mgd to 36.6 mgd, depending on the cycle of concentration [U.S. EPA, 1996]. 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

After the cooling water has been used to condense the steam in the condenser, the oncethrough or recirculating cooling water is discharged (treated or untreated) to surface waters or a 

POTW, or reused in other processes such as FGD make-up or transporting fly ash or bottom ash 

to the ash pond. 

Some plants use the large flow rates of the cooling water discharges to help meet their 

effluent limits for other process wastewaters by diluting these other process wastes. This dilution 

allows plants to meet low concentration limits for certain metals or other pollutants, but it does 

not reduce the overall mass of pollutants discharged from the plant. This could result in nutrient 

loads or bioaccumulative metals, such as arsenic, mercury, or selenium, accumulating in the 

receiving water body. 

Some plants treat the cooling tower blowdown generated at the plant, including a number 

of plants that use vapor-compression evaporation systems in combination with a final drying 

process for treatment system residuals, to treat cooling tower blowdown. Section 4.3 describes 

the operation of vapor-compression evaporation/distillation systems used to treat FGD 

wastewaters. The systems used to treat cooling tower blowdown are similar to the system used to 

treat FGD scrubber purge; however, it is generally easier and more economical for plants to treat 

cooling tower blowdown because cooling tower blowdown does not contain the types of salts 

present in FGD scrubber purge. The distillate generated from the vapor-compression evaporation 

system is reused for processes such as boiler or cooling water make up. 

Several best management practices and treatment technologies are available to reduce the 

discharge of chlorine and other biocides from steam electric plants. The 1982 Development 

Document describes the following four biocide management practices in use at steam electric 

plants for once-through and/or recirculating cooling systems [U.S. EPA, 1982; UWAG, 2006]: 

• Low-level biocide application. Perform optimization study to determine 

minimum amount of biocide needed to control biofouling; 

• Natural decay of total residual oxidants (TRO)/free available oxidants. Isolate 

(i.e., shut off) blowdown from cooling system after biocide application until the 

biocide has naturally decayed to an acceptable level; 

• Dechlorination (Dehalogenation). Add reducing agent, typically sulfur dioxide, 

to the cooling water stream prior to discharge to consume the oxidizing biocide 

present; and 

• Mechanical cleaning. Clean the condenser tubes using a mechanical operation 

(e.g., circulate oversized sponge rubber balls through the condenser tubes) instead 

of using biocides, or to allow for reduced use of biocides. 

3.2.5 Low Volume Wastes 

Low volume wastes, as defined by the effluent guidelines, include a variety of waste 

streams, such as wastewater associated with wet scrubber air pollution control systems, ion 

exchange water treatment systems, water treatment evaporator blowdown, laboratory and 

sampling streams, boiler blowdown, floor drains, cooling tower basin cleaning wastes, and 

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Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

recirculating house service water systems. See 40 CFR 423.11. The wastewater associated with 

wet scrubber air pollution control systems are described in section 3.2.2 and chapter 4 of this 

report. The 1982 Development Document presents information on the generation and 

characteristics of boiler blowdown, boiler feed water treatment wastewaters, and drains and 

spills. For example, the 1982 Development Document describes that boiler blowdown can be 

discharged continuously or intermittently to control the build-up of suspended and dissolved 

solids in the boiler water and that the average blowdown flow rate is 33,000 gpd/plant (for 231 

coal-fired power plants) [U.S. EPA, 1982]. 

Low volume wastes are typically combined with other plant wastewaters for treatment, 

often in settling ponds. In some cases, low volume wastewaters can be recycled within the plant. 

One data request plant reported using untreated low volume wastewater as a source for bottom 

ash sluicing and another reported using it as a source for FGD make-up water. Some plants also 

report reusing settling pond effluent from systems that receive a variety of wastewaters including 

ash transport water and low volume wastes. 

3.2.6 Metal Cleaning 

The Steam Electric Power Generating effluent guidelines define metal cleaning waste as 

“any wastewater resulting from cleaning [with or without chemical cleaning compounds] any 

metal process equipment, including, but not limited to, boiler tube cleaning, boiler fireside 

cleaning, and air preheater cleaning.” (See 40 CFR 423.11). Chemicals are used to remove scale 

and corrosion products that accumulate on the boiler tubes and retard heat transfer. The major 

constituents of boiler cleaning wastes are the metals of which the boiler is constructed, typically 

iron, copper, nickel, and zinc. Boiler firesides are commonly washed with a high-pressure water 

spray against the boiler tubes while they are still hot. Fossil fuels with significant sulfur content 

will produce sulfur oxides that adsorb on air preheaters. Water with alkaline reagents is often 

used in air preheater cleaning to neutralize the acidity due to the sulfur oxides, maintain an 

alkaline pH, and prevent corrosion. The types of alkaline reagents used include soda ash, caustic 

soda, phosphates, and detergent. 

Metal cleaning wastes are generated infrequently at many plants, with some operations 

taking place perhaps once every 10 years. The metal cleaning wastewater is often sent to an ash 

pond, but it may first receive initial treatment in a separate impoundment/basin as necessary to 

meet NPDES permit limitations such as limitations on pH and selected metals. Some plants 

handle metal cleaning wastes differently than other wastewaters because the metal cleaning 

wastes are generated so infrequently and often have high pollutant concentrations. For example, 

one plant EPA visited transfers its metal cleaning wastes to a concrete basin and allows the water 

to evaporate over time (e.g., several years). Another plant EPA visited has its metal cleaning 

wastes hauled off site by a contractor. Some plants have reported that they do not discharge 

metal cleaning wastewater, accomplishing this by feeding the wastes to the boiler. The 1982 

Development Document discusses the use of incineration, ash basin treatment, and physical 

chemical treatment as options for handling metal cleaning wastes [U.S. EPA, 1982]. 

3.2.7 Coal Piles 

Coal-fired power plants typically receive the coal via train or barge; however, depending 

on the location of the mine, trucks may also be used to transport the coal to the plant. The coal is 

unloaded in a designated area and conveyed to an outdoor storage area, referred to as the coal 

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Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

pile. Power plants generally store between 25 and 40 days worth of coal in the coal pile, but this 

varies by plant. Some coal-fired plants may operate more than one coal pile depending on the 

location of the boilers and whether different types of coal are used or blended. 

Rainwater and melting snow contacting the coal pile generates a waste stream that 

contains pollutants associated with the coal, referred to as coal pile runoff. The quantity of runoff 

depends upon the amount of precipitation, the physical location and layout of the pile, and the 

extent to which water infiltrates the ground underneath the pile. Coal pile runoff is usually 

collected in a runoff pond during or immediately after times of rainfall. Table 3-7 presents the 

estimated coal pile runoff flow rates reported in the data request responses. Most of the flow 

rates in Table 3-7 were estimated by the plants based on the amount of rainfall at the plant, the 

size of the coal pile, and a runoff coefficient (based on plant experiences). The flow rates that are 

normalized on a MW basis are based on the plants’ total coal-fired capacity. The average coalfired capacity for the 30 plants included in the dataset is 1,490 MW per plant, and the median 

coal-fired capacity per plant is 1,300 MW. 

Table 3-7. Coal Pile Runoff Generation Reported for the EPA Data Request 

Number of Plants Average a Median a Range a 

Number of days runoff was 

generated in 2006 b 

30 133 124 40 – 365 

Flow Rate per Plant

gpy/plant 30 31,100,000 17,600,000 2,070,000 – 364,000,000

Flow Rate Normalized by Coal-Fired Capacity 

gpy/MW c 30 19,300 12,600 2,650 – 109,000 

Flow Rate Normalized by Tons of Coal Burned 

gpy/Ton of Coal 30 6.61 5.20 1.25 – 26.2 

Source: [U.S. EPA, 2008a]. 

Note: The coal pile runoff flow rate depends upon the geographic location of the plant (determines the amount of 

rainfall), the capacity of the plant, and the amount of coal reserve at the plant (determines the size of the pile). 

a – The flow rates presented have been rounded to three significant figures. 

b – Estimated number of days coal pile runoff wastewater was generated in 2006. 

c – For this summary, EPA assumed that the total capacity for each coal-fired steam electric unit is associated with 

coal use. Non-coal-fired units are not included in the capacity calculations. 

EPA also obtained coal pile runoff data from the NPDES Form 2C data provided by 

UWAG. Within this dataset, there were 13 plants which reported a discharge for coal pile runoff. 

Of these 13 plants, 7 reported flow rates associated with the outfall. The average flow rate for 

these 7 plants was 213 gpm, but the flow rates ranged from 25 to 953 gpm [UWAG, 2008]. EPA 

did not calculate the flow rates in gallons per year because EPA does not have data for the 

duration or the frequency of the discharge from the outfalls in the Form 2C data set. 

The type and amount of contaminants generated in coal pile runoff depends upon the coal 

characteristics and the residence time of water within the coal pile. The rainfall generating the 

coal pile runoff can dissolve inorganic salts or cause chemical reactions in the coal piles, which 

will be carried away in the runoff. Coal pile runoff is typically acidic due to the oxidation of iron 

sulfide, which produces sulfuric acid, and ferric hydroxide or ferric sulfate. Coal pile runoff may 

contain high concentrations of copper, iron, aluminum, nickel, and other constituents present in 

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Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

coal [U.S. EPA, 1982]. Plants typically direct coal pile runoff wastewaters to a holding pond 

along with stormwater runoff from other areas near the coal pile. 

During the site visit program, EPA requested that plants report the pH of their coal pile 

runoff ponds. In some cases, EPA collected the pH measurement directly while on site, while in 

other cases the plants collected the measurements before, during, or after EPA’s site visit. These 

coal pile runoff ponds were generally acidic with observed pH values often near 3 S.U. The 

lowest pH observed in a coal pile runoff pond during a site visit was 2.57 S.U. The highest 

observed pH was 8 S.U.; however, in this case, the plant’s coal pile runoff pond also received 

limestone pile runoff. 

Because the transfers to the coal pile runoff are intermittent depending on rainfall, and 

the transfers from the coal pile runoff pond are based on the level in the pond, the residence time 

for treating the coal pile runoff is highly variable. For example, if the plant receives a heavy 

rainfall for several hours causing the pond to overflow and transfer the runoff to surface waters, 

then some of the runoff may only have been managed in the pond for an hour or two before 

being discharged. However, if the plant receives a light rainfall that doesn’t cause the pond to 

overflow and the plant receives no rain for several weeks, then the rainfall that was collected will 

have been in the pond that entire time. Most of the coal pile runoff ponds that EPA visited during 

the site visit program are designed to manage the volume of coal pile runoff associated with a 

10-year, 24-hour storm event. 

3.2.8 Landfill Leachate and Runoff 

Coal combustion residues (CCR) comprise a variety of wastes from the coal combustion 

process, including fly ash, bottom ash, boiler slag, and FGD solids (e.g., gypsum and calcium 

sulfite). CCR may be stored at the plant in on-site landfills or surface impoundments. Leachate is 

the liquid that drains or leaches from a landfill or an impoundment. The two sources of landfill 

leachate are precipitation that percolates through the waste deposited in the landfill and the 

liquids contained within the CCR when it was placed in the landfill. Surface runoff is 

precipitation that contacts the landfill wastes and flows over the landfill. Landfills typically have 

some sort of storm water drainage to minimize the amount of rainwater entering the landfill. 

Figure 3-5 presents a diagram depicting the generation and collection systems for landfill 

leachate and landfill runoff. 

As discussed in Section 4.2, some plants operating FGD systems can completely reuse 

the FGD wastewater. To do this, most of these plants dispose of the FGD solids (i.e., gypsum or 

calcium sulfite) in an on-site landfill. Additionally, many plants transfer fly ash or bottom ash to 

an on-site landfill. These FGD solids and ash contained in the landfill can contaminate the water 

that contacts it and this wastewater may eventually be discharged as contaminated runoff or 

leachate. 

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Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

Figure 3-5. Diagram of Landfill Leachate and Landfill Runoff Generation and Collection 

Landfill leachate and surface runoff will contain heavy metals and other contaminants 

through the contact with the CCRs. Because the various CCRs have different characteristics 

(e.g., pollutant levels, moisture content, leaching ability), the characteristics of the leachate and 

runoff depend upon the types of CCRs that are contained in the landfill. EPA’s ORD is currently 

conducting research evaluating the potential for pollutants to leach during the disposal or use of 

CCRs. This research is being conducted to identify any potential cross-media transfers of 

mercury and other metals and to meet EPA’s commitment in the Mercury Roadmap 

(www.epa.gov/hg/roadmap.htm) to report on the fate of mercury and other metals from 

implementation of multi-pollutant control at coal-fired power plants. A series of reports are being 

developed to document the results from the ORD research. Two reports have been published to 

date: 

• Characterization of Mercury-Enriched Coal Combustion Residuals from Electric 

Utilities Using Enhanced Sorbents for Mercury Control [U.S. EPA, 2006a]; and 

• Characterization of Coal Combustion Residues from Electric Utilities Using Wet 

Scrubbers for Multi-Pollutant Control [U.S. EPA, 2008c]. 

These reports document changes in fly ash resulting from the addition of sorbents for 

enhanced mercury capture, and evaluate residues from the expanded use of wet scrubbers. A 

third report currently being prepared will provide data for additional CCR samples to cover coal 

types and air pollution control configurations that were not addressed in the first two reports. 

Adding to the previous research on the leaching potential for fly ash and FGD gypsum, the third 

report will include data for other types of CCRs including non-gypsum scrubber residues 

(primarily scrubber sludge containing calcium sulfite), blended CCRs (non-gypsum scrubber 

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Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

residues, fly ash, and lime), and wastewater treatment filter cake. The data compiled in these 

reports can be used to evaluate the composition and leaching behavior of CCRs. 

Some of the plants that EPA visited during the site visit program have a runoff and/or 

leachate collection system for the landfills they operate. Typically, the leachate collected from 

the landfill flows through a collection system consisting of ditches and/or underground pipes. 

From the collection system, the leachate is transported to a collection pond. The runoff collection 

systems typically consist of one or more small collection ponds surrounding the landfill area. 

The leachate and runoff waters may be treated in separate ponds or combined together. Some 

plants discharge the effluent from these collection ponds, while other plants send the collection 

pond effluent to the ash pond. 

When a landfill has reached its capacity, it will typically be closed (i.e., covered) to 

protect against environmental release of the pollutants contained in the waste. The covering for 

these landfills typically comprises several layers of material, which may include a clay liner to 

keep as much moisture from entering the landfill as possible and a top layer of top soil on which 

vegetation is planted. After the covering is applied to the landfill, the runoff should not become 

contaminated from the solids in the landfill, but because the covering may still be permeable, 

these landfills may continue to generate leachate. 

CCRs can also be stored in surface impoundments (i.e., ash ponds and FGD ponds) as 

well as landfills. Some of these surface impoundments may have liners and collection systems 

similar to the landfills discussed previously. EPA lacks data quantifying the extent to which the 

effluent from the surface impoundment collection systems is recycled back to the surface 

impoundment, rather than discharged directly to surface water. 

3.2.9 Combined Cycle Generating Units 

Approximately 411 power plants operate one or more combined cycle systems fueled by 

fossil or fossil-type fuels to produce electricity. A combined cycle system is a combination of 

one or more combustion turbine electric generating units operating in conjunction with one or 

more steam turbine electric generating units. Combustion turbines, which typically are similar to 

jet engines, are usually fueled with natural gas, but may also be fueled with oil. 

Exhaust gases from combustion are sent directly through the combustion turbine which is 

connected to a generator to produce electricity. The exhaust gases exiting the combustion turbine 

still contain useful waste heat, so they are directed to heat recovery steam generators (HRSGs) to 

generate steam to drive an additional turbine. The steam turbine is also connected to a generator 

(which may be a different generator or the same generator that is connected to a combustion 

turbine) that produces additional electricity. Thus, combined cycle systems use steam turbine 

technology to increase the efficiency of the combustion turbines. Figure 3-6 illustrates the 

combined cycle system process. 

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Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

Figure 3-6. Combined Cycle Process Flow Diagram 

The operation of steam electric units within combined cycle systems is virtually identical 

to stand-alone steam electric units, with the exception of the boiler. In a combined cycle system, 

the combustion turbines and HRSGs functionally take the place of the boiler of a stand-alone 

steam electric unit. The other two major components of steam electric generating units within 

combined cycle systems, the steam turbine/electric generator and steam condenser, are virtually 

identical to those of stand-alone steam electric units. Thus, the wastewaters and pollutants 

generated from the combined cycle system are the same as those from the stand-alone steam 

electric process. These wastewaters include cooling water and steam condensate water treatment 

wastes. 

Combustion turbines may generate wastewaters from emissions control, equipment 

cooling, and equipment cleaning [U.S. EPA, 1996]. Because combustion turbines require cleanburning fuels, combined cycle combustion turbines do not discharge ash wastewaters. Although 

the amount generated from the combustion turbines is relatively low, these wastewaters may 

contain similar pollutants and concentrations as the regulated steam electric wastewaters. 

3.2.10 Integrated Gasification Combined Cycle (IGCC) 

IGCC is an electric power generation process that combines gasification technology with 

both gas turbine and steam turbine power generation (i.e., combined cycle power generation). In 

an IGCC system, a gasifier is used to convert carbon-based feedstock (e.g., coal or petroleum 

coke) into a syngas. The syngas is cleaned of particulates, sulfur, and other contaminants and is 

then combusted in a high-efficiency combustion gas turbine/generator. Heat from the combustion 

turbine exhaust is then extracted in a heat recovery steam generator to produce steam and drive a 

steam turbine/generator. IGCC plants can achieve higher thermodynamic efficiencies, emit lower 

levels of criteria air pollutants, and consume less water than traditional coal combustion power 

plants [Ratafia-Brown, 2002]. 

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Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

According to DOE’s NETL Gasification World Database, 144 plants around the world 

operated gasification systems that generate electricity as of 2007 and approximately 10 

additional gasification plants were planned to be built between 2008 and 2010. The total 2007 

installed global capacity amounts to approximately 29,000 MW of electricity [U.S. DOE, 

2007a]. NETL reports that there are currently 15 operating IGCC projects around the world as of 

March 2009, four of which are commercial-scale [Stiegel, 2009]. Two of these commercial-scale 

IGCC systems are located in the United States -- the 262-MW Wabash River IGCC Repowering 

Project (Wabash River) in Indiana and the 250-MW Tampa Electric Polk Power Station IGCC 

Project (Polk) in Florida. Other U.S. power companies are investigating or planning IGCC 

systems at new or existing plants, such as the proposed Duke Energy Edwardsport Station in 

Knox County, Indiana, which is planning to start up an IGCC plant by 2011 or 2012 [Duke 

Energy, 2009]. 

This section discusses the IGCC operations at the currently operating U.S. systems and 

the wastewaters generated from these systems. The majority of information is specific to the 

Wabash River IGCC gasification process, which EPA visited in February 2009. Supplemental 

information from the Polk process is also included here. The following stages of the Wabash 

River IGCC gasification process are discussed below and shown in Figure 3-7: 

• Gasification and slag handling. A gasifier converts hydrocarbon feedstock into 

gaseous components by applying heat under pressure in the presence of steam. 

The feedstock is broken down into a syngas consisting of primarily hydrogen, 

carbon monoxide, water, and carbon dioxide gases. Sulfur in the fuel is converted 

to primarily hydrogen sulfide (H2S) with a small portion converted to carbonyl 

sulfide (COS). In the gasifier, mineral matter in the fuel forms a molten slag that 

drops down to the bottom of the gasifier into a water quench bath. The slag/water 

slurry is dewatered in a dewatering bin and settler, and the overflow water is 

recycled as slag quench water. 

• Syngas cooling and particulate removal. Syngas contains impurities from the 

coal such as sulfides, chlorides, mercury, particulate matter, and other impurities 

from the feedstock that must be removed prior to combusting the syngas. 

Particulate matter is removed from the syngas using filter elements. 

• Low-temperature heat recovery, chloride scrubbing, and syngas 

moisturization. The particulate-free sour syngas (i.e., syngas containing a 

significant amount of sulfur compounds) is sent to a water scrubber that removes 

chlorides and trace metals from the syngas. The syngas then enters the COS 

hydrolysis unit where COS in the gas is converted to H2S. The syngas is then 

cooled, which condenses water from the syngas and transfers ammonia (NH3), 

carbon dioxide (CO2), and H2S from the syngas into the condensed “sour” water, 

which is transferred to the sour water treatment system. The cooled sour syngas is 

transferred to the acid gas removal system, in which the sulfur compounds are 

removed, producing sweet syngas (i.e. syngas with very few sulfur compounds 

present). The sweet syngas is then moisturized and superheated prior to use in the 

combustion turbine. 

3-27 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

• Acid gas removal. The remaining hydrogen sulfide and carbon dioxide in the 

sour syngas stream are removed in the absorber of the acid gas removal system, 

which uses methyldiethanolamine (MDEA) as a solvent. 

• Sulfur recovery. In the sulfur recovery unit, H2S from the acid gas removal 

stripper and the sour water treatment system is converted into pure, molten 

elemental sulfur (or sulfuric acid, such as in the Polk process). 

• Sour water treatment. Sour water treatment involves removing the ammonia, 

CO2, and H2S dissolved gases in a two-step stripping process in which steam is 

used to drive off the dissolved gases. First, the CO2 and H2S are stripped, 

generating a gas stream and a water stream, a large portion of which is recycled 

for feedstock slurry preparation. A small portion of the water is treated in an 

ammonia stripping column, which generates a “sweet” water stream, which 

contains 500 to 1,000 ppm chlorides. 

Figure 3-7. Wabash River ConocoPhillips E-GasTM Gasification Process 

Although it has been treated by steam stripping, the sweet water stream contains elements 

from the gasifier such as selenium, chromium, and arsenic. Additionally, at the high operating 

temperatures and pressures of a gasification unit, various metal compounds are formed, such as 

selenocyanate, which are not known to be generated in a traditional coal-fired unit. At Wabash 

River, prior to 2002, the sweet water was sent to a settling pond but the plant often was unable to 

meet its permit limits. To resolve this situation, in 2002 a vapor-compression evaporator system 

was installed at Wabash River to treat the sweet water. The concentrated brine from the 

evaporator is sent to a rotary drum dryer that concentrates the pollutants through evaporation and 

deposits solid waste on the drum as a cake. The salt cake, which is treated as a hazardous waste 

due to selenium and arsenic levels, is hauled away one to two times per week and it is made into 

3-28 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

a cement product that is used for stabilization only (i.e., for disposal). The distillate from the 

rotary drum dryer is sent to the gasification wastewater settling pond. The effluent from the 

gasification wastewater settling pond is transferred to Wabash River’s ash pond and then 

discharged. Since operation of the evaporator unit, Wabash River has had more success in 

meeting its permit requirements [ERG, 2009f; EPRI, 2007d]. 

The following is a list of the key wastewaters that are associated with the operation of the 

Wabash River IGCC unit: 

• Rotary drum dryer distillate; 

• Slag handling wastewater; 

• Blowdown from the heat recovery steam generator; 

• CO2 stripper wastewater 

• Petroleum coke pile runoff pond effluent; 

• Air separation unit blowdown; 

• Raw water filtration backwash; 

• Demineralizer system reject; 

• Sump water (miscellaneous liquid waste from the process area); and 

• Cooling tower blowdown. 

The rotary drum dryer distillate, cooling tower blowdown, and sump water is treated in 

the gasification wastewater settling pond. Other wastewaters generated in the Wabash River 

IGCC gasification process are able to be reused in the gasifier or in the feedstock slurry 

preparation [ERG, 2009f; Wabash River Energy, 2000]. 

The processes and wastewaters generated at the Polk plant are generally similar to those 

described above for Wabash River, with a few differences. The major difference is that Polk uses 

a brine concentrator/evaporator system to treat the gasification process wastewater. The only 

solid product from the brine evaporator is ammonium chloride, which is transferred to a landfill. 

The distillate from the brine concentrate displaces boiler make-up boiler feed water for 

instrument tap purges and pump seal flushes. Because the distillate is reused, there are no 

wastewaters discharged from Polk’s gasification process [EPRI, 2007d; Tampa Electric 

Company, 2008]. 

Because IGCC syngas contains high concentrations of carbon compared to postcombustion flue gas, CO2 capture is expected to be less expensive for pre-combustion capture 

from IGCC systems than for post-combustion capture. Although no current IGCC plants use 

carbon capture, several technologies have been proposed. One is to convert the carbon monoxide 

in the syngas to carbon dioxide and hydrogen gas using a water gas shift reactor [EPRI, 2009]. 

The following section discusses carbon capture and storage processes in more detail. 

3.2.11 Carbon Capture and Storage 

Carbon capture and storage is an approach being investigated to reduce or mitigate the 

contribution of fossil fuel emissions to global warming. Due to potential future regulations on 

carbon dioxide (CO2) emissions, many steam electric power plants are considering alternatives 

available for reducing carbon emissions. 

3-29 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-30 

There are three main approaches for capturing the CO2 associated with generating 

electricity: post-combustion, pre-combustion, and oxyfuel combustion. 

• In post-combustion capture, the CO2 is removed after combustion of the fossil 

fuel. 

• In pre-combustion capture, the fossil fuel is partially oxidized, for instance in a 

gasifier. The resulting syngas (CO and H2) is shifted into CO2 and more H2 and 

the resulting CO2 can be captured from a relatively pure exhaust stream before 

combustion takes place. 

• In oxy-fuel combustion, also known as oxy-combustion, the fuel is burned in 

oxygen instead of air. The flue gas consists of mainly carbon dioxide and water 

vapor, the latter of which is condensed through cooling. The result is an almost 

pure carbon dioxide stream that can be transported to the sequestration site and 

stored. Processes based on oxyfuel combustion are sometimes referred to as "zero 

emission" cycles, because the CO2 stored is not a fraction removed from the flue 

gas stream (as in the cases of pre- and post-combustion capture) but the flue gas 

stream itself. However, a certain fraction of the CO2 generated during combustion 

will inevitably end up in the condensed water. 

After capture, the CO2 would be transported to a suitable storage, or sequestration, site. 

Approaches under consideration include geologic sequestration (injection of the CO2 into an 

underground geologic formation), ocean sequestration (typically injecting the CO2 into the water 

column at depths to allow dissolution or at deeper depths where the CO2 is denser than water and 

would form CO2 “lakes”), and mineral storage where CO2 is exothermically reacted with metal 

oxides to produce stable carbonates. 

DOE’s National Energy Technology Laboratory (NETL) is currently leading a research 

effort to develop retrofit technologies for coal-fired power plants, including the oxy-combustion 

process, and pre-combustion carbon capture technologies specifically for IGCC plants (see 

Section 3.2.10 for discussion of the IGCC process) [U.S. DOE, 2009]. Based on preliminary 

information regarding these technologies, EPA believes they may result in new air pollution 

control wastewaters that will need to be addressed at steam electric power plants. However, as 

these technologies are currently in the early stages of research and development and/or pilot 

testing, the industry has little information on the potential wastewaters generated from carbon 

capture processes or the characteristics of these wastewaters. 

American Electric Power’s (AEP’s) Mountaineer Power Plant and We Energies’ Pleasant 

Prairie Power Plant are participating in EPRI-led pilot tests demonstrating one of Alstom 

Corporation’s post-combustion carbon capture technologies, the chilled ammonia process 

[Alstom, 2009]. Alstom has several demonstration projects11 either operating or being built for 

three carbon capture technologies: chilled ammonia, advanced amines, and oxy-combustion. The 

Pleasant Prairie Power Plant CO2 capture project started operating in 2008 and the Mountaineer 

Power Plant CO2 capture and storage pilot project is expected to start operating this year. The 

latter project will be the first phase of the Alstom/AEP two-phase process to bring the chilled 

ammonia process to full scale by 2011. For the second phase, Alstom plans to design, build, and 

 

11 Alstom has four carbon capture projects operating or under construction, and six additional projects scheduled. 

These projects are taking place in seven different countries using coal, oil, or natural gas as fuels [Alstom, 2008] 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

add the first commercial-scale CO2 capture system at one of the AEP plants [Power Magazine, 

2008]. 

The chilled ammonia process planned at Mountaineer absorbs and strips CO2 from flue 

gas following the FGD process (see Figure 3-8). First, the water-saturated flue gas is cooled and 

cleaned by refrigerated water injected directly into the gas stream. As the flue gas is cooled, 

water condenses from the gas, carrying the residual contaminants with it. The water is then 

evaporated in cooling towers, which reduces the total flue gas volume prior to entry into the CO2 

absorber unit. In the absorber, a dissolved and suspended mix of ammonium carbonate and 

ammonium bicarbonate reacts with the flue gas, potentially removing 90 percent or more of the 

CO2 in the flue gas. The cleaned flue gas exits the absorber and then exits the stack. Residual 

ammonia is captured by a cold-water wash and recycled to the absorber. The CO2-rich slurry is 

pumped through a heat exchanger, in which the slurry is dissolved. The slurry is then transferred 

to a high-pressure regenerator, in which additional heat is added by a reboiler and the CO2 gas is 

stripped from the solution. The removed CO2 can be washed, compressed, and sequestered by 

injection into geologic formations, such as deep saline aquifers or depleted oil and gas reservoirs. 

[AWMA, 2008; Power Magazine, 2008]. 

Source: [Power Magazine, 2008]. 

Figure 3-8. AEP’s Chilled Ammonia Process at Mountaineer Power Station 

As discussed previously in this section, there are other post-combustion carbon capture 

technologies currently being developed for the industry. One such technology is planned to be 

pilot tested at the Alabama Power Company’s Plant Barry beginning in 2011. The pilot test is a 

partnership between DOE, Mitsubishi Heavy Industries, EPRI, and Southern Company. The 

carbon capture technology is an amine solvent based technology developed by Mitsubishi Heavy 

Industries [POWERnews, 2009]. 

3-31 
Final Detailed Study Report Chapter 3 – Steam Electric Industry Profile 

3-32 

3.3 Effluent Guidelines for the Steam Electric Power Generating Point Source Category 

The Clean Water Act establishes a structure for regulating discharges of pollutants to 

surface waters of the United States. As part of the implementation of the Act, EPA issues 

effluent guidelines for industrial dischargers. EPA first issued effluent guidelines for the Steam 

Electric Power Generating Point Source Category (i.e., the Steam Electric effluent guidelines) in 

1974 with subsequent revisions in 1977 and 1982. The Steam Electric effluent guidelines are 

codified at 40 CFR Part 423 and include limitations for the following waste streams: 

• Once-through cooling water; 

• Cooling tower blowdown; 

• Fly ash transport water; 

• Bottom ash transport water; 

• Metal cleaning wastes; 

• Coal pile runoff; and 

• Low-volume waste sources, including but not limited to wastewaters from wet 

scrubber air pollution control systems, ion exchange water treatment systems, 

water treatment evaporator blowdown, laboratory and sampling streams, boiler 

blowdown, floor drains, cooling tower basin cleaning wastes, and recirculating 

house service water systems (sanitary and air conditioning wastes are not 

included) [40 CFR 423.11(b)]. 

The current effluent guidelines are summarized in Table 3-8 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.” [40 CFR 423.10] 

The effluent guidelines do not apply to plants that primarily use a non-fossil or nonnuclear fuel source (e.g., wood waste, municipal solid waste) to power the steam electric 

generators, nor do they apply to generating units operated by establishments that are not 

primarily engaged in generating electricity for distribution and sale. 
Final Detailed Study Report Chapter 3 – Stea

3-33 

Table 3-8. Current Effluent Guidelines and Standards for the Steam Electric Power Generating Point 

Waste Stream BPT a BAT a NSPS a P

All Waste Streams pH: 6-9 S.U. b

PCBs: Zero discharge 

PCBs: Zero discharge pH: 6-9 S.U. b

PCBs: Zero discharge 

PCBs: Z

Low-Volume Wastes 

TSS: 100 mg/L; 30 mg/L Oil & Grease: 20 mg/L; 15 mg/L 

TSS: 100 mg/L; 30 mg/L Oil & Grease: 20 mg/L; 15 mg/L 

Fly Ash Transport TSS: 100 mg/L; 30 mg/L 

Oil & Grease: 20 mg/L; 15 mg/L 

Zero discharge Zero dis

(PSNS oNo limit

Bottom Ash Transport 

TSS: 100 mg/L; 30 mg/L Oil & Grease: 20 mg/L; 15 mg/L 

TSS: 100 mg/L; 30 mg/L Oil & Grease: 20 mg/L; 15 mg/L 

Once-Through Cooling 

Free Available Chlorine: 0.5 mg/L; 0.2 mg/L 

Total Residual Chlorine: If > 25 MW: 0.20 mg/L 

instantaneous maximum; If < 25 MW, equal to BPT 

Total Residual Chlorine: If > 25 MW: 0.20 mg/L 

instantaneous maximum; If < 25 MW, equal to BPT 

Cooling Tower Blowdown 

Free Available Chlorine: 0.5 mg/L; 0.2 mg/L 

Free Available Chlorine: 0.5 mg/L; 0.2 mg/L 126 Priority Pollutants: Zero discharge, except: Chromium: 0.2 mg/L; 0.2 mg/L Zinc: 1.0 mg/L; 1.0 mg/L 

Free Available Chlorine: 0.5 mg/L; /0.2 mg/L 126 Priority Pollutants: Zero discharge, except: Chromium: 0.2 mg/L; 0.2 mg/L Zinc: 1.0 mg/L; 1.0 mg/L 

126 PriodischargChromiuZinc: 1.0 

Coal Pile Runoff TSS*: 50 mg/L instantaneous 

maximum 

TSS*: 50 mg/L instantaneous maximum 
Final Detailed Study Report Chapter 3 – Stea

3-34 

Table 3-8. Current Effluent Guidelines and Standards for the Steam Electric Power Generating Point 

Waste Stream BPT a BAT a NSPS a P

Metal Cleaning Wastes 

TSS: 100 mg/L; 30 mg/L Oil & Grease: 20 mg/L; 15 mg/L Copper: 1.0 mg/L; 1.0 mg/L Iron: 1.0 mg/L; 1.0 mg/L 

See Chemical Metal Cleaning Wastes below 

See Chemical Metal Cleaning Wastes below 

See CheWastes b

Chemical See Metal Cleaning Wastes above Copper: 1.0 mg/L; 1.0 mg/L 

Iron: 1.0 mg/L; 1.0 mg/L 

TSS: 100 mg/L; 30 mg/L Oil & Grease: 20 mg/L; 15 mg/L Copper: 1.0 mg/L; 1.0 mg/L Iron: 1.0 mg/L; 1.0 mg/L 

Copper: maximu

Non-chemical See Metal Cleaning Wastes above Reserved Reserved Reserve

Source: [40 CFR Part 423]. a – The limitations for TSS, oil & grease, copper, iron, chromium, and zinc are presented as daily maximum (mg/L); 30-day average (m

guidelines, where two or more waste streams are combined, the total pollutant discharge quantity may not exceed the sum of allowable each individual waste stream. BPT, BAT, and NSPS allow either mass- or concentration-based limitations. b – The pH limitation is not applicable to once-through cooling water. Free Available Chlorine: 0.5 mg/L; 0.2 mg/L - 0.5 mg/L instantaneous maximum, 0.2 mg/L average during chlorine release period. Dishrs/day/unit. Simultaneous discharge of chlorine from multiple units is prohibited. Limitations are applicable at the discharge from an icombination with the discharge from another unit. Total Residual Chlorine: 0.20 mg/L instantaneous maximum. Total residual chlorine (TRC) = free available chlorine (FAC) + combineTRC discharge is limited to 2 hrs/day/unit. TRC is applicable to plants ≥25 MW, and FAC is applicable to plants <25 MW. The TRC lithe discharge point to surface waters of the United States and may be subsequent to combination with the discharge from another unit. 126 Priority Pollutants: zero discharge - 126 priority pollutants from added maintenance chemicals (refer to App. A to 40 CFR 423). At discretion, compliance with the zero-discharge limitations for the 126 priority pollutants may be determined by engineering calculation

the regulated pollutants are not detectable in the final discharge by the analytical methods in 40 CFR part 136. TSS*: 50 mg/L instantaneous maximum on coal pile runoff streams. No limitation on TSS for coal pile runoff flows ≥10-year, 24-hour 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-1 

4. FLUE GAS DESULFURIZATION SYSTEMS

This chapter presents an overview of flue gas desulfurization (FGD) systems at coal-fired 

power plants within the steam electric industry, with particular emphasis on FGD wastewater 

characteristics and treatment. This chapter also presents a profile of the current and projected 

future use of FGD systems within the industry. 

Power plants use FGD systems to control SO2 emissions from the flue gas generated in 

the plants’ boilers. Wet FGD scrubbers are the most common type of FGD system; however, 

approximately 20 percent of electric generating units serviced by SO2 scrubbers are serviced by 

dry FGD systems [U.S. DOE, 2005b]. There are several variations of wet FGD systems, but this 

section focuses on the limestone forced oxidation system and the lime or limestone inhibited 

oxidation system, which are the designs predominantly used in the industry today. This section 

also presents some information about other types of FGD systems used at coal-fired power 

plants, including dry scrubbers, which do not generate wastewaters. 

EPA has compiled information on the current and projected use of FGD systems at coalfired power plants using information collected from the 2005 Form EIA-767 [U.S. DOE, 2005b], 

the 2005 Form EIA-860 [U.S. DOE, 2005a], EPA’s site visit and sampling data, EPA’s data 

request information [U.S. EPA, 2008a], EPA’s National Electric Energy Data System (NEEDS) 

2006 database [U.S. EPA, 2006h], the Integrated Planning Model [U.S. EPA, 2006b] developed 

by ICF Consulting, Inc., and other publicly available information (e.g., company websites, 

vendor news releases). The collective data from these data sources are referred to in this report as 

the “combined data set12.” See Chapter 2 for additional information about EPA’s data collection 

activities. 

4.1 Coal-Fired FGD System Statistics

This section presents statistics on the number and characteristics of coal-fired power 

plants that currently operate wet or dry FGD systems, or are expected to install an FGD system 

in the next decade. Also included in this section are estimates of the coal-fired steam electric 

industry’s current and projected total generating capacity and scrubbed capacity. 

4.1.1 Current Coal-Fired FGD System Profile 

The current coal-fired FGD system profile presents a picture of the coal-fired steam 

electric industry as of June 2008, including the number of coal-fired power plants with FGD 

systems, the associated scrubbed capacity, and plant characteristics. EPA used information from 

the combined data set to generate the profile. 

Wet FGD systems are in operation at 108 plants, treating the flue gases from 223 

generating units. These 223 electric generating units represent the number of electric generating 

units scrubbed and is not exactly equal to the number of FGD systems. The two numbers are 

similar; however, EPA is aware of several plants that use a single FGD scrubber to service more 

than one electric generating unit. The combined generating capacity of the wet-scrubbed 

generating units represents approximately 33 percent of the total nationwide coal-fired steam 

 

12 Due to the limited time available upon receiving the surface impoundment data collected by EPA’s ORCR, the 

ORCR data are not included in the combined data set. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

electric power generating capacity. EPA expects that percentage to increase significantly over 

the next decade, as discussed in Section 4.1.2. Table 4-1 presents statistics on the current coalfired steam electric power generation associated with FGD systems, relative to total industry 

coal-fired and fossil-fueled steam electric power generation. 

Table 4-1. Scrubbed Coal-Fired Steam Electric Power Generation as of June 2008 

Industry Category 

Number of 

Plants a

Number of Electric 

Generating Units a,b

Capacity 

(MW) a,c

Fossil-Fueled Steam Electric Power Generation d, e, f 1,120 2,450 657,000 

Coal-Fired Steam Electric Power Generation d, f 488 1,180 330,000 

Coal-Fired Steam Electric Power Generation with 

Any FGD System (Wet or Dry) g

146 280 123,000 i

Coal-Fired Steam Electric Power Generation with a 

Wet FGD System g, h

108 223 108,000 i

Coal-Fired Steam Electric Power Generation with a 

Dry FGD System g, h

41 57 14,900 i

a – The numbers presented have been rounded to three significant figures. 

b – The number of electric generating units represents the number of electric generating units scrubbed and does not 

represent the number of FGD systems. The two numbers are similar, but several plants use a single FGD scrubber 

for more than one electric generating unit. 

c – The capacities presented represent the nameplate capacity for the electric generating unit. 

d – Source: 2005 EIA-860 [U.S. DOE, 2005a]. 

e – Fossil-fueled generation includes coal, oil, and natural gas. It does not include nuclear generation. 

f – The table includes the stand-alone steam electric and all combined cycle turbines (i.e., combined cycle steam 

turbine, combined cycle single shaft, and combined cycle combustion turbine). 

g – Source: Combined data set (2005 EIA-767 [U.S. DOE, 2005b], UWAG-provided data [ERG, 2008g], data 

request information [U.S. EPA, 2008a], and site visit and sampling information). 

h – The wet and dry FGD system information is a subset of the information for “Any FGD System.” Note that 

several plants operate both wet and dry FGD systems. Thus, there is overlap between the number of plants with wet 

FGD systems and the number of plants with dry FGD systems. 

i – Includes only the capacity for the scrubbed electric generating units. 

The majority of the plants in the combined data set with wet FGD systems (46 percent) 

use eastern bituminous coal as the primary fuel source. This is to be expected because eastern 

bituminous coal typically contains a higher sulfur content than other coal types, thus producing 

higher SO2 emissions than other types of coal. Other coals reported to be used in wet-scrubbed 

units include subbituminous (24 percent of plants), lignite (9 percent of plants), and other 

bituminous coal (20 percent of plants). Table 4-2 summarizes plant characteristics for the 

currently operating wet scrubbed electric generating units included in the combined data set. 

4-2 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Table 4-2. Characteristics of Coal-Fired Power Plants with Wet FGD Systems 

Combined Data Set a 

Number of Plants with 

Wet FGD Systems 

Number of Wet Scrubbed 

Electric Generating Units

Wet Scrubbed Capacity b 

(MW) 

Total 108 223 108,000 

Primary Coal Type c

Bituminous 72 161 76,300 

Subbituminous 26 48 22,700 

Lignite 10 14 9,060 

Type of Oxidation System

Forced Oxidation 50 111 61,600 

Inhibited or Natural Oxidation 36 62 30,000 

No Information 26 50 16,700 

Sorbent

Limestone 74 151 78,200 

Limestone & Fly Ash 1 1 50 

Lime 17 33 11,800 

Lime & Fly Ash 2 5 2,750 

Magnesium-Enhanced Lime 3 8 7,390 

Magnesium Oxide 2 3 896 

Fly Ash 3 6 2,360 

Soda Ash 1 2 530 

Soda Liquor 1 4 2,320 

Sodium Carbonate 2 5 938 

No Information 3 4 800 

NOx Controls

SCR d 40 79 47,000 

SNCR 7 15 4,700 

None/Other (no SCR/SNCR) 44 80 35,600 

No Information 25 49 20,900 

Note: All 108 plants are included in the each of the categories presented in this table. Because a plant may operate multiple 

electric generating units that may represent more than one type of operation in each specific category, the sum of the plants for 

each category may be greater than 108 plants. 

a – Source: Combined Data Set (2005 Form EIA-767 [U.S. DOE, 2005b], the 2005 Form EIA-860 [U.S. DOE, 2005a], EPA’s 

site visit and sampling data, EPA’s data request information [U.S. EPA, 2008a], EPA’s NEEDS 2006 database [U.S. EPA, 

2006h], and other publicly available information (e.g., company web sites, vendor news releases)). 

b – The capacities represent the reported nameplate capacity. The capacities presented have been rounded to three significant 

figures. Due to rounding, the total capacity may not equal the sum of the individual capacities. 

c – Some plants/electric generating units use a blend of more than one coal in the electric generating units. This table presents 

information for only the primary type of coal burned in the electric generating unit. 

d – Some of the SCRs included in the table are planned/under construction. 

Of these wet scrubbed electric generating units, 111 (50 percent) are serviced by forced 

oxidation systems and 62 (28 percent) are serviced by natural or inhibited oxidation systems. 

EPA does not have information regarding the type of oxidation system for the FGD systems 

servicing the remaining 50 electric generating units (22 percent). 

Wet FGD systems use a sorbent to transfer pollutants from the flue gas to the liquid 

stream. Limestone is by far the predominant sorbent used in wet FGD systems (68 percent of the 

4-3 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-4 

currently operating electric generating units), followed by lime (17 percent of electric generating 

units), and magnesium-enhanced lime (4 percent of electric generating units). Magnesium oxide, 

fly ash, soda ash, soda liquor, or sodium carbonate sorbents collectively are used in FGD systems 

servicing 9 percent of electric generating units. EPA does not have sufficient information to 

determine the type of sorbent used for the remaining 2 percent of electric generating units. 

Nearly one-third of the plants reported using additives in their FGD systems. Some plants 

add organic acids, such as dibasic acid (DBA) or formic acid, to improve the sulfur dioxide 

removal efficiency. Inhibited oxidation plants typically will add emulsified sulfur or a similar 

compound to prevent oxidation of the calcium sulfite by-product so that calcium sulfate 

(gypsum) will not be formed. 

Over 40 percent of the wet-scrubbed electric generating units in the combined data set 

operate either a SCR or SNCR system to reduce NOx emissions (35 percent SCR; 7 percent 

SNCR). See Section 3.2 for details regarding the operation of NOx control systems at power 

plants. 

No plants in the combined data set were identified as currently operating advanced flue 

gas mercury controls; however, according to the DOE, more than 130 full-scale activated carbon 

injection systems have been ordered by coal-fired plants [Feeley, 2009]. One outcome of 

litigation surrounding the Clean Air Mercury Rule has been that in the absence of a specific 

regulatory requirement, plants are refraining from operating the mercury control systems that 

have been installed. 

4.1.2 Projected Use of FGD Systems at Coal-Fired Plants 

EPA used information from EPA’s NEEDS 2006 database [U.S. EPA, 2006h], and the 

IPM [U.S. EPA, 2006b] to evaluate the expected trends in the number and capacity of units that 

will be scrubbed in the future. 

The use of FGD systems has increased substantially since the effluent guidelines were 

last revised in 1982. Power plants are expected to continue installing new FGD systems in 

substantial numbers until at least 2025.13 Table 4-3 presents the projected use of wet and dry 

FGD systems, from 2009 through 2025, and compares the projected scrubbed capacity to the 

projected total coal-fired capacity.14 EPA models have predicted that over 60 percent of coalfired capacity will be wet scrubbed by 2020. EPA predicts that the industry’s dry scrubbed 

capacity will increase only slightly into the future and that most new FGD systems will be wet 

scrubbers [ERG, 2008f]. 

 

13 EPA projected future generating capacity with FGD systems using IPM Base Case 2006 (v.3.0), which reflects the 

CAMR mercury reduction requirements and the CAIR NOx and SO2 emission reduction requirements for power 

plants. 

14 The data presented in Table 4-3 is based on the NEEDS 2006 database and IPM Base Case 2006 (v. 3.0). The 

2020 capacity presented is the basis for the future FGD wastewater treatment industry profile presented in Section 

4.6.1; however, the two data sets are not identical because the future FGD wastewater treatment industry profile 

does not include the “NEW” plants from the IPM data set and EPA’s Office of Water made additional corrections to 

the IPM data set in some instances for the purpose of the detailed study. The data set corrections were necessary to 

address conflicting information. For more information about the future FGD wastewater treatment industry profile, 

see Section 4.6.1 or the memorandum entitled “Development of the Current and Future Industry Profile for the 

Steam Electric Detailed Study,” dated October 9, 2009 [ERG, 2009r]. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-5 

Table 4-3. Projected Future Use of FGD Systems at Coal-Fired Power Plants 

2009 

Capacity 

(MW) 

2010 

Capacity 

(MW) 

2015 

Capacity 

(MW) 

2020 

Capacity 

(MW) 

2025 

Capacity 

(MW) 

Wet Scrubbed a 136,000 162,000 189,000 231,000 282,000 

Dry Scrubbed a 21,000 21,500 30,100 36,700 38,600 

Total Scrubbed a 157,000 184,000 219,000 268,000 321,000 

Total Coal-Fired Generating 

Capacity a 316,000 318,000 333,000 371,000 409,000 

Percent Wet Scrubbed 43% 51% 57% 62% 69% 

Percent Scrubbed (Wet & Dry 

Combined) 50% 58% 66% 72% 78% 

Source: [ERG, 2008f]. 

a – The capacities presented have been rounded to three significant figures. Due to rounding, the total capacity may 

not equal the sum of the individual capacities. The 2009 capacities are from the NEEDS 2006 database which 

preferentially uses summer and winter capacity before nameplate capacity. Capacities presented in this table for the 

period 2010 through 2025 are from estimates based on the IPM model [U.S. EPA, 2006b], which uses the NEEDS 

2006 database [U.S. EPA, 2006h] as a starting point. Because the nameplate capacities are not used in these 

projections, caution should be used when comparing the capacities in this table to Table 4-1 and the industry profile 

tables presented in Chapter 3. 

Figure 4-1 shows the locations and relative scrubbed capacity of coal-fired plants 

currently operating wet FGD systems and those plants projected to operate wet FGD systems in 

2020. The figure illustrates the expected growth in wet FGD systems, especially in the eastern 

United States due to the use of higher sulfur coal. Note that the projections for 2020 only include 

FGD installations for power plants and generating units that are currently in operation. New 

generating units or power plants that will be built in the future are not depicted, although many if 

not all new coal-fired generating units are likely to operate wet or dry FGD systems. 

Based on communications with industry and corroborated by responses to the data 

request, EPA expects that new wet FGD systems will be limestone forced oxidation systems that 

produce a commercial-grade gypsum by-product, even for those plants located in an area where 

there may be no market available for the sale of such a byproduct. Additionally, EPA expects 

that the majority of wet scrubbed steam electric generating units will also include SCR systems 

to meet state and federal requirements to reduce stack emissions of NOx. 
Final Detailed Study Report Chapter 4 – Flue G

Source: [ERG, 2008b; ERG, 2008c; ERG, 2008g; ERG, 2009s; ERG, 2009w]. Note: The capacities in the figures represent the plant-level wet scrubbed capacity for the entire plant; they do not represent the plant’s generating capacity. The capacities in June 2008 figure represent the reported nameplate capacity. The capacities in Projected 2020 figu

based on the IPM model, which uses a variety of capacities in its estimate, but preferentially uses summer and winter capacity before n

Figure 4-1. Wet FGD Systems at Coal-Fired Power Plants (Current and Projected 2020

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4.2 Process Description and Wastewater Generation

4.2.1 Forced Oxidation FGD Systems 

The EPA site visit and sampling program focused primarily on forced oxidation systems 

because these types of FGD systems are the most common systems operating segregated 

wastewater treatment systems prior to discharging FGD wastewater. In addition, based on 

discussions with industry representatives, EPA expects that the majority of future wet FGD 

systems will be forced oxidation. 

Most forced oxidation systems use limestone as the sorbent in the process, but lime can 

also be used in a forced oxidation system. The limestone forced oxidation FGD system works by 

contacting the flue gas stream with a liquid slurry stream containing a limestone (CaCO3) 

sorbent, which effects the mass transfer of pollutants from the flue gas to the liquid stream. 

Equation 4-1 shows the reaction that occurs between limestone and sulfur dioxide, producing 

hydrated calcium sulfite (CaSO3) [EPRI, 2006a]. 

 CaCO3 (s) + SO2 (g) + 1/2 H2O → CaSO3 •1/2 H2O (s) + CO2 (g) (4-1) 

The calcium sulfite is then oxidized to calcium sulfate (gypsum) by injecting air into the 

calcium sulfite slurry. Equation 4-2 shows the reaction producing gypsum (CaSO4 •2H2O) from 

calcium sulfite [EPRI, 2006a]. 

 CaSO3 •1/2 H2O (s) + 1⁄2 O2 (g) + 3/2 H2O (l) → CaSO4 •2H2O (s) (4-2) 

During the site visits to power plants, EPA determined that the operation of these 

limestone forced oxidation systems varies somewhat by plant; however, most of the systems 

follow the same general operating procedure. Figure 4-2 presents a typical process flow diagram 

for a limestone forced oxidation FGD system. 

Most of the plants EPA visited operate a spray or tray tower FGD scrubber, in which the 

flue gas and the limestone slurry are configured with countercurrent flow. The fresh limestone 

slurry is typically fed to the reaction tank at the bottom of the FGD scrubber to maintain the pH 

levels in the system. This fresh limestone slurry mixes with the already reacted scrubber slurry 

and is pumped to the top of the FGD scrubber where it is sprayed downward from several 

different spray levels. The flue gas enters near the bottom of the FGD scrubber, just above the 

water level of the reaction tank. As the flue gas rises through the absorber vessel, the spray 

droplets of the limestone/water slurry contact the flue gas and absorb the sulfur dioxide. The 

limestone and water react with the sulfur dioxide to produce calcium sulfite (see Equation 4-1). 

To increase the sulfur dioxide removal efficiency, some plants use additives such as organic 

acids (e.g., DBA or formic acid) in the FGD system. These additives buffer the scrubber slurry, 

which controls the sulfur dioxide vapor pressure in the scrubbers, thereby maximizing the sulfur 

dioxide absorption rate [Babcock & Wilcox, 2005]. The scrubbed flue gas exits the top of the 

FGD scrubber through a mist eliminator and then is emitted through the stack. 

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Final Detailed Study Report Chapter 4 – Flue G

Scrubber Blowdown

Figure 4-2. Typical Process Flow Diagram for a Limestone Forced Oxidation FGD Syste

4-8 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-9 

The spray droplets, some containing the calcium sulfite product and others with 

unreacted limestone, fall to the bottom of the FGD scrubber into a reaction tank. The plant 

injects air into the reaction tank and vigorously mixes the slurry to oxidize the calcium sulfite to 

gypsum (see Equation 4-2). The scrubber recycle pumps pump the slurry from the reaction tank 

to the various spray levels within the FGD scrubber. The plant continuously recirculates the 

slurry in the FGD scrubber. When the percent solids or the chlorides concentration in the slurry 

reach a certain high set point in the reaction tank, the plant uses the scrubber blowdown pumps to 

remove some of the slurry from the FGD scrubber. As the blowdown stream is removed from the 

scrubber, the levels of solids and chlorides in the scrubber slurry decreases until a low set point is 

reached within the FGD scrubber. The plant then shuts off the blowdown pumps until the solids 

and chlorides build up again to the point of triggering a blowdown. Therefore, the scrubber 

blowdown is typically an intermittent transfer from the scrubber. Some plants, however, operate 

an FGD scrubber with a continuous blowdown, which can either be a once-through FGD system 

with no recycle or an FGD system that recycles some of the slurry but is constantly blowing 

down slurry at a rate that maintains the solids and chlorides levels within a defined operating 

range. 

The parameter used to control the FGD system (e.g., percent solids or chlorides 

concentration) and the level at which it is controlled varies by plant. Plants maintain a chlorides 

concentration below the maximum level which the FGD scrubber materials of construction can 

withstand to prevent corrosion, normally around 12,000 – 20,000 ppm; however, some systems 

operate with chloride concentrations as low as 2,000 to 3,000 ppm and other plants may operate 

near 40,000 ppm. Plants also monitor and control the FGD system based on the percent solids 

because the solids can affect the operation of the FGD system and because the plant must limit 

the amount of fines (small inert particles) in the gypsum by-product [EPRI, 2006a]. 

The scrubber blowdown, which for a forced oxidation system is a gypsum slurry, is 

transferred to a solids separation process. Often, this process uses one or two sets of 

hydrocyclones, referred to in the industry as hydroclones.15 The hydroclones separate the 

gypsum solids from the water using centrifugal force. The gypsum solids are forced outward to 

the walls of the hydroclones and fall downward, while the water exits the top of the hydroclones. 

The underflow, or solids-rich stream, from the solids separation process contains the gypsum 

solids and is transferred to a dewatering process. The overflow, or solids-lean stream (which is 

mostly water and fines), from the solids separation process is typically transferred to the purge 

tank. 

The solids-rich stream from the solids separation process is transferred to a dewatering 

process, which is usually a vacuum belt filter or a vacuum drum filter. The dewatering process 

removes the water from the gypsum, drying the gypsum to its desired moisture content. If the 

plant intends to market the gypsum for wallboard production, then a vacuum belt filter is 

typically used because it can dry the gypsum to a lower moisture content than a drum filter. 

Additionally, the gypsum is usually rinsed with service water at the beginning of the belt filter to 

reduce the chlorides concentration to meet the wallboard manufacturer’s specifications. If the 

plant does not intend to market the gypsum, then the gypsum does not need to be rinsed and 

either a vacuum belt or vacuum drum filter can be used for the dewatering because the gypsum 

 

15 Another approach for solids separation practiced by some plants entails using settling ponds instead of 

hydroclones or other mechanical devices. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-10 

most likely will not need to meet any chloride or moisture content specifications. However, EPA 

has visited several plants that are currently unable to market the gypsum, but the plant still rinses 

the gypsum prior to on-site disposal in case a future gypsum market develops for the gypsum. 

The dried gypsum product is removed from the dewatering process and transferred to a storage 

area until it is transported off site (for beneficial use or disposal at an off-site landfill) or to a 

disposal area on site. The filtrate from the dewatering process is recovered in a reclaim tank and 

either returned to the FGD scrubber or used in the limestone slurry preparation process. 

The solids-lean stream from the solids separation process is typically transferred to a 

purge tank and then sent to a wastewater treatment system and discharged. Alternatively, the 

solids-lean stream can be transferred to a second solids separation process (e.g., a second set of 

hydroclones) to remove additional solids prior to wastewater treatment. Many plants that are 

operating clarifiers in the FGD wastewater treatment system have two stages of solids separation 

to minimize the size requirements and/or prevent overloading of the clarifier. In this case, the 

solids-lean stream from the second solids separation process is transferred to the purge tank and 

the solids-rich stream is typically transferred to the reclaim tank and recycled back to the FGD 

system or limestone preparation process. 

From the purge tank, the scrubber purge16 is typically transferred to some type of FGD 

wastewater treatment system, such as a settling pond or a more advanced system (see Section 

4.4). It may also be commingled with other wastewater streams (e.g., cooling water or ash pond 

wastewater) and discharged. Because most FGD treatment systems currently being used do not 

significantly affect the level of chlorides in the wastewater, the treated FGD wastewater is not 

recycled back to the FGD scrubber. 

Some plants are able to operate their solids removal process in a manner that purges 

sufficient chlorides along with the solids to allow reuse of the FGD wastewater. For example, 

plants that dispose of their gypsum solids in a landfill do not typically have to meet 

specifications for the chlorides or fines content in the gypsum; therefore, these plants can operate 

the FGD system (including the solids separation and dewatering process) to allow the gypsum to 

retain more water and, therefore, more chlorides and fines. Operating the system in this manner 

allows the plant to purge scrubber water (and by extension chlorides and fines) through the solids 

disposal process. If they are able to purge enough chlorides with the FGD solids, these plants 

may then be able to recycle the solids-lean stream from the solids separation process. Most of the 

plants that sell the gypsum for beneficial use have to meet chloride and fines specifications, and 

therefore, must operate with a scrubber purge stream [Sargent & Lundy, 2007]. 

4.2.2 Inhibited Oxidation FGD System 

Both the forced oxidation and inhibited oxidation FGD systems remove sulfur dioxide 

from the flue gas; however, in the inhibited oxidation FGD system, a chemical such as 

emulsified sulfur is added to the system to prevent gypsum from forming during the process. 

 

16 For the purpose of this document, the scrubber blowdown refers to the slurry stream exiting the FGD scrubber, 

which is typically transferred to a solids separation process. The scrubber purge refers to the waste stream from the 

FGD scrubber system (typically from a solids separation process) that is transferred to a wastewater treatment 

system or discharged. Both the scrubber blowdown and scrubber purge waste streams are depicted in . In 

some instances, the scrubber blowdown and scrubber purge may be the same waste stream if the plant does not 

operate a solids separation process prior to wastewater treatment or discharge. 

Figure 4-2
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-11 

Many of the plants operating inhibited oxidation systems do not have wastewater treatment 

systems, other than settling ponds, to treat the scrubber purge. In addition, some plants are able 

to recycle their FGD wastewater back to the FGD system and, therefore, do not produce a 

scrubber purge waste stream. 

The lime or limestone inhibited oxidation FGD systems work by contacting the flue gas 

stream with a liquid slurry stream containing a lime (Ca(OH)2) or limestone sorbent, which 

effects mass transfer. Equation 4-1 shows the reaction between limestone and sulfur dioxide and 

Equation 4-3 shows the reaction that occurs between lime and sulfur dioxide, producing hydrated 

calcium sulfite. 

 Ca(OH)2 (s) + SO2 (g) → CaSO3 •1⁄2 H2O (s) + 1⁄2 H2O (l) (4-3) 

The operation and absorption of the SO2 in an inhibited oxidation FGD system is similar 

to the forced oxidation FGD system. A FGD process operation description for a forced oxidation 

system is presented in Section 4.2.1. The most significant differences between the two systems 

are that in an inhibited oxidation FGD system, elemental or emulsified sulfur is added to the 

FGD system, and oxidation air is not introduced to the absorber. The sulfur forms thiosulfate 

within the FGD system, which is an oxygen scavenger. Because thiosulfate reacts so readily with 

the dissolved oxygen, it inhibits the calcium sulfite from oxidizing to calcium sulfate, thereby 

generating a calcium sulfite by-product instead of a gypsum by-product. 

Although the operation of the FGD scrubber is similar for the two FGD systems, there are 

some differences in the solids separation and solids dewatering processes. Figure 4-3 presents a 

typical process flow diagram for a lime or limestone inhibited oxidation FGD system. One of the 

major differences between the forced oxidation and inhibited oxidation systems is that inhibited 

oxidation systems are more likely than forced oxidation systems to be operated in a manner that 

recycles the solids-lean stream from the solids separation process back to the scrubber, and thus 

are less likely to discharge a scrubber purge stream. 

As is done for the limestone forced oxidation system, the scrubber blowdown is 

transferred to a solids separation process. The calcium sulfite by-product generated from the 

inhibited oxidation process is more difficult to dewater than the gypsum by-product generated by 

the limestone forced oxidation process; therefore, plants operating inhibited oxidation FGD 

systems typically use a thickener for the solids separation process; however, hydroclones can 

also be used for inhibited oxidation systems. Thickeners operate with long residence times that 

allow the solids to settle out of the solution. The underflow, or solids-rich stream, from the solids 

separation process contains the calcium sulfite and is transferred to a dewatering process which 

is typically a centrifuge or vacuum drum filter. 
Final Detailed Study Report Chapter 4 – Flue G

Figure 4-3. Process Flow Diagram for a Lime or Limestone Inhibited Oxidation FGD Sys

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

The dewatering process removes water from the calcium sulfite, drying it to its desired 

moisture content. The filtrate from the dewatering process is transferred to a reclaim tank. The 

solid cake from the final dewatering process is usually sent to a landfill, either on or off site. 

Although the calcium sulfite FGD solids can be landfilled after the final dewatering process, 

some plants operating inhibited oxidation systems further process the calcium sulfite by mixing 

it with dry fly ash and lime in a pug mill to generate a cementitious material similar to concrete. 

The resultant cementitious material is transported to a landfill. 

The overflow, or solids-lean stream, from the solids separation process and the filtrate 

from the dewatering process are typically transferred to a reclaim tank. Some of the wastewater 

collected in the reclaim tank is recycled back to the FGD scrubber process and some may be 

discharged or transferred to an additional treatment system. Because the inhibited oxidation 

system typically does not generate a saleable solid product, the solids are typically disposed of in 

a landfill. Like the limestone forced oxidation systems that are not beneficially using the 

gypsum, the plant may be able to recycle the FGD wastewater without a purge stream because 

the chlorides can be removed from the FGD system by retaining the chlorides with the solids that 

are sent to the landfill [Sargent & Lundy, 2007]. However, not all plants operating inhibited 

oxidation FGD systems completely recycle the FGD wastewater. For example, Louisville Gas & 

Electric Company’s Cane Run plant stated that they do not achieve complete recycle because of 

instances where they have accumulated rainfall in their ponds which treat the recycle water. 

When this happens, they manage the additional water volume by discharging from the FGD 

ponds. 

4.2.3 Other Types of FGD Systems 

Natural Oxidation FGD Systems 

Sections 4.2.1 and 4.2.2 describe the operation of the forced oxidation and inhibited 

oxidation systems. A natural oxidation system operates similarly to both the forced oxidation and 

inhibited oxidation systems, except that air is not fed to the reaction tank to force the oxidation of 

calcium sulfite to calcium sulfate as in the forced oxidation system; likewise, emulsified sulfur is 

not added to inhibit the calcium sulfite from oxidizing as in the inhibited oxidation system. In a 

natural oxidation system, some of the calcium sulfite (typically the majority) is oxidized to 

calcium sulfate using the dissolved oxygen present in the system; however, because the plant is 

not forcing the oxidation, some of the calcium sulfite may not oxidize and the FGD process may 

produce a mixture of calcium sulfite and calcium sulfate. The solids handling associated with the 

operation of a natural oxidation FGD system is also similar to the solids handling of the forced 

oxidation and/or the inhibited oxidation systems (see Figure 4-2 and Figure 4-3). 

During the detailed study, EPA visited one plant that operates a natural oxidation FGD 

system. The plant operates a thickener for the solids separation process and a vacuum drum filter 

for the dewatering process. The FGD solids produced, which consist predominantly of calcium 

sulfate, are transferred to a third party distributor for sale (primarily to a cement manufacturer). 

The overflow from the thickeners is transferred to a reclaim tank and is typically reused within 

the FGD process. The plant occasionally transfers the thickener overflow to a settling pond, 

which is ultimately discharged [ERG, 2009o]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Dual-Alkali FGD Systems 

The dual-alkali FGD process is different from the other FGD processes previously 

discussed because two alkaline sorbents are used in the process. For this type of FGD system, a 

soda ash (sodium carbonate, Na2CO3) liquor/solution is fed into the FGD scrubber to absorb the 

sulfur dioxide from the flue gas. The sodium is dissolved in this liquor, and therefore the liquor 

contains almost no suspended solids. The sodium reacts with the sulfur dioxide and the product 

is transferred to the reaction tank where the second alkaline sorbent, lime, is added. The lime 

reacts with this product to generate hydrated calcium sulfite. Additionally, the sodium solution is 

regenerated in this reaction and can be reused in the scrubbing process. The slurry from the 

reaction tank is then sent to a solids separation process, such as a thickener. The underflow, or 

solids-rich stream, from the solids separation process contains mostly calcium sulfite, and is 

transferred to a dewatering process similar to the description for the lime inhibited oxidation 

system (see Section 4.2.2). The overflow, or solids-lean stream, that contains the sodium solution 

is recycled back to the FGD system as the sorbent for the scrubbing process. Because some of 

the sodium will leave the system with the solids-rich stream from the solids separation process, a 

make-up soda ash solution is added to the sodium solution that is recycled back to the FGD 

scrubber. 

Dry FGD Systems 

A dry FGD system is a spray dryer absorption process in which a lime slurry removes 

sulfur dioxide from the flue gas. These dry FGD systems are also sometimes referred to as semidry FGD systems because a wet slurry is injected into the flue gas; a dry sorbent is not used in 

the process. In the dry FGD process, the wet lime slurry, which ranges from approximately 18 to 

25 percent solids, is atomized and sprayed into the spray dryer. The percent solids in the lime 

slurry is calculated to control the sulfur dioxide removal from the flue gas but also allows for 

essentially all the water to evaporate within the spray dryer. The flue gas can enter the spray 

dryer from one or more different locations and typically enters through a disperser to allow for 

effective contact with the atomized spray droplets. The sulfur dioxide in the flue gas is absorbed 

by the spray droplets and reacts with the lime to generate calcium sulfite. These reactions take 

place in the aqueous phase of the spray droplets at the same time that the heat from the flue gas is 

evaporating the water from the spray droplets. The evaporation of the water cools the flue gas 

and produces a calcium sulfite product with low moisture content [Babcock & Wilcox, 2005]. 

The flue gas exiting the spray dryer is then transferred to a particulate removal system 

(e.g., electrostatic precipitator (ESP) or baghouse), which collects the solids generated in the 

spray dryer and some unreacted lime, as well as fly ash if there is no particulate removal system 

upstream of the spray dryer. A plant may operate a pre-collection particulate removal system if it 

intends to market the fly ash generated. The particulates removed from the process are usually 

transferred to a silo for storage until the plant disposes of the material or transfers it off site. 

Additionally, the solids removed from the particulate removal process can be reused in the 

process as slurry feed to reduce lime usage. This recycle also has the benefit of using the inherent 

alkalinity in the fly ash for the sulfur dioxide absorption. In these recycle systems, some of the 

solids removed from the particulate removal process are mixed with water to approximately 35 

to 45 percent solids and returned to the process. Not all of the solids can be recycled for the 

process; therefore, the remaining solids are stored on site, sold for beneficial use, or disposed of 

in a landfill [Babcock & Wilcox, 2005]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4.3 FGD Wastewater Characteristics

This section discusses the pollutant characteristics and flow rates for FGD wastewaters 

based on information EPA collected during the detailed study. Pollutant concentration data are 

presented for samples collected during the EPA wastewater sampling program and monitoring 

data provided by the individual plants/companies. These pollutant concentration data represent 

information from limestone forced oxidation systems. This section also presents flow rate data 

from EPA’s site visit and sampling program and responses to EPA’s data request. These flow 

rate data include information from limestone forced oxidation systems, as well as non-forced 

oxidation systems. Chapter 2 describes EPA’s data collection activities. 

The FGD system works by contacting the flue gas stream with a slurry stream containing 

a sorbent. The contact between the streams allows for a mass transfer of sulfur dioxide as it is 

absorbed into the slurry stream. Other pollutants in the flue gas (e.g., metals, nitrogen 

compounds, chloride) are also transferred to the scrubber slurry and leave the FGD system via 

the scrubber blowdown (i.e., the slurry stream exiting the FGD scrubber that is not immediately 

recycled back to the spray/tray levels). Depending upon the pollutant, the type of solids 

separation process and the solids dewatering process used, the pollutants may partition to either 

the solid phase (i.e., FGD solids) or the aqueous phase (i.e., scrubber purge waste stream). 

As described in Section 4.2 and shown in Figure 4-2 and Figure 4-3, the FGD scrubber 

blowdown is typically intermittently transferred from the FGD scrubber to the solids separation 

process. As a result, the FGD scrubber purge (i.e., the waste stream from the FGD scrubber 

system that is transferred to a wastewater treatment system or discharged) is also usually 

intermittent. Factors that can affect the characteristics and flow rate of the FGD scrubber purge 

wastewater include the type of coal, scrubber design and operating practices, solids separation 

process, and solids dewatering process used at the plant. 

The type of coal burned at the plant can affect the FGD scrubber purge flow rate 

associated with the system. Generally, burning a higher sulfur coal will lead to a higher flow rate 

for the scrubber blowdown and scrubber purge. Higher sulfur coals produce more sulfur dioxide 

in the combustion process, which in turn increases the amount of sulfur dioxide removed in the 

FGD scrubber. As a result, more solids are generated in the reaction in the scrubber, which 

increases blowdown volumes. 

Likewise, a high chlorine coal can increase the volume and frequency of the scrubber 

blowdown and scrubber purge. Many FGD systems are designed with materials resistant to 

corrosion for specific chloride concentrations. An electric generating unit burning coal with 

higher chlorine content will more quickly reach the maximum allowable chloride concentration 

in the scrubber, which may trigger more frequent blowdowns. In addition, the plant will need to 

purge more FGD wastewater from the system to prevent chlorides from building up to an 

unacceptable concentration. 

Table 4-4 summarizes the FGD scrubber purge flow rates reported in the data request 

responses and collected during EPA’s site visit and sampling program. In Table 4-4, there are 26 

plants that operate a total of 57 wet FGD systems, which scrub the flue gas from 65 coal-fired 

electric generating units. The size of the plants varies from scrubbed capacities of 300 to 2,700 

MW. The average scrubbed capacity per plant is 1,310 MW, with a median scrubbed capacity of 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

1,330 MW/plant. Most of the plants operate limestone forced oxidation systems; however, 

several plants operate lime inhibited oxidation systems. 

Table 4-4. FGD Scrubber Purge Flow Rates 

Number of Plants Average Flow Rate Median Flow Rate Range of Flow Rate

Flow Rate per Plant 

gpm/plant 26 448 340 30.0 – 2,300 

gpd/plant 26 598,000 410,000 24,300 – 3,310,000 

gpy/plant 26 211,000,000 142,000,000 4,980,000 – 

1,210,000,000 

Normalized Flow Based on Wet-Scrubbed Capacity 

gpm/scrubbed MW 26 0.423 0.250 0.0365 – 2.04 

gpd/scrubbed MW 26 578 301 19.7 – 2,940 

gpy/scrubbed MW 26 202,000 106,000 2,500 – 1,070,000 

Source: Data request information [U.S. EPA, 2008a] and site visit and sampling information.

a – The flow rates presented have been rounded to three significant figures. 

b – The instantaneous (gpm) flow rate represents the rate during the actual purge, unless it is a design scrubber purge 

flow rate for a planned FGD wastewater treatment system installation. 

c – Because some FGD scrubber purge flows are intermittent, instantaneous rates cannot be directly used to 

calculate daily and annual average flows. 

Table 4-4 presents the actual purge flow rates for the 26 plants, as well as calculated 

normalized purge flow rates that are based on the plants’ wet scrubbed capacity. The scrubber 

purge flow rates reported, including the normalized flow rates, vary significantly from plant to 

plant. Figure 4-4 and Figure 4-5 present the distribution of the scrubber purge flow rates for the 

26 plants included in Table 4-4. The majority of plants report scrubber purge flow rates less than 

1.5 mgd. However, one plant operates a once-through FGD system (i.e., no recirculation of the 

scrubber slurry) and has a scrubber purge flow rate exceeding 3 mgd (see Figure 4-4). There are 

three plants that have normalized scrubber purge flow rates greater than 2,000 gpd/MW 

scrubbed. One of the three plants operates a once-through FGD system, as described above. The 

other two plants operate lime inhibited oxidation systems that transfer the FGD wastewater to a 

settling pond for treatment. Because these plants are generating a calcium sulfite byproduct, 

which is not marketable, and the scrubber purge is being transferred to a settling pond for 

treatment, the plants are transferring the entire scrubber blowdown to the settling pond (i.e., there 

is no solids separation process). For this reason, the normalized scrubber purge flow rate for 

these plants is larger than the other plants because the solids, as well as the water retained in the 

solids, are included in the scrubber purge flow rate. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

0

0.5

1

1.5

2

2.5

3

3.5

Flow Rate (m gd /P lant)

0

500

1,000

1,500

2,000

2,500

3,000

3,500

No rm aliz ed F low (gp d/M W S crub bed)

Figure 4-4. Distribution of FGD Scrubber 

Purge Daily Flow Rates 

Figure 4-5. Distribution of FGD Scrubber 

Purge Normalized Daily Flow Rates 

Source: Data request information [U.S. EPA, 2008a] and site visit and sampling information. 

The average gpd/plant and gpd/scrubbed MW purge flow rates calculated for these 26 

plants are similar to the FGD blowdown stream flow rates EPA observed when developing the 

effluent guidelines promulgated in 1982 (671,000 gpd/plant and 811 gpd/MW) [U.S. EPA, 

1982]. 

The pollutant concentrations in FGD scrubber purge vary from plant to plant depending 

on the coal type, the sorbent used, the materials of construction in the FGD system, the FGD 

system operation, and the air pollution control systems operated upstream of the FGD system. 

The coal is the source of the majority of the pollutants that are present in the FGD wastewater 

(i.e., the pollutants present in the coal are likely to be present in the FGD wastewater). The 

sorbent used in the FGD system also introduces pollutants into the FGD wastewater and 

therefore, the type and source of the sorbent used affects the pollutant concentrations in the FGD 

wastewater. 

The air pollution controls operated upstream of FGD system can also affect the pollutant 

concentrations in the FGD wastewater. For example, if a plant does not operate a particulate 

collection system (e.g., ESP) upstream of the FGD system, then the FGD system will act as the 

particulate control system and the FGD blowdown exiting the scrubber will contain fly ash and 

other particulates. As a result, the FGD scrubber purge will likely contain increased amounts of 

pollutants associated with the fly ash. 

Research conducted by EPA’s ORD has observed that the use of post-combustion NOx 

controls (e.g., SCR and SNCR) is correlated to an increased fraction of chromium in CCR 

(including FGD wastes) being oxidized to hexavalent chromium (Cr+6), a more toxic form of 

chromium than trivalent chromium (Cr+3). Hexavalent chromium is more a soluble form of 

chromium than the Cr+3 usually measured in CCRs, which could explain why ORD has observed 

increased leachability of chromium when post-combustion NOx controls are operating [U.S. 

EPA, 2008c]. 

The materials of construction in the FGD system and the FGD system operation affect the 

pollutants present in the wastewater, as well as the levels of the pollutants. The use of organic 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-18 

acid additives contributes to higher levels of BOD5 in the FGD scrubber purge. Additionally, the 

type of oxidation (i.e., forced oxidation, inhibited oxidation, natural oxidation) in the FGD 

system has the potential to affect the form of the pollutants present in the FGD wastewater. The 

materials of construction and the other FGD system operations can also affect the levels of 

pollutants present in the FGD wastewater because as discussed previously, they affect the rate at 

which scrubber purge is generated. For example, the larger the maximum allowable chlorides 

concentration in the scrubber, the lower the scrubber purge flow rate; however, this leads to 

additional cycling in the scrubber, which increases the pollutant concentrations present in the 

FGD wastewater. 

Table 4-5 presents the pollutant concentrations representing the influent to the FGD 

wastewater treatment systems for the FGD wastewaters that EPA sampled.17 FGD wastewater 

contains significant concentrations of chloride, TDS, nutrients, and metals, including 

bioaccumulative pollutants such as arsenic, mercury, and selenium. Table 4-5 also shows that 

some of the pollutants are more likely to be present in the particulate phase (e.g., aluminum, 

chromium, mercury), whereas other pollutants are almost exclusively present in the dissolved 

phase (e.g., boron, magnesium, manganese). 

For the Big Bend sampling episode, EPA collected a grab sample of the influent to the 

wastewater treatment system downstream of the equalization tank feeding the treatment system. 

The equalization tank receives FGD scrubber purge from secondary hydroclones, treatment 

system recirculation flows, and other related treatment process waste streams. During sampling, 

the plant was recirculating 154 gpm off-specification filter press filtrate to the equalization tank, 

which caused the plant to divert some of the FGD scrubber purge away from the equalization 

tank. As a result, the scrubber purge comprised only one-third (96 gpm of 250 gpm) of the total 

influent-to-treatment flow sampled by EPA. The sampling episode report for Big Bend contains 

more detailed information regarding the sampling event [ERG, 2008n]. 

For the Homer City sampling episode, EPA collected a grab sample of the influent to the 

wastewater treatment system downstream of the equalization tank feeding the treatment system. 

The equalization tank receives FGD scrubber purge from the secondary hydroclones and 

backwash from sand filters. During sampling, the flow rate from the equalization tank to the 

wastewater treatment system was 109 gpm. The sampling episode report for Homer City 

contains more detailed information regarding the sampling event [ERG, 2008l]. 

 

17 Note that the influent-to-treatment sample obtained for a given plant does not necessarily represent the unaltered 

scrubber purge, since the sample collected may include both scrubber purge and treatment system recirculation flow 

streams. 
Final Detailed Study Report Chapter 4 – Flue G

Table 4-5. Influent to FGD Wastewater Treatment System Concentrations 

Analyte Method Unit 

Big Bend – 

Influent to FGD 

Wastewater 

Treatment a

Homer City – 

Influent to FGD 

Wastewater 

Treatment a 

Widows Creek –

FGD Scrubber 

Blowdown a 

Mitchell 

FGD Scrub

Purge a 

Routine Total Metals – 200.7Aluminum 200.7 μg/L 31,200 289,000 234,000 17,900 Antimony 200.7 μg/L 62.5 86.4 ND (86.9) 28.7 Arsenic 200.7 μg/L 75.5 1,590 523 72.5 Barium 200.7 μg/L 1,590 11,900 R 7,200 588 Beryllium 200.7 μg/L 12.9 28.8 44.3 8.04 Boron 200.7 μg/L 626,000 224,000 28,900 229,000 Cadmium 200.7 μg/L 224 150 89.2 19.7 Calcium 200.7 μg/L 6,690,000 3,220,000 5,990,000 3,030,000 Chromium 200.7 μg/L 757 1,400 1,360 70.7 Cobalt 200.7 μg/L 172 369 ND (217) 68.0 Copper 200.7 μg/L 120 811 653 164 Iron 200.7 μg/L 23,500 824,000 299,000 60,600 Lead 200.7 μg/L 69.1 340 436 103 Magnesium 200.7 μg/L 4,830,000 2,760,000 321,000 1,470,000 Manganese 200.7 μg/L 21,900 225,000 2,780 28,800 Mercury 245.1 μg/L ND (10.0) 243 26.5 67.5 Molybdenum 200.7 μg/L 618 375 1,340 65.0 Nickel 200.7 μg/L 2,090 2,560 R 489 554 Selenium 200.7 μg/L 4,150 4,000 R 652 2,130 Silver 200.7 μg/L ND (20.0) ND (40.0) ND (86.9) ND (20.0) Sodium 200.7 μg/L 2,530,000 1,430,000 104,000 314,000 Thallium 200.7 μg/L ND (10.0) Exclude ND (43.4) ND (10.0) Titanium 200.7 μg/L 420 1,300 R 8,180 377 Vanadium 200.7 μg/L 724 766 1,580 203 Yttrium 200.7 μg/L 245 586 217 64.9 

4-19 
Final Detailed Study Report Chapter 4 – Flue G

4-20 

Table 4-5. Influent to FGD Wastewater Treatment System Concentrations 

Analyte Method Unit 

Big Bend – 

Influent to FGD 

Wastewater 

Treatment a

Homer City – 

Influent to FGD 

Wastewater 

Treatment a 

Widows Creek –

FGD Scrubber 

Blowdown a 

Mitchell 

FGD Scrub

Purge a 

Zinc 200.7 μg/L 1,540 1,900 3,140 885 Routine Dissolved Metals – 200.7Aluminum 200.7 μg/L ND (50.0) ND (50.0) 86.6 ND (50.0) Antimony 200.7 μg/L 33.9 ND (20.0) ND (20.0) ND (20.0) Arsenic 200.7 μg/L 18.6 ND (10.0) 13.9 ND (10.0) Barium 200.7 μg/L 1,820 149 R 257 488 Beryllium 200.7 μg/L ND (5.00) 10.5 ND (5.00) 6.02 Boron 200.7 μg/L 618,000 254,000 24,100 232,000 Cadmium 200.7 μg/L 179 26.2 ND (5.00) ND (5.00) Calcium 200.7 μg/L 4,470,000 1,990,000 849,000 2,350,000 Chromium 200.7 μg/L ND (10.0) ND (10.0) 18.7 ND (10.0) Hexavalent Chromium D1687-92 μg/L 24.0 ND (2.00) ND (2.00) 5.00 Cobalt 200.7 μg/L ND (50.0) 201 ND (50.0) ND (50.0) Copper 200.7 μg/L 27.2 14.5 ND (10.0) ND (10.0) Iron 200.7 μg/L ND (100) ND (100) ND (100) ND (100) Lead 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) ND (50.0) Magnesium 200.7 μg/L 4,110,000 3,100,000 176,000 1,370,000 Manganese 200.7 μg/L 9,610 173,000 583 27,900 Mercury 245.1 μg/L ND (10.0) ND (10.0) ND (2.00) ND (10.0) Molybdenum 200.7 μg/L 581 30.6 876 22.2 Nickel 200.7 μg/L 851 1,350 ND (50.0) 355 Selenium 200.7 μg/L 3,610 656 R 366 46.9 Silver 200.7 μg/L ND (20.0) ND (20.0) ND (20.0) ND (20.0) Sodium 200.7 μg/L 1,970,000 1,440,000 76,700 324,000 Thallium 200.7 μg/L 14.3 61.2 14.3 ND (10.0) Titanium 200.7 μg/L 12.5 ND (10.0) ND (10.0) ND (10.0) 
Final Detailed Study Report Chapter 4 – Flue G

4-21 

Table 4-5. Influent to FGD Wastewater Treatment System Concentrations 

Analyte Method Unit 

Big Bend – 

Influent to FGD 

Wastewater 

Treatment a

Homer City – 

Influent to FGD 

Wastewater 

Treatment a 

Widows Creek –

FGD Scrubber 

Blowdown a 

Mitchell 

FGD Scrub

Purge a 

Vanadium 200.7 μg/L 108 ND (20.0) ND (20.0) ND (20.0) Yttrium 200.7 μg/L ND (5.00) 6.28 ND (5.00) ND (5.00) Zinc 200.7 μg/L 16.8 ND (10.0) ND (10.0) 87.8 Low-Level Total Metals – 1631E, 1638, HG-AFSAntimony 1638 μg/L 24.9 31.1 51.8 9.23 Arsenic 1638 μg/L 165 1,220 617 59.9 Arsenic 1638 – DRC μg/L NA NA NA NA Arsenic HG-AFS μg/L NA NA NA NA Cadmium 1638 μg/L 238 52.8 R 86.0 5.28 Chromium 1638 μg/L 651 L 1,270 1,380 176 Chromium 1638 – DRC μg/L NA NA NA NA Copper 1638 μg/L 103 747 826 139 Lead 1638 μg/L 69.9 351 545 68.1 Mercury 1631E μg/L 16.4 533 24.7 138 Nickel 1638 μg/L 2,570 2,840 634 650 Nickel 1638 – DRC μg/L NA NA NA NA Selenium 1638 μg/L 3,470 3,530 651 1,990 Selenium 1638 – DRC μg/L NA NA NA NA Selenium HG-AFS μg/L NA NA NA NA Thallium 1638 μg/L 39.8 37.3 93.8 6.33 Zinc 1638 μg/L 1,870 2,130 2,720 730 Zinc 1638 – DRC μg/L NA NA NA NA Low-Level Dissolved Metals - 1631E, 1636, 1638, HG-AFSAntimony 1638 μg/L 21.9 ND (0.400) 8.90 1.97 Arsenic 1638 μg/L 137 24.2 R 18.0 20.2 Arsenic 1638-DRC μg/L NA NA NA NA 
Final Detailed Study Report Chapter 4 – Flue G

4-22 

Table 4-5. Influent to FGD Wastewater Treatment System Concentrations 

Analyte Method Unit 

Big Bend – 

Influent to FGD 

Wastewater 

Treatment a

Homer City – 

Influent to FGD 

Wastewater 

Treatment a 

Widows Creek –

FGD Scrubber 

Blowdown a 

Mitchell 

FGD Scrub

Purge a 

Arsenic HG-AFS μg/L NA NA NA NA Cadmium 1638 μg/L 190 24.5 3.16 ND (1.00) Chromium 1638 μg/L ND (160) ND (16.0) ND (16.0) ND (80.0) Chromium 1638-DRC μg/L NA NA NA NA Copper 1638 μg/L ND (40.0) 11.3 ND (4.00) ND (20.0) Lead 1638 μg/L ND (10.0) ND (1.00) ND (1.00) ND (0.500Mercury 1631E μg/L 0.206 0.0809 0.0761 0.0111 Nickel 1638 μg/L 1,030 1,450 29.6 433 Nickel 1638-DRC μg/L NA NA NA NA Selenium 1638 μg/L 3,280 584 325 443 Selenium 1638-DRC μg/L NA NA NA NA Selenium HG-AFS μg/L NA NA NA NA Thallium 1638 μg/L 39.4 23.2 22.5 4.47 Zinc 1638 μg/L ND (100) 34.7 ND (10.0) 160 Zinc 1638-DRC μg/L NA NA NA NA ClassicalsAmmonia As Nitrogen (NH3-N) 4500-NH3Fb mg/L 31.5 4.12 2.26 1.89 Nitrate/Nitrite (NO3-N + NO2-N) 353.2 mg/L NA 54.5 1.00 20.6 Total Kjeldahl Nitrogen (TKN) 4500-N,Cb mg/L 51.6 14.2 22.3 13.3 Biochemical Oxygen Demand (BOD)

5210B mg/L 1,370 ND (120) 172 21.0 

Chemical Oxygen Demand (COD) 

5220 C mg/L NA NA NA NA 

Chloride 4500-CL-Cb mg/L 24,200 11,800 832 7,200 Hexane Extractable Material (HEM)

1664A mg/L ND (6.00) ND (5.00) 22.0 11.0 
Final Detailed Study Report Chapter 4 – Flue G

4-23 

Table 4-5. Influent to FGD Wastewater Treatment System Concentrations 

Analyte Method Unit 

Big Bend – 

Influent to FGD 

Wastewater 

Treatment a

Homer City – 

Influent to FGD 

Wastewater 

Treatment a 

Widows Creek –

FGD Scrubber 

Blowdown a 

Mitchell 

FGD Scrub

Purge a 

Silica Gel Treated HEM (SGTHEM) 1664A mg/L NA NA 6.00 E ND (5.00) Sulfate D516-90b mg/L 3,590 6,920 11,900 1,640 Total Dissolved Solids (TDS) 2540 C mg/L 44,600 23,200 4,740 18,100 Total Phosphorus 365.3b mg/L 0.990 2.64 10.5 3.57 Total Suspended Solids (TSS) 2540 D mg/L 4,970 13,300 25,300 E 7,320 

Source: [ERG, 2008l; ERG, 2008m; ERG, 2008n; ERG, 2008o; ERG, 2009q]. Note: EPA used several analytical methods to analyze for metals during the sampling program. For the purposes of sampling program, the analytical methods as “routine” and some of them as “low-level.” EPA designated all of the methods that require the use of clean hacollection techniques (i.e., EPA Method 1669 sample collection techniques) as “low-level” methods. Note that although not required by 

EPA used clean hands/dirty hands collection techniques for all low-level and routine metals samples. a – The concentrations presented have been rounded to three significant figures. b – The method used for the Belews Creek sampling analysis is different than the method presented in the table. See Table 2-3 for detai

DRC – Dynamic reaction cell. For the Belews Creek analysis, a DRC was used in combination with EPA Method 1638 for certain analE – Sample analyzed outside holding time. HG-AFS – Hydride generation and atomic fluorescence spectrometry.

L – Sample result between 5x and 10x the blank result.R – MS/MSD % recovery outside method acceptance criteria. Exclude – Results were excluded because the MS/MSD samples had a zero percent recovery. NA – Not analyzed. ND – Not detected (number in parentheses is the report limit). The sampling episode reports for each of the individual plants contains a

information, including analytical results for analytes measured above the detection limit, but below the reporting limit (i.e., J-values). 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Widows Creek operates once-though FGD scrubbers (i.e., no recirculation of slurry 

within the absorber), with the scrubber blowdown continuously sent to settling ponds. For the 

Widows Creek sampling episode, EPA collected a four-hour composite sample of the influent to 

the FGD settling pond from a diked channel containing FGD scrubber blowdown from the two 

FGD scrubbers. EPA collected the samples from the diked channel at a point downstream of the 

influent to the channel to allow for some initial solids settling, but upstream of the inlet to the 

FGD settling pond. At the time of the sampling, although one of the electric generating units 

operating a FGD system was shut down and therefore not sending flue gases through the 

scrubber, the plant continued to transfer water from the scrubber to the FGD settling pond. The 

flow rate entering the open water area of the FGD settling pond at the time of sampling was 

approximately 1,170 gpm, and plant personnel estimated that approximately 390 gpm of the flow 

rate (one-third of the entire flow) was from the FGD system of the electric generating unit that 

was shut down. The sampling episode report for Widows Creek contains more detailed 

information regarding the sample collection procedures [ERG, 2008o]. 

For the Mitchell sampling episode, EPA collected a grab sample of the FGD scrubber 

purge transfer to the FGD wastewater treatment system. The sample collected contained only 

FGD scrubber purge, which was transferred to the system at a flow rate of approximately 500 

gpm. The sampling episode report for Mitchell contains more detailed information regarding the 

sampling event [ERG, 2008m]. 

For the Belews Creek sampling episode, EPA collected a grab sample of the FGD 

scrubber purge transfer to the FGD wastewater treatment system. The sample collected contained 

only FGD scrubber purge, which was transferred from the purge tank to the system at a flow rate 

of 489 gpm during the sample collection. The sampling episode report for Belews Creek contains 

more detailed information regarding the sampling event [ERG, 2009q]. 

EPA also collected self-monitoring data for the FGD scrubber purge from four plants. 

Table 4-6 presents the number of facilities that reported concentration data for specific analytes, 

the total number of samples from all the plants for each analyte, and the average, minimum, and 

maximum concentrations for all the monitoring data. These monitoring data were used along 

with EPA’s sampling data to calculate the pollutant mass loads in scrubber purge, as discussed in 

Section 4.6. 

The monitoring data collected from industry confirm EPA’s sampling data and 

demonstrate that FGD scrubber purge wastewater contains significant concentrations of chloride, 

TSS, TDS, and metals. The type of treatment system operated at an individual plant is typically 

dependent on the permit limits that the plant must meet. Section 4.4 describes the wastewater 

treatment systems planned or currently operated by coal-fired power plants to treat FGD 

wastewaters. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Table 4-6. FGD Scrubber Purge Self-Monitoring Data 

Analyte 

Number of 

Plants 

Number of 

Samples 

Minimum 

Concentration 

Maximum 

Concentration a Units 

Total Metals 

Aluminum 1 38 8,200 333,000 μg/L 

Antimony 1 38 4.1 23 μg/L 

Arsenic 4 99 58 5,070 μg/L 

Barium 1 38 110 2,050 μg/L 

Beryllium 1 38 ND (0.7) 113 μg/L 

Boron 3 95 7,410 250,000 μg/L 

Cadmium 2 51 ND (0.5) 302 μg/L 

Chromium 2 51 1.7 350 μg/L 

Cobalt 1 38 6.4 148 μg/L 

Copper 2 43 12.8 456 μg/L 

Iron 3 79 1,100 300,000 μg/L 

Lead 1 38 14.7 252 μg/L 

Magnesium 1 13 1,200,000 1,800,000 μg/L 

Manganese 1 38 339 5,460 μg/L 

Mercury 4 132 ND (0.1) 872 μg/L 

Molybdenum 1 38 ND (2) 250 μg/L 

Nickel 3 67 23.4 710 μg/L 

Selenium 4 158 400 21,700 μg/L 

Silver 3 44 ND (0.2) 65 μg/L 

Thallium 2 46 ND (4) 746 μg/L 

Vanadium 1 38 14.2 14,800 μg/L 

Zinc 4 72 33.1 1,060 μg/L 

Dissolved Metals

Mercury 1 17 60 440 μg/L 

Selenium 2 33 130 3,000 μg/L 

Classicals 

BOD5 1 8 3.40 21.0 mg/L 

COD 2 49 140 1,100 mg/L 

Total suspended solids 2 111 24.0 14,000 mg/L 

Total dissolved solids 3 106 6,500 26,000 mg/L 

Sulfate 4 85 780 4,100 mg/L 

Chloride 4 104 1,100 13,000 mg/L 

Bromide 1 28 43.0 96.0 mg/L 

Fluoride 1 37 6.80 57.0 mg/L 

Nitrate/nitrite 2 76 ND (10.0) 270 mg/L 

Total Kjeldahl nitrogen 2 37 2.80 24.0 mg/L 

Total phosphorus 1 1 4.00 4.00 mg/L 

Source: [ERG, 2009x]. 

a – The maximum concentration presented is the maximum detected value in the data set, unless all the results in the 

data set were not detected for the analyte. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4.4 FGD Wastewater Treatment Technologies

During this detailed study, EPA identified and investigated wastewater treatment systems 

operated by steam electric plants for the treatment of FGD scrubber purge, as well as 

operating/management practices that were used to reduce the discharge of FGD wastewater. This 

section describes the following technologies: 

• Settling ponds; 

• Chemical precipitation (using hydroxide and/or sulfide precipitation); 

• Biological treatment; 

• Constructed wetlands; 

• Vapor-compression evaporation system; 

• Design/operating practices achieving zero discharge; and 

• Other technologies under investigation. 

Most plants currently discharging FGD wastewater use settling ponds; however, the use 

of more advanced wastewater treatment systems is increasing to a limited extent due to more 

stringent requirements imposed by some states on a site-specific basis. Section 4.4.8 presents 

information EPA has compiled on the types of FGD wastewater treatment systems currently 

operating or expected to be installed. 

4.4.1 Settling Ponds 

Settling ponds are designed to remove particulates from wastewater by means of gravity. 

For this to occur, the wastewater must stay in the pond long enough to allow sufficient time for 

particles to fall out of suspension before being discharged from the pond. The size and 

configuration of settling ponds varies by plant; some settling ponds operate as a system of 

several ponds, while others consist of one large pond. The ponds are initially sized to provide a 

certain residence time to reduce the TSS levels in the wastewater and to allow for a certain lifespan of the pond based on the expected rate of solids buildup within the pond. Coal-fired power 

plants do not typically add treatment chemicals to settling ponds, other than to adjust the pH of 

the wastewater before it exits the pond to bring it into compliance with NPDES permit limits. 

Settling ponds can reduce the amount of TSS in wastewater, as well as specific pollutants 

that are in particulate form, provided that the settling pond has a sufficiently long residence time; 

however, settling ponds are not designed to reduce the amount of dissolved metals in the 

wastewater. The FGD wastewater entering a treatment system contains significant concentrations 

of several pollutants in the dissolved phase, including boron, manganese, and selenium. These 

dissolved metals are likely discharged largely unremoved from FGD wastewater settling ponds. 

Additionally, EPRI has reported that adding FGD wastewater to ash ponds may reduce the 

settling efficiency in the ash ponds, due to gypsum particle dissolution, thus increasing the 

effluent TSS concentration [EPRI, 2006b]. EPRI has also reported that the FGD wastewater 

includes high loadings of volatile metals which can impact the solubility of metals in the ash 

pond, thereby potentially leading to increases in the effluent metal concentrations [EPRI, 2006b]. 

Section 5.4.1 contains a more detailed discussion of this topic. 

EPA compiled data for plants operating wet FGD systems and wastewater treatment 

systems used to treat the FGD wastewaters generated. Based on these data, settling ponds are the 

most commonly used systems for managing FGD wastewater. Most plants using ponds transfer 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

FGD scrubber purge directly to a settling pond that also treats other waste streams, specifically 

fly ash transport water and/or bottom ash transport water. Approximately one-third of the plants 

using FGD ponds transfer the FGD scrubber purge to a settling pond specifically designated to 

treat FGD wastewater. In these cases, the FGD wastewater pond effluent is either discharged 

directly to surface waters (with or without first mixing with cooling water or other large volume 

wastes streams) or transferred to an ash pond for further settling and dilution. 

EPA has also identified two plants (one currently operating an FGD system and one 

planned) that transfer the FGD scrubber purge to a settling pond for initial solids removal and 

then transfer the wastewater to a biological treatment system for further treatment. 

EPA reviewed information to determine whether the use of settling ponds to treat FGD 

wastewater was limited to relatively older scrubbers. Approximately 20 percent of the plants 

using settling ponds began operating an additional wet FGD system after 2000. Each of these 

plants was already operating another FGD system prior to 2000. This suggests plants do not 

replace the settling pond treatment system with a more advanced system when a new FGD 

system is installed; instead, the plants begin transferring the additional FGD wastewater to the 

existing treatment system. In addition, some plants currently without scrubbers have announced 

that they intend to rely on settling ponds to treat their FGD wastewater. The information 

compiled by EPA for this study indicates that the use of pond systems will continue to be 

significant in the future, with about half of plants discharging FGD wastewater in 2020 using 

settling ponds. 

4.4.2 Chemical Precipitation 

In a chemical precipitation wastewater treatment system, chemicals are added to the 

wastewater to alter the physical state of dissolved and suspended solids to facilitate settling and 

removal of the solids. The specific chemical(s) used depends upon the type of pollutant requiring 

removal. Steam electric plants commonly use the following three types of precipitation systems 

to precipitate metals out of FGD wastewater: 

• Hydroxide precipitation; 

• Iron coprecipitation; and 

• Sulfide precipitation. 

In a hydroxide precipitation system, lime (calcium hydroxide) is often added to elevate 

the pH of the wastewater and help precipitate metals into insoluble metal hydroxides that can be 

removed by settling or filtration. Sodium hydroxide can also be used in a hydroxide chemical 

precipitation system, but it is more expensive than lime and therefore, not used as commonly. 

Many plants use iron coprecipitation as a way to increase the removal of metals in a 

hydroxide precipitation system. Ferric or ferrous chloride can also be added to the precipitation 

system to coprecipitate additional metals and organic matter. The ferric chloride also acts as a 

coagulant, forming a dense floc that enhances settling of the metals precipitate in downstream 

clarification stages. 

In a sulfide precipitation system, sulfide chemicals (e.g., trimercapto-s-triazine (TMT), 

Nalmet®, sodium sulfide) are used to precipitate and remove heavy metals, such as mercury. 

While hydroxide precipitation can remove some heavy metals, sulfide precipitation can be more 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-28 

effective because metal sulfides have lower solubilities than metal hydroxides. FGD wastewater 

chemical precipitation systems may include various configurations of lime, ferric chloride, and 

sulfide addition stages, as well as clarification stages. 

A process flow diagram for a typical chemical precipitation system using both hydroxide 

and sulfide addition to treat FGD wastewater is illustrated by Figure 4-6. A chemical 

precipitation system that omits the sulfide precipitation stage would be similar, but would 

exclude the reaction tank where sulfide is added. 

For the system illustrated by Figure 4-6, the FGD scrubber purge from the plant’s solid 

separation/dewatering process is transferred to an equalization tank, where the intermittent flows 

are equalized, allowing the plant to pump a constant flow of wastewater through the treatment 

system. The equalization tank also receives wastewater from a filtrate sump, which includes 

water from the gravity filter backwash and filter press filtrate. 

The FGD scrubber purge is transferred at a continuous flow from the equalization tank to 

reaction tank 1, where the plant adds hydrated lime to raise the pH of the wastewater from 

between 5.5 – 6.0 to between 8.0 – 10.5 to precipitate the soluble metals as insoluble hydroxides 

and oxyhydroxides. The reaction tank also desaturates the remaining gypsum in the wastewater, 

which prevents gypsum scale formation in the downstream wastewater treatment equipment. 

From reaction tank 1, the wastewater flows to reaction tank 2, where organosulfide (most 

commonly TMT) or inorganic sulfide is added. The treatment system can also be configured so 

that the organosulfide addition occurs before the hydroxide precipitation step, or with a 

clarification step between the two chemical addition steps. 

From reaction tank 2, the wastewater flows to reaction tank 3, where ferric chloride is 

added to the wastewater for coagulation and coprecipitation. The effluent from reaction tank 3 

flows to the flash mix tank, where polymer is added to the wastewater, prior to be being 

transferred to the clarifier. Alternatively, the polymer can be added directly to the waste stream 

as it enters the clarifier or added to reaction tank 3. The polymer is used to flocculate fine 

suspended particles in the wastewater. 

The clarifier settles the solids that were initially present in the FGD scrubber purge as 

well as the additional solids (precipitate) that were formed during the chemical precipitation 

steps. A sand filter may also be included in the process to further reduce solids, as well as metals 

attached to the particulates. The backwash from the sand filters is transferred to a filtrate sump 

and recycled back to the equalization tank at the beginning of the treatment system. 

The treated FGD wastewater is collected in a wastewater holding tank and either 

discharged directly to surface waters or, in most cases, commingled with other waste streams 

prior to discharge to dilute the concentration of pollutants in the wastewater. As described in 

Section 4.2, plants do not typically reuse this treated FGD wastewater because the chlorides are 

at levels that have the potential to corrode downstream equipment. 
Final Detailed Study Report Chapter 4 – Flue G

Figure 4-6. Process Flow Diagram for a Hydroxide and Sulfide Chemical Precipitation Sy

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

The solids settling in the clarifier (clarifier sludge) are transferred by pumps to the sludge 

holding tanks, after which the sludge is dewatered using a filter press. The dewatered sludge, or 

filter cake, is typically sent to an on-site landfill for disposal. The filtrate from the filter press is 

transferred to a sump and recycled back to the equalization tank at the beginning of the treatment 

system. 

4.4.3 Biological Treatment 

Biological wastewater treatment systems use microorganisms to consume biodegradable 

soluble organic contaminants and bind much of the less soluble fractions into floc. Pollutants 

may be reduced aerobically, anaerobically, and/or by using anoxic zones. Based on the 

information EPA collected during the detailed study, two main types of biological treatment 

systems are currently used (or planned) to treat FGD wastewater: aerobic systems to remove 

BOD5 and anoxic/anaerobic systems to remove metals and nutrients. These systems can use 

fixed film or suspended growth bioreactors, and operate as conventional flow-through or as 

sequencing batch reactors (SBRs). The wastewater treatment processes for each of these 

biological treatment systems is discussed below. 

Aerobic Biological Treatment 

An aerobic biological treatment system can effectively reduce BOD5 from wastewaters. 

In a conventional flow-through design, the wastewater is continuously fed to the aerated 

bioreactor. The microorganisms in the reactor use the dissolved oxygen from the aeration to 

digest the organic matter in the wastewater, thus reducing the BOD5. The digestion of the 

organic matter produces sludge, which may be dewatered with a vacuum filter to better manage 

its ultimate disposal. The treated wastewater from the system overflows out of the reactor. 

An SBR is a type of activated sludge treatment system that can reduce BOD5 and, when 

operated to create anoxic zones under certain conditions, can also reduce nitrogen compounds 

through nitrification and denitrification. Plants often operate at least two identical reactors 

sequentially in batch mode. The treatment in each SBR consists of a four-stage process: fill, 

aeration and reaction, settling, and decant. While one of the SBRs is settling and decanting, the 

other SBR is filling, aerating, and reacting. 

When operated as an aerobic system, the SBR operates as follows. The filling stage of the 

SBR consists of transferring the FGD wastewater into a reactor that contains some activated 

sludge from the previous reaction batch. During the aeration and reaction stage, the reactor is 

aerated and the BOD5 is reduced as the microorganisms digest the organic matter in the 

wastewater. During the settling phase, the air is turned off and the solids in the SBR are allowed 

to settle to the bottom. The wastewater is then decanted off the top of the SBR and either 

transferred to surface water for discharge or transferred for additional treatment. Additionally, 

some of the solids from the bottom of the SBR are removed and dewatered, but some of the 

solids are retained in the SBR to retain microorganisms in the system. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Anoxic/Anaerobic Biological Treatment 

Some coal-fired power plants are moving towards using anoxic/anaerobic biological 

systems to achieve better reductions of certain pollutants (e.g., selenium, mercury, nitrates) than 

has been possible with other treatment processes used at power plants. Figure 4-7 presents a 

process flow diagram for an anoxic/anaerobic biological treatment system. These biological 

systems include either a settling pond or chemical precipitation system as a pretreatment step to 

reduce TSS entering the bioreactors. Additionally, the microorganisms are susceptible to high 

temperatures, which may require the FGD wastewater to be cooled prior to entering the 

biological system. 

The fixed-film bioreactor consists of an activated carbon bed that is inoculated with 

microorganisms which reduce selenium and other metals. Growth of the microorganisms within 

the activated carbon bed creates a fixed-film that retains the microorganisms and precipitated 

solids within the bioreactor. A molasses-based feed source for the microorganisms is added to 

the wastewater before it enters the bioreactor [Pickett, 2006]. 

Figure 4-7. Process Flow Diagram for an Anoxic/Anaerobic Biological Treatment System 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

The bioreactor is designed for plug flow, containing different zones within the reactor 

that have differing oxidation potential. The top part of the bioreactor is aerobic and allows for 

nitrification and organic carbon oxidation. As the wastewater moves down through the 

bioreactor, it enters an anoxic zone where denitrification occurs as well as chemical reduction of 

both selenate and selenite, which are forms of selenium [Pickett, 2006]. 

As selenate and selenite are reduced within the bioreactor, elemental selenium forms 

nanospheres that adhere to the cell walls of the microorganisms. Because the microorganisms are 

retained within the bioreactor by the activated carbon bed, the elemental selenium is essentially 

fixed to the activated carbon until it is removed from the system. The bioreactor can also reduce 

other metals, including arsenic, cadmium, and mercury, by forming metal sulfides within the 

system [Pickett, 2006]. 

The bioreactor system typically contains multiple bioreactors; however, they can either 

be set up in series, as shown in Figure 4-7, or they can be set up in parallel, where the FGD 

wastewater is split and treated in separate bioreactors. Multiple bioreactors are typically required 

to allow for additional residence time to achieve the specified removals. 

Periodically, the bioreactor must be flushed to remove the solids and inorganic materials 

that have accumulated within it. The flushing process involves fluidizing the carbon bed by 

flowing water upward through the system, which dislodges the particles fixed within the 

activated carbon. The water and solids overflow from the top of the bioreactor and are removed 

from the system. This flush water must be treated prior to being discharged because of the 

elevated levels of solids and selenium [Pickett, 2006]. One plant currently operating an 

anoxic/anaerobic bioreactor system recycles the flush water to the beginning of the chemical 

precipitation wastewater treatment system so that the solids can be removed by the clarifier. The 

other plant transfers the flush water to a segregated portion of the settling pond upstream of the 

bioreactor [ERG, 2008h; Jordan, 2008a]. 

Another system developed by a treatment system vendor is similarly based on 

anoxic/anaerobic biological treatment, but relies on using suspended growth flow-through 

bioreactors instead of fixed-film bioreactors. Both designs share the fundamental processes that 

lead to denitrification and reduction of metals in anoxic and anaerobic environments. This 

suspended growth bioreactor system recently completed long-term pilot testing. 

SBRs can also be operated to achieve the anoxic/anaerobic conditions described for the 

flow-through systems. The SBR operation would be similar to that described above for the 

aerobic biological treatment system; however, to create anoxic conditions, the aeration stage 

would be followed by periods of air on, air off, which create aerobic zones for nitrification and 

anoxic zones for denitrification to remove the nitrogen in the wastewater. EPA has collected 

information on four coal-fired power plants that are planning to operate anoxic/anaerobic 

biological SBRs, with startup scheduled to occur by 2010. The SBR systems at these plants are 

expected to be operated in combination with chemical precipitation systems, with the overall 

systems designed to optimize removal of metals and nitrogen compounds. According to the 

treatment system vendor, these SBR systems will denitrify the wastewaters, but the oxidation 

reduction potential in the system will not be conducive for reducing metals. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-33 

4.4.4 Constructed Wetlands 

A constructed wetland treatment system is an engineered system that uses natural 

biological processes involving wetland vegetation, soils, and microbial activity to reduce the 

concentrations of metals, nutrients, and TSS in wastewater. A constructed wetland typically 

consists of several cells that contain bacteria and vegetation (e.g., bulrush, cattails), which are 

selected based on the specific pollutants targeted for removal. The vegetation completely fills 

each cell and produces organic matter (i.e., carbon) used by the bacteria. The bacteria reduce 

metals that are present in the aqueous phase of the wastewater, such as mercury and selenium, to 

their elemental state. The targeted metals partition into the sediment where they either 

accumulate or are taken up by the vegetation in the wetland cells [EPRI, 2006b; Rodgers, 2005]. 

High temperature, COD, nitrates, sulfates, boron, and chlorides in wastewater can 

adversely affect constructed wetlands performance. To overcome this FGD wastewater is 

typically diluted with service water before it enters a constructed wetland to reduce the 

temperature and concentration of chlorides and other pollutants, which can harm the vegetation 

in the treatment cells. Chlorides in a constructed wetlands treatment system typically must be 

maintained below 4,000 mg/L. Most plants operate their FGD scrubber system to maintain 

chloride levels within a range of 12,000-20,000 ppm, so plants must dilute the FGD wastewater 

prior to transferring it to the wetlands. EPA has observed that power plants operating a 

constructed wetland tend to operate the FGD scrubber at the lower end of the chloride range. To 

do this, the plants purge FGD wastewater from the system at a higher flow rate than they 

otherwise would do if operating the FGD scrubber at a higher chloride level. 

4.4.5 Vapor-Compression Evaporation System 

Evaporators in combination with a final drying process can significantly reduce the 

quantity of wastewater discharged from certain process operations at various types of industrial 

plants, including power plants, oil refineries, and chemical plants. One type of evaporation 

system uses a falling-film evaporator (also referred to as a brine concentrator) to produce a 

concentrated wastewater stream and a reusable distillate stream. The concentrated wastewater 

stream may be further processed in a crystallizer or spray dryer, in which the remaining water is 

evaporated, eliminating the wastewater stream. When used in conjunction with a crystallizer or 

spray dryer, this process reportedly generates a clean distillate and a solid by-product that can 

then be disposed of in a landfill. Figure 4-8 presents a process flow diagram for a vaporcompression evaporation system. 

Power plants most often use vapor-compression evaporator systems to treat waste 

streams such as cooling tower blowdown and demineralizer waste, but they have recently begun 

to operate vapor-compression evaporator systems to treat FGD wastewater as well. One U.S. 

coal-fired plant and six coal-fired power plants in Italy are treating FGD wastewater with vaporcompression evaporator systems [Rao, 2008; Veolia, 2007; ERG, 2009a]. 
Final Detailed Study Report Chapter 4 – Flue G

FGD 

Scrubber 

Purge

Acid

Distillate for 

Reuse/Discharge

Feed/Distillate 

Heat Exchanger

Distillate 

Tank

Deaerator

Vent to 

Atmosphere

Brine Concentrator/

Vapor Separator

Mult

Comp

Blo

Vent to 

Atmosphere

FGD Waste Brine 

Solution

Brine 

Recycle

Co

- C- S- F

Distillate

Figure 4-8. Process Flow Diagram for a Vapor-Compression Evaporation System 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

When a vapor-compression evaporator system is used to treat FGD wastewater, the first 

step is to adjust the pH of the FGD scrubber purge to approximately 6.5. Following pH 

adjustment, the scrubber purge is sent through a heat exchanger to bring the waste stream to its 

boiling point. The waste stream continues to a deaerator where the noncondensable materials 

such as carbon dioxide and oxygen are vented to the atmosphere [Aquatech, 2006]. 

From the deaerator, the waste stream enters the sump of the brine concentrator. Brine 

from the sump is pumped to the top of the brine concentrator and enters the heat transfer tubes. 

While falling down the heat transfer tubes, part of the solution is vaporized and then compressed 

and introduced to the shell side of the brine concentrator (i.e., the outside of the tubes). The 

temperature difference between the compressed vapor and the brine solution causes the 

compressed vapor to transfer heat to the brine solution, which flashes to a vapor. As heat is 

transferred to the brine, the compressed vapor cools and condenses as distilled water [Aquatech, 

2006]. 

The condensed vapor (distillate water) can be recycled back to the FGD process, used in 

other plant operations (e.g., boiler make-up water), or discharged. If the distillate is used for 

other plant operations that generate a discharge stream (e.g., used as boiler make-up and 

ultimately discharged as boiler blowdown), then the FGD process/wastewater treatment system 

is not achieving true zero liquid discharge. Therefore, the operation of the vapor-compression 

evaporation system itself does not guarantee that the FGD process/wastewater treatment system 

achieves zero discharge. 

To prevent scaling within the brine concentrator as a result of the gypsum present in the 

FGD scrubber purge, the brine concentrator is seeded with calcium sulfate. The calcium salts 

preferentially precipitate onto the seed crystals instead of the tube surfaces of the brine 

concentrator [Shaw, 2008]. 

The concentrated brine slurry from the brine concentrator tubes falls into the sump and is 

recycled with the feed (FGD scrubber purge) back to the top of the brine concentrator, while a 

small amount is continuously withdrawn from the sump and typically transferred to a final 

drying process. The brine concentrator can typically concentrate the FGD scrubber purge five to 

ten times, which reduces the inlet FGD scrubber purge water volume by 80 to 90 percent [Shaw, 

2008]. 

Three options are typically considered to be available for eliminating the brine 

concentrate: (1) final evaporation in a brine crystallizer; (2) evaporation in a spray dryer; or (3) 

using the brine to condition (add moisture to) dry fly ash or other solids, and disposal of the 

mixture in a landfill. 

Power plants may use brine concentrators to treat a waste stream other than FGD 

scrubber purge (e.g., cooling tower blowdown). For these non-FGD systems, the concentrated 

brine withdrawn from the sump is typically sent to a forced-circulation crystallizer to evaporate 

the remaining water from the concentrate and generate a solid product for disposal. However, the 

calcium and magnesium salts present in the scrubber purge can pose difficulties for the forcedcirculation crystallizer. To prevent this, the FGD scrubber purge can be pretreated using a limesoftening process (i.e., chemical precipitation) upstream of the brine concentrator. With water 

softening, the magnesium and calcium ions precipitate out of the purge water and are replaced 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

with sodium ions, producing an aqueous solution of sodium chloride that can be more effectively 

treated with a forced-circulation crystallizer [Shaw, 2008]. 

Coal-fired power plants can avoid having to operate the chemical precipitation 

pretreatment process by using a spray dryer to evaporate the residual waste stream from the brine 

concentrator. Because the material is hygroscopic (i.e., readily taking up and retaining moisture), 

the solid residual from the brine concentrator is typically bagged immediately and disposed of in 

a landfill. Alternatively, the concentrated brine waste stream can be combined with dry fly ash or 

other solids and disposed of in a landfill. 

4.4.6 Design/Operating Practices Achieving Zero Discharge 

During its site visit program, EPA observed that many of the plants operating wet FGD 

systems were able to design and/or manage the FGD system in a manner that prevented the need 

for a discharge of FGD wastewater. Based on information EPA collected during the detailed 

study, EPA identified four design/operating practices available to prevent the discharge of FGD 

wastewater: evaporation ponds, conditioning dry fly ash, underground injection, and several 

variations of complete recycle. The wastewater treatment processes for each of these practices 

are discussed below. 

Complete Recycle 

As discussed in Section 4.2, most plants do not recycle the treated FGD wastewater 

within the FGD system because of the elevated chloride levels in the treated effluent. Some 

plants, however, can completely recycle the FGD wastewater within the system without using a 

wastewater purge stream to remove chlorides. Such plants generally do not produce a saleable 

solid product from the FGD system (e.g., wallboard-grade gypsum). Because the FGD solid byproduct is not being sold and is most likely disposed of in a landfill, there are no specific 

chloride specifications for the material. Therefore, the plant can operate the FGD system and 

solids separation/dewatering process such that the moisture retained with the landfilled solids 

entrains sufficient chlorides that a separate wastewater purge stream is not needed. By operating 

in this manner, the transfer of the FGD solids to the landfill essentially serves as the chloride 

purge from the system. 

EPA visited four plants that operate limestone forced oxidation FGD systems that do not 

discharge any FGD wastewaters directly to surface waters. Case Study I describes how one of 

these plants, Dominion Resources’ Mount Storm Plant, is able to completely reuse the FGD 

wastewaters within the system. 

EPA also visited three plants that operate lime or limestone inhibited oxidation FGD 

systems and do not discharge any FGD wastewaters directly to surface waters. Case Study II 

describes how one of these plants was able to completely reuse the FGD wastewaters within the 

system. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Case Study I: Coal-Fired Power Plant Water Reuse 

Limestone Forced Oxidation FGD System 

Dominion Resources’ Mount Storm Plant 

The Facility

FGD type: Limestone forced oxidation spray tower 

Scrubber chlorides conc.: 40,000 ppm 

Materials of construction chlorides limit: 120,000 ppm 

FGD WWT system: None: complete recycle 

Gypsum destination: Landfill, concrete manufacturing, land application 

The FGD Wastewater Handling System

The gypsum slurry blowdown from the FGD system is transferred to hydroclones for initial 

dewatering. The underflow from the hydroclones contains the gypsum solids and is transferred 

to vacuum rotary drum filters. The hydroclone overflow, which is mostly water and fines, is 

recycled back to the FGD scrubber. 

The hydroclone underflow sent to the vacuum rotary drum filters is not rinsed with service 

water, as some plants do. The underflow is fed to a tray that holds the underflow as the vacuum 

drum filter rotates and the bottom of the drum filter is dipped in the underflow water. The 

vacuum on the rotary drum filter pulls the solids and water to the drum and then pulls the water 

out of the solids to dry the gypsum. The dry gypsum (20-25% moisture content) is then scraped 

off the drum as it rotates. The gypsum collected from the vacuum rotary drum filters is 

conveyed to the storage area until it is either sent to the on-site landfill, transferred off site to a 

concrete manufacturer, or transferred off site for land application. The filtrate from the vacuum 

rotary drum filters is either recycled back to the FGD scrubber or to the limestone preparation 

process. 

Why the Plant is Able to Completely Reuse FGD Wastewater

Gypsum is not sold to a wallboard manufacturer; therefore, the gypsum dried on the vacuum 

rotary drum filters does not need to meet any particular specifications. Since higher levels of 

chlorides are acceptable, the gypsum does not require washing. Chlorides are purged from the 

system entrained in the gypsum (20-25% moisture), and the mass removal rate is sufficient to 

maintain the chlorides in the FGD system at a constant level. 

Source: [ERG, 2008p]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Case Study II: Coal-Fired Power Plant Water Reuse 

Lime or Limestone Inhibited Oxidation FGD System 

Ohio Power Company’s General James M Gavin Plant 

The Facility

FGD type: Magnesium-enhanced lime inhibited oxidation spray/tray towers 

Scrubber chlorides conc.: 2,500 to 3,000 ppm 

FGD WWT system: None: complete recycle 

Calcium sulfite destination: Landfilled as cementitious material 

The FGD Wastewater Handling System

The calcium sulfite slurry from the FGD system is transferred to a pair of thickeners to separate 

the solids from the water. The underflow from the thickener contains the calcium sulfite solids 

and is transferred to centrifuges for final dewatering. The thickener overflow is sent to a reclaim 

tank and recycled back to the FGD scrubber. 

The thickener underflow sent to the centrifuges is not rinsed with service water. The underflow 

is fed to a centrifuge to dewater the solids. The water leaving the centrifuge, referred to as 

centrate, is recycled back to the FGD scrubber. The solids stream from the centrifuge contains 

40-50 percent moisture. This stream is combined with dry fly ash and lime in a pug mill to 

generate a cementitious material that can be landfilled. 

How FGD Wastewater is Completely Reused

The calcium sulfite does not need to meet any particular specifications; therefore, it is not 

washed to remove chlorides prior to dewatering. The dewatered calcium sulfite has a moisture 

content of 40 to 50 percent water (before mixing with fly ash and lime) and chlorides are 

retained in the cementitious material sent to the landfill. The FGD system has reached a steady 

state operation in which the chlorides entering the system from the coal are equal to the 

chlorides that are leaving the system in the cementitious material. 

Source: [ERG, 2009b]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Evaporation Ponds 

EPA identified three coal-fired power plants located in the southwestern United States 

using evaporation ponds to avoid discharging FGD wastewater. Because of the warm, dry 

climate in this region, the plants can send the FGD wastewater to one or more ponds where the 

water is allowed to evaporate. At these plants, the evaporation rate from the pond is greater than 

or equal to the flow rate of the FGD wastewater to the pond and no water is discharged from the 

evaporation pond. 

Conditioning Dry Fly Ash 

Many plants that operate dry fly ash handling systems need to add water to the fly ash for 

dust suppression or to improve handling and/or compaction characteristics. EPA has identified 

one plant that uses FGD wastewater to condition its dry fly ash. In addition, another plant is 

using a vapor-compression evaporation system in combination with conditioning dry fly ash to 

prevent the discharge of FGD wastewater [ERG, 2009a]. The plant uses the vapor-compression 

evaporation system to reduce the volume of the FGD scrubber purge and then mixes the effluent 

from the brine concentrator with dry fly ash and disposes of it in a landfill. 

Underground Injection 

Underground injection is a technique used to dispose of wastes by injecting them into an 

underground well. This technique is an alternative to discharging wastewater to surface waters. 

One plant began using underground injection to dispose of the FGD wastewater in 2007, but due 

to unexpected pressure issues and problems with building the wells due to geological formations 

encountered, which may not be related to the characteristics of the FGD wastewater, the plant 

has not been able to continuously inject the wastewater. The plant operates a chemical 

precipitation system as pretreatment for the injection system. When the plant is not injecting the 

FGD wastewater, the effluent from the chemical precipitation system is transferred to the plant’s 

pond system. Since the pond water is used as make-up for the plant’s service water, the chlorides 

from the FGD wastewater are not purged from the system. The plant needs to sustain continuous 

injection of the wastewater to avoid chlorides increasing to a level that would promote corrosion 

of equipment [ERG, 2009e]. Another plant is also scheduled to begin injecting the FGD 

wastewater underground later this year [Gulf Power, 2009]. Underground injection has its own 

permitting and regulations, which are not covered under the NPDES program. 

Combination of Wet and Dry FGD Systems 

The combination of a wet and a dry FGD system operated on the same unit or at the same 

plant can result in elimination of the scrubber purge associated with the wet FGD process. As 

described in Section 4.2.3, the dry FGD process involves atomizing and injecting wet lime 

slurry, which ranges from approximately 18 to 25 percent solids, into a spray dryer. The water 

contained in the slurry is evaporated from the heat of the flue gas within the system, leaving 

behind a dry residue which is removed from the flue gas by a fabric filter (i.e., baghouse). By 

operating a combination of a wet and dry FGD system, the scrubber purge associated with the 

wet FGD system can be used as make-up water for the lime slurry feed to the dry FGD process, 

thereby eliminating the FGD wastewater. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

From its data collection activities, EPA has identified one plant that is expected to 

operate a dry FGD system in combination with a wet FGD system to eliminate the need to 

discharge the FGD wastewater associated with the wet FGD system. Case Study III describes 

how this plant is expected to operate when the new electric generating unit begins operation in 

2012. 

4.4.7 Other Technologies under Investigation 

Industry-funded studies are being conducted by EPRI to evaluate and demonstrate 

technologies that have the potential to remove trace metals from FGD wastewater. EPRI is 

conducting pilot- and full-scale optimization field studies on some technologies already in use by 

coal-fired power plants to treat FGD wastewater, such as chemical precipitation (organosulfide 

and iron coprecipitation), constructed wetlands, and an anoxic/anaerobic biological treatment 

system. EPRI is also conducting lab- and pilot-scale studies for other technologies that may be 

capable of removing metals from FGD wastewaters. EPA obtained limited information regarding 

these other technologies, which include iron cementation, reverse osmosis, absorption media, ion 

exchange, and electro-coagulation. Each of these technologies are discussed below. 

Iron Cementation 

EPRI conducted laboratory feasibility studies of the metallic iron cementation treatment 

technology as a method for removing all species of selenium from FGD wastewater. EPRI 

believes this process may also be effective at removing mercury. The iron cementation process 

consists of contacting the FGD wastewater with an iron powder, which reduces the metal to its 

elemental form (cementation). The pH of the wastewater is raised to form metal hydroxides, and 

the wastewater is filtered to remove the precipitated solids. The iron powder used in the process 

is separated from the wastewater and recycled back to the cementation step. From the initial 

studies, EPRI concluded that the metallic iron cementation approach is promising for treating 

FGD wastewater for multiple species of selenium, including selenite, selenate, and other 

unknown selenium compounds. EPRI is planning to continue conducting laboratory- and pilotscale feasibility studies of the technology to evaluate selenium and mercury removal 

performance [EPRI, 2008b]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Case Study III: Coal-Fired Power Plant Water Reuse 

Integrated Dry and Wet FGD Systems 

Duke Energy Carolinas’ Cliffside Steam Station 

The Facility

FGD type: Unit 6: Lime spray dryer and wet limestone forced oxidation 

spray tower; Unit 5: wet limestone forced oxidation spray tower 

FGD WWT system: Unit 6: None; Unit 5: chemical precipitation system 

FGD solids destination: Sold for wallboard production or landfilled 

The FGD Operation and Wastewater Handling System

When Unit 6 begins operation (expected in 2012), its flue gas will first be treated with a dry 

lime FGD system (spray dryer). The flue gas exiting the spray dryer will pass through a fabric 

filter baghouse to remove the FGD solids, fly ash, and other particulates from the flue gas. The 

flue gas will then be directed to the wet limestone forced oxidation system. The wet FGD 

system will operate similarly to Figure 4-2; however, instead of the scrubber purge being 

transferred to wastewater treatment and discharged, the scrubber purge will be reused in the 

lime slurry feed to the dry FGD system. 

Unit 5 is currently operating at the plant, but its wet FGD system is not yet operating. Once the 

FGD system is operating, the Unit 5 flue gas will be treated by a cold-side ESP followed by a 

wet limestone forced oxidation system. When Unit 6 is not operating, the scrubber purge from 

Unit 5 will be transferred to a chemical precipitation wastewater treatment system. When Unit 6 

is operating, most, if not all, of the scrubber purge from Unit 5 can be used in the lime slurry 

feed for the Unit 6 dry FGD system; the remainder will be transferred to the wastewater 

treatment system. Units 5 and 6 operate independently from each other and, therefore, the 

wastewater treatment system will allow the plant to operate Unit 5 and discharge its scrubber 

purge stream when Unit 6 is not operating. 

How the FGD Wastewater Discharge will be Eliminated

The scrubber purge streams from Units 5 & 6 will be reused in the feed stream to Unit 6’s dry 

FGD system, which will evaporate the water during the process and generate only solid 

residues that are removed in the fabric filter baghouse. 

Source: [McGinnis, 2009]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Reverse Osmosis 

Reverse osmosis systems are currently in use at power plants, usually to treat boiler 

make-up water or cooling tower blowdown wastewaters. EPRI has identified a high-efficiency 

reverse osmosis (HEROTM) process which operates at a high pH, allowing the system to treat 

high silica wastewaters without scaling or membrane fouling because silica is more soluble at 

higher pHs. The wastewater undergoes a water-softening process to raise the pH of the 

wastewater prior to entering the HEROTM system. 

Although the HEROTM system has been demonstrated for use with power plant cooling 

tower blowdown wastewater, its use for FGD wastewater is potentially limited due to the 

osmotic pressure of the FGD wastewater resulting from the high concentrations of chloride and 

TDS [EPRI, 2007a]. 

Although many power plants may not be able to use the HEROTM system to treat FGD 

wastewater, some plants with lower TDS and chloride concentrations may be able to do so. The 

HEROTM system is of particular interest for treating boron from FGD wastewaters because boron 

becomes ionized at an elevated pH and, therefore, could be removed using a reverse osmosis 

system [EPRI, 2007a]. 

Sorption Media 

Sorption media has been used by the drinking water industry to remove arsenic from the 

drinking water. These sorption processes are designed to adsorb pollutants onto the media’s 

surface area using physical and chemical reactions. The designs most commonly used in the 

drinking water industry use metal-based adsorbents, typically granular ferric oxide, granular 

ferric hydroxide, or titanium-based oxides. The sorption media is usually a single use application 

that can typically be disposed of in a nonhazardous landfill after its use. In addition, the singleuse design prevents the plant from needing to further treat the residuals. According to EPRI, 

these sorption media have been shown to remove the common forms of arsenic and selenium 

from drinking water [EPRI, 2007a]. 

Ion Exchange 

Ion exchange systems are currently in use at power plants to pretreat boiler make-up 

water. Ion exchange systems are designed to remove specific constituents from wastewater; 

therefore, specific metals can be targeted by the system. The typical metals targeted by ion 

exchange systems include boron, cadmium, cobalt, copper, lead, mercury, nickel, uranium, 

vanadium, and zinc. Although the ion exchange process does not generate any residual sludge, it 

does generate a regenerant stream that contains the metals stripped from the wastewater. EPA 

has compiled information on a plant that is pilot testing two ion exchange resins for treatment of 

FGD wastewater. The plant and the ion exchange resins tested in the pilot study are focused 

specifically on the removal of mercury. [EPRI, 2007a]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-43 

Electro-Coagulation 

Electro-coagulation uses an electrode to introduce an electric charge to the wastewater, 

which neutralizes the electrically charged colloidal particles. These systems typically use 

aluminum or iron electrodes, which are dissolved into the waste stream during the process. The 

dissolved metallic ions precipitate with the other pollutants present in the wastewater and form 

insoluble metal hydroxides. According to EPRI, additional polymer or supplemental coagulants 

may need to be added to the wastewater depending on the specific characteristics. These systems 

are typically used to treat small waste streams, ranging from 10 to 25 gpm, but may also be able 

to treat waste streams of up to 50 or 100 gpm [EPRI, 2007a]. 

Other Technologies 

Other technologies under laboratory-scale study include polymeric chelates, taconite 

tailings, and nano-scale iron reagents. In addition, EPRI is investigating various physical 

treatment technologies, primarily for mercury removal, including filtration [EPRI, 2008a]. 

4.4.8 Wastewater Treatment System Use in the Coal-Fired Steam Electric Industry 

Table 4-7, presents information on the FGD wastewater treatment systems currently 

operating (as of June 2008) at plants included in EPA’s combined data set. Table 4-7 also 

includes information on FGD wastewater treatment systems projected to be operating in 2020. 

EPA’s combined data set includes wastewater treatment system information for 84 of the 108 

plants (78 percent) operating wet FGD scrubber systems as of June 2008, representing 175 of the 

223 wet-scrubbed coal-fired electric generating units (78 percent). Of these 84 plants, 32 plants 

(38 percent) do not discharge FGD wastewater.18 These plants are able to achieve “zero 

discharge” by either recycling all FGD wastewater back to the scrubber (28 plants), using 

evaporation ponds (3 plants), mixing the FGD wastewater with dry fly ash (1 plant), or deep well 

injecting the FGD wastewater (1 plant19). Figure 4-9 shows the distribution of FGD wastewater 

management/treatment within the group of 84 plants. 

 

18 There is a plant that operates several wet FGD systems and for some of the wet FGD systems there is a 

wastewater discharge; however, the other wet FGD systems operate without discharging. In , this plant is 

included in the count of plants for both the “zero discharge” wastewater treatment systems and the other type of 

wastewater treatment system operated by the plant. 

Table 4-7

19 As discussed in Section 4.4.6, the plant began using underground injection to dispose of the FGD wastewater in 

2007, but due to issues encountered with the system, has not been able to continuously inject the wastewater. 
Final Detailed Study Report Chapter 4 – Flue G

4-44 

Table 4-7. FGD Wastewater Treatment Systems Identified During EPA’s Detailed Stud

Wet FGD Systems in the Combined Data Set 

Operating as of June 2008 a

Wet FGD Systems in th

Projected to be Op

Number of Plants 

with FGD 

Wastewater 

Treatment 

Systems 

Number of Electric 

Generating Units 

Serviced by FGD 

Wastewater 

Treatment Systems

Wet 

Scrubbed 

Capacity c

(MW) 

Number of Plants With or Expected 

to Operate FGD 

Wastewater 

Treatment Systems 

Projec

of 

Gener

Servi

Tr

S

Settling Ponds 29 63 27,700 35 

Combined FGD and Ash Ponds (FGD solids removal prior) d, e

17 41 14,400 18 

Combined FGD and Ash Ponds (No FGD solids removal prior) d, f

2 4 1,440 2 

FGD Ponds (FGD solids removal prior) e, g 4 8 4,450 7 FGD Ponds (No FGD solids removal prior) f, g

6 10 7,350 8 

Chemical Precipitation (“Chem Precip”) 15 27 14,200 24 

Chem Precip (type unknown) — — — 5 Hydroxide Chem Precip 10 18 10,500 11 Hydroxide and Sulfide Chem Precip 2 4 2,350 5 Combination Settling Pond and Chem Precip 

2 3 896 2 

Chem Precip and Constructed Wetland 1 2 414 1 

Tank-Based Biological 1 3 2,150 2 

Combination Settling Pond and Anoxic/Anaerobic Biological (designed for metals & nitrogen removal) 

1 3 2,150 2 
Final Detailed Study Report Chapter 4 – Flue G

4-45 

Table 4-7. FGD Wastewater Treatment Systems Identified During EPA’s Detailed Stud

Wet FGD Systems in the Combined Data Set 

Operating as of June 2008 a

Wet FGD Systems in th

Projected to be Op

Number of Plants 

with FGD 

Wastewater 

Treatment 

Systems 

Number of Electric 

Generating Units 

Serviced by FGD 

Wastewater 

Treatment Systems

Wet 

Scrubbed 

Capacity c

(MW) 

Number of Plants With or Expected 

to Operate FGD 

Wastewater 

Treatment Systems 

Projec

of 

Gener

Servi

Tr

S

Combination Chem Precip and Tank-Based Biological 

3 5 4,720 8 

Chem Precip and Aerobic Biological (designed for metals and BOD5 removal) 

2 3 2,560 1 

Chem Precip and Aerobic/Anaerobic Biological (designed for removing nitrogen and selected metals) 

— — — 4 

Chem Precip and Anoxic/Anaerobic Biological (designed for metals & nitrogen removal) 

— — — 3 

Chem Precip, Anoxic/Anaerobic Biological (designed for metals & nitrogen removal), and CWTS 

1 2 2,160 — 

Zero Discharge 33 65 38,700 35 

Zero Discharge: Recycle All FGD Water 28 56 33,800 27 Zero Discharge: Evaporation Pond 3 4 1,800 3 Zero Discharge: Conditioning Dry Fly Ash 1 2 1,140 1 Zero Discharge: Deep Well Injection 1 3 2,000 2 Zero Discharge: Evaporator & Conditioning Dry Fly Ash 

— — — 1 

Zero Discharge: Recycled to Dry FGD — — — 1 
Final Detailed Study Report Chapter 4 – Flue G

4-46 

Table 4-7. FGD Wastewater Treatment Systems Identified During EPA’s Detailed Stud

Wet FGD Systems in the Combined Data Set 

Operating as of June 2008 a

Wet FGD Systems in th

Projected to be Op

Number of Plants 

with FGD 

Wastewater 

Treatment 

Systems 

Number of Electric 

Generating Units 

Serviced by FGD 

Wastewater 

Treatment Systems

Wet 

Scrubbed 

Capacity c

(MW) 

Number of Plants With or Expected 

to Operate FGD 

Wastewater 

Treatment Systems 

Projec

of 

Gener

Servi

Tr

S

Other Handling 5 12 5,010 5 

Clarifier 1 3 521 1 Clarifier and Constructed Wetland 1 4 2,000 1 Commingled with other Wastewater 3 5 2,490 3 

No Information 24 48 15,600 85 

Subtotal: Wastewater treatment systems for 

which EPA has information available h

84 175 92,500 107 

Subtotal: Systems treating FGD wastewater 

discharged to surface waters h

53 110 53,800 74 

Total h 108 223 108,000 192 

a – Source: Combined data set (UWAG-provided data [ERG, 2008g], data request information [U.S. EPA, 2008a], and site visit and samIncludes treatment systems servicing electric generating units identified in the “combined data set” with wet FGD systems operating as OSWER data for surface impoundments containing CCRs. b – Source: Combined data set (UWAG-provided data [ERG, 2008g], data request information [U.S. EPA, 2008a], and site visit and saIncludes treatment systems servicing electric generating units identified in the “combined data set” with wet FGD systems operating by c – The capacities presented have been rounded to three significant figures. Due to rounding, the total capacity may not equal the sum o

capacities. The capacities presented represent the reported nameplate capacity for the unit. d – The combined FGD and ash pond system refers to a settling pond that handles untreated FGD scrubber purge and ash wastewaters (ash transport water). Some plants transfer treated FGD wastewaters to an ash pond for dilution prior to discharge, but these systems are 

e – “FGD Solids removal prior” means that gypsum or calcium sulfite sludge was removed prior to treatment. f – “No FGD Solids removal prior” means that gypsum or calcium sulfite sludge was sent to the settling pond. g – The FGD pond system refers to settling ponds that handle untreated FGD scrubber purge, but do not handle ash wastewaters. The F

other wastewaters along with the FGD scrubber purge, such as low-volume wastes, but the pond cannot receive ash wastewaters to be ch – There are two plants with multiple types of wastewater treatment systems; therefore, there is overlap in these totals. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-47 

Settling Ponds

34%

Chemical Precipitation

Anoxic/Anaerobic 20%

Biological

2%

Other Handling

6%

Zero Discharge

38%

Figure 4-9. Distribution of FGD Wastewater Treatment Systems Among Plants Operating 

Wet FGD Systems 

Figure 4-10 compares the distribution of FGD wastewater treatment systems within the 

group of plants that operate limestone forced oxidation FGD systems, to the group of plants 

operating inhibited/natural oxidation FGD systems. EPA has information about FGD wastewater 

management/treatment for 50 plants operating forced oxidation FGD systems servicing 111 

electric generating units, and 36 plants operating inhibited or natural oxidation FGD systems 

servicing 65 electric generating units20. A larger percentage of the plants operating forced 

oxidation FGD systems discharge the FGD wastewater, relative to plants that operate inhibited 

and natural oxidation FGD systems. This is largely due to the fact that inhibited oxidation FGD 

systems produce calcium sulfite by-product which, since it has little or no value in the 

marketplace, typically is disposed of in a landfill. This provides plants the opportunity to operate 

the FGD system in a manner that purges chlorides from the FGD system along with the 

landfilled solids and eliminates the need for the FGD wastewater discharge. See section 4.2 for 

additional discussion of this operational practice. 

 

20 EPA has information regarding FGD wastewater treatment systems for 84 plants; however, two of these plants 

operated both forced oxidation and natural/inhibited oxidation FGD systems. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-48 

(13)

(4)

(2)

(17)

(15)

(0) (1) (2)

(12)

(22)

0

10

20

30

40

50

60

70

Settling Ponds Chemical

Precipitation

Anoxic/

Anaerobic

Biological

Other Handling Zero Discharge

FGD Wastewater Treatment Technology

Percent of Use by Oxidation Type

Forced Oxidation Inhibited/Natural Oxidation

(Number of plants shown in parantheses)

Figure 4-10. Comparison of Distribution of FGD Wastewater Treatment Systems by Type 

of Oxidation System 

Of the 84 plants for which EPA has information about FGD wastewater, 53 discharge the 

FGD wastewater. The technologies used by these 53 plants to treat FGD wastewater is 

summarized below, and illustrated by Figure 4-11. It should be noted that most of these plants 

subsequently commingle the treated FGD wastewater with other waste streams (e.g., ash 

wastewater or cooling water) to enable dilution to reduce the pollutant concentrations in the 

discharged wastewater. 

• Twenty-nine plants treat the wastewater using a settling pond.21

• Eighteen plants operate chemical precipitation systems. Fifteen of these 18 plants 

operate a hydroxide chemical precipitation system, and three use both hydroxide 

and sulfide precipitation in the treatment system. Additionally, two of the 15 

hydroxide plants currently have equipment installed to also perform a sulfide 

precipitation step, but are no longer adding sulfide to the system. 

• Two of the 18 plants with chemical precipitation systems also operate aerobic 

biological reactors following the precipitation system. Both of these plants use 

 

21 For comparison, note that the OSWER data on surface impoundments identifies 78 plants operating a total of 170 

ponds that contain FGD wastes. There is insufficient data to determine whether the FGD wastestream undergoes 

solids separation to remove gypsum or calcium sulfite prior to the ponds, nor is there information to determine 

which of these ponds may discharge to surface water. Some of the ponds also contain ash wastes and may be more 

accurately described as ash ponds that also receive FGD wastes (with or without first removing FGD solids) 

[Schroeder, 2009]. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-49 

organic acid additives in their FGD scrubbers to improve the SO2 removal 

efficiency, increasing the BOD5 concentration in the scrubber purge. 

• Two plants operate fixed-film anoxic/anaerobic bioreactors. One of these plants 

also operates a chemical precipitation system (one of the 18 plants described 

previously) and the other operates a settling pond as pretreatment to the 

bioreactor. Two additional plants are in the process of installing similar fixed-film 

bioreactors. One will operate the biological system in conjunction with chemical 

precipitation; the other will use a settling pond for pretreatment. 

• One plant uses a clarifier and one plant uses a constructed wetlands treatment 

system as the primary treatment mechanism. Two other plants also operate 

constructed wetland systems; however, the constructed wetland acts as a polishing 

step following chemical precipitation and/or biological treatment. 

• Three plants commingle the FGD wastewater with other waste streams (other than 

ash transport water). 

Settling Ponds

Chemical Precipitation 55%

32%

Anoxic/Anaerobic 

Biological

4%

Other Handling

9%

Figure 4-11. Distribution of FGD Wastewater Treatment Systems Among Plants that 

Discharge FGD Wastewater 

Table 4-7 also presents information for the type of treatment systems that, based on the 

combined data set, EPA anticipates will be used to treat wastewater from the FGD scrubbers that 

will be operating in 2020. Despite recent interest in the use of more advanced wastewater 

treatment systems, the data compiled by EPA indicate that widespread use of settling ponds to 

treat FGD wastewater will continue. 

EPA expects that more than 192 plants will be operating wet FGD scrubbers by 2020 and 

that 158 of these plants will discharge FGD wastewater22. Of these 158 plants, there are 74 for 

which EPA has information on their expected system use. Below is a description of the type of 

 

22 As discussed in section 4.1.2, EPA’s projections for new FGD systems do not include the systems that will be 

installed at new generating units or new plants. Thus, the projections for 2020 are considered to under-estimate the 

actual number of FGD systems that will be installed. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

wastewater treatment systems either currently operating or expected to be operating at these 74 

plants: 

• Thirty-five plants are expected to treat the wastewater using a settling pond; 

• Thirty-four plants are expected to rely on more advanced treatment such as 

chemical precipitation or biological treatment; 

• One plant is expected to use a clarifier and one plant is expected to use a 

constructed wetlands treatment system as the primary treatment mechanism; and 

• Three plants are expected to commingle the FGD wastewater with other waste 

streams (other than ash transport water). 

4.5 Comparison of FGD Wastewater Control Technologies

As part of the detailed study, EPA evaluated several treatment technologies or 

combinations of treatment technologies that plants are using to remove heavy metals and other 

pollutants from FGD wastewater. Using the data available for these systems, EPA evaluated 

these systems as potential controls for the treatment of FGD wastewater, as follows: 

• Chemical Precipitation. Physical/chemical precipitation for heavy metals 

removal using hydroxide or a combination of hydroxide and sulfide precipitation; 

• Chemical Precipitation + Biological Metals Removal. Chemical precipitation 

followed by anoxic/anaerobic biological treatment for removing additional metals 

and to reduce nitrogen compounds; and 

• Chemical Precipitation/Softening + Evaporation + Crystallization. Chemical 

precipitation or softening followed by evaporation in a brine concentrator and 

crystallization for potential elimination of the FGD wastewater stream. 

EPA used information collected throughout the detailed study in evaluating these 

technologies, including operational and performance information from plants, vendors, and 

EPA’s site visit and sampling programs. Data collected during EPA’s sampling program and 

self-monitoring data obtained from individual plants were used to evaluate the performance of 

the chemical precipitation and biological treatment technologies. These data show that chemical 

precipitation is an effective means for removing many metals from the FGD wastewater. 

Biological treatment, specifically fixed-film anoxic/anaerobic bioreactors when paired with a 

chemical precipitation pretreatment stage, is very effective at removing additional pollutants 

such as selenium and nitrogen compounds (e.g., nitrates, nitrites). If operated with a nitrification 

step, the technology would also be expected to remove ammonia that may be present in the waste 

stream. Coal-fired power plants have only recently begun to use evaporation/crystallization 

systems to treat FGD scrubber purge, so EPA was able to collect only limited data for these 

systems. 

Figure 4-12 (A-G) and Figure 4-13 (A-G) present a series of graphs of monitoring data 

collected in 2008 from the FGD wastewater treatment systems at Duke Energy Carolinas’ 

Belews Creek Steam Station and Progress Energy Carolinas’ Roxboro Power Plant, respectively. 

For each plant, the graphs present the concentrations of arsenic, mercury, selenium, and TDS at 

the following points in the FGD wastewater treatment systems: 

4-50 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-51 

• FGD scrubber purge; 

• Intermediate point preceding the biological treatment stage (i.e., settling pond 

effluent for Roxboro and chemical precipitation effluent for Belews Creek); and 

• Effluent from the anoxic/anaerobic biological treatment system. 

The Belews Creek FGD wastewater treatment system consists of an equalization tank 

followed by a chemical precipitation system to reduce dissolved metals using lime for hydroxide 

precipitation, ferric chloride for iron co-precipitation, and a clarifier and sand filter for solids 

removal. After the sand filter, the wastewater is transferred to a fixed-film, anoxic/anaerobic 

biological treatment system designed to remove metals and nitrogen compounds. Belews Creek 

operates two stages of the biological reactors in series. After the biological system, the 

wastewater is transferred to a constructed wetland and then to the ash pond and discharged. 

The Roxboro FGD wastewater treatment system consists of a settling pond followed by a 

fixed-film, anoxic/anaerobic biological treatment system designed to remove metals and nitrogen 

compounds. The settling pond was designed specifically for FGD wastewater, to reduce the 

wastewater temperature and TSS prior to the bioreactor. The bioreactor operates with four 

parallel trains that each has two biological cells in series. Wastewater flows from the bioreactor 

to the ash pond discharge canal and is discharged. 

The Belews Creek and Roxboro graphs show that the chemical precipitation system, the 

settling pond, and the biological treatment systems are all able to remove arsenic, mercury, and 

selenium to some extent from the FGD scrubber purge. Figure 4-12 and Figure 4-13 show that 

the chemical precipitation system at Belews Creek is achieving lower pollutant concentrations of 

metals than the settling pond at Roxboro. Despite the two plants having relatively comparable 

levels of mercury, selenium, and arsenic in their scrubber purge stream, the chemical 

precipitation stage at Belews Creek achieved pollutant concentrations approximately an order of 

magnitude lower than was observed for the settling pond at Roxboro. In addition, the 

anoxic/anaerobic biological treatment stage at both plants further reduced the metals in the FGD 

wastewater. The effectiveness of the biological treatment stage is particularly notable for 

selenium which, depending on the form of selenium present in the wastewater, usually is not 

effectively nor consistently removed by settling ponds or chemical precipitation. The bioreactor 

effluent selenium concentrations at Belews Creek are substantially lower than those observed for 

Roxboro’s bioreactor effluent, presumably due to the chemical precipitation stage providing 

more effective pretreatment than achieved by the settling pond. Finally, the figures show that 

TDS is not significantly removed by the settling pond, the chemical precipitation system, or the 

biological treatment system. 
Final Detailed Study Report Chapter 4 – Flue G

Belews Creek Monitoring Data (2008) Roxboro Monitoring D

4-52 

0

500

1,0001,5002,0002,500

1-Jun 21-Jun 11-Jul 31-Jul 20-Aug 9-Sep 29-Sep 19-Oct

As (ug/L) 

Purge Chem Precip Bio

0

1,0002,0003,0004,0005,0006,000

22-Feb 12-Apr 1-Jun 21-Jul 9-

As (ug/L) 

Purge Settling Pond Bio

Figure 4-12A. Concentration of Arsenic in FGD Scrubber Purge 

and Effluent from Chemical Precipitation and Biological 

Treatment Systems at Belews Creek 

Figure 4-13A. Concentration of Arsen

and Effluent from Settling Pond an

Systems at Roxb

02468

10121416

1-Jun 21-Jun 11-Jul 31-Jul 20-Aug 9-Sep 29-Sep 19-Oct

As (ug/L) 

Chem Precip Bio

0

50

100150200250

22-Feb 12-Apr 1-Jun 21-Jul 9-S

As (ug/L) 

Settling Pond Bio

Figure 4-12B. Concentration of Arsenic in Effluent from 

Chemical Precipitation and Biological Treatment Systems at 

Belews Creek 

Figure 4-13B. Concentration of Arseni

Pond and Biological Treatment 
Final Detailed Study Report Chapter 4 – Flue G

Belews Creek Monitoring Data (2008) Roxboro Monitoring D

4-53 

0

50

100150200250300350400

1-Jun 21-Jun 11-Jul 31-Jul 20-Aug 9-Sep 29-Sep 19-Oct

Hg (ug/L) 

Purge Chem Precip Bio

0

100200300400500600700800900

1,000

22-Feb 12-Apr 1-Jun 21-Jul 9-S

Hg (ug/L) 

Purge Settling Pond Bio

Figure 4-12C. Concentration of Mercury in FGD Scrubber 

Purge and Effluent from Chemical Precipitation and Biological 

Treatment Systems at Belews Creek 

Figure 4-13C. Concentration of Me

Purge and Effluent from Settling 

Treatment Systems at 

0.000.100.200.300.400.500.60

1-Jun 21-Jun 11-Jul 31-Jul 20-Aug 9-Sep 29-Sep 19-Oct

Hg (ug/L) 

Chem Precip Bio

012345678

Hg (ug/L) 

22-Feb 12-Apr 1-Jun 21-Jul 9-Sep 

Settling Pond Bio

Figure 4-12D. Concentration of Mercury in Effluent from 

Chemical Precipitation and Biological Treatment Systems at 

Belews Creek 

Figure 4-13D. Concentration of Me

Settling Pond and Biological Treatm
Final Detailed Study Report Chapter 4 – Flue G

Belews Creek Monitoring Data (2008) Roxboro Monitoring D

4-54 

0

2,0004,0006,0008,000

10,00012,00014,00016,000

1-Jun 21-Jun 11-Jul 31-Jul 20-Aug 9-Sep 29-Sep 19-Oct

Se (ug/L) 

Purge Chem Precip Bio

0

5,000

10,00015,00020,00025,000

22-Feb 12-Apr 1-Jun 21-Jul 9-S

Se (ug/L

Purge Settling Pond Bio

)

Figure 4-12E. Concentration of Selenium in FGD Scrubber 

Purge and Effluent from Chemical Precipitation and Biological 

Treatment Systems at Belews Creek 

Figure 4-13E. Concentration of Sele

Purge and Effluent from Settling 

Treatment Systems at 

0

50

100150200250300350

1-Jun 21-Jun 11-Jul 31-Jul 20-Aug 9-Sep 29-Sep 19-Oct

Se (ug/L) 

Chem Precip Bio

0

500

1,0001,5002,0002,5003,000

Se (ug/L

22-Feb 12-Apr 1-Jun 21-Jul 9-Se

)

Settling Pond Bio

Figure 4-12F. Concentration of Selenium in Effluent from 

Chemical Precipitation and Biological Treatment Systems at 

Belews Creek 

Figure 4-13F. Concentration of Sel

Settling Pond and Biological Treatm
0

2,000,0004,000,0006,000,0008,000,000

10,000,00012,000,00014,000,00016,000,00018,000,000

22-Feb 12-Apr 1-Jun 21-Jul 9-

TDS (ug/L) 

Final Detailed Study Report Chapter 4 – Flue G

4-55 

Belews Creek Monitoring Data (2008) Roxboro Monitoring D

0

5,000,000

10,000,00015,000,00020,000,00025,000,00030,000,000

1-Jun 21-Jun 11-Jul 31-Jul 20-Aug 9-Sep 29-Sep 19-Oct

TDS (ug/L) 

Purge Chem Precip Bio

Figure 4-12G. Concentration of TDS in FGD Scrubber Purge 

and Effluent from Chemical Precipitation and Biological 

Treatment Systems at Belews Creek 

Figure 4-13G. Concentration of TDS 

and Effluent from Settling Pond an

Systems at Roxb

Purge Settling Pond Bio
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Table 4-8 presents the pollutant concentrations associated with the effluent from the FGD 

wastewater treatment systems for the plants that EPA sampled. For comparison, refer to Table 

4-5 in Section 4.3 for the pollutant concentrations representing the influent to the FGD 

wastewater treatment systems for these plants. Three of these plants operate chemical 

precipitation systems (Big Bend, Homer City, and Mitchell), and one of these plants operates 

both chemical precipitation and biological treatment stages (Belews Creek). The Widows Creek 

plant operates only a settling pond system. 

The Widows Creek FGD wastewater treatment system is a pond system that consisted of 

three settling ponds at the time of sampling; however, during the two site visits prior to the 

sampling episode, the plant was operating four settling ponds. The FGD scrubber blowdown is 

pumped to the inlet channels of the pond system, which direct the wastewater to the first FGD 

settling pond. The overflow from the first FGD settling pond is transferred to a second FGD 

settling pond and then to a final FGD settling pond. The overflow from the final settling pond is 

then discharged from the plant. EPA collected a grab sample of the effluent from the third 

settling pond. [ERG, 2008o]. 

The Big Bend FGD wastewater treatment system consists of an equalization tank 

followed by a chemical precipitation system to reduce dissolved metals using lime for hydroxide 

precipitation and ferric chloride for coagulation and iron co-precipitation. The plant then adds a 

flocculating polymer to the wastewater and transfers it to a clarifier to remove the solids. The 

overflow from the clarifiers is filtered using sand gravity filters, transferred to a final holding 

tank, and then discharged. EPA collected a grab sample of the effluent downstream of the final 

holding tank. [ERG, 2008n]. 

The Homer City FGD wastewater treatment system consists of an equalization tank 

followed by a chemical precipitation system to reduce dissolved metals using lime for hydroxide 

precipitation, ferric chloride for coagulation and iron co-precipitation, and a clarifier for solids 

removal. The FGD wastewater is sent through a first stage of lime and ferric chloride 

precipitation followed by a clarifier, and the wastewater is then treated in a second stage of lime 

and ferric chloride precipitation followed by a clarifier. After the second clarifier, the wastewater 

is transferred to an aerobic biological treatment system designed to remove BOD. After the 

aerobic biological system, the wastewater is filtered, transferred to a final holding tank, and 

discharged. EPA collected a grab sample of the effluent directly from the final holding tank. 

[ERG, 2008l]. 

The Mitchell FGD wastewater treatment system consists of a chemical precipitation 

system to reduce dissolved metals using lime for hydroxide precipitation followed by a clarifier 

for solids removal. The overflow from the clarifier is transferred to an equalization tank, where 

treated effluent is recycled by the plant when the system is not discharging. After the 

equalization tank, the plant uses ferric chloride for iron co-precipitation and then adds an anionic 

polymer and transfers the wastewater to a second clarifier. The overflow from the second 

clarifier is transferred to a final holding tank and either transferred to the bottom ash pond and 

eventually discharged or recycled back to the equalization tank. EPA collected a grab sample of 

the effluent from the discharge line of the final holding tank. [ERG, 2008m]. 

4-56 
Final Detailed Study Report Chapter 4 – Flue G

Table 4-8. Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment S

Settling Pond Chemical Precipitation

Analyte Method Unit

Widows Creek – 

Effluent from FGD 

Pond System a, b Big Bend a, b Homer a, b Mitchell a, b Belews 

Routine Total Metals – 200.7Aluminum 200.7 μg/L 111 ND (50.0) ND (50.0) ND (50.0) ND (5Antimony 200.7 μg/L ND (20.0) 22.1 R <20.8 ND (20.0) ND (4Arsenic 200.7 μg/L 49.5 ND (10.0) ND (10.0) <10.3 ND (2Barium 200.7 μg/L 179 1,490 71.3 R 433 326 Beryllium 200.7 μg/L ND (5.00) ND (5.00) 7.68 ND (5.00) ND (1Boron 200.7 μg/L 31,500 369,000 191,000 208,000 291,0Cadmium 200.7 μg/L ND (5.00) 24.9 ND (5.00) ND (5.00) ND (0.Calcium 200.7 μg/L 987,000 4,420,000 2,000,000 2,380,000 5,670,Chromium 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) ND (10.0) 25.Cobalt 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) ND (50.0) ND (2Copper 200.7 μg/L ND (10.0) <10.3 12.5 16.2 ND (2Iron 200.7 μg/L ND (100) ND (100) <117 318 ND (2Lead 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) ND (50.0) ND (1Magnesium 200.7 μg/L 189,000 2,510,000 2,610,000 1,280,000 983,0Manganese 200.7 μg/L 623 60.1 30,100 4,440 3,28Mercury 245.1 μg/L ND (2.00) ND (10.0) ND (10.0) ND (10.0) NA Molybdenum 200.7 μg/L 1,500 450 R 37.6 22.9 NA Nickel 200.7 μg/L ND (50.0) 221 ND (50.0) ND (50.0) 21.Selenium 200.7 μg/L 236 2,910 R 771 83.6 R 82.Silver 200.7 μg/L ND (20.0) ND (20.0) ND (20.0) ND (20.0) 7.9Sodium 200.7 μg/L 69,500 1,590,000 1,280,000 305,000 60,3Thallium 200.7 μg/L ND (10.0) 16.8 ND (10.0) ND (10.0) 62.Titanium 200.7 μg/L ND (10.0) 13.5 ND (10.0) <10.1 NA Vanadium 200.7 μg/L 42.1 ND (20.0) ND (20.0) ND (20.0) 2.1Yttrium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) ND (5.00) NA Zinc 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) 25.4 ND (2

4-57 
Final Detailed Study Report Chapter 4 – Flue G

Table 4-8. Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment S

Settling Pond Chemical Precipitation

Analyte Method Unit

Widows Creek – 

Effluent from FGD 

Pond System a, b Big Bend a, b Homer a, b Mitchell a, b Belews 

Routine Dissolved Metals – 200.7Aluminum 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) ND (50.0) 97.Antimony 200.7 μg/L ND (20.0) 20.8 T ND (20.0) ND (20.0) 4.5Arsenic 200.7 μg/L 46.7 10.8 R,T ND (10.0) ND (10.0) 6.4Barium 200.7 μg/L 191 1,410 70.6 R,T 389 270 Beryllium 200.7 μg/L ND (5.00) ND (5.00) 7.71 ND (5.00) ND (1Boron 200.7 μg/L 29,200 397,000 184,000 199,000 306,0Cadmium 200.7 μg/L ND (5.00) 19.3 ND (5.00) ND (5.00) 2.3Calcium 200.7 μg/L 932,000 5,210,000 1,930,000 2,270,000 5,790,Chromium 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) ND (10.0) ND (0.Hexavalent Chromium D1687-92 μg/L ND (2.00) ND (2.00) ND (2.00) 11.0 1.5Cobalt 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) ND (50.0) ND (2Copper 200.7 μg/L ND (10.0) ND (10.0) 11.8 14.1 ND (2Iron 200.7 μg/L ND (100) ND (100) 166 R ND (100) ND (2Lead 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) ND (50.0) ND (1Magnesium 200.7 μg/L 184,000 2,930,000 2,510,000 1,220,000 970,0Manganese 200.7 μg/L 543 R 55.6 29,100 4,120 3,24Mercury 245.1 μg/L ND (2.00) ND (10.0) ND (10.0) ND (10.0) NA Molybdenum 200.7 μg/L 1,470 430 T 35.8 21.4 NA Nickel 200.7 μg/L ND (50.0) 210 ND (50.0) ND (50.0) 28.Selenium 200.7 μg/L 226 2,860 R 741 R 71.7 58.Silver 200.7 μg/L ND (20.0) ND (20.0) ND (20.0) ND (20.0) 7.7Sodium 200.7 μg/L 66,200 1,880,000 1,230,000 300,000 59,3Thallium 200.7 μg/L ND (10.0) 12.5 ND (10.0) ND (10.0) 105 Titanium 200.7 μg/L ND (10.0) 13.7 ND (10.0) ND (10.0) NA Vanadium 200.7 μg/L 40.0 ND (20.0) ND (20.0) ND (20.0) 2.5Yttrium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) ND (5.00) NA Zinc 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) ND (10.0) ND (2

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Final Detailed Study Report Chapter 4 – Flue G

Table 4-8. Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment S

Settling Pond Chemical Precipitation

Analyte Method Unit

Widows Creek – 

Effluent from FGD 

Pond System a, b Big Bend a, b Homer a, b Mitchell a, b Belews 

Routine Total Metals – 200.8Aluminum 200.8 μg/L NA NA NA NA 61.Antimony 200.8 μg/L NA NA NA NA 3.6Arsenic 200.8 μg/L NA NA NA NA 200 Arsenic 200.8 – DRC μg/L NA NA NA NA 6.9Barium 200.8 μg/L NA NA NA NA 465 Beryllium 200.8 μg/L NA NA NA NA ND (0.Boron 200.8 μg/L NA NA NA NA 260,0Cadmium 200.8 μg/L NA NA NA NA 1.7Calcium 200.8 μg/L NA NA NA NA 4,920,Chromium 200.8 μg/L NA NA NA NA 13.Chromium 200.8 – DRC μg/L NA NA NA NA 0.85Cobalt 200.8 μg/L NA NA NA NA 17.Copper 200.8 μg/L NA NA NA NA 2.1Iron 200.8 μg/L NA NA NA NA 173 Iron 200.8 – DRC μg/L NA NA NA NA ND (5Lead 200.8 μg/L NA NA NA NA ND (0.Magnesium 200.8 μg/L NA NA NA NA 973,0Manganese 200.8 μg/L NA NA NA NA 3,11Manganese 200.8 – DRC μg/L NA NA NA NA 3,33Nickel 200.8 μg/L NA NA NA NA 159 Nickel 200.8 – DRC μg/L NA NA NA NA 72.Selenium 200.8 μg/L NA NA NA NA 1,12Selenium 200.8 – DRC μg/L NA NA NA NA 313 Sodium 200.8 μg/L NA NA NA NA 48,2Thallium 200.8 μg/L NA NA NA NA 7.0Vanadium 200.8 μg/L NA NA NA NA 113 Vanadium 200.8 – DRC μg/L NA NA NA NA 3.6

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Final Detailed Study Report Chapter 4 – Flue G

Table 4-8. Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment S

Settling Pond Chemical Precipitation

Analyte Method Unit

Widows Creek – 

Effluent from FGD 

Pond System a, b Big Bend a, b Homer a, b Mitchell a, b Belews 

Zinc 200.8 μg/L NA NA NA NA 5.8Zinc 200.8 – DRC μg/L NA NA NA NA ND (2Routine Dissolved Metals – 200.8Aluminum 200.8 μg/L NA NA NA NA 51.Antimony 200.8 μg/L NA NA NA NA 3.6Arsenic 200.8 μg/L NA NA NA NA 194 Arsenic 200.8 – DRC μg/L NA NA NA NA 8.1Barium 200.8 μg/L NA NA NA NA 457 Beryllium 200.8 μg/L NA NA NA NA ND (0.Boron 200.8 μg/L NA NA NA NA 261,0Cadmium 200.8 μg/L NA NA NA NA 1.6Calcium 200.8 μg/L NA NA NA NA 5,050,Chromium 200.8 μg/L NA NA NA NA 13.Chromium 200.8 – DRC μg/L NA NA NA NA 0.77Cobalt 200.8 μg/L NA NA NA NA 17.Copper 200.8 μg/L NA NA NA NA 2.2Iron 200.8 μg/L NA NA NA NA 15Iron 200.8 – DRC μg/L NA NA NA NA ND (5Lead 200.8 μg/L NA NA NA NA ND (0.Magnesium 200.8 μg/L NA NA NA NA 1,010,Manganese 200.8 μg/L NA NA NA NA 3,08Manganese 200.8 – DRC μg/L NA NA NA NA 3,14Nickel 200.8 μg/L NA NA NA NA 158 Nickel 200.8 – DRC μg/L NA NA NA NA 74.Selenium 200.8 μg/L NA NA NA NA 1,11Selenium 200.8 – DRC μg/L NA NA NA NA 28Sodium 200.8 μg/L NA NA NA NA 48,7Thallium 200.8 μg/L NA NA NA NA 7.0

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Final Detailed Study Report Chapter 4 – Flue G

Table 4-8. Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment S

Settling Pond Chemical Precipitation

Analyte Method Unit

Widows Creek – 

Effluent from FGD 

Pond System a, b Big Bend a, b Homer a, b Mitchell a, b Belews 

Vanadium 200.8 μg/L NA NA NA NA 13Vanadium 200.8 – DRC μg/L NA NA NA NA 4.6Zinc 200.8 μg/L NA NA NA NA 6.2Zinc 200.8 – DRC μg/L NA NA NA NA ND (2Low-Level Total Metals - 1631E, 1638, HG-AFSAntimony 1638 μg/L 11.8 14.2 ND (0.400) <1.37 3.7Arsenic 1638 μg/L 47.6 68.0 23.0 <25.2 197 Arsenic 1638 – DRC μg/L NA NA NA NA 4.8Arsenic HG-AFS μg/L NA NA NA NA 2.2Cadmium 1638 μg/L 3.73 25.8 ND (2.00) ND (3.00) 1.5Chromium 1638 μg/L ND (16.0) ND (80.0) ND (16.0) ND (120) 6.0Chromium 1638 – DRC μg/L NA NA NA NA 0.61Copper 1638 μg/L ND (4.00) ND (20.0) 9.67 ND (30.0) 2.1Lead 1638 μg/L ND (1.00) ND (5.00) ND (1.00) ND (1.50) ND (0.Mercury 1631E μg/L 0.0438 0.156 0.117 0.788 0.07Nickel 1638 μg/L 36.2 381 92.1 <155 113 Nickel 1638 – DRC μg/L NA NA NA NA 54.Selenium 1638 μg/L 208 2,500 613 431 T 616 Selenium 1638 – DRC μg/L NA NA NA NA 300 Selenium HG-AFS μg/L NA NA NA NA 139 Thallium 1638 μg/L 11.1 31.1 16.0 3.96 8.4Zinc 1638 μg/L ND (10.0) ND (50.0) 15.2 <83.5 6.2Zinc 1638 – DRC μg/L NA NA NA NA ND (2Low-Level Dissolved Metals - 1631E, 1636, 1638, HG-AFSAntimony 1638 μg/L 11.9 13.7 ND (0.400) 1.64 3.7Arsenic 1638 μg/L 46.5 72.4 22.5 20.9 T 196 Arsenic 1638 – DRC μg/L NA NA NA NA 5.7Arsenic HG-AFS μg/L NA NA NA NA 2.1

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Final Detailed Study Report Chapter 4 – Flue G

Table 4-8. Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment S

Settling Pond Chemical Precipitation

Analyte Method Unit

Widows Creek – 

Effluent from FGD 

Pond System a, b Big Bend a, b Homer a, b Mitchell a, b Belews 

Cadmium 1638 μg/L 3.74 22.2 ND (2.00) ND (1.00) 1.5Chromium 1638 μg/L ND (16.0) ND (80.0) ND (16.0) ND (80.0) 6.2Chromium 1638 – DRC μg/L NA NA NA NA 0.70Hexavalent Chromium 1636 μg/L 3.20 ND (5.00) ND (2.50) ND (2.50) ND (0.Copper 1638 μg/L ND (4.00) ND (20.0) 9.39 ND (20.0) 1.5Lead 1638 μg/L ND (1.00) ND (5.00) ND (1.00) ND (0.500) ND (0.Mercury 1631E μg/L 0.0107 0.0688 0.0542 0.159 0.008Nickel 1638 μg/L 33.3 L 396 93.5 102 84.Nickel 1638 – DRC μg/L NA NA NA NA 43.Selenium 1638 μg/L 293 2,560 620 407 65Selenium 1638 – DRC μg/L NA NA NA NA 305 Selenium HG-AFS μg/L NA NA NA NA 137 Thallium 1638 μg/L 11.0 31.5 15.8 3.99 8.5Zinc 1638 μg/L ND (10.0) ND (50.0) 15.7 ND (50.0) 4.4Zinc 1638 – DRC μg/L NA NA NA NA ND (2ClassicalsAmmonia As Nitrogen (NH3-N) 4500-NH3F mg/L 0.220 24.1 0.295 3.49 1.8Nitrate/Nitrite (NO3-N + NO2-N) 353.2 mg/L 0.0945 NA 36.5 R 25.4 14.Total Kjeldahl Nitrogen (TKN) 4500-N,C mg/L 2.51 98.7 3.04 9.74 4.0Biochemical Oxygen Demand (BOD) 5210B mg/L <10.0 >1,720 ND (120) <7.50 ND (4Chemical Oxygen Demand (COD) mg/L NA NA NA NA 50Chloride 4500-CL-C mg/L 1,120 22,500 11,800 6,700 9,72Hexane Extractable Material (HEM) 1664A mg/L ND (5.00) 6.00 ND (5.00) 5.00 ND (5Silica Gel Treated HEM (SGT-HEM) 1664A mg/L NA ND (6.00) NA ND (4.00) ND (5Sulfate D516-90 mg/L 2,060 1,920 2,790 1,770 1,21

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Final Detailed Study Report Chapter 4 – Flue G

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Table 4-8. Pollutant Concentrations in Sampled Effluent from FGD Wastewater Treatment S

Settling Pond Chemical Precipitation

Analyte Method Unit

Widows Creek – 

Effluent from FGD 

Pond System a, b Big Bend a, b Homer a, b Mitchell a, b Belews 

Total Dissolved Solids (TDS) 2540 C mg/L 5,830 40,600 22,600 17,700 34,0Total Phosphorus 365.3 mg/L 0.0115 E 0.355 0.520 0.0745 ND (0.Total Suspended Solids (TSS) 2540 D mg/L 8.00 E 31.5 <5.50 17.5 30.

Source: [ERG, 2008l; ERG, 2008m; ERG, 2008n; ERG, 2008o; ERG, 2009q]. Note: EPA used several analytical methods to analyze for metals during the sampling program. For the purposes of sampling program, EPA designated some of the analy

some of them as “low-level.” EPA designated all of the methods that require the use of clean hands/dirty hands sample collection techniques (i.e., EPA Method 1669 sam

“low-level” methods. Note that although not required by the analytical method, EPA used clean hands/dirty hands collection techniques for all low-level and routine meta – The FGD effluent results represent the average of the FGD effluent and the duplicate of the FGD effluent analytical measurements. 

b – The concentrations presented have been rounded to three significant figures. c – The FGD chemical precipitation effluent results represent the average of the FGD chemical precipitation effluent day 1 and FGD chemical precipitation effluent day 

was collected on both days of sample collection. d – The FGD effluent results represent the average of the FGD effluent day 1, the FGD effluent day 2, and the duplicate of the FGD effluent analytical measurements, if 

collected for the analyte. Otherwise, it represents the average of the FGD effluent day 1 and the duplicate of the FGD effluent analytical measurements. 

< – Average result includes at least one nondetect value (calculation uses the report limit for nondetected results). > – Result above measurement range. E – Sample analyzed outside holding time. L – Sample result between 5x and 10x blank result. R – MS/MSD % Recovery outside method acceptance criteria. T – MS/MSD RPD outside method acceptance criteria. NA – Not analyzed. ND – Not detected (number in parenthesis is the report limit). The sampling episode reports for each of the individual plants contains additional sampling information, in

analytes measured above the detection limit, but below the reporting limit (i.e., J-values). 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

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The Belews Creek FGD wastewater treatment system consists of an equalization tank, 

chemical precipitation system, clarifier, anoxic/anaerobic biological treatment system, and 

constructed wetland23. EPA collected grab samples of the effluents from the chemical 

precipitation and biological treatment stages. [ERG, 2009q]. 

Table 4-9 through Table 4-11 summarize the monitoring data EPA collected from 

individual plants/companies representing the effluent from settling ponds, effluent from chemical 

precipitation systems, and the effluent from anoxic/anaerobic biological treatment systems, 

respectively. The tables present the number of plants that reported concentration data for the 

analyte at the given effluent point, the total number of samples at the point for all the plants, and 

the minimum and maximum concentrations. Because the data included in these tables were 

provided by individual plants and the plants may monitor different analytes, the data presented in 

each table do not necessarily contain the same list of analytes [ERG, 2009x]. 

Table 4-9. Monitoring Data: Pollutant Concentrations in Effluent from Settling Ponds 

Analyte 

Number of 

Plants 

Number of 

Samples 

Minimum 

Concentration 

Maximum 

Concentration a Units 

Total Metals 

Aluminum 1 37 ND (50) 632 μg/L 

Antimony 1 37 ND (2) 36 μg/L 

Arsenic 1 37 6.4 201 μg/L 

Barium 1 37 37.5 528 μg/L 

Beryllium 1 37 ND (0.7) 1.02 μg/L 

Boron 1 37 7,950 108,000 μg/L 

Cadmium 1 37 ND (0.5) 6.11 μg/L 

Chromium 1 37 ND (0.61) 2,110 μg/L 

Cobalt 1 37 ND (1.1) 36 μg/L 

Copper 1 37 ND (1.6) 44.4 μg/L 

Iron 1 37 ND (20) 13,000 μg/L 

Lead 1 37 ND (1.9) ND (220) μg/L 

Manganese 1 37 ND (11) 3,210 μg/L 

Mercury 1 36 ND (0.11) 7.32 μg/L 

Molybdenum 1 37 ND (0.11) 47 μg/L 

Nickel 1 37 11.5 2,190 μg/L 

Selenium 1 37 1,180 2,740 μg/L 

Silver 1 37 ND (0.2) 30 μg/L 

Thallium 1 37 ND (0.2) 102 μg/L 

Vanadium 1 37 ND (0.36) 285 μg/L 

Zinc 1 37 ND (3.8) 136 μg/L 

 

23 At the time sampling was conducted, Belews Creek was transferring the effluent from the biological treatment 

system to the constructed wetland treatment system (CWTS); however, Belews Creek plans to reroute the biological 

treatment effluent to bypass the CWTS and be transferred directly to the ash pond. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Table 4-9. Monitoring Data: Pollutant Concentrations in Effluent from Settling Ponds 

Analyte 

Number of 

Plants 

Number of 

Samples 

Minimum 

Concentration 

Maximum 

Concentration a Units 

Classicals 

COD 1 33 120 370 mg/L 

TSS 1 36 2.60 53.0 mg/L 

TDS 1 36 9,600 12,000 mg/L 

Sulfate 1 34 1,100 1,300 mg/L 

Chloride 1 36 3,600 5,300 mg/L 

Fluoride 1 36 6.30 10.0 mg/L 

Nitrate/nitrite 1 1 12.0 12.0 mg/L 

Total Kjeldahl nitrogen 1 1 1.20 1.20 mg/L 

Total Phosphorus 1 1 ND (0.050) ND (0.050) mg/L 

Source: [ERG, 2009x]. 

a – The maximum concentration presented is the maximum detected value in the data set, unless all the results in the 

data set were not detected for the analyte. 

Table 4-10. Monitoring Data: Pollutant Concentrations in Effluent from Chemical 

Precipitation Systems 

Analyte 

Number of 

Plants 

Number of 

Samples 

Minimum 

Concentration 

Maximum 

Concentration a Units 

Total Metals 

Aluminum 1 1 183 183 μg/L 

Antimony 2 8 3.7 28 μg/L 

Arsenic 5 101 1.6 310 μg/L 

Barium 1 1 1,520 1,520 μg/L 

Beryllium 3 52 ND (0.03) 0.94 μg/L 

Boron 2 7 17,000 474,000 μg/L 

Cadmium 3 18 0.07 21.9 μg/L 

Calcium 1 7 670,000 790,000 μg/L 

Chromium 4 48 0.12 69 μg/L 

Cobalt 1 1 ND (10) ND (10) μg/L 

Copper 4 50 1.3 71 μg/L 

Iron 3 16 19 6,000 μg/L 

Lead 4 47 ND (0.07) 11 μg/L 

Magnesium 2 8 ND (3,000) 9,200,000 μg/L 

Manganese 2 7 ND (10) 63,000 μg/L 

Mercury 5 275 0.0019 61 μg/L 

Molybdenum 1 1 63 63 μg/L 

Nickel 5 66 4.7 810 μg/L 

Selenium 6 398 16 18,000 μg/L 

Silver 3 17 0.02 1.64 μg/L 

Sodium 2 7 1,000,000 1,700,000 μg/L 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-66 

Table 4-10. Monitoring Data: Pollutant Concentrations in Effluent from Chemical 

Precipitation Systems 

Analyte 

Number of 

Plants 

Number of 

Samples 

Minimum 

Concentration 

Maximum 

Concentration a Units 

Thallium 1 1 ND (10) ND (10) μg/L 

Tin 1 1 ND (50) ND (50) μg/L 

Titanium 1 1 ND (50) ND (50) μg/L 

Vanadium 1 1 ND (10) ND (10) μg/L 

Zinc 4 35 1.7 15 μg/L 

Dissolved Metals 

Antimony 1 6 4 6 μg/L 

Arsenic 1 23 ND (2.4) 240 μg/L 

Beryllium 1 19 ND (0.19) 0.94 μg/L 

Boron 1 4 17,000 22,000 μg/L 

Cadmium 1 3 0.74 0.74 μg/L 

Calcium 1 5 660,000 710,000 μg/L 

Chromium 1 6 12 27 μg/L 

Copper 1 6 11 36 μg/L 

Iron 1 5 ND (32) ND (8,800) μg/L 

Lead 1 4 ND (0.6) 5.2 μg/L 

Magnesium 1 6 6,200,000 7,400,000 μg/L 

Manganese 1 6 42,000 62,000 μg/L 

Mercury 1 195 0.032 54 μg/L 

Nickel 1 6 170 810 μg/L 

Selenium 1 25 62 4,300 μg/L 

Silver 1 4 0.61 1.9 μg/L 

Sodium 1 5 1,100,000 1,300,000 μg/L 

Zinc 1 5 7.7 17 μg/L 

Classicals 

TSS 1 10 3.93 33 mg/L 

TDS 1 16 12,000 23,000 mg/L 

Sulfate 2 9 930 24,000 mg/L 

Chloride 2 21 4,700 20,500 mg/L 

Bromide 1 4 180 260 mg/L 

Fluoride 1 8 0.91 8.60 mg/L 

NH3-N 2 27 2.30 65.6 mg/L 

Total Nitrogen, as N 1 30 2.05 165 mg/L 

HEM 1 6 ND (5.00) ND (5.00) mg/L 

n-Hexane 1 29 ND (1.40) 2.70 mg/L 

Source: [ERG, 2009x]. 

a – The maximum concentration presented is the maximum detected value in the data set, unless all the results in the 

data set were not detected for the analyte. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

Table 4-11. Monitoring Data: Pollutant Concentrations in Effluent from Biological 

Treatment Systems 

Analyte 

Number of 

Plants 

Number of 

Samples 

Minimum 

Concentration 

Maximum 

Concentration a Units 

Total Metals 

Aluminum 1 37 ND (32) 602 μg/L 

Antimony 1 37 ND (2) 92 μg/L 

Arsenic 2 53 ND (10) 93 μg/L 

Barium 1 37 26.2 2,440 μg/L 

Beryllium 1 37 ND (0.7) 1.89 μg/L 

Boron 2 38 7,820 666,000 μg/L 

Cadmium 1 37 ND (0.5) 3.57 μg/L 

Chromium 1 37 ND (1) 4,020 μg/L 

Cobalt 1 37 ND (1.1) 241 μg/L 

Copper 1 37 ND (1.6) 628 μg/L 

Iron 1 37 ND (22) 23,000 μg/L 

Lead 1 37 ND (1.9) 291 μg/L 

Manganese 1 37 52 3,170 μg/L 

Mercury 2 51 ND (0.001) 0.3 μg/L 

Molybdenum 1 37 ND (2) 192 μg/L 

Nickel 2 53 ND (1.8) 3,770 μg/L 

Selenium 2 53 ND (10) 510 μg/L 

Silver 1 37 ND (0.2) 36 μg/L 

Thallium 1 37 ND (0.36) 97 μg/L 

Vanadium 1 37 ND (1) 293 μg/L 

Zinc 2 53 ND (1) 432 μg/L 

Dissolved Metals 

Selenium 1 16 ND (10) 18 μg/L 

Classicals 

COD 1 33 120 380 mg/L 

TSS 1 36 1.10 12.0 mg/L 

TDS 2 52 2,500 23,000 mg/L 

Sulfate 2 39 970 1,300 mg/L 

Chloride 1 36 3,800 5,100 mg/L 

Fluoride 1 36 5.30 11.0 mg/L 

NO3-N + NO2-N 1 1 0.056 0.056 mg/L 

TKN 1 1 2.70 2.70 mg/L 

Total Phosphorus 1 1 0.160 0.160 mg/L 

Source: [ERG, 2009x]. 

a – The maximum concentration presented is the maximum detected value in the data set, unless all the results in the 

data set were not detected for the analyte.

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4.6 FGD Pollutant Loads Estimates

As discussed in Section 4.2, wet FGD systems need to prevent the buildup of certain 

constituents (e.g., chlorides), which is often accomplished by purging a wastewater stream. 

Because of the corrosivity of chlorides, plants do not typically reuse the FGD wastewater for 

other process operations and will typically discharge the FGD purge stream. 

EPA used data collected during EPA’s sampling program, as well as self-monitoring data 

obtained from individual plants, to estimate the mass of pollutants (pollutant loads) associated 

with the FGD scrubber purge (prior to treatment) and the effluent associated with four treatment 

alternatives: settling ponds; chemical precipitation; biological treatment; and 

evaporation/crystallization. EPA estimated these loads for two model plant sizes, which are 

discussed further below. EPA then used these model plant loads to estimate industry-wide total 

pollutant loads for FGD wastewaters being discharged from the coal-fired steam electric 

industry. EPA also estimated the pollutant removals that would be achieved by the industry 

through installing or upgrading existing FGD wastewater controls. 

4.6.1 FGD Wastewater Treatment Industry Profile 

To estimate FGD wastewater loads for the entire steam electric industry, EPA developed 

an industry profile and determined the number of coal-fired power plants that currently operate 

wet or dry scrubbers (as of June 2008), and the number of plants that are planning or projected to 

install wet or dry scrubbers by 2020. 

To generate this industry profile, EPA used EIA data to identify power plants that operate 

at least one coal-fired electric generating unit. From the available information, EPA identified 

488 coal-fired power plants that are currently operating a coal-fired generating unit as well as 

three additional plants that are either planning or constructing a coal-fired generating unit. For 

each of these 491 plants, EPA then determined whether the plant currently operates a wet or dry 

scrubber (as of June 2008) and whether the plant has announced plans or is projected to install a 

scrubber by 2020. EPA additionally used information from the site visit and sampling program, 

the data request, and other publicly available information to identify the wastewater treatment 

systems that the plants operate to treat the FGD wastewater stream. If EPA did not have 

information to identify the type of FGD wastewater treatment system for the plant, EPA assumed 

that the plant operates a settling pond, which is the most commonly used FGD wastewater 

treatment system. 

As part of this industry profile and for estimating the pollutant loads, EPA also classified 

the plants into one of two model plant sizes, “small” or “large,” based on the FGD purge flow 

rate and the necessary treatment system capacity. For those plants for which purge flow rate is 

unknown, EPA classified the plants based on the total wet scrubbed capacity of the plant (i.e., the 

total capacity of the electric generating units that are wet scrubbed). 

EPA used these model plants to better estimate the loads associated with the industry, by 

grouping the plants into two different sizes instead of assuming that all plants in the industry are 

the same size. The data and methodologies used to generate the FGD wastewater treatment 

industry profile are discussed in detail in the memorandum entitled “Development of the Current 

and Future Industry Profile for the Steam Electric Detailed Study,” dated October 9, 2009 [ERG, 

2009s]. 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

For each model plant size, EPA calculated a flow rate to use in the loads calculation for 

each of the model plants. The memorandum entitled “Technology Option Loads Calculation 

Analysis for Steam Electric Detailed Study,” dated October 9, 2009 [ERG, 2009t], describes in 

detail the calculation of the model plant flow rates. 

4.6.2 Calculation of Loads 

EPA used data collected during EPA’s sampling program and monitoring data obtained 

from individual plants to calculate loads associated with the FGD wastewater discharges from 

coal-fired power plants. EPA calculated these loads to evaluate the effectiveness of the FGD 

wastewater treatment systems 

To calculate pollutant loads associated with the FGD scrubber purge, EPA calculated 

plant-specific loads to account for differences in the FGD system configurations and operating 

characteristics at the plants. EPA first calculated the scrubber purge loads on a plant basis using 

data from the four plants for which EPA had both scrubber purge concentrations and scrubber 

purge flow rate data available. After calculating the plant-specific loads for each of these plants, 

EPA calculated an average load for each pollutant and an average flow rate associated with the 

load for each pollutant. EPA then divided the average pollutant load by the average flow rate to 

calculate a weighted-average concentration for each pollutant. 

To calculate pollutant loads associated with FGD settling pond effluent, EPA used data 

representing the effluent from a settling pond treating FGD scrubber purge from all the plants for 

which EPA had available data. For some plants, EPA estimated the settling pond effluent 

concentrations based on scrubber purge concentrations obtained during EPA’s sampling 

program. The assumptions used to estimate the settling pond effluent concentrations are 

described in the memorandum entitled “Technology Option Loads Calculation Analysis for 

Steam Electric Detailed Study,” dated October 9, 2009 [ERG, 2009t]. EPA used the settling pond 

effluent concentration data from all the plants for which data were available to determine an 

average concentration for each pollutant. 

To calculate the effluent pollutant loads for the chemical precipitation and biological 

treatment technologies, EPA used effluent concentration data from plants that represent these 

treatment technologies. The effluent data from these plants were used to determine an average 

concentration for each pollutant. For the evaporation/crystallization treatment technology, EPA 

assumed the effluent pollutant loads were equal to zero. 

After calculating these average pollutant concentrations, EPA multiplied the 

concentrations by the “small” and “large” model plant flow rates to determine the individual 

pollutant loads for the FGD scrubber purge, settling pond effluent, and effluent from each of the 

treatment technologies for both a “small” and a “large” model plant. EPA then multiplied the 

loads by each pollutant’s individual toxic weighting factor (TWF) to calculate the toxic-weighted 

pound equivalent (TWPE) for each pollutant. Because the TWPE accounts for each pollutant’s 

toxicity, it allows for a relative comparison of the pollutant discharges. Finally, EPA summed the 

individual pollutant TWPE to calculate the total TWPE for the FGD scrubber purge, settling 

pond effluent, and effluent from each of the treatment technologies for each model plant size. 

Table 4-12 presents EPA’s model plant loads, in TWPE per year, for the FGD scrubber 

purge, settling pond effluent, and effluent from each of the treatment technologies. The 

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Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

4-70 

memorandum entitled “Technology Option Loads Calculation Analysis for Steam Electric 

Detailed Study,” dated October 9, 2009 [ERG, 2009t], describes the data and methodology used 

to calculate pollutant loads. 

Table 4-12. Treatment Technology Loads by Model Plant Size 

Waste Stream/Treatment System 

Small Model Plant Loads 

(TWPE/Year) 

Large Model Plant Loads 

(TWPE/Year) 

FGD Scrubber Purge (prior to treatment) 28,400 97,300 

Settling Pond 10,900 37,300 

Chemical Precipitation 6,410 22,000 

Chemical Precipitation + Biological Treatment 2,650 9,080 

Chemical Precipitation + Evaporation 0 0 

Source: [ERG, 2009t]. 

4.6.3 Industry Baseline and Treatment Technology Loads 

EPA used the FGD wastewater treatment industry profile information (see Section 4.6.1) 

and the model plant treatment technology loads (see Section 4.6.2) to estimate the FGD 

discharge loads associated with the steam electric industry. EPA calculated the loads for the 

“current” industry, based on the status of FGD operations as of June 2008, and the “future” 

industry, based on projections of FGD operations in 2020. EPA estimated the baseline loads for 

the industry by multiplying the model plant loads for each treatment scenario by the number of 

small and large plants operating that treatment system. If EPA lacked treatment information for a 

plant, EPA assumed the plant currently operates or will operate a settling pond treatment system. 

Based on information in EPA’s combined data set, 108 plants are currently operating wet 

FGD systems and EPA estimates that 77 of these plants discharge FGD wastewater. EPA also 

estimates that more than 192 plants will be operating wet FGD scrubbers by 2020 and that 158 of 

these plants will discharge FGD wastewater.24

EPA estimated the industry loads for the FGD scrubber purge, settling pond effluent, and 

the three control technologies by multiplying the model plant loads by the number of plants 

operating that treatment system. EPA then summed the resulting “small” and “large” model plant 

TWPE to determine the total TWPE for each scenario. EPA calculated the baseline loads by 

summing the total TWPE for the settling pond and three treatment technologies. 

EPA also calculated industry-level loads that would result from plants installing or 

upgrading to a particular level of treatment technology (i.e., the industry-level chemical 

precipitation loads assume that all plants operating a settling pond will install a chemical 

precipitation system and all other plants will continue operating with their current system). 

Figure 4-14 presents a comparison of the total baseline industry effluent loads to the effluent 

loads estimated for each of the different scenarios. 

 

24 As discussed in section 4.1.2, EPA’s projections for new FGD systems do not include the systems that will be 

installed at new generating units or new plants. Thus, the projections for 2020 are considered to under-estimate the 

actual number of FGD systems that will be installed. 
Final Detailed Study Report Chapter 4 – Flue Gas Desulfurization Systems 

0

1,140,000

732,000

313,000

0

2,250,000

1,450,000

618,000

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

Baseline Chemical

Precipitation

Chemical

Precipitation and

Biological

Chemical

Precipitation and

Evaporation

Treatment Scenario

FGD Effluent Discharge Loading (TWPE)

Current 2020 (Projected)

Figure 4-14. Estimated Industry-Level FGD Effluent Discharge Loadings By Treatment 

Scenario 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

5. COAL ASH HANDLING SYSTEMS

Combusting coal in steam electric boilers generates solid, noncombustible constituents of 

the coal, referred to as ash. The heavier ash particles that collect on the bottom of the boiler are 

referred to as bottom ash and may also be called slag. The finer ash particles that are light 

enough to be transferred out of the boiler with the flue gas exhaust are referred to as fly ash. 

Some of the particles that are initially carried with the flue gases collect in the economizer or air 

preheater sections of the boiler. Depending on operations at the plant, this ash may be handled 

along with either the fly ash or bottom ash. 

This chapter presents an overview of fly ash and bottom ash handling systems at coalfired power plants within the steam electric industry, with particular emphasis on the 

wastewaters generated from the process and the treatment of those wastewaters. 

5.1 Fly Ash Handling Operations

To remove the fly ash particles from the flue gas at coal-fired power plants, many plants 

operate electrostatic precipitators (ESPs). ESPs use high voltage to generate an electrical charge 

on the particles contained in the flue gas. The charged particles then collect on a metal plate with 

an opposite electric charge. Additionally, some plants may use agglomerating agents, such as 

ammonia, which help small charged ash particles form larger agglomerates that are more readily 

attracted to the charged plates, improving the removal efficiency of the ESPs. As the particles 

begin to layer on the metal plates, the plates are tapped/rapped to loosen the particles, which fall 

into collection hoppers. ESPs are the most common type of fly ash collection system used by the 

steam electric industry, and the system can achieve removals of greater than 99.9 percent 

[Babcock & Wilcox, 2005]. 

Plants may also use other particulate control technologies, such as baghouse filters. A 

baghouse system contains several compartments, each containing fabric filter bags that are 

suspended vertically in the compartment. The bags can be quite long (e.g., 40 feet) and small in 

diameter [Babcock & Wilcox, 2005]. 

The reverse air system is the baghouse configuration most commonly used by steam 

electric plants. In this system, the flue gas enters into the various compartments and is forced to 

flow into the bottom of the fabric filter bags. The flue gas passes through the fabric filter 

material, but the fly ash particulates cannot pass and are captured on the inside walls of the 

baghouses. As the baghouses collect more particulates, the layer of particulates becomes thicker 

and also helps to remove particulates from the flue gas. After a specified period of time or once 

the pressure drop in the baghouses reaches a high set point level, the plants reverse the flow in a 

compartment and send clean flue gas from the outside of the fabric filter bags to the inside, 

which dislodges the particulates. The particulates are captured in hoppers at the bottom of the 

compartment [Babcock & Wilcox, 2005]. 

Additionally, some plants use venturi-type wet scrubbers to remove fly ash and SO2

emissions. Venturi scrubbers contain a tube with flared ends and a constricted middle section. 

The flue gas enters from one of the flared ends and approaches the constricted section. The liquid 

slurry stream is added to the scrubber just prior to or at the constricted section. As the flue gas 

enters the constricted section, its pressure increases and the velocity of the gas increases, which 

causes the gas and liquid slurry to mix. The greater the pressure drop in the scrubber, the better 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

the mixing and the better the reaction rate, which increases the sulfur dioxide and particulate 

removal efficiency. However, venturi scrubbers must be operated at high pressure drops to 

remove the same level of particulates as ESPs, which results in higher operating expenses for 

venturi scrubbers compared to ESPs. The scrubber blowdown from a venturi scrubber is handled 

similarly to the FGD scrubber blowdown from other FGD operations, which are described in 

Section 4.2 [Babcock & Wilcox, 2005; U.S. EPA, 2007b]. 

After the ESP or baghouse deposits the fly ash into the hoppers, the plant can either 

handle the fly ash in a dry or wet fashion. In either system, dry fly ash is initially drawn away 

from the hoppers using a vacuum to pneumatically transport the ash. Plants that operate a dry fly 

ash handling system pneumatically transfer the fly ash from the hoppers to fly ash storage silos. 

From the silos, the fly ash is loaded into trucks or rail cars and either hauled to a landfill for 

disposal or hauled off site for beneficial use. 

Plants operating a wet fly ash handling system also use vacuum to draw the fly ash away 

from the hoppers, but this vacuum will typically be created by water flowing through an eductor. 

These water jet eductors, also known as venture eductors, use the kinetic energy of the water to 

create the vacuum for the dry portion of the ash handling system. The ash is pulled to a 

separator/transfer tank, where it combines with the water flowing through the sluice pipes and is 

transported to the ash pond. Plants usually have a sluice stream for each individual ESP or set of 

hoppers, with the sluice water flowing continuously to maintain the necessary vacuum and 

prevent solids from settling in the piping. 

EPA compiled information regarding management techniques for fly ash and wastewater 

treatment systems for fly ash transport water. Table 5-1 presents fly ash handling practices at 

plants included in EPA’s combined data set, which includes UWAG-provided data, site visits 

and sampling data, and data request information. Approximately one-third of these plants handle 

the majority of their fly ash wet. In addition to the combined data set, EPA identified 46 

additional plants that operate wet fly ash handling systems through application data reported to 

the NPDES permit program (also known as Form 2C data) [UWAG, 2008]. However, EPA was 

unable to determine the number of generating units and capacity associated with these wet fly 

ash handling operations; therefore, these plants are not included in Table 5-1. Nevertheless, these 

data suggest that at least 80 plants are operating wet fly ash handling systems (34 plants in 

combined data set plus 46 additional plants in the Form 2C database). 

EPA also reviewed data recently collected by EPA’s Office of Solid Waste and 

Emergency Response (OSWER), which sent letters to power plants requiring that they report 

certain information about waste management units used for the storage or disposal of coal 

combustion residues. The OSWER database identifies 188 plants that are operating 398 surface 

impoundments containing fly ash. Sixty-four of these ponds contain only fly ash; the remainder 

also contain bottom ash (212 ponds), FGD wastes (14 ponds), or both (108 ponds) [Schroeder, 

2009]. 

More plants in the combined data set operate wet bottom ash handling systems than wet 

fly ash handling systems. Fewer wet fly ash systems are expected because the NSPS 

promulgated in 1982 prohibit the discharge of wastewater pollutants from fly ash transport water. 

Not surprisingly, EPA has found that the steam electric units generating wet fly ash transport 

water tend to be older units, while dry ash handling systems tend to be operated on newer units. 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

EPA identified several plants that have installed dry fly ash handling systems, either to 

replace the pre-existing wet handling system or to operate as a parallel system. The reasons for 

installing the dry handling systems include environmental remediation (i.e., discharges from the 

fly ash ponds caused environmental impacts), economic opportunity (e.g., revenues from sale of 

fly ash), and the need to replace ash ponds approaching full storage capacity. Because dry fly ash 

handling practices do not generate wastewater streams, converting to a dry system eliminates the 

discharge of fly ash transport water and the pollutants typically present in the wastewater (e.g., 

arsenic, mercury, and selenium). In addition, it reduces the amount of water used by the plant 

and eliminates the need for the fly ash pond. 

Table 5-1. Fly Ash Handling Practices at Plants Included in EPA’s Combined Data Set 

Fly Ash Handling Number of Plants a

Number of Electric 

Generating Units b 

Capacity c 

(MW) 

Wet-Sluiced 34 (35%) 95 (40%) 38,300 (33%) 

Handled Dry or Removed in Scrubber 63 (65%) 128 (54%) 73,600 (63%) 

Other – Most Ash Handled Dry or Unknown 7 (7%) 14 (6%) 4,950 (4%) 

Total 97 237 117,000 

Source: Combined Data Set (defined in Chapter 4). 

a – Number of plants is not additive because some plants operate units with different types of fly ash handling 

practices. 

b – The number of electric generating units in the table represents the number of boilers, not the number of 

turbines/generating units associated with fly ash handling systems. The number of boilers does not necessarily 

correspond to the same number of turbines.

c – Due to rounding, the total capacity may not equal the sum of the individual capacities. The capacities for the 

UWAG-provided data, data request information, and site visit and sampling information are based on information 

provided to EPA and may represent various capacities (e.g., nameplate capacity, net summer capacity, gross winter 

capacity, etc.). 

5.2 Bottom Ash Handling Operations

As discussed previously, the combustion of coal produces heavy bottom ash particulates 

that are collected in the bottom of the boiler. In a typical boiler, the lower portion of the boiler 

slopes inward from the front and rear walls of the boiler, leaving a three- to four-foot opening 

that runs the width of the bottom of the boiler. These sloped walls and opening allow the bottom 

ash to feed by gravity to the bottom ash hoppers that are positioned below the boiler. The bottom 

ash hoppers are connected directly to the boiler bottom to prevent any boiler gases from leaving 

the boiler. The hoppers have sloped side walls as well, except the hoppers’ left and right walls 

slope downward, which allows the hoppers to have a single exit point. Depending on the size of 

the boiler, there may be more than one bottom ash hopper running along the opening of the 

bottom of the boiler. Most bottom ash hoppers are filled with water to quench the hot bottom ash 

as it enters the hopper [Babcock & Wilcox, 2005]. 

Once the bottom ash hoppers have filled with bottom ash, a gate at the bottom of the 

hopper opens and the ash is directed to grinders to reduce the bottom ash into smaller pieces. 

After the bottom ash hoppers below the boiler have been emptied, the gate at the bottom of the 

hoppers closes and the hoppers again fill with water. The bottom ash hoppers are typically sized 

to accommodate approximately eight hours of bottom ash generation; therefore, the bottom ash is 

sluiced about two to four times a day. The frequency of bottom ash sluicing depends upon the 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

hopper size and the operation of the boiler. The duration of the bottom ash sluicing depends upon 

the number and size of hoppers and the bottom ash transport water flow rate. From EPA’s site 

visit experiences, the bottom ash sluicing duration is generally between 30 minutes to one hour 

for each unit [Babcock & Wilcox, 2005]. 

After the bottom ash has been ground, the ash is sluiced with water and pumped either to 

a pond or a dewatering bin. Some plants operate large settling ponds for bottom ash, while others 

use a system of relatively small ponds operating in series and/or parallel. 

Because the bottom ash particles are heavier than the fly ash particles, they are more 

easily separated from the sluice water than the fly ash particles. A dewatering bin system is a 

tank-based settling operation that is used to separate the bottom ash solids from the transport 

water. A dewatering bin system generally consists of at least two bins because while one bin is 

receiving bottom ash, the other bin is decanting the water from the collected bottom ash material. 

The dewatering bins are cylindrical in shape and have a gate at the bottom of the bin for 

removing the bottom ash [Babcock & Wilcox, 2005]. 

The bottom ash transport water is fed to the center of the bin and contacts a bar screen 

classifier that allows the finer particulates to fall down to the center of the bin while the coarser 

particulates are forced to the outside walls of the bin. As the dewatering bins are receiving 

bottom ash, they fill with the bottom ash transport water. The particulates are contained at the 

bottom of the bin, while the water rises to the top of the bin. At the top of the bin, an underflow 

baffle prevents finer particulates from floating out of the bin with the overflow. Excess water in 

the bin flows over a serrated overflow weir and leaves the dewatering bin. This overflow water 

can either be reused directly as bottom ash transport water, sent to an ash pond for additional 

settling, or discharged directly to surface water [Babcock & Wilcox, 2005]. 

As the dewatering bin continues to receive bottom ash transport water, the bin eventually 

reaches its solids loading capacity, at which time the operator will direct the bottom ash transport 

water to another dewatering bin and will begin the decanting process in the first bin. As the water 

is being decanted, the coarser particulates at the outside of the bin act as a filter to prevent the 

finer particulates at the center of the bin from leaving the bin. After the water has been drained 

from the system, the gate at the bottom of the bin is opened and the bottom ash is removed, 

usually by loading trucks that drive under the bin structure [Babcock & Wilcox, 2005]. 

Most plants operate with a wet bottom ash handling system, as described above; 

however, some plants operate a dry bottom ash handling system. As seen in Table 5-2, 13 

percent of the plants in EPA’s combined data set handle at least a portion of their bottom ash dry. 

The dry bottom ash handling systems that EPA observed during the site visit program operated a 

drag chain system. In the drag chain system, the bottom ash is collected in a water bath trough at 

the bottom of the boiler to cool the ash. The plant operates a drag chain that moves along the 

bottom of the trough and drags the bottom ash out of the boiler. At the end of the trough, the drag 

chain reaches an incline, which dewaters the bottom ash by gravity, draining the water back to 

the trough as the ash moves upward. The bottom ash is often conveyed to a nearby collection 

area, such as a small bunker outside the boiler building, from which it is loaded onto trucks and 

either sold for beneficial use or stored on-site in a landfill. 

Most of the plants in EPA’s combined data set (88 percent; 85 plants) operate wet 

handling systems for bottom ash. EPA also reviewed the OSWER data recently collected for 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

waste management units at coal-fired power plants. The OSWER data identifies 211 plants 

operating a total of 417 surface impoundments containing bottom ash. Ninety-one of these ponds 

contain only bottom ash; the remainder also contain fly ash (212 ponds), FGD wastes (6 ponds), 

or both (108 ponds). The OSWER database likely does not identify plants using wet handling 

systems that employ dewatering bins, unless the decant from the bins is sent to a pond 

[Schroeder, 2009]. 

Table 5-2. Bottom Ash Handling Practices at Plants Included in EPA’s Combined Data 

Set 

Bottom Ash Handling Number of Plants a

Number of Electric 

Generating Units b 

Capacity c 

(MW) 

Wet-Sluiced 85 (88%) 214 (90%) 106,000 (91%) 

Handled Dry 13 (13%) 22 (9%) 10,200 (9%) 

Unknown 1 (1%) 2 (1%) 600 (<1%) 

Total 97 238 117,000 

Source: Combined Data Set (defined in Chapter 4). 

a – Number of plants is not additive because some plants operate units with different types of bottom ash handling 

practices. 

b – The number of electric generating units in the table represents the number of boilers, not the number of 

turbines/generating units associated with fly ash handling systems. The number of boilers does not necessarily 

correspond to the same number of turbines. 

c – Due to rounding, the total capacity may not equal the sum of the individual capacities. The capacities for the 

UWAG-provided data, data request information, and site visit and sampling information are based on information 

provided to EPA and may represent various capacities (e.g., nameplate capacity, net summer capacity, gross winter 

capacity, etc.). 

5.3 Ash Transport Water Characteristics

Fly ash transport water is one of the larger volume flows for coal-fired power plants. 

Table 5-3 presents the fly ash transport water flow rates reported in the data request responses. 

The flow rates that are normalized on a MW basis are based on the plant’s total coal-fired 

capacity. The average coal-fired capacity for the plants in the data set is 1,210 MW and the 

median coal-fired capacity per plant is 1,140 MW. 

Sluice flow rates are not the same as pond overflow rates. Ash ponds typically receive 

other waste streams in addition to bottom ash and fly ash. Factors acting to reduce the pond 

overflow rate include pond losses from infiltration through the bottom of the pond or retaining 

dikes, evaporation, and whether the water held in the ash pond is recycled back to the plant for 

reuse. The average fly ash pond overflow flow rates collected during the development of the 

1982 effluent guidelines are 2,610,000 gpd/plant and 3,810 gpd/MW [U.S. EPA, 1982]. 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

Table 5-3. Fly Ash Transport Water Flow Rates 

Number of 

Plants Average Flow Rate a Median Flow Rate a Range of Flow Rate a 

Flow Rate per Plant 

gpm/plant b 17 5,890 3,000 188 - 27,500 

gpd/plant d 17 7,640,000 4,030,000 270,000 - 39,600,000 

gpy/plant d 17 2,710,000,000 1,470,000,000 6,480,000 - 

14,500,000,000 

Normalized Flow Rate based on Total Coal-Fired Capacity 

gpm/Coal-Fired MW b, c 17 4.59 4.08 0.291 - 9.38 

gpd/Coal-Fired MW c, d 17 5,830 5,140 419 - 11,900 

gpy/Coal-Fired MW c, d 17 2,090,000 1,870,000 2,050 - 4,350,000 

Source: [U.S. EPA, 2008a]. 

a – The flow rates presented have been rounded to three significant figures. 

b – The gpm flow rate represents the flow rate during the actual sluice. 

c – For this analysis, EPA assumed that the total capacity for each coal-fired steam electric unit is associated with 

coal use. Non-coal-fired units are not included in the capacity calculations. 

d – Because the fly ash transport water flow rate is not always continuous, the gpd cannot be directly calculated 

from the gpm. Similarly, some of the fly ash transport water flows are not generated 365 days per year, so gpy 

cannot be directly calculated from gpd.

As described in Section 5.2, bottom ash transport water is an intermittent stream from 

each of the coal-fired units. The bottom ash transport water flow rates are typically not as large 

as the fly ash transport water flow rates. However, bottom ash transport water is still one of the 

larger volume flows for steam electric plants. 

Table 5-4 presents the bottom ash transport water flow rates reported in the data request 

responses. The flow rates that are normalized on a MW basis are based on the plants’ total coalfired capacity. The average coal-fired capacity per plant is 1,570 MW and the median coal-fired 

capacity per plant is 1,560 MW. 

As was noted above, sluice flow rates are not the same as pond overflow rates. The 

average bottom ash pond overflow flow rates collected during the development of the 1982 

effluent guidelines are 2,600,000 gpd/plant and 3,880 gpd/MW [U.S. EPA, 1982]. The bottom 

ash transport water flow rates presented in Table 5-4 may be lower than the bottom ash pond 

overflow flow rates collected during the 1982 effluent guideline development because the bottom 

ash pond overflow likely includes other plant wastewaters, in addition to bottom ash transport 

water. 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

Table 5-4. Bottom Ash Transport Water Flow Rates from EPA Data Request Responses 

Number of Plants a 

Average Flow 

Rate b 

Median Flow 

Rate b 

Range of Flow 

Rate b 

Flow Rate per Plant 

gpm/plant c 27 3,370 1,740 358 - 12,600 

gpd/plant d 27 3,290,000 2,380,000 253,000 - 

18,100,000 

gpy/plant d 27 1,190,000,000 810,000,000 92,400,000 - 

6,600,000,000 

Normalized Flow Rate Based on Total Coal-Fired Capacity

gpm/Coal-Fired MW c, e 27 2.21 1.18 0.479 - 9.38 

gpd/Coal-Fired MW d, e 27 1,940 1,600 222 - 7,070 

gpy/Coal-Fired MW d, e 27 701,000 585,000 81,100 - 2,580,000 

Source: [U.S. EPA, 2008a]. 

a – Twenty-nine of the 30 data request plants reported generating bottom ash transport water; however, two plants 

are excluded from this summary because they were unable to estimate the bottom ash transport water flow rates. 

b – The flow rates presented have been rounded to three significant figures. 

c – The gpm flow rate represents the flow rate during the actual sluice. 

d – Because the bottom ash transport water flow rate is not always continuous, the gpd cannot be directly calculated 

using only the gpm. Similarly, some of the bottom ash transport water flows are not generated 365 days per year, so 

gpy cannot be directly calculated from gpd.

e – For this summary, EPA assumed that the total capacity for each coal-fired steam electric unit is associated with 

coal use. Non-coal-fired units are not included in the capacity calculations. 

The pollutant concentrations in ash transport water vary from plant to plant depending on 

the coal used, the type of boiler, and the particulate control system used by the plant. In addition, 

the waste stream characteristics also vary in a cyclical fashion during the discharges. For 

example, the fly ash transport water characteristics vary depending on which of the ash hoppers 

is being sluiced. The bottom ash transport water characteristics at the beginning of the 

intermittent sluicing period are likely to be different than the characteristics at the end of the 

sluice period. Table 5-5 presents the pollutant concentrations representing the influent to the ash 

pond systems sampled during EPA’s sampling program. 

Table 5-5. Ash Pond Influent Concentrations 

Analyte Method Unit 

Widows Creek – Diked 

Channel Influent to 

Combined Ash Pond a, b 

Cardinal – Influent to 

Fly Ash Pond a 

Routine Metals – Total 

Aluminum 200.7 μg/L 94,800 320,000 

Antimony 200.7 μg/L ND (38.0) ND (81.2) 

Arsenic 200.7 μg/L 131 1,520 

Barium 200.7 μg/L 6,080 5,060 

Beryllium 200.7 μg/L 11.3 71.5 

Boron 200.7 μg/L 4,330 2,790 

Cadmium 200.7 μg/L ND (9.50) 39.6 

Calcium 200.7 μg/L 103,000 204,000 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

5-8 

Table 5-5. Ash Pond Influent Concentrations 

Analyte Method Unit 

Widows Creek – Diked 

Channel Influent to 

Combined Ash Pond a, b 

Cardinal – Influent to 

Fly Ash Pond a 

Chromium 200.7 μg/L 107 1,300 

Cobalt 200.7 μg/L ND (95.0) 381 

Copper 200.7 μg/L 188 964 

Iron 200.7 μg/L 80,700 298,000 

Lead 200.7 μg/L 208 786 

Magnesium 200.7 μg/L 25,700 35,100 

Manganese 200.7 μg/L 337 1,120 

Mercury 245.1 μg/L 2.66 2.31 

Molybdenum 200.7 μg/L 65.5 333 

Nickel 200.7 μg/L ND (95.0) 739 

Selenium 200.7 μg/L 27.5 ND (20.3) 

Sodium 200.7 μg/L 31,200 69,900 

Thallium 200.7 μg/L ND (19.0) ND (40.6) 

Titanium 200.7 μg/L 7,150 24,900 

Vanadium 200.7 μg/L 346 2,340 

Yttrium 200.7 μg/L 133 521 

Zinc 200.7 μg/L 785 1,220 

Routine Metals – Dissolved

Aluminum 200.7 μg/L 663 283 

Antimony 200.7 μg/L ND (20.0) ND (20.0) 

Arsenic 200.7 μg/L 46.0 86.8 

Barium 200.7 μg/L 178 164 

Beryllium 200.7 μg/L ND (5.00) ND (5.00) 

Boron 200.7 μg/L 2,150 1,380 

Cadmium 200.7 μg/L ND (5.00) ND (5.00) 

Calcium 200.7 μg/L 40,300 94,800 

Chromium 200.7 μg/L ND (10.0) ND (10.0) 

Hexavalent Chromium D1687-92 μg/L ND (2.00) 5.00 

Cobalt 200.7 μg/L ND (50.0) ND (50.0) 

Copper 200.7 μg/L ND (10.0) ND (10.0) 

Iron 200.7 μg/L ND (100) ND (100) 

Lead 200.7 μg/L ND (50.0) ND (50.0) 

Magnesium 200.7 μg/L 7,110 15,200 

Manganese 200.7 μg/L ND (15.0) 40.3 

Mercury 245.1 μg/L ND (0.200) ND (0.200) 

Molybdenum 200.7 μg/L 50.1 243 

Nickel 200.7 μg/L ND (50.0) ND (50.0) 

Selenium 200.7 μg/L 26.8 16.6 

Sodium 200.7 μg/L 13,400 64,400 
Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

5-9 

Table 5-5. Ash Pond Influent Concentrations 

Analyte Method Unit 

Widows Creek – Diked 

Channel Influent to 

Combined Ash Pond a, b 

Cardinal – Influent to 

Fly Ash Pond a 

Thallium 200.7 μg/L ND (10.0) ND (10.0) 

Titanium 200.7 μg/L ND (10.0) ND (10.0) 

Vanadium 200.7 μg/L 66.8 70.7 

Yttrium 200.7 μg/L ND (5.00) ND (5.00) 

Zinc 200.7 μg/L ND (10.0) ND (10.0) 

Low-Level Metals – Total 

Antimony 1638 μg/L 13.1 L 33.1 

Arsenic 1638 μg/L 88.9 519 

Cadmium 1638 μg/L ND (20.0) 9.51 

Chromium 1638 μg/L ND (160) 569 

Copper 1638 μg/L 114 719 

Lead 1638 μg/L 104 260 

Mercury 1631E μg/L 1.02 1.16 

Nickel 1638 μg/L ND (200) 291 

Selenium 1638 μg/L ND (200) ND (200) 

Thallium 1638 μg/L ND (4.00) 43.6 

Zinc 1638 μg/L 198 720 

Low-Level Metals – Dissolved

Antimony 1638 μg/L 8.54 17.4 

Arsenic 1638 μg/L 49.5 80.7 

Cadmium 1638 μg/L ND (2.00) ND (1.00) 

Chromium 1638 μg/L ND (16.0) ND (80.0) 

Hexavalent Chromium 1636 μg/L NA NA 

Copper 1638 μg/L ND (4.00) ND (20.0) 

Lead 1638 μg/L ND (1.00) ND (0.500) 

Mercury 1631E μg/L ND (0.000500) 0.000550 

Nickel 1638 μg/L ND (20.0) ND (100) 

Selenium 1638 μg/L ND (100) 21.2 

Thallium 1638 μg/L ND (0.400) 3.10 

Zinc 1638 μg/L ND (10.0) ND (50.0) 

Classicals

Ammonia As Nitrogen (NH3-

N)

4500-

NH3F

mg/L 0.400 0.170 

Nitrate/Nitrite (NO3-N + NO2-

N) 

353.2 mg/L 0.360 2.65 

Total Kjeldahl Nitrogen (TKN) 4500-N,C mg/L 7.41 1.01 

Biochemical Oxygen Demand 

(BOD)

5210B mg/L 53.0 ND (2.00) 

Chloride 4500-CL-C mg/L 21.4 56.8 
Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

5-10 

Table 5-5. Ash Pond Influent Concentrations 

Analyte Method Unit 

Widows Creek – Diked 

Channel Influent to 

Combined Ash Pond a, b 

Cardinal – Influent to 

Fly Ash Pond a 

Hexane Extractable Material 

(HEM)

1664A mg/L ND (5.00) 7.00 

Silica Gel Treated HEM (SGTHEM)1664A mg/L NA 6.00 

Sulfate D516-90 mg/L 58.1 1,110 

Total Dissolved Solids (TDS) 2540 C mg/L 224 662 

Total Phosphorus 365.3 mg/L 16.6 4.03 

Total Suspended Solids (TSS) 2540 D mg/L 9,190 E 23,400 

Source: [ERG, 2008k; ERG, 2008o]. 

Note: EPA used several analytical methods to analyze for metals during the sampling program. For the purposes of 

sampling program, EPA designated some of the analytical methods as “routine” and some of them as “low-level.” 

EPA designated all of the methods that require the use of clean hands/dirty hands sample collection techniques (i.e., 

EPA Method 1669 sample collection techniques) as “low-level” methods. Although not required by the analytical 

methods, EPA used clean hands/dirty hands collection techniques for all low-level and routine metals samples. 

a – The concentrations presented have been rounded to three significant figures. 

b – The sample collected from the diked channel influent to the combined ash pond represents only the wastewaters 

associated with six of the eight generating units. The wastewaters for the other two units enter the combined ash 

pond at a different point. 

E – Sample analyzed outside holding time.

L – Sample result between 5x and 10x blank result.

NA – Not analyzed. 

ND – Not detected (number in parenthesis is the report limit). The sampling episode reports for each of the 

individual plants contains additional sampling information, including analytical results for analytes measured above 

the detection limit, but below the reporting limit (i.e., J-values). 

For the Widows Creek sampling episode, EPA collected a 12-hour composite sample of 

the influent to the ash pond from a diked channel containing fly ash transport water, bottom ash 

transport water, and several low-volume wastewaters, including coal pile runoff overflow, boiler 

blowdown, nonchemical metal cleaning wastewater, roof and switchyard drainage, flow wash 

water, and miscellaneous cooling water. Due to the very high flow rates and solids loading of the 

influent stream and the challenge of safely collecting a representative sample, EPA collected the 

samples from the diked channel at a point downstream of the influent to the channel to allow for 

some initial solids settling, but upstream of the open water area of the ash pond. The wastewater 

contained within the diked channel represents the wastewater generated from six of the eight 

units at the plant, which represents approximately 42 percent of the plant’s generating capacity. 

The other two units also generate wastewaters that enter the ash pond; however, the wastewaters 

enter the pond at a different location. Plant personnel estimated that the flow rate entering the ash 

pond at the time of sampling for the six units was approximately 12.1 mgd. The sampling 

episode report for Widows Creek contains more detailed information regarding the sample 

collection procedures [ERG, 2008o]. 

For the Cardinal sampling episode, EPA collected a three-hour composite sample of the 

influent to the fly ash pond. The influent to the fly ash pond consisted of fly ash transport water 

and some dilution water (approximately one-third of the total influent flow). Due to the very high 

flow rates and solids loading of the influent stream and the challenge of safely collecting a 
Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

representative sample, EPA collected the sample near the influent point but was not able to 

sample the influent stream directly from the ash sluice pipes. The fly ash is collected by ESPs at 

the plant and sluiced to the fly ash pond. During the sampling episode, the plant personnel 

estimated the influent flow rate to the fly ash pond was 9.1 mgd. The sampling episode report for 

Cardinal contains more detailed information regarding the sample collection procedures [ERG, 

2008k]. 

Table 5-5 shows that the ash transport water streams contain significant concentrations of 

TSS and metals. The ash transport water metals concentrations are typically lower than those of 

the FGD wastewater (see Table 4-5 and Table 4-6), but the TSS concentration is higher. Many of 

the metals in the ash transport water stream are primarily present in the particulate phase. The 

TSS and metals concentrations present in the ash transport water are large enough that the waste 

stream typically requires some form of treatment prior to being discharged, at a minimum to 

lower the TSS concentrations to meet the 30 mg/L (30-day average) effluent guidelines limit for 

fly ash and bottom ash transport water (see Section 3.2.3 for more details). 

5.4 Ash Transport Water Treatment Systems

Fly ash transport water and bottom ash transport water are typically treated in large 

settling pond systems. For plants operating both wet fly ash and wet bottom ash handling 

systems, the two sluice streams are often commingled within the same settling pond system 

along with other waste streams. For plants operating only one wet ash handling system (e.g., fly 

or bottom ash, but typically wet bottom ash), the ash transport water may be treated in an ash 

pond, which would likely receive other plant wastewaters. The design and operation of ash 

settling ponds is comparable to that of FGD settling ponds, which is described in Section 4.4.1. 

Ash ponds are designed to remove particulates from wastewater by means of gravity. For 

this to occur, the wastewater must reside in the pond long enough for removal of the desired 

particle size. The ponds provide residence time for the fly ash, bottom ash, and other solids (e.g., 

FGD solids) to settle out of the wastewater to the bottom of the pond. Ash ponds can be an 

effective way to reduce TSS in ash transport water, particularly from bottom ash transport water, 

which contains relatively dense ash particles. Because ash ponds remove solid particulates, they 

may also be an effective means of removing some metals from fly ash transport water when 

these metals are present in particulate form. 

Surface impoundments (i.e., ash ponds and FGD ponds) can vary substantially in size, 

capacity, and age. According to a survey conducted by EPRI, pond surface areas ranged from 5 

acres to 1,500 acres, with a median of 91 acres. Disposal capacities ranged from 100,000 cubic 

yards to 63 million cubic yards, with a median of 3.4 million cubic yards. The ponds in the 

survey had been in operation for less than two years to nearly 50 years, with a median of 22 

years of operation. Some ponds were projected to continue operating beyond 2045 [EPRI, 

1997a]. 

During the summer, some ash ponds become thermally stratified. When this occurs, the 

top layer of the pond is warmer and contains higher levels of dissolved oxygen, whereas the 

bottom layer of the pond is colder and has significantly lower levels of oxygen, often being 

anoxic. Typically during fall, as the air temperature decreases, the upper layer of the pond 

becomes cooler and more dense, then sinks and causes the entire volume of the ash pond to 

circulate. Solids that have settled at the bottom of the pond could potentially become 

5-11 
Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

resuspended due to the mixing, increasing the concentrations of pollutants being discharged 

during the turnover period. In addition, anaerobic conditions at the bottom of the pond may be 

conducive to the formation of methylmercury, which could then be present in the discharge. 

Seasonal turnover effects largely depend upon the size and configuration of the ash pond. 

Smaller, and especially shallow, ponds likely do not experience turnover because they do not 

have physical characteristics that promote thermal stratification. However, some power plant 

settling ponds are large (e.g., greater than 300 acres) and deep (e.g., greater than 10 meters deep) 

and likely experience some degree of turnover [MDC, 2004; Heidorn, 2005]. 

Table 5-6 shows that 95 percent of the plants in the combined data set that handle any 

amount of fly ash wet send the fly ash transport water to settling ponds. Sixty-five percent of the 

fly ash ponds from the combined data set receive both fly ash and bottom ash. Only one of the 

fly ash ponds included in the combined data set is completely segregated (i.e., it receives only fly 

ash wastewater). 

Table 5-6. Fly Ash Transport Wastewater Treatment Systems at Plants Included in EPA’s 

Combined Data Set 

Type of Fly Ash Wastewater Treatment 

System 

Number of 

Plants 

Number of 

Electric 

Generating 

Units a 

Capacity 

(MW) b 

Number of 

Treatment 

Systems That 

Also Receive 

FGD Wastewater

Settling pond, fly ash commingled with bottom 

ash 

22 (58%) 74 (68%) 25,300 (59%) 4 

Settling pond, fly ash NOT commingled with 

bottom ash 

4 (11%) 9 (8%) 7,240 (17%) 1 

Settling pond, not known if fly ash is commingled 

with bottom ash 

10 (26%) 24 (22%) 9,690 (23%) 2 

Other (trucked away, no wastewater discharge) 2 (5%) 2 (2%) 747 (2%) 0 

Total 38 109 43,000 7 

Source: Combined Data Set (defined in Chapter 4). 

a – The number of electric generating units in the table represents the number of boilers, not the number of 

turbines/generating units associated with fly ash handling systems. The number of boilers does not necessarily 

correspond to the same number of turbines.

b – Due to rounding, the total capacity may not equal the sum of the individual capacities. The capacities for the 

UWAG-provided data, data request information, and site visit and sampling information are based on information 

provided to EPA and may represent various capacities (e.g., nameplate capacity, net summer capacity, gross winter 

capacity). 

The plants within EPA’s combined data set that operate wet bottom ash handling systems 

send their bottom ash transport water to dewatering bins, settling ponds, or both. EPA has 

observed that most bottom ash settling ponds also receive other plant wastewaters. In response to 

the data request, no plants reported operating segregated bottom ash ponds. Table 5-7 shows that 

90 percent of the plants in the combined data set that handle the bottom ash with a wet system 

transfer the bottom ash transport water to a settling pond for treatment. Only 18 percent of the 

plants are operating dewatering bins prior to the settling pond. As shown in Table 5-7, there are 

more plants that keep their bottom ash transport and fly ash transport waters segregated than not. 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

Table 5-7. Bottom Ash Transport Wastewater Treatment Systems at Plants Included in 

EPA’s Combined Data Set 

Type of Bottom Ash Wastewater 

Treatment System 

Number of 

Plants 

Number of 

Electric 

Generating 

Units 

Capacity 

(MW) 

Number of 

Treatment Systems 

That Also Receive 

FGD Wastewater 

Dewatering bins, NOT sent to settling pond 

(not known if commingled with fly ash) 

8 18 11,100 0 

Dewatering bins, overflow to settling pond 

(comingled with fly ash) 

2 6 3,300 1 

Dewatering bins, overflow to settling pond 

(not comingled with fly ash) 

14 28 17,200 3 

Dewatering bins, overflow to settling pond 

(not known if commingled with fly ash) 

1 1 176 1 

Settling pond (comingled with fly ash) 23 73 25,200 11 

Settling pond (not commingled with fly ash) 37 78 44,700 10 

Settling pond (not known if commingled 

with fly ash) 

7 14 5,270 2 

Unknown 1 2 596 0 

Total 93 220 108,000 28 

Source: Combined Data Set (defined in Chapter 4). 

a – The number of electric generating units in the table represents the number of boilers, not the number of 

turbines/generating units associated with fly ash handling systems. The number of boilers does not necessarily 

correspond to the same number of turbines.

b – Due to rounding, the total capacity may not equal the sum of the individual capacities. The capacities for the 

UWAG-provided data, data request information, and site visit and sampling information are based on information 

provided to EPA and may represent various capacities (e.g., nameplate capacity, net summer capacity, gross winter 

capacity).

For all of the fly and bottom ash ponds reported in response to the data request, waste 

streams other than ash transport water ranged from 3 to 93 percent of the total pond influent flow 

(in 2006). The major types of influent, other than ash transport water, were cooling tower 

blowdown, FGD wastewater, and various types of low-volume wastes [U.S. EPA, 2008a]. Other 

types of wastewater that may be transferred to ash ponds include coal pile runoff, transport water 

containing mill rejects (which may be pyritic), or coal washing operations (if washed on site). 

Because these wastewaters are in direct contact with the coal, they often have low pH (i.e., they 

are acidic wastewaters). According to information that EPRI collected during its PISCES 

program, coal pile runoff can have a pH as low as 1.5 S.U. EPRI determined when that metals 

entering an ash pond from the fly ash and/or bottom ash transport water come in contact with an 

acidic waste stream, such as coal pile runoff, more of the metals will become dissolved. 

Therefore, because ash ponds are not designed to treat for dissolved metals, the introduction of 

acidic waste streams to an ash pond can result in an increase in the metals concentration at the 

effluent of the ash pond [EPRI, 1997b]. 

From the 2005 EIA data, EPA identified 130 steam electric plants that dispose of their fly 

ash in a surface impoundment (i.e., ash pond). EPA also identified that 156 steam electric plants 

dispose of their bottom ash in an ash pond. EPA determined that a total of 186 plants dispose of 

either their fly ash or bottom ash in a pond. Additionally, EPA determined that all of the 186 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

5-14 

plants burn coal in at least one of the electric generating units at the plant. Within the EIA data 

set, 100 of the 488 coal-fired steam electric plants did not report any information regarding the 

disposal of the fly ash and bottom ash; therefore, from the EIA data, EPA identified that at least 

186 of the 488 coal-fired plants dispose of fly or bottom ash in a pond. 

Table 5-8 presents a summary of data recently collected by EPA’s OSWER, which sent 

letters to power plants requiring that they report certain information about waste management 

units used for the storage or disposal of coal combustion residues. The OSWER data includes 

information for 214 plants in 35 states operating a total of 537 ponds containing coal combustion 

residues (i.e., fly ash, bottom ash, boiler slag, or FGD solids)25. All but one of these plants 

operates at least one ash pond, with a total nationwide population of 213 plants operating 495 ash 

ponds. Table 5-8 presents summary statistics that identify the type of coal combustion residues 

contained in ash ponds, most of which also receive other power plant wastewaters. For 

completeness, the table also includes information OSWER collected for ponds that receive FGD 

wastes [Schroeder, 2009]. 

Table 5-8. Ponds Containing Coal Combustion Residues 

Type of CCR Contained in Pond Number of CCR Ponds 

Fly ash and bottom ash 212 

Fly ash, bottom ash, and FGD 108 

Fly ash only 64 

Bottom ash only 91 

FGD only 42 

Fly ash and FGD 14 

Bottom ash and FGD 6 

Total 537 

Source: [Schroeder, 2009]. 

As shown in Table 5-6 and Table 5-7, some plants combine the FGD wastewater in ash 

ponds. EPRI conducted settling tests to determine whether transferring FGD wastewater to an 

ash pond presents any issues with the settling pond treatment. EPRI determined that when the 

FGD wastewater was mixed with the more dilute ash pond water, the gypsum particles in the 

water dissolved and became smaller, which caused the solids to settle slower. EPRI determined 

that this mixing reduces the settling efficiency in the ash pond and therefore, may result in an 

increase in the effluent TSS concentration from the ash pond [EPRI, 2006b]. Additionally, EPRI 

reported that the FGD wastewater includes high loadings of volatile metals which can impact the 

solubility of metals in the ash pond, thereby potentially leading to increases in the effluent metal 

concentrations from the ash pond [EPRI, 2006b]. According to the OSWER data, 61 power 

plants operate a total of 128 ponds that combine FGD wastes with fly ash and/or bottom ash 

wastes. 

 

25 The OSWER database also includes information for another 47 ponds which reportedly contain no coal 

combustion residues. However, a review of the wastes contained in these additional ponds or the names given these 

ponds suggests that some of these ponds may also contain CCRs. Some of the non-CCR ponds are located at five 

plants included in the OSWER database, which reportedly do not operate any ponds containing CCR. 
Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

The design, operation, and maintenance of ash ponds in the steam electric industry vary 

by plant/company. As described above, the ash ponds are designed for TSS removal; therefore, 

the size of the pond is dependent on the flow rate of the influent waste streams, as well as the 

settling properties of the solids in the waste stream. The amount of land available to the plant is 

another factor that may determine the size of the ash pond. Ash ponds may be lined with clay or 

geosynethic liners, but many ash ponds are unlined. From EPA’s site visit program, EPA 

determined that relatively new ash ponds may have some type of liner, but older ponds are more 

likely to be unlined. EPA was unable to identify a comprehensive source of data quantifying the 

number of lined and unlined ash ponds. 

Some plants may add chemicals to the ash ponds to control the pH of the ash pond 

effluent discharge. The current effluent guidelines pH limit for discharges from steam electric 

plants is the range of 6.0 to 9.0 S.U. Common chemicals used to control the pH in ash ponds are 

sodium hydroxide and hydrochloric acid. Other plants, such as Widows Creek, inject CO2 into 

the pond, which becomes carbonic acid in the aqueous phase and therefore reduces the alkalinity 

of the pond [ERG, 2007h]. Some plants may operate additional treatment systems to control the 

ash pond discharges. For example, Kentucky Utilities’ Ghent Generating Station operates a 

filtration system that treats approximately 50 percent of the ash pond overflow prior to 

commingling it with the other 50 percent of the ash pond overflow and discharging it [ERG, 

2009g]. Polymers may also be added to the ash pond to promote coagulation/flocculation to 

enhance settling of the solids [ERG, 2009r]. 

During the site visit program, EPA observed varying ways of maintaining the ash ponds. 

Some plants constantly remove settled ash solids from the ash pond delta and stack them on the 

sides of the pond to dewater and build up the height of the pond. Alternatively, some plants 

periodically dredge the pond to remove the ash from the bottom of the pond and transfer the 

solids off site for disposal or to an on-site landfill, or use the solids to build up the height of the 

ash pond. Finally, some plants may not dredge the ash pond at all. These plants leave the ash in 

the pond permanently and, when the ash pond reaches its capacity, a new ash pond is built and 

the old pond is decommissioned. 

Table 5-9 presents the pollutant concentrations representing the effluent from ash ponds 

collected during EPA’s sampling program. Each of these pond systems treats different types of 

wastewater; therefore, the various effluents cannot be directly compared with each other. In 

addition, the influent concentrations presented in Table 5-5 for Widows Creek should not be 

directly compared with the effluent concentrations in Table 5-9 because the influent represents 

only a portion of the waste streams entering the pond system. Table 5-9 shows that the treated 

ash pond effluent wastewaters contain low concentrations of TSS and most nutrients; however, 

metals are still present in the pond effluent. Table 5-9 also shows that most of the metals present 

in the treated ash pond wastewater are predominantly in the dissolved phase. 

Homer City operates a dry fly ash handling system and a wet bottom ash handling 

system. The bottom ash transport water from Homer City is first transferred to dewatering bins, 

which remove approximately 90 to 95 percent of the solids from the wastewater. The overflow 

from the dewatering bins is transferred to the two bottom ash ponds operating in parallel. The 

overflow from the bottom ash ponds is transferred to a clearwell and then discharged or reused to 

sluice more bottom ash. EPA collected a grab sample of the effluent from the bottom ash 

treatment system at Homer City directly from the clearwell. The average flow rate discharged 

5-15 
Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

5-16 

from the clearwell during the sampling episode was 0.453 mgd. The sampling episode report for 

Homer City contains more detailed information regarding the sample collection procedures 

[ERG, 2008l]. 

Widows Creek operates a combined fly ash and bottom ash pond system. The fly ash 

from seven of the eight units (one unit uses the FGD system for particulate control, which sends 

the wastewater to a separate FGD settling pond system) and bottom ash from all eight units, as 

well as several other low-volume wastewaters enter the combined ash pond. The wastewater 

enters the ash pond at two different areas, then flows by gravity through diked channels made of 

ash until it reaches the open water portion of the main pond. The overflow from the main ash 

pond flows to a second pond where the plant injects carbon dioxide, if needed, to decrease the 

pH of the wastewater to within the range of 6.0 to 9.0 S.U. The overflow from the second pond 

enters the pumping basin, where the treated wastewater is pumped to a stub canal off the river 

where the plant draws intake water from the river. Alternatively, if the pumping basin begins to 

overflow, then the plant has an emergency overflow discharge directly to surface water. EPA 

collected a grab sample of the effluent from the combined ash pond directly from the pumping 

basin. EPA estimated that the average flow rate discharged from the pumping basin during the 

sampling episode was 29.9 mgd. The sampling episode report for Widows Creek contains more 

detailed information regarding the sample collection procedures [ERG, 2008o]. 

Mitchell operates a fly ash pond treatment system. The fly ash pond receives the fly ash 

transport water from Mitchell, fly ash transport water from a neighboring power plant, 

wastewater from a coal washing preparation plant, treated acid mine drainage wastewater, and 

stormwater runoff. The waste streams enter the fly ash pond at various locations within the pond 

and flow to the dam located at the end of the pond. The dam controls the flow from the pond into 

a channel that discharges to surface water. EPA collected a grab sample of the fly ash pond 

effluent from the channel discharging to the surface water. The average flow rate discharged 

from the fly ash pond during the sampling episode was 7.8 mgd. The sampling episode report for 

Mitchell contains more detailed information regarding the sample collection procedures [ERG, 

2008m]. 
Final Detailed Study Report Chapter 5 – C

Table 5-9. Ash Pond Effluent Concentrations 

Analyte Method Unit 

Homer City – 

Effluent from Bottom 

Ash Pond a 

Widows Creek – 

Effluent from 

Combined Ash Pond a

Mitchell – Effluent 

from Fly Ash Pond 

Routine Metals - Total Aluminum 200.7 μg/L 323 1,070 404 Antimony 200.7 μg/L ND (20.0) ND (20.0) 24.6 Arsenic 200.7 μg/L ND (10.0) 38.2 150 Barium 200.7 μg/L 101 227 133 Beryllium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) Boron 200.7 μg/L 396 2,210 2,350 Cadmium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) Calcium 200.7 μg/L 186,000 58,500 115,000 Chromium 200.7 μg/L ND (10.0) 13.5 15.9 Cobalt 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) Copper 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) Iron 200.7 μg/L 355 144 ND (100) Lead 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) Magnesium 200.7 μg/L 31,800 6,680 21,000 Manganese 200.7 μg/L 128 ND (15.0) ND (15.0) Mercury 245.1 μg/L ND (0.200) ND (0.200) ND (0.200) Molybdenum 200.7 μg/L 19.7 143 359 Nickel 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) Selenium 200.7 μg/L 6.02 16.2 177 Sodium 200.7 μg/L 106,000 21,300 526,000 Thallium 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) Titanium 200.7 μg/L ND (10.0) 14.5 ND (10.0) Vanadium 200.7 μg/L ND (20.0) 68.5 110 Yttrium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) Zinc 200.7 μg/L 21.6 ND (10.0) ND (10.0) 

5-17 
Final Detailed Study Report Chapter 5 – C

Table 5-9. Ash Pond Effluent Concentrations 

Analyte Method Unit 

Homer City – 

Effluent from Bottom 

Ash Pond a 

Mitchell – Effluent 

from Fly Ash Pond 

Widows Creek – 

Effluent from 

Combined Ash Pond a

Routine Metals - DissolvedAluminum 200.7 μg/L 231 357 241 Antimony 200.7 μg/L ND (20.0) ND (20.0) 23.9 Arsenic 200.7 μg/L ND (10.0) 30.1 138 Barium 200.7 μg/L 106 206 128 Beryllium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) Boron 200.7 μg/L 397 2,200 2,290 Cadmium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) Calcium 200.7 μg/L 192,000 55,400 113,000 Chromium 200.7 μg/L ND (10.0) 11.9 14.1 Hexavalent Chromium D1687-92 μg/L ND (2.00) 12.0 7.00 Cobalt 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) Copper 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) Iron 200.7 μg/L 106 ND (100) ND (100) Lead 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) Magnesium 200.7 μg/L 32,600 6,430 20,300 Manganese 200.7 μg/L 129 ND (15.0) ND (15.0) Mercury 245.1 μg/L ND (0.200) ND (0.200) ND (0.200) Molybdenum 200.7 μg/L 20.2 136 330 Nickel 200.7 μg/L ND (50.0) ND (50.0) ND (50.0) Selenium 200.7 μg/L 6.10 L 15.3 162 Sodium 200.7 μg/L 106,000 20,000 514,000 Thallium 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) Titanium 200.7 μg/L ND (10.0) ND (10.0) ND (10.0) Vanadium 200.7 μg/L ND (20.0) 64.7 108 Yttrium 200.7 μg/L ND (5.00) ND (5.00) ND (5.00) Zinc 200.7 μg/L 35.2 ND (10.0) ND (10.0) 

5-18 
Final Detailed Study Report Chapter 5 – C

Table 5-9. Ash Pond Effluent Concentrations 

Analyte Method Unit 

Homer City – 

Effluent from Bottom 

Ash Pond a 

Mitchell – Effluent 

from Fly Ash Pond 

Widows Creek – 

Effluent from 

Combined Ash Pond a

Low-Level Metals - Total Antimony 1638 μg/L 1.09 4.39 25.8 Arsenic 1638 μg/L 6.52 34.9 142 Cadmium 1638 μg/L ND (0.500) ND (0.500) 1.32 Chromium 1638 μg/L ND (4.00) 13.5 L 20.4 Copper 1638 μg/L 2.37 1.49 5.47 Lead 1638 μg/L ND (0.250) 0.490 0.580 Mercury 1631E μg/L 0.00511 0.00157 0.00212 Nickel 1638 μg/L 10.7 ND (5.00) 11.0 Selenium 1638 μg/L 5.74 17.1 191 Thallium 1638 μg/L 1.32 1.46 1.72 Zinc 1638 μg/L 24.2 ND (2.50) 10.1 Low-Level Metals - DissolvedAntimony 1638 μg/L 0.990 4.45 22.5 Arsenic 1638 μg/L 5.00 29.0 131 Cadmium 1638 μg/L ND (0.500) ND (0.500) 1.17 Chromium 1638 μg/L ND (4.00) 12.6 L 16.0 Hexavalent Chromium 1636 μg/L 3.01 14.7 17.4 Copper 1638 μg/L 2.08 ND (1.00) 4.54 Lead 1638 μg/L ND (0.250) ND (0.250) ND (0.250) Mercury 1631E μg/L 0.00141 ND (0.000500) ND (0.000500) Nickel 1638 μg/L 10.4 ND (5.00) 9.57 Selenium 1638 μg/L 5.16 15.6 161 Thallium 1638 μg/L 1.31 1.49 1.42 Zinc 1638 μg/L 15.0 ND (2.50) 9.51 

5-19 
Final Detailed Study Report Chapter 5 – C

5-20 

Table 5-9. Ash Pond Effluent Concentrations 

Analyte Method Unit 

Homer City – 

Effluent from Bottom 

Ash Pond a 

Widows Creek – 

Effluent from 

Combined Ash Pond a

Mitchell – Effluent 

from Fly Ash Pond 

ClassicalsAmmonia As Nitrogen (NH3-N) 4500-NH3F mg/L 0.340 0.160 0.150 Nitrate/Nitrite (NO3-N + NO2-N) 353.2 mg/L 37.0 0.230 0.730 Total Kjeldahl Nitrogen (TKN) 4500-N,C mg/L 1.36 3.39 ND (0.100) Biochemical Oxygen Demand (BOD) 5210B mg/L ND (2.00) 4.00 2.00 Chloride 4500-CL-C mg/L 90.0 20.0 240 Hexane Extractable Material (HEM) 1664A mg/L ND (5.00) 6.00 ND (5.00) Silica Gel Treated HEM (SGT-HEM) 1664A mg/L NA ND (5.00) NA Sulfate D516-90 mg/L 1,290 80.7 1,110 Total Dissolved Solids (TDS) 2540 C mg/L 1,250 281 2,050 Total Phosphorus 365.3 mg/L 1.09 0.250 E 0.200 Total Suspended Solids (TSS) 2540 D mg/L 5.00 12.0 E 15.0 

Source: [ERG, 2008l; ERG, 2008m; ERG, 2008k; ERG, 2008o]. Note: EPA used several analytical methods to analyze for metals during the sampling program. For the purposes of sampling program, the analytical methods as “routine” and some of them as “low-level.” EPA designated all of the methods that require the use of clean hacollection techniques (i.e., EPA Method 1669 sample collection techniques) as “low-level” methods. Note that although not required by 

EPA used clean hands/dirty hands collection techniques for all low-level and routine metals samples. a – The concentrations presented have been rounded to three significant figures. b – The ash pond effluent results represent the average of the ash pond effluent and the duplicate of the ash pond effluent analytical me

< – Average result includes at least one non-detect value. (Calculation uses the report limit for non-detected results). E – Sample analyzed outside holding time.L – Sample result between 5x and 10x blank result.NA – Not analyzed. ND – Not detected (number in parenthesis is the report limit). The sampling episode reports for each of the individual plants contains a

information, including analytical results for analytes measured above the detection limit, but below the reporting limit (i.e., J-values). 
Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

Cardinal operates a fly ash pond treatment system. The fly ash pond receives fly ash 

transport water and occasionally some dilution water. The ash transport water and dilution water 

enter at the same point in the pond and flow to the dam located at the opposite end of the pond. 

The dam controls the flow from the pond into a channel that discharges to surface water. EPA 

collected a grab sample of the fly ash pond effluent from the channel discharging to the surface 

water. The average flow rate discharged from the fly ash pond during the sampling episode was 

7.8 mgd. The sampling episode report for Cardinal contains more detailed information regarding 

the sample collection procedures [ERG, 2008k]. 

If the fly ash and/or bottom ash transport water is treated in an ash pond, then the 

overflow from these systems can be reused as sluice water or recycled elsewhere within the 

plant. During the site visit program, EPA visited two plants that operate combined ash ponds 

receiving both fly ash and bottom ash transport water that are completely reusing the overflow 

from the ash pond as the bottom ash and fly ash transport waters with no discharge. One of these 

plants is highlighted in Case Study IV. 

Additionally, EPA visited two plants with segregated bottom ash handling systems and 

these plants reused the bottom ash pond overflow as the bottom ash transport waters; however, 

these plants do discharge some of the overflow from the bottom ash pond. These plants only 

discharged the bottom ash overflow if the water began accumulating in the system and needed to 

be discharged to manage the volume of water in the system. One of these plants is highlighted in 

Case Study V. 

Some plants achieve partial recycle from ash ponds. For example, from information 

obtained through the data request, EPA estimates that Georgia Power’s Bowen plant is recycling 

approximately 85 percent of the water from its ash pond. This ash pond receives and recycles 

several types of wastewaters including bottom ash and fly ash transport water. 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

Case Study IV: Coal-Fired Power Plant Water Reuse 

Fly Ash and Bottom Ash Transport Water Reuse 

Western Kentucky Energy’s Kenneth C. Coleman Station 

The Facility

Number of coal-fired units: 3 (485 total MW capacity for all three units) 

Coal used: Eastern bituminous 

Bottom ash handling: Wet 

Fly ash handling: Wet 

Ash treatment system: Ash ponds (no discharge) 

The Ash Handling and Treatment System

Bottom ash transport water and fly ash transport water are pumped to Ash Pond A, which was 

built in 1980 and has a discharge point (Outfall 002), but the plant does not typically discharge 

from the pond. Ash pond A also receives the effluent from the coal pile runoff pond and 

stormwater collected in Ash Pond C (the old pond, which is now closed). Coleman also has a 

new ash pond (Ash Pond D), which receives the dredged ash solids from Ash Pond A and the 

gypsum solids from the FGD process. All of the ponds at the plant have clay liners. 

The ash transport water collected in Ash Pond A is treated by the pond and then reused as fly 

ash and bottom ash transport water by the plant. The plant operates the system with a complete 

recirculation and does not discharge from the ash pond system, even though the plant has a 

permitted outfall that allows it to discharge. 

Water is removed from the ash system through evaporation from the ponds and evaporation of 

bottom ash quench water in the boiler. There may also be some loss to infiltration if water is 

able to pass through the clay liner of the pond. The plant monitors the levels of the ponds 

closely and adjusts the make-up water to the sluicing system to control the level of the ponds. 

During the rainy season, the plant keeps the levels lower to allow to additional rainfall to 

accumulate in the ponds. 

Highlights of Ash Transport Water Reuse

Recycle achieved: Complete recycle from combined ash pond 

Type of water reused: Bottom and fly ash transport water, coal pile runoff, rainfall, 

stormwater 

Recycle destination: Bottom ash transport water and fly ash transport water 

Source: [ERG, 2009m]. 

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Final Detailed Study Report Chapter 5 – Coal Ash Handling Systems 

5-23 

Case Study V: Coal-Fired Power Plant Water Reuse 

Bottom Ash Transport Water Reuse 

EME Homer City Generation L.P.’s Homer City Power Plant 

The Facility

Number of coal-fired units: 3 (650 MW; 650 MW; 700 MW) 

Coal used: Eastern bituminous 

Bottom ash handling: Wet 

Fly ash handling: Dry 

Ash treatment system: Dewatering bins and bottom ash pond 

The Ash Handling and Treatment System

Bottom ash transport water is piped from the boilers to dewatering bins, which remove 90 to 95 

percent of the solids. The dewatered bottom ash from the dewatering bins is either used locally 

for antiskid and road construction or placed in the on-site, unlined ash landfill. The decant 

overflow from the dewatering bins drains to ash settling ponds. 

Homer City operates four ash settling ponds. The plant typically operates two ash settling ponds 

at one time, which are operated in series. Each ash pond has an approximate volume of 1.76 

million gallons. The ash settling ponds receive overflow from the bottom ash dewatering bins, 

as well as stormwater runoff and rainfall. Runoff from the ash handling and precipitator areas 

(covering approximately six acres) drains into the ponds. Water from the first pond in a series 

pair overflows to the second pond, which in turn overflows to a clearwell. From the clearwell, 

water is recycled for use as bottom ash transport water. There is a periodic discharge from the 

clearwell through the NPDES outfall as needed to maintain the water balance in the system, the 

frequency of which depends on the amount of rainfall that has been received. As one pair of ash 

settling ponds fills with solids, the transport water is shifted to the other pair of ponds so that 

the settled ash can be removed. The ash settling ponds are dredged every six to eight months. 

The recovered solids are transported to the on-site, unlined ash landfill. 

Highlights of Ash Transport Water Reuse

Recycle achieved: Significant percentage of recycle from bottom ash pond 

Type of water reused: Bottom ash transport water and contaminated stormwater 

Recycle destination: Bottom ash transport water 

Source: [ERG, 2007j]. 
Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

6. ENVIRONMENTAL ASSESSMENT OF COAL COMBUSTION WASTEWATER

Numerous studies have shown that the pollutants found in wastewater associated with 

coal combustion wastes can impact aquatic organisms and wildlife, and can result in lasting 

environmental impacts on local habitats and ecosystems. Many of these impacts may not be 

realized for years due to the persistent and bioaccumulative nature of the pollutants released. The 

total amount of toxic pollutants currently being released in wastewater discharges from coal-fired 

power plants is estimated to be significant and raises concerns regarding the long-term impacts to 

aquatic organisms, wildlife, and human health that are exposed to these pollutants. This chapter 

presents case study examples to illustrate the impacts that pollutants present in coal-fired power 

plant wastewater can have on the environment. 

As described in Chapters 4 and 5, coal combustion wastes comprise a variety of residuals 

from the coal combustion process, including fly ash, bottom ash, and FGD solids (i.e., gypsum 

and calcium sulfite). Coal-fired plants remove these solid wastes through both wet and dry 

disposal methods. Dry disposal practices typically involve transferring the combustion wastes to 

a storage silo or outdoor storage pile to either be hauled to a landfill or, depending on the 

particular residual, sent offsite where it may be used to create beneficial by-products such as 

drywall or cement. In wet handling systems, bottom ash and fly ash is transported from the boiler 

and particulate removal units and is typically disposed of in surface impoundment settling ponds. 

Wet FGD systems use lime or limestone slurry to remove sulfur dioxide from flue gas. The water 

remaining from the slurry at the end of the FGD process, commonly called scrubber purge, is 

either discharged to a surface impoundment or sent to an advanced wastewater treatment system 

prior to discharge to a receiving stream. 

Although there are several wastewater streams associated with coal-fired power plants, 

for the purposes of this chapter, coal combustion wastewater includes the following waste 

streams: 

• FGD wastewater (i.e., scrubber purge) - the wastewater remaining following the 

use of a sorbent slurry (e.g., lime, limestone) to remove sulfur dioxide from flue 

gas; 

• Fly ash transport water - the wastewater stream used to transport the fly ash away 

from the electrostatic precipitators (ESPs) or fabric filter baghouses; 

• Bottom ash transport water - the wastewater stream used to transport the bottom 

ash away from the boiler; and 

• Leachate or seepage from surface impoundments or landfills containing coal 

combustion residues. 

The most common treatment and disposal practice for coal combustion wastewater 

involves pumping the slurried wastes into surface impoundments that serve as a physical 

treatment to remove particulate material through gravitational settling. The coal combustion 

wastewater present in surface impoundments can include one specific wastewater stream (e.g., 

fly ash transport water) or a combination of combustion wastewaters (e.g., fly ash transport water 

and FGD wastewater). The wastewaters sent to surface impoundments can also include coal pile 

runoff. Although coal pile runoff is not the result of a combustion process, it can contain many of 

the pollutants present in coal combustion wastewater. Some coal-fired power plants have 

implemented more advanced wastewater treatment systems such as chemical precipitation, 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

biological treatment, and evaporation/distillation to treat the FGD wastewater. Chapter 4 

describes these advanced treatment practices in more detail. Regardless of whether a plant uses a 

settling pond or advanced treatment system, coal combustion wastewater is typically discharged 

into the natural environment where numerous studies have raised concern regarding the toxicity 

of these waste streams [Rowe et al., 2002; U.S. EPA, 2007c; NRC, 2006]. 

A number of variables can affect the composition of coal combustion wastewater, 

including parent coal composition, type of combustion process, flue gas cleaning technologies 

implemented, and management techniques used to dispose of coal combustion wastewater 

[Carlson and Adriano, 1993]. In particular, the practice of commingling coal combustion 

wastewater with other waste streams from the plant in surface impoundments can result in a 

chemically complex effluent that is ultimately released to the environment [Rowe et al., 2002]. 

Exposure to coal combustion wastewater has been associated with fish kills, reductions in the 

growth and survival of aquatic organisms, behavioral and physiological effects in wildlife and 

aquatic organisms, potential impacts to human health (i.e., drinking water contamination), and 

changes to the local habitat [Rowe et al., 2002; Carlson and Adriano, 1993]. The 

bioaccumulative properties of several coal combustion wastewater pollutants and long recovery 

times associated with many of the ecological impacts emphasize the potential threat these wastes 

present to the local environment. Research published in the scientific literature demonstrates that 

coal combustion wastewater is not a benign waste and further study is needed to fully understand 

how these chemically complex waste streams interact with the environment [Rowe et al., 2002; 

NRC, 2006]. 

This chapter examines the potential impacts of coal combustion wastewater on the 

environment by addressing the following three questions: 

• What are the characteristics of coal combustion wastewater? 

• How does coal combustion wastewater interact with the environment? 

• What are the environmental effects of coal combustion wastewater? 

Section 6.1 discusses the characteristics of coal combustion wastewater and why they are 

a threat to the environment. Section 6.2 explores the various ways that pollutants in coal 

combustion wastewater can come into contact with the environment through different waste 

management practices (e.g., surface impoundments and landfills). In addition this section 

describes how different surface water environments (e.g., lentic and lotic systems) can influence 

the environmental effect of coal combustion wastewater. Section 6.3 provides an overview of the 

different environmental effects reported in the literature resulting from exposure to coal 

combustion wastewater. 

6.1 Coal Combustion Wastewater Pollutants

An increasing amount of evidence indicates that the characteristics of coal combustion 

wastewater have the potential to impact human health and the environment. Many of the 

common pollutants found in coal combustion wastewater (e.g., selenium, mercury, and arsenic) 

are known to cause environmental harm and can potentially represent a human health risk. 

Pollutants in coal combustion wastewater are of particular concern because they can occur in 

large quantities (i.e., total pounds) and at high concentrations (i.e., exceeding Maximum 

Contaminant Levels (MCLs)) in discharges and leachate to groundwater and surface waters. In 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

addition, some pollutants in coal combustion wastewater present an increased ecological threat 

due to their tendency to persist in the environment and bioaccumulate in organisms, which often 

results in slow ecological recovery times following exposure. 

Constituents present in coal combustion wastewater are primarily derived from the parent 

coal. A number of these constituents have the potential to cause environmental harm depending 

on the mass pollutant load, wastewater concentration, and how organisms are exposured to them 

in the environment. Table 6-1 lists some of the common pollutants found in coal combustion 

wastewater that have been associated with documented environmental impacts or could have the 

potential to cause environmental impacts based on the loads and concentrations present in the 

wastewater. Table 6-1 is intended to highlight the most frequently cited pollutants in coal 

combustion wastewater associated with environmental impacts and does not include all 

pollutants that may cause adverse impacts. The remainder of this section provides an overview of 

the metals and pollutants most frequently cited as causing ecological impacts following exposure 

to coal combustion wastewater, some of which have been the focus of some state NPDES permit 

programs. 

Table 6-1. Selected Coal Combustion Wastewater Pollutants 

Compound Potential Environmental Concern a,b,c,d

Arsenic Frequently observed in high concentrations in coal combustion wastewater; causes poisoning of

the liver in fish and developmental abnormalities; is associated with an increased risk of cancer 

in humans in the liver and bladder. 

BOD Can cause fish kills because of a lack of available oxygen; increases the toxicity of other 

pollutants, such as mercury. Has been associated with FGD wastewaters that use organic acids 

for enhanced SO2 removal in the scrubber. 

Boron Frequently observed in high concentrations in coal combustion wastewater; leachate into 

groundwater has exceeded state drinking water standards; human exposure to high

concentrations can cause nausea, vomiting, and diarrhea. Can be toxic to vegetation. 

Cadmium Elevated levels are characteristic of coal combustion wastewater-impacted systems; organisms 

with elevated levels have exhibited tissue damage and organ abnormalities. 

Chlorides Sometimes observed at high concentrations in coal combustion wastewater (dependent on FGD 

system practices); elevated levels observed in fish with liver and blood abnormalities. 

Chromium Elevated levels have been observed in groundwater receiving coal combustion wastewater 

leachate; invertebrates with elevated levels require more energy to support their metabolism and 

therefore exhibit diminished growth. 

Copper Coal combustion wastewater can contain high levels; invertebrates with elevated levels require 

more energy to support their metabolism and therefore exhibit diminished growth. 

Iron Leachate from impoundments has caused elevated concentrations in nearby surface water; biota 

with elevated levels have exhibited sublethal effects including metabolic changes and 

abnormalities of the liver and kidneys. 

Lead Concentrations in coal combustion wastewater are elevated initially, but lead settles out quickly; 

leachate has caused groundwater to exceed state drinking water standards. Human exposure to 

high concentrations of lead in drinking water can cause serious damage to the brain, kidneys, 

nervous system, and red blood cells. 

Manganese Coal combustion wastewater leachate has caused elevated concentrations in nearby groundwater 

and surface water; biota with elevated levels have exhibited sublethal effects including metabolic 

changes and abnormalities of the liver and kidneys. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

6-4 

Table 6-1. Selected Coal Combustion Wastewater Pollutants 

Compound Potential Environmental Concern a,b,c,d

Mercury Biota with elevated levels have exhibited sublethal effects including metabolic changes and 

abnormalities of the liver and kidneys; can convert into methylmercury, increasing the potential 

for bioaccumulation; human exposure at levels above the MCL for relatively short periods of 

time can result in kidney damage. 

Nitrogen Frequently observed at elevated levels in coal combustion wastewater; may cause eutrophication 

of aquatic environments. 

pH Acidic conditions are often observed in coal combustion wastewater; acidic conditions may 

cause other coal combustion wastewater constituents to dissolve, increasing the fate and transport 

potential of pollutants and increasing the potential for bioaccumulation in aquatic organisms. 

Phosphorus Frequently observed at elevated levels in coal combustion wastewater; may cause eutrophication 

of aquatic environments. 

Selenium Frequently observed at high concentrations in coal combustion wastewater; readily 

bioaccumulates; elevated concentrations have caused fish kills and numerous sublethal effects 

(e.g., increased metabolic rates, decreased growth rates, reproductive failure) to aquatic and 

terrestrial organisms. Short term exposure at levels above the MCL can cause hair and fingernail 

changes; damage to the peripheral nervous system; fatigue and irritability in humans. Long term 

exposure can result in damage to the kidney, liver, and nervous and circulatory systems. 

Total dissolved 

solids 

High levels are frequently observed in coal combustion wastewater; elevated levels can be a 

stress on aquatic organisms with potential toxic effects; elevated levels can have impacts on 

agriculture & wetlands. 

Zinc Frequently observed at elevated concentrations in coal combustion wastewater; biota with 

elevated levels have exhibited sublethal effects such as requiring more energy to support their 

metabolism and therefore exhibiting diminished growth, and abnormalities of the liver and 

kidneys. 

a – Source: [Rowe et al., 2002]. 

b – Source: [NRC, 2006]. 

c – Source: EPA Drinking Water Contaminants (http://www.epa.gov/safewater/contaminants/index.html#mcls) 

d – Source: [U.S. EPA, 2007c]. 

Selenium 

Selenium is the most frequently cited pollutant associated with documented 

environmental impacts following exposure to coal combustion wastewater [NRC, 2006]. 

Selenium concentrations present in coal combustion wastewater originate from the parent coal 

used in the combustion process. The toxic potential of selenium is related to its chemical form 

(i.e., selenite, selenate, elemental selenium) and solubility. The predominate forms of selenium in 

aquatic systems that receive coal combustion wastewater discharges are selenite and selenate 

[Besser et al., 1996]. Availability of selenium is controlled by dissolved oxygen levels, hardness, 

pH, salinity, temperature, and the other chemical constituents present [NPS, 1997]. 

Selenium has been tied to fish kills, and to developmental and reproductive failure in fish, 

reptiles, and birds. In a 1991 study, Sorensen found that selenium levels as low as 3-8 μg/L in 

aquatic environments can be life-threatening to fish [NPS, 1997]. Selenium has the potential to 

bioaccumulate and can be transferred maternally. As a result, selenium-related environmental 

impacts can linger for years even after exposure to coal combustion wastewater has ceased 

[Rowe et al., 2002]. Aquatic organisms exposed to coal combustion wastewater have exhibited 

elevated selenium concentration in organs such as their kidneys, liver, and gonads, resulting in 

abnormalities that hinder growth and survival [Rowe et al., 2002]. In addition to ecological 
Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

impacts, EPA has documented numerous damage cases where selenium in coal combustion 

wastewater discharges resulted in the issuance of fish consumption advisories in surface waters 

and the exceedance of selenium MCLs in groundwater, suggesting that selenium concentrations 

in coal combustion wastewater has the potential to represent a human health risk [U.S. EPA, 

2007c; NRC, 2006]. 

Arsenic 

Arsenic, like selenium, is soluble in near-neutral pH and in alkaline conditions, which are 

commonly associated with coal combustion wastewater. Because of these solubility 

characteristics, arsenic is highly mobile and is frequently observed at elevated concentrations at 

sites located downstream from coal combustion wastewater impoundments [NRC, 2006]. In 

addition, EPA has documented several damage cases where arsenic levels exceeded drinking 

water standards in groundwater near coal combustion waste management facilities [U.S. EPA, 

2007c]. Groundwater contamination of arsenic at these concentrations represents a potential 

human health risk if the aquifer is used as a drinking water source or has the potential to impact a 

drinking water source. 

Arsenic is also of concern due to its tendency to bioaccumulate in aquatic communities 

and potentially impact higher trophic level organisms in the area. For example, studies have 

documented water snakes, which feed on fish and amphibians, with arsenic tissue concentrations 

higher than their prey [Rowe et al., 2002]. Elevated arsenic tissue concentrations are associated 

with several biological impacts such as liver tissue death, developmental abnormalities, and 

reduced growth [NRC, 2006; Rowe et al., 2002]. 

Mercury 

Although mercury concentrations in coal combustion wastewater are relatively low, 

mercury is a highly toxic compound that represents an environmental and human health risk even 

in small concentrations. One of the primary environmental concerns regarding mercury 

concentrations in coal combustion wastewater is the potential for methylmercury to form in 

surface impoundments and constructed wetlands prior to discharge. Methylmercury is an organic 

form of mercury that readily bioaccumulates in fish and other organisms and is associated with 

high rates of reproductive failure. Bacteria found in anaerobic conditions, such as those that may 

be present in sediments found on the bottom of coal combustion surface impoundments or in 

river sediments, convert mercury to methylmercury through a process called methylation. 

Microbial methylation rates increase in acidic and anoxic environments with high concentrations 

of organic matter. Studies have documented fish and invertebrates exposed to mercury from coal 

combustion wastewater exhibiting elevated levels of mercury in their tissues and developing 

sublethal effects such as reduced growth and reproductive success [Rowe et al., 2002]. 

Biochemical Oxygen Demand (BOD) 

Biochemical oxygen demand (BOD) is a measure of the quantity of oxygen used by 

microorganisms (e.g., aerobic bacteria) in the oxidation of organic matter. The primary source of 

BOD in coal combustion wastewater is the addition of organic acid buffers to the FGD 

scrubbers. High BOD concentrations in surface waters have the potential to decrease dissolved 

oxygen levels and contribute to fish kills in waters that receive coal combustion wastewater. 

BOD levels can also influence the availability and toxicity of other coal combustion wastewater 

6-5 
Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

constituents such as metals. For example, the rate of methylation, or the conversion from 

elemental mercury to methylmercury, increases at high concentrations of BOD, thus increasing 

the potential toxic effects of mercury present in coal combustion wastewater. 

pH 

The pH of coal combustion wastewater varies depending on the type of coal and the 

amount of metal oxides present [NRC, 2006]. Although some coal combustion wastewaters are 

alkaline, wastewater that is generated from power plants burning bituminous coal from 

southeastern or mid-Atlantic states is acidic [NRC, 2006]. Many pollutants in coal combustion 

wastewater, including cadmium, copper, chromium, lead, nickel, and zinc, are highly soluble in 

acidic, or non-neutral, conditions [NRC, 2006]. As a result, coal combustion wastewater often 

has high dissolved metal concentrations. 

Chlorides and Total Dissolved Solids 

Chloride levels in coal combustion wastewater are dependent upon chlorine 

concentrations present in the parent coal as well as the amount of recirculation in the FGD 

system. FGD systems with many iterations of circulation between blowdown cycles exhibit high 

concentrations of chlorides. Studies have found that coal combustion wastewater leachate 

reaching groundwater has caused chloride levels to exceed secondary MCLs [NRC, 2006]. 

Chlorides also contribute to the high total dissolved solids (TDS) levels typical of coal 

combustion wastewater. TDS, a reflection of water’s salinity level, is a measure of the amount of 

dissolved matter in water. Calcium and magnesium also factor heavily into TDS levels of coal 

combustion wastewater. The remaining composition of TDS consists of other common dissolved 

metals and constituents, particularly at acidic pH levels when they exhibit high solubilities. Both 

chloride levels and TDS play a role in determining the availability and toxicity of other coal 

combustion wastewater constituents, including metals. As TDS and chloride levels fluctuate, so 

do the amounts of other metals that dissolve due to solubility characteristics. 

Nutrients 

Nutrient concentrations present in coal combustion wastewater are primarily attributed to 

the parent coal composition and air pollution controls in the coal combustion process. 

Phosphorus concentrations in coal combustion wastewater tend to vary based on the parent coal 

composition with high sulfur coals commonly associated with higher levels of phosphorus. 

The primary concern with nutrients in coal combustion wastewater is the potential for the 

total nitrogen load from coal-fired power plants to significantly increase in the future as air 

pollution limits become stricter and the use of air pollution controls increases. While the current 

concentration of nitrogen present in coal combustion wastewater from any individual power 

plant is probably relatively low, the total nitrogen load from a single plant can be significant due 

to large wastewater flow rates. There are concerns that nutrient impacts could occur on 

waterbodies receiving discharges from multiple power plants. This is especially a concern on 

waterbodies that are nutrient impaired or in watersheds that contribute to downstream nutrient 

problems. Higher nutrient loads from coal-fired power plants could result in the eutrophication of 

waters receiving coal combustion wastewater. Eutrophication is the process where excess 

nutrients stimulate excessive plant and algal growth which can lead to declining dissolved 

oxygen levels. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

6.2 Coal Combustion Wastewater Interactions with the Environment

The interaction of a pollutant source with the environment can be described as either a 

release from the source that alters the physical, chemical, or biological characteristics of an 

ecosystem or the attraction of wildlife and humans to the pollutant source (i.e., an attractive 

nuisance) prior to discharge. In 2007, EPA’s Office of Resource Conservation and Recovery 

(ORCR, formerly named the Office of Solid Waste) evaluated 85 cases of environmental damage 

to determine if the observed impacts were due to pollutants from coal combustion wastes [U.S. 

EPA, 2007c]. EPA’s Office of Water reviewed this information, along with several other 

instances where environmental impacts are attributable to coal combustion wastewater. Table 6-2

summarizes the number of environmental impact cases by type of waste management system and 

type of impacted water body resource. 

Table 6-2. Number of Documented Cases of Environmental Impacts from Coal 

Combustion Wastewater 

Source of Pollutant Release 

(Waste Management System) Impacted Water Resource Surface Impoundment Landfill Both Surface Impoundment and Landfill Not Identified Surface Water Groundwater Both Surface Water and Groundwater 

34 30 2 4 10 51 9 

Total Number of Cases = 70 

Source: [Jordan, 2009].

The three primary routes through which coal combustion wastewater interacts with the 

environment are: 

• Discharges to surface waters; 

• Leaching to groundwater; and 

• Surface impoundments and constructed wetlands acting as attractive nuisances. 

The method of exposure plays an important role in determining the potential effects of 

coal combustion wastewater on the environment. For example, the physical and chemical 

characteristics of receiving waters and groundwater aquifers can affect the fate and transport of 

pollutants from coal combustion wastewater to the environment and how the pollutants interact 

with the biological community. This section describes the three primary methods through which 

coal combustion wastewater interacts with the environment and explores how each route can 

affect the potential for environmental impact from coal combustion wastewater. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

6.2.1 Discharges to Surface Waters 

Coal combustion wastewater is commonly discharged directly to surface waters 

following treatment in settling ponds. More recently, FGD wastewater at some power plants may 

be treated using advanced wastewater treatment systems employing tanks and similar structures 

(e.g., chemical precipitation or biological treatment systems) prior to discharge to an ash pond or 

directly to surface water. 

One of the primary factors controlling the environmental impact of coal combustion 

wastewater on surface waters is the residence time of the pollutants once they enter an aquatic 

system. Residence times are often determined by the flow rate of the receiving water and type of 

ecosystem it supports. For example, the potential for pollutant retention in lentic (i.e., still or 

slow-moving water) aquatic systems and the creation of hot spots in lotic (i.e., actively-moving 

water) aquatics systems are of particular concern especially when bioaccumulative pollutants are 

present in coal combustion wastewater. Several coal combustion wastewater constituents (e.g., 

arsenic, mercury, selenium) can readily bioaccumulate in exposed biota. Bioaccumulation is the 

process wherein an organism absorbs a toxic substance through food and exposure to the 

environment at a faster rate than the substance is removed from the body. The bioaccumulation 

of coal combustion wastewater pollutants is of particular concern due to the potential for 

impacting higher tropic levels, local terrestrial environments, and transient species in addition to 

the aquatic organisms directly exposed to coal combustion wastewater. Aquatic systems with 

long residences times and potentially exposed to bioaccumulative pollutants often experience a 

persistence of environmental effects and suffer from long recovery times following the 

introduction of coal combustion wastewater to the system. The following sections describe how 

the differences in stream flow between lentic and lotic systems can impact the environmental 

effect of coal combustion wastewater on aquatic organisms and wildlife and the role that 

sediments in surface waters play in the persistence of these effects in aquatic systems. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

Lentic Systems 

Many aquatic environments that 

contain coal combustion wastewater 

(e.g., surface impoundments) or receive 

coal combustion wastewater discharges 

are lentic systems such as lakes, ponds, 

reservoirs, and swamps. The majority of 

ecological studies on the impact of coal 

combustion wastewater in aquatic 

environments have focused on lentic 

systems [Rowe et al., 2002]. In lentic 

aquatic systems, the hydraulic residence 

time, or the amount of time it takes for 

the water in the aquatic system to be 

replaced by influent (i.e., streams, 

precipitation), is relatively long, 

allowing pollutants to build up over time 

and making lentic systems more 

vulnerable to impacts from coal 

combustion wastewater. In addition, 

aquatic organisms are limited in their 

ability to avoid areas of high pollutant 

concentrations and are restricted to the 

food supply available within the water 

body. Some coal combustion wastewater 

pollutants (e.g., selenium) are known to 

bioaccumulate and have been known to 

concentrate in the upper tiers of the 

aquatic food web in lentic systems. For 

example, samples of sediments, plants, 

and aquatic organisms collected from 

the swamp near the D-Area Power 

Facility on the U.S. Department of 

Energy’s Savannah River Site near 

Aiken, SC, reported elevated concentrations of arsenic, cadmium, chromium, copper, and 

selenium. In addition to the accumulation of these pollutants in organisms directly exposed to 

discharges of the coal combustion wastewater, studies of turtles, alligators, and birds living near 

the drainage swamp have shown these animals transfer trace metals such as selenium to their 

offspring. Chronic exposure to coal combustion wastewater pollutants in the swamp has been 

linked to detrimental changes in morphology, behavior, energetics, and endocrinology in local 

wildlife [Rowe et al. 2002]. In a 1999 study, Hopkins et al. observed that water snakes, which 

fed on fish and amphibians in the areas contaminated with coal combustion wastes, had 

accumulated higher arsenic tissue concentrations than their prey [Rowe et al., 2002]. 

Lentic System Case Study: 

Belews Lake, North Carolina 

 In 1970, Duke Power Company constructed 

Belews Lake, a 1,500 hectare cooling reservoir to support 

the Belews Creek Steam Station in Stokes County, North 

Carolina. Following completion of the reservoir, Duke 

Power began monitoring the fish populations in Belews 

Lake prior to any discharges of coal combustion 

wastewater. From 1974 to 1985, ash pond effluent was 

discharged into Belews Lake. Almost immediately 

following the introduction of the ash pond effluent to lake 

employees observed rapid and dramatic changes in the fish 

populations [Rowe et al., 2002]. By 1975, one year after 

discharges began, morphological abnormalities were 

reported for all 19 fish species monitored in the lake. 

Within two years following the release of coal combustion 

wastewater into the lake, several species experienced 

complete reproductive failure with only four species 

remaining by 1978 (i.e., four years after discharges 

began). Water samples collected in the lake reported 

elevated levels of arsenic, selenium, and zinc. The 

observed fish abnormalities were eventually correlated 

with high selenium whole-body concentrations with the 

planktonic community identified as the key source of 

selenium to the impacted fish. 

 In 1985 the Belews Creek Steam Station 

switched to a dry landfilling disposal method for the coal 

ash and ash pond discharges to the lake ended. In a 1997 

study, Lemly determined that there was evidence that the 

lake was recovering; however, even 11 years after the 

discharges ceased selenium levels in the sediments still 

posed a risk to wildlife that feed on benthic organisms 

[Rowe et al., 2002]. Lemly also observed that despite the 

reduction in the selenium concentration present in fish 

ovaries, reproductive abnormalities remained persistent 

highlighting the long ecological recovery times commonly 

experienced in lentic systems with high pollutant retention 

rates and low sedimentation rates such as Belews Lake 

[Rowe et al., 2002]. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

Lotic Systems 

Lotic systems are water bodies with flowing water such as streams, rivers, and springs 

that may provide more rapid dilution of coal combustion wastewater discharges than lentic 

systems. The moving water in lotic systems provides a transport mechanism to disperse coal 

combustion constituents greater distances from the power plant, and enables aquatic organisms 

to move away from the areas of coal combustion wastewater contamination [Rowe et al., 2002]. 

Although the discharge of coal combustion wastewater into a lotic system has the potential to 

increase the distribution of pollutants across a greater spatial area, changes in flow velocity may 

result in the concentration of pollutants at a single location further downstream [Rowe et al. 

2002]. For example, coal combustion wastewater discharged to a river may encounter areas of 

slower moving water downstream where pollutants would fall out of suspension and concentrate 

in a limited area. These pockets of higher pollutant concentrations, or hot spots, could be 

vulnerable to continued resuspension as stream velocities are affected by rainfall events, 

resulting in the pollutants being available to aquatic organisms over much longer periods of time 

[Rowe et al., 2002; Lemly, 1996]. 

Few studies have demonstrated lethal and sublethal effects to aquatic organisms from the 

discharge of coal combustion wastewater into lotic systems; however, several studies have 

demonstrated the bioaccumulation of trace elements in fish and invertebrates in creeks 

downstream of coal combustion wastewater impoundments [Rowe et al., 2002]. In a 2001 study 

by Lemly et al., fish and water quality samples were collected downstream from the American 

Electric Power (AEP) John E. Amos Plant in Winfield, WV along Little Scary Creek and at a 

reference location along the Ohio River. Water quality samples reported elevated levels of 

arsenic, copper, and selenium in Little Scary Creek relative to the reference location. Bluegill 

fish liver concentrations were higher than the reference location for arsenic, cadmium, copper, 

chromium, selenium, and zinc demonstrating that pollutants from the ash pond discharge are 

accumulating in fish living downstream from the Amos Plant. Although currently there is a 

limited amount of information available on the environmental impacts of coal combustion 

wastewater on lotic systems, Lemly’s results show that discharges from coal-fired power plants 

can affect organisms living downstream in lotic environments [Rowe et al., 2002]. 

Sediments in Surface Waters 

Sediments present in both lentic and lotic aquatic environments play a major role in the 

residence time of coal combustion wastewater pollutants. Sediments act as long-term storage 

sites for contaminants, serving as an exposure source for organisms and downstream waters even 

after coal combustion wastewater discharges have ceased [Rowe et al., 2002]. This characteristic 

causes recovery of aquatic systems following coal combustion wastewater release to be 

extremely slow [Rowe et al., 2002]. A 1985 study by Lemly found that detrital pathways (i.e., 

processes associated with decomposition) in Belews Lake provided toxic doses of sedimentstored selenium to local biota many years after water concentrations of selenium were below 

levels of concern [Rowe et al., 2002]. The recovery of aquatic systems is particularly slow when 

sediment release acts in combination with a lentic system to continuously expose and reintroduce 

bioaccumulative pollutants to aquatic organisms. These factors cause pollutant levels in aquatic 

organisms to steadily rise because the pollutants remain stationary due to the slow-moving water, 

the organisms are exposed to additional pollutants that are released from sediments over time, 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

and the tissue concentrations of aquatic organisms increase beyond levels available in the water 

due to bioaccumulative properties. 

6.2.2 Leaching to Groundwater 

Pollutants in coal combustion wastewater and coal combustion wastes (e.g., ash, gypsum, 

calcium sulfite) can impact local groundwater systems through leaching from surface 

impoundments, landfills, and minefills. Coal combustion wastewater held in unlined surface 

impoundments can infiltrate through the subsurface and enter the groundwater system. Unlined 

landfills and minefills, used to dispose of coal combustion residues, are also subject to leaching 

as rainfall penetrates the residue pile dissolving pollutants into the pore water, which eventually 

migrates to aquifers. Pollutants from coal combustion wastewater can also enter the groundwater 

system when liners fail or when a disposal site is inappropriately situated such that natural 

groundwater fluctuations come into contact with the disposed-of waste. As Table 6-2 indicates, 

EPA has identified 51 instances where coal combustion wastes and wastewater have caused 

impacts to ground water. 

Older disposal sites are of particular concern because most of these surface 

impoundments and landfills were not built with liners. Although the use of liners for surface 

impoundments and landfills is increasing at new facilities, many states do not require basic 

environmental protection standards such as leachate collection systems and impermeable liners 

[Rowe et al., 2002]. 

Once in the groundwater system, coal combustion wastewater pollutants have the 

potential to migrate from the site at concentrations that could contaminate drinking water wells 

and surface waters [NRC, 2006]. The fate of coal combustion wastewater pollutants in 

groundwater systems is controlled by an array of geochemical (e.g., adsorption, desorption, and 

precipitation reactions with aquifer materials) and biological processes that can vary over large 

spatial and temporal scales [NRC, 2006]. For example, pollutants leaching from unweathered 

coal combustion residues disposed of in landfills and minefills may experience an initial set of 

rapid dissolution and desorption reactions followed by slower reactions as alkalinity is leached 

from the residue pile over time [NRC, 2006]. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

The degree of degradation caused 

by coal combustion wastewater leaching 

into groundwater systems depends on the 

type and concentration level of the 

pollutants, volume of contaminated water 

entering the subsurface, and the ability of 

the aquifer to dilute or attenuate the 

contamination [NRC, 2006]. Some coal 

combustion wastewater pollutants may 

be unaffected by subsurface geochemical 

processes and move freely with the 

groundwater flow, readily contaminating 

local drinking water wells and surface 

waters [NRC, 2006]. However, other 

pollutants may be subject to adsorption 

or precipitation reactions or transformed 

by microbiotic mediated biological 

reactions altering the extent of the 

contamination [NRC, 2006]. 

The rate of pollutant transport in 

groundwater systems depends on several 

factors such as the biogeochemical 

characteristics of the subsurface (e.g., 

soil pH and oxidation-reduction 

potentials), local rates of groundwater 

recharge, and unsaturated and saturated 

groundwater flow velocities. Predicting 

the transport of coal combustion 

pollutants in groundwater can be 

challenging due to the wide range of 

biogeochemical characteristics that can 

exist between sites and within a given site. Groundwater models that require information on the 

groundwater chemistry, the mass and form of mineral phases present at the site, and the 

dominant microbially mediated geochemical reactions can be used to predict the potential for 

transport. However, the conditions (e.g., pH, oxidation-reduction conditions, and hydraulic 

conductivity) influencing the field behavior of coal combustion wastes over the extended time 

frames typically encountered at coal combustion wastewater disposal sites is poorly understood 

[NRC, 2006]. Pollutant transport times can vary significantly and it might take relatively little 

time or many years before pollutants from coal combustion wastewater degrade local drinking 

water wells and surface waters. For example, in the damage case at the Wisconsin Electric Power 

Company facility in Port Washington, Wisconsin, fly ash had been disposed of in a quarry for 

over 20 years (1943-1971) prior to the selenium and boron contamination being reported in a 

down-gradient private drinking water well [U.S. EPA, 2007c]. This suggests that a longer period 

of groundwater monitoring may be required at some sites to adequately assess the full release of 

contaminants, which can occur over several decades [NRC, 2006]. In addition to potentially long 

temporal scales, groundwater contamination can occur on large spatial scales based on the 

Groundwater Case Study: Constellation Ash Disposal 

at Waugh Chapel and Turner Pits 

Anne Arundel County, Maryland 

 For over a decade, Constellation Energy Group 

(Constellation) supplied fly ash for structural fill at the 

B.B.S.S. Inc. (BBSS) sand and gravel mines in Anne 

Arundel County, Maryland. Fly ash from Constellation’s 

Brandon Shores and Wagner plants were used to reclaim 

portions of BBSS’ Turner Pit starting in 1995 and the 

Waugh Chapel Pit starting in 2000. In the fall of 2006, 

Anne Arundel County Health Department officials 

documented concentrations of sulfate and metals (i.e., 

antimony, beryllium, cadmium, manganese, and nickel) 

exceeding the state’s screening criteria for potable aquifers 

in residential wells located downgradient from Waugh 

Chapel and Turner Pits [Erbe et al., 2007]. 

 An independent study of the contamination 

confirmed that the elevated concentrations of sulfate and 

metals observed in the wells were the direct result of 

precipitation infiltrating the fly ash deposited in the BBSS 

sand and gravel mines [Erbe et al., 2007]. In October 

2007, MDE fined Constellation and BBSS $1 million for 

the ground water contamination and included requirements 

for the companies to restore the local aquifer water quality 

[MDE, 2008]. In addition, a group of Anne Arundel 

homeowners impacted by the contamination filed a class 

action lawsuit against Constellation and were awarded a 

$45 million settlement that required Constellation to pay 

the costs for converting 84 homes from well water to 

public water; cease future deliveries of new coal ash to the 

quarry; and to establish trust funds to compensate 

impacted property owners, enhance the neighborhood, and 

remediate and restore a former quarry site [Schultz, 2008]. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

hydraulic properties of the subsurface traveling long distances before it encounters a drinking 

water well or discharges as a spring or as seepage into a stream, lake, or ocean [NRC, 2006]. 

6.2.3 Surface Impoundments and 

Constructed Treatment Wetlands 

as Attractive Nuisances 

The environmental characteristics 

of settling ponds or surface 

impoundments and constructed wetlands 

that are used to treat coal combustion 

wastewater often support an ecosystem 

unto themselves that attracts wildlife to 

these waste and wastewater storage 

areas. Surface impoundments can be 

classified as a lentic system supporting 

aquatic vegetation and organisms, and 

serving as an attractive nuisance that 

draws wildlife from other terrestrial 

habitats. An attractive nuisance is 

typically defined as an area or habitat 

that is attractive to wildlife and that is 

contaminated with pollutants at 

concentrations high enough to potentially 

cause harm to exposed organisms. 

As an attractive nuisance, surface 

impoundments holding coal combustion 

wastewater may impact local wildlife as 

well as transient species that may rely on 

them during critical reproduction periods 

such as seasonal breeding events [Rowe 

et al., 2002]. Exposure to coal 

combustion wastewater during sensitive 

life cycle events is potentially of concern 

given that exposure to coal combustion 

wastewater has been associated with 

complete reproductive failure in various 

vertebrate species [Rowe et al., 2002]. 

Surface Impoundment Case Study: 

Gibson Lake and Cane Ridge Wildlife Management 

Area (WMA) Gibson County, Indiana 

 Gibson Lake is a large (3,000-acre) man-made 

shallow impoundment that provides cooling water for 

Duke Energy’s Gibson Generating Station located near the 

Wabash River in Gibson County, Indiana. In addition to 

cooling water discharges, the lake also receives ash pond 

effluent. Starting in 1986, least terns, an endangered 

species of migratory birds, began using the dike in Gibson 

Lake as a nesting ground for breeding [Pruitt, 2000]. By 

1993, nearby ash ponds at the Gibson Generating Station 

were also attracting nesting least terns, placing these 

sensitive species in direct contact with coal combustion 

wastewater. To address the attractive nuisance problem 

presented by the ash ponds and Gibson Lake, the Gibson 

Generating Station began a cooperative program with the 

Indiana Department of Natural Resources to protect the 

nesting birds by creating a nearby alternative habitat 

known as the Cane Ridge WMA [Pruitt, 2000]. To create 

the new habitat, water from Gibson Lake was pumped into 

ponds at the Cane Ridge WMA. 

 In April of 2007, Duke Energy closed access to 

Gibson Lake for recreational fishing due to elevated 

selenium levels [Duke Energy, 2007]. Selenium levels in 

the lake fish presented a human health risk based on 

EPA’s recommended concentration for subsistence fishers. 

A year later, the U.S. Fish and Wildlife Service (USFWS) 

became concerned about selenium levels in the water and 

fish present in the Cane Ridge WMA. A result, the 

USFWS decided to immediately stop the flow of water 

from Gibson Lake into Cane Ridge, discourage least terns 

from using the refuge, draw down the water in the ponds, 

and remove the contaminated fish [USFWS, 2008]. In 

addition, the pond bottom was plowed to redistribute and 

bury the selenium in the soil and water was piped in from 

the Wabash River, instead of from Gibson Lake. Duke 

Energy paid to stock the Cane Ridge ponds with fathead 

minnows to lure back migratory birds. As of June 2009 

avocets, dunlins, black terns, Forster's terns, Caspian terns 

and 50 endangered least terns have returned to Cane Ridge 

[USFWS 2009]. 6.3 Types of Environmental Effects

The discharge of coal combustion wastewater from coal-fired power plants has caused a 

wide range of environmental effects to local aquatic life. Studies have documented numerous 

ecological impacts from the intentional and accidental release of coal combustion wastewaters, 

as well as through detailed laboratory and field studies examining the toxicity of the 

characteristics of coal combustion wastewater. Environmental effects documented in the 

literature can be broken into the following three categories: 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

• Lethal effects – fish kills and mortality to other organisms; 

• Sublethal effects – histopathological changes, or accumulation of trace elements 

in tissue, and damage to reproductive and developmental success; and 

• Population and community effects – changes in species abundance and 

composition. 

In addition to a direct impact on aquatic ecology and local wildlife, coal combustion 

wastewater has also resulted in other environmental impacts such as altering local habitats, 

contaminating drinking water, and resulting in fish advisories. 

Lethal Effects Case Study: 

Hyco Reservoir, North Carolina 

 Hyco Reservoir is a large cooling reservoir 

located in Roxboro, North Carolina. In addition to 

receiving cooling tower blowdown, the reservoir also 

received effluent from fly ash basins prior to 1981. In the 

fall of 1981, a large-scale fish kill occurred in the reservoir 

prompting numerous scientific studies to examine the 

extent and cause of the environmental damage. 

 In a 1981 study conducted by Carolina Power & 

Light, fish and water chemistry samples were collected in 

the reservoir to evaluate the cause of the fish kill. Water 

samples indicated that dissolved selenium concentrations 

were quite high (up to 5.5 ppb), whereas concentrations of 

other coal combustion wastewater-derived trace elements 

were not elevated. Similarly, fish tissue samples exhibited 

high concentrations of selenium, while other trace 

elements were within normal concentration ranges. 

Bluegill fish livers were found to have selenium 

concentrations approximately 50 times greater than liver 

concentrations found in fish not exposed to water from 

Hyco Reservoir. While other coal combustion wastewaterderived trace elements may also contribute to lethal 

effects, this case study indicates that elevated selenium 

concentrations from coal combustion wastewater can 

result in lethal effects, such as fish kills. 

6.3.1 Lethal Effects 

Fish kills are one of the most 

common lethal effects documented in the 

literature from exposure to coal 

combustion wastewater. In many cases, 

fish kills are the result of the accidental 

release of coal combustion wastewater; 

however, fish kills have been associated 

with the intentional discharge of coal 

combustion wastewater. In a number of 

these documented fish kills, coal 

combustion wastewater was discharged 

to what appeared to be a healthy aquatic 

habitat until lethal effects such as fish 

kills were observed in the system. For 

example, in 1978 the Texas Utilities 

Generating Company located in Martin 

Creek, Texas, began discharging coal 

combustion wastewater from two fly ash 

settling ponds into a 2,000-hectare 

cooling water reservoir located on the 

facility’s property. Within eight months 

after the discharges began, a major fish 

kill occurred in the reservoir prompting 

Texas Utilities to cease discharging coal combustion wastewater into the reservoir. The sudden 

appearance of fish kills and other ecological effects, such as developmental abnormalities and 

reproductive failure, in aquatic systems receiving coal combustion wastewater prompted 

numerous research studies to identify the extent of damage and the specific cause. In a 1981 

study conducted by Carolina Power and Light Company, Environmental Services Station at 

Hyco Reservoir, scientists concluded that elevated selenium concentrations were likely the 

primary factor contributing to fish kills and to lethal effects towards amphibians and crustaceans 

[Rowe et al., 2002]. Long-term studies of aquatic environments exposed to coal combustion 

wastewater found that, after experiencing fish kills, the affected environments can experience 

population and community effects for many years before biomass returns to normal levels [Rowe 

et al., 2002]. 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

Laboratory and outdoor mesocosm studies have confirmed that both acute and chronic 

exposure to coal combustion wastewater can be lethal to a wide range of aquatic organisms. For 

example, in a 1976 study by Guthrie and Cherry, shrimp darters and salamanders were found to 

be highly sensitive to acute exposures of coal combustion wastewater. In the study, shrimp 

darters and salamanders caged for five days in a drainage basin outflow located on the D-Area 

Power Facility grounds experienced nearly 100 percent mortality [Rowe et al., 2002]. 

Invertebrates and fish in the study were also affected by the exposure to coal combustion 

wastewater; however, they reported lower rates of mortality [Rowe et al., 2002]. In a 2001 study 

by Hopkins, juvenile chubsuckers (a benthic fish) demonstrated a high sensitivity to chronic 

exposure to coal combustion wastewater [Rowe et al., 2002]. In this outdoor mesocosm study, 

organisms were exposed to sediments, water, and food from the D-Area Power Facility grounds, 

and experienced a 75 percent mortality rate after 45 days. These studies and others indicate that 

the lethal effects of coal combustion wastewater exposure can be quite potent, even though 

extreme differences in species sensitivity have been observed [Rowe et al., 2002]. 

6.3.2 Sublethal Effects 

Sublethal effects from exposure to coal combustion wastewater can vary widely and 

include changes that impact growth, reproduction, and survival of susceptible organisms. 

Numerous vertebrate and invertebrate species have demonstrated a sensitivity to coal combustion 

wastewater and developed sublethal conditions such as increased metabolic rates, decreased 

growth rates, abnormal teeth and fin morphology, accumulation of trace elements in tissue, and 

reproductive failure [Rowe et al., 2002]. Sublethal effects documented in the literature are 

primarily linked to exposure to selenium concentrations present in coal combustion wastewater; 

however, sublethal effects have also been attributed to a number of other coal combustion 

wastewater pollutants such as arsenic, cadmium, chromium, copper, and lead [Rowe et al., 

2002]. 

Histopathological effects (i.e., accumulation of trace elements in tissue), increased 

metabolic rate, and decreased growth rates are typical growth effects caused by coal combustion 

wastewater contamination. Water and fish samples collected before and after the discharge of 

coal combustion wastewater to the Texas Utilities Martin Creek Reservoir found that selenium 

concentrations were significantly elevated in the reservoir and in fish livers, kidneys, and gonads 

[Rowe et al., 2002]. In 1984, Garrett and Inman reported that elevated selenium concentrations 

persisted in the livers and kidneys of several species of fish for up to three years after the coal 

combustion wastewater discharges ceased [Rowe et al., 2002]. Additionally, a 1988 study by 

Sorensen found that red ear sunfish native to the reservoir exhibited ovary abnormalities related 

to elevated selenium concentrations up to eight years following the brief exposure to coal 

combustion wastewater [Rowe et al., 2002]. Although the ash pond discharge was short-lived 

(i.e., eight months), many of the histopathological effects persisted for years after the discharge 

had ceased [Rowe et al., 2002]. 

Fish are not the only organisms with documented sublethal impacts from exposure to coal 

combustion wastewater. Several studies have demonstrated increased metabolic rates and 

decreased growth rates in crustaceans exposed to coal combustion wastewater. In Rowe’s 1998 

study, grass shrimp caged in situ in the D-Area Power Facility’s secondary settling basin 

experienced a 51 percent increase in standard metabolic rate after eight months [Rowe et al., 

2002]. Similarly, crayfish captured in the vicinity of the secondary basin as well as crayfish 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

collected from unpolluted sites and exposed to sediments and food collected from the secondary 

basin both experienced increased metabolic rates and decreased growth rates. These changes in 

metabolism reflect that the organism wastes energy during normal metabolic processes in 

response to contaminant exposure and accumulation [Rowe et al., 2002]. 

Exposure to coal combustion wastewater has caused a number of organisms to experience 

reproductive failure and other forms of diminished reproductive success. A 1986 study by 

Gillespie and Baumann at Hyco Reservoir found that bluegill sunfish exposed to coal 

combustion wastewater accumulated selenium in ovarian tissue. Affected sunfish produced 

edematous, or fluid-swelled, larvae that died before maturing [Rowe et al., 2002]. Maternal 

transfer of coal combustion wastewater pollutants to offspring has been observed for several 

species. A 2001 study conducted by Nagle et al. at the D-Area Power Facility found that turtles, 

alligators, and birds inhabiting the vicinity of the settling basins and drainage swamp transfer 

coal combustion wastewater contaminants to developing offspring [Rowe et al., 2002]. Nagle et 

al., however, concluded that this transfer of contaminants did not cause any noticeable biological 

ramifications [Rowe et al., 2002]. 

Morphological changes that affect survival have also been observed for organisms 

exposed to coal combustion wastewater. A 2003 laboratory study by Hopkins et al. found that 

the sustained swimming speed and burst swimming speeds of the lake chubsucker (fish) were 

greatly reduced when exposed to coal combustion wastewaters [Rowe et al., 2002]. This 

reduction in speed was caused by fin abnormality, a morphological change that can be attributed 

to exposure to coal combustion wastewater [Rowe et al., 2002]. A study of larval bullfrogs living 

in the D-Area Power Facility’s secondary settling basin found that more than 95 percent of 

individuals had abnormal oral structures, such as the absence of grazing teeth or entire rows of 

teeth. Rowe et al.’s 1996 study found that these oral malformations changed the feeding ecology 

of the affected individuals, limiting their feeding niche and subsequently reducing their growth 

rate [Rowe et al., 2002]. A 1998 study by Raimondo et al. found that larval bullfrogs also 

displayed abnormal swimming behavior, which was caused by malformations of their tails 

[Rowe et al., 2002]. These abnormal larval bullfrogs, living in the secondary basin of the DArea, were more frequently preyed upon than were bullfrogs from an unpolluted site [Rowe et 

al., 2002]. 

6.3.3 Population and Community Effects 

In addition to environmental effects on individual organisms, coal combustion 

wastewater has the potential to modify higher-order ecological processes (i.e., population and 

community dynamics) in the surrounding ecosystems. Changes to the number of aquatic 

organisms and wildlife present in a system, interspecies interactions, and the structure of aquatic 

communities have all been linked to contamination of aquatic habitats by coal combustion 

wastewater [Rowe et al., 2002]. 

Numerous studies have documented the decline in invertebrates, fish, and local wildlife 

populations following exposure to coal combustion wastewater [Rowe et al., 2002]. Population 

effects (i.e., decline in number of organisms present) have been attributed to lethal effects of 

pollutants present in coal combustion wastewater, declines in organism survival rates from 

abnormalities attributed to coal combustion wastewater exposure, and declines in the abundance 

or quality of prey. For example, many species of benthic fish rely on small invertebrates as a 

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Final Detailed Study Report Chapter 6 – Environmental Assessment of Coal Combustion Wastewater 

source of food and, when the food source is diminished (i.e., lower invertebrate abundance and 

density), benthic fish exhibit higher mortality rates and smaller growth than fish exposed to coal 

combustion wastewater with high quality food sources [Rowe et al., 2002]. In a 1980 study of 

Rocky Run Creek by Forbes and Magnuson, fungal decomposition of detritus was extremely 

limited due to the effects of coal combustion wastewater. Benthic invertebrates, which graze on 

detrital material, displayed a lower population density as a result. Similarly, benthic fish that 

prey upon small invertebrates exhibited increased mortality due to a reduction in available 

resources, and therefore a decreased population density [Rowe et al., 2002]. 

In addition to density effects, communities have experienced alterations in species 

diversity due to exposure to coal combustion wastewater. In the Martin Creek Reservoir, during 

a short eight-month period of coal combustion wastewater input, both planktivorous (i.e., diet 

primarily consists of plankton) and carnivorous (i.e., diet primarily consists of meat) fish 

experienced severe reductions in total biomass, while omnivorous (i.e., diet consists of meat and 

plants) fish increased in biomass [Rowe et al., 2002]. A study by Garrett and Inman in 1984 

found that in the three years after the effluent release was halted, planktivorous fish populations 

remained extremely low, while carnivorous fish populations nearly recovered. This recovery 

occurred because carnivorous fish have a more diverse diet than planktivorous fish, so food 

availability increased relatively quickly as the aquatic system recovered [Rowe et al., 2002]. 

These changes in population diversity indicate a significant change in community structure as a 

result of exposure to coal combustion wastewater. 

In contrast to the Martin Creek Reservoir studies, coal combustion wastewater can also 

affect species diversity in the top predators of the food chain. In 1993, a study conducted by 

Lemly at Belews Lake found that large predatory fish were some of the first fish species to die 

out completely, due to the lethal and sublethal effects of coal combustion wastewater exposure 

[Rowe et al., 2002]. Because a top predator was no longer present, some fish that exhibited 

developmental abnormalities were able to survive, despite their otherwise high susceptibility to 

predation [Rowe et al., 2002]. 

Density and diversity effects caused by coal combustion wastewater contamination have 

the potential to be wide-ranging geographically. A 1972 study by Cairns et al. examined the 

effects of an ash effluent spill from the AEP Clinch River Power Plant into the Clinch River in 

Virginia. A dike surrounding an ash settling pond collapsed, releasing effluent with a pH greater 

than 12.0 and killing more than 200,000 fish. The study observed drastic reductions in both 

diversity and densities of aquatic organisms [Carlson and Adriano, 1993]. A follow-up survey 

taken two years after the spill indicated that some recovery was occurring, but the diversity and 

density of benthic fauna was still greatly reduced downstream from the spill [Carlson and 

Adriano, 1993]. 

6.3.4 Human Health Impacts 

In addition to the individual and community ecological impacts discussed above, coal 

combustion wastewater has been linked to human health concerns as a result of elevated 

pollutant concentrations in surface water and groundwater, which have resulted in fish advisories 

and groundwater that has exceeded SDWA MCLs. 

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6-18 

Metals and other pollutants present in coal combustion wastewater may contaminate 

actual or potential drinking water sources by leaching from surface impoundments or landfills 

into groundwater or surface waters. For example, at the Chisman Creek Disposal Site, a fly ash 

landfill in Virginia, water in nearby residential wells turned green and testing revealed the wells 

were contaminated with selenium and sulfate from groundwater contaminated with leachate from 

coal combustion wastewater [NRC, 2006]. EPA closed the residential wells to reduce the risk of 

human exposure to coal combustion pollutants [NRC, 2006]. EPA’s ORCR has documented 

instances where coal combustion wastewater contaminated groundwater at concentrations 

exceeding EPA’s MCL for drinking water [U.S. EPA, 2007c]. Although the contaminated 

groundwater sources may not directly be used as a drinking water source in all cases, the 

contamination represents a possible human health risk due to the potential for groundwater to 

impact other nearby aquifers and surface waters designated as drinking water sources. 

EPA has also identified cases of human health concerns related to coal combustion 

wastewater causing elevated pollutant concentrations in biota. Fish consumption advisories are 

the most common human health concern and are issued in response to elevated pollutant 

concentrations in fish that are considered unsafe for human consumption. In 1992, the Texas 

Parks and Wildlife Department’s monitoring program documented elevated levels of selenium in 

fish at the Southwestern Electric Power Company Welsh Reservoir in Mount Pleasant, Texas. 

The reservoir received influent from ash settling ponds, which was the likely source of high 

selenium levels. In response to these elevated levels, the Texas Commissioner of Health issued a 

fish advisory that lasted for 12 years before it was lifted. A similar case identified by EPA 

occurred in the Brandy Branch Reservoir in Marshall, Texas. The cooling reservoir received ash 

pond effluent from Southwestern Electric Power Company’s Pirkey Power Plant [U.S. EPA, 

2007c]. Studies by the Texas Parks and Wildlife Department reported that average selenium 

concentrations in fish nearly tripled between 1986 and 1989, once coal combustion wastewater 

discharges began [U.S. EPA, 2007c]. The Texas Department of Health issued a fish consumption 

advisory that lasted from 1992 to 2004 [U.S. EPA, 2007c]. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7. PRELIMINARY INVESTIGATION OF OTHER INDUSTRY SEGMENTS

As described in Chapter 3, the electric generating industry is generally categorized by 

NAICS Code 2211. However, prior to the introduction of NAICS codes, the electric generating 

industry had been categorized by three Standard Industrial Classification (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 percent 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. 

It should be noted that these SIC codes include all electric generating plants, not just 

steam electric plants. For example, some of the plants included in SIC code 4911 generate 

electricity solely by way of combustion turbines or hydroelectric turbines (i.e., steam is not used 

to move the turbine). EPA did not investigate the operations at power plants that do not use a 

water/steam thermodynamic medium to generate electricity (e.g., combustion turbines, 

hydroelectric plants). However, during the detailed study, 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 are not currently subject to the effluent guidelines. 

EPA assessed information regarding the following types of plants and operations: 

• Plants that generate electric power using steam to drive a turbine, but whose 

energy/heat source used to produce the steam is not a fossil or nuclear fuel 

(referred to in this report as “alternative-fueled” plants). These energy sources 

may include combustible fuels (e.g., municipal solid wastes, wood and wood 

wastes, landfill gas) or other energy sources, such as solar power and geothermal 

energy. 

• Industrial plants that generate electric power using steam to drive a turbine, but 

that are not primarily engaged in distributing and/or selling that electric power 

(referred to in this report as “industrial non-utilities”). These industrial steam 

electric non-utilities provide electric power to an industrial process (e.g., chemical 

manufacturing, petroleum refining) and in some cases may sell excess electrical 

power to the grid. EPA’s focus for these plants is on the waste streams generated 

by the electric generating units, and not the other waste streams generated by the 

primary industrial processes at the plant. 

• Plants that generate steam for distribution and/or sale, but that do not primarily 

use that steam to drive a turbine and produce electric power (referred to in this 

report as “steam and air conditioning supply” plants). 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

• Plants that provide a combination of electric power and other utility services (i.e., 

SIC Code 4939 - referred to in this report as “combination utilities”). EPA 

specifically focused on those combination utilities that generate electric power by 

using steam to drive a turbine. 

This chapter describes the information EPA obtained during the detailed study regarding 

these types of operations and resulting wastewaters. Section 3.1 provides additional definitions 

and demographics for the electric generating industry. 

7.1 Alternative-Fueled Steam Electric Plants

This section describes EPA’s study of alternative-fueled steam electric plants, which 

produce electricity for distribution and/or sale using steam that is created by means other than 

fossil-fueled or nuclear-fueled processes. In this report, alternative-fueled steam electric plants 

refer to those plants that produce steam by combusting a solid or gaseous alternative fuel, those 

that use steam from geothermal reservoirs (geothermal steam electric plants), and those that 

produce steam using the sun’s energy (solar steam electric plants). 

EPA reviewed NPDES permits for a prioritized subset of alternative-fueled steam electric 

plants to identify sources of wastewater and determine how wastewater discharges from these 

plants are currently regulated (e.g., whether the Steam Electric Power Generating effluent 

guidelines are applied using best professional judgment (BPJ)). Additionally, EPA contacted 

several companies operating alternative-fueled steam electric plants to discuss the operations and 

wastewaters generated at the plants related to steam or electricity production. 

Wastewater generated by alternative-fueled steam electric processes is not currently 

regulated by the Steam Electric Power Generating effluent guidelines, because the electricity 

does not result “...primarily from a process utilizing fossil-type fuel (coal, oil, or gas) or nuclear 

fuel...”, as defined at 40 CFR Part 423.10. Information that EPA obtained during the detailed 

study indicate that these alternative-fueled plants use similar processes to plants that are 

regulated under the Steam Electric Power Generating effluent guidelines. In fact, many of these 

alternative-fueled plants also combust fossil fuels as a secondary energy source to generate the 

steam (40 percent of plants), typically within the same generating unit and typically natural gas 

or oil instead of coal. Because many of the waste streams generated from the operation of 

combustion processes are associated with the handling of fuel wastes (e.g., ash transport water), 

the characteristics of the wastewaters may vary depending on the type of fuel used by the plant. 

During the detailed study, EPA collected little information about the pollutants and 

associated concentrations in the wastewater discharged from steam electric processes using 

alternative fuels. However, EPA determined that these plants generally produce a much smaller 

amount of electricity and discharge a smaller amount of wastewater to the environment than 

steam electric plants regulated by the Steam Electric Power Generating effluent guidelines. EPA 

also determined that permits regulating the discharges from alternative-fueled plants vary from 

plant to plant and are dependent on both the type of fuel used and the handling of the 

wastewaters generated. EPA found that some of the permits reviewed contained few limits based 

on the Steam Electric Power Generating effluent guidelines, while others wholly incorporate the 

Steam Electric Power Generating effluent guidelines limits. 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7.1.1 Demographic Data for Alternative-fueled Steam Electric Plants 

The 2005 EIA database includes 198 plants that reported a NAICS code of 22 (Utilities) 

and the use of an alternative fuel as a primary energy source to drive a steam turbine. Some of 

these plants use alternative fuels in combination with a fossil-type (i.e., 423-type) fuel. Three of 

the 198 plants reported operating an electric generating unit burning a fossil fuel as a primary 

energy source, in addition to the electric generating unit(s) burning alternative fuels. Seventy-six 

of the 198 plants reported using both an alternative fuel and a fossil fuel to power the same 

generator (the fossil fuel is reported as the secondary or tertiary energy source); however, these 

secondary fossil fuel energy sources may be serving as a starter or supplemental fuel in the 

boiler. 

The average electric generating capacity for alternative-fueled plants in the 2005 EIA 

database is less than 50 MW. Excluding geothermal steam electric plants, the 156 alternativefueled plants produce less than one percent of the electricity produced by the fossil- and nuclearfueled steam electric plants currently regulated by the Steam Electric Power Generating effluent 

guidelines. EPA did not include geothermal steam electric plants in this calculation because they 

are assumed not to directly discharge wastewater [CEPA, 2006d; CEPA, 2006c; U.S. DOE, 

2006a]. Table 7-1 presents a breakdown of plant energy capacity by fuel type. Section 3.1.2.2 of 

this report provides additional detail on the demographics of the Steam Electric Power 

Generating Point Source Category. 

EPA is not aware of any analyses demonstrating that pollutant loadings are correlated to 

electric power generated; however, EPA believes it is reasonable to assume that alternativefueled plants will produce smaller pollutant loadings than those produced by steam electric 

plants with energy capacities that are one or two orders of magnitude larger. 

7.1.2 Alternative-Fueled Steam Electric Fuel Types and Processes 

The steam electric generating process used at alternative-fueled steam electric plants is 

similar to that used by all steam electric plants, as described in Section 3.2, in that these plants 

use a steam/water system as the thermodynamic medium to produce electricity. Alternativefueled steam electric plants use steam (which may or may not be produced in a boiler) to drive a 

steam turbine/electric generator and condense the steam by noncontact cooling. 

Because the alternative-fueled process operations are similar to those of the steam electric 

plants regulated under the Steam Electric Power Generating effluent guidelines, they may 

generate many of the same types of wastewaters (e.g., ash transport water, boiler blowdown, 

cooling water). Because there are similar operations between the different types of plants, the 

wastewaters that do not directly contact the fuel (i.e., boiler blowdown, cooling water) may have 

similar pollutant characteristics. Because these wastewaters are not associated with the fuels used 

at the plant, they are likely to be similar in characteristics to the wastewaters generated by the 

steam electric plants regulated under the Steam Electric Power Generating effluent guidelines. 

The wastewaters that do contact the fuel (e.g., fuel storage runoff) or the fuel wastes (ash 

transport water) may not have similar characteristics as the wastewaters generated by steam 

electric plants regulated under the Steam Electric Power Generating effluent guidelines because 

the different fuels have different constituents. 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

Table 7-1. Summary of Alternative-Fueled Steam Electric Plants, by Fuel/Energy Source 

Type 

Fuel/Energy Source Number of Plants 

Total Capacity a

(MW) 

Steam Electric Plants Regulated Under the Steam Electric Power Generating effluent guidelines

Fossil and Nuclear Fuel 1,187 762,000 

Alternative-Fueled Steam Electric Plants

Municipal Solid Waste 59 2,270 

Wood Solid Waste 66 1,830 

Solar 9 400 

Landfill Gas 12 261 

Agricultural By-products 5 184 

Other Biomass Solids 2 58 

Tires 2 57 

Other Biomass Gas 1 23 

Total for Alternative-Fueled Facilities (excluding Geothermal) 156 b 5,080 

Geothermal c 42 2,950 

Source: [U.S. DOE, 2005a]. 

Note: The table includes only the capacity associated with stand-alone steam turbines, combined cycle steam 

turbines, combined cycle single shaft turbines, and combined cycle combustion turbines. 

a – The capacities represent the reported nameplate capacity. The capacities presented have been rounded to three 

significant figures. Due to rounding, the total capacity may not equal the sum of the individual capacities. 

b – It is possible that some of these 156 alternative-fueled plants may be cogeneration plants, as discussed in Section 

3.2.1. 

c – Steam electric processes using geothermal energy sources are assumed not to generate wastewater [CEPA, 

2006d; CEPA, 2006c; U.S. DOE, 2006a]. 

The steam electric process, sources of wastewater, potential wastewater pollutants, 

current operating practices, and current permitting practices for various types of alternativefueled steam electric plants are discussed below by type of fuel. 

7.1.2.1 Solid Fuels 

Steam electric plants fueled by solid alternative fuels (e.g., municipal solid waste (MSW), 

wood solid waste, agricultural by-products, tires) use a similar process as those plants that are 

currently regulated under the Steam Electric Power Generating effluent guidelines. These 

alternative-fueled steam electric plants combust a solid fuel, typically in a boiler, to produce 

steam, which powers a steam turbine/electric generator. This combustion process generates ash. 

The steam exiting the turbine is condensed with cooling water and the condensate is typically fed 

back to the boiler. Thus, steam electric plants fueled by solid alternative fuels generate some of 

the same types of wastewaters as those currently regulated under the Steam Electric Power 

Generating effluent guidelines. As described in Section 3.2.1, these wastewaters include fly ash 

and/or bottom ash transport water, metal cleaning wastes, once-through cooling water and/or 

recirculating cooling tower blowdown, fuel storage runoff, boiler feedwater treatment wastes, 

boiler blowdown, and other low-volume wastes [CEPA 2006a; CEPA, 2006b; U.S. DOE, 2000a; 

IDNR, 2006a; Fairfax, 2006; U.S. EPA, 2006i; FDEP, 2006]. 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

The types of solid alternative fuels included in EPA’s study of alternative-fueled steam 

electric plants are discussed below. 

Municipal Solid Waste 

Typical constituents of MSW include paper, paperboard, yard waste, plastics, metals, 

glass, food waste, wood, rubber, leather, and textiles. Refuse-derived fuel is produced from 

MSW through processing steps such as, at a minimum, coarse shredding of the MSW and 

magnetic separation of ferrous metals [Kirk-Othmer, 2000]. 

At the time of the initial 1974 Steam Electric Power Generating effluent guidelines, EPA 

identified one steam electric plant in the United States as using refuse-derived fuel for 10 percent 

of its fuel [U.S. EPA, 1974]. As shown in Table 7-1, there were 59 plants operating electric 

generating units powered by municipal solid waste in 2005 [U.S. DOE, 2005a]. The 1974 

Development Document stated that incinerating “garbage” produces moderate amounts of 

hydrogen chloride, and that EPA should continue to study the disposal of the effluents from 

steam electric plants using these alternative fuels. 

During the detailed study, EPA obtained data on the pollutant concentrations found in 

MSW ash, wood ash, and coal ash. Although the compositions of these ashes vary significantly 

depending on the type of material that is combusted and the location that the ash is sampled (e.g., 

fly ash, bottom ash), EPA noted general differences between MSW ash and coal ash. Table 7-2

presents the range of concentrations associated with both the bottom and fly ash generated from 

coal ash, MSW ash, and wood ash (which is discussed below). As shown in Table 7-2, MSW ash 

can contain significantly higher amounts of barium, cadmium, mercury, molybdenum, nickel, 

selenium, and zinc than coal ash. 

Table 7-2. Comparison of Available Coal Ash, Municipal Solid Waste Ash, and Wood Ash 

Composition Data 

Component 

Coal Ash 

(ppm) 

Municipal Solid Waste Ash

(ppm) 

Wood Ash 

(ppm) 

Aluminum 60,000 - 157,000 NIA NIA 

Antimony NIA NIA 9 - 11.58 

Arsenic 10.4 - 169.6 2.9 - 50 1 - 28.5 

Barium 210 - 310 79 - 2,700 130 - 527 

Beryllium NIA ND - 2.4 ND - 2 

Boron 14 - 618 24 - 174 1 - 16.9 

Cadmium 7 - 10 0.18 - 100 1 - 16 

Calcium 3,100 - 125,600 NIA NIA 

Chloride NIA NIA 382.35 – 3,200 

Chromium (III) NIA NIA 43 

Chromium (VI) NIA NIA 0.7 - 4 

Chromium - Total NIA 12 - 1,500 16.8 - 33.55 

Cobalt NIA 1.7 - 91 4.6 - 20 

Copper NIA 40 - 5,900 31.3 - 176.5 

Cyanide NIA NIA 0.08 - 6 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-6 

Table 7-2. Comparison of Available Coal Ash, Municipal Solid Waste Ash, and Wood Ash 

Composition Data 

Component 

Coal Ash 

(ppm) 

Municipal Solid Waste Ash

(ppm) 

Wood Ash 

(ppm) 

Iron 3,000 - 163,000 NIA NIA 

Lead NIA 31 - 36,600 7.7 - 142.5 

Magnesium 900 - 60,200 700 - 16,000 NIA 

Manganese NIA 14 - 3,130 NIA 

Mercury ND - 0.08 0.05 - 17.5 ND - 0.6 

Molybdenum 5.6 - 39.3 2.4 - 290 3.0 - 14 

Nickel 123 - 242 13 - 12,910 11 - 50 

Phosphorus 300 - 2,800 NIA NIA 

Potassium 6,500 - 31,900 NIA 23,220 - 59,918 

Selenium 7.6 - 36.1 0.1 - 50 ND - 20 

Silicon 302,000 - 331,000 NIA NIA 

Silver NIA NIA ND - 4 

Sodium 560 - 1,200 NIA 934.25 - 3,110 

Strontium NIA 12 - 640 NIA 

Thallium NIA NIA ND - 70.5 

Titanium 7,700 - 11,600 NIA NIA 

Vanadium NIA NIA 22 - 27 

Zinc 13 - 378 92 - 46,000 130 - 886 

Source: [Evangelou, 1996; Otero-Rey, 2003; Narukawa, 2003; Kirk-Othmer, 2000; CEPA, 2006b; WAI, 2003]. 

ND - Not detected. 

NIA – No information available. 

To obtain additional information about the process operations and wastewaters generated 

from MSW plants, EPA reviewed EIA information and contacted two companies that operate 

MSW plants. According to information EPA obtained from EIA and these two companies, most 

of these plants operate dry FGD systems and baghouses or ESPs to remove the fly ash, sulfur 

dioxide, hydrogen chloride, and hydrogen fluoride from the flue gas. At these plants, the 

particulates collected in the baghouse or ESP are handled dry and transported to a landfill. The 

bottom ash aggregate generated in the boiler is quenched in a water bath, which is drained, and 

the quenched aggregate then goes through the metal recovery process and is transported to a 

landfill. The water that drains off of the bottom ash is reused in the water bath. Therefore, most 

of these plants do not generate and/or discharge FGD or ash transport water waste streams. 

Additionally, some of the other wastewaters generated during the process (e.g., boiler blowdown, 

cooling tower blowdown, low-volume wastewaters) are often reused as make-up water for the 

bottom ash quench process or discharged indirectly to municipal wastewater treatment plants. 

Therefore, it appears these MSW plants may discharge fewer, if any, wastewater streams directly 

to surface waters than plants regulated by the Steam Electric Power Generating effluent 

guidelines [Covanta, 2009; Xcel Energy, 2009c; Xcel Energy, 2009d]. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

Wood Solid Waste 

Wood wastes combusted in steam electric processes typically consist of chipped lumber 

and residuals from sawmills or other forest industry operations, including bark, trim ends, 

sawdust, and planer shavings [Kirk-Othmer, 2000]. 

EPA obtained data on the pollutant concentrations found in wood ash, which is presented 

in Table 7-2. As with MSW ash, EPA noted general differences between wood ash and coal ash. 

Wood ash generally has a lower metal content (e.g., arsenic, boron, molybdenum, nickel, and 

selenium) than coal ash; however, as shown in Table 7-2, wood ash often contains higher 

amounts of potassium and zinc, and may contain slightly higher amounts of barium, cadmium, 

and mercury, than coal ash. 

To obtain additional information about the process operations and wastewaters generated 

from wood solid waste plants, EPA contacted two companies that operate these types of plants. 

According to information EPA obtained from the two companies, some of these plants operate 

dry FGD systems and baghouses. However, not all of the plants operate a dry FGD system; some 

just operate the baghouse. These systems remove the fly ash, sulfur dioxide, and hydrogen 

chloride from the flue gas. The particulates that collect in the baghouse are handled dry and 

transported to a landfill or beneficially reused. The bottom ash is typically handled dry, but if it 

is handled wet, the water is drained from the solids and reused in the process. Therefore, these 

types of plants do not generate and/or discharge any FGD or ash transport water waste streams. 

The wastewaters that are typically discharged from these plants, indirectly to municipal 

wastewater treatment plants in some cases, consist of cooling tower blowdown, boiler 

blowdown, wash waters associated with operation areas, and other low-volume wastewaters 

[Xcel Energy, 2009a; Xcel Energy, 2009b; U.S. Renewables Group, 2009]. 

Agricultural By-Products 

Typical types of agricultural by-products combusted in steam electric processes include 

bagasse (plant residue) from sugar-refining operations, rice hulls, orchard and vineyard prunings, 

cotton gin trash, and the by-products of many other food and fiber-producing operations. 

Agricultural wastes are relatively low in metals content, and the ash often contains a lower 

metals content than coal and wood ash [Kirk-Othmer, 2000]. 

Tires 

Scrap tires can be combusted in steam electric processes either in shredded form, which 

is known as tire-derived fuel, or as whole tires. Scrap tires, which have a high heating value, are 

often used as a supplement to other fuels, such as coal or wood. Tires produce roughly the same 

amount of energy as oil and roughly 25 percent more energy than coal, by weight. The ash 

residues from tire-derived fuel may contain lower heavy metals content than some coals [U.S. 

EPA, 2006i]. 

7.1.2.2 Gaseous Fuels 

Steam electric plants fueled by gaseous alternative fuels (e.g., landfill gas) use a similar 

process as those plants that are fueled by natural gas or other gases and are currently regulated 

under the Steam Electric Power Generating effluent guidelines. These alternative-fueled steam 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

electric plants combust a gaseous fuel in a boiler to produce steam, which powers a steam 

turbine/electric generator; however, like the natural gas combustion process, the gaseous 

alternative fuel combustion process does not generate ash. The steam exiting the turbine is 

condensed with cooling water and the condensate is typically fed back to the boiler. Thus, steam 

electric plants fueled by gaseous alternative fuels generate some of the same types of 

wastewaters as those currently regulated under the Steam Electric Power Generating effluent 

guidelines and described in Section 3.2.1 (e.g., boiler blowdown, cooling tower blowdown, lowvolume wastewaters). 

Landfill gas, by volume, consists of approximately 50 percent methane and 50 percent 

carbon dioxide. It also contains small amounts of nitrogen, oxygen, and hydrogen, less than 1 

percent nonmethane organic compounds, and trace amounts of inorganic compounds. The gas is 

generated in landfills as bacteria degrade organic matter. This gas mixture can be captured and 

processed for use as fuel in steam electric plants. During processing, a portion of the nonmethane 

components is typically removed from landfill gas, which results in a fuel with a higher heating 

value [U.S. EPA, 2006g; CEC, 2006]. A steam electric plant fueled with landfill gas is similar to 

a steam electric plant fueled with natural gas in terms of fuel composition (natural gas and 

landfill gas are both composed primarily of methane) and overall process [PDEP, 2006]. Because 

these gaseous fuel operations do not generate wastewaters that contact the fuel or fuel wastes like 

the solid-fueled plants, these plants typically only generate wastewaters such as boiler 

blowdown, cooling water, and other low-volume wastewaters. These wastewaters generally are 

expected to have similar characteristics as the wastewaters generated from the plants regulated 

under the Steam Electric Power Generating effluent guidelines. 

7.1.2.3 Geothermal 

In the geothermal steam electric process, geothermal fluids (typically steam) are extracted 

from geothermal reservoirs and are used to power steam turbine/electric generators. No fuels are 

combusted to produce steam. Steam exiting the turbines is condensed with cooling water and the 

condensate is injected into the geothermal reservoir. Geothermal steam electric plants generate 

steam condensate wastewater and condenser cooling wastes (typically cooling tower blowdown) 

[CEPA, 2006d]. 

EPA addressed geothermal electric generation in developing both the 1974 and 1982 

Steam Electric Power Generating effluent guidelines. The 1982 Development Document states 

that geothermal fluids are disposed of by reinjection to the subsurface geothermal reservoir after 

use [U.S. EPA, 1982]. Permit writers confirmed this statement, indicating that geothermal steam 

electric plants do not typically have NPDES permits because they do not discharge their 

wastewater to surface waters [CEPA, 2006d; CEPA, 2006c]. These plants inject wastewater 

underground into the geothermal steamfield reservoirs for two major reasons [CEPA, 2006d; 

CEPA, 2006c; U.S. DOE, 2006a]. First, injecting water into the steamfield reservoirs is required 

to maintain steam production [CEPA, 2006d; U.S. DOE, 2006a]. Second, the geothermal steam 

condensate from the steam electric generating process contains high levels of salts and metals, 

specifically arsenic and boron, which would be costly to remove to meet limits for discharges to 

surface waters [CEPA, 2006d; CEPA, 2006c]. 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7.1.2.4 Solar 

Solar electric generating plants concentrate sunlight onto receivers using various 

reflecting devices. Heat transfer fluid is heated as it flows through the receivers and is used to 

create steam, which, in turn, is used to create electricity in steam turbines/generators. Most solar 

electric plants that use parabolic trough reflectors to concentrate sunlight (such as the Solar 

Electric Generating Stations plants in the Mojave Desert, CA) generate cooling water, boiler 

blowdown, and demineralizer wastewater. These wastewaters are typically transferred to an 

evaporation pond and are not discharged to surface waters [IEEE, 1989]. Many solar electric 

plants burn natural gas when necessary to meet electrical demands [IEEE, 1989; Kirk-Othmer, 

2000]. 

According to the 1982 Development Document, all solar electric generating plants at that 

time were developmental; however, EPA acknowledged that more systems would be developed 

in the future as traditional fossil fuels were depleted [U.S. EPA, 1982]. Since 1982, the solar 

power technologies have advanced and the 2005 EIA database includes nine solar-powered 

plants (see Table 7-1) [U.S. DOE, 2005a]. 

7.1.3 Summary of NPDES Permit Review 

During the detailed study, EPA obtained NPDES permits for 13 alternative-fueled plants. 

EPA obtained at least one permit for each of the fuels discussed in Section 7.1.2, except solar. 

EPA reviewed the permits to determine the types of wastewaters generated by the plants and 

how the wastewaters were being permitted. 

Based on the limited number of permits reviewed and communications with permitting 

authorities, EPA was not able to determine any trends in the regulation of wastewaters based on 

alternative fuel type; however, EPA was able to make some general observations about the types 

of wastewaters generated at these operations and determine some general trends in the way the 

wastewaters are regulated. 

EPA found that some of the permits reviewed contained relatively few limits based on the 

Steam Electric Power Generating effluent guidelines. In each of these cases, the process 

wastewaters are not discharged directly to surface waters, whereas direct discharge of these 

wastewaters is the typical practice for plants regulated under the Steam Electric Power 

Generating effluent guidelines. Specific examples include geothermal electric wastewaters that 

are reinjected into underground geothermal reservoirs, agricultural-by-product-fueled steam 

electric wastewaters that are discharged to percolation ponds (these are permitted via state 

groundwater monitoring program), and other process wastewaters from indirect dischargers 

(these are usually permitted under a separate state program, not the NPDES program). 

In most cases for direct dischargers, permit writers established limitations using BPJ. The 

bases used for these BPJ limits vary and may include the Steam Electric Power Generating 

effluent guidelines, more stringent state water quality standards, or general permitting 

requirements. Most parameters limited appear to have been selected based on state water quality 

standards. 

A small portion of the permits wholly incorporate the requirements of the Steam Electric 

Power Generating effluent guidelines. These permits are unique in that the plants use a fossil fuel 

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7-10 

in addition to the alternative fuel to generate electricity, or the permit only specifies the use of a 

fossil fuel. In at least one of these cases, the fossil-fueled steam electric wastewaters have 

separate limits than the alternative-fueled steam electric wastewaters. 

7.2 Industrial Non-Utilities

This section describes EPA’s review of plants within various industrial sectors operating 

steam electric generators that produce electricity and/or thermal output primarily to support the 

activities performed at the plant. These industrial non-utilities include cogenerators26, small 

power plants, and other non-utility generators, and generally do not produce electric power for 

distribution and/or sale. 

EPA reviewed NPDES permits for a prioritized subset of industrial non-utilities to 

identify sources of wastewater generated from steam electric processes and determine how the 

wastewater discharges from these operations are currently regulated (e.g., whether the Steam 

Electric Power Generating effluent guidelines are applied as BPJ). Additionally, EPA contacted 

several companies operating electric generating units at their industrial plants to discuss the 

operations and wastewaters generated from the plant related to steam or electricity production. 

The steam electric generating process used at industrial non-utilities is similar to that 

used by all steam electric plants, as described in Section 3.2. A boiler or Heat Recovery Steam 

Generator (HRSG) is used to generate steam that is in turn used (at least in part) to drive an 

electric generator or turbine. Finally, the steam is condensed through noncontact cooling before 

it is returned to the boiler. Additionally, some of the steam generated may be used by the plant 

for other process operations. Since the processes are similar, EPA expects that industrial nonutilities generate wastewater from the same sources as do steam electric plants regulated under 

the Steam Electric Power Generating effluent guidelines. 

Wastewater generated by the steam electric processes at industrial non-utilities is not 

currently regulated by the Steam Electric Power Generating effluent guidelines, because the 

plants are not “...primarily engaged in the generation of electricity for distribution and sale...” 

With the exception of certain instances (e.g., certain subcategories of the Pulp, Paper and 

Paperboard effluent guidelines; see 40 CFR Part 430.01(m)), steam electric wastewaters from 

industrial non-utilities are not directly regulated by effluent guidelines. Information that EPA 

obtained during the detailed study indicate that industrial plants operating steam electric 

generating units use a similar process as those plants currently regulated under the Steam Electric 

Power Generating effluent guidelines. These industrial plants use both fossil and non-fossil fuels 

to generate the steam to drive the turbines. 

The electric generating units at industrial facilities are typically smaller than those at 

plants regulated under the Steam Electric Power Generating effluent guidelines. Additionally, the 

industrial non-utilities burning coal as the primary fuel source typically burn significantly less 

coal than the coal-fired steam electric plants regulated under the Steam Electric Power 

Generating effluent guidelines. Because industrial non-utilities tend to be smaller in terms of 

electric power production and coal usage, the relative volume of wastewater discharged by these 

 

26 A cogenerator is defined as “a generating plant that produces electricity and another form of useful thermal 

energy (such as heat or steam), used for industrial, commercial, heating, or cooling purposes” [U.S. DOE, 2006b]. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

plants associated with electricity generation is likely to be less than that discharged by steam 

electric plants regulated under the Steam Electric Power Generating effluent guidelines. 

The information collected during the detailed study indicates that most industrial plants 

commingle the wastewaters associated with the electric generating units with the other plant 

process wastewaters. Because the wastewaters are commingled, they may be treated in the 

plant’s wastewater treatment system. These commingled wastewaters typically have permit 

limits based on the industry-specific effluent guidelines; the Steam Electric Power Generating 

effluent guidelines limits are typically not used to set BPJ-based limits. 

7.2.1 Overview of Industrial Non-Utilities 

EPA identified industrial non-utilities for this detailed study through data collected in 

2005 by EIA. Industrial plants that operate an electric power generator having at least one MW 

of electric generating capacity report to EIA each year. Included in these data is the plant’s 

primary NAICS code. EPA identified industrial non-utilities in the 2005 EIA data as those 

reporting NAICS codes other than 22 – Utilities. 

EPA examined the 2005 EIA data to determine the relative size of electric generating 

units at industrial non-utilities, as well as the types of fuels used by industrial non-utilities to 

generate the steam. EPA also performed a more detailed analysis of the EIA data for the subset 

of industrial non-utilities that use fossil fuels to power a steam generator. Section 7.2.2 

summarizes the available demographic data for fossil-fueled, steam electric industrial nonutilities. 

According to the 2005 EIA data, there are 855 industrial non-utilities, most of which 

(over 75 percent) produce a relatively small amount of electric power (no more than 50 MW per 

plant) [U.S. DOE, 2005a]. These 855 industrial non-utilities include plants operating both steam 

and non-steam generating units (e.g., stand-alone combustion turbines, internal combustion 

engines, and hydraulic turbines) powered by either fossil or non-fossil fuel types. No nuclearpowered industrial non-utilities were reported to EIA in 2005. 

For comparison, only 10 percent of steam electric plants regulated under the Steam 

Electric Power Generating effluent guidelines each produce less than 50 MW of electricity. In 

fact, nearly half of the Part 423 steam electric plants each generate more than 500 MW of electric 

power [U.S. DOE, 2005a]. Section 3.1.2.2 contains additional information on steam electric 

plants regulated under the Steam Electric Power Generating effluent guidelines. 

Industrial non-utilities may be fueled either by a fossil fuel (e.g., coal, oil, or natural gas) 

or an alternative, non-fossil fuel. The fuels used by these industrial non-utilities are often derived 

from a by-product of the primary industrial process. These non-utilities may also use a 

combination of fossil and non-fossil fuels to power the steam electric generating unit. No 

industrial non-utilities were found to use nuclear fuels [U.S. DOE, 2005a]. 

The following non-fossil fuels were reported to EIA by industrial non-utilities as the 

primary fuel for the steam electric generating unit: 

• Agricultural Crop By-Products, Straw, Energy Crops; 

• Black Liquor; 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-12 

• Municipal Solid Waste; 

• Other Biomass Gases (e.g., digester gas, methane); 

• Other Biomass Solids (e.g., animal manure and waste, solid by-products); 

• Other Fuels (e.g., batteries, chemicals, coke breeze, hydrogen, pitch, sulfur, tar 

coal); 

• Wood Waste Liquids (e.g., red liquor, sludge wood, spent sulfite liquor); and 

• Wood and Wood Waste Solids (e.g., paper pellets, railroad ties, utility poles, 

wood chips). 

In 2005, 160 steam electric industrial non-utilities reported using at least one of these 

non-fossil fuel types. Among these non-fossil fuel types, black liquor and wood and wood waste 

solids were the most prevalently used primary fuels for steam electric power generation by 

industrial non-utilities [U.S. DOE, 2005a]. 

As previously mentioned, it is not uncommon for an industrial non-utility to use more 

than one type of fuel; in fact, these plants often will use a combination of fossil and non-fossil 

fuels to power the same steam electric generating unit. For example, several industrial nonutilities that reported using natural gas as the primary fuel also reported using black liquor and 

other gases as alternates, as did several coal-burning industrial non-utilities. In addition, several 

of the 160 primarily non-fossil-fueled industrial non-utilities reported using coal, oil, or natural 

gas as alternate fuels for the steam electric generating unit [U.S. DOE, 2005a]. 

7.2.2 Demographic Data for Fossil-Fueled Industrial Non-Utilities 

EPA identified industrial non-utilities through data collected in 2005 by EIA for plants 

reporting a primary NAICS code other than 22 – Utilities27. Similar to the analysis of the steam 

electric plants regulated by the Steam Electric Power Generating effluent guidelines described in 

Section 3.1.2.2, EPA used the NAICS code, prime mover, and energy source information 

reported in Form EIA-860 to develop a demographic profile for steam electric industrial nonutilities. EPA identified the subset of industrial non-utilities in the EIA database that are fossilfueled steam electric as those operating at least one prime mover that utilizes steam, produced by 

burning a fossil fuel, to generate electricity. 

Using the criteria for the prime mover type and fossil fuel described above for plants 

reporting a primary purpose/NAICS code other than 22, EPA estimates that 314 fossil-fueled, 

steam-electric, industrial non-utilities reported to EIA in 2005. These plants are estimated to 

operate 813 stand-alone steam generators or combined cycle systems28, which have a total steam 

or combined cycle turbine electric generating capacity of 19,393 MW29 [U.S. DOE, 2005a]. The 

total steam or combined cycle turbine electric generating capacity for all industrial non-utilities, 

including non-fossil fuels, is 25,512 MW [U.S. DOE, 2005a]; therefore, 76 percent of the 

 

27 Additionally, EPA identified 14 plants reporting a NAICS code of 22 that are, in fact, industrial non-utilities. For 

the analyses presented in this report, these 14 plants were placed in the appropriate industrial category and were not 

included in the steam electric industry analyses presented in Section 3.1. 

28 Refer to Section 3.2.9 for a description of the combined cycle system of electric power generation. 

29 The total steam or combined cycle electric generating capacity includes capacity associated with stand-alone 

steam turbines, combined cycle steam turbines, combined cycle single shaft turbines, and combined cycle 

combustion turbines. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-13 

industrial non-utility capacity is associated with fossil fuels. The industrial non-utility steam 

turbine electric generating capacity, including fossil and non-fossil fuels, is less than four 

percent30 of the electricity produced by the steam electric industry regulated under the Steam 

Electric Power Generating effluent guidelines. 

Because not all of the steam generated by industrial non-utilities is necessarily used to 

generate electricity, EPA compared the amount of coal burned by the coal-fired industrial nonutilities to the amount of coal burned by coal-fired steam electric plants regulated under the 

Steam Electric Power Generating effluent guidelines. According to 2005 EIA information, the 

average amount of coal burned by an industrial non-utility is 318,000 tons per year (median is 

182,000 tons) and the average amount of coal burned by a steam electric plant regulated under 

the Steam Electric Power Generating effluent guidelines is 2,155,000 tons per year (median is 

1,221,000 tons) [U.S. DOE, 2005b]. Based on these numbers, EPA expects that the amount of 

wastewater generated by the industrial non-utilities associated with the steam electric process 

operations is substantially less than that generated by steam electric plants regulated under the 

Steam Electric Power Generating effluent guidelines. 

Table 7-3 summarizes the industries that reported industrial non-utilities to EIA in 2005, 

the number of plants, and the number of fossil fuel-burning steam electric generating units. The 

top five industries reporting operation of steam electric generating units, ranked by steam electric 

generating capacity include: 

• Chemical Manufacturing; 

• Paper Manufacturing; 

• Petroleum and Coal Products Manufacturing; 

• Primary Metal Manufacturing; and 

• Food Manufacturing [U.S. DOE, 2005a]. 

The top five industries comprise an estimated 221 non-utilities operating 575 steam or 

combined cycle generating units and producing 16,963 MW of electric power (87 percent of the 

steam electric generating capacity of all fossil-fueled, steam-electric industrial non-utilities 

reported to EIA) [U.S. DOE, 2005a]. The remainder of this section presents more detailed 

demographic information for these five industries. 

 

30 EPA estimates that the total steam electric generating capacity of the steam electric industry regulated under the 

Steam Electric Power Generating effluent guidelines in 2005 was 762,386 MW (refer to Section 3.1.4.2) [U.S. DOE, 

2005a]. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

Table 7-3. Summary of Fossil-Fueled, Steam Electric Industrial Non-Utilities, 

by NAICS Code in 2005 

NAICS Code - Description 

Number 

of Plants 

Number of 

Electric 

Generating 

Units a 

Total Steam and 

Combined Cycle 

Turbine Electric 

Generating Capacity

(MW) b 

Fossil-Fueled and Nuclear Steam Electric Plants Regulated Under 40 CFR Part 423 

22 – Utilities 1,187 2,557 762,386 

Fossil-Fueled Steam Electric Industrial Non-Utilities 

325 - Chemical Manufacturing 55 129 7,535 

322 - Paper Manufacturing 81 169 3,348 

324 - Petroleum and Coal Products Manufacturing 29 69 2,571 

331 - Primary Metal Manufacturing 18 53 2,383 

311 - Food Manufacturing 38 80 1,127 

Total for Top 5 Industries, by Capacity (Percentage of 

Total Fossil-Fueled Industrial Non-Utilities) 

221 

(70%) 

500 

(71%) 

16,963 

(87%) 

611 - Educational Services 33 75 770 

314 - Textile Product Mills 6 15 325 

211 - Oil and Gas Extraction 8 12 261 

212 - Mining (Except Oil and Gas) 3 6 238 

3345 - Navigational, Measurement, Electromedical, and 

Control Instruments Manufacturing 

1 11 200 

92 - Public Administration 5 15 96 

339 - Miscellaneous Manufacturing 2 8 90.7 

327 - Nonmetallic Mineral Product Manufacturing 4 10 83.3 

622 - Hospitals 9 16 83.2 

336 - Transportation Equipment Manufacturing 2 4 64.5 

221 - Utilities c 3 7 43.9 

326 - Plastics and Rubber Products Manufacturing 1 4 40 

481 - Air Transportation 1 1 31 

333 - Machinery Manufacturing 2 7 24 

3122 - Tobacco Manufacturing 2 3 20.6 

321 - Wood Product Manufacturing 3 3 14.8 

332 - Fabricated Metal Product Manufacturing 1 2 12.5 

521 - Monetary Authorities - Central Bank 1 2 12 

814 - Private Households 1 1 6 

514 - Information Services and Data Processing Services 1 1 4.7 

482 - Rail Transportation 1 2 4 

561 - Administrative and Support Services 1 1 2.3 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-15 

Table 7-3. Summary of Fossil-Fueled, Steam Electric Industrial Non-Utilities, 

by NAICS Code in 2005 

NAICS Code - Description 

Number 

of Plants 

Number of 

Electric 

Generating 

Units a 

Total Steam and 

Combined Cycle 

Turbine Electric 

Generating Capacity

(MW) b 

624 - Social Assistance 1 2 2 

562212 - Solid Waste Landfill 1 1 1 

Total Fossil-Fueled Industrial Non-Utilities 314 709 19,393 

Source: [U.S. DOE, 2005a]. 

a – The number of electric generating units represents the number of stand-alone steam turbines and the estimated 

number of combined cycle systems. EPA estimated the number of combined cycle systems by adding the number of 

combined cycle steam turbines and the number of combined cycle single shaft turbines. Typically there are multiple 

combustion turbines to a single steam turbine in a combined cycle system; therefore, EPA believes this methodology 

is a better representation of the number of combined cycle systems than simply adding the number of combined 

cycle combustion and steam turbines. 

b – The table includes stand-alone steam turbines, combined cycle steam turbines, combined cycle single shaft 

turbines, and combined cycle combustion turbines. 

c – Operations included in NAICS code 221 include natural gas distribution, water sewage and other systems, water 

supply and irrigation systems, and sewage treatment plants. Based on these descriptions, EPA believes that these 

plants should be treated as industrial non-utilities. 

7.2.2.1 Prime Movers/Generating Units 

Table 7-4 shows the distribution of the types of steam electric prime movers used by 

industrial non-utilities within each of the top five industries. The table presents the numbers of 

plants and electric generating units and capacities for each type of steam electric prime mover. 

Based on the 2005 EIA data, industrial non-utilities generate over half of their electricity (54 

percent) through stand-alone steam turbines, which are also the most prevalent type of steam 

electric prime mover used by the regulated steam electric plants regulated under the Steam 

Electric Power Generating effluent guidelines. 

The two exceptions to this among the top five industries are the chemical manufacturing 

and the petroleum and coal products manufacturing industries, which reported more electric 

generating capacity for combined cycle systems than stand-alone steam turbines in 2005 [U.S. 

DOE, 2005a]. Comments received on the preliminary 2006 effluent guidelines program plan 

from the American Petroleum Institute (API) indicate that most petroleum refineries use natural 

gas or residual gases from the refinery process to power a combustion turbine, the waste heat of 

which is used to produce steam either to generate additional electric power or to be used directly 

within the refining process [API, 2005]. According to API’s description of petroleum refinery 

non-utilities, not only are these plants using combined cycle systems, but they are considered to 

be cogenerators (i.e., steam is produced both to power a generator and to use in other operations). 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

Table 7-4. Distribution of Prime Mover Types Among Fossil-Fueled, 

Steam Electric Industrial Non-Utilities 

Steam Electric Prime Mover Number of Plants a

Number of Electric 

Generating Units b 

Total Steam and Combined 

Cycle Turbine Electric 

Generating Capacity (MW) c

All Industrial Non-utilities 

Stand-Alone Steam Turbine 264 

(84%) 

625 

(88%) 

10,378 

(54%) 

Combined Cycle System 102

(32%) 

84

(12%) 

9,015

(46%) 

Total 314 709 19,393 

NAICS 325 – Chemical Manufacturing 

Stand-Alone Steam Turbine 41 97 1,579 

Combined Cycle System 28 32 5,955 

Total 55 129 7,535 

NAICS 322 – Paper Manufacturing

Stand-Alone Steam Turbine 78 164 3,107 

Combined Cycle System 8 5 241 

Total 81 169 3,348 

NAICS 324 – Petroleum and Coal Products Manufacturing 

Stand-Alone Steam Turbine 21 50 756 

Combined Cycle System 18 19 1,815 

Total 29 69 2,571 

NAICS 331 – Primary Metal Manufacturing 

Stand-Alone Steam Turbine 18 53 2,383 

Combined Cycle System 0 0 0 

Total 18 53 2,383 

NAICS 311 – Food Manufacturing 

Stand-Alone Steam Turbine 36 78 1,108 

Combined Cycle System 4 2 18.7 

Total 38 80 1,127 

Source: [U.S. DOE, 2005a]. 

a – Because a single plant may operate multiple generating units of various types, the number of plants by prime 

mover type is not additive. The totals reflect the number of industrial non-utilities that are operating at least one 

steam electric generating unit powered by a fossil fuel. 

b – The number of electric generating units represents the number of stand-alone steam turbines and the estimated 

number of combined cycle systems. EPA estimated the number of combined cycle systems by adding the number of 

combined cycle steam turbines and the number of combined cycle single shaft turbines. Typically there are multiple 

combustion turbines to a single steam turbine in a combined cycle system; therefore, EPA believes this methodology 

is a better representation of the number of combined cycle systems than simply adding the number of combined 

cycle combustion and steam turbines. 

c – The table includes stand-alone steam turbines, combined cycle steam turbines, combined cycle single shaft 

turbines, and combined cycle combustion turbines.

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7.2.2.2 Fossil Fuel Types 

Table 7-5 shows the distribution of the fossil fuels used by industrial non-utilities by 

electric generating capacity, specifically broken out for the top five industries. The 2005 EIA 

data demonstrate that fossil-fueled industrial non-utilities generally use either coal or 

natural/other gas to fuel their steam electric generating units; however, some industries tend to 

use a particular type of fossil fuel more than other types of fuels. For example, most food 

manufacturing non-utilities reported using coal, while most petroleum and coal products 

manufacturing non-utilities reported using natural/other gas [U.S. DOE, 2005a]. These trends 

coincide with the predominant types of generators used in these industries (e.g., nearly all 

combined cycle systems are powered by natural/other gas). 

Table 7-5. Distribution of Fuel Types Among Fossil-Fueled, Steam Electric 

Industrial Non-Utilities 

Fossil Fuel a

Number of 

Plants b

Number of Electric 

Generating Units c 

Total Steam and Combined 

Cycle Turbine Electric 

Generating Capacity (MW) d

All Fossil-Fueled Industrial Non-Utilities 

Coal: 132 

(42%) 

337 

(48%) 

6,651 

(34%) 

Anthracite Coal, Bituminous Coal 

(BIT) 104 275 5,077 

Subbituminous Coal (SUB) 25 57 1,142 

Lignite Coal (LIG) 2 4 365 

Waste Coal (WC) 1 1 67 

Petroleum Coke (PC) 4 

(1%) 

6 

(1%) 

197 

(1%) 

Oil: 29 

(9%) 

50 

(7%) 

395 

(2%) 

Residual Fuel Oil (RFO) 26 45 367 

Distillate Fuel Oil (DFO) 2 4 20 

Waste/Other Oil (WO) 1 1 8 

Natural/Other Gas: 155 

(49%) 

316 

(44%) 

12,150 

(63%) 

Natural Gas (NG) 125 241 10,663 

Blast Furnace Gas (BFG) 9 28 834 

Other Gas (OG) 21 47 654 

Total 314 709 19,393 

NAICS 325 – Chemical Manufacturing 

Coal (BIT, LIG, and SUB) 18 56 1,116 

Petroleum Coke (PC) 1 2 46 

Oil (DFO and WO) 2 4 27 

Natural/Other Gas (NG and OG) 35 67 6,346 

Total 55 129 7,535 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-18 

Table 7-5. Distribution of Fuel Types Among Fossil-Fueled, Steam Electric 

Industrial Non-Utilities 

Fossil Fuel a

Number of 

Plants b

Number of Electric 

Generating Units c 

Total Steam and Combined 

Cycle Turbine Electric 

Generating Capacity (MW) d

NAICS 322 – Paper Manufacturing

Coal (BIT, SUB, and WC) 38 88 1,871 

Petroleum Coke (PC) 1 2 90 

Oil (RFO) 14 21 250 

Natural/Other Gas (NG) 29 58 1,137 

Total 81 169 3,348 

NAICS 324 – Petroleum and Coal Products Manufacturing 

Petroleum Coke (PC) 2 2 61 

Oil (RFO) 1 1 0.4 

Natural/Other Gas (NG and OG) 27 66 2,509 

Total 29 69 2,571 

NAICS 331 – Primary Metal Manufacturing 

Coal (BIT, LIG and SUB) 5 12 1,410 

Natural/Other Gas (BFG, NG, and OG) 13 41 973 

Total 18 53 2,383 

NAICS 311- Food Manufacturing 

Coal (BIT and SUB) 30 63 1,056 

Oil (RFO) 1 2 8 

Natural/Other Gas (NG) 7 15 63 

Total 38 80 1,127 

Source: [U.S. DOE, 2005a]. 

a – No steam electric generating units operated at industrial non-utilities were reported to use jet fuel, kerosene, coal 

synfuel, gaseous propane, or nuclear fuel in the 2005 EIA database. 

b – Because a single plant may operate multiple generating units utilizing differing fuel types, the number of plants 

by fuel type is not additive. EPA estimates there are 314 industrial non-utilities operating at least one steam electric 

generating unit powered by a fossil fuel. 

c – The number of electric generating units represents the number of stand-alone steam turbines and the estimated 

number of combined cycle systems. EPA estimated the number of combined cycle systems by adding the number of 

combined cycle steam turbines and the number of combined cycle single shaft turbines. Typically there are multiple 

combustion turbines to a single steam turbine in a combined cycle system; therefore, EPA believes this methodology 

is a better representation of the number of combined cycle systems than simply adding the number of combined 

cycle combustion and steam turbines. 

d – The total steam electric generating capacity shown does not equal the sum of the steam electric capacities for 

each fuel type due to rounding errors. The table includes stand-alone steam turbines, combined cycle steam turbines, 

combined cycle single shaft turbines, and combined cycle combustion turbines.

7.2.3 Review of Industrial Non-Utility Discharge Permits 

EPA reviewed NPDES permits for 28 industrial plants operating a steam electric 

industrial non-utility on site to determine the extent to which steam electric process wastewater is 

segregated from other process wastewaters and whether Steam Electric Power Generating 

effluent guidelines are applied to the wastewaters on the basis of BPJ. These plants use either a 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

fossil fuel or other non-fossil fuel to power the steam electric generating unit(s), and were 

identified within the following four industries: 

• Chemical Manufacturing; 

• Paper Manufacturing; 

• Primary Metal Manufacturing; and 

• Petroleum and Coal Products Manufacturing. 

EPA found that the NPDES permits for the plants within these industries rarely provide 

enough detail about the plant waste streams to identify the steam electric process wastewaters; 

however, some permits generally described waste streams that could include the steam electric 

waste streams or waste streams from other on-site operations (e.g., “cooling water,” “boiler 

blowdown”). The final effluent wastewaters from industrial sites are commingled with all plant 

wastewater at the point of discharge, if not upstream; therefore, the steam electric wastewaters 

are typically commingled with the other plant wastewaters. 

The 28 plants are covered by seven existing industrial point source effluent guidelines. 

EPA determined that wastewaters discharged from these industrial sites are often regulated only 

by the effluent guidelines for the primary industrial process (e.g., Organic Chemicals, Plastics, 

and Synthetic Fibers, Petroleum Refining). Rarely are the discharges associated with steam 

electricity generation limited specifically with the Steam Electric Power Generating effluent 

guidelines limits. Additionally, the Steam Electric Power Generating effluent guidelines limits 

are rarely used as a BPJ basis to regulate pollutants that may not be covered under the specific 

industrial effluent guideline. 

EPA researched three of these seven existing effluent guidelines (i.e., Iron and Steel 

Manufacturing, Petroleum Refining, and Pulp, Paper & Paperboard Point Source Categories) to 

determine whether the waste streams from the steam electric operations were considered in 

developing the final effluent limitations. The Pulp, Paper & Paperboard effluent guidelines (40 

CFR Part 430) specifically define Part 430-regulated process wastewater (in certain subparts) as 

including wastewaters generated by co-located non-utility power plants (see 40 CFR Part 

430.01(m)). 

Comments received on the preliminary 2006 effluent guidelines program plan from API 

stated that petroleum refinery steam electric generating units primarily generate wastewater from 

boiler and cooling tower blowdown and demineralizer streams that are typically permitted as 

low-contaminant streams (i.e., streams containing low concentrations of toxics, oxygen demand, 

and nonconventional pollutants). API also commented that these streams possess the same 

wastewater characteristics as the petroleum refining wastewater with which they are commingled 

prior to discharge [API, 2005]. On the preliminary 2008 effluent guidelines program plan, the 

American Chemistry Council provided similar comments stating that the wastewaters associated 

with the steam electric generating units are considered low-contaminant streams by permit 

writers and are controlled by BPJ-based limits [Walls, 2007] 

While the Pulp, Paper, & Paperboard effluent guidelines were developed incorporating 

wastewaters from on-site steam electric power plants, this is not the case for all industrial 

effluent guidelines. For example, the Iron and Steel effluent guidelines (40 CFR Part 420) 

identify that wastewaters from the operation of steam electric generating units may be discharged 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

and are identified as non-process wastewaters; however, the effluent guideline does not set limits 

for these non-process wastewaters nor incorporate them into the effluent guideline limits. 

In many cases, the primary industry effluent guidelines (or the permit for the industrial 

plant discharge) either does not address or contains a less stringent limit for the pollutants 

included in the Steam Electric Power Generating effluent guidelines. For example, the Pulp, 

Paper, & Paperboard effluent guidelines, which include wastewaters generated from on-site 

power plants, do not currently regulate chlorine discharges. 

7.2.4 Contacts with Industrial Non-Utilities 

As part of the detailed study, EPA contacted several companies that operate steam 

electric generating units colocated at their industrial plants. EPA contacted these companies to 

determine the types of fuels used, process operations, wastewaters generated, and the 

handling/treatment of the wastewaters associated with the operation of the steam electric 

generating units. EPA contacted at least one company in each of the top five industries, ranked 

by electric generating capacity. 

From these contacts, EPA identified a primary metal manufacturer with steam electric 

generating units at one of its plants that operates similarly to some coal-fired power plants 

regulated under the Steam Electric Power Generating effluent guidelines. This non-utility 

operates four coal-fired units, each of which has a wet FGD system. The FGD scrubber purge is 

transferred to an ash pond for treatment, where it is commingled with fly ash transport and 

bottom ash transport waters. The ash pond does not receive any wastewater associated with the 

other plant operations. The ash pond effluent is discharged to surface water and this discharge is 

required to comply with the Steam Electric Power Generating effluent guidelines limits [Alcoa, 

2009]. 

The food manufacturing company that EPA contacted operates eight plants with coalfired electric generating units. EPA only discussed the operation of one of the plants with the 

company; however, the contact stated that the operations at the other seven plants are similar. 

The plant discussed does not operate any wet FGD systems. Additionally, both the bottom ash 

and fly ash are collected using dry handling practices. The cooling tower blowdown generated by 

the steam electric process is commingled with the plant’s sanitary wastewaters and transferred to 

a publicly owned treatment works [ADM, 2009]. 

The paper manufacturing company that EPA contacted operates electric generating units 

powered by several different types of fuels. One of the most common types of fuels used is black 

liquor, which is a by-product of the pulping process. The company also burns coal, wood wastes, 

tires, and other solid fuels. The company has over 20 paper mills that operate steam electric 

generating units, and the operations at these mills differ by site. According to the contact, the 

company does not operate any wet FGD systems; however, it does operate a few dry FGD 

systems. The company operates a mixture of wet and dry ash handling systems, and some of the 

mills operate ash ponds to treat the fly and/or bottom ash transport waters. The other types of 

wastewaters generated by the steam electric generating operations consist of boiler blowdown, 

cooling water, and process area wash waters. All these wastewaters are commingled with the 

other mill wastewaters and treated in a pond or clarifier followed by an aerated stabilization 

basin, some of which have activated sludge treatment [International Paper, 2009]. 

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Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-21 

The petroleum refining company that EPA contacted operates three refineries that have 

electric generating units on site. These units burn gases that are by-products of the industrial 

operations. The flue gas generated from the electric generating units is combined with the other 

gases in the plant operations and treated with those gases. The wastewaters generated from the 

steam electric generating units are cooling tower blowdown, boiler blowdown, and process area 

wash waters. These wastewaters are treated in the plants’ wastewater treatment systems, which 

typically consist of oil/water separators, an activated sludge biological systems, and clarifiers 

[Valero, 2009]. 

The chemical manufacturing company that EPA contacted operates two plants that have 

coal-fired electric generating units on site. One of the plants is only capable of burning coal, 

while the other can use oil as a secondary fuel. Both plants generate steam primarily for the 

plants’ process operations and not for generating electricity (i.e., one plant uses 10 percent of the 

steam generated to produce electricity and the other uses 16 percent of the steam to produce 

electricity). Neither of the plants operates a FGD systems for sulfur dioxide control. Both plants 

operate dry fly ash handling systems. One plant operates a dry bottom ash handling system and 

the other operates a wet system and trucks the wet bottom ash to a sand filter and the filtrate is 

transferred to the plant’s wastewater treatment facility. Both plants generate coal pile runoff, 

boiler blowdown, and cooling tower blowdown waste streams. The coal pile runoff is sent 

through a settling treatment system prior to discharge. The boiler blowdown and cooling tower 

blowdown are discharged directly by one of the plants; the other plant treats the wastes in a 

settling pond prior to discharge [Vasavada, 2009]. 

7.3 Steam and Air Conditioning Supply Plants

As part of the detailed study, EPA reviewed data from other industry segments that may 

have similar operations to steam electric plants, but are not currently subject to the Steam 

Electric Power Generating effluent guidelines. These industry segments include plants within 

SIC Code 4939 (Combination utilities, not elsewhere classified), discussed further in Section 7.4, 

and SIC Code 4961 (Steam and air conditioning supply), discussed in this section. EPA reviewed 

available discharge data from plants within these SIC codes to determine if these plants have 

operations and wastewater characteristics similar to those in the Steam Electric Power 

Generating Point Source Category. 

This section discusses steam and air conditioning supply plants and the findings of EPA’s 

examination of the processes and wastewaters generated by their operation. According to the 

2002 Economic Census, 63 establishments were engaged in steam and air conditioning supply31

in the United States in 2002 [USCB, 2002]. Types of plants within the Steam and Air 

Conditioning Supply sector include the following: 

• Air conditioning supply services; 

• Cooled air suppliers; 

• Distribution of cooled air; 

• Chilled water suppliers; 

• Geothermal steam production; 

 

31 The 2002 Economic Census is based on the North American Industrial Classification System (NAICS). The 

NAICS code for steam and air conditioning supply (22133) corresponds directly to SIC code 4961. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-22 

• Steam heating systems (suppliers of heat); and 

• Steam supply systems, including geothermal. 

Many of these plants combust fossil fuels in a boiler to generate steam, which is similar 

to the operation at steam electric plants regulated under the Steam Electric Power Generating 

effluent guidelines; however, the primary purpose of this steam is not electricity generation. The 

steam generated from the process is typically distributed to off-site customers and, therefore, it 

does not power a steam turbine/electric generator. 

Wastewater generated by these steam and air conditioning supply plants is not currently 

regulated by the Steam Electric effluent guidelines, because the plants are not “... engaged in the 

generation of electricity...”, as defined at 40 CFR Part 423.10. As part of the detailed study, EPA 

investigated steam and air conditioning supply plants and compared their processes and types of 

wastewaters generated to those of fossil-fueled plants currently regulated by the Steam Electric 

Power Generating effluent guidelines. EPA also compared the way the wastewater discharges are 

regulated for these plants to the plants subject to the Steam Electric Power Generating effluent 

guidelines. 

Information that EPA obtained during the detailed study indicate that these steam and air 

conditioning supply plants generate similar types of wastewaters as steam electric plants 

regulated under the Steam Electric Power Generating effluent guidelines; however, most of the 

plants combust natural gas or oil and, therefore, do not generate the quantity of FGD and/or ash 

transport wastewaters that are generated by coal-fired power plants. EPA identified that some of 

the wastewater discharges contain similar pollutants to those discharged by steam electric plants. 

Additionally, some of the wastewaters from these plants are regulated using the Steam Electric 

Power Generating effluent guidelines as the basis for BPJ-derived limits. EPA also identified that 

there are relatively few of these plants in operation and most of them discharge a relatively small 

amount of wastewater compared to the steam electric plants regulated under the Steam Electric 

Power Generating effluent guidelines. 

The remainder of this section summarizes data and information that were available for 

the Steam and Air Conditioning Supply sector during EPA’s study of this sector. EPA reviewed 

data for SIC code 4961 reported to PCS and ICIS-NPDES32. EPA also reviewed several permits 

and contacted three companies that operate steam supply plants to learn about the operations and 

wastewaters generated at these plants. These sources provided information about potential types 

of wastewater generated by steam supply plants, as well as the relative number of these plants 

that are likely to generate and discharge wastewater. 

 

32 In 2007, some states’ discharge monitoring report (DMR) data were reported to the PCS database, while the 

remaining states reported DMR data to the Integrated Compliance Information System – National Pollutant 

Discharge Elimination System (ICIS-NPDES) database. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-23 

7.3.1 Wastewater Discharge Characterization Data 

EPA extracted effluent monitoring data reported to PCS and ICIS-NPDES in 2007 for 

plants within SIC code 4961. Table 7-6 summarizes the data extracted for these plants along with 

their calculated total TWPE, which is a loading that accounts for the toxicity of the pollutants 

discharged. The Technical Support Document for the Annual Review of Existing Effluent 

Guidelines and Identification of Potential New Point Source Categories [U.S. EPA, 2009c], 

discusses EPA’s method of calculating TWPE. EPA in particular identified whether these 

operations reported discharges of chlorine, total residual oxidants (TRO), chlorine-produced 

oxidants (CPO), or metals, which are pollutants typically discharged from steam electric plants 

regulated under the Steam Electric Power Generating effluent guidelines. 

Table 7-6 also indicates whether the plants are classified as “major” or “minor” 

dischargers. To provide an initial framework for setting permit issuance priorities, EPA 

developed a major/minor classification system for industrial and municipal wastewater 

dischargers. Each permitting authority establishes its own definitions, but major dischargers 

almost always have the capability to impact receiving waters if not controlled and, therefore, 

have been accorded more regulatory attention than minor dischargers. Plants are classified as 

major based on an assessment of six characteristics: (1) toxic pollutant potential; (2) flow/stream 

flow volume; (3) conventional pollutant loading; (4) public health impact; (5) water quality 

factors; and (6) proximity to coastal waters. Facilities with major discharges must report 

compliance with NPDES permit limits via monthly Discharge Monitoring Reports (DMRs) 

submitted to the permitting authority. Minor discharges may, or may not, adversely impact 

receiving water if not controlled. The DMRLoads2007 database includes data only for a limited 

set of minor dischargers when the states choose to include these data. As shown in Table 7-6, the 

2007 PCS and ICIS-NPDES contain data for 46 steam and air conditioning supply plants, 42 of 

which are classified as minor dischargers [U.S. EPA, 2009b]. This suggests that steam and air 

conditioning supply plants may discharge relatively small volumes of wastewater and/or 

pollutants. 

7.3.2 NPDES Permit Review 

In researching the operations, waste streams, and existing discharge requirements 

currently applied to steam and air conditioning supply wastewaters, EPA reviewed NPDES 

permits for four steam and air conditioning supply plants (plants identified with bolded text in 

Table 7-6). All four plants generate steam; however, none use the steam to generate electricity. 

Some of the plants produce chilled water in addition to steam. The five plants generate 

wastewaters that are similar to those of steam electric plants regulated under the Steam Electric 

Power Generating effluent guidelines, including boiler blowdown, coal pile runoff, and cooling 

tower blowdown; however, the cooling water waste streams and cooling tower blowdown listed 

in the permits could be associated with the chilled water production process. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation o

Table 7-6. Steam and Air-Conditioning Supply Plants Identified in DMRLoads2007 Datab

NIDD Name City 

Type of 

Discharger 

Monitoring 

Data in 

Database? 

Total 

TWPE a 

Cl/TRO

Discha

AL0052400 Powell Avenue Steam Plant Birmingham Minor Y NA CCA0029106 GAFF Power Systems-Site I Pittsburg Minor N NA CA0029122 GAFF Power Systems-Site V Pittsburg Minor N NA CA0082406 Alturas High School Geothermal Alturas Minor N NA CA8000015 San Bernardino Geothermal Facility San Bernardino Minor N NA CO0043427 Thermal Energy Distribution Denver County Minor N NA CT0004014 Hartford Steam Company Hartford Major Y 4,645 CDC0000035 GSA - (West Heating Plant) Washington Minor Y NAID0025488 Boise, City Of Boise Minor N NAIL0001368 MED Thermal Technologies Inc Chicago Minor Y NAIL0037613 MED Thermal Technologies-Pl. #5 Chicago Minor Y NA CIL0072320 SIC Physical Plant, SUIT Carbondale Minor Y NA IL0073741 Metro Pier & Expo Authority Chicago Minor Y NAIN0004677 Citizens Thermal Energy Indianapolis Minor Y NA CMD0001554 Trigged-Baltimore Energy Corp Baltimore Minor N NAMD0061930 Trigged-Energy Baltimore – SPRY Baltimore Minor Y NA CMD0065986 Housing Authority of Baltimore Baltimore Minor N NAMD0066249 Trigged-Baltimore Energy Corp Baltimore Minor N NAMD0066877 Trigged-Energy Baltimore – SARA Baltimore Minor Y NA CMN0054739 Energy Park Utility Co Saint Paul Minor N NA MN0055719 Duluth Steam Cooperative Assoc Duluth Minor N NA MN0056995 North Riverfront Plant Minneapolis Minor N NA MN0066559 Minnesota Power Rapids Energy Grand Rapids Minor N NA MO0004847 Trigged KC Dist. Energy CUR Kansas City Minor Y NA MO0099236 BASF Corp Agra Products Palmyra Minor Y NA MO0127825 University Of MO-Physical Rolla Minor Y NA MT0030651 Don Abbey Residence Rollins Minor Y NA

7-24 
Final Detailed Study Report Chapter 7 – Preliminary Investigation o

7-25 

Table 7-6. Steam and Air-Conditioning Supply Plants Identified in DMRLoads2007 Datab

NIDD Name City 

Type of 

Discharger 

Monitoring 

Data in 

Database? 

Total 

TWPE a 

Cl/TRO

Discha

NJ0109673 Central Heat Plant Bldg 2401 New Hanover Twp Major Y NA CPNY0005134 59th Street Steam Station New York Major Y NA NY0005151 Hudson Ave. Steam Plant Brooklyn Minor Y NA NY0005177 74th Street Steam Plant New York Major Y NA NY0227153 South Nassau Communities Hosp Oceanside Minor N NA NY0245097 Remington Arms Co, Inc Ilion Minor Y NA OK0002461 Trigged - Tulsa Energy Corp Tulsa Minor Y NA CPA0000493 Pittsburgh Allegheny County Pittsburgh Minor N NA PA0008427 NRG Energy Center Hag. Inc Harrisburg Minor N NA PA0239542 Impact PA Geothermal Well Warren Minor N NA PA0253235 Tarentum Senior Housing - Geothermal Well Tarentum Minor N NA SD0025569 Haakon School District No. 27-1 Philip Minor Y NA SD0025798 St Joseph's Indian School Chamberlain Minor Y NA TX0008851 Texas Medical Center Central Houston Minor Y NAVA0032000 US Department Of Defense - Pentagon Arlington Minor N NAVA0091995 Reston Lake Anne Air Condition Reston Minor N NAWA0001503 Seattle Steam Port of Seattle Minor Y NAWI0038296 U W Madison Charter Street Madison Minor N NAWI0040282 WI University Milwaukee Power Milwaukee Minor N NA

Source: [U.S. EPA, 2009b]. a – TWPE was not calculated for minor plants in the DMRLoads2007 database. 

b – Cl – Chlorine; TRO – Total residual oxidants; and CPO – Chlorine produced oxidants (EPA has not developed TWFs for TRO and 

loads are not included in TWPE totals). NA – Not available. The plant is either a minor discharger, in which case ERG does not calculate TWPE, or the plant did not report botdata and/or the plant reported only parameters for which EPA has not developed a TWF (e.g., TSS, BOD5). 

Note: The rows with bold text in the table identify the plants for which EPA reviewed NPDES permits. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-26 

Some of the permits reviewed showed that the Steam Electric Power Generating effluent 

guidelines standards were used as the basis for BPJ limits, although not all of the steam electric 

regulated pollutants are necessarily included in the steam and air conditioning supplier permits. 

This shows that some permit writers feel the operations at these steam supply plants are similar 

enough to the operations at Part 423-regulated steam electric plants that the wastewaters may 

have similar characteristics and, therefore, should have the same effluent limitations. 

Upon review of the permit for the Hartford Steam Company, EPA learned that, in 

addition to steam and chilled water production, the plant used to generate electricity with excess 

steam; however, the electricity generation portion of the process has been closed since 1995. The 

permit has retained the limits of the Steam Electric Power Generating effluent guidelines as the 

basis for the current wastewater discharge requirements. This plant continues to report 

significant discharges of chlorine, zinc, copper, and lead, which shows that the wastewaters from 

the steam and air conditioning supply operations are discharging chlorine and metals to surface 

waters. 

7.3.3 Contacts with Steam Supply Companies 

During the detailed study, EPA contacted three companies operating a total of 20 plants33

to obtain information on the operations and wastewaters generated at steam supply plants. These 

steam supply plants typically provide steam for district heating and cooling purposes in large 

cities. Many steam supply plants provide chilled water and/or hot water in addition to providing 

steam. Some of the steam supply plants are providing electricity (i.e., they are cogeneration 

plants). 

From communications with the companies, EPA found that the majority of the steam 

supply plants burn either oil or natural gas in their boilers. Because these fuels are generally low 

in sulfur, these plants do not operate FGD scrubbers. Steam supply plants that use natural gas as 

a fuel do not typically generate any ash or residual solid waste in their boilers and therefore do 

not generate any ash transport waters. Some of the oil-fired plants generate a small amount of 

ash that they remove from the boiler by periodic washes. One of the oil-fired plants transports its 

ash wastewater and/or ash sludge off site to a treatment, storage, and disposal facility. 

In addition to ash transport waters that may be generated by oil-fired plants, typical 

wastewaters generated at natural gas or oil-fired steam supply plants are: 

• Boiler blowdown; 

• Cooling water; 

• Demineralizer wastewater; 

• Equipment drains and overflows; and 

• Plants sumps. 

According to one of the companies EPA contacted, the steam supply plants operated by 

the company neutralize the boiler blowdown and demineralizer wastewaters to meet the pH 

limits in their permits. Because most of the steam supply plants are located in large cities, they 

 

33 Of the 20 plants operated by the three steam supply companies, only seven were identified as steam supply plants 

reporting SIC code 4961 to PCS or ICIS-NPDES in 2007. The remaining 13 plants are identified either as 

combination utilities (SIC Code 4931) or steam electric generating plants. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-27 

do not operate treatment ponds due to limited space availability, but typically neutralize the 

boiler blowdown in large tanks [Consolidated Edison, 2009; Hartford Steam Company, 2009]. 

Of the 20 plants that were reviewed, only one plant reported using coal in their boilers. 

The plant burns a low-sulfur coal and therefore, does not operate a FGD system. The plant is a 

cogeneration plant that generates 5 MW of electricity and provides steam and chilled water for a 

commercial district. 

7.4 Combination Utility Plants

EPA reviewed available discharge information for plants within SIC Code 4939 

(Combination utilities, not elsewhere classified) to determine if these plants have operations and 

wastewater characteristics similar to those in the Steam Electric Power Generating Point Source 

Category. The U.S. Census Bureau defines combination utilities as: 

“Establishments primarily engaged in either providing electric services in combination 

with other services, with electric service as the major part though less than 95 percent of 

the total or providing gas services in combination with other services, with gas services 

as the major part though less than 95 percent.” [USCB, 2000] 

According to the U.C. Census Bureau’s Comparative Statistics, there were 1,989 

combination utilities in the United States in 199734 [USCB, 2000]; however, not all of these 

plants are relevant to the detailed study. By definition, combination utilities perform services 

other than electric power generation, and more specifically services other than steam electric 

power generation. 

Wastewaters generated by plants classified as combination utilities are likely not 

currently subject to existing effluent guidelines; however, combination utilities by definition 

include plants that generate electric power, albeit in combination with providing other utility 

services. Because at least a portion of these plants are expected to be engaged in the generation 

of electricity for distribution and sale, EPA determined that the electric generating activities 

performed at some combination utilities might be similar to those at plants regulated by the 

Steam Electric Power Generating effluent guidelines, in terms of processes and wastewaters 

generated. EPA examined effluent monitoring data reported in DMRs, as well as pollutants 

reported to TRI as discharged, and determined that the pollutants are similar in nature to those 

discharged by the steam electric plants currently regulated by the Steam Electric Power 

Generating effluent guidelines [U.S. EPA, 2005b]. However, the wastewater discharge 

characterization data suggests that combination utilities may discharge relatively small volumes 

of wastewater and/or pollutants, particularly as compared to those plants regulated under the 

Steam Electric Power Generating effluent guidelines. 

EPA’s review of NPDES permits for five combination utilities revealed that four of these 

plants do not produce electricity, even as an auxiliary activity, and the processes and wastewaters 

generated by these non-electric generating plants are not similar to those of steam electric plants 

 

34 EPA used 1997 Economic Census data instead of 2002 Economic Census data because the 1997 data was reported 

by SIC code and the 2002 data was reported by NAICS code. SIC code 4939 does not have a direct correlation to a 

NAICS code; therefore, EPA could not determine the number of combination utilities from the 2002 Economic 

Census data. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-28 

regulated under the Steam Electric Power Generating effluent guidelines. The wastewatergenerating activities performed at these plants may be classified within other existing SIC codes, 

including Electric Services, Sewerage Systems, and Water Supply. 

7.4.1 Wastewater Discharge Characterization Data 

EPA extracted data reported to TRI in 2005 for all plants within SIC code 4939. EPA 

used 2005 TRI data because they were the most recent TRI data for which the plants reported 

their SIC code, for years after 2005, plants began reporting NAICS codes. Only 13 combination 

utilities reported to TRI, and of these, only one reported a direct release to water (barium and 

barium compounds with a TWPE of 0.003). The remaining seven reported no discharge of a TRI 

chemical to water [ERG, 2008a]. TRI does not specifically identify the process source(s) of the 

wastewater and pollutants discharged. 

EPA also extracted effluent monitoring data reported to PCS and ICIS-NPDES in 2007 

for plants within SIC code 4939. Table 7-7 summarizes the data extracted for these plants (47 

combination utilities) along with their calculated total TWPE, which is a loading that accounts 

for the toxicity of the pollutants discharged. The 2009 screening-level analysis report, 2009 

Annual Screening-Level Analysis: Supporting the Annual Review of Existing Effluent Limitations 

Guidelines and Standards and Identification of Potential New Categories for Effluent 

Limitations Guidelines and Standards [U.S. EPA, 2009c], discusses EPA’s method of 

calculating TWPE. Table 7-7 identifies whether these operations reported discharges of chlorine, 

TRO, CPO, or metals, which are pollutants typically discharged from steam electric plants 

regulated under the Steam Electric Power Generating effluent guidelines. As shown in Table 7-7, 

10 of the 47 combination utilities reported discharges of chlorine. 

Table 7-7 also indicates whether the plants are classified as “major” or “minor” 

dischargers. To provide an initial framework for setting permit issuance priorities, EPA 

developed a major/minor classification system for industrial and municipal wastewater 

dischargers. Each permitting authority establishes its own definitions, but major dischargers 

almost always have the capability to impact receiving waters if not controlled and, therefore, 

have been accorded more regulatory attention than minor dischargers. Plants are classified as 

major based on an assessment of six characteristics: (1) toxic pollutant potential; (2) flow/stream 

flow volume; (3) conventional pollutant loading; (4) public health impact; (5) water quality 

factors; and (6) proximity to coastal waters. Facilities with major discharges must report 

compliance with NPDES permit limits via monthly DMRs submitted to the permitting authority.

Minor discharges may, or may not, adversely impact receiving water if not controlled. Therefore, 

EPA does not require DMRs for facilities with minor discharges. For this reason, the 

DMRLoads2007 database includes data only for a limited set of minor dischargers when the 

states choose to include these data. As shown in Table 7-7, 45 of the 47 combination utilities are 

classified as minor dischargers [U.S. EPA, 2009b]. This suggests that combination utilities may 

discharge relatively small volumes of wastewater and/or pollutants. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation o

Table 7-7. Combination Utilities Identified in DMRLoads2007 Database 

NPDES ID Plant Name City 

Type of 

Discharger 

Monitoring 

Data in 

Database? 

Total 

TWPE a 

Cl/T

Dis

AR0034363 Shumaker Public Service Corp. East Camden Minor N NA CA0047953 Paso Robles WWTP Paso Robles Major Y 173 CO0042447 Rifle Station Garfield County Minor N NA CT0030279 City of Stamford Stamford Minor N NAIA0062421 Coats Utility Company Fort Dodge Minor N NA IL0045527 Aqua Il Inc-Candlewick Lake Poplar Grove Minor Y NA IL0048593 Otter Creek Lake Utility Stp Davis Minor Y NA IL0052817 Stonewall Utility Co Stp Oakbrook Terrace Minor Y NA IL0071030 Emmett Utilities Inc. Stp Colchester Minor Y NA ILG551012 Sheridan Estates Disp Stp Quincy Minor Y NA ILG640079 Aqua Illinois-Woodhaven Sublette Minor Y NA IN0000311 BPC Manufacturing Operations Plymouth Minor N NAIN0002941 Western Electric Co Indianapolis Minor N NA IN0031011 USDAF USAF Grissom AFB Grissom AFB Minor N NAIN0031836 Gateway Utilities, Inc. Terre Haute Minor N NAKY0105091 Western Lewis Rectorville Wtr Mason County Minor N NALA0116424 US 165 North Regional WWTF West Monroe Minor N NA LA0119679 North Vermilion WTP Maurice Minor N NALA0119687 Pecan Island WTP Kaplan Minor N NAME0102512 Hampden WWTF Hampden Minor N NA MN0041271 Franklin Heating Station Rochester Minor N NAMO0000345 Tractebel Power Incorporated Saint Louis Minor N NANY0005894 Glenwood Landing Energy Center Glenwood Landing Minor Y NA NY0026344 Shoreham Combustion Turbine Facility Shoreham Major Y <1 NY0106259 Covanta Niagara, L.P. Niagara Falls Minor Y NA NY0200778 East 60th Street Steam Plant New York Minor Y NA NY0201138 Consolidated Edison Co Of NY Long Island City Minor Y NANY0201154 Astoria Liquified Nat Gas Storage Astoria Minor Y NANY0225282 Brookhaven Combustion Turbine Wading River Minor Y NA NY0225860 Shoreham Nuclear Power Station Shoreham Minor N NA NY0226009 Southold Internal Combustion Greenport Minor Y NA

7-29 
Final Detailed Study Report Chapter 7 – Preliminary Investigation o

7-30 

Table 7-7. Combination Utilities Identified in DMRLoads2007 Database 

NPDES ID Plant Name City 

Type of 

Discharger 

Monitoring 

Data in 

Database? 

Total 

TWPE a 

Cl/T

Dis

NY0226017 Keyspan - East Hampton Icf East Hampton Minor Y NANY0226025 Keyspan - Montauk Icf Montauk Minor Y NA NY0226033 Southamptom Icf Southampton Minor Y NANY0259055 DTE Tonawanda LLC Buffalo Minor Y NA NY0265039 White Plains Substation White Plains Minor Y NA NY0266515 Brookhaven Energy Yaphank Minor N NANY0267538 Astoria Energy Power Plt Astoria Minor Y NA NY0268003 Consolidated Edison Co Of NY White Plains Minor Y NANY0270407 TBG Cogen Partners Hicksville Minor Y NA NY0270423 Bayswater/Jamaica Bay Peak Fac Far Rockaway Minor Y NANY0271438 Tomson Converter Station Shoreham Minor Y NAOH0041335 Prince Inland Terminal Co Belpre Belpre Minor N NA PA0020435 White Haven WWTP White Haven Minor N NAPA0061590 Eagle Rock Community Assoc Hazleton Minor N NAPAR900004 Convanta Delaware Valley LP Chester Minor N NAUTS000002 Salt Lake City Corporation Salt Lake City Minor N NA 

Source: [U.S. EPA, 2009b]. a – TWPE was not calculated for minor plants in the DMRLoads2007 database. 

b – Cl – Chlorine; TRO – Total residual oxidants; and CPO – Chlorine produced oxidants (EPA has not developed TWFs for TRO and loads are not included in TWPE totals). Plants shown in bold identify plants for which EPA was able to acquire and review the plant’s NPDES permit. NA – Not Available. The plant is either a minor discharger, in which case EPA does not calculate TWPE, or the plant did not report bo

data and/or the plant reported only parameters for which EPA has not developed a TWF (e.g., TSS, BOD5). 

Note: The rows with bold text in the table identify the plants for which EPA reviewed NPDES permits. EPA had initially selected the f

review based on combination utilities identified in the 2002 PCS database; however, two of these five plants are not identified as comb

DMRLoads2007 database. Therefore, only three of the plants for which EPA reviewed permits are identified in the table. 
Final Detailed Study Report Chapter 7 – Preliminary Investigation of Other Industry Segments 

7-31 

7.4.2 NPDES Permit Review 

During the detailed study, EPA obtained NPDES permits for five35 plants initially 

believed to be combination utilities. EPA reviewed the permits to determine the operations at the 

plants, the types of wastewaters generated by the plants, and how the wastewaters were being 

permitted. 

Through the permit review, EPA identified one of the five combination utilities as an 

electric generating plant. The Rifle Station plant in Rifle, Colorado, operates a natural gaspowered combined cycle system with a total electric generating capacity of 108 MW. According 

to the 2003 Summary of Rationale for the permit, the Rifle plant is an electric peaking power 

generation plant categorized by the permitter to be within SIC code 4911 – Electric Services. 

Until 2002, the plant was operated in conjunction with a large greenhouse that utilized steam 

heat provided by the plant. The plant still provides steam heat to the greenhouse; however, the 

peaking plant and greenhouse are currently under separate ownership [CDPHE, 2003]. 

The NPDES permit for this plant also indicated that the cooling tower blowdown 

contributes 50 to 70 percent of the total discharge, which is intermittent due to the sporadic 

demand for electric power from this peaking plant. The wastewater discharged by this plant is 

currently limited by the requirements of the Steam Electric Power Generating effluent 

guidelines36, since it meets the applicability at 40 CFR Part 423.10 [CDPHE, 2003]. 

EPA found the remaining four plants to be wastewater treatment and water supply plants. 

None of these plants reported an electric generating unit to the EIA. In addition, the limited 

amount of information on the waste streams provided in the permits indicated they had little in 

common with the waste streams expected from a steam electric generating plant, as previously 

described in Section 3.2. Since these plants do not appear to be “...primarily engaged in the 

generation of electricity for distribution and sale...” [40 CFR Part 423.10], they do not meet the 

current applicability of the Steam Electric Power Generating effluent guidelines. Further, the 

processes and wastewaters generated by these non-electric-generating plants are not similar to 

those of steam electric plants regulated under the Steam Electric Power Generating effluent 

guidelines. 

 

Table 7-7

35 EPA selected these five plants based on combination utilities identified in the 2002 PCS database. Two of these 

five plants are not identified as combination utilities in the DMRLoads2007 databases. The other three plants are 

listed in . 

36 The permit did not address limitations on copper and iron discharged with chemical metal cleaning wastewaters. 
Final Detailed Study Report Chapter 8 – References 

8-1 

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178. U.S. EPA. 2008b. Fly Ash. Available online at: 

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199. Xcel Energy. 2009a. Xcel Energy's Response to Questions Regarding Bay Front Plant. 

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201. Xcel Energy. 2009c. Xcel Energy's Response to Questions Regarding Red Wing Plant. 

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