MEMORANDUM

TO: Steam Electric Rulemaking Record

FROM: TJ Finseth, ERG

Danielle Lewis, ERG

DATE: April 19, 2013

SUBJECT: Additional Announced Retirements Not Accounted for in the Proposed ELGs

ERG is providing technical support to the U.S. Environmental Protection Agency’s Office of 

Water, Engineering and Analysis Division (EAD) for development of effluent limitations 

guidelines and standards (ELGs) for the Steam Electric Power Generating Industry. EPA, with 

the support of ERG, distributed the Questionnaire for the Steam Electric Power Generating 

Effluent Guidelines (Steam Electric Survey) to 733 power plants in the summer of 2010 to gather 

plant-specific data on the steam electric industry. The Steam Electric Survey requested data on 

plant operations in 2009. EPA used the collected data to inform various analyses including, but 

not limited to, estimating the compliance costs and pollutant removals associated with the 

proposed ELGs, developing the profile of the industry, and obtaining characterization data for 

the wastestreams generated by the industry. 

EPA recognizes that plant operations and future plans regarding upgrades and modifications may

have changed since the plants submitted responses to the Steam Electric Survey. Therefore, ERG 

gathers information on an ongoing basis from public sources, including company press releases 

and information from technology vendors to account for the following changes to the industry:

 Plants retiring units;

 Plants converting fuel types to eliminate fossil fuel combustion residuals, 

especially residuals from coal or petroleum coke;

 Plants upgrading a flue gas desulfurization (FGD) or leachate wastewater 

treatment system; and

 Plants converting one or more units to a dry fly or bottom ash handling system.

The memorandum entitled, “Changes to Industry Profile for Steam Electric Generating Units for 

the Steam Electric Effluent Guidelines Proposed Rule” (DCN SE02033), describes the process 

ERG used to identify and verify the retirements, fuel conversions, upgrades, and ash system 

conversions at plants. The memorandum also provides a listing of all the changes to the industry

profile that ERG incorporated for the proposed ELGs. Specifically, as described in that 

memorandum, due to the need to complete certain analyses (e.g., compliance costs, pollutant 

loadings) to meet the deadline for proposing the revised ELGs, ERG incorporated unit 
Memorandum

April 19, 2013

Page 2

retirements or fuel conversions announced through August 2012 in the costs and loadings 

analyses for the proposed ELGs. ERG was not able to incorporate retirements announced after 

August 2012 into the costs and loadings analyses.

This memorandum lists those additional unit retirements or fuel conversions announced after 

August 2012 (through the date of this memorandum), and provides an estimate of the reductions 

in incremental compliance costs and pollutant reductions that would result from these 

retirements/conversions. For this analysis, ERG considered announced plans through 2022, 

which marks the end of the implementation period for the ELGs. Therefore, in addition to 

assessing the retirements and fuel conversions announced since August 2012, ERG also 

reevaluated the announcements identified prior to August 2012 because ERG only excluded 

plants/units from the costs and loadings analyses if the retirement/conversion was scheduled to 

occur on or prior to December 31, 2014.1 ERG will consider all of these announcements, as well 

as any additional future announcements, when developing the industry profile and the 

compliance costs and loadings analyses for the final ELGs.

Table 1 lists the name and location of plants announcing the retirement or fuel conversion2of at 

least one generating unit scheduled to occur by December 31, 2022, that were not already

incorporated into EPA’s industry profile and costs and loadings analyses for the proposed ELGs. 

Table 1 also identifies the company press release or other source documenting the 

announcement, which EPA has included in the rulemaking record.

Table 1. Plants with at Least One Generating Unit Retiring or Converting Fuels by 

December 31, 2022, but Not Incorporated in the Proposed ELG

Plant Name City State

Document Control 

Number

Avon Lake Power Plant Avon Lake OH SE01974

B.C. Cobb Power Plant Muskegon MI SE01970

Big Sandy Plant Louisa KY SE01739

Bremo Power Station Bremo Bluff VA SE02943

Buck Steam Station Salisbury NC SE03800

Canadys Plant Walterboro SC SE01811

Cane Run Louisville KY SE02938

Chesapeake Energy Center Chesapeake VA SE02943

Clinch River Plant Cleveland OH SE01739

Dolphus M. Grainger Generating Station Conway SC SE02937

Edgewater Generating Station Edgewater WI SE02941

Glen Lyn Plant Glen Lyn PA SE01739

J.C. Weadock Power Plant Essexville MI SE01970

 

1

For the proposal, EPA used December 31, 2014 as the cutoff date for retirements because the promulgation of the 

final ELGs is scheduled to occur in 2014.

2 ERG did not identify any companies announcing plans to convert generating units from wet to dry ash handling or 

upgrades to plant FGD and/or leachate treatment systems which would result in exclusion from the EPA’s industry 

profile.
Memorandum

April 19, 2013

Page 3

Table 1. Plants with at Least One Generating Unit Retiring or Converting Fuels by 

December 31, 2022, but Not Incorporated in the Proposed ELG

Plant Name City State

Document Control 

Number

J.E. Corette Billings MA SE02940

J.R. Whiting Power Plant Luna Pier MI SE01970

Jefferies Generating Station Moncks Corner SC SE02937

Kammer Plant Captina WV SE01739

Kanawha River Plant Glasgow WV SE01739

Muskingum River Plant Beverly OH SE01739

Nelson Dewey Generating Station Cassville WI SE02941

New Castle Power Plant West Pittsburg PA SE01974

Phillip Sporn Plant Graham Station WV SE01739

Picway Plant Lockbourne OH SE01739

Plant Branch Milledgeville GA SE03799

Plant Kraft Port Wentworth GA SE03799

Plant McManus Brunswick GA SE03799

Plant Yates Newnan GA SE03799

Portland Generating Station Mt. Bethel PA SE01974

Riverbend Steam Station Mount Holly NC SE03800

Riverside Generating Station Bettendorf IA SE03801

San Juan Generating Station Waterflow NM SE03802

Shawville Shawville PA SE01974

Tanners Creek Plant Lawrenceberg IN SE01739

Titus Generation Station Birdsboro PA SE01974

Walter C Beckjord Station New Richmond OH SE01743

Walter Scott Jr Energy Center Council Bluffs IA SE03801

Yorktown Power Station Yorktown VA SE02943

Table 2 presents estimated incremental annualized costs and pollutant removals, by wastestream 

and regulatory option, for three groups of plants:

 “Current Population” - the industry profile assumed for the proposed ELGs (incorporates

changes (e.g., announced unit retirements and fuel conversions) identified through 

August 2012);

 “Additional Retirements” - the plants listed in Table 1 above (e.g., unit retirements and 

fuel conversions announced after August 2012 or retirements/conversions announced 

prior to August 2012 that are scheduled to occur between January 1, 2015 and December 

31, 2022);

 “Current Population Excluding Additional Retirements” – the industry profile that would 

have been assumed for the proposed ELGs, if EPA had incorporated all changes that have 
Memorandum

April 19, 2013

Page 4

been identified and scheduled to occur on or prior to December 31, 2022 (i.e., “Current 

Population” minus “Additional Retirements”).

ERG considers the estimates presented in Table 2 for the “Additional Retirements” population, 

and by difference for the “Current Population Excluding Additional Retirements” population, to 

be estimates because they were calculated using an abbreviated methodology as compared to that

used for the proposed ELGs. Specifically, for each plant listed in Table 1, ERG prorated the 

plant’s ELG costs and pollutant removals for the proposed rule based on the percentage of the 

plant’s units announced for retirement or fuel conversion that incur costs for each wastestream. 

For example, a plant has three units that incur FGD costs and two units that incur fly ash costs 

and one unit that incurs costs for both FGD and fly ash is announced to be retired prior to 

December 31, 2022. In this example, ERG estimated the “Additional Retirements” portion of this 

plant’s estimated incremental annual compliance costs and pollutant removals as one-third of the 

plant’s FGD costs and pollutant removals for the proposed rule and one-half of the plant’s fly ash 

costs and pollutant removals. 
Memorandum

April 6, 2013

Page 5

Table 2. Estimated Incremental Annualized Costs and Pollutant Removals, by Waste Stream and Regulatory Option, for Three 

Industry Profiles

Waste Stream 

Current Population

Portion of Costs/Removals Associated With 

Additional Changes (e.g., Retirements)

Current Population Excluding 

Additional Changes (e.g., Retirements)

Annualized Pre-Tax 

Compliance Cost 

(in millions, $2010)c

Pollutant 

Removalsa

(TWPE/yr)

Annualized Pre-Tax 

Compliance Cost 

(in millions, $2010)c

Pollutant 

Removalsa

(TWPE/yr)

Annualized Pre-Tax 

Compliance Cost 

(in millions, $2010)c

Pollutant 

Removalsa

(TWPE/yr)

Technology Option

FGD (Chemical Precipitation) $266 1,534,258 $7.5 34,865 $258 1,499,393

FGD (Chemical Precipitation + 

Biological Treatment) $393 2,615,339 $10.6 58,713 $383 2,556,626

Fly Ash (Zero Discharge) $168 2,488,469 $17.9 395,176 $150 2,093,293

Bottom Ash (Zero Discharge) $719 2,705,159 $87.4 209,628 $631 2,495,531

Leachate Only (Chemical 

Precipitation)

Leachate with FGD (Chem Precip + 

Biological Treatment)b$93 37,863 $4.4 741 $89 37,122

Regulatory Option

1 $265.90 1,534,258 $7.5 34,865 $258.36 1,499,393

2 $393.30 2,615,339 $10.6 58,713 $382.74 2,556,626

3 $561.30 5,103,808 $28.5 453,889 $532.83 4,649,919

4 $1,373.20 7,846,830 $120.3 664,259 $1,252.93 7,182,571

a Pollutant removals represent the removals for the plants based on oil-fired units and units with a capacity of 50 MW or less not needing to install the technology basis (i.e., oil-fired units 

and units with a capacity of 50 MW or less do not achieve any removals). The removals exclude the pollutant parameters BOD, COD, TDS, and TSS because they double count the loadings 

for specific pollutants already included.

b Costs and pollutant removals are based on plants that have both FGD wastewater and landfill leachate treating the two wastestreams in a combined treatment system with chemical 

precipitation and biological treatment. Plants that only have landfill leachate treat it in a separate treatment system with chemical precipitation. The costs represent the incremental increase

in the biological treatment system to build a larger system to handle the leachate flow rate. The pollutant removals represent the removals associated with only the leachate stream. These 

costs and removals, in combination with the FGD biological treatment costs and removals, were used for Regulatory Option 4. Plants treating both FGD wastewater and landfill leachate in 

a combined treatment system receive loadings for the biological treatment option. Plants treating landfill leachate in a separate treatment system receive loadings for chemical precipitation 

treatment option.

c Costs shown are pre-tax compliance costs, discounted using 7%; compare to RIA Table 3-2. For details on methodology, see Chapter 3 in RIA.