### MEMORANDUM

**TO:** Steam Electric Rulemaking Record
**FROM:** TJ Finseth, ERG

Danielle Lewis , ERG
**DATE:** April 19 , 201 3
**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 (ELG s ) 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 a ssociated with the proposed ELG s , 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 respon ses 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, especiall y residuals from coal or petroleum coke;

 Plants upgrading a flue gas desulfurization (FGD) or leachate wastewater treatment s ys tem; and

 Plants converting one or more units to a dry fly or bottom ash handling s ys tem. The memorandum entitled, “Changes to Industry Profile for Steam Electric Generating Units for the Steam Electric Effluent Guidelines Proposed Rule ” (DCN SE 02033 ) , describes the process ERG use d to identify

and verify

the retirements, fuel conversions, upgrades, and ash s ys tem conversions at plants . The memorandum also provides a listing of all the changes to the industry profile that ERG incorporated for the proposed ELGs. Specificall y, a s described in that memorandum, d

ue to the need to complete certain anal ys es (e.g., compliance costs, pollutant loadings) to meet the deadline for proposing the revised ELGs, ERG incorporate d unitMemorandum

April 19 , 2013 Page 2
retirements or fuel conversions announced through August 2012 in the costs and loadings anal ys es for the proposed ELG s
. ERG was not able to incorporate retirements announced after August 2012 into the costs and loadings anal ys es. 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 anal ys is, 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 anal ys es 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 announc ements , when developing the industry profile and the compliance costs and loadings anal ys es for the final ELGs. Table 1 lists the name and location of plants announcing the retirement or fuel conversion2 of at least one generating unit scheduled to occur b y December 31, 2022 , that were not already incorporated into EPA’s industry profile and costs and loading s anal ys es 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 F**  **uels by**

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

**Plant Nam e**  **City State**  **D ocument 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 com panies 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 F**  **uels by**

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

**Plant Nam e**  **City State**  **D ocument 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 SE0 3799 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 haveMemorandum

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 Popul ation Excluding Additional Retirements” population, to be estimates because they were calculated using an abbreviated methodology as compared to th at used for the proposed ELGs. Specificall y, 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 fl y 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 Removals**  **a (TWPE/yr)**  **Annualized Pre**
**- Tax** 

**Compliance Cost (in**  **millions, $2010) c**  **Pollutant Removals**  **a (TWPE/yr)**  **Annualized Pre**
**- Tax** 

**Compliance Cost (in**  **millions, $2010) c**  **Pollutant Removals**  **a (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 sepa rate 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.