MEMORANDUM 

TO: Ron Jordan, EPA 

FROM: Becky Schwantes, ERG 

TJ Finseth, ERG 

DATE: 26 February 2010 

SUBJECT: Development of the List of Plant Mailing Addresses for the Steam Electric 

ICR 

As part of EPA’s Steam Electric Power Generating effluent guidelines rulemaking, EPA is 

preparing a questionnaire that will be sent to selected steam electric power plants through an 

information collection request (ICR). To prepare for sending the questionnaire to the plants, 

ERG created a draft list of plant mailing addresses for all potential respondents that are within 

the scope of the ICR. This memorandum describes the development of the list of plant mailing 

addresses. 

ERG first reviewed data reported to DOE’s Energy Information Association (EIA) in the 2007 

EIA-860 reports to identify plants that are likely subject to the Steam Electric Power Generating 

effluent guidelines (40 CFR Part 423). ERG evaluated the following criteria: 

 The plant must report a North American Industry Classification System (NAICS) code of 

22 (Utilities); 

 The plant must operate at least one generating unit that uses coal, gas, oil, petroleum 

coke, or nuclear fuel as the primary energy source (or coal or petroleum coke as the 

secondary energy source); and 

 The plant must operate at least one generating unit using the fuels listed above that uses 

steam as a prime mover, which includes combined cycle generating units. 

Based on these criteria, ERG identified 1,201 plants that are potential respondents for the Steam 

Electric ICR. 

ERG next created a dataset of these plants, including mailing addresses for each of the plants. 

ERG identified the mailing addresses for each of the plants from the 2007 EIA-860 data; 

however, ERG also used Envirofacts to supplement the 2007 EIA-860 where the EIA data 

appeared to be incomplete or incorrect (e.g., data from EIA stated that the street address for 

Austin Northeast Power Station was “Austin”, which is the city the plant is located in and not a 

street address). 

Following creation of the plant dataset, EPA delivered it, as well as the draft glossary for the ICR 

questionnaire, to industry stakeholders (see DCN SE00193) and environmental groups (see DCN 
Memorandum 

February 26, 2010 

Page 2 

SE00192) to get comments/corrections to the addresses included in the list. EPA did not receive 

any comments on the list of mailing addresses from the environmental groups. The Utility Water 

Act Group (UWAG), an industry trade association, provided EPA with comments on the list of 

mailing addresses (see DCN SE00191). UWAG’s comments consisted of the following: 

 Deleting some plants because they are either no longer in existence, permanently shut 

down, closed, or a hydroelectric plant; 

 Adding some plants that were not previously included; and 

 Correcting addresses with inaccuracies and/or identifying addresses needed for overnight 

delivery. 

As part of the comments, UWAG also provided additional recipient and alternate delivery 

options should EPA choose to send the questionnaire to corporate contacts instead of sending it 

directly to the plant manager. 

The UWAG comments will be incorporated into the plant dataset after the 2nd FRN public 

comment period, along with any additional comments that may be received. 

.