### MEMORANDUM

TO: Ron Jordan, EPA

FROM: Becky Schwantes, ERG TJ Finseth, ERG

DATE: 26 February 2010

SUBJECT: Development of the List of Plant Mail ing Addresses for the Steam Electric

ICR

As part of EPA’s Steam Electric Power Gene rating effluent guideli nes rulemaking, EPA is preparing a questionnaire that wi ll be sent to selected steam el ectric power plants through an information collection request (ICR). To prepar e for sending the questionnaire to the plants, ERG created a draft list of plant mailing addresse s for all potential respondents that are within the scope of the ICR. This memorandum descri bes the development of the list of plant mailing

addresses.

ERG first reviewed data repor ted to DOE’s Energy Information Association (EIA) in the 2007 EIA-860 reports to identify plants that are likely subject to th e Steam Electric Power Generating effluent guidelines (40 CF R Part 423). ERG evaluated the following criteria:

 The plant must report a North American Indus try Classification System (NAICS) code of 22 (Utilities);

 The plant must operate at least one generati ng 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 list ed above that uses steam as a prime mover, which includes combined cycle generating units.

Based on these criteria, ERG iden tified 1,201 plants that are poten tial respondents for the Steam

Electric ICR.

ERG next created a dataset of these plants, incl uding 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 s upplement 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 delivere d it, as well as the draft glossary for the ICR questionnaire, to industry stakeholders (see DCN SE00193) and environmental groups (see DCNMemorandum 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 questionna ire to corporate contacts instead of sending it directly to the plant manager.

The UWAG comments will be incorporated into the plant dataset after the 2 nd FRN public comment period, along with any additional comments that may be received.

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