## MEMORANDUM

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

Danielle Lewis , ERG **DATE:** January 28 , 201 3 **SUBJECT: Changes to Industry Profile for Steam Electric Generating Units**  **for the** 

**Steam Electric Effluent Guidelines Proposed Rule** 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 E lectric 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 char acterization data for the waste streams generated by the industry

. EPA recognizes that pl ant operations and future plans regarding upgrades and modifications may have changed since the plants submitted respon ses to the Steam Electric Survey

. This memorandum discusses changes in the operating status of steam electric generating units since 2009 and how EPA incorporated the changes into the profile developed for the industry and the costs and loadings anal ys e s. The principal source of information and data used in developing the proposed ELG s is the industry response to the survey

distributed by

E PA under the authority of section 308 of the Clean Water Act. The Steam Electric Survey obtained information on the following :

 

### General power plant operations;
 

### Flue gas desulfurization system operations;
 

### Ash handling operations;
 

### Pond/impoundment system and other wastewater treatment operations;
 

### Metal cleaning process operations;
 

### Pond/impoundment and landfill management practices;
 

### Pond/impoundment and landfill leachate sampling data; and
 

### Nuclear power operations. The steam electric industry is a dyn amic indus try with frequent changes in air pollution controls and/or ash handling s ys tems
. The Steam Electric Survey requested information on plants for the 2009 operatin g year . EPA recognizes that there may have been changes to plant operations

### Memorandum

January 28, 2013 Page 2 between 2009 and the time the survey was distributed in 2010 and additional changes that will occur by 2014 , the ye ar the ELG s are expected to be promulgated. 1 

### EPA attempted to account for these planned changes in the costs and loadings analysis , where appropriate

. EPA gather ed information from public sources , including company press releases and information from technology vendors , to account for the following:

 

### Plants retiring units ;

 

### Plants converting fuel ty pe s to eliminate fossil fuel combustion residual s , especiall y residuals from coal or petroleum coke ;

 

### Plants upgrading a f lue g as 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. P lanned modifications that would result in compliance with the proposed ELG s by December 31, 2014 were excluded from the costs and loadings anal ys is , described in the Incremental Costs and Pollutant Removals for Proposed Effluent Limitation Guidelines and Standards for the Steam Electric Generating Point Source Category (DCN SE01964 )

. EPA identified 6 8 plants that by August 2012 had announced the retirement or fuel conversion of at least one generating unit that is scheduled to occur by December 31, 2014

. 2 

### Table 1 lists the name and location of plants announcing the retirement or fuel conversion of a generating unit

. EPA determined that generating units would not incur incremental costs or loading reductions associated with the proposed ELGs if the unit met the following criteria: 1. The retirement or fuel modification had to be to complete by December 3 1, 201 4; and 2. The retirement had to be substantiated by information directly from the operating company, either through an article, report, or press release. Table 1 indicates whether the units were included or excluded3 

### in the costs and loadings analysis:

 

### Excluded

— Plants retiring units or converting fuels by December 31, 2014 , were excluded from the anal ys is

.

1 For the analyses that will be conducted for the final ELGs, EPA may account for additional changes that will occur by 2017, the year implementation of ELG revisions more stringent than the current ELGs will begin

. 2 Due to the need to complete certain analyses to meet the deadline for proposing revised ELGs, EPA was not able to incorporate unit retirements or fuel conversions announced after August 2012 in the costs and loadings analyses for the propos ed ELGs. EPA may continue to evaluate announced retirements and fuel conversions and may factor announcements made after August 2012 in the analyses for the final ELGs. 3 For the purpose of this memorandum, “excluded” refers to generating units that are not expected to incur incremental costs or loading reductions associated with the proposed ELGs, as a result of the unit being retired or undergoing fuel conversion by Dece mb er 31, 2014.

### Memorandum

January 28, 2013 Page 3

 

### In cluded

— Plants completing the modification after December 31, 2014 , were

included in the an al ys is

.

 

### Not Applicable (NA)

— Plants were not included in the costs and loadings because they

were not surveyed or do not discharge any of the waste streams regulated b y the proposed ELG s .

 

### In cluded/Excluded

— Plants listed as both included and excluded indicates that some units at the plant will be modified prior to December 31, 2014 , while others will be modified after December 31, 2014

. Generating units modified after December 31, 2014 , were included in the costs and loadings analysis. EPA modified the costs and loading s analysis for 30 plants based on the planned retirement or fuel conversion of at least one generating unit

. Through conversations with specific plants and vendors, as well as company press releases , EPA identified several plants that are in the process of upgrading their ash handling practices on specific generating units that will result in compliance with the propo sed ELG s . EPA evaluated ash handling conversion announcements using criteria similar to th ose used to evaluate retirement/fuel conversion announcements
. EPA determined that generating units would not incur incremental costs or loading reductions associated with certain wastestreams if the unit met the following criteria: 1. The upgrade/modification had to be to complete by December 31, 2014 , and 2. The upgrade had to be substantiated by information directly

from the operating company, either through an article, report, or press release. Table 2 lists the name and location of those plants excluded from the anal ysis due to system upgrades/modifications that EPA identified by August 2012

. 4 

### EPA modified the costs and loading s analysis f

or 11 plants due to upgrades/modifications in ash handling systems. Onl y the affected generating units were removed from the analysis, in some cases this resulted in the entire plant being excluded from the costs and loadings anal ys is. **Table 1**  **. Plants with at Least One Generating Unit Retiring or Converting Fuels by**  **December 31, 2014**

**Plant Nam e**  **City State**  **Included or Excluded from** **Costs and Loadings Document Control**  **Number** Albright Power Station Albright WV Exclude d SE01261 Alma Alma WI Exclude d SE02051 Altavista Power Station Altavista VA NA SE00952 Armstrong Power Station Adrian PA Exclude d SE01262

4 Due to the need to complete certain analyses to meet the deadline for proposing revised ELGs, EPA was not able to incorporate ash handling conversions (i.e., upgrades or other relevant modifications) announced after August 2012 in the cost s and loadings analyses for the proposed ELGs. EPA may continue to evaluate announced conversions and may factor announcements made after August 2012 in the analyses for the final ELGs.

### Memorandum

January 28, 2013 Page 4 **Table 1**  **. Plants with at Least One Generating Unit Retiring or Converting Fuels by**  **December 31, 2014**

**Plant Nam e**  **City State**  **Included or Excluded from** **Costs and Loadings Document Control**  **Number** Ashtabula Power Plant Ashtabula OH Exclude d SE01262 Avon Lake Power Plant Avon Lake OH Include d SE01974 B C Cobb Power Plant Muskegon MI Include d SE01970 Bay Shore Plant Oregon OH Exclude d SE01262 Ben French Station Rapid City SD Exclude d SE01969 Big Sandy Louisa KY Include d SE01739 B L England Beesleys Point NJ Include d SE01824 Canadys Station Walterboro SC Include d/Exclude d a SE01811 Cape Fear Steam Electric Plant Moncure NC Exclude d SE01751 Cliffside Steam Station Cliffside NC Exclude d SE01971 Clinch River Plant Cleveland VA Include d SE01739 Conesville Conesville OH NA SE01739 Contra Costa Power Plant Antioch CA NA SE01976 Crawford Station Chicago IL Exclude d SE01973 Exelon

- Crom

by Generating Station Phoenixville PA NA SE00954 NIPSCO D. H. Mitchell Generating Station Gary IN NA SE01334 Dunkirk Generating Plant Dunkirk NY Include d SE01975 Eastlake Power Plant Eastlake OH Exclude d SE01262 Eddystone Generating Station Eddystone PA Exclude d SE00951 Elrama Power Plant Elrama PA Exclude d SE01974 Fisk Station Chicago IL Exclude d SE01973 Gallagher Generating Station New Albany IN Exclude d SE00950 Glen Lyn Plant Glen Lyn VA Include d SE01739 H.B. Robinson Fossil Plant Hartsville SC Exclude d SE01751 Lee Plant Goldsboro NC NA SE01746 Hopewell Power Station Hopewell VA NA SE00952 Hutsonville Power Station Hutsonville IL Exclude d SE00943 JR Whiting Power Plant Luna Pier MI Include d SE01970 John Sevier Rogersville TN NA SE00757, SE01747 Johnsonville New Johnsonville TN NA SE007 5 7, SE01749 JT Deely Steam Electric Station San Antonio TX Include d SE00949 Kammer Plant Captina WV Include d SE01739 Kanawha River Plant Glasgow WV Include d SE01739 JC Weadock Power Plant Essexville MI Include d SE01970 Lake Shore Plant Cleveland OH Exclude d SE01262 L V Sutton Steam Electric Plant Wilmington NC Exclude d SE01746 McMeekin Station Columbia SC Include d SE01811

### Memorandum

January 28, 2013 Page 5 **Table 1**  **. Plants with at Least One Generating Unit Retiring or Converting Fuels by**  **December 31, 2014**

**Plant Nam e**  **City State**  **Included or Excluded from** **Costs and Loadings Document Control**  **Number** Meredosia Power Station Meredosia IL Exclude d SE00943 Muskingum River Beverly OH Include d SE01739 Neil Simpson Gillette WY NA SE01969 New Castle Power Plant West Pittsburg PA Include d SE01974 Niles Power Plant Niles OH Exclude d SE01974 Osage Power Plant Osage WY Exclude d SE01740 , SE01969 Philip Sporn Graham Station WV Include d SE01739 Picway Lockbourne OH Include d SE01739 Plant Harllee Branch Milledgeville GA Exclude d SE01334 Plant Mitchell Albany GA Exclude d SE01334 RRI Energy Inc. Portland Generating Station Mt. Bethel PA Include d SE01974 Mirant Potomac River Alexandria VA NA SE00948 R. Paul Smith Power Station Williamsport MD Exclude d SE01262 Rivesville Power Station Rivesville WV Exclude d SE01261 Salem Harbor Station Salem MA NA SE01742 Shawville Shawville PA Include d SE01974 Southampton Power Station Franklin VA NA SE00952 State Line Energy, LLC Hammond IN NA SE01741 AEP Tanners Creek Plant Lawrenceburg IN Include d SE01739 Titus Generation Station Birdsboro PA Include d SE01974 Urquhart Station Beech Island SC Exclude d SE01811 Waukegan Station Waukegan IL Include d SE01976 Walter C Beckjord Station New Richmond OH Include d SE01743 W H Weatherspoon Steam Electric Plant Lumberton NC Exclude d SE01745 Welsh Pittsburg TX Exclude d SE01739 , SE01972 Widows Creek Stevenson AL NA SE00757 Willow Island Power Station Willow Island WV Exclude d SE01261 a
– One of three generating units are planned to be retired by December 31, 201 4

. 

### Table **2 .**  **Plants with at Least One Generating Unit Upgrading/** **Modifying Ash Handling Practices**  **by December 31, 2014**

**Plant Nam e**  **City State**  **Upgrade/ Modification**  **Document Control Number**  Allen Steam Plant Mem phis TN Dry Fly Ash Conversion SE 0 2043 , SE02044 Bull Run Clinton TN Dry Bottom A sh Conversion SE02043, SE02044 Colbert Tuscumbia AL Dry Bottom A sh Conversion SE02043, SE02044 Cumberland Cumberland City TN Dry Bottom A sh Conversion SE02043, SE02044

### Memorandum

January 28, 2013 Page 6 **Table 2**  **. Plants with at Least One Generating Unit**  **Upgrading/ Modifying Ash Handling**  **Practices by December 31, 2014** 

**Plant Nam e**  **City State**  **Upgrade/ Modification**  **Document Control Number**  Gallatin Gallatin TN Dry Fly Ash and Bottom

A sh Conversion SE02043, SE02044 John Sevier Rogersville TN Dry Bottom A sh Conversion SE02043, SE02044 Johnsonville New Johnsonville TN Dry Fly Ash and Bottom Ash Conversion SE02043, SE02044 Kingston Harriman TN Dry Fly Ash and Bottom Ash Conversion SE02043, SE02044 Paradise Drakesboro KY Dry Fly Ash and Bottom Ash Conversion SE02043, SE02044 Shawnee West Paducah KY Dry Bottom A sh Conversion SE02043, SE02044 Widows Creek Stevenson AL Dry Fly Ash and Bottom Ash Conversion SE02043, SE02044