MEMORANDUM

TO: Steam Electric Rulemaking Record

FROM: TJ Finseth, ERG

Danielle Lewis, ERG

DATE: January 28, 2013

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 (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. 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 analyses.

The principal source of information and data used in developing the proposed ELGs is the 

industry response to the survey distributed by EPA 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 dynamic industry with frequent changes in air pollution controls 

and/or ash handling systems. The Steam Electric Survey requested information on plants for the 

2009 operating 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 year the ELGs are expected to be promulgated.1

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

appropriate. EPA gathered information from public sources, including company press releases 

and information from technology vendors, to account for the following:

 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.

Planned modifications that would result in compliance with the proposed ELGs by December 31, 

2014 were excluded from the costs and loadings analysis, 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 68 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 31, 2014;

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 excluded3in the costs and loadings analysis:

 Excluded — Plants retiring units or converting fuels by December 31, 2014, were 

excluded from the analysis.

 

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 proposed 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 December 31, 2014.
Memorandum

January 28, 2013

Page 3

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

included in the analysis.

 Not Applicable (NA) — Plants were not included in the costs and loadings 

because they were not surveyed or do not discharge any of the wastestreams 

regulated by the proposed ELGs.

 Included/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 loadings 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 proposed ELGs. EPA evaluated 

ash handling conversion announcements using criteria similar to those 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 analysis due to system 

upgrades/modifications that EPA identified by August 2012.

4

EPA modified the costs and 

loadings analysis for 11 plants due to upgrades/modifications in ash handling systems. Only 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 analysis.

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

December 31, 2014

Plant Name City State

Included or Excluded 

from Costs and Loadings

Document Control 

Number

Albright Power Station Albright WV Excluded SE01261

Alma Alma WI Excluded SE02051

Altavista Power Station Altavista VA NA SE00952

Armstrong Power Station Adrian PA Excluded 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 costs 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 Name City State

Included or Excluded 

from Costs and Loadings

Document Control 

Number

Ashtabula Power Plant Ashtabula OH Excluded SE01262

Avon Lake Power Plant Avon Lake OH Included SE01974

B C Cobb Power Plant Muskegon MI Included SE01970

Bay Shore Plant Oregon OH Excluded SE01262

Ben French Station Rapid City SD Excluded SE01969

Big Sandy Louisa KY Included SE01739

B L England Beesleys Point NJ Included SE01824

Canadys Station Walterboro SC Included/Excluded

a

SE01811

Cape Fear Steam Electric Plant Moncure NC Excluded SE01751

Cliffside Steam Station Cliffside NC Excluded SE01971

Clinch River Plant Cleveland VA Included SE01739

Conesville Conesville OH NA SE01739

Contra Costa Power Plant Antioch CA NA SE01976

Crawford Station Chicago IL Excluded SE01973

Exelon - Cromby Generating 

Station

Phoenixville PA NA SE00954

NIPSCO D. H. Mitchell 

Generating Station

Gary IN NA SE01334

Dunkirk Generating Plant Dunkirk NY Included SE01975

Eastlake Power Plant Eastlake OH Excluded SE01262

Eddystone Generating Station Eddystone PA Excluded SE00951

Elrama Power Plant Elrama PA Excluded SE01974

Fisk Station Chicago IL Excluded SE01973

Gallagher Generating Station New Albany IN Excluded SE00950

Glen Lyn Plant Glen Lyn VA Included SE01739

H.B. Robinson Fossil Plant Hartsville SC Excluded SE01751

Lee Plant Goldsboro NC NA SE01746

Hopewell Power Station Hopewell VA NA SE00952

Hutsonville Power Station Hutsonville IL Excluded SE00943

JR Whiting Power Plant Luna Pier MI Included SE01970

John Sevier Rogersville TN NA SE00757, SE01747

Johnsonville New Johnsonville TN NA SE00757, SE01749

JT Deely Steam Electric Station San Antonio TX Included SE00949

Kammer Plant Captina WV Included SE01739

Kanawha River Plant Glasgow WV Included SE01739

JC Weadock Power Plant Essexville MI Included SE01970

Lake Shore Plant Cleveland OH Excluded SE01262

L V Sutton Steam Electric Plant Wilmington NC Excluded SE01746

McMeekin Station Columbia SC Included 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 Name City State

Included or Excluded 

from Costs and Loadings

Document Control 

Number

Meredosia Power Station Meredosia IL Excluded SE00943

Muskingum River Beverly OH Included SE01739

Neil Simpson Gillette WY NA SE01969

New Castle Power Plant West Pittsburg PA Included SE01974

Niles Power Plant Niles OH Excluded SE01974

Osage Power Plant Osage WY Excluded SE01740, SE01969

Philip Sporn Graham Station WV Included SE01739

Picway Lockbourne OH Included SE01739

Plant Harllee Branch Milledgeville GA Excluded SE01334

Plant Mitchell Albany GA Excluded SE01334

RRI Energy Inc. Portland 

Generating Station

Mt. Bethel PA Included SE01974

Mirant Potomac River Alexandria VA NA SE00948

R. Paul Smith Power Station Williamsport MD Excluded SE01262

Rivesville Power Station Rivesville WV Excluded SE01261

Salem Harbor Station Salem MA NA SE01742

Shawville Shawville PA Included SE01974

Southampton Power Station Franklin VA NA SE00952

State Line Energy, LLC Hammond IN NA SE01741

AEP Tanners Creek Plant Lawrenceburg IN Included SE01739

Titus Generation Station Birdsboro PA Included SE01974

Urquhart Station Beech Island SC Excluded SE01811

Waukegan Station Waukegan IL Included SE01976

Walter C Beckjord Station New Richmond OH Included SE01743

W H Weatherspoon Steam 

Electric Plant

Lumberton NC Excluded SE01745

Welsh Pittsburg TX Excluded SE01739, SE01972

Widows Creek Stevenson AL NA SE00757

Willow Island Power Station Willow Island WV Excluded SE01261

a – One of three generating units are planned to be retired by December 31, 2014.

Table 2. Plants with at Least One Generating Unit Upgrading/Modifying Ash Handling 

Practices by December 31, 2014

Plant Name City State Upgrade/Modification

Document Control 

Number

Allen Steam Plant Memphis TN Dry Fly Ash Conversion SE02043, SE02044

Bull Run Clinton TN Dry Bottom Ash Conversion SE02043, SE02044

Colbert Tuscumbia AL Dry Bottom Ash Conversion SE02043, SE02044

Cumberland Cumberland City TN Dry Bottom Ash 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 Name City State Upgrade/Modification

Document Control 

Number

Gallatin Gallatin TN Dry Fly Ash and Bottom Ash 

Conversion

SE02043, SE02044

John Sevier Rogersville TN Dry Bottom Ash 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 Ash Conversion SE02043, SE02044

Widows Creek Stevenson AL Dry Fly Ash and Bottom Ash 

Conversion

SE02043, SE02044