From: Jordan, Ronald

To: Thomas Finseth

Subject: FW: Response to Proposed Steam Electric Effluent Guidelines Data Request

Date: Monday, February 24, 2014 10:33:00 AM

Attachments: Analytical Data Table.xlsx

TMT15 msds.pdf

QGESS_DetailCoalSpecs_Rev4_20130510.pdf

Keystone Laboratory Reports 2012.2013.pdf

SE04293_Data Request Spreadsheet_NRG_Energy_01212014.xlsx

Process Flow Diagram for FGD WWT.pdf

From: Frank, Stephen [mailto:Stephen.Frank@nrgenergy.com]

Sent: Friday, February 21, 2014 9:02 AM

To: Jordan, Ronald

Cc: Alicea, Jezebele; Flanders, Phillip; Schroeder, Cuc; Shriner, Paul

Subject: Response to Proposed Steam Electric Effluent Guidelines Data Request



### Dear Mr. Jordan,

As requested on January 17, 2014, GenOn Northeast Management

Company (GenOn), a subsidiary of NRG Energy, is providing information

about the influent and effluent from the Keystone Generating Station’s

(Keystone) FGD Scrubber Wastewater Treatment Plant (WWTP). This

information includes:

1. Arsenic and mercury concentration data collected during the period

January 2012 to December 2013. The data are presented on the

attached Analytical Data Table. Note that influent flow data was

not available. However, because we collect our influent and

effluent samples on the same day, the effluent flow rates are

representative of the influent flow rates. Minor differences in flows

would be associated with moisture in filter cake solids and the

addition of water associated with chemical additives.

Samples represent the same sampling locations as those used

during EPA's sampling episode at the Keystone Generating Station

that took place in September 2010, including the FGD scrubber

purge (from purge tank) and the effluent discharged to the

Allegheny River (prior to commingling with any other waste

streams. A process flow diagram of the system sampled, including

the specific sample

locations (SP-1 [influent] and SP-2 [effluent]) for which data are

being provided is attached. Laboratory reports associated with the

sampling data are attached (note that the oldest to newest files

generally are reflective of the oldest to newest sample collection

dates).

2. An MSDS for the organosulfide additive (TMT 15®) used in the FGD

### WWTP is attached. Chemicals and dosages added to the treatment

system, including location of injection points are shown on the

Process Flow Diagram.

3. As discussed, Keystone is operated by GenOn and has multiple

owners, and coal is selected by the Keystone Conemaugh Owners

Group. In 2012 and 2013, the coal used at Keystone was High

Volatile Bituminous coal from the Appalachian Basin. Multiple coal

supplies are blended and used at the station. Exhibit 6.2 in the

QGESS report summarizes BTU, Sulfur, Mercury and Chlorine

information, which is generally consistent with the blends of coal

used at Keystone. Our coal will mainly come from PA, WV and IL in

the future.

4. Information regarding the specific type and source of coal used at

Keystone was not available. However, Keystone does monitor

several parameters that are being requested. This information is

provided on SE04293 Data Request Spreadsheet NRG Energy

01212014. Specifically, the BTU and Sulfur content data are the

average for the coal blend burned in Unit 1 and Unit 2 on the dates

indicated. In 2012 and 2013, chlorine content was not monitored,

but was consistent with the concentrations provided in Exhibit 6.2

in the QGESS report for Pennsylvania (1,048 ppm dry) and West

Virginia (1,044 ppm dry). As indicated above, our coal will mainly

come from PA, WV and IL in the future. Therefore, the chlorine

content in our fuel blend would increase if utilizing coal from the

Illinois Basin (1,691 ppm dry).

5. Available information for each day of operation in 2012 and 2013

are provided in SE04293 Data Request Spreadsheet NRG Energy

01212014. Average daily ORP data from the Unit 1 & 2 absorbers

are not collected on a consistent basis. Therefore, only a few data

points are available. Chloride concentration, pH, and average daily

ORP are not monitored at the influent to the FGD WWTP. However,

the average of the data provided for the Unit 1 & 2 absorbers

should be representative of the influent to the FGD WWTP.

Electricity Generation output is included on the spreadsheet. Gaps

in the output for each unit represent periods when the units were

not being operated.

In January 2014, Keystone began using a more sensitive analytical

method (Modified Method 200.8) for the analysis of arsenic, selenium and

other trace metals. This new method became available at our local

laboratory (Geochemical Testing) in November 2013. Therefore,

Keystone could provide this data in the future if requested.

Please do not hesitate to contact me with any questions or comments.Stephen M. Frank, PE

Senior Environmental Specialist

Office: 724-597-8310

Mobile: 724-249-3610



### NRG Energy Stephen M. Frank, PE

Senior Environmental Specialist

Office: 724-597-8310

Mobile: 724-249-3610 

### Regards, Steve

From: Jordan, Ronald [ mailto:Jordan.Ronald@epa.gov ]

Sent: Tuesday, January 21, 2014 11:08 AM

To: Frank, Stephen

Cc: Alicea, Jezebele; Flanders, Phillip; Schroeder, Cuc; Shriner, Paul

Subject: RE: Follow up to comments on proposed Steam Electric effluent guidelines



### Steve,

My Friday email should’ve included a couple additional attachments. Please use the attached Excel

files for the data you provide.

Regards,

Ron

From: Frank, Stephen [ mailto:Stephen.Frank@nrgenergy.com ]

Sent: Friday, January 17, 2014 12:24 PM

To: Jordan, Ronald

Cc: Alicea, Jezebele; Flanders, Phillip; Schroeder, Cuc; Shriner, Paul

Subject: RE: Follow up to comments on proposed Steam Electric effluent guidelines



### Ron,

We will review the request internally and with Keystone Generating

Station and get back to you with any questions. Does EPA have an

anticipated schedule for receipt of this additional information?

Thanks, Steve

From: Jordan, Ronald [ mailto:Jordan.Ronald@epa.gov ]

Sent: Friday, January 17, 2014 11:53 AM

To: Frank, Stephen

Cc: Alicea, Jezebele; Flanders, Phillip; Schroeder, Cuc; Shriner, Paul

Subject: Follow up to comments on proposed Steam Electric effluent guidelines

### Good morning Mr. Frank,

As you are aware, on June 7, 2013, EPA published proposed revisions to the effluent limitations

guidelines and standards (ELGs) for the steam electric power generating point source category. The

comment period for the proposed rule closed on September 20. Based on our review of comments

submitted by your company and other comments relating to the proposed ELGs, we have concluded

that additional information is either needed or would be useful in evaluating comments with respect

to FGD wastewater characterization and treatment performance. Please see the attached letter for

a description of the information that EPA is asking you to provide.

We appreciate the information you’ve provided to date, as well as the cooperation your company

provided as EPA collected information for the proposed rule. Should you have any questions

regarding this request for additional information related to the comments we received, please

contact me at jordan.ronald@epa.gov or by phone at (202) 566-1003.

Regards,

Ron Jordan

-------------------------------

Ron Jordan

EPA Office of Water

Engineering and Analysis Division

(202) 566-1003

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into the EPA network. EPA is deleting all computer program attachments

sent from the Internet into the agency via Email.

If the message sender is known and the attachment was legitimate, you

should contact the sender and request that they rename the file name

extension and resend the Email with the renamed attachment. After

receiving the revised Email, containing the renamed attachment, you can

rename the file extension to its correct name.

For further information, please contact the EPA Call Center at

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