From: Jordan, Ronald

To: Thomas Finseth

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

Date: Monday, February 24, 2014 8:50:00 AM

Attachments: Copy of Copy of SE04292_Data Request Spreadsheet_FirstEnergy_01212014jpledits+GenData.xlsx

Nalmet1689.pdf

From: jlapcev@firstenergycorp.com [mailto:jlapcev@firstenergycorp.com]

Sent: Thursday, February 20, 2014 12:05 PM

To: Jordan, Ronald

Cc: wcannon@firstenergycorp.com; jmeade@firstenergycorp.com; mjjirousek@firstenergycorp.com

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



### Ron,

This email is in response to your January 17, 2014 email and letter requesting

additional information regarding Hatfield’s Ferry Power Station (Hatfield). As

mentioned in my earlier correspondence, Hatfield officially ceased generating

on October 9, 2013 and became an unmanned facility in mid-January 2014. The

following responses are to the questions raised in your letter (01/17/2014).

1.) FirstEnergy confirms that the data submitted by UWAG in their comments on the EPA’s proposed ELG Rule reflects all available data for

the timeframe mentioned. To ensure that you have our complete data set, attached is the spreadsheet you provided, filled in with Hatfield’s effluent arsenic and mercury data from their FGD-WWTP discharge (IMP-306). The data was pulled from each of our Laboratory Information Management Systems (LIMS), pre and post-merger (Allegheny’s & FirstEnergy ’s). Please note, your spreadsheet only had an

influent tab, so I added a tab for this effluent data. This effluent data was analyzed by either Allegheny’s, or FirstEnergy’s laboratory and previously submitted on Hatfield’s monthly Discharge Monitoring Reports (DMRs) to the PADEP and US-EPA. The only influent FGD-WWT system data that I am aware of is what was collected/analyzed as part of the EPA’s 2010-11 ELG request. There may be a sample, or two of influent data from commissioning the FGD-WWTP, but due to the deactivation of the generating units we were unable to locate any of that data. Supplemental information requested in item one is addressed below in my response to your other questions, or provided on the attached spreadsheet.

2.) Effluent data is provided on the attached spreadsheet for the time period from July 7, 2009 through December 10, 2013. However, any sample collected after October 6, 2013, the last day Hatfield generated, is not representative of typical FGD-WWTP effluent. Rather, these samples were collected after the absorber units ceased operations and the entire FGD system was being treated and discharged through the FGD-WWTP (IMP-306). As discussed in item 1 above, I am not aware of any influent data collected between October 26, 2011 and December 31, 2013. As with item one above, supplemental information requested is addressed below in my response to your other questions, or provided on the attached spreadsheet.

### 3.) The organosulfide product Hatfield used in their FGD-WTP was Nalmet® 1689, a Nalco Company product. A copy of the products Material Safety Data Sheet (MSDS) is attached.

4.) Due to confidentiality agreements with our coal vendors, our Legal Department is claiming the information requested in Item 4 as

confidential business information. Therefore, I am unable to provide any of this information without an official section 308 letter requiring us to provide the information. However, Hatfield’s coal specifications stipulated only BTU, ash, sulfur, and moisture content.

5.) As with Item 4, confidentiality agreements with our coal vendors prevents me from providing this information without a formal 308 letter requiring us to provide it. Furthermore, Hatfield did not track, on a daily basis, the information requested. When coal was delivered, it was placed in a common pile according to its type designation. The total inventory at the plant was typically 25 to 30 days and any given delivery could be consumed across a number of days and would be blended with an unknown

number of other deliveries. There was no way to match the exact delivery with the daily consumption.

6.) Operation information for Hatfield’s FGD system was purged shortly

after the units were deactivated in October 2013. One employee found a small file containing some of the information requested here. I inserted the data on the FGD System Information tab on the attached spreadsheet.

As always, please let me know of any questions you have regarding this

information, or if you need anything further.

Take care,

Joe Lapcevic

Senior Scientist

(724) 838 – 6099 work

(234) 678 – 2385 fax

FirstEnergy Corp.

800 Cabin Hill Drive

Greensburg, PA 15601-1689

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

Sent: Wednesday, February 19, 2014 9:56 AM

To: Lapcevic, Joseph P

Cc: Cannon, William E

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

Thanks for the update. What about effluent/influent data for the treatment system?

From: jlapcev@firstenergycorp.com [ mailto:jlapcev@firstenergycorp.com ]

Sent: Wednesday, February 19, 2014 8:48 AM

To: Jordan, Ronald

Cc: wcannon@firstenergycorp.comSubject: RE: Follow up to comments on proposed Steam Electric effluent guidelines

Ron,

Due to Hatfield’s deactivation last October, most of the FGD operational data was

purged. On the coal burn type/source, we didn’t track much other than btu, sulfur,

moisture, and ash content. Plus, legal is having issues with providing mine info without

getting approvals from the mines. Fuels is working on making the info appear more

generic (mines A, B, & C, etc.). I should hear from them today.

I’m at an EPRI meeting today, in California, but intended to send you what I have

tomorrow (2/20). Depending on how things go with legal on the mine issue, I may need

more time, or just won’t be able to provide that info. I’ll keep you posted. Try my cell

if wish to discuss further (724) 244 – 9606. As mentioned, I’m in & out of meetings

all day today, but wide open tomorrow.

Take care,



### Joe Lapcevic

Senior Scientist

(724) 838 – 6099 work

(234) 678 – 2385 fax

FirstEnergy Corp.

800 Cabin Hill Drive

Greensburg, PA 15601-1689

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

Sent: Wednesday, February 19, 2014 7:13 AM

To: Lapcevic, Joseph P

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

Good morning,

Just wanted to confirm you’re still on track to provide the requested information today.

Regards,

Ron

From: jlapcev@firstenergycorp.com [ mailto:jlapcev@firstenergycorp.com ]

Sent: Friday, January 17, 2014 3:55 PM

To: Jordan, Ronald

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



### Ron,

Received you e-mail and letter requesting additional info on Hatfield. Good to hear

from you and glad to see you're making headway through all the ELG comments.

You may not be aware, but for economic reasons Hatfield was deactivated last fall,

ceased all generation on October 6, 2013, and is essentially an unmanned facility

going forward. Station records were shipped off-site, so it may take some time to

track down the requested info, especially regarding coal usage. I'll have a better feel

for how we can respond after I route the request around and track down the

### appropriate staff with access to the info requested - hopefully by end of next week.

Also, the Attachment to your letter referenced using the format provided in Microsoft's

Excel Workbook titled "Analytical Data Table." Is this a template Microsoft Excel

provides, or is it a spreadsheet EPA developed? If possible, please provide a copy,

or advise where to obtain.

Take care,

Joe Lapcevic

Senior Scientist

(724) 838 – 6099 work

(234) 678 – 2385 fax

FirstEnergyCorp.

800 Cabin Hill Drive

Greensburg, PA 15601-1689

From: "Jordan, Ronald" < Jordan.Ronald@epa.gov >

To: " jlapcev@firstenergycorp.com " < jlapcev@firstenergycorp.com >

Cc: "Alicea, Jezebele" < Alicea.Jezebele@epa.gov >, "Flanders, Phillip" < Flanders.Phillip@epa.gov >, "Schroeder, Cuc"

< Schroeder.Cuc@epa.gov >, "Shriner, Paul" < Shriner.Paul@epa.gov >

Date: 01/17/2014 11:52 AM

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

Good morning Joe,

I hope all is well with you. It’s been quite some time since we last spoke.

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

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

Ron JordanEPA Office of Water

Engineering and Analysis Division

(202) 566-1003

[attachment "Ltr to FirstEnergy_Hatfields Ferry_Jan 17 2014.pdf" deleted by Joseph P Lapcevic/FirstEnergy]



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