MEMORANDUM

TO: Steam Electric Rulemaking Record

FROM: Danielle Lewis, ERG

Anna Dimling, ERG

DATE: September 30, 2015

SUBJECT: Changes to Industry Profile for Steam Electric Generating Units for the 

Steam Electric Effluent Guidelines Final 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 the 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”; DCN SE05903) to 733 steam electric 

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 final 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 that EPA is aware have 

occurred since 2009, additional future changes that EPA identified and are expected to occur by 

December 31, 2023, and EPA’s incorporation of the industry profile changes into the population 

used for costs and loadings analyses.1 EPA identified a total of 483 steam electric generating 

units at 191 plants with industry profile changes; the following are the counts broken out by type 

of industry profile change: 

 416 units at 170 plants retiring or converting fuels;

 46 units at 18 plants converting to dry fly ash handling systems;

 53 units at 17 plants converting to dry bottom ash handling systems; and 

 5 units at 4 plants updating wastewater treatment systems. 

The principal source of information and data used in developing the final 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:

 

1 The Best Available Technology Economically Achievable (BAT) limitations for the final ELGs do not begin to 

apply until a date determined by the permitting authority that is as soon as possible beginning November 1, 2018 

(approximately 3 years following promulgation of the final rule), and they must be achieved by December 31, 2023 

(approximately 8 years from the promulgation of this rule). Therefore, EPA’s analysis of the regulatory options 

considered for the final ELGs included all plants subject to the previously established ELGs, accounting for plant 

retirements and fuel conversions expected to occur prior to full implementation of the final rule.
Memorandum

September 30, 2015

Page 2

 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.

EPA accounted for these completed and planned changes in the costs and loadings 

analysis, where appropriate. In addition, EPA gathered readily available information from public 

sources, including company announcements and government sources, 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 converting one or more units to a dry fly ash handling system or a dry or 

closed-loop wet bottom ash handling system; and

 Plants upgrading a flue gas desulfurization (FGD) or combustion residual leachate 

wastewater treatment system.

Planned modifications that would result in compliance with the final ELGs by December 

31, 2023 were accounted for by the costs and loadings analysis, described in the Incremental 

Costs and Pollutant Removals for the Final Effluent Limitation Guidelines and Standards for the 

Steam Electric Generating Point Source Category (DCN SE05831) when they met the 

acceptance criteria identified below. Because these criteria are that the announcement had to be 

substantiated by information directly from the operating company or government entity, this 

reflects the best information available to EPA. Furthermore, where EPA identified a 

modification as credible based on these criteria, EPA reviewed recent announcements or other 

public sources related to these modifications to ensure that the modification had already occurred 

or was still scheduled to occur.

Generating Unit Retirements and Fuel Conversions

EPA identified plants that by August 2014 had announced the retirement or fuel 

conversion of at least one generating unit that is scheduled to occur by December 31, 2023.2

Based on this information, EPA adjusted the costs and loadings analysis for 170 plants that have 

already or plan to retire or convert the type of fuel used for at least one generating unit. Table 1

lists the name and location of plants announcing the retirement or fuel conversion of a generating 

unit. EPA determined that generating units retiring or converting fuels prior to the 

 

2 EPA accounted for all retirements and fuel conversions announced and verified as of August 2014 in the analyses. 

Any retirements or fuel conversions identified after that date were too late to be fully factored into all analyses; 

however, EPA did consider any retirements or fuel conversions identified between August 2014 and June 2015 in a 

sensitivity analysis. (See the discussion below for Table 34)
Memorandum

September 30, 2015

Page 3

implementation of the final rule would not incur compliance costs or pollutant loading reductions 

associated with the final ELGs if the steam electric generating unit retirement/fuel conversion 

met the following criteria:

 The retirement or fuel modification had to be to complete by December 31, 2023; and

 The retirement had to be substantiated by information directly from the operating 

company or government entity, either through an article, report, or press release.

For those units meeting the criteria, Table 1 indicates whether the units were fully or 

partially removed from the costs and loadings analysis.3 EPA characterized the plants retiring, 

converting fuels, or converting ash handling systems using the following definitions:

 Full Removal – Plants that are retiring, converting fuels, and/or converting ash 

handling practices for all units included in compliance costs and/or pollutant 

loadings for the final ELGs.

 Partial Removal – Plants that are retiring, converting fuels, and/or converting ash 

handling practices for some units, but still maintain units with compliance costs 

and/or pollutant loadings for the final ELGs.

 SE Units Included in Costs and/or Loadings – For partial plant retirements, SE 

Units that were included in either FGD or ash compliance costs and/or pollutant 

loadings.

Ash Handling System Conversions 

Through conversations with specific plants and vendors, public comments, and company 

press releases, EPA identified a number of plants that are known to be in the process of 

upgrading their ash handling practices on specific generating units that will result in compliance 

with the final ELGs. Based on this information, EPA adjusted the costs and loadings analysis for 

46 units at 18 plants converting to dry fly ash handling systems, and 53 units at 17 plants 

converting to dry bottom ash handling systems. 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:

 The upgrade/modification had to be to complete by December 31, 2023; and

 The upgrade had to be substantiated by information directly from the operating 

company or government entity, either through an article, report, or press release.

For those units meeting the criteria, Table 2 lists the name and location of those plants excluded 

from the analysis due to ash handling conversions that EPA identified by August 2014.4 Only the 

 

3 For the purpose of this memorandum, EPA defines full removal as plants retiring/converting all coal- or petroleum 

coke-fired generating units (or for fly ash or bottom ash costs and loadings, converting to a dry or closed-loop 

system) by December 31, 2013, which results in incremental costs or loading reductions associated with the final 

ELGs. However, a partial removal indicates that the plant did not retire all coal- or petroleum coke-fired steam 

electric generating units incurring a compliance cost or pollutant loading reduction.
Memorandum

September 30, 2015

Page 4

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.

Upgrades to Wastewater Treatment Systems

In addition to the retirements, fuel conversions and ash system conversions described 

above, EPA identified 5 units at 4 plants that are known to be updating their wastewater 

treatment systems. This information was used to adjust the costs and loadings analysis for these 

plants. EPA determined that compliance cost and pollutant loadings estimates would need to be 

updated for generating units if the wastewater treatment upgrade met the following criteria: 

 The upgrade/modification had to be to complete by December 31, 2023; and

 The upgrade had to be substantiated by information directly from the operating 

company or government entity, either through an article, report, or press release.

For those units meeting the criteria, Table 3 lists the plants for which EPA was able to 

substantiate wastewater treatment upgrades. Specifically, EPA identified two plants that 

upgraded their FGD wastewater treatment system since 2009, one plant that upgraded its 

combined treatment for FGD wastewater and combustion residual leachate, and an additional 

plant that plans to update their combustion residual leachate treatment system. Section 9.8 of the 

Technical Development Document for the Limitations Guidelines and Standards for the Steam 

Electric Power Generating Point Source Category (“TDD”; EPA-821-R15-007) provides more 

detail on how these treatment system upgrades were incorporated into compliance cost 

estimates.5

Sensitivity Analysis to Evaluate Changes Identified After August 2014

EPA incorporated all retirements/fuel conversions, ash handling upgrades/modifications, 

and wastewater treatment upgrades identified prior to August 2014 in the Updated Industry 

Profile Population (see Section 4.5.1 of the TDD) which was used to estimate compliance costs, 

pollutant loadings and other analyses associated with the final ELGs. EPA used the August 2014 

date because it needed to complete certain analyses (e.g., compliance costs, pollutant loadings) in 

time to meet the consent decree deadline for the final ELGs. After August 2014, using the same 

criteria identified above, EPA identified additional planned retirements or fuel conversions that 

would affect the ELG analyses.

6 Table 4 lists those planned changes that EPA identified between 

August 2014 and June 2015, where the source of information met EPA’s acceptance criteria, and 

identifies the wastestream each unit is estimated to incur costs for under the final ELG. EPA 

identified only four steam electric generating units in this sensitivity analysis that were not 

already identified as retirements associated with the Clean Power Plan (CPP). Removing these 

four generating units from the pollutant loadings and compliance costs for the final ELGs would 

result in some decreased costs and loadings for FGD wastewater and bottom ash. Because there 

were so few generating units identified as part of the sensitivity analysis, EPA expects that 

 

4 EPA accounted for all ash handling conversions announced and verified as of August 2014 in the analyses. EPA 

did not identify any additional ash handling conversion announcements after August 2014 

5 EPA accounted for all wastewater treatment upgrades announced and verified as of August 2014 in the analyses. 

EPA did not identify any additional wastewater treatment system upgrade announcements after August 2014.

6 EPA did not identify any additional ash handling conversions or wastewater treatment system upgrades during the 

period between August 2014 and June 2015.
Memorandum

September 30, 2015

Page 5

removing these units from the population would result in only minimal changes to the 

compliance costs and pollutant loadings associated with the final ELGs. 

After completing the sensitivity analysis in June 2015, EPA identified planned

retirements for 11 more plants. Table 5 identifies all industry profile changes that were identified 

after June 2015. EPA expects that these additional retirements would result in some further 

reduction in compliance costs and pollutant loadings for the final ELGs.

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

December 31, 2023

Plant Name City State Full/Partial 

Removal

SE Units 

Included in 

Costs and/or 

Loadings

Document Control 

Number(s)

AES Greenidge LLC Dresden NY Partial SE Unit-2 SE05651

AES Thames Uncasville CT Full NA SE05651

AES Westover Johnson City NY Full NA SE05651

Albright Power Station Albright WV Full NA SE01261

Alma Alma WI Full NA SE02051

Altavista Power Station Altavista VA Full NA SE04940

Arapahoe Station Denver CO Full NA SE05014, SE05056

Armstrong Power Station Adrian PA Full NA SE01262

Ashtabula Power Plant Ashtabula OH Full NA SE01262

Astoria Generating Station Astoria NY Full NA SE05651

Avon Lake Power Plant Avon Lake OH Full NA SE01974

B C Cobb Power Plant Muskegon MI Full NA SE04951, SE05026

B L England Beesleys Point NJ Full NA SE05651

Bay Shore Plant Oregon OH Full NA SE01262

Ben French Station Rapid City SD Full NA SE04941

Big Cajun 2 New Roads LA Full NA SE04994

Big Sandy Louisa KY Full NA SE04936

Black Dog Generating Plant Burnsville MN Full NA SE05017

Black River Generation, LLC Fort Drum NY Full NA SE05002

Blount Generating Station Madison WI Full NA SE04943

Boardman Boardman OR Full NA SE04952

Brayton Point Station Somerset MA Partial SE Unit-4 SE04946

Bremo Power Station Bremo Bluff VA Full NA SE04953

Buck Steam Station Salisbury NC Full NA SE04949

Canadys Station Walterboro SC Full NA SE05007

Cane Run Louisville KY Full NA SE04919, SE04918, 

SE04890

Cape Fear Steam Electric 

Plant Moncure NC Full NA SE01751, SE04949

Carbon Helper UT Full NA SE05651

Centralia Centralia WA Partial SE Unit-2 SE05012

Chamois Power Plant Chamois MO Full NA SE04947

Cherokee Station Denver CO Full NA SE04948

Chesapeake Energy Center Chesapeake VA Full NA SE04953

Cliffside Steam Station Cliffside NC Partial SE Unit-5, SE SE04949
Memorandum

September 30, 2015

Page 6

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

December 31, 2023

Plant Name City State Full/Partial 

Removal

SE Units 

Included in 

Costs and/or 

Loadings

Document Control 

Number(s)

Unit-A

Clinch River Plant Cleveland VA Full NA SE04936

Colbert Tuscumbia AL Full NA SE04950

Conesville Conesville OH Partial

SE Unit-4, SE 

Unit-5, and SE 

Unit-6

SE04950

Contra Costa Power Plant Antioch CA Full NA SE05652

Crawford Station Chicago IL Full NA SE01973

Crystal River Crystal River FL Full NA SE05651, SE04949

Dan River Steam Station Eden NC Full NA SE04949

Danskammer Generating 

Station Newburgh NY Full NA SE05651

Deepwater Pasadena TX Full NA SE05651

Dubuque Generating Station Dubuque IA Full NA SE04938

Eagle Valley Generating 

Station Martinsville IN Full NA SE04991

East Third Street Power Plant Pittsburg CA Full NA SE05024

Eastlake Power Plant Eastlake OH Full NA SE01262

Eddystone Generating 

Station Eddystone PA Full NA SE00951

Edgewater Generating 

Station Sheboygan WI Full NA SE02941

Elrama Power Plant Elrama PA Full NA SE01974

Fair Station Muscatine IA Full NA SE05030

Far Rockaway Power Station Far Rockaway NY Full NA SE04998

Fisk Station Chicago IL Full NA SE01973

Four Corners Fruitland NM Full NA SE04961

Frank E Ratts Petersburg IN Full NA SE05651

Gallagher Generating Station New Albany IN Partial SE Unit-2, SE 

Unit-4

SE00950, SE04949

George Neal North Sergeant Bluff IA Partial SE Unit-3 SE04995

Glen Lyn Plant Glen Lyn VA Full NA SE04936

Grainger Generating Station Conway SC Full NA SE04928

GRDA Chouteau OK Full NA SE04996

Green River Central City KY Full NA SE04917, SE04890

H.B. Robinson Fossil Plant Hartsville SC Full NA SE04949

Hanford Power Plant Hanford CA Full NA SE05018, SE05019, 

SE05020

Harbor Beach Power Plant Harbor Beach MI Full NA SE04933

Harding Street Station Indianapolis IN Partial SE Unit-5 SE04968

Hatfield's Ferry Power 

Station Masontown PA Full NA SE04032

Havana Power Station Havana IL Partial SE-Unit-6 SE04957

Hoot Lake Plant Fergus Falls MN Full NA SE04969

Hopewell Hopewell VA Full NA SE04940
Memorandum

September 30, 2015

Page 7

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

December 31, 2023

Plant Name City State Full/Partial 

Removal

SE Units 

Included in 

Costs and/or 

Loadings

Document Control 

Number(s)

Howard Down Vineland NJ Full NA SE05651

Hunlock Power Station Hunlock Creek PA Full NA SE05052

Hutsonville Power Station Hutsonville IL Full NA SE00943

Indian River Generating 

Station Titusville FL Full NA SE05021

JC Weadock Power Plant Essexville MI Full NA SE04951, SE05026

Jefferies Generating Station Moncks Corner SC Full NA SE04928

John Sevier Rogersville TN Full NA SE04992

Johnsonville New 

Johnsonville TN Full NA SE04993

Joliet 29 Joliet IL Full NA SE04235

Joliet 9 Joliet IL Full NA SE04235

JR Whiting Power Plant Luna Pier MI Full NA SE04951, SE05026

Kammer Plant Captina WV Full NA SE04936

Kanawha River Plant Glasgow WV Full NA SE04936

Kewaunee Kewaunee WI Full NA SE05651

L V Sutton Steam Electric 

Plant Wilmington NC Full NA SE01746, SE04949

Lake Shore Plant Cleveland OH Full NA SE01262

Lansing Generating Station Lansing IA Partial SE Unit-4 SE04938

Laskin Energy Center Hoyt Lakes MN Full NA SE05009, SE05010

Lee Plant Goldsboro NC Full NA SE04949

Lee Steam Station Belton SC Full NA SE04949

Loveridge Road Power Plant Pittsburg CA Full NA SE04935, SE05024

M.L. Kapp Generating 

Station Clinton IA Partial SE Unit-2 SE04938

McIntosh Lakeland FL Partial SE Unit-3 SE05651

McMeekin Plant Columbia SC Full NA SE05006

Meredosia Power Station Meredosia IL Full NA SE00943

Miami Fort Station North Bend OH Partial SE Unit-2, SE 

Unit-3

SE04949

Mitchell Power Station Courtney PA Full NA SE04032

Mt. Poso Cogeneration Bakersfield CA Full NA SE05023, SE04935

Muskingum River Beverly OH Full NA SE04936

Neil Simpson I Gillette WY Full NA SE04941

Nelson Dewey Generating 

Station Cassville WI Full NA SE02941

New Castle Power Plant West Pittsburg PA Full NA SE01974

Nichols Road Power Plant Bay Point CA Full NA SE05024, SE04935

Niles Power Plant Niles OH Full NA SE01974

North Branch Power Station Gormania WV Full NA SE04954

Northeastern Power Station Oolagah OK Partial SE Unit-4 SE04963

O H Hutchings Miamisburg OH Full NA SE05651

Osage Power Plant Osage WY Full NA SE04941
Memorandum

September 30, 2015

Page 8

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

December 31, 2023

Plant Name City State Full/Partial 

Removal

SE Units 

Included in 

Costs and/or 

Loadings

Document Control 

Number(s)

Paradise Drakesboro KY Partial SE Unit-3 SE04999

Pearl Station Pearl IL Full NA SE05651

Pella Municipal Power Plant Pella IA Full NA SE05000

Philip Sporn Graham Station WV Full NA SE04936

Picway Lockbourne OH Full NA SE04936

Plant E C Gaston Wilsonville AL Partial SE Unit-5 SE04937

Plant Gadsden Gadsden AL Full NA SE04937

Plant Gorgas Parrish AL Partial

SE Unit-3, SE 

Unit-4, SE Unit5SE05031

Plant Greene County Demopolis AL Full NA SE05031

Plant Harllee Branch Milledgeville GA Full NA SE04945, SE04930, 

SE01334

Plant Jack McDonough Smyrna GA Full NA SE05001, SE05005

Plant Kraft Port Wentworth GA Full NA SE04930

Plant McManus Brunswick GA Full NA SE04930

Plant Mitchell Albany GA Full NA SE04930

Plant Scholz Sneads FL Full NA SE04967

Plant Yates Newnan GA Full NA SE03799, SE04930

Potomac River Alexandria VA Full NA SE05022

Prairie Creek Generating 

Station Cedar Rapids IA Partial SE Unit-3, SE Unit-4

SE04938

Pulliam Green Bay WI Partial SE Unit-5, SE 

Unit-6

SE04990

Quindaro Power Plant Kansas City KS Full NA SE04944

R. E. Burger Plant Shadyside OH Full NA SE05008

R. Paul Smith Power Station Williamsport MD Full NA SE01262

Reid Gardner Moapa NV Full NA SE05651

Riverbend Steam Station Mount Holly NC Full NA SE04949

Riverside Baltimore MD Full NA SE04964, SE04965

Riverside Generating Station Bettendorf IA Full NA SE04995

Riverton Power Station Riverton KS Full NA SE05004

Rivesville Power Station Rivesville WV Full NA SE01261

Riviera Riviera Beach FL Full NA SE04997

RRI Energy Inc. Portland 

Generating Station Mt. Bethel PA Full NA SE01974

Salem Harbor Station Salem MA Full NA SE05055

San Juan Generating Station Waterflow NM Full NA SE03802

Schuylkill Generating Station Philadelphia PA Full NA SE04965

Shawville Shawville PA Full NA SE01974

Shelby Municipal Light Plant Shelby OH Full NA SE05651

Silver Lake Plant Rochester MN Full NA SE05003

Somerset Station Somerset MA Full NA SE05011

Southampton Franklin VA Full NA SE04940, SE04953

State Line Energy, LLC Hammond IN Full NA SE05045
Memorandum

September 30, 2015

Page 9

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

December 31, 2023

Plant Name City State Full/Partial 

Removal

SE Units 

Included in 

Costs and/or 

Loadings

Document Control 

Number(s)

Stockton Stockton CA Full NA SE04935, SE05023

Stoneman Generating Station Cassville WI Full NA SE04956

Sutherland Generating 

Station Marshalltown IA Full NA SE04938

Taconite Harbor Energy 

Center Schroeder MN Partial SE Unit-1, SE Unit-2

SE05009

Tanners Creek Plant Lawrenceburg IN Full NA SE05651, SE04936

Titus Generation Station Birdsboro PA Full NA SE01974

Turkey Point Homestead FL Full NA SE05651

Urquhart Station Beech Island SC Full NA SE01811

Valley Power Plant Milwaukee WI Full NA SE05015

Valmont Boulder CO Full NA SE05013

Vermilion Power Station Oakwood IL Full NA SE04958, SE04959

W H Weatherspoon Steam 

Electric Plant Lumberton NC Full NA SE01745

W.N. Clark Station Cañon City CO Full NA SE04942

Wabash River Generating 

Station

West Terre 

Haute IN Full NA SE04949

Walter C Beckjord Station New Richmond OH Full NA SE04949, SE01743

Walter Scott Jr. Energy 

Center Council Bluffs IA Partial SE Unit-3 SE04995

Welsh Pittsburg TX Full NA SE01739, SE01972

Weston Plant Rothschild WI Partial SE Unit-3, SE 

Unit-4

SE04990

Widows Creek Stevenson AL Partial SE Unit-7 SE05016

Wilbur East Power Plant Antioch CA Full NA SE04935, SE05024

Wilbur West Power Plant Antioch CA Full NA SE04935, SE05024

Will County Station Romeoville IL Partial SE Unit-4 SE04960

Willow Island Power Station Willow Island WV Full NA SE01261

Wood River Power Station Alton IL Partial SE Unit-4, SE 

Unit-5

SE04957

Yorktown Power Station Yorktown VA Full NA SE04953
Memorandum

September 30, 2015

Page 10

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

Practices by December 31, 2023

Plant Name City State Upgrade/Modification Document Control 

Number(s)

Allen Steam Plant Memphis TN Dry Fly Ash and Bottom Ash 

Conversion SE02043, SE02044

Allen Steam Station Belmont NC Dry Bottom Ash Conversion SE04239, SE04240, 

SE05635

Asheville Steam Electric 

Plant Arden NC Dry Fly Ash and Bottom Ash Conversion

SE04239, SE04240, 

SE05635

Belews Creek Steam 

Station Belews Creek NC Dry Fly Ash and Bottom Ash Conversion

SE04239, SE04240, 

SE05025, SE05635

Bull Run Clinton TN Dry Fly Ash Conversion SE02043, SE02044

Cliffside Steam Station Cliffside NC Dry Fly Ash and Bottom Ash 

Conversion

SE04239, SE04240, 

SE05635

Cumberland Cumberland 

City TN Dry Fly Ash and Bottom Ash Conversion SE02043, SE02044

DE Karn Power Plant Essexville MI Dry Fly Ash Conversion SE05026

Gallatin Gallatin TN Dry Fly Ash and Bottom Ash 

Conversion SE02043, SE02044

Gibson Generating 

Station Owensville IN Dry Fly Ash Conversion SE05028

Kingston Harriman TN Dry Fly Ash and Bottom Ash 

Conversion SE02043, SE02044

Lumberton Power Plant Lumberton NC Dry Bottom Ash Conversion SE04239, SE04240, 

SE05635

Marshall Steam Station Terrell NC Dry Fly Ash and Bottom Ash 

Conversion SE05025, SE05635

Mayo Electric 

Generating Plant Roxboro NC Dry Fly Ash and Bottom Ash Conversion SE05025, SE05635

Mitchell Plant Captina WV Dry Fly Ash Conversion SE04236

Paradise Drakesboro KY Dry Fly Ash and Bottom Ash 

Conversion SE02043, SE02044

Roxboro Steam Plant Semora NC Dry Fly Ash and Bottom Ash 

Conversion

SE04239, SE04240, 

SE05025, SE05635

Shawnee West Paducah KY Dry Bottom Ash Conversion SE02043, SE02044

TES Filer City Station Filer City MI Dry Fly Ash Conversion SE05026

Wateree Station Eastover SC Dry Fly Ash and Bottom Ash 

Conversion SE05027

Welsh Pittsburg TX Dry Bottom Ash Conversion SE00955

Widows Creek Stevenson AL Dry Fly Ash and Bottom Ash 

Conversion SE02043, SE02044

*All upgrade/modifications in this table are full removals from costs/loadings for specified type of ash. For the 

purpose of this table, dry bottom ash conversion also includes closed-loop wet bottom ash systems (e.g., remote 

mechanical drag systems).

Note: Plants with verified retirements of all steam electric generating units that were previously identified as ash 

handling conversions were not included in Table 2.
Memorandum

September 30, 2015

Page 11

Table 3. Plants with Upgrades/Modifications to Wastewater Treatment Systems by 

December 31, 2023

Plant Name City State Type of 

Wastewater Upgrade/Modification

Document 

Control 

Number(s)

Flint Creek Power Plant Gentry AL Landfill Leachate ABMet Biological 

Treatment System SE05068

Mayo Electric 

Generating Plant Roxboro NC FGD Wastewater Vapor-Compression Evaporation System SE05066

Merrimack Station Bow NH FGD Wastewater Vapor-Compression 

Evaporation System SE05067

Mountaineer Power 

Plant New Haven WV FGD Wastewater and Leachate

Biological Treatment 

System

SE04375A1, 

SE04375A6
Memorandum

September 30, 2015

Page 12

Table 4. Steam Electric Generating Units Identified after August 2014 and before June 2015 with at Least One Generating Unit 

Retiring or Converting Fuels by December 31, 2023

Plant Name SE Unit ID City State

ELG Costs

CPP 

Retirementa

Document 

Control 

Number(s) Fly Ash 

Transport Water

Bottom Ash 

Transport Water

FGD 

Wastewater

Combustion 

Residual Leachate

Asheville Steam Electric Plant SE-Unit 1 Arden NC  SE05633

Asheville Steam Electric Plant SE-Unit 2 Arden NC  SE05633

Lake Road Generating Station SE-Unit 4 St. Joseph MO   SE05074

Montrose Generating Station SE-Unit 1 Montrose MO   SE05074

Montrose Generating Station SE-Unit 2 Montrose MO  SE05074

Montrose Generating Station SE-Unit 3 Montrose MO  SE05074

Sibley Generating Station SE-Unit 1 Sibley MO     SE05074

Note: Units with a capacity of 50 MW or less are not included because they do not need to meet any more stringent requirements than already existed under BPT 

regulations.

a – Steam electric generating units expected to retire under the proposed CPP.
Memorandum

January 28, 2013

Page 13

Table 5. List of Plants Identified after June 2015 with at Least One Generating Unit 

Retiring, Converting Fuels, Converting Ash Handling Practices, or Updating Wastewater 

Treatment System by December 31, 2023

Note: Some plants in this table also appear in Table 1 because additional industry profile changes to other steam 

electric generating units were identified.

Plant Name City State Industry Profile Change 

Description

Document Control 

Number(s)

Burlington Generation 

Station Burlington IA Cease burning coal SE05668

Cedar Bay Generating 

Company L.P. Jacksonville FL Retirement SE05688

J.E. Corette Treatment Plant Billings MT Retirement SE05669

M.L. Kapp Generating 

Station Clinton IA Refuel with natural gas SE05667, SE05668

Prairie Creek Generating 

Station Cedar Rapids IA Refuel with natural gas SE05667, SE05668

Reid Gardner Moapa NV Retirement SE05675

Shelby Municipal Power 

and Light Shelby OH Retirement SE05673

Taconite Harbor Energy 

Center Schroeder MN Economic idling, then cease coal operations SE05672

White Pine Electric Power White Pine MI Retirement SE05669

Widows Creek Stevenson AL Retirement SE05674

William C. Dale Power 

Station Winchester KY Retirement SE05670