1 

### Danielle Lewis

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

Sent: Saturday, June 06, 2015 10:10 PM

To: Flanders, Phillip; Thomas Finseth; Danielle Lewis; Deborah Bartram

Cc: Alicea, Jezebele; Matuszko, Jan Subject: Fw: Paper you authored for MEGA Symposium
Attachments: removed.txt

Categories: Unresolved

From: Tom.Higgins@CH2M.com <Tom.Higgins@CH2M.com>

Sent: Saturday, June 6, 2015 11:11:13 AM

To: Jordan, Ronald

Cc: Kristen.Jenkins@CH2M.com; Dennis.Fink@CH2M.com; He yward.Suber@CH2M.com Subject: RE: Paper you authored for MEGA Symposium

Ron,

I have client approval of the answers and have had others check the responses also against the data. I listed your questions and answers below:

1. Q. Your presentation states that the boron limit le d the plant to select ZLD to treat the FGD wastewat er, although the paper also mentions limitations for ca dmium, iron and sulfate. I just wonder whether tho se were also factors, or the plant concluded those paramete rs could be addressed without having to install ZLD

. A. For this particular plant ZLD was the least cost option, and had ability to handle future limits ex pected for
boron or other future limits.

2. Q. The presentation mentions “influent nitrate spik es cause nitrate upsets but not Se.” Could you ela borate on that? I really didn’t note that in the plots. A. In Figure 4, we did not see selenium increasing when nitrate/nitrite spiked to 700 ug/L and 1,710 ug/L. However, in reviewing the influent and efflu ent data (Figure 3), we do not see any change in in fluent nitrate/nitrite that occurred during days that the effluent nitrate/nitrite concentrations spiked. The refore the conclusion that nitrate spikes were caused by influ ent spikes is not supported by the data. We do not have data that would explain these effluent spikes.

3. Q. The paper summary mentions the 95 th percentile value for selenium was greater than hal f the draft ELG monthly average limit. Do you recall what the 95 th percentile value was?
A. The ABMet Effluent 95 th percentile value was 9.1 ug/L.

4. Q. I have observed other ABMet data which show remo val of mercury and other pollutants across the bioreactor, as is shown in your paper for arsenic ( Figure 5) and mercury (Figure 6). Did you quantify the amount of arsenic and mercury removed by the bioreactor, p erhaps compiling summary statistics such as median or mean values for the phys/chem effluent and ABMet ef fluent? A. The phys/chem pilot system effluent averaged 0.2 2 ug/L total mercury and total arsenic 8.8 ug/L. Th e 95 th percentiles of these were 0.39 ug/L mercury and 20. 9 ug/L arsenic. The ABMet effluent averaged 0.028 ug/L of total mercury and 1.4 ug/L of total arsenic. The 95 th percentiles of these were 0.09 ug/L mercury and 2. 8 ug/L arsenic. We did not collect filtered data, so it is not known how much this difference is due to rem oval of soluble mercury and arsenic, and how much is due to the filtration benefits of the ABMet filters. The TSS of the phys/chem effluent averaged 12 mg/L.

5. Q. What was the TDS concentration for the FGD waste water?2

A. The average TDS of the wastewater was 15,000 m g/L. The 95 percentile was 24,000 mg/L and ranged from about 6,000 to about 27,000 mg/L during the pilot t est.
6. Q. Am I misinterpreting Figure 4, or is there somet hing wrong with the presentation of the nitrate/nit rite data? Is Figure 4 actually showing the ABMet influ ent, rather than the effluent? The plotted observ ations for nitrate/nitrite are way above the horizontal lines that reflect the proposed ELG limits, and are in th e range of 10- 80 ug/L. A. There are a couple of items in the paper that ha ve led to confusion. Figure 3 uses mg/L for y- axis and Figure 4 uses ug/L. In addition the ELG limit lines for nit rate/nitrite are drawn wrong in Figure 4. Since th is graph uses ug/L, the values should be 130 and 170 ug/L, or 0.1 3 and 0.17 mg/L. This figure shows the effluent fr om the ABMet reactors (not influent), with nitrate/nitrite values of 700 and 1,710 ug/L on these two days of excursions, or up to 10 times the proposed ELG limits, not the 10,000 times shown. Selenium did not change on the se days. We have rechecked this data a number of time s.

Tom Higgins PhD, P E Senior Technology Fellow – Power Water and Process

2112 Lirio Court Reston, VA 20191
Tel. 703.391.0741
Mobile. 703.625.4747

Fax. 703.376.5639

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

Sent: Thursday, May 28, 2015 9:50 AM

To: Higgins, Tom/WDC Subject: RE: Paper you authored for MEGA Symposium

Hi Tom,

Hope all is well with you. I have one more question about the paper. Am I misi nterpreting Figure 4, or is there something wrong w ith the presentation of the nitrate/nitrite data? Is Figur e 4 actually showing the ABMet influent, rather tha n the effluent? The plotted o bservations for nitrate/nitrite are way above the h orizontal lines that reflect the proposed ELG limit s, and are in the range of 10-80 ug/L.

Regards,

Ron

From: Tom.Higgins@CH2M.com [ mailto:Tom.Higgins@CH2M.com ]

Sent: Thursday, May 14, 2015 2:41 PM

To: Jordan, Ronald Subject: RE: Paper you authored for MEGA Symposium

Ron,

Just to let you know that I have not forgotten abou t this. I am working through some minor medical is sues and working to get approval from client to release other data t hat was not in the paper.3 Best wishes,

Tom Higgins PhD, P E Senior Technology Fellow – Power Water and Process

2112 Lirio Court Reston, VA 20191
Tel. 703.391.0741
Mobile. 703.625.4747

Fax. 703.376.5639

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From: Higgins, Tom/WDC

Sent: Wednesday, May 06, 2015 12:24 PM

To: 'Jordan, Ronald' Subject: RE: Paper you authored for MEGA Symposium

Ron,

Thanks for the kind words. It does take an effort to make technical information understandable to a b roader audience. I think of a letter Lincoln once wrote to someone, an d after a long reply, he apologized that he didn’t have time to write a
shorter letter. It takes time and effort to be con cise and clear, and I appreciate your noticing and appreciating it.

I am going to take a day or two to find the information requested and make sure it is accurate, rather than answering off the cuff. I will get back soon with it.

Best wishes,

Tom Higgins PhD, P E Senior Technology Fellow – Power Water and Process

2112 Lirio Court Reston, VA 20191
Tel. 703.391.0741
Mobile. 703.625.4747

Fax. 703.376.5639

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

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

Sent: Tuesday, May 05, 2015 8:16 PM

To: Higgins, Tom/WDC Subject: RE: Paper you authored for MEGA Symposium

Hi Tom,

Thanks so much for your paper and the presentation. The paper does a great job presenting data in a way that is easy to interpret. That’s not as easy as it sounds (which I ’m sure you’re well aware of), so kudos to you!4 There are a few aspects of your paper I’d like to f ollow up on, if I may.

• Your presentation states that the boron limit led t he plant to select ZLD to treat the FGD wastewater, although the paper also mentions limitations for cadmium, ir on and sulfate. I just wonder whether those were a lso factors, or the plant concluded those parameters co uld be addressed without having to install ZLD.

• The presentation mentions “influent nitrate spikes cause nitrate upsets but not Se.” Could you elabor ate on that? I really didn’t note that in the plots.

• The paper summary mentions the 95 th percentile value for selenium was greater than half the draft ELG monthly average limit. Do you recall what the 95 th percentile value was?

• I have observed other ABMet data which show removal of mercury and other pollutants across the bioreac tor, as is shown in your paper for arsenic (Figure 5) an d mercury (Figure 6). Did you quantify the amount of arsenic and mercury removed by the bioreactor, perhaps comp iling summary statistics such as median or mean val ues for the phys/chem effluent and ABMet effluent?

• What was the TDS concentration for the FGD wastewat er?

I appreciate your consideration of these questions. Again, thanks for sharing your paper. If it’s ea sier for you to just call me instead of emailing, give me a holler when conve nient.

Regards,

Ron

--------------------------------- Ron Jordan
USEPA Office of Water Engineering and Analysis Division (202) 566-1003

From: Tom.Higgins@CH2M.com [ mailto:Tom.Higgins@CH2M.com ]

Sent: Tuesday, May 05, 2015 6:34 AM

To: Jordan, Ronald Subject: RE: Paper you authored for MEGA Symposium

Good Morning Ron,

Of course I remember you. You are hard to forget. I am pleased to provide the paper. You didn’t ask , but I am also including a PDF of the presentation.

Below find a list of other papers that are recent, if you are interested in any of those.

Best wishes,

Tom Higgins PhD, P E Senior Technology Fellow – Power Water and Process

2112 Lirio Court Reston, VA 20191
Tel. 703.391.0741
Mobile. 703.625.4747

Fax. 703.376.56395 Tom Higgins, Dennis Fink, Kristen Jenkins, and Deb Egeland. 2015. “Guidance for Power Plants in Respon ding to the FGD
Wastewater Numeric Standards.” ENV.Vision Conferenc e, EPRI and A&WMA. Crystal City, VA. May.

Tom Higgins, Dennis Fink, Kristen Jenkins, Chris Ha rdin, and Karen Leber. 2015. “Water Management to m eet CCR Rule.” ENV.Vision Conference, EPRI and A&WMA. Crystal City , VA. May.

Thomas E Higgins, Dennis Fink, Kristen Jenkins, and Julianne Schucker. 2015 “Weathering the Perfect St orm of Regulations - Wastewater Impacts of Final CCR Rule. ” Power Engineering. May.

Thomas E Higgins, Hal Davis, and Ken Martins. 2015. “Power Plant Wastewater Treatment to Meet a Changi ng Regulatory Environment.” EUCI Conference. Nashvill e, TN. April.

Thomas E Higgins, and Kristen Jenkins. 2015. “Wate r Management Under-Fire at Coal-Fired Power Plants. ” EUCI Conference. Nashville, TN. April.

Dennis Fink, Chris Hardin, Kristen Jenkins, and Tom Higgins. 2014. “Setting a Course to ELG and CCR Co mpliance in Uncertain Times.”PowerGen. Orlando, FL. December.

Tom Higgins, Nysa Hogue, David Kehres, Dennis Fink, Kar Minirathinam, Kristen Jenkins, Heyward Suber, and Kyle Doup. 2014. “Recent Applications of Meeting Compliance Ch allenges through Flue Gas Desulfurization (FGD) Was tewater.” Air and Waste Management Mega Symposium. Baltimore, MD. August.

Kristen Jenkins, Dennis Fink, Thomas Higgins, and C hristina Joiner. 2014. “Planning to Achieve ELG Com pliance in a Period of Uncertainty.” International Water Confere nce. San Antonio, TX. November.

Dennis Fink, Paul Chu, Tom Higgins, Kristen Jenkins , and Cynthia Yeager. 2013. “Meeting Part-per-Trill ion Mercury Limits for Power Plant Wastewater.” PowerGen. Orlando, FL . November.

Thomas E. Higgins, Cynthia Yeager, Dennis Fink and Kristen Jenkins. 2013. “Meeting Part-per-Trillion M ercury Limits for
Power Plant Wastewater.” International Water Confe rence. Orlando, FL. November.

Tom Higgins, Kristen Jenkins, Cindy Yeager and Denn is Fink. 2013 “Meeting Low Level Metals Limits – Ch allenges and Successes.” Water Environment Federation Technology Exhibition and Conference (WEFTEC). Chicago, IL. October.

Dennis Fink, Thomas E. Higgins, Hollie Scott, David Goldwater and Kristen Jenkins. 2013. “Power Plant Wastewater Treatment to Meet a Changing Regulatory Environment .” EUCI Conference. Orlando, FL. June.

Thomas E. Higgins, Dana French and Dennis Fink. 201 3. “Beyond Ash Ponds.” Energy, Utility & Environme nt Conference (EUEC). Phoenix, AZ. January.

Kristen Jenkins and Thomas Higgins. 2013. “Zero Liq uid Discharge for Compliance.” Energy, Utility & E nvironment Conference (EUEC). Phoenix, AZ. January.

James S Bays, Tom Higgins, Dana French and BT Thoma s. 2013. “Prospects for Passive Biological Treatmen t of Selenium in FGD Wastewaters.” Energy, Utility & Environment Conference (EUEC). Phoenix, AZ. January.

Natarajan Sekhar, Albert Leungand Tom Higgins. Des ign, installation, start-up & operation of a 2720 m we fgd & waste water treatment system. Energy, Utility & Environm ent Conference (EUEC). Phoenix, AZ. January.

Thomas E. Higgins, Debbie Siebold French and Hollie Scott. 2012. “Power Plant Wastewater Treatment to Meet the Effluent Limitation Guidelines.” PowerGen, Orlando, FL. November.

Thomas E. Higgins. 2012. “Navigating a Sea of New R egulations.” **Power Magazine** . pp. 34-43. December.

Thomas E. Higgins, Kristen Jenkins, Natarajan Sekha r, Ken Martins, Krystal Perez and Laura Reid. 2012 . “Ash Pond Replacement Therapy.” International Water Conferen ce. San Antonio, TX. November.

Kristen Jenkins, Tom Higgins, Jim Mavis, Tom Sandy, Laura Reid and Ken Martins. 2012. “Dischargers Exa mining Alternatives for Zero Liquid Discharge.” **Industrial Water World** . pp. 28-31. May/June.6 Thomas E. Higgins. 2011. “Selenium Control in Wet FGD Systems” Discussion of paper by Katherine Searc y, Mandi Richardson , Gary Blythe, Paul Chu. Chuck Dene, and Dirk Wallschläger, Intern ational Water Conference. Orlando, FL.
November.

Thomas E. Higgins, Karen Meade and Dennis Fink. 201 1. “Demonstration Test of Iron Addition to a Flue G as Desulfurization (FGD) Absorber to Enhance Flue Gas Selenium Removal.” International Water Conference. Orlando,
FL. November.

Kristen Jenkins, Tom Higgins, Jim Mavis, Tom Sandy, Laura Reid and Ken Martins. 2011. “Conceptual Desi gn and Evaluation of Zero Liquid Discharge Systems for Man agement of Industrial Wastewater.”Water Environment
Federation Technical Exhibition and Conference. Oct ober.

Tom Higgins PhD, P E Senior Technology Fellow – Power Water and Process

2112 Lirio Court Reston, VA 20191
Tel. 703.391.0741
Mobile. 703.625.4747

Fax. 703.376.5639

The linked image cannot be displayed. The file may have been moved, renamed, or deleted. Verify that the link points to the correct file and location.

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

Sent: Monday, May 04, 2015 11:06 AM

To: Higgins, Tom/WDC Subject: Paper you authored for MEGA Symposium

Good morning Tom,

I don’t know if you remember me, but we met a few y ears ago at the International Water Conference. I see you continue to actively publish information about trea tment of FGD wastewater. Recently, I came across me ntion of a paper you prepared for the Power Plant Pollutant Co ntrol “MEGA” Symposium that was held last August in Baltimore, MD. I reached out to the conference organizer and was told that, as author, you retain the copyright for the paper. Would you please send me a copy of your pap er “Recent Applications of Meeting Compliance Chall enges through Flue Gas Desulfurization (FGD) Wastewater” (Conference Paper #61)?

I look forward to hearing from you. Regards,

Ron

--------------------------------------------- Ron Jordan USEPA, Office of Water Engineering and Analysis Division (202) 566-1003