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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; Heyward.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 led the plant to select ZLD to treat the FGD wastewater, 

although the paper also mentions limitations for cadmium, iron and sulfate. I just wonder whether those were 

also factors, or the plant concluded those parameters 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 expected for 

boron or other future limits. 

2. Q. The presentation mentions “influent nitrate spikes cause nitrate upsets but not Se.” Could you elaborate 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 effluent data (Figure 3), we do not see any change in influent 

nitrate/nitrite that occurred during days that the effluent nitrate/nitrite concentrations spiked. Therefore the 

conclusion that nitrate spikes were caused by influent 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 95th percentile value for selenium was greater than half the draft ELG 

monthly average limit. Do you recall what the 95th percentile value was?

A. The ABMet Effluent 95th percentile value was 9.1 ug/L. 

4. Q. I have observed other ABMet data which show removal 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, perhaps compiling summary statistics such as median or 

mean values for the phys/chem effluent and ABMet effluent?

A. The phys/chem pilot system effluent averaged 0.22 ug/L total mercury and total arsenic 8.8 ug/L. The 95th

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 95th 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 removal 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 wastewater?
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A. The average TDS of the wastewater was 15,000 mg/L. The 95 percentile was 24,000 mg/L and ranged from 

about 6,000 to about 27,000 mg/L during the pilot test. 

6. Q. Am I misinterpreting Figure 4, or is there something wrong with the presentation of the nitrate/nitrite 

data? Is Figure 4 actually showing the ABMet influent, rather than the effluent? The plotted observations for 

nitrate/nitrite are way above the horizontal lines that reflect the proposed ELG limits, and are in the range of 10-

80 ug/L.

A. There are a couple of items in the paper that have led to confusion. Figure 3 uses mg/L for y-axis and Figure 4 

uses ug/L. In addition the ELG limit lines for nitrate/nitrite are drawn wrong in Figure 4. Since this graph uses 

ug/L, the values should be 130 and 170 ug/L, or 0.13 and 0.17 mg/L. This figure shows the effluent from 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 these 

days. We have rechecked this data a number of times. 

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 misinterpreting Figure 4, or is there something wrong with the 

presentation of the nitrate/nitrite data? Is Figure 4 actually showing the ABMet influent, rather than the effluent? The 

plotted observations for nitrate/nitrite are way above the horizontal lines that reflect the proposed ELG limits, 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 about this. I am working through some minor medical issues and working 

to get approval from client to release other data that 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 broader audience. I 

think of a letter Lincoln once wrote to someone, and after a long reply, he apologized that he didn’t have time to write a 

shorter letter. It takes time and effort to be concise 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

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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!
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There are a few aspects of your paper I’d like to follow up on, if I may.

• Your presentation states that the boron limit led the plant to select ZLD to treat the FGD wastewater, although 

the paper also mentions limitations for cadmium, iron and sulfate. I just wonder whether those were also 

factors, or the plant concluded those parameters could be addressed without having to install ZLD.

• The presentation mentions “influent nitrate spikes cause nitrate upsets but not Se.” Could you elaborate on 

that? I really didn’t note that in the plots.

• The paper summary mentions the 95th percentile value for selenium was greater than half the draft ELG monthly 

average limit. Do you recall what the 95th percentile value was?

• I have observed other ABMet data which show removal 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, perhaps compiling summary statistics such as median or mean values 

for the phys/chem effluent and ABMet effluent?

• What was the TDS concentration for the FGD wastewater?

I appreciate your consideration of these questions. Again, thanks for sharing your paper. If it’s easier for you to just call 

me instead of emailing, give me a holler when convenient.

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. 703.376.5639
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Tom Higgins, Dennis Fink, Kristen Jenkins, and Deb Egeland. 2015. “Guidance for Power Plants in Responding to the FGD 

Wastewater Numeric Standards.” ENV.Vision Conference, EPRI and A&WMA. Crystal City, VA. May. 

Tom Higgins, Dennis Fink, Kristen Jenkins, Chris Hardin, and Karen Leber. 2015. “Water Management to meet 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 Storm 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 Changing 

Regulatory Environment.” EUCI Conference. Nashville, TN. April. 

Thomas E Higgins, and Kristen Jenkins. 2015. “Water 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 Compliance 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 Challenges through Flue Gas Desulfurization (FGD) Wastewater.” 

Air and Waste Management Mega Symposium. Baltimore, MD. August. 

Kristen Jenkins, Dennis Fink, Thomas Higgins, and Christina Joiner. 2014. “Planning to Achieve ELG Compliance in a 

Period of Uncertainty.” International Water Conference. San Antonio, TX. November. 

Dennis Fink, Paul Chu, Tom Higgins, Kristen Jenkins, and Cynthia Yeager. 2013. “Meeting Part-per-Trillion 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 Mercury Limits for 

Power Plant Wastewater.” International Water Conference. Orlando, FL. November. 

Tom Higgins, Kristen Jenkins, Cindy Yeager and Dennis Fink. 2013 “Meeting Low Level Metals Limits – Challenges 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. 2013. “Beyond Ash Ponds.” Energy, Utility & Environment Conference 

(EUEC). Phoenix, AZ. January. 

Kristen Jenkins and Thomas Higgins. 2013. “Zero Liquid Discharge for Compliance.” Energy, Utility & Environment 

Conference (EUEC). Phoenix, AZ. January. 

James S Bays, Tom Higgins, Dana French and BT Thomas. 2013. “Prospects for Passive Biological Treatment of Selenium 

in FGD Wastewaters.” Energy, Utility & Environment Conference (EUEC). Phoenix, AZ. January. 

Natarajan Sekhar, Albert Leungand Tom Higgins. Design, installation, start-up & operation of a 2720 mwe fgd & waste 

water treatment system. Energy, Utility & Environment 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 Regulations.” Power Magazine. pp. 34-43. December. 

Thomas E. Higgins, Kristen Jenkins, Natarajan Sekhar, Ken Martins, Krystal Perez and Laura Reid. 2012. “Ash Pond 

Replacement Therapy.” International Water Conference. San Antonio, TX. November. 

Kristen Jenkins, Tom Higgins, Jim Mavis, Tom Sandy, Laura Reid and Ken Martins. 2012. “Dischargers Examining 

Alternatives for Zero Liquid Discharge.” Industrial Water World. pp. 28-31. May/June. 
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Thomas E. Higgins. 2011. “Selenium Control in Wet FGD Systems” Discussion of paper by Katherine Searcy, Mandi 

Richardson , Gary Blythe, Paul Chu. Chuck Dene, and Dirk Wallschläger, International Water Conference. Orlando, FL. 

November. 

Thomas E. Higgins, Karen Meade and Dennis Fink. 2011. “Demonstration Test of Iron Addition to a Flue Gas 

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 Design and 

Evaluation of Zero Liquid Discharge Systems for Management of Industrial Wastewater.”Water Environment

Federation Technical Exhibition and Conference. October. 

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: 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 years ago at the International Water Conference. I see you 

continue to actively publish information about treatment of FGD wastewater. Recently, I came across mention of a 

paper you prepared for the Power Plant Pollutant Control “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 paper “Recent Applications of Meeting Compliance Challenges 

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