SUPPORTING STATEMENT 

QUESTIONNAIRE FOR THE STEAM ELECTRIC POWER GENERATING 

EFFLUENT GUIDELINES 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

February 2010 
i 

CONTENTS 

Page 

PART A OF THE SUPPORTING STATEMENT .......................................................................1-1 

1. IDENTIFICATION OF THE INFORMATION COLLECTION ....................................1-1 

1(a) Title of the Information Collection......................................................................1-1 

1(b) Short Characterization/Abstract...........................................................................1-1 

2. NEED FOR AND USE OF THE INFORMATION COLLECTION ...............................2-1 

2(a) Need/Authority for the Information Collection ...................................................2-1 

2(b) Practical Utility/Users of the Data .......................................................................2-1 

(i) General Use of the Data...........................................................................2-1 

(ii) Detailed Technical Analyses Supported by the Questionnaire................2-4 

(iii) Detailed Economic Analyses Supported by the Questionnaire ...............2-6 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

EFFORTS ........................................................................................................................3-1 

3(a) Nonduplication.....................................................................................................3-1 

(i) Technical..................................................................................................3-1 

(ii) Financial and Economic...........................................................................3-3 

3(b) Public Notice Required Prior to ICR Submission to OMB .................................3-5 

(i) Publication of the Federal Register Notice ..............................................3-5 

(ii) Public Response to the Federal Register Notice......................................3-6 

3(c) Consultations......................................................................................................3-12 

3(d) Effects of Less Frequent Collection...................................................................3-13 

3(e) General Guidelines.............................................................................................3-13 

3(f) Confidentiality ...................................................................................................3-13 

3(g) Sensitive Questions............................................................................................3-14 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED..............................4-1 

4(a) Respondents NAICS Codes .................................................................................4-1 

4(b) Information Requested.........................................................................................4-1 

(i) Detailed Description of the Steam Electric Effluent Guidelines 

Questionnaire ...........................................................................................4-1 

(ii) Respondents Activities...........................................................................4-35 

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION ...................................................................5-1 

5(a) Agency Activities.................................................................................................5-1 

5(b) Collection Methodology and Management..........................................................5-1 

5(c) Small Entity Flexibility........................................................................................5-2 

5(d) Collection Schedule .............................................................................................5-3 
CONTENTS (Continued) 

Page 

ii 

6. ESTIMATING THE BURDEN AND COST OF COLLECTION ...................................6-1 

6(a) Estimating Respondent Burden............................................................................6-1 

(i) Respondent Burden..................................................................................6-2 

(ii) Total Estimated Respondent Burden .......................................................6-2 

6(b) Estimating Respondent Costs ..............................................................................6-8 

(i) Estimating Labor Costs............................................................................6-8 

(ii) Estimating Capital/Start-up Operating and Maintenance Costs ..............6-8 

(iii) Annualizing Capital Costs .....................................................................6-10 

(iv) Estimating Agency Burden and Costs ...................................................6-10 

6(c) Estimating the Respondents Universe and Total Burden Costs.........................6-11 

6(d) Bottom Line Burden Hours and Costs...............................................................6-11 

6(e) Reasons for Change in Burden ..........................................................................6-12 

6(f) Burden Statement...............................................................................................6-12 

Appendix A: DRAFT QUESTIONNAIRE FOR THE STEAM ELECTRIC POWER

GENERATING EFFLUENT GUIDELINES 

Appendix B: SUMMARY OF COMMENTS ON THE PUBLIC NOTICE FOR THE 

PROPOSED INFORMATION COLLECTION FOR THE STEAM ELECTRIC 

POWER GENERATING EFFLUENT GUIDELINES AND EPA’S RESPONSE 
iii 

LIST OF TABLES 

Page 

Table 2-1. Number of Questionnaire Respondents (Plant Level Counts) ................................... 2-2 

Table 4-1. Steam Electric Power Plant Operations Question Justifications ................................ 4-2 

Table 4-2. FGD System Question Justifications.......................................................................... 4-9 

Table 4-3. Ash Handling Question Justifications ...................................................................... 4-13 

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations

Question Justifications................................................................................................... 4-22 

Table 4-5. Wastes from Cleaning Metal Process Equipment Question Justifications............... 4-26 

Table 4-6. Management Practices for Pond/Impoundment Units and Landfills Question 

Justifications .................................................................................................................. 4-28 

Table 4-7. Leachate Sampling Data for Pond/Impoundments and Landfills Question 

Justifications .................................................................................................................. 4-32 

Table 4-8. Nuclear Power Question Justifications..................................................................... 4-33 

Table 4-9. Economic and Financial Data Question Justifications ............................................. 4-35 

Table 4-10. Number of Questionnaire Respondents.................................................................. 4-36 

Table 5-1. NAICS Codes and SBA Size Standards for Entities with a Primary Business 

Other Than Electric Power Generation............................................................................ 5-3 

Table 5-2. Collection Schedule.................................................................................................... 5-4 

Table 6-1. Economic and Financial Data Burden Estimates for Part I........................................ 6-3 

Table 6-2. Estimated Respondent Hours per Section of the Questionnaire................................. 6-4 

Table 6-3. Estimated Respondent Hours per Part of the Questionnaire ...................................... 6-7 

Table 6-4. Estimated Respondent Burden (Hourly) per Type of Plant........................................ 6-7 

Table 6-5. 2009 Labor Rate Data................................................................................................. 6-8 

Table 6-6. Total Estimated Respondent Burden.......................................................................... 6-9 

Table 6-7. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire..... 6-10 

Table 6-8. Total Capital/Start-up Operating and Maintenance Costs for Sampling.................. 6-10 

Table 6-9. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire..... 6-10 

Table 6-10. Agency Burden and Costs ...................................................................................... 6-11 
LIST OF TABLES (Continued) 

Page 

iv

Table 6-11. Total Estimated Respondent Burden and Cost Summary ...................................... 6-12 

Table 6-12. Total Estimated Agency Burden and Cost Summary............................................. 6-12 

Table 6-13. Annual Estimated Burden and Cost Summary....................................................... 6-12 
1-1 

PART A OF THE SUPPORTING STATEMENT 

1. IDENTIFICATION OF THE INFORMATION COLLECTION 

1(a) Title of the Information Collection 

U.S. Environmental Protection Agency 

Questionnaire for Steam Electric Power Generating Effluent Guidelines 

EPA ICR No. 2368.01 

OMB Control No. 2040-NEW 

1(b) Short Characterization/Abstract 

The United States Environmental Protection Agency (EPA), through this Information 

Collection Request (ICR) package, requests that the Office of Management and Budget (OMB) 

review and approve the ICR for Steam Electric Power Generating Effluent Guidelines. Through 

this collection, EPA will obtain data essential to the review and revision of the Steam Electric 

Power Generating effluent limitations guidelines and standards (ELGs) (40 CFR Part 423). 

EPA first identified the industry during its 2005 annual review of discharges from 

categories with existing effluent guidelines regulations, when publicly available data indicated 

that this industry ranked high in discharges of toxic and nonconventional pollutants. Because of 

these findings, EPA initiated a more detailed study of the industry and collected data through site 

visits, wastewater sampling, a limited data request, and secondary sources of data. EPA 

determined that steam electric power plants are responsible for a significant amount of the toxic 

pollutant loadings discharged to surface waters by point sources. Further information regarding 

these conclusions can be found in EPA’s study, Steam Electric Power Generating Point Source 

Category: Final Detailed Study Report (EPA 821-R-09-008). This ICR will support the review 

and revision of the Steam Electric ELGs. 

EPA’s Office of Water will administer the Steam Electric ICR (questionnaire) to power 

plants regulated by the steam electric ELGs codified at 40 CFR Part 423. The questionnaire 

(located in Appendix A) will be distributed to all coal- and petroleum coke-fired power plants 

and a statistically sampled subset of the rest of the steam electric industry, including oil-fired, 

gas-fired, and nuclear power plants. Therefore, many power plants will not receive the 

questionnaire. The questionnaire consists of several sections that have been tailored to address 

specific processes, specific data needs, or types of power plants. Parts A and I of the 

questionnaire will be sent to all questionnaire recipients; the remaining sections will be sent to 

discrete subpopulations of questionnaire recipients. By structuring the questionnaire in this 

manner, EPA will obtain information on specific aspects of power plant operations, while at the 

same time balancing the need for data with minimizing the number of respondents and the 

burden imposed by the questionnaire. 

Part A of the questionnaire will collect general plant information and selected technical 

information about the plant processes and the electric generating units. Additional sections of the 

questionnaire are designed to collect economic data and to collect technical information on flue 

gas desulfurization (FGD) wastewater, ash handling, cleaning of metal process equipment, 

wastewater treatment, surface impoundment and landfill operations, and nuclear operations. One 

section of the questionnaire will also require certain power plants to collect and analyze samples 
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of leachate from ponds/surface impoundments and landfills containing coal combustion residues. 

All respondents will be required to complete and submit an electronic version of the 

questionnaire. 

EPA has identified approximately 1,200 fossil- and nuclear-fueled steam electric power 

plants that are potentially within scope of the data collection objectives of the questionnaire. To 

reduce burden on the industry, EPA intends to distribute the questionnaire to a statisticallysampled subset of these facilities. Approximately 734 fossil- or nuclear-fueled steam electric 

plants will be required to complete Parts A and I of the questionnaire. This total includes 

approximately 495 coal-fired, 9 petroleum coke-fired, 20 oil-fired, 168 gas-fired, 20 nuclear 

power plants, and 22 combination power plants. For the purpose of this data collection, 

combination power plants refer to plants that have at least two generating units that have 

different unit-level fuel classifications (e.g., gas and oil, gas and gas-combined cycle) and do not 

operate generating units fueled by coal or petroleum coke. One or more of these subpopulations 

will also be required to fill out certain additional detailed sections (for some sections of the 

questionnaire, the coal-fired respondents will be reduced to a subset of approximately 94 plants). 

EPA has determined that the data obtained through the Steam Electric ICR is necessary 

for EPA to review and revise the ELGs for the steam electric industry. The ICR will obtain 

information about steam electric power generating industry operations for use in characterizing 

waste streams and the processes that generate the wastes, environmental data, and the availability 

and affordability of technologies that may be used to reduce wastewater pollutant discharges 

associated with this industry. These data will be used to perform detailed technical and economic 

analyses that will support EPA’s potential development of numerical limitations or best 

management practices for wastewaters generated by steam electric plants. 

The steam electric industry will devote time and resources to respond to the Steam 

Electric ICR. EPA estimates that the total burden to the 734 steam electric power plants for 

responding to the questionnaire will be approximately 144,451 hours, or $ 9,228,948 (including 

labor and O&M costs). The collection design represents EPA’s efforts to gather sufficient data to 

perform the analysis required to accurately review and revise the steam electric ELGs, yet at the 

same time administer an ICR that limits the burden placed on respondents. 
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2. NEED FOR AND USE OF THE INFORMATION COLLECTION 

2(a) Need/Authority for the Information Collection 

The objective of the Clean Water Act is to restore and maintain the chemical, physical, 

and biological integrity of the Nation’s waters. To help meet this objective, the CWA directs 

EPA to develop and issue ELGs for categories of point sources discharging to waters of the U.S. 

Under the authority of Section 308 of the Clean Water Act (Federal Water Pollution 

Control Act, 33 U.S.C. Section 1318), EPA’s Office of Water has begun an effort to develop

revised ELGs for wastewater discharges from the steam electric power generating industry. The 

steam electric industry has undergone significant changes since the ELGs were last revised in 

1982. For example, since that time, many power plants have installed FGD scrubbers to treat flue 

gas from their coal-fired units, generating a scrubber purge waste stream containing high 

concentrations of selenium, mercury, arsenic, and other pollutants of concern. EPA plans to 

administer a questionnaire to a statistical subset of the steam electric industry to collect general 

plant information, as well as additional economic and detailed technical data necessary to 

support technical analyses that will be used to develop revised ELGs. 

EPA will use the questionnaire data (along with information obtained from other sources 

consulted over the course of the rulemaking) to develop an industry profile, and to assess the 

pollutant reductions, costs, and economic achievability of candidate pollution control 

technologies, management practices, and process changes. This information is necessary to fulfill 

requirements established by the Clean Water Act and to inform Agency decision making about 

the appropriate course of regulatory action to address the pollutants present in wastewater 

discharges from power plants. EPA compiled certain information through a recently-completed 

study of the steam electric power generating industry and through public sources of information, 

but was not able to obtain the detailed plant-level and generator-level data that will be collected 

through this questionnaire. 

2(b) Practical Utility/Users of the Data 

(i) General Use of the Data 

EPA plans to use a questionnaire, consisting of multiple detailed sections, to solicit 

information from the steam electric industry. EPA will use the information collected from the 

survey to gain knowledge of current steam electric processes, characterize and quantify the 

pollutants currently discharged by the industry, and assess technical and economic achievability 

of available controls and potential environmental impacts. The information collected will provide 

EPA with owner/operator-level, plant-level, and/or generating unit-level data on processes, 

production, and costs that complement, and go beyond, data that are available from public 

sources. 

The steam electric questionnaire is designed to collect the following information. Part A 

of the questionnaire focuses on gathering general information from all coal- and petroleum cokefired power plants and a subset of the oil-, gas-, and nuclear-fueled steam electric plants. Part A 

gathers information on all steam electric generating units at the surveyed plant, the fuels used to 

generate electricity, air pollution controls, cooling water, an inventory of ponds/impoundments 
2-2 

and landfills used for coal combustion residues, coal storage and processing, and outfall 

information. 

Parts B through I collect economic data and detailed technical information on certain 

aspects of power plant operations, including requiring some plants to collect and analyze 

wastewater samples. These parts, depending on the specific section, will be sent to either all or a 

subset of coal- or petroleum coke-fired plants, and a statistical subset of the oil-, gas-, and 

nuclear-fueled power plants. The planned distribution of the questionnaire parts to plant 

respondents is illustrated by Table 2-1. Parts B through I will collect information on the 

following topics: 

• Part B: FGD systems; 

• Part C: Ash handling; 

• Part D: Pond/impoundment systems and other wastewater treatment operations; 

• Part E: Wastes from cleaning metal process equipment; 

• Part F: Management practices for ponds/impoundments and landfills; 

• Part G: Leachate sampling data for ponds/impoundments and landfills; 

• Part H: Nuclear power generation; and 

• Part I: Economic and financial data. 

Table 2-1. Number of Questionnaire Respondents (Plant Level Counts) 

Steam Electric Power Plants by Fuel Type 

Questionnaire Part Coal 

Petroleum 

Coke Oil Gas a Nuclear Combination b Total 

Estimated population of fossil/ 

nuclear steam electric plants 

495 9 43 561 63 32 1,203 

Total number of respondents 495 9 20 168 20 22 734 

Part A: Power plant operations 495 9 20 168 20 22 734 

Part B: FGD systems 495 c 9 c 20 c — — 22 c 546 c

Part C: Ash handling 495 9 20 — — 22 546 

Part D: Ponds/treatment 495 9 20 — — 22 546 

Part E: Cleaning wastes 94 3 20 168 20 22 327 

Part F: Management practices 94 3 — — — — 97 

Part G: Leachate sampling 94 d 3 d — — — — 97 d

Part H: Nuclear power 495 e 9 e 20 e 168 e 20 e 22 e 734 e

Part I: Economic data 495 9 20 168 20 22 734 

a – The “Gas” fuel type includes plants classified as “Gas” and plants classified as “Gas Combined Cycle.” See Part 

B of the Supporting Statement for further information on the different fuel type categories. 

b – Combination plants operate at least two generating units that use different types of fuel, but do not operate units 

fueled by coal or petroleum coke. The specific questionnaire parts that will be completed by these plants are 

dependent on the operations and types of units present. See Table B-3, in Part B of the Supporting Statement, for a 

more specific break out of combination plants. 

c – Number of plants is a maximum. Part B will only be completed by plants operating or planning to install FGD 

systems. EPA estimates 242 plants (less than half of coal, petroleum coke, and oil plants) will need to complete 

Part B. 

d – EPA estimates that 97 plants will receive Part G, but only about 30 percent of respondents (~30 plants) actually 

operate leachate collection systems and would therefore collect and analyze wastewater samples. 

e – Part H will be distributed to all respondents in the scope of the questionnaire; however, very few coal-, 

petroleum coke-, oil-, and gas-fired power plants receiving the questionnaire will also have nuclear generating units 

(e.g., EPA estimates only two coal-fired power plants have one or more nuclear units). 
2-3 

For EPA to determine appropriate revisions to the steam electric ELGs, EPA needs to 

gather information on steam electric generating units and the processes currently operated at 

plants. EPA also needs information on pollutants being discharged in power plants wastewaters, 

including wastewater from FGD systems, ash handling systems, process equipment cleaning 

operations, cooling water, and leachate collection systems. EPA also needs information about the 

wastewater treatment systems operated at power plants, and the availability and pollutant 

removal efficacy of new technologies or best management practices (BMPs) for the industry. In 

addition, EPA needs information to determine the costs and affordability of new technologies 

and/or BMPs, both for existing technologies and technologies implemented in the future. EPA 

will use the information collected by the questionnaire to address these factors and determine 

appropriate revisions to the ELGs. 

Note that in revising the ELGs, EPA may decide to take different actions for different 

subcategories or segments of the industry. For example, certain regulations may be revised for a 

specific segment of the steam electric industry (e.g., regulations for oil-fired plants vs. nuclear 

plants). 

Specifically, EPA will use information gathered throughout the questionnaire to: 

• Properly characterize and classify the steam electric industry. EPA may determine 

it is necessary or appropriate to subcategorize the steam electric industry based on 

fuel type, operational characteristics, location, size, or other factors yet to be 

determined. 

• Establish baseline estimates of pollutants discharged in steam electric process 

wastewater so that the reductions achievable by implementing process changes, 

treatment technologies, or BMPs can be determined. 

• Identify BMPs and pollution prevention opportunities that can reduce pollutant 

discharges. 

• Identify best available and best demonstrated technologies, as defined by the 

factors established in the Clean Water Act for effluent limitations guidelines and 

standards. 

• Determine potential environmental impacts of steam electric process wastewater. 

In addition to supporting a detailed profile of the steam electric industry to inform the 

rulemaking process, EPA will use the data collected through the questionnaire in conducting the 

following analyses: 

• Compliance cost assessment; 

• Facility-level cost impact analysis; 

• Parent entity-level cost impact analysis; 

• Household impact analysis; 

• Electricity rate impact analysis; 

• Electricity market analysis; 

• Regulatory Flexibility Act (RFA) analysis; 

• Unfunded Mandates Reform Act (UMRA) analysis; 

• Assessment of short-term reduction in capacity availability due to installation 

downtime; 
2-4 

• Analyses to address executive orders such as Executive Order 12866; and 

• Assessment of total social costs and benefits. 

(ii) Detailed Technical Analyses Supported by the Questionnaire 

EPA will conduct a detailed analysis of the technical data gathered in the questionnaire to 

clearly define the steam electric industry. EPA will also use the data to identify applicable and 

demonstrated technologies, wastewater treatment options, or BMPs that would substantially 

reduce pollutant discharges from steam electric power plants. Specific analyses using the 

technical data are described below. 

(a) Identification of Steam Electric Wastewater Characteristics 

Wastewater characteristics determine the technologies that can be used for treatment of 

steam electric generating wastewater. EPA needs to gather information identifying and 

quantifying the pollutants in wastewater from FGD systems, ash handling operations, leachate 

collection systems, process equipment cleaning activities, cooling water, and other steam electric 

processes, in order to identify and evaluate possible treatment solutions. EPA will use the data 

collected throughout the questionnaire to determine if process changes, BMPs, treatment 

technologies, or recycle/reuse processes are feasible options to reduce pollutant discharges. 

EPA will use data collected by the questionnaire and sampling data to identify pollutants 

that are commonly found in wastewaters from steam electric processes. EPA will also use the 

data to compare the performance of the different treatment technologies among steam electric 

plants to control these pollutants. 

(b) Potential Subcategorization of the Steam Electric Industry 

The steam electric power generating industry has undergone significant changes since the 

ELGs were revised in 1982 due to implementation of new technologies that alter existing or 

create new wastewater streams. Because of the variety of fuel types used to generate steam, a 

diverse group of technologies, processes, and wastewater treatment systems are used at facilities 

regulated by the ELGs. 

EPA will evaluate the different subsets of the industry to determine if subcategorization 

is appropriate for the steam electric industry. EPA will consider subcategorizing the industry 

based on such factors as: 

• Fuel type; 

• Plant age; 

• Plant size; 

• Steam electric generating process (e.g., combined cycle systems); or 

• Air pollution controls (e.g., FGD systems). 

EPA will use the questionnaire data, site visits, field sampling and other monitoring data, 

and secondary data to consider appropriate factors for subcategorization. 
2-5 

(c) Technology Analysis 

To determine appropriate requirements to include in revised ELGs, EPA will identify 

available technologies for reducing pollutant discharges associated with waste streams of 

concern, such as FGD scrubber purge, ash handling, cooling water, and other wastewaters. EPA 

will also evaluate the feasibility of using these technologies throughout the industry or for certain 

segments of the industry. EPA will evaluate and compare candidate pollution control 

technologies, as well as any factors that are relevant to the implementation of treatment 

technologies, process changes, or BMPs at certain types of facilities or categories of facilities. 

(d) Pollutant Loadings and Removals 

EPA will calculate baseline pollutant discharges that represent the quantity and nature of 

pollutants currently discharged by power plants. EPA will also calculate the amount of pollutant 

reductions that would be achieved if various candidate pollution control technologies, process 

changes, and/or BMPs were implemented. EPA will use these calculations to evaluate the 

effectiveness of candidate regulatory options for revised ELGs. EPA also intends to evaluate the 

benefits that would be realized by implementing candidate regulatory options and the cost 

effectiveness of the options in reducing pollutant loads. Calculating pollutant loads and removals 

includes the following: 

• Calculating baseline discharges for the year 2009 (the pollutant loadings 

discharges prior to any ELG revisions) using estimates of the volume of water 

discharged from specific steam electric processes and corresponding pollutant 

discharges; 

• Calculating estimated future pollutant loads that reflect how pollutant releases 

may change due to revised ELG requirements, using estimates of pollutant 

concentrations/mass and volume of water that would be discharged after 

implementation of new technologies and/or BMPs; and 

• Calculating the pollutant reductions that would be attributable to revised ELG 

requirements, by quantifying the difference between the baseline pollutant 

loadings and the post-treatment pollutant loadings. 

(e) Assessment of Technology Costs and Environmental Impacts 

EPA will estimate the incremental investment costs and incremental operating and 

maintenance costs for operators to implement technologies, process changes, and best 

management practices. These compliance costs will be used to determine the potential economic 

impacts on the steam electric industry. In addition, these compliance costs will be weighed 

against the effluent reductions resulting from each proposed technology/BMP option. 

To estimate these incremental costs, EPA will use industry profile information in 

conjunction with the following information collected with the questionnaire about FGD and ash 

handling treatment system components, as well as other operations as appropriate: capital costs 

for direct and indirect costs including, but not limited to, engineering design, construction cost, 

purchased equipment, and site preparation; and annual operating and maintenance (O&M) costs 

for equipment and operators. EPA will use the estimated compliance costs in economic analyses 

to determine the economic achievability of candidate technologies, process changes, and BMPs. 
2-6 

EPA will use data collected from the questionnaire to perform an environmental 

assessment to identify potentially affected environmental resources and assess the environmental 

impacts associated with the steam electric industry. The environmental assessment will be used 

to help characterize any environmental or economic benefits that would be attributable to revised 

ELG requirements. 

(iii) Detailed Economic Analyses Supported by the Questionnaire 

EPA will conduct detailed analyses using economic and financial data collected in Part I 

of the questionnaire. These analyses will be designed to determine if the costs of ELG regulatory 

control options are affordable to the steam electric industry. In each of these analyses, the survey 

data may be used as the primary input (e.g., cost information for a given technology is used 

directly in the cost model), or may be used to identify a subset of facilities for which a given 

analysis will be conducted. For example, information on revenue, number of employees, and 

electricity sales for the ultimate parent will be used to identify small entities according to the 

Small Business Administration (SBA) definition. Consequently, accurately capturing 

information on who the ultimate parent is and this parent’s revenue, number of employees, and 

electricity sales in the survey will be crucial for the RFA analysis. 
3-1 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

EFFORTS

3(a) Nonduplication 

(i) Technical 

The Engineering and Analysis Division (EAD) of EPA’s Office of Water made every 

reasonable attempt to ensure that the steam electric power generating effluent guidelines 

questionnaire does not request data and information currently available through less burdensome 

mechanisms. Specifically, EAD explored Agency databases, directories, contacts, and sources to 

locate data and information significant to the regulatory development process. EAD also 

examined other ongoing or completed EPA information collection efforts. In addition, EAD has 

conducted a thorough collection and review of secondary sources, which include data, reports, 

and analyses published by government agencies; reports, data, and analyses published by the 

steam electric industry and its associated organizations; and publicly available financial 

information compiled by both government and private organizations. This section summarizes 

the major data sources that EPA considered using as alternatives to parts of the steam electric 

questionnaire. 

The Energy Information Administration (EIA) is a statistical agency of the Department of 

Energy that collects information on U.S. electric generating plants and associated equipment to 

evaluate the current status and potential trends in the industry. During the steam electric detailed 

study, EPA used the 2005 EIA database as the primary source of data for the Steam Electric 

Power Generating Point Source Category: Final Detailed Study Report and is currently using 

the most recent version (2007) of this dataset to define the population to receive the steam 

electric questionnaire. The EIA data are useful for identifying steam electric generating units and 

certain aspects about processes at these units, but the data do not provide sufficient information 

about operations after 2007 or about wastewater generation and management. EIA data will be 

used to the extent possible to reduce burden on the industry; as such, EPA has developed the 

questionnaire in such a way to avoid duplication where practical. For example, EPA will use the 

EIA database to collect information on electric generating units, including the type of boiler, 

initial date of operation, date of retirement, and total capacity for units operating prior to 2009. 

In March 2009, EPA’s Office of Solid Waste and Emergency Response (OSWER) 

requested information from certain power plants regarding the design and management practices 

for some waste management units located at the facilities. This included surface impoundments 

or similar diked or bermed management units or management units designated as landfills that 

receive (or once received) liquid-borne material for the storage or disposal of residuals or byproducts from the combustion of coal, including, but not limited to, fly ash, bottom ash, boiler 

slag, or flue gas emission control residuals. The OSWER database contains information collected 

from plants that were identified as potentially operating ash ponds or FGD ponds, using the EIA 

data described above. The EIA data lacks information about waste disposal practices for some 

plants, and also omits information about landfills and certain ash/FGD ponds. Since the OSWER 

information request was based on the EIA data, the information collected does not provide 

statistically representative data about leachate, the wastes contained in the ponds/landfills, or the 

management/treatment practices used. For the purpose of the effluent guidelines rulemaking 

effort, EPA needs additional information that was not obtained by the OSWER information 

request, such as information about impoundments used to manage residues or by-products from 
3-2 

the combustion of other fuels (e.g., oil), impoundments at plants not included in OSWER’s data 

request effort, financial data, leachate collection and treatment for surface impoundments and 

landfills, and additional detail regarding surface impoundment BMPs. 

In January 2000, EAD distributed a detailed questionnaire to power plants to collect 

information on cooling water intake structures under Phase II, Section 316(b) of the Clean Water 

Act. The questionnaire collected information on current and planned operations, such as the 

number of cooling towers operated at power plants and whether or not the cooling towers were 

operated as “once-through” systems, and operational data from 1996 to 1998. The 316(b) 

questionnaire focused on data regarding the intake of cooling water, while the steam electric 

questionnaire collects data on characteristics and treatment of cooling water discharges, 

including information on the use of chemicals (e.g., biocides, corrosion control additives) in 

cooling water systems. 

EPA’s Office of Enforcement and Compliance (OECA) submitted an information 

collection request to 18 power plants in June 2009 requesting information on storage “areas” 

used to collect, store, treat, or dispose of waste or wastewater generated from the burning of coal. 

“Areas” in this request included, but were not limited to: underground mines; underground 

injection wells; landfills; tanks; waste piles; ponds; lagoons; storm drains; pipes; and surface 

impoundments. The power plants were not selected to be statistically representative and the data 

collected are not sufficient (i.e., dataset too small and not statistically representative) for 

extrapolating to industry-wide projections, and do not fulfill the data requirements for the 

effluent guidelines rulemaking identify to industry trends, evaluate technology options, and 

analyze the costs and affordability of pollution control options. Also, OECA’s information 

collection request was limited to coal-fired power plants. These data will not be sufficient for the 

other parts of the steam electric industry that EAD intends to survey. 

EPA’s Office of Air and Radiation is currently collecting information on existing utility 

steam electric generating units to support the Utility Maximum Achievable Control Technology 

(“Utility MACT”) rulemaking effort. The Utility MACT questionnaire, approved by OMB on 

December 31, 2009, collects information on the control of hazardous air pollutants (HAP) from 

both existing and new electric generating units. EAD will use the particulate matter system and 

mine location data, previously requested in the Steam Electric questionnaire, from OAR’s 

information collection effort. EAD also removed the analytical data for fuels by power plants 

requested in the questionnaire and will use fuel usage information from OAR. However, the 

scope of the Utility MACT ICR still differs from questionnaire in the following ways: 

• Although the Utility MACT ICR will collect information about the presence of 

certain air pollution control equipment, it will not collect information about the 

wastewaters generated from this equipment, nor will it collect information 

regarding related operating practices that affect the wastewater pollutant 

characteristics and generation rate. The Utility MACT ICR also will not collect 

the plant-level and parent-level financial data needed to assess the affordability of 

ELG pollution control options. 

• The effluent guidelines questionnaire will be distributed to plants that operate all 

types of fossil-fueled (coal, petroleum coke, oil, and gas) and nuclear-fueled 

steam electric units. The Utility MACT ICR will only collect information on coaland oil-fired steam electric units. 
3-3 

• The Utility MACT ICR will be distributed to coal- and oil-fired generating units 

producing more than 25 megawatts. The effluent guidelines questionnaire would 

collect information on steam electric units with capacities greater than 1 MW1. 

Therefore, the effluent guidelines questionnaire includes generating units that are 

not included in the Utility MACT ICR. 

In August 2008, EPA’s Office of Air and Radiation distributed an information collection 

request to facilities operating industrial, commercial, and institutional boilers and process heaters 

to support the Boiler Maximum Achievable Control Technology (“Boiler MACT”) rulemaking 

effort. The Boiler MACT questionnaire collected information for units not covered by the Utility 

MACT ICR (i.e., units under 25 megawatts that produce less than one-third of its potential 

electrical output capacity for sale). The Boiler MACT ICRs did not collect information from 

generating units that are subject to the effluent guidelines; therefore, the data collected are not 

useful for the effluent guidelines rulemaking. 

(ii) Financial and Economic 

EPA reviewed existing data sources to determine whether publicly available economic 

and financial data are available for steam electric entities regardless of their regulatory status and 

that these data are consistent and comparable. 

Publicly available economic and financial information for potential survey respondents 

differs depending on the regulatory status of the facility or generation unit, and on the ownership 

and operating structure. Furthermore, the level of detail at which information is provided (e.g., at 

the level of the owner rather than the generating unit) often differs from that which is needed by 

EPA. EPA has identified several sources that provide economic and financial data for steam 

electric utilities. Utilities are currently subject to annual reporting requirements by various 

government entities, including the Federal Energy Regulatory Commission (FERC) and EIA. In 

reviewing these data, EPA determined that the information available for regulated utilities are 

generally not sufficiently detailed and complete to support the plant level economic/financial 

impact analyses that will be conducted for the effluent guidelines rulemaking. Further, EPA 

determined that even less data are available for non-utilities (e.g., independent power producers). 

Therefore, EPA determined it is necessary to obtain financial data from both regulated utilities 

and non-utilities to ensure sufficient data consistency and comparability. 

To reduce respondents’ burden, however, EPA plans to use data already available from

public government and other public sources wherever possible, including when the data are the 

same as requested by the Agency in this questionnaire for some respondents. For example, EPA 

plans to use information major utilities provide to FERC to support analyses of the potential 

impacts of ELG revisions on these entities. 

In general, the questionnaire asks for three years of financial and operational information. 

The three-year period was selected to allow for the characterization of the industry and its level 

of activity over a period of more than one year, and thus avoid potentially anomalous 

 

1

 Although the scope of the steam electric ICR includes any generating unit primarily engaged in the production of 

electricity, the mailing list will be developed from EIA Forms 860 and 767. The minimum capacity necessary to be 

included in the EIA database is 1 MW. Therefore, the steam electric questionnaire will be distributed to plants 

operating steam electric generating units with a capacity of 1 MW or greater. 
3-4 

observations about a given plant, entity, or even the industry, based on a single year of data – 

while keeping respondent burden to a practical minimum. 

Below, EPA describes sources of data and information that were reviewed to identify 

existing sources of economic and financial data to reduce duplication of effort and minimize 

burden on survey respondents. 

FERC compiles information relating to such matters as financial operations, energy 

production or supply, and compliance with applicable regulations. FERC Forms 1 and 1-

F collect accounting, financial, and operating data from major and nonmajor privatelyowned electric utilities, respectively.2

 Neither form collects information for nonregulated entities (i.e., nonutilities), and the data collected do not include sufficient 

generating unit-level information and/or information for the ultimate parent. Further, 

Form 1-F data are much less detailed than data collected by Form 1, limiting their 

usefulness for the economic/financial impacts analyses EPA anticipates conducting for 

the effluent guidelines rulemaking. EPA plans to use information collected through 

Form 1 as a primary source of data for major utilities; respondents from plants owned by 

major utilities are therefore exempt from providing the information already reported on 

FERC Form 1.3 Considering the limitations of the FERC Form 1 data set, EPA is 

requesting that nonmajor utilities and nonutilities provide the necessary information using 

this questionnaire. 

EPA reviewed data collection forms used by the EIA and identified several forms that are 

potentially relevant to ELG economic analyses. Relevant EIA data forms include Form 

EIA-860, EIA-861, and EIA-923. Neither form provides data sufficient for EPA’s 

economic analyses to assess impacts of potential ELG options on individual plants or 

companies. The data are useful, however, to help identify potential recipients for the 

questionnaire and will be used in selecting a statistically representative subset of facilities 

for the questionnaire. 

The Rural Utility Service (RUS) is a program within the U.S. Department of Agriculture 

that provides rural infrastructure assistance in electricity, water and telecommunications. 

Rural utilities that borrow from RUS are subject to annual reporting requirements 

administered by RUS. The information collected is similar to data collected from major 

privately-owned electric utilities in FERC Form 1, albeit only for a subset of rural 

utilities. The limitations of these data are similar to those of the FERC Form 1 regarding 

the ability to relate financial information to specific plants and/or generating units. This 

data source is therefore not comprehensive enough to support the analyses EPA intends

to complete. Additionally, the RUS data are not readily available, which further limits 

their usefulness with respect to the ELG economic analyses. 

 

2

 This form only applies to privately-owned utilities. A privately-owned electric utility is considered “major” if its 

sales and transmission services, in each of the three previous calendar years, exceeded one of the following: 1) one 

million megawatt hours of total annual sales; 2) 100 megawatt hours of annual sales for resale; 3) 500 megawatt 

hours of annual power exchanges delivered; or 4) 500 megawatt hours of annual wheeling for others. A privatelyowned electric utility is considered “nonmajor” if it had total annual sales of 10,000 megawatt hours or more in the 

previous calendar year but is not classified as “major” under FERC Form 1 definition. 

3

 FERC Form 1 data for 2009 are expected to be available shortly after they are filed (due by April 18, 2010); 

consequently, EPA anticipates that Form 1 data will be publicly available by the time the survey is completed. 
3-5 

The Nuclear Regulatory Commission compiles and publishes data and reports regarding 

the nuclear sector of the electric power industry. However, these data and reports are 

based on information collected by other agencies and do not overlap with information 

requested in the detailed questionnaire. 

The Securities and Exchange Commission (SEC) administers federal securities law. 

Information filed with the SEC, such as standard financial statements, is made available 

through the Electronic Data Gathering, Analysis, and Retrieval system (EDGAR). 

Reports available through the SEC do not contain detailed site-specific information, but

they have firm-specific data that may be useful. EPA will use these data as a secondary 

source of parent firm-specific data. However, widespread use of these data will be limited 

because the SEC only collects information for publicly traded companies. In addition, the 

lack of facility-specific financial, engineering, and environmental data, the lack of unit 

level data, and the difficulty of accurately relating data to specific entities limit the use of 

this data source for effluent guidelines rulemaking. 

Edison Electric Institute (EEI) maintains comprehensive statistical data on shareholderowned electric companies and the electricity industry. This includes an annual financial 

review of shareholder-owned electric companies and key statistics for various aspects of 

the industry as a whole, including capacity, transmission, generation, fuel mix, emission 

reductions, and sales. While some data presented in the EEI annual financial review 

report duplicate data requested in the detailed questionnaires, the EEI data are considered 

confidential and EEI will only disseminate information in an aggregated form. In order 

for the information to be useful for this rulemaking effort, EPA must have the raw data 

on a facility-specific basis. 

To support analyses for revised effluent guidelines EPA has determined that, used alone, 

the sources discussed in this section are generally insufficient to meet its needs, and that more 

comprehensive, consistent, and statistically representative information on steam electric power 

plant operations is needed. 

3(b) Public Notice Required Prior to ICR Submission to OMB 

(i) Publication of the Federal Register Notice 

On October 29, 2009 (74 FR 55837), EPA published a notice in the Federal Register, 

announcing the Agency’s intent to submit a request for a new ICR and to collect comments on 

the Draft Questionnaire for the Steam Electric Power Generating Effluent Guidelines. EPA plans 

to publish a second notice in the Federal Register announcing the Agency’s intent to submit a 

request for a new ICR and to collect comments on a revised version of the Draft Questionnaire 

for the Steam Electric Power Generating Effluent Guidelines that incorporates comments 

received from the first comment period. The notice will include a description of the entities to be 

affected by the proposed questionnaire, a brief explanation of the need for the questionnaire, 

identification of the authority under which the questionnaire will be issued, and an estimate of 

burden to be incurred by questionnaire respondents. By means of this notice, the Agency will 

request any further comments and suggestions regarding the questionnaire and the reduction of 

data collection burden, and ask that the public submit all final comments and suggestions within 

30 days of the Federal Register notice publication. 
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Pursuant to section 3506(c)(2)(A) of the Paperwork Reduction Act, EPA will specifically 

solicit comments and information to enable it to: 

1. Evaluate whether the proposed collection of information is necessary for the 

proper performance of the functions of the Agency, including whether the 

information will have practical utility. 

2. Evaluate the accuracy of the Agency’s estimate of burden of the proposed 

collection of information, including the validity of the methodology and 

assumptions used. 

3. Enhance the quality, unity, and clarity of the information to be collected. 

4. Evaluate and test the MS Excel electronic format questionnaire that will be 

implemented for this information collection request. 

5. Minimize the burden of the collection of information on those who are to respond. 

(ii) Public Response to the Federal Register Notice 

 EPA received public comments from a variety of interested stakeholders following 

publication of the 1st FR Notice (October 2009). EPA received comments from power 

companies, industry trade associations, and an environmental group. These comments addressed 

general aspects of the ICR, and specific questions included in each part of the questionnaire. In 

addition to publishing the Federal Register notice, EPA informed trade associations and other 

industry contacts, environmental groups, and state and interstate regulatory authorities of the 

notice publication via phone and e-mail. 

EPA is appreciative of the efforts made by stakeholders to support and improve the focus 

and content of the draft questionnaire. EPA has benefited from this input and used the 

information gained to improve the ICR and the overall approach to developing revised effluent 

guidelines. An overview of the comments received and changes EPA has made to the 

questionnaire is presented below. Additional information about the comments received is 

presented in Appendix B at the end of this document. 

(a) General Comments 

Several comments noted that some data requested by EPA are available through other 

sources. In response, EPA has carefully reviewed the questionnaire to identify opportunities to 

obtain data from government databases and other EPA information collection efforts. EPA has 

revised the questionnaire to substantially reduce the reporting requirement, where possible, to 

eliminate requests for data that EPA can retrieve from the 2007 EIA, FERC data, and a 

questionnaire EPA distributed for the Utility MACT rule. Specific changes that were made in 

this respect are discussed more fully in Appendix B. 

Comments submitted by industry representatives stated a preference for EPA to distribute 

the questionnaire in Microsoft Excel format. The questionnaire previously made available for 

review and comment was prepared as a Microsoft Word document and EPA solicited comment 
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on the preferred format. EPA revised the questionnaire to the MS Excel format, to acknowledge 

the stated preference and to lessen the burden associated with data entry and data collection. 

The instructions for the previous version of the questionnaire included a requirement for

respondents to include information providing justification for any claims that the data submitted 

with the completed questionnaire should be afforded protections as confidential business

information (CBI). EPA included this requirement in the draft questionnaire to discourage 

unjustifiable CBI claims and because any requests for information claimed as CBI would 

necessitate EPA contacting the respondent for information to justify the claim. In general, it is 

more efficient for the respondents to provide justification information at the same time they are 

completing the questionnaire, rather than doing so at a later date. Nevertheless, EPA recognizes 

that supplying these justifications does impose a burden on respondents and that, unless

subsequently requested to justify the CBI claim, this may be an unnecessary burden. EPA 

considered establishing up-front categorical CBI protection for certain categories of data, but 

determined this approach would not sufficiently reduce unnecessary burden on respondents. 

Therefore, EPA has amended the requirement to simply allow answers to be marked as CBI 

according to practices familiar to the industry. Respondents will not be required to provide CBI 

justifications when they submit the completed questionnaire. Should EPA receive a request for 

information claimed CBI, the respondent will need to justify the CBI claim in accordance with 

procedures outlined in 40 CFR Part 2. 

Industry stakeholders commented that a glossary of key terms and definitions should be 

developed and included in the questionnaire to reduce potential ambiguities and confusion. EPA 

agrees that a glossary would improve understanding of the terms used in specific questions and 

would likely improve the quality of the data obtained. EPA prepared a glossary and, in advance 

of the public comment period for the second Federal Register notice, shared this draft glossary 

with interested stakeholders (industry and environmental groups) and offered them the 

opportunity to provide early feedback on the terms defined, as well as to identify other terms that 

should be included. EPA considered this feedback in revising the glossary, which is included in 

the current version of the questionnaire. 

Industry and trade associations commented that the initial hourly burden for this ICR was 

underestimated. EPA carefully reviewed each comment regarding the burden and thoroughly 

explored suggested burden estimates received from industry. The burden estimate was revised in 

response to industry comment, as well as the changes made to questionnaire since the publication 

of the first Federal Register notice. In order to revise the burden, EPA compared the first burden 

estimate and the suggested estimate from industry to develop a more accurate hourly burden. For 

example, EPA revised the burden estimate of each part to allow for upfront coordination time 

required to gather information for and review the questionnaire. Additions and revisions to 

questionnaire parts (e.g., Parts C, F, and H) also increased the hourly burden. EPA did not

increase the legal hourly burden as the requirement for CBI justifications was removed from the 

questionnaire. Decreases in hourly burden estimates resulted from removing burdensome 

questions, as suggested in public comment, such as the request for analytical coal data and mine 

location data. In many questions, the number of years for which data was requested was 

decreased (e.g., all revenue questions throughout the questionnaire only request data from three 

years instead of the five consecutive years previously requested). The adjustments made to the 

burden estimate increased the hourly burden per part; however, the changes in the number of 

respondents decreased the overall hourly burden originally estimated for the industry. 
3-8 

Industry and trade associations commented that the 60 day response period for the 

questionnaire is insufficient, especially if the questionnaire will be sent to facilities in Spring 

2010. Commenters specifically expressed concern about overlapping reporting requirements (in 

terms of timeframe) with annual reporting for EPA’s Toxics Release Inventory, DOE’s Energy 

Information Administration, and the Federal Energy Regulatory Commission. EPA does not 

agree that additional time should be provided for responding to the questionnaire. EPA is aware 

that the questionnaire requests a substantial amount of detailed information; however, the Steam 

Electric questionnaire will be distributed to industry after these other annual reporting 

requirements are due and therefore they should not interfere with this questionnaire. Facilities 

should answer the questionnaire with the best available information provided the scope and time 

constraint of the ICR. In addition, EPA will distribute the questionnaire electronically and 

provide separate files for each part to allow facilities to distribute the questionnaire to 

appropriate personnel. Respondents that have individual circumstances affecting their ability to 

respond within the 60 day response time should apply individually for an extension, as described 

in the instructions for the questionnaire. EPA’s decision to grant any extensions will be based 

upon consideration of an individual plant’s or company’s situation. 

EPA reviewed public comment regarding the scope of the questionnaire and decided that

the facilities included in the scope will provide the best information to aid EPA in this

rulemaking effort. All coal-, petroleum coke-, oil-, gas-fired and nuclear steam electric power 

plants identified by the 2007 EIA database will be included in the industry population and used 

to select the specific questionnaire recipients. EPA did not elect to statistically sample a subset of 

the coal-fired power industry for Parts A through D and I due to the number and types of factors 

to be considered regarding FGD and ash operations, and the limited data available for identifying 

these factors at power plants to the extent necessary for establishing and defining strata for 

statistical sampling, as well as the individual plants that populate each sampling strata. 

Throughout the detailed study and during initial rulemaking activities, stakeholders have stressed 

the need to evaluate how variability in equipment and operating practices between plants affect 

wastewater discharges. In addition, stakeholders expressed concern over properly accounting for 

the financial conditions at each plant, considering ownership of individual generating units 

including, in a number of instances, multiple partial owners. The types of operations and the 

associated process wastewaters can change from facility to facility depending on factors, such as 

the type of coal burned, air pollution controls in place, type of wet FGD absorber design, FGD 

wastewater treatment, type of ash handling system, ash pond management, type of cooling water 

system, and the water source. Considering the large number of characteristics to be evaluated and 

the limited data currently available, EPA will distribute Parts A through D and I of this 

questionnaire to all coal-fired power plants. 

However, to reduce overall burden, EPA selected a statistical subset of coal-fired plants 

to receive more detailed parts of the questionnaire, including parts requiring sampling of 

collected leachate. EPA eliminated small entities from the subset of plants selected to sample 

leachate from ponds/impoundments and landfills to reduce the overall burden to small 

businesses. In addition, EPA removed any plants that will be permanently retired by

December 31, 2011 from the scope to reduce overall industry burden. Information from plants 

that do not discharge wastewater is relevant to the rulemaking process because it provides 

valuable insight to approaches to reduce or eliminate pollutant discharges and it will be factored 

into the development and consideration of effluent guidelines options for other plants. Therefore, 

these plants remain in the scope of this ICR. Commenters also requested that EPA exempt those 
3-9 

nine companies that responded to the 2007 data request used to support EPA’s detailed study. 

However, this ICR collects more broad operational data that was not obtained by the 2007 data 

request and that is not obtainable through publicly available sources, therefore EPA has retained 

those facilities in the potential pool of respondents. 

EPA reviewed and considered comments requesting that EPA allow the submittal of data 

for 2008 versus 2009. Due to ongoing changes in the industry with respect to installation of air 

pollution controls, treatment systems, and other technology improvements, EPA needs the most 

current data available in order to best determine if revisions need to be made to the effluent 

guidelines. EPA has also reviewed comments regarding cost information requested in the 

questionnaire. EPA is aware that gathering capital cost information for systems that are several 

or more decades old may take some effort and has limited the cost requests to a reasonable 

timeframe, to include systems that are technologically relevant and for which data should be 

available. Depending on the data requested, EPA asks for plants to provide cost information for 

systems installed since 1985 or 1990. Relatively few plants have installed treatment systems 

since then, therefore EPA has selected these dates to obtain the data necessary to evaluate 

potential technology options. 

(b) Comments Related to Specific Parts of the Questionnaire 

EPA reviewed comments submitted to the docket during the first comment period for 

each specific part of the questionnaire. The following paragraphs summarize EPA’s responses 

and major changes made to questionnaire since the publication of the first Federal Register 

notice. See Appendix B for a more detailed discussion of changes made to the questionnaire. 

EPA revised questions in all questionnaire parts regarding the request for marketing and 

revenue data for each of the past five years (found in Parts B and C). EPA has determined that 

sufficient information can be obtained using data reported for three years of the five-year period 

and has changed these questions to request information for years 2005, 2007, and 2009. 

Part A. Steam Electric Power Plant Operations

EPA revised questions to help clarify the information requested in the ICR. For 

example, the directions and format of Table A-5 were revised to make it more apparent 

what plants should be included in the table. Questions on fuel usage were revised so that 

plants only had to indicate the total amount of fuel used and not specify how much was 

used for startup versus normal operations. 

EPA also evaluated questions in all questionnaire parts identified as overlap with 

other industry ICRs (e.g., EIA, Utility MACT), as noted in the General Comment 

Response section. EPA removed questions from Part A, where possible, to decrease the 

burden on the industry. For example, the questions asking for analytical data and mine 

location information for coal sources were removed because similar information is being 

obtained from the Utility MACT ICR. EPA recognizes that this change will not collect 

information on boilers less than 25 MW, but believes information on larger boilers will 

provide sufficient information to evaluate this population of boilers. Additionally, the 

tables requesting information on particulate matter and sulfur dioxide control systems 

were removed from Part A. 
3-10 

As a result of industry comment, EPA revised or removed several questions from 

the questionnaire to decrease burden on plants. For example, the requirements for the 

property map and water balance diagram were revised to decrease the burden on plants. 

To compensate for the removal/revision of certain questions, EPA added some questions 

into the ICR. For example, questions about the plant’s permitted outfalls were added so 

the question asking plants to identify all plant waste streams and flow rates in 2009 could 

be removed. EPA also added/revised questions to help clarify who should complete the 

questionnaire. For example, EPA added a question so plants that will be permanently 

retired by December 31, 2011 would not need to complete the ICR. EPA also added 

questions based on public comments. For example, EPA added questions about SCR 

catalyst washing based on a commenter’s suggestion. 

Part B. Flue Gas Desulfurization (FGD) Systems

EPA revised questions in Part B to help clarify the information requested in the 

questions and reduce the burden on the industry. EPA consulted industry representatives 

in revising the FGD system terminology used in the section and to make changes to

Figure B-1, the example FGD system diagram, to include all wastewaters associated with 

the FGD system operation. Additionally, to reduce burden on respondents, EPA revised 

several questions that previously requested five years of data to request only three years 

of data. EPA also deleted a table that obtained detailed information on materials of

construction for the FGD system. 

Part C. Ash Handling

After reviewing public comment and researching ash handling techniques in 

further detail, EPA restructured the sections within Part C. EPA revised Part C to gather 

information from plants based on an ash handling system level, rather than a steam 

electric generating unit level. This approach is more consistent with the manner the 

systems are operated and the change should help plants provide EPA with a more 

complete picture of ash handling systems, while avoiding having to report certain 

information more than once. EPA also restructured the ash handling cost sections to 

respond to industry comment on the best way to collect this information, as well as to 

collect the information necessary to evaluate costs accurately (e.g., costs for combined 

storage and disposal of fly and bottom ash). 

Part D. Pond/Impoundment Systems and Other Wastewater Treatment Operations

EPA revised questions and instructions in Part D in response to public comment. 

General instructions for Part D were revised to provide clarity and direction for 

respondents. EPA also revised questions to address potential differences in plant 

responses (e.g., added more options for responses regarding chemical addition, flow rate) 

to reduce the potential for inconsistent answers, pointed out as a potential issue in public 

comment. In addition to these revisions, EPA added questions to collect improved 

compliance cost data for treatment systems. These questions, which include effects on the 

plant and/or wastewater treatment system due to climate and space availability, will 

ultimately provide EPA with more accurate cost information to develop potential 

technology options for the industry. EPA also revised the capital cost table for 
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ponds/impoundments and wastewater treatment systems to distinguish plants that hired 

an outside contractor to construct/install the wastewater treatment system. 

Part E. Wastes from Cleaning Metal Process Equipment

EPA revised Part E to require plants to provide information on each type of 

cleaning operation that was performed within the last 10 years, and to provide “typical” 

values such as volume of wastewater per cleaning event, instead of requiring plants to 

provide data for every process cleaning option since January 1, 2000. After reviewing 

information collected from the 2007 data request for the Steam Electric Power

Generating Industry and site visits, EPA concluded that cleanings are sporadic in nature 

and long periods of time pass between each cleaning. EPA also defined terms throughout

Part E to improve the questionnaire. 

Part F. Management Practices for Ponds/Impoundments and Landfills

EPA reduced the information in Part F requesting previously-conducted 

impoundment inspections as these data would not have a significant impact on the 

revisions to the effluent guidelines. EPA reconsidered information requesting respondents 

to provide BMP information for planned ponds/impoundments and landfills and 

eliminated the requests to further reduce industry burden. 

In order to collect all information necessary to accurately revise the effluent 

guidelines, EPA added questions to request information on segregated leachate treatment 

systems, if the plant has not already provided information about those systems in Part D. 

This segregated leachate treatment information will be used to develop potential options 

for treatment of the leachate waste stream. 

As a result of public comment, EPA also revised the stormwater runoff questions 

to request information on stormwater that contacts the capped portion separately from the 

questions requesting information on stormwater that contacts the uncapped portion to 

remove any confusion regarding the definition of stormwater. 

Part G. Leachate Sampling data for Ponds/Impoundments and Landfills

EPA recognizes the costs associated with the sampling requirement in this part 

and has accounted for the costs in the overall burden of the ICR. However, EPA did not 

remove the sample collection requirement because these data are necessary for 

characterizing leachate streams and evaluating potential revisions to the ELG. 

To reduce burden on small entities, EPA intends to exclude plants operated by 

small entities from the requirement to collect and analyze leachate samples. EPA is 

providing substantial flexibility to those firms selected to complete Part G. First, the 

plants are allowed to submit previously-collected data in lieu of sampling, if the prior 

data includes all information requested by Part G. Second, EPA is allowing plants to 

collect samples from a single “representative” leachate collection point for each 

individual pond or landfill, rather than every leachate collection point that may be present 

at the pond or landfill. Third, EPA is providing additional flexibility in the analytical 

method that may be used to analyze the samples, for certain parameters. 
3-12 

Leachate sample instructions were revised to clarify how to select the leachate 

sample location and how to complete the sample collection if the facility does not 

generate leachate weekly. EPA considered comments about laboratory availability for 

analysis by low level methods (e.g., Method 1631 E) and determined that laboratory 

availability will not cause a significant problem due to the limited number of plants 

expected to complete Part G. In addition, the holding time for EPA Method 1631E is 90 

days; therefore, samples will not need to be analyzed immediately. This holding time will 

allow laboratories time to receive and preserve the samples in order to handle the 

required analyses within the timeframe required by Part G. 

Part H. Nuclear Power Generation

After reviewing public comment, EPA reduced burden by removing requested 

information that can be found using other data sources (e.g., information about the type 

of reactor is publicly available from NRC). EPA also added a list of process wastewaters 

expected to be generated nuclear plants to help plants understand what should be reported 

in the questionnaire and to ensure that all plants respond consistently. EPA also added a 

new section called “Wastewater Treatment Systems” to Part H. EPA will use information 

in this section to better characterize how process wastewater associated with nuclear 

generating units is treated and handled. 

Part I. Economic and Financial Data

EPA received comments pertaining specifically to Part I. In addition to concerns 

regarding certain specific questions, commenters raised several substantive general 

concerns regarding: the duplication of data currently provided to other regulatory

agencies; EPA’s request for certain data not currently compiled by facilities under 

customary business practices; the challenge of coordination of responses from multiple 

plant owners; and the need to clarify terms used in the questionnaire. In response to these 

comments, EPA made several changes to Part I of the questionnaire to reduce the

respondent burden and/or clarify the data request. For example, EPA reduced burden by

allowing respondents who submit data to FERC in Form 1 to skip questions and by 

eliminating or reducing the number of items or years for which respondents are asked to 

provide data. In response to comments received by EPA regarding the availability of 

certain data, the Agency revised its burden estimate to account for the potentially higher 

level of effort involved in compiling certain financial information that may not be readily 

available. For example, EPA increased the burden estimate for compiling information 

regarding the share of electricity sold under different pricing conditions and for 

estimating plant-level financial data when such data are not already reported under 

customary business practice by the plant. 

3(c) Consultations 

The Agency will continue to solicit comments from industry and other stakeholders 

following publication of the second Federal Register Notice. Following the first Federal Register 

Notice, EPA hosted a number of teleconferences and meetings with representatives from the 

Utility Water Act Group (UWAG), Electric Power Research Institute (EPRI), other industry 

trade associations, individual power plants, state regulatory authorities, and environmental 

groups to solicit input and better understand stakeholder comments. EPA presented information 
3-13 

about the effluent guidelines regulatory process and schedule, data collection objectives, and 

various aspects of the draft questionnaire. Discussions about the questionnaire addressed topics 

such as the terminology for FGD systems and throughout the questionnaire, structure and format 

of the questionnaire, and specific matters such as ash handling, leachate collection, and FGD 

operations. EPA also shared a draft glossary and mailing list of power plants with industry and 

environmental group representatives to obtain feedback in advance of the second Federal 

Register notice. EPA plans to conduct additional teleconferences and meetings with industry, 

other government agencies, and other interested stakeholders, as needed, to solicit any further 

input on the steam electric effluent guidelines questionnaire. 

3(d) Effects of Less Frequent Collection 

This survey is to be administered one time only. If this survey is not conducted, the 

specific data sought in this survey will not be available for EPA’s use in decision making about 

the need for and scope of potential actions to prevent or mitigate the environmental impacts of 

discharges from steam electric facilities. Reliance on public data alone would significantly 

impair EPA’s ability to evaluate treatment technologies and analyze the costs and financial 

impacts of regulatory options on the steam electric industry, as well as to evaluate other factors 

as established by the Clean Water Act. 

3(e) General Guidelines 

EPA will conduct data collection activities in accordance with the PRA guidelines in 5 

CFR 1320.6 and EPA’s Quality Assurance Guidance. Information to be disseminated will 

comply with EPA’s Information Quality Guidelines, which were developed for implementing 

OMB’s Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity 

of the Information Disseminated by Federal Agencies. 

3(f) Confidentiality 

The questionnaire informs respondents of their right to claim information as confidential 

in accordance with 40 CFR Part 2, Subpart B, Section 2.203. The questionnaire provides 

instructions for claiming confidentiality, and informs respondents of the terms and rules 

governing the protection of Confidential Business Information (CBI) under the Clean Water Act 

and 40 CFR 2.203(B). Each question which requests potentially confidential information is 

accompanied by a CBI checkbox. Questionnaire respondents are directed to check the CBI 

checkboxes which accompany responses they claim as confidential. 

EPA and its contractors will follow existing procedures to protect data labeled as CBI. 

These procedures include the following: 

• Ensure secure handling of completed questionnaires to preclude access by 

unauthorized personnel. 

• Store completed questionnaires and databases in secured areas of offices, and 

restrict access to authorized EPA and contractor personnel only. 

• Restrict any publication or dissemination of confidential study results or findings 

to aggregate statistics and coded listings. 
3-14 

Information covered by a claim of confidentiality will be disclosed by EPA only to the 

extent of, and by means of, the procedures set forth in 40 CFR Part 2, Subpart B. In general, 

submitted information protected by a business confidentiality claim may be disclosed to other 

employees, officers, or authorized representatives of the United States concerned with 

implementing the Clean Water Act. Exemption 4 of the Freedom of Information Act (FOIA) 

protects from disclosure "trade secrets and commercial or financial information obtained from a 

person and privileged or confidential." See 5 U.S.C. 552(b)(4). 

Information covered by a claim of confidentiality will be made available to EPA 

contractors under EPA Contract Numbers No. 68-C-02-095 and EP-C-07-023 to enable the 

contractors to perform the work required by their contracts with EPA. Each EPA contractor that 

collects, possesses, or stores CBI is responsible for the proper handling of that data. Each 

contractor will safeguard information as described in Section 2.211(d) of Subpart B and is 

obligated to use or disclose information only as permitted by the contract under which the 

information is furnished. 

3(g) Sensitive Questions 

No sensitive questions pertaining to private or personal information, such as sexual 

behavior or religious beliefs, will be asked in the questionnaire. 
4-1 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) Respondents NAICS Codes 

The respondents affected by this ICR are classified under the North American Industry 

Classification System identification number 2211 – Electric Power Generation, Transmission, 

and Distribution, which includes establishments that may perform one or more of the following 

activities: 

• Operate generation plants that produce electric energy; 

• Operate transmission systems that convey the electricity from the generation plant 

to the distribution system; and 

• Operate distribution systems that convey electric power received from the 

generation plant or the transmission system to the final consumer. 

Within NAICS code 2211, the following specific NAICS codes apply to steam electric 

plants: 

• 221112 – Fossil Fuel Electric Power Generation; 

• 221113 – Nuclear Electric Power Generation; and 

• 221119 – Other Electric Power Generation. 

Affected entities may also include immediate and ultimate parent firms in other NAICS 

codes. 

4(b) Information Requested 

(i) Detailed Description of the Steam Electric Effluent Guidelines Questionnaire 

EPA is planning to conduct a survey of steam electric power plants. The questionnaire is 

designed to collect technical information related to wastewater generation and treatment, and 

economic information such as costs of wastewater treatment technologies and financial 

characteristics of affected companies. It will provide information that will be used to evaluate 

pollution control options for establishing revisions to the effluent guidelines for the steam 

electric power generating point source category. 

The questionnaire consists of nine parts as described in Section 2(b). EPA will distribute 

the questionnaire in electronic format, and respondents will be required to submit the completed 

questionnaire to EPA in electronic format. The electronic questionnaire will be developed to 

meet the 1998 Government Paperwork Elimination Act (GPEA). Given the level of information 

technology implementation at electric power generating facilities and requirements established 

by EIA which require electronic submission of data, EPA anticipates that respondents will be 

familiar and comfortable with electronic submission forms. Additionally, the electronic 

questionnaire will allow for automatic population of a database with responses—reducing the 

potential for errors introduced though key-entry of data. 

EPA designed the questionnaire to include many burden-reducing features. For example, 

it contains many “screening” questions that direct respondents to skip portions or entire sections 
4-2 

of the questionnaire containing detailed questions that may not pertain to their company or steam 

electric power generation operations. 

The questionnaire was designed in modular fashion to reduce respondent burden by 

making it easier for them to separate the questionnaire into sections that can be delegated to 

various plant and corporate staff. The computer disk that will be distributed to questionnaire 

recipients will include both the electronic-fillable questionnaire and a pdf-file that can be printed 

out and used as a working copy. Copies of selected sections can be made when needed, and 

selected sections of the working copy distributed to the appropriate staff. The electronic 

questionnaire format further simplifies this task by allowing facilities to electronically generate 

the required number of copies of each section. 

Some sections will not be applicable to all respondents. General instructions to the

questionnaire describe allowable responses for cases in which a facility will be unable to respond 

to a question. A response of “NA” corresponds to questions that are not applicable. 

Justifications for the Questionnaire Questions 

The data items requested by the questionnaire and justifications for requesting the 

information are shown below: 

Part A: Steam Electric Power Plant Operations 

Part A gathers information on all steam electric generating units, the fuels used to run the 

units, air pollution controls, cooling water, coal storage and processing, and pilot studies. 

Table 4-1. Steam Electric Power Plant Operations Question Justifications 

Question 

Number Question Description Purpose of Question 

A1-1 through 

A1-5 

Requests plant name and address, and the 

primary and secondary contacts for the 

technical and economic questionnaire 

information. 

EPA needs to know the location of the plant to 

determine any geographic limitations/restrictions 

for the plant. EPA also needs to know who should 

be contacted to verify or clarify the technical and

economic questionnaire information provided. 

A1-6 Asks if the plant will be permanently retired 

by December 31, 2011. 

EPA would use this question to identify plants that

should complete the questionnaire; plants that will

be permanently retired by December 31, 2011 are 

exempted from completing the remainder of the 

questionnaire. 

A1-7 Asks if the plant generated electricity or has 

the potential to generate electricity from a 

steam electric generating unit. 

EPA would use this question to identify plants that

should complete the questionnaire; plants that do 

not generate electricity from a steam electric 

generating unit would not complete the rest of the 

questionnaire. 

A1-8 Requests the plant to identify the types of 

fuels used by the plant to generate electricity. 

EPA would use this question to identify plants that

should complete the questionnaire; plants that do 

not use a fossil or nuclear fuel to generate 

electricity would not complete the rest of the 

questionnaire. 
4-3 

Table 4-1. Steam Electric Power Plant Operations Question Justifications 

Question 

Number Question Description Purpose of Question 

A1-9 Requests information about end use/handling 

of the electricity generated at the plant. 

EPA would use this question to identify industry 

trends and in its economic evaluation of the 

industry. 

A1-10 and 

A1-11 

Requests the primary, secondary, and tertiary, 

six-digit NAICS codes for the plant and asks 

if the primary purpose of the plant is 

electricity generation. 

EPA would use the responses from these questions 

to identify the operations occurring at the plants,

classify them into specific categories, and identify 

small businesses (along with economic/financial 

information). EPA expects that these questions 

would help identify industrial facilities. EPA 

would also use this question to identify plants that 

should complete the questionnaire; plants that do 

not generate electricity as its primary purpose 

would not complete the rest of the questionnaire. 

A1-12 Asks the plant to identify how it uses the 

steam generated at the plant. 

EPA would use the responses from this question to 

determine whether the plant is using the steam for 

purposes other than electricity generation because 

if it is, the amount of fuel used at the plant may not 

correlate directly with the amount of electricity 

produced. This information would be used in 

developing production-normalized effluent limits. 

A1-13 Requests the total nameplate, summer, and 

winter capacities for the entire plant. 

EPA would use this information to classify plants 

by size, which is a characteristic that will be 

evaluated for possible subcategorization. This 

information informs EPA of the non-steam electric 

plant capacity (when compared to the steam 

electric capacity obtained later in this part). 

A1-14 Requests the net and gross electricity 

generation for the plant from 2007 to 2009. 

EPA would use this information to compare the 

amount of electricity generated to the total plant 

capacity and to calculate the parasitic load 

associated with the plant. Several years of data are 

requested due to the reduced power generation 

during the economic recession. 

Plant Identification and Information on Permits and Studies 

A2-1 and 

A2-2 

Requests the identification codes of the plant 

when reporting to Energy Information 

Administration (EIA) and Rural Utilities 

Service (RUS). 

RUS and EIA both collect data on steam electric 

power plants relevant to the rulemaking. EPA 

would use these codes to link the plant to the data

collected by RUS and EIA. 

A2-3 Request information on any Environmental 

Assessment (EA) or Environmental Impact 

Statement (EIS) studies the plant conducted 

on receiving water or pond/impoundments. 

EPA would use this information to assess the 

environmental impact of discharges from steam 

electric plants as well as the impacts that 

pond/impoundments have on the environment. 
4-4 

Table 4-1. Steam Electric Power Plant Operations Question Justifications 

Question 

Number Question Description Purpose of Question 

A2-4 Requests permit IDs, approval dates, and 

expiration dates for several permitting 

programs. Also requests whether a 

new/pending permit is under development. 

Also directs plants, who do not have a NPDES 

permit, to skip to Question A3-1. 

EPA would use this information to identify the 

permitting programs under which the plants are 

permitted. Additionally, EPA would use the permit 

IDs to be able to obtain specific permits, if desired, 

instead of requesting that all plants provide all of 

their permits. EPA would use this question to 

identify plants that should complete questions A2-

5 through A2-10; plants that do not have a NPDES 

permit would not need to complete questions A2-5 

through A2-10. 

A2-5 through 

A2-10 

Asks the plant to identify information for all 

outfalls designated in the plant’s NPDES 

permit. For each outfall, the plant would be 

required to specify the outfall name, 

coordinates, discharge flow, the types of 

wastewaters discharged in the outfall, and 

information about the receiving waters. 

EPA would use this information to evaluate how 

plants are impacting receiving waters and to 

determine if changes have occurred in the industry 

since the last rulemaking that warrant revisions to

the effluent guideline. Additionally, EPA would 

use this information to characterize the types of 

surface waters which receive discharges from 

steam electric power plants and use this 

information in the industry profile and for 

assessing environmental benefits. 

Ponds/Impoundments 

A3-1 through 

A3-3 

Asks the plants to identify any existing or 

planned ponds/impoundments that are/will be 

used for the storage or disposal of process 

wastes, residues, or by-products. Requests 

information about pond contents, locations, 

liners, and leachate collection. 

EPA would use this information to identify the 

total number of ponds/impoundments that are 

operated by the industry respondents and to 

identify the types of materials that are disposed of 

in each pond/impoundment. The 

pond/impoundment liner and leachate questions 

will be used to identify management practices for 

ponds operated by the industry. Additionally, the 

location information would be used to identify 

transport requirements and possible leaching 

issues associated with the pond/impoundment. 

Landfills 

A4-1 through 

A4-3 

Asks the plants to identify any existing or 

planned landfills that are/will be used for the 

storage or disposal of process wastes, 

residues, or by-products. Requests information 

about landfill contents, locations, liners, and 

leachate collection. 

EPA would use this information to identify the 

total number of landfills that are operated by the 

industry respondents and the types of materials 

that are disposed of in the landfills. The landfill

liner and leachate questions will be used to 

identify management practices for landfills 

operated by the industry. Additionally, the location 

information would be used to identify transport 

requirements and possible leaching issues 

associated with the landfill. 

Plant Property and Water Balance 

A5-1 Requests the latitude and longitude of the 

plant, if not already reported to EIA 

The location of the plant would help EPA to 

determine any geographic limitations/restrictions 

for the plant. 
4-5 

Table 4-1. Steam Electric Power Plant Operations Question Justifications 

Question 

Number Question Description Purpose of Question 

A5-2 Requests a property map showing the plant 

boundaries. 

EPA would use the property map to better 

understand the general layout of the plant and the 

amount of land available for installation of 

equipment required for compliance with potential 

regulatory options. 

A5-3 Requests a water balance diagram for the 

plant that shows all process wastewaters 

generated at the plant, their flow rates and 

handling/treatment, and plant outfalls. 

EPA would use the water balance diagram to 

assess how wastewaters are generated and how 

they are handled, treated, and discharged. 

Steam Electric Generating Unit Information 

A6-1 Requests general information on the steam 

electric units that have been operated by the 

plant prior to December 31, 2009. 

EPA would use this information to characterize the 

steam electric units operated in the industry and 

update the industry profile. EPA would use the 

information to determine whether the unit 

characteristics affect the wastewaters generated 

and use the information to predict the type of 

wastewaters associated with planned units. 

A6-2 Requests general information on the steam 

electric units that first began operating after 

January 1, 2010, that the plant is currently 

constructing/installing, or that the plant is 

planning to construct/install by December 31, 

2015. 

EPA would use this information to characterize the 

planned steam electric units and update the future 

industry profile. EPA would also use the 

information to predict the type of wastewaters 

associated with the units. 

Condenser Cooling Water Systems 

A7-1 Requests information about the condenser 

cooling systems operated during 2009 that are 

associated with steam electric generating units 

including the type of cooling system (e.g., 

once through), and information on the 

chemical additives used in the cooling system.

EPA would use this information to identify 

industry trends. EPA would also use the 

information to determine the dilution occurring if 

the cooling water is commingled with other 

wastewater streams prior to being discharged. If 

significant dilution is occurring and commonplace, 

internal monitoring limits may be warranted. 

A7-2 Asks how the plant demonstrates compliance 

with the current priority pollutant limits for 

cooling tower blowdown. 

EPA would use this information to evaluate the 

current effluent limitation and determine whether 

any changes to the limitation or implementation 

guidance are needed. 

Fuel Usage by Steam Electric Generating Unit 

A8-1 Requests information about the types and 

amount of fuels used in the steam electric 

generating unit during 2009 (including fuels 

used for start up). 

EPA would use this information to classify the 

units by the type of fuel used. Additionally, EPA 

would potentially use the amount of fuel as a 

normalizing factor for the costs and loads models, 

and possibly for production-normalized effluent 

limits. 
4-6 

Table 4-1. Steam Electric Power Plant Operations Question Justifications 

Question 

Number Question Description Purpose of Question 

A8-2 and 

A8-3 

Asks if the total BTUs generated by the 

fossil/nuclear fuels comprise 50 percent or 

more of the total BTUs generated by all fuels 

in 2009 for each steam electric generating 

unit. Also asks if a fossil or nuclear fuel was 

reported as the predominant or second most 

predominant energy source on Form EIA-860 

for each generating unit. 

EPA would use this information to identify 

whether a steam electric generating unit is a 

fossil/nuclear electric generating unit. Plants 

would not need to complete many questions 

throughout the questionnaire for units that are not

fossil/nuclear electric generating units. Plants that 

had no fossil/nuclear electric generating units 

would not be required to complete the remainder 

of the questionnaire. 

NOx Control Systems 

A9-1 Requests information about NOx control 

systems associated with steam electric 

generating units that the plant is currently 

operating, currently constructing/installing, or 

planning to construct/install by December 31, 

2020. 

EPA would use this information to update the 

industry profile. The operation of NOx control 

systems can impact the pollutant characteristics of

wastewater streams (e.g., fly ash transport water).

A9-2 Requests information about SCR catalysts 

sent off site for regeneration. 

EPA would use this information to identify 

companies to contact to determine how the SCR 

catalysts are regenerated and the wastewaters 

generated and the characteristics of the 

wastewater. 

A9-3 through 

A9-11 

Requests information about on-site SCR 

catalyst regeneration and catalyst washing, 

including any wastewater generated from the 

process, how the wastewater is handled, if any 

wastewater treatment techniques are used, and 

the destination(s) of the wastewater. 

EPA would use the information from these 

questions to identify trends in the industry and 

characterize the best management practices for the 

SCR catalyst regeneration wastewaters and 

catalyst washing wastewaters. EPA would also use 

the information to identify wastewater treatment 

systems being used to treat these wastewaters. 

Flue Gas Mercury Control Systems 

A10-1 and 

A10-2 

Requests information about operating and 

planned flue gas mercury control systems 

associated with steam electric generating 

units, including a description of the process 

operation and how waste streams are handled. 

EPA would use this information to update the 

industry profile and to determine if any 

wastewaters are generated that may warrant 

effluent limitations or if the process operations 

affect other wastewater streams that may warrant 

revisions to those wastewaters’ effluent limits. 

A10-3 and 

A10-5 

Asks whether the plant has participated in or 

plans to participate in a pilot study for a flue 

gas mercury control system(s). Additionally, 

if the pilot study evaluated wastewaters 

generated by the technology, EPA requests 

copies of the technical evaluation report. 

EPA would use this information to identify new 

technologies and processes that are or may be 

implemented and the wastewaters associated with 

the operation. 

Carbon Capture Systems 

A11-1 and 

A11-2 

Requests information about operating and 

planned carbon capture systems associated 

with steam electric generating units, including 

a description of the process operation. 

EPA would use this information to update the 

industry profile and to determine if any 

wastewaters are generated that may warrant 

effluent limitations or if the process operations 

affect other wastewater streams that may warrant 

revisions to those wastewaters’ effluent limits. 
4-7 

Table 4-1. Steam Electric Power Plant Operations Question Justifications 

Question 

Number Question Description Purpose of Question 

A11-3 and 

A11-4 

Asks whether the plant has participated in or 

plans to participate in a pilot study for a 

carbon capture system(s). Additionally, if the 

pilot study evaluated wastewaters generated 

by the technology, EPA requests copies of the 

technical evaluation report. 

EPA would use this information to identify new 

technologies and processes that are or may be 

implemented and the wastewaters associated with 

the operation. 

A11-5 and 

A11-6 

Asks for flow characteristics of the process 

wastewater generated from the carbon capture 

system. Also if characterization samples were 

collected during the study, requests the plant 

to provide analytical results for the carbon 

capture wastewater. 

EPA would use this information to help 

characterize process wastewaters generated by 

carbon capture systems and to determine if any 

wastewaters are generated that may warrant 

effluent limitations. 

Wet Electrostatic Precipitator Systems 

A12-1 Requests information about operating and 

planned wet electrostatic precipitator (ESP) 

systems associated with steam electric 

generating units, including the date of 

installation, the location of the wet ESP, 

whether it is a full-scale or pilot-scale system, 

and the percent of flue gas treated. 

EPA would use this information to update the 

industry profile and to determine if the wet ESP 

wastewaters may warrant effluent limitations. 

A12-2 Requests information about the flow rate, 

duration, and frequency of the wet ESP 

wastewater generated by the system 

EPA would use this information to identify the 

amount of wet ESP wastewater generated by the 

industry. 

A12-3 and 

A12-4 

Requests information about the water sources 

used for wet ESP wastewater and the criteria 

that the water must meet to be used as a 

source for wet ESP wastewater. 

The responses from these questions would help 

EPA identify potential water reuse options for 

power plants. 

A12-5 Asks plants to identify the destinations of the 

wet ESP wastewater. 

EPA would use the response from this question to 

update wastewater management practices 

associated with wet ESP operations. 

A12-6 

through 

A12-8 

Asks whether the plant has participated in a 

full- or pilot-scale study for a wet ESP 

system(s) in which the wastewaters generated 

were evaluated. If so, EPA requests 

information about the company and the time 

period of the study, as well as requesting 

copies of the technical evaluation report. Also 

if characterization samples were collected 

during the study, requests the plant to provide 

analytical results for the carbon capture 

wastewater. 

EPA would use this information to identify 

wastewater management practices associated with 

wet ESP operations, identify issues/problems 

encountered during their operation, and 

characterize the wet ESP wastewaters. EPA would 

use this information to determine if the wet ESP 

wastewaters warrant effluent limitations. 

Coal Storage and Processing

A13-1 Asks whether the plant stored or processed 

any coal during 2009. 

EPA would use this question to identify plants that

should complete this section of the questionnaire; 

plants that did not store or process coal during 

2009 would skip to the end of the section. 
4-8 

Table 4-1. Steam Electric Power Plant Operations Question Justifications 

Question 

Number Question Description Purpose of Question 

A13-2 

through 

A13-5 

Requests information about the generation, 

handling, and characteristics of coal pile 

runoff generated at the plant. 

EPA would use this information to characterize the 

coal pile runoff waste streams generated by the 

industry and to identify best management practices 

for handling the waste stream. 

A13-6 

through 

A13-7 

Requests information about the coal washing 

performed at the plant and how the coal wash 

waters are handled. 

EPA would use this information to characterize the 

coal wash water streams generated by the industry 

and determine if an effluent limitation may be 

warranted for the stream. Additionally, EPA 

would use the information to identify potential 

best management practices. 

A13-8 and 

A13-9 

Requests information about coal blending 

performed at the plant and whether there are 

wastewaters generated from the operation. 

EPA would use this information to determine 

whether coal blending operations generate 

wastewater streams. Additionally, EPA would use 

the information to identify the volume of coal 

blending wastewaters generated by the industry to 

determine if effluent limitations may be warranted.

A13-10 

through 

A13-15 

Requests information about whether the plant 

pulverizes coal on site and how the plant 

handles the mill rejects associated with the 

pulverization process. 

EPA would use this information to determine the 

amount of mill reject sluice generated by the 

industry to determine if effluent limitations may be 

warranted. Additionally, EPA would use the 

information to identify potential best management 

practices. 

A13-16 and 

A13-17 

Asks whether the plant gasified coal, 

petroleum coke, or oil to operate an IGCC 

generating unit and whether the plant 

operates, is constructing/installing, or plans to 

construct/install an IGCC unit. 

EPA would use this information to update the 

industry profile and evaluate the number of IGCC 

units currently operating and that will be operated

in the future. EPA would use this information in 

developing effluent limitations. 

Part B: Flue Gas Desulfurization (FGD) Systems 

Part B collects information on wastewater generated and treated from flue gas 

desulfurization. 
4-9 

Table 4-2. FGD System Question Justifications 

Question 

Number Question Description Purpose of Question 

General FGD System Information 

B1-1 Asks if the plant operates one or more FGD 

systems or if the plant is currently 

constructing/installing or planning to begin 

constructing at least one FGD system. 

EPA would use this question to identify plants that

should complete this FGD part of the questionnaire;

plants that do not operate or plan to operate a FGD

system would not complete Part B of the 

questionnaire. 

B1-2 Requests the plant to include the date the 

system initially began operation or is 

planned to begin operation, identify the 

steam electric units that exhaust to the FGD 

system, the type of FGD system and sorbent 

used, whether the system generates a slurry 

blowdown stream, and the SO2 removal 

efficiency. 

Plants will fill out information for both FGD 

systems operated in 2009 and planned FGD 

systems. EPA would use this information to link 

the generating unit(s) and its specific characteristics 

to the associated FGD system. In addition, EPA 

would use the information to characterize FGD 

operations and to update the industry profile, and as 

an input to models used to predict the costs 

associated with FGD wastewater treatment. 

Planned FGD System Information 

B2-1 Requests the plant to identify the method for 

handling solids generated, whether a purge 

stream will be generated, the type of 

wastewater treatment system planned, the 

design maximum and 24-hour daily average 

flow rate for the treatment system, and the 

date the treatment system will be brought on 

line for FGD systems that are planned or 

under construction/installation. 

EPA would use the information to update the future 

industry profile. EPA would use this information to

estimate how the industry is expected to change and

to estimate the industry-level loadings associated 

with FGD wastewater discharges and costs 

associated with treatment of FGD wastewaters. 

EPA will use this information to estimate the 

treatment systems planned in the future for use in 

industry cost analysis. The type of wastewater 

treatment and design flow rate will be used to 

predict the industry-wide cost of wastewater 

treatment in the future industry profile, as well as 

develop reasonable projections of pollutant 

reductions. 

FGD Additive Information 

B3-1 Asks the plant for information about the 

additive(s) used or planned to be used in 

each FGD system. 

EPA would use the type of additive used in each 

FGD system to characterize wet FGD operations 

and to update the industry profile. EPA would also 

relate the type of additive to the characteristics of 

the FGD wastewater. 

Wet FGD System Information

B4-1 Asks if the plant reported use of a FGD 

system that generates a slurry blowdown 

stream (i.e., wet system). 

Plants that do not operate a wet FGD system will 

not complete Part B, Sections 4 through 7, of the 

questionnaire 

B4-2 and B4-3 Asks the plant to provide the operating 

concentration range of chlorides within the 

FGD scrubber absorber and the maximum 

design chlorides concentration for the FGD 

system and indicate which equipment unit(s) 

of the FGD system determines this 

concentration and the materials of 

construction for the equipment unit(s). 

EPA would use this information to relate the 

chlorides concentration in the FGD system to the 

materials of construction for the FGD scrubber 

absorber and the volume of FGD scrubber purge 

generation (asked in later questions). This 

information would be used to help EPA establish 

trends and predict wastewater generation and 

characteristics for planned wet FGD systems (i.e., 

not currently operating). 
4-10 

Table 4-2. FGD System Question Justifications 

Question 

Number Question Description Purpose of Question 

B4-4 and B4-5 Asks the plant to provide the FGD system 

parameters used to control the FGD slurry 

blowdown from the FGD system and 

indicate the maximum chlorides 

concentration and maximum solids 

percentage that is acceptable for the water 

used as a source of FGD reagent preparation 

water or absorber make-up water to be used 

for those purposes. 

The responses from these questions would help 

EPA identify potential water reuse options for 

power plants. Plants may increase or decrease the 

FGD blowdown flow rate for a variety of reasons. 

Additionally, the flow rates of the blowdown and 

blowdown recycle are related to the flow rate of 

water sent to wastewater treatment. These questions

will help EPA understand the reasons plants chose 

to increase or decrease the blowdown rate and may 

help EPA establish trends and predict wastewater 

generation for plants that may install FGD units. 

B4-6 through 

B4-12 

Asks the plant to provide the flow rates, 

durations, frequencies, and sources of the 

mist eliminator wash water used for the 

FGD system, the absorber make-up water, 

the FGD reagent preparation water, and the 

FGD reagent slurry. 

The responses from these questions would help 

EPA identify potential water reuse options for 

power plants. 

B4-13 

through 

B4-17 

Asks information about the solids generated 

from the FGD scrubber system including the 

types of solids that are generated, the 

percentage of FGD solids within the system, 

if the solids are combined with other 

materials, whether a cementitious/pozzolanic 

material is generated, the methods of solids 

separation, and the methods of solids 

dewatering used by the plant. 

EPA would use the responses from these questions 

to identify trends in the industry. The type of solid 

byproducts produced in a wet FGD system dictate 

the types of wastewaters generated and the ultimate

destination of the solids. Additionally, EPA must 

identify how the solids are separated and dewatered

separately because the methods of separation and 

dewatering range from settling ponds to 

combinations of more advanced mechanical 

separation technologies (e.g., hydrocyclones, 

vacuum belt filters). 

B4-18 

through 

B4-22 

Requests information on FGD solids 

disposition, FGD solids marketed/sold, and 

the costs incurred to remove or dispose of 

FGD solids for the calendar years 2005, 

2007, and 2009, the typical maximum and 

minimum chlorides concentration for the 

FGD solids, and the parameters that affect 

the ability of the FGD solids to be marketed, 

sold and/or given away. 

EPA would use the responses from these questions 

to develop industry-wide estimates for FGD solids 

disposal and marketing. The responses to these 

questions would be used by EPA to develop a cost 

model that incorporates the cost for disposal of 

particular types of FGD solids and to predict the 

operations for plants with planned wet FGD 

systems. As a part of this cost model, EPA requests

information on the amount of revenue generated by 

the selling of FGD solids to incorporate into the 

cost model. 
4-11 

Table 4-2. FGD System Question Justifications 

Question 

Number Question Description Purpose of Question 

FGD Wastewater Generation

B5-1 and B5-2 Requests the source(s) and percent 

contributions of FGD reagent preparation 

water, absorber make-up water, and the mist 

eliminator wash water, the absorber type, the 

typical FGD slurry blowdown flow rate 

exiting the absorber, the typical range of 

percent solids of FGD slurry blowdown 

exiting the absorber, the typical amount of 

solids separation recycle returned to the 

absorber, the typical amount of scrubber 

purge sent to wastewater treatment or 

discharge, and the typical duration and 

frequency of scrubber purge generation. 

The information in these tables would be used to 

help EPA establish trends and predict wastewater 

generation and characteristics for planned wet FGD 

systems (i.e., not currently operating). The 

responses will also be used to develop a cost model

to predict the costs associated with required FGD 

wastewater treatment based on specific operating 

characteristics The information in this table will 

allow EPA to determine the percent solids of the 

blowdown and the flow rates of the blowdown, 

recycle, and purge streams. EPA will relate these 

factors to characteristics of each wet FGD system 

(i.e. sorbent, coal chlorine content, etc.). 

Additionally, EPA will use this information to 

project purge flow rates and treatment systems 

costs for plants that do not currently have wet FGD

systems. EPA will use this information in cost 

models and for estimating pollutant reductions. 

B5-3 Asks the plant to provide chlorides and 

solids concentrations of the untreated FGD 

purge stream transferred to the wastewater 

treatment system. 

The response to this question would be used to help

EPA establish trends and predict wastewater 

generation and characteristics for wet FGD 

systems. The chlorides and solids concentrations 

are two factors that affect blowdown and purge 

flow rates and affect wastewater treatment system 

design. EPA will use these concentrations to 

develop a complete mass balance of solids and 

chlorides within the FGD system. 

FGD Monitoring Data 

B6-1 and B6-2 Asks the plant to provide monitoring data 

collected for the untreated FGD purge 

stream in an electronic format and to 

identify the FGD systems and steam electric 

generating units associated with the 

monitoring data provided. 

EPA would use the monitoring data collected from 

this question to characterize the FGD scrubber 

purge stream (including determining a range of 

pollutant concentrations and evaluating variability

in the FGD scrubber purge stream) and evaluate 

treatability of the FGD scrubber purge stream. EPA 

would use the FGD systems and steam electric 

generating units associated with the monitoring 

data to determine how FGD system and steam 

electric process operations impact the 

characteristics of the FGD scrubber purge. 
4-12 

Table 4-2. FGD System Question Justifications 

Question 

Number Question Description Purpose of Question 

FGD Wastewater Treatment 

B7-1 through 

B7-3 

Asks if the plant transfers the FGD scrubber 

purge to a settling pond. If it does, the plant 

is asked to indicate which process 

wastewaters are commingled with the FGD 

scrubber purge in the settling pond and to 

select an option that best describes the 

configuration of the ponds. 

EPA would use the responses from these questions 

to update the industry profile, which would be used

to estimate industry-level loadings associated with

FGD wastewater discharges and costs to comply 

with any regulations. EPA needs to identify plants 

that use ponds to treat the FGD wastewater 

independent of other wastewater treatment 

technologies. Some plants combine the FGD 

wastewater with other process wastewaters during 

treatment. Question B7-2 will allow EPA to select 

and analyze all plants that operate a single FGD 

treatment system, or combinations of FGD 

treatment systems. 

B7-4 and B7-5 Asks plants to indicate the wastewater 

treatment technologies used to treat the FGD 

scrubber purge and to identify the ultimate 

destination of the treated FGD scrubber 

purge. 

EPA would use the responses from these questions 

to update the industry profile, which would be used

to estimate industry-level loadings associated with

FGD wastewater discharges and costs to comply 

with any regulations. Question B7-4 is necessary to

determine the possible combinations of wastewater 

treatment technologies used to treat FGD scrubber 

purge. Question B7-5 is necessary to determine the 

ultimate destination of FGD wastewaters after 

treatment. EPA will use these questions to develop 

industry-wide trends. 

B7-6 and B7-7 Asks plants that produce gypsum from wet 

FGD systems to identify if gypsum-related 

waters are generated and, if so, asks the 

average volume of the gypsum-related 

waters generated per day. Also asks the 

plants to indicate how the gypsum-related 

waters are handled. 

EPA would use the responses from these questions 

to establish trends and predict wastewater 

generation and characteristics for planned wet FGD 

systems. Plants may temporarily store gypsum 

and/or wash the gypsum prior to hauling off site. 

This question is necessary to collect information on 

gypsum wash water and gypsum pile runoff, which 

may contain chlorides and other pollutants present 

in the gypsum material. 

Dry FGD System Information

B8-1 Asks if the plant reported use of a dry FGD 

system. 

Plants that do not operate a dry FGD system will 

not complete Part B, Section 8 of the questionnaire. 

B8-2 and B8-3 Asks the plant to indicate how the FGD solid 

is removed from the flue gas and if the FGD 

system is located upstream or downstream of 

the fly ash collection system. 

EPA would use the responses from these questions 

to assess whether fly ash would be marketable. 

B8-4 through 

B8-6 

Asks the plant to provide information about 

FGD reagent preparation water. 

The response from this question would help EPA 

identify potential water reuse options for power 

plants. 
4-13 

Table 4-2. FGD System Question Justifications 

Question 

Number Question Description Purpose of Question 

B8-7 through 

B8-10 

Asks the plant to indicate if any FGD 

wastewaters are generated from the 

operation of the dry FGD scrubber, identify 

the ultimate destination of the FGD 

wastewater, indicate if any FGD 

wastewaters are generated from cleaning the 

dry FGD scrubber, and identify the ultimate 

destination of the FGD wastewater for 

cleaning. 

EPA would use the responses to these questions to 

identify wastewater generation and management 

practices associated with dry FGD operations. 

These questions ask the plant to identify any 

potential wastewaters associated with dry scrubber 

operation and the destination of those wastewaters.

Although EPA does not anticipate that there is 

much wastewater generated from dry FGD systems, 

this will provide EPA with a definitive answer. 

B8-11 

through 

B8-14 

Requests information on FGD solids 

disposition, FGD solids marketed/sold, and 

total costs incurred to remove or dispose of 

FGD solids for calendar years 2005, 2007, 

and 2009. Also asks what parameters affect 

the ability of the FGD solids to be marketed, 

sold and/or given away. 

EPA would use the responses from these questions 

to identify trends in the industry and develop 

industry-wide estimates for FGD solids disposal 

and marketing associated with dry FGD systems. 

The responses to these questions will also be used 

by EPA to develop a cost model for estimating the 

costs of converting from a wet FGD system to a dry 

system. EPA needs to develop industry-wide 

estimates for how much solids are sold and 

disposed of in landfills. Also, knowing whether the

sold material is landfilled permanently or 

temporarily will help identify which plants may 

need to install runoff/leachate controls within the

landfills. 

Part C: Ash Handling 

Part C collects information on wastewater generated and treated from the handling of ash 

from coal-, petroleum coke-, or oil-fired generating units. 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

Ash Handling Systems 

C1-1 Asks if the plant generates ash in any of its 

steam electric generating units. 

Plants that do not generate ash in any of their steam 

electric generating units do not need to complete 

Part C. 

C1-2 Asks the plant for total acreage of the plant. 

Question also requests acreage for specific 

area categories at the plant. 

EPA will use this information to determine the total 

acreage of the plant, along with developed and 

undeveloped areas. 

Fly Ash Handling – System Level Information 

C2-1 Asks if the plant generates fly ash in any of 

its steam electric generating units. 

Plants that do not generate fly ash in any of their

steam electric generating units do not need to 

complete the remainder of Part C, Section 2. 
4-14 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

C2-2 Requests that plants identify all fly ash 

handling systems located at the plant. For 

each handling system identified, plants are 

asked to provide the type of fly ash 

collection system, amount of fly ash 

produced, the design handling rate, and the 

loss on ignition and class of fly ash. 

EPA will use this information to update the 

industry profile. Specifically, this question 

identifies the number of wet and dry fly ash 

handling systems in the industry (for all coal-fired 

and a subset of oil-fired generating units), which 

EPA would use to estimate compliance costs for 

potential regulatory options and to estimate 

pollutant reductions. 

Fly Ash Handling – Unit Level information 

C2-3 Requests information on all fly ash handling 

systems that service each steam electric 

generating unit at the plant, including the 

percentage of ash that is handled by each 

defined system and the number of days that 

ash was handled. 

Informs EPA of the number of fly ash handling 

systems currently operated. This information also 

develops fly ash handling system profiles for the 

industry. This information can help EPA identify 

wastewaters that are generated. 

C2-4 through 

C2-7 

Questions request information regarding wet 

and dry systems that service ash from one 

unit, the reasons why multiple fly ash 

handling systems are necessary, the 

modifications that would be required to 

convert to a completely dry fly ash handling 

system, and changes in fly ash handling 

operations. 

EPA will use this information to determine the 

reasons and/or challenges associated with 

converting from a wet to dry fly ash handling 

system. 

Fly Ash Handling Information

C2-8 and 

C2-10 

Questions ask for the type of dry fly ash 

handling system, any unscheduled boiler 

outages caused by the system between 2005 

and 2009, length of outages, reasons for the 

outages and methods used to resolve the 

outages. 

This information informs EPA of additional costs, 

beyond capital/operating costs, associated with a 

conversion from wet to dry fly ash handling. 

C2-11 and 

C2-12 

Asks whether dry fly ash handling system 

was installed with the generating unit or was 

a retrofit, requests shutdown time for 

retrofits, and whether the retrofit was 

completed during a regularly scheduled 

outage. 

Informs EPA of additional cost, beyond 

capital/operating costs, associated with conversion

to dry fly ash handling. 

C2-13 

through 

C2-15 

Requests if the retrofit was made to an 

existing dry system or if it was a conversion 

from wet to dry. Also requests the reasons 

for the retrofit from a wet to dry system or 

changes to an existing dry system and the 

changes required for the retrofit. 

EPA would use this information to assess/predict 

the number of plants/generating units that may 

convert to dry fly ash handling, apart from a 

potential EPA requirement. Also allows better 

understanding of conversion costs. 

Dry Fly Ash Handling Information 

C2-16 Requests dry fly ash transport/storage 

information including type of destination, 

distance and amount transported, the method 

of transportation, and percent moisture of 

the fly ash. 

EPA would use this information to compare 

operating costs obtained for dry fly ash handling 

systems. 
4-15 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

C2-17 Asks if they dry fly ash is combined with 

FGD solids to form a pozzolanic material. 

EPA would use this information to understand all 

possible destinations of dry fly ash. 

C2-18 and 

C2-19 

Asks if and to which destinations the dry fly 

ash was marketed in 2005, 2007, and 2009, 

and the gross revenue generated. Also 

requests the typical percent moisture of the 

fly ash marketed. 

Informs EPA of potential revenue that would offset 

dry fly ash handling system costs. 

C2-20 Requests the highest LOI at which fly ash 

can be marketed. 

EPA would use this information to assess/predict 

the number of plants that could market their fly ash.

C2-21 

through C2-

23 

Requests the source of water used to moisten 

ash and the criteria plant uses to determine if 

a water source is acceptable or unacceptable 

for that purpose. 

Identifies potential water reuse options for power 

plants. 

Wet Fly Ash Handling Information 

C2-24 Requests the fly ash sluice flow rate, 

duration and frequency of sluicing, sources 

of sluice water, and percent contribution of 

source to sluice water flow for each coal- or 

oil-fired generating unit in 2009. 

Informs EPA of amount of fly ash wastewater 

generated (sluice flow rate and frequency), which 

EPA would use in consideration of technology 

options, and identifies potential water reuse options 

for power plants. 

C2-25 and 

C2-26 

Requests the distance between hoppers and 

dry to wet mixing junction, number of 

junctions, destinations of wet fly ash, and 

distance between wet-to-dry junction and 

ash pond or other final destination. 

Informs EPA of the equipment needed to convert 

systems to dry fly ash handling. 

C2-27 and 

C2-28 

Requests criteria plant uses to determine if a 

water source is acceptable or unacceptable 

for use as fly ash sluice water. 

Identifies potential water reuse options for power 

plants. 

C2-29 and 

C2-30 

Asks if the plant has had any unscheduled 

boiler outages due to the wet fly ash 

handling system between 2005 and 2009, 

length of outages, reasons for outages, and 

methods used to resolve outages. 

This information informs EPA of additional costs, 

beyond capital/operating costs, associated with wet

fly ash handling. 

C2-31 

through 

C2-34 

Asks about installation of dry fly ash 

handling systems, the modifications 

required, the planned destinations for the fly 

ash, and if and to which destinations the 

plant plans to sell the dry fly ash. 

Better informs EPA of the number of 

plants/generating units that may install dry fly ash 

handling systems, apart from a potential EPA 

requirement, and the potential costs for 

conversion/installation. 

C2-35 Asks if and to which destinations wet fly ash 

was marketed in 2005, 2007, and 2009, and 

the gross revenue generated. Also requests 

the typical percent moisture of the fly ash 

marketed. 

Informs EPA of potential revenue that would offset 

wet fly ash handling system costs, especially 

compared to dry fly ash potential revenue. 

C2-36 Question asks plants that are currently not 

installing or planning to install dry fly ash 

handling systems whether 

installation/conversion has ever been 

considered and requests associated 

documentation/costs. 

Informs EPA of the potential costs of 

conversion/installation for plants are currently not 

installing or planning to install dry fly ash handling 

systems. 
4-16 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

 Fly Ash Handling Cost Information 

C2-37 Asks plants to identify all major components 

of the fly ash conveyance system. 

This information will help EPA appropriately 

develop compliance costs and understand variations 

in costs from different ash handling systems. 

C2-38 Requests a block diagram that shows the fly 

ash handling system. 

EPA would use the block diagram to verify, 

interpret, and clarify the information provided in 

Question C2-33. 

C2-39 and 

C2-40 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of the fly ash conveyance system. 

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 

C2-41 and 

C2-42 

Requests operation and maintenance (O&M) 

costs for fly ash handling systems operated 

in 2009, and capital costs for fly ash 

conveyance system. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

conveyance portion of a new fly ash handling 

systems. 

C2-43 Asks about intermediate storage for ash. Determines if respondents need to answer the 

remainder of Part C, Section 2.6. 

C2-44 

through 

C2-46 

Asks whether and with which ash handling 

systems the fly ash handling system shares 

intermediate storage components, which 

components are shared, if a 

pond/impoundment is the intermediate 

storage or final destination of the fly ash 

collected, and whether the plant has already 

provided cost information for the 

intermediate storage portion of the fly ash 

handling system and if so, the amount of 

shared costs. 

Determines if respondents need to answer the 

remainder of Part C, Section 2.6. Also informs EPA 

of how components/costs are shared between 

multiple ash handling systems. 

C2-47 Asks plants to identify all major components 

of the fly ash intermediate storage system. 

This information will help EPA appropriately 

develop compliance costs and compare costs from 

different ash handling systems. 

C2-48 and 

C2-49 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of the fly ash intermediate storage 

system. 

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 

C2-50 and 

C2-51 

Requests operation and maintenance (O&M) 

costs for fly ash handling systems operated 

in 2009, and capital costs for the 

intermediate storage portion of the fly ash 

handling system. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

intermediate storage portion of a new fly ash 

handling systems. 

C2-52 

through 

C2-54 

Asks whether and with which ash handling 

systems the fly ash handling system shares 

transport/disposal components, which 

components are shared, if a 

pond/impoundment is the final destination of 

the fly ash collected, whether the plant has 

already provided cost information for the 

transport/disposal portion of the fly ash 

handling system and if so, the amount of 

shared costs. 

Determines if respondents need to answer the 

remainder of Part C, Section 2.7. Also informs EPA 

of how components/costs are shared between 

multiple ash handling systems. 
4-17 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

C2-55 Asks about the methods used to transport the 

ash to the final destination. 

Determines the different transport options the 

industry is utilizing for fly ash. EPA will also use 

this information to relate capital and O&M costs to

different transport/disposal processes. 

C2-56 and 

C2-57 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of fly ash transport/disposal. 

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 

C2-58 and 

C2-59 

Requests operation and maintenance (O&M) 

costs for fly ash handling systems operated 

in 2009, and capital costs for fly ash 

transport/disposal. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

transport/disposal portion of a new fly ash handling 

systems. 

Bottom Ash Handling – System Level Information 

C3-1 Asks if the plant generates bottom ash in any 

of its steam electric generating units. 

Plants that do not generate bottom ash in any of 

their steam electric generating units do not need to 

complete the remainder of Part C, Section 3. 

C3-2 Requests that plants identify all bottom ash 

handling systems located at the plant. For 

each handling system identified, plants are 

asked to provide the type of boiler, amount 

of bottom ash produced, typical percent 

moisture of the bottom ash, the design 

handling rate, the loss on ignition for bottom 

ash produced, and the class of bottom ash. 

EPA will use this information to update the 

industry profile. Specifically, this question 

identifies the number of wet and dry bottom ash 

handling systems in the industry (for all coal-fired 

and a subset of oil-fired generating units), which 

EPA would use to estimate compliance costs for 

potential regulatory options and to estimate 

pollutant reductions. 

Bottom Ash Handling Information 

C3-3 and 

C3-4 

Requests information on the type of boiler 

used and the bottom ash handling systems 

that service each steam electric generating 

unit, including the percentage of ash that is 

handled by each system, and the number of 

days that ash was handled. 

Informs EPA of the number of bottom ash handling 

systems currently operated. This information will 

also help develop a bottom ash handling system 

profile of the industry. This information can help 

EPA identify wastewaters that are generated. 

C3-5 through 

C3-8 

Questions request information regarding wet 

and dry systems that service ash from one 

unit, the reasons why multiple bottom ash 

handling systems are necessary, the 

modifications that would be required to 

convert to a completely dry bottom ash 

handling system, and changes in bottom ash 

handling operations. 

EPA will use this information to determine the 

reasons and/or challenges associate with converting

from a wet to dry bottom ash handling system. 

Dry Bottom Ash Handling Information

C3-9 Asks if the plant operates a mechanical drag 

system. 

EPA would use this information to compare costs 

obtained for dry bottom ash handling 

systems/conversions. 

C3-10 and 

C3-11 

Asks if the plant has had any unscheduled 

boiler outages due to the dry bottom ash 

handling system between 2005 and 2009, 

length of outages, reasons for outages, and 

methods used to resolve outages. 

This information informs EPA of additional costs, 

beyond capital/operating costs, associated with a 

conversion from wet to dry bottom ash handling. 
4-18 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

C3-12 Asks whether dry bottom ash handling 

system was installed with the generating unit 

or was a retrofit, requests shutdown time for 

retrofits, and whether the retrofit was 

completed during a regularly scheduled 

outage. 

Informs EPA of additional cost, beyond 

capital/operating costs, associated with conversion

to dry bottom ash handling 

C3-13 

through 

C3-16 

Asks whether the retrofit was to an existing 

dry bottom ash handling system or a 

conversion from wet to dry. Requests the 

reasons for the retrofit from the wet to dry 

system or changes to an existing dry system. 

Also requests the changes required for the 

retrofit. 

EPA would use this information to assess/predict 

the number of plants/generating units that may 

convert to dry bottom ash handling, apart from a 

potential EPA requirement. Also allows better 

comparison of conversion costs received.

C3-17 Requests engineering process diagrams for 

the retrofit. 

Informs EPA of factors potentially impacting the 

feasibility of future dry bottom ash handling 

retrofits and options for addressing the factors. 

C3-18 Requests dry bottom ash transport/storage 

information, including destination, distance 

and amount transported, method of 

transportation, and percent moisture of 

bottom ash. 

EPA would use this information to compare 

operating costs obtained for dry bottom ash 

handling systems. 

C3-19 and 

C3-20 

Asks if and to which industries the dry 

bottom ash was marketed in 2005, 2007, and 

2009, and the gross revenue generated. 

Informs EPA of potential revenue that would offset 

dry bottom ash handling system costs. 

Wet Bottom Ash Handling Information 

C3-21 and 

C3-25 

Requests bottom ash sluice flow rate, 

duration and frequency of sluicing, sources 

of sluice water, and percent contribution of 

source to sluice water flow, and the 

destination of the sluice water for each coalor oil-fired generating unit in 2009. 

Informs EPA of amount of bottom ash wastewater 

generated (sluice flow rate and frequency), which 

EPA would use in consideration of technology 

options, and identifies potential water reuse options 

for power plants. 

C3-22 and 

C3-23 

Requests criteria plant uses to determine if a 

water source is acceptable or unacceptable 

for use as bottom ash sluice water. 

Identifies potential water reuse options for power 

plants. 

C3-24 and 

C3-26 

Requests solids removal information for the 

wet ash sluice system, including the type of 

solids removal, the type of solid waste 

disposal, and the amount and percent 

moisture of ash disposed.. 

Identifies the number of wet bottom ash handling 

systems in the industry that are able to use methods 

other than ash ponds to remove ash solids and how 

effective the methods are. EPA would use this 

information for evaluation of potential technology 

options for bottom ash handling. 

C3-27 and 

C3-28 

Requests the amount of wastewater overflow 

from solids removal, amount of wastewater 

re-used, and a description of how/where the 

water is re-used. 

Informs EPA of possible effectiveness of these 

solids removal methods as technology options, and 

identifies potential water reuse options for power 

plants. 

C3-29 and 

C3-30 

Asks if the wet bottom ash handling system 

caused any unscheduled boiler outages 

between 2005 and 2009, length of outages, 

reasons for outages, and methods used to 

resolve outages. 

This information informs EPA of additional costs, 

beyond capital/operating costs, associated with wet

bottom ash handling. 
4-19 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

C3-31 

through 

C3-34 

Asks about installation of dry bottom ash 

handling systems, the modifications 

required, the planned destinations for the 

bottom ash, and if and to which destinations 

the plant plans to sell the dry bottom ash. 

Better informs EPA of the number of 

plants/generating units that may install dry bottom

ash handling systems, and the potential costs for 

installing dry bottom ash handling systems. 

C3-35 Asks if and to which destinations wet 

bottom ash was marketed in 2005, 2007, and 

2009, and the gross revenue generated. Also 

requests the typical percent moisture of the 

bottom ash marketed. 

Informs EPA of potential revenue that would offset 

wet bottom ash handling system costs. 

C3-36 Question asks plants that are currently not 

installing or planning to install dry bottom 

ash handling systems whether 

installation/conversion has ever been 

considered and requests associated 

documentation/costs. 

Informs EPA of the potential costs of 

conversion/installation for plants are currently not 

installing or planning to install dry bottom ash 

handling systems. 

Bottom Ash Handling Cost Information 

C3-37 Asks plants to identify all major components 

of the bottom ash conveyance system. 

This information will help EPA appropriately 

develop compliance costs and understand variations 

in costs from different ash handling systems in the

industry. 

C3-38 Requests a block diagram that shows the 

bottom ash handling system. 

EPA would use the block diagram to verify, 

interpret, and clarify the information provided in 

Question C3-33. 

C3-39 and 

C3-40 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of the bottom ash conveyance system.

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 

C3-41 and 

C3-42 

Requests operation and maintenance (O&M) 

costs for bottom ash handling systems 

operated in 2009, and capital costs for 

bottom ash conveyance handling systems. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

conveyance portion of a new bottom ash handling 

systems. 

C3-43 Asks about intermediate storage for ash. Determines if respondents need to answer the 

remainder of Part C, Section 3.6 

C3-44 

through 

C3-46 

Asks whether and with which ash handling 

systems the bottom ash handling system 

shares intermediate storage components, 

which components are shared, if a 

pond/impoundment is the intermediate 

storage or final destination of the bottom ash 

collected, and whether the plant has already 

provided cost information for the 

intermediate storage portion of the bottom 

ash handling system and if so, the amount of 

shared costs. 

Determines if respondents need to answer the 

remainder of Part C, Section 3.6. Also informs EPA 

of how components/costs are shared between 

multiple ash handling systems. 

C3-47 Asks plants to identify all major components 

of the bottom ash intermediate storage 

system. 

This information will help EPA appropriately 

develop compliance costs and compare costs from 

different ash handling systems. 
4-20 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

C3-48 and 

C3-49 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of the bottom ash intermediate 

storage system. 

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 

C3-50 and 

C3-51 

Requests operation and maintenance (O&M) 

costs for bottom ash handling systems 

operated in 2009, and capital costs for 

bottom ash intermediate storage. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

intermediate storage portion of a new bottom ash 

handling systems. 

C3-52 

through 

C3-54 

Asks whether and with which ash handling 

systems the bottom ash handling system 

shares transport/disposal components, which 

components are shared, if a 

pond/impoundment is the final destination of 

the bottom ash collected, whether the plant 

has already provided cost information for the 

transport/disposal portion of the bottom ash 

handling system and if so, the amount of 

shared costs. 

Determines if respondents need to answer the 

remainder of Part C, Section 2.7. Also informs EPA 

of how components/costs are shared between 

multiple ash handling systems. 

C3-55 Asks about the methods used to transport the 

ash to the final destination. 

Determines the different transport options the 

industry is utilizing for bottom ash. EPA will also

use this information to relate capital and O&M 

costs to different transport/disposal processes. 

C3-56 and 

C3-57 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of bottom ash transport/disposal. 

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 

C3-58 and 

C3-59 

Requests operation and maintenance (O&M) 

costs for bottom ash handling systems 

operated in 2009, and capital costs for 

bottom ash transport/disposal. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

transport/disposal portion of a new bottom ash 

handling systems. 

Combined Fly Ash and Bottom Ash Handling Cost Information

C4-1 Asks whether any fly ash and bottom ash 

handling systems share intermediate storage 

or transport/disposal components. 

Determines if respondents need to answer the 

remainder of Part C, Section 4. 

C4-2 Requests plants to identify which ash 

handling systems share intermediate storage 

or transport/disposal components. 

Informs EPA of which ash handling systems share 

costs. 

C4-3 and 

C4-4 

Asks whether any fly ash and bottom ash 

handling systems share intermediate storage 

components, which components are shared, 

and , if a pond/impoundment is the 

intermediate storage or final destination of 

the combined ash. 

Determines if respondents need to answer the 

remainder of Part C, Section 4.2. Also informs EPA 

of how components/costs are shared between fly 

ash and bottom ash handling systems 

C4-5 Asks plants to identify all major components 

of the combined fly ash and bottom ash 

intermediate storage system. 

This information will help EPA appropriately 

develop compliance costs and compare costs from 

different ash handling systems. 

C4-6 and 

C4-7 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of the combined fly ash and bottom 

ash intermediate storage system. 

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 
4-21 

Table 4-3. Ash Handling Question Justifications 

Question 

Number Question Description Purpose of Question 

C4-8 and 

C4-9 

Requests operation and maintenance (O&M) 

costs for the combined fly ash and bottom 

ash handling systems operated in 2009, and 

capital costs for combined fly ash and 

bottom ash intermediate storage. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

intermediate storage portion of a new combined fly 

ash and bottom ash handling systems. 

C4-10 and 

C4-11 

Asks whether any fly ash and bottom ash 

handling systems share transport/disposal 

components, which components are shared, 

and , if a pond/impoundment is the final 

destination of the combined ash. 

Determines if respondents need to answer the 

remainder of Part C, Section 4.3. Also informs EPA 

of how components/costs are shared between fly 

ash and bottom ash handling systems 

C4-12 Asks about the methods used to transport the 

ash to the final destination. 

Determines the different transport options the 

industry is utilizing for combined fly ash and 

bottom ash. EPA will also use this information to 

relate capital and O&M costs to different 

transport/disposal processes. 

C4-13 and 

C4-14 

Asks if a contractor was hired to 

install/construct or operate/maintain any 

aspect of combined fly ash and bottom ash 

transport/disposal. 

Informs EPA of any costs that need to be adjusted 

based on the involvement of a contractor. 

C4-15 and 

C4-16 

Requests operation and maintenance (O&M) 

costs for combined fly ash and bottom ash 

handling systems operated in 2009, and 

capital costs for combined fly ash and 

bottom ash transport/disposal. 

EPA would use this cost information to estimate 

compliance costs for the industry to install the 

transport/disposal portion of a new combined fly 

ash and bottom ash handling systems. 

Economizer Ash Handling Information (steam electric generating unit level) 

C5-1 Asks whether economizer and air heater ash 

are handled together. 

Determines if respondents need to answer any of 

Part C, Section 6. 

C5-2 through 

C5-6 

Requests amount and destination of 

economizer ash produced, the type of 

economizer ash handling system, whether 

economizer ash wastewater is generated, and 

the amount and destination of the 

wastewater. 

Informs EPA of the amount of economizer ash 

handled in a wet fashion and whether dry 

economizer ash handling should be considered as a 

potential control technology (or other alternatives). 

Air heater Ash Handling Information 

C6-1 through 

C6-5 

Requests amount and destination of air 

heater ash produced, the type of air heater 

ash handling system, whether air heater ash 

wastewater is generated, and the amount and 

destination of the wastewater. 

Informs EPA of the amount of air heater ash 

handled in a wet fashion and whether dry handling 

should be considered as a potential control 

technology (or other alternatives). 

Part D: Pond/Impoundment Systems and Other Wastewater Treatment Operations 

Part D collects information on pond systems and other wastewater treatment operations. 
4-22 

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations 

Question Justifications 

Question 

Number Question Description Purpose of Question 

D1-1 and 

D1-2 

Asks about the use of ponds/impoundments 

for the storage, treatment, and/or disposal of 

residues or by-products from the combustion 

of coal, petroleum coke, or oil; and 

wastewater treatment systems for ash 

handling or FGD process wastewaters. 

These questions determine if respondents should 

answer any sections regarding Part D. Respondents 

that reply “No” to both of these questions are not 

required to complete Part D. 

Pond/Impoundment System and Wastewater Treatment System Identification 

D2-1 through 

D2-4 

Asks about wastewater treatment pilot 

studies and whether the studies are ongoing. 

Additionally, requests reports from the pilot 

and full-scale studies, a description of the 

studies, and a list of any FGD wastewater 

treatment technologies explored by the plant, 

not covered in the pilot or full-scale request. 

EPA will use the information to identify the types 

of wastewater treatment systems that are being 

investigated by the industry. Additionally, pilot 

study reports will help EPA understand the reasons 

why a technology option may or may not be 

feasible for plants with similar characteristics. 

D2-5 Asks about operation of pond/impoundment 

systems and/or wastewater treatment 

systems for the treatment of process waters 

from ash handling or FGD operations. 

This question determines if it is necessary for 

respondents to complete the remainder of Section 2 

and Section 3. 

D2-6 Identifies pond systems located (or planned 

to be located) at the plant for the treatment 

of wastewaters from ash handling or FGD 

operations. Identifies which 

pond/impoundment units are included in 

each pond system. 

EPA would use the information collected from this 

question to identify pond systems operated or 

planned to be operated by the plant. The question 

assigns system IDs which will be used to identify 

the systems in later questions. EPA would also use 

this information to link the pond/impoundment 

unit(s) and its specific characteristics (identified in 

Part A) to the pond system. 

D2-7 Identifies wastewater treatment systems 

(other than pond systems) that the plant 

operates or plans to operate for the treatment 

of wastewaters from ash handling or FGD 

operations. 

EPA would use the information collected from this 

question to identify wastewater treatment systems 

(other than pond systems) operated or planned to be

operated by the plant. The question assigns system 

IDs which will be used to identify the systems in 

later questions. 

Wastewater Treatment Diagram and Wastewater Flows (wastewater treatment system level) 

D3-1 Requests block diagrams for each pond and 

wastewater treatment system identified in 

Tables D-1 and D-2. 

EPA would use the block diagrams as a guide to 

understand the operation of the pond or wastewater 

treatment systems. The diagrams would help EPA 

understand the physical configuration of the pond 

or wastewater treatment units (e.g., operated in 

parallel or series). 

D3-2 and 

D3-3 

Requests influent and effluent wastewater 

flow information for each pond and 

wastewater treatment system operated or 

planned to be operated by the plant. The 

question also requests the amount of solids 

or sludge leaving the pond or wastewater 

treatment system, and the destination of the 

wastewater/solids. 

EPA would use the information to determine the 

types of wastewaters that are treated by pond and 

wastewater treatment systems at steam electric 

power plants. Additionally, EPA will use the 

information to identify wastewater reuse 

opportunities in the industry. 

EPA would use the flow rate information for sizing 

equipment technology options and estimating 

compliance costs for regulatory options. 
4-23 

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations 

Question Justifications 

Question 

Number Question Description Purpose of Question 

Active/Inactive/Open and Planned Pond/Impoundment Units (pond/impoundment level) 

D4-1 Asks if the plant uses ponds/impoundments 

for the storage, treatment, and/or disposal of 

residues or by-products from the 

combustions of coal, petroleum coke, or oil. 

Question determines if respondents are required 

complete the remainder of this section. 

D4-2 Requests the residence time, life expectancy, 

and number of cells for each active/open and 

planned pond/impoundment unit at the plant.

EPA would use the responses from these questions 

to characterize the specific pond/impoundment 

unit(s) comprising the pond system to understand 

the specific characteristics that may affect the costs 

for the pond system. EPA would use the 

pond/impoundment characteristics to estimate 

compliance costs. 

D4-3 Requests information about the 

pond/impoundment unit volume, surface 

area, top and bottom elevation, maximum 

height of the berm/dam, and freeboard 

height. Requests this as design information 

for planned units. 

EPA would use the responses from these questions 

to establish a relation between pond/impoundment 

size and costs. EPA will use the relationship to 

estimate the cost for a plant to install a new 

pond/impoundment system for the treatment of 

FGD or ash wastewaters. 

D4-4 Asks about pond/impoundment liners 

characteristics. 

EPA would use the liner information in the industry

profile and to identify best management practices in 

pond/impoundment unit design. 

D4-5 through 

D4-9 

Requests information on pond/impoundment 

dredging practices and pond/impoundment 

expansions. 

EPA would use the responses from these questions 

to update the industry profile and identify best 

management practices for the handling of solids 

from pond/impoundment units and expanding 

pond/impoundment units. 

D4-10 and 

D4-11 

Requests the pollutants targeted for removal 

by the pond by techniques other than settling 

and which pollutant limitations are driving 

the operation of the pond/impoundment. 

EPA would use this information to determine 

whether and how plants are operating pond systems 

to target specific analytes using techniques in 

addition to gravity settling. EPA will use the 

responses to evaluate best management practices 

for the industry. 

D4-12 Requests information on chemicals used in 

the pond/impoundment unit including dose, 

purpose of chemical, location of chemical 

addition, addition rate, and frequency of 

addition. 

EPA would use the responses from this question to 

identify industry practices for chemical treatment in 

pond/impoundment units and to identify best 

management practices. 

Closed Pond/Impoundment Units (pond/impoundment level) 

D4-13 Asks if the plant has pond/impoundments 

that have been closed (on or after January 1, 

2000) that were used for the storage, 

treatment, and/or disposal of residues or byproducts from the combustions of coal, 

petroleum coke, or oil. 

Question determines if respondents are required to 

complete the remainder of this section. 
4-24 

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations 

Question Justifications 

Question 

Number Question Description Purpose of Question 

D4-14 and 

D4-15 

Requests the date of closure, 

pond/impoundment life duration, and 

number of cells for all the closed 

pond/impoundment units at the plant. 

Additionally, a question requests the 

volume, surface area, top and bottom 

elevation, maximum height of the 

berm/dam, and freeboard height of the 

pond/impoundment units. 

EPA would use the information from this question 

to identify trends in the life of pond systems in the 

industry. EPA would use the size information to 

establish a relation between pond/impoundment 

size and costs. EPA would use the relationship to 

estimate the cost for a plant to install a new 

pond/impoundment system for the treatment of 

FGD or ash wastewaters. 

D4-16 and 

D4-17 

Requests information about liner 

characteristics for closed pond/impoundment 

units at the plant. Also requests the 

information for the cap/cover of the closed 

pond/impoundment units. 

EPA would use the liner and cap/cover materials 

and permeability in the industry profile and to 

identify best management practices in 

pond/impoundment unit design. 

D4-18 and 

D4-20 

Asks if the pond/impoundment was 

expanded during its life and requests details 

about the pond/impoundment expansion. 

EPA would use the responses from these questions 

to identify if and how the industry expands their 

pond/impoundment units and identify best 

management practices associated with 

pond/impoundment expansions. 

D4-21 and 

D4-22 

Asks if the plant had a closure plan for the 

pond/impoundment unit, requests a copy of 

the plan, a description of the closure process, 

and costs associated with the closure. 

EPA would use the information to identify best 

management practices associated with closing a 

pond/impoundment unit. EPA may use the cost 

information when evaluating the cost to convert 

from a wet ash handling system to a dry ash 

handling system. 

D4-23 Asks if the plant has built any structures on 

top of the closed pond/impoundment. 

EPA would use the information to identify 

opportunities and potential space available to 

further develop the facility area. 

D4-24 Requests information on long-term 

groundwater, soil or overflow monitoring of 

the closed pond/impoundment. 

EPA would use the responses from this question to 

identify best management practices associated with 

groundwater, soil, and overflow monitoring of 

closed pond/impoundment units. 

Wastewater Treatment Unit Information for Other Wastewater Treatment Systems 

D5-1 Asks if the plant identified any wastewater 

treatment systems in Table D-2. 

Question determines if the respondents need to 

complete the remainder of this section. 

D5-2 Asks about the wastewater treatment 

systems, on the unit level, at the plant. Also 

requests the plant designation, the date the 

unit was added to the wastewater treatment 

system, the volume, surface area, residence 

time, and materials of construction for each 

unit in the wastewater treatment system. 

EPA would use this information to identify the unit

operations comprising each wastewater treatment 

system and to update the industry profile. EPA 

would also use the information when evaluating the 

costs of the wastewater treatment systems (e.g., 

identify why some systems are more expensive 

than others). 
4-25 

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations 

Question Justifications 

Question 

Number Question Description Purpose of Question 

D5-3 Requests the average and maximum design 

flow rate, the typical and maximum system 

flow rates in 2009, and the duration and 

frequency of the effluent transfers in 2009. 

EPA would use the flow rate information to 

establish a relationship between the flow rate and 

cost of the wastewater treatment system. EPA 

would use the relationship to estimate compliance 

costs for plants that would be required to install 

wastewater treatment systems based on actual or 

predicted wastewater flow rates. 

D5-4 and 

D5-5 

Requests the pollutants targeted for removal 

by the treatment unit by techniques other 

than settling and which pollutant limitations 

are driving the operation of the unit. 

EPA would use this information to determine 

whether and how plants are operating wastewater 

treatment systems to target specific analytes. EPA 

would use the responses to evaluate best 

management practices for the industry. 

D5-6 and 

D5-7 

Asks if the wastewater treatment system has 

the capability for sulfide precipitation and if 

sulfide is currently being added to 

wastewater treatment system. 

EPA would use this information to determine 

which wastewater treatment systems have the 

capability of adding sulfide and how many facilities 

are actually adding sulfide. This would help EPA 

associate and develop compliance costs with the 

necessity of chemical addition to reach certain 

limits or standards. 

D5-8 through 

D5-10 

The questions also ask the plants to provide 

information on any impacts that climate or 

space available may have had on the design 

and cost of the wastewater treatment system. 

The bid proposal/engineering report for the 

wastewater treatment system is also 

requested. 

EPA will collect information on the impacts of 

climate and space availability to provide ranges in

the compliance costs developed regarding the 

industry. 

EPA would use the bid proposal/engineering 

reports to gain a better understanding of the 

wastewater treatment system to account for 

variations in costs for the treatment systems. 

D5-11 and 

D5-12 

Requests information on any planned 

improvements to existing wastewater 

treatment systems. 

EPA would use this information to identify 

potential improvements that can be done to a 

wastewater treatment system to achieve certain 

limits. Without this question, EPA would not 

account for planned improvements when 

developing technology options for the industry. 

D5-13 Requests information on chemicals used in 

the wastewater treatment unit including 

dose, purpose of chemical, addition rate, and 

frequency of addition. 

EPA would use the responses from this question to 

identify industry practices for chemical treatment in 

wastewater treatment systems and identify best 

management practices. 

Wastewater Treatment System Costs (wastewater treatment system level) 

D6-1 Asks if any pond/impoundment systems 

and/or wastewater treatment systems were 

defined in Tables D-1 and D-2. 

Question determines if respondents are required to 

complete the remainder of this section. 
4-26 

Table 4-4. Pond/Impoundment Systems and Other Wastewater Treatment Operations 

Question Justifications 

Question 

Number Question Description Purpose of Question 

D6-2 and 

D6-3 

Requests operation and maintenance (O&M) 

cost information for each pond and 

wastewater treatment system operated in 

2009. The question specifically requests the 

cost of labor, chemicals, energy, steam, and 

sludge disposal. 

Requests capital cost information for each 

current and planned pond and wastewater 

treatment system at the plant including direct 

costs (e.g. buildings and land) and indirect 

costs (e.g. engineering costs and contractor 

expenses). 

EPA would use this information to develop 

compliance costing estimates. EPA would use the 

O&M and capital costs to estimate an annualized 

cost for the various wastewater treatment options 

for compliance purposes. 

D6-4 and 

D6-5 

Asks whether FGD wastewater treatment 

system was installed with the FGD system 

or was a retrofit. Also asks if the FGD 

wastewater treatment system was purchased 

as part of the FGD scrubber purge package. 

This question will be incorporated into the cost of

compliance for installing a new FGD system for 

plants that have existing wastewater treatment 

technologies that may be retrofitted. 

D6-6 Asks plants to identify the major equipment 

included in the wastewater treatment system 

that are included in the capital costs 

provided in question E5-2. 

EPA would use this information to evaluate 

differences in capital costs provided by plants with 

similar wastewater treatment systems. 

Part E: Wastes from Cleaning Metal Process Equipment 

Part E collects information on wastewater generation and treatment of wastes from 

cleaning metal process equipment at the plant. 

Table 4-5. Wastes from Cleaning Metal Process Equipment Question Justifications 

Question 

Number Question Description Purpose of Question 

Metal Cleaning Operations

E1-1 Asks whether the plant generated wastes from 

cleaning metal processing equipment since 

January 1, 2000. 

EPA would use this information to identify plants 

that should complete the metal cleaning wastes 

section of the ICR/questionnaire; plants that have 

not generated wastes from cleaning metal 

processing equipment since January 1, 2000 would 

not complete Part E of the questionnaire. 
4-27 

Table 4-5. Wastes from Cleaning Metal Process Equipment Question Justifications 

Question 

Number Question Description Purpose of Question 

Generating Unit Cleaning Data

E2-1 and 

E2-2

Requests information about the chemicals 

used, average dose and amount added for 

each chemical, source of water used, volume 

of wastewater generated, and frequency of 

cleaning for each metal cleaning operation 

performed by steam electric generating unit. 

EPA would use this information to identify the 

types of metal cleaning operations performed by 

the industry to determine if revisions to the 

existing regulations are necessary. EPA would also 

use the information to characterize wastewaters 

generated by metals cleaning operations, and 

identify potential water reuse operations and best 

management practices. If needed, EPA would also 

use this information to calculate industry-level 

estimates for the wastewater discharges. 

Cleaning Operation Data

E3-1 Requests a description of the metal cleaning 

operation. 

EPA would use the responses to this question to 

characterize the metal cleaning operations to 

identify best management practices associated with 

the wastewater generation. 

E3-2 and 

E3-3

Asks whether the metal cleaning wastes are 

commingled with other wastewaters and if so, 

identify other wastewaters. Also requests the 

ultimate destination of the treated cleaning 

wastes. 

EPA would use the information from these 

questions to identify trends in the industry and 

characterize the best management practices for the 

metal cleaning wastewaters. EPA would also use 

the information to identify wastewater treatment 

systems being used to treat the metal cleaning 

wastewaters. 

E3-4 

through 

E3-6

Asks whether residues or other solid byproducts are generated from the metal 

cleaning operation. If so, asks whether the 

residues are considered hazardous wastes and 

the characteristics that make the waste 

hazardous. 

EPA would use this question to identify plants that

should complete the remaining questions about 

solid by-product generation associated with metal 

cleaning wastes; plants that do not generate solid 

by-products from metal cleaning operations would 

not need to complete the remaining questions. EPA 

would also use this information to characterize the

solid by-product generation associated with metal 

cleaning wastes and identify industry trends. 

E3-7 and 

E3-8

Requests information on the handling and 

storage of residues or solid by-products from 

the metal cleaning operations. 

EPA would use the responses from these questions 

to identify best management practices associated 

with the handling of metal cleaning waste residues 

and solid by-products. 

Part F: Management Practices for Ponds/Impoundments and Landfills 

Part F collects information on the best management practices used for ponds, 

impoundments, and landfills located at steam electric power plants. 
4-28 

Table 4-6. Management Practices for Pond/Impoundment Units and Landfills Question 

Justifications 

Question 

Number Question Description Purpose of Question 

Pond/Impoundment and Landfill Use 

F1-1 Asks if the plant has active/inactive/open or 

retired/closed ponds/impoundments or 

landfills used for the storage, treatment, 

and/or disposal of residues or byproducts 

from the combustion of coal. 

EPA would use this information to identify plans 

that should complete Part F of the questionnaire. 

Pond/Impoundment Management Practices 

F2-1 Requests embankment materials of 

construction. 

The embankment materials of construction affect 

the structural integrity of the embankment. EPA 

would use this information to identify industry 

trends in embankment construction and to identify 

best management practices. 

F2-2 

through 

F2-4 

Requests information on hydrologic design 

criteria and overflow history. 

These questions will capture any design 

considerations for stormwater overflow 

management. EPA would use this information to 

establish the baseline industry profile of current 

stormwater overflow management practices. 

F2-5 Asks if the pond/impoundment unit has a 

system to collect leachate. 

EPA would use this information to develop industry 

trends and identify best management practices 

among all waste management units. 

F2-6 Requests the volume and frequency of 

leachate collected in the pond/impoundment 

in 2009. 

EPA would use this data to determine the extent to 

which leachate is collected from 

ponds/impoundments in the industry. 

F2-7 

through 

F2-9 

Requests leachate handling practices 

including commingling with other 

wastewaters, treatment information, and 

chemicals added to treat leachate. 

EPA would use the information collected in these 

questions to determine the extent to which leachate

is treated, ultimately released to surface waters, and 

identify other wastewaters treated by leachate 

treatment systems. EPA may also use this 

information to identify potential water reuse options 

for plants. 

F2-10 Asks if the plant regularly monitors or 

inspects the structural integrity of the 

pond/impoundment. 

EPA would use this information to identify plants 

that should provide information on monitoring 

measures and inspections conducted on the 

pond/impoundment unit. 

F2-11 Requests which aspects of 

pond/impoundment unit structural integrity 

are monitored or inspected and the frequency 

and hours per month spent performing 

monitoring. 

EPA would use the information collected from this 

question to understand the monitoring practices and

inspections for several aspects of 

pond/impoundment integrity. 

F2-12 Requests pond/impoundment inspections 

information for the last five inspections 

including the date of inspection, affiliation of 

the inspector, and the cost of the inspection. 

If applicable, plants are also asked provide 

any corrective actions that resulted in 

response to the inspection and costs 

associated with implementing the corrective 

actions. 

The information collected in this question would be

used by EPA to assess inspection practices. EPA 

would use the cost of inspections and the cost of 

any corrective actions in forecasting the industrywide cost of compliance with best management 

practices. 
4-29 

Table 4-6. Management Practices for Pond/Impoundment Units and Landfills Question 

Justifications 

Question 

Number Question Description Purpose of Question 

Landfill Management Practices 

F3-1 

through 

F3-3 

Requests information on the area, volume 

capacity, and height of the landfill. 

EPA requests original, present, and completed 

landfill dimensions to understand how plants 

respond to the increase in solid wastes that must be 

stored. Additionally, the progression of landfill size 

will help EPA understand how expansions in 

landfill size relate to the overall plant layout. 

F3-4 

through 

F3-7 

Asks if the landfill has been expanded since 

it was built and the type of expansion. Also 

requests the costs associated with the 

expansion, a description of the landfill 

expansion, and the Requests the calendar 

year 2009 operation and maintenance (O&M) 

costs associated with the expansion. 

Information on expansion would help EPA 

understand how plants respond to the increase in 

solid wastes that must be stored and how 

expansions in landfill size relate to the overall plant 

layout. Additionally, the information would help 

EPA understand the landfill expansion process and 

the costs that have been incurred from the plant to

expand a landfill. 

F3-8 and 

F3-9 

Asks about the landfill liner and cap/cover 

characteristics. Requests the liner and 

cap/cover layer thickness and permeability of 

each layer in the liner and cap/cover. 

EPA would use the liner and cap/cover materials, 

thickness, and permeability in the industry profile, 

and to identify landfill best management practices.

F3-10 Asks if the plant built any structures on top 

of the closed landfill. Requests a description 

of the structure(s) and any challenges that the 

plant faced building on top of the landfill. 

EPA would use this information to identify methods 

of constructing on top of closed landfills. EPA 

would also use this information to determine a 

plant’s land availability for future construction. 

F3-11 and 

F2-12 

Asks if the plant has a leachate collection 

system and requests the amount of leachate 

collected in 2009. 

EPA would use this data to determine the extent to 

which leachate is collected from landfills in the 

industry. 

F3-13 and 

F3-14 

Requests leachate handling practices 

including treatment information and 

chemicals added to treat leachate. 

EPA would use the information collected in these 

questions to determine how leachate is treated and 

the ultimate destination of collected leachate. EPA

may also use this information to identify potential

water reuse options for plants and current industry

practices for leachate treatment. 

F3-15 

through 

F3-18 

Requests collection and treatment system 

information for stormwater runoff that has 

contacted the capped and uncapped portions 

of the landfill. 

EPA would use the information collected in these 

questions to determine whether stormwater runoff is

collected with leachate, how the runoff is treated,

and the ultimate destination of runoff. EPA may 

also use this information to identify potential water 

reuse options for plants. 
4-30 

Table 4-6. Management Practices for Pond/Impoundment Units and Landfills Question 

Justifications 

Question 

Number Question Description Purpose of Question 

Leachate Treatment System Design

F4-1 Identifies leachate treatment systems for 

leachate from pond/impoundment units and 

landfills. 

EPA would use the information collected from this 

question to identify leachate treatment systems (not 

including wastewater treatment systems previously 

defined in Table D-2 that receive 

pond/impoundment or landfill leachate) operated or 

planned to be operated by the plant. The question 

assigns system IDs which will be used to identify 

the systems in later questions. 

F4-2 Requests block diagrams for each leachate 

treatment system. 

EPA would use the block diagrams as a guide to 

understand the operation of the leachate treatment 

systems. The diagrams would help EPA understand 

the physical configuration of the leachate treatment 

units (e.g., operated in parallel or series). 

Leachate Treatment System Flows

F4-3 Requests leachate treatment system flow 

information. 

EPA would use the information to determine the 

types of wastewaters that are treated by leachate 

treatment systems at steam electric power plants. 

Additionally, EPA will use the information to 

identify wastewater reuse opportunities in the 

industry. 

EPA would use the flow rate information for sizing 

equipment technology options and estimating 

compliance costs. 

Leachate Treatment System Units 

F4-4 Asks for information about treatment units 

for the leachate treatment system. 

EPA would use this information to identify the unit

operations comprising each leachate treatment 

system and to update the industry profile. EPA 

would also use the information when evaluating the 

costs of the leachate treatment systems (e.g., 

identify why some systems are more expensive than 

others). 

F4-5 and 

F4-6 

Requests information on planned 

improvements to the leachate treatment 

system, including a description of the 

improvement, the expected date of the 

improvement, the total capital cost related to 

the improvement, and reasons for planned 

improvement. 

EPA would use this information to identify changes 

that will be made on leachate treatment systems in 

the near future and to update the industry profile.

EPA would also use this information to identify 

methods of improving different types of leachate 

treatment systems, evaluate the cost of the 

improvements, and identify the impact on pollutant 

concentrations. 

F4-7 Requests the typical and maximum leachate 

treatment system flow rates in 2009 and the 

duration and frequency of the effluent 

transfers in 2009. 

EPA would use the flow rate information to 

establish a relationship between the flow rate and 

cost of the leachate treatment system. EPA would 

use the relationship to estimate compliance costs for 

plants that would be required to install leachate 

treatment systems based on actual or predicted 

leachate flow rates. 
4-31 

Table 4-6. Management Practices for Pond/Impoundment Units and Landfills Question 

Justifications 

Question 

Number Question Description Purpose of Question 

Leachate Treatment Unit Information

F4-8 

through 

F4-11 

Requests the volume, footprint/surface area, 

residence time, and materials of construction 

for each unit in the leachate treatment 

system. 

EPA would use the information from these 

questions to evaluate difference among leachate 

treatment systems between plants and identify 

characteristics that factor into the cost of a leachate 

treatment system. 

F4-12 and 

F4-13 

Requests information about leachate 

treatment by techniques other than settling. 

EPA would use this information to determine 

whether plants are operating leachate treatment 

systems to target specific analytes using techniques 

other than settling. EPA would use the responses to

evaluate best management practices for the industry.

F4-14 Requests information on chemicals used in 

leachate treatment. 

EPA would use the responses from this question to 

identify industry practices for chemical treatment in 

leachate treatment systems and identify best 

management practices. 

F4-15 Requests information on plant species used 

in the leachate treatment unit (i.e., 

constructed wetland cell). 

EPA would use the responses from this question to 

identify industry practices for constructed wetlands 

as leachate treatment systems and identify best 

management practices. 

Leachate Treatment System Costs

F4-16 and 

F4-17 

Requests capital and operation and 

maintenance (O&M) cost information for the 

leachate treatment system. 

EPA would use this information to develop 

compliance cost estimates. 

Leachate Treatment System Equipment

F4-18 Asks plants to identify the major equipment 

included in the leachate treatment system that 

are included in the capital costs provided in 

question F4-17. 

EPA would use this information to evaluate 

differences in capital costs provided by multiple 

plants with similar leachate treatment systems. 

Groundwater Monitoring Practices

F5-1 Asks if the plant performs groundwater 

monitoring at the pond/impoundment and 

landfill and information pertaining to the 

frequency of monitoring. 

EPA would use this information to evaluate the 

prevalence of groundwater monitoring practices. 

F5-2 Asks plants to identify the locations of 

monitoring wells around each 

pond/impoundment and landfill. For each 

well location, EPA requests the average 

water table depth and distance to surface 

water. 

This information would help EPA evaluate the 

potential of pond/impoundment and landfill 

leachate contaminating groundwater and ultimately 

surface waters. 

F5-3 

through 

F5-6 

Asks if the plant has plant measured pollutant 

concentrations from ash and FGD related 

constituents in ground water that exceed a 

primary or secondary MCL, state-issued 

standard/criteria, or background 

concentrations. If so, asks the plant to 

identify the pollutants that exceeded. 

EPA would use this question to assess the potential

of pond/impoundment and landfill leachate 

contaminating groundwater and ultimately surface 

waters. EPA would also use this information to 

identify pollutants of concern. 
4-32 

Part G: Leachate Sampling Data for Ponds/Impoundments and Landfills 

Part G collects sampling data for landfills and ponds/impoundments. Plants are asked to 

sample treated and untreated leachate for metals, chlorides, mercury, sulfates, total dissolved 

solids, total suspended solids, and pH. EPA would use the monitoring data collected from this 

part to characterize treated and untreated leachate streams, evaluate wastewater treatment 

performance, estimate pollutant discharge loadings, and establish effluent limitations. 

Table 4-7. Leachate Sampling Data for Pond/Impoundments and Landfills Question 

Justifications 

Question 

Number Question Description Purpose of Question 

Leachate Collection

G1-1 Asks whether leachate is currently collected 

from any pond/impoundment and/or landfill 

at the plant.

EPA would use this information to identify plants 

that should complete Part G of the questionnaire; 

plants that do not currently collect leachate would

not complete Part G. 

Leachate Generated from Pond/Impoundments and Landfills

G2-1 Asks whether leachate is currently collected 

from the pond/impoundment and/or landfill. 

EPA would use the responses from this question to 

identify pond/impoundment units and/or landfills 

that require leachate sample collection. 

G2-2 and 

G2-3

Asks whether all of the collected leachate 

from the pond/impoundment and/or landfill is 

transported off-site for treatment and/or 

disposal. If not, asks whether the collected 

leachate is treated. 

EPA would use responses from these questions to 

identify plants that should sample only untreated 

leachate. 

G2-4 Asks whether the leachate is combined with 

other waste streams prior to treatment. If so, 

asks if the leachate is combined with only 

stormwater runoff or if it is combined with 

other waste streams. 

EPA would use responses from this question to 

identify plants that should sample both untreated 

and treated leachate. 

Leachate Sample Collection Instructions

G3-1 Requests the plant to collect wastewater 

samples from untreated and/or treated 

leachate streams generated from each 

pond/impoundment unit and landfill that 

collect leachate. 

EPA would use the analytical data from the 

collected leachate samples to characterize 

untreated and treated leachate streams. EPA may 

also use this information to develop numerical 

limits on discharges of leachate. 

G3-2 and 

G3-3 

Requests an aerial photograph or drawing 

showing the entire waste management unit, 

including all leachate collection points and 

the active and inactive areas of the landfill. 

Also, requests identification of the leachate 

sample locations used for this sample 

collection in the block diagram previously 

requested in Question F4-2. 

EPA would use the aerial photograph and block 

diagram to identify trends in the number and 

location of leachate collection points found in 

pond/impoundment units and landfills in the 

industry and characterize the best management 

practices for the waste management sites. EPA 

would also use the aerial photograph and block 

diagram to determine how leachate generation 

differs between active/uncapped or inactive/capped 

waste management sites. 
4-33 

Table 4-7. Leachate Sampling Data for Pond/Impoundments and Landfills Question 

Justifications 

Question 

Number Question Description Purpose of Question 

Sample Collection Information

G4-1 and 

G4-2 

Requests information on the leachate sample 

collection, including a description of the 

sample collection location, the date the 

sample was collected, whether the leachate 

stream is treated or untreated, and rainfall 

patterns preceding and during the sample 

collection. 

EPA would use this information to determine how 

the sample collection location and variation in 

rainfall patterns impacts leachate generation and 

characterization. 

Waste Information

G5-1 Requests identification of all the process 

wastes, residues, or by-products that are 

stored, treated, and/or disposed of in each 

pond/impoundment unit and/or landfill 

located on-site. Also requests the amount of 

waste under the capped and uncapped 

portions of the landfill. 

EPA would use this information to identify the 

types and the amounts of materials that are 

disposed of in each pond/impoundment and 

landfill. EPA would compare this information to 

the analytical results to determine how the types 

and amounts of waste impact leachate 

characteristics. 

Part H: Nuclear Power Generation 

Part H collects information on wastewater generation and treatment at nuclear power 

plants. 

Table 4-8. Nuclear Power Question Justifications 

Question 

Number Question Description Purpose of Question 

Nuclear Generating Unit Data

H1-1 Asks if the plant operated an electric 

generating unit using nuclear energy in 2009. 

EPA would use this question to identify plants that

need to complete the nuclear power generating 

units part; plants that did not operate any nuclear

generating units in 2009 would not complete Part 

H of the questionnaire. 

H1-2 Asks if the plant generated process wastewater 

associated with the nuclear electric generating 

units. 

EPA would use this question to identify the plants 

that need to complete the nuclear process 

wastewater generation section; nuclear plants that 

did not generate process wastewater in 2009 would 

not complete that section. 

H1-3 Requests information on process wastewater 

generated by the nuclear electric generating 

units. 

EPA would use this information to identify the 

types of process wastewater generated by the 

nuclear electric generating units. 

Process Wastewater Generation 

H2-1 Asks for the characteristics of the process 

wastewater generated by the nuclear electric 

generating units. 

EPA would use the responses to this question to 

characterize the process wastewater generated at 

nuclear plants and cost technology options, if 

appropriate. 
4-34 

Table 4-8. Nuclear Power Question Justifications 

Question 

Number Question Description Purpose of Question 

H2-2 Asks information on how process wastewater 

generated by nuclear electric generating units 

is handled. 

EPA would use the responses to this question to 

identify how nuclear plants typically manage 

process wastewater including information on 

recycling and ultimate destination. 

Wastewater Treatment Systems 

H3-1 Asks if the wastewater treatment system treats 

radioactive waste. 

EPA would use the responses to this question to 

identify how nuclear plants treat process 

wastewater differently depending on whether it is 

radioactive or nonradioactive. 

H3-2 and 

H3-3 

Asks the plant to identify all the process 

wastewater that a wastewater treatment system 

treats and indicate flow rates for the 

wastewater treatment system. 

EPA would use this information to determine, 

which process wastewaters are typically combined 

for treatment and help characterize wastewater 

treatment systems at nuclear power plants. 

H3-4 and 

H3-5 

Asks for the treatment technologies used in 

the wastewater treatment system, the 

pollutants targeted for removal by each 

technology. 

EPA would use the information from these 

questions to determine how different process 

wastewaters are treated at nuclear power plants and

to determine best management practices and/or 

treatment technologies. 

H3-6 Asks information on treatment technologies 

the plant is currently adding or planning to add 

to the wastewater treatment system. 

EPA would use this information to evaluate if 

changes are being made to how the plant treats 

process wastewater. 

H3-7 and 

H3-8 

Asks information on how the treated process 

wastewater is handled. 

EPA would use the responses to these questions to 

determine how nuclear plants typically manage 

treated process wastewater including information 

on recycling and ultimate destination. These 

questions would help EPA to characterize nuclear 

power plant recycling practices and determine 

management practices. 

Part I: Economic and Financial Data 

Part I of the survey asks for economic and financial information about each plant, the 

plant’s owner(s), and its steam-electric generating units. This part requests identifying and 

contact information, information on economic activities, including activities other than 

generation of electricity, and revenues and costs associated with the economic activities. This 

part also asks for three years of data on a plant-level financial balance sheet and operational 

information about the generating units. The Agency will use this information to assess the 

potential impacts of compliance with steam electric ELGs and on the economic viability of all 

affected plants and their steam-electric generating units. 

The questionnaire is designed to be completed with standard accounting information that

is generated as a matter of customary business practice and which should be readily available to 

a knowledgeable company representative. 
4-35 

Table 4-9. Economic and Financial Data Question Justifications 

Question 

Number Question Description Purpose of Question 

Immediate Parent-Level

I1-1 

through 

I2-13 

Requests information pertaining to the 

immediate legal parent owner(s) of the plant or 

other entities that have a financial interest in 

the plant. The section includes a general 

question regarding the identity of the owner(s). 

It also includes several questions asking for 

more detailed information on the owner with 

the largest ownership share in the steam 

electric capacity of the plant, including 

ownership type and structure, sales, purchases 

and generation of electricity, income 

statement, balance sheet, and cash flow 

information.

EPA would use information gathered through these 

questions to identify entities that may be affected

by the regulations and for economic impact 

analyses, household impact and electricity rate 

impact analyses as well as to extrapolate certain 

plant-level information when necessary. In those 

instances when the immediate parent is also the 

ultimate parent, this information would be used for

parent-level cost impact, RFA, and UMRA 

analyses. 

Ultimate Domestic Parent-Level

I3-1 and 

I3-2 

Asks respondents to provide revenue, 

electricity sales, and total number of 

employees for the ultimate parent unless the 

immediate parent is also the ultimate parent. 

This information would be used for the parentlevel cost impact, RFA, and UMRA analyses. 

Plant-Level

I4-1 

through 

I4-12 

Asks for total number of employees, total 

generating capacity, total electricity 

generation, capital outlays for plant and 

equipment, income statement, and balance 

sheet information for the plant. The questions 

also ask for the description of economic 

activities other than electricity generation and 

costs and revenues associated with these 

activities.

Information collected through these questions 

would be used for facility-level cost impact 

analysis. 

Generating Unit-Level

I5-1 

through 

I5-4 

Asks for information on nonutility status and 

operating status, undepreciated value of 

generating plant and equipment, generating 

capacity, electricity generation, net peak 

demand, energy source, planned/scheduled and 

forced/unscheduled outages, and total, fuel, 

and variable O&M costs for each steam 

electric generating unit.

EPA would use the information collected through 

these questions in: assessing the unit-level impact

of compliance requirements, estimating the 

potential cost of unit downtime during technology 

installation, assessing the short-term and long-term 

reduction in capacity availability due to installation 

downtime, and conducting electricity rate impact 

analyses. 

(ii) Respondents Activities 

Each respondent will receive a transmittal letter with attachments citing authority of 

Section 308 of the Clean Water Act and confidentiality and handling of any responses for which 

assertions of confidential business information (CBI) may be made. Respondents will also need 

to read the Introduction, General Instructions, Glossary of Key Terms, and Certification 

Statement sections in the beginning of the questionnaire. The Introduction section provides the 

purpose and use of the questionnaire, questionnaire outline, e-mail/help line information, and 

information on how to return the completed questionnaire. The General Instructions section will 
4-36 

give the respondent guidance on completing the responses and including attachments, if needed. 

The Glossary of Key Terms provides respondents with all pertinent definitions and acronyms to 

understand and complete the questionnaire sections. 

There are four different categories of respondents for the questionnaire. These categories 

include coal- and petroleum coke-fired power plants included in the statistical subset, coal- and 

petroleum coke-fired power plants not included in the statistical subset, oil-fired and 

combination power plants, and gas-fired and nuclear power plants. EPA will distribute four

different versions of questionnaire, corresponding to the categories stated above, to avoid 

respondents from potentially answering parts not applicable to their facility. 

The coal- and petroleum coke-fired power plants included in the statistical subset will 

receive Parts A through I of the questionnaire. The coal- and petroleum coke-fired power plants 

not included in the statistical subset will receive Parts A through D, H, and I of the questionnaire. 

Oil-fired and combination power plants will receive Parts A through E, H, and I of the 

questionnaire. Gas-fired and nuclear power plants will receive Parts A, E, H, and I of the 

questionnaire. Respondents must still read the instructions preceding each part to determine 

whether that part needs to be completed for their plant. These instructions also give the 

respondents guidance on completing the responses in each part. The planned distribution of the

questionnaire parts is illustrated by Table 4-10. 

Table 4-10. Number of Questionnaire Respondents 

Steam Electric Power Plants by Fuel Type 

Questionnaire Part Coal 

Petroleum 

Coke Oil Gas a Nuclear Combination b Total 

Estimated population of fossil/ 

nuclear steam electric plants 

495 9 43 561 63 32 1,203 

Total number of respondents 495 9 20 168 20 22 734 

Part A: Power plant operations 495 9 20 168 20 22 734 

Part B: FGD systems 495 c 9 c 20 c — — 22 c 546 c

Part C: Ash handling 495 9 20 — — 22 546 

Part D: Ponds/treatment 495 9 20 — — 22 546 

Part E: Cleaning wastes 94 3 20 168 20 22 327 

Part F: Management practices 94 3 — — — — 97 

Part G: Leachate sampling 94 d 3 d — — — — 97 d

Part H: Nuclear power 495 e 9 e 20 e 168 e 20 e 22 e 734 e

Part I: Economic data 495 9 20 168 20 22 734 

a – The “Gas” fuel type includes plants classified as “Gas” and plants classified as “Gas Combined Cycle.” See Part 

B of the Supporting Statement for further information on the different fuel type categories. 

b – Combination plants operate at least two generating units that use different types of fuel, but do not operate units 

fueled by coal or petroleum coke. The specific questionnaire parts that will be completed by these plants are 

dependent on the operations and types of units present. See Table B-3, in Part B of the Supporting Statement, for a 

more specific break out of combination plants. 

c – Number of plants is a maximum. Part B will only be completed by plants operating or planning to install FGD 

systems. EPA estimates 242 plants (less than half of coal, petroleum coke, and oil plants) will need to complete 

Part B. 

d – EPA estimates that 97 plants will receive Part G, but only about 30 percent of respondents (~30 plants) actually 

operate leachate collection systems and would therefore collect and analyze wastewater samples. 

e – Part H will be distributed to all respondents in the scope of the questionnaire; however, very few coal-, 

petroleum coke-, oil-, and gas-fired power plants receiving the questionnaire will also have nuclear generating units 

(e.g., EPA estimates only two coal-fired power plants have one or more nuclear units). 
4-37 

The questionnaire respondents must review the instructions to understand the 

questionnaire. Other respondent activities will include searching data sources to consult records 

and reviewing plant information regarding production techniques, equipment types, expenditure 

histories, and financial company information. The respondent will also have to compile and 

review information and complete the questionnaire. A subset of questionnaire recipients will be 

required to collect and analyze samples of leachate from surface impoundments and landfills 

containing coal combustion residues. The respondents will be required to return the completed 

questionnaire and leachate sampling data to EPA in electronic format (i.e., MS Excel format). 

The respondents should retain the completed questionnaire for up to one year in the event that 

EPA has to contact the facility for clarification of any response. The respondents will not need to 

maintain any new records because this is a one-time information collection effort. 
5-1 

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION

METHODOLOGY, AND INFORMATION

5(a) Agency Activities 

The Agency has conducted, is conducting, or will conduct the following activities to 

administer the steam electric questionnaire: 

• Develop the questionnaire; 

• Develop the sample frame; 

• Develop the ICR supporting statement; 

• Provide the questionnaire for review by trade associations, industry 

representatives, public interest groups, state regulatory agencies, EPA workgroup 

members, OMB, and other stakeholders; 

• Revise the questionnaire based on comments from trade associations, industry 

representatives, public interest groups, state regulatory agencies, EPA workgroup 

members, OMB, and other stakeholders; 

• Develop a mailing list database and mailing labels; 

• Develop a tracking system for questionnaire mail-out, receipt, and return 

activities; 

• Distribute questionnaires; 

• Develop and maintain help lines for respondents who require assistance in 

completing their questionnaire; 

• Develop an electronic database for questionnaire responses; 

• Receive and review questionnaire responses; 

• Summarize and analyze questionnaire responses; and 

• Conduct technical analyses. 

The Agency will transfer data received from the questionnaire forms to a master database 

for future use. 

5(b) Collection Methodology and Management 

Each selected plant will be assigned a specific plant identification number and will 

receive an electronic MS Excel version of the questionnaire to complete. Plants will be required 

to fill out the electronic version of the questionnaire, but EPA will also include a pdf file of the 

questionnaire that can be printed out and used as a working copy. The questionnaire will be sent 

via Federal Express or similar delivery service to each plant to ensure that a point of contact (the 

plant contact person) receives and signs for the questionnaire package. Each plant will be 

allowed 60 calendar days from the time of receipt to return the completed questionnaire, for all 

portions of the questionnaire except Part G. Plants will be allowed 120 calendar days to submit 

Part G along with the leachate sampling data. 

EPA will include an e-mail address and phone number in the instructions that 

respondents can use to request assistance in completing the questionnaire. Using these assistance 

methods enables the respondents to receive a timely response to any inquiries that they may 

have. E-mail and telephone communication will also reduce any misinterpretations of the 

questionnaire and thus decrease the burden of follow-up phone calls and letters to the 

respondents. 
5-2 

The plant will enter their unique plant identification number on each section of the 

questionnaire for ease of tracking. The plant identification number will be used to track the 

mailing date of the questionnaire, questionnaire receipt date, follow-up letters and telephone calls 

to respondents, and EPA’s receipt of the completed questionnaire. EPA will also use the

identification number as an identification code in the questionnaire database. The Agency will 

make follow-up calls as needed to clarify inconsistencies in responses, and to remind nonrespondents of their requirement to complete and return the questionnaire. 

Upon receipt of completed questionnaires, EPA and its contractors will review the 

questionnaire responses for completeness and CBI claims. All questionnaires will also be 

reviewed for consistency and reasonableness and follow-up calls will be conducted as needed to 

clarify inconsistencies found in the responses. Reviewed questionnaire files will then be 

uploaded into the questionnaire database. The database developed using the questionnaire 

responses will be used by EPA to perform data analysis for the purpose of revising the steam 

electric ELGs. 

5(c) Small Entity Flexibility 

In accordance with requirements of the Regulatory Flexibility Act (RFA), EPA must 

assess whether actions would have “a significant impact on a substantial number of small 

entities” (SISNOSE). Small entities include small businesses, small organizations, and small 

governmental jurisdictions. EPA has determined that approximately 734 plants will be required 

to respond to this questionnaire. Based on EPA’s past analyses of steam electric entities, the 

majority of the businesses that EPA is targeting to receive the detailed questionnaires are not 

defined as small. Whether a respondent is defined as small depends on the size of the domestic 

parent and is based on the appropriate Small Business Administration (SBA) entity size criterion 

(codified at 13 CFR part 121). The criteria for entity size determination vary by the 

organization/operation category of the parent entity, as follows: 

• Private Entities: Private entities include investor-owned utilities, non-utility 

entities, and entities with a primary business other than electric power generation. 

For entities with electric power generation as a primary business, small entities 

are those with total annual electric output less than 4 million MWh. For entities 

with a primary business other than electric power generation, the relevant size 

criteria are based on revenue or number of employees by NAICS sector (see

Table 5-1). 4

• Public entities: Public entities include federal, state, municipal, and political 

subdivision entities. Facilities owned by Federal and State governments are 

considered to be large; facilities owned by municipalities and other political units 

with population less than 50,000 are considered to be small. 

• Not-for-profit enterprises: Not-for-profit enterprises include rural electric 

cooperatives. Small entities are those with total annual electric output less than 4 

million MWh. 

 

4

 Certain in-scope facilities are owned by entities whose primary business is not electric power generation. 
5-3 

Table 5-1. NAICS Codes and SBA Size Standards for Entities with a Primary Business 

Other Than Electric Power Generation 

NAICS Code NAICS Description SBA Size Standard 

221210 Natural Gas Distribution 500 Employees 

221310 Water Supply and Irrigation Systems Revenue of $7,000,000 

331315 Aluminum Sheet, Plate, and Foil Manufacturing 750 Employees 

524126 Direct Property and Casualty Insurance Carriers 1,500 Employees 

525990 Other Financial Vehicles Revenue of $7,000,000 

551112 Offices of Other Holding Companies Revenue of $7,000,000 

562212 Solid Waste Landfill Revenue of $12,000,000 

562219 Other Nonhazardous Waster Treatment and Disposal Revenue of $12,000,000 

562920 Materials Recovery Facilities Revenue of $12,000,000 

611310 Colleges, Universities, and Professional Schools Revenue of $7,000,000 

Source: SBA, 2008. 

EPA has designed the survey to minimize respondent burden while obtaining sufficient 

and accurate information. The survey employs the use of checkboxes where feasible, or provides 

a set of potential responses for respondents to choose from. The questions are phrased with 

commonly used terminology. Questions requesting similar types of information are arranged 

together to facilitate review of pertinent records and completion of the questionnaire. The 

questionnaire will include initial questions to determine which parts of the questionnaire the 

plant will be required to complete. EPA will revise the questionnaire as necessary in response to 

public comments on this information collection request in order to minimize respondent burden 

while ensuring the practical utility of the data. EPA will be providing a helpline to answer 

questions respondents might have when completing the questionnaire. 

To further reduce the burden on small entities, EPA is excluding small entities from the 

requirement to collect and analyze samples of leachate from ponds/impoundments and landfills. 

By doing so, small entities will be relieved of the labor burden required to collect the samples 

and compile and review analytical data, as well as the costs associated with sampling supplies, 

shipping samples to analytical laboratories, and laboratory analysis of the samples. EPA’s 

methodology to identify potential respondents and distribute the questionnaire will result in not 

requiring small entities to complete Parts E, F, and G of the questionnaire. In providing this 

burden relief to small entities, EPA is assuming that the information collected in Parts E, F and G 

from non-small entities is appropriate for use in characterizing wastewater 

generation/characteristics and practices at small entities. 

5(d) Collection Schedule 

The specific dates for distribution, response receipt, and data collection activities for the 

questionnaire have not yet been established but will include the following activities listed below 

in Table 5-2. 
5-4 

Table 5-2. Collection Schedule 

Activity Estimate of Schedule 

EPA send questionnaires to recipients Late May/Early June 2010 

Plants complete questionnaire (all parts except for Part G) 60 days following receipt 

Plants complete Part G of questionnaire 120 days following receipt 

EPA conduct questionnaire follow-up 4 months 

EPA complete ICR database, assign statistical weighting factors 2-4 weeks 
6-1 

6. ESTIMATING THE BURDEN AND COST OF COLLECTION 

6(a) Estimating Respondent Burden 

EPA published a notice in the Federal Register announcing EPA’s intent to submit the 

Steam Electric ICR to OMB on October 29, 2009 (74 FR 55837). EPA reviewed all public 

comments regarding burden estimates and carefully revised estimates as appropriate. EPA will 

publish a final notice in the Federal Register in March 2010. EPA encourages the receipt of 

public comments and suggestions regarding the revised questionnaire and associated estimates of 

burden. 

Because the steam electric industry will devote time and resources to respond to the 

questionnaire, EPA has made significant efforts to minimize the burden on the industry. Many of 

the changes made in this regard are described in Appendix B. EPA worked to eliminate 

redundant, unclear, and unnecessary questions from the questionnaire. EPA also developed a

user-friendly, MS Excel electronic version of the questionnaire. This electronic version should 

allow plants to easily enter data using check boxes, drop down menus, and option buttons. 

The burden to respondents for Parts A through H includes the time necessary to read 

through all instructions and questions, develop a data gathering plan, gather data, transfer data to 

the questionnaire, and review/check the responses. Each section of the survey is expected to be 

completed by technical and clerical staff, and reviewed by managerial staff. The burden 

estimates reflect the assumption that technical and clerical staff will devote their time to reading 

instructions, gathering information and completing the survey form; managers will devote their 

time to reading instructions and reviewing survey responses. 

The burden to the respondents for Part I includes the time necessary to read general 

instructions and review before submittal, provide owner table with shares, provide detailed 

immediate parent level and ultimate parent level information, perform a contracts review, and 

provide plant and unit level information. EPA predicts that only a subset of plants will incur the 

burden of answering certain questions. For example, plants that already provide certain data to 

FERC on Form 1 may skip the questions asking for detailed financial information for the 

immediate parent. EPA estimated that approximately 40 percent of the steam electric plants that 

will receive this questionnaire are owned by major regulated utilities and are therefore required 

to submit FERC Form 1 data. The Agency adjusted the overall burden of these questions (I1-8 

through I1-12) on the universe of respondents accordingly. Additionally, EPA’s review of the 

respondent universe showed multiple plants owned by the same immediate parent firms. Because 

detailed financial information for the immediate parent only needs to be compiled once, EPA 

adjusted the burden estimate for these questions (I1-2 through I1-16) to account for the expected 

number of unique responses. Finally, only a subset (2/3) of respondents is assumed to currently 

sell electricity using contracts and therefore would incur the burden of answering the relevant 

questions (I1-13 and I1-14). Table 6-1 presents the hourly burden estimate for Part I. These 

estimates are used, along with the burden for Parts A through H, to calculate the total respondent 

burden, shown in Table 6-2. 

EPA identified labor categories associated with all respondent activities necessary to 

complete the questionnaire: operating engineer, engineering manager, engineering technician, 

clerical support, legal support, junior accountant, and financial manager. 
6-2 

(i) Respondent Burden 

For the purpose of estimating the burden, the questionnaire will be sent to approximately

734 steam electric plants, including a census of all coal-fired power plants and a subset of the 

rest of the industry that will be statistically selected using a sample frame population identified 

by the 2007 EIA Database (Form 860 and Form 923) and confirmed by NAICS code. All 

questionnaire recipients will receive the parts of the questionnaire corresponding to designated 

fuel type (734 steam electric plants). EPA will require statistical sample subpopulations of the 

steam electric industry to fill out additional detailed sections of the questionnaire, as illustrated 

by Table 2-1. 

EPA estimates the total burden for the steam electric questionnaire to be approximately 

144,451 hours. For the purpose of estimating the burden of completing this questionnaire, EPA 

assigned burden estimates for all sections of the questionnaire. Table 6-2 presents a summary of 

the average hourly burden, estimated number of respondents, and total burden by labor category

associated with each section of the questionnaire. 

By calculating separate burden estimates for each section, EPA can estimate respondent 

burden by predicting the number of respondents per section. This number changes based on the 

criteria required for each section (e.g., number of plants, number of generating units, number of 

FGD systems, etc.) in order to account for all units and/or systems throughout the industry. This 

estimated respondent number will also change based on the intended population of each part. For 

example, Table 6-2 shows that EPA expects responses for 772 generating units in Part E. These 

generating units are not the total estimated number of units in the respondent universe; they are 

the estimated number of units in all the subpopulations required to respond to Part E. EPA 

estimated the total number of respondents per section using EIA data and information collected 

from the data request, site visits, and communication with the industry. 

EPA also estimated the associated burden with certain subsets of the industry population. 

As described earlier, EPA will send the questionnaire to all coal-fired fired power plants, but 

only a statistical subset of these plants will be required to complete Sections E, F, and G. 

Therefore, EPA estimated the hourly burden for a coal plant that is in the statistical subset (and 

subject to report on all parts of the questionnaire) versus a coal plant that is not in the subset. In 

addition, EPA estimated the average hourly burden for non-coal plants. Table 6-4 presents the 

burden for these types of plants. 

(ii) Total Estimated Respondent Burden 

EPA calculated the total estimated respondent burden using the estimated response time 

per section and the total number of estimated respondents and respondent elements shown in 

Table 6-2. Multiplying the hourly burden section estimates by the number of respondents 

provided a total industry burden per section of the questionnaire; further broken down by labor 

category. EPA summed all labor category estimates to calculate the total respondent burden, per 

part of the questionnaire, of 144,451 hours shown in Table 6-3. 
6-3 

Table 6-1. Economic and Financial Data Burden Estimates for Part I 

Number of Hours 

Survey Section Activity Jr. Acct 

Financial 

Manager 

Clerical 

Support Legal 

Total 

Burden 

Estimated 

Fraction of 

Respondents 

Incurring 

Burden 

Adju

Re

Burd

Multi

O

Economic/ Financial Section 

Read general instructions and do final review before submitting 

1.00 3.00 0.00 2.00 6.00 100% 

Provide owner table with shares 

2.00 2.00 0.00 0.00 4.00 100% 

Detailed info (except contracts) - Applies to non-FERC respondents only 

8.00 2.00 2.00 0.00 12.00 60% 

Immediate Parent Info 

Contracts review - applies only to entities that sell under contract 

12.00 3.00 1.00 0.00 16.00 64% 

Ultimate Parent Level 

Detailed info 2.00 1.00 0.00 0.00 3.00 100% 

Plant-Level and General information 5.00 1.00 0.00 0.00 6.00 100% Unit-Level Info Estimate from corporate 

info 

10.00 3.00 3.00 0.00 16.00 100% 

TOTAL 40.00 15.00 6.00 2.00 63.00 
6-4 

Table 6-2. Estimated Respondent Hours per Section of the Questionnaire 

Hours by Job Category 

Section 

Estimated 

Number of 

Response 

Elements 

Response Element 

(e.g., Plant, Generating 

Unit, FGD System, etc.) Operating Engineer Engineer Manager Engineer Tech Jr. Acct Financial Manager Cler

Sup

Part A (Total Respondents: 734 Plants) Section 1 through Section 7 

734 Plant 14.00 4.00 0.00 0.00 0.00 

Section 8 734 Plant 4.75 0.75 0.00 0.00 0.00 Section 9 through 11 734 Plant 6.25 2.50 0.00 0.00 0.00 Section 12 495 Plant 4.00 0.75 0.00 0.00 0.00 Part A Total 29.00 8.00 0.00 0.00 0.00 Part B a (Total Respondents: 546 Plants) Section 1 through Section 3 

242 Plant a 6.00 1.25 0.00 0.00 0.00 

Section 4 259 FGD System a 8.00 1.25 0.00 0.00 0.00 Section 5 and Section 7 259 FGD System a 4.00 1.25 0.00 0.00 0.00 Section 6 55 FGD System a 3.50 0.00 0.00 0.00 0.00 Section 8 68 FGD System a 6.75 1.25 0.00 0.00 0.00 Part B Total 28.25 5.00 0.00 0.00 0.00 Part C (Total Respondents: 546 Plants) Section 1 530 Plant 1.50 0.50 0.00 0.00 0.00 Section 2 (2.1 through 2.7) 642 Fly Ash Handling System b 19.00 3.50 0.00 0.00 0.00 Section 2 (2.2 only) 1296 Generating Unit 1.50 0.50 0.00 0.00 0.00 Section 3 (3.1 through 3.7) and Section 4 (4.1 through 4.3) 

530 Bottom Ash Handling 

System b 

16.00 2.75 0.00 0.00 0.00 

Section 3 (3.2 only) 1296 Generating Unit 1.50 0.50 0.00 0.00 0.00 Section 4 1296 Generating Unit 1.25 0.50 0.00 0.00 0.00 Section 5 1296 Generating Unit 1.25 0.50 0.00 0.00 0.00 Part C Total 42.00 8.75 0.00 0.00 0.00 
6-5 

Table 6-2. Estimated Respondent Hours per Section of the Questionnaire 

Hours by Job Category 

Section 

Estimated 

Number of 

Response 

Elements 

Response Element 

(e.g., Plant, Generating 

Unit, FGD System, etc.) Operating Engineer Engineer Manager Engineer Tech Jr. Acct Financial Manager Cler

Sup

Part D (Total Respondents: 546 Plants) Section 1 and Section 2 530 Plant 3.75 1.25 0.00 0.00 0.00 Section 3 619 Pond/Impoundment/WWT 

System c 

8.25 2.00 0.00 0.00 0.00 

Section 4 573 Ponds/Impoundment c 7.25 2.00 0.00 0.00 0.00 Section 5 46 WWT System c 7.50 1.25 0.00 0.00 0.00 Section 6 608 Pond/Impoundment/WWT 

System c 

6.75 1.75 0.00 0.00 0.00 

Part D Total 33.50 8.25 0.00 0.00 0.00 Part E (Total Respondents: 327 Plants) Section 1 and Section 2 772 Generating Unit 2.75 0.75 0.00 0.00 0.00 Section 3 772 Generating Unit 2.25 0.75 0.00 0.00 0.00 Part E Total 5.00 1.50 0.00 0.00 0.00 Part F (Total Respondents: 97 Plants) Section 1 and 2 140 Pond d 4.75 1.50 0.00 0.00 0.00 Section 3 55 Landfill d 5.75 1.50 0.00 0.00 0.00 Section 4 9 Leachate Treatment 

System e 

15.50 4.00 0.00 0.00 0.00 

Section 5 195 Pond and Landfill d 3.25 1.25 0.00 0.00 0.00 Part F Total 29.25 8.25 0.00 0.00 0.00 Part G (Total Respondents: 97 Plants) Lab Procurement 30 Plant 0.00 18.00 6.00 0.00 0.00 Sample Collection 204 Sample e 8.00 0.00 14.00 0.00 0.00 Data Entry and Submittal 204 Sample e 0.00 2.00 8.00 0.00 0.00 Part G Total 8.00 20.00 28.00 0.00 0.00 
6-6 

Table 6-2. Estimated Respondent Hours per Section of the Questionnaire 

Hours by Job Category 

Section 

Estimated 

Number of 

Response 

Elements 

Response Element 

(e.g., Plant, Generating 

Unit, FGD System, etc.) Operating Engineer Engineer Manager Engineer Tech Jr. Acct Financial Manager Cler

Sup

Part H (Total Respondents: 734 Plants) Section 1 21 Plant 2.25 1.25 0.00 0.00 0.00 Section 2 21 Plant 4.25 1.25 0.00 0.00 0.00 Section 3 21 Plant 3.50 1.25 0.00 0.00 0.00 Part H Total 10.00 3.75 0.00 0.00 0.00 Part I (Total Respondents: 734 Plants) Section 1 and Section 2 734 Plant 0.00 0.00 0.00 27.50 11.50 Part I Total 0.00 0.00 0.00 27.50 11.50 

a – For purpose of this burden calculation, EPA estimated the number of plants that currently operate and/or plan to operate FGD systemoperating wet/dry FGD systems in the industry, and the estimated number of wet FGD systems that have scrubber purge data available. system estimates were developed by observing trends in the industry. The following estimates were determined using the 2007 EIA dat

Electric Detailed Study. b – Part C of this questionnaire is based on the number of ash handling systems (both fly and bottom) that a facility operates. EPA estim

and petroleum coke-fired power plants have 1 fly ash and 1 bottom ash handling system. After reviewing facility data, EPA estimated toperate two fly ash handling systems (both wet and dry) in order to estimate industry burden. c – EPA used the number of ponds/impoundments reported to the ORCR ICR, for all facilities in the respondent universe. EPA estimatoperating wastewater treatment systems using data from site visits and the Steam Electric Detailed Study. Estimates for planned wastewwere developed by observing trends for planned wet FGDs in the industry. d – EPA estimated the number of ponds and landfills for the statistical subset or coal- and all of petroleum coke-fired power plants usinTable B-5, in Part B of the Supporting Statement. Petroleum coke plants, selected for the statistical subset (3), were assumed to be in thPond" category. For the purpose of this burden, EPA estimated 2 ponds for each facility identified as having a pond and 1 landfill for eahaving a landfill. e – EPA used Supporting Statement Part B Table B-5 information to gather information on plants having ponds, landfills, or both. EPA plants would collect leachate and that 25% of those plants would have a segregated leachate treatment system. Petroleum coke plants, ssubset (3), were assumed to be in the "Both Landfill and Pond" category. All numbers were multiplied by 4 to estimate the number of p204 samples correspond to 51 individual sample points. 
6-7 

Table 6-3. Estimated Respondent Hours per Part of the Questionnaire 

Hours by Job Category 

Part Operating Engineer Engineer Manager Engineer Tech Jr. Acct Financial Manager Clerical Support Legal 

Part A 20,330 5,693 0 0 0 3,431 Part B 5,212 1,035 0 0 0 966 Part C 28,601 6,562 0 0 0 2,609 Part D 15,698 4,168 0 0 0 1,548 Part E 3,860 1,158 0 0 0 386 Part F 1,755 572 0 0 0 288 Part G 1,632 948 4,668 0 0 0 Part H 210 79 0 0 0 16 Part I 0 0 0 20,185 8,441 2,936 Total 77,297 20,214 4,668 20,185 8,441 12,178 

Table 6-4. Estimated Respondent Burden (Hourly) per Type of Plant 

Type of Plant Part of Statistical Subset Questionnaire Part(s) 

Es

Coal Yes A through I 

No A, B, C, D, H, I 

Yes a Petroleum Coke A through I 

No a A, B, C, D, H, I 

Oil Yes A through E, H, I Gas b Yes A, E, H, I Nuclear Yes A, E, H, I Combination Yes A through E, H, I 

a – Petroleum coke facilities identified as small entities will not be included in the sample frame for the statistical subset receiving Partb – Gas plants are not expected to incur burden associated with Part H. 
6-8 

6(b) Estimating Respondent Costs 

(i) Estimating Labor Costs 

EPA obtained mean labor rates for the steam electric industry from the May 2009, U.S. 

Department of Labor, Bureau of Labor Statistics: 2008 National Occupational Employment and 

Wage Data publication. EPA used the Employment Cost Index (ECI) to adjust May 2008 wages 

to September 2009 wages (the most recently available wage data). EPA also assumed 30% 

increase for overhead and benefits. Table 6-5 presents the adjusted labor data for 2009. 

Table 6-5. 2009 Labor Rate Data 

Job Category 

Operating 

Engineer 

Engineer 

Manager 

Engineer 

Tech Jr. Acct 

Financial 

Manager 

Clerical 

Support Legal 

Mean Hourly 

Earnings ($/hour) 

57.48 77.80 36.49 42.48 71.39 20.33 80.50 

The direct labor cost to respondents to complete the questionnaire equals the time 

required to read through and understand all of the instructions, develop a data gathering plan, 

gather data, transfer it to the questionnaire, review/check the responses, collect wastewater 

samples, and report analytical results. Non-labor costs are discussed in Section 6(b)(ii). 

EPA calculated the estimated respondent burden using the estimated total response time 

per part shown in Table 6-3 and the labor rates shown in Table 6-5 to calculate a total labor cost 

of $8,011,899 shown in Table 6-6. 

(ii) Estimating Capital/Start-up Operating and Maintenance Costs 

EPA estimates there will be other direct costs associated with responding to Part G of the 

questionnaire. Plants required to collect and analyze samples will need to purchase supplies and 

equipment, including bottles, sampling collection equipment, sample packing supplies, and 

pumps. The plants will also have to analyze the samples collected for certain analytes, according 

to specified laboratory analytical methods, and will incur costs to procure these services and ship 

samples to the laboratory(ies). EPA estimates that approximately 204 samples will be collected 

by plants subject to this part of the questionnaire. EPA estimated this number by using Table B-5 

in Part B of the Supporting Statement. The number of sampling points estimated is based on the 

number of plants having ponds, landfills, or both. EPA estimated that 30% of the plants would 

collect leachate and that 25% of the plants with leachate collection also operate a segregated 

leachate treatment system. EPA also assumed that all petroleum coke plants would have both a 

landfill and a pond for the purpose of this burden estimate. All points were multiplied by 4 to 

estimate for the 4 weeks of sampling. 

Other costs for completing the questionnaire include photocopying and shipping. 

Respondents will complete an electronic version of the questionnaire (CD/DVD), which will 

reduce burden and ensure efficient transfer of data. EPA assumes the respondents will incur a 

photocopying rate of $0.10 per page if a paper copy is printed out for use as a working copy, but 

they will incur no photocopying cost if no working copy is printed. EPA also assumes that 

industry will return the completed questionnaire (CD/DVD) via Federal Express or a comparable 

delivery carrier that require a signature to acknowledge receipt. 
6-9 

Table 6-6. Total Estimated Respondent Burden 

Labor Cost by Job Category 

Part Operating Engineer Engineer Manager Engineer Tech Jr. Acct Financial Manager Clerical Support Legal 

Part A 1,168,599.89 442,900.12 0.00 0.00 0.00 69,761.17 0Part B 299,565.09 80,523.76 0.00 0.00 0.00 19,631.13 0Part C 1,644,029.78 510,489.51 0.00 0.00 0.00 53,047.77 0Part D 902,316.61 324,273.46 0.00 0.00 0.00 31,464.71 0Part E 221,878.78 90,093.25 0.00 0.00 0.00 7,848.39 0Part F 100,851.38 44,521.47 0.00 0.00 0.00 5,845.62 0Part G 93,809.89 73,755.09 170,341.49 0.00 0.00 0.00 0Part H 12,071.13 6,126.81 0.00 0.00 0.00 320.24 0Part I 0.00 0.00 0.00 857,398.77 602,565.52 59,696.53 118,17Total 4,443,122.55 1,572,683.47 170,341.49 857,398.77 602,565.52 247,615.55 118,17
6-10 

Tables 6-7 and 6-8 below, represent the total Capital/Start-up Operating and Maintenance 

Costs for the questionnaire and for sampling. 

Table 6-7. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire 

Number of 

Respondents 

Total Photocopying 

Cost 

Total 

Shipping Cost 

Total 

Telephone Cost 

Total File 

folder/label Cost Total 

734 $12,478 $3,303 $426 $734 $16,941 

Table 6-8. Total Capital/Start-up Operating and Maintenance Costs for Sampling 

Number of 

Sampling 

Points 

Number of 

Sampling 

Plants 

Total Supplies 

Cost 

Total Shipping 

Cost 

Total 

Analytical 

Testing Cost Total 

204 30 $396,780 $21,600 $781,728 $1,200,108 

(iii) Annualizing Capital Costs 

EPA estimates that there will be no capital costs associated with responding to the 

questionnaire. 

(iv) Estimating Agency Burden and Costs 

Table 6-9 presents an estimate for the total capital/start-up O&M costs incurred by the 

Agency. These initial capital and O&M costs should include purchasing and preparing 734 

electronic copies of the questionnaire and the shipping costs associated with mail out of the 

questionnaire. 

Table 6-9. Total Capital/Start-up Operating and Maintenance Costs for the Questionnaire

Number of Respondents 

Total Questionnaire 

Distribution Cost Total Shipping Cost Total 

734 $1,837 $3,303 $5,140 

Table 6-10 presents an estimate of the burden and labor costs that EPA will incur to 

administer the questionnaire. The table identifies the collection administration tasks to be 

performed by EPA employees and contractors, with the associated hours required for each 

grouping of related tasks. EPA determined Agency labor costs by multiplying Agency burden 

figures by an average hourly Agency labor rate for technical and managerial support using the 

Salary Table 2009-GS from the U.S. Office of Personal Management. This table can be found at 

the Web site http://www.opm.gov/oca/09tables/indexGS.asp. The government employee labor 

rates are $33.84 per hour for technical (GS-13, Step1) and $47.03 per hour for managerial 

(GS-15, Step 1). EPA determined contractor labor costs by multiplying contractor burden figures 

by an average contract labor rate of $80 per hour. This rate is consistent with current Agency 

contracts. 
6-11 

Table 6-10. Agency Burden and Costs 

Burden (hours) Labor Cost 

Activities Agency Contractor

Total 

Hours 

Agency 

($40.44/hr) 

Contractor 

($80/hr) Total Cost

Develop the questionnaire 

instruments; Provide the draft 

questionnaire instruments to 

industry for review 

Meet with trade association 

representatives 

Publish notice of anticipated ICR 

in Federal Register 

Respond to all comments 

received 

Revise Questionnaire instruments 

based on reviewer’s comments 

300 2,000 2,300 $12,131 $160,000 $172,131 

Design sampling approach 

Develop a mailing list database 

Develop a system to track 

mailing/e-mailing and receipt 

activities 

Mail questionnaire files 

200 920 1,120 $8,087 $73,600 $81,687 

Develop and maintain e-mail 

helpline 

120 1200 1,320 $4,852 $96,000 $100,852 

Maintain response tracking 

system 

Implement appropriate 

procedures for handling CBI 

responses 

Review responses and collect 

missing data 

Engineering and economic 

followup to clarify responses to 

questionnaires 

800 24,700 25,500 $32,348 $1,976,000 $2,008,348 

Develop questionnaire database 

Upload and verify data 

40 1,800 1,840 $1,617 $144,000 $145,617 

Total 1,460 30,620 32,080 $59,035 $2,449,600 $2,508,635 

6(c) Estimating the Respondents Universe and Total Burden Costs 

EPA expects to receive 734 completed questionnaires. EPA estimates a total burden of 

144,451 hours and a total labor and O&M costs of $ 9,228,948 for all respondents. 

6(d) Bottom Line Burden Hours and Costs 

Tables 6-11 through 6-13 summarize the total costs that the steam electric industry and 

the Agency will incur as a result of the ICR. 
6-12 

Table 6-11. Total Estimated Respondent Burden and Cost Summary 

Number of 

Respondents 

Total Burden 

(Hours) Total Labor Cost Total O&M Cost Total Cost 

734 144,451 $8,011,899 $1,217,049 $9,228,948 

Table 6-12. Total Estimated Agency Burden and Cost Summary 

Total Burden (Hours) Total Labor Cost Total O&M Cost Total Cost 

32,080 $2,508,635 $5,140 $2,513,775 

Table 6-13. Annual Estimated Burden and Cost Summary 

Entity Total Burden (Hours) Total Labor Cost Total O&M Cost Total Cost 

Industry Burden 48,150 $2,670,633 $405,683 $3,076,316 

Agency Burden 10,693 $836,212 $1,713 $837,925 

6(e) Reasons for Change in Burden 

Not applicable. This is a new collection. 

6(f) Burden Statement 

EPA estimates that the total burden to the 734 steam electric power plants for responding 

to the questionnaire will be approximately 197 hours per response. Burden means the total time, 

effort, or financial resources expended by persons to generate, maintain, retain, or disclose or 

provide information to or for a federal agency. This includes the time needed to review 

instructions; develop, acquire, install, and utilize technology and systems to collect, validate, and 

verify information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to respond to a collection of information; search 

data sources; complete and review the collection of information; and transmit or otherwise 

disclose information. An agency may not conduct or sponsor, and a person is not required to 

respond to, a collection of information unless it displays a currently valid OMB control number. 

The OMB control number for EPA’s regulations are listed in 40 CFR part 9 and 48 CFR chapter 

15. 

To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, including the 

use of automated collection techniques, EPA has established a public docket for this ICR under 

Docket ID No. EPA-HQ-OW-2009-0819, which is available for online viewing at 

www.regulations.gov, or in person viewing at the Water Docket in the EPA Docket Center 

(EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA 

Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through 

Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-

1744, and the telephone number for the Water Docket is (202) 566-2426.An electronic version of 

the public docket is available at www.regulations.gov. This site can be used to submit or view 

public comments, access the index listing of the contents of the public docket, and to access 
6-13 

those documents in the public docket that are available electronically. Once in the system, select 

“search” then key in the Docket ID number identified above. Also, you can send comments to 

the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th

Street, NW, Washington, DC. 20503, Attention: Desk Officer for EPA. Please include the EPA 

Docket ID No. EPA-HQ-OW-2009-0819 and OMB Control No. 2040-NEW in any 

correspondence.