MEMORANDUM 

TO: Bill Swietlik, EPA 

FROM: Joanna Kind, ERG 

DATE: April 19, 2013 

SUBJECT: Site-Specific Estuary Dilution Analysis (DCN SE03577) 

1.0 INTRODUCTION

 ERG is providing technical support to the U.S. Environmental Protection Agency (EPA) 

for development of revised effluent limitations guidelines and standards (ELGs) for the Steam 

Electric Power Generating Point Source Category. In support of the development of revised 

ELGs, ERG developed a water quality model to calculate surface water concentrations for the 

majority of receiving waters (e.g., lakes and streams). The water quality model, however, is not 

designed to account for the complex hydrodynamics found in estuarine or large lake settings 

(e.g., varying inputs from upstream freshwater and downstream saltwater bodies). This 

memorandum describes an alternative, site-specific estuary dilution analysis for estimating 

pollutant concentrations in receiving waters that are estuaries or Great Lakes. ERG 

recommended using critical dilution factors (CDFs) to model surface water concentrations of 

these systems. This approach is based on the methodology used for modeling surface water 

concentrations of estuaries and bays in the Environmental Assessment (EA) for the proposed 

ELGs for the centralized waste treatment industry (U.S. EPA, 1998). 

 ERG examined baseline conditions and four regulatory options (see Table 1-1) for four 

evaluated waste streams (flue gas desulfurization (FGD) wastewater, fly ash transport water, 

bottom ash transport water, and leachate). ERG evaluated the following metals in this analysis: 

total arsenic, total cadmium, total chromium VI, total copper, total lead, total mercury, total 

nickel, total selenium, total thallium, and total zinc. 

Table 1-1. Regulatory Options Evaluated in the Site-Specific Estuary Dilution Analysis a

Waste Stream First Option Second Option Third Option Fourth Option 

FGD Wastewater Chemical 

Precipitation 

Chemical 

Precipitation + 

Biological 

Treatment 

Chemical 

Precipitation + 

Biological 

Treatment 

Chemical Precipitation + 

Biological Treatment 

Fly Ash Transport 

Water 

Same as baseline Same as baseline Dry handling Dry handling 

Bottom Ash 

Transport Water 

Same as baseline Same as baseline Same as baseline Dry handling/closed loop 
Memorandum 

April 19, 2013 

Page 2 

Table 1-1. Regulatory Options Evaluated in the Site-Specific Estuary Dilution Analysis a

Waste Stream First Option Second Option Third Option Fourth Option 

Leachate Same as baseline Same as baseline Same as baseline With FGD wastewater: 

Chemical Precipitation + 

Biological Treatment 

Without FGD wastewater: 

Chemical Precipitation 

a – The regulatory options evaluated as part of this analysis have since been revised for the proposed ELG. This 

table presents the four draft options evaluated for this analysis, which do not directly correspond to the regulatory 

scenarios evaluated in the final EA. See the Environmental Assessment for the Proposed Effluent Limitations 

Guidelines and Standards for the Steam Electric Power Generating Point Source Category (EA Report) (DCN 

SE01995) for the proposed regulatory options and EA results. 

2.0 METHODOLOGY

 Based on survey responses, ERG identified 241

 plants discharging an evaluated waste 

stream to either an estuary or one of the Great Lakes. ERG used Equation 2-1 below to calculate 

a site-specific CDF for each plant/receiving water combination for these 24 plants. This 

calculation is based on the dissolved concentration potential (DCP) of a water body. A DCP 

value is a measure of the potential concentration of a dissolved pollutant throughout the entire 

estuary under well-mixed steady-state conditions. A high DCP value generally suggests an 

estuary is likely to concentrate a dissolved pollutant loading whereas a low DCP suggests an 

estuary has a high probability of diluting the pollutant loading due to either large estuarine 

volumes and/or flushing ability from tidal or riverine influences. EPA obtains DCPs for estuaries 

and bays from the Strategic Assessment Branch of the National Oceanic and Atmospheric 

Administration (NOAA)’s Ocean Assessments Division (EPA, 1998 and Versar Inc., 1992). 

Based on these values, ERG identified a receiving water specific DCP value for 16 of the 24 

plants [See Table A-1 in Attachment A].The DCP values ranged from 0.0042 milligrams per liter 

(mg/L) to 0.52 mg/L. 

EQUATION 2-1 

CDF=

BL·CF1

DCP·OD·FF·CF2

where: 

CDF = Critical dilution factor (unitless) Output from 

Equation 2-1 

BL = Benchmark load (tons/year) Assumed value of 

10,000 tons/yeara

DCP = Dissolved concentration potential (mg/L) U.S. EPA, 1998b

; 

Versar Inc., 1992b

OD = Power plant operation (days/year) Assumed value of 

365 days/year

 

1

 At the time of this analysis, the number of potentially regulated facilities that discharged to an estuary or Great 

Lake was 24. In the final EA, the number of potentially regulated facilities that discharged to an estuary or Great 

Lake fell to 20. 
Memorandum 

April 19, 2013 

Page 3 

FF = Effluent flow from power plant (gallons/day [gal/day])

Survey data 

Question A2-5 

(U.S. EPA, 2013a)

CF1 = 907.185 (kg/ton) Conversion factor

CF2 = 2.64 x 10-7 (kg • gal/mg • L) = 10-6 (kg/mg) × 0.264 (gal/L) Conversion factor 

a - NOAA calculates the water body DCP based on an assumed annual pollutant load of 10,000 tons 

(Versar Inc., 1992). 

b - The DCP values are based on an average across the water body and do not represent the concentration 

in the immediate discharge zone. 

Next, ERG used Equation 2-2 to calculate a total pollutant concentration for each water 

body using baseline and regulatory option loadings. 

EQUATION 2-2 

Ces= FF CF

CDF

where: 

Ces = Receiving water pollutant concentration (milligrams per liter 

[mg/L]) 

Output from 

Equation 2-2 

Ltotal = Total metal loading to receiving water from steam effluent 

(grams per day [g/day]) 

Calculated for this 

analysis (see 

Tables A-3 

through A-12)a

FF = Effluent flow from power plant (gal/day) 

Survey data, 

Question A2-5 

(U.S. EPA, 2013a)

CDF = Critical dilution factor (unitless) Calculated in 

Equation 2-1

CF3 = 264 (mg • gal /g • L) = 103 (mg/g) × 0.264 (gal/L) Conversion factor

a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 

These were interim loadings that do not correspond to the final loadings values used in support of the 

proposed ELGs; however, ERG determined that the change in loadings did not warrant revision of the 

analysis, because the conclusions would remain the same. 

 The tables presented in Attachment A present the input values used for Equations 2-1 and 

2-2. The tables presented in Attachment B present the output values calculated using Equations 

2-1 and 2-2. 

 After calculating the total pollutant concentrations in the identified estuarine or Great 

Lake receiving waters, ERG compared the concentrations at baseline conditions and following 

the implementation of the four regulatory options to the following benchmarks: 

 National Recommended Water Quality Criteria (NRWQC) for Fresh Water Chronic 

Aquatic Life Criteria for total selenium; 
Memorandum 

April 19, 2013 

Page 4 

 NRWQC for Human Health – Organism Only Criteria for total arsenic, total nickel, total 

selenium, total thallium, and total zinc; 

 NRWQC for Human Health – Water & Organism for total arsenic, total copper, total 

nickel, total selenium, total thallium, and total zinc; and 

 Drinking Water Maximum Contaminant Level (MCL) for total arsenic, total cadmium, 

total chromium2

, total copper, total lead, total mercury, total selenium, and total thallium. 

The benchmarks are presented in Table C-1 in Attachment C. 

3.0 RESULTS AND CONCLUSIONS

 The results of the analysis are presented in Attachment B. Tables B-2 through B-11 

present the receiving water pollutant concentrations for the baseline and regulatory options for 

each pollutant for the 16 plants included in the analysis (DCP values were not available for the 

other 8 plants that discharge to estuaries or the Great Lakes). It is important to note that this 

analysis served as a screening tool to determine if discharges of the evaluated waste streams 

result in elevated surface water pollutant concentrations throughout the receiving water body 

(i.e., concentrations that exceed various benchmarks used in the EA). At this screening level, 

ERG made simplifying assumptions that potentially overestimate the calculated concentrations. 

Despite these assumptions, calculated concentrations are well below all identified benchmarks. 

This result is not unexpected as the analysis considers only steam electric discharges and does 

not account for other point, non-point, and background sources and pollutant concentrations. 

Based on the results of this analysis, ERG and EPA determined that the impact of steam electric 

power plant discharges on estuary and Great Lake systems would be better evaluated by 

comparing their discharges to other industrial and point source discharges to these systems. The 

EA Report compares the pollutant loadings from steam electric plants to other point source 

discharges into the Chesapeake Bay (estuary) watershed and the Great Lakes watershed. 

4.0 REFERENCES

U.S. EPA. 1998. Environmental Assessment For The Proposed Effluent Limitations Guidelines, 

Pretreatment Standards, And New Source Performance Standards For The Centralized Waste 

Treatment Industry. EPA 821-R-98-017. Washington, D.C. 

U.S. EPA. 2009a. National Recommended Water Quality Criteria. Washington, DC. DCN 

SE01908. 

U.S. EPA. 2009b. National Primary Drinking Water Regulations. EPA 816-F-09-004. 

Washington, DC. (May). DCN SE01909. 

 

2

 For this analysis, ERG estimated the concentration of chromium VI in the estuary and compared that value to the 

total chromium MCL. 
Memorandum 

April 19, 2013 

Page 5 

U.S. EPA. 2013a. Steam Electric Technical Questionnaire Database. Washington, DC. DCN 

SE01958. 

U.S. EPA. 2013b. Site-Specific Estuary Dilution Analysis Documentation Database. 

Washington, DC. DCN SE02152A1. 

Versar, Inc. 1992. Mixing Zone Dilution Factors for New Chemical Exposure Assessments. 

Draft Report. Contract 68-D9-0166. Task 3-35. Springfield, VA.
Attachment A 

April 19, 2013 Page A-1 Attachment A: Inputs for Equations 2-1 and 2-2 

Table A-1. DCP Values for Plants Directly Discharging Evaluated Waste Streams to the Estuaries an

Plant Name Receiving Water Name Receiving Water Type DCP (mg/L) 

B L England Great Egg Harbor Estuary -- Crystal River Energy Complex Gulf of Mexico Estuary 0.46 Tampa Electric - Big Bend Station Hillsborough Bay Estuary -- Ashtabula Power Plant Lake Erie Great Lake 0.2 Avon Lake Power Plant Lake Erie Great Lake 0.2 Bay Shore Plant Lake Erie Great Lake 0.2 Dunkirk Generating Plant Lake Erie Great Lake 0.2 Eastlake Power Plant Lake Erie Great Lake 0.2 JR Whiting Power Plant Lake Erie Great Lake 0.2 Lake Shore Plant Lake Erie Great Lake 0.2 Monroe Power Plant Lake Erie Great Lake 0.2 Harbor Beach Power Plant Lake Huron Great Lake -- Edgewater Generating Station Lake Michigan Great Lake 0.3 JH Campbell Power Plant Lake Michigan Great Lake 0.0042 NIPSCO Bailly Generating Station Lake Michigan Great Lake 0.0042 NIPSCO Michigan City Generating Station Lake Michigan Great Lake 0.0042 Oak Creek Power Plant Lake Michigan Great Lake 0.3 Pleasant Prairie Power Plant Lake Michigan Great Lake 0.3 Waukegan Station Lake Michigan Great Lake -- AES - Somerset Lake Ontario Great Lake -- Presque Isle Power Plant Lake Superior Great Lake -- Brayton Point Station Mount Hope Bay Estuary 0.52 DE Karn Power Plant Saginaw Bay Estuary -- JC Weadock Power Plant Saginaw Bay Estuary -- 

Source: U.S. EPA, 2013b. 
Attachment A 

April 19, 2013 Page A-2 

Table A-2. Effluent Flows for Plants Directly Discharging Evaluated Waste Streams to Estuaries an

Plant Name Receiving Water Name 

Effluent Flowa (gal/day) 

Baseline 

First 

Option 

Second 

Option 

T

O

B L England Great Egg Harbor 

[Confidential Business Information (CBI) ha

this document.] 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 effluent flows. 
Attachment A 

April 19, 2013 Page A-3 

Table A-3. Total Arsenic Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuarie

Plant Name Receiving Water Name 

Total Arsenic Loada (g/da

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this d

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-4 

Table A-4. Total Cadmium Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuar

Plant Name Receiving Water Name 

Total Cadmium Loada (g/d

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-5 

Table A-5. Total Chromium VI Loadings for Plants Directly Discharging to the Estuaries and G

Plant Name Receiving Water Name 

Total Chromium VI Loada (g

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. N/A – Chromium VI loads were not calculated for this plant. 
Attachment A 

April 19, 2013 Page A-6 

Table A-6. Total Copper Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuarie

Plant Name Receiving Water Name 

Total Copper Loada (g/da

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-7 

Table A-7. Total Lead Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuaries 

Plant Name Receiving Water Name 

Total Lead Loada (g/day

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-8 

Table A-8. Total Mercury Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuari

Plant Name Receiving Water Name 

Total Mercury Loada (g/d

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-9 

Table A-9. Total Nickel Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuarie

Plant Name Receiving Water Name 

Total Nickel Loada (g/da

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-10 

Table A-10. Total Selenium Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuar

Plant Name Receiving Water Name 

Total Selenium Loada (g/d

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-11 

Table A-11. Total Thallium Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuar

Plant Name Receiving Water Name 

Total Thallium Loada (g/d

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment A 

April 19, 2013 Page A-12 

Table A-12. Total Zinc Loadings for Plants Directly Discharging Evaluated Waste Streams to Estuaries 

Plant Name Receiving Water Name 

Total Zinc Loada (g/day

Baseline 

First 

Option 

Second 

Option 

B L England Great Egg Harbor 

[CBI has been removed from this 

Crystal River Energy Complex Gulf of Mexico Tampa Electric - Big Bend Station Hillsborough Bay Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Ashtabula Power Plant Lake Erie Dunkirk Generating Plant Lake Erie Monroe Power Plant Lake Erie Harbor Beach Power Plant Lake Huron NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan NIPSCO Michigan City Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Waukegan Station Lake Michigan Edgewater Generating Station Lake Michigan AES - Somerset Lake Ontario Presque Isle Power Plant Lake Superior Brayton Point Station Mount Hope Bay JC Weadock Power Plant Saginaw Bay DE Karn Power Plant Saginaw Bay 

Source: U.S. EPA, 2013b. a – For the site-specific estuary dilution analysis, ERG used the November 17, 2011 pollutant loadings. 
Attachment B 

April 19, 2013 Page B-1 Attachment B: Outputs from Equations 2-1 and 2-2 

Table B-1. CDF Values for Plants Directly Discharging Evaluated Waste Streams to Estuaries and 

Plant Name Receiving Water Name 

CDF 

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – For these plants, effluent flow rates of the evaluated waste streams are zero under the fourth option. This results in a CDF of infinity
Attachment B 

April 19, 2013 Page B-2 

Table B-2. Total Arsenic Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuari

Plant Name Receiving Water Name 

Total Arsenic Ces (mg/L

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total arsenic Ces values were compared to the following benchmarks for total arsenic: human health water and organism NRWQ

human health organism NRWQC (0.00014 mg/L), and drinking water MCL (0.01 mg/L). The Ces values did not exceed any of the benc
Attachment B 

April 19, 2013 Page B-3 

Table B-3. Total Cadmium Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuar

Plant Name Receiving Water Name 

Total Cadmium Ces (mg/

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total cadmium Ces values were compared to the drinking water MCL for total cadmium (0.01 mg/L). The Ces values did not exc
Attachment B 

April 19, 2013 Page B-4 

Table B-4. Total Chromium VI Ces Values for Plants Directly Discharging Evaluated Waste Streams to E

Lakes 

Plant Name Receiving Water Name 

Total Chromium VI Ces (m

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total chromium VI Ces values were compared to the drinking water MCL for total chromium (0.005 mg/L). The Ces values did n

N/A – Chromium VI loads were not calculated for this plant. 
Attachment B 

April 19, 2013 Page B-5 

Table B-5. Total Copper Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuari

Plant Name Receiving Water Name 

Total Copper Ces (mg/L

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total copper Ces values were compared to the following benchmarks for total copper: human health water and organism NRWQ

water MCL (1.3 mg/L). The Ces values did not exceed any of the benchmarks. 
Attachment B 

April 19, 2013 Page B-6 

Table B-6. Total Lead Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuarie

Plant Name Receiving Water Name 

Total Lead Ces (mg/L) 

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total lead Ces values were compared to the drinking water MCL for total lead (0.015 mg/L). The Ces values did not exceed this b
Attachment B 

April 19, 2013 Page B-7 

Table B-7. Total Mercury Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuar

Plant Name Receiving Water Name 

Total Mercury Ces (mg/L

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total mercury Ces values were compared to the drinking water MCL for total mercury (0.002 mg/L). The Ces values did not exce
Attachment B 

April 19, 2013 Page B-8 

Table B-8. Total Nickel Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuarie

Plant Name Receiving Water Name 

Total Nickel Ces (mg/L) 

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total nickel Ces values were compared to the following benchmarks for total nickel: human health water and organism NRWQC 

health organism NRWQC (4.6 mg/L). The Ces values did not exceed any of the benchmarks. 
Attachment B 

April 19, 2013 Page B-9 

Table B-9. Total Selenium Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuar

Plant Name Receiving Water Name 

Total Selenium Ces (mg/L

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total selenium Ces values were compared to the following benchmarks for total selenium: freshwater chronic NRWQC (0.005 m

and organism NRWQC (0.17 mg/L), human health organism NRWQC (4.2 mg/L), and drinking water MCL (0.05 mg/L). The Ces value

the benchmarks. 
Attachment B 

April 19, 2013 Page B-10 

Table B-10. Total Thallium Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuar

Plant Name Receiving Water Name 

Total Thallium Ces (mg/L

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total thallium Ces values were compared to the following benchmarks for total thallium: human health water and organism NRW

human health organism NRWQC (0.00047 mg/L), and drinking water MCL (0.002 mg/L). The Ces values did not exceed any of the ben
Attachment B 

April 19, 2013 Page B-11 

Table B-11. Total Zinc Ces Values for Plants Directly Discharging Evaluated Waste Streams to Estuarie

Plant Name Receiving Water Name 

Total Zinc Ces (mg/L) 

Baseline 

First 

Option 

Second 

Option 

Crystal River Energy Complex Gulf of Mexico 

[CBI has been removed from this 

Ashtabula Power Plant Lake Erie Bay Shore Plant Lake Erie Avon Lake Power Plant Lake Erie Eastlake Power Plant Lake Erie Lake Shore Plant Lake Erie JR Whiting Power Plant Lake Erie Monroe Power Plant Lake Erie Dunkirk Generating Plant Lake Erie NIPSCO Michigan City Generating Station Lake Michigan NIPSCO Bailly Generating Station Lake Michigan JH Campbell Power Plant Lake Michigan Pleasant Prairie Power Plant Lake Michigan Edgewater Generating Station Lake Michigan Oak Creek Power Plant Lake Michigan Brayton Point Station Mount Hope Bay 

Source: U.S. EPA, 2013b. a – The total zinc Ces values were compared to the following benchmarks for total zinc: human health water and organism NRWQC (7.

organism NRWQC (2.6 mg/L). The Ces values did not exceed any of the benchmarks. 
Attachment C 

April 19, 2013 Page C-1 Attachment C: Benchmarks for Comparison to Calculated Ces Values 

Table C-1. NRWQC and MCL Benchmarks 

Pollutant Freshwater Chronic NRWQCa (mg/L) Human Health Water and Organism NRWQCa (mg/L) Human Health Organism NRWQCa (mg/L) 

Total Arsenic - 0.000018 0.00014 Total Cadmium - - - Total Chromiumc - - - Total Copper - 1.3 - Total Lead - - - Total Mercury - - - Total Nickel - 0.61 4.6 Total Selenium 0.005 0.17 4.2 Total Thallium - 0.00024 0.00047 Total Zinc - 7.4 26 

a – National Recommended Water Quality Criteria. Washington, D.C. [U.S. EPA, 2009a]. b – National Primary Drinking Water Regulations. EPA 816-F-09-004. May. Washington, D.C. [U.S. EPA, 2009b]. c – For this analysis, ERG estimated the concentration of chromium VI in the estuary or Great Lake and compared that value to the total chromium M