Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 1 of 44Question # Question ResponseGeneral What accuracy is required on reported latitude andlongitude throughout the questionnaire? Is the 15 secondaccuracy required by my NPDES permit sufficient?The accuracy required for your NPDES permit is sufficient for thequestionnaire.Q A1-6 The coal-fired power plant has recently been retired andreplaced with new gas turbines and a new combined cycleplant. Should we answer "yes" to this question?Although the coal-fired generating units have been retired, answer“no” to Question A1-6, because the plant has not been retired.Q A1-6 The plant will be out of operation by the end of 2010, butthere may still be activity onsite after the December 31,2011 deadline. These activities will likely includecleanup, demolition, material loading, landfill closure,etc. Would the plant still qualify under “permanentlyretired” since the plant will not be producing power by thedeadline, even though it can technically be "switched"back on?A plant is generally considered to be permanently retired if thefacility is unable to generate electricity and there is no intention oftaking steps to establish that capability, or if it has ceased generatingelectricity and will not generate electricity in the future. Mothballedplants are not permanently retired. A claim that the plant will bepermanently retired should not be made lightly. The respondent isreminded that in certifying the questionnaire, they are also certifyingthe veracity of the claim that the plant is or will be permanentlyretired.Q A1-6 If a plant is permanently retired before the December 31,2011 deadline, what parts of the questionnaire must bereturned?If a plant is permanently retired before the December 31, 2011, theplant only has to complete A1-1 through A1-6 and the certificationstatement.Part AVersion 3August 27, 2010Frequently Asked Questions - TechnicalP. 2 of 44Question # Question ResponseQ A1-8 We are currently in the process of making conversions tothe plant and have no intention to use fossil fuel in thefuture. However, we used coal in 2009. Should Icontinue to fill out the questionnaire or should I stop afterthe completion of this question?Although the plant has no intention of using fossil fuels in thefuture, the plant used coal as a fuel source in 2009; therefore, youshould continue to fill out the questionnaire on the operations of theplant in 2009. Please complete as much of the questionnaire aspossible for the time in 2009 that the plant used fossil fuels, and adda comment to Part A to elaborate on your current operations.A1-8 If the plant uses a little natural gas, but primarily usesblast furnace gas, what should they report?They should select "gas" and add a comment in the comments pagefor the use of blast furnace gas.A1-8 If the plant is a coal-fired plant, but oil is used for start-upand stabilization, should I mark oil in Question A1-8?Fuels only used for start up or in emergency generators should notbe reported in Question A1-8. If the plant uses a secondary fuel forother purposes (including stabilization that is not associated withstart-up activities), mark that fuel in Question A1-8.A1-8 If a plant produced power during testing andcommissioning activities in 2009, but was notcommercially operational until 2010, how should theyanswer question A1-8?Because the plant was not in commercial operation until 2010, theyshould select "None" in question A1-8 and not complete theremainder of the questionnaire.A1-8 throughA1-14Should the plant include information for just the steamunit or for both the steam unit and the combustion turbinewhen answering these questions?The plant should include information for both the steam unit and forthe combustion turbine when answering questions A1-8 and A1-14.A1-10 If the facility only has one NAICS code, what do we putunder secondary and tertiary codes?If the facility only has one NAICS code, you may leave the answerblank for the secondary and tertiary codes.A1-10 How can a facility identify their NAICS code? Information about NAICS codes can be found atwww.census.gov/eos/www/naics/.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 3 of 44Question # Question ResponseA1-11 The plant's primary purpose is to provide thermal energy,but the electric generation revenue is greater than therevenue provided by thermal energy. How shouldquestion A1-11 be answered?For the purpose of this questionnaire, a plant that receives more thanhalf of its revenue from the sale of electricity has the primarypurpose of electric generation.A1-11 The plant's primary purpose is the production of processsteam to local paper mills, with electrical generation as abyproduct. How should question A1-11 be answered?For the purpose of this questionnaire, a plant that receives more thanhalf of its revenue from the sale of electricity has the primarypurpose of electric generation.A2-1 For Question A2-1 should the plant name (as listed in EIAForm 860, Schedule 2, Line 1) be provided or should theEIA Code number (listed in EIA Form 860 above Line 1)be provided?Provide the EIA Plant Identification Code, not the plant name.Section 2.2 My facility does not record outfall locations ingeographical coordinates (latitude and longitude), but inGPS UTM (Universal Transverse Mercator) coordinates.If your facility does not have the latitude and longitude coordinatesfor the outfalls at your facility, check your NPDES permit. If yourNPDES permit only reports the outfall locations in GPS UTMcoordinates, please convert the coordinates to latitude and longitude.You may find a UTM/geographic coordinate converter through anInternet search (one example ishttp://home.hiwaay.net/~taylorc/toolbox/geography/geoutm.html).The information required to convert your coordinates is the x, y, andzone of the outfall location. As a simple check, you can enter thegeographical coordinates into Google maps to see if it matches thelocation of your outfall(s).Section 2.2 If the facility did not discharge any flow through itsoutfalls in 2009, what do we enter for flow?Please enter "0" (zero) in the flow answer cells.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 4 of 44Question # Question ResponseSection 2.2 How should this section be completed if the facility hasno NPDES permitted outfalls?Do not complete Part A, Section 2.2 if there are no NPDESpermitted outfalls and state in the comments section that there areno outfalls. However, if the plant has emergency outfalls present andpermitted, such as an emergency outfall for a surface impoundment,you must complete Part A, Section 2.2.Section 2.2 If one of the outfalls at the facility is a storm sewer inletand the plant does not measure the flow rate, how shouldthe plant answer Section 2.2?The plant should estimate this flow and report it in Section 2.2. Youmay reference design flow calculations that were completed whenthe plant storm sewer piping was designed, or you may use thenumber of days of discharge in 2009 with an estimate of the averagestorm event to estimate the stormwater flow. If the plant does notkeep these records, you can estimate flow by using precipitationdata from a local rain gauge (available through USGS) andperforming runoff calculations based on the contributing area of theplant. One method that can be used to calculate runoff is the NRCSCurve Number Method; however, you may choose the method thatis most appropriate for your plant. Report all estimations used in theComments section.Section 2.2 Is the outfall information required in Section 2.2 only forthe individual NPDES permit for industrial activitydischarges, or does it also include the stormwater generalNPDES permit?All general stormwater NPDES permits, such as EPA's Multi-SectorGeneral Permit for Stormwater Discharges Associated withIndustrial Sources, should be designated as "Stormwater" permitsand you do not need to include outfall information from generalstromwater permits in Section 2.2.A2-3 Should a fish impingement study for 316(b) be includedas an environmental assessment in question A2-3?Fish impingement studies from 316(b) do not need to be included inquestion A2-3.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 5 of 44Question # Question ResponseA2-4 If the facility has an industrial discharge permit through aPublicly Owned Treatment Works (POTW) does thiscount as a NPDES permit?No, this permit is not a NPDES permit and does not requirereporting in Question A2-4 (Table A-2) or Section 2.2. However,questions throughout the survey may require the destination of awaste stream to be noted and, where appropriate, the plant shouldselect "Indirect discharge to a publicly or privately owned treatmentworks" (see, for example, Question A9-6).A2-4 Is a TPDES permit the same as a NPDES permit? Yes. The National Pollutant Discharge Elimination System(NPDES) program may be administered by an individual state, suchas Texas, and be referred to by a state name, such as the TexasPollutant Discharge Elimination System (TPDES). However, it isstill a NPDES permit and should be reported as such.A2-4 Are plants required to submit copies of permits inaddition to including permit ID numbers in Table A-2?No, plants are not required to submit copies of their permits.A2-5 If a plant has no flow records for a stormwater discharge,can they leave the flow space blank?No. If you do not have flow records, you should estimate the flowand specify in the comments page the method you used to calculatethe value.A2-5, A3-2,and A4-2Do nuclear facilities still need to providelatitude/longitude for discharges, pond/impoundments,and landfills? There is concern that this information needsto be kept safe from disclosure.An exception will not be provided for these questions. All plants arerequired to provide latitude/longitude for all discharges,ponds/impoundments, and landfills located at the plant. Ifdisclosure of this information is a high concern for nuclear plants,they should claim their response as CBI.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 6 of 44Question # Question ResponseA2-10 For emergency outfalls on stormwater ponds, what shouldbe used for the percentages in Table A-3 if there was noactual discharge in 2009?Base the percentages on the relative contributions of wastewaters inthe pond (e.g., for stormwater ponds, enter 100% stormwater).Enter comments to describe the specific situation if necessary.Section 3 Should sedimentation ponds be reported? If the sedimentation ponds contain process wastewater, thensedimentation ponds should be reported. Note: contaminatedstormwater is considered to be process wastewater.Section 3 Are Questions A3-1 through A3-3 applicable to coolingwater that is sent to a pond/impoundment?For the purpose of this questionnaire, condenser cooling water isconsidered a process wastewater; therefore, any pond/impoundmentcontaining condenser cooling water should be reported.A3-1 Does coal pile runoff need to be included in Table A-4? For the purpose of this questionnaire, coal pile runoff needs to bereported in Table A-4.A-3-2 In Table A-4, what constitutes a liner? Is spreading dirtaround and sloping it, could be considered a liner? Ordoes a liner have to go through a more formal process ofcompaction where porosity, etc. are measured (e.g., like alandfill)?Liners go through a compaction process where a target hydraulicconductivity is achieved. For the purpose of this questionnaire, dirtthat is spread and graded, but not compacted, is not considered aliner.A3-2 How should a pond be reported in Table A-4 if it wastaken out of service, lined, and brought back into serviceat a later date considering the pond had the samefootprint? Additionally, how should a pond be reported ifit was taken out of service, split into two impoundments(same total footprint), lined, and brought back into serviceat a later date?Identify each pond to be entered into Table A-4 based on the plant'scurrent configuration. For the first example, report the pond as linedand enter the year initially brought on line as the year the initialunlined pond was put into service. For the second example, reportthe two individual lined ponds and enter the year initially brought online as the year the original unlined pond was put into service. Adda comment for both ponds to say they were originally one pond.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 7 of 44Question # Question ResponseA3-2 Does a cooling water pond need to be reported? All ponds containing process wastewater (including once-throughcooling water and cooling tower blowdown) need to be included inTables A-4 and A-5. However, cooling water ponds do not need tobe reported in any of the tables in Part D.A3-2 How should a plant report latitude and longitude for apond that has no discharge outlets including noemergency outlets?The plant should provide the latitude and longitude of the ponditself (e.g., center point) and state in the comments section that thepond has no outlets and the coordinates provided are for the ponditself.A3-2 Because the units requested are feet, how specific doesthe reported distance between the pond and the nearestsurface water need to be? For example, if the plant onlyknows this distance is around 10 miles, what should bereported?The plant should report the distance by multiplying the distance inmiles by 5,280 feet.A3-2 Should a thermal mitigation pond only used to cool plantprocess wastewater prior to discharge be included in PartA Section 3?Yes, all pond/impoundment units should be reported in Table A-4,in Part A Section 3.A3-2, A4-2 These questions request the closest distance to the nearestsurface water. What is your definition for surface water?Besides ponds, reservoirs (including cooling waterreservoirs), rivers, where there is water present most ofthe time, would it also include intermittent streams,waterways, or road ditches where water may only bepresent during runoff events?For the purpose of the questionnaire, surface water includeswaterbodies such as reservoirs, lakes, rivers, and streams, includingintermittent streams and other waterways. The road ditch itself isnot considered surface water for the purpose of the questionnaire.The distance to surface water should not be based on the distance tothe road ditch. Note,however, that if water collected in the roadditch ultimately makes its way to a surface water then thewastewater is considered to be discharged to surface water.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 8 of 44Question # Question ResponseA3-3 For Table A-5, what should I do if there are more processwastewaters entering the pond/impoundment than thereare dropdown options available?A plant should use the dropdowns to select the six most prominentprocess wastewaters and use the "other" fields to list all remainingprocess wastewaters stored or disposed of in thepond/impoundment. If necessary, separate multiple entries withcommas.A3-3 For Table A-5 if a pond receives underflow from asoftening clarifier, how should the plant list the pond?The plant should select "other" in the process wastewater dropdownoptions and describe the wastewater in the space provided.Section 4 For Section A-4, if the plant disposes of ash in a landfillthat is not owned or operated by the plant or its parentcompany, does it need to be included in Table A-6?For the purpose of this questionnaire, the landfill described wouldnot need to be included in Table A-6. If the plant has landfillslocated on non-adjoining properties that are under the operationalcontrol of the plant or parent company, that are used for the purposeof storing/disposing of process wastewaters, residues, or by-productsfrom the plant, they do need to be included on Table A-6.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 9 of 44Question # Question ResponseA4-2 I store bottom ash and coal pile runoff sludge on a linedcoal pile storage pad. Should I identify this as a landfill inTable A-6?For the purpose of this questionnaire, the coal pile storage padshould not be identified as a landfill in Table A-6.If a landfill is used by more than one plant, but is physically locatedwithin the boundaries of one specific plant, report the landfill inTable A-6 for the plant in which it's located and do not report thelandfill in Table A-6 for the other plant(s).If a landfill is used by more than one plant, but is not physicallylocated within the boundaries of any plant, the company shouldselect one plant and report the landfill in that survey. Then whencompleting Table A-7 for this landfill, designate all wastes from allplant(s) that are stored or disposed of in this landfill. If certain typesof waste are only sent from one of the plants to the landfill, pleasedesignate this in the comments page. For example, consider ascenario where only fly ash is sent to the landfill from plant A andonly bottom ash is sent to the landfill from plant B. In Table A-7,you would select fly ash and bottom ash for this landfill. Then in thecomments section you would explain fly ash comes from plant Aand bottom ash from plant B. In Parts B and C of the questionnaire,you will have to designate where certain wastes are disposed of. Forthe plant in which you did not report the landfill in Table A-6,please designate that this waste is sent to a landfill not reported inTable A-6.A4-3 If boiler blowdown is used to moisten fly ash beforesending it to the landfill, what should be included aswaste stored or disposed of in the landfill?You should check both the "fly ash" and "other" boxes. Enter"boiler blowdown" in the "other, specify" field.If multiple plants owned by the same company share alandfill, how should this landfill be reported?A4-2Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 10 of 44Question # Question ResponseA5-1 What should be the basis for the geographical coordinatesfor the plant?The plant should report the coordinates that were reported inresponse to Form EIA-860, schedule 2, line 6. If the plant doesnot/has not reported coordinates to Form EIA-860, then the plantcan use a structure located within the plant boundaries (e.g.,administration building, unit location) as the basis for the response.A5-2 A5-2 requests that an “aerial map” be provided. Not surewhat an “aerial map” is; would you be referring to a UStopographic map? Or are you asking for an “aerialphotograph”?In Question A5-2, EPA is looking for an aerial depiction of the sitethat shows the property boundary of the plant site and relative layoutof buildings, ponds/impoundments, landfills, and other significantfeatures of the plant. You may submit an aerial photograph,supplemented with notes as necessary, or a topographic map, aslong as the requested information is shown.A5-3 Since the process wastewater definition on page xviincludes condenser cooling water, how would we labelthat process wastewater? And would it be addressed inPart A? In Part D?The condenser cooling water flow will need to be included in thePart A water balance diagram. From the codes table, once-throughcondenser cooling water is labeled as "CW". Cooling towerblowdown is "CTB." This process wastewater should be identifiedin Part D ONLY if it is an influent or effluent to/from apond/impoundment system required to be reported in Part D.A5-3 EPA requires flow rates to be reported in gpm or gpd.Can flows instead be provided in other units, such asmgd?Flow rates will have to be provided in gpm or gpd, as specified bythe specific questions in the questionnaire.A5-3 What if my plant only tracks total plant flows and doesnot keep track of any internal flows necessary to completethe diagram for Part A?The plant should provide their best estimates of all internal flowsrequired for the diagram. Some flows can be determined usingestimates that involve tank volume and frequency of discharge. Anyestimation methods used should be explained in the Commentssection.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 11 of 44Question # Question ResponseA5-3 Should city water used for bathrooms and then sent to thecity sewer and/or city water used for boiler make-up waterafter it is run through a treatment system be included inthe water balance diagram?If river water is used to cool the turbine condenser, whatcode should be used for the turbine condenser?If water is used to wash down the floors, what codeshould be used for floor wash water?Do not include sanitary water, such as that used for bathrooms.Include city water used for boiler make-up water, but you do notneed to include the water treatment system. You only need toinclude treatment systems for process wastewater.You do not need a code for the turbine condenser because you canuse the steam electric generating unit code assigned in Table A-8.You should use the code for floor drain wastewater (FDW) for floorwash water.A6-1 If a plant operates three 200MW gas turbines, should theturbine capacity be listed as 200MW in Table A-8 or thesum (600MW)?The plant should include the sum of the gas turbine capacities in thecombustion turbine capacity column (in this case, 600 MW).A6-1 How should IDs for electrical generators be assignedwhen you have multiple boilers that can feed generators inany configuration?Question A6-1 (Table A-8) should be completed on the generatorbasis. To complete question A8-1 (Table A-11) determine thecombination of fuels (from multiple boilers) that supplied thatgenerator with steam.A6-1 Does the total electric generation per unit in Part ASection 6 refer to net or gross?Table A-6 is requesting the total gross generation of per unit.A6-1 Question A6-1 asks for calendar days of operation foreach steam electric unit. If a unit only operates for 2hours on a calendar day, is that to be counted as acalendar day for the purposes of completing Table A-8?For the purpose of Table A-8 (Question A6-1), if a unit has operatedfor any part of a calendar day (2 hours, 13 hours, or 24 hours), thatis to be counted as a calendar day.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 12 of 44Question # Question ResponseA6-1 Is there a MW size limitation for steam electric generatingunits such as 25 MW as found in the Clean Air Act?No, please provide information for all steam electric generatingunits regardless of their size.A6-2 How can I record that the plant does not operate a steamelectric generating unit that commenced after December31, 2009 and the plant is not currently planning oninstalling or planning to construct/install by December 31,2015?If the plant does not operate a steam electric generating unit thatcommenced after December 31, 2009 or the plant is not currentlyplanning on installing or planning to construct/install by December31, 2015, Table A-9 does not need to be completed. You may add anote to the comments section, if you wish.A7-1 If a once-through cooling system has no blowdown, can aplant enter zero for amount of wastewater generated andduration/frequency?Question A7-1 requests the typical amount of process wastewatergenerated OR blow down from the cooling system. Once throughcooling water is considered a process wastewater. Therefore, theplant should supply the generation, duration, and frequency of theonce through cooling water.A7-1 What should a plant enter for the amount of wastewatergenerated for a once-through condenser cooling systems?In the "Typical Amount of Process Wastewater..." and "TypicalDuration and Frequency...." columns, you should provideinformation for the water that flows through the once throughcooling system.A7-1 For Question A7-1, Table A-10, should I include anychemicals that are added to the boilers in the heatrecovery steam generators (HRSGs)?In Part A Section 7, EPA is requesting chemical additions to coolingwater systems. This section does not include reporting of anychemical addition to the condensers within the boiler or the HRSGs.However, chemicals added directly to the cooling tower, the closedcooling water system which empties into the cooling tower, or anyother parts of the cooling water system should be included.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 13 of 44Question # Question ResponseA7-1 If a plant has four turbines and four condensers but justone cooling water pond. Should this be considered as oneor four cooling systems in Part A, Section 7? If it isconsidered four systems, all four systems would have thesame data.You may report this as one cooling system (for example, if all fourunits are serviced by the same once through cooling water) or fourseparate cooling systems (if they are operated independently),whichever makes more sense for your plant.A8-1 If a plant has a combined cycle unit with three generators(two gas turbines and one steam turbine), how should theycomplete Table A-11?First, the plant should identify the combined cycle unit (two gasturbines and one steam turbine) as one steam electric unit and NOTthree separate steam electric units in Question A6-1 (Table A-8).Then, in Question A8-1 (Table A-11), the plant should report thetotal fuel usage for the combined cycle unit as a whole (the two gasturbines and one steam turbine).A8-1 Should I enter an instantaneous or annual number for"BTU generated ..."?Enter the total BTU generated for 2009 (i.e., the annual total not aninstantaneous rate).A8-1 What should be provided for the "BTU generated by gas",and is there a difference between BTU generated andamount of natural gas?The BTU generated by burning the gas and the amount of naturalgas burned are two separate requests in the questionnaire. The BTUcontent of the gas and the amount of gas burned in 2009 can be usedto determine the BTU generated.A8-1 We consume the BTUs produced when we burn coal, wedo not generate them. Do you mean the number of BTUsgenerated when the coal is burned?For the purposes of this questionnaire, Question A8-1 refers to thenumber of BTUs generated when coal is burned.A9-1 How should the facility report different NOXcontrolsystems for different boilers serving the same generatingunit, particularly if the boilers have the same type ofsystem (e.g., overfire air)?Complete a row for each generator/boiler combination and add acomment on the Comments page.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 14 of 44Question # Question ResponseA9-1 We operate CFB boilers that burn between 1,500 and1,550 degrees. Although they are not classified as lowNOx boilers, should we mark them as a NOx controlsystem because we do burn at lower temperatures?No, the CFB boiler should not be marked as a NOx control system,but you may provide a comment about the CFB boiler and thetemperature of the boiler.A10-1 If a plant has one type of flue gas mercury control on eachunit, do I complete Table A-14 for each control on eachunit?The plant should only report the types of flue gas mercury controlsystems at their plant once, and then use the third column todistinguish which steam electric units have that type of control.A13-2 There is a berm around the plant's coal pile yard in whichcoal pile runoff collects. This water typically evaporateswithin a day and there is no discharge from this berm.How should the plant answer question A13-2?Enter "0" (zero) for gpy of discharge. Identify this bermed area as apond/impoundment in Table A-4 and indicate in Q A13-4 that thecoal pile runoff is transferred to that pond. Then explain that thecoal pile run-off is transferred to a pond that does not discharge inA13-5.Part BB1-1 Is the ash produced by the addition of limestone to acirculating fluidized bed boiler considered an FGDmaterial? No water is involved in any part of the process.The addition of limestone to the CFB boiler does not constitute anFGD system for the purpose of this questionnaire; therefore, the ashproduced is not considered an FGD material. If no FGD systems arepresent at the plant, answer QB1-1 as "no" and the plant does nothave to respond to the rest of Part B. Additionally, the plant shouldadd a comment to Part A, Question 6-1 indicating which generatingunits are CFB boilers and have limestone added.B1-2 If an old scrubber (shut down in 1996) is being retrofitted,how should it be entered in Table B-1, as one entry, ortwo separate scrubbers?Table B-1 asks plants to list scrubbers in operation or planning to beoperated. The system should only be entered once with theinformation about how they plan to operate it once the retrofit iscomplete. They can add a comment saying it is a retrofit of aprevious scrubber.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 15 of 44Question # Question ResponseB6-2 TKN and Nitrate/Nitrite analytes do not have CASnumbers. What should be reported?Enter "No CAS" for these analytes.B6-2 Question B6-2 requires data to be reported beforetreatment. The data requires indicates metals and otherparameters. However, selenium (which is not a metal), isnot listed. Should selenium data be reported?Analytical data for selenium should be provided to EPA in QuestionB6-2. The analytical methods used for the determination ofselenium, such as EPA Method 200.7 or 200.8, are used to analyzefor metals and other trace elements in environmental samples, andoften are commonly referred to as metals analytical methods. Forthe purpose of the questionnaire, selenium and other trace elementsmeasured by these methods are collectively referred to as metals andshould be reported in Question B6-2.B8-9 In Question B8-9, should wastewater from cleaning a dryFGD scrubber include building washdowns or only theFGD system internal parts?Questions B8-9 does not need to include building washdowns aswastewater generated from cleaning a dry FGD scrubber.General How should Part C be completed, if bottom ash and flyash are conveyed and stored dry in combination?Complete Section 3 (bottom ash) rather than Section 2 (fly ash) andadd comments to both sections that the plant has a combined fly andbottom ash conveyance and storage system.General The plant may not have costs and design records prior tothe last 5-7 years for ash handling systems, or othersystems at the plant.Cost questions only require information for systems installed on orafter January 1, 2000. In the event that exact data are not available,provide your best engineering estimate and note the methods youused in the Comments page at the end of the Part.Part CVersion 3August 27, 2010Frequently Asked Questions - TechnicalP. 16 of 44Question # Question ResponseGeneral If a plant's ash handling system was installed and beganoperating prior to January 1, 2000 and has not beenmodified after January 1, 2000, do they need to answerquestions asking for information about ash handlingsystems that began operating or were converted afterJanuary 1, 2000?No.C1-1, C1-3 What is the difference between "ash" referenced in C1-1and "fly ash" referenced in C1-3?"Ash" in question C1-1 refers to any ash that is created by the unit(i.e., fly, bottom, economizer). EPA included this question to directplants with units that do not produce ash to skip completion of PartC. Question C1-3 "fly ash" is ash that is carried out of the furnace bythe gas stream (see the Questionnaire Instructions for a definition offly ash).C1-2 What is meant by "other developed areas" in Table C-1? Table C-1 is intended to capture a distribution of the total acreageofthe plant. The category "Buildings and Other Developed Areas" isintended to capture acreage that is used for buildings or has beendeveloped for a specific use (other than those uses listed elsewherein the table). For example, "other developed areas" would includeswitch yards and ash silos.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 17 of 44Question # Question ResponseC2-1 What is LOI and do I have to report it if I have nevermeasured it before?The loss on ignition (LOI) is defined as a measure of the amount ofunburnt fuel remaining in the ash/residue from the combustionprocess. For the combustion of coal, the loss on ignition is ameasure of the carbon content remaining in the ash. The loss onignition is a property of the ash (typically reported in mass percent)that is affected by the type of coal burned, type of boiler, and certaintypes of NOx controls (specifically, over fire air systems, and lowNOx burners). Please use the following link for further backgroundinformation and to see the methods for measuring LOI provided bythe American Society for Testing and Materials (ASTM);http://www.astm.org/Standards/D7348.htm. Please note that EPA isnot requiring your company or plant to perform non-routine tests ormeasurements solely for the purpose of responding to thisquestionnaire (with the exception of Part G). In the event that exactdata are not available, provide your best engineering estimate andnote the methods you used in the Comments page at the end of thePart.C2-1 What is the difference between a cold side and hot sideESP?Cold side and hot side refers to the location based on the air heater.In a cold side ESP, the ESP is after the air heater and, therefore, theair going through the ESP is colder. In a hot side ESP, the ESP isbefore the air heater.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 18 of 44Question # Question ResponseC2-3, C2-4,C3-3, and C3-4Is it correct that even if units identified in Table A-8 havefly ash conveyance systems, the only units that arerequired to provide data in this section are those unitswhose fly ash conveyance system began operating afterJanuary 1, 2000?Any ash handling system(s) that were installed and began operatingprior to January 1, 2000 and have not been modified after January 1,2000, do not need to be included in sections 2.3, 2.4, 3.3, and 3.4 ofPart C, even if the associated units/destinations were identified inthe reference tables (e.g., Steam Electric Units (SEUs) listed inTable A-8, or storage destinations identified in Table C-6). Pleasenote, the January 1, 2000 installation or modification cutoff dateapplies specifically to the ash handling system(s), not the SEUs. Forexample, if a SEU was installed or last modified prior to January 1,2000, but the ash handling system was installed in 2005, the ashsystem must be included in sections 2.3, 2.4, 3.3, and 3.4 of Part C.C2-6 What is a wet vacuum pneumatic system? A wet vacuum system (pneumatic) refers to a system where thevacuum that pulls the ash is created from a water source (i.e., thesluice water). A completely dry pneumatic system does not usewater to create the vacuum or pressure that is the motive force forthe ash.C2-6 How should this question be answered for a pneumaticsystem which is not wet?Depending on the configuration of your system, you would select"Dry vacuum system," "Pressure system," or "Combinedvacuum/pressure system" for "Type of Fly Ash Handling" in Q C2-1, then select "No" in Q C2-2 and Q C2-6.C2-24 In Table C-5, should ESP outages be included in the FlyAsh Handling System outages?ESP outages should not be included in the Fly Ash Handling Systemoutages. Only outages associated with the conveyance systemshould be included.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 19 of 44Question # Question ResponseC2-25 If the plant does not directly measure the percent moistureof the fly ash, what should they report?Estimate the percent moisture and indicate in the comments pagethe method you used to determine the estimation.Section 2.3 Is my plant required to complete Questions C2-30 throughC2-36 if we do not have a ‘fly ash handling system thatbegan operating or was converted after January 1, 2000’BUT have purchased a screw conveyor for one unit in2010 and intend on installing it this year?As long as the the fly ash handling system has not been convertedsince January 1, 2000, then the plant does not need to complete PartC, Section 2.3, because the system has not begun operation orconversion since January 1, 2000. However, please note that for thepurpose of the questionnaire, installation of a screw conveyor isconsidered a modification, which should be kept in mind for othersections, such as 2.4 and 2.5.Sections 2.3and 2.4The instructions for Part C Sections 2.3 and 2.4 (costinformation for fly ash conveyance and interim storage)initially state that these sections should be completed foreach unit that began operating or was converted afterJanuary 1, 2000. But the instructions later state that thesesections should be completed for units operated in 2009.If a utility has a unit that began operating BEFOREJanuary 1, 2000, and that unit was in operation in 2009,do Sections 2.3 and 2.4 need to be completed for theseunits?The instructions for Part C Sections 2.3 and 2.4 (also stated in 3.3and 3.4) first state to complete the section for the conveyance of flyash. The plant is required to provide this data for all fly ash handlingsystems, not steam electric units, that began operating or wereconverted on or after January 1, 2000. EPA has provided revisedinstructions to provide more clarity:For all units operated in 2009, make copies of Section 2.3 for eachwet and dry fly ash handling system (conveying ash) that beganoperating on or after January 1, 2000, is being installed, or plannedto be installed by December 31, 2020 using the "Copy Section 2.3"button below.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 20 of 44Question # Question ResponseSections 2.3through 2.5What is the definition of modfication or major change?Does this include new valves that were added to system?While answering the Sections 2.3 through 2.5 in Part C,modifications include changes such as an addition of a silo,expansion of a silo, or changing the motive force for moving ash(e.g., vacuum system to a vacuum/pressure system). However,replacing small pieces of equipment (e.g., pumps, valves) do notqualify as modifications to the system.C2-42 For Part C, Table C-14, should plants include all fly ashcosts from 2000 to present?Answer the question for any equipment installed/modified on orafter January 1, 2000. For example, if a change was made to themotive force to move the fly ash (e.g., converted from a vacuumsystem to a vacuum/pressure sytem) in 2005, the cost for thesechanges should be included in Table C-14.Tables C-30and C-32Why does Table C-14 (Capital Cost for IntermediateStorage of Fly Ash Handling) and C-16 (Capital Cost forTransport/Disposal of Collected Fly Ash) request costssince January 1, 2000; however, Table C-30 (Capital Costfor Intermediate Storage of Bottom Ash Handling) andTable C-32 (Capital Cost for Transport/Disposal ofCollected Bottom Ash) do not request costs for a specificperiod of time. All of the other tables requesting costsspecify since January 1, 2000.Although the instructions to Tables C-30 and C-32 do not specifythat the plant should provide costs after January 1, 2000, the Section3.4 and 3.5 instructions specify this date cutoff. Therefore, the plantshould provide cost data in Tables C-30 and C-32 for each ashhandling system as originally installed or modified since January 1,2000.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 21 of 44Question # Question ResponseC3-4 A plant has no maximum acceptable limits on theirsystem. How should they respond to Question C3-4?Provide the maximum acceptable limits for chlorides based on thematerials of constructions used in your system. Your equipmentshould at least be rated for chlorides and possibly other species toprevent corrosion. Please note in the comments section if youtypically operate the system at a lower level. Also provide themaximum solids percentage based on how the water is reused ormanaged. If you truly have no limit as to the solids content, pleaseindicate this in the comments.C3-6 If a facility sends bottom ash sluice to a pond to settle outthe ash and then transfers water from the pond to aPOTW, how should they answer Question C3-6?The plant should answer "Yes" to questions C3-6.C3-33 If a plant has to subsidize the recycling of bottom ash inorder to encourage its use, sometimes at a loss, shouldthey report the loss in the gross revenue generatedcolumn?No, do not report loss. If you have no revenue, report it as zerorevenue. Please feel free to provide additional details in thecomments page.C5-3 Question C5-3 asks for the average amount of dry airheater ash produced in tons per day and days per year.Air heater ash is typically blown from the air heaterperiodically into the fly ash stream. If there is no way ofmeasuring and no good way to estimate how much ash isremoved from the air heater during this operation, can thisquestion be skipped?In regard to Question C5-3, an estimation is required if you areunable to provide the measured amount. Please use the commentspage in Part C to explain the calculations and assumptions made forcompleting this question.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 22 of 44Question # Question ResponseC4-4 and C5-3These questions request the amount of economizer and airheater ash produced, respectively. If both the economizerand air heater ash is collected with the fly ash, can I skipthese questions?In regard to Questions C4-4 and C5-3, an estimation is required ifyou are unable to provide the measured amount. Please use thecomments page in Part C to explain the calculations andassumptions made for completing this question.C5-4 Is there a mismatch of pond IDs available in Table A-4versus the dropdown box in Question C5-4?No. The pond IDs in Table A-4 refer to individual ponds. The pondID in Question C5-4 refers to the pond system IDs identified inTable D-1.Part DGeneral If the plant sends the wastewaters to a pond/impoundmentthat is located at and owned by another facility, does theplant have to fill out the information in Part D?Throughout the questionnaire, the plant should report that thewastewaters generated at the plant are sent off-site to a publicly orprivately owned treatment works, as appropriate. The plant shouldalso answer "no" to Question D1-1 if no other ponds/impoundmentsare used or planned to be used (or begin construction/installation of)at the plant. The plant should make a comment in Part D explainingthe situation, reporting the types of wastewaters being sent, andwhether the plant shares the cost of treatment with the othercompany operating the pond/impoundment.General Does a demineralizer need to be reported in this section ofthe quesitonnaire?Demineralizers do not need to included in Part DVersion 3August 27, 2010Frequently Asked Questions - TechnicalP. 23 of 44Question # Question ResponseGeneral An on-site stormwater collection pond is used to collectstormwater runoff from the on-site coal pile. No liquidprocess wastes or process wastes containing free liquidsare added to the pond. This pond is lined and thestormwater is re-used in the plant as process water. Anycoal fines that are in the stormwater settle out by gravityand are collected in the lined basin. The basin isoccasionally dredged to remove the accumulated coalfines. At times, the pond level is high and the stormwatermust be discharged to the surface water under an existingNPDES permit. Under Part D of the ICR, would this typeof pond be considered a “pond/impoundment” as defined?The pond is considered a “pond/impoundment” as defined in thequestionnaire, because the runoff from the coal pile is considered aprocess wastewater (i.e., coal pile runoff); therefore, this pondshould be identified as a pond/impoundment in Table A-4 of Part A.However, the pond should not be reported in Part D, because Part Dis restricted to pond/impoundments that receive waste from thecombustion of coal.General Based on the definitions of "wastewater treatment unit"and "wastewater treatment system," is it possible for apond to be classified as a wastewater treatment system?For the purpose of the questionnaire, a pond/impoundment may bepart of a pond/impoundment system (see Part D instructions anddefinitions), as long as the system only consists ofponds/impoundments (i.e., there are not any non-pond wastewatertreatment units). Additionally, a pond/impoundment may be awastewater treatment unit, but ONLY if it is used in combinationwith non-pond wastewater treatment units (e.g., chemical/physicalseparation, biological treatment).General Do sewage treatment operations need to be included inthe wastewater treatment system sections of thequestionnaire?Sewage treatment operations should only be included in thewastewater treatment system section (Part D) of the questionnaire ifthey are used for the treatment of process wastewaters from ashhandling or FGD operations.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 24 of 44Question # Question ResponseGeneral For the purpose of Part D, are bottom ash sluicedewatering bins considered wastewater treatment units ifused to remove bottom ash prior to additional settling inponds?For the purpose of Part D, the bottom ash sluice dewatering binsshould not be considered wastewater treatment system units. Theinformation for the bins will be collected in Part C of thequestionnaire.General FGD blowdown from the absorber is sent to a pond fortreatment. Prior to the pond, a polymer is added to thickenthe blowdown and it is sent through a vacuum filter. Isthis considered a wastewater treatment system?No. Because the vacuum filter is the primary solids removal, thepolymer addition and vacuum filter are not considered an advancedwastewater treatment system.General FGD blowdown from the absorber is sent to a pond fortreatment. Prior to the pond, a polymer is added to thickenthe blowdown and it is sent through a vacuum filter. Howdo I label the water from the vacuum filter entering thepond?The FGD water from the primary solids removal operation (e.g., thevacuum filter) is FGD scrubber purge.General Is a sump considered a primary/secondary equalizationwastewater treatment unit?No, a sump should not be considered a primary/secondaryequalization unit.General Do you define water for limestone preparation as "FGDslurry preparation water?"Yes, water used for limestone preparation is "FGD SlurryPreparation Water."Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 25 of 44Question # Question ResponseGeneral Does Part D apply to ponds/impoundments or wastewatertreatment systems used to treat boiler blowdown or spentcooling water?Part D applies to ponds/impoundments or wastewater treatmentsystems used for the storage, treatment, and/or disposal of processwastewater, residues, or by-products (or sludges or water streamscontaining the residues or byproducts) from the combustion of coal,petroleum coke, or oil, including but not limited to fly ash, bottomash, boiler slag, or flue gas emission control residues. Please notethat Part D is requesting information on ponds/impoundments orwastewater treatment systems with process wastewaterassociated/related to the combustion of coal/coke/oil, not for allprocess wastewater, regardless of whether other processwastewaters, such as boiler blowdown water and/or spent coolingtower water are also managed in the pond/impoundment.Ponds/impoundments and wastwater treatment systems that onlycontain or treat other process wastewaters, like cooling water orboiler blowdown water, do NOT need to be reported in Part D.However, information regarding ponds/impoundments andwastwater treatment systems that only contain or treat other processwastewaters, like cooling water or boiler blowdown watershould bepVersion 3August 27, 2010Frequently Asked Questions - TechnicalP. 26 of 44Question # Question ResponseGeneral What is the definition of a "basin" in the definition forpond/impoundment in the Questionnaire Instructions?There is no specific definition required for "basin." The definitionof pond/impoundment indicates that "outdoor collection/transferconcrete basins" are not considered ponds/impoundments.However, basins (including concrete basins) that are used to holdprocess wastewater, other than for the purpose of a temporaryholding or transfer station (e.g., sump), should be reported.General Is evaporation from a pond an effluent? Evaporation from a pond is not an effluent. However, please includeevaporation from your pond system on your diagram, as appropriate,to make the flows balance. It does not need to be listed in Table D4.General Is Part D only for combustion by-product wastewaters? Part D is only for ponds/impoundments and wastewater treatmentsystems for process wastewaters associated with the combustion ofcoal, petroleum coke, or oil. Therefore, only thosepond/impoundment systems and advanced wastewater treatmentsystems should be reported. However, if process wastewaters notassociated with the combustion of coal, pet coke, or oil are part ofthe pond/impoundment or wastewater treatment system (as influentsor effluents), they must be included in Part D, as they are part of thesystem and necessary for the block diagram.D2-6 If the plant has a pond that is primarily used for otherwastewaters at the facility (e.g., coal pile runoff, rainfall,floor wash water), should it be included in Part D if asmall amount of ash may be collected with the floor washwater?No, the pond does not have to be included in Part D.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 27 of 44Question # Question ResponseD3-1 Are rain and run-off into a pond influents? If so, are theythe same influent?Direct precipitation (rain) does not need to be included as aninfluent in Table D-3. However, runoff contributing to the systemdoes need to be included.If direct rain and run-off are not broken out separately, pleaseprovide the direct rain and run-off as one total into the pond. Youshould provide comment explaining that the influent includes bothdirect rain and run-off. Alternatively, you could use local rainfallrecords to estimate the inches of precipitation received and based onthe surface area of the pond estimate the amount of directprecipitation entering the pond.D3-1 Should every stream leaving the pond system be labeledas an effluent in the block diagram?Everything leaving the pond system should be labeled as an effluent(i.e., EFF-1, EFF-2) in the diagram, unless the stream leaving isalready identified as another process wastewater or sludge. Use thetables on the Code Tables tab, located at the end of Part D, to labelthe influents and effluents of the system and the destination of eacheffluent. For example, you may recycle the water from the last pondin your system to use as bottom ash sluice. You would label this asan effluent from the system (e.g., EFF-1) and then also add the codefor the destination "Reuse as bottom ash sluice" (e.g., RECYC -BAS). See the POND-1 example diagram in the questionnaire foranother example.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 28 of 44Question # Question ResponseD3-1 When submitting the block diagram(s) for Question D3-1,what is meant by the pond/impoundment or wastewatertreatment system ID and the block diagram number?Use the checklist provided below D3-1 to complete the blockdiagram. The pond/impoundment system or wastewater treatmentsystem ID is the ID from the 1st column in Tables D-1 and D-2. Forexample, POND-1, POND-2, WWT-1. The block diagrams shouldbe numbered in the upper right corner. The 1st block diagramshould be numbered D-1, second D-2, etc. D-1 and D-2 are blockdiagram numbers.D3-1 If flows are intermittent (e.g., a wash that happens everythree years), should the flow rate be reported as a flowrate occuring 3 days every 3 years or should the flow ratebe divided by 3 and the flow rate be reported per year?There is no need to average any values. To provide information on awashing event that occurred every three years, write the flow rateduring the event, the number of days of discharge during the event,and frequency the event occurs (every 3 years).D3-1 Should all the effluents be labeled in the D3-1 diagramswith an Effluent-# designation, even if the numbersincrease beyond 6?Yes, the effluents should be numbered EFF-1 through EFF-6, andthen keep numbering (7, 8, 9, etc.) even though they are notprovided in the drop down or codes table.D3-1 Should all block diagrams requested by the questionnairebalance?Yes, all diagrams should balance. You should include estimationsmade (i.e., water loss to evaporation) in order to balance the blockdiagram. Make sure the include these estimations in the commentstab for Part D.D3-1 Should one stream from one pond, or wastewatertreatment unit, to another be labeled as an effluent?A stream leaving one pond and entering another, in the same pondsystem (or unit to unit in a wastewater treatment system), should notbe labeled as an effluent. Please note that all influents and effluentsshould be identified for the system, not each individual pond or unit.You can see in the POND-1 example diagram in the questionnaire,that the flow from SPD-1 to SPD-2 is not labeled as it is not aninfluent or effluent from the system.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 29 of 44Question # Question ResponseD3-1 In the Part D diagrams, I plan to only list the flow ratesattributable to the combustion byproduct process. Is thatappropriate?In the Part D diagrams you should list all of the influents andeffluents to the pond system, and corresponding flow rates, even if itdoesn't relate to the combustion by product process.Table D-3 How should I label the numerous influents to our pondsystem?While identifying influents to your pond system, you should use theprocess wastewaters table and the treated wastewaters table in theCode Tables tab.Section D4-1 Does coal pile runoff and once through cooling waterneed be included in section D4.1?For the purposes of this questionnaire, ponds that only contain coalpile runoff and once through cooling water do not need to beincluded in Part D, including Section D4.1. However, they shouldbe included in Part A.D4-3 For Part D, Table D-5:1) Current section – which volume should be entered,the remaining capacity for storage or the volume stored?2) Expected End of Life section – for a pond beingplanned for closure – what should we enter for the finalsurface area (zero?), Bottom elevation, Top elevation (topof crest or the berm)?3) We have a run-off pond from a coal combustion byproducts landfill. Does Pond/Impoundment include theentire landfill or just the pond?1) Current - enter the volume currently stored including free waterand added solids.2) End of life - enter the surface area of the added solids and anyremaining water at closure. For bottom elevation, please enter theelevation at the top of the added solids. For the top elevation, pleaseenter the elevation at the top of the berm.3) The individual pond/impoundment unit (reported in Table A-4)should just include the runoff pond. The pond/impoundment system(reported in Table D-1) should only include the runoff pond and anyother associated ponds. It should not include the landfill.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 30 of 44Question # Question ResponseD4-5 If the plant is currently dredging the pond, should theinformation be reported in Question D4-5?Yes, enter 2010 for the year dredged and supply all of theaccompanying information to the best of your ability (i.e., amount ofsolids dredged, number of days dredged), as well as all informationfor dredge operations in the last five years. If necessary, use thecomments section to document any notes about the dredging.Section 4.2 If a former ash pond has not been closed but has been putto another use by the plant, does it need to be included inPart D Section 4.2 - Closed Pond/Impoundment UnitInformaiton?If a former ash pond has not been closed but has been put to anotheruse by the utility, it should not be included in Part D Section 4.2 -Closed Pond/Impoundment Unit Information. However, it should beincluded in Part D Section 4.1 Active/Inactive/Open and PlannedPond/Impoundment Unit Information. Even though the ash pond hasbeen put to another use by the utility, it is still storing ash and hasnot yet been closed. You should provide the information for thepond and then use the comments section to further explain when thepond was converted from ash to another use, if the ash was dredgedfirst, and what is being placed in the pond now.D5-11 If a plant intends to install a scrubber, in which other plantprocess wastewaters (e.g., boiler blowdown) will be usedduring operation, is using process wastewaters for thispurpose, rather than sending it on to wastewater treatmentconsidered a planned improvement to the wastewatertreatment system?No, if you already have a pre-existing wastewater treatment systemthat treats process wastewater such as boiler blowdown, planning touse boiler blowdown or other process wastewaters in the scrubber,rather than sending them to the wastewater treatment system is notconsidered a planned improvement to the wastewater treatmentsystem.Version 3August 27, 2010Frequently Asked Questions - TechnicalP. 31 of 44Question # Question ResponseGeneral In part E, we have a problem in the titles and plant IDentry in the upper right-hand corner. We have used theTOC and inputted the plant ID and plant numbers. Oncewe get to sections 1, 2, and 3, the plant name and plant IDare reversed. The plant name is populated with the plantID and the plant ID is populated with a reference numberbecause I guess the name is too long. How can I fix this?Fill in the plant ID and plant name as written on the TOC. Althoughthe plant name is cut off and only displays the reference number inthe cell, we can still access the whole name.E2-1 In Table E-1, the amount of chemicals added is requestedin gallons. If some of the chemicals used are delivered assolids, can I report these chemicals as pounds?Yes, for this question you can report the amount of chemical used inpounds rather than in gallons. Please put a note in the commentspage designating that the units are in pounds rather than gallons.E2-2 If high pressure steam is used for soot blowing in theboiler, using boiler steam during boiler operation and thesteam exits out the stack, how should Question E2-2 becompleted? Since the steam goes out the stack, no wateris created from this process.Partially fill in the soot blower line on the table, complete how oftenyou soot blow and list steam as the fluid, and fill in the columnshowing numbers of gallons as “zero” because it all goes out assteam. Please use the comments page to explain the situation, so thatwe understand that the boiler steam goes out the stack.NA If I have a landfill that is currently under construction,that has not been previously in use (i.e., no materialsadded to the landfill), do I have to complete Part F?Planned landfills, including those under construction that have nothad any materials added to date, are not required to be reported inPart F.Part FPart EVersion 3August 27, 2010Frequently Asked Questions - TechnicalP. 32 of 44Question # Question ResponseGeneral Does leachate include stormwater runoff of an activelandfill area? At one of our plants, we do not collect anyleachate that may have percolated through our wastes, butdo have sedimentation basins for the surface runoff thathas contacted waste. Will we need to sample at thislocation pursuant to Section G?We also have an older landfill that has final cover andvegetative growth, but hasn’t gone through formalclosure. Its runoff is also collected in a sedimentationbasin, but this runoff would not have contacted thelandfilled waste. Will we need to sample this runoff as a“leachate”?Sedimentation basins that collect only stormwater that has contactedthe uncapped portion of a landfill do not need to be sampledpursuant to Part G.Landfills do not have to go through formal closure to be consideredclosed for the purposes of this questionnaire. However, the closedlandfill may still contribute leachate to your sedimentation basins. Ifthe sedimentation basins do not contain leachate, they do not needto be sampled for Part G.General If I do not have a leachate collection system, but I do havestormwater runoff ponds and groundwater monitoringwells, do I have to answer Part G?The plant should not respond to Part G for groundwater monitoringwells as they are not a form of leachate collection. Stormwaterrunoff ponds should only be included if the pond also collectsleachate. Please contact the helpline for further clarifictionregarding the situation at your facility.General If I have a pond configuration including two or moreponds, where should I collect leachate?Instructions to Question G3-1 state that the plant should collectsamples from eachleachate collection point for eachpond/impoundment and landfill. If a plant determines that a samplefrom one or more collection points are representative of anindividual pond/impoundment or landfill, they may collect samplesfrom only the representative sample point(s)for thatpond/impoundment or landfill.Part GVersion 3August 27, 2010Frequently Asked Questions - TechnicalP. 33 of 44Question # Question ResponseSection 4 Can the plant use local rainfall records to reportprecipitation instead of directly measuring it on site?Local rainfall measurements are acceptable.G4-1 The question asks for flow rate of the leachate stream, butthere is no entry field in the table for flow rate or units.Respondents should provide this information in the Commentssection for Part G.G5-1 Shouldn't the "Type and Amount of Waste" column referto "FGD Calcium Sulfite - Not Pozzolanic", rather than“FGD Calcium Sulfate – Not Pozzolanic”?If a pond/impoundment contains FGD calcium sulfite – notpozzolanic, respondents should select the "Other" checkbox andtype “FGD calcium sulfite – not pozzolanic” as the description.G5-1 Is Table G-3 asking for total tons of each type of wastestored/disposed or tons disposed in 2009?In Table G-3, please indicate the total amount of waste that isstored, treated, and/or disposed of in each pond/impoundment unitand/or landfill. Please note, we are looking for the gross amount ofwaste put into the pond or landfill during the year. For example,waste that is stored in 2009, but also removed in 2009 (e.g., wastethat is stored for one month) should be included in the table.Part HNA I received Part H on my disk, but I do not have anynuclear units. What should I do?Answer "no" to question H1-1. You do not have to provide anyother information in the Part H file.H1-2 What is meant by the term "service water treatmentsystems"?A service water treatment system would be a system that treats lakeor river water, so that it could be used in the boiler or for otheronsite uses.I5-4 The table is requesting annual fuel costs in dollars, but anumber greater than 8,760 cannot be entered into thecells.Respondents should download the new revised version of Part Ifrom the EPA website.Part IVersion 3August 27, 2010Frequently Asked Questions - ApplicabilityP. 34 of 44Question ResponseIf a plant has two coal units and two gas units, do they have to completeVersion 2 of the questionnaire for all units or can they complete Version2 for the coal units and Version 4 for the gas units?Respondents should complete Version 2 of the questionnaire for all unitsat the plant. There will be many questions that apply to all the units. Forquestions that only apply to certain types of units, the directions in thequestionnaire will clearly indicate which units plants should include intheir response.If the plant’s SIC is 4961 (steam and air conditioning supply) and theplant’s primary purpose is to provide steam, does the plant need tocomplete the questionnaire? The plant does have electric generationcapacity.The first questions in Part A of the questionnaire specify that if a plantdoes not meet certain requirements they do not need to complete theremainder of the questionnaire. For example, in this case, question A1-11 asks if the primary purpose of the plant is to generate electricity. Youwould state no, designate the primary purpose in the box provided, andnot complete the remainder of the questionnaire. The completedquestionnaire and signed certification must be returned to the addressspecified in the questionnaire instructions.If the operating company needs to get information from other owners ofthe plant, should the owners send the operating company the completedinformation or can each owner send the information to EPA directly?Respondents should NOT submit the questionnaire to EPA in pieces.Operating companies should obtain the required information fromowners, use this information to complete the questionnaire, and submitone complete copy to EPA.If a plant is scheduled for retirement, do they need to complete thequestionnaire?In Part A, question A1-6 asks about the retirement date and states thatplants that will be permanently retired by December 31, 2011 will notneed to answer questions beyond A1-6. The completed questionnaireand signed certification must be returned to the address specified in thequestionnaire instructions.If the plant only received certain files on their disk, are they required todownload the remaining files from EPA's web site?If the facility received Version 2, 3, or 4 of the questionnaire, they areonly required to complete a subset of the questionnaire. Please see yourcover letter or the general instructions for more details.Version 3August 27, 2010Frequently Asked Questions - ApplicabilityP. 35 of 44Question ResponseTwo of our facilities utilize the same generating technology andequipment and burn the same fuel; therefore, the plants have identicalinformation. Do we have to complete both questionnaires?The questionnaire must be completed for both facilities.If the plant stopped burning coal in the middle of 2009 and is in theprocess of switching to a different fuel source such as biofuels, do theyneed to complete the questionnaire?The plant must complete as much of the questionnaire as possible for allmonths it operated the coal units in 2009.If the plant's coal unit shut down in May 2010, and the plant is building anew gas unit, should the questionnaire be answered for the coal or thegas unit?The plant must complete the questionnaire for the coal unit because itwas in operation in 2009. The plant must also include all of theinformation available for the planned gas unit.The coal-fired generating station was recently repowered using gasturbines with waste heat powering one of original steam turbines. Theplant began operation as a gas facility in April 2009 but did not generateelectricity using coal in 2009. There are no remaining coal or ashhandling or storage facilities and no leachate is generated for sampling.Can the plant answer "no" to Parts B, C, D, F, G, and H.The plant should answer “no” to the first question in Parts B, C, D, F, G,and H if the following statements are true:1.) Part B: Did not operate, construct/install, or plan to construct/install aflue gas desulfurization (FGD) system;2.) Part C: Did not operate ash handling or storage systems;3.) Part D: Did not operate or plan to use pond/impoundments AND didnot operate or plan to operate any wastewater treatment systems;4.) Part F: Did not have one or more active/inactive/open orretired/closed pond/impoundment units or landfills.5.) Part G: Did not collect leachate from a pond/impoundment orlandfill; and6.) Part H: Did not operate one or more nuclear units.Does surface water include on-site ponds/impoundments or are only offsite receiving waters included?On-site ponds/impoundments that are part of a wastewater treatmentsystem are not generally considered surface water, unless they areconsidered as such by the permitting authority for the purposes of theClean Water Act. Whether the location is on or ofVersion 3August 27, 2010Frequently Asked Questions - GeneralP. 36 of 44Question ResponseEPA distributed this questionnaire to all coal-fired power plants and a subset ofother power plants that are likely subject to the Steam Electric Power Generatingeffluent guidelines (40 CFR Part 423). EPA identified these plants by reviewingcertain data reported to DOE’s Energy Information Associated (EIA) in the 2007-860 reports. Your facility was selected as a potential respondent to thequestionnaire based on the following criteria:· Your reported a North American Industry Classification System (NAICS)code of 22 (Utilities);· You reported that you operate at least one generating unit that uses coal,gas, oil, petroleum coke, or nuclear fuel as the primary energy source (or coal orpetroleum coke as the secondary energy source); and· You reported that you operate at least one generating unit using the fuelslisted above that uses steam as a prime mover, which includes combined cyclegenerating units.If your facility receives a version of the questionnaire (delivered on CD) by mail orexpress courier, then you are required to complete the questionnaire. EPA isadministering this questionnaire under the authority of Section 308 of the CleanWater Act (Federal Water Pollution Control Act, 33 U.S.C. Section 1318). Failureto respond, late filing, or failure to comply with the instructions may result incriminal fines, civil penalties, and other sanctions, as provided by law.Depending on the specific fuel burned and operations at the facility, you may notbe required to complete the entire questionnaire. Follow the directions provided inthe cover letter and throughout the questionnaire to determine if all parts areapplicable to your facility.Why did I receive a questionnaire?Am I required to complete the questionnaire?Version 3August 27, 2010Frequently Asked Questions - GeneralP. 37 of 44Question ResponseDo I have to complete the questionnaire if I am a zero dischargefacility?Zero discharge facilities are still required complete the entire questionnaire. Theinformation that zero discharge plants provide will help EPA to better characterizeand understand the steam electric industry. EPA is specifically interested in zerodischarge facilities because their impact on the environment is significantly lessthan other steam electric plants. Better understanding how you are able to functionwhile not discharging wastewater is very important to EPA.You can obtain assistance in completing the questionnaire using EPA’s telephoneor email helpline. For assistance with technical questions, please call 703-633-1696 (or tollfree at 1-877-353-7560), or email steamhelp@erg.com.If you need assistance with Part I of the questionnaire, please call the economicshelpline at 617-520-2336 (or tollfree at 1-877-344-9540), or emailsteam_econ@abtassoc.com.Use the return label provided in your package to return your electronic response toERG at the following address:U.S. Environmental Protection AgencyQuestionnaire for the Steam Electric Power Generating Effluent Guidelinesc/o Eastern Research Group, Inc.14555 Avion Parkway, Suite 200Chantilly, VA 20151Who should certify the questionnaire? The individual that directed or supervised questionnaire preparation should readand sign the certification statement. The signatory should be a corporate official ortheir authorized representative.Does EPA has specific requirements for who certifies the response? No, whoever is given the authority at the operation to certify the response isacceptable to EPA.Does the certifier need to be pre-approved by EPA? No.I didn’t complete the questionnaire myself. How can I sign thecertification?Your signature means that to the best of your knowledge, employees under yoursupervision properly completed the questionnaire.How can I get assistance to complete responses to the questionnaire?Where do I send the completed questionnaire?Version 3August 27, 2010Frequently Asked Questions - GeneralP. 38 of 44Question ResponseHow long do I have to complete the questionnaire? You have 90 days from the time of receipt to complete the questionnaire, withtheexception of Part G. If you are required to complete Part G, you have 120 days tocomplete and report data for that part. The due date is the specified period (90 or120 days) calculated from the date of signed receipt.If you wish to request an extension, you must do so in writing within 21 days ofreceipt of this questionnaire. Written requests may be e-mailed (preferred) ormailed to:Jezebele AliceaUSEPA HeadquartersAriel Rios Building1200 Pennsylvania Avenue, NWMail Code: 4303TWashington, DC 20460alicea.jezebele@epa.gov202-566-1755Extension requests will be evaluated on a case-by-case basis. Submittal of anextension request to EPA does not alter the due date of your questionnaire unlessand until EPA agrees to the extension and establishes a new date.How long will it take to complete the questionnaire? Due to the nature of this questionnaire, different plants will be requiredto fill outdifferent parts of the questionnaire based on fuel type and specific operationsperformed at the plant. In addition, only certain plants are required to complete thequestionnaire in its entirety. EPA estimated an average burden of 168 hours perrespondent; however, the actual burden can vary significantly, from only a fewhours to several hundred hours.Can I get a paper copy of the questionnaire? EPA supplied the facility with MS Excel and PDF versions of the questionnaire.To obtain a paper copy, print the PDF version of the questionnaire.Can I get an extension of time to complete the questionnaire?Version 3August 27, 2010Frequently Asked Questions - GeneralP. 39 of 44Question ResponseClose (do not save) the file. Follow the directions below for correctly opening theelectronic forms and entering your Plant ID. Note these directions are alsoprovided in the Questionnaire Instructions.pdf file, which can be found on the CDprovided and online.1. Download the excel file(s) from the CD provided or online.2. Launch Microsoft® Excel, then select Tools > Macro > Security. In theSecurity Level tab, select "Medium." (Note: This security level allows you to runessential macros contained in the electronic form.)3. As you open each part of the questionnaire, a security window should appearregarding macros. Select "Enable Macros" and then "OK." If the window does notappear, close the file and repeat step 2 above.4. On the first tab only (i.e., the Table of Contents tab) in each Part, type yourPlant ID. The Excel program will automatically copy your ID into the ID field atthe top of every page in the file.I am not able to click on the yes or no radio buttons or the CBI boxin the questionnaire file.Close and reopen the file following the direction above. Alternatively, you maydownload a new copy of the file from the website or make a note and provideanswers in the comments section. If responses are CBI, state this in the commentsection and check the CBI box next to the comment.Do I have to answer all the questions? You must complete all applicable technical and financial questions as instructed,and provide best estimates for all questions. Use the comments page to provideany additional explanations, or if you have trouble entering your response into thespecific answer field.What if my response is larger than the space provided (i.e., notenough space in a cell or column)?Most cells in the survey have a limit of 255 characters. If the space provided isinsufficient, write “see comments” and provide the extended answer in thecomments question at the end of the section. Use multiple comments cells asnecessary.The excel file will not open, I cannot select answers in thequestionnaire, and/or the Plant ID did not pre-populate at the top ofevery worksheet in the electronic version of the questionnaire.Version 3August 27, 2010Frequently Asked Questions - GeneralP. 40 of 44Question ResponseI cannot see the number I entered. It does not fit in the spaceprovided. Can I expand or reformat the cell?EPA has locked the Excel files so that the format and size of the cells cannot bechanged. Please enter numbers without any commas or other characters. If thenumber is too large to fit in the cell, the number should be displayed in scientificnotation. If it does not convert to scientific notation, you may see “######”displayed; however, the full number is still located in the cell itself. If you click inthe cell, you will see the cell contents displayed near the top of the Excel windowbetween the toolbars and the spreadsheet itself. You are required to return theelectronic Excel files to EPA, and EPA will retrieve the data from the spreadsheetelectronically.What if I need more rows to report the information for my operation(e.g., pond/impoundments in Table A-4)?Please contact the technical helpline to discuss your situation and determine thebest approach for documenting your answers.What if I need more copies of a section? Click the copy button located directly under the instructions for each section.Selecting the copy button will generate new worksheets within the Excel filecontaining the same tables and questions from the specific section. If additionalworksheets are accidentally generated from selecting the copy button, theunneeded worksheets can simply be deleted.How many plants have received this questionnaire? A total of 733 steam electric plants received the questionnaire. A list of thoseplants can be found on EPA’s web site, atwww.epa.gov/guide/steam.Why did EPA send the questionnaire to a subset of plants in theindustry?EPA has identified approximately 1,200 fossil- and nuclear-fueled steam electricpower plants that are potentially within scope of the data collection objectives ofthe questionnaire. To reduce the overall burden on the industry, EPA distributedthe questionnaire to all coal-fired (including petroleum coke-fired) power plantsand to a statistically-sampled subset of other power plants.Version 3August 27, 2010Frequently Asked Questions - GeneralP. 41 of 44Question ResponseHow will the questionnaire results be used? EPA will use the technical data collected by the steam electric questionnaire torevise the effluent limitation guidelines and standards (ELGs) for the steam electricpower generating industry. These revisions will focus on FGD wastewater,treatment, and ash handling practices. In combination with the technical data, thefinancial data collected will aid EPA in developing appropriate technology basedguidelines for the steam electric industry.What are effluent limitation guidelines and standards? Effluent limitation guidelines and standards are discharge limits for categories ofdischargers of wastewater. Depending on the industrial category, the dischargelimits may cover process wastewater, stormwater and/or cooling water. The limitsare incorporated into NPDES permits.If you wish to protect any information submitted from public disclosure, you mayassert a claim of business confidentiality covering all or part of the information yousubmit. This claim should be made at the time of questionnaire submittal.Regulations regarding data confidentiality and directions for claiming dataconfidentiality are discussed in the questionnaire instructions on page (vi). Checkthe “CBI” box if you wish to designate the response to that question as CBI.Regulations governing the confidentiality of business information are contained in40 CFR Part 2, Subpart B.What assurances do I have that CBI will be protected? Regulations governing the handling of confidential business information arecontained in 40 CFR Part 2, Subpart B. Please refer to the questionnaireIntroduction for a summary of these regulations.In what format should I submit the questionnaire back to EPA? You must return the completed Microsoft Excel version of the questionnaire toEPA. Do NOT return the questionnaire in PDF format.Do I have to submit the survey electronically and follow it up with ahardcopy?You only need to submit an electronic copy, we do not need a hardcopy. Thecertification certification statement can be scanned and saved on the cd orsubmitted as a hardcopy.What about submitting confidential business information (CBI)?Version 3August 27, 2010Frequently Asked Questions - GeneralP. 42 of 44Question ResponseHow should I submit the signed certification page and the requiredmaps with our responses?Please either save a pdf version of the signed certification statement page and mapsto the CD/DVD with the responses or return a hardcopy of the signed certificationpage and maps. EPA prefers to receive these document in electronic format, ifpossible.May I submit the files to EPA for more than one plant on one CD orDVD?Yes, you may submit the files for multiple plants on the same CD or DVD. Pleaseuse the following naming convention for files submitted in this way:PlantID_PartX.xls. For example, name the Part A response for Plant ID 00001 as"00001_PartA.xls."What if the CD containing the questionnaire files was broken when itarrived or my plant misplaced the CD?All the questionnaire files can be downloaded from the EPA website athttp://www.epa.gov/guide/steam/.Can the questionnaire be saved to the CD/DVD already provided orshould it be saved to a new CD/DVD?It would be best to save the files to a clean CD/DVD. If you choose to save them tothe CD/DVD already provided, be sure to rename the files.I accidently answered a question that I did not mean to answer. Isthere any way to clear the answer?Answers cannot be cleared. Make sure the final response contains the correctselection. If the selection did not need to be made, please enter a comment for thatquestion.If a plant is in the process of changing its name, such that the plantname on the submission date is not the same as on the issue date,what name should be provided on the submitted questionnaire?The plant should report the plant name at the time of submittal and note the changein the comments section.Version 3August 27, 2010Frequently Asked Questions - GeneralP. 43 of 44Question ResponseSome questions refer to “as reported in US DOE/EIA Form 860Schedule 3, line 1.” Where can I locate this form?The Form EIA-860 is a generator level data file that includes specific informationabout generators at electric power plants owned and operated by electric utilitiesand nonutilities (including independent power producers, combined heat andpower producers, and other industrials).All existing plants and proposed (5-year plans) plants that: 1) have a totalgenerator nameplate capacity (sum for generators at a single site) of 1 MW orgreater; and 2) where the generator(s), or the facility in which the generator(s)resides, is connected to the local or regional electric power grid and has the abilityto draw power from the grid or deliver power to the grid are required to completeand submit the Form EIA-860 to EIA on an annual basis.The instructions for the form can be found at the following website:http://www.eia.doe.gov/cneaf/electricity/forms/eia860.pdfIs it sufficient to provide the plant's name and ID on just the firstpage, instead of every page, of a document requested in thequestionnaire?If the plant submits the document electronically as one file, the plant can onlyinclude the plant name and ID on the first page of the report. However, if the plantsubmits the document in hard copy, the plant must include the plant name and IDon every page.The questionnaire instructions state "Do not leave any questionsblank." Does this include questions you are instructing to skip?No, if you are instructed to skip a question, set of questions, or entire section, youcan leave the question(s) blank. All questions that you are instructed to answer, notincluding skips, must be answered.Version 3August 27, 2010Frequently Asked Questions - GeneralP. 44 of 44Question ResponseIf a plant does not have the requested data/figures/diagrams, can theplant state so on the ICR or does the plant have to collect/create thedata/figures for the ICR?If a plant does not have certain data or figures requested in the ICR, it is the plant'sresponsibility to provide a best engineering estimate or informal diagram. As itstates in the questionnaire instructions, "EPA is not requiring your company orplant to perform non-routine tests or measurements solely for the purpose ofresponding to the questionnaire, with the exception of companies or plants chosento complete Part G. In the event that exact data are not available, provide bestengineering estimates and note the methods that were used to make the estimates inthe Comments page located at the end of each part of the questionnaire."Table A-4 provides space to add up to 14 active/inactive/open and/or4 retired/closed and/or 5 planned pond/impoundment units but ourplant has more. How do we account for the additionalpond/impoundment units?We will need to amend both Parts A and D of your questionnaire to accommodatethe additional ponds. If you have already started filling out the questionnaire, wewill need you to send your partially completed electronic copy of both Part A andPart D so that we can modify these files for you. If you have not started filling outthe questionnaire, we can send a modified version of each before you beginanswering questions. Let us know how many additional rows you need in Table A4 for each group (active/inactive/open, retired/closed, and planned).