MEMORANDUM 

TO: Bill Swietlik, EPA 

FROM: Jill Lucy, ERG 

 

DATE: April 19, 2013 

SUBJECT: Loadings Analysis for the Steam Electric ELGs Environmental Assessment 

(SE01956) 

 The U.S. Environmental Protection Agency (EPA) is proposing revised effluent 

limitations guidelines and standards (ELGs) for the Steam Electric Power Generating Point 

Source Category (40 CFR 423). In support of the development of the revised ELGs, ERG 

supported EPA in conducting an environmental assessment (EA) to evaluate the environmental 

impact of pollutant loadings released under current (i.e., baseline) discharge practices and assess 

the potential environmental improvement from pollutant loading reductions under varying 

regulatory options. 

 Pollutants commonly found in combustion wastewater, such as metals, nutrients, and 

total dissolved solids (TDS) (including bromides and chlorides), can cause considerable harm to 

surface waters, aquatic life, wildlife, and human health. This memorandum provides a summary 

of the data and calculations performed to estimate pollutant loadings from steam electric power 

plants for the waste streams evaluated as part of the proposed ELGs and presented in EPA’s 

Environmental Assessment for the Proposed Effluent Limitations Guidelines and Standards for 

the Steam Electric Power Generating Point Source Category (EA Report) (DCN SE01995) . The 

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

water, bottom ash transport water, and landfill and surface impoundment leachate wastewater. 

1.0 BACKGROUND ON POLLUTANT LOADINGS METHODOLOGY 

 ERG calculated pollutant loadings on a plant-by-plant basis for all steam electric power 

plants that fell within the scope of the proposed ELGs. The loadings methodology and 

calculations are documented in Section 10 of EPA’s Technical Development Document for the 

Proposed Effluent Limitations Guidelines and Standards for the Steam Electric Power 

Generating Point Source Category (TDD) (DCN SE01964), and Incremental Costs and 

Pollutant Removals for Proposed Effluent Limitation Guidelines and Standards for the Steam 

Electric Generating Point Source Category (Costs and Loads Report) (DCN SE01957). Pollutant 

loadings are presented in the TDD, Costs and Loads Report, and the EA Report in two ways: 

pounds per year (lbs/yr) and toxic-weighted pound equivalents (TWPE) per year (lbequivalent/yr). EPA developed TWPE to account for differences in toxicity across pollutants and 

provide the means to compare mass loadings of different pollutants on the basis of their toxic 

potential. EPA multiplies a mass loading of a pollutant in pounds per year by a pollutant-specific 

weighting factor, called the toxic weighting factor (TWF), to derive a "toxic-equivalent" loading, 
Memorandum 

April 19, 2013 

Page 2 

or TWPE. EPA has developed TWFs for more than 1,900 pollutants based on aquatic life and 

human health toxicity data, as well as physical/chemical property data [U.S. EPA, 2006]. 

Table 1-1 presents the pollutants included in the loadings methodology. For the EA, ERG 

considered a subset of these pollutants. Specifically, ERG considered the following when 

determining which pollutants to include in the EA loadings analyses: 

 Is the pollutant present in waste streams evaluated in the EA (i.e., fly ash transport water, 

bottom ash transport water, FGD wastewater, and/or landfill and surface impoundment 

leachate)? 

 Have elevated levels of the pollutant been observed in surface waters or wildlife from 

exposure to combustion wastewater?
Memorandum 

April 19, 2013 

Page 3 

Table 1-1. Pollutants Included in the Steam Electric ELG Pollutant Loadings Analysis and 

EA Loadings Analyses 

Pollutant 

Associated Waste Streams Evaluated in EA 

Fly Ash Transport Water Bottom Ash Transport Water FGD Wastewater Leachate 

Included in EA Loadings Analyses 

Aluminum X X X X 

Arsenic X X X X 

Boron X X X X 

Cadmium X X X X 

Chromium (VI) X X X 

Copper X X X X 

Iron X X X X 

Lead X X X X 

Manganese X X X X 

Mercury X X X X 

Nickel X X X X 

Selenium X X X X 

Thallium X X X X 

Vanadium X X X X 

Zinc X X X X 

Chloride X X X X 

Total dissolved solids (TDS) X X X X 

Phosphorus, total X X X 

Nitrate / Nitrite as N a X X X 

Nitrogen, Total Kjeldahl a X X X 

Not Included in EA Loadings Analyses 

Ammonia 

See Section 10 of the TDD 

Antimony 

Barium 

Beryllium 

Biochemical oxygen demand 

Calcium 

Chemical oxygen demand 

Chromium 

Cobalt 

Cyanide, total 

Magnesium 

Molybdenum 

Silver 

Sodium 

Sulfate 

Tin 

Titanium 

Total suspended solids 

a – Included in analysis as total nitrogen. Total nitrogen is equal to nitrate/nitrite + Total Kjeldahl Nitrogen 

(TKN).
Memorandum 

April 19, 2013 

Page 4 

2.0 LOADINGS FROM EVALUATED WASTE STREAMS AT STEAM ELECTRIC POWER PLANTS

 ERG used the following four methods to evaluate the pollutant loadings from evaluated 

waste streams discharging from steam electric power plants: 

1. Total pounds and TWPE of pollutant loadings discharged to receiving waters. 

2. Comparison of steam electric evaluated waste stream loadings to those from other point 

source categories. 

3. Comparison of steam electric evaluated waste stream loadings to those from publicly 

owned treatment works (POTWs). 

4. Comparison of average pollutant loadings by waste stream from a steam electric plant to 

pollutant loadings discharged by a “typical” POTW. 

These four methods of evaluation are described in the following sections. 

2.1 Pollutant Loadings to Receiving Waters 

 As discussed in Section 1.0 of this memorandum, the EA loadings analyses included only 

a subset of the pollutants included in the pollutant loadings calculations completed for the 

proposed ELGs. Table 2-1 presents the baseline annual pollutant loadings discharged in the 

evaluated waste streams for select pollutants considered for analysis in the EA. 

 Table 2-1. Annual Baseline Discharges of EA-Evaluated Pollutants from the Evaluated 

Waste Streams 

Pollutant a TWF b

Annual Discharge, 

pounds (lbs) 

Annual TWPE, poundequivalents (lb-eq) 

Metals 

Manganese 0.07043 14,500,000 1,020,000 

Cadmium 23.1168 31,900 738,000 

Boron 0.00834 54,300,000 453,000 

Mercury 117.118 2,820 330,000 

Arsenic 4.0413 79,200 320,000 

Selenium 1.1213 225,000 252,000 

Thallium 1.0271 164,000 168,000 

Lead 2.24 64,400 144,000 

Aluminum 0.0647 1,970,000 128,000 

Copper 0.6348 69,900 44,400 

Nickel 0.1089 287,000 31,200 

Iron 0.0056 4,990,000 27,900 

Zinc 0.0469 393,000 18,400 

Chromium VI 0.5166 11,800 6,090 

Vanadium 0.035 158,000 5,530 

Total Metals c 1,790,000,000 4,800,000 
Memorandum 

April 19, 2013 

Page 5 

 Table 2-1. Annual Baseline Discharges of EA-Evaluated Pollutants from the Evaluated 

Waste Streams 

Pollutant a TWF b

Annual Discharge, 

pounds (lbs) 

Annual TWPE, poundequivalents (lb-eq) 

Nutrients 

Total Nitrogen Not applicable 30,400,000 Not applicable 

Total Phosphorus Not applicable 682,000 Not applicable 

Other 

Chlorides 2.435 X 10-05 1,640,000,000 39,800 

Total Pollutants c,d 5,500,000,000 8,320,000 

Source: U.S. EPA, 2013a; U.S. EPA, 2006. 

a – The list of pollutants included in this table is only a subset of pollutants included in the loadings analysis (see Section 10 of 

the TDD). 

b – TWFs for the following metals apply to all metal compounds: arsenic, chromium, copper, lead, manganese, mercury, nickel, 

selenium, thallium, vanadium, and zinc. EPA updated TWFs for boron, chlorides, chromium compounds, and iron for the Steam 

Electric ELGs pollutant loadings analysis.

c – To avoid double-counting of dissolved metals, the totals include all pollutants from the loadings analysis with the exception 

of TDS. Annual baseline discharges of TDS from the evaluated waste streams total approximately 7,120,000,000 pounds. 

d – The totals represent the pollutant loadings in discharges of the evaluated waste streams – specifically, FGD wastewater, fly 

ash transport wastewater, bottom ash transport wastewater, and leachate (see Section 10 of the TDD). 

2.2 Comparison of Evaluated Waste Stream Loadings from Steam Electric Power 

Plants to Those from Other Point Source Categories

 ERG completed two evaluations as part of the pollutant loadings comparison to other 

point source categories. The first included comparing TWPE loadings from the evaluated waste 

streams at steam electric power plants (regulated under 40 CFR 423) to TWPE loadings from all 

other point source categories. The second analysis compared the TWPE loadings from the 

evaluated waste streams at steam electric power plants to the other top point source category 

dischargers. 

 To determine pollutant loadings from other point source categories, ERG used the 

loadings calculated by EPA as part of its 2012 Effluent Guidelines Program Plan and 2010 

Effluent Guidelines Program Plan (see http://water.epa.gov/lawsregs/lawsguidance/cwa/304m/

for more details on this program). The source of the data for the 2012 Effluent Guidelines 

Program Plan is the discharge monitoring report (DMR) database, 

DMRLoadsAnalysis2009_v02.mdb (the database with tables and queries used for the steam 

electric ELGs is included in the record as DCN SE01961). The source of the data for the 2010 

Effluent Guidelines Program Plan is the Technical Support Document for the 2010 Effluent 

Guidelines Program Plan (EPA 821-R-09-006) [U.S. EPA, 2011]. 

 The calculation and results of the first total pollutant loadings comparison analysis are 

documented in the ERG memorandum, Comparison of Steam Electric Industry Toxic Loadings 

to Other Industrial Dischargers (DCN SE02155). ERG calculated that the total TWPE loadings 

from the evaluated waste streams at steam electric power plants account for at least 50 to 60 

percent of the toxic pollutants reported to be discharged in industrial National Pollutant 

Discharge Elimination System (NPDES) permits. 
Memorandum 

April 19, 2013 

Page 6 

 Table 5-3 of the Technical Support Document for the 2010 Effluent Guidelines Program 

Plan [EPA 821-R-09-006] presents the TWPE discharges for point source categories evaluated 

by EPA.1

 Table 2-2 presents the total loadings from the top ten discharging categories, along 

with the estimated TWPE for the evaluated waste streams at steam electric power plants. 

Table 2-2. Pollutant Loadings for the Final 2010 Effluent Guidelines Planning Process: 

Top 10 Point Source Categories

40 CFR Part Point Source Category 

Total TWPE 

 (lb-eq/yr) 

423 Steam Electric Industry – Evaluated Waste Streams 8,320,000 a

430 Pulp, Paper And Paperboard 1,030,000 

419 Petroleum Refining 1,030,000 

421 Nonferrous Metals Manufacturing 994,000 

418 Fertilizer Manufacturing 826,000 

414 Organic Chemicals, Plastics And Synthetic Fibers 649,000 

440 Ore Mining And Dressing 448,000 

415 Inorganic Chemicals Manufacturing 299,000 

444 Waste Combustors 254,000 

410 Textile Mills 250,000 

Source: U.S. EPA, 2011. 

a – As presented in Section 10 of the TDD, EPA estimates that 8,320,000 TWPE are discharged annually from steam electric 

power plants associated with the waste streams evaluated as part of the proposed rule. 

2.3 Comparison of Evaluated Waste Stream Loadings from Steam Electric Power 

Plants to Those from POTWs

 To provide additional perspective on the magnitude of the pollutant loadings included in 

the loadings analysis, ERG calculated pollutant loadings discharged from an average POTW. 

EPA selected POTWs for comparison because, for point sources, POTWs and steam electric 

plants dwarf all other point source discharges in terms of total TWPE of metals discharged to 

waters in the United States [U.S. EPA, 2010].2

 In addition, the approximately 16,000 POTWs are 

 

1

 EPA did not calculate steam electric point source categories as part of the annual review because EPA had already begun 

revising Part 423. “Because the Steam Electric rulemaking is underway, EPA excluded discharges from these facilities from 

further consideration under the current planning cycle.” See Section 5.2.1 of the Technical Support Document for the 2010 

Effluent Guidelines Program Plan [EPA 821-R-09-006]. 

2

 Based on metal loadings (total TWPE) calculated by EPA’s DMR Pollutant Loading Tool, 2010 data, by Standard Industrial 

Classification (SIC) code. The top two industries are SIC 4952 – sewerage systems (i.e., POTWs) and SIC 4911 – electrical 

services. 

EPA’s DMR Pollutant Loading Tool is an online tool (http://cfpub.epa.gov/dmr/) that calculates pollutant loadings from permit 

and DMR data from EPA‘s Permit Compliance System (PCS) and Integrated Compliance Information System for the National 

Pollutant Discharge Elimination System (ICIS-NPDES). The tool also ranks dischargers, industries, and watersheds based on 

pollutant mass and toxicity, and presents “top 10” lists to help users determine which facilities and industries are producing these 

discharges and which watersheds are impacted. Facilities report pollutant discharge monitoring data in their DMR as mass-based 

quantities (e.g., pounds per day) and/or concentrations (e.g., mg/L). The DMR Pollutant Loading Tool allows users to gather 

annual loadings data. For this EA, EPA reviewed the 2010 loadings reported in DMRs. 

The use of the DMR data has its limitations. Only pollutants included in the facility’s NPDES permit are included in the PCS and 

ICIS-NPDES databases; therefore, if a facility does not have mercury limitations, mercury discharges from that facility will not 

be included in the total for industrial discharges. States (or other permitting authorities) have some discretion as to which data 
Memorandum 

April 19, 2013 

Page 7 

located across the United States, are known to have consistent wastewater influent 

characteristics, and are a common metric used for point source evaluations. 

2.3.1 Calculation of Average Discharge Flow Rate from a Typical POTW 

 ERG defined an average (or typical) POTW discharge as equaling an effluent flow rate 

between 3 and 5 million gallons per day (MGD). 3 This was based on the number of POTWs in 

various flow rate categories as reported in Metcalf and Eddy, 2003. ERG used the Metcalf and 

Eddy data and performed the following calculations: 

 Step 1. Use midpoint of flow ranges as the average flow for the number of facilities 

represented in that flow rate group. For example, the average flow rate for the group: 

1.001 – 10.0 MGD is calculated as: 

[1.001 + 10.0] = 5.5005 MGD 

 2 

For the group >100 MGD, ERG assumed an average flow rate of 100 MGD. 

 Step 2. Multiply the average flow rate by the number of facilities in each group. 

 Step 3. Sum the results of Step 2 and divide by the total number of facilities in all groups 

(15,986 POTWs). The result is an average discharge rate weighted by number of facilities 

in each flow rate group. 

Σ (Scaled flow rate by number of facilities)group

Total Number of Facilities in All Groups 

The data and calculations performed are included in Table 2-3. The calculated average flow rate 

from a typical POTW is 3.0 MGD. To expand the number of facilities that would be included as 

typical or average when selecting monitoring data, ERG chose to use the average flow rate range 

of 3 to 5 MGD. 

 For comparison purposes, ERG also calculated the average flow rate reported for POTWs 

in the DMR database, DMRLoadsAnalysis2009_v02.mdb (the database with tables and queries 

used for the steam electric ELGs is included in the record as DCN SE01961). ERG used the 

POTW2009 database table and calculated the average flow rate across all database entries (see 

Queries POTW flow1 and POTW flow 2 in the database). The calculated average flow rate is 3.6 

MGD. 

 they make available (or enter) in PCS and ICIS-NPDES. For example, permitting authorities enter DMR and permit information 

for facilities that are considered major dischargers. However, they do not necessarily enter DMR or permit information into PCS

for minor dischargers or facilities covered by a general permit. 

3

 For comparison, the average discharge flow rate for the steam electric waste streams of concern are 0.5 MGD for FGD 

wastewater; 2.4 MGD for fly ash sluice water; 1.8 MGD for bottom ash sluice water; and 0.06 MGD for leachate (U.S. EPA, 

2012b). 
Memorandum 

April 19, 2013 

Page 8 

Table 2-3. Number of POTWs by Flow Range 

Flow Ranges (MGD) a Number of POTWs a Average Flow 

Calculation to Scale Flow Rate 

by Number of POTWs 

0 - 0.100 6,444 0.05 [6,444 × 0.05] = 322 

0.101 - 1.0 6,476 0.5505 [6,476 × 0.5505] = 3,565 

1.001 - 10.0 2,573 5.5005 [2,573 × 5.5005] = 14,153 

10.001 - 100.0 446 55.0005 [446 × 55.00005] = 24,530 

>100.0 47 100 [47 × 100] = 4,700 

Total Number of 

POTWs: 

15, 986 

Average Flow scaled by 

Number of POTWs: 

3.0 MGD

a – Based on 1996 data from Metcalf and Eddy, 2003 (page 14). 

MGD – Million gallons per day. 

2.3.2 Calculation of Pollutant Loadings from a Typical POTW 

 EPA calculated the average pollutant loadings discharged from a typical POTW using 

EPA’s DMR database, DMRLoadsAnalysis2009_v02.mdb (the database with tables and queries 

used for the steam electric ELGs is included in the record as DCN SE01961). ERG developed 

queries in the database, as follows: 

 Query POTW query selects the POTWs that discharge between 3 and 5 MGD 

included in the database table, DMR2009_download. The query links 

DMR2009_Download and DMRFAC2009 and PRAM Codes (provides description of 

the monitoring parameter) and uses two criteria for data selection: 

1. DMR2009_Download: AVG_Flow = “Between 3 and 5” (MGD) 

2. DMRFAC2009: Facility Type = “POTW” 

 Query POTW query2 calculates the average DMR loadings (in pounds and TWPE per 

year) for each pollutant. Table 2-4 presents the results of the database queries.

Table 2-4. Average Pollutant Loadings for POTWs Discharging Between 3 and 5 MGD 

Parameter 

Code 

Pollutant 

(Parameter Description) 

Pollutant Loading 

(lb/yr) 

Pollutant TWPE 

(lb-eq/yr) 

Average Flow Rate 

(MGD) b

01105 Aluminum, total (as Al) 3,587.99 215.28 4.07 

01002 Arsenic, total (as As) 45.95 185.63 3.83 

01022 Boron, total (as B) 1,536.20 12.81 3.85 

01027 Cadmium, total (as Cd) 3.54 81.91140558 3.884276824 

01032 Chromium, hexavalent (as Cr) 17.69 9.022483591 3.942416667 

01042 Copper, total (as Cu) 153.99 97.01 3.836265231 

01045 Iron, total (as Fe) 2,533.32 14.19 3.922394928 

01051 Lead, total (as Pb) 48.53 108.70 3.906622537 

01055 Manganese, total (as Mn) 353.96 24.78 3.828868421 
Memorandum 

April 19, 2013 

Page 9 

Table 2-4. Average Pollutant Loadings for POTWs Discharging Between 3 and 5 MGD 

Parameter 

Code 

Pollutant 

(Parameter Description) 

Pollutant Loading 

(lb/yr) 

Pollutant TWPE 

(lb-eq/yr) 

Average Flow Rate 

(MGD) b

71900 Mercury, total (as Hg) 3,178.97 372,289.13 3.964028137 

01067 Nickel, total (as Ni) 30.61 3.06 3.861026891 

01147 Selenium, total (as Se) 18.45 20.67 3.898502866 

01059 Thallium, total (as Tl) 9.94 10.14 3.744368 

 Vanadium, total No data No data No data 

01092 Zinc, total (as Zn) 453.30 18.13 3.937479809 

00600 Nitrogen, total (as N) 123,059.42 Not applicable 3.898905349 

00665 a Phosphorus, total (as P) 17,778.60 Not applicable 3.86 

00940 Chloride (as Cl) 1,614,511.49 39.31 3.89 

 Total dissolved solids (TDS) No data No data No data 

Source: U.S. EPA, 2013b. 

a – Phosphorous loadings are also reported under parameter code 51426; however, ERG did not include these loadings due to 

their low value (251.32 lbs/yr) when compared to parameter code 00665. 

b – Flow rate included for informational purposes; ERG did not use the flow data for any further analysis. 

2.3.3 Results of Comparison 

 To compare the total annual loadings from the evaluated waste streams at the 290 steam 

electric plants included in the loadings analysis (see Table 2-1) to total annual loadings from 

POTWs, ERG determined the number of typical POTWs that would discharge the equivalent of 

the evaluated waste streams for the 290 steam electric plants. To calculate this, ERG divided the 

annual loadings value for a pollutant, listed in Table 2-1, by the annual loadings of a typical 

POTW, listed in Table 2-4. For example, the steam electric plants in this analysis discharge 

225,000 pounds of selenium per year. A typical POTW discharges 18.45 pounds of selenium per 

year (rounded to 18 pounds per year). The number of typical POTWs whose discharge of 

selenium is equivalent to the steam electric plant discharges is: 

225,000 lb/yr = 12,500 POTWs (compared to 290 steam electric power plants) 

 18 lb/yr 

Because TWPEs are calculated using the same TWF regardless of industry, the number of 

typical POTWs discharging the same TWPE as the steam electric power plants is also 12,500 

POTWs. Table 2-5 presents the number of typical POTWs that would discharge an equivalent 

amount of pollutant loadings to surface water compared to the 290 steam electric power plants in 

this analysis. 
Memorandum 

April 19, 2013 

Page 10 

Table 2-5. Estimated Number of POTW Equivalents for Total Pollutant Loadings from the 

Evaluated Waste Streams

Pollutant 

Annual Discharge by Steam 

Electric Power Plants, lbs a

Annual Discharge by 

Typical POTW, lbs b

Equivalent Number of 

Typical POTWs 

Aluminum 1,970,000 3,590 550 

Arsenic 79,200 46 1,720 

Boron 54,300,000 1,540 35,300 

Cadmium 31,900 4 7,980 

Chromium VI 11,800 18 655 

Copper 69,900 154 454

Iron 4,990,000 2,530 1,970

Lead 64,400 49 1,320

Manganese 14,500,000 354 41,000

Mercury 2,820 3,180 <1

Nickel 287,000 31 9,250

Selenium 225,000 18 12,500

Thallium 164,000 10 16,400

Vanadium 158,000 No data No data

Zinc 393,000 453 868

Total Nitrogen 30,400,000 123,000 247

Total Phosphorus 682,000 17,800 38

Chlorides 1,640,000,000 1,610,000 1,020

TDS 7,120,000,000 No data No data

a – U.S. EPA, 2013a. 

b – U.S. EPA, 2013b. 

2.4 Comparison of Average Steam Electric Waste Stream Loadings to Typical POTW 

Loadings

 To provide additional perspective on the magnitude of the pollutant loadings from steam 

electric power plants, ERG compared loadings for the evaluated waste streams to those of a 

typical POTW. The evaluated waste streams include FGD wastewater, fly ash wastewater, 

bottom ash wastewater, and leachate. Table 2-6 presents total pollutant loadings for the evaluated 

waste streams (for the 290 plants) and the annual loadings from a typical POTW. 

 Example calculation: The average FGD wastewater discharge of selenium equals 1,490 

pounds per year from a single steam electric power plant. A typical POTW discharges 18 pounds 

of selenium per year. The number of POTWs whose discharge is equivalent to the average FGD 

wastewater discharge from a steam electric power plant (of selenium) is: 

 1,490 lb/yr = 83 POTWs (compared to 1 steam electric power plant) 

 18 lb/yr 

Because TWPEs are calculated using the same TWF regardless of industry, the number of 

typical POTWs discharging the same TWPE as the average FGD wastewater discharge from a 

steam power plant (of selenium) is also 83 POTWs. Table 2-7 presents the number of POTWs 

that would discharge an equivalent amount of pollutant loadings to surface water compared to 

the average waste stream discharge from a steam electric power plant. 
Memorandum 

April 19, 2013 Page 11 

Table 2-6. Comparison of Average Pollutant Loadings in the Evaluated Waste Streams to a Typ

Pollutant 

Average Plant FGD 

Discharge a,b

Average Plant Fly Ash 

Discharge a,c

Average Plant Bottom 

Ash Discharge a,d

Average Plant 

Leachate Discharge a,e

Loadings 

(lbs/yr) 

TWPE 

(lb-eq/yr) 

Loadings 

(lbs/yr) 

TWPE (lbeq/yr) Loadings (lbs/yr) TWPE (lb-eq/yr) Loadings (lbs/yr) TWPE (lb-eq/yr) 

Aluminum 2,500 162 7,660 495 2,220 144 1,110 71.9 Arsenic 10.1 40.9 479 1,940 69 279 11.1 44.7 Boron 410,000 3,420 18,900 158 8,330 69.5 4,780 39.8 Cadmium 133 3,070 58.6 1,350 30.5 705 0.594 13.7 Chromium VI 6.7 3.46 77.6 40.1 7.95 4.11 (g) (g) Copper 26.1 16.6 280 178 113 72 2.11 1.34 Iron 1,850 10.4 5,850 32.7 8,610 48.2 15,100 84.4 Lead 5.93 13.3 206 461 134 299 0.335 0.751 Manganese 115,000 8,090 3,680 259 680 47.9 1,050 74.2 Mercury 6.58 771 8.65 1,010 3.33 390 0.26 30.4 Nickel 1,030 112 239 26.1 451 49.1 16.6 1.81 Selenium 1,490 1,670 257 289 44.7 50.2 20.5 23 Thallium 19.3 19.8 300 308 427 439 0.359 0.369 Vanadium 25.9 0.908 428 15 50.7 1.77 876 30.7 Zinc 1,630 76.7 790 37 338 15.9 40.1 1.88 Total Nitrogen h 109,000 - 39,000 - 39,400 - (g) - Total Phosphorus h 651 - 1,810 - 1,320 - (g) - Chlorides 12,800,000 311 265,000 6.46 187,000 4.55 155,000 3.78 TDS 44,100,000 - 3,690,000 - 4,350,000 - 993,000 - a – All values are rounded to three significant figures. b – Average FGD loadings are based on 117 plants assumed to discharge FGD wastewater under baseline conditions [U.S. EPA, 2013a]. c – Average fly ash loadings are based on 93 plants assumed to discharge fly ash sluice under baseline conditions [U.S. EPA, 2013a]. d – Average bottom ash loadings are based on 244 plants assumed to discharge bottom ash sluice under baseline conditions [U.S. EPA, 2013a]. e – Average leachate loadings are based on 102 plants assumed to discharge leachate under baseline conditions [U.S. EPA, 2013a]. f – Typical POTW loadings are based on average loadings calculated by DMRLoadsAnalysis2009_v02.mdb for POTWs discharging 3 to 5 MGD of wg – EPA did not calculate loadings for this pollutant and waste stream. See Section 10 of the TDD. h – EPA has not developed a TWF for this pollutant; therefore ERG did not calculate a TWPE value.
Memorandum 

April 19, 2013 Page 12 

Table 2-7. Results of Comparison of Average Pollutant Loadings in the Evaluated Waste Streams to a 

Pollutant 

Number of POTWs Equivalent to: 

Average Plant FGD 

Discharge 

Average Plant Fly Ash 

Discharge 

Average Plant Bottom Ash 

Discharge 

Ave

Aluminum 2,500 / 3,590 = <1 7,660 / 3,590 = 2 2,220 / 3,590 = <1 1Arsenic 10.1 / 46 = <1 479 / 46 = 10 69 / 46 = 2 Boron 410,000 / 1,540 = 266 18,900 / 1,540 = 12 8,330 / 1,540 = 5 4Cadmium 133 / 4 = 33 58.6 / 4 = 15 30.5 / 4 = 8 0Chromium VI 6.7 / 18 = <1 77.6 / 18 = 4 7.95 / 18 = <1 Copper 26.1 / 154 = <1 280 / 154 = 2 113 / 154 = <1 Iron 1,850 / 2,530 = <1 5,850 / 2,530 = 2 8,610 / 2,530 = 3 15Lead 5.93 / 49 = <1 206 / 49 = 4 134 / 49 = 3 0Manganese 115,000 / 354 = 325 3,680 / 354 = 10 680 / 354 = 2 1Mercury 6.58 / 3,180 = <1 8.65 / 3,180 = <1 3.33 / 3,180 = <1 Nickel 1,030 / 31 = 33 239 / 31 = 8 451 / 31 = 15 Selenium 1,490 / 18 = 83 257 / 18 = 14 44.7 / 18 = 2 Thallium 19.3 / 10 = 2 300 / 10 = 30 427 / 10 = 43 0Vanadium Not calculated Not calculated Not calculated Zinc 1,630 / 453 = 4 790 / 453 = 2 338 / 453 = <1 Total Nitrogen 109,000 / 123,000 = <1 39,000 / 123,000 = <1 39,400 / 123,000 = <1 Total Phosphorus 651 / 17,800 = <1 1,810 / 17,800 = <1 1,320 / 17,800 = <1 Chlorides 12,800,000 / 1,610,000 = 8 265,000 / 1,610,000 = <1 187,000 / 1,610,000 = <1 155,0TDS Not calculated Not calculated Not calculated 
Memorandum 

April 19, 2013 

Page 13 

3.0 LOADINGS TO THE CHESAPEAKE BAY AND THE GREAT LAKES

 ERG evaluated pollutant loadings from evaluated waste streams that discharge to two 

sensitive watersheds, the Chesapeake Bay (an estuary) and the Great Lakes. For both watersheds, 

ERG performed the following steps: 

1. Identified steam electric power plants discharging the evaluated waste streams to the 

watershed and their pollutant loadings at baseline. 

2. Performed a literature search to identify studies or data collected on the total 

industrial or point source discharges of pollutants included in the EA analysis. 

3. Compared the steam electric evaluated waste stream discharges to literature data. 

4. Compared the steam electric evaluated waste stream discharges to a typical POTW 

(see Section 2.3 for methodology).

3.1 Evaluation of Steam Electric Power Plant Discharges to the Chesapeake Bay

 Based on survey data and further review of discharge locations, ERG identified 20 steam 

electric power plants discharging to the Chesapeake Bay watershed. Based on the loadings 

analysis completed for the steam electric proposed ELGs, these plants discharge 2.2 million 

pounds of nitrogen and 60,000 pounds of phosphorus to the Bay annually from the evaluated 

waste streams [U.S. EPA, 2012a; U.S. EPA, 2012b]. See Table 3-1 for a list of pollutant loadings 

used for this analysis. Attachment 1 of this memorandum lists the 20 steam electric power plants 

discharging to the Chesapeake Bay watershed. 

 During the literature search, ERG found two references with pollutant loadings data for 

industrial or point source discharges to the Chesapeake Bay: 1) the December 2010 EPA report, 

Chesapeake Bay Total Maximum Daily Load for Nitrogen, Phosphorus and Sediment (DCN 

SE01910), which included loadings data on total nitrogen and total phosphorus and 2) the 

Chesapeake Bay Program’s 1999 Chesapeake Bay Basin Toxics Loading and Release Inventory

(DCN SE01903), which included loadings data for metals included in the EA. ERG also 

contacted other EPA programs, including the Chesapeake Bay Program Office, to obtain 

additional or more recent data, but did not find additional data sources. 

 From the December 2010 EPA report, EPA identified 1,679 NPDES-permitted facilities 

discharging industrial wastewaters in the Chesapeake Bay watershed. In 2009, these facilities 

contributed an estimated 7.3 million pounds of total nitrogen and 1.27 million pounds of total 

phosphorus to the Bay, an estimated 3 percent and 8 percent, respectively, of all nitrogen and 

phosphorus loadings delivered to Chesapeake Bay watershed [U.S. EPA, 2010b]. 

 The 1999 Chesapeake Bay Basin Toxics Loading and Release Inventory from the 

Chesapeake Bay Program included charts showing range and midpoint of loadings estimated by 

discharge source type for multiple pollutants (see pages i-10 through i-12). ERG used best 

engineering judgment to estimate the midpoint of the chart for point source discharges of the 
Memorandum 

April 19, 2013 

Page 14 

following pollutants included in the report: arsenic, cadmium, copper, lead, mercury, and zinc. 

Table 3-1 in the following section presents the estimates.

3.1.1 Comparison of Pollutant Loadings: Steam Electric Power Plants and Other Point 

Source Discharges to the Chesapeake Bay Watershed 

 To calculate the percentage of point source loadings entering the Chesapeake Bay 

watershed from the steam electric power evaluated waste streams, ERG completed the following 

calculations: 

X lbs/yr from evaluated waste streams = Percentage of Loadings from Evaluated Waste Streams 

Y lbs/yr from all point source dischargers 

For nitrogen: 

2.2 million lbs/yr = 30% 

 7.3 million lbs/yr 

For phosphorus: 

0.060 million lbs/yr = 5% 

 1.27 million lbs/yr 

Calculations for the metal loadings comparison were completed using the same approach as 

described above. 

 Table 3-1 presents the baseline pollutant loadings for the evaluated waste streams and the 

estimated loadings from all point sources to the Chesapeake Bay watershed. The results indicate 

that pollutant loadings from the evaluated waste streams represent a large portion of the point 

source metal loadings to the Chesapeake Bay watershed for arsenic, cadmium, lead, and zinc. 

 The estimated total point source loadings of arsenic from the 1999 Chesapeake Bay Basin 

Toxics Loading and Release Inventory [Chesapeake Bay Program, 1999] was less than the 

estimated amount of arsenic discharged in evaluated waste streams from the 20 steam electric 

power plants. This inconsistency may be due to incomplete data sets. In the report, the Program 

noted that point source loadings are based on best available data and estimated only for major 

facilities (facilities with a flow of 0.5 MGD or greater) included in EPA’s Permit Compliance 

System (PCS). As part of their NPDES permits, many point sources are not required to monitor 

for arsenic and other pollutants associated with the evaluated waste streams; therefore, the report 

might not fully account for these pollutant loadings. In addition, the data are over 10 years old 

and metal pollutant loadings to the Bay may have changed during that time. 
Memorandum 

April 19, 2013 

Page 15 

Table 3-1. Comparison of Steam Electric Evaluated Waste Stream Pollutant Loadings to 

Other Point Source Discharges to the Chesapeake Bay Watershed

Pollutant 

Steam Electric Baseline 

Loadings to the 

Chesapeake Bay 

Watershed, lbs/year a

Total Point Source 

Loadings to the 

Chesapeake Bay 

Watershed, lbs/year b,c

Percentage of Point 

Source Loadings from 

Steam Electric Plants 

Arsenic 5,180 3,500 (c) 100% 

Cadmium 1,820 3,000 (c) 61% 

Copper 5,150 78,100 (c) 7% 

Lead 5,630 15,000 (c) 38% 

Mercury 168 2,660 (c) 6% 

Zinc 21,500 125,000 (c) 17% 

Total Nitrogen 2,200,000 7,340,000 (b) 30% 

Total Phosphorus 60,000 1,270,000 (b) 5% 

Sources: 

a – U.S. EPA, 2012a; U.S. EPA, 2012b. 

b – U.S. EPA, 2010b. 

c – Chesapeake Bay Program, 1999. 

3.1.2 Calculation of Equivalent Number of Typical POTWs that Discharge the Same 

Pollutant Loadings as Steam Electric Power Plants to the Chesapeake Bay 

Watershed 

 To provide additional perspective on the magnitude of the loadings, EPA calculated the 

equivalent number of typical POTWs that would discharge loadings equal to the 20 steam 

electric power plants that discharge the evaluated waste streams to the Chesapeake Bay 

watershed. Table 3-2 presents total pollutant loadings for the evaluated waste streams 

discharging to the Chesapeake Bay and the number of typical POTWs that would discharge 

equivalent loadings. 
Memorandum 

April 19, 2013 

Page 16 

Table 3-2. Estimated Number of POTW Equivalents for Pollutant Loadings to the 

Chesapeake Bay Watershed from the Evaluated Waste Streams

Pollutant 

Steam Electric Discharge 

to the Chesapeake Bay 

Watershed (20 Plants), 

lbs/yr a

Typical POTW 

Discharge 

(see Section 2.3), 

 lbs/yr 

Number of Typical POTWs 

Equivalent to 20 Steam Electric 

Plants Discharging to the 

Chesapeake Bay b 

Arsenic 5,180 46 5,180 / 46 = 113 

Cadmium 1,820 4 1,820 / 4 = 455 

Chromium VI 681 18 681 / 18 = 38 

Copper 5,150 154 5,150 / 154 = 33 

Lead 5,630 49 5,630 / 49 = 115 

Mercury 168 3,180 168 / 3,180 = <1 

Nickel 20,700 31 20,700 / 31 = 668 

Selenium 10,100 18 10,100 / 18 = 561 

Thallium 16,700 10 16,700 / 10 = 1,670 

Zinc 21,500 453 21,500 / 453 = 48 

Total Nitrogen 2,200,000 123,000 2,200,000 / 123,000 = 18 

Total Phosphorus 60,000 17,800 60,000 / 17,800 = 3 

a – U.S. EPA, 2012a; U.S. EPA, 2012b. 

b – Equivalent number of POTWs is estimated by dividing the total annual pollutant loadings to the Chesapeake Bay by the 

average POTW loadings presented in Table 2-5 for POTWs with an effluent flow rate of 3 to 5 MGD. 

3.2 Evaluation of Steam Electric Power Plant Discharges to the Great Lakes

 Based on survey data and further review of discharge locations, ERG identified 26 steam 

electric power plants discharging to the Great Lakes watershed . ERG estimated the total 

loadings associated with the evaluated waste streams from the 26 steam electric power plants 

using data from the loadings analysis (U.S. EPA, 2012a; U.S. EPA, 2012b). Table 3-3 lists the 

steam electric power plant loadings used for this analysis. Attachment 1 of this memorandum 

lists the 26 steam electric power plants discharging to the Great Lakes watershed. 

Table 3-3. Steam Electric Pollutant Loadings to the Great Lakes Watershed 

Pollutant 

Steam Electric Baseline Loadings to the 

Great LakesWatershed (lbs/year) 

Arsenic 4,170 

Cadmium 1,410 

Chromium VI 380 

Copper 5,180 

Lead 5,840 

Mercury 117 

Nickel 18,300 

Selenium 6,240 

Thallium 15,900 

Zinc 19,800 

Total Nitrogen 1,990,000 

Total Phosphorus 53,200 

Source: U.S. EPA, 2012a; U.S. EPA, 2012b. 
Memorandum 

April 19, 2013 

Page 17 

 During the literature search, ERG found one reference with nutrient loadings data for 

industrial or point source discharges to the Great Lakes. ERG contacted other EPA programs, 

including EPA Region 5 Water Division, but did not identify loadings data for metals. D.M. 

Robertson and D. A. Saad’s October 2011 article, “Nutrient Inputs to the Laurentian Great Lakes 

by Source and Watershed Estimated Using SPARROW Watershed Models” in the Journal of the 

American Water Resources presents estimated annual loadings of total phosphorus and total 

nitrogen into each Great Lake, normalized to 2002. Table 3-4 presents the relevant data included 

in Table 4 of the article. 

Table 3-4. Estimated U.S. Annual Loadings of Total Phosphorus and Total Nitrogen to 

the Great Lakes 

Great Lake 

Total Phosphorus Total Nitrogen 

2002 Total U.S. Load 

(tonnes) a

2002 Total U.S. Load from 

Direct Point Sources 

(tonnes) 

2002 Total U.S. Load 

(tonnes) a

Erie 4,610 1,150 136,000 

Huron 927 126 25,900 

Michigan 3,430 374 70,000 

Ontario 1,800 464 32,800 

Superior 782 75 10,900 

Source: Robertson, 2011. 

a – Loadings from the U.S. part of each lake’s watershed, and do not include direct atmospheric deposition. 

 The article provides data for total phosphorus in both the total U.S. loadings and U.S. 

loadings from point sources. ERG used the loadings from point sources for the comparison 

analysis. The only calculation steps were the summation of the loadings from all five Great 

Lakes and converting the metric tonnes to pounds using the following conversion factor: 

1 metric tonne = 1000 kilogram (kg)/tonne × 2.2046 lbs/kg = 2,204.6 lbs 

The annual total phosphorus loadings from point sources to the Great Lakes are 2,189 tonnes, or 

4.8 million pounds. 

 To estimate the annual total nitrogen loadings from point sources, ERG used information 

provided in the literature article that states the percentage of loadings to the Great Lakes 

attributed from point sources. In the Abstract section, the authors write “Point sources were also 

significant, contributing [approximately] 14 – 44% of the (phosphorus) and 13 – 34% of the 

(nitrogen).” Using the range of numbers provided, ERG determined the range of total nitrogen 

loadings from point sources. The total loadings to the Great Lakes from the U.S. are 275,600 

tonnes, or 608 million pounds. Between 13 and 34% of these total nitrogen loadings is from 

point sources, or between 79 and 207 million pounds. 
Memorandum 

April 19, 2013 

Page 18 

3.2.1 Comparison of Pollutant Loadings: Steam Electric Power Plants and Other Point 

Source Discharges to the Great Lakes Watershed 

 To calculate the percentage of point source loadings entering the Great Lakes watershed 

from the steam electric power evaluated waste streams, ERG completed the following 

calculations: 

X lbs/yr from evaluated waste streams = Percentage of Loadings from Evaluated Waste Streams 

Y lbs/yr from all point source dischargers 

For nitrogen: 

 1.99 million lbs/yr = Between 1% and 2.5% 

 79 to 207 million lbs/yr 

For phosphorus: 

0.0532 million lbs/yr = 1% 

 4.8 million lbs/yr 

3.2.2 Calculation of Equivalent Number of Typical POTWs that Discharge the Same 

Pollutant Loadings as Steam Electric Power Plants to the Great Lakes 

Watershed 

 To provide additional perspective on the magnitude of the loadings, EPA calculated the 

equivalent number of typical POTWs that would discharge loadings equal to the 26 steam 

electric power plants that discharge the evaluated waste streams to the Great Lakes watershed. 

Table 3-5 presents total pollutant loadings for the evaluated waste streams discharging to the 

Great Lakes and the number of typical POTWs that would discharge equivalent loadings. 
Memorandum 

April 19, 2013 

Page 19 

Table 3-5. Estimated Number of POTW Equivalents for Pollutant Loadings to the Great 

Lakes Watershed from the Evaluated Waste Streams 

Pollutant 

Steam Electric Discharge 

to the Great Lakes 

Watershed (26 Plants), 

lbs/yr a

Typical POTW 

Discharge 

(see Section 2.3), 

lbs/yr 

Number of Average POTWs 

Equivalent to 26 Steam Electric 

Plants Discharging 

to the Great Lakes b

Arsenic 4,170 46 4,170 / 46 = 91 

Cadmium 1,410 4 1,410 / 4 = 353 

Chromium VI 380 18 380 / 18 = 21 

Copper 5,180 154 5,180 / 154 = 34 

Lead 5,840 49 5,840 / 49 = 119 

Mercury 117 3,180 117 / 3,180 = <1 

Nickel 18,300 31 18,300 / 31 = 590 

Selenium 6,240 18 6,240 / 18 = 347 

Thallium 15,900 10 15,900 / 10 = 1,590 

Zinc 19,800 453 19,800 / 453 = 44 

Total Nitrogen 1,990,000 123,000 1,990,000 / 123,000 = 16 

Total Phosphorus 53,200 17,800 53,200 / 17,800 = 3 

a – U.S. EPA, 2012a; U.S. EPA, 2012b. 

b – Equivalent number of POTWs is estimated by dividing the total annual pollutant loadings to the Great Lakes by the average 

POTW loadings presented in Table for POTWs with an effluent flow rate of 3 to 5 MGD. Numbers may vary due to rounding. 

4.0 REFERENCES

Chesapeake Bay Program. 1999. Chesapeake Bay Basin Toxics Loading and Release Inventory. 

Annapolis, MD (May). DCN SE01903. 

Metcalf and Eddy, Inc. 2003. Wastewater Engineering: Treatment and Reuse. McGraw-Hill, Inc. 

4th edition. DCN SE01967. 

Robertson. 2011. D.M. Robertson and D. A. Saad. Nutrient Inputs to the Laurentian Great Lakes 

by Source and Watershed Estimated Using SPARROW Watershed Models. Journal of the 

American Water Resources Association, Vol 47, No. 5. October. 

U.S. EPA. 2006. Toxic Weighting Factor Development in Support of CWA 304(m) Planning 

Process. Washington, DC. (June). EPA-HQ-OW-2004-0032-1634. DCN SE01952. 

U.S. EPA. 2010. Discharge Monitoring Report (DMR) Pollutant Loading Tool: 2010 Data. 

Available online at: http://cfpub.epa.gov/dmr/. DCN SE01959. 

U.S. EPA. 2010b. Chesapeake Bay Total Maximum Daily Load for Nitrogen, Phosphorus and 

Sediment. Washington, DC. (December). DCN SE01910. 

U.S. EPA. 2011. Technical Support Document for the 2010 Effluent Guidelines Program Plan. 

EPA 821-R-09-006. Washington, DC. (October). DCN SE07320. 
Memorandum 

April 19, 2013 

Page 20 

U.S. EPA. 2012a. Chesapeake Bay and Great Lakes Proximity Database. Washington, DC. DCN 

SE03571. 

U.S. EPA. 2012b. Loads Preparation Database for Chesapeake Bay and Great Lakes Analysis. 

Washington, DC. DCN SE02990.

U.S. EPA, 2013a. Technical Development Document for the Proposed Effluent Limitations 

Guidelines and Standards for the Steam Electric Power Generating Point Source Category (EPA821-R-13-002). Washington, DC. DCN SE01964. 

U.S. EPA. 2013b. DMRLoadsAnalysis2009_v02.mdb: Tables and Queries Used for the Steam 

Electric Industry ELGs. DCN SE01961. 
Attachment 1 

April 19, 2013 Page A-1 Attachment 1: Steam Electric Power Plants Discharging to the Chesapeake Bay and Great Lakes Watersh

Table A-1 Steam Electric Power Plants Directly Discharging to the Chesapeake Bay Water

COMID Plant Name Receiving Water 

8151995 PPL Montour Chillisquaque Creek 

14640413 Clinch River Plant Clinch River 

8677721 Dan River Steam Station Dan River 8679473 Belews Creek Steam Station Dan River 

10054602 Chesapeake Energy Center Deep Creek 14638941 Clinch River Plant Dumps Creek 14365710 Mount Storm Power Station Four Mile Run 

8696233 Roxboro Steam Plant Hyco Lake 8548185 Bremo Power Station James River 

10067405 Dominion - Chesterfield Power Station James River 

8099955 AES Westover, LLC Little Choconut Creek 8693517 Mayo Electric Generating Plant Mayo Reservoir 

14365968 Mount Storm Power Station Mount Storm Lake 

6908685 Glen Lyn Plant New River 

11690558 Brandon Shores Patapsco River 11908816 Chalk Point Generating Station Patuxent River 

4507392 Dickerson Generating Station Potomac River 4532873 Mirant Mid-Atlantic, LLC Potomac River 8653054 Clover Power Station Roanoke River 

14365968 Mount Storm Power Station Stony River 

4518760 Sunbury Generation LP Susquehanna River 4722211 PPL Brunner Island Susquehanna River 8152547 PPL Montour Susquehanna River 

11690522 Brandon Shores Wagner Plant Discharge Canal 

4672489 Shawville West Branch Susquehanna River 

Source: U.S. EPA, 2012a; U.S. EPA, 2012b. 
Attachment 1 

April 19, 2013 Page A-2 

Table A-2 Steam Electric Power Plants Directly Discharging to the Great Lakes Watersh

COMID Plant Name Receiving Water Name 

28125104 Avon Lake Power Plant Lake Erie Erie 25769231 JR Whiting Power Plant Lake Erie Erie 

9840314 Dunkirk Generating Plant Lake Erie Erie 

30726982 Monroe Power Plant Lake Erie Erie 

9840092 Dunkirk Generating Plant Van Buren Bay Creek Erie 

12919103 Harbor Beach Power Plant Lake Huron Huron 12927619 JC Weadock Power Plant Saginaw Bay Huron 12927619 DE Karn Power Plant Saginaw Bay Huron 12005077 Pulliam Fox River Michig

9005799 J. B. Sims Generating Station Grand River Michig

12245290 Eckert Station Grand River Michig

9017879 James De Young Generating Station Lake Macatawa Michig

12169377 Pleasant Prairie Power Plant Lake Michigan Michig

3397270 NIPSCO Michigan City Generating Station Lake Michigan Michig3398586 NIPSCO Bailly Generating Station Lake Michigan Michig9017399 JH Campbell Power Plant Lake Michigan Michig

12169333 Oak Creek Power Plant Lake Michigan Michig12170709 Waukegan Station Lake Michigan Michig12176006 Edgewater Generating Station Lake Michigan Michig12162650 Valley Power Plant Menomonee River Michig12135490 B C Cobb Power Plant Muskegon Lake Michig

9017837 JH Campbell Power Plant Pigeon Lake Michig

12254504 Michigan South Central Power Agency Saint Joseph River Michig21979641 AES Cayuga LLC a Cayuga Lake Ontario 21978203 AES Greenidge LLC Keuka Outlet Ontario 15561361 AES – Somerset Lake Ontario Ontario 21979923 AES Greenidge LLC Seneca Lake Ontario 12026640 Presque Isle Power Plant Lake Superior Superi

1767108 Laskin Energy Center Partridge River Superi

Source: U.S. EPA, 2012a; U.S. EPA, 2012b. a – The outfall coordinates and the receiving water name were claimed CBI in the Steam Electric Survey. However, EPA waived the claim because thand receiving water were identified in a publically available source [AES Eastern Energy LP, 2010].