MEMORANDUM 

TO: Steam Electric Rulemaking Record 

FROM: TJ Finseth, ERG 

Danielle Lewis, ERG 

DATE: April 19, 2013 

SUBJECT: Steam Electric Analytical Database 

ERG is providing technical support to the U.S. Environmental Protection Agency’s Office of 

Water, Engineering and Analysis Division (EAD) for development of effluent limitations 

guidelines and standards (effluent guidelines) for the Steam Electric Power Generating Industry. 

ERG was responsible for compiling all sampling data gathered during the rulemaking into a 

single database, referred to as the Analytical Database. The Analytical Database contains 

sampling results from EPA’s three- and four-day sampling episodes, the CWA 308 monitoring 

program, data provided by the industry and state entities, as well as publicly available data from 

Electric Power Research Institute (EPRI) reports and other technical sources. This memorandum 

describes the data contained in the database, how the data were revised or edited if necessary, 

and the use of the data in engineering analyses. 

1.0 INTRODUCTION

EPA, together with ERG, conducted a sampling program at steam electric power plants to collect 

wastewater characterization data and treatment performance data associated with FGD 

wastewater and to collect data for other emerging waste streams for which characterization data 

were not available (i.e., carbon capture and gasification wastewater). As part of this sampling 

program, EPA obtained wastewater samples from 13 plants. The samples were collected as 

follows: 

 For seven plants, EPA collected performance data for four consecutive days and 

the plants also subsequently collected four sets of samples over a four to five 

month period; 

 For four plants, the facility collected performance data for four consecutive days; 

 For one plant, EPA collected performance data for three consecutive days; and 

 For one plant, the facility collected performance data for one day. 

EPA (or the plant) collected representative samples at the influent and effluent of the treatment 

system being evaluated using a combination of 24-hour composite and grab samples, depending 

on the sample location and the parameter to be analyzed. EPA analyzed the samples for up to 64 

parameters, including conventional pollutants (e.g., TSS, BOD5), nonconventional pollutants 

(e.g., TDS, nutrients), and metals. For samples collected by EPA, EPA quantified both the total 

amount of metal and the dissolved portion only. For samples collected by the plants, EPA 

quantified the total amount of metal. Prior to initiating sampling activities, regardless of who 
Memorandum 

April 19, 2013 

Page 2 

collected the samples, EPA developed sampling plans that detailed the procedures for sample 

collection, including the pollutants to be sampled, location of the sampling points, and sample 

collection, preservation, and shipment techniques. 

2.0 EPA-COLLECTED SAMPLES

EPA selected and conducted sampling activities over four consecutive days at the following 

plants in the U.S.: 

 Duke Energy Carolina’s Belews Creek Steam Station; 

 We Energies’ Pleasant Prairie Power Plant; 

 Duke Energy’s Miami Fort Station; 

 Duke Energy Carolina’s Allen Steam Station; 

 Mirant Mid-Atlantic, LLC’s Dickerson Generating Station; 

 RRI Energy’s Keystone Generating Station; and 

 Allegheny Energy’s Hatfield’s Ferry Power Station. 

All of the selected plants operate chemical precipitation wastewater treatment systems to treat 

their FGD wastewater. The treatment systems at Belews Creek, Allen, and Dickerson also 

include a biological treatment stage following the chemical precipitation. 

The pollutants selected for analysis reflect the current understanding of FGD wastewaters, 

including contributions from the fuel, air pollution control scrubber sorbents, treatment 

chemicals, and other sources. Table 1 lists the analytical methods in EPA’s sampling program. 

EPA collected representative samples at the influent and effluent of the FGD wastewater 

treatment systems and, where applicable, the mid-point of the FGD treatment system (i.e., 

effluent from chemical precipitation system prior to biological treatment). All influent samples 

were collected as grab samples. EPA collected 24-hour composite samples at the mid-point and 

effluent sampling points for all analytes except mercury and cyanide. EPA collected cyanide as a 

single grab sample and mercury as four individual grab samples over the 24-hour period (i.e., a 

grab sample collected every six hours) at the mid-point and effluent sampling points. 
Memorandum 

March 11, 2013 

Page 3 

Table 1. Analytical Methods Used for EPA’s Sampling Program 

Parameter Method Number 

Classicals

Biochemical oxygen demand (BOD5)

1

 SM 5210 B 

Chemical oxygen demand (COD) EPA 410.4 

Total suspended solids (TSS) SM 2540 D 

Total dissolved solids (TDS) SM 2540 C 

Sulfate EPA 300.0 

Chloride EPA 300.0 

Ammonia as nitrogen EPA 350.1 

Nitrate/nitrate as nitrogen EPA 353.2 

Total Kjeldahl nitrogen (TKN) EPA 351.2 

Total phosphorus EPA 365.1 

Total cyanide1 SM 4500 CN E 

Total and Dissolved Metals

Mercury EPA 1631E4 

Hexavalent chromium (dissolved only)1 EPA 218.6 

Antimony, arsenic, cadmium, chromium, copper, lead, manganese2, 

nickel, selenium, silver, thallium, and vanadium 

EPA 200.8 with collision 

cell5

 

Aluminum, barium, beryllium, boron, calcium, cobalt, iron, magnesium, 

molybdenum, sodium, tin, titanium, and zinc3

 

EPA 200.76 

1

 Only sites in the United States were analyzed for this parameter. 2

 At sites in the United States, manganese was analyzed using method EPA 200.8 with collision cell. At sites not in 

the United States, manganese was analyzed using method EPA 200.7. 

3 Zinc was analyzed using EPA Method 200.8 with collision cell for the Belews Creek, Pleasant Prairie, Miami Fort, 

and Allen sampling episodes, but was analyzed by EPA Method 200.7 for the Dickerson, Keystone, Hatfield’s 

Ferry, Brindisi, and Monfalcone sampling episodes. 

4

 For samples requiring biphasic separation because the solids content was greater than one percent, the solid 

samples were analyzed using Method FGS-069. 

5

 For samples requiring biphasic separation because the solids content was greater than one percent, the solid 

samples were analyzed using Method 6020. 

6

 For samples requiring biphasic separation because the solids content was greater than one percent, the solid 

samples were analyzed using Method 6010B. 

EPA also conducted a three-day sampling episode at Enel’s Federico II Power Plant (Brindisi), 

located in Brindisi, Italy to characterize untreated FGD scrubber purge wastewater and treated 

FGD wastewater from an FGD wastewater treatment system consisting of chemical precipitation 

followed by vapor-compression evaporation. EPA collected samples for the same list of analytes 

listed in Table 1, except for excluding the following analytes either because of holding time 

considerations or time constraints for the sampling event: 

 BOD5; 

 Total cyanide; and 

 Dissolved metals (all analytes). 
Memorandum 

April 19, 2013 

Page 4 

EPA collected representative samples of the influent to the FGD wastewater treatment system, 

the distillate from the brine concentrator, and the condensate from the crystallizer. EPA collected 

all analytes at the influent to the FGD wastewater treatment system as one-day grab samples. 

EPA collected six-hour composite samples at the brine concentrator and crystallizer sampling 

points for all analytes except mercury. EPA collected mercury as three individual grab samples 

over the six-hour period (i.e., a grab sample collected every two hours) at these points. 

EPA also requested that a second plant in Italy, A2A’s Centrale di Monfalcone (Monfalcone), 

collect one-day grab samples. Monfalcone operates a chemical precipitation followed by vaporcompression evaporation system to treat FGD wastewater. Monfalcone personnel collected 

samples of the FGD influent to wastewater treatment, the distillate from the brine concentrator, 

and the condensate from the crystallizer. 

3.0 CWA 308 MONITORING PROGRAM

In addition to the sampling activities conducted by EPA, the CWA 308 monitoring program 

required a subset of steam electric power plants to collect samples. Each of the seven U.S. plants 

selected for the EPA sampling program were required to participate in the CWA 308 monitoring 

program. For those seven plants, EPA required the collection of four sets of samples over a fouror five-month period. 

EPA required four additional plants (not sampled by EPA) to participate in its CWA 308 

monitoring program. The four plants are listed below along with the reason for their selection: 

 Tampa Electric Company’s Polk Station - One of two currently operating 

integrated gasification combined cycle (IGCC) plants; 

 Wabash Valley Power Association’s Wabash River Station - One of two currently 

operating IGCC plants; 

 Appalachian Power Company’s Mountaineer Plant - Only plant in United States 

operating a carbon capture system; and 

 Kansas City Power & Light’s Iatan Station - Only plant in United States operating 

a one-stage vapor-compression evaporation system for treatment of FGD 

wastewater.1

For these four plants, EPA required the plants to collect four consecutive days of samples at two 

to four locations specifically identified for each plant. EPA selected the sample locations to 

characterize gasification wastewater, carbon capture wastewater, and the treatment of FGD 

wastewater and gasification wastewater by vapor-compression evaporation systems. EPA used 

the same sampling approach that was used for EPA’s on-site sampling program as described 

above. The CWA 308 monitoring samples were collected directly by the plants and shipped to 

EPA-contracted laboratories for analysis. 

 

1

 At the time of the sampling episode, the Iatan Station was the only plant in the United that EPA had identified as 

operating a vapor-compression evaporation system. Since that time, two additional plants are in the process of 

installing or operating a vapor-compression evaporation system for the treatment of FGD wastewater. 
Memorandum 

April 19, 2013 

Page 5 

4.0 ANALYSIS OF EPA-COLLECTED AND CWA 308 MONITORING PROGRAM SAMPLES

Two contracted laboratories, Frontier Global Services (Frontier) and TestAmerica Laboratories – 

Denver (TestAmerica), analyzed both the EPA collected samples and the CWA 308 monitoring 

samples. Frontier analyzed all total and dissolved mercury samples and TestAmerica analyzed 

the remaining classicals and total and dissolved metals samples. Both laboratories followed the 

requirements of the analytical methods listed in Table 1. ERG verified that the performance of 

the laboratories was acceptable by conducting QC checks of the analytical data as outlined in the 

Quality Assurance Project Plan for the Steam Electric Rulemaking (QAPP). ERG chemists 

reviewed all data and documented any qualifications of the analytical data from each sampling 

event. 

ERG compiled a database to hold all sampling results, known as the Steam Electric Analytical 

Database. This database contains sampling results for each sampling point for all analytes at the 

EPA sampling sites and the CWA 308 monitored sites. This database also includes the results of 

the field blank and field duplicate analyses. ERG modified the results to reflect any 

qualifications identified by laboratories and ERG chemists as part of the data review process. 

These modifications are detailed in the data review narratives that accompany each of the 

Sampling Episode Reports (SERs) for the EPA sampled plants and the CWA 308 monitoring 

program memorandum2. 

5.0 ADDITIONAL SOURCES OF SAMPLING DATA

In addition to the EPA sampling program and the CWA 308 monitoring program, EPA obtained 

sampling results from states, operating companies, and other public sources. These data were 

added to the Analytical Database, and include the following: 

 Long-term monitoring data for Progress Energy Carolinas’ Roxboro Steam Electric Plant 

provided by the North Carolina Department of Environment and Natural Resources; 

 Long-term monitoring data for the Belews Creek Steam Station and Allen Steam Station 

provided by Duke Energy Carolinas; 

 Ash impoundment sampling data collected during the EPA’s detailed study sampling 

program; 

 Ash impoundment sampling data included in Electric Power Research Institute (EPRI) 

Power Plant Integrated Systems-Chemical Emissions Study (PISCES) Reports; 

 Permit application data provided by member companies of the Utility Water Act Group 

(UWAG); and 

 Data included in the Development Document for Final Effluent Limitations Guidelines, 

New Source Performance Standards, and Pretreatment Standards for the Steam Electric 

Point Source Category, EPA 440-1-82-029, November 1982. 

 

2

 See DCNs SE01304, SE01305, SE01306, SE01307, SE01308, SE01309, SE01310, SE01295, and SE01295A1 

through SE01295A11. 
Memorandum 

April 19, 2013 

Page 6 

6.0 USES OF SAMPLING DATA 

EPA used the data contained in the Steam Electric Analytical Database to conduct analyses for 

the proposed steam electric effluent guidelines. EPA used the Steam Electric Analytical 

Database to: 

 Evaluate wastewater discharges from steam electric power plants; 

 Evaluate technology options for handling and treating steam electric wastewater; 

 Calculate concentrations of pollutants after implementation of selected treatment 

technologies; 

 Calculate industry baseline loadings and associated pollutants removals after 

implementation of selected treatment technologies; and 

 Develop the proposed effluent limitations. 

All data obtained by EPA during the rulemaking process is contained in the Steam Electric 

Analytical Database (DCN SE02120.A1). 

After calculating the pollutant loadings presented in the proposed rule, ERG determined that 

some of the analytical data were not entered into the database correctly. The data entry errors 

were associated only with the long-term self-monitoring data submitted directly from Duke 

Energy for its Belews Creek Steam Station. Additionally, the affected results are associated only 

with samples from the effluent of the biological treatment system. The following is a summary of 

the errors: 

 Forty-five arsenic results were treated as detected values at the reporting limit (RL) but 

should have been non-detect results. This change means these results should have been 

treated as 1/2 the RL value (e.g., 10 x 0.5 = 5) instead of being treated as the RL value 

(e.g., 10) in the calculation of the average concentration used to represent the arsenic 

biological treatment effluent in the pollutant loadings. 

 Two mercury results were treated as detected values at the RL of 1 ng/L but should have 

been non-detect results. This change means these results should have been treated as 1/2 

the RL value (i.e., 0.5 ng/L) instead of being treated as the RL value (i.e., 1 ng/L) in the 

calculation of the average concentration used to represent the mercury biological 

treatment effluent in the pollutant loadings. 

 One mercury result was entered as 0.432 ug/L when it should have been 0.423 ug/L. 

Table 2 provides a detailed listing of the results that were affected by these data entry errors. 

The table includes information on the plant name, analyte, and date of each sample, along with 

the actual non-detect indicator, amount, and RL which are the values presented in the analytical 

database and the non-detect indicator, amount, and RL used in calculation of average 

concentrations for pollutant loadings. 

ERG has corrected these data entry errors in the Steam Electric Analytical Database (DCN 

SE02120.A1). The results included in the database reflect the information in the “Actual Result” 

columns contained in Table 2; however, ERG was unable to recalculate the pollutant loadings to 

account for these changes prior to proposal. All changes listed in Table 2 would result in a 

biological treatment post-compliance concentration that is lower than the value used in the 
Memorandum 

April 19, 2013 

Page 7 

version of the pollutant loadings presented for the proposed rule, which would increase the 

calculated pollutant removals from baseline. EPA plans to use the corrected values to revise the 

pollutant loadings calculations for the final rule3. 

Table 2. List of Samples Affected by Data Entry Errors 

Plant Name Sample Date Analyte 

Actual Resulta

Data Used in Calculation of 

Average Concentrations for 

Pollutant Loadingsb

NonDetect 

Indicator Amount RL 

NonDetect 

Indicator Amount RL 

Belews Creek 8/4/2008 Arsenic ND 10 D 10 

Belews Creek 8/11/2008 Arsenic ND 10 D 10 

Belews Creek 8/18/2008 Arsenic ND 10 D 10 

Belews Creek 8/25/2008 Arsenic ND 10 D 10 

Belews Creek 9/2/2008 Arsenic ND 10 D 10 

Belews Creek 9/8/2008 Arsenic ND 10 D 10 

Belews Creek 9/15/2008 Arsenic ND 10 D 10 

Belews Creek 9/22/2008 Arsenic ND 10 D 10 

Belews Creek 9/29/2008 Arsenic ND 10 D 10 

Belews Creek 10/6/2008 Arsenic ND 10 D 10 

Belews Creek 10/12/2008 Arsenic ND 10 D 10 

Belews Creek 10/20/2008 Arsenic ND 10 D 10 

Belews Creek 10/26/2008 Arsenic ND 10 D 10 

Belews Creek 11/3/2008 Arsenic ND 10 D 10 

Belews Creek 11/9/2008 Arsenic ND 10 D 10 

Belews Creek 11/16/2008 Arsenic ND 10 D 10 

Belews Creek 11/24/2008 Arsenic ND 10 D 10 

Belews Creek 1/21/2010 Arsenic ND 2 D 2 

Belews Creek 1/27/2010 Arsenic ND 2 D 2 

Belews Creek 3/10/2010 Arsenic ND 2 D 2 

Belews Creek 3/24/2010 Arsenic ND 2 D 2 

Belews Creek 4/7/2010 Arsenic ND 2 D 2 

Belews Creek 4/28/2010 Arsenic ND 2 D 2 

Belews Creek 5/12/2010 Arsenic ND 2 D 2 

Belews Creek 5/26/2010 Arsenic ND 2 D 2 

Belews Creek 6/9/2010 Arsenic ND 2 D 2 

Belews Creek 6/23/2010 Arsenic ND 2 D 2 

 

3

 EPA will also revise the pollutant loadings calculations as a result of the difference between the data set used to 

calculate effluent limitations and the data set used to calculate pollutant loadings. There are a total of 14 data points, 

which affect both chemical precipitation and chemical precipitation with biological treatment effluent 

concentrations, included in loadings calculations that are not included in the data set used for limitations 

development. EPA plans to remove these points for the final rule. These changes are described in Analysis of 

Differences Between the Data Set Used for Limitations Development and the Data Set Used for Loadings (DCN 

SE02122). 
Memorandum 

April 19, 2013 

Page 8 

Table 2. List of Samples Affected by Data Entry Errors 

Plant Name Sample Date Analyte 

Actual Resulta

Data Used in Calculation of 

Average Concentrations for 

Pollutant Loadingsb

NonDetect 

Indicator Amount RL 

NonDetect 

Indicator Amount RL 

Belews Creek 7/28/2010 Arsenic ND 5 D 5 

Belews Creek 8/11/2010 Arsenic ND 2 D 2 

Belews Creek 8/25/2010 Arsenic ND 2 D 2 

Belews Creek 9/8/2010 Arsenic ND 2 D 2 

Belews Creek 10/7/2010 Arsenic ND 5 D 5 

Belews Creek 10/27/2010 Arsenic ND 5 D 5 

Belews Creek 11/4/2010 Arsenic ND 2 D 2 

Belews Creek 11/23/2010 Arsenic ND 2 D 2 

Belews Creek 12/8/2010 Arsenic ND 5 D 5 

Belews Creek 1/26/2011 Arsenic ND 5 D 5 

Belews Creek 2/16/2011 Arsenic ND 5 D 5 

Belews Creek 2/23/2011 Arsenic ND 5 D 5 

Belews Creek 3/9/2011 Arsenic ND 5 D 5 

Belews Creek 3/23/2011 Arsenic ND 5 D 5 

Belews Creek 4/13/2011 Arsenic ND 5 D 5 

Belews Creek 4/27/2011 Arsenic ND 5 D 5 

Belews Creek 5/11/2011 Arsenic ND 5 D 5 

Belews Creek 5/25/2011 Arsenic ND 5 D 5 

Belews Creek 9/15/2008 Mercury ND 0.001 D 0.001 

Belews Creek 9/22/2008 Mercury ND 0.001 D 0.001 

Belews Creek 8/11/2010 Mercury D 0.423 D 0.432 

a – Actual result indicates the non-detect indicator, amount, and RL as reported by the plant providing the long-term 

monitoring data. 

b – Data used in concentration calculations indicates the non-detect indicator, amount, and RL as it was used in 

calculations associated with developing pollutant loadings for the proposed rule. EPA will update the pollutant 

loadings calculations to use the “Actual Results” for the final rule.