Comments / ICR Glossary

Jennifer Peterson

to:
Ronald Jordan

01/22/2010 06:35 PM

Cc: Jezebele Alicea, Eric Schaeffer

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Hi Ron,

The only concern we have rega rding the ICR glossary is how EPA’s definition of “disch arge” impacts the location of the samples that the ICR dire cts plants to collect. As I noted in my December 23, 2009 emai l, we have found that plants do not always sample and report for al l pollutants at both the internal outfall (i.e. discharges within the plant)

and the external outfall (i.e. discharges to surface wate rs). We think it is import ant to analyze dat a from both of

these locations in order to fully understand the compositi on of wastewater streams.

The definition of “discharge,” however, a ppears to refer only to dischar ges to surface waters or treatment facilities. “Discharge” is defined as “The conveyan ce of process wastewater to: (1) su rface waters; or (2 ) a publicly owned, privately owned, federally owned, co mbined, or other treatment works.”

Our concern with this definition is that facilities will not sample and report at inter nal outfalls/discharge points when responding to the ICR. Because we th ink it is important to have sample information from discharge points within the plant and locations that discharge directly to surface waters, we res pectfully request that E PA revise (or clarify) the definition of “discharge ” to include internal dischar g

es to ensure that these dischar g

e points are within the scope

of the ICR.

Thank you for considering our comments. Please feel free to contact me directly if you have any questions.

Best,

Jennifer S. Peterson Attorney Environmental Integrity Project 1920 L Street NW, Suite 800 Washington, DC 20036 (202) 263-4449 PHONE (202) 296-8822 FAX j peterson @ environmentalinte g rit y

.or g

From: Jordan.Ronald@epamail.epa.gov [mailto:Jordan.Ronald@epamail.epa.gov]

Sent: Friday, January 15, 2010 8:39 AM

To: Eric Schaeffer; Jennifer Peterson; craig. segall@sierraclub.org; akron@defenders.org; msenatore@defenders.org; nstoner@ nrdc.org; levans@earthjustice.org

Cc: Alicea.Jezebele@epamail. epa.gov; Deborah Bartram Subject: Steam electric effluent guidelines -- ICR materials

EPA has prepared a couple docu ments which you may find of interest, relating to the info rmation collection request (ICR) for the steam electric po wer generating effluent guidelines. As you are aware, the public comment Page 1 of 2

1/28/2010 file://C:\Documents and Settin g s\r j ordan\Local Settin g s\Tem p \notesFCBCEE\~web2007.h

...period for the First Federal Regist er notice ended on December 28, 2009 and EPA is currently in the process of reviewing and addressing these comments.

1. Draft Glossary We have prepared a draft glossary th at will be included as part of the questionnaire (see attached file). The glossary will be included along with the IC R that will be submitted to the Office of Mana gement and Budget (OMB) for approval, and will be available for public comment when EPA publishes a Federal Register notice announcing submission of the ICR to OMB. However, we would like to offer you the opportunity for an early review of the draft glossary and invite you to provi de feedback. In order for us to acco mmodate changes prior to submitting the ICR to OMB, we ask you to send us your suggestions for changes to the definitions, as well as identifying any terms that should be added or deleted, by Friday, January 22

.

2. Plant Mailing Addresses

A ttached is a file listing all power pl ants included in EPA's da tabase of potential res pondents. (Note that EPA does not intend to send the questionnaire to every plant on the list; however, EPA does not know at this time which plants will be selected, nor will that be known until after the random sele ction process occurs .). The plants were identified using Energy Information Administration (EIA) data, which in most cases is also the source of data for the mailing addresses. We invite you to review th e addresses and operator names, and to provide feedback on any corrections that may be needed, including identifying any plants t hat may have been incorrectly omitted from the list. We ask that you send us yo ur suggested changes to us by February 1

.

---------------------------------------------------------- Ron Jordan Engineering and Analysis Division (4303T)
Office of Water U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20460 (202) 566-1003 http://www.epa.gov/waterscience Page 2 of 2

1/28/2010 file://C:\Documents and Settin g s\r j ordan\Local Settin g s\Tem p \notesFCBCEE\~web2007.h

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