MEMORANDUM 

TO: Ron Jordan, EPA 

 Jezebele Alicea, EPA 

FROM: Anna Dimling, ERG 

 Deborah Bartram, ERG 

DATE: September 30, 2015 

SUBJECT: Evaluation of Verified Retirements in the Updated Industry Profile 

Population for the Steam Electric Effluent Guidelines Final Rule 

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

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

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

EPA, with the support of ERG, distributed the Questionnaire for the Steam Electric Power 

Generating Effluent Guidelines (“Steam Electric Survey”; DCN SE05903) to 733 steam electric 

power plants in the summer of 2010 to gather plant-specific data on the steam electric industry. 

The Steam Electric Survey requested data on plant operations in 2009. While the Steam Electric 

Survey remains the best source of plant specific information for the final ELGs, EPA recognizes 

that plant operations may have changed since 2009. Therefore, EPA incorporated plant 

retirements or fuel conversions if the industry profile change met the following criteria1

: 

1. The retirement or fuel modification had to be to complete by December 31, 2023; 

and 

2. The retirement had to be substantiated by information directly from the operating 

company or government entity, either through an article, report, or press release. 

 EPA has a high degree of confidence that the identified retirements and fuel conversions 

will occur because excluded generating unit retirements and fuel conversions were factored in 

only if they could be verified by information directly from the plant operating company or a 

government entity.2

 At the request of EPA, ERG conducted an additional review all plants listed 

in the Updated Industry Profile Population to confirm that all announced retirements and fuel 

conversions have occurred or are still planned to occur. EPA confirmed that 406 of 416 of the 

steam electric generating units are still retiring or converting fuels before the implementation of 

the final rule, which represents 98 percent of the total nameplate capacity of units 

retiring/converting fuels. EPA also identified additional (new) retirements or fuel conversions, 

 

1

 EPA also incorporated into the industry profile and the rulemaking analyses other updates such as FGD treatment 

system upgrades and wet-to-dry conversions for ash handling systems. Those changes are not discussed in this 

memorandum. 

2

 For the review discussed in this memorandum, which was performed to confirm the status of planned 

retirements/conversions, additional sources were also consulted. Consideration of a broader range of sources is 

acceptable for this additional review, since the purpose is merely to confirm the status of previously identified plans 

for retirement/conversion. 
Memorandum 

September 30, 2015 

Page 2 

during the evaluation of verified retirements. However, these retirements and fuel conversions 

were identified too late to be incorporated in EPA’s analyses (for more information see Changes 

to Industry Profile for Steam Electric Generating Units for Steam Electric Effluent Guidelines 

Final Rule; DCN SE05069). 

 Generating units that are projected to convert fuels (i.e., cease burning coal or petroleum 

coke) or retire prior to implementation of the final rule will not incur any capital expenditures to 

comply with the final ELGs nor will they contribute to environmental improvements associated 

with the ELGs. For the purposes of this memorandum, EPA refers to those generating units 

excluded from compliance costs and pollutant loadings due to planned retirements or fuel 

conversions as part of the Updated Industry Profile Population (for more information on the 

Updated Industry Profile Population, see Section 4.5.1. of the Technical Development Document 

for the Final Limitations Guidelines and Standards for the Steam Electric Power Generating 

Point Source Category (“TDD”; EPA-821-R15-007)). 

 Table 1 presents the count of steam electric generating units and plants in the Updated 

Industry Profile Population that were identified as retiring or converting fuel by December 31, 

2023, along with the year that action was scheduled to occur. The table also includes the total 

generating capacity for all retiring or converting generating units by year. As identified in Table 

1, the retired or refueled units in the Updated Industry Profile Population represent a total of 232 

GW of generating capacity, of which 209 GW (307 generating units located at 126 plants) was 

scheduled to retire or convert fuels by the end of 2015. As a result of the additional review, ERG 

confirmed that 212 GW (340 generating units located at 143 power plants) has already or will be 

retired or refueled by the end of 2015. The increase in the capacity and number of generating 

units is due to some generating units, previously identified as retiring/refueling after 2015, 

having retired/refueled sooner. For more information on each plant and steam electric generating 

unit reviewed for retirement or fuel conversions, please see DCN SE05702A1.
Memorandum 

September 30, 2015 Page 3 Table 1. Total Capacity, Count of Units, and Count of Plants Retiring or Converting Fuels by Year in the Updated Industry Profile Pop

of Verified Retirements 

Year of Retirement 

or Fuel Conversion 

Updated Industry Profile Population Evaluation of Verified Retir

Number of SE Units 

Retiring/Converting 

Fuels 

Number of Plants 

Retiring/Converting 

Fuels 

Total Nameplate 

Capacity of Units 

Retiring/Converting 

Fuels (GW) 

Number of SE Units 

Retiring/Converting 

Fuels 

Number of Plants 

Retiring/Converting 

Fuels 

Retired/Refueledb 8 2 0.375 48 21 

2010 13 10 0.833 10 7 2011 31 13 164 32 12 2012 84 39 11.9 80 40 2013 39 20 6.85 46 21 2014 48 22 9.50 24 10 2015 84 33 15.6 100 46 2016 82 40 15.6 39 17 2017 19 8 4.32 20 8 2018 4 3 1.85 3 2 2019 0 0 0 0 0 2020 4 3 1.46 4 3 2021 0 0 0 0 0 2022 0 0 0 0 0 2023 0 0 0 0 0 

Unconfirmed 0 0 0 10 7 

Total 416 170c 232 416 170c 

a – ERG identified the year of retirement or fuel conversion from more recent source. Not all sources used for confirming the retirements were s

from the operating company or a government entity). Some sources indicated that retirements or fuel conversions were still planned or expectedERG assumed the same date as was used for the Updated Industry Profile Population. See DCN SE05702A1 for more information. b - No date is available for these generating units but publicly available data indicates that these units have already been removed from service. c - The number of plants by year is not additive as one plant may operate steam generating units identified as retiring or converting fuels in diffe
Memorandum 

January 28, 2013 

Page 4 

 During the additional review of all plants listed in the Updated Industry Profile 

Population, ERG was able to confirm the retirement or fuel conversion for all but ten of the 

steam electric generating units (located at seven plants) included in the Updated Industry Profile 

Population. EPA considered a unit retirement or fuel conversion unconfirmed if no source was 

identified or if an additional source indicates the unit is retiring/converting fuels after 

implementation of the rule. Table 2 presents a summary of the plants and units that were not able 

to be confirmed in this evaluation. 

Table 2. Unconfirmed Unit Retirements or Fuel Conversions from the Evaluation of the 

Verified Retirements 

Plant Name Plant 

ID 

SE Unit 

ID 

Capacity

(MW) 

Updated 

Industry Profile 

Population 

Evaluation of Verified Retirementsa

Retirement/ 

Conversion Year 

Retirement/ 

Conversion 

Year 

Additional Data 

Astoriab 6727 SE Unit-2 176.3 2016 No Date No source identified. 

Big Cajun II 2334 SE Unit-1 626 2015 2025 Retirement date 

beyond 2023. 

Big Cajun II 2334 SE Unit-3 619 2015 No Date No source identified. 

Eddystoneb 9768 SE Unit-3 399.5 2012 No Date No source identified. 

Eddystoneb 9768 SE Unit-4 391 2012 No Date No source identified. 

Four Corners 3191 SE Unit-4 818.1 2016 2041 Potential retirement 

date beyond 2023. 

Four Corners 3191 SE Unit-5 818.1 2016 2041 Potential retirement 

date beyond 2023. 

Northeastern 

Power Station 6933 SE Unit-3 473 2016 2026 Retirement date 

beyond 2023. 

Plant 

McIntoshb 3200 SE Unit-1 103.5 2016 No Date No source identified. 

Turkey Pointb 9963 SE Unit-2 402 2016 No Date No source identified. 

a – ERG identified year of retirement or fuel conversion from more recent source. Not all sources used for 

confirming the retirements were substantiated (i.e., directly from the operating company or a government entity). 

b - These steam electric generating units do not utilize coal or petroleum coke as a fuel (i.e., unit operates on oil or 

natural gas). 

 

 In addition to Table 2, ERG analyzed the unconfirmed units to determine the impact on 

the ELGs. ERG provides further description of the plants containing unconfirmed steam electric 

generating unit retirements and/or fuel conversions below. 

 Astoria Generating Station (Plant ID: 6727) SE Unit-1 was originally confirmed with 

NEEDS database as retiring by 2016, ERG did not identify an additional source to 

confirm the retirement is still scheduled for that date. The company website indicates that 

all units run on low sulfur no. 6 fuel oil and natural gas and unit 4 (SE Unit-3) was 

mothballed since 2012. Therefore, this plant would not affect the ELG analyses. 

 Big Cajun II (Plant ID: 2334) is in the Updated Industry Profile Population as refueling 

SE Unit-1, SE Unit-2, and SE Unit-3 by 2015. However, based on additional review it 

seems that SE Unit-2 converted to natural gas, SE Unit-1 must retire/refuel/retire/retrofit 

by 4/1/2025, and SE Unit-3 is not planned to retire/convert. However, SE Unit-3 does not 
Memorandum 

September 30, 2015 

Page 5 

generate wastewater and SE Unit-1 only generates bottom ash transport water, so the 

change in compliance costs would be negligible.

 Eddystone Generating Station (Plant ID: 9768) is in the Updated Industry Profile 

Population as retiring all 4 units (SE Unit-1 through SE Unit-4) on 12/31/2012. ERG 

confirmed SE Unit-1 was retired in 2011 and SE Unit-2 was retired in 2012. ERG did not 

find confirmation that SE Unit-3 and SE Unit-4 retired, however, both of these units run 

on fuel and/or natural gas so they would not affect the ELG analyses. 

 Four Corners (Plant ID: 3191) is in the Updated Industry Profile Population as retiring all 

5 units (SE Unit-1 through SE Unit-5) by 7/1/2016. ERG found confirmation that SE 

Unit-1, SE Unit-2, and SE Unit-3 retired in 2014. However, ERG identified another 

source (from the U.S. Department of the Interior: Office of Surface Mining) that indicates 

the Arizona Public Service is petitioning to extend operation of SE Unit-4 and SE Unit-5 

to 2041. 

 Plant McIntosh (Plant ID: 3200) SE Unit-1was originally confirmed with NEEDS 

database as retiring by 2016, ERG did not identify an additional source to confirm the 

retirement is still scheduled for that date; however, no sources were identified to suggest 

that retirement has been cancelled or postponed. This unit does not burn coal or 

petroleum coke as fuel, and therefore does not affect the ELG analyses. 

 Northeastern Power Station (Plant ID: 6933) announced one steam electric generating 

unit would be retiring in 2016 and the second would be retrofitted in 2016 and retired in 

2026. In the Updated Industry Profile Population, ERG included SE Unit-3 as retiring in 

2016; however, based on this additional review it appears as though SE Unit-4 will retire 

in 2016 and SE Unit-3 will retire in 2026. This plant does not generate fly ash or flue gas 

desulfurization (FGD) wastewater; however, the plant does generate bottom ash transport 

water from both Unit-3 and Unit-4. Both steam electric generating units have the same 

nameplate capacity, therefore the change in compliance costs would be negligible (less 

than 5% difference in compliance costs for the plant based on bottom ash transport flow 

reported in the Steam Electric Survey). 

 Turkey Point (Plant ID: 9963) SE Unit-2 was originally confirmed with NEEDS database 

as retiring by 2016, ERG did not identify an additional source to confirm the retirement is 

still scheduled for that date; however, no sources were identified to suggest that 

retirement has been cancelled or postponed. This unit does not burn coal or petroleum 

coke as fuel, and therefore does not affect the ELG analyses. 

 Plants stated several reasons for unit retirement and fuel conversions, which varied for 

each plant and company. ERG has provided a listing of some common reasons cited by steam 

electric power plants for retiring or converting fuels: 

 Market Conditions: Cost of coal and decreased power demand was cited as a reason for 

several plants. 

 Age of Plant: Several older plants indicated that the steam electric generating process was 

no longer efficient due to the age of the plant and upgrading the system would incur 

significant costs. 
Memorandum 

September 30, 2015 

Page 6 

 Settlements: There were several settlements between the industry and the EPA or other 

entities (e.g., Sierra Club) that required plants to retire/refuel particular steam electric 

generating units by a certain date. 

 State Regulations: Some plants indicated that state regulations (e.g., Colorado Clean Air 

Act, Georgia Environmental Protection Division (EPD) Multipollutant Rule) forced the 

retirement or refueling of steam electric generating units. 

 Federal Regulations: Some plants indicated that the need to upgrade pollution controls as 

a result of several different federal regulations caused the retirement or fuel conversion at 

their plant. 

 Improve Efficiency: Plants that converted fuels (i.e., natural gas, biomass) stated that the 

company aimed to increase the energy output, cut emissions, and/or use renewable fuel.