### MEMORANDUM

TO: Steam Electric Rulemaking Record

FROM: TJ Finseth, ERG

DATE: April 19, 2013

SUBJECT: Nonchemical Metal Cleaning Waste Permit Review

ERG is providing technical support to the U.S. Environmental Protection Agency’s Office of Water, Engineering and Analysis Division (E AD) for development of effluent limitations guidelines and standards (ELGs) for the Steam Electric Power Generating Industry. As part of this technical support, ERG supported EPA with coordinating a permit review to evaluate how nonchemical metal cleaning wastes discharges from power plants are currently being regulated in NPDES permits. ERG used data from the Questionnaire for the Steam Electric Power Generating Effluent Guidelines (Steam Electric Survey) to iden tify those plants that reported generating nonchemical and chemical metal cleaning wastes. 1 EPA then provided the listing of these plants, included in Attachment 1 to th is memorandum (spreadsheet titled “Survey MCW Plant Listing”), to the EPA Regional offices and asked them to review permits contained within their region and provide answers to the fo llowing questions for each permit reviewed:

1. How is the metal cleaning waste handled at the plant? Is th ere any distinction between chemical cleaning waste and nonche mical cleaning waste? If so, what are the limits for each? 2. How is the nonchemical cleaning waste hand led at the plant, as metal cleaning waste or low-volume waste? What is the limit used? 3. If the non-chemical cleaning waste is handl ed as low-volume waste, what is the basis for this assumption? Does the factsh eet make any specific reference to the 1975 EPA “Jordan Memo” or provi de other justification? EPA’s Regional offices completed reviews for 56 permits. ERG compiled the responses from each of the regions and entered the information in to a spreadsheet, included in Attachment 1 to this memorandum (spreadsheet titled “Permit Re view Information”). Because EPA’s Regional offices provided varying levels of detail in thei r responses, ERG used best professional judgment to classify the information provided by the regi ons. In some cases, ERG determined there was insufficient detail to classify the responses and the plant was excluded from the analysis.

Attachment 1 to this memorandum is a Microsoft® Excel Workbook that contains two spreadsheets. The first spreadsheet, “Survey MCW Plant Listing,” is the plant listing provided to the EPA Regional offices identifying those pl ants that reported ge nerating chemical or nonchemical metal cleaning wastes in response to the Steam Electric Survey. The second

1 Because only a subset of steam electri c power plants were required to resp ond to Part E: Wastes from Cleaning Metal Process Equipment, the list of plants generating th ese wastes is not a complete listing for the industry.Memorandum April 19, 2013 Page 2

spreadsheet, “Permit Review Information,” is th e compiled results from the permit review. Table 1 includes descriptions for each field in the sp readsheet and how ERG po pulated the field based on the information provided by the EPA Regional offices.

Table 1. Nonchemical Metal Cleaning Waste Permit Review Compiled Spreadsheet Description

Field Name Field Description and Population Methodology Region Region in which the plant is located. State State in which the plant is located.

NPDES Permit NPDES Permit Identification Number. Plant Name Name of the plant reviewed. Metal Cleaning Waste Type Identifies the type of metal cl eaning waste generated at th e plant (i.e., “chemical,” “nonchemical,” or “chemical and nonch emical”). This field was generally populated based on the responses to the Steam Electric Survey; however, it was updated based on the permit review responses, if discrepancies were identified.

Is there a distinction between chemical and nonchemical cleaning waste? Identifies if the permit makes any type of distinction between chemical and nonchemical metal cleaning wastes, or if th e two wastes are regulated similarly. In certain cases, additional information may be provided in this column (e.g., “NA; CMCW is trucked off site. There is no di scharge to surface waters.”) to expand on the response. Is nonchemical cleaning waste permitted with limits for metal cleaning waste or low volume waste? Identifies whether the nonchemical cleaning wastes are permitted based on the metal cleaning waste BPT limits or the low volume wastes BPT limits. In general, this column was populated based on whether the permit review identified if the plant had copper and iron limits for the nonchemical metal cleaning waste discharges. ERG assumed the wastes were permitted based on metal cleaning waste BTP limits if the plant was required to meet copper and iron limits. If nonchemical cleaning waste is handled as low volume waste, what is the basis? Identifies the basis for the nonchemical metal cleaning waste limits if they are based on low volume waste limits (i.e., no copper and iron limits). The main purpose of this column was to identify if the “Jordan Memo” was used as a basis for low volume waste limits. Limits and Other Comments Contains additional information provided by the EPA Regional offices based on the permit review, such as the specific limits for metal cleaning waste discharges or additional information about the basis for the limits. Evaluation of the Permit Review Results: The following fie lds were populated based on ERG’s assessment of the information provided by the EPA Regional offices. Can’t Evaluate Cleaning Type ERG concluded that there was not enough information provided to include this plant in the analysis (indicated by a “1”). Reason For those plants for which ERG “Can ’t Evaluate Cleaning Type,” this field provides additional information as to why the plant was not included in the analysis. Chemical Cleaning Wastes Only ERG concluded that the plant only genera tes chemical metal cleaning wastes and does not have nonchemical metal clean ing wastes (indicated by a “1”). Zero Discharge ERG concluded that the plant do es not discharge any ch emical or nonchemical metal cleaning wastes (indicated by a “1”). Chemical plus Nonchemical Metal Cleaning Wastes? ERG concluded that the plant generates both chemical and nonchemical metal cleaning wastes (indicated by a “1”). Nonchemical Metal Cleaning Wastes? ERG concluded that the plant generates only nonchemical metal cleaning wastes (indicated by a “1”).Memorandum April 19, 2013 Page 3

Table 1. Nonchemical Metal Cleaning Waste Permit Review Compiled Spreadsheet Description

Field Name Field Description and Population Methodology Low-Volume Waste Limits? ERG concluded that the pl ant’s metal cleaning waste discharges are regulated based on the low volume waste BPT re quirements (indicated by a “1”). Metal Cleaning Waste Limits? ERG concluded that the pl ant’s metal cleaning waste discharges are regulated based on the metal cleaning waste BPT requirements (indicated by a “1”). Chemical Metal Cleaning Waste Limits? ERG concluded that the plant’s metal cl eaning waste discharges are regulated based on the chemical metal cleaning waste BAT requirements (indicated by a “1”). Notes Additional notes regarding the evaluation of the permit review information.