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Summary of Comments on the Public Notice for the Proposed Information Collection for Steam Electric 

Effluent Guidelines and EPA’s Response1

Comment Response 60 Day Response Timea. 60 days to complete and submit the ICR (which requests a high volume of data, high quality data, and historical data) is not sufficient and generally unworkable. EPA should allow a minimum of 180 days to complete the survey. b. Many of the individuals that will be required to provide information hold positions in which they perform activities essential to maintaining and operating out power plants. These individuals cannot be spared to do weeks or months of work on the ICR in a condensed time period. Instead, the will have to work their schedules after certain duties have been completed. c. It is unreasonable to expect the “most knowledgeable person” or the “best engineering estimate” to be available in the 60 day timeframe. d. Response time should be extended considering the government forms and other ICRs facilities are required to complete and submit. e. When EPA distributed the 316(b) survey in 2000, the response time was 90 days to complete a survey that was less than one half the length of this questionnaire. f. Response time should be extended to accommodate small utilities, co-owned utilities, and companies that own multiple utilities. g. The general criteria for an extension request should be laid out. EPA should reply to extension requests in a fair and timely manner.

a., b., and c. EPA has carefully evaluated the time required to coincluding reviewing comments on this topic, and codays is sufficient time for completing the questionnplants have extenuating circumstances that result in time, they can request an extension. EPA will consion a case-by-case basis. EPA is aware that, literallyperson” may not be accessible for this questionnaire instructions to use the term “personnel knowledgeabthe comment about “best engineering estimate.” Threspondents will make the engineering estimate as rcontext, including the time constraint of the ICR. Thprovides a reasonable degree of flexibility to responthe burden of collecting measurement data (other ththe express purpose of responding to ICR questionsd. and e. EPA has structured the questionnaire in a manner thefficiently compile the necessary information, incluthat can be distributed among plant staff. The time pother surveys is not relevant to the time plants will nEPA notes that the steam electric questionnaire will than May 2010. Therefore, EPA does not anticipate collection activities such as EIA and FERC. f. EPA recognizes the concern raised but believes suprovided to complete the survey. EPA has reduced boperated by small entities by excluding them from Pquestionnaire is structured so that individual plants completing the survey, therefore the fact that plants 

1 Question numbers referred to throughout this table refer to the 1st FRN version of the questionnaire. 
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Comment Response 

companies operate multiple facilities alone is not suadditional time for completing the ICR. g. See the response to a-f. EPA will not automaticalICR. Each extension request will be considered on a EPA will respond in a timely manner. Until they recrequest for additional time, plants should not delay questionnaire. 

Defining the Scope of the ICRa. Facilities that do not possess a NPDES permit should not be required to respond to the questionnaire. b. Facilities that have no discharges associated to the effluent limitation guidelines should not have to respond to the questionnaire. Many of the questions request analytical data but have no indication of final discharge. When these discharges go to evaporative systems or are recycled back into the plant system there often are not adequate responses provided in the questionnaire. c. Zero liquid discharge facilities should not be included in the scope of this questionnaire. d. Participants of the 2007 Data Request for the Steam Electric Power Generating Industry should not be included in the scope of this questionnaire. e. Consider “screener” surveys and/or questionnaires to gather information from the coal-fired power plant population. f. Plants that are closing and/or repowering in 2009 should not be included in the scope of this questionnaire. g. Small businesses should not be included in the scope of this questionnaire. 

a., b., and c. Information from plants that do not discharge waste

rulemaking process because it provide valuable insior eliminate pollutant discharges and it will be factoand consideration of effluent guidelines options for these plants remain within the scope of this ICR. d. This ICR collects more broad operational data annot obtained by the 2007 data request and that is no

sources; therefore, those facilities remain within the questionnaire. Also see Part A of the supporting sta

e. EPA did not elect to statistically sample a su

power industry for Parts A through D and I due 

of factors to be considered regarding FGD and 

limited data available for identifying these fact

extent necessary for establishing and defining ssampling, as well as the individual plants that pstrata. Throughout the detailed study and durinactivities, stakeholders have stressed the need t

variability in equipment and operating practice

wastewater discharges. In addition, stakeholderover properly accounting for the financial cond

considering ownership of individual generating 

number of instances, multiple partial owners. Eapproach that would issue a screener survey fol
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Comment Response 

detailed questionnaire to selected plants, but derange of variables to be evaluated would still resection of the industry being selected for the deDespite the commenter’s suggestion to issue a noted that the comment identified more than sixserve as strata for statistically sampling plants; accounting for financial strata criteria and other interest. Given this situation, a screener questioextensive itself, and in the end possibly would the number of coal-fired plants that would recequestionnaire. The types of operations and the wastewaters can change from facility to facility such as the type of coal burned, air pollution cowet FGD absorber design, FGD wastewater trehandling system, ash pond management, type oand the water source. Considering the large numbe evaluated and the limited data currently avaidistribute Parts A through D and I of this questpower plants.f. EPA has revised the questionnaire so that facilitieretired or will be permanently retired by December complete only a few questions at the beginning of ththat are repowering and will resume operating must g. EPA will include small businesses in the scope of obtain information necessary to understand their opimposed by revised effluent guidelines would affect financially. However, to reduce burden imposed on excluding coal-fired plants operated by small entitieE, F, and G. 

Notification of the ICRa. EPA should provide the list of respondents prior to the mail out of the questionnaire. 

a. EPA does not intend to publish the list of facility 

the questionnaire because doing so could potentially 

or force EPA to aggregate CBI (to prevent revealing 
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Comment Response b. EPA should notify trade associations and industry of any changes made to the questionnaire (from the 1st FRN Draft) prior to the 2nd FRN publication. 

that makes it more difficult for the public to view de

analysis.. b. EPA has continued outreach with industry and andiscuss plans and potential ICR revisions, as approp

questionnaire will be published as part of the 2nd FRhave an additional opportunity to review and submi

Distribution of the ICRa. If the distribution of the questionnaire happens in the May-June 2010 period it would be very difficult to spend 200 to 500 hours answering the questionnaire for each facility. Facilities also have to file routine reports such as DMRs and TRI reports by July 1st. Suggest distributing the questionnaire after July 1st. b. Delay the ICR until January 2011 to reduce burden on respondents, as well as increase the utility of the ICR. c. There should be some consideration given, when distributing the ICR, to the other ICRs that facilities will be required to respond to. d. EPA should delay the distribution of the ICR until after the pending CCR Rule (specifically questions and requirements regarding ash handling and leachate sampling). It is likely that the CCR rule will have a significant impact on cement management practices for fly ash, bottom ash, FGD scrubber solids, etc. When the CCR rule is finalized, the information for Part B, C, D, and G could be largely obsolete. 

a., b., and c. EPA is aware that the questionnaire may be distribu

are engaged in other data collection and reporting ef

recognizes that some of these efforts are year-round for which plants are already staffed, and that it is imdata collection efforts. In addition, this ICR will occ

completed efforts for EIA and FERC, and much of t

The proposed effluent guidelines are scheduled for order to meet this deadline, data collection must occ

d. EPA has made every effort to reduce or eliminate 

collected, and to tailor this questionnaire to informaELGs. Although EPA recognizes that future changehandling of CCR, the data requested on current and useful in evaluation technologies for control of was

see response to comments for Part C and G. 

Development of the Questionnairea. In developing this ICR, EPA has not been willing to discuss industry concerns and adopt suggestions as EPA has been in the context of other ICRs. b. This ICR attempts to better understand power plant operations with regard to water discharges for a number of different plant designs. However, based on trade association experience, the chemistry of trace elements and their partitioning to the water stream is not well understood, and the existing data will not be sufficient in terms of quality and breadth to allow Agency to project water impacts. 

a. EPA encourages industry input and has consistenfacilitate communications over the course of the dearulemaking, including the ICR development. See thabout outreach and technical discussions with indus

b. EPA feels that the questionnaire requests appropr

data to understand current and future discharges in tencourages discussions with industry on content of improve the questionnaire. In addition, EPA invites additional data they believe EPA needs to project w

All Parts/Definitions/Terms
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Comment Response a. EPA should prepare a list of definitions/glossary for terms found within the ICR. b. The Utility Water Act Group (“UWAG”) submitted a letter to EPA requesting that EPA provide definitions for several undefined terms used throughout the draft questionnaire. EPA should formally respond to the request. c. To ensure consistent understanding by both EPA and the industry, it is imperative that EPA make its glossary available for public comment before sending the proposed ICR to OMB for review. d. EPA has failed to provide adequate notice because of the lack of a glossary and incomplete nature of the draft questionnaire. e. Request for “planned” activities will likely yield inconsistent results. EPA needs to define “planned” and “future” in both scope and scale. f. In order to facilitate completion of the questionnaire as soon as possible, a detailed table of contents is needed. 

a., b., and c. EPA prepared a glossary of terms for the questionnaUWAG’s recommendations in developing the glossglossary with stakeholders in advance of the second 

extensive feedback from industry. These suggestion

revising the glossary, which is included in the curred. EPA disagrees that the Agency failed to provide disagrees that because a separate list of definitions wdraft questionnaire, that it is not possible for the pubcomment. Many of the terms were defined within tquestions of the survey. e. EPA has revised the questionnaire to more specifthe request for “planned” and “future” activities. f. EPA will include a Table of Contents in the quest

Request for 2008/2009 Dataa. Requesting 2008 data as the most recent year would allow companies to start gathering information sooner. 2008 data is already available and given the economic downturn late in 2008, the argument could be made that 2008 was a more representative year for facilities than 2009. 

a. EPA has minimized the specific request for 2009 necessary. In many instances, EPA does not limit th

and instead asks for data that represent “normal ope

page provides an opportunity to identify any atypica2009, where appropriate, to establish consistency am

Overlap with Existing Dataa. A number of questions request information which appears to be available via the Energy Information Administration (EIA)/Federal Energy Regulatory Commission (FERC) databases. Where possible, utilization of existing resources would reduce unnecessary efforts by the Agency and respondents. b. Under section 3506(c)(3)(B) of the Paperwork Reduction Act, EPA must certify to OMB that the information sought under an ICR is not unnecessarily duplicative of information otherwise reasonably accessible to the agency. Commenters believe that EPA's proposed ICR does not meet this standard. Questions in the proposed ICR overlap with information that is proposed to be collected by EPA under the ICR for developing MACT standards for coal- and oil-fired electric utility steam generating units (the “Utility MACT ICR”). Thus, the Office of Water must use information that will be collected by the Office of 

a. EPA has completed a thorough review of the enti

potential overlap with other sources (e.g., EIA, FEREPA deleted or revised certain requests or otherwise providing the exact information in more than one refor identification purposes). Specific overlap has becomment responses for each part. b. EPA has completed a thorough review of the entioverlap with other completed or ongoing ICRs (inclICR and the ORCR data). Where possible, EPA has 

questions to minimize or eliminate overlap. Specifi

addressed in specific comment responses for each p
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Comment Response Air and Radiation as well as information that has already been collected by the Office of Solid Waste and Emergency Response, instead of collecting duplicate information. Electronic Format for the Questionnairea. In a recent EPA-sponsored conference call, EPA personnel asked for recommendations for software to be used for the electronic version of the ICR. After review, EPA should use MS Excel. b. EPA should thoroughly test the electronic version of the questionnaire before release. 

a. and b. EPA is using MS Excel as the format for the electroformat is being distributed as part of the 2nd FRN to format and allow stakeholders the opportunity to tesaddition, EPA has conducted initial testing and will questionnaire prior to its distribution. This electroni

minimize burden on the industry and ensure efficien

collected data. 

CBI Justificationsa. EPA has made the process for claiming information as CBI extremely burdensome. The request to provide justifications departs significantly from previous ICRs. EPA should work the industry to designate portions or even complete section CBI. 

a. EPA recognizes that supplying justifications for Cmay impose burden unnecessarily on the industry. Tmarked as CBI according to practices familiar to the the question will be marked and no justification at tbe required. 

Certification Statementa. EPA's proposed certification statement, requiring "best knowledge and belief' that the information is accurate, is inappropriate for an ICR of this complexity. In contrast, the proposed MACT ICR does not include a general certification statement. (There are certifications associated with some of the individual questions.) 

a. Respondents should certify that the requested info"best of their knowledge and belief" given the time of the questionnaire. The certification language is tand is appropriate for a data collection such as this. 

Request for Cost Dataa. Providing capital cost estimates of past projects, many by engineering judgment, will stretch the usefulness of the resulting data, but coming up with a breakdown of O&M costs associated with specific plant operations (for example the fly and bottom ash handling costs in Part C) or per pond/impoundment (per Question D54) will result in data of very limited value. b. Some capital costs are over 30 years old and may be estimates. Should 30-year dollars be used or should the dollar estimates be escalated forward? 

a and b. EPA does not agree that the requested O&M value. These data are necessary to evaluate potentiathe impacts that new pollution control requirements has limited the request of O&M costs for ponds/impash handling systems to those installed after January Respondents should answer these questions with the and use the comments page to call attention to any ethat may have been made. Respondents should answcapital costs with the best available information and the provided costs. EPA has limited the request of c
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Comment Response 

ponds/impoundments, landfills, and ash handling syafter January 1, 1985 to reduce burden. No inflation to the costs provided by respondents. 

Burdena. EPA’s burden estimate is too low, especially for utilities with multiple plant sites. The amount of information called for seems over burdensome in that it is not clear that the amount of requested detail is needed. b. Companies have noted that completing the questionnaire will take on the order of five to ten full-time staff several months per facility, a burden that is very difficult to sustain. EPA needs to provide a more realistic burden and look for ways to reduce the burden. c. EPA consistently states that the survey is divided into sections to reduce burden, saying that no facilities will have to complete all sections. All coal plants will have to complete at least four, one third will have to complete all except, obviously, the nuclear section. This does not reduce the burden. d. EPA’s average burden estimate of 205 hours is extremely underestimated and does not account for different facilities being subject to different questionnaire requirements or any first level coordination. This estimate should at least be doubled for coal-fired power plants. e. Nowhere in the calculation of the responded time burden does EPA account for facilities having multiple units. f. EPA could reduce the burden by eliminating questions unrelated to discharges to “Waters of the United States”. g. Eliminate questions requesting capital costs in Parts C and D for older installations to reduce burden. h. EPA’s estimate of total burden is not clear and unable to be replicated. i. EPA’s labor costs and time estimates are questionable. 

a. and b. EPA has reviewed and considered all comments rec

FRN burden estimate. EPA has revised the burden e

comments from the industry and revisions made to carefully reviewed and revised the questionnaire to 

requests that are unnecessary. See Part A of the sup

information on why the data are being requested. c. and d. EPA reviewed the questionnaire and comments to restimate, taking into account some time for first lev

recognizes that the calculated average burden differ

fuel segments of the industry. EPA will estimate a bthe industry to come up with a more accurate averag

a specific fuel type. e. EPA revised the burden to account for all plants, 

ponds and landfills, and wet/dry FGDs. The revised published with the 2nd FRN, explains the number of revising the burden. f. The questions included in the ICR are relevant to States” in that they characterize operations that genthose wastewaters are managed, or identify practiceand/or discharging wastewater. As part of the rulemoptions will be considered, this information is requeaccordingly and make informed decisions about potELGs. g. EPA has limited the request of capital and O&M 

ponds/impoundments, landfills, and ash handling syafter January 1, 1985 to reduce burden. h. EPA revised the Supporting Statement so that the 
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Comment Response 

and able to be replicated. i. EPA will adjust labor rates by 30% to account for benefits. The time estimates were reevaluated for thconsideration of comments on this topic. 

Supporting Statementa. Page one states, "... determined that significant amount of the toxic pollutant loadings discharged to surface water by point sources." appears not necessarily fact based, and is not supported by references. Recommend changing wording or provide an example/proof for the statement that it was "determined that significant amount of the toxic pollutant loadings discharged to surface water by point sources." b. Support statement language regarding EPA seeking information on, "candidate pollution control technologies" to meet the effluent guidelines approach, appears to be open to candidate technologies regardless of their point of development. EPRI is concerned that technologies not yet proven on specific power plant wastewater at a full-scale should be noted as such. Reference needs to be made to "demonstrated controls" with respect to "candidate pollution control technologies" to meet the effluent guidelines approach. 

a. EPA refers to the findings of the Steam Electric PSource Category: Final Detailed Study Report (EPA this statement. See the report for information suppob. EPA plans to use the information collected by the additional research to consider and review candidattechnologies. EPA will evaluate all aspects of potenincluding their technical feasibility, whether they areconomic affordability, before using them as a basinecessary for a technology to be proven at full-scale 

plant wastewater for it to be considered as a basis fo

Front Mattera. Page iii states “Extension requests will be evaluated on a case-by-case basis. Submittal of an extension questionnaire to EPA...” The word “questionnaire” should be changed to “request” in the second sentence of this paragraph. b. Page ii states “Each part should be completed by the person(s) most knowledgeable about the information requested.” Throughout the Questionnaire, references to “persons most knowledgeable” should be changed to “qualified personnel” consistent with the certification statement. Given the very short response time for the Questionnaire, it is unreasonable to expect that the most knowledgeable person will always be available or could even be immediately identified and assigned to the appropriate topics. All companies will need multiple personnel to respond to the questions. By the time the Questionnaire is circulated to all personnel who will need to contribute to the answers, a significant portion of the 60-day period will have already passed. The Questionnaire does not provide adequate time for intra-company 

a. EPA incorporated this change. b. See response above for “60 Day Response Time.c. EPA added a glossary that defines all key terms f

and added a list of acronyms at the end of the front for “All Parts/Definitions/Terms.” d. See response above for “60 Day Response Time.
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Comment Response communications and quality assurance steps. c. EPA should provide definitions of key terms. Definitions of key terms, according to the instructions, are supposed to be “at the back of the questionnaire” but are not attached. Neither is the promised list of acronyms and measurement units. Among many other undefined terms, EPA should define the following bold, italicized terms: plant-p. vi; wastewater treatment, p. vi; pollution prevention, p. vi; best management practices, p. vi; permanently, p. E-5; temporarily, p. E-5; pond/impoundment, p. E-5; disposal, p. E-5. d. Although the instructions provide for individual extensions to be decided on a case-by-case basis, and provides a 21-day period for filing an extension request, EPA does not specify how quickly it will act on those extension requests. Requests that EPA agree to respond to extension requests within one week after electronic receipt of the request. Also, EPA should provide some general criteria that will be considered in granting extension requests. Part A/Steam Electric Power Plant Operationsa. Commenters believe a question should be added, so that if a facility does not discharge wastewater (i.e., do not possess a NPDES permit), then the facility would not be required to complete the questionnaire. b. Commenters believe that Q. A1-2 through A1-5 should be revised to require the submission of a single contact name due to the complexity of the questions in the Questionnaire. This person would be responsible for contacting additional individuals for responses to additional questions posed by EPA. c. Commenters think Q A1-6 should to be more specific. They ask if the unit has not generated electricity during the 2009 calendar year, would the answer be no. d. In Q. A1-9, commenters ask EPA to provide clarification regarding what constitutes "Distributed NOT for sale" to ensure consistency in responses. They are uncertain if it refers to power used for station service. e. In Q. A1-11, commenters ask what standard applies for judging whether the primary purpose of the plant is generation of electricity. Does it mean 50% or more of the profits are from electricity generation?f. Commenters believe the information requested should be limited to 2007 through 2009 in Q. A1-15. Requiring information from 2005 through 2009 is

a. EPA does not agree. See response for “Defining t

b. EPA requests a primary and secondary contact fo

economic data for cases when one of the contacts mAdditionally, the contacts for economic and technic

different. If the plant determines the same contact cand technical information, they can answer accordinprimary and secondary contacts are still required. c. EPA changed the wording to ask if the plant has tequipment available on site) to generate electricity fgenerating unit. d. EPA removed the “Distributed NOT for sale” res

is generating power for the distribution and use off “Other” and provide a description. e. EPA defines primary purpose as “the predominanprincipal reason for operation.” f. EPA reduced this request to 2007-2009, and intenand 2006 from EIA, as available. 
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Comment Response overly burdensome and is unlikely to provide information that is more representative. g. Commenters ask EPA to confirm that Q. A1-18 requests information for permits associated with wastewater or stormwater discharges from industrial activities and does not include permits required for construction of wastewater and/or sanitary sewage facilities; erosion and sediment control permits associated with construction activities; temporary permits, general permits for hydrostatic testing water, water obstruction and encroachment permits and/or water allocation permits. Furthermore, commenters believe that EPA should delete the requirement to include pending permits. Pending permits have not been issued as yet, may be changed prior to issuance in final, and often do not have permit IDs, approval dates, or expiration dates. Additionally, commenters ask why EPA needs information on the plant’s RCRA, air, and UIC permits for the purpose of setting effluent guidelines. h. Limited or zero discharge facilities may not have receiving waters for certain discharges to include in Table A-3. i. Commenters believe that EPA should clarify that the surface waters at issue are those that are waters of the United States or waters of a State and not waters outside the jurisdiction of EPA and a State. As Q. A1-19 is currently worded, respondents may believe they need to identify non-regulated on-site waters such as private ponds or water bodies that are part of the wastewater management system. In addition, it is assumed that plants discharging to cooling ponds that are not Waters of the U.S. do not need to answer this question. Additionally, “Reservoir” should be added as a possible response under type of receiving surface water in Table A-3. j. Throughout Part A, EPA uses the term “planned.” Commenters ask EPA to define this term to ensure consistent responses. They suggest a short-time frame such as within the next 2 years. k. Many power stations utilize small sediment traps along access roads, haul roads, soil borrow areas, closed landfills, etc. to minimize the quantity of suspended solids to receiving streams. Pennsylvania, along with other states, broadly defines these same terms. Therefore, commenters request that EPA define the terms ponds, impoundments, storage, disposal, process wastes, 

g. EPA clarified in the instructions for Table A-2 th

cover permits associated with industrial activities anconstruction of wastewater and/or sanitary sewage fsediment control permits associated with constructipermits, general permits for hydrostatic testing wateencroachment permits and/or water allocation perm

added an additional column in Table A-2 asking pla

permit under development and revised the instructioneed to provide the ID numbers and dates associateInformation in permits not related to water such as R

permits will provide EPA with the information needpermits, if necessary, to evaluate potential waste str

from other process operations associated with the repermits. For example, these permits will include inf

and storage systems and other technologies, which g

interest. h. EPA revised Table A-3 to request this informatio

a question format. EPA clarified that plants should 

outfall information if the plant does not have a NPDoutfalls). i. EPA revised Q. A1-19 to request information on t

outfall designated in the plant’s NPDES permit. EPresponse option for the type of surface water.

j. EPA agrees that it would be useful to define a tim

planned systems, but disagrees that "planned" shoul

years. EPA established appropriate timeframes for questionnaire. k. EPA defined the terms "pond/impoundment", "pr"residue" in the glossary of the questionnaire. EPA are required for “storage,” “disposal,” and "by-proddoes not require plants to report information on sedl. The term "effluent point" has been changed to "podefined as "the point at which the pond/impoundmepond/impoundment, surface water, or other process
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Comment Response residues, and by-products and clarify if sediment traps are included within these definitions. l. Commenters ask EPA to clarify in Q. A1-20 whether the effluent point is the point at which the effluent is discharged to a water of the United States or a water of the State or whether it includes internal discharges between ponds/impoundments. Many ponds have outlet structures that lead to additional water treatment and then an effluent discharge; it is unclear under the existing language whether a pond outlet would be considered an effluent point. “Effluent point” should be defined as that point where the treated effluent (pond or otherwise) discharges to the receiving water as defined in the applicable NPDES permit. m. Commenters believe “landfills” should be defined. n. In column 5 of Table A-4 in the heading, commenters ask what does EPA mean by “is leachate collected.” Commenters state that leaks from ponds/impoundments are not leachate. Commenters ask why does EPA need information on retired and closed ponds/impoundments and believe EPA should define “closed” and “retired.” o. Commenters think that Table A-5 needs a separate column for water/wastewater treatment chemicals and/or metals and should include columns for metal cleaning wastes, coal pile runoff, and low volume wastes. Additionally, the instructions for Table A-5 and Table A-7 should clarify that respondents do not need to report de minimis or incidental amounts of wastes stored or disposed of in ponds/impoundments or landfills. p. Commenters state that the heading in column 3 of Table A-6 is wrong. This is the table for landfills, not ponds/impoundments. q. Q. A1-22 requests latitude and longitude of the site. Commenters ask EPA to clarify the location at which the geographical coordinates of the plant should be identified (e.g., the center of the plant, the entrance gate, etc.). r. In Q. A1-23, commenters think that the word “available” is ambiguous and needs clarification. Land at some facilities could be made available for process equipment, treatment systems, etc. but only after extensive site work and grading is performed. Distance from the plant and limitations posed by existing structures also affect availability but could be overcome at great expense. Most electric generating stations have extensive arrays of buried electrical lines and pipes that 

clarifies that emergency outlets should be used for ptransference to another location. m. EPA defined the term “landfills” in the glossary n. EPA revised the definition of the term “leachate” 

seepage, leachate collection, and leak detection sour

information on closed and retired units is necessary units have a potential to impact surface waters. For the pond is lined is relevant whether the pond is opedoes not agree that “closed/retired" requires a definio. Plants are not required to report water/wastewateand/or metals in this table. EPA revised Table A-5 twastes, but also process wastewaters that are storedeach pond/impoundment unit. EPA disagrees that c

required to be reported in Table A-5 and Table A-7have been made. p. EPA corrected the heading in column 3. q. EPA revised this question to allow respondents to 

reported their coordinates to EIA on U.S. DOE/EIA schedule 2, line 6. EPA did not clarify the location 

respondents could use their EIA responses (EIA doe

for the coordinates). r. EPA has removed Q. A1-23 from Part A. s. EPA revised the instructions of Q. A1-24 so that 

provide aerial photographs or maps, but do not need 

information on the map (e.g., wetland areas, surface t. EPA revised the instructions of the water balance 

burden on plants. The instructions now specify that water balance diagrams from previous years as long representative of current operations. In addition, EPto request that plants report the process operations a

requiring them to report and present all the equipmeEPA has developed a destinations table located in thend of the part, which provide more general destina
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Comment Response seriously complicate development activities. Additionally, most power plants are located near waterways with associated wetland areas. Commenters believe available land should be defined as upland areas with no or minimal existing infrastructure and within a certain distance (i.e. 500’) of existing units. s. Commenters believe that the maps requested in Q. A1-24 will be very timeconsuming to prepare. This is overly burdensome. EPA should use existing public sources of information. Some companies would need to include within the property map a map of the facility’s reservoir (ranging in the thousands of acres) because the reservoir part of the facility is property. Additionally, if there is no discharge to wetlands, there is no reason to include them in the questionnaire. t. Commenters believe preparing the water balance diagram requested in Q. A1-25 will be very time consuming and burdensome. Much of the information requested (e.g., flows) does not exist for many of the streams EPA has indicated must be included on the Block Flow Diagram. EPA should not expect the water balance diagram to actually balance. In addition, diagrams are typically prepared by our environmental consultants when preparing permit applications, so none will contain data from 2009. As a result, subcontractors will be required to complete this activity putting more burden on the plant. In addition, the average annual flow rates should be estimates; otherwise it may be very difficult to ensure the flow rates match information in Table A-8. The final destinations indentified in the block diagram requested in Q. A1-25 should be general (e.g., off-site disposal, off-site reclamation, etc.) and not specific (e.g., the names of off-site locations that receive materials). u. Commenters think that the purpose of Table A-8 is unclear. Why does EPA need sludge data for a water balance table? Also, does the “solids or sludge” column refer to tons of sludge or tons of water in the sludge? Also, the volume of sludge or solids should be an average because the amount of sludge or solids produced on a daily basis can vary greatly over time. The terms “source water”, “process wastewater”, “treated wastewater”, “solids”, “sludge” used in Table A-8 should be defined. v. The “Date of Retirement or Expected Date of Retirement” column in Table A9 implies that any retired unit should be described. Responders may interpret requirement of how far back to report differently. Because retired plants generally do not generate wastewaters for discharge, this information request appears to be excessive and would not yield useful information about the 

u. EPA deleted Table A-8 from the Questionnaire; not needed. EPA deleted Table A-8; however, EPA the following terms in the glossary: “process wastew

“sludge” in the glossary of the questionnaire. v. EPA removed the “Date of Retirement or Expect

column from Table A-9, because this information cMACT ICR. w. Although EPA removed the need to report type oadded "Pressurized water reactor," “Boiling water rheavy water reactor” as response options in the "Ty

column for Table A-10. EPA also defined the terms 

"intermediate unit" in the glossary of the questionnax. Cooling system data are not provided in Table A-commenter was referring to Table A-11. Table A-1allow multiple cooling systems at the same plant to 

a cooling system in each row and indicating what un

system. Respondents should not use the 316(b) desiy. EPA revised Table A-11 so that plants can specifand more than one active ingredient can be added pz. EPA revised the “Average Amount of Wastewateand “Typical Duration AND Frequency of Generati

Table A-11 by changing "average" to "typical" in bo

aa. EPA revised Table A-11 by changing the fourth Biocide Used in Cooling System" to "Chemical Add

Cooling System and Make-up Water System." bb. EPA revised Table A-11 to include only conden

cc. EPA deleted the request for copies of the reports EPA refers to any type of monitoring used to demonmay provide further explanation in the comments paassumes that this question actually applies to A1-29 tower blowdown is relevant to the revision. Blowdo
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Comment Response industry as a whole. Furthermore, personnel familiar with retired units are often retired as well or no longer have detailed knowledge about older retired units. Lastly, information about older retired units is often archived and/or is not readily available. Therefore, EPA should consider requesting information for units retired since a set date. w. In Table A-9, EPA should include “nuclear” as an option in the “type of boiler” column. EPA provides definitions for “peaking unit” and “baseload unit”, but also needs to define “cycling” and “intermediate.” x. Commenters ask how should multiple cooling systems at the same facility be distinguished in Table A-9 and also should the designations used for the 316(b) questionnaire be used for this questionnaire as well. y. For each cooling system there is only space for listing one biocide used in a system in Table A-11. Commenters state that table A-11 should be revised to allow for the identification of more than one biocide and more than one active ingredient per biocide. z. Table A-11 requests information in a manner that is certain to produce responses that may not be comparable to other responses or may not meet the agency's intentions with regards to the requested information. The fifth column from the left asks for "Average amount of wastewater generated/blown down." EPA needs to clarify the averaging period. aa. Information regarding the use of biocides should be expanded to include all chemical additives added to the cooling tower and make-up water systems. The beneficial effects of these additives may impact the performance of downstream wastewater treatment systems (WWTS) including, but not limited to the clarification and/or filtration of cooling tower blowdown and chemical treatment of FGD scrubber purge water where cooling tower blowdown is used as makeup water to the scrubber system. bb. Commenters believe that Table A-11 needs to be clarified to identify the type of cooling systems to be included. If this is asking only for condenser cooling systems, then that needs to be stated. cc. Commenters state that in most cases, chemical additives used within cooling tower systems can often be certified by our suppliers to be free of priority pollutants. This should be added as a fourth check-box. Q. A1-30 requests for 

under the existing ELGs, regardless of whether treasuch, EPA is characterizing these waste streams, incgenerated/blown down. dd. EPA reworded the instructions to state that "Thrprovide information for all steam electric generating in 2009 including units that operated for only part o

"idle" and "extended period of time" do not need to 

ee. EPA agrees. EPA deleted Q. A2-1 from the ques

instructions for Q. A2-2 to include fuels used for sta

further clarification is needed. ff. EPA revised Q. A2-2 to remove the terminology 

has also revised the question to request use of “bitum

gg. EPA deleted. Q. A2-3 and Q. A2-4 from the quehh. EPA added questions to Section 3 asking if the pcatalyst on site. If so, the plant is prompted to answare asked for the SCR catalyst regeneration wastewdefined the terms "SCR catalyst regeneration" and "the glossary of the questionnaire. ii. EPA added a "NA" box to the "Where Last SCR Occurred" column. EPA believes that the comment of SCR offsite regeneration" probably applies to QAagrees that it can reduce burden by limiting the respregenerations. EPA defined the term “NOx control the questionnaire. EPAdoes not believe the other terjj. EPA converted Q. A3-2 to a table to allow two cokk. EPA has retained the request for planned systemrespond regarding any planned systems at the time tquestionnaire. ll. EPA revised Q. A3-9 to exclude particulate matte

with FGD and SCR/SNCR systems that are not inclmm. EPA defined the term "flue gas mercury contro
Page 14 of 39 Ver

Comment Response copies of the reports and calculation sheets, which is excessive and unnecessary for the development of revised ELGs and should be omitted from the ICR. Additionally, commenters ask does Q. A1-30 refer to monitoring in addition to priority pollutant sampling submitted with the permit renewal application or reviewed on an annual basis. Commenters ask is the fate of the cooling tower blowdown relevant to the steam electric guidelines revision. Cooling tower blowdown is used internally or the cooling tower blowdown is sent to a wastewater treatment system and not discharged directly to the receiving water body. Are these flows still to be reported as "wastewater generated/blown down?" dd. Commenters believe the instructions of Section 2 need to be revised. They are uncertain if a unit that did not operate at all in 2009 would be included. EPA needs to define “idle” and “extended period of time.” ee. Commenters wonder what the relevance is, for purposes of effluent guidelines, of distinguishing fuels used for start-up from other fuels in Q. A2-1 and recommend deleting this question. Additionally, on a natural gas-fired unit, which uses gas to both start up and generate, is there a clear demarcation for when start-up ends and “steady state” operation begins. It is common practice in air permits to define “start up” and it may vary. EPA needs to clearly define when the start up period is over. ff. For Q. A2-2, EPA should provide a definition for “normal operation.” EPA should also provide definitions for “Eastern Bituminous” and “Western Bituminous” as they are used in Table A-12. What is the relevance of this question for effluent guidelines purposes? gg. Commenters believe that Q. A2-3 requests for data on "any oil or coal" could yield very large amounts of data, if coal samples are collected daily. Also plants sample their coal differently, as some sample as received and other sample as fired, which could include blends of various coals. They suggest EPA to re-think this request as this data is not likely readily transferable to ELG water quality data or standard setting. Additionally, Question A2-4 seems to imply that analytical data required by A2-3 is required for each mine used to supply coal burned by the unit. Question A2-3 should be revised to include only representative data for each single type of fuel burned to minimize the ICR burden. Or EPA should consider requesting averages of available data. Additionally, EPA should consider limiting the coal analyses to volatile trace elements – mercury, selenium, chloride, and boron – and consider more detailed 

of the questionnaire. nn. EPA assumes the commenter is referring to Q. Arequest for "type of materials of construction" from 

oo. EPA reworded the language as suggested by the pp. EPA has revised the request to specify all techn

provide reports from technologies generate wastewa

pilot test data requested in Q. A3-11 are not applicauseful for evaluating potential technology options th

generate future wastewater streams. qq. EPA replaced “Table A- 16’ with “Table A-17.” rr. EPA changed the date in Q. A3-13 to January 1, 2005. ss. EPA defined the term "carbon capture system" in questionnaire. EPA has phrased Q. A3-14 to allow pnecessary to adequately provide the information reqQ. A3-14 so that plants would only need to provide 

technologies that generate wastewater. tt. EPA disagrees that reports should be limited to th“impacts” due to the ambiguity in that term, and the

A3-15 from the questionnaire. uu. EPA clarified in Q. A4-1 that processing coal into prepare the coal for use at the plant including but crushing/pulverizing coal.vv. EPA clarified in Q. A4-2 that the plant can mak

pile runoff, but a description of the calculation needclarified the request to report number of days of dis

of days of runoff. ww. EPA rephrased Q. A4-3 to ask "Was the coal ppH?" If yes, the plant is required to provide data. xx. EPA revised the question so that plants indicate
Page 15 of 39 Ver

Comment Response studies at select facilities Commenters believe that EPA's reason for requesting the coal quality data is based on a false premise and EPA has failed to state an adequate justification for this onerous data request. hh. Commenters state that EPA should clarify Q. A3-1 to ask if catalysts are washed with water onsite, and note that this does not include regeneration with various acids/bases offsite. Most, if not all, catalysts are regenerated offsite using various acids and bases. Some plants may wash the catalyst onsite to remove fly ash. Some clarification is needed to ensure consistent responses. The limited water data at most power plants will likely be of minimal benefit. Comprehensive multimedia studies (consisting of flue gas, water, and solids sampling and analyses) at numerous power plants are needed to characterize and be able to accurately quantify the effects of NOx control on water. ii. In Table A-14, EPA should define the terms “NOx control system”, “SCR”, “SNCR”, “overfire air”, and “low NOx burner”. In addition, the “Where Last SCR Catalyst Regeneration Occurred” column needs an “N/A” box. Answers to the questions about future replacements/regenerations will be very speculative and will depend on unit operation and current catalyst condition. Must the plant report every instance of SCR offsite regeneration? This question needs a reasonable timeframe – e.g., sent offsite within the last two years. jj. Additional lines should be provided for plants that send SCR catalyst off-site to more than one facility for regeneration in Table A-14. kk. Q. A3-9 asks for planned Hg flue gas controls. It is unclear how power plants would respond since a mercury rule has not been finalized. This may also depend upon other EPA actions on climate/carbon, CCPs, cooling system retrofits etc. Commenters suggest limiting "planned" to a relatively short time period, such as 2 or 3 years – or a planned approach for responding to the proposed (and now vacated) CAMR rule. ll. Commenters believe the wording in Q. A3-9 needs further clarification. Particulate collection systems, including baghouses, need to be excluded from the questionnaire, along with the FGD and SCR/SNCR systems. mm. EPA should define the term “flue gas mercury control systems.” nn. Q. A3-9 Asks for the materials of construction for all mercury controls. Commenters are unclear how this information could be used to characterize 

runoff was transferred to a pond/impoundment and multiple options. EPA also defined the term “dischaquestionnaire. yy. EPA revised Q. A4-5 by replacing the response discharged" with "All treated coal pile runoff discha

should provide their best estimate of generation. zz. “Coal washing” is defined in the glossary of the 

aaa. EPA defined blending to be the intentional mixprior to combustion, and does not include natural blbbb. EPA replaced the term "pyritic mill rejects" widefined the term "mill rejects" in the glossary of the ccc. “Waste coal” is defined in the glossary of the q

removed anthracite culm and bituminous gob from 
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Comment Response water quality or use, especially for activated carbon injection. oo. Commenters believe that Q. A3-10 is badly designed, will result in inconsistent answers, and should be deleted. This question requires, inter alia, that the respondent identify “any potential effect on other water streams” caused by flue gas mercury control system processes. This language is too broad. At a minimum, it should be reworded to require identification of “any known or anticipated probable effect.” pp. Commenters had several concerns about Q. A3-11. First, they believe pilot studies do not indicate whether the full-scale plant will actually install this technology and suggest limiting the request to reports that include impacts on wastewater, given uncertainty over the dates and compliance approaches of future rulemaking. In addition, data from a pilot test that will not be used at the plant would also not appear to be relevant to this ICR and only increases the burden on each respondent. Pilot studies are usually only of a slip-stream of flue gas and are of short duration. In addition, many companies have performed multiple pilot-scale flue gas mercury control studies. Many of these experimental tests have never been implemented full scale; therefore, the results are not pertinent to the effluent guidelines rulemaking. Additionally, most of these studies have not evaluated wastewater impacts. At a minimum, this question should be limited to reports that include wastewater impacts. This request is extremely burdensome and will require a significant amount of time to locate reports. qq. In the description of Table A- 17, there is a reference to Table A- 16 that is wrong – it should be A-17. rr. In Q. A3-13 the time period for data request is for 2005 instead of 2009. Commenters ask if this question should read as the previous section as January 1, 2009 or is it 2005. ss. EPA should define what it means by a "carbon capture system" and provide that definition to the public for review and comment prior to finalizing the questionnaire. In addition, the request for "any potential effect on other water streams" in Question Q. A-14 is too vague and speculative. EPA should identify the effects that it is concerned about and specifically identify them in the question so the respondents can determine if they are applicable. Commenters are also concerned that the open ended nature of this question will result in inconsistent answers. 
Page 17 of 39 Ver

Comment Response tt. Some companies have performed multiple pilot-scale carbon capture studies. Many of these experimental tests have never been implemented full-scale; therefore, the results are not pertinent to the effluent guidelines rulemaking. Additionally, most of these studies have not evaluated wastewater impacts. At a minimum, Q. A3-15 should be limited to reports that include wastewater impacts. This request is extremely burdensome and will require a significant amount of time to locate reports. uu. EPA needs to define “process.” Does crushing/pulverizing coal constitute processing coal? vv. Q. Commenters believe that A4-2 is badly phrased and should be modified or deleted. EPA should allow the use of an estimate in Q. A4-2 because actual amounts will vary. Companies can report on rainfall received or the amount of discharge, but cannot report the total runoff or how many days it took to collect the runoff. This is because runoff is affected by many factors, including reuse/recycling, evaporation rate, ambient temperature, wind speed relative humidity, and cloud cover, as well as the frequency, amount, and duration of precipitation. ww. Coal pile runoff is not required to be monitored for pH. Q. A4-3 should include a response box for “Not Monitored.” xx. In Q. A4-4 the respondent must specify if coal pile runoff is segregated, commingled, or discharged without treatment. Commenters wonder how the respondent answers if the plant has the ability to do any of these options, depending on operating needs? Also, EPA should define “discharged.” yy. Q. A4-2 through Q. A4-5 refer to coal pile runoff. One commenter states that the volume of coal pile runoff at some of our sites is immediately captured and reused in ash sluicing systems. There is no direct measurement of runoff volumes collected during the process; it would strictly have to be a calculation of inches of precipitation multiplied by the surface area of coal yard. Calling coal pile runoff leachate, whether treated and discharged or otherwise reused, is incorrect. It is not leachate, it is surface runoff. Therefore, the word “effluent” or the phrase “treated coal pile runoff” should be substituted for “leachate” in the third choice for this question. zz. EPA should define “coal washing.” 
Page 18 of 39 Ver

Comment Response aaa. Commenters believe that Q. A4-10 should be clarified so that it focuses only on blending various coal types, such as PRB with eastern bituminous (i.e., the intentional mixing of separate piles prior to combustion.. Coals from various suppliers are blended naturally when each coal shipment is placed on the pile. bbb. EPA should define the terms “pyritic mill rejects” and “mill rejects.” ccc. EPA should define the term “waste coal” and distinguish it from anthracite culm and bituminous gob. Typically, culm and gob are considered waste coal. Part B/Flue Gas Desulfurization (FGD) Systemsa. Commenters noted that the use of “FGD System ID” in Table B-1 does not agree with the nomenclature of “Sulfur Dioxide Control Systems” used in Table A-17. Commenters also noted that some of the information requested in Table B-1 is already reported in Form EIA-860 and Form EIA-923. b. Commenters believe that EPA should identify a time period for “planned” FGD systems and that it should be limited to relatively short time period, such as 2 to 3 years. c. Commenters believe that the terms “purge stream” and “scrubber purge” should be defined. d. Commenters noted that Q. B1-4 does not include a response category for adipic acid. e. Commenters noted that Table B-4 requested the materials of construction for the FGD systems, including all of the pumps; but the shafts, impellers, housing, etc., on the pumps may have different materials of construction. f. Commenters noted that if a respondent answers “No” to Q. B2-1, the respondent is allowed to skip to Section 3; however, Section 3 is also associated with Wet FGD systems. Commenters recommended that if a respondent answers “No” to Q. B2-1, the respondent can skip to Section 4. g. Commenters noted that the phrase "which section of system," in Q. B2-3 could potentially lead to a wide range of responses; therefore, the commenters suggested re-phrasing sentence to "and indicate which specific equipment units of 

the FGD system determines...." 

a. EPA deleted Table A-17 from the questionnaire; 

make any revisions to Table B-1. Additionally, EPA of the information in Table B-1 is reported in Form 923; however, EPA is using 2009 as its base year fofor this rulemaking and 2009 EIA will likely not be 

middle of 2011. Additionally, EPA is requesting in

planned until 2020, which would not be available frb. EPA revised Q. B1-3 by directing plants to provi“planned” FGD systems that will be operating or beconstruction/installation by Dec 31, 2020. c. EPA replaced the term "purge stream" and "scrubscrubber purge (or slurry discharge)" throughout PaEPA also defined the term “FGD scrubber purge” a

glossary of the questionnaire. d. EPA added adipic acid as an option in Table B-3e. EPA deleted Table B-4; however, EPA is now req

the equipment unit(s) that determine the maximum 

concentration of the FGD system. If multiple materused in the equipment unit(s), the plants are ask to p

construction that is most vulnerable to corrosion duf. EPA corrected the skip pattern for this question. g. EPA incorporated these changes. 
Page 19 of 39 Ver

Comment Response h. Commenters noted that Q. B2-4 asks for system parameters “used to control the FGD slurry blowdown from the FGD system.” The commenters asked whether this refers to the parameters used to control the quality of the FGD slurry as it leaves the absorber vessel, or at some other point in the process. i. Commenters noted that Q. B2-5 asks for the water sources that may be used as a source of FGD slurry water or FGD slurry water makeup. The commenters stated that the second reference to slurry water should be deleted. j. Commenters stated that many companies do not measure the mist eliminator wash, limestone preparation water, and FGD make-up water flow rates and that the flows vary widely based on operating conditions. Commenters believe that these questions are unlikely to generate usable, consistent responses. Commenters believe that an estimate would better fit an annual average instead of the stated instantaneous flows, durations, and frequency. A water balance based on annual flows and power production would be a more accurate reflection of operation. k. Commenters noted that Table X-X, which is referenced in several questions, was not provided. l. Commenters noted that Q. B2-13 seems to presume that blending fly ash with FGD solids always results in a pozzolanic material and that is not always the case. m. Commenters noted that Q. B2-14 uses the term “blowdown slurry,” and asked if that is the same as “slurry blowdown”? n. Commenters requested that EPA clarify the distinction between solids separation and solids settling. o. Commenters requested that EPA define the term “gypsum stack” from Q. B2-15. p. Commenters noted that Q. B2-16 uses the terms “permanently” and “temporarily” regarding the storage of FGD solids in landfills and/or pond/impoundments. The commenters requested that EPA define these terms. q. Commenters believe that the 5 year period of time requested for Tables B-5, B-6, B-8, and B-9 is not necessary to gain an understanding of FGD solids 

h. EPA revised Q. B2-4 to read “Indicate the FGD sused to determine when the FGD slurry is blown doi. EPA reworded Q. B2-5 to ask for “water sources source of FGD reagent preparation water or absorbefresh intake, recycled process water).” j. EPA changed the wording of those questions to aduration, and frequency” and, if the FGD was not orate data for 2010 should be provided. k. EPA included the process codes in the dropdown version of the questionnaire. EPA also added a “Coof each part for reference. l. EPA revised the question to ask if the FGD solids 

then included an additional question to ask whether 

formed. m. EPA incorporated these changes by replacing "b

"FGD slurry blowdown" throughout this part. n. EPA amended Figure B-1 to clarify “FGD solids Part B. EPA also added the term “FGD solids separo. EPA replaced the term “gypsum stack” with “gypAdditionally, EPA defined the term “gypsum stacki

questionnaire. p. EPA provided an example in the question to claripermanent storage. q. EPA revised the question to request three years o

However, EPA believes obtaining data that spans 20represent disposal and sale practices for FGD solids

data for 2005, 2007, and 2009. EPA acknowledges information regarding FGD solids disposition is inchowever, the 2009 data will not be available until thAdditionally, the information is reported on a plant EPA is requesting the information on a unit level to 
Page 20 of 39 Ver

Comment Response disposal and resale. Commenters believe the request is overly burdensome and is unlikely to provide information that is more representative than the 2007 through 2009 time period. The commenters recommended using a 3 year period of time to minimize the questionnaire burden. Commenters also noted that the some of the information regarding FGD solids disposition is reported in Form EIA-923. r. Commenters noted that Q. B2-17 through B2-19 request information regarding revenue generated from marketing of FGD solids. Commenters believe that the potential changes to the classification of ash products under RCRA could severely restrict or eliminate any beneficial reuse of coal combustion residuals and therefore, would decrease or eliminate the projected revenue streams and needs to be considered when EPA begins analysis for the compliance cost model. s. Commenters suggested that Q. B2-18 and B2-19 should be redesigned to be more explicit about the costs that should be included, such as labor costs. Additionally, commenters noted that Q. B2- 18 requests total costs incurred to remove or dispose of FGD solids in calendar year 2009, while Table B-6 asks for five years of FGD solids sales and marketing information. The commenters believe this creates an incomplete economic picture of the costs and benefits of FGD solids management. t. Commenters asked what basis the concentration of chlorides in FGD solids is to be provided (e.g., dry solids, liquor, other). u. Commenters believe that the terminology used in Table B-7 is confusing. Commenters suggest that the terms be defined and used consistently throughout the ICR. Commenters also noted that an estimate would better fit an annual average instead of the stated instantaneous flows, durations, and frequency. Additionally, commenters asked what period of time the average should apply (e.g., calendar year 2009), as well as whether the average should be a median, mode, or mean value. v. Commenters noted that it is difficult to obtain representative analytical data on untreated FGD purge stream, as requested in Q. B3-3, due to its high TSS and heterogeneous nature. Commenters suggested that EPA should request information on sample collection and analysis techniques. Commenters also believe that the data request should be limited to data collected during 2009 because providing 2010 data will be too burdensome, in that the data needs to be validated and analyzed before it is provided. Commenters requested that EPA define “solids separation process” and provide examples, such as, how does a 

unit/FGD system characteristics impact the disposit

r. EPA acknowledges that future rules may affect thhowever, past actions will assist EPA in characterizthe request to three years to minimize burden. s. EPA provided additional clarification in Q. B2-18 

included in the costs (e.g., labor, materials, transpor

addition, EPA combined Q. B2-18 with Q. B2-19 re2005, 2007, and 2009. In the table, EPA included s

the items identified in QB2-19 and requested the est

and the sum at the bottom of the table. t. EPA clarified that the plants should provide the chwet basis (i.e., analyze the chlorides for the FGD socontent included); however, if they do not have the 

basis they should provide the dry-basis concentratiocomments. u. EPA discussed potential changes to the terminolo

revised it in Figure B-1 and throughout Part B. In Tthe term “slurry water.” EPA replaced the “Slurry B

Absorber as Makeup following Solids Separation” c

Separation Recycle Returned to Absorber” and repl

with “typical” in the column headers. EPA also defreagent preparation water” in the glossary of the qu

v. EPA clarified in Q. B3-3 that respondents can pro

information regarding the sample collection techniq

in the “Part B Comments” tab at the end of the part. 

"FGD solids separation" in the glossary and added c

monitoring data should be collected after the last somultiple processes exist, and that the “last 12 month

the receipt of the ICR. In addition, EPA clarified th

location by providing examples. EPA notes that thedilution corrected quantitation limits because it is asspecific quantitation limit. EPA disagrees that data limited to data collected under normal operating concan provide additional details regarding any data prComments” tab at the end of the part. 
Page 21 of 39 Ver

Comment Response plant with primary and secondary hydroclones respond. Commenters also believe that EPA should provide clear instructions for describing the monitoring location. Commenters noted that EPA asks for the sample-specific nominal quantitation limit stipulated for the method used; however, they believe EPA should be requesting the sample-specific (dilution corrected) quantitation limit. Additionally, commenters believe these terms also need to be defined. Commenters believe that the data request should be limited to data collected under normal operating conditions and that any data collected during research and development activities should be excluded. w. Commenters believe that the requested information in Q. B3-3 is important, however, they believe that providing the monitoring data in the specific ICR electronic format adds additional burden to respondents. Commenters noted that monitoring data, in most cases, were not provided in electronic format and were not supplied in the ICR specified format. Therefore, hardcopies of the monitoring data could be scanned and provided, but commenter believe the manual transfer of this data into electronic format is not feasible in the time period provided. x. Commenters believe that the submittal of monitoring data requested in Q. B3-3 should be limited to that obtained using EPA-approved laboratories and methods. Commenters also believe it should be limited to NPDES permitrequired monitoring. y. Commenters noted that FGD water streams can be sent to a pond with a NPDES permitted outfall, but not discharge the water since the FGD waste stream has been sent to the pond. Therefore, the FGD pond water is stored in preparation for possible discharge, and the answer to Q. B3-4 is neither yes nor no, the only two options available. A third option, such as a general “Other (Explain)” is needed for this question. z. Commenters requested that EPA distinguish “FGD water” from “FGD purge wastewater.” aa. Commenters requested that EPA define “mill reject sluice.” bb. Commenters noted that Q. B3-8 is not appropriately drafted for facilities that use deep well injection as the ultimate destination for their FGD water stream. Commenters suggested that EPA add an “other – please specify” category of response to this question. 

w. EPA understands that the transfer of data to an eburden if not already available electronically. How

necessary to ensure collection of all data requested 

subject to misinterpretation by EPA. x. EPA disagrees with the suggestion to limit responNPDES monitoring because plants are not typically 

untreated FGD scrubber purge samples as part of N

known to collect these data internally for evaluation 

Additionally, all monitoring data collected should bmethod or laboratory as it is still useful for characte

purge stream. y. EPA has changed the wording of Q. B3-4 to ask i

FGD scrubber purge (or slurry discharge) to a settlin

z. EPA replaced the term “FGD water” to “FGD scrdischarge).” aa. EPA defined the term “mill reject sluice” in the questionnaire bb. EPA added a specific option for “deep well injefor “Other.” cc. EPA did not incorporate these changes because specific chemicals used in the system is obtained in dd. EPA replaced the term "gypsum stack runoff" wEPA defined the terms “gypsum wash water” and “glossary for the questionnaire. ee. EPA is gathering data on all potential technologeliminate potential pollutant discharges associated wTherefore, information on dry solids handling is per

ELG. ff. EPA acknowledges that future rules may affect t

however, past actions will assist EPA in characteriz
Page 22 of 39 Ver

Comment Response cc. Commenters noted that Q. B3-7 chemical precipitation option does not break out lime, iron, and sulfide. Commenters suggest that EPA provide extra response categories for lime, iron, and sulfide. dd. Commenters suggested that EPA define “gypsum wash water” and “gypsum stack runoff.” ee. There are several instances where the questionnaire requests detailed information on processes that cannot reasonably be expected to contribute wastewater sources that would be covered by the ELG's (for example Question B4-11 regarding five years of disposal records for dry FGD solids. ff. Commenters noted that information on revenue generated from marketing of dry FGD ash in Q. B4-12 could be significantly impacted by changes to ash disposal regulations. Commenters also noted that the technologies that may be required to meet upcoming mercury removal requirements could negatively impact the marketability of the ash products. For example, use of activated carbon for mercury removal can significantly change the characteristics of the ash produced and make it undesirable for other uses. Commenters believe this would significantly impact the accuracy of the compliance cost model. gg. Commenters suggested that EPA clarify what should be included and excluded when calculating total costs in Q. B4-13. hh. Commenters suggested that changes be made to Table B-10 regarding chemical additives, types of FGD system, and materials of construction. ii. Commenters noted that Q. B1-1 asks information that is requested in Form EIA-860.

the request to three years to minimize burden. gg. EPA provided additional clarification in this que

labor, materials, transportation, and energy. hh. EPA deleted Table B-10 from Part B; however, 

changes to the appropriate drop down boxes and/or 

the end of Part B: - EPA added “Soda ash” to the list of sorbent ty

- EPA changed “TMT-15” to “Organosulfide”; - EPA added an option for “spray/tray”; and - EPA added the list of FGD materials of constr

B4-3 (based on 2nd FRN version numbering). 

EPA disagrees that the standard types of FGD systdefined; therefore, EPA did not define mechanical

ii. EPA acknowledges that the information collecte

collected in Form EIA-860; however, EPA is using if the plant has to complete the remainder of Part B. 

asks requests information for planned FGD systems 

captured by Form EIA-860. 

Part C/Ash Handlinga. The conversion to dry handling could greatly increase the costs for dust suppression activities on the site yet there is no mention of this in the survey. b. Commenters believe that the 5 year period of time for requested for Part C is not necessary to gain an understanding of fly ash and bottom ash solids disposal and resale and recommends using a 3 year period of time to minimize the ICR burden. c. Commenters believe that Part C is not well laid out for a facility that handles both bottom ash and fly ash dry, but combines all the ash in a silo for storage 

a. EPA has revised the cost sections in Part C, whic

for dust suppression activities (e.g., around silos in occurs, and that associated with landfilling, etc.). b. EPA revised the instructions to request informati

2007, and 2009) instead of 2005-2009. c. To address the possibility of plants that combine silo, EPA has added a new section to Part C for com
Page 23 of 39 Ver

Comment Response prior to beneficial reuse and that EPA should consider, for each portion of Part C, how such a facility would respond to the question. d. Commenters suggested that Table C-1 be modified in several ways including adding the definition of “average” amount of dry fly ash, and specifying that information is for the year 2009. Commenters also believe that loss on ignition is not relevant to the effluent guidelines rulemaking and that determining the percent of fly ash handled as dry or wet will be difficult to determine for a plant that operates both systems. Also commenters requested the clarification of the ton basis in Tables C-1, C-6, C-13, and C-14 to indicate dry tons of ash. e. Commenters noted that Q. C1-4 and C1-5 do not take into account any changes or retrofits from one type of dry ash handling system to another type of dry ash handling system and ask how the reasons for fly ash and bottom ash handling system retrofits are relevant to the rulemaking. f. Commenters believe that Q. C1-5, C1-6, C1-24, C1-27 and 2-5 are very openended and will produce inconsistent answers. Commenters stated that there are many types of changes that could be discussed under this question, including physical changes to the facility, changes in personnel, changes in training, changes in ash disposal practices, changes in ash marketing practices. In addition, commenters noted that current personnel may not be aware of why certain actions/retrofits occurred, and there may not be any documentation available to answer this question. g. Commenters noted that Table C-2 in Q. C1-9 asks for percent moisture of fly ash, but does not segregate the question for ash wastes that are moistureconditioned prior to final disposal. Commenters also believe that the tons of fly ash transported to a silo at a plant that also sluices fly ash will be difficult to determine, since this value is not calculated/measured/recorded. h. Commenters indicated that Q. C1-11, Q. C1-13, Q. C3-3, and Q.C4-3 refer to process wastewater/treatment codes in Table X-X, which is not present in the draft questionnaire. i. Commenters believe that potential changes in revenue streams from beneficial uses as a result of changes to ash handling and air emissions regulations must be accounted for in the compliance cost model and that more restrictive state regulations on beneficial use of ash products need to be considered in development of a national compliance cost model. 

ash handling. d. EPA replaced the term “average” with “typical” a

and specified where data should be provided for the 

loss on ignition of fly ash in Table C-1 to determine ash for EPA’s cost analysis. EPA recognizes that pr

ash handling percentage information may be more d

not keep track of this information. Therefore, they estimates, which is explained in the front matter of tEPA revised the tables and other questions throughotonnage on a dry basis where appropriate. e. EPA would use the information to assess/predict may convert to dry ash handling, apart from a potenAdditionally, EPA would use this question to assess converting to dry ash handling and how this might aThis information will be considered when evaluatinof such options. EPA modified these questions and to account for dry fly ash handling systems that wer

EPA made the same changes to the bottom ash secti f. EPA added response options to the questions to oAdditionally, the questions were expanded to encom

handling system, including components associated w

EPA recognizes that providing this information may 

plants that do not keep track of this information. Thplants to provide information to the best of their abiuncertainties in the Comments page. g. EPA revised Table C-2 by changing the column hMoisture of the Fly Ash Entering Destination.”EPA this information may be more difficult for plants tha

information. Therefore, they should provide their b

explained in the front matter of the questionnaire. h. EPA included the process codes in the dropdown version of the questionnaire. EPA also added a “Coof each part to refer to. i. EPA is aware that such changes may affect benefi
Page 24 of 39 Ver

Comment Response j. Q. C1-13 and Q. C1-14 relate to water usage in fly ash which is sold in order to evaluate water reuse opportunities. Commenters noted that water may also be used with fly ash that is not sold, and is a potential reuse option. Commenters also asked why data on chlorides or solids in the water used for moistening fly ash is being requested and recommend that EPA ask specifically about operational criteria – i.e., “Identify any other operational criteria that the source water must meet.” k. Commenters believe that Q. C1-16 and Q. C2-28 are likely to produce inconsistent answers because EPA does not specify what should be included in “total costs” and asked whether costs associated with constructing a landfill and dry handling systems, adjustments to the facility air permit or labor costs should be included. l. Commenters noted that there is no information available for fly ash quantities related to individual electrostatic precipitators..Also, commenters suggested that the instructions for Q. C1-18 refer to “dry to wet” instead of “wet to dry junctions” and clarify how the distance from the dry-to-wet junctions and the ash ponds or other final destination should be measured particularly if multiple ponds were used. Commenters noted that in Table C-5 Column 3’s heading should be “Number of Dry-to-Wet Mixing Junctions” and needs the phrase “ junctions” added in the second row. m. Commenters believe that Q. C1-21 is very open-ended and will produce inconsistent responses. n. Commenters believe that systems that are “planned” should be limited to systems that are planned to be installed by the end of 2012. o. Commenters believe that in Q. C1-26 and Table C-6 the term “Wet Fly Ash” is potentially misleading and recommend changing the wording from “Wet Fly Ash” to “Fly Ash Moved by Wet Handling” and that a similar change should be made in the bottom ash section. p. Commenters believe that the requirement to include bid proposals in Q. C1-27 is unnecessary because bid proposals may have little relation to actual cost estimates for an entire project and can reflect many pricing issues that are not objective, such as the business relationship between the site and the bidder. Commenters also believe that bids do not reflect true costs of the 

assessing the impact. j. EPA revised the skip patterns to require all plants ash handling section to complete Q. C1-13 and Q. Cmarket the ash. EPA is requesting information chlowater used for moistening fly ash in order to evaluaopportunities. If the plantdoes not measure chloride

can respond in the "Other" space provided. EPA did not modify the question to ask only about 

k. EPA deleted Q. C1-16 and C2-28 and revised the include separate sections for fly ash conveyance, intransport/disposal. l. EPA deleted the request for “Number of Hopper T

question C1-18 and EPA replaced any references in 

with “dry to wet.” Additionally, EPA specified in t

question that the distance to the ash pond(s) is the d

sluice pipe at the furthest ash pond (if multiple pond“junctions” to the second row of column 3 in Table m. EPA phrased Q. C1-21 in this manner to provide necessary to provide the information requested. n. EPA revised questions throughout the questionna

provide information on “planned” units/systems thaconstruction/installation by Dec 31, 2020. Power pl

changes to equipment in recent years and are expectsignificant changes in the near future. EPA is collecallow the Agency to reasonably predict the costs anwith revisions to the ELGs. o. EPA revised Q. C1-26 and Table C-6 by replacin

with “Fly Ash Transported by Wet Sluicing” and m

bottom ash section. p. EPA recognizes the limitations of system/cost infproposals/engineering reports; however they may pr

to fill data gaps, particularly for previously planned systems, and as general verification of other ash hanobtained. Additionally, EPA provided clarification 
Page 25 of 39 Ver

Comment Response installation/construction and that EPA should not request the submittal of bid information for any purpose. q. Commenters believe that the O&M and capital cost categories are too specific in Tables C-7 and C-8. Commenters recommended specifying the types of O&M and indirect and direct capital costs to be considered in the description for clarification and requesting only the total O&M cost and total capital costs in order to reduce the burden of the ICR. Also, commenters stated that O&M costs are not tracked by individual systems, such as the fly ash handling system but instead, generally compiled for all CCB systems (bottom ash, fly ash, scrubber solids, etc.) together and therefore, commenters believe that industry accounting systems make this table (and all the similar tables) very difficult and time consuming to prepare. r. Commenters noted that Q. C1-27 and Q. C2-27 request capital costs, but do not request information related to design ash generation rates (only actual 2009 rates) and recommended adding a question to request the design ash handling rate, so that capital costs can be adjusted if actual generation rates differ from design. s. Commenters believe that asking how fly ash handling system components are used between multiple generating units is open-ended and likely to produce inconsistent answers and that EPA should specify what it means by “O&M or capital cost overlap.” t. Commenters noted that there should be some information in the instructions in Section 2 telling respondents which question to skip to if there are no dry bottom ash collection systems and requested the addition of a question asking if the plant has a dry bottom ash handling system. u. Commenters stated that bottom ash produced is not a measured value but is instead calculated based on plant and coal characteristics and that EPA should remove the “check” in the box for “both” in column 3, row 2. v. Commenters believe that Q. C1-3 and Q. C2-2 are very open-ended and will likely produce inconsistent answers. w. Commenters asked how the distance should be calculated when multiple parties or locations received bottom ash in 2009. x. Commenters stated that EPA needs to define “solid wastes” for purposes of 

proposals/engineering reports CBI, if applicable. q. The O&M and capital cost breakouts will allow Ecompare costs for ash handling systems in the indus

provide information to the best of their ability, provnecessary. Estimated responses should be noted in Also, Obtaining separate O&M costs for fly ash and 

systems (and separate from other CCB systems) wilanalysis. EPA expects plants to provide these data using estimates as necessary. r. EPA added questions requesting the design ash haand fly ash handling system sections. s. EPA changed the questionnaire sections to reques

systems rather than on the electric generating unit l

minimize instances of reporting “overlap.” Overlap one system shares common components (e.g., intermaddition, EPA requested systems to be defined for cversus transport and disposal, and added more descrdefine systems to avoid this reporting “overlap.” t. EPA modified the subsection instructions to indicshould only be filled out for dry bottom ash handlinu. EPA expects plants to provide accurate data to thproviding estimated data as necessary. EPA revised of the comment is no longer relevant. v. EPA expanded these questions into multiple quesspecifically why the fly/bottom ash is sluiced and wcapability to handle all fly/bottom ash dry. w. EPA revised Table C-10 to provide long drop-domultiple options for each of the types of destinationrow in the table). x. EPA replaced the term “solid waste” with “bottom the term “solid waste” is not defined in the glossary 
Page 26 of 39 Ver

Comment Response this Table C-13. y. Commenters believe that Q. C2-20 through Q. C2-27 should clarify if the Agency is referring to wet handling, wet disposal, or both. Subsequent questions should be structured to address the desired scenarios. z. Commenters suggested that the cost of any modifications required to install dry bottom ash handling systems be requested as part of Q. C2-22. aa. Commenters stated that segregation of the ash types requested in sections 3 and 4 varies from plant to plant and on a unit by unit basis and believe that it may not be possible to provide all of the information, such as that requested in question C3-2.bb. Commenters stated that one option EPA is considering is to establish federal non-hazardous waste regulations for CCBs pursuant to RCRA Subtitle D and that such a regulation would impose requirements for the landfilling of coal ash and other CCBs, such as possible requirements for landfill liners, leachate collection systems, and possible phase-out and closure of CCB surface impoundments. Commenters believe that if EPA finalized the rule using this option, significant portions of the Questionnaire would be rendered largely obsolete or irrelevant including the much of Part C. Commenters also believe that if EPA proceeds with the Subtitle C option, even more of Part C would become irrelevant for purposes of the effluent guidelines rulemaking. cc. Commenters stated that the typical technologies for dry bottom ash conversions rely upon a long, water-filled rectangular trough at the base of a boiler, with a drag out chain and dry conveyor to remove the ash from the boiler building and while the space can usually be allocated for a new facility or unit, most existing boilers have no room for this equipment. Commenters indicated that the bases of many existing boilers are located in small sub-basements that are surrounded by massive amounts of steel and concrete that support the multistory boilers and to re-engineer the base of these boilers to provide room for a trough, drag-out chain and conveyor would require removing and relocating massive amounts of steel and concrete supports which is a major impediment to dry bottom ash retrofits at most existing facilities. Commenters noted that the questionnaire does not ask any questions about the feasibility of retrofitting bottom ash handling at such facilities and recommended that at a minimum, EPA should develop a set of questions about the following: (1) whether there is 

y. EPA defined the terms “wet bottom ash handling

handling” in the Part C instructions, clarified that Q

ash that is moved by wet sluicing. z. EPA requested the costs of modifications requirehandling systems in the bottom ash handling system aa. EPA did not revise the question, because EPA edata to the best of their ability, providing estimates EPA did add a question asking whether economizer handled together. If this is the case, the plant can ansection for economizer and air heater ash together. bb. EPA is not removing any questions in Part C, beinformation requested in this part is independently ioutcome of the CCB rule. cc. EPA added questions requesting the estimated lenecessary to perform a bottom ash retrofit and askin

necessary for a dry bottom ash retrofit. However, in

question requesting the space available below or aro

requested engineering diagrams to depict the configash handling conveyance system. 
Page 27 of 39 Ver

Comment Response available space for a possible bottom ash retrofit; (2) whether the boiler’s base is below grade; (3) the estimated length of the outage necessary to perform a bottom ash retrofit; and (4) a description of the equipment necessary to be installed for a dry bottom ash retrofit. Part D/ Pond/Impoundment Systems and Other Wastewater Treatment Operationsa. Commenters expressed their concern regarding the instructions and terms used in Part D. For example, respondents were confused on whether or not ponds/impoundments that perform treatment should be included as ponds/impoundments or wastewater treatment units. Commenters also expressed concerns about missing definitions for key terms throughout part D. These terms include things such as non-pond unit, “planned activity”, and pond/impoundment unit versus system. EPA should confirm that the responses to Part D are limited to CCB management units. b. Throughout Part D, questions regarding retired units should not be included if the pond/impoundment unit discharges wastewaters other than stormwater (e.g., leachate). c. Under the section on closed pond/impoundment units there is no mention of pond dewatering systems and the costs associated with installation and operation of those systems. These costs should be included in any compliance cost model. d. In Q. D1-1 and Table D-1, EPA does not define what it means by “retired” or “closed” pond/impoundment systems. These terms should be defined. e. Commenters suggested revising the last column heading of Table D-1 to read "Individual Ponds/Impoundments Included in the Pond/Impoundment System (identified in Table A-4)." f. It is unclear how to label ponds in Q. D1-1 and Q. D1-2. Clarify how ponds should be labeled. g and h. Q. D1-3 and Q. D1-5 are overly burdensome and will provide inconsistent answers. The reliability of study data varies, particularly as studies become dated and information about correct sampling and analysis techniques is developed. It is important to ensure that older, outdated studies are not relied on for purposes of this rulemaking. In addition, the ICR should inquire about concerns associated with the quality of the study data. EPA should request information only on full-scale studies conducted from January 2005 or 2007 to 

a. EPA has carefully reviewed and revised the instru

the type information that is being requested. For exa

ponds/impoundments that perform treatment should pond/impoundment system, unless part of a broader system. Clear definitions and examples were added and to the glossary to aid respondents in answering also provided guidance for requests of “planned actcomment. b. EPA kept all questions regarding retired units, begather information on trends in the life of pond systBMPs for closed or retired units, and to understand implement or close a pond/impoundment. c. EPA believes that Q. D3-21, which asks facilities process for ponds/impoundments (including requirecosts), captures any dewatering process associated wponds/impoundments. EPA clarified that the responcosts associated with the closure. d. EPA has set up Part D to allow all ponds to be re“active/inactive/operating,” “retired/closed,” or “plait is necessary to define these terms individually. Pin the most appropriate category. e. EPA incorporated these changes. f. EPA revised the example in the instructions to proclarification on how to label the pond designations. 

example diagrams (EPA_D-1 and D-2) to Part D fo

g and h. EPA revised these questions to request stud1995) to reduce burden. EPA also removed the deta
Page 28 of 39 Ver

Comment Response December 2009.. i. Does Section 2 include all wastewater ponds including non-ash or industrial wastewater-only ponds? j. Commenters stated that because specific instructions are provided and must be met for the Block Diagram requested in Q. D2-1, existing block diagrams will not meet these requirements, and block diagrams from planned WWTS will need to be more fully developed. In addition, diagrams are typically prepared by our environmental consultants when preparing permit applications. Therefore, none will contain data from 2009. As a result, subcontractors will be required to complete this activity. Also, final destinations required in the diagram should be general and average flow rates should be estimates in order to match Table D-3. k. Many of the flows requested are not currently monitored. Normally, the discharge flow is taken from reading pump curves on the intake. It is unlikely that the resulting “water balance” will actually balance because of the number of estimations involved. l. EPA needs to provide Table X-X. m. Table D-3 requests information on influent/effluent solids/sludge streams, but the column headings do not clearly identify these streams. Add a column stating whether the stream is influent or effluent, and clarify units for solid/sludge streams (tons/day of solids or gallons per day flow rate). n. Residence time and life of impoundment varies depending on the state of the unit, when it was last dredged, etc. Q. D3-1 alone may cause detailed surveys to be performed. EPA should define “residence time.” o. Many of these impoundments were designed and built over 30 years ago. Design information requested in D3-2 will be very difficult to find and may not exist at all. p. Q. D3-2, Q. D3-3, and Q. D3-4 should be revised because the maximum pond/impoundment depth for some facilities may include a requirement to maintain a certain minimum level of freeboard below the top of the embankment. q. Maximum current depth data requested in Q. D3-3 may not be available without taking field measurements from a boat! EPA should not require responders to generate new data specifically for this questionnaire 

studies. i. EPA stated in the instructions that Section 2 shoupond/impoundment system or wastewater treatment Tables D-1 and D-2. These tables are limited to syst

from ash or FGD operations. j. EPA did not remove the block diagram requireme

and necessary. EPA recognizes that the survey requwhat is used for permit requirements; however, the 

question is lessened by only requiring block diagraminterest, not all treatment systems. Additionally, due 

mail-out, 2009 data will be available. EPA also cla

block diagram checklist to explain that the destinati

and that codes should be used from the “Code Tablek. EPA recognizes that some flow rates requested m

Therefore, plants should provide their best estimatel. EPA included the process codes in the dropdown version of the questionnaire. EPA also added a “Co

of each part for reference. m. EPA revised this table by making it specific to in

a second table for effluent streams. In addition, EPA 

solid/sludge streams in tons per day or gallons per mn. EPA rephrased Q. D3-1 to ask for "residence tim

o. EPA is aware that it may be difficult to obtain de

that were built over 30 years ago, however, respondavailable data to respond to the questions. Responde

comments page to explain any estimates or assumpt

requested information. p. EPA added a specific request for freeboard heighfrom Part F of the questionnaire. EPA also providepond/impoundment diagram to show the depth and pond/impoundments. q. EPA clarified in Q. D3-3 that plants are not requi
Page 29 of 39 Ver

Comment Response r. The information requested in Q. D3-6 should be limited to the last three years. Requiring information beyond the last three years is overly burdensome, will needlessly increase the time necessary to respond to this question, and is unlikely to provide information that is more representative than information for the last three years. s. Q. D3-9, Q. D3-19, and Q. D3-21 are very open-ended questions that will produce inconsistent answers. t. Clarify what should be included and excluded when calculating costs in Q. D3-9. For example, should labor costs be included? u. Commenters suggests that the check boxes should include a “none or N/A” choice for Q. D3-10. In addition, commenters suggest rewording the question to state "using techniques other than solely settling" for clarification. v. In Q. D3-12 and Q. D4-10, it may be necessary to provide chemical dosages as yearly estimates. In addition, the questions request concentration of treatment chemicals in the treatment unit in g/L, as well as the addition rate in gpm. For a lot of chemicals, such as liquid polymer or ferric chloride, the plant will know gpd fed and ppm by volume. g/L may apply to a dry feed system such as lime. Clarify to give the option for solid chemicals to use g/L, or for liquid reagents to report in gph. w. Commenters expressed concern with Q. D3-13 through Q. D3-15 stating that the request for all closed units is extremely broad. Information for closed units may not be readily available. The request should be limited to units closed within the last 3 years. The request should also exclude units for which the solids where removed (e.g., “clean” closed) prior to closure and for units that were replaced in-kind. Commenters also feel that EPA does need the original dimensions of a closed pond. It was also stated that Q. D3-15 should be revised to require the maximum depth based on the final elevation of the waste within the pond or impoundment, not the height of the berm because the final elevation constitutes the final maximum depth. EPA should also request the quantity of solids that went into the pond over the life of the pond/impoundment. x. In Q. D3-20, why does EPA need the closure plan, if any, for a closed pond? This is excessive, especially since EPA asks in the next question for a summary of the steps of closure and closure costs. 

measurements to provide this data; however, best avbe used to answer this question. r. EPA already had limited the bulk of this question 

volume dredged) to the last five years. EPA does nolimit the request for the year of last dredging, freque

and amount of material removed that year to the las

ponds/impoundments (perhaps many or even most p

not been dredged within the last three years. s. EPA phrased these questions in this manner to prneeded to provide the information requested. t. EPA revised Q. D3-9 instructions to clarify the cou. EPA added a "NA" response option to accommodhave "techniques other than settling." EPA also rev“solely settling (e.g., adding chemicals to remove cev. EPA clarified in Q. D3-12 and Q. D4-10 that plan

chemical dosage response in gpd and, if necessary, total yearly chemical dosage by the number of days EPA also revised the "Average Addition Rate" colu

and pounds per day options. w. EPA revised Q. D3-13 through D3-15 to limit th

information regarding closed pond/impoundment un

lessen the burden on the industry and still receive thfor the rulemaking. EPA revised Q. D3-15 to reques

unit's volume, surface area, bottom and top elevatio

maximum height of berms and dams above the surr

total quantity of solids placed in the pond/impoundmbuilt and at its end of life. EPA also added the reque

that went to the pond over the life of the pond. x. EPA requests the closing plan and associated costhe option of converting wet ash handling systems tD3-21 to explain that if the plants have provided a cthe closure process, the required steps, and the total associated with the closure, that they do not need to 
Page 30 of 39 Ver

Comment Response y. Q. D3-21 as currently worded is very broad and likely will result in the gathering and provision of information that does not aid in the potential rulemaking process. z. Are UICs considered wastewater treatment systems for purposes of Section 4? aa. Design, average 2009, and maximum 2009 flow rates are requested. Recommend adding average and maximum period for consistent responses (i.e., annual average, maximum daily flow). bb. Q. D4-3 should be deleted from the Questionnaire. Respondents should not be required to provide bid proposals for wastewater treatment systems. Bid proposals are not reliable information, as they are merely estimates of anticipated costs. Also, bid proposals may be influenced by the working relationships between the parties. Bid proposals also do not normally include the balance of ancillary equipment or installations, such as interconnecting pipes and controls. EPA should focus instead on actual installed systems. Best estimates for total capital and O&M costs would be more appropriate requests, yield better quality information, and less burdensome. cc. Commenters stated that since EPA requires submittal of the current NPDES permit and several system diagrams, EPA should refer to the permit and the diagrams for the effluent limitations applicable to the wastewater treatment unit and its discharge, instead of asking Q. D4-7. dd. Replace column heading “2006 Annual Cost” with “2009 Annual Cost” in Table D-10. ee. In Q. D5-1/Table D-10, EPA does not provide instructions for determining what rate per kilowatt hour to use for power for pumping and power for operations other than pumping. Also, the individual O&M categories identified in Table D-10 are too specific. EPA should generalize these costs and allow respondents to provide the total O&M costs for the questionnaire. ff. Q. D5-2 requests capital costs for wastewater treatment systems. In many cases these systems may have been installed 25 to 50 years ago. Collecting records of capital costs from that long ago could be extremely burdensome. Also, The individual capital costs identified in Table D-11 are too specific. We recommend specifying the types of direct and indirect capital costs to be considered in the description for clarification and requesting only the total capital 

y. EPA phrased these questions in this manner to pr

needed to provide the information requested. z. For the purpose of the questionnaire, UICs are NO

they are considered disposal. aa. EPA revised this question to request maximum dmaximum daily flow (in gpd). bb. EPA recognizes the limitations of system/cost inproposals/engineering reports; however EPA did no

the bid proposals/engineering reports provide useful 

gaps, particularly for planned wastewater treatment cc. EPA is aware that certain wastewater treatment specified effluent limits for different pollutants; how

being requested to determine if there are certain pol

overall treatment system operation. This may not apermitted limitations. dd. EPA incorporated these changes. ee. EPA added an explanation to Table D-10 to clar

total kWh used for pumping (for the treatment syste

$/kWh for pumping costs. Similarly, for $/pound stthe total pounds of steam used (for the treatment syscost breakouts will allow EPA to most accurately cosystems in the industry. EPA expects plants to provof their ability, providing estimates if necessary. Esbe noted in the Comments page. ff. EPA revised Q. D5-1 and Q. D5-2, only request 

installed in the past 25 years. The capital cost breakmost accurately compare costs for treatment system

expects plants to provide information to the best of estimates if necessary. Estimated responses should page. 
Page 31 of 39 Ver

Comment Response cost and year on which the cost is based. Simplifying the request will minimize the time necessary to gather more specific information. Part E/Wastes from Cleaning Metal Processing Equipmenta. Revise Q. E1-1 and E1-2 to request information on generation of wastes since 2007 instead of 2000. b. Facilities that ship all metal cleaning wastes to off site treatment or disposal should be exempt from answering Part E. c. Clarify definitions of the terms “episode” and “residues.” d. Revise Q. E1-2 instructions: “an” should be “on.” e. One commenter suggested that Table E-1 should be split into two separate tables, one for cleanings using chemicals and one for cleanings without chemicals. Many commenters also requested that the seventh column in Table E1 be modified to allow reporting of volume by cleaning event instead of annually and the eighth column be revised to request the frequency of cleaning events. f. Q. E1-3 is a very open-ended question and it will result in inconsistent answers. g. Q. E1-4 should include evaporation as a response option.h. Q. E1-8 asks for a waste determination status that may not be known until the wastes are generated and sampled. The results of the testing may determine whether the wastes are hazardous or non-hazardous. 

a. EPA has revised this question to request informatcleaning event for each cleaning operation with chechemical addition on metal process equipment that 1, 2000. EPA is aware that some cleaning operation

and does not want to risk mischaracterizing the indu

generation by limiting the duration of the question. b. EPA does not agree to exempt facilities that ship answering the questionnaire. EPA has already limitquestionnaire to a statistical subset and therefore reqfrom all respondents in order to characterize nationac. EPA replaced the term “episode” with “cleaning 

in the instructions of Q. E1-2. EPA also defined the 

questionnaire glossary. d. EPA incorporated these changes. e. EPA incorporated these changes. f. EPA recognizes that close-ended questions are prorder to provide plants the flexibility necessary to p

requested, EPA has retained the format for this ques

g. EPA incorporated these changes. h. EPA has revised this question to provide a more t

require sampling data. 

Part F/Management Practices for Ponds/Impoundments and Landfillsa. Revise Section 1 to also apply to oil. b. Are ponds/impoundments that perform treatment included in Section 1 and 3? c. In Q. F1-5, “storms in close succession” should be defined. The Agency could get many varied responses unless some definition of size, frequency, and/or duration is not requested. Also, EPA should define what it means by a “design 

a. EPA did not revise Section 1 to also apply to oil iand because the combustion of oil is not the focus o

b. EPA reworded the instructions of Section 1 and 3 “pond/impoundment units or landfills used for the sdisposal of residuals or by-products...." 
Page 32 of 39 Ver

Comment Response storm.” d. Commenters stated that ponds and impoundments typically do not have leachate collection systems. However, units with single and double liners may have a leak detection system from which water can be removed and treated. Commenters also requested that EPA define the terms “leak detection system” and “leachate collection system” in order for respondents to give an accurate reply. e. Q. F1-8 and Q. F2-9 assumes plants have monitoring controls to determine the number of days leachate is collected, however all plants may not have monitoring controls. Add a sub-question regarding estimate method (e.g., pumping logs, flow meters, and engineering judgment). f. Q. F1-12 through Q. F1-15 are redundant with the USEPA Ash Management Unit Survey questions and Q. F3-3 is redundant with the April 2009 question from the House Committee on Transportation and Infrastructure's Subcommittee on Water Resources and Environment. g. The fourth question in Q. F1-9, Q. F2-10, and Q. F2-15 requests the treatment system ID from Table A-4, but Table A-4 is intended to list pond/impoundment areas, not treatment systems. Correct the table reference. h. Q. F1-10, Q. F2-12, and Q. F2-16 do not specify how much leachate is recycled back in the plant. For leachate recycled back into the plant, request an estimate of the amount reused (as a percent of total).i. Many commenters expressed concern about the request for the cost of corrective actions, cost of inspection, and qualifications of the inspector in Table F-1. Commenters stated that the cost of corrective actions will already be included in the total O&M costs for each unit, that it will be difficult to estimate the cost without conducting engineering studies, and that the table requires further clarification of what should be included and excluded when calculating the cost. Commenters also stated that the request for the qualifications of the inspector goes beyond the scope of the questionnaire and that most inspectors do not have construction experience. Additionally, it was requested that a footnote be added to the “cost of inspection” column to require the respondent to indicate if the inspection was self-performed. j. Q. F2-1 should be rephrased. Not all landfills are “licensed,” in the sense that 

c. EPA revised Q. F1-5 to ask if the pond/impoundm

experienced an overflow, excluding routine permittnew question to ask if such overflow was discharge

d. EPA revised the definition of the term “leachate” 

seepage, leachate collection, and leak detection sour

terms "leak detection system" and "leachate collectiof the questionnaire. e. EPA clarified that the plants should provide a des

method in the “Part F Comments” tab at the end of 

f. EPA has generally retained Q. F1-12, Q. F1-13, a

However, EPA deleted Q. F1-14 and removed the "

Inspector" and “Findings of Inspection” columns in 

EPA did not remove Q. F3-3 because it does not reqmonitoring data; therefore, the question does not coburden. g. EPA revised the question to refer to Table D-2 inh. EPA did not incorporate these changes because th

absolutely necessary to evaluate option for the ELG may be overly burdensome. i. In Table F-1, EPA did not remove the “cost of cor

because the questionnaire only requests the total O&

However, EPA provided additional clarification of w

the cost of corrective actions (e.g., labor costs)., EP

providing this information may be more difficult wi

engineering studies for those corrective actions that and in these instances plants should provide their be

necessary comments in the Comments tab. Enginee

necessary for those corrective actions which have alIn addition, EPA removed the “qualifications of instable, as noted above. However, EPA did not add a “Company/Consultant Name” column to “Affiliatiothe respondent specify if the inspector was a plant/cconsultant. Additionally, EPA revised the instructio

estimating the cost for on site or company personne
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Comment Response the state provides an official license. In some states, while the state reviews and approves design plans, it does not issue a license. k. In Q. F2-5 clarify what should be included and excluded when calculating costs. l. In Q. F2-5, include the date of the expansion, specify what dimensions are required, and request information on future plans to expand. m. In Q. F2-12 further define the term “discharged” to clarify if this is means through a NPDES permitted outfall. n. In Q. F2-14 “Conveyance for stormwater run-off from the landfill” suggests all stormwater has contacted active surfaces of the landfill and does not distinguish between stormwater from capped areas of the landfill versus runoff from non-capped areas. Clarify that this is water that does not contact solids (assumes any water contacting an uncovered, working face would become leachate). o. EPA’s instructions for Section 2refer to on site landfills previously defined in Table A-6. Table A-6 includes operating/active, retired/closed, and planned landfills. Section 2 questions seem to be directed toward operating/active landfills. Landfill characteristics/design for planned landfills may not be available or may change prior to construction. p. The checkbox for “No” in Q. F3-1 needs a (Skip to End of Section F) instruction. q. Q. F3-3 could be interpreted differently depending on the definition of pollutant (e.g., is calcium a pollutant), and background (e.g. a well upgradient of the landfill / pond or a regional background computed as in a RCRA study). Clarify the terms "pollutants" and "background". r. Commenters expressed concern about the relevancy of section 3 and requested the removal of these questions. Commenters also requested that the section be applicable to pond/impoundment systems, wastewater treatment systems, and landfills rather than specific pond/impoundment units and that EPA should specify if Q. F3-3 is focused on ash related constituents and/or on agricultural related compounds. 

based on their labor costs and time involved. j. EPA replaced the term “licensed volume” with “ain Q. F2-1. k. EPA clarified that the costs requested in Q. F2-5 materials, and energy costs. In addition, EPA also scapital costs should be listed separately from the geexpansion. l. EPA clarified that the dimensions refer to surface materials, and height and added a request to provide 

However, EPA did not find it necessary to include a 

expansions. m. EPA reworded the response options throughout tof discharge, either to a POTW or discharged direct

outfall number). n. In revising the questionnaire, EPA has differentia

uncapped portions of the landfill. o. EPA revised the instructions throughout Part F to complete this part for all active/inactive/open and repond/impoundment units and landfills. p. EPA added “Continue to Question F3-2” next to and added “Skip to next Questionnaire Part” next to q. In Q. F3-3 EPA clarified the term “pollutant” for by referring to a list of analytes in Part G. EPA defconcentration” for the purpose of the ICR in the glo

r. EPA did not remove Section 3, because the grouninformation is requested to evaluate the industry-wigroundwater monitoring practices and to help evalucontaminating surface waters. However, EPA clari

to pollutant concentrations from ash and FGD relateSection 3 to request the information on a pond syste

D-1, D-2, or A-6). 
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Comment Response Part G/Leachate Sampling Data for Ponds/Impoundments and Landfillsa. Include analyses of TSS, sulfates, dissolved metals, and dissolved mercury. b. Leachate streams from landfills are already regulated through state solid waste laws in most jurisdictions. Therefore, further regulation of leachate from coal combustion landfills may not be necessary, and EPA shouldn’t prejudge the issue. c. Many commenters stated that it does not make sense to ask for leachate data from a pond or impoundment, because ponds/impoundments typically do not have leachate collection systems. However, units with single and double liners may have leak detection systems from which water can be removed and treated and therefore, it is unclear if the intent of this request includes water collected from leak detection systems. Additionally, commenters requested definitions for the terms “leachate,” “runoff,” “untreated,” “treated,” and “detection limit.” d. If the respondent answers “no” to Q. G1-2, there should be an instruction to skip to Q. G1-5. e. Multiple commenters stated that many of the facilities will not be able to accomplish the leachate sample collection in the required amount of time, because some facilities do not regularly generate leachate weekly and there are a limited number of labs that are certified to collect and analyze the samples by low-level methods (e.g., Method 1631E). Therefore, every facility chosen for the sample collection will need to have their collection and analysis completed at the same time, which could prove to be impossible during a short window of time. f. Facilities that collect and dispose of leachate off site (i.e., not discharged) should be exempt from the sampling requirement, as the information collected likely would not be representative of typical leachate discharges. g. Clarify if pond/impoundments that perform treatment are included in this part. h. The costs for collecting and analyzing eight samples of leachate (treated and untreated) per treatment unit will be significant. One commenter estimated that the costs for collection and laboratory analysis per sample are in the range of $1,000 to $1,500. Therefore, the costs will be especially high for facilities that will be required to collect both untreated and treated samples. In addition, the burden will be very large for small facilities that are frequently on very tight budgets. 

a. EPA added analyses of TSS and sulfates; howevedissolved metals and dissolved mercury, because of (including cost) associated with the sample collectiob. EPA has not prejudged this issue, but requires adif revisions to the ELGs are necessary for leachate dc. EPA defined the term “leachate” in the questionnleakage, leak, seepage, leachate collection, and leak also defined the terms “treated” and “detection limiglossary and clarified the difference between untreathe leachate sample collection instructions. d. EPA has now included skip instructions for this qe. EPA revised the instructions of the leachate samp

leachate samples every week for four weeks or as so

leachate is available for collection, therefore collectweeks may not happen in all cases. Laboratory avaibe a problem because of the small number of sampland analyzed, relative to the number of samples labnationwide from a variety of facilities, even when canalytical methods required by the ICR. The holdin1631E is 90 days; therefore, samples will not need tupon collection. This will allow labs ample time to samples in order to handle the required analyses witprovided. f. Even those plants that send leachate off-site are redata for untreated leachate because the data will be 

raw wastewater and evaluate treatment technology fHowever, EPA has revised the instructions to clarif

and dispose of leachate off site are not required to ptreated leachate; only facilities that treat leachate on provide treated data. g. EPA clarified in the instructions that pond/impoutreatment are included in this part. 
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Comment Response i. EPA should develop a screener questionnaire that would allow EPA to investigate all potential analytical issues with the leachate matrices and determine whether any further existing data or sampling would be beneficial for characterizing leachate discharges. j. EPA should consider allowing the submittal of historic leachate data, if available, instead of requiring four new and additional weekly leachate sample results. k. Many commenters expressed concern that EPA’s instructions for sampling are not clear. EPA does not specify where to sample for untreated or treated leachate, and therefore the resulting data will be inconsistent. l. Depending on the characteristics of the leachate samples, Method 200.8 may be an inappropriate choice for some metals. It has been demonstrated that Method 200.8 can produce erroneous results for some metals in certain matrices due to polyatomic interferences. These interferences can result in erroneous analytical results. m. EPA should require rainfall information (in inches per day) for 30 days prior to the first leachate sampling, and also during the entire sampling period. n. Depending on the configuration of the leachate collection system, sampling may be difficult due to confined space entry issues (i.e., in manholes). There may be significant safety concerns at some facilities due to this sampling requirement. o. Q. G1-6 is duplicative of Tables A-5 and A-7. The respondent already identifies types of wastes in each management unit on those tables. EPA should refer to those answers and not ask for the same information twice. In addition, EPA should clarify that the amount of waste requested in Q. G1-6 applies to the uncapped portion of landfill that contributes to leachate. 

h.. EPA estimated in the supporting statement that t

leachate sample at one sample location (taking into 

supply costs, and sample collection labor) would co

significantly higher than each of the commenters’ e

whether a plant has a pond, a landfill, or both, EPA from 4 to 16 sample points at a plant. Therefore, EP

burden associated with this sampling effort. Howev

small entities, EPA has excluded them from the subselected to respond to Parts E, F, and G (and thus is 

sampling). i. EPA does not agree that a screener questionnaire 

of investigating analytical issues for leachate. j. EPA revised the leachate sample collection instruprovide existing data in lieu of collecting new data i

the specific requirements articulated in Part G. k. EPA revised the leachate sample collection instruplant should collect samples from each leachate col

pond/impoundment and landfill. If the plant determor more collection points are representative of an inpond/impoundment or landfill, then the plant may srepresentative sample(s) instead of sampling each c

l. Method 200.8 is an EPA-approved method and th

effluent limitations. It remains the required analytic

analytes; however, EPA has added flexibility for altcertain parameters. m. EPA added a question requiring rainfall informa

and throughout the sampling period, because the amcharacterization and the amount of leachate generatn. EPA recognizes there could be safety issues assosampling; therefore, EPA revised the instructions of collection to allow the plant to request exemption frthrough the submittal of a written request within twquestionnaire. The submittal must explain why the 
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Comment Response 

the samples safely. o. EPA has revised the request, but still retains the rin each management unit because Part G requests thwaste, whereas Part A simply asks what type of wasaddition, EPA revised Q. G1-6 to request the plant tTable G-3 if the landfill is partially capped, one for the capped portion of the landfill and one for the amuncapped portion of the landfill. 

Part H/Nuclear Power Generationa. Several of the questions within Part H refer to “water streams,” while others refer to “wastewater streams.” Commenters believe these terms should be defined. b. Commenters believe Q. H1-2 is not necessary. The type of nuclear unit is not later correlated to specific waste streams. c. Commenters believe that the term “associated with the nuclear generating units” should be defined. They question whether this only includes streams directly associated with the nuclear reactor, or if it includes all streams associated with the generation of electricity. Additionally, they ask whether streams not associated with electricity generation should be included (potable water, sewage, fire protection, car washes, etc.)? d. Commenters believe the electronic version of the Questionnaire needs to allow for more than four entries on Table H-1 Also guidance should be provided for describing the “type of water stream.” Commenters are not certain whether this is meant to be a simple description using existing Effluent Guideline descriptions (low volume wastes, chemical cleaning wastes, etc.) or if each facility should develop unique descriptors. e. Commenters believe it would be problematic to answer Q. H2-1 for nonroutine, intermittent streams. Some of these waste streams may go years between discharge events. f. Commenters believe Q. H2-2 should include a response box for “discharged with treatment” and replace “All leachate discharged” to “All treated water discharged.” Additionally, the choices for destinations of treated water in Q. H2-3 include leachate and sluice water, both of which do not exist at nuclear 

a. EPA replaced the term “wastewater streams” and 

“process wastewater.” EPA added and defined the 

in the glossary of the questionnaire. b. EPA deleted Q. H1-2 from the questionnaire sincreceived from NRC. However, EPA does request ththe “Type of Boiler or Reactor” column in Table A-c. EPA has revised the wording to say “associated w

electricity from nuclear generating units” and expec

process wastewater associated with running the nucupdated the definition of “process wastewater” to en

including non-contact cooling water, sanitary waterwater, portable water, sewage, fire protection, or ca

d. The electronic version of the questionnaire allowrevised the table by including a drop down box with 

wastewater streams identified, including an "other" 

can define any additional streams not already identie. EPA revised Q. H2-1 to allow plants to provide dintermittent streams. f. EPA combined Q. H2-2 and H2-3 and revised the 

question so that they were applicable to nuclear plan

the use of the term “leachate.” 
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Comment Response facilities. EPA should modify this question to remove these response boxes. Part I/Economic and Financial Dataa. Several commenters noted the challenge of coordinating responses from plant’s having multiple owners, expressing concerns with both the limited time provided to complete the questionnaire and the utility of collecting detailed information from each owner. b. Commenters noted that certain terms used in the questionnaire refer to concepts that are not accurate legal descriptions of the plants’ ownership structures c. One commenter questioned the utility of asking for total revenue and total employment rather than focusing strictly on revenue or employment associated directly with electricity generation. d. Several commenters questioned the utility of asking for data on activities not directly related to electricity generation. e. Commenters noted that this information is not currently compiled under customary business practice and completing the questionnaire would therefore impose a significant burden on respondents. f. Commenters questioned the utility of asking for information about the overall operations of the ultimate parent rather than focusing only on electricity generation. g. Commenters asked for clarification of the activities included in “revenue generating activities other than generation of electricity.” h. Commenters also questioned the purpose of asking for other revenue in Question I1-30 and suggested deleting this row from the table. i. One commenter asked for clarifications on how variable O&M costs should be determined for the purpose of this questionnaire 

a. In response to the comments, EPA has clarified ththat it seeks detailed information (balance sheet, inc

from the owner that has the largest ownership share 

steam electric capacity at the plant. Only summary inumber of employees and identity of the ultimate paowners. This summary information is expected to b

be used to assess the potential for substantial econom

own or have another form of financial interest in ste

including in identifying entities that meet the definiRegarding the logistics of coordinating responses amEPA has designed the questionnaire to be modular a

be completed by different individuals, as needed, prEPA. b. EPA recognizes that plants can have types of own

differ from a partnership or joint venture. In responhas revised the instructions and the definitions provbroaden the concept of ownership to also include ot

participation or interest”. The simple term “plant owcomment is general and is captured by the concept odescribed in the revised questionnaire and glossary. c. The intent of this question is to help determine enSmall Business Administration (SBA) standards for the Regulatory Flexibility Act (RFA) and the Unfun(UMRA) if the immediate parent is also the ultimatasked at the immediate parent- as well as the ultimathe skip pattern for questions. For the purpose of sizneeds total revenue, employment, and electricity sal

those related to steam electric operations. EPA is as

employment associated with electricity generation fto allow the eventual assessment of the uncertainty compliance costs and other impacts only to immediequity share) and to support a cost-to-revenue analy
Page 38 of 39 Ver

Comment Response 

affected entities. d. The intent of this question is to determine the scothe immediate parent including those activities asidgeneration as well as the relative importance of theswith respect to profitability of the firm. EPA will ussupport the regulatory cost impact. Based on the comments, EPA has revised the questi(1) production activities that are electricity generatiof steam or ash, waste combustion (which depend dof electricity) and (2) production activities that are ndependent, such as leasing of land. EPA has also revspecify that, in this section, it is asking for informatof the immediate parent and not just those of the plaseparate questions. e. In response to these comments, EPA has modifiereduce respondent burden to the extent possible whito conduct analyses. The questions have been reviserequested, to specify that approximate shares are suthis data collection, and to explain that respondents contracts to determine the exact fraction of sales subconditions. EPA expects that respondents will alreaapproximate share of electricity sold under differenhave the exact statistics for each year. Additionally, the number of data items it is requesting by asking fcontract duration and terms for only the most recent While EPA does not expect that respondents will hareview of all contracts and their terms, the Agency hburden estimate to account for the potentially greateanswering this question. EPA has also clarified the basis for the shares requebased on physical quantities (MWh). f. EPA retained this question but explained the purpinformation in the instructions. 
Page 39 of 39 Ver

Comment Response 

The intent of this question is to help determine entitSmall Business Administration (SBA) standards for the Regulatory Flexibility ACT (RFA) and the UnfuAct (UMRA). For the purpose of size determination employment, and electricity sales, as opposed to onoperations. g. EPA has revised the question to specify that activparties and for which the plant incurs no cost and renot be included in the response. h. Regarding draft Question I1-30, because informais already asked for, EPA deleted the row from this i. EPA provided a description of variable O&M cos