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MEMORANDUM

TO: Steam Electric Rulemaking Record

FROM: Steve Strackbein, ERG

Ryan Novak, ERG

DATE: September 30, 2015

SUBJECT: Ash Transport Water Analytical Data Review Methodology Memorandum

(DCN SE05547)

1. INTRODUCTION/BACKGROUND

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

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

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

As part of this technical support, ERG performed a detailed review of ash transport water 

analytical data to identify acceptable data for use in identifying ash transport water pollutants of 

concern (POC) and calculating pollutant loadings for ash transport water discharges. This 

memorandum describes the data sources evaluated for ash transport water and the methodology 

ERG used to review each of the identified data sources. This memorandum supplements 

the Development Memorandum for the Steam Electric Analytical Database for the Final 

Rule [ERG, 2015a]. ERG developed the Steam Electric Analytical Database for the Final Rule 

[ERG, 2015b], which is a compilation of the analytical data compiled and analyzed for 

wastestreams evaluated as part of the final rule.

2. DATA SOURCES

ERG performed a detailed review of 14 sources of data containing information related to ash 

transport water. These data sources were compiled by EPA during the rulemaking, and include 

EPA detailed study sampling data, industry-supplied data, and data from publicly-available data 

sources, including data received during public comment. EPA collected some of these data from 

reports submitted by steam electric power plants as part of their responses to the Questionnaire 

for the Steam Electric Power Generating Effluent Guidelines (Steam Electric Survey). EPA 

received these data in a variety of different formats including, but not limited to, Microsoft Excel 

spreadsheets, Microsoft Access databases, analytical reports, and summary tables within 

published reports. The following subsections describe each data source and the type of data 

reviewed by ERG within each source.
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2.1 American Electric Power

As part of their Steam Electric Survey response, American Electric Power (AEP) provided a 

document titled Prediction of Effects of FGD Scrubber Wastes on Ash Pond Effluent at Six AEP 

Tier 2 Plants, Conesville Excerpt [AEP, 2006]. This document presents an evaluation of the 

effects of discharging flue gas desulfurization (FGD) scrubber chloride purge streams to the 

existing ash management impoundments at the Conesville plant (Conesville). Conesville is a 6-

unit 1925 MW coal and gas-fired plant. This document presents sample results from Conesville 

including two single fly ash bottom transport water samples, one sample representing four 

operating units and one sample representing two operating units. Additionally, this document 

presents average bottom ash transport water data for three operating units.

2.2 Dayton Power and Light Company

As part of their Steam Electric Survey response, Dayton Power and Light Company (Dayton) 

provided a document titled Review of Information on FGD Modifications for Killen and Stuart 

Generating Stations Dayton Power & Light Company [Dayton, 2007]. This document presents 

findings from a contractor review of a report on the addition of the new FGD equipment at two 

plants and the associated drawings and spreadsheets. This document presents monitoring data for 

one outfall at each of the plants. The two plants presented in this report are the Stuart Generating 

Station (Stuart), a 4-unit 2,390 MW capacity coal and oil-fired plant, and the Killen Generating 

Station, a 1-unit 600 MW capacity coal and oil-fired plant. Sampling data from Outfall 001 at the 

Killen Plant represents effluent from a combined ash impoundment and sampling data from 

Outfall 012 at the Stuart Plant data set represents bottom ash impoundment effluent.

2.3 Duke Energy

EPA received public comments on the proposed rule from Duke Energy, where the company 

submitted data for paired samples of simulated effluent bottom ash transport water1and source 

water from the Marshall Steam Station (Marshall) and the Belews Creek Steam Station (Belews 

Creek) [Duke, 2013]. EPA requested additional information to clarify the sample collection 

procedure, sample quality information, the selection criteria used by Duke Energy when 

sampling Belews Creek and Marshall, and to request bottom ash transport water data collected 

from any other Duke Energy plants. 

EPA ultimately requested and received sample collection and quality information from Duke 

Energy and used these data to interpret, validate, and evaluate the bottom ash transport water 

data collected at Belews Creek and Marshall against EPA’s acceptance criteria [Duke Energy, 

2014]. Duke Energy confirmed they collected bottom ash transport water data for their East 

Bend Station, Cliffside Steam Station, and Miami Fort Station and indicated that bottom ash 

samples from Cliffside Steam Station (Cliffside) and Cayuga Station were collected and 

 

1 The samples of the bottom ash transport water were collected from the discharge pipe prior to mixing or 

comingling with any other wastestream or other waters. In an attempt to simulate treatment from a surface water 

impoundment, these samples were allowed to settle for three hours or longer before collection of the supernatant for 

analysis.
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analyzed by UWAG. However, Duke Energy was only able to provide data for one split sample 

collected during the UWAG sampling episode at Cliffside. EPA ultimately received the 

additional information and reviewed the bottom ash transport water data for the five following 

plants:

1. Marshall, a 4-unit 2,200 MW capacity coal-fired station (paired source water and 

simulated bottom ash transport water data).

2. Belews Creek, a 2-unit 2,400 MW capacity coal-fired station (paired source water 

and simulated bottom ash transport water data).

3. Miami Fort Generating Station (Miami Fort), a 3-unit 1,180 MW capacity coalfired station (data claimed CBI) (paired source water and untreated bottom ash 

transport water; untreated bottom ash transport water not paired with source 

water).

4. East Bend Generating Station, a 1-unit 600MW capacity coal-fired station (paired 

source water and simulated bottom ash transport water data).

5. Cliffside Steam Station, a 5-unit 760 MW capacity coal and oil-fired station

(paired source water and untreated bottom ash transport water).

2.4 Electric Power Research Institute Reports

Electric Power Research Institute (EPRI) is a research-oriented trade association for the steam 

electric industry. EPRI conducts research funded by the steam electric industry and has 

extensively studied wastewater discharges from FGD systems and ash impoundments. EPA 

received technical reports from the trade association and as part of plant responses to the Steam 

Electric Survey.

The trade association provided EPA with the PISCES Water Characterization Field Study, Sites 

A-G reports that summarize the data collected during seven separate site visits to characterize 

wastewater at coal-fired power plants [EPRI, 1997-2001].

As part of its response to the Steam Electric Survey, one steam electric power plant submitted an 

EPRI study on wastewater discharges from FGD systems and ash impoundments at the plant. 

Mitigation of SCR-Ammonia Related Aqueous Effects in a Fly Ash Pond [EPRI, 2006] presents 

sampling data from a fly ash impoundment at American Electric Power’s (AEP) John E. Amos 

plant. The report was part of the John E. Amos plant’s response to the Steam Electric Survey.

EPA received public comments on the proposed rule from EPRI, which contained two reports 

containing ash-related analytical data. The Impact of Wet Flue Gas Desulfurization (FGD) 

Design and Operating Conditions on Selenium Speciation: 2009 Update [EPRI 2009a] presents 

fly ash sampling data from four plants and the Integrated Fly Ash Pond Management. A Field 

Study of Five Central United States Pond Systems presents data from a study of fly ash ponds at 

five operating coal-fired power plants.
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2.5 Holyoke

As part of their Steam Electric Survey response, Holyoke provided a document titled Mt. Tom 

Station Bottom Ash Transport Water Treatability Study [Holyoke, 2002]. This report presents the 

results of a feasibility study to determine if a gravity sedimentation process could reliably treat 

the bottom ash transport water at Mt. Tom Generating Station (Mt. Tom) to the limits required 

by the plant’s interim NPDES permit. Mt. Tom is a 1-unit 145MW capacity coal-fired plant. 

Data in Table 2-3 of the report include a wastewater characterization summary of bottom ash 

transport water resulting from the burning of domestic coal. Tables 2-4 and 2-5 present similar 

wastewater characterization summaries with different coal sources. Table 2-4 presents 

wastewater characterization of bottom ash transport water with Chinese coal and 2-5 presents the 

characterization using mixed coal with polymer.

2.6 Hoosier Energy

EPA received public comments on the proposed rule from Hoosier Energy Rural Electric 

Cooperative (Hoosier Energy), where Hoosier Energy provided fly ash impoundment effluent 

data and bottom ash impoundment effluent collected between September 2008 and December 

2009 at the Frank E. Ratts Generating Station for a Reasonable Potential to Exceed analysis of 

nine parameters for a permit renewal. Additionally, Hoosier Energy provided paired data on 29 

samples of fly ash impoundment effluent and 28 samples of bottom ash impoundment effluent 

collected for mercury analysis [Hoosier, 2013].

EPA requested that Hoosier Energy provide EPA with any fly ash and/or bottom ash 

impoundment effluent data collected since December 2009. In addition, EPA requested 

identification of the specific impoundments (using impoundment IDs reported in the Steam 

Electric Survey), impoundment dimensions, impoundment treatment operations, atypical 

operations that occurred, and identification of other wastestreams that enter the impoundment. 

EPA ultimately received and reviewed additional paired source water and fly ash impoundment 

effluent data and paired source water and bottom ash impoundment effluent data collected since 

2009 for possible inclusion in the ash loadings analysis [Hoosier, 2014].

2.7 Interstate Power and Light

As part of their Steam Electric Survey response, Interstate Power and Light (Interstate) provided 

a series of four documents representing four different plants. Descriptions of each of the 

documents submitted to EPA by Interstate are below:

1. The Options Analysis Report for Settling Pond Maintenance, Reconfiguration, 

and Upgrades Marshalltown, Iowa report summarizes a sampling event 

conducted at Southerland Generating Station (Southerland) to determine the 

source of an algae problem. The Southerland generating station is a 3-unit 135 

MW capacity coal-, gas-, and petroleum coke-fired plant. Samples were collected 

from all influent streams to the settling impoundments, within the impoundment 

(near outfall), and from the soil in and around the impoundment. [Interstate, 2005]
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2. The Ash Pond Study Report, Prairie Creek Generation Station Cedar Rapids, 

Iowa report presents the results from the field investigation activities, which 

include settling tests, laboratory physical analysis, and loss-on-ignition tests at the 

Prairie Creek Generating Station (Prairie Creek) in Cedar Rapids, Iowa. The 

Prairie Creek Generating Station is a 4-unit 208 MW capacity coal and gas-fired 

plant. Attachment A of the report presents analytical results from a controlled 

settling test of ash transport water conducted to evaluate total suspended solids 

and turbidity. [Interstate, 2010]

3. The Report for Interstate Power and Light Company – Dubuque Generating 

Station, Bottom Ash Wastewater Evaluation provides the results of evaluations 

conducted on the bottom ash wastewater generated at the Dubuque generating 

station (Dubuque) in Dubuque, IA. The Dubuque generating station is a single 

unit 81 MW capacity coal and gas-fired plant. Tables 2.03-1 and 2.03-2 of the 

report present paired source water data with ash impoundment sample data (27 

bottom ash samples) and east and west impoundment sample data (14 samples 

each), respectively. [Interstate, 2004]

4. The Coal Combustion Residue Reuse Exemption Request - Interstate Power & 

Light Company (an Alliant Energy Company) M.L. Kapp Generating Station, 

Clinton, Iowa document is a request for exemption from a limit imposed by the 

state of Iowa for the total weight of coal combustion residue. The M.L. Kapp 

Generating Station (M.L. Kapp) is a 2-unit 220 MW capacity coal-fired plant. 

Samples’ collection was from the main ash impoundment. The main ash 

impoundment consists of bottom ash and fly ash wastewaters. Attachment A to 

this document present the analytical data results for the samples collected from 

the main ash impoundment. [Interstate, 2002]

2.8 Minnesota Power

As part of their Steam Electric Survey response, Minnesota Power provided a document titled

Final Pilot Testing Report and Design Basis, Mercury Removal Project [Minnesota Power, 

2010]. This document is a summary of Minnesota Power Laskin Energy Center’s (Laskin) 

mercury treatability study that was provided to the Minnesota Pollution Control Agency and 

provides recommendations for full-scale design of a GE multimedia filtration technology. Laskin 

is a 2-unit 106 MW capacity coal-fired plant. Data in this report represent combined fly ash and 

bottom ash impoundment effluent from Laskin.

2.9 South Carolina Electric & Gas

As part of their Steam Electric Survey response, South Carolina Electric & Gas provided a 

document titled South Carolina Electric and Gas Canadys Station WWTP for Arsenic Treatment 

Canadys Station, South Carolina, Preliminary Engineering Report, Final Report, and Pilot 

Study Report [South Carolina Electric & Gas, 2007]. This document summarizes the efforts 
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taken by South Carolina Electric and Gas to comply with permit limits for the Canadys Station 

(Canadys) plant. Canadys is a 3-unit 400 MW capacity coal-, oil- and gas-fired plant. Data 

presented in the series of reports submitted to EPA includes ash impoundment influent sample 

data, ash impoundment effluent sample data, and sample data that was collected from the middle 

of the impoundment.

2.10 Southern Company

As part of their response to the Steam Electric Survey, Southern Company (Southern) provided a 

document titled The Selective Non-Catalytic Reduction Unit (SNCR) Study report, which presents 

the results of a study of selective non-catalytic reduction units at the Lansing Smith plant 

[Southern, 2009]. The Lansing Smith plant is a 3-unit 840 MW capacity coal-, gas-, and oil-fired 

plant. Sampling data from the time of the study includes intake water, ash transport water, ash 

impoundment, and discharge canal.

2.11 EPA Detailed Study Ash Pond Sampling Data

As part of the detailed study conducted prior to beginning the rulemaking process, EPA 

conducted a sampling program to characterize untreated wastewaters generated by coal-fired 

steam electric power plants, as well as to evaluate treatment technologies and best management 

practices for reducing pollutant discharges.

Between July 2007 and October 2008, EPA collected and analyzed samples to characterize 

wastewater streams at six coal-fired steam electric power plants. EPA analyzed the samples for 

total metals (including 25 specific metals), hexavalent chromium, nitrogen compounds, and other 

classical analytes. Specifically, EPA characterized wastewater streams associated with wet FGD 

systems and ash handling operations and evaluated the capability of various types of treatment 

systems to remove metals and other pollutants of concern prior to discharge.

During the sampling program, EPA identified that four plants operated some type of wet ash 

handling system, either wet bottom ash or wet fly ash handling, or both. EPA collected samples 

representing two impoundments receiving fly ash transport water; one impoundment receiving 

bottom ash transport water, and one impoundment receiving combined fly ash and bottom ash 

transport water [U.S. EPA, 2009]. The categorization of impoundments at the four plants was as 

follows:

 Cardinal – Fly ash impoundment;

 Homer City – Bottom ash impoundment;

 Mitchell – Fly ash impoundment; and

 Widows Creek – Combined ash impoundment.

2.12 EPA Technical Development Documents

Two documents prepared by EPA during previous rulemakings for the Steam Electric Category 

have provided useful information for the current rulemaking. These documents are the 1974 

Development Document for Effluent Limitations Guidelines and New Source Performance 
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Standards for the Steam Electric Power Generating Point Source Category (referred to in this 

report as “the 1974 Development Document”) [U.S. EPA, 1974] and the 1982 Development 

Document for Effluent Limitations Guidelines and Standards and Pretreatment Standards for the 

Steam Electric Point Source Category (referred to in this report as “the 1982 Development 

Document”) [U.S. EPA, 1982]. These development documents contain findings, conclusions, 

and recommendations on control and treatment technology relating to discharges from steam 

electric power plants.

The data in the 1974 Development Document comes from a previous study of the steam electric 

industry from which effluent standards were developed and existed from 1974-1982. The data in 

the 1974 Development Document includes ash transport water data for 44 plants. Data presented 

for these 44 plants represent a combination of effluent data from fly, bottom, and combined ash 

impoundments along with source water data.

The 1982 Development Document presents the results of studies of the steam electric industry 

that EPA conducted in revising the Steam Electric Power Generating effluent guidelines. Ash 

impoundment characterization data are provided in three separate tables and an appendix 

contained within the 1982 Development Document.

2.13 Permit Application Data - Form 2C

During the detailed study and throughout the rulemaking, EPA has coordinated efforts with the 

Utility Water Act Group (UWAG). The industry trade association created a database of NPDES 

Form 2C data from UWAG’s member companies and provided the database to EPA during the 

detailed study [UWAG, 2008]. The NPDES Form 2C (or an equivalent form used by a state 

permitting authority) is an application for a permit to discharge wastewater that must be 

completed by existing industrial plants, including manufacturing, commercial, mining, and 

silvicultural operations. This form includes plant information, data on plant outfalls, process flow 

diagrams, treatment information, and intake and effluent characteristics.

The NPDES Form 2C database provide by UWAG contains information about the outfalls from 

86 coal-fired steam electric power plants that discharge FGD, ash handling, or coal pile runoff 

waste streams. The database does not include Form 2C information for plants that have neither a 

wet FGD system nor wet fly ash handling. For example, if a plant has no wet FGD system and 

the plant’s only wet ash handling is for bottom ash sluicing, UWAG did not include its 

information in the database. In some cases, the Form 2C data also includes source water 

concentration data for the plant; however, EPA did not accept these source water data because 

there is no sample collection date information on which to pair with the ash impoundment 

effluent data. 

2.14 Utility Water Act Group

As part of its public comment submission in September 2013, UWAG provided a table 

presenting bottom ash transport water data for samples collected from 21 plants [UWAG, 2013]. 

The UWAG database samples were collected from 2001 to 2013, with samples from 17 plants 

collected between 2010 and 2013. In some cases, UWAG also provided source water data 
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collected on the same sample day as the bottom ash transport water samples. Also, as part of 

their public comment submission, UWAG provided a report prepared by URS Corporation with 

2013 sampling data for sulfides and some other parameters at nine plants. UWAG masked the

identity of all plants included in the bottom ash transport water database and sulfides report.

EPA requested additional information and clarification from UWAG in order to properly 

interpret, validate, and evaluate the data submitted to determine if these data met EPA’s 

acceptance criteria for inclusion in the POC and pollutant loadings analyses. Specifically, EPA 

requested UWAG to provide more information about the identity of the sampled plants, the 

sample collection location and methods used, the selection criteria used by UWAG when 

developing their data set, information on how non-detect values were handled when calculating 

average concentrations, total suspended solids results associated with the samples, and other 

plant-specific information. EPA ultimately received and reviewed these data for possible 

inclusion in the ash loadings analysis [UWAG, 2014a].

Please see Additional Bottom ash Transport Water Data [UWAG, 2014b] for information on late 

data submittals provided by UWAG that were unable to be included in EPA’s review.

3. ASH DATA REVIEW MATRIX

ERG performed a detailed review of each of the data sources described in Section 2 to identify 

ash transport water concentration data that met EPA’s data acceptance criteria for inclusion in 

analyses for identifying POCs and for characterizing discharges of ash transport water. Error! 

Reference source not found. presents the data acceptance criteria for the POC analysis and 

loads analysis. To complete the review of the multiple data sources and data types described in 

Section 2, ERG developed the Ash Data Review Matrix [ERG, 2015c] to compile information 

from each data source related to EPA’s data acceptance criteria. This data review matrix allowed 

EPA to ensure that data were evaluated consistently across all sources. 
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Table 3-1. Ash Data Acceptance Criteria

Acceptance Criteria POC Analysis Ash Loadings

Sample locations must be unambiguous and clearly described such that 

it can be categorized by type (e.g., bottom ash impoundment effluent 

rather than impoundment effluent with no further definition) and level 

of treatment (e.g., untreated, partially treated).

  

Sample must only be comprised of fly ash or bottom ash transport 

water (i.e., no combined ash transport water).



Sample must be at least 75% by volume ash transport water.   

Sample must be representative of actual ash impoundment effluent 

(simulated treated effluent used for sensitivity analysis).

 

Analytical data must represent individual sample results or plant-level 

average sample concentrations rather than average results representing 

multiple plants.

 

For biphasic samples (i.e., those with solids content >1%), sample 

analysis must provide results for both phases.

 

Data must not be from an ash-settling test conducted in a column (i.e., 

a simulated sample of partially treated wastewater).

 

Sample must be representative of full-scale, typical plant operations.  

Sample analysis must be completed using accepted analytical 

methods.

a  

Data must not be duplicative of other accepted data.  

Sample data must provide sufficient information to identify units.  

Non-detect results were not accepted if no limit (e.g., detection limit, 

quantitation limit) was provided.



Sample results must represent total (i.e., dissolved results were not 

accepted except for TDS).



a

See “Ash Data Review Matrix” for a list of EPA accepted analytical methods [ERG, 2015c].

During the detailed review of the individual data sources, ERG extracted data and entered 

information from each data source into the Ash Data Review Matrix [ERG 2015c]. Once all of 

the data was reviewed and entered into the data review matrix, ERG applied acceptance criteria 

to the data review matrix to identify data sources that meet the acceptance criteria. See Table 3-1

for a listing of the information ERG extracted from each data source and entered into the ash 

data matrix, the reason for extracting such information, and the acceptance criteria applied to the 

extracted data.
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Table 3-1. Information Extracted from Each Data Source Received by EPA2

Information Extracted 

from Data Source Reason for Collection Acceptance Criteria

Data Source Name Identify the source of the data. No data were excluded based on source. 

These data were used to identify duplicative 

data.

Plant Name/Plant ID Identify the plant, which is sometimes 

necessary to verify whether the samples 

met all the acceptance criteria of the 

POC and pollutant loadings analyses. 

For example, if the data source 

provided sufficient information to 

assess the sources and volumes of 

wastewaters managed in an 

impoundment, the data were accepted. 

However, if the data source did not 

provide this information, ERG used the 

plant identity to refer to such data 

collected in the Steam Electric Survey 

and to evaluate whether the plant was 

already represented in the analytical 

dataset.

No data were excluded solely based on the 

identity of the plant. These data were used 

to identify plant characteristics as needed 

and duplicative data.

Wastestream Classification Indicate if the data represents source 

water, fly ash transport water, bottom 

ash transport water, or combined ash 

transport water.

Data were found to be unacceptable for 

review in the POC analysis if the 

wastestream represented combined fly ash 

and bottom ash transport water. If the waste 

stream could not be identified from the data 

source, ERG relied on information in the 

Steam Electric Survey [ERG, 2015g] to 

classify the wastestream, if the plant 

identify was known.

Level of Treatment For both source water samples and ash 

transport water, these data were 

collected to determine the level of 

treatment performed prior to sample 

collection (e.g., raw intake water, 

treated intake water, untreated ash 

transport water, partially treated 

transport water, treated ash transport 

water/ ash impoundment influent).

Data were found to be unacceptable if the 

level of treatment could not be identified 

with the analytical results. The sample 

location must be unambiguous. All levels of 

treatment were evaluated in the POC 

analysis; only effluent samples were 

evaluated in the loading analysis.a

Sample Identification Identify where the sample was 

collected from and if the data represents 

individual sample results or average 

samples results from multiple samples.

Data were found to be unacceptable if the 

data represented average concentrations 

from multiple plants. Analytical data must 

represent individual sample results or plantspecific average sample concentrations.

 

2 See SE04745 Bottom Ash and Fly Ash Pollutants of Concern (POC) Analysis Methodology Memorandum [ERG. 

2015b] for specific acceptance criteria as applied to the POC analysis. See the Incremental Costs and Pollutant 

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

Point Source Category [ERG. 2015e] for specific acceptance criteria as applied to the pollutant loadings analysis.
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Table 3-1. Information Extracted from Each Data Source Received by EPA2

Information Extracted 

from Data Source Reason for Collection Acceptance Criteria

Analytes Identified Identify the pollutant represented by the 

analytical results.

Data were found unacceptable if the 

analytes were not identified. EPA only 

evaluated data for “Total” results in the 

pollutant loadings analysis.

Units Identified Ensure the data source specifies the 

exact analytical results of all samples.

Data were found to be unacceptable if the 

units of measure were not indicated with 

analytical results.

Method Detection Limits 

Identified

Identify if detection limits are presented 

for analytical methods represented in 

the data.

Data were found to be unacceptable if the 

non-detection results were not associated 

with a method detection limit or reporting/ 

quantitation limit.

Reporting/ Quantitation 

Limit Identified

Identify if reporting or quantitation 

limits are presented for analytical 

methods represented in the data.

Data were found to be unacceptable if the 

non-detection results were not associated 

with a method detection limit or reporting/ 

quantitation limit.

Analytical Methods 

Identified

Identify the analytical methods used. Data were found to be unacceptable if the 

samples were analyzed using a method not 

approved by EPA, or if no analytical 

method was reported. See “Ash Analytical 

Data Review Memorandum” for a list of 

accepted analytical methods.

Representative of Typical, 

Full-Scale Operations

Identify if the data represents typical 

plant operations.

Data were found to be unacceptable if the 

samples were collected during times of 

atypical operation (e.g., pilot study, unit 

disruption) and these atypical operations 

may influence the sample data. Samples 

must be representative of full-scale, typical 

plant operations.

Percent Ash Transport 

Water

Determine if the percent of the sample 

that is fly ash transport water and/or 

bottom ash transport water. 

Data were found to be unacceptable if the 

sample represents less than 75% ash 

transport water.

Other Wastestreams Determine if the data indicates other 

wastestreams that may be commingled 

with the ash transport water sample.

Data were found to be unacceptable if the 

sample represents less than 75% ash 

transport water.

a- Simulated effluent samples were evaluated in a pollutant loadings sensitivity analyses. The Incremental Costs and 

Pollutant Removals for the Final Effluent Limitations Guidelines and Standards for the Steam Electric Power 

Generating Point Source Category [ERG. 2015e] provides additional information about ash transport water loadings 

sensitivity analyses.
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4. ACCEPTANCE CRITERIA CONCLUSIONS

EPA applied the acceptance criteria described in Section 0 to all of the data in the ash data 

review matrix. Table 4-1 presents data sources containing data that was accepted and used in the 

POC analyses and the pollutant loadings analyses based on ERG’s review of the information in 

the ash data review matrix. The Ash Data Review Matrix [ERG, 2105b] presents information 

collected during the assessment of the data and the rationale to include or exclude each dataset

from the POC analyses and pollutant loadings analyses.

The POC analysis was conducted in two parts as explained in the Bottom Ash and Fly Ash 

Pollutants of Concern (POC) Analysis Methodology Memorandum [ERG, 2015d]. The ash 

pollutant loadings analysis is described in the Incremental Costs and Pollutant Removals for the 

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

Point Source Category [ERG, 2015e]. That document also includes descriptions of the sensitivity 

analysis that applied different acceptance criteria to the data used for the pollutant loadings.
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Table 4-1. EPA’s Data Source Acceptance Criteria Summary

Data Source Dataset Plant Identification

POC 

Analysis 

Part 1

POC 

Analysis 

Part 2

Loadings 

Analysis

Loadings 

Sensitivity 

Analysis

No Data 

Accepted 

For Use

AEP, 2006 Table 5-1c Conesville Generating Plant 

Dayton, 2007 Appendix B Stuart Generating Station 

Dayton, 2007 Appendix B Killen Generating Station 

Duke, 2013 & 2014 Appendix B Marshall Steam Station  

Duke, 2013 & 2014 Appendix B Belews Creek Steam Station  

Duke, 2014 Follow-Up Correspondence 

After Public Comment Miami Fort Generating Station  

Duke, 2014 Follow-Up Correspondence 

After Public Comment East Bend Generating Station 

Duke, 2014 Follow-Up Correspondence 

After Public Comment Cliffside Steam Station  

EPRI, 1997-2001 Appendix A PISCES Site A 

EPRI, 1997-2001 Appendix A PISCES Site B 

EPRI, 1997-2001 Appendix A PISCES Site C  

EPRI, 1997-2001 Appendix A PISCES Site D 

EPRI, 1997-2001 Appendix A PISCES Site E 

EPRI, 1997-2001 Appendix A PISCES Site F  

EPRI, 1997-2001 Appendix A PISCES Site G  

EPRI, 2006 Appendix A John E. Amos Plant  

EPRI, 2009a Table B-2 & Table B-5 Unidentified (4 plants) 

EPRI, 2009b Tables 3-2, 3-4, 3-5, 3-6, & 3-7 Unidentified (5 plants) 

Holyoke, 2002 Tables 2-3, 2-4, & 2-5 Mt. Tom Station 

Hoosier, 2013 & 2014 Public Comment Letter & 

Follow-Up Correspondence Frank E. Ratts Generating Station  

Interstate, 2005 Table 3.1 & Table 3.2 Southerland Generating Station 
Memorandum

30 September 2015

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INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE

Table 4-1. EPA’s Data Source Acceptance Criteria Summary

Data Source Dataset Plant Identification

POC 

Analysis 

Part 1

POC 

Analysis 

Part 2

Loadings 

Analysis

Loadings 

Sensitivity 

Analysis

No Data 

Accepted 

For Use

Interstate, 2010 Table 5 Prairie Creek Generating Station 

Interstate, 2004 Table 2.03-1 & Table 2.03-2 Dubuque Generating Station 

Interstate, 2002 Appendix A M.L. Kapp Generating Station 

Minnesota Power, 2010 Table 1 & Appendix D Laskin Energy Center 

South Carolina Electric 

and Gas, 2007 Table C-1 & Appendix A Canadys Station 

Southern, 2009 Appendix A Lansing Smith Plant 

U.S. EPA, 2009 EPA Detailed Study Analytical 

Results Homer City  

U.S. EPA, 2009 EPA Detailed Study Analytical 

Results Widow’s Creek 

U.S. EPA, 2009 EPA Detailed Study Analytical 

Results Mitchell Plant 

U.S. EPA, 2009 EPA Detailed Study Analytical 

Results Cardinal 

U.S. EPA, 1974 Table A-V-9 Unidentified (29 plants) 

U.S. EPA, 1974 Table A-VII-12 Unidentified (4 plants) 

U.S. EPA, 1974 Table A-VII-13 Unidentified (1 plants) 

U.S. EPA, 1974 Table A-VII-14 Unidentified (10 plants) 

U.S. EPA, 1982 Table V-32 Unidentified (11 ash impoundments) 

U.S. EPA, 1982 Table V-33

Unidentified (4 fly ash 

impoundments, 9 bottom ash 

impoundments, 20 combined ash 

impoundments)


Memorandum

30 September 2015

Page 15

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE

Table 4-1. EPA’s Data Source Acceptance Criteria Summary

Data Source Dataset Plant Identification

POC 

Analysis 

Part 1

POC 

Analysis 

Part 2

Loadings 

Analysis

Loadings 

Sensitivity 

Analysis

No Data 

Accepted 

For Use

U.S. EPA, 1982 Table V-34

Unidentified (3 fly ash 

impoundments, 3 bottom ash 

impoundments, 10 combined ash 

impoundments)



U.S. EPA, 1982 Appendix A

Unidentified (3 fly ash 

impoundments, 3 bottom ash 

impoundments, 10 combined ash 

impoundments)

 

UWAG, 2008 Form 2C Database 86 Plants a  

UWAG, 2013 & 2014 UWAG Plant 1 Widows Creek 

UWAG, 2013 & 2014 UWAG Plant 2 Bull Run 

UWAG, 2013 & 2014 UWAG Plant 3 Yates  

UWAG, 2013 & 2014 UWAG Plant 4 EC Gaston  

UWAG, 2013 & 2014 UWAG Plant 5 Gorgas  

UWAG, 2013 & 2014 UWAG Plant 6 Greene County  

UWAG, 2013 & 2014 UWAG Plant 7 Crist  

UWAG, 2013 & 2014 UWAG Plant 8 Kammer  

UWAG, 2013 & 2014 UWAG Plant 9 Unidentified 

UWAG, 2013 & 2014 UWAG Plant 10 Unidentified 

UWAG, 2013 & 2014 UWAG Plant 11 Monroe Power Plant  

UWAG, 2013 & 2014 UWAG Plant 12 Frank E. Ratts Generating Station 

UWAG, 2013 & 2014 UWAG Plant 13 River Rouge  

UWAG, 2013 & 2014 UWAG Plant 14 Meredosia Power Station 

UWAG, 2013 & 2014 UWAG Plant 15 Sioux Power Plant  

UWAG, 2013 & 2014 UWAG Plant 16 Burlington 
Memorandum

30 September 2015

Page 16

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE

Table 4-1. EPA’s Data Source Acceptance Criteria Summary

Data Source Dataset Plant Identification

POC 

Analysis 

Part 1

POC 

Analysis 

Part 2

Loadings 

Analysis

Loadings 

Sensitivity 

Analysis

No Data 

Accepted 

For Use

UWAG, 2013 & 2014 UWAG Plant 17 Dubuque  

UWAG, 2013 & 2014 UWAG Plant 18 Kingston 

UWAG, 2013 & 2014 UWAG Plant 19 Unidentified 

UWAG, 2013 & 2014 UWAG Plant 20 Unidentified 

UWAG, 2013 & 2014 UWAG Plant 21 Unidentified 

UWAG, 2013 & 2014 UWAG Plant A Kyger Creek Station 

UWAG, 2013 & 2014 UWAG Plant D1 Unidentified 

UWAG, 2013 & 2014 UWAG Plant D2 Unidentified 

UWAG, 2013 & 2014 UWAG Plant D3 Unidentified 

UWAG, 2013 & 2014 UWAG Plant D4 Unidentified 

UWAG, 2013 & 2014 UWAG Plant E EC Gaston 

UWAG, 2013 & 2014 UWAG Plant M Miller 

UWAG, 2013 & 2014 UWAG Plant G Gorgas 

UWAG, 2013 & 2014 UWAG Plant N Unidentified 

a EPA accepted data from 25 plants for use in the loadings analysis and data from 6 plants for use in part 1 of the POC analysis. See the Ash Data Review Matrix 

[ERG, 2015c] for conclusions related to plants included in the Form 2C database.
Memorandum

30 September 2015

Page 17

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE

5. REFERENCES

1. AEP. 2006. Prediction of Effects of FGD Scrubber Wastes on Ash Pond Effluent at Six 

AEP Tier 2 Plants Conesville Excerpt. Section 5. (November). DCN SE02253.

2. Dayton. 2007. Review of Information on FGD Modifications For Killen and Stuart 

Generating Stations, Dayton Power & Light Company. (March 13). DCN SE02720.

3. Duke. 2013. Duke Energy. Comments of Duke Energy on Effluent Limitations 

Guidelines and Standards for the Steam Electric Power Generating Point Source 

Category. (7 June) EPA-HQ-OW-2009-0819-4305.

4. Duke. 2014. Duke Energy. Duke Energy Response to EPA Data Request. (4 December 

and 28 March). DCN SE04331 and SE04360.

5. ERG. 2015a. Eastern Research Group, Inc. “Development Memorandum for the Steam 

Electric Analytical Database for the Final Rule.” (30 September). DCN SE05876.

6. ERG. 2015b. Eastern Research Group, Inc. Analytical Database for Final Rule. 

(September 30). DCN SE05359.

7. ERG. 2015c. Eastern Research Group, Inc. Ash Data Review Matrix. (September 30). 

DCN SE05575.

8. ERG. 2015d. Eastern Research Group, Inc. “Bottom Ash and Fly Ash Transport Water 

Pollutants of Concern (POC) Analysis Methodology” (30 September). DCN SE04745.

9. ERG. 2015e. Eastern Research Group, Inc. Incremental Costs and Pollutant Removals for 

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

Generating Point Source Category. (September 30). DCN SE05851.

10. ERG. 2015g. Eastern Research Group, Inc. Steam Electric Technical Questionnaire 

Database (“Steam Electric Survey”). (30 September). DCN SE05903.

11. EPRI. 1997 - 2001. Electric Power Research Institute. PISCES Water Characterization 

Field Study, Sites A-G. Palo Alto, CA. DCNs SE01818-01823.

12. EPRI. 2006. Electric Power Research Institute. Mitigation of SCR-Ammonia Related 

Aqueous Effects in a Fly Ash Impoundment: Algal Enhancement and Water Chemistry. 

Palo Alto, CA. DCN SE04742.

13. EPRI 2009a. Electric Power Research Institute. Impact of Wet Flue Gas Desulfurization 

(FGD) Design and Operating Conditions on Selenium Speciation: 2009 Update. DCN 

SE04369.
Memorandum

6 August 2015

Page 18

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE

14. EPRI 2009b. Electric Power Research Institute. Integrated Fly Ash Pond Management. A 

Field Study of Five Central United States Pond Systems. DCN SE04361.

15. Holyoke. 2002. Mt. Tom Station Bottom Ash Transport Water Treatability Study. (April) 

DCN SE02465.

16. Hoosier. 2013. Hoosier Energy Rural Electric Cooperative. Comments of Hoosier Energy 

on Effluent Limitations Guidelines and Standards for the Steam Electric Power 

Generating Point Source Category. (20 September). EPA-HQ-OW-2009-0819-4471.

17. Hoosier. 2014. Hoosier Energy Rural Electric Cooperative. Hoosier response to Post 

Proposal Information Request. (11 and 14 April). DCN SE04701-04702.

18. Interstate. 2002. Interstate Power and Light Co. Coal Combustion Residue Reuse 

Exemption Request - Interstate Power & Light Company (an Alliant Energy Company) 

M.L. Kapp Generating Station, Clinton, Iowa. (March). DCN SE02241.

19. Interstate. 2004. Interstate Power and Light Co. Report for Interstate Power and Light 

Company – Dubuque Generating Station, Bottom Ash Wastewater Evaluation. (June). 

DCN SE02279.

20. Interstate. 2005. Interstate Power and Light Co. Options Analysis Report for Settling 

Pond Maintenance, Reconfiguration, and Upgrades Marshalltown, Iowa. (December). 

DCN SE02231.

21. Interstate. 2010. Interstate Power and Light Co. Ash Pond Study Report, Prairie Creek 

Generation Station Cedar Rapids, Iowa. (August 9). DCN SE02265.

22. Minnesota Power. 2010. Final Pilot Testing Report and Design Basis, Mercury Removal 

Project. (August) DCN SE02741.

23. South Carolina Electric & Gas. 2007. South Carolina Electric and Gas Canadys Station 

WWTP for Arsenic Treatment Canadys Station, South Carolina, Preliminary Engineering 

Report. (July). DCN SE02280.

24. Southern 2009. Selective Non-Catalytic Reduction Unit (SNCR) Study. (November). 

DCN SE02570.

25. U.S. EPA. 1974. Development Document for Effluent Limitations Guidelines and 

Standards and Pretreatment Standards for the Steam Electric Point Source Category. 

EPA-440-1-74-029a. Washington, DC. (October).
Memorandum

6 August 2015

Page 19

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE

26. U.S. EPA. 1982. U.S. Environmental Protection Agency. Development Document for 

Effluent Limitations Guidelines and Standards and Pretreatment Standards for the Steam 

Electric Point Source Category. EPA-440-1-82-029. Washington, DC. (November).

27. U.S. EPA. 2009. U.S. Environmental Protection Agency. Steam Electric Power 

Generating Point Source Category: Final Detailed Study Report. EPA 821-R-09-008. 

Washington, DC. (October). Available online at: 

http://water.epa.gov/lawsregs/guidance/cwa/304m/archive/upload/2009_10_26_guide_ste

am_finalreport.pdf. DCN SE00003.

28. U.S. EPA. 2014. U.S. Environmental Protection Agency. Meeting Notes for the Steam 

Electric Rulemaking Record, September 10, 2014 Meeting with Utility Water Act Group 

(UWAG) Regarding Proposed Steam Electric ELGS. (September 10). DCN SE05578.

29. UWAG. 2008. Utility Water Act Group. UWAG Form 2C Effluent Guidelines Database. 

(30 June). DCNs SE02918 and SE02918A1.

30. UWAG. 2013. Utility Water Act Group. Comments on EPA’s Proposed Effluent 

Limitations Guidelines and Standards for the Steam Electric Power Generating Point 

Source Category. (7 June). EPA-HQ-OW-2009-0819-4655.

31. UWAG. 2014a. Utility Water Act Group. UWAG Response to Post Proposal Information 

Request. (1 August). DCN SE04717.

32. UWAG. 2014b. Utility Water Act Group. Additional Bottom ash Transport Water Data. 

(25 November). DCN SE05597.