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



### 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. I NTRODUCTION /B ACKGROUND

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 load ings for ash transp ort 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 Ana lytical Database for the Final

Rule [ERG, 2015 a ]. 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. D ATA S OURCES

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 dat a, 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 response s to the Questionnaire for the Steam Electric P ower Generating Effluent Gu idelines (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

pu blished reports. The following subsections describe each data source and the type of data reviewed by ERG within each source.Memorandum

30 September 2015 Page 2

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE 2.1 American Electric Power

As part of the ir 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 the ir Steam Electric S urvey 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 co ntractor 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 S tuart G enerating

S tation (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 O ut fall 001 at the Killen Plant represents effluent from a comb ined ash impoundment and sampling data from

O utfall 012 at the Stuart Plant data set re presents bottom ash impoundment effluent.

2.3 Duke Energy

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

s ubmitted data for paired sam ples of simulated effluent bottom ash transport water 1 and 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 procedu re, 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 co llection 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 co nfirm ed 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

ana lysis.Memorandum

30 September 2015 Page 3

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE 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 followin g plants:

1. M arshall , a 4

- unit 2,200 MW capacity coal

- fired station (p aired source water and

simulated bottom ash transport water data )

.

2. Belews Creek, a 2

- unit 2,400 MW capacity coal

- fired station (p aired source water and simulated bottom ash transport wate r data )

.

3. Miami Fort Generating Station (Miami Fort), a 3

- unit 1,180 MW capacity coal

fired station (data claimed CBI) (p aired source water and untreated bottom ash

transport water; u ntreated bottom ash transport water not paired with source

water )

.

4. East Bend Generating Station, a 1

- unit 600MW capacity coal

- fired station (p aired source water and simulated bottom ash transport water data )

.

5. Cliffside Steam Station, a 5

- unit 760 MW capacity coal and oil

- fired station (p aired source water and untre ated 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

extens ively 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 Chara cterization 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 da ta. 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.Memorandum

30 September 2015 Page 4

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE 2.5 Holyoke

As part of the ir Steam Electric S urvey response, Holyoke provided a document titled Mt. Tom Station Bottom Ash Transport Water Treatab ility 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 p lant’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 resultin g from the burning of domestic coal. Tables 2

- 4 and 2

- 5 pr esent 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 Ene rgy

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

, wh ere 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

, 2 013].

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

identificat ion of the specific impoundments (using i mpoundment 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 Inters tate Power and Light

As part of the ir Steam Electric S urvey response, Interstate Power and Light (Interstate) provided

a series of four documents re p resenting four different plants. Descriptions of each of the

documents submitted to EPA by Int erstate 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]Memorandum

30 September 2015 Page 5

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

re port present paired source water data with ash impoundm ent 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 P ower & 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. Sampl es ’ 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 the ir Steam Electric S urvey response, Minnesota Power provided a document titled Final Pilot Testing Report and Design Basis, Mercury Removal Project [Minnesot a 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 filtr ation 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 the ir Steam Electric S urvey response, South Caro lina 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 effortsMemorandum

30 September 2015 Page 6

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE 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 the ir response to the Steam Electric S urvey, So uthern 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 S mith plant is a 3

- unit 840 MW capacity coal

- , gas

- , and oil

- fired plant. Sampling data from the time of the study include s intake water, ash transport water, ash impoundment, and discharge canal.

2.11 EPA Detailed Study Ash Pond Sampling Data

As part of the det ailed 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

p ractices 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 spe cific metals), hexavalent chromium, nitrogen compounds, and other classical analytes. Spe cifically, 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 s amples 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 t he four plants w as a s 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 PerformanceMemorandum

30 September 2015 Page 7

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE Standards for the Steam Elect ric 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 Electri c Point Source Category (referred to in this report as “the 1982 Development Document”) [U.S. EPA, 1982]. T hese development documents contain findings, conclusions, and recommendations on control and treatment technology relating to discharges from steam

e lectric 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 trans port 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 st eam 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 a nd 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 exist ing industrial plan ts, 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 p rovide 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 on ly 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 U tility Water Act Group

As part of its public comm ent 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 dataMemorandum

30 September 2015 Page 8

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE collected on the same sample day as the bottom ash transport water samples. A lso, a s part of their public comment submission, UWAG provided a report prepared by URS Corporation with

2013 sa mpling 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 cri teria used by UWAG when developing their data set, information on how non

- detect values were handled when calculating average concentrations, total suspended solids r esults 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. A SH D ATA R EVIEW M ATRIX

ERG performed a detailed review of each of the data sources described in Section 2 to identify ash transport water concentrati on 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 a nalysis 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, 2015 c ] to compile information from each data source related to EPA’s data acceptance crite ria. This data review matrix allowed

EPA to ensure that data were evaluated c onsistently across all sources.Memorandum

30 September 2015 Page 9

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

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 f ly 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 se nsitivity 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 we re 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 a nalytical methods [ERG, 2015 c ].

During the detailed review of the individual data sources

, ERG extract ed data and entered

information from each data source into the Ash Dat a Review Matrix [ERG 2015 c ]

. 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, t he reason for extract ing such information, and the acceptance criteria applied to the

extracted data.Memorandum

30 September 2015 Page 10

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE Table 3

- 1 . Information Extracted from Each Data Source Rece ived by EPA 2

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 I D 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 o f wastewaters managed in an impoundment, the data were accepted. However, if the data source did not provide this information, ERG used the plant identi t y to refer to such data collected in the Steam Electric Survey and to evaluate whether the plant was

al ready 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 wa ste
stream could not be identified from the data source, ERG relied on information in the Steam Electric Survey [ERG, 2015 g ] to classify the wastestream, if the plant identify was known.

Level of Treatment For both source water samples and ash

transport w ater, 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 impou ndment 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 w ere 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

dat a represented average concentrations from multiple plants. Analytical data must represent individual sample results or plant

specific 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 Li mitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category [ERG. 2015e] for specific acceptance criteria as applied to the polluta nt loadings analysis.Memorandum

30 September 2015 Page 11

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE Table 3

- 1 . Information Extracted from Each Data Source Rece ived by EPA 2

Information Extracted

from Data Source Reason for Collection Acceptance Criteria

Analytes Identified Identify the pollutant represented by the analytical results. Data wer e 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

- de tection 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 we re 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

samp les 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 method s

. Representative of Typical,

Full

- Scale Operations Identify if the data rep resents 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 represen tative 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

t ransport 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

- Si mulated effluent samples were evaluated in a pollutant loading s 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 [ER G. 2015e] provides additional information about ash transport water loadings sensitivity analyses.Memorandum

30 September 2015 Page 12

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE 4. A CCEPTANCE C RITERIA C ONCLUSIONS

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

colle cted 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 c onducted in two parts as explained in the Bottom Ash and Fly Ash Pollutants of Concern (POC) Analysis Methodology Memorandum [ERG

, 2015 d ]. The ash pollutant loading s analysis is described in the Incremental Costs and Pollutant Removals for the Final Efflue nt Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category [ERG

, 2015 e ]

. That document also includes descriptions of the sensitivity analysis that applied different acceptance criteria to the data used for the pol lutant loadings.Memorandum

30 September 2015 Page 13

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

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  

Du ke, 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 P ISCES 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 Unident ified (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 Page 14

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 Ap pendix 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 Anal ytical

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 UW AG 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 U WAG 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 Un identified 

a EPA accepted data from 2 5 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, 2015 c ] for conclusions related to plants included in the Form 2C databa se.Memorandum

30 September 2015 Page 17

INTERNAL DRAFT DELIBERATIVE: DO NOT DISTRIBUTE, QUOTE, OR CITE 5. R EFERENCES

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 SE0 2253

.

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

G enerating Stations

, Dayton Power & Light Company. (March 13)

. DCN SE0 2720

.

3. D uke. 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. 2015 a . Eastern Research Group, Inc. “Development Memorandum for the Steam Electric Analytical Database for the Fin al Rule.” (30 September). DCN SE05876.

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

. (September 30). DCN SE05359

.

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

DCN SE05575.

8. ERG. 2015 d . E astern Research Group, Inc

. “Bottom Ash and Fly Ash Transport Water Pollutants of Concern (POC) Analysis Methodology” ( 30 September) . DCN SE 0 4745

.

9. ERG

. 2015 e

. Eastern Research Group, Inc. Incremental Costs and Pollutant Removals for

the Final Effluent Limi tations Guidelines and Standards for the Steam Electric Power Generating Point Source Category

. (September 30). DCN SE0 5851

.

10. ERG. 2015 g

. 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

SE043 69

.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 Trea tability Study. (April)

D CN 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. Hoo sier. 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

- Intersta te Power & Light Company (an Alliant Energy Company) M.L. Kapp Generating Station, Clinton, Iowa. (March). DCN SE0 2241

.

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

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

DCN SE0 2279

.

20. Interstate. 2005. Interstate Power and Light Co. Options Analysis Report for Settling Pond Maintenance, Reconfiguration, and Upgrades Marshalltown, Iowa. (December).

DCN SE0 2231

.

21. Interstate. 2010. Interstate P ower and Light Co. Ash Pond Study Report, Prairie Creek Generation Station Cedar Rapids, Iowa. (August 9). DCN SE0 2265

.

22. Minnesota Power. 2010. Final Pilot Testing Report and Design Basis, Mercury Removal Project. (August) DCN SE0 2741

.

23. South Carolina Elec tric & Gas. 2007. South Carolina Electric and Gas Canadys Station WWTP for Arsenic Treatment Canadys Station, South Carolina, Preliminary Engineering Report. (July). DCN SE0 2280

.

24. Southern 2009. Selective Non

- Catalytic Reduction Unit (SNCR ) Study. (Novembe r).

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

- 0 29a. 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. Environme n tal 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 Protecti on 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, Septe mber 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. 20 13. 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. 2014 a . 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.