From: Dear Schramm

To: Thomas Finseth

Subject: RE: WVPA Comments on Steam ELG

Date: Friday, January 31, 2014 10:58:00 AM

Attachments: sgSolutions - Flow Diagram for ELG (1-30-14).pdf

Hi TJ,

Per your request, attached is a flow diagram that shows how the wastestreams flow prior to

discharge at the outfall for the sgSolutions, LLC facility in West Terre Haute, Indiana.

As shown in the diagram, many types of waters from the gasification process commingle on its way

to the water treatment pond. It is my understanding that the other two existing gasification plants

could be plumbed differently than this facility – this may be based on the differing gasification

technologies for each facility.

As my company evaluated the proposed limits and the background data, the proposed limits are very

stringent and partially based on sample results from the RCC distillate effluent only. This is very

clean distillate water that is a result of vapor compression evaporation from one of the gasification

processes – but not all wastestreams at this facility are processed through vapor compression

evaporation. Based on my understanding of the proposed rule, it would be highly unlikely that the

remaining streams proposed to be subject to these newly proposed limits could even be released to

the water treatment pond without spending a considerable amount of monies to fully evaluate and

install additional pollutant control technologies for the ‘interim’ treatment of these wastestreams

prior to being treated at the water treatment pond.

Hopefully this helps USEPA re-evaluate imposing such a standard on the gasification wastewaters

until additional streams are fully evaluated.

Please let me know if I can clarify anything for you.

Thanks,

Dear

S. Dear Schramm-Satayathum | Manager, Environmental Affairs

Wabash Valley Power Association

722 North High School Road | Indianapolis, IN 46214

317.481.2868 p | 317.243.6416 f | 317.308.1814 c

d_schramm@wvpa.com

From: Thomas Finseth [mailto:Thomas.Finseth@erg.com] 

Sent: Thursday, January 23, 2014 4:20 PM

To: Dear Schramm
Subject: WVPA Comments on Steam ELG

Dear,

As we just discussed, please provide me with a description of all the various wastestreams that are discharged

from the facility, as well as a process flow diagram that shows where those wastestreams are generated and

where they are commingled with other wastestreams prior to discharge.

If any of the information that you provide is CBI, DO NOT SEND IT ELECTRONICALLY. Instead, please send it

via FedEx/UPS/USPS to the following address:

Attn: TJ Finseth

14555 Avion Parkway

Suite 200

Chantilly, VA 20151

Thank you very much for your help in this matter.

TJ Finseth

ERG

14555 Avion Parkway, Suite 200

Chantilly, VA 20151

(703) 633-1698 (phone)

(703) 263-7479 (fax)

thomas.finseth@erg.com

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