February 26, 2010

Memorandum to Steam Electric Record

From: Ron Jordan Engineering and Analysis Division

Subject: Discussions with Utility Wate r Act Group (UWAG) Regarding the Proposed Steam Electric ICR

In addition to holding two rounds of outreach telec onferences with stakehol ders to review EPA’s proposed Information Collection Request (ICR) for the Steam Electric Power Generating Effluent Guidelines, EPA also engaged in seve ral discussions with the Utility Water Act Group (UWAG) to exchange views on the ICR process a nd the substance of the draft questionnaire. This memorandum summarizes the topics discussed with UWAG. 1

January 19, 2010

• Burden estimates for proposed ICR. Industry co ncern about the level of effort required to complete the questionnaire and the amount of time that will be provided for submitting the completed questionnaires.

• Statistical methodology that will be used to se lect plants that will receive questionnaires.

• Intended recipients for the questionnaire – corporate contacts vs. plant manager.

January 21, 2010 The agenda and FGD diagram prepared for the call are attached. Topi cs discussed include:

• Leachate sampling – sample co llection frequency; where sa mples would be collected; number of potential sample poi nts at any individual plant

• Ash handling – ash storage systems that combine both fly ash and bottom ash; reorganization of the ash sect ion to collect information on a “system” approach rather than a “generating unit” approach.

• FGD terminology – potential revisions to the FGD diagram included in the questionnaire; terminology used for FGD process and streams.

• EIA/FERC data – efforts to reduce redundant da ta collection in the steam electric ICR where EIA or FERC data can be used.

• Questionnaire format – preference for MS Excel format

• CBI justification – plans to eliminate requirement to justify CBI claims at the time questionnaires are submitted.

• Amount of time that will be provi ded for completing questionnaires.

• Need for time constraints when asking for information on planned systems, or when obtaining cost data for systems built long ago.

1 The outreach teleconferences are summ arized in a separate memorandum. See the memorandum titled “Outreach Calls for the Proposed Steam Electric ICR,” East ern Research Group, Inc. February 25, 2010.2 January 26, 2010

• Draft mailing list for power plants within th e statistical sample frame for the ICR.

• Flexibility for analytical methods to be used for leachate samples.

February 16, 2010

• Draft glossary

• Mailing list

• Ash handling system component list

# AGENDA

ICR for the Steam Electric Powe r Generating Effluent Guidelines EPA – UWAG Conference Call

January 21, 2010 2:00 p.m. – 3:30 p.m. (EST)

Topics for Discussion

• Leachate Sampling

• Ash Handling – combined fly ash and bottom ash storage systems

• FGD Terminology (Diagram is included in doc ument entitled FGD Example Diagram_1_20_10.pdf)

• EIA/FERC Data

• Questionnaire Format

• CBI Justification

Other Discussion and Wrap-up

Additional Instructions: The teleconference call in number is 1-866- 299-3188 and the access code is 2025661003 followed by the # sign.