# HUNTON&



# WilliAMS

October 24, 2014



# Via Electronic Mail

wood.robert@epa.gov

Mr. Robert K. 

# Wood, Director

Engineering & 

# Analysis Division (4303T)

Office of Science and Technology

U.S. EPA Headquarters

William Jefferson Clinton Building

1200 Pennsylvania Avenue, N. W.

Washington, DC 20460 HUNTON & 

# WILLIAMS LLP

RIVERFRONT PLAZA, EAST TOWER

951 EAST BYRD STREET

RICHMOND, VIRGINIA 23219-4074

TEL 804 • 788 • 8200

FAX 804 • 788 • 8218

ELIZABETH E. ALDRIDGE

DIRECT DIAL: 804 • 788 • 8549

EMAIL: ea1dridge@hunton.com

FILE NO: 29142.070312



# alicea.jezebele@epa.gov

Ms. Jezebele Alicea- Virella

Engineering and Analysis Division (4303T)

U.S. EPA Headquarters

William Jefferson Clinton Building

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460



# RE: CBI Substantiation Response: Freedom of Information Act (FOIA)

EPA- HQ-2014-009568

Dear Mr. Wood and Ms. Alicea-Virella:

On September 5, 2014, the Utility Water Act Group (UWAG) received your letter

dated August 29, 2014 asking that UW AG substantiate information claimed as confidential

business information (CBI) in UWAG' s letter to EPA dated August 1, 2014. The August 1

letter was in response to EPA's letter ofDecember 30,2013 requesting more information

about data included in UWAG's comments on EPA's proposed revisions to the steam electric

effluent limitations guidelines. By letter of September 25,2014, from Kevin Miller, EPA

Assistant General Counsel, UW AG and its affected members were granted a 20 business day

extension to the original 15 working day response deadline.

The UWAG member companies who provided information included in UWAG's

August 1, 2014 letter hereby waive all CBI designations as to the August 1, 2014 letter.

This waiver does not apply to any other data or information, including any data or

information that UW AG member companies may have designated as CBI in response to

EPA's Questionnaire for the Steam Electric Power Generating Effluent Guidelines (OMB

Control. No. 2040-0281).

ATLANTA AUSTIN BANGKOK BEIJING BRUSSELS CHARLOTTE DALLAS HOUSTON LONDON LOS ANGELES

McLEAN MIAMI NEW YORK NORFOLK RALEIGH RICHMOND SAN FRANCISCO TOKYO WASHINGTON

www.hunton.com

# HUNTON& 

# WILLIAMS

Mr. Robert K. 

# Wood

Ms. Jezebele Alicea-Virella

October 24, 2014

Page 

# 2

Please feel free to call me if you have any questions regarding this matter.

29142.070312 EMF 

# _us 52529252v1 

# Very truly yours,

# ~2~

Elizabeth E. Aldridge

Counsel to UW AG

# ATLANTA AUSTIN BANGKOK BEIJING BRUSSELS CHARLOTTE DALLAS HOUSTON LONDON LOS ANGELES

McLEAN MIAMI NEW YORK NORFOLK RALEIGH RICHMOND SAN FRANCISCO TOKYO WASHINGTON

www.hunton.com HUNTON & WILLIAMS LLP

RIVERFRONT PLAZA, EAST TOWER

951 EAST BYRD STREET

RICHMOND, VIRGINIA 23219-4074

TEL 804 • 788 • 8200

FAX 804 • 788 • 8218

ELIZABETH E. ALDRIDGE

DIRECT DIAL: 804 • 788 • 8549

EMAIL: ealdridge@hunton.com

FILE NO: 29142.070312 

# August 1, 2014

VIA ELECTRONIC MAIL

Ms. Jezebele Alicea-Virella

Engineering and Analysis Division CONTAINS CONFIDENTIAL

U. S. EPA Headquarters BUSINESS INFORMATION

William Jefferson Clinton Building

1200 Pennsylvania Avenue, N.W.

Mail Code 4303T

Washington, DC 20460

RE: EPA Information Request Regarding UWAG Data for Effluent Guidelines

Rulemaking

Dear Ms. Alicea-Virella:

Thank you for your interest in the data that UWAG members provide d as part of UWAG’s

comments on the proposed Steam Electric Efflue nt Guidelines rule (UWAG Comments).

This letter responds to your information reque st of December 30, 2013. We believe that the

data you are reviewing, both our bottom ash trans port water characterizati on data and our data

showing the absence of sulfides in ash pond discharges, demonstrate that EPA should reevaluate its characterization of bottom ash transport water.

Bottom Ash Transport Water

UWAG provided analysis of botto m ash transport water for 21 facilities. (See Attachment 7

to the UWAG Comments.) We also provided cer tificates of analysis or certified Form 2Cs

for all of the samples. (See Attachments 8 and 9 to the UWAG Comments.)

The UWAG analysis indicates that levels of bottom ash transport water pollutants are far

lower than EPA’s estimated pollutant levels for bottom ash transport water.

As we noted in our comments, EPA used out dated bottom ash transport water data (and

commingled bottom ash and fly ash transpor t water data) from the 1970s-80s. EPA,

therefore, proposes to base its regulatory d ecisions for bottom ash transport water on data

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 2

collected prior to implementation of the current steam electric effluent guidelines, which were

promulgated in October 1982. Data which pre- date the 1982 guidelines obviously are not

representative of current discharges.

In addition, the 1970s-80s data were analyzed using far less sensitive methods than are now

available, which led to overestimates of pollutant s in bottom ash transport water. These errors

were compounded when EPA used its characte rization data to calcu late toxic-weighted

pounds equivalents (TWPEs) for bottom ash tr ansport water, resulting in significant

overestimates of TWPEs attributable to bottom ash transport water.

In contrast to the 1970s-80s data, EPA’s analysis of Homer City’s botto m ash transport water,

based on a single sample collected in August 2007, is very similar to UWAG’s results for all

parameters except nitrate/nitrite, which is believed to be an error. Even with the error, EPA’s

results demonstrate very low TWPEs for botto m ash transport water. See UWAG Comments,

pp. 75-78.

Since proper characterization data are key to TW PE calculation and thus to the process of

selecting and limiting pollutants through revised effluent guide lines, UWAG has urged EPA

to revisit its bottom ash transport water charact erization data and its estimates of bottom ash

transport water TWPEs.

UWAG is encouraged that EPA is seeking fu rther information on the bottom ash transport

water characterization data we provided. For th e last several months, we have been working

with members of our group to address EPA’s que stions as thoroughly as possible. There are

some limitations to what we can supply, however, as noted in the next section.

Confidential Business Information

On behalf of the members who provided bottom ash transport water data and sulfides data,

UWAG is asserting a confidential business inform ation claim for a portion of this submittal.

Attachment 1 to this letter includes plant na me, company name, state, plant ICR ID, ICR pond

SPD number, average annual flow rate, source water, sampling duration and frequency, and

sampling date for some of the facilities that provided bottom ash tr ansport water samples

included in the UWAG Comments. Attachment 2 to this letter includes plant name, plant ICR

ID number, company name, state, ICR SPD ID number, SPD volume, SPD residence time,

average annual bottom ash sluice flow rate, source water information, and sampling date for

some of the facilities that provided ash pond sample s to be analyzed for sulfides. All of these

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 3

categories of information, as provided on A ttachments 1 and 2, are confidentia l business

information because they are competitively sensitiv e. Coal-fired steam electric units seek to

market their bottom ash whenever possible. Ma rketing the ash produces storage and disposal

savings as well as, in some cases, a revenue stream. The bottom ash transport water

characterization data and the sulfides data in UWAG’s comments – when combined with

facility-specific information – is competitively sensitive because ash purchasers routinely

compare the quality of various sources of coal ash before entering into purchase contracts for

the ash. The characterization data provided in the UWAG Comments, wh en coupled with the

identifying information about specific plants, is a factor that could influence ash purchasing

decisions. Therefore we are asserting a confid ential business information claim on behalf of

all facilities and comp anies that provided bottom ash transport water samples and ash pond

samples used in the UWAG Comments and which are listed in Attachments 1 and 2 to this

letter.

In some cases, UWAG members individually decided not to provide the additional

information which EPA has requested. In t hose cases, we have answered EPA’s general

questions in light of the inform ation we have about those facilit ies, but we have not included

specific information for those facilities on Att achments 1 and 2. The f acilities not providing

additional plant-specific information are Plants 9, 10, 19, 20, and 21 for the bottom ash

transport water data and Pl ants D1, D2, D3, D4, and N1 for the sulfide data.

Below we respond to EPA’s questions about UWAG’s bottom ash transport water data.

1. Please provide the plant name and plant lo cation associated with each plant ID

identified in Attachment 7. In additi on, please provide the Pond/Impoundment

Unit ID (e.g., SPD-2) for the sampled po nd, as reported in the Questionnaire for

the Steam Electric Effluent Guidelines.

Please see Attachment 1, the bottom ash tran sport water data summary sheet. In

consultation with our members, we have provided as much data as possible in

response to EPA’s questions.

2. Please describe the solids separation processes and treatment procedures

employed at each power plant for which da ta are provided. For example, does

the plant use dewatering bins to separate solids from the ash transport water?

Please identify if these solids separation processes and/or treatment procedures

are located upstream or downstream of the sample location. For each plant,

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 4

please identify what chemicals are a dded to the wastewater upstream of the

sample location.

All 21 plants have ash ponds for solids se paration. In addition, Plants 7 and 13 use

dewatering bins prior to the ash ponds for solids separation. At Plant 7, the sample

was collected after the dewatering bin (prior to the settling pond) a nd allowed to settle

prior to collecting the analyti cal sample. At Plant 13, the sample was collected at the

bottom ash pond effluent after dewatering and settling.

Attachment 1 provides information regardi ng the sampling location in relationship to

the solids separation process. Bottom ash sluice water samples (Plants 1-6, 9-11, and

18-21) were collected at the end of the sluice pipe prior to entering the

pond/impoundment. No chemicals were adde d to these ash sluice streams prior to

entering the pond/impoundment. The samples co llected were allowed to settle before

collecting the analytical sample.

Bottom ash pond effluent samples (Plant s 8, 12, 13, 14, 15, 16, 17) were collected

after settling at or near the bottom ash pond e ffluent. All but one of the effluent data

sets are based on certified Form 2Cs.

At the time of sampling, only two of th e plants (Plants 14 and 17) were adding

chemicals to the sluice water prior to en tering the ash pond to aid in solids settling. 1



# Samples from both plants were collected downstream of the chemical addition and

solids separation. Plant 14 added anionic and cationic polymers along with sulfuric

acid to aid in settling and pH adjustment. Plant 17 added a coagulant to the sluice

water prior to the ash ba sin to aid in settling.

3. From which plants and companies did UWAG request bottom ash

characterization data? If UWAG did not request data from all members, what

criteria were used to identify the plants for which data were requested? Did any

plants provide data to UWAG that w ere not included in UWAG’s Comments to

EPA? If so, why were these data excluded?

As explained in the UWAG Comments, we asked all UWAG members to supply

bottom ash transport water characterization data meeting the following criteria:

1 

# Plant 17 has been converted to natural gas and no longer uses the chemical additives in question.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 5

1. The bottom ash transport water should not be comingled with other wastestreams,

such as fly ash transport water, F GD wastewater, or cooling water.

2. If possible, the average annual discharge flow from the bottom ash pond should be

included.

3. If possible, the data should include an an alysis of the pollutants in the source water

(i.e., river water) used to sluice the bottom ash.

4. The water samples should be analyzed using sensitive methods, such as Method

200.8 or 200.7, for metals and Method 1631E or equivalent for mercury.

5. For facilities that do not have sepa rate bottom ash ponds, UWAG advised that

bottom ash sluice water samples should be co llected at the end of the sluice pipe

prior to entering the pond to collect a sample that has not been commingled with

other wastestreams. These sluice water samples were allowed to settle for

approximately one hour before drawi ng off the supernatant for analysis.

6. UWAG requested that its members provide laboratory reports or certificates of

analysis for all characterization data.

See UWAG’s Comments, p. 58. Using these criteria, UWAG reviewed all data

received from members. We th en rejected any data that failed to meet the criteria.

For example, we did not use any data fo r samples that reflected comingled bottom

ash and fly ash samples, and we did not us e any samples in which water from other

processes was used as sluice water, excep t that Plant 2 uses condenser cooling

water for sluicing and Plant 19 uses coo ling tower blowdown for sluicing. We

selected samples from Plants 2 and 19 b ecause the plants initially indicated river

water as the source for slui cing bottom ash. Later, afte r the comments were filed,

we learned that the plants use river water for sluicing but only after it is used as

condenser cooling water. Therefore, th e sluice water which originates from the

river is technically condenser cooling wate r. We also rejected any mercury data

that were not analyzed by a low-level method (Methods 1631E, 245.7 or an

equivalent). Mercury data from seven pl ants were not used due to high MDLs.

All of the results from these plants were reported as <MDL of 0.2 ppb. The source

water for these plants were also reported as <MDL of 0.2 ppb.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 6

4. Is the median source water and bottom ash sluice water concentrations provided

for the dataset calculated using all indivi dual samples (i.e., the entire dataset) or

using the plant averages?

As explained in our comments, if a facility provided more than one sample for the

same outfall, we averaged those samples to obtain the pollutant concentration. See

UWAG Comments, p. 58. All averages in th e UWAG dataset repres ent an average of

results for the same outfall only, and not an average across th e entire dataset. To be

conservative, UWAG used the detection level (MDL) as the concentration for

pollutants that were not detectable. This virtually guarantees that the calculated

concentrations are higher than the actual ones.

5. For each pond where the data you submitte d is comprised of multiple sample

results, please provide the pollutant concentration data for each individual

sample.

We provided this information in our comments. See UWAG Attachment 8,

“Supporting Documentation for UWAG Botto m Ash Characterization Table Sluice

Water/Pond Discharge,” and UWAG Att achment 9, “Supporting Documentation for

UWAG Bottom Ash Characterization Sour ce Water.” All quality control data

submitted to UWAG were also included in these attachments.

6. For plants that list the bottom ash tran sport water sampling location as “BA

Sluice Pipe” (Plants 1, 2, 3, 4, 5, 6, 9, 10, 11, 18, 19, 20, & 21), please explain why

ash pond effluent concentr ations were not provided.

The listed plants do not have a dedicate d bottom ash settling pond. Therefore, any

sample of ash pond effluent would not repr esent bottom ash transport water, but the

pollutant levels of the wastewaters (which might include fly ash transport water,

cooling water, etc.) comingled in the pond. For these plants, as noted in our list of

bottom ash transport water criteria, memb ers collected bottom ash sluice water

samples at the end of the sluice pipe prio r to entering the ash pond. For this plant

configuration, the sample that would best represent bottom ash transport water is a

composited and settled sample from the end of the bottom ash sluice pipe prior to

entering the ash pond.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 7

7. For each plant, please provide addi tional details regarding the sampling

locations.

a. Source water

i. Please specify the location of the source water samples provided

(e.g., Ohio River upstream of plant, Oh io River at poin t of intake to

plant (note if intake is ups tream or downstream of plant

discharges), piping prior to mixing with bottom ash).

ii. Does the plant treat the intake wa ter prior to use in the bottom ash

sluicing system? If so, how is the intake water treated?

iii. Does the plant recycle any process wastewater for use in the bottom

ash sluicing system? If so, how?

b. Bottom ash transport water

i. Please specify the location of the bottom ash sample provided (e.g.,

for “bottom ash sluice pipe” please identify if the sample was

collected immediately after mixing or coming out of the pipe at the

pond influent).

ii. For each ash pond, please identify all wastestreams that enter the

ash pond and their relative contribution (flow rates, pollutant

concentrations, and pollutant mass loads) to the pond.

a. Source Water

Attachment 1 provides information on the samp ling location of source water samples.

UWAG members collected source water samples either at the plant intake or from a

service water tap (if available). UWAG requested that the source water sample

represent the water used to sluice the bottom ash to the pond. All of the plants, except

Plants 2 and 19, use river water to sluice bottom ash. Plant 2 uses once-through

condenser cooling water for sluicing while Plant 19 uses cooling tower blowdown.

Plant 1 uses river water for sluicing bottom as h, but the intake water is downstream of

the plant’s primary wastewater discharge.

None of the plants treat their source water prior to using it for sl uicing. Only one of

the plants (Plant 13) that provided bottom ash transport water samples recycle the ash

pond water (i.e., reuses it for continued slui cing of bottom ash.) All of the plants,

except Plants 1, 18, and 19, withdraw river wa ter upstream of the plant discharges.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 8

Again Plant 2 uses once-through condenser cooling water and Plant 19 uses cooling

tower blowdown for bottom ash sluicing, ther efore the source water is considered a

process wastewater. Plants 1 and 18 use river water for sluicing bottom ash, but the

intake water is downstream of the pl ant’s primary wastewater discharge.

b. Bottom Ash Transport Water Samples

See our response to question 2 above for a description of the BATW sample location

and collection protocols. For the bottom ash pond effluent samples, we obtained the

BATW characterization data from each plan t’s Form 2C. See Attachment 8 to the

UWAG Comments, which includes the Form 2C s. UWAG did not collect flow rates

and pollutant concentrations for other wa stestreams entering the pond. However, in

response to EPA’s questions, we asked the in dividual facilities to provide information

about the other wastestreams entering the pond and the annual average flow rate for

the pond. See Attachment 1 for a summary of this information.

8. For each plant, please provide the asso ciated TSS concentration for the source

water (before and after any treatment prior to its use for transporting ash) and

the bottom ash samples.

UWAG did not ask members to measure the TSS concentration in the source water.

Some plants provided source water TSS con centrations, and those were provided in

the Certificates of Analysis in Attachment 9 of the UWAG Comments. In response to

EPA’s questions, UWAG gathered additional information on the TSS for some of the

subject plants which is provided in Attachment 1.

9. Please provide a more detailed descriptio n of the “sampling method” field, as

well as a description for each of the id entifiers included in the spreadsheet (e.g.,

“multiple grabs & composited,” “settled”). In addition, please provide duration

and frequency information for compos ite sampling (e.g., 24-hour composite

collected every hour).

The description of the sampling method pr ovided to EPA in Attachment 7 of the

UWAG Comments was not entirely clear. The supplemental information provided in

Attachment 1 should clarify the descri ption of the sampling location and its

relationship to the solids separati on process and treatment (if any).

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 9

Some of the data for the indi vidual plants are averages of single grab samples taken at

different units and/or differ ent days. Some of the data represent composite samples

composed of grab samples taken over the bottom ash sluicing period. Attachment 1

provides the duration and frequency for the composite samples.

10. For each plant, please describe any atyp ical operations occurring at the plant at

the time of sampling (e.g., test bum of new coal).

No abnormal conditions were noted during sample collection except for one sample

of bottom ash pond effluent collected from Plant 12. This sample was collected

during the excavation of the ash pond a nd does not represent normal treatment by

settling. However, this sample was incl uded in the averages provided to EPA for

Plant 12.

11. For each plant, please provide the flow rate of the wastewater at the time of

sampling, as well as the average annual bottom ash discharge flow rate.

UWAG did not request that its participati ng members measure flow rate at the time

of sample collection. Plants 12, 14, and 15 provided the average annual bottom ash

discharge flow rates on their Form 2Cs, wh ich were submitted as part of Attachment

8 to the UWAG Comments. In respons e to EPA’s questions, UWAG gathered

additional information on the average annual flow rates and provided it in

Attachment 1.

12. Do any of these data correspond to data included in EPRI PISCES reports? If

so, please identify which Plant ID and the corresponding PISCES report.

UWAG’s bottom ash transport water characterization data is entirely distinct from the

data in the EPRI PISCES reports.

13. A previous version of the table include d in Attachment 7 was provided to the

Small Business Association (SBA) during interagency review of the proposed

steam electric ELGs. There, the table in cluded a footnote “Note 1 - Multiple

grabs of bottom ash sluice water were sa mpled throughout the sluicing period

and composited. Then, the composite was a llowed to settle at least one hour prior

to sampling the supernatant.” Please iden tify which, if any, plants used this

procedure for collecting the samples. Pl ease provide justification that the

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 10

approach described in Note 1 is comparab le to the actual performance expected

in the surface impoundments at the plants for whic h the samples represent.

Only ash pond effluent samples from plants with primarily bottom ash transport water

were included in the UWAG data. The sa mpling approach described in the table’s

footnote (Note 1) was the recommended UW AG protocol provided to plants that

commingle fly ash water, cooling water or FGD wastewater in the same pond as the

bottom ash water. The ash pond effluent from these plants (i.e., plants that treat fly

ash, bottom ash and cooling water in the sa me pond) would not be representative of

bottom ash transport water. Plants that used the UWAG protocol were 3, 9, 10, 11, 20

and 21. Plants 1, 2, 4, 5, 6 and 7 also collected bottom ash sluice water samples at the

end of the pipe prior to entering the pond for the same reason; however these samples

were grabs instead of composite samples. UWAG believes that th e data representing

settled bottom ash sluice water collected at the end of the sluice pipe prior to entering

the pond are comparable to the actual treatment performance expected from a bottom

ash settling pond (i.e., bottom ash pond effluent). Additional data will be submitted to

EPA in the near future to demonstrate that this sampling approach is comparable to the

actual performance expected in the surface impoundments.

In addition, the bottom ash sluice wate r data collected for the UWAG Comments

contain more quantified data (i.e., data a bove the quantification limits) than the bottom

ash effluent data taken fro m the Form 2Cs. The Form 2C data contain more nondetect data and the detection limits for some of the pollutants, such as silver, are much

higher than the detections limits reported for the bottom ash sluice water data.

Therefore, the average concentrations for some of the pollutants in the effluent

samples are artificially higher. Howeve r, to be conservative, UWAG used the

detection limit value to calculate the average concentrations.

14. In addition, the data provided in Attachment 7 differs from the data included in

the previous version of the table submitte d to SBA (described in Question 12) for

Plants 2, 15, and 21. Please provide an explanation for the differences between

these reported values.

The table provided for the OMB meeti ng (which was labeled “Draft”) was

preliminary. As UWAG continued to review and collect data, it updated the table.

Thus, the preliminary table is different from the one submitted as an attachment to the

UWAG Comments. A more detail ed explanation of the change s to the data for Plants

2, 15, and 21 is provided below.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 11

Plant 2 – The data in the draft table repres ent one bottom ash slui ce water grab sample

collected at the end of the sluice pipe pr ior to entering the pond. The final data

submitted with the UWAG Comments represent an average of three bottom ash sluice

water grab samples collected on the sa me day and analyzed separately.

Plant 15 – UWAG replaced the data in the draf t table with another se t of data from the

same plant because the Certifi cate of Analysis could not be found to validate the data

provided to UWAG. The data provided in the UWAG Comm ents represents a bottom

ash pond effluent sample that was report ed in the Form 2C permit application.

Plant 21 – The data in the draft table are an average of four bottom ash sluice water

composite samples collected at the end of the sluice pipe prior to entering the pond.

The data submitted with the UWAG Comments are an average of six composite

samples, including the original four samples. The Certificates of Analysis for all six

composite samples were provided in Attachment 8 of the UWAG Comments

.

Sulfides Data

EPA estimated that sulfides in botto m ash transport water accounted for 1,587,993

TWPEs per year which accounts for 58% of the total TWPEs for bottom ash transport

water. This level of loading –if it were true –would make sulfides the largest

contributor of TWPEs for bottom ash transp ort water by far. As part of EPA’s

Sensitivity Analysis Evaluating the Effect of Nondetect Results in the Ash Loadings

Model, April 19, 2013 (DCN SE03882), EPA looke d at the change to the baseline ash

loadings if sulfide was excluded from the ash loadings. EPA considered the impacts

of the limited sulfide data when evalua ting bottom ash loadin gs. If EPA had

eliminated the sulfide data, its conclusi on on bottom ash transport water would have

been very different. As explained in UWAG’s Comments, EPA’s sulfides TWPEs do

not withstand scrutiny. In brie f, here are the reasons why.

1. EPA chose three sulfide values from Form 2C data that were oste nsibly “detected.”

These three values are the basis for all of EP A’s sulfide estimates. But for each of the

three samples, the Form 2C provided corre sponding source water data that indicated

sulfide was also present in the river water at essentially the same concentrations.

Since sulfide is formed onl y under anoxic conditions, the intake results were most

likely false positives, probably due to analytical interferences, and thus the effluent

sulfide results are likel y false positives too.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 12

2. Some plants aerate their discharges prio r to or at the discharge point to further

increase the oxygen content of the water, and in other ca ses the construction of the

discharge point is such that aeration of the discharge is increased. In these cases,

sulfides are unlikely to be present in ash pond discharges.

3. There are documented problems with false positives from some sulfide analytical

methods, as explained in the UWAG Commen ts. For example, the most commonly

used analytical methods for sulfides ar e colorimetric methods, Method 376.2 and the

20 th 

# Ed. SM-4500-S2 D. The colorimetric me thods have lower de tection limits than

other methods, but can produce false positiv e results due to various types of

interferences, most notably turbidity and total suspended solids.

UWAG decided to analyze for sulfides in ash ponds to determine if it is a common

pollutant. The results of our analyses are pr esented in Attachment 5 of our comments.

As stated in Attachment 5, we believe this study conclusively refutes the EPA estimate

of average concentrations of sulfide up to 1 mg/L being consistently discharged from

ash ponds.

The evidence suggests that sulfide is in fact not present at all in the ponds. High

dissolved oxygen was found in all of the sa mples associated with the ash transport

process, including the ponds themselves. Since sulfides form only in anoxic

conditions, the presence of high dissolved oxygen is further pr oof that sulfides are not

present.

Additionally, the titration and field colorimetric results were all below the detection

limit. Even with the colorimetric analysis, there were no results above the laboratory

quantitation limit and the same “J” flagged detections were also reported for the

upstream river water. When EPA evaluate d its own data for other pollutants, it

considered values below the laboratory qua ntitation limit to be non-detected results.

Below we respond to EPA’s questions about UWAG’s sulfide data

.

1. Please prov id e the plant name and plant location associated with each plant ID

identified in Attachment 5. In add ition, plea se provide the Pond / Imp o undment

Unit ID (e.g., SPD- 2) for th e sa mpl ed pond, as reported in th e Q u estion n aire for

th e Steam E l ec tric E fflu ent Guide lin es.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 13

In consultation with our members, we have provided as much data as possible in

response to EPA’s questions. See Attachment 2.

2. What are th e curre nt sol id s sepa ration processes and tr ea tm ent procedures

e mplo ye d at each power plant for which data are provided ? Please identify if

these so lid s separa tion proces ses a n d/or treatment procedures are lo ca t ed

up s tream or downstream of the sample location. For each plant

, please identify

what, if any

, chemicals are added to the wastewater upstream of the sample

location.

All nine plants sampled for sulfides use settling ponds for solids separation. Plant M1

uses a dewatering bin followed by a settli ng pond to remove bottom ash. Two plants

(Plants E1 and G1) add ferric chloride to th e ash pond to aid in me tals removal. The

remaining seven plants do not use any ch emical addition. See Attachment 2 for

information regarding the sampling location and its relationship to the solids

separation process and chemical treatment.

3. From whic h plant s/c ompanies did UWAG r eq u est s ulfide characterization data ?

What c ri ter i a were u se d t o ident i fy the 9 pla nts chosen for sa mpling ?

UWAG made a general request to all members to offer ash ponds for sulfides testing.

Nine plants volunteered to conduct the sampling and send the samples to the selected

laboratory (Empirical Laborator ies) for analyses. Empirical agreed prior to sampling

to perform all of the sulfide analyses a nd interference removal procedures requested,

including the selective ion electrode method.

4. What is the depth

, volume, and residence time for the s urface i m po u ndmen t s

from w hi ch sa mple s were co ll ected?

UWAG did not request the depth, volume , and residence time for the surface

impoundments sampled for sulfides. Some of this information may be available in

responses to EPA’s ICR. The pond’s resi dence time and the original and current

pond/impoundment dimensions can be found in the plant’s response to ICR, Questions

D4-2 and D4-3, respectively. Table D- 5 includes volume, surface area, bottom

elevation, top elevation, freeboa rd height, etc. for the pond.

# Ms. Jezebele Alicea-Virella

August 1, 2014

Page 14

5. For each plant, p l ease provide furt h e r additional detail s regardi n g the sa mpling

location s.

a. Source water

i. Please specify th e l ocat i on of the source water sa mp l es pro v ided

(e.g., Ohio River upstream of plant

, Ohio River at point of intake to

plant (note if intake is upstream o r downstream of plant

di sc harges)

, piping prior to mixing with bottom ash).

ii. I s intak e water treat e d prior to use in the bottom ash sluicing

syste m ? I f so, please describe the treatment proce ss.

iii. Does the plant recycle any process was t ewate r for u se in the bottom

as h s l uicing syste m ? If so, how ?

See Attachment 2 for information requested regarding the specific sampling location

of the source water samples. None of the source water samples were treated prior to

use in the bottom ash sluicing system. Only one of the nine plants uses process

wastewater in the bottom ash sluicing syst em. Plant M1 recycles ash pond water for

sluicing ash and uses river wa ter as makeup to the system.

b

. Bottom a s h transport water

i. Please specify th e l ocat i on of the bottom ash sa mp l e pro v ided for

Plants D1, D2, D3, and D4 (e.g., ash pond near effluent).

ii. For ash pond effluent samples, please identify all wastestreams that

enter the ash pond and their relative contribution (flow rates,

pollutant concentrations, and pollu tant mass loads) to the pond.

iii. Please identify which ash pond samples were collected at a depth

near the bottom of the pond and the depth at which the sample was

collected.

See Attachment 2 for information requested regarding the specific sampling location

of the ash pond samples. UWAG did not request flow rates, pollutant concentrations,

and mass loads for wastestreams that en ter the ash pond; howev er, as noted in

Attachment 2, we have collected some a dditional information in response to EPA’s

questions. For the samples collected in the middle of the pond, the samples were

collected about 1-2 feet below the surface of the pond.

# HUNTON& 

# WILLIAMS

Ms. Jezebele Alicea-Virella

August 1, 2014

Page 15



# 6. For each plant, please describe any atypical operations occurring at the plant at

the time of sampling (e.g., test burn of new coal).

No atypical operations were noted during sample collection.



# 7. For each plant, please provide the flow rate of the wastewater at the time of

sampling, as well as the average annual bottom ash discharge flow rate.

UWAG did not request that the volunteer facilities measure flow rate during the

sampling event or provide average annual bottom ash discharge flow rates. Average

flow rates for 2009 can be found in the ICR. However, the flow rates in the ICR may

not be typical of the flow rates at these facilities. Due to decreased operations of coalfired plants due to the competitive natural gas prices, the flow rates may have

decreased significantly.



# 8. Please explain the meaning of the asterisk(*) next to "Field Sulfide" in Field Test

Data Table 1.

The asterisk refers to the footnote at the bottom of the table. The asterisk was

inadvertently left off the footnote. "Field Sulfide" indicates that sulfide was analyzed

in the field using a LaMotte Sulfide Field Test Kit in accordance with SM 4500S2D.

# ~[~

Elizabeth E. Aldridge

Attachments

29142.070312 EMF 

# _us 51536421v3*Allinformationincolumslabeled"CBI"isconfidentialbusinessinformationAttachment1BottomAshTransportWaterDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantNumberCBIPlantNameCBICompanyCBIStateCBIICRPlantIDCBIICRPondSPD#BATW‐SamplingLocation BATW‐SampleRepresentationCBIAnnualAverageFlowRate(MGY)BA‐SolidsSeparationProcessChemicalsAddedUpstreamofSampleLocation1 WidowsCreek TVA AL 6257 SPD‐1 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWater1219MGYbottomashsluiceflowratefortotalplantin2009Settling None2 BullRun TVA TN 9481 SPD‐1 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWater241MGYbottomashsluiceflowratefortotalplantin2009Settling None3 Yates GeorgiaPower GA 6370 SPD‐2 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWater277MGYbottomashsluiceflowratefortotalplantin2009Settling None4 ECGaston AlabamaPower AL 928 SPD‐1 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWater390MGYbottomashsluiceflowratefortotalplantin2009Settling None5 Gorgas AlabamaPower AL 4599 SPD‐6 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWater450MGYbottomashsluiceflowratefortotalplantin2009Settling None6 GreeneCounty AlabamaPower AL 6368 SPD‐1 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWater201MGYbottomashsluiceflowratefortotalplantin2009Settling None7 Crist GulfPower FL 4702 SPD‐1 HydrobinEffluent/PondInfluent SettledBottomAshSluiceWater197MGYbottomashsluiceflowratefortotalplantin2009Hydrobin/Settling None8 Kammer AEP WV 2149 SPD‐1 BAPondEffluentSamplerepresentsbottomashpondeffluent.Nootherwastestreamsenterthebottomashpond.Bottomashponddischargemaximumdesignflowrateof4.32mgdSettling None11 Monroe DTE MI 4533 SPD‐4 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWater430MGYbottomashsluicewaterflowratefortotalplantin2009Settling None12 RattsGeneratingStationHoosierEnergy IN 2314 1 BAPondEffluentSamplerepresentsbottomashtransportwater.Infrequently:Coalpilerunoff;metalcleaningwastes.0.282MGY Settling None13 RiverRougeDTEMI 9120 Pond1 BAPondEffluentSamplerepresents90%bottomashsluicewaterand10%flyashsilowashdown.Infrequently:non‐chemicalmetalcleaningwastesaredischargedintoPond1abouttwiceayear.Atthetimethesamplewascollected,therewasnorecentnon‐chemicalmetalcleaningwasteinputtothebasin.180MGYbottomashsluicewaterflowratefortotalplantin2009Hydrobins(dewatering)followedbySettlingNone14 Meredosia Ameren IL 4764 2 BAPondEffluentBASluice‐0.238mgd,AshHopperWaterSeals‐0.664mgd,Heatexchanger‐0.798mgd,BoilerRoomSumpsandDrains‐0.684mgd,variousotherLVWStreams‐intermittentflows2.4 SettlingAnionicpolymer,cationicpolymer,sulfuricacidDocID#510447701*Allinformationincolumslabeled"CBI"isconfidentialbusinessinformationAttachment1BottomAshTransportWaterDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantNumberCBIPlantNameCBICompanyCBIStateCBIICRPlantIDCBIICRPondSPD#BATW‐SamplingLocation BATW‐SampleRepresentationCBIAnnualAverageFlowRate(MGY)BA‐SolidsSeparationProcessChemicalsAddedUpstreamofSampleLocation15 SiouxEnergyCenter Ameren MO 8902 1 BAPondEffluentBASluice‐4.35mgd,DrainSump‐0.535mgd,stormwaterrunoff‐0.078mgd,otherIntermittantflows4.97 Settling None16 Burlington AlliantEnergy IA 189 SPD‐4 BAPondEffluent(Outfall001)Bottomashandeconomizerashsluice(2.87mgd),FloorDrainsandROReject(0.12mgd),AshSealSystem(0.684mgd).Infrequently:StormwaterRunoff(1.07mgd),CoalPileRunoff(0.394mgd),RinsatefromChemCleaning(0.02mgd).Bottomashdischargeflowrate:1277MGYSettling None17 Dubuque AlliantEnergy IA 1754 SPD‐1 BAPondEffluent(Outfall002)Primarilycomposedofbottomashsluicewaters‐0.091mgdaverageflowfor365daysperyear.Stormwaterrunoff(10yrstormeventonly).Bottomashdischargeflowrate:14.0MGYConcretebottomashbasinfollowedbysettlingpondCoagulantaddedpriortoashbasintoaidinsolidssettling18 Kingston TVATN 265 SPD‐1 EndofBASluicePipe/PondInfluent SettledBottomAshSluiceWaterBottomashsluicewaterflowrate:583MGYin2009Settling NoneDocID#510447702*Allinformationincolumslabeled"CBI"isconfidentialbusinessinformationAttachment1BottomAshTransportWaterDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantNumberCBIPlantName1 WidowsCreek2 BullRun3 Yates4 ECGaston5 Gorgas6 GreeneCounty7 Crist8 Kammer11 Monroe12 RattsGeneratingStation13 RiverRouge14 MeredosiaTreatmentlocationinrelationtosamplinglocationBATW‐CompositeorGrabBATW‐SamplingMethodCBIBATW‐SamplingDuration&FrequencyBATW‐NumberofSamplesUsedinAverageCBIBATW‐SamplingDate(s)BATW‐TSS(ppm)AtypicalOperationsatTimeofSamplingCoalTypeCBISourceWater(Noteifanyprocesswaterisused.)RecycleBATW?SourceWater‐CompositeorGrabSampleSampleswerecollectedatendofthebottomashsluicepipepriortoenteringthepond.Treatmentissettlingponddownstreamofsamplepoint.Grab GrabGrabsamplestakenfromtwoseparateunits2 09/14/2010190ppm‐settledBAsluicewaterNonenoted Bituminous RiverWater No GrabSampleswerecollectedatendofthebottomashsluicepipepriortoenteringthepond.Treatmentissettlingponddownstreamofsamplepoint.Grab Grab Singlegrabsamples 3 03/24/2010585ppm‐settledBAsluicewaterNonenoted BituminousOnce‐ThroughCondenserCoolingWaterNo GrabSampleswerecollectedatendofthebottomashsluicepipepriortoenteringthepond.Treatmentissettlingponddownstreamofsamplepoint.Composite UWAGProtocol14grabsamplescollectedover55minutesluiceperiod1 01/11/201231ppm‐settledBAsluicewaterNonenoted Bituminous ChattahoocheeRiver No GrabSampleswerecollectedatendofthebottomashsluicepipepriortoenteringthepond.Treatmentissettlingponddownstreamofsamplepoint.Grab GrabSinglegrabsamplesonmultipledaysfromseparateunits63/8/2011(2samplesfromdifferentunits),3/10/2011(1unit),7/5/2011(3samplesfromdifferentunits)Notanalyzed Nonenoted Bituminous CoosaRiver No GrabSampleswerecollectedatendofthebottomashsluicepipepriortoenteringthepond.Treatmentissettlingponddownstreamofsamplepoint.Grab GrabSinglegrabsamplescollectedfrom2separateunits3 8/30/2011,8/31/2011Notanalyzed Nonenoted Bituminous BlackWarriorRiver No GrabSampleswerecollectedatendofthebottomashsluicepipepriortoenteringthepond.Treatmentissettlingponddownstreamofsamplepoint.Grab GrabSinglegrabsamplescollectedfrom2separateunits2 08/24/2011 Notanalyzed Nonenoted Bituminous BlackWarriorRiver No GrabSamplewascollectedatthehydrobineffluentpriortoenteringthepond.Treatmentisdewateringbinandsettlingponddownstreamofsamplepoint.Grab Grab Singlegrabsample 1 04/25/20126ppm‐HydrobineffluentNonenoted Bituminous EscambiaRiver No 24‐hourcompositeBottomashpondeffluentsampleswerecollectedfromtheendofthepipeleavingthebottomashpond. GrabTwosinglegrabsamplesusingcleanhands,dirtyhandproceduresTwosinglegrabsamples 2 10/09/2012 Notanalyzed NonenotedBituminousOhioRiver No GrabSamplewascollectedpriortoanytreatment.Collectedatendofbottomashsluicepipepriortoenteringtheashbasin.Composite UWAGProtocol12grabs(~1000mlea)overonehourperiod1 11/05/2012Notanalyzed;13ppmmonthlyaveragein2013Nonenoted SubbituminousLakeErie No SingleGrabSampleswerecollectednearthebottomashpondeffluent.Grab Grab Singlegrab Varies1‐32 9/2008‐12/2009 81of19Hgsampleswasabnormallyhigh(Oct‐07)duetocontractoractivitiesBituminousWhiteRiverNo GrabSamplewascollectedfromthedischargeweirofPond1.TheplantusesdewateringbinspriortodischargingbottomashsluicewatertoPond1.Composite Composite Informationnotavailable 1 11/28/2001 Notanalyzed Nonenoted BituminousDetroitRiverYes,abouthalfofthePond1dischargeisrecycledforBAsluicewaterSingleGrabSamplecollectedaftersettling.Sulfuricacidisaddedapproximately25feetfromeffluentweir.Polymersaddedattheinfluenttotheimpoundment.Grab Grab Singlegrab 1 03/23/2010 7.6 Nonenoted Subbituminous IllinoisRiver NoCompositeconsistingof8grabsduring16‐hourperiodDocID#510447703*Allinformationincolumslabeled"CBI"isconfidentialbusinessinformationAttachment1BottomAshTransportWaterDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantNumberCBIPlantName15 SiouxEnergyCenter16 Burlington17 Dubuque18 KingstonTreatmentlocationinrelationtosamplinglocationBATW‐CompositeorGrabBATW‐SamplingMethodCBIBATW‐SamplingDuration&FrequencyBATW‐NumberofSamplesUsedinAverageCBIBATW‐SamplingDate(s)BATW‐TSS(ppm)AtypicalOperationsatTimeofSamplingCoalTypeCBISourceWater(Noteifanyprocesswaterisused.)RecycleBATW?SourceWater‐CompositeorGrabSampleSamplecollectedaftersettling.Nochemicaltreatment.Composite CompositeEightflow‐proportionalgrabsduring24hourperiod1 05/29/2008 54 Nonenoted SubbituminousMississippiRiver NoCompositeconsistingof4grabsduring12‐hourperiodSampleswerecollecteddownstreamofsettlingpond.CompositeAutomatedSampler24‐hourcomposite(multiplegrabsat15minuteintervals)1 11/10/201031.04(long‐termaverage)Nonenoted Subbituminous(PRB)MississippiRiver;34,000GPDofexcessboilermakeupandboilerblowdownisincorporatedintobottomashsluicingsystemNo CompositeNochemicaladditivesused.Howeveracoagulantisinjectedupstreamofashpondtoaidinsolidssettling.Samplewascollecteddownstreamofsolidssettling.CompositeAutomatedSampler24‐hourcomposite(multiplegrabsat15minuteintervals)1 03/07/20076.45(long‐termaverage)Nonenoted Subbituminous(PRB) MississippiRiver No CompositeSampleswerecollectedatendofthebottomashsluicepipepriortoenteringthepond.Treatmentissettlingponddownstreamofsamplepoint.Grab GrabGrabsamplestakenfromtwoseparateunits2 08/26/2010 12 NonenotedE.Bit/Subbit(PRB)50‐50BlendRiverWater No GrabDocID#510447704*Allinformationincolumslabeled"CBI"isconfidentialbusinessinformationAttachment1BottomAshTransportWaterDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantNumberCBIPlantName1 WidowsCreek2 BullRun3 Yates4 ECGaston5 Gorgas6 GreeneCounty7 Crist8 Kammer11 Monroe12 RattsGeneratingStation13 RiverRouge14 MeredosiaCBISourceWater‐SamplingDateSourceWater‐SamplingLocationIntakeWaterUpstreamofPlantDischarges?SourceWater‐TreatmentSourceWater‐TSS(ppm)09/14/2010AttheintaketunnelsupstreamofthecondensersNo,downstreamofplant'sprimarywastewaterdischargeNotreatment 2.503/24/2010AttheintaketunnelsupstreamofthecondensersYes Notreatment 6.601/11/2012TapattheservicewatertankYes Notreatment 6NotavailableRiverintake,upstreamofplantYes Notreatment NotanalyzedNotavailableRiverintake,upstreamofplantYes Notreatment NotanalyzedNotavailableRiverintake,upstreamofplantYes Notreatment Notanalyzed04/25/2012Riverintake,upstreamofplantYes Notreatment 1110/09/2012Plantintake,upstreamofdischargesexceptsewagetreatmentdischargeYes,exceptsewagetreatmentdischargeNotreatment Notanalyzed11/05/2012Plant'sintakebayjustpriortogeneralservicewaterpumpYes Notreatment Notanalyzed9/2008‐12/2009 RiverwaterintakeAllprocesswastewaterdischargesdownstreamofintake.Onestormwaterdischargeupstreamfromparkinglot/roads.Notreatment Notanalyzed11/28/2001Plant'sintakebayjustpriortogeneralservicewaterpumpYes Notreatment Notanalyzed03/23/2010 Plantrawwaterintake Yes Notreatment 15DocID#510447705*Allinformationincolumslabeled"CBI"isconfidentialbusinessinformationAttachment1BottomAshTransportWaterDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantNumberCBIPlantName15 SiouxEnergyCenter16 Burlington17 Dubuque18 KingstonCBISourceWater‐SamplingDateSourceWater‐SamplingLocationIntakeWaterUpstreamofPlantDischarges?SourceWater‐TreatmentSourceWater‐TSS(ppm)05/29/2008RawwatertreatmentinfluentNo,however87xdilutionfromtheMississippiRiverNotreatment 8711/09/2010 Riverwaterintake Yes Notreatment 7603/07/2007 Riverwaterintake Yes Notreatment 31608/27/2010Once‐ThroughCondenserreturnculvertNo,downstreamofplant'sprimarywastewaterdischargeNotreatment 1.8DocID#510447706*Allinformationincolumnslabeled"CBI"isconfidentialbusinessinformationAttachment2SulfidesDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantIDCBIPlantNameCBIPlantICRIDCBICompanyCBIStateCBISPDIDSolidsSeparationProcessSPDDepth(ft)CBISPDVolume(ft3)CBISPDResidenceTime(days)AshTransportWater‐SulfideSamplingLocationSamplingLocationinrelationshiptosolidsseparationChemicalAdditionUpstreamofSamplingLocation?CBISampleCollectionDateA1KygerCreek AEP OH SPD‐1 Settling NA NA NA EndofBASluicePipe/PondInfluent Sampledbeforesolidsseparation None 06/24/2013A1KygerCreek AEP OH SPD‐1 Settling Varies 3,515,200 15.29 BAPondNearEffluentSampledaftersolidsseparationpriortomixingwithanyotherwastestreamsNone 06/24/2013A1KygerCreek AEP OH SPD‐2 Settling NA NA NA EndofFASluicePipe/PondInfluent Sampledbeforesolidsseparation None 06/24/2013A1KygerCreek AEP OH NA NA NA NA NA SourceWater NA NA 06/24/2013E1ECGaston APC AL NA NA NA NA NA SourceWater NA NA 06/24/2013E1ECGaston APC AL SPD‐1 Settling NA NA NA EndofBASluicePipe/PondInfluent Sampledbeforesolidsseparation None 06/24/2013E1ECGaston APC AL SPD‐1 Settling NA NA NA EndofFASluicePipe/PondInfluent Sampledbeforesolidsseparation None 06/24/2013E1ECGaston APC AL SPD‐1 Settling NA NA 1.3 AshPond‐MiddleofPond Sampledinthemiddleofashpond Yes,FeCl3 06/24/2013E1ECGaston APC AL SPD‐1 NA Notavailable 499million 1.3 AshPondNearEffluentSampledaftersolidsseparationpriortomixingwithanyotherwastestreamsYes,FeCl3 06/24/2013M1Miller APC AL NA NA NA NA NA SourceWater NA NA 06/25/2013M1Miller APC AL NAHydrobin/SettlingNA NA NA HydrobinOverflow/PondInfluentSampledafterthehydrobinbutpriortotheashpondNone 06/25/2013M1Miller APC AL SPD‐4 Settling NA NA NAEndofEconomizerAshSluicePipe/PondInfluentSampledbeforesolidsseparation None 06/25/2013M1Miller APC AL SPD‐4 Settling NA NA NA AshPond‐MiddleofPond Sampledinmiddleofashpond None 06/25/2013M1Miller APC AL SPD‐4 NA Notavailable 593million 5 AshPondNearEffluentSampledaftersolidsseparationpriortomixingwithanyotherwastestreamsNone 06/25/2013G1Gorgas APC AL NA NA NA NA NA SourceWater NA NA 06/25/2013G1Gorgas APC AL SPD‐6 Settling NA NA NA EndofBASluicePipe/PondInfluent Sampledbeforesolidsseparation None 06/25/2013G1Gorgas APC AL SPD‐6 Settling NA NA NA EndofFASluicePipe/PondInfluent Sampledbeforesolidsseparation None 06/25/2013G1Gorgas APC AL SPD‐6 Settling NA NA NA AshPond‐MiddleofPond Sampledinthemiddleofashpond None 06/25/2013G1Gorgas APC AL SPD‐6 Settling Notavailable 468million 3+ AshPondNearEffluentSampledaftersolidsseparationpriortomixingwithanyotherwastestreamsYes,FeCl3 06/25/201392814934599771DocID#510447841*Allinformationincolumnslabeled"CBI"isconfidentialbusinessinformationAttachment2SulfidesDataSummarySheetCONTAINSCONFIDENTIALBUSINESSINFORMATION*PlantIDCBIPlantNameA1KygerCreekA1KygerCreekA1KygerCreekA1KygerCreekE1ECGastonE1ECGastonE1ECGastonE1ECGastonE1ECGastonM1MillerM1MillerM1MillerM1MillerM1MillerG1GorgasG1GorgasG1GorgasG1GorgasG1GorgasForeffluentsamples,identifywastestreamsthatcontributetoashponddischargeandpercentcontributionCBIAverageAnnualBottomAshSluiceWaterFlowRate(MGY)CBISourcewaterusedforSluicingSourceWater‐SamplingLocationSourceWaterSamplingLocationUpstreamofPlantDischarge(s)?SourceWaterTreatedPriortoUseinSluicing?RecycleAnyProcessWaterforUseinAshSluicing?AtypicalOperationsDuringSampling?NA 791MGY OhioRiver NA NA NA No NonenotedBAsluicewateristheonlywastestreamthatdischargesintothebottomashpondcomplex.NA OhioRiver NA NA NA No NonenotedNA NA OhioRiver NA NA NA No NonenotedNA NA OhioRiver Intakeatriver NA None NA NonenotedNA NA CoosaRiver Intakeatriver Yes None NA NonenotedNA389MGY CoosaRiver NA NA NA No NonenotedNA2474MGY(FlyashSluiceWater)CoosaRiver NA NA NA No NonenotedNA NA CoosaRiver NA NA NA No NonenotedFlyashsluicewater(74%),bottomashsluicewater(8%),coolingwater(10%),FGDwastewater(1%),coalpilerunoff(1%),stormwater(5%),other(1%)NA CoosaRiver NA NA NA No NonenotedNA NAMulberryForkRiverisusedformakeupServicewatertapaftertheservicewaterpondNAServicewaterholdingpondNA NonenotedNA 445MGY Ashpondwater NA NA NAYes,ashpondwaterusedforsluicingashNonenotedNA476MGY(EconomizerAshSluiceWater)Ashpondwater NA NA NAYes,ashpondwaterusedforsluicingashNonenotedNA NA Ashpondwater NA NA NAYes,ashpondwaterusedforsluicingashNonenotedFlyashsluicewater(38.5%),bottomashsluicewater(29%),coolingwater(5%),FGDwastewater(8.4%),coalpilerunoff(0.7%),leachate(2%),other(16.3%)NA Ashpondwater NA NA NAYes,ashpondwaterusedforsluicingashNonenotedNA NA WarriorRiver Intakeatriver Yes None NA NonenotedNA 450MGY WarriorRiver NA NA NA No NonenotedNA1812MGY(FlyashSluiceWater)WarriorRiver NA NA NA No NonenotedNA NA WarriorRiver NA NA NA No NonenotedFlyashsluicewater(21%),bottomashsluicewater(21%),FGDwastewater(1%),coalpilerunoff(1%),stormwater(13%),other(43%)NA WarriorRiver NA NA NA No NonenotedDocID#510447842