HUNTON 

WilliAMS 

November 25,2014 

VIA ELECTRONIC MAIL AND OVERNIGHT DELIVERY 

Mr. Ronald Jordan 

Engineering and Analysis Division 

EPA Headquarters 

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N.W. 

Mail Code 4303T 

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: ealdridge@hunton.com 

FILE NO: 29142.070312 

RE: Steam Electric Effluent Guidelines Rulemaking: Additional Bottom Ash 

Transport Water Data 

Dear Ron: 

As discussed in our September 10 meeting, the Utility Water Act Group (UWAG) has 

collected and analyzed additional samples of bottom ash transport water (BATW), and we are 

submitting those analyses with this letter. See Attachment 1 for all sample characterization 

data, and Attachment 2 for certificates of analyses and chain of custody forms for each 

sample. We request that you consider these analyses and this letter as you work to finalize the 

revised steam electric effluent limitations guidelines. 

These new data support UW AG' s position that further regulating BATW is not cost 

effective. Some of the ponds sampled are dedicated bottom ash ponds, and some receive a 

variety of typical wastewaters in addition to BATW. The pollutant loading exiting both types 

of ponds is very low, which results in a very high cost per toxic-weighted pound equivalent 

(TWPE) removed. 

1. Sampling Methodology 

UWAG collected BATW samples from the following facilities: 

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 
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Table 1. Summary of Facilities Sampled 

Facility State Date Sampled Coal Type 

AEP/Kammer wv 4/2/14 Bituminous 

OVEC/Kyger Creek OH 4/2/14 Bituminous 

Indiana Michigan IN 6/4/14 Bituminous Power/Tanner's Creek 

Mississippi Power/Daniel MS 7/31114 Bituminous/ 

Sub bituminous 

Great River Energy/Stanton ND 8/5/14 Powder River 

Basin 

Hoosier Energy/Ratts IN 8/27114 Bituminous 

The plant information sheets (Attachment 3) contain additional background and operational 

data regarding each of the facilities sampled, including source waterbody, capacity, and 

bottom ash pond characteristics such as depth, volume and estimated residence time. One of 

the facilities, Daniel, recycles its bottom ash pond effluent for use as sluice water. 

UWAG believes the data from the six bottom ash ponds sampled are representative of 

BATW characteristics for the industry as a whole. Three of the ponds are used to treat 

wastewaters other than BATW, including coal pile runoff, metal cleaning wastes, and low 

volume wastes. Two of the three ponds used to treat other wastewaters also receive mill 

rejects. 1 The table below describes the wastewaters received by these three ponds. 

Table 2. Wastewaters Treated in Bottom Ash Ponds 

Facility Other Wastewater Entering Pond 

Boiler Blowdown 

Filter Backwash 

Mill Reject Sluice 

Stanton Ion Exchange wastewater 

Boiler Seal wastewater 

Coal Pile Runoff 

Bottom Ash Sluice 

1 Mill rejects are dense materials found in coal that are too hard to be ground by the mills to the desired 

size for burning in the boilers. This material may include scrap steel, hard coal, rocks with quartz, and iron 

sulfide minerals such as pyrite and marcasite. 
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Facility 

Daniel 

Ratts 

Other Wastewater Entering Pond 

Storm water 

Coal Pile Runoff 

Ash Landfill Storm water 

Boiler Tube Cleaning wastewater 

Ion Exchange wastewater 

Combined Cycle Unit wastewater 

Combined Cycle Oil/Water Separator 

wastewater 

Yard Drain Wastewater 

Boller Blowdown 

Sewage Treatment 

Mill Rejects 

Bottom Ash Sluice 

Coal Pile Runoff 

Bottom Ash Sluice 

In addition to Stanton and Daniel, Kyger Creek and Tanner's Creek also sluice or 

place mill rejects in their bottom ash ponds. The Tanner's Creek and Stanton mill rejects are 

pyritic; it is unknown whether Kyger Creek's and Daniel's mill rejects are pyritic. 

At each facility, the sampling team collected samples at three locations: at the source 

water (SP-1 ), at the bottom ash sluice pipe prior to entering the pond (SP-2), and at the bottom 

ash pond near the effluent (SP-3). For each facility, the three samples were collected on the 

same day. For SP-1 and SP-3, we collected single grab samples. For SP-2 (bottom ash sluice 

pipe sample prior to entering the pond), we collected composite samples from multiple grabs 

over the sluicing period. To collect the bottom ash sluice pipe samples, once the sluicing 

cycle began, the sampling team waited until all the clear water in the sluice pipe was flushed 

out and there was a visible presence of ash within the water leaving the pipe. The team 

collected grab samples at regular periods throughout the sluicing cycle, composited them, and 

allowed the composited sample to settle for a minimum of one hour. The team then collected 

the supernatant of the composite sample for analysis. 

The experienced sampling crew used clean sampling in accordance with EPA Method 

1669 for the collection of metals and mercury. The conventional samples were properly 

preserved and chilled to< 6°C. As required for EPA Method 1631E, mercury field blanks 
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were collected at each sampling location. At locations SP-1 (source water) and SP-3 (bottom 

ash pond near the discharge), metals field blanks were collected. 

The sampling crew took field measurements of pH, conductivity, temperature, 

dissolved oxygen, and sulfide at each sampling location. A Hach Model HQ40d portable 

multi-meter was used to measure pH, conductivity, temperature, and dissolved oxygen.

2 

Certified reference standards were used for calibration of pH and conductivity, and check 

standards were analyzed prior to each measurement to ensure proper calibration. 

The crew used a LaMotte 4456-01 sulfide test kit to test for sulfides. This kit is 

comparable to EPA Method 376.2 and measures down to 0.2 ppm sulfide. See Attachment 3 

for all field measurements. 

For total mercury determination, UW AG had all samples analyzed in accordance with 

EPA Method 1631 E by a laboratory specializing in analysis and speciation of trace level 

mercury, Cebam Analytical, Inc. Applied Speciation performed all total recoverable metals 

analyses using inductively coupled plasma triple quadrupole mass spectrometry (ICP-QQQMS), which uses either reactive or collision gases that preferentially react with interfering 

ions of the same target mass-to-charge ratios to remove interferences. TSS, TDS, chlorides, 

sulfate, total nitrogen, ammonia, nitrate/nitrite, total phosphorus, and TKN were preserved 

and analyzed using EPA-approved methods. 

2. Quality Assurance/Quality Control Procedures 

For all mercury and metals samples, we used preparation blanks, certified reference 

materials, matrix duplicates, and matrix spike/matrix spike duplicates for Quality Control 

(QC). For TSS, TDS, chlorides, sulfate, total nitrogen, ammonia, nitrate/nitrite, total 

phosphorus, and TKN analysis, the labs followed the method-specific QA/QC procedures. 

All QC parameters associated with the samples were within acceptance limits. No significant 

issues were encountered with the analyses except as described below: 

• First, the mercury result for the bottom ash pond effluent at Tanner's Creek is Rflagged due to field contamination. The field blank at the pond effluent is ten times 

higher than the average of the other field blanks and is essentially the same result as 

2 At Tanner's Creek, the sampling crew used a YSI 556 multi-parameter meter for these measurements. 
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the bottom ash pond effluent. The laboratory repeated the analyses of both samples to 

rule out analytical error. 

• Second, the TDS results at all three sampling locations at Stanton are R-flagged due to 

exceeding the recommended holding time of seven days. These samples were 

analyzed on the ninth day, and the results are recorded in Attachment 3. 

3. Field Measurements Confirm the Absence of Sulfides in Bottom Ash Ponds 

The field measurements detected no sulfides at SP-2 (bottom ash sluice pipe sample) 

or SP-3 (near-effluent bottom ash pond sample). Also, the dissolved oxygen levels recorded 

at the time of sampling indicate sufficient levels of oxygen to convert any sulfide present to 

sulfate. Therefore, each ofthe new samples supports UWAG's contention that sulfides are 

not present in BATW, and that EPA's TWPE estimates for BATW should not include 

sulfides. See UWAG's 2013 Comments on EPA's Proposed Guidelines and Standards for the 

Steam Electric Power Generating Point Source Category (UWAG 2013 Comments), p. 44. 

4. UWAG's Use of Settled BATW Sluice Pipe Samples Overestimated the Pollutant 

Loading Attributable to BATW Effluent Samples 

In its 2013 Comments, UWAG provided characterization data for 21 samples of 

BATW (see Attachment 6 to UWAG's 2013 Comments). As explained in UWAG's 

comments and my letter of August 1, 2014, UWAG collected 14 out of the 21 samples from 

the bottom ash sluice pipes prior to entering the ash ponds.3 The other seven samples were 

collected either at the actual bottom ash pond discharge point or near the discharge point. 

EPA questioned the representativeness of UW AG' s settled bottom ash sluice pipe 

samples, so UWAG decided to compare settled sluice pipe samples to near-effluent discharge 

point samples at each of the six facilities sampled. As anticipated, the settled bottom ash 

sluice pipe samples collected prior to entering the pond greatly overestimate the pollutant 

loadings attributable to bottom ash pond effluent. For example, the table below compares 

several major constituents in the Kyger Creek settled bottom ash sluice sample and the Kyger 

Creek near-effluent sample. 

3 One of the 14 bottom ash sluice water samples was collected at the effluent of the dewatering bin prior 

to entering the ash pond. 
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Table 3. Comparison of Certain Constituents in Kyger Creek's 

Bottom Ash Sluice Pipe Sample and Near-Effluent Sample4 

Pollutant BAS (SP-2) Near-Effluent (SP-3) Relative % Diff 

Aluminum (ppb) 6850 222 97% 

Arsenic (ppb) 8.91 0.99 J 89% 

Chromium (ppb) 13.2 u (<0.68) 95% 

Copper (ppb) 6.18 0.49J 92% 

Iron (ppb) 8240 485 94% 

Lead (ppb) 3.37 0.227 J 93% 

Mercury (ppt) 6.55 1.60 76% 

Nickel (ppb) 14.6 8.01 45% 

Selenium (ppb) 0.86 J 0.36 J 58% 

Averaging the pollutant characterization data for the six facilities shows that the settled 

bottom ash sluice pipe samples contain a much higher pollutant load overall, as shown in 

Table 4. 

Table 4. Comparison of Certain Constituents at SP-2 and SP-3, 

Averaging All Six Samples Together5

•

6 

Pollutant Average BAS Average Near- Relative% 

(SP-2) Effluent (SP-3) Difference 

Aluminum (ppb) 4085 964 76% 

Arsenic (ppb) 9.16 8.99 2% 

Chromium (ppb) 8.01 1.31 84% 

Copper (ppb) 9.78 1.45 85% 

Iron (ppb) 2656 326 88% 

Lead (ppb) 2.70 0.818 70% 

4 U=Below MDL; J=Between MDL and RL. 

5 The average result for mercury is based on five samples since the Tanner's Creek sample was Rflagged. 

6 For average calculations, UWAG used J-flagged values as well as unflagged values. For values 

<MDL, we used the MDL. 
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Pollutant 

Mercury (ppt) 

Nickel (ppb) 

Selenium (ppb) 

Average BAS 

(SP-2) 

3.72 

8.58 

1.08 

Average Near- Relative% 

Effluent (SP-3) Difference 

1.85 50% 

3.71 57% 

0.990 9% 

At each of the six sampled facilities, the settled bottom ash sluice pipe samples contain 

substantially higher concentrations of pollutants than the near-effluent bottom ash pond 

samples. The average percent difference when comparing the settled bottom ash sluice results 

(SP-2locations) to the samples collected from the near-effluent bottom ash pond (SP-3 

locations) for all constituents is 47% (Kammer), 36% (Kyger Creek), 29% (Tanner's Creek), 

30% (Daniel), 29% (Stanton), and 47% (Ratts). 

In fact, a majority of the constituents are lower in concentration near the effluent than 

in the source water entering the facility. The average source water concentrations are greater 

than the average pond near-effluent concentrations for aluminum, copper, cobalt, chromium, 

iron, manganese, nickel, lead, tin, titanium, zinc, mercury, ammonia, nitrate/nitrite, total 

Kjedahl nitrogen, phosphorus, and total suspended solids. 

Whether viewed from the individual facility perspective or as averaged across the six 

facilities, it is clear that the settled bottom ash sluice pipe samples substantially overestimate 

bottom ash effluent pollutant loadings. 

UW AG also compared its original BATW data from 21 plants to the recently collected 

BATW data from the six new plants. Using the near-effluent characterization data (SP-3) for 

the six new samples, the estimated TWPEs (using medians and without subtracting out the 

source water pollutant contribution) are significantly lower than the TWPEs UW AG 

calculated in its 2013 Comments, as illustrated in Table 5. 

Table 5. TWPE and $/TWPE Comparison: Original21 Plants to 6 New Plants 

(Including Source Water Contribution) 

Original Data 6 New Plants 

21 Plants (UW AG 2013 Comments)_ BA Pond- Near Effluent_{SP-3) 

Capacity BAS Flow TWPE/Year $/TWPE Removed TWPE/Year $/TWPE Removed 

(MW) Mgal/year Removed 1981$ Removed 1981$ 

<50 9.4 16 $16,492 5.8 $46,497 

50-100 30.2 52 $5,597 19 $15,780 
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Capacity BAS Flow 

(MW) MgaVyear 

100-150 63.8 

150-200 110 

200-300 152 

300-400 200 

400-500 197 

500-700 278 

700-900 308 

>900 223 

Original Data 6 New Plants 

21 Plants_{UWAG 2013 Comments) BA Pond- Near Effluent (SP-31 

TWPENear $/TWPE Removed TWPENear $/TWPE Removed 

Removed 1981$ Removed 1981$ 

110 $3,106 39 $8,758 

191 $2,056 68 $5,797 

263 $1,780 93 $5,018 

347 $1,635 123 $4,610 

341 $1,954 121 $5,509 

482 $1,694 171 $4,775 

534 $1,902 190 $5,362 

386 $3,146 137 $8,869 

Therefore, UW AG' s use of 14 settled bottom ash sluice pipe samples out of 21 total samples 

in its 2013 Comments was a very conservative approach. That approach overstated BATW 

pollutant loadings for the industry as a whole, and reduced the dollars per TWPE result for 

BATW. 

5. Bottom Ash Ponds that Treat Other Wastewaters Do Not Have Substantially 

Higher TWPEs Than Ponds That Receive Bottom Ash Only 

To evaluate whether treating coal pile runoff, mill rejects, and metal cleaning wastes 

in bottom ash ponds makes a significant difference in overall TWPEs, UWAG compared the 

TWPEs generated from the full database of257 plants to the TWPEs generated using only the 

characterization data from the three new samples for ponds that receive various combinations 

of coal pile runoff, mill rejects, metal cleaning wastes, and low volume wastes in addition to 

BA TW (Stanton, Daniel, and Ratts). Table 6 provides the comparison of TWPEs removed 

and $/TWPE without source water adjustments. 

7 Since both Kammer and Ratts were included in the original grouping of21 plants and in the new 

sampling effort, the full database includes 25 plants. 
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Capacity BAS Flow 

(MW) Mgal/year 

<50 9.4 

50-100 30.2 

100-150 63.8 

150-200 110 

200-300 152 

300-400 200 

400-500 197 

500-700 278 

700-900 308 

>900 223 

Table 6: Comparison of TWPE and $/TWPE for 25 BATW 

Samples to Plants with Bottom Ash Ponds That Treat Coal Pile 

Runoff and/or Mill Rejects in the Bottom Ash Pond 

(No Adjustment for Source Water Contribution) 

~ Plants That Treat Other 2 Plants That Place 

Mill Rejects in BA 25 Plants Wastewaters and BATW 

(Stanton, Daniel, Ratts) Pond (Kyger Creek, 

Tanner's Creek) 

TWPE/Year $/TWPE TWPE/Year $/TWPE TWPE/Year $/TWPE 

Removed Removed Removed Removed 1981$ Removed 1981$ Removed 1981$ 

12 $21,753 10 $26,689 6.9 $38,782 

40 $7,383 32 $9,058 22 $13,162 

84 $4,097 68 $5,027 47 $7,305 

145 $2,712 118 $3,327 81 $4,835 

199 $2,348 162 $2,881 112 $4,186 

263 $2,157 214 $2,646 148 $3,845 

259 $2,577 211 $3,162 145 $4,595 

366 $2,234 298 $2,741 205 $3,983 

405 $2,508 330 $3,077 227 $4,472 

293 $4,149 239 $5,091 164 $7,398 

The TWPEs for the three ponds that treat other wastewaters, including coal pile 

runoff, metal cleaning waste, and low volume wastes, are lower than the overall TWP Es 

calculated using all 25 plants. Also, UWAG compared the TWPEs for two plants8 that place 

mill rejects in their ponds to the TWPEs for all25 plants, and their TWPEs are also lower 

than the overall TWPEs calculated using all 25 plants. 

8 We used Kyger Creek and Tanner's Creek for this example. The Tanner's Creek mill rejects are 

pyritic, and it is unknown whether Kyger Creek's mill rejects are pyritic. These plants do not treat any other 

wastestream in the pond other than BATW. 
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From this analysis, UWAG finds that its 25-plant BATW database is representative of 

the industry. It contains plants that treat other typical industry wastewaters with BATW and 

plants that place pyritic mill rejects in the ponds. 

6. TWPE and $/TWPE Comparisons and Adjustments 

To calculate TWPEs removed from the conversion of wet bottom ash handling to dry 

or closed-loop using the model plant approach, UW AG used the characterization data from 

all25 plants in its database (Attachment 6 to UWAG's 2013 Comments plus the 6 new 

samples), with two adjustments as noted below. 

• Hoosier Energy/Ratts: In its 2013 Comments, UWAG used data reported on Form 2C 

(the permit application form) for the Ratts BATW characterization. Most of those 

data points were based on less sensitive test methods, and most of the results were 

reported as less than the method detection limit (MDL). Also, the original Ratts data 

did not include the full analyte list.9 Since UWAG had new, high quality data from 

the 2014 Ratts sampling event, we substituted the new data for the incomplete and less 

sensitive original data. 

• Kammer: Like Ratts, Kammer supplied data for the 2013 Comments and was sampled 

again for the new dataset. Because UW AG analyzed the 2013 Kammer data for a full 

analyte set and used sensitive test methods, we averaged the new Kammer data with 

the original data. 

The new UWAG data set represents 25 facilities, including 13 bottom ash sluice pipe 

samples (prior to entering the pond), 11 bottom ash pond effluent or near-effluent samples, 10 

and one sample from the effluent of a dewatering bin. UW AG used the revised data set to 

estimate TWPEs and $/TWPE. 

Tables 7 and 8 below provide the revised cost-effectiveness analyses using the model 

plant approach. Tables 7 and 8 are revisions ofTables 4 and 5 in UWAG's 2013 Comments 

9 The original Ratts data did not include results for aluminum, barium, boron, copper, cobalt, 

magnesium, manganese, molybdenum, sodium, tin, titanium, vanadium, chloride, total suspended solids, total 

dissolved solids, nitrate/nitrite, and total nitrogen. 

10 The eleven bottom ash pond effluent data include the effluent data from the six new plants. The 

settled sluice water data from these facilities were not included in the newly revised UW AG data set. 
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(UWAG 2013 Comments, pp. 74-75) but use the updated UWAG data representing 25 

facilities. 

Table 7: TWPE and $/TWPE Using UWAG BATW Data (25 Facilities)11 

(No Adjustment for Source Water Contribution) 

Capacity BAS Flow TWPE/Year $/TWPE 

Removed (MW) (Mgallyear) Removed 1981$ 

<50 9.4 12 $21,753 

50-100 30.2 40 $7,383 

100-150 63.8 84 $4,097 

150-200 110 145 $2,712 

200-300 152 199 $2,348 

300-400 200 263 $2,157 

400-500 197 259 $2,577 

500-700 278 366 $2,234 

700-900 308 405 $2,508 

>900 223 293 $4,149 

Table 8: TWPE and $/TWPE Using UWAG BATW Data (25 Facilities) 

(Less Source Water Contribution) 

Capacity BAS Flow TWPE/Year $/TWPE 

Removed (MW) (Mgal/year) Removed 1981$ 

<50 9.4 4 $60,813 

50-100 30.2 14 $20,639 

100-150 63.8 30 $11,454 

150-200 110 52 $7,581 

200-300 152 71 $6,564 

300-400 200 94 $6,030 

11 See also Attachment 4, TWPEs and $/TWPE for Updated 25-Plant UW AG Database. 
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Capacity 

(MW) 

400-500 

500-700 

700-900 

>900 

BAS Flow 

(Mgal/year) 

197 

278 

308 

223 

TWPE/Year $/TWPE 

Removed Removed 1981$ 

93 $7,205 

131 $6,245 

145 $7,012 

105 $11,600 

The analyses demonstrate that further regulation ofBATW is not cost effective for any 

units. The cost per TWPE removed is far greater than any cost per TWPE value used by EPA 

in the past to justify revised effluent limitations. The $/TWPE ranges from $2,157 to $21,753 

(1981$) for BATW (with no adjustment for the source water contribution) and from $6,030 to 

$60,813 (1981$) with an adjustment reflecting the source water contribution. These results, 

regardless of flow rate, are much greater than the highest $/TWPE that EPA has selected for 

BAT in previous rulemakings ($404 for the Electrical and Electronic Components industry 

category). In addition, the TWPE removals using the updated data are 23 percent lower than 

the TWPE removals using UWAG's original data for 21 facilities. 

Comparing the TWPE calculations with and without the source water contribution 

demonstrates that the majority ofTWPEs from BATW ponds originate in the source water. 

For example, out of a total of 145 TWPEs removed for plants with a capacity of 15 0-200 

MWs, 93 TWPEs, or about 64%, originate in the source water. 

7. Industry-wide Cost-Effectiveness Analysis 

Because UW AG updated its database of BATW characterization data, we also asked 

its consultant, NERA Economic Consulting, Inc., (NERA) to provide a new industry-wide 

cost-effectiveness analysis for BATW. 12 That analysis is Attachment 5 to this letter. Based 

on the new characterization data, UW AG developed new TWPE removal coefficients for 

BATW and BATW with source water contributions removed. The new coefficients are as 

follows: 

12 The industry-wide cost-effectiveness analysis was conducted on a unit basis based on sluice water 

flow rates and sluicing frequency from the ICR database and UWAG member input. See Attachment 14 of 

UWAG's 2013 Comments for a detailed description of the NERA methodology. 
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BATW TWPE removed/year = 1.31 x BA Sluice Annual Flow (Million 

Gallons/Year) 

BATW (minus source water contribution) TWPE removed/year= 0.47 x BA 

Sluice Annual Flow (Million Gallons/Year) 

Using these coefficients and changing no other factors of its analysis, NERA's 

estimate of cost-effectiveness for all units is $2,588 $/TWPE removed (1981 $), including 

source water contributions. In its September 2013 analysis, the comparable value was $1,959 

$/TWPE removed (1981$). (See Attachment 14 to UWAG's 2013 Comments.) NERA's new 

estimate of cost-effectiveness assuming subtraction of source water contributions is $7,212 

$/TWPE removed. 

UW AG subtracted the source water TWPEs from the total BATW TWPE to illustrate 

that source water is a major contributor ofTWPEs for BATW. For BATW, a large part ofthe 

"pounds removed" is already present in the intake water and is not added by the power plant. 

Without the adjustment for pounds of pollutants present in the intake water, the TWPE 

calculation penalizes power plants for pollutants naturally occurring in the waterbody (such as 

iron and aluminum) and also for pollutants added by upstream users. 

To subtract out the contribution of the source water in the effluent concentrations, 

UWAG calculated the net difference for each plant by subtracting the source water 

concentration from the BATW concentration for each analyte. If the source water 

concentration was higher than that in the BATW, UW AG used 0 as the net difference. The 

net difference concentrations for each analyte were then used to calculate the TWPEs that 

would be removed if each plant converted to dry or closed loop bottom ash handling. 13 

13 UWAG calculated the bottom ash sluice rate (in million gallons per year) based on the plants' 

responses in C3-3, Table C-19 of the ICR. Table C-19 asked for the average bottom ash sluice rate (gallons per 

day) and the typical frequency (days per year). For plants that did not have a response for Table C-19 (missing 

or redacted data), UW AG used the median flow rate and frequency for comparably sized units. In total, 665 

units at 268 plants were identified from the ICR database or the UW AG survey responses as having wet bottom 

ash handling. NERA calculated the TWPE removed and 1981 $/TWPE based on the two bottom ash handling 

options in the proposed ELG rule: (1) all units, and (2) units 400 MW or greater. 
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8. Summary 

UWAG requests that EPA consider this new BATW data as it works toward finalizing 

the rule. The BATW data UWAG has provided is more recent and ofhigher quality than the 

BATW data EPA used in its proposal. As UWAG noted in its 2013 Comments, all of the 

BA TW and fly ash data that EPA extracted from the 1982 Technical Development Document 

or related documents are outdated and do not reflect the industry's current bottom ash 

handling wastewater characteristics. See UWAG 2013 Comments, pp. 28-43. Some ofthe 

data points EPA used were collected before the industry had implemented the 1982 effluent 

limitation guidelines, and thus they are not representative oftoday's discharges. All of the 

1980s and prior data points EPA used were analyzed using outdated methods. And it is 

inconceivable that EPA would base a major rulemaking on data that are not supported by 

adequate documentation, such as certificates of analysis, quality control reports, or chain of 

custody forms. See UWAG 2013 Comments, pp. 31-37. In contrast, UWAG has provided 

very recent data collected under rigorous QA/QC procedures and analyzed using sensitive 

methods. For all of these reasons, UWAG's BATW database is far superior to EPA's 

characterization data. 

The UW AG BATW data from 25 power plants are representative of the industry. The 

data represent a variety of coals, boiler types, geographic locations, and plant configurations. 

The database includes plants that treat other wastewaters, including coal pile runoff, metal 

cleaning wastes, and low volume wastes, with BATW, and plants that sluice or place mill 

rejects, including some that are pyritic, in the bottom ash pond. Based on UWAG's analysis, 

the addition of coal pile runoff, pyrites, and other wastewaters to bottom ash ponds does not 

significantly affect the TWPEs discharged from bottom ash ponds. Therefore, for purposes of 

determining whether further regulating BA TW is justified, the treatment of other wastewaters 

in bottom ash ponds and the presence of pyritic mill rejects in the ponds are not relevant. 

Based on UWAG's full database ofBATW samples and NERA's updated industrywide cost-effectiveness analysis, and using EPA's standard metric of 1981 $/TWPE removed, 

any further regulation of BATW is not cost effective, regardless of the capacity of the unit. 

Sincerely, 

Elizabeth E. Aldridge 

Counsel to UWAG 
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Attachment 1-New BATW Data Table (6 new samples) 

Attachment 2- Certificates of Analysis for New BATW Data (including COCs) 

Attachment 3- Plant Information and Field Measurements (6 new samples) 

Attachment 4- TWPEs and $/TWPE for Updated 25-Plant UWAG Database 

Attachment 5 - NERA Updated Industry-wide BATW Cost Effectiveness Analysis 

29142.070312 EMF_US 52958252vll