Comment Summary Table

Summary of Comments on the Public Notice for the Proposed Information Collection for Steam Electric Power Generating
Effluent Guidelines and EPA’s Response1
Comment
60 Day Response Time

Response

a. 60 days to complete and submit the ICR (which requests a high volume of
data, high quality data, and historical data) is not sufficient and generally
unworkable. EPA should allow a minimum of 180 days to complete the survey.

a., b., and c.

b. Many of the individuals that will be required to provide information hold
positions in which they perform activities essential to maintaining and operating
out power plants. These individuals cannot be spared to do weeks or months of
work on the ICR in a condensed time period. Instead, the will have to work their
schedules after certain duties have been completed.
c. It is unreasonable to expect the “most knowledgeable person” or the “best
engineering estimate” to be available in the 60 day timeframe.
d. Response time should be extended considering the government forms and
other ICRs facilities are required to complete and submit.
e. When EPA distributed the 316(b) survey in 2000, the response time was 90
days to complete a survey that was less than one half the length of this
questionnaire.
f. Response time should be extended to accommodate small utilities, co-owned
utilities, and companies that own multiple utilities.
g. The general criteria for an extension request should be laid out. EPA should
reply to extension requests in a fair and timely manner.

EPA has carefully evaluated the time required to complete the questionnaire,
including reviewing comments on this topic, and continues to believe that 60
days is sufficient time for completing the questionnaire. Should individual
plants have extenuating circumstances that result in the need for additional
time, they can request an extension. EPA will consider each extension request
on a case-by-case basis. EPA is aware that, literally, the “most knowledgeable
person” may not be accessible for this questionnaire and has revised the
instructions to use the term “personnel knowledgeable in.” EPA disagrees with
the comment about “best engineering estimate.” The expectation is that
respondents will make the engineering estimate as reflects the scope and
context, including the time constraint of the ICR. This approach actually
provides a reasonable degree of flexibility to respondents and avoids imposing
the burden of collecting measurement data (other than leachate sampling) for
the express purpose of responding to ICR questions.
d. and e.
EPA has structured the questionnaire in a manner that allows plants to
efficiently compile the necessary information, including use of divisible parts
that can be distributed among plant staff. The time provided for responding to
other surveys is not relevant to the time plants will need to complete this ICR.
EPA notes that the steam electric questionnaire will be distributed no earlier
than May 2010. Therefore, EPA does not anticipate any overlap with
collection activities such as EIA and FERC.
f. EPA recognizes the concern raised but believes sufficient time is being
provided to complete the survey. EPA has reduced burden for coal-fired plants
operated by small entities by excluding them from Parts E, F, and G. The
questionnaire is structured so that individual plants (i.e., plant staff) will be
completing the survey, therefore the fact that plants may be co-owned or that

1

Question numbers referred to throughout this table refer to the 1st FRN version of the questionnaire.

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Comment

Response
companies operate multiple facilities alone is not sufficient reason to provide
additional time for completing the ICR.
g. See the response to a-f. EPA will not automatically grant extensions for this
ICR. Each extension request will be considered on a case-by-case basis and
EPA will respond in a timely manner. Until they receive EPA’s response to a
request for additional time, plants should not delay responding to the
questionnaire.

Defining the Scope of the ICR
a., b., and c.

a. Facilities that do not possess a NPDES permit should not be required to
respond to the questionnaire.
b. Facilities that have no discharges associated to the effluent limitation
guidelines should not have to respond to the questionnaire. Many of the questions
request analytical data but have no indication of final discharge. When these
discharges go to evaporative systems or are recycled back into the plant system
there often are not adequate responses provided in the questionnaire.
c. Zero liquid discharge facilities should not be included in the scope of this
questionnaire.
d. Participants of the 2007 Data Request for the Steam Electric Power
Generating Industry should not be included in the scope of this questionnaire.

d. This ICR collects more broad operational data and financial data that were
not obtained by the 2007 data request and that is not obtainable through other
sources; therefore, those facilities remain within the scope of this
questionnaire. Also see Part A of the supporting statement.
e. EPA did not elect to statistically sample a subset of the coal-fired

e. Consider “screener” surveys and/or questionnaires to gather information from
the coal-fired power plant population.
f. Plants that are closing and/or repowering in 2009 should not be included in the
scope of this questionnaire.
g. Small businesses should not be included in the scope of this questionnaire.

Information from plants that do not discharge wastewater is relevant to the
rulemaking process because it provide valuable insight to approaches to reduce
or eliminate pollutant discharges and it will be factored into the development
and consideration of effluent guidelines options for other plants. Therefore,
these plants remain within the scope of this ICR.

power industry for Parts A through D and I due to the number and types
of factors to be considered regarding FGD and ash operations, and the
limited data available for identifying these factors at power plants to the
extent necessary for establishing and defining strata for statistical
sampling, as well as the individual plants that populate each sampling
strata. Throughout the detailed study and during initial rulemaking
activities, stakeholders have stressed the need to evaluate how
variability in equipment and operating practices between plants affect
wastewater discharges. In addition, stakeholders expressed concern
over properly accounting for the financial conditions at each plant,
considering ownership of individual generating units including, in a
number of instances, multiple partial owners. EPA considered an
approach that would issue a screener survey followed by a more

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Comment

Response

detailed questionnaire to selected plants, but determined that the wide
range of variables to be evaluated would still result in a wide crosssection of the industry being selected for the detailed questionnaire.
Despite the commenter’s suggestion to issue a screener, it should be
noted that the comment identified more than sixty factors that should
serve as strata for statistically sampling plants; this is without
accounting for financial strata criteria and other technical factors of
interest. Given this situation, a screener questionnaire would be rather
extensive itself, and in the end possibly would not substantially reduce
the number of coal-fired plants that would receive the detailed
questionnaire. The types of operations and the associated process
wastewaters can change from facility to facility depending on factors,
such as the type of coal burned, air pollution controls in place, type of
wet FGD absorber design, FGD wastewater treatment, type of ash
handling system, ash pond management, type of cooling water system,
and the water source. Considering the large number of characteristics to
be evaluated and the limited data currently available, EPA will
distribute Parts A through D and I of this questionnaire to all coal-fired
power plants.
f. EPA has revised the questionnaire so that facilities that are permanently
retired or will be permanently retired by December 31, 2011 will have to
complete only a few questions at the beginning of the survey. However, plants
that are repowering and will resume operating must complete the survey.
g. EPA will include small businesses in the scope of this questionnaire to
obtain information necessary to understand their operations and how changes
imposed by revised effluent guidelines would affect them operationally or
financially. However, to reduce burden imposed on these entities EPA is
excluding coal-fired plants operated by small entities from responding to Parts
E, F, and G.
Notification of the ICR
a. EPA should provide the list of respondents prior to the mail out of the
questionnaire.

a. EPA does not intend to publish the list of facility recipients prior to mail of
the questionnaire because doing so could potentially jeopardize CBI responses,
or force EPA to aggregate CBI (to prevent revealing CBI) in such a manner
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Comment
b. EPA should notify trade associations and industry of any changes made to the
questionnaire (from the 1st FRN Draft) prior to the 2nd FRN publication.

Response
that makes it more difficult for the public to view details of EPA’s regulatory
analysis..
b. EPA has continued outreach with industry and and other stakeholders to
discuss plans and potential ICR revisions, as appropriate. A revised
questionnaire will be published as part of the 2nd FRN and the public will then
have an additional opportunity to review and submit comments on the ICR.

Distribution of the ICR
a. If the distribution of the questionnaire happens in the May-June 2010 period it
would be very difficult to spend 200 to 500 hours answering the questionnaire for
each facility. Facilities also have to file routine reports such as DMRs and TRI
reports by July 1st. Suggest distributing the questionnaire after July 1st.
b. Delay the ICR until January 2011 to reduce burden on respondents, as well as
increase the utility of the ICR.
c. There should be some consideration given, when distributing the ICR, to the
other ICRs that facilities will be required to respond to.
d. EPA should delay the distribution of the ICR until after the pending CCR Rule
(specifically questions and requirements regarding ash handling and leachate
sampling). It is likely that the CCR rule will have a significant impact on cement
management practices for fly ash, bottom ash, FGD scrubber solids, etc. When
the CCR rule is finalized, the information for Part B, C, D, and G could be
largely obsolete.

a., b., and c.
EPA is aware that the questionnaire may be distributed at a time when plants
are engaged in other data collection and reporting efforts. However, EPA
recognizes that some of these efforts are year-round and/or recurring activities
for which plants are already staffed, and that it is impossible to avoid all other
data collection efforts. In addition, this ICR will occur after plants have
completed efforts for EIA and FERC, and much of the Utility MACT ICR.
The proposed effluent guidelines are scheduled for publication in 2012. In
order to meet this deadline, data collection must occur by mid-2010.
d. EPA has made every effort to reduce or eliminate overlap of industry data
collected, and to tailor this questionnaire to information necessary to revise
ELGs. Although EPA recognizes that future changes may occur in the
handling of CCR, the data requested on current and past operations will still be
useful in evaluation technologies for control of wastewater discharges. Also
see response to comments for Part C and G.

Development of the Questionnaire
a. In developing this ICR, EPA has not been willing to discuss industry concerns
and adopt suggestions as EPA has been in the context of other ICRs.
b. This ICR attempts to better understand power plant operations with regard to
water discharges for a number of different plant designs. However, based on
trade association experience, the chemistry of trace elements and their
partitioning to the water stream is not well understood, and the existing data will
not be sufficient in terms of quality and breadth to allow Agency to project water
impacts.

a. EPA encourages industry input and has consistently kept an open door to
facilitate communications over the course of the deatailed study and for this
rulemaking, including the ICR development. See the docket for information
about outreach and technical discussions with industry and other stakeholders.
b. EPA feels that the questionnaire requests appropriate current and planned
data to understand current and future discharges in the industry. EPA
encourages discussions with industry on content of and ways to continually
improve the questionnaire. In addition, EPA invites stakeholders to provide
additional data they believe EPA needs to project water impacts.

All Parts/Definitions/Terms

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Comment
a. EPA should prepare a list of definitions/glossary for terms found within the
ICR.

Response
a., b., and c.

b. The Utility Water Act Group (“UWAG”) submitted a letter to EPA requesting
that EPA provide definitions for several undefined terms used throughout the
draft questionnaire. EPA should formally respond to the request.
c. To ensure consistent understanding by both EPA and the industry, it is
imperative that EPA make its glossary available for public comment before
sending the proposed ICR to OMB for review.

EPA prepared a glossary of terms for the questionnaire and considered
UWAG’s recommendations in developing the glossary. EPA shared this draft
glossary with stakeholders in advance of the second FR notice and received
extensive feedback from industry. These suggestions were considered in
revising the glossary, which is included in the current version of the ICR.
d. EPA disagrees that the Agency failed to provide adequate notice. EPA also
disagrees that because a separate list of definitions was not provided with the
draft questionnaire, that it is not possible for the public to provide meaningful
comment. Many of the terms were defined within the instructions and
questions of the survey.

d. EPA has failed to provide adequate notice because of the lack of a glossary
and incomplete nature of the draft questionnaire.
e. Request for “planned” activities will likely yield inconsistent results. EPA
needs to define “planned” and “future” in both scope and scale.

e. EPA has revised the questionnaire to more specifically instruct facilities on
the request for “planned” and “future” activities.

f. In order to facilitate completion of the questionnaire as soon as possible, a
detailed table of contents is needed.

f. EPA will include a Table of Contents in the questionnaire.

Request for 2008/2009 Data
a. Requesting 2008 data as the most recent year would allow companies to start
gathering information sooner. 2008 data is already available and given the
economic downturn late in 2008, the argument could be made that 2008 was a
more representative year for facilities than 2009.

a. EPA has minimized the specific request for 2009 data to the extent
necessary. In many instances, EPA does not limit the request to a specific year
and instead asks for data that represent “normal operations”. The comment
page provides an opportunity to identify any atypical data. EPA will ask for
2009, where appropriate, to establish consistency among responses.

Overlap with Existing Data
a. A number of questions request information which appears to be available via
the Energy Information Administration (EIA)/Federal Energy Regulatory
Commission (FERC) databases. Where possible, utilization of existing resources
would reduce unnecessary efforts by the Agency and respondents.
b. Under section 3506(c)(3)(B) of the Paperwork Reduction Act, EPA must
certify to OMB that the information sought under an ICR is not unnecessarily
duplicative of information otherwise reasonably accessible to the agency.
Commenters believe that EPA's proposed ICR does not meet this standard.
Questions in the proposed ICR overlap with information that is proposed to be
collected by EPA under the ICR for developing MACT standards for coal- and
oil-fired electric utility steam generating units (the “Utility MACT ICR”). Thus,
the Office of Water must use information that will be collected by the Office of

a. EPA has completed a thorough review of the entire questionnaire for
potential overlap with other sources (e.g., EIA, FERC). Following this review,
EPA deleted or revised certain requests or otherwise attempted to minimize reproviding the exact information in more than one report (except where needed
for identification purposes). Specific overlap has been addressed in the specific
comment responses for each part.
b. EPA has completed a thorough review of the entire questionnaire for
overlap with other completed or ongoing ICRs (including the Utility MACT
ICR and the ORCR data). Where possible, EPA has deleted or revised
questions to minimize or eliminate overlap. Specific overlap has been
addressed in specific comment responses for each part.

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Comment
Air and Radiation as well as information that has already been collected by the
Office of Solid Waste and Emergency Response, instead of collecting duplicate
information.

Response

Electronic Format for the Questionnaire
a. In a recent EPA-sponsored conference call, EPA personnel asked for
recommendations for software to be used for the electronic version of the ICR.
After review, EPA should use MS Excel.

a. and b.
EPA is using MS Excel as the format for the electronic questionnaire. This
format is being distributed as part of the 2nd FRN to gather additional input on
format and allow stakeholders the opportunity to test it before distribution. In
addition, EPA has conducted initial testing and will continue testing the
questionnaire prior to its distribution. This electronic method was created to
minimize burden on the industry and ensure efficient processing of the
collected data.

b. EPA should thoroughly test the electronic version of the questionnaire before
release.

CBI Justifications
a. EPA has made the process for claiming information as CBI extremely
burdensome. The request to provide justifications departs significantly from
previous ICRs. EPA should work the industry to designate portions or even
complete section CBI.

a. EPA recognizes that supplying justifications for CBI marked information
may impose burden unnecessarily on the industry. Therefore, answers can be
marked as CBI according to practices familiar to the industry. A checkbox for
the question will be marked and no justification at the time of submittal will
be required.

Certification Statement
a. EPA's proposed certification statement, requiring "best knowledge and belief'
that the information is accurate, is inappropriate for an ICR of this complexity. In
contrast, the proposed MACT ICR does not include a general certification
statement. (There are certifications associated with some of the individual
questions.)

a. Respondents should certify that the requested information is accurate to the
"best of their knowledge and belief" given the time and complexity constraints
of the questionnaire. The certification language is typical for EAD programs
and is appropriate for a data collection such as this.

Request for Cost Data
a. Providing capital cost estimates of past projects, many by engineering
judgment, will stretch the usefulness of the resulting data, but coming up with a
breakdown of O&M costs associated with specific plant operations (for example
the fly and bottom ash handling costs in Part C) or per pond/impoundment (per
Question D54) will result in data of very limited value.
b. Some capital costs are over 30 years old and may be estimates. Should 30-year
dollars be used or should the dollar estimates be escalated forward?

a and b. EPA does not agree that the requested O&M data will be of limited
value. These data are necessary to evaluate potential technology options and
the impacts that new pollution control requirements may have on plants. EPA
has limited the request of O&M costs for ponds/impoundments, landfills, and
ash handling systems to those installed after January 1, 1985 to reduce burden.
Respondents should answer these questions with the best available information
and use the comments page to call attention to any estimates or assumptions
that may have been made. Respondents should answer questions referring to
capital costs with the best available information and specify the year basis of
the provided costs. EPA has limited the request of capital costs for

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Comment

Response
ponds/impoundments, landfills, and ash handling systems to those installed
after January 1, 1985 to reduce burden. No inflation costs need to be applied
to the costs provided by respondents.

Burden
a. EPA’s burden estimate is too low, especially for utilities with multiple plant
sites. The amount of information called for seems over burdensome in that it is
not clear that the amount of requested detail is needed.

a. and b.

b. Companies have noted that completing the questionnaire will take on the order
of five to ten full-time staff several months per facility, a burden that is very
difficult to sustain. EPA needs to provide a more realistic burden and look for
ways to reduce the burden.
c. EPA consistently states that the survey is divided into sections to reduce
burden, saying that no facilities will have to complete all sections. All coal plants
will have to complete at least four, one third will have to complete all except,
obviously, the nuclear section. This does not reduce the burden.
d. EPA’s average burden estimate of 205 hours is extremely underestimated and
does not account for different facilities being subject to different questionnaire
requirements or any first level coordination. This estimate should at least be
doubled for coal-fired power plants.
e. Nowhere in the calculation of the responded time burden does EPA account
for facilities having multiple units.
f. EPA could reduce the burden by eliminating questions unrelated to discharges
to “Waters of the United States”.
g. Eliminate questions requesting capital costs in Parts C and D for older
installations to reduce burden.
h. EPA’s estimate of total burden is not clear and unable to be replicated.
i. EPA’s labor costs and time estimates are questionable.

EPA has reviewed and considered all comments received regarding the 1st
FRN burden estimate. EPA has revised the burden estimate, incorporating
comments from the industry and revisions made to the questionnaire. EPA has
carefully reviewed and revised the questionnaire to eliminate any burdensome
requests that are unnecessary. See Part A of the supporting statement for
information on why the data are being requested.
c. and d.
EPA reviewed the questionnaire and comments to revise the hourly burden
estimate, taking into account some time for first level coordination. EPA
recognizes that the calculated average burden differs according to different
fuel segments of the industry. EPA will estimate a burden for each segment of
the industry to come up with a more accurate average burden corresponding to
a specific fuel type.
e. EPA revised the burden to account for all plants, units, wastewater systems,
ponds and landfills, and wet/dry FGDs. The revised Supporting Statement,
published with the 2nd FRN, explains the number of respondents estimated for
revising the burden.
f. The questions included in the ICR are relevant to “water of the United
States” in that they characterize operations that generate wastewater and how
those wastewaters are managed, or identify practices that avoid generating
and/or discharging wastewater. As part of the rulemaking, different regulatory
options will be considered, this information is requested to address each option
accordingly and make informed decisions about potential revisions to the
ELGs.
g. EPA has limited the request of capital and O&M costs for
ponds/impoundments, landfills, and ash handling systems to those installed
after January 1, 1985 to reduce burden.
h. EPA revised the Supporting Statement so that the calculated burden is clear

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Comment

Response
and able to be replicated.
i. EPA will adjust labor rates by 30% to account for employee overhead and
benefits. The time estimates were reevaluated for the revised ICR, including
consideration of comments on this topic.

Supporting Statement
a. Page one states, "… determined that significant amount of the toxic pollutant
loadings discharged to surface water by point sources." appears not necessarily
fact based, and is not supported by references. Recommend changing wording or
provide an example/proof for the statement that it was "determined that
significant amount of the toxic pollutant loadings discharged to surface water by
point sources."
b. Support statement language regarding EPA seeking information on, "candidate
pollution control technologies" to meet the effluent guidelines approach, appears
to be open to candidate technologies regardless of their point of development.
EPRI is concerned that technologies not yet proven on specific power plant
wastewater at a full-scale should be noted as such. Reference needs to be made to
"demonstrated controls" with respect to "candidate pollution control
technologies" to meet the effluent guidelines approach.

a. EPA refers to the findings of the Steam Electric Power Generating Point
Source Category: Final Detailed Study Report (EPA 821-R-09-008) to support
this statement. See the report for information supporting these findings.
b. EPA plans to use the information collected by the questionnaire and
additional research to consider and review candidate pollution control
technologies. EPA will evaluate all aspects of potential control technologies,
including their technical feasibility, whether they are demonstrated, and their
economic affordability, before using them as a basis for revised ELGs. It is not
necessary for a technology to be proven at full-scale or on a specific power
plant wastewater for it to be considered as a basis for revised ELGs.

Front Matter
a. EPA incorporated this change.

a. Page iii states “Extension requests will be evaluated on a case-by-case basis.
Submittal of an extension questionnaire to EPA…” The word “questionnaire”
should be changed to “request” in the second sentence of this paragraph.

b. See response above for “60 Day Response Time.”

b. Page ii states “Each part should be completed by the person(s) most
knowledgeable about the information requested.” Throughout the Questionnaire,
references to “persons most knowledgeable” should be changed to “qualified
personnel” consistent with the certification statement. Given the very short
response time for the Questionnaire, it is unreasonable to expect that the most
knowledgeable person will always be available or could even be immediately
identified and assigned to the appropriate topics. All companies will need
multiple personnel to respond to the questions. By the time the Questionnaire is
circulated to all personnel who will need to contribute to the answers, a
significant portion of the 60-day period will have already passed. The
Questionnaire does not provide adequate time for intra-company

c. EPA added a glossary that defines all key terms found in the questionnaire
and added a list of acronyms at the end of the front matter. See response above
for “All Parts/Definitions/Terms.”
d. See response above for “60 Day Response Time.”

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Comment
communications and quality assurance steps.

Response

c. EPA should provide definitions of key terms. Definitions of key terms,
according to the instructions, are supposed to be “at the back of the
questionnaire” but are not attached. Neither is the promised list of acronyms and
measurement units. Among many other undefined terms, EPA should define the
following bold, italicized terms: plant-p. vi; wastewater treatment, p. vi; pollution
prevention, p. vi; best management practices, p. vi; permanently, p. E-5;
temporarily, p. E-5; pond/impoundment, p. E-5; disposal, p. E-5.
d. Although the instructions provide for individual extensions to be decided on a
case-by-case basis, and provides a 21-day period for filing an extension request,
EPA does not specify how quickly it will act on those extension requests.
Requests that EPA agree to respond to extension requests within one week after
electronic receipt of the request. Also, EPA should provide some general criteria
that will be considered in granting extension requests.
Part A/Steam Electric Power Plant Operations
a. Commenters believe a question should be added, so that if a facility does not
discharge wastewater (i.e., do not possess a NPDES permit), then the facility
would not be required to complete the questionnaire.

a. EPA does not agree. See response for “Defining the Scope of the ICR.”

b. Commenters believe that Q. A1-2 through A1-5 should be revised to require
the submission of a single contact name due to the complexity of the questions in
the Questionnaire. This person would be responsible for contacting additional
individuals for responses to additional questions posed by EPA.
c. Commenters think Q A1-6 should to be more specific. They ask if the unit has
not generated electricity during the 2009 calendar year, would the answer be no.
d. In Q. A1-9, commenters ask EPA to provide clarification regarding what
constitutes "Distributed NOT for sale" to ensure consistency in responses. They
are uncertain if it refers to power used for station service.
e. In Q. A1-11, commenters ask what standard applies for judging whether the
primary purpose of the plant is generation of electricity. Does it mean 50% or
more of the profits are from electricity generation?
f. Commenters believe the information requested should be limited to 2007
through 2009 in Q. A1-15. Requiring information from 2005 through 2009 is

b. EPA requests a primary and secondary contact for both the technical and
economic data for cases when one of the contacts may leave the company.
Additionally, the contacts for economic and technical information are often
different. If the plant determines the same contact can provide both economic
and technical information, they can answer accordingly. However, both
primary and secondary contacts are still required.
c. EPA changed the wording to ask if the plant has the potential (i.e.,
equipment available on site) to generate electricity from a steam electric
generating unit.
d. EPA removed the “Distributed NOT for sale” response option. If the plant
is generating power for the distribution and use off site, the plant will select
“Other” and provide a description.
e. EPA defines primary purpose as “the predominant source of revenue and
principal reason for operation.”
f. EPA reduced this request to 2007-2009, and intends to obtain data on 2005
and 2006 from EIA, as available.

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Comment
overly burdensome and is unlikely to provide information that is more
representative.
g. Commenters ask EPA to confirm that Q. A1-18 requests information for
permits associated with wastewater or stormwater discharges from industrial
activities and does not include permits required for construction of wastewater
and/or sanitary sewage facilities; erosion and sediment control permits associated
with construction activities; temporary permits, general permits for hydrostatic
testing water, water obstruction and encroachment permits and/or water
allocation permits. Furthermore, commenters believe that EPA should delete the
requirement to include pending permits. Pending permits have not been issued as
yet, may be changed prior to issuance in final, and often do not have permit IDs,
approval dates, or expiration dates. Additionally, commenters ask why EPA
needs information on the plant’s RCRA, air, and UIC permits for the purpose of
setting effluent guidelines.
h. Limited or zero discharge facilities may not have receiving waters for certain
discharges to include in Table A-3.
i. Commenters believe that EPA should clarify that the surface waters at issue are
those that are waters of the United States or waters of a State and not waters
outside the jurisdiction of EPA and a State. As Q. A1-19 is currently worded,
respondents may believe they need to identify non-regulated on-site waters such
as private ponds or water bodies that are part of the wastewater management
system. In addition, it is assumed that plants discharging to cooling ponds that
are not Waters of the U.S. do not need to answer this question. Additionally,
“Reservoir” should be added as a possible response under type of receiving
surface water in Table A-3.
j. Throughout Part A, EPA uses the term “planned.” Commenters ask EPA to
define this term to ensure consistent responses. They suggest a short-time frame
such as within the next 2 years.
k. Many power stations utilize small sediment traps along access roads, haul
roads, soil borrow areas, closed landfills, etc. to minimize the quantity of
suspended solids to receiving streams. Pennsylvania, along with other states,
broadly defines these same terms. Therefore, commenters request that EPA
define the terms ponds, impoundments, storage, disposal, process wastes,

Response
g. EPA clarified in the instructions for Table A-2 that Q. A1-18 should only
cover permits associated with industrial activities and that permits required for
construction of wastewater and/or sanitary sewage facilities; erosion and
sediment control permits associated with construction activities; temporary
permits, general permits for hydrostatic testing water, water obstruction and
encroachment permits and/or water allocation permits are not required. EPA
added an additional column in Table A-2 asking plants if they have a pending
permit under development and revised the instructions so that plants will not
need to provide the ID numbers and dates associated with the pending permits.
Information in permits not related to water such as RCRA, air, and UIC
permits will provide EPA with the information needed so it can obtain the
permits, if necessary, to evaluate potential waste streams that may be generated
from other process operations associated with the requirements for those
permits. For example, these permits will include information on carbon capture
and storage systems and other technologies, which generate wastewater of
interest.
h. EPA revised Table A-3 to request this information on an outfall basis and in
a question format. EPA clarified that plants should skip the section collecting
outfall information if the plant does not have a NPDES permit (i.e., no
outfalls).
i. EPA revised Q. A1-19 to request information on the receiving water for each
outfall designated in the plant’s NPDES permit. EPA added “Reservoir” as a
response option for the type of surface water.
j. EPA agrees that it would be useful to define a timeframe for reporting
planned systems, but disagrees that "planned" should be limited to the next two
years. EPA established appropriate timeframes for specific questions in the
questionnaire.
k. EPA defined the terms "pond/impoundment", "process wastewater", and
"residue" in the glossary of the questionnaire. EPA does not believe definitions
are required for “storage,” “disposal,” and "by-products." The questionnaire
does not require plants to report information on sediment traps.
l. The term "effluent point" has been changed to "pond outlet," which is
defined as "the point at which the pond/impoundment releases water to another
pond/impoundment, surface water, or other process." The question also

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Comment
residues, and by-products and clarify if sediment traps are included within these
definitions.

Response
clarifies that emergency outlets should be used for ponds with no regular
transference to another location.

l. Commenters ask EPA to clarify in Q. A1-20 whether the effluent point is the
point at which the effluent is discharged to a water of the United States or a water
of the State or whether it includes internal discharges between
ponds/impoundments. Many ponds have outlet structures that lead to additional
water treatment and then an effluent discharge; it is unclear under the existing
language whether a pond outlet would be considered an effluent point. “Effluent
point” should be defined as that point where the treated effluent (pond or
otherwise) discharges to the receiving water as defined in the applicable NPDES
permit.

m. EPA defined the term “landfills” in the glossary of the questionnaire.

m. Commenters believe “landfills” should be defined.
n. In column 5 of Table A-4 in the heading, commenters ask what does EPA
mean by “is leachate collected.” Commenters state that leaks from
ponds/impoundments are not leachate. Commenters ask why does EPA need
information on retired and closed ponds/impoundments and believe EPA should
define “closed” and “retired.”
o. Commenters think that Table A-5 needs a separate column for
water/wastewater treatment chemicals and/or metals and should include columns
for metal cleaning wastes, coal pile runoff, and low volume wastes. Additionally,
the instructions for Table A-5 and Table A-7 should clarify that respondents do
not need to report de minimis or incidental amounts of wastes stored or disposed
of in ponds/impoundments or landfills.
p. Commenters state that the heading in column 3 of Table A-6 is wrong. This is
the table for landfills, not ponds/impoundments.
q. Q. A1-22 requests latitude and longitude of the site. Commenters ask EPA to
clarify the location at which the geographical coordinates of the plant should be
identified (e.g., the center of the plant, the entrance gate, etc.).
r. In Q. A1-23, commenters think that the word “available” is ambiguous and
needs clarification. Land at some facilities could be made available for process
equipment, treatment systems, etc. but only after extensive site work and grading
is performed. Distance from the plant and limitations posed by existing structures
also affect availability but could be overcome at great expense. Most electric
generating stations have extensive arrays of buried electrical lines and pipes that

n. EPA revised the definition of the term “leachate” to include leakage, leak,
seepage, leachate collection, and leak detection sources. EPA believes that
information on closed and retired units is necessary because retired and closed
units have a potential to impact surface waters. For example, knowing whether
the pond is lined is relevant whether the pond is operational or retired. EPA
does not agree that “closed/retired" requires a definition.
o. Plants are not required to report water/wastewater treatment chemicals
and/or metals in this table. EPA revised Table A-5 to include not only solid
wastes, but also process wastewaters that are stored, treated, and/or disposed in
each pond/impoundment unit. EPA disagrees that certain wastes should not be
required to be reported in Table A-5 and Table A-7. Therefore, no changes
have been made.
p. EPA corrected the heading in column 3.
q. EPA revised this question to allow respondents to skip if they already
reported their coordinates to EIA on U.S. DOE/EIA Form-860 (2007),
schedule 2, line 6. EPA did not clarify the location for the coordinates so that
respondents could use their EIA responses (EIA does not specify the location
for the coordinates).
r. EPA has removed Q. A1-23 from Part A.
s. EPA revised the instructions of Q. A1-24 so that plants will only need to
provide aerial photographs or maps, but do not need to identify various
information on the map (e.g., wetland areas, surface waters bordering site).
t. EPA revised the instructions of the water balance diagram to reduce the
burden on plants. The instructions now specify that plants are allowed to use
water balance diagrams from previous years as long as they are still
representative of current operations. In addition, EPA revised the instructions
to request that plants report the process operations at the unit level instead of
requiring them to report and present all the equipment that is used in each unit.
EPA has developed a destinations table located in the “Code Tables” tab at the
end of the part, which provide more general destination options.

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seriously complicate development activities. Additionally, most power plants are
located near waterways with associated wetland areas. Commenters believe
available land should be defined as upland areas with no or minimal existing
infrastructure and within a certain distance (i.e. 500’) of existing units.
s. Commenters believe that the maps requested in Q. A1-24 will be very timeconsuming to prepare. This is overly burdensome. EPA should use existing
public sources of information. Some companies would need to include within
the property map a map of the facility’s reservoir (ranging in the thousands of
acres) because the reservoir part of the facility is property. Additionally, if there
is no discharge to wetlands, there is no reason to include them in the
questionnaire.
t. Commenters believe preparing the water balance diagram requested in Q. A125 will be very time consuming and burdensome. Much of the information
requested (e.g., flows) does not exist for many of the streams EPA has indicated
must be included on the Block Flow Diagram. EPA should not expect the water
balance diagram to actually balance. In addition, diagrams are typically prepared
by our environmental consultants when preparing permit applications, so none
will contain data from 2009. As a result, subcontractors will be required to
complete this activity putting more burden on the plant. In addition, the average
annual flow rates should be estimates; otherwise it may be very difficult to
ensure the flow rates match information in Table A-8. The final destinations
indentified in the block diagram requested in Q. A1-25 should be general (e.g.,
off-site disposal, off-site reclamation, etc.) and not specific (e.g., the names of
off-site locations that receive materials).

Response
u. EPA deleted Table A-8 from the Questionnaire; therefore, clarification is
not needed. EPA deleted Table A-8; however, EPA has included definitions of
the following terms in the glossary: “process wastewater”, “treated”, and
“sludge” in the glossary of the questionnaire.
v. EPA removed the “Date of Retirement or Expected Date of Retirement”
column from Table A-9, because this information can be obtained from the
MACT ICR.
w. Although EPA removed the need to report type of boiler in Table A-9, EPA
added "Pressurized water reactor," “Boiling water reactor,” and “Pressurized
heavy water reactor” as response options in the "Type of Boiler or Reactor”
column for Table A-10. EPA also defined the terms "cycling unit" and
"intermediate unit" in the glossary of the questionnaire.
x. Cooling system data are not provided in Table A-9. EPA assumed the
commenter was referring to Table A-11. Table A-11 is already designed to
allow multiple cooling systems at the same plant to be reported, by designating
a cooling system in each row and indicating what units are serviced by the
system. Respondents should not use the 316(b) designations for the ICR.
y. EPA revised Table A-11 so that plants can specify more than one biocide
and more than one active ingredient can be added per biocide.
z. EPA revised the “Average Amount of Wastewater Generation/Blowndown”
and “Typical Duration AND Frequency of Generation/Blowdown” columns in
Table A-11 by changing "average" to "typical" in both columns.

u. Commenters think that the purpose of Table A-8 is unclear. Why does EPA
need sludge data for a water balance table? Also, does the “solids or sludge”
column refer to tons of sludge or tons of water in the sludge? Also, the volume of
sludge or solids should be an average because the amount of sludge or solids
produced on a daily basis can vary greatly over time. The terms “source water”,
“process wastewater”, “treated wastewater”, “solids”, “sludge” used in Table A-8
should be defined.

aa. EPA revised Table A-11 by changing the fourth column header "Type of
Biocide Used in Cooling System" to "Chemical Additives Added to the
Cooling System and Make-up Water System."

v. The “Date of Retirement or Expected Date of Retirement” column in Table A9 implies that any retired unit should be described. Responders may interpret
requirement of how far back to report differently. Because retired plants
generally do not generate wastewaters for discharge, this information request
appears to be excessive and would not yield useful information about the

cc. EPA deleted the request for copies of the reports and calculation sheets.
EPA refers to any type of monitoring used to demonstrate compliance. Plants
may provide further explanation in the comments page, as necessary. EPA
assumes that this question actually applies to A1-29 (Table A-11). Cooling
tower blowdown is relevant to the revision. Blowdown is currently covered

bb. EPA revised Table A-11 to include only condenser cooling systems.

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Comment
industry as a whole. Furthermore, personnel familiar with retired units are often
retired as well or no longer have detailed knowledge about older retired units.
Lastly, information about older retired units is often archived and/or is not
readily available. Therefore, EPA should consider requesting information for
units retired since a set date.
w. In Table A-9, EPA should include “nuclear” as an option in the “type of
boiler” column. EPA provides definitions for “peaking unit” and “baseload
unit”, but also needs to define “cycling” and “intermediate.”

Response
under the existing ELGs, regardless of whether treated prior to discharge. As
such, EPA is characterizing these waste streams, including how much is
generated/blown down.
dd. EPA reworded the instructions to state that "Throughout this section,
provide information for all steam electric generating units which were operated
in 2009 including units that operated for only part of 2009." With this change
"idle" and "extended period of time" do not need to be defined.
ee. EPA agrees. EPA deleted Q. A2-1 from the questionnaire and revised the
instructions for Q. A2-2 to include fuels used for start up. Therefore, no
further clarification is needed.

x. Commenters ask how should multiple cooling systems at the same facility be
distinguished in Table A-9 and also should the designations used for the 316(b)
questionnaire be used for this questionnaire as well.

ff. EPA revised Q. A2-2 to remove the terminology “normal operation.” EPA
has also revised the question to request use of “bituminous” coal.

y. For each cooling system there is only space for listing one biocide used in a
system in Table A-11. Commenters state that table A-11 should be revised to
allow for the identification of more than one biocide and more than one active
ingredient per biocide.

gg. EPA deleted. Q. A2-3 and Q. A2-4 from the questionnaire.
hh. EPA added questions to Section 3 asking if the plant ever washes the
catalyst on site. If so, the plant is prompted to answer similar questions that
are asked for the SCR catalyst regeneration wastewater. Additionally, EPA
defined the terms "SCR catalyst regeneration" and "SCR catalyst washing" in
the glossary of the questionnaire.

z. Table A-11 requests information in a manner that is certain to produce
responses that may not be comparable to other responses or may not meet the
agency's intentions with regards to the requested information. The fifth column
from the left asks for "Average amount of wastewater generated/blown down."
EPA needs to clarify the averaging period.
aa. Information regarding the use of biocides should be expanded to include all
chemical additives added to the cooling tower and make-up water systems. The
beneficial effects of these additives may impact the performance of downstream
wastewater treatment systems (WWTS) including, but not limited to the
clarification and/or filtration of cooling tower blowdown and chemical treatment
of FGD scrubber purge water where cooling tower blowdown is used as makeup
water to the scrubber system.
bb. Commenters believe that Table A-11 needs to be clarified to identify the type
of cooling systems to be included. If this is asking only for condenser cooling
systems, then that needs to be stated.
cc. Commenters state that in most cases, chemical additives used within cooling
tower systems can often be certified by our suppliers to be free of priority
pollutants. This should be added as a fourth check-box. Q. A1-30 requests for

ii. EPA added a "NA" box to the "Where Last SCR Catalyst Regeneration
Occurred" column. EPA believes that the comment regarding "every instance
of SCR offsite regeneration" probably applies to QA3-2, in which case EPA
agrees that it can reduce burden by limiting the response to the last two
regenerations. EPA defined the term “NOx control system” in the glossary of
the questionnaire. EPAdoes not believe the other terms need to be defined.
jj. EPA converted Q. A3-2 to a table to allow two companies to be specified.
kk. EPA has retained the request for planned systems and expects plants to
respond regarding any planned systems at the time they are completing the
questionnaire.
ll. EPA revised Q. A3-9 to exclude particulate matter control systems along
with FGD and SCR/SNCR systems that are not included in Table A-16.
mm. EPA defined the term "flue gas mercury control system" in the glossary

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Comment
copies of the reports and calculation sheets, which is excessive and unnecessary
for the development of revised ELGs and should be omitted from the ICR.
Additionally, commenters ask does Q. A1-30 refer to monitoring in addition to
priority pollutant sampling submitted with the permit renewal application or
reviewed on an annual basis. Commenters ask is the fate of the cooling tower
blowdown relevant to the steam electric guidelines revision. Cooling tower
blowdown is used internally or the cooling tower blowdown is sent to a
wastewater treatment system and not discharged directly to the receiving water
body. Are these flows still to be reported as "wastewater generated/blown
down?"
dd. Commenters believe the instructions of Section 2 need to be revised. They
are uncertain if a unit that did not operate at all in 2009 would be included. EPA
needs to define “idle” and “extended period of time.”
ee. Commenters wonder what the relevance is, for purposes of effluent
guidelines, of distinguishing fuels used for start-up from other fuels in Q. A2-1
and recommend deleting this question. Additionally, on a natural gas-fired unit,
which uses gas to both start up and generate, is there a clear demarcation for
when start-up ends and “steady state” operation begins. It is common practice in
air permits to define “start up” and it may vary. EPA needs to clearly define
when the start up period is over.
ff. For Q. A2-2, EPA should provide a definition for “normal operation.” EPA
should also provide definitions for “Eastern Bituminous” and “Western
Bituminous” as they are used in Table A-12. What is the relevance of this
question for effluent guidelines purposes?

Response
of the questionnaire.
nn. EPA assumes the commenter is referring to Q. A3-10 and removed the
request for "type of materials of construction" from this question.
oo. EPA reworded the language as suggested by the commenter.
pp. EPA has revised the request to specify all technologies studied, but to only
provide reports from technologies generate wastewaters. EPA disagrees that
pilot test data requested in Q. A3-11 are not applicable to the ELG. They are
useful for evaluating potential technology options that may be installed and
generate future wastewater streams.
qq. EPA replaced “Table A- 16’ with “Table A-17.”
rr. EPA changed the date in Q. A3-13 to January 1, 2009 from January 1,
2005.
ss. EPA defined the term "carbon capture system" in the glossary of the
questionnaire. EPA has phrased Q. A3-14 to allow plants the flexibility
necessary to adequately provide the information requested. EPA also revised
Q. A3-14 so that plants would only need to provide information on
technologies that generate wastewater.
tt. EPA disagrees that reports should be limited to those with wastewater
“impacts” due to the ambiguity in that term, and therefore has not removed Q.
A3-15 from the questionnaire.

gg. Commenters believe that Q. A2-3 requests for data on "any oil or coal" could
yield very large amounts of data, if coal samples are collected daily. Also plants
sample their coal differently, as some sample as received and other sample as
fired, which could include blends of various coals. They suggest EPA to re-think
this request as this data is not likely readily transferable to ELG water quality
data or standard setting. Additionally, Question A2-4 seems to imply that
analytical data required by A2-3 is required for each mine used to supply coal
burned by the unit. Question A2-3 should be revised to include only
representative data for each single type of fuel burned to minimize the ICR
burden. Or EPA should consider requesting averages of available data.
Additionally, EPA should consider limiting the coal analyses to volatile trace
elements – mercury, selenium, chloride, and boron – and consider more detailed

uu. EPA clarified in Q. A4-1 that processing coal includes any methods used
to prepare the coal for use at the plant including but not limited to
crushing/pulverizing coal.
vv. EPA clarified in Q. A4-2 that the plant can make an estimation of the coal
pile runoff, but a description of the calculation needs to be included. EPA also
clarified the request to report number of days of discharge rather than number
of days of runoff.
ww. EPA rephrased Q. A4-3 to ask "Was the coal pile runoff monitored for
pH?" If yes, the plant is required to provide data.
xx. EPA revised the question so that plants indicated whether the coal pile

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Comment
studies at select facilities Commenters believe that EPA's reason for requesting
the coal quality data is based on a false premise and EPA has failed to state an
adequate justification for this onerous data request.

Response
runoff was transferred to a pond/impoundment and had the option to choose
multiple options. EPA also defined the term “discharge” in the glossary of the
questionnaire.

hh. Commenters state that EPA should clarify Q. A3-1 to ask if catalysts are
washed with water onsite, and note that this does not include regeneration with
various acids/bases offsite. Most, if not all, catalysts are regenerated offsite
using various acids and bases. Some plants may wash the catalyst onsite to
remove fly ash. Some clarification is needed to ensure consistent responses. The
limited water data at most power plants will likely be of minimal benefit.
Comprehensive multimedia studies (consisting of flue gas, water, and solids
sampling and analyses) at numerous power plants are needed to characterize and
be able to accurately quantify the effects of NOx control on water.

yy. EPA revised Q. A4-5 by replacing the response option "All leachate
discharged" with "All treated coal pile runoff discharged." In Q. A4-2, plants
should provide their best estimate of generation.

ii. In Table A-14, EPA should define the terms “NOx control system”, “SCR”,
“SNCR”, “overfire air”, and “low NOx burner”. In addition, the “Where Last
SCR Catalyst Regeneration Occurred” column needs an “N/A” box. Answers to
the questions about future replacements/regenerations will be very speculative
and will depend on unit operation and current catalyst condition. Must the plant
report every instance of SCR offsite regeneration? This question needs a
reasonable timeframe – e.g., sent offsite within the last two years.

zz. “Coal washing” is defined in the glossary of the questionnaire.
aaa. EPA defined blending to be the intentional mixing of different coal types
prior to combustion, and does not include natural blending in the coal pile.
bbb. EPA replaced the term "pyritic mill rejects" with "mill rejects." EPA also
defined the term "mill rejects" in the glossary of the questionnaire.
ccc. “Waste coal” is defined in the glossary of the questionnaire. EPA also
removed anthracite culm and bituminous gob from examples of "Other coal."

jj. Additional lines should be provided for plants that send SCR catalyst off-site
to more than one facility for regeneration in Table A-14.
kk. Q. A3-9 asks for planned Hg flue gas controls. It is unclear how power plants
would respond since a mercury rule has not been finalized. This may also depend
upon other EPA actions on climate/carbon, CCPs, cooling system retrofits etc.
Commenters suggest limiting "planned" to a relatively short time period, such as
2 or 3 years – or a planned approach for responding to the proposed (and now
vacated) CAMR rule.
ll. Commenters believe the wording in Q. A3-9 needs further clarification.
Particulate collection systems, including baghouses, need to be excluded from
the questionnaire, along with the FGD and SCR/SNCR systems.
mm. EPA should define the term “flue gas mercury control systems.”
nn. Q. A3-9 Asks for the materials of construction for all mercury controls.
Commenters are unclear how this information could be used to characterize

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Comment
water quality or use, especially for activated carbon injection.

Response

oo. Commenters believe that Q. A3-10 is badly designed, will result in
inconsistent answers, and should be deleted. This question requires, inter alia,
that the respondent identify “any potential effect on other water streams” caused
by flue gas mercury control system processes. This language is too broad. At a
minimum, it should be reworded to require identification of “any known or
anticipated probable effect.”
pp. Commenters had several concerns about Q. A3-11. First, they believe pilot
studies do not indicate whether the full-scale plant will actually install this
technology and suggest limiting the request to reports that include impacts on
wastewater, given uncertainty over the dates and compliance approaches of
future rulemaking. In addition, data from a pilot test that will not be used at the
plant would also not appear to be relevant to this ICR and only increases the
burden on each respondent. Pilot studies are usually only of a slip-stream of flue
gas and are of short duration. In addition, many companies have performed
multiple pilot-scale flue gas mercury control studies. Many of these experimental
tests have never been implemented full scale; therefore, the results are not
pertinent to the effluent guidelines rulemaking. Additionally, most of these
studies have not evaluated wastewater impacts. At a minimum, this question
should be limited to reports that include wastewater impacts. This request is
extremely burdensome and will require a significant amount of time to locate
reports.
qq. In the description of Table A- 17, there is a reference to Table A- 16 that is
wrong – it should be A-17.
rr. In Q. A3-13 the time period for data request is for 2005 instead of 2009.
Commenters ask if this question should read as the previous section as January 1,
2009 or is it 2005.
ss. EPA should define what it means by a "carbon capture system" and provide
that definition to the public for review and comment prior to finalizing the
questionnaire. In addition, the request for "any potential effect on other water
streams" in Question Q. A-14 is too vague and speculative. EPA should identify
the effects that it is concerned about and specifically identify them in the
question so the respondents can determine if they are applicable. Commenters are
also concerned that the open ended nature of this question will result in
inconsistent answers.

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Response

tt. Some companies have performed multiple pilot-scale carbon capture studies.
Many of these experimental tests have never been implemented full-scale;
therefore, the results are not pertinent to the effluent guidelines rulemaking.
Additionally, most of these studies have not evaluated wastewater impacts. At a
minimum, Q. A3-15 should be limited to reports that include wastewater
impacts. This request is extremely burdensome and will require a significant
amount of time to locate reports.
uu. EPA needs to define “process.” Does crushing/pulverizing coal constitute
processing coal?
vv. Q. Commenters believe that A4-2 is badly phrased and should be modified or
deleted. EPA should allow the use of an estimate in Q. A4-2 because actual
amounts will vary. Companies can report on rainfall received or the amount of
discharge, but cannot report the total runoff or how many days it took to collect
the runoff. This is because runoff is affected by many factors, including
reuse/recycling, evaporation rate, ambient temperature, wind speed relative
humidity, and cloud cover, as well as the frequency, amount, and duration of
precipitation.
ww. Coal pile runoff is not required to be monitored for pH. Q. A4-3 should
include a response box for “Not Monitored.”
xx. In Q. A4-4 the respondent must specify if coal pile runoff is segregated,
commingled, or discharged without treatment. Commenters wonder how the
respondent answers if the plant has the ability to do any of these options,
depending on operating needs? Also, EPA should define “discharged.”
yy. Q. A4-2 through Q. A4-5 refer to coal pile runoff. One commenter states that
the volume of coal pile runoff at some of our sites is immediately captured and
reused in ash sluicing systems. There is no direct measurement of runoff volumes
collected during the process; it would strictly have to be a calculation of inches
of precipitation multiplied by the surface area of coal yard. Calling coal pile
runoff leachate, whether treated and discharged or otherwise reused, is incorrect.
It is not leachate, it is surface runoff. Therefore, the word “effluent” or the
phrase “treated coal pile runoff” should be substituted for “leachate” in the third
choice for this question.
zz. EPA should define “coal washing.”

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Response

aaa. Commenters believe that Q. A4-10 should be clarified so that it focuses only
on blending various coal types, such as PRB with eastern bituminous (i.e., the
intentional mixing of separate piles prior to combustion.. Coals from various
suppliers are blended naturally when each coal shipment is placed on the pile.
bbb. EPA should define the terms “pyritic mill rejects” and “mill rejects.”
ccc. EPA should define the term “waste coal” and distinguish it from anthracite
culm and bituminous gob. Typically, culm and gob are considered waste coal.
Part B/Flue Gas Desulfurization (FGD) Systems
a. Commenters noted that the use of “FGD System ID” in Table B-1 does not
agree with the nomenclature of “Sulfur Dioxide Control Systems” used in Table
A-17. Commenters also noted that some of the information requested in Table
B-1 is already reported in Form EIA-860 and Form EIA-923.
b. Commenters believe that EPA should identify a time period for “planned”
FGD systems and that it should be limited to relatively short time period, such as
2 to 3 years.

a. EPA deleted Table A-17 from the questionnaire; therefore, EPA did not
make any revisions to Table B-1. Additionally, EPA acknowledges that some
of the information in Table B-1 is reported in Form EIA-860 and Form EIA923; however, EPA is using 2009 as its base year for the technology evaluation
for this rulemaking and 2009 EIA will likely not be publicly available until the
middle of 2011. Additionally, EPA is requesting information for FGD systems
planned until 2020, which would not be available from either EIA form.
b. EPA revised Q. B1-3 by directing plants to provide information for
“planned” FGD systems that will be operating or begin
construction/installation by Dec 31, 2020.

c. Commenters believe that the terms “purge stream” and “scrubber purge”
should be defined.
d. Commenters noted that Q. B1-4 does not include a response category for
adipic acid.
e. Commenters noted that Table B-4 requested the materials of construction for
the FGD systems, including all of the pumps; but the shafts, impellers, housing,
etc., on the pumps may have different materials of construction.
f. Commenters noted that if a respondent answers “No” to Q. B2-1, the
respondent is allowed to skip to Section 3; however, Section 3 is also associated
with Wet FGD systems. Commenters recommended that if a respondent answers
“No” to Q. B2-1, the respondent can skip to Section 4.
g. Commenters noted that the phrase "which section of system," in Q. B2-3 could
potentially lead to a wide range of responses; therefore, the commenters
suggested re-phrasing sentence to "and indicate which specific equipment units of
the FGD system determines…."

c. EPA replaced the term "purge stream" and "scrubber purge" with "FGD
scrubber purge (or slurry discharge)" throughout Part B of the questionnaire.
EPA also defined the term “FGD scrubber purge” and “slurry discharge” in the
glossary of the questionnaire.
d. EPA added adipic acid as an option in Table B-3.
e. EPA deleted Table B-4; however, EPA is now requesting the materials for
the equipment unit(s) that determine the maximum design chlorides
concentration of the FGD system. If multiple materials of construction are
used in the equipment unit(s), the plants are ask to provide the material of
construction that is most vulnerable to corrosion due to chlorides.
f. EPA corrected the skip pattern for this question.
g. EPA incorporated these changes.

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Comment
h. Commenters noted that Q. B2-4 asks for system parameters “used to control
the FGD slurry blowdown from the FGD system.” The commenters asked
whether this refers to the parameters used to control the quality of the FGD slurry
as it leaves the absorber vessel, or at some other point in the process.
i. Commenters noted that Q. B2-5 asks for the water sources that may be used as
a source of FGD slurry water or FGD slurry water makeup. The commenters
stated that the second reference to slurry water should be deleted.
j. Commenters stated that many companies do not measure the mist eliminator
wash, limestone preparation water, and FGD make-up water flow rates and that
the flows vary widely based on operating conditions. Commenters believe that
these questions are unlikely to generate usable, consistent responses.
Commenters believe that an estimate would better fit an annual average instead
of the stated instantaneous flows, durations, and frequency. A water balance
based on annual flows and power production would be a more accurate reflection
of operation.
k. Commenters noted that Table X-X, which is referenced in several questions,
was not provided.

m. Commenters noted that Q. B2-14 uses the term “blowdown slurry,” and asked
if that is the same as “slurry blowdown”?
n. Commenters requested that EPA clarify the distinction between solids
separation and solids settling.

j. EPA changed the wording of those questions to ask for “typical flow rate,
duration, and frequency” and, if the FGD was not operating in 2009, the flow
rate data for 2010 should be provided.
k. EPA included the process codes in the dropdown boxes in the 2nd FRN
version of the questionnaire. EPA also added a “Code Tables” tab at the end
of each part for reference.
l. EPA revised the question to ask if the FGD solids are mixed with ash and
then included an additional question to ask whether a pozzolanic material is
formed.

n. EPA amended Figure B-1 to clarify “FGD solids separation” systems for
Part B. EPA also added the term “FGD solids separation” to the glossary.
o. EPA replaced the term “gypsum stack” with “gypsum stacking.”
Additionally, EPA defined the term “gypsum stacking” in the glossary of the
questionnaire.
p. EPA provided an example in the question to clarify both temporary and
permanent storage.

o. Commenters requested that EPA define the term “gypsum stack” from Q. B215.

q. Commenters believe that the 5 year period of time requested for Tables B-5,
B-6, B-8, and B-9 is not necessary to gain an understanding of FGD solids

i. EPA reworded Q. B2-5 to ask for “water sources that may be used as a
source of FGD reagent preparation water or absorber make-up water (e.g.,
fresh intake, recycled process water).”

m. EPA incorporated these changes by replacing "blowdown slurry" with
"FGD slurry blowdown" throughout this part.

l. Commenters noted that Q. B2-13 seems to presume that blending fly ash with
FGD solids always results in a pozzolanic material and that is not always the
case.

p. Commenters noted that Q. B2-16 uses the terms “permanently” and
“temporarily” regarding the storage of FGD solids in landfills and/or
pond/impoundments. The commenters requested that EPA define these terms.

Response
h. EPA revised Q. B2-4 to read “Indicate the FGD system parameter(s) that are
used to determine when the FGD slurry is blown down from the FGD system.”

q. EPA revised the question to request three years of data to minimize burden.
However, EPA believes obtaining data that spans 2005-2009 will better
represent disposal and sale practices for FGD solids, so has instead requested
data for 2005, 2007, and 2009. EPA acknowledges that some of the
information regarding FGD solids disposition is included in Form EIA-923;
however, the 2009 data will not be available until the middle of 2011.
Additionally, the information is reported on a plant level to EIA, whereas,
EPA is requesting the information on a unit level to determine how different

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disposal and resale. Commenters believe the request is overly burdensome and is
unlikely to provide information that is more representative than the 2007 through
2009 time period. The commenters recommended using a 3 year period of time
to minimize the questionnaire burden. Commenters also noted that the some of
the information regarding FGD solids disposition is reported in Form EIA-923.

Response
unit/FGD system characteristics impact the disposition of the FGD solids.

r. Commenters noted that Q. B2-17 through B2-19 request information regarding
revenue generated from marketing of FGD solids. Commenters believe that the
potential changes to the classification of ash products under RCRA could
severely restrict or eliminate any beneficial reuse of coal combustion residuals
and therefore, would decrease or eliminate the projected revenue streams and
needs to be considered when EPA begins analysis for the compliance cost model.

s. EPA provided additional clarification in Q. B2-18 on what should be
included in the costs (e.g., labor, materials, transportation, energy). In
addition, EPA combined Q. B2-18 with Q. B2-19 requesting the costs for
2005, 2007, and 2009. In the table, EPA included separate rows for each of
the items identified in QB2-19 and requested the estimated costs for each item
and the sum at the bottom of the table.

s. Commenters suggested that Q. B2-18 and B2-19 should be redesigned to be
more explicit about the costs that should be included, such as labor costs.
Additionally, commenters noted that Q. B2- 18 requests total costs incurred to
remove or dispose of FGD solids in calendar year 2009, while Table B-6 asks for
five years of FGD solids sales and marketing information. The commenters
believe this creates an incomplete economic picture of the costs and benefits of
FGD solids management.

t. EPA clarified that the plants should provide the chlorides concentration on a
wet basis (i.e., analyze the chlorides for the FGD solids with the moisture
content included); however, if they do not have the concentration on a wet
basis they should provide the dry-basis concentration and note it in the
comments.

t. Commenters asked what basis the concentration of chlorides in FGD solids is
to be provided (e.g., dry solids, liquor, other).
u. Commenters believe that the terminology used in Table B-7 is confusing.
Commenters suggest that the terms be defined and used consistently throughout
the ICR. Commenters also noted that an estimate would better fit an annual
average instead of the stated instantaneous flows, durations, and frequency.
Additionally, commenters asked what period of time the average should apply
(e.g., calendar year 2009), as well as whether the average should be a median,
mode, or mean value.
v. Commenters noted that it is difficult to obtain representative analytical data on
untreated FGD purge stream, as requested in Q. B3-3, due to its high TSS and
heterogeneous nature. Commenters suggested that EPA should request
information on sample collection and analysis techniques. Commenters also
believe that the data request should be limited to data collected during 2009
because providing 2010 data will be too burdensome, in that the data needs to be
validated and analyzed before it is provided. Commenters requested that EPA
define “solids separation process” and provide examples, such as, how does a

r. EPA acknowledges that future rules may affect the use of FGD solids;
however, past actions will assist EPA in characterizing options. EPA limited
the request to three years to minimize burden.

u. EPA discussed potential changes to the terminology with UWAG and
revised it in Figure B-1 and throughout Part B. In Table B-7, EPA removed
the term “slurry water.” EPA replaced the “Slurry Blowdown Returned to
Absorber as Makeup following Solids Separation” column heading with “Solid
Separation Recycle Returned to Absorber” and replaced the term “average”
with “typical” in the column headers. EPA also defined the term “FGD
reagent preparation water” in the glossary of the questionnaire.
v. EPA clarified in Q. B3-3 that respondents can provide additional
information regarding the sample collection techniques or analytical methods
in the “Part B Comments” tab at the end of the part. EPA defined the term
"FGD solids separation" in the glossary and added clarification that the
monitoring data should be collected after the last solid separation process, if
multiple processes exist, and that the “last 12 months” applies to the date of
the receipt of the ICR. In addition, EPA clarified the type of monitoring
location by providing examples. EPA notes that they are requesting for
dilution corrected quantitation limits because it is asking for the samplespecific quantitation limit. EPA disagrees that data request should only be
limited to data collected under normal operating conditions, because the plants
can provide additional details regarding any data provided in the “Part B
Comments” tab at the end of the part.

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plant with primary and secondary hydroclones respond. Commenters also believe
that EPA should provide clear instructions for describing the monitoring location.
Commenters noted that EPA asks for the sample-specific nominal quantitation
limit stipulated for the method used; however, they believe EPA should be
requesting the sample-specific (dilution corrected) quantitation limit.
Additionally, commenters believe these terms also need to be defined.
Commenters believe that the data request should be limited to data collected
under normal operating conditions and that any data collected during research
and development activities should be excluded.
w. Commenters believe that the requested information in Q. B3-3 is important,
however, they believe that providing the monitoring data in the specific ICR
electronic format adds additional burden to respondents. Commenters noted that
monitoring data, in most cases, were not provided in electronic format and were
not supplied in the ICR specified format. Therefore, hardcopies of the monitoring
data could be scanned and provided, but commenter believe the manual transfer
of this data into electronic format is not feasible in the time period provided.
x. Commenters believe that the submittal of monitoring data requested in Q. B33 should be limited to that obtained using EPA-approved laboratories and
methods. Commenters also believe it should be limited to NPDES permitrequired monitoring.

Response
w. EPA understands that the transfer of data to an electronic format can add
burden if not already available electronically. However, EPA believes this is
necessary to ensure collection of all data requested in a format that is not
subject to misinterpretation by EPA.
x. EPA disagrees with the suggestion to limit responses to data collected for
NPDES monitoring because plants are not typically required to collect
untreated FGD scrubber purge samples as part of NPDES permitting, but are
known to collect these data internally for evaluation of their operation.
Additionally, all monitoring data collected should be provided regardless of
method or laboratory as it is still useful for characterizing the FGD scrubber
purge stream.
y. EPA has changed the wording of Q. B3-4 to ask if the plant transfers “the
FGD scrubber purge (or slurry discharge) to a settling pond."
z. EPA replaced the term “FGD water” to “FGD scrubber purge (or slurry
discharge).”
aa. EPA defined the term “mill reject sluice” in the glossary of the
questionnaire
bb. EPA added a specific option for “deep well injection” and another option
for “Other.”

y. Commenters noted that FGD water streams can be sent to a pond with a
NPDES permitted outfall, but not discharge the water since the FGD waste
stream has been sent to the pond. Therefore, the FGD pond water is stored in
preparation for possible discharge, and the answer to Q. B3-4 is neither yes nor
no, the only two options available. A third option, such as a general “Other
(Explain)” is needed for this question.

cc. EPA did not incorporate these changes because information regarding the
specific chemicals used in the system is obtained in Part D of the ICR.
dd. EPA replaced the term "gypsum stack runoff" with "gypsum pile runoff."
EPA defined the terms “gypsum wash water” and “gypsum pile runoff” in the
glossary for the questionnaire.

z. Commenters requested that EPA distinguish “FGD water” from “FGD purge
wastewater.”
aa. Commenters requested that EPA define “mill reject sluice.”
bb. Commenters noted that Q. B3-8 is not appropriately drafted for facilities that
use deep well injection as the ultimate destination for their FGD water stream.
Commenters suggested that EPA add an “other – please specify” category of
response to this question.

ee. EPA is gathering data on all potential technology options that can reduce or
eliminate potential pollutant discharges associated with this industry.
Therefore, information on dry solids handling is pertinent to the revision of the
ELG.
ff. EPA acknowledges that future rules may affect the use of FGD solids;
however, past actions will assist EPA in characterizing options. EPA limited

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cc. Commenters noted that Q. B3-7 chemical precipitation option does not break
out lime, iron, and sulfide. Commenters suggest that EPA provide extra response
categories for lime, iron, and sulfide.
dd. Commenters suggested that EPA define “gypsum wash water” and “gypsum
stack runoff.”
ee. There are several instances where the questionnaire requests detailed
information on processes that cannot reasonably be expected to contribute
wastewater sources that would be covered by the ELG's (for example Question
B4-11 regarding five years of disposal records for dry FGD solids.
ff. Commenters noted that information on revenue generated from marketing of
dry FGD ash in Q. B4-12 could be significantly impacted by changes to ash
disposal regulations. Commenters also noted that the technologies that may be
required to meet upcoming mercury removal requirements could negatively
impact the marketability of the ash products. For example, use of activated
carbon for mercury removal can significantly change the characteristics of the
ash produced and make it undesirable for other uses. Commenters believe this
would significantly impact the accuracy of the compliance cost model.

Response
the request to three years to minimize burden.
gg. EPA provided additional clarification in this question to include costs for
labor, materials, transportation, and energy.
hh. EPA deleted Table B-10 from Part B; however, EPA made the following
changes to the appropriate drop down boxes and/or the “Code Tables” tab at
the end of Part B:
- EPA added “Soda ash” to the list of sorbent types;
- EPA changed “TMT-15” to “Organosulfide”;
- EPA added an option for “spray/tray”; and
- EPA added the list of FGD materials of construction to to options in Q.
B4-3 (based on 2nd FRN version numbering).
EPA disagrees that the standard types of FGD systems need to be specifically
defined; therefore, EPA did not define mechanically aided.
ii. EPA acknowledges that the information collected in Q. B1-1 is also
collected in Form EIA-860; however, EPA is using the information to identify
if the plant has to complete the remainder of Part B. Additionally, Q. B1-1
asks requests information for planned FGD systems that go beyond that
captured by Form EIA-860.

gg. Commenters suggested that EPA clarify what should be included and
excluded when calculating total costs in Q. B4-13.
hh. Commenters suggested that changes be made to Table B-10 regarding
chemical additives, types of FGD system, and materials of construction.
ii. Commenters noted that Q. B1-1 asks information that is requested in Form
EIA-860.
Part C/Ash Handling
a. The conversion to dry handling could greatly increase the costs for dust
suppression activities on the site yet there is no mention of this in the survey.
b. Commenters believe that the 5 year period of time for requested for Part C is
not necessary to gain an understanding of fly ash and bottom ash solids disposal
and resale and recommends using a 3 year period of time to minimize the ICR
burden.
c. Commenters believe that Part C is not well laid out for a facility that handles
both bottom ash and fly ash dry, but combines all the ash in a silo for storage

a. EPA has revised the cost sections in Part C, which include obtaining costs
for dust suppression activities (e.g., around silos in which fly ash conditioning
occurs, and that associated with landfilling, etc.).
b. EPA revised the instructions to request information from three years (2005,
2007, and 2009) instead of 2005-2009.
c. To address the possibility of plants that combine fly ash and bottom ash in a
silo, EPA has added a new section to Part C for combined fly ash and bottom

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prior to beneficial reuse and that EPA should consider, for each portion of Part C,
how such a facility would respond to the question.
d. Commenters suggested that Table C-1 be modified in several ways including
adding the definition of “average” amount of dry fly ash, and specifying that
information is for the year 2009. Commenters also believe that loss on ignition is
not relevant to the effluent guidelines rulemaking and that determining the
percent of fly ash handled as dry or wet will be difficult to determine for a plant
that operates both systems. Also commenters requested the clarification of the
ton basis in Tables C-1, C-6, C-13, and C-14 to indicate dry tons of ash.
e. Commenters noted that Q. C1-4 and C1-5 do not take into account any
changes or retrofits from one type of dry ash handling system to another type of
dry ash handling system and ask how the reasons for fly ash and bottom ash
handling system retrofits are relevant to the rulemaking.
f. Commenters believe that Q. C1-5, C1-6, C1-24, C1-27 and 2-5 are very openended and will produce inconsistent answers. Commenters stated that there are
many types of changes that could be discussed under this question, including
physical changes to the facility, changes in personnel, changes in training,
changes in ash disposal practices, changes in ash marketing practices. In
addition, commenters noted that current personnel may not be aware of why
certain actions/retrofits occurred, and there may not be any documentation
available to answer this question.
g. Commenters noted that Table C-2 in Q. C1-9 asks for percent moisture of fly
ash, but does not segregate the question for ash wastes that are moistureconditioned prior to final disposal. Commenters also believe that the tons of fly
ash transported to a silo at a plant that also sluices fly ash will be difficult to
determine, since this value is not calculated/measured/recorded.
h. Commenters indicated that Q. C1-11, Q. C1-13, Q. C3-3, and Q.C4-3 refer to
process wastewater/treatment codes in Table X-X, which is not present in the
draft questionnaire.
i. Commenters believe that potential changes in revenue streams from beneficial
uses as a result of changes to ash handling and air emissions regulations must be
accounted for in the compliance cost model and that more restrictive state
regulations on beneficial use of ash products need to be considered in
development of a national compliance cost model.

Response
ash handling.
d. EPA replaced the term “average” with “typical” amount of fly ash produced
and specified where data should be provided for the year 2009. EPA kept the
loss on ignition of fly ash in Table C-1 to determine potential markets for fly
ash for EPA’s cost analysis. EPA recognizes that providing the wet and dry
ash handling percentage information may be more difficult for plants that do
not keep track of this information. Therefore, they should provide their best
estimates, which is explained in the front matter of the questionnaire. Also,
EPA revised the tables and other questions throughout the part to require
tonnage on a dry basis where appropriate.
e. EPA would use the information to assess/predict the number of plants that
may convert to dry ash handling, apart from a potential EPA requirement
Additionally, EPA would use this question to assess the reasons behind
converting to dry ash handling and how this might affect future operations.
This information will be considered when evaluating the technical feasibility
of such options. EPA modified these questions and added additional questions
to account for dry fly ash handling systems that were modified/retrofitted.
EPA made the same changes to the bottom ash section.
f. EPA added response options to the questions to obtain consistent responses.
Additionally, the questions were expanded to encompass the entire dry ash
handling system, including components associated with transport/disposal.
EPA recognizes that providing this information may be more difficult for
plants that do not keep track of this information. Therefore, EPA expects
plants to provide information to the best of their ability and note any
uncertainties in the Comments page.
g. EPA revised Table C-2 by changing the column heading to “Percent
Moisture of the Fly Ash Entering Destination.”EPA recognizes that providing
this information may be more difficult for plants that do not keep track of this
information. Therefore, they should provide their best estimates, which is
explained in the front matter of the questionnaire.
h. EPA included the process codes in the dropdown boxes in the 2nd FRN
version of the questionnaire. EPA also added a “Code Tables” tab at the end
of each part to refer to.
i. EPA is aware that such changes may affect beneficial uses, and EPA will be

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Response
assessing the impact.

j. Q. C1-13 and Q. C1-14 relate to water usage in fly ash which is sold in order to
evaluate water reuse opportunities. Commenters noted that water may also be
used with fly ash that is not sold, and is a potential reuse option. Commenters
also asked why data on chlorides or solids in the water used for moistening fly
ash is being requested and recommend that EPA ask specifically about
operational criteria – i.e., “Identify any other operational criteria that the source
water must meet.”
k. Commenters believe that Q. C1-16 and Q. C2-28 are likely to produce
inconsistent answers because EPA does not specify what should be included in
“total costs” and asked whether costs associated with constructing a landfill and
dry handling systems, adjustments to the facility air permit or labor costs should
be included.
l. Commenters noted that there is no information available for fly ash quantities
related to individual electrostatic precipitators..Also, commenters suggested that
the instructions for Q. C1-18 refer to “dry to wet” instead of “wet to dry
junctions” and clarify how the distance from the dry-to-wet junctions and the ash
ponds or other final destination should be measured particularly if multiple ponds
were used. Commenters noted that in Table C-5 Column 3’s heading should be
“Number of Dry-to-Wet Mixing Junctions” and needs the phrase “ junctions”
added in the second row.
m. Commenters believe that Q. C1-21 is very open-ended and will produce
inconsistent responses.
n. Commenters believe that systems that are “planned” should be limited to
systems that are planned to be installed by the end of 2012.
o. Commenters believe that in Q. C1-26 and Table C-6 the term “Wet Fly Ash” is
potentially misleading and recommend changing the wording from “Wet Fly
Ash” to “Fly Ash Moved by Wet Handling” and that a similar change should be
made in the bottom ash section.
p. Commenters believe that the requirement to include bid proposals in Q. C1-27
is unnecessary because bid proposals may have little relation to actual cost
estimates for an entire project and can reflect many pricing issues that are not
objective, such as the business relationship between the site and the bidder.
Commenters also believe that bids do not reflect true costs of the

j. EPA revised the skip patterns to require all plants that complete the dry fly
ash handling section to complete Q. C1-13 and Q. C1-14, not just those that
market the ash. EPA is requesting information chlorides and solids in the
water used for moistening fly ash in order to evaluate water reuse
opportunities. If the plantdoes not measure chlorides/solids percentage, they
can respond in the "Other" space provided.
EPA did not modify the question to ask only about operational criteria.
k. EPA deleted Q. C1-16 and C2-28 and revised the cost sections of Part C to
include separate sections for fly ash conveyance, intermediate storage, and
transport/disposal.
l. EPA deleted the request for “Number of Hopper Trains in ESP/Baghouse” in
question C1-18 and EPA replaced any references in Q. C1-18 of “wet to dry”
with “dry to wet.” Additionally, EPA specified in the instructions of the
question that the distance to the ash pond(s) is the distance to the end of the
sluice pipe at the furthest ash pond (if multiple ponds). EPA added the phrase
“junctions” to the second row of column 3 in Table C-5.
m. EPA phrased Q. C1-21 in this manner to provide plants the flexibility
necessary to provide the information requested.
n. EPA revised questions throughout the questionnaire by directing plants to
provide information on “planned” units/systems that will be operating or begin
construction/installation by Dec 31, 2020. Power plants have made substantial
changes to equipment in recent years and are expected to continue making
significant changes in the near future. EPA is collecting this information to
allow the Agency to reasonably predict the costs and other impacts associated
with revisions to the ELGs.
o. EPA revised Q. C1-26 and Table C-6 by replacing the term “Wet Fly Ash”
with “Fly Ash Transported by Wet Sluicing” and made the same change in the
bottom ash section.
p. EPA recognizes the limitations of system/cost information in bid
proposals/engineering reports; however they may provide useful information
to fill data gaps, particularly for previously planned wastewater treatment
systems, and as general verification of other ash handling system costs
obtained. Additionally, EPA provided clarification to mark any bid

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installation/construction and that EPA should not request the submittal of bid
information for any purpose.

Response
proposals/engineering reports CBI, if applicable.

q. Commenters believe that the O&M and capital cost categories are too specific
in Tables C-7 and C-8. Commenters recommended specifying the types of O&M
and indirect and direct capital costs to be considered in the description for
clarification and requesting only the total O&M cost and total capital costs in
order to reduce the burden of the ICR. Also, commenters stated that O&M costs
are not tracked by individual systems, such as the fly ash handling system but
instead, generally compiled for all CCB systems (bottom ash, fly ash, scrubber
solids, etc.) together and therefore, commenters believe that industry accounting
systems make this table (and all the similar tables) very difficult and time
consuming to prepare.
r. Commenters noted that Q. C1-27 and Q. C2-27 request capital costs, but do not
request information related to design ash generation rates (only actual 2009 rates)
and recommended adding a question to request the design ash handling rate, so
that capital costs can be adjusted if actual generation rates differ from design.
s. Commenters believe that asking how fly ash handling system components are
used between multiple generating units is open-ended and likely to produce
inconsistent answers and that EPA should specify what it means by “O&M or
capital cost overlap.”

q. The O&M and capital cost breakouts will allow EPA to most accurately
compare costs for ash handling systems in the industry. EPA expects plants to
provide information to the best of their ability, providing estimates if
necessary. Estimated responses should be noted in the Comments page.
Also, Obtaining separate O&M costs for fly ash and bottom ash handling
systems (and separate from other CCB systems) will be critical for EPA's cost
analysis. EPA expects plants to provide these data to the best of their ability,
using estimates as necessary.
r. EPA added questions requesting the design ash handling rate in the bottom
and fly ash handling system sections.
s. EPA changed the questionnaire sections to request data on ash handling
systems rather than on the electric generating unit level, which should
minimize instances of reporting “overlap.” Overlap occurs when more than
one system shares common components (e.g., intermediate storage silo). In
addition, EPA requested systems to be defined for conveyance versus storage
versus transport and disposal, and added more description of how to best
define systems to avoid this reporting “overlap.”
t. EPA modified the subsection instructions to indicate that the subsection
should only be filled out for dry bottom ash handling systems.

t. Commenters noted that there should be some information in the instructions in
Section 2 telling respondents which question to skip to if there are no dry bottom
ash collection systems and requested the addition of a question asking if the plant
has a dry bottom ash handling system.

u. EPA expects plants to provide accurate data to the best of their ability,
providing estimated data as necessary. EPA revised Table C-9 so the latter part
of the comment is no longer relevant.

u. Commenters stated that bottom ash produced is not a measured value but is
instead calculated based on plant and coal characteristics and that EPA should
remove the “check” in the box for “both” in column 3, row 2.

v. EPA expanded these questions into multiple questions to find out more
specifically why the fly/bottom ash is sluiced and whether the plant has the
capability to handle all fly/bottom ash dry.

v. Commenters believe that Q. C1-3 and Q. C2-2 are very open-ended and will
likely produce inconsistent answers.

w. EPA revised Table C-10 to provide long drop-down menus that provide
multiple options for each of the types of destinations currently listed (for each
row in the table).

w. Commenters asked how the distance should be calculated when multiple
parties or locations received bottom ash in 2009.

x. EPA replaced the term “solid waste” with “bottom ash disposal;” therefore,
the term “solid waste” is not defined in the glossary of the questionnaire.

x. Commenters stated that EPA needs to define “solid wastes” for purposes of

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this Table C-13.
y. Commenters believe that Q. C2-20 through Q. C2-27 should clarify if the
Agency is referring to wet handling, wet disposal, or both. Subsequent questions
should be structured to address the desired scenarios.
z. Commenters suggested that the cost of any modifications required to install
dry bottom ash handling systems be requested as part of Q. C2-22.
aa. Commenters stated that segregation of the ash types requested in sections 3
and 4 varies from plant to plant and on a unit by unit basis and believe that it may
not be possible to provide all of the information, such as that requested in
question C3-2.
bb. Commenters stated that one option EPA is considering is to establish federal
non-hazardous waste regulations for CCBs pursuant to RCRA Subtitle D and that
such a regulation would impose requirements for the landfilling of coal ash and
other CCBs, such as possible requirements for landfill liners, leachate collection
systems, and possible phase-out and closure of CCB surface impoundments.
Commenters believe that if EPA finalized the rule using this option, significant
portions of the Questionnaire would be rendered largely obsolete or irrelevant
including the much of Part C. Commenters also believe that if EPA proceeds
with the Subtitle C option, even more of Part C would become irrelevant for
purposes of the effluent guidelines rulemaking.

Response
y. EPA defined the terms “wet bottom ash handling” and “dry bottom ash
handling” in the Part C instructions, clarified that Q. C2-24 refers to bottom
ash that is moved by wet sluicing.
z. EPA requested the costs of modifications required to install bottom ash
handling systems in the bottom ash handling system cost sections.
aa. EPA did not revise the question, because EPA expects plants to provide
data to the best of their ability, providing estimates if necessary. However,
EPA did add a question asking whether economizer and air heater ash are
handled together. If this is the case, the plant can answer the economizer ash
section for economizer and air heater ash together.
bb. EPA is not removing any questions in Part C, because EPA believes the
information requested in this part is independently important regardless of the
outcome of the CCB rule.
cc. EPA added questions requesting the estimated length of the outage
necessary to perform a bottom ash retrofit and asking what modifications are
necessary for a dry bottom ash retrofit. However, instead of including a
question requesting the space available below or around boiler, EPA has
requested engineering diagrams to depict the configuration and location of the
ash handling conveyance system.

cc. Commenters stated that the typical technologies for dry bottom ash
conversions rely upon a long, water-filled rectangular trough at the base of a
boiler, with a drag out chain and dry conveyor to remove the ash from the boiler
building and while the space can usually be allocated for a new facility or unit,
most existing boilers have no room for this equipment. Commenters indicated
that the bases of many existing boilers are located in small sub-basements that
are surrounded by massive amounts of steel and concrete that support the multistory boilers and to re-engineer the base of these boilers to provide room for a
trough, drag-out chain and conveyor would require removing and relocating
massive amounts of steel and concrete supports which is a major impediment to
dry bottom ash retrofits at most existing facilities. Commenters noted that the
questionnaire does not ask any questions about the feasibility of retrofitting
bottom ash handling at such facilities and recommended that at a minimum, EPA
should develop a set of questions about the following: (1) whether there is

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available space for a possible bottom ash retrofit; (2) whether the boiler’s base is
below grade; (3) the estimated length of the outage necessary to perform a
bottom ash retrofit; and (4) a description of the equipment necessary to be
installed for a dry bottom ash retrofit.

Response

Part D/ Pond/Impoundment Systems and Other Wastewater Treatment Operations
a. Commenters expressed their concern regarding the instructions and terms used
in Part D. For example, respondents were confused on whether or not
ponds/impoundments that perform treatment should be included as
ponds/impoundments or wastewater treatment units. Commenters also expressed
concerns about missing definitions for key terms throughout part D. These terms
include things such as non-pond unit, “planned activity”, and pond/impoundment
unit versus system. EPA should confirm that the responses to Part D are limited
to CCB management units.

a. EPA has carefully reviewed and revised the instructions in Part D to clarify
the type information that is being requested. For example, it is clear that
ponds/impoundments that perform treatment should be identified as a
pond/impoundment system, unless part of a broader wastewater treatment
system. Clear definitions and examples were added to the Part D instructions
and to the glossary to aid respondents in answering the questionnaire. EPA
also provided guidance for requests of “planned activity” as a result of public
comment.

b. Throughout Part D, questions regarding retired units should not be included if
the pond/impoundment unit discharges wastewaters other than stormwater (e.g.,
leachate).

b. EPA kept all questions regarding retired units, because they are used to
gather information on trends in the life of pond systems, to gain knowledge on
BMPs for closed or retired units, and to understand costs required to
implement or close a pond/impoundment.

c. Under the section on closed pond/impoundment units there is no mention of
pond dewatering systems and the costs associated with installation and operation
of those systems. These costs should be included in any compliance cost model.
d. In Q. D1-1 and Table D-1, EPA does not define what it means by “retired” or
“closed” pond/impoundment systems. These terms should be defined.
e. Commenters suggested revising the last column heading of Table D-1 to read
"Individual Ponds/Impoundments Included in the Pond/Impoundment System
(identified in Table A-4)."
f. It is unclear how to label ponds in Q. D1-1 and Q. D1-2. Clarify how ponds
should be labeled.

c. EPA believes that Q. D3-21, which asks facilities to describe the closure
process for ponds/impoundments (including required steps and associated
costs), captures any dewatering process associated with the closing of
ponds/impoundments. EPA clarified that the respondent must include the
costs associated with the closure.
d. EPA has set up Part D to allow all ponds to be reported as either
“active/inactive/operating,” “retired/closed,” or “planned” and does not believe
it is necessary to define these terms individually. Plants should classify ponds
in the most appropriate category.
e. EPA incorporated these changes.

g and h. Q. D1-3 and Q. D1-5 are overly burdensome and will provide
inconsistent answers. The reliability of study data varies, particularly as studies
become dated and information about correct sampling and analysis techniques is
developed. It is important to ensure that older, outdated studies are not relied on
for purposes of this rulemaking. In addition, the ICR should inquire about
concerns associated with the quality of the study data. EPA should request
information only on full-scale studies conducted from January 2005 or 2007 to

f. EPA revised the example in the instructions to provide additional
clarification on how to label the pond designations. EPA has also provided to
example diagrams (EPA_D-1 and D-2) to Part D for further clarification.
g and h. EPA revised these questions to request studies since 2000 (versus
1995) to reduce burden. EPA also removed the detailed request for bench-scale

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Comment
December 2009..

Response
studies.

i. Does Section 2 include all wastewater ponds including non-ash or industrial
wastewater-only ponds?

i. EPA stated in the instructions that Section 2 should be completed for each
pond/impoundment system or wastewater treatment system identified in
Tables D-1 and D-2. These tables are limited to systems that treat wastewaters
from ash or FGD operations.

j. Commenters stated that because specific instructions are provided and must be
met for the Block Diagram requested in Q. D2-1, existing block diagrams will
not meet these requirements, and block diagrams from planned WWTS will need
to be more fully developed. In addition, diagrams are typically prepared by our
environmental consultants when preparing permit applications. Therefore, none
will contain data from 2009. As a result, subcontractors will be required to
complete this activity. Also, final destinations required in the diagram should be
general and average flow rates should be estimates in order to match Table D-3.
k. Many of the flows requested are not currently monitored. Normally, the
discharge flow is taken from reading pump curves on the intake. It is unlikely
that the resulting “water balance” will actually balance because of the number of
estimations involved.
l. EPA needs to provide Table X-X.
m. Table D-3 requests information on influent/effluent solids/sludge streams, but
the column headings do not clearly identify these streams. Add a column stating
whether the stream is influent or effluent, and clarify units for solid/sludge
streams (tons/day of solids or gallons per day flow rate).
n. Residence time and life of impoundment varies depending on the state of the
unit, when it was last dredged, etc. Q. D3-1 alone may cause detailed surveys to
be performed. EPA should define “residence time.”
o. Many of these impoundments were designed and built over 30 years ago.
Design information requested in D3-2 will be very difficult to find and may not
exist at all.
p. Q. D3-2, Q. D3-3, and Q. D3-4 should be revised because the maximum
pond/impoundment depth for some facilities may include a requirement to
maintain a certain minimum level of freeboard below the top of the embankment.
q. Maximum current depth data requested in Q. D3-3 may not be available
without taking field measurements from a boat! EPA should not require
responders to generate new data specifically for this questionnaire

j. EPA did not remove the block diagram requirement, because it is standard
and necessary. EPA recognizes that the survey requests more information than
what is used for permit requirements; however, the overall burden of this
question is lessened by only requiring block diagrams for treatment systems of
interest, not all treatment systems. Additionally, due to the timing of the ICR
mail-out, 2009 data will be available. EPA also clarified in the 5th item of the
block diagram checklist to explain that the destinations should be "general"
and that codes should be used from the “Code Tables” tab.
k. EPA recognizes that some flow rates requested may not be monitored.
Therefore, plants should provide their best estimates.
l. EPA included the process codes in the dropdown boxes in the 2nd FRN
version of the questionnaire. EPA also added a “Code Tables” tab at the end
of each part for reference.
m. EPA revised this table by making it specific to influent streams, and added
a second table for effluent streams. In addition, EPA specified units for
solid/sludge streams in tons per day or gallons per minute.
n. EPA rephrased Q. D3-1 to ask for "residence time (as currently operated)."
o. EPA is aware that it may be difficult to obtain design information for ponds
that were built over 30 years ago, however, respondents should use the best
available data to respond to the questions. Respondents should use the
comments page to explain any estimates or assumptions made for the
requested information.
p. EPA added a specific request for freeboard height and removed the request
from Part F of the questionnaire. EPA also provided a generic
pond/impoundment diagram to show the depth and other dimensions of
pond/impoundments.
q. EPA clarified in Q. D3-3 that plants are not required to take new

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Comment
r. The information requested in Q. D3-6 should be limited to the last three years.
Requiring information beyond the last three years is overly burdensome, will
needlessly increase the time necessary to respond to this question, and is unlikely
to provide information that is more representative than information for the last
three years.
s. Q. D3-9, Q. D3-19, and Q. D3-21 are very open-ended questions that will
produce inconsistent answers.
t. Clarify what should be included and excluded when calculating costs in Q. D39. For example, should labor costs be included?
u. Commenters suggests that the check boxes should include a “none or N/A”
choice for Q. D3-10. In addition, commenters suggest rewording the question to
state "using techniques other than solely settling" for clarification.
v. In Q. D3-12 and Q. D4-10, it may be necessary to provide chemical dosages as
yearly estimates. In addition, the questions request concentration of treatment
chemicals in the treatment unit in g/L, as well as the addition rate in gpm. For a
lot of chemicals, such as liquid polymer or ferric chloride, the plant will know
gpd fed and ppm by volume. g/L may apply to a dry feed system such as lime.
Clarify to give the option for solid chemicals to use g/L, or for liquid reagents to
report in gph.
w. Commenters expressed concern with Q. D3-13 through Q. D3-15 stating that
the request for all closed units is extremely broad. Information for closed units
may not be readily available. The request should be limited to units closed within
the last 3 years. The request should also exclude units for which the solids where
removed (e.g., “clean” closed) prior to closure and for units that were replaced
in-kind. Commenters also feel that EPA does need the original dimensions of a
closed pond. It was also stated that Q. D3-15 should be revised to require the
maximum depth based on the final elevation of the waste within the pond or
impoundment, not the height of the berm because the final elevation constitutes
the final maximum depth. EPA should also request the quantity of solids that
went into the pond over the life of the pond/impoundment.
x. In Q. D3-20, why does EPA need the closure plan, if any, for a closed pond?
This is excessive, especially since EPA asks in the next question for a summary
of the steps of closure and closure costs.

Response
measurements to provide this data; however, best available information should
be used to answer this question.
r. EPA already had limited the bulk of this question (frequency, duration, and
volume dredged) to the last five years. EPA does not believe it is necessary to
limit the request for the year of last dredging, frequency of dredging that year,
and amount of material removed that year to the last three years since some
ponds/impoundments (perhaps many or even most ponds/impoundments) have
not been dredged within the last three years.
s. EPA phrased these questions in this manner to provide plants the flexibility
needed to provide the information requested.
t. EPA revised Q. D3-9 instructions to clarify the cost request..
u. EPA added a "NA" response option to accommodate any ponds that don't
have "techniques other than settling." EPA also revised the question by adding
“solely settling (e.g., adding chemicals to remove certain metals)”.
v. EPA clarified in Q. D3-12 and Q. D4-10 that plants should provide the
chemical dosage response in gpd and, if necessary, the plants can divide the
total yearly chemical dosage by the number of days added throughout the year.
EPA also revised the "Average Addition Rate" column to allow for both gpd
and pounds per day options.
w. EPA revised Q. D3-13 through D3-15 to limit the number of years for
information regarding closed pond/impoundment units to the last 10 years to
lessen the burden on the industry and still receive the information necessary
for the rulemaking. EPA revised Q. D3-15 to request the pond/impoundment
unit's volume, surface area, bottom and top elevation, freeboard height,
maximum height of berms and dams above the surrounding grade, and the
total quantity of solids placed in the pond/impoundment when it was originally
built and at its end of life. EPA also added the request for the quantity of solids
that went to the pond over the life of the pond.
x. EPA requests the closing plan and associated cost information to evaluate
the option of converting wet ash handling systems to dry. EPA rephrased Q.
D3-21 to explain that if the plants have provided a closure plan that describes
the closure process, the required steps, and the total capital and O&M costs
associated with the closure, that they do not need to respond to D3-21.

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Comment
y. Q. D3-21 as currently worded is very broad and likely will result in the
gathering and provision of information that does not aid in the potential
rulemaking process.

Response
y. EPA phrased these questions in this manner to provide plants the flexibility
needed to provide the information requested.

z. Are UICs considered wastewater treatment systems for purposes of Section 4?
aa. Design, average 2009, and maximum 2009 flow rates are requested.
Recommend adding average and maximum period for consistent responses (i.e.,
annual average, maximum daily flow).
bb. Q. D4-3 should be deleted from the Questionnaire. Respondents should not
be required to provide bid proposals for wastewater treatment systems. Bid
proposals are not reliable information, as they are merely estimates of anticipated
costs. Also, bid proposals may be influenced by the working relationships
between the parties. Bid proposals also do not normally include the balance of
ancillary equipment or installations, such as interconnecting pipes and controls.
EPA should focus instead on actual installed systems. Best estimates for total
capital and O&M costs would be more appropriate requests, yield better quality
information, and less burdensome.
cc. Commenters stated that since EPA requires submittal of the current NPDES
permit and several system diagrams, EPA should refer to the permit and the
diagrams for the effluent limitations applicable to the wastewater treatment unit
and its discharge, instead of asking Q. D4-7.
dd. Replace column heading “2006 Annual Cost” with “2009 Annual Cost” in
Table D-10.
ee. In Q. D5-1/Table D-10, EPA does not provide instructions for determining
what rate per kilowatt hour to use for power for pumping and power for
operations other than pumping. Also, the individual O&M categories identified
in Table D-10 are too specific. EPA should generalize these costs and allow
respondents to provide the total O&M costs for the questionnaire.
ff. Q. D5-2 requests capital costs for wastewater treatment systems. In many
cases these systems may have been installed 25 to 50 years ago. Collecting
records of capital costs from that long ago could be extremely burdensome. Also,
The individual capital costs identified in Table D-11 are too specific. We
recommend specifying the types of direct and indirect capital costs to be
considered in the description for clarification and requesting only the total capital

z. For the purpose of the questionnaire, UICs are NOT considered treatment,
they are considered disposal.
aa. EPA revised this question to request maximum design flow rate and
maximum daily flow (in gpd).
bb. EPA recognizes the limitations of system/cost information in bid
proposals/engineering reports; however EPA did not remove Q. D4-3, because
the bid proposals/engineering reports provide useful information to fill data
gaps, particularly for planned wastewater treatment systems.
cc. EPA is aware that certain wastewater treatment systems may achieve
specified effluent limits for different pollutants; however, this information is
being requested to determine if there are certain pollutant(s) that drive the
overall treatment system operation. This may not always correspond to the
permitted limitations.
dd. EPA incorporated these changes.
ee. EPA added an explanation to Table D-10 to clarify that plants may use the
total kWh used for pumping (for the treatment system) in 2009 to estimate
$/kWh for pumping costs. Similarly, for $/pound steam costs, plants may use
the total pounds of steam used (for the treatment system) in 2009. The O&M
cost breakouts will allow EPA to most accurately compare costs for treatment
systems in the industry. EPA expects plants to provide information to the best
of their ability, providing estimates if necessary. Estimated responses should
be noted in the Comments page.
ff. EPA revised Q. D5-1 and Q. D5-2, only request information for systems
installed in the past 25 years. The capital cost breakouts will allow EPA to
most accurately compare costs for treatment systems in the industry. EPA
expects plants to provide information to the best of their ability, providing
estimates if necessary. Estimated responses should be noted in the Comments
page.

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Comment
cost and year on which the cost is based. Simplifying the request will minimize
the time necessary to gather more specific information.

Response

Part E/Wastes from Cleaning Metal Processing Equipment
a. Revise Q. E1-1 and E1-2 to request information on generation of wastes since
2007 instead of 2000.
b. Facilities that ship all metal cleaning wastes to off site treatment or disposal
should be exempt from answering Part E.
c. Clarify definitions of the terms “episode” and “residues.”
d. Revise Q. E1-2 instructions: “an” should be “on.”
e. One commenter suggested that Table E-1 should be split into two separate
tables, one for cleanings using chemicals and one for cleanings without
chemicals. Many commenters also requested that the seventh column in Table E1 be modified to allow reporting of volume by cleaning event instead of annually
and the eighth column be revised to request the frequency of cleaning events.
f. Q. E1-3 is a very open-ended question and it will result in inconsistent
answers.

a. EPA has revised this question to request information about the most recent
cleaning event for each cleaning operation with chemical addition and without
chemical addition on metal process equipment that has occurred since January
1, 2000. EPA is aware that some cleaning operations may occur years apart
and does not want to risk mischaracterizing the industries wastewater
generation by limiting the duration of the question.
b. EPA does not agree to exempt facilities that ship these wastes off site from
answering the questionnaire. EPA has already limited this part of the
questionnaire to a statistical subset and therefore requires complete answers
from all respondents in order to characterize national practices.
c. EPA replaced the term “episode” with “cleaning event” and defined the term
in the instructions of Q. E1-2. EPA also defined the term “residue” in the
questionnaire glossary.
d. EPA incorporated these changes.

g. Q. E1-4 should include evaporation as a response option.

e. EPA incorporated these changes.

h. Q. E1-8 asks for a waste determination status that may not be known until the
wastes are generated and sampled. The results of the testing may determine
whether the wastes are hazardous or non-hazardous.

f. EPA recognizes that close-ended questions are preferable. However, in
order to provide plants the flexibility necessary to provide the information
requested, EPA has retained the format for this question.
g. EPA incorporated these changes.
h. EPA has revised this question to provide a more typical answer that does not
require sampling data.

Part F/Management Practices for Ponds/Impoundments and Landfills
a. Revise Section 1 to also apply to oil.
b. Are ponds/impoundments that perform treatment included in Section 1 and 3?
c. In Q. F1-5, “storms in close succession” should be defined. The Agency could
get many varied responses unless some definition of size, frequency, and/or
duration is not requested. Also, EPA should define what it means by a “design

a. EPA did not revise Section 1 to also apply to oil in order to minimize burden
and because the combustion of oil is not the focus of this part.
b. EPA reworded the instructions of Section 1 and 3 to include
“pond/impoundment units or landfills used for the storage, treatment, and/or
disposal of residuals or by-products…."

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Comment
storm.”

Response
c. EPA revised Q. F1-5 to ask if the pond/impoundment unit has ever
experienced an overflow, excluding routine permitted discharges and added a
new question to ask if such overflow was discharged to a receiving water

d. Commenters stated that ponds and impoundments typically do not have
leachate collection systems. However, units with single and double liners may
have a leak detection system from which water can be removed and treated.
Commenters also requested that EPA define the terms “leak detection system”
and “leachate collection system” in order for respondents to give an accurate
reply.

d. EPA revised the definition of the term “leachate” to include leakage, leak,
seepage, leachate collection, and leak detection sources. EPA also defined the
terms "leak detection system" and "leachate collection system" in the glossary
of the questionnaire.

e. Q. F1-8 and Q. F2-9 assumes plants have monitoring controls to determine the
number of days leachate is collected, however all plants may not have monitoring
controls. Add a sub-question regarding estimate method (e.g., pumping logs,
flow meters, and engineering judgment).
f. Q. F1-12 through Q. F1-15 are redundant with the USEPA Ash Management
Unit Survey questions and Q. F3-3 is redundant with the April 2009 question
from the House Committee on Transportation and Infrastructure's Subcommittee
on Water Resources and Environment.
g. The fourth question in Q. F1-9, Q. F2-10, and Q. F2-15 requests the treatment
system ID from Table A-4, but Table A-4 is intended to list pond/impoundment
areas, not treatment systems. Correct the table reference.
h. Q. F1-10, Q. F2-12, and Q. F2-16 do not specify how much leachate is
recycled back in the plant. For leachate recycled back into the plant, request an
estimate of the amount reused (as a percent of total).
i. Many commenters expressed concern about the request for the cost of
corrective actions, cost of inspection, and qualifications of the inspector in Table
F-1. Commenters stated that the cost of corrective actions will already be
included in the total O&M costs for each unit, that it will be difficult to estimate
the cost without conducting engineering studies, and that the table requires
further clarification of what should be included and excluded when calculating
the cost. Commenters also stated that the request for the qualifications of the
inspector goes beyond the scope of the questionnaire and that most inspectors do
not have construction experience. Additionally, it was requested that a footnote
be added to the “cost of inspection” column to require the respondent to indicate
if the inspection was self-performed.
j. Q. F2-1 should be rephrased. Not all landfills are “licensed,” in the sense that

e. EPA clarified that the plants should provide a description of the estimation
method in the “Part F Comments” tab at the end of Part F.
f. EPA has generally retained Q. F1-12, Q. F1-13, and Q. F1-15/Table F-1.
However, EPA deleted Q. F1-14 and removed the "Qualifications of the
Inspector" and “Findings of Inspection” columns in Table F-1. Additionally,
EPA did not remove Q. F3-3 because it does not request groundwater
monitoring data; therefore, the question does not contribute significantly to the
burden.
g. EPA revised the question to refer to Table D-2 instead of Table A-4.
h. EPA did not incorporate these changes because the percent recycled is not
absolutely necessary to evaluate option for the ELG revisions and EPA felt this
may be overly burdensome.
i. In Table F-1, EPA did not remove the “cost of corrective actions” column
because the questionnaire only requests the total O&M costs for 2009.
However, EPA provided additional clarification of what should be included in
the cost of corrective actions (e.g., labor costs)., EPA also recognizes that
providing this information may be more difficult without conducting
engineering studies for those corrective actions that have not yet been taken,
and in these instances plants should provide their best estimates and any
necessary comments in the Comments tab. Engineering studies would not be
necessary for those corrective actions which have already been implemented.
In addition, EPA removed the “qualifications of inspector” column from the
table, as noted above. However, EPA did not add a footnote, but renamed the
“Company/Consultant Name” column to “Affiliation of Inspector,” which has
the respondent specify if the inspector was a plant/company employee or a
consultant. Additionally, EPA revised the instructions to clarify that
estimating the cost for on site or company personnel to conduct inspections is

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Comment
the state provides an official license. In some states, while the state reviews and
approves design plans, it does not issue a license.
k. In Q. F2-5 clarify what should be included and excluded when calculating
costs.

Response
based on their labor costs and time involved.
j. EPA replaced the term “licensed volume” with “approved/licensed volume”
in Q. F2-1.
k. EPA clarified that the costs requested in Q. F2-5 should include any labor,
materials, and energy costs. In addition, EPA also stated that any unique
capital costs should be listed separately from the general costs associated with
expansion.

l. In Q. F2-5, include the date of the expansion, specify what dimensions are
required, and request information on future plans to expand.
m. In Q. F2-12 further define the term “discharged” to clarify if this is means
through a NPDES permitted outfall.

l. EPA clarified that the dimensions refer to surface area, volume of stored
materials, and height and added a request to provide the date(s) of expansion.
However, EPA did not find it necessary to include a request about future
expansions.

n. In Q. F2-14 “Conveyance for stormwater run-off from the landfill” suggests
all stormwater has contacted active surfaces of the landfill and does not
distinguish between stormwater from capped areas of the landfill versus runoff
from non-capped areas. Clarify that this is water that does not contact solids
(assumes any water contacting an uncovered, working face would become
leachate).

m. EPA reworded the response options throughout this part to specify the type
of discharge, either to a POTW or discharged directly (and to specify the
outfall number).

o. EPA’s instructions for Section 2refer to on site landfills previously defined in
Table A-6. Table A-6 includes operating/active, retired/closed, and planned
landfills. Section 2 questions seem to be directed toward operating/active
landfills. Landfill characteristics/design for planned landfills may not be
available or may change prior to construction.
p. The checkbox for “No” in Q. F3-1 needs a (Skip to End of Section F)
instruction.

n. In revising the questionnaire, EPA has differentiated between capped and
uncapped portions of the landfill.
o. EPA revised the instructions throughout Part F to require the respondent to
complete this part for all active/inactive/open and retired/closed
pond/impoundment units and landfills.
p. EPA added “Continue to Question F3-2” next to the “yes” response option
and added “Skip to next Questionnaire Part” next to the “no” response option.

q. Q. F3-3 could be interpreted differently depending on the definition of
pollutant (e.g., is calcium a pollutant), and background (e.g. a well upgradient of
the landfill / pond or a regional background computed as in a RCRA study).
Clarify the terms "pollutants" and "background".

q. In Q. F3-3 EPA clarified the term “pollutant” for the purpose of the question
by referring to a list of analytes in Part G. EPA defined the term “background
concentration” for the purpose of the ICR in the glossary.

r. Commenters expressed concern about the relevancy of section 3 and requested
the removal of these questions. Commenters also requested that the section be
applicable to pond/impoundment systems, wastewater treatment systems, and
landfills rather than specific pond/impoundment units and that EPA should
specify if Q. F3-3 is focused on ash related constituents and/or on agricultural
related compounds.

r. EPA did not remove Section 3, because the groundwater monitoring
information is requested to evaluate the industry-wide prevalence of
groundwater monitoring practices and to help evaluate the potential of leachate
contaminating surface waters. However, EPA clarified that Q. F3-3 is limited
to pollutant concentrations from ash and FGD related constituents and revised
Section 3 to request the information on a pond system level (referring to Table
D-1, D-2, or A-6).

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Comment
Part G/Leachate Sampling Data for Ponds/Impoundments and Landfills

Response

a. Include analyses of TSS, sulfates, dissolved metals, and dissolved mercury.

a. EPA added analyses of TSS and sulfates; however, EPA did not add
dissolved metals and dissolved mercury, because of the additional burden
(including cost) associated with the sample collection and analysis.

b. Leachate streams from landfills are already regulated through state solid waste
laws in most jurisdictions. Therefore, further regulation of leachate from coal
combustion landfills may not be necessary, and EPA shouldn’t prejudge the
issue.
c. Many commenters stated that it does not make sense to ask for leachate data
from a pond or impoundment, because ponds/impoundments typically do not
have leachate collection systems. However, units with single and double liners
may have leak detection systems from which water can be removed and treated
and therefore, it is unclear if the intent of this request includes water collected
from leak detection systems. Additionally, commenters requested definitions for
the terms “leachate,” “runoff,” “untreated,” “treated,” and “detection limit.”
d. If the respondent answers “no” to Q. G1-2, there should be an instruction to
skip to Q. G1-5.
e. Multiple commenters stated that many of the facilities will not be able to
accomplish the leachate sample collection in the required amount of time,
because some facilities do not regularly generate leachate weekly and there are a
limited number of labs that are certified to collect and analyze the samples by
low-level methods (e.g., Method 1631E). Therefore, every facility chosen for the
sample collection will need to have their collection and analysis completed at the
same time, which could prove to be impossible during a short window of time.
f. Facilities that collect and dispose of leachate off site (i.e., not discharged)
should be exempt from the sampling requirement, as the information collected
likely would not be representative of typical leachate discharges.
g. Clarify if pond/impoundments that perform treatment are included in this part.
h. The costs for collecting and analyzing eight samples of leachate (treated and
untreated) per treatment unit will be significant. One commenter estimated that
the costs for collection and laboratory analysis per sample are in the range of
$1,000 to $1,500. Therefore, the costs will be especially high for facilities that
will be required to collect both untreated and treated samples. In addition, the
burden will be very large for small facilities that are frequently on very tight
budgets.

b. EPA has not prejudged this issue, but requires additional data to determine
if revisions to the ELGs are necessary for leachate discharges.
c. EPA defined the term “leachate” in the questionnaire glossary to include
leakage, leak, seepage, leachate collection, and leak detection sources. EPA
also defined the terms “treated” and “detection limit” in the questionnaire
glossary and clarified the difference between untreated and treated leachate in
the leachate sample collection instructions.
d. EPA has now included skip instructions for this question.
e. EPA revised the instructions of the leachate sample collection to collect
leachate samples every week for four weeks or as soon thereafter as sufficient
leachate is available for collection, therefore collection during consecutive
weeks may not happen in all cases. Laboratory availability is not expected to
be a problem because of the small number of samples that will be collected
and analyzed, relative to the number of samples laboratories routinely analyze
nationwide from a variety of facilities, even when considering the specific
analytical methods required by the ICR. The holding time for EPA Method
1631E is 90 days; therefore, samples will not need to be analyzed immediately
upon collection. This will allow labs ample time to receive and preserve
samples in order to handle the required analyses within the timeframe
provided.
f. Even those plants that send leachate off-site are required to provide sampling
data for untreated leachate because the data will be used to characterize the
raw wastewater and evaluate treatment technology for revised ELGs.
However, EPA has revised the instructions to clarify that facilities that collect
and dispose of leachate off site are not required to provide sampling data for
treated leachate; only facilities that treat leachate on site are required to
provide treated data.
g. EPA clarified in the instructions that pond/impoundments that perform
treatment are included in this part.

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Comment
i. EPA should develop a screener questionnaire that would allow EPA to
investigate all potential analytical issues with the leachate matrices and
determine whether any further existing data or sampling would be beneficial for
characterizing leachate discharges.
j. EPA should consider allowing the submittal of historic leachate data, if
available, instead of requiring four new and additional weekly leachate sample
results.
k. Many commenters expressed concern that EPA’s instructions for sampling are
not clear. EPA does not specify where to sample for untreated or treated
leachate, and therefore the resulting data will be inconsistent.
l. Depending on the characteristics of the leachate samples, Method 200.8 may be
an inappropriate choice for some metals. It has been demonstrated that Method
200.8 can produce erroneous results for some metals in certain matrices due to
polyatomic interferences. These interferences can result in erroneous analytical
results.
m. EPA should require rainfall information (in inches per day) for 30 days prior
to the first leachate sampling, and also during the entire sampling period.
n. Depending on the configuration of the leachate collection system, sampling
may be difficult due to confined space entry issues (i.e., in manholes). There
may be significant safety concerns at some facilities due to this sampling
requirement.
o. Q. G1-6 is duplicative of Tables A-5 and A-7. The respondent already
identifies types of wastes in each management unit on those tables. EPA should
refer to those answers and not ask for the same information twice. In addition,
EPA should clarify that the amount of waste requested in Q. G1-6 applies to the
uncapped portion of landfill that contributes to leachate.

Response
h.. EPA estimated in the supporting statement that the cost to analyze one
leachate sample at one sample location (taking into account analytical testing,
supply costs, and sample collection labor) would cost $2,212.55, which is
significantly higher than each of the commenters’ estimates. Depending on
whether a plant has a pond, a landfill, or both, EPA has estimated anywhere
from 4 to 16 sample points at a plant. Therefore, EPA has accounted for the
burden associated with this sampling effort. However, to reduce burden on
small entities, EPA has excluded them from the subset of coal-fired plants
selected to respond to Parts E, F, and G (and thus is excluding them from
sampling).
i. EPA does not agree that a screener questionnaire is necessary for the purpose
of investigating analytical issues for leachate.
j. EPA revised the leachate sample collection instructions to allow a plant to
provide existing data in lieu of collecting new data if the historic data fulfills
the specific requirements articulated in Part G.
k. EPA revised the leachate sample collection instructions to clarify that the
plant should collect samples from each leachate collection point for each
pond/impoundment and landfill. If the plant determines that a sample from one
or more collection points are representative of an individual
pond/impoundment or landfill, then the plant may simply collect the
representative sample(s) instead of sampling each collection point.
l. Method 200.8 is an EPA-approved method and therefore is valid for setting
effluent limitations. It remains the required analytical method for selected
analytes; however, EPA has added flexibility for alternative methods for
certain parameters.
m. EPA added a question requiring rainfall information for two weeks prior to
and throughout the sampling period, because the amount of rainfall can impact
characterization and the amount of leachate generated.
n. EPA recognizes there could be safety issues associated with leachate
sampling; therefore, EPA revised the instructions of the leachate sample
collection to allow the plant to request exemption from the data collection
through the submittal of a written request within two weeks after receiving the
questionnaire. The submittal must explain why the plant is unable to collect

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Response
the samples safely.
o. EPA has revised the request, but still retains the request for types of wastes
in each management unit because Part G requests the amounts of each type of
waste, whereas Part A simply asks what type of wastes are managed. In
addition, EPA revised Q. G1-6 to request the plant to complete two rows in
Table G-3 if the landfill is partially capped, one for the amount of waste under
the capped portion of the landfill and one for the amount of waste under the
uncapped portion of the landfill.

Part H/Nuclear Power Generation
a. Several of the questions within Part H refer to “water streams,” while others
refer to “wastewater streams.” Commenters believe these terms should be
defined.

a. EPA replaced the term “wastewater streams” and “water streams” with
“process wastewater.” EPA added and defined the term “process wastewater”
in the glossary of the questionnaire.

b. Commenters believe Q. H1-2 is not necessary. The type of nuclear unit is not
later correlated to specific waste streams.

b. EPA deleted Q. H1-2 from the questionnaire since this information can be
received from NRC. However, EPA does request the type of nuclear unit in
the “Type of Boiler or Reactor” column in Table A-10 (planned systems).

c. Commenters believe that the term “associated with the nuclear generating
units” should be defined. They question whether this only includes streams
directly associated with the nuclear reactor, or if it includes all streams associated
with the generation of electricity. Additionally, they ask whether streams not
associated with electricity generation should be included (potable water, sewage,
fire protection, car washes, etc.)?
d. Commenters believe the electronic version of the Questionnaire needs to allow
for more than four entries on Table H-1 Also guidance should be provided for
describing the “type of water stream.” Commenters are not certain whether this is
meant to be a simple description using existing Effluent Guideline descriptions
(low volume wastes, chemical cleaning wastes, etc.) or if each facility should
develop unique descriptors.
e. Commenters believe it would be problematic to answer Q. H2-1 for nonroutine, intermittent streams. Some of these waste streams may go years between
discharge events.
f. Commenters believe Q. H2-2 should include a response box for “discharged
with treatment” and replace “All leachate discharged” to “All treated water
discharged.” Additionally, the choices for destinations of treated water in Q. H23 include leachate and sluice water, both of which do not exist at nuclear

c. EPA has revised the wording to say “associated with the production of
electricity from nuclear generating units” and expects respondents to report all
process wastewater associated with running the nuclear plant. EPA also
updated the definition of “process wastewater” to ensure that plants are not
including non-contact cooling water, sanitary water, uncontaminated storm
water, portable water, sewage, fire protection, or car washes.
d. The electronic version of the questionnaire allows for 36 entries. EPA
revised the table by including a drop down box with specific process
wastewater streams identified, including an "other" category where the plant
can define any additional streams not already identified.
e. EPA revised Q. H2-1 to allow plants to provide data on both continuous and
intermittent streams.
f. EPA combined Q. H2-2 and H2-3 and revised the response options for the
question so that they were applicable to nuclear plants. This included removing
the use of the term “leachate.”

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Comment
facilities. EPA should modify this question to remove these response boxes.

Response

Part I/Economic and Financial Data
a. Several commenters noted the challenge of coordinating responses from
plant’s having multiple owners, expressing concerns with both the limited time
provided to complete the questionnaire and the utility of collecting detailed
information from each owner.

a. In response to the comments, EPA has clarified the instructions to clarify
that it seeks detailed information (balance sheet, income statement, etc.) only
from the owner that has the largest ownership share or financial interest in the
steam electric capacity at the plant. Only summary information (revenue,
number of employees and identity of the ultimate parent) is requested for other
owners. This summary information is expected to be easier to gather and will
be used to assess the potential for substantial economic impacts on entities that
own or have another form of financial interest in steam electric plants,
including in identifying entities that meet the definition of a “small business.”

b. Commenters noted that certain terms used in the questionnaire refer to
concepts that are not accurate legal descriptions of the plants’ ownership
structures
c. One commenter questioned the utility of asking for total revenue and total
employment rather than focusing strictly on revenue or employment associated
directly with electricity generation.

Regarding the logistics of coordinating responses among multiple owners,
EPA has designed the questionnaire to be modular and to allow each section to
be completed by different individuals, as needed, prior to being returned to
EPA.

d. Several commenters questioned the utility of asking for data on activities not
directly related to electricity generation.
e. Commenters noted that this information is not currently compiled under
customary business practice and completing the questionnaire would therefore
impose a significant burden on respondents.
f. Commenters questioned the utility of asking for information about the overall
operations of the ultimate parent rather than focusing only on electricity
generation.
g. Commenters asked for clarification of the activities included in “revenue
generating activities other than generation of electricity.”
h. Commenters also questioned the purpose of asking for other revenue in
Question I1-30 and suggested deleting this row from the table.
i. One commenter asked for clarifications on how variable O&M costs should be
determined for the purpose of this questionnaire

b. EPA recognizes that plants can have types of ownership structures that
differ from a partnership or joint venture. In response to the comment, EPA
has revised the instructions and the definitions provided in the glossary to
broaden the concept of ownership to also include other forms of “financial
participation or interest”. The simple term “plant owner” suggested in one
comment is general and is captured by the concept of immediate parent
described in the revised questionnaire and glossary.
c. The intent of this question is to help determine entity size according to the
Small Business Administration (SBA) standards for the analyses required by
the Regulatory Flexibility Act (RFA) and the Unfunded Mandates Reform Act
(UMRA) if the immediate parent is also the ultimate parent. This question was
asked at the immediate parent- as well as the ultimate parent-level to simplify
the skip pattern for questions. For the purpose of size determination, EPA
needs total revenue, employment, and electricity sales, as opposed to only
those related to steam electric operations. EPA is asking for revenue and
employment associated with electricity generation for every immediate parent
to allow the eventual assessment of the uncertainty associated with attributing
compliance costs and other impacts only to immediate parent owner (largest
equity share) and to support a cost-to-revenue analysis of impacts to all

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Response
affected entities.
d. The intent of this question is to determine the scope of business activities of
the immediate parent including those activities aside from electricity
generation as well as the relative importance of these other business activities
with respect to profitability of the firm. EPA will use the information to
support the regulatory cost impact.
Based on the comments, EPA has revised the question to distinguish between
(1) production activities that are electricity generation-dependent, such as sale
of steam or ash, waste combustion (which depend directly upon the generation
of electricity) and (2) production activities that are not electricity generationdependent, such as leasing of land. EPA has also revised the instructions to
specify that, in this section, it is asking for information regarding all operations
of the immediate parent and not just those of the plant, as these are covered in
separate questions.
e. In response to these comments, EPA has modified the two questions to
reduce respondent burden to the extent possible while getting the data needed
to conduct analyses. The questions have been revised to clarify the information
requested, to specify that approximate shares are sufficient for the purpose of
this data collection, and to explain that respondents need not review individual
contracts to determine the exact fraction of sales subject to different pricing
conditions. EPA expects that respondents will already have a sense of the
approximate share of electricity sold under different terms, even if they do not
have the exact statistics for each year. Additionally, the Agency has reduced
the number of data items it is requesting by asking for information regarding
contract duration and terms for only the most recent year of data (2009).
While EPA does not expect that respondents will have to conduct an historical
review of all contracts and their terms, the Agency has nonetheless revised its
burden estimate to account for the potentially greater level of effort involved in
answering this question.
EPA has also clarified the basis for the shares requested to specify that they be
based on physical quantities (MWh).
f. EPA retained this question but explained the purpose for requesting the
information in the instructions.

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Response
The intent of this question is to help determine entity size according to the
Small Business Administration (SBA) standards for the analyses required by
the Regulatory Flexibility ACT (RFA) and the Unfunded Mandates Reform
Act (UMRA). For the purpose of size determination EPA needs total revenue,
employment, and electricity sales, as opposed to only those related to steam
operations.
g. EPA has revised the question to specify that activities carried out by third
parties and for which the plant incurs no cost and receives no revenue should
not be included in the response.
h. Regarding draft Question I1-30, because information on other plant revenue
is already asked for, EPA deleted the row from this question.
i. EPA provided a description of variable O&M costs in the glossary.

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