Surviving the New Steam Generating Effluent Guidelines

Surviving the New Steam Generating EffluentGuidelines

Ivan A. Cooper, P.E., BCEE1*

1Civil & Environmental Consultants, Inc. (CEC), Charlotte, NC.* Email: [email protected].

Session I7EUEC Conference 2014Phoenix, AZ

ABSTRACT

The US EPA’s draft update regulations for Steam Electric PowerGenerating Effluent Limitation Guidelines (ELGs) were released onApril 19, 2013. The proposed rule was published on June 7, 2013.The ELGs are nationally applicable, technology-based dischargerequirements. Additionally, each state may regulate effluentsfrom electric utilities more stringently than on the federallevel. These ELGs are incorporated into NPDES discharge permits.The EPA first issued effluent guidelines for the Steam ElectricPower Generating Point Source Category (i.e., the Steam ElectricEffluent Guidelines) in 1974. There were revisions in 1977 and1982. The ELGs are codified in 40 CFR Part 423 and address thefollowing waste streams:

Once-through cooling water; Cooling tower blowdown; Fly ash transport water; Bottom ash transport water; Metal cleaning wastes; Coal pile runoff; and Low-volume wastes sources.

The Low-Volume category includes wastewaters from units such aswet scrubber air pollution control systems, ion exchange watertreatment systems, water treatment evaporator blowdown,

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laboratory and sampling streams, boiler blowdown, floor drains,cooling tower basin cleaning wastes, and recirculating houseservice water systems. Sanitary and air conditioning wastes arenot included [40 CFR 423.11(b)].

KEYWORDS: Effluent Guidelines, FGD, Blowdown, Ponds, Fly Ash,Gypsum Systems, Coal Pile Runoff.

BACKGROUND

The U.S. Environmental Protection Agency is in the process ofrevising the ELGs for the steam electric power generating pointsource category. Under a consent decree entered into in Defendersof Wildlife v. EPA, No. 10-cv-01915 (D.D.C.), and since revised,EPA agreed to sign a notice of proposed rulemaking by April 19,2013, and to sign a decision taking final action by May 22, 2014.The agency released their prepublication notice on April 19,2013. The rule was published June 7, 2013. Based on review ofpublished EPA documents, the focus of the rulemaking addressesthe following wastes:

Flue gas desulfurization (FGD) wastewater from SO2 airpollution controls;

Discharges of fly ash and bottom ash transport water; Leachate from ponds and landfills containing coal combustion

residues; Gasification wastewater from integrated gasification combined

cycle (IGCC) plants; Wastewater associated with flue gas mercury controls (e.g.,

wastewater resulting from transporting/handling solids fromactivated carbon injection);

Nonchemical metal cleaning wastes; and Gasification of fuels like coal and petroleum coke.

EPA is also proposing clarifications to the definition of “metalcleaning waste” and “chemical metal cleaning waste” to clarifythe existing definitions. Surviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

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EPA reported that steam electric power plants contribute overhalf of all toxic pollutants discharged to surface waters by allindustrial categories currently regulated in the United Statesunder the Clean Water Act. According to the EPA’s estimate ofannual water based discharges from steam electric plants,although contested by several industry groups, the annual loadingincludes:

64,400 lb. of lead; 30,000,000 lb. of nitrogen; 2,820 lb. of mercury; 682,000 lb. of phosphorus; 79,200 lb. of arsenic; 14,500,000 lb. of manganese; 225,000 lb. of selenium; 158,000 lb. of vanadium; 1,970,000 lb. of aluminum; 4,990,000 lb. of zinc; and 27 other pollutants.

Therefore, these proposed regulations will reduce discharges ofthese toxic pollutants which have been linked to cancer,neurological damage, and ecological damage. Further, EPA claimsthat these pollutant discharges contribute to:

Over 160 water bodies not meeting state quality standards; 185 waters for which there are fish consumption advisories;

and Degradation of 399 water bodies across the country that are

drinking water supplies.

Significant costs are anticipated to address the proposedcompliance requirements for coal-burning utilities to address FGDwastewater, fly and bottom ash wastewater, pond/landfillleachate, gasification wastewater, and wastewater from mercurycontrols or SCRs.

Surviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE3

The proposed regulations are related to several documents. Theseinclude an October 2009 study by EPA (“Steam Electric PowerGenerating Point Source Category: Final Detailed Study Report”,EPA 821-R-09-008) and subsequent EPA documents, including “SteamElectric Power Generating Effluent Guidelines RulemakingSupplemental Information Package #2 for Federalism and UnfundedMandates Reform Act (UMRA) Consultations”, October 2011. The EPAlargely focused on discharges associated with coal ash handlingoperations and wastewater from flue gas desulfurization (FGD) airpollution control systems because EPA believes that these sourcesare a major contributor of the pollutants discharged by steamelectric power plants. The prognostication of the possibleeffluent requirements may be drawn from the proposed drafteffluent discharge permit of the Merrimack Station of the PublicService of New Hampshire located in Bow, NH. (Technology-BasedEffluent Limits for the Flue Gas Desulfurization Wastewater atMerrimack Station in Bow, New Hampshire, EPA Region 1.9/23/2011). The Merrimack proposed effluent limitations for BestProfessional Judgment/Best Available Treatment (BPJ/BAT), and thepossible basis for the new ELGs, were developed for elevenpollutants: arsenic, cadmium, chromium, copper, lead, manganese,mercury, selenium, zinc, chlorides and TDS.

EPA did suggest preliminary compliance cost estimates forpollution controls as the technology basis for regulatoryoptions, but there has been much controversy and speculationabout the rule, impacts, and effluent standards to be proposed.EPA’s proposed options include exclusions for smaller generators(i.e., 50-megawatt and 400- megawatt).

EPA has proposed one option for new sources. For existingsources EPA developed four different regulatory options. The newrequirements for existing sources would apply for the permitcycle beginning “on a date determined by the permitting authoritythat is as soon as possible when the next permit is issuedbeginning July 1, 2017.” EPA proposes that the new limitationswill apply to all steam electric generating facilities no laterthan July 1, 2022, with extensions for voluntary Incentives if aSurviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

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facility agrees to dewater, close and cap CCR impoundments (Tier1 – 2 years extension) or eliminating all process wastewaterdischarges to surface water (Tier 2 – 5 years).

EPA intends to coordinate the proposed RCRA rule regulating CCRdisposal with the Steam Electric ELG and gave strong indicationsthat the CCR disposal regulations will be managed under RCRASubtitle D. EPA’s proposed Steam Electric ELG preamble statedthat there is “strong support for a conclusion that regulationof CCR disposal under RCRA Subtitle D would be adequate.”

EPA identified a number of candidate options to address theeffluent limitation guidelines, as presented below. There is anumber of preferred alternatives form the options listed. Thewastestreams and the associated options and technologies arepresented below, excerpted from the Federal Register publicationnotice of June 7, 2013, Table VIII-1 – Steam Electric MainRegulatory options:.


EPA has identified the following four Best Available Technology(BAT) alternatives as its preferred alternatives for existingsources (other than oil-fired units or smaller than 50 megawatts(MW)) with surface water discharges. Of the options listed above,EPA identified the following as “Preferred Alternatives.”

These alternatives comprise the four preferred BAT Alternativesfor Existing Sources. Alternative 1 (Option 3a in the Steam Electric ELG):

1. Fly ash transport water and wastewater from flue gas mercurycontrol system discharges - zero discharge effluent limit.

2. Gasification process discharges – numeric effluent limits formercury, arsenic, selenium, and total dissolved solids.

3. Nonchemical metal cleaning waste discharges – numeric effluentlimits for copper and iron.

4. Bottom ash transport water and CCR residual leachate fromlandfills/surface impoundments – numeric effluent limits fortotal suspended solids, oil and grease will mirror current BPTeffluent limits.

5. Flue gas desulfurization (FGD) wastewater –site specificeffluent limits.

Alternative 2 (Option 3b in the Steam Electric ELG): In additionto the non-FGD wastewater requirements for Alternative 1 above,Alternative 2 includes:

FGD wastewater for plants with a total wet scrubbed capacityof 2,000 MW or greater – numeric effluent limits for mercury,arsenic, selenium, and nitrate-nitrite.

Alternative 3 (Option 3 in the Steam Electric ELG): In additionto the non-FGD wastewater requirements for Alternative 1 above,Alternative 3 includes:


FGD wastewater (exception for units that are 50 MW or smalleror oil fired) – numeric effluent limits for mercury, arsenic,selenium, and nitrate-nitrite.

Alternative 4 (Option 4a in the Steam Electric ELG): In additionto the requirements stated in Alternative 3 above, Alternative 4also would include:

Bottom ash transport water from units greater than 400 MW –zero discharge (ZD).

The table below shows a side by side comparison of the effluentlimitations of the options proposed by EPA.


EPA has further listed effluent limitations for the major flowprocesses with the following numerical limits.

Process Asug/l

Hgng/l

Seug/l

Nitrate/Nitrite

TDSmg/l

FGD WW by ChemicalPrecipitation

8/6

242/119

FGD WW by ChemicalPrecipitation & BiologicalTreatment

8/6

242/119

16/10 0.17/0.13

FGD WW by ChemicalPrecipitation & VaporCompression Evaporation

4/-

39/24 5/- 50/24

Vapor Compression Evaporationfor Gasification Wastewater

4/-

1.76/1.29

453/227

38/22

Leachate by ChemicalPrecipitation

8/6

242/119

In addition to managing wastewater associated with FGD processes,the effluent limitation guidelines addresses discharges at steamelectric generating stations from other sources listed above.Therefore, a critical first step for utilities is understandingthe source and the volume, characteristics, and variability ofother flows at steam electric generating plants. The approach toa characterization and flow identification program is present andshould be implemented. Many utilities have not identified thisinformation, or may only have a rough estimate. Frequently, thisinformation is not well organized or easily attainable.

IMPACT OF REGULATIONS


The impact of the updated Effluent Limitation Guidelines will benumerous. In addition to more stringent effluent standards toexisting wastewater discharges, EPA may require segregation ofsome wastes, additional internal monitoring points (IMPs),additional analyses at lower detection levels, additionalreporting, and additional treatment of certain wastes. Some ofthese additional wastewater treatment requirements may includetreatment of internal flow streams, a step not requiredpreviously by regulations. EPA has identified the potential forcircumventing the effluent limitations by reusing flows from oneprocess in another process, and thereby reducing the effluentrequirements for a certain flow. In order to eliminate thisapproach, EPA is proposing an “Anti-Circumvention” regulationthat would require internally reused flows to be treated to thesame quality as they would be if they were discharged.

Annually, EPA projects different levels of costs and pollutantreductions for the entire fleet of affected utilities associatedwith these preferred options:

Compliance costs range from $185 million and $954 million Pollutant reductions range from 0.47 billion to 2.62 billion

pounds

Utilities should be prepared to do more monitoring, developcomprehensive water management plans, determine if decentralizedwater treatment units treating various flows separately makessense, identify upgrades to treatment early, and be prepared tospend a lot more time and money to comply with the upcomingregulations. Many utilities have not identified this information,or may only have a rough estimate. Frequently, this informationis not well organized or easily attainable.

SHORTCOMINGS OF THE PROPOSED REGULATIONS

Several areas in the proposed regulations were not addressed, andwere components of comments submitted to the Agency through theSurviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

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comment period ending September 20, 2013. These possibleshortcomings include:

EPA’s lack of input from mayors on electric and water utilitycosts;

Lack of consideration on feasibility; Accommodation for life expectancy of existing units; Physical space requirements for improvements to plants with

limited available area; Reasonable limits and deadlines as power plants transition to

new air standards; Consideration for multiple construction projects at power

plants as upgrades to comply with air requirements, CoalCombustion Residuals (CCR) requirements, and ELGs occur withinthe same time frames;

Combined effluent data over several decades misrepresentsimprovements that have occurred that lowered EPA’s effluentloadings;

Lack of consideration for pretreatment pass-through that uses1982 pretreatment efficiency. For example EPA considered a66% removal efficiency, while the Utility Water Action Group(UWAG) estimates the current activated sludge removalefficiency is 91%; and

Concern that EPA’s proposed compliance costs are significantlyunderrepresented.

Additional comments are anticipated and will be compiled andissued by EPA in subsequent Federal Register documents to befinalized by May 22, 2014.

WHAT SHOULD UTILITIES DO?

As a first step, utilities should develop strategies andimplementation techniques to plan their compliance with theanticipated requirements of the new ELGs. These plans shouldinclude a comprehensive water evaluation to identify (i) high-volume water uses, (ii) low-volume water uses, (iii)Surviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

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constituents, (iv) flow patterns, (v) existing treatment, and(vi) possible improvements. Utility staff or consultants canprovide plant level advice for identifying and addressing datagaps that may exist from the historical sampling and flowcharacterization that may exist. The goal of this effort is todevelop a reliable estimate of flow and characterization fromeach of the low-volume wastes sources to identify like-characteristic wastes, group similar wastes for recycle/reuse,zero liquid discharge, subsurface discharge, or end of pipetreatment to comply with anticipated regulatory changes.

Typical parameters to be determined should include:

Average and maximum flow rates (gallons per minute); Flow routes; Pollutant sources; Pollutant concentrations; Pollutant loadings; Frequency of discharges during normal operation; Expected changes in wastewater streams during start-up and

shutdown; and Existing treatment technologies and detailed descriptions and

effectiveness.

Some of the factors impacting the characterization for managementof wastewater at steam electric generating stations include anumber of factors:

Understanding the water flow balance to develop or confirmprocess flow schematics, including temporal variations inwater quantity and quality due to factors such as energyproduction rates, cleaning cycles, blowdown frequency, season,climate, and other factors;

Variations in water quantity and quality due to productionchanges, schedules and upsets;

Contribution to water quality due to background conditions;


Understanding of overall site water balance and the impacts ofbackground hydrological conditions on water quantity andquality;

Specific water quality protection requirements and dischargeoptions for the facility effluent; and

State of development of traditional and innovative watertreatment unit operations.

WATER MANAGEMENT PLANNING

Due to these and other various factors, development of watermanagement and treatment alternatives must proceed in a logicalstep-wise fashion. To complete the understanding of the overallwater quality and confirm an initial estimate of pollutantloadings from each source, a sampling program is often the bestapproach. One of the inherent challenges in completing thedevelopment of an estimate of water quality to be managed overtime is the tendency to rely on data that is a “snapshot” intime. Data gathered in the past or today may not accuratelyreflect reality (neither past nor present, nor provide reliablepredictions for the ten-year future) due to changes in afacility’s operations and characteristics over time. Thecombination of limited existing data and a single sampling eventwill likely not provide a full and accurate characterization ofsome wastewater sources. The approach to solve this challengelies in attempting to “bound” the likely conditions over time.This requires an understanding of the basic influences that willaffect the quality of the discharge. The overall result of theseanalyses may not be a rigorous determination of water quality.Rather, it may consist of a range of potential projectedcontaminant concentrations that must be considered in theevaluation of potential treatment processes.

Developing an understanding of the flows is also critical. Manyflow sources are not measured or even identified. An approach isto develop a plan and execute it for identifying and measuringthe identified low-volume wastes source flows with one of severalSurviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

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techniques. Since many sump pumps and other pumping units do nothave flow measurements, run time meters, totalizers, or outputfrom spare contacts for pump starts or run times, a flowmeasurement activity should be undertaken. The techniques mayinclude:

Clip-on or strap-on ultrasonic and Doppler flow meters andrecorders – caution: pipe integrity must be sound and have asmooth inside wall, pipe must run full;

Sump draw-down (if incoming source can be isolated) and countnumber of cycles per time period;

Runtime meter with pump curve or sump draw down (if incomingsource can be isolated);

Bucket test at discharge of pipe; For outfall pipes – record liquid depth measurements in a

discharge pipe and estimate flow rate from engineering curves;and/or

Collect stormwater data (this is an integral component of theflow study).

IDENTIFYING FLOW GROUPS

After this flow and quality data is collected and process flowdrawings are confirmed, the wastewater streams can be groupedinto several categories, such as:

Low-volume minor flows; High-volume, “lightly” contaminated flows; and High-volume “high strength” flows.

Each grouping can be evaluated with respect to reuse potentialusing some of the following factors including whichcharacteristics of that grouping are acceptable as a reuse sourceas compared to reuse acceptance criteria. The flow of eachgrouping can be compared to reuse volume requirements, and thepotential for cycle-up impacts should be considered – for exampleif cooling water makeup is a reuse option, then would the reuseSurviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

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of a given wastewater source result in the cycle-up of dissolvedspecies such as chlorides that could cause operational issues?

SEGREGATED TREATMENT?

An analysis of the location and characteristics of the sourceshould be performed to identify if the flow can be easilysegregated and cost effectively collected and conveyed to thepoint of reuse. At a reuse point of application issues such asrequired temperatures or pressures must be considered. Forexample if the point of application is at elevated pressures, theengineering challenge in completing the tie-in may be judged tonot be cost-effective.

Some of the reuse options may be viable with no or minimalpretreatment of a given wastewater source (i.e. pH adjustment,suspended solids removal) – this will also enter into a costeffectiveness evaluation.

A treatment option for low flow and higher strength flows such asFGD blowdown may include zero liquid discharge (ZLD). This optionwould produce a very high quality stream suitable for many reuseapplications. The reuse evaluation will consider the variousreuse options and develop an estimate of the maximum number oftechnically viable options and the total volume of reuse water toservice all of those options.

Compliance with discharge requirements of future NPDES permitsdemands consideration of the reuse potential above plustechnologies for meeting effluent characteristics in ELGs andsite specific permits. The first factor in the treatmentalternatives development will be the number/location of treatmentfacilities Comparing multiple treatment systems at a sitetreating individual flows with a single treatment facility at asite may have the advantage of reduced infrastructure (roads,utilities, etc.) compared to multiple treatment locations at asite. Operating staff would also be located in a single areaSurviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

14

with a possible reduction in labor cost. Alternatively, andsimilar to the reuse options, treatment alternatives will need toconsider conveyance issues. Further, utilities should consider amixing model that uses flow and water quality data to determinethe characteristics of different blends of wastewater sourcesbased on potential site locations for treatment facilities.

TREATMENT CONSIDERATIONS

The contaminants of concern can be broadly categorized intogeneral classifications, (i.e. dissolved metals, dissolvedsolids, organics, and other toxics). Unit operations withpotential applicability to each broad category can be identifiedbased primarily on proven usage in similar applications, althoughemerging and innovative technologies should also be considered.The unit operations should be qualitatively screened against eachother to determine actual applicability to each site.

The considerations and the general types of technologies that arelikely to be the evaluated and recommended treatment alternativesappropriate to meet the anticipated ELGs include severalconsiderations, including structural and non-structuralalternatives. The structural alternatives may includephysical/chemical and physical/chemical paired with anaerobicbiological processes, and zero liquid discharge (evaporationponds, mechanical evaporation/crystallization, and deep wellinjection) or novel systems. Non-structural may include internalrecycling and reuse or discharge to a POTW offsite.

Guidance that is being developed by the EPRI should be consideredfor low-volume wastes treatment, and includes thermal zero liquiddischarge (ZLD) approaches to evaporating and reusingwastewaters, as well as innovative approaches to the managementof solid residues (full ZLD) and brine concentrate (partial ZLD).A site evaluation should consider the overall water qualitymatrix in terms of potential for scaling and corrosion. Membrane


processes will also be considered to reduce the required size ifa thermal evaporation system is proposed to be evaluated.

Although conventional metals removal processes are well provenfor common constituents, power plant discharges may have tracemetals issues such as arsenic, selenium and mercury.A range of structural alternative technologies that may meet theanticipated ELGs include biological selenium treatment usingbiofilm reactors with post-treatment including membranefiltration and/or iron treatment; nanotechnology for seleniumand mercury treatment; innovative activated carbon approaches;use of specialty adsorbents targeted to specific metals; noveliron-based reagents; and microfiltration targeting submicronmercury particles.

In addition to unit operations for primary contaminant removal,potential unit operations for ancillary operations are alsoimportant. Examples include sludge dewatering and chemicalreceipt and storage. Other site-specific factors should beevaluated including the need for process water storage and reuse,utility requirements, waste storage and disposal options, andemergency and stand-by power requirements. These are importantfor reasonably complete cost estimates for alternatives to meetthe ELGs.

Identification and evaluation of unit operations for watertreatment alternatives should also include verification ofsuccessful commercial use on similar wastestreams.

COST CONSIDERATIONS

Cost evaluations for alternatives to meet the ELGs shouldconsider an overall project cost for items such as wastewaterconveyance to and from the treatment facility; equipment;treatment building(s); civil/site work; mechanical and electricalconstruction; design engineering and construction oversight; andlife cycle operation and maintenance costs for each alternative,Surviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

16

including power, chemicals, operator attention, replacements, andsimilar factors.

Cost opinions or estimates should be based on data from previousprojects, vendor budgetary estimates, and standard costestimating guides. The annual operations cost can becomesignificant, over an extended operational history, especially ifthere is a large cost element for secondary waste management.Elements of the operations cost include power, reagents andchemicals, labor, secondary waste management, and facilitymaintenance. Total life cycle cost can be expressed as a netpresent value using both escalation and discount factors.

STRUCTURED EVALUATION OF TREATMENT OPTIONS

In addition to a cost evaluation of treatment improvements, anumber of criteria should be considered in an alternative non-monetary evaluation. Evaluation using non-monetary evaluationcriteria is largely subjective, non-monetary criteria can beweighted, and a total non-monetary ranking can then beestablished for each alternative. The following presents a listof non-monetary evaluation criteria:

Operability - Ease of operation minimizes operatorattention/expertise required to ensure successful processperformance;

Ease of maintenance - Maintenance requirements are notexcessive and do not require special expertise; facilities andequipment readily accessible;

Operator familiarity - Staff familiarity and ability to usestaff experience from existing facilities;

Reliability - Demonstrated performance; provenprocess/technology to meet treatment criteria reliably;

Hydraulic sensitivity - Capability to handle variations inhydraulic loads with minimal process impacts;

Waste loading sensitivity - Capability to handle variations inwaste loads with minimal process impacts;


Process control stability - Not subject to upset frominadvertent operational changes, toxic sludges;

Flexibility - Capability for changes in process operations tohandle differing waste load conditions and to meet differingtreatment objectives for different effluent requirements;

Environmental effects - Minimizes potential for odors;sustainability;

Noise - Minimize potential for noise; Visual impacts - Minimizes negative visual impact of facility; Hydrological impact - Either relates to recirculation of

effluent/reject to the landfill or minimizes changes tofloodplain/runoff (if applicable);

Footprint - Minimizes footprint and disruption to site,including removal of trees;

Expandability - Footprint maximizes area available forexpansion;

Flexibility - Easily modified to meet differing future loads,effluent requirements, and/or treatment objectives; and

Implementability - Time to implement permit, design,construction, commissioning.

The following table presents an example of an evaluativeselection criterion for alternative technologies to meetanticipated effluent guidelines, but this type of approach mustbe created for each facility with site-specific evaluationcriteria.


Table 1. Fatal Flaw Analysis Table.

Effl

uent

Reli

abilit

yOper

abilit

yCons

tructi

o

O &

M Cost

Oper

ator

Hydr

aulic

Wast

e Lo

ad

Flex

ibilit

y

Odor

/Offs

ite

Nois

eVisu

al

Hydr

ologic

a

Foot

print

Expa

ndabil

i

Cons

tructi

on Ti

ming

No Action F L L L L L H L H L L L L L LDischargeto a POTW H L M L L M H L L L M M M H M

EvaporationPonds M M H H M M H L H M H M F H M

Flue GasInjection M M M L L L M H H L M H L M M

Fixation F H H M H M H M M M M M M H MDeep WellInjection F H M M M M H H M L M M M H M

FGD WWTSEffluentReuse/Recycle

H H M L M M H L M L H M M M M

SettlingPonds H H H H M F M L L M M F L H M

Treatmentby theexistingWWTS

M M F L H M H M H L M F H M M

Vapor-CompressionEvaporation

M M M L H L M H H L H H M L M

Physical/ChemicalTreatment

M M M L H L M H H L H H L L M

Physical/Chemicalwith AddedBiological

L H H H M H H L M M L M H H H


Effl

uent

Reli

abil

ity

Oper

abil

ity

Cons

truc

tio

O &

M Co

st

Oper

ator

Hydr

auli

c

Wast

e Load

Flex

ibil

ity

Odor

/Of

fsite

Nois

eVi

sual

Hydr

olog

ica

Foot

prin

t

Expa

ndab

ili

Cons

truc

tio

n Ti

ming

Treatment


Table 2. Multiplier Weightings for Ranking Evaluation.Heading Multiplier CommentCommercially Proven 10 Fundamental.Operability (easeof) 8

HydraulicVariability (abilityto manage)

5Feed tank shouldbuffer this.

Waste LoadingVariability (abilityto manage)

5Feed tank shouldbuffer this.

Chemical Storage &Delivery (extent,hazard, DGcompliancerequirements,complexity)

7

Impacts footprintand distances topremises boundaries;System security.

Secondary Waste

6

Was secondary wastecreated? If so,what is thedifficulty and costto manage?

Footprint (small) 10 Critical for thissite.

Power Requirement(low) 4 Small flows - all

relatively low.Capital Cost (low) 5O&M Cost (low)

7Can override capitalover a long periodof operation.

Start-up Period(low) 3

This is intended tobe "initialcommissioning".


Table 3. Summary of the Consideration Ranking Definitions andWeighting Used for Technology Review.Considerations

Rankings

Multiplier Definition

CommerciallyAvailable

5

10

Frequently Used3 Often, but not Frequently Used

1 Infrequent, but commerciallyavailable

Operability

5

8

Requires moderate operatorattention and expertise

3 Requires full operator attentionand expertise

1 Requires full operator attentionand expertise

HydraulicVariability

5

5

Capable of handling wide flowvariations

3 Moderate upset due to flowvariations

1 Process unable to perform withflow variation

WasteLoadingVariability

5

5

Capable of handling large waterquality variations

3 Moderate upset due to waterquality variations

1Process upset without largeequalization to address waterquality variation

ChemicalStorage &Delivery

5

7

Chemical storage and deliverynot required

3 Chemical storage and deliveryrequired

1 Hazardous chemical storage anddelivery required

SecondaryWaste 5 6 Produces no waste that needs

further treatment/disposal3 Produces waste that needs

disposalSurviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

22

1Produces waste that needsfurther treatment prior todisposal

Footprint5

10Requires small footprint

3 Require moderate footprint1 Require large footprint

PowerRequirement

54

Requires little energy3 Requires moderate energy1 Requires high energy

Capital Cost5

5Low capital cost

3 Moderate capital cost1 High capital cost

O&M Cost5

7Low O&M cost

3 Moderate O&M cost1 High O&M cost

Start-upPeriod

5

3

No start-up period required

3 Moderate start-up periodrequired

1 Long start-up period required

Alternatives for FGD wastewater, low-volume wastes, and othersources can be evaluated and potential options reduced to amanageable number. Then, to provide comparison of remainingtreatment options, the treatment options can be subjectivelycompared using a Pair-Wise Comparison. For the Pair-WiseComparison method, each candidate alternative is matched head-to-head with each other candidate alternative. Each alternative getsone point for a one-on-one win on the appropriate row and nopoints for a loss. Candidates with the most points arepreferable.

CONCLUSION

The US EPA’s regulations for Steam Electric Power GeneratingEffluent Limitation Guidelines will cause impacts to each of aSurviving the New Steam Generating Effluent Guidelines - Ivan A. Cooper, P.E., BCEE

23

utility’s facilities upon promulgation. Many utilities havealready begun an important step in the analysis of its wastewaterflows but most have not. For preparation of compliance, longerlead items of treatment improvements should consider additionalanalysis of its wastewater systems and determine the potentialimplications of a proposed rulemaking. In addition,consideration of a utility’s disposal facilities andleachate/contact water management and potential treatment basedon a proposed effluent rulemaking may be prudent.

In conclusion, the ELGs will constrain the options for steamelectric generating station to meet significantly more stringentstandards. A structured approach to evaluate the implications offlow, characteristics, and variability is presented above alongwith societal and economic evaluation criteria to allow theimpacted stakeholders to select and implement the mostappropriate alternatives for regulatory compliance.

Preparations for compliance with the speculative limits for thesoon-to-be-proposed Steam Generating Effluent Guidelines shouldinclude the following:

A detailed evaluation of the flow, characteristics, andvariability of each of the sources contributing to each of theoutfalls is a reasonable first step in preparation of theissuance of the draft regulations.

Considerations should be made for possible Ash Landfillleachate treatment, where present.

If additional air pollution controls are required, similar toFGD technologies, the discharge from air pollution controlblowdown should be considered.

If pond closure is performed, where ponds are present, and ashis handled in a dry ash handling system, then a reevaluationof any existing wastewater management systems would berequired.

Other low-volume wastes will be addressed in the draft ELGs,and additional treatment or management will have to beaddressed.


As a result of the implementation of these regulations,additional in-plant and effluent monitoring will be required.Other tasks include a structured comprehensive water managementplan for each facility to focus on water savings, reuse,decentralized water treatment for various flows compared to asingle water treatment plant, delineating an upgrade plan early,and spending more time and money for regulatory compliance.

REFERENCES

Chu, P. (2012). EPA's Effluent Guidelines: Potential Impact onCoal Plants and EPRI R&D. EUEC Conference. Phoenix, AZ.

Federal Register Notice, pre-publication (PDF) (491 pp, 1.2MB)April 19, 2013 Federal Register, Volume 78, Number 110 (Friday, June 7, 2013)Proposed Rules Pages 34431-34543.(http://water.epa.gov/scitech/wastetech/guide/steam-electric/upload/steam_prepub.pdfHoulihan, M., & Hayes, K. M. (2011). Practical Approaches to

Meeting the Pending Steam Electric Power Effluent Guidelinesfor CCB Landfill Leachate. 2011 World of Coal Ash (COA) Conference.Denver, CO.

Merrimack Station Draft NPDES Permit. (n.d.). Retrieved from USEnvironmental Protection Agency:http://www.epa.gov/region1/npdes/merrimackstation/

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Surviving the New Steam Generating Effluent Guidelines

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