MEMORANDUM

TO:	Preliminary 2008 Effluent Guidelines Plan Docket,
EPA-HQ-OW-2006-0771

FROM:	Sarah Holman, ERG

DATE:	September 25, 2007

SUBJECT:	Collection of NPDES Form 2C Application Data for Steam Electric
Plants  

EPA and the Utility Water Act Group (UWAG) are coordinating efforts to
compile selected NPDES Form 2C data from UWAG’s member companies.  The
NPDES Form 2C is an application for a permit to discharge wastewater
that must be completed by existing industrial facilities (including
manufacturing, commercial, mining and silvicultural operations).  This
form includes facility information, data on facility outfalls, process
flow diagrams, treatment information, and intake and effluent
characteristics.  During EPA’s development of the “Data Request for
the Steam Electric Power Generating Industry,” UWAG proposed, as an
alternative to the Data Request including a requirement for plants to
collect wastewater samples, to gather current Form 2Cs from its members
and summarize relevant data contained on the forms.  While this
compilation of Form 2C data will provide less information than a
sampling requirement for a given plant, EPA believes it is a reasonable
alternative that will provide wastewater characteristics for a broader
population of plants than EPA had contemplated, encompassing a greater
variety of plant operations and characteristics and possibly resulting
in a better characterization of the waste streams of interest.  In
addition, this approach eases the burden that would have been borne by
plants responding to the Data Request.  

EPA and UWAG held a conference call on September 6, 2007 to discuss the
scope of the NPDES Form 2C data collection, the timeframe of the data
collection, and the structure of the database to be used for the data
collection.  EPA and UWAG decided that the NPDES Form 2C collection will
focus on the outfalls of coal-fired facilities that receive flue gas
desulfurization (FGD), ash handling, and/or coal pile runoff waste
streams.  Other outfalls – such as separate outfalls for sanitary
sewerage, cooling water, landfill runoff, and other miscellaneous
purposes – will not be included in the database.  The database will
not include Form 2C information for plants that do not have either a wet
FGD or wet fly ash.  For example, if a plant has no wet FGD and it is
known that the only wet ash handling at the plant is for bottom ash
sluicing, its information will not be included in the database.  

Attached to this memorandum are email communications between EPA and
UWAG regarding the NDPES Form 2C data collection effort.  These emails
contain materials that EPA and UWAG generated to facilitate the data
collection including a project outline and data collection instructions.

Memorandum

May 11, 2007

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