POWER December 2015 - 40

REGULATORY COMPLIANCE
Take These Five Steps Now to
Ensure ELG Compliance at Your
Power Plant
The first effluent limitation guidelines update since 1982 is game-changing for
many U.S. power plants. This unfiltered look at the rule and its nuances
will help you understand how each component affects your plant and
presents the five steps you need to take now to be on pace with the compliance
timeline.
Colleen Layman
T
he U.S. Environmental Protection Agency's
(EPA's) first update to the Steam
Electric Power Generating Effluent
Guidelines (commonly called effluent limitation
guidelines or ELGs) since 1982 changes
the way many power plants will operate in the
future. The complex rule, coming in at a staggering
311 pages, covers a lot of ground. But
the main focus falls on coal-fired power plants
and integrated gasification combined cycle
(IGCC) power plant wastewaters.
To grasp the impact of the rule at your
plant, it's important to know the history of
the rule and the reasoning behind some of
its nuances. That's the logical start. Next
you need to understand the latest update's
six main focus areas and how they apply to
your facility. Once you're up to speed on the
rule itself, it's time to take a hard look at the
five steps you need to take now so your plant
is ready for compliance, which could be as
early as three years down the road.
The Update
It's been a decade since the EPA first identified
the power industry's ELGs for study and
a potential update. And on September 30,
2015, after 10 long years of studying, surveying,
and debating, the EPA administrator
signed the final ELGs rule for the steam electric
power generating point source category
and submitted it for publication in the Federal
Register. The result? Lots of expected
updates and a few surprising changes.
Here's the brief background of this new
rule. The steam electric power generating
point source category ELGs rule regulates
wastewater discharges from fossil- and nuclear-powered
steam generating plants whose
primary purpose is to generate electricity for
distribution and sale, and that discharge to
a surface water body via a National Pollutant
Discharge Elimination System (NPDES)
40
permit (direct dischargers) or discharge to a
publicly owned treatment works (POTW) via
a pretreatment permit (indirect dischargers).
The ELGs are technology-based regulations,
which means the limitations set by the
EPA under this rule are established based on
what is achievable given the implementation
of a certain treatment technology the agency
selects as a basis.
Although nuclear and combined cycle
power plants fall into this ELG category and
are subject to this rule, the primary focus of
the EPA update is coal-fired power plant and
IGCC power plant wastewaters-particularly
the wastewaters from these facilities associated
with flue gas air pollution control systems
or solid waste handling systems. Given that a
number of these wastewater sources weren't
commonly used when the rule was last updated
33 years ago, many of these wastewaters
were regulated as low-volume wastewaters.
Now that these wastewaters are commonplace
sources, a major intent of the update is
to remove them from the catch-all category of
low-volume wastewater and establish separate
regulation of each using its own set of limits
and treatment technology basis.
Six Focus Areas: What's Changed
and What Hasn't
The 2015 ELGs update focuses on six power
plant wastewater streams:
■ Flue gas mercury control (FGMC) system
wastewater
■ Bottom ash transport waters
■ Fly ash transport waters
■ Flue gas desulfurization (FGD) wastewater
■ Coal combustion residuals (CCR)
leachate
■ IGCC wastewater
Although additional regulation of
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nonchemical metal-cleaning wastes was proposed
in the draft version of the rule, the EPA
reserved this category of wastewater for future
consideration. That decision was based
on comments received from the industry and
a general lack of data on the waste stream.
Regulators will still be expected to use their
best professional judgment when determining
limits for discharge of these wastewaters.
The first three ELG updates ban FGMC
wastewaters, fly ash transport waters, and
bottom ash transport waters from being discharged
to surface water bodies or POTWs.
FGMC wastewaters include any " process
wastewater generated from an air pollution
control system installed or operated for the
purpose of removing mercury from flue gas. "
This refers to the sluice or transport waters
used to transfer the mercury adsorbent (usually
activated carbon) from the collection
hoppers to an impoundment. In the previous
version of the rule, these wastewaters were
included as low-volume wastewaters. Now
they're one of the streams (along with FGD
wastewater, IGCC wastewater, and CCR
leachate) being removed from the low-volume
waste category to be regulated individually.
In the final rule update, FGMC wastewaters
are a stand-alone category. The EPA set dry
handling systems as the technology basis for
regulation and established a zero-discharge
policy for new and existing sources generating
this wastewater stream.
Bottom ash and fly ash sluice or transport
waters are also zero-discharge streams under
the updated ELG rule. Fly and bottom ash
transport systems will need to be converted to
the EPA technology basis options of dry handling
or closed loop systems-or use other alternatives
that do not necessitate discharge of
ash transport wastewaters. However, the EPA
did allow for ash transport waters to be reused
within the plant on a very limited basis as an
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