Get Your Ducks in a Row for ELG Compliance

Transcription

1 Get Your Ducks in a Row for ELG Compliance

2 New ELG Regulations The U.S. Environmental Protection Agency (EPA) finalized the new effluent limitation guidelines (ELGs) on September 30, This is the first update since 1982, and it s a game changer for many U.S. power plants. The new, technology-based guidelines increase regulation on discharges from steam electric power plants into surface waters. It s time to get your ducks in a row for ELG compliance if you re an electric utility or independent power producer that falls within NAICS codes 22111, or 22113, and your facility discharges wastewater to a surface water body via a National Pollutant Discharge Elimination System (NPDES) permit or to a publically-owned treatment works (POTW). EPA s Planned Implementation Timeline APRIL 17, 2015 Final CCR Rule Issued SEPTEMBER 30, 2015 Final Rule signed by EPA Effective Date (TBD) 60 days after publication in Federal Register DECEMBER 31, 2023 Deadline for ELG implementation if complying via voluntary incentive program for Flue Gas Desulfurization (FGD) Wastewater SEPTEMBER 2009 Final detailed study report released and EPA announces decision to proceed with amendment JUNE 7, 2013 Proposed ELG amendment issued NOVEMBER 2018-DECEMBER 2023 PERMIT IMPLEMENTATION PERIOD Permitting authorities incorporate final ELGs into NPDES and pre-treatment permits

3 New ELG Regulations What You Should Know»» Primarily impacts coal-fired power plants with a generating capacity greater than 50 MW, and integrated gasification combined cycle (IGCC) facilities.»» Removes FGD wastewater, IGCC wastewater and coal combustion residuals (CCR) leachate from current definition of low volume waste.»» Prohibits discharge of fly and bottom ash transport waters and flue gas mercury control systems (FGMC) wastewaters.»» Sets new numerical limits for arsenic, mercury, selenium, nitrite and nitrate for FGD wastewater from existing sources.»» Sets new numerical limits for arsenic, mercury, selenium and total dissolved solids (TDS) for FGD wastewater from new sources.»» Sets new numerical limits for arsenic, mercury, selenium and TDS for IGCC wastewaters.»» Sets new numerical limits for arsenic and selenium for new CCR leachate sources.»» Does not establish new regulations for non-chemical metal cleaning wastes regulation is left to the best professional judgment of the regulating authority.»» Legacy wastewaters (generated prior to effective date of new permit) are not subject to the new rule limitations.»» Voluntary incentive program for direct dischargers extends the compliance timeline for facilities that agree to install vapor compression evaporation systems to treat FGD wastewaters.»» Anti-circumvention provision prohibits the internal reuse of fly and bottom ash transport waters and FGMC wastewaters, except in the case where ash transport waters are used as FGD scrubber makeup.»» Implementation will begin with NPDES permit renewals on or after November 1, 2018, through December 2023.

4 Technology Basis and Limits for Preferred Regulatory Options Current Rule New Rule BAT/PSES (Existing Sources) New Rule NSPS/PSNS (New Sources) Chemical precipitation + biological treatment Evaporation FGD Wastewater Included as low volume waste Hg, As, Se, NO 2 + NO 3 Limits Hg, As, Se, TDS limits Fly Ash Transport Water Total suspended solids (TSS), oil and gas (O&G) limits Dry handling Dry handling Dry handling/closed loop Dry handling/closed loop Bottom Ash Transport Water TSS, O&G limits Coal Combustion Residual (CCR) Leachate Included as low volume waste TSS, O&G limits no change from current Chemical precipitation Additional Hg, As limits Flue Gas Mercury Control Systems (FGMC) Wastewater Included as low volume waste Dry handling Dry handling Integrated Gasification Combined-Cycle (IGCC) Wastewater Included as low volume waste Evaporation Hg, As, Se, TDS limits Evaporation Hg, As, Se, TDS limits Non-chemical Metal Cleaning Wastes Reserved for future consideration Reserved for future consideration Reserved for future consideration

5 Numerical Limits Flue Gas Desulfurization Wastewater (Existing Sources) Arsenic, ppb 30-Day Average: 8 Daily Maximum: 11 Mercury, ppt 30-Day Average: 356 Daily Maximum: 788 Selenium, ppb 30-Day Average: 12 Daily Maximum: 23 Nitrite-Nitrate, ppm as N 30-Day Average: 4.4 Daily Maximum: 17 Flue Gas Desulfurization Wastewater (New Sources + Incentive Program) Arsenic, ppb 30-Day Average: Daily Maximum: 4 Mercury, ppt N/A 30-Day Average: 24 Daily Maximum: 39 Selenium, ppb 30-Day Average: Daily Maximum: 5 Total Dissolved Solids, ppm N/A 30-Day Average: 24 Daily Maximum: 50 Coal Combustion Residuals Leachate (New + Existing Sources) *Arsenic, ppb 30-Day Average: 8 Daily Maximum: 11 *Mercury, ppt 30-Day Average: 356 Daily Maximum: 788 Total Suspended Solids, ppm 30-Day Average: 30 Daily Maximum: 100 Oil & Grease, ppm 30-Day Average: 15 Daily Maximum: 20 Integrated Gasification Combined-Cycle (New + Existing Sources) Arsenic, ppb 30-Day Average: Daily Maximum: 4 Mercury, ppt N/A 30-Day Average: 1.3 Daily Maximum: 1.8 Selenium, ppb 30-Day Average: 227 Daily Maximum: 453 Total Dissolved Solids, ppm 30-Day Average: 22 Daily Maximum: 38 * New sources only

6 Frequently Asked Questions Q: The coal burning unit at my site will be decommissioned in 2016; however, we might still have wastewater stored in the on-site ash impoundment after the rule implementation date. Are these wastewaters subject to the new ELG rules? A: Legacy FGD wastewaters, fly ash transport waters, bottom ash transport waters, FGMC wastewaters or gasification wastewaters generated prior to the rule implementation date and stored in an impoundment will only need to meet the previous ELG and permit limits for those wastewater streams prior to discharge. This means they will likely only be required to meet TSS and oil and grease limits, unless other parameters for these wastewater streams existed previously in the owner s discharge permit. Q: What is the definition of a new source versus an existing source in the proposed new rule? A: A new source is defined by the EPA as a building, structure, facility or installation generating wastewater where construction began after the promulgation of the final ELG rule. A new source is the part of the facility that generates a new wastewater stream, such as a new wet FGD system whether it is a new power plant or a new piece of equipment. A new source does not refer to a new wastewater treatment system or upgrades to an existing wastewater treatment system, as the treatment system is not considered to be the wastewater source. Q: How will these ELG changes be implemented into my existing NPDES permit? Q: My plant currently combines CCR leachate and FGD wastewater for treatment in a common wastewater treatment facility. Will this still be permitted under the new regulation? A: Permitting authorities will begin incorporating the new ELG requirements into NPDES and pre-treatment permits after November 1, This will provide facilities a minimum of three years to comply. The plan is to have all permits updated within five years of the anticipated implementation date, or by December 31, However, all new sources will be subject to the new rules upon the implementation date. It s important to note that the new ELG limits are the minimum level of pollutant regulation permit writers will be expected to require. In addition to the ELG technology-based effluent limits, a facility may be required to meet other water quality based effluent limits to protect the receiving water streams. A: At existing facilities, CCR leachate can be combined with FGD wastewater prior to treatment provided the combined wastewater stream is treated to the new effluent limit standards for FGD wastewater prior to discharge. The combined stream will be subject to the numerical discharge limits for arsenic, mercury, selenium, nitrite and nitrate for FGD wastewater. An evaluation for treating each stream separately may be beneficial as a lower cost option since CCR leachate from existing sources will follow previously regulated low volume waste requirements for only TSS and oil and grease.

7 5 Steps to Get Your Ducks in a Row 1 Evaluate the impact of all regulations The EPA has recently issued additional regulation for CCR, CWA 316(b) and flue gas emissions. Evaluating the plant holistically by considering the impact of all regulation changes is important to develop cost-effective, practical solutions to meet a facility s needs for all regulatory challenges. 2 Know your plant s current water/wastewater picture To determine the best solution for the future and evaluate how changes will impact your plant, you need to understand your current plant picture. If you haven t already done so, now is the time to update your plant water and mass balances, determine data gaps, and implement a plan to fill in the gaps and develop a complete plant picture. 3 Weigh the benefits of the incentive program The EPA has proposed an incentive program with an extended compliance timeline for plants who voluntarily choose to treat their FGD wastewater via a vapor-compression evaporation system and accept stricter discharge limitations. Considering other WQBELs that your plant might be subject to and other site specific factors, evaluate whether participation in this incentive program might make sense at your facility. Best-In-Class Process Water Solutions HDR is a global employeeowned firm providing environmental, engineering, consulting and construction services. We think holistically by considering all pending environmental changes for the lowest cost and most practical solutions when it comes to power plant process water. Facility planning, modeling, water quality compliance, wastewater treatment and waste minimization are a few services we offer. 4 Look into reuse/recycle opportunities and other ways to eliminate or reduce wastewater streams Analyze your plant s water and mass balance to see if there are low cost opportunities to reuse wastewater streams or minimize flow rates to reduce your treatment volumes. The EPA made significant changes to the proposed anti-circumvention provision from the draft version, giving plants more flexibility. Combining streams for treatment or discharge is permitted in most cases with modification of numerical limits based on flow rates. 5 Lock in your plan of attack Now is the time to act. The anticipated implementation date of the ELG amendment is November 2018, leaving some facilities just three years to comply. Review your NPDES or pre-treatment permit renewal dates and establish a site-specific timeline and plan of attack. For more information, please contact: Colleen Scholl (Layman), PE P: (304) E: colleen.scholl@hdrinc.com

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