10-K - SCANA Corporation

Table of Contents
The EPA is conducting an enforcement initiative against the utilities industry related to the NSR provisions and the new
source performance standards of the CAA. As part of the initiative, many utilities have received requests for information under
Section 114 of the CAA. In addition, the DOJ, on behalf of EPA, has taken civil enforcement action against several utilities. The
primary basis for these actions is the assertion by EPA that maintenance activities undertaken by the utilities at their coal-fired power
plants constituted “major modifications” which required the installation of costly BACT. Some of the utilities subject to the actions
have reached settlement.
To date, SCE&G and GENCO have received and responded to Section 114 requests for information related to Canadys,
Wateree and Williams Stations. The current state of continued DOJ civil enforcement is the subject of industry-wide speculation, and
it cannot be determined whether the Company will be affected by the initiative in the future. The Company believes that any
enforcement action relative to its compliance with the CAA would be without merit. The Company further believes that installation of
equipment responsive to CAIR previously discussed will mitigate many of the alleged concerns with NSR.
Water Quality
The CWA provides for the imposition of effluent limitations that require treatment for wastewater discharges. Under the
CWA, compliance with applicable limitations is achieved under a national permit program. Discharge permits have been issued and
renewed for all of SCE&G’s and GENCO’s generating units. Concurrent with renewal of these permits, the permitting agency has
implemented a more rigorous program of monitoring and controlling discharges, has modified the requirements for new cooling water
intake structures, and has required strategies for toxicity reduction in wastewater streams. The EPA has said that it will issue a rule by
mid-2012 that modifies requirements for existing cooling water intake structures. The Company is conducting studies and is
developing or implementing compliance plans for these initiatives. Congress is expected to consider further amendments to the CWA.
Such legislation may include limitations to mixing zones and toxicity-based standards. These provisions, if passed, could have a
material impact on the financial condition, results of operations and cash flows of the Company, SCE&G and GENCO. The Company
believes that any additional costs imposed by such regulations would be recoverable through rates.
Hazardous and Solid Wastes
The EPA has stated its intention to propose, in late 2012, new federal regulations affecting the management and disposal of
CCRs, such as ash. Such regulations could result in the treatment of some CCRs as hazardous waste and could impose significant
costs to utilities, such as SCE&G and GENCO. While the Company cannot predict how extensive the regulations will be, the
Company believes that any additional costs imposed by such regulations would be recoverable through rates.
The Nuclear Waste Act required that the United States government accept and permanently dispose of high-level radioactive
waste and spent nuclear fuel by January 31, 1998. The Nuclear Waste Act also imposed on utilities the primary responsibility for
storage of their spent nuclear fuel until the repository is available. SCE&G entered into a Standard Contract for Disposal of Spent
Nuclear Fuel and/or High-Level Radioactive Waste with the DOE in 1983. As of December 31, 2011, the federal government has not
accepted any spent fuel from Summer Station Unit 1 or any other nuclear generating facility, and it remains unclear when the
repository may become available. SCE&G has on-site spent nuclear fuel storage capability until at least 2017 and expects to be able to
expand its storage capacity to accommodate the spent nuclear fuel output for the life of Summer Station Unit 1 through dry cask
storage or other technology as it becomes available.
The provisions of CERCLA authorize the EPA to require the clean-up of hazardous waste sites. In addition, the states of
South Carolina and North Carolina have similar laws. The Company maintains an environmental assessment program to identify and
evaluate current and former operations sites that could require environmental clean-up. In addition, regulators from the EPA and other
federal or state agencies periodically notify the Company that it may be required to perform or participate in the investigation and
remediation of a hazardous waste site. As site assessments are initiated, estimates are made of the amount of expenditures, if any,
deemed necessary to investigate and remediate each site. These estimates are refined as additional information becomes available;
therefore, actual expenditures may differ significantly from the original estimates. Amounts estimated and accrued to date for site
assessments and clean-up relate solely to regulated operations. Such amounts are recorded in deferred debits and amortized, with
recovery provided through rates. The Company has assessed the following matters:
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