December 3, 2014 

Mr. Robert K. Wood, Director 

Engineering and Analysis Division 

Mail Code 4303T 

U.S. Environmental Protection Agency 

William Jefferson Clinton Building 

1200 P.e1msylvania Avenue, N. W. 

Washington, DC 20460 

American Electric Power 

1 Riverside Plaza 

Columbus, OH 43215-2373 

AEP.com 

Re: lriformation Request Pursuant to Section 308 of the Clean T,Vater Act 

Pilot Testing Conducted at John E. Amos Plant and Other AEP Plants 

Dear Mr. Wood: 

On November 4, 2014, a letter was hand-delivered to Dr. Timothy Lohner by Ronald Jordan of 

U.S. EPA, seeking certain information related to pilot testing recently conducted at the Jolm E. 

Amos Plant in Winfield, West Virginia, and similar testing conducted at other plants within the 

American Electric Power (AEP) system. The requested infotmation was submitted to the agency 

on November 26, 2014; however, certain supplemental information, mainly in response to 

Question 11, was not provided. 

Enclosed are two COs with the requested supplemental information. The first CD, labeled, 

AEP John E. Dolan Lab Reports 

Ques. 11. Supplemental Information for 

SE05159Al Analytical Data Table Purge Data conect.xlsx 

NON-CONFIDENTIAL DATA 

provides information that is relevant to Question 10, Part a, (FGD purge stream) and corr-esponds 

with the infmmation provided in the Excel file: SE05159Al Analytical Data Table Purge Data 

conect.xlsx. 

The second CD, labeled, AEP Jolm E. Dolan Lab Reports 

Ques. 11. Supplemental Information for 
In addition, a third CD, labeled, 

"NON-CONFIDENTIAL DATA" Information Request Pursuant to Sec. 308 of 

the CWA Pilot Testing Conducted at the John E. Amos Plant- w/Corrected File, 

is being provided to replace the original CD with the same title. One of the files on the original 

CD (SE05159Al Analytical Data Table Purge Data.xlsx) included incoiTect reporting and 

method detection limits for mercury. The new CD includes a corrected file, which includes the 

appropriate reporting and detection limits. 

The information that is "confidential business information" has been placed on a separate CD, 

and is identified by a stamp or other marking directly on the information submitted herewith. 

We understand that confidential information may be shared with contractors working with U.S. 

EPA on the development ofthe Effluent Limitation Guidelines for the Steam Electric Generating 

Sector, as set forth in Enclosure 4 to your letter, and that U.S. EPA has included provisions in the 

contracts with those vendors all provisions necessary to implement the confidentiality provisions 

of 40 CFR Part 2, specifically, 40 CFR §§ 2.30l(h)(2), 2.302(h)(2) and 2.305(h)(2). Should 

further disclosure of our confidential infonnation be necessary, we understand that it is U.S. 

EPA's obligation to provide us with notice of any transfer of confidential information. We also 

understand that U.S. EPA will notify AEP if a request is made for release of the information 

designated as confidential, that U.S. EPA may request further substantiation of our claims of 

business confidentiality, and that we will be notified of any determination that a request for 

confidential treatment has been denied. 

The data included on the CD that is marked "CONFIDENTIAL BUSINESS INFORMATION" 

is primarily infmmation obtained during the pilot testing. The pilot testing was conducted 

pursuant to a supplemental agreement with the Electric Power Research Institute (EPRI), and is 

valuable research and development data that could provide AEP and its affiliates with economic 

and commercial advantages in determining how best to comply with the effluent limitations 

currently under review at U.S. EPA. AEP has expended substantial resources to pruticipate in 

these research activities, and the results of that reseru·ch should not be made publicly available to 

AEP's competitors without charge, because doing so will rob AEP of its investment in that 

research. 

AEP's contract with EPRI also designates this information as CONFIDENTIAL 

INFORMATION of EPRI and its funders, gives AEP limited rights to use the data and 
None of the data for which AEP is requesting confidential treatment is "effluent data" as that 

term is defined in 40 CFR §2.302(a)(2)(i), because all of the data relates to wastewaters that were 

specially developed for purposes of the pilot testing, and were retumed to the systems at the John E. Amos Plant for further treatment prior to discharge. This information is being voluntarily submitted by AEP to further the agency's tmderstanding of technologies that have not yet progressed to the point of commercial availability. While AEP understands that the agency can consider certain research-related information to be "effluent data" if necessary to demonstrate the feasibility, practicability, or attainability (or lack thereof) of an existing or proposed standard or limitation, pursuant to 40 CFR § 2.302(a)(2)(ii)(A), and may disclose such information publicly, AEP submits that the preliminary natl.rre of the requested data, and the limited nature of the pilot testing perfonned to date, is insufficient to allow U.S. EPA to make such a determination based 

on this data alone. 

Should you have any questions concerning the information provided on the CDs, please contact 

me at (614) 716-1255, or by e-mail at twlolmer@aep.com. 

Very truly yours, 

Timothy W. Lohner, Ph.D. 

Consulting Environmental Specialist 

Enclosures: 

cc: 

CD Supplemental Information "CONFIDENTIAL BUSINESS INFORMATION" 

CD Supplemental Information "NON-CONFIDENTIAL DATA" 

CD Corrected file "NON-CONFIDENTIAL DATA" 

~ordan- U.S. EPA 

Phillip Flanders -U.S. EPA 

John M. McManus- VP, AEP Environmental Services 

Janet J. Henry- AEP Deputy General Counsel