(_ DUKE 

ENERGY~ 

March 28, 20 14 

VIA FED-EX OVERNIGHT 

Ronald Jordan 

EPA 

EPA West Building/Connecting Wing, Room 6233-W 

1301 Constitution A venue, NW 

Washington DC 20004 

Subject: Supplemental Information Request 

Dear: Mr. Ron Jordan 

Environmental Services 

Duke Energy 

526 South Church Street 

Charlotte, NC 28202 

Mailing Address: 

Mail Code EC13KI P.O. Box 1006 

Charlotte, NC 28201-1006 

On January 27, 2014, EPA submitted to Duke Energy a Supplemental Information Request 

seeking data related to Duke Energy's Comments to EPA's Proposed Effluent Limitation Guidelines 

and Standards for Electric Power Generation Point Sources (78 FR 34432). Please find enclosed two 

compact discs (CD) satisfying this information request: one for confidential business information, the 

other for non-confidential business information. 

EPA's Supplemental Information Request sought extensive multi-year data pertaining to 

seven coal fired facilities, with a 30 day production deadline. After negotiations, EPA extended the 

production deadline to March 31, 2014. Even with the extension of time, EPA's Supplemental 

Information Request placed an undue burden upon Duke Energy to obtain extensive data from seven 

coal tired facilities. To Duke Energy's knowledge, other utility companies were not required to 

perform such an exhaustive and burdensome data review and production in response to a 

supplemental information request. Duke Energy is responding to the Supplemental Information 

Request to the best of its knowledge, relying upon available information and belief in accordance 

with applicable law. Duke Energy has found that some portions of the Supplemental Information 

Request to be vague ancl/ambiguous. As a result, Duke Energy is responding to the Supplemental 

Information Request tv the best ot its ability, utilizing its reasonable interpretation of the language 

contained in the Supplemental Information Request. Duke Energy's Response is only intended to 

supply information and documents that are not protected from disclosure pursuant to attorney-client 

privilege, the work product doctrine, the critical self-evaluation privilege or any other applicable 

privilege or protection afforded by law. When requested data could not be collected and reviewed 

within the timeframe imposed by EPA, Duke Energy will provide estimates of when such data will 

be produced. 
Mr. Ron Jordon 

March 28, 2014 

Page 2 

The Supplemental Informa tion Request seeks disclosure of certain contidential or proprietary 

information or trade secrets and/or confidential business or commercial information (collectively 

"Confidential Business Information" or "CBI"). The information and documents that Duke Energy 

designates as .. CBI" satisfy all the requisite conditions governing CBI claims set forth in EPA's 

applicable regulations. Inc luded within Duke Energy's designation of CBI material are the following 

types of data: Fuel contracts, costs and tons; fuel additives and other data which could reveal 

operational practices, outage schedules or costs to Duke Energy's competitors. All CBI designated 

data is marked accordingly and is provided to EPA on a separate CD. If EPA does not agree with, or 

has questions about, the proprietary of any CBI designation for certain documents or information, 

EPA should immediately contact Julie L. Ezell, Duke Energy Legal Department, 1000 East Main 

Street, Plainfield, Indiana 46 168. Telephone: 317-838- 1100. Email: Julie.ezell @dukecnergy.com. 

If EPA has any question specifi c to the data submitted, please contact Nathan Craig, Duke 

Energy, 526 South Church St., Charlotte, NC 28202. Telephone: 704-382-9622. Email: 

nathan.craig@duke-eneryg.com. 

ff.~ NathanC

~ a~ Senior Environmental Specialist 

Enclosure 

Cc: Julie Ezell 

Richard Baker 

John Velte 

Jennifer Stenger 

Brandon Delis 

Bill Kennedy 

Joe Potts 

Pat Coyle 

Derek Henderson