# (_**DUKE ENERGY** **~**

March 28, 20 14 

### VIA FED-EX OVERNIGHT Ronald Jordan EPA EPA We s t Build in g/Connecting Wing, Room 6233 -W 1301 Cons ti tu ti on A venue, NW Washington DC 20004 Subjec t: Supplemental Information Request Dear: Mr. Ron Jordan Environmental Serv i ces 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 seekin g 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) satisfy in g this information request: one for confidential business i nformati on, 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 Marc h 31, 2014. Even with the extension of time, EPA's Supplemental Information Request placed an undu e burden upon Duke Energy to obtain ex tensive 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 i s responding to the Supplemental Information Request to the best of its knowledge, relying upon available information and belief in accordance with applicab l e 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 I nformation Request tv the best ot its ability, utilizing its reasonable interpretation of the language contained in the Supplemental Information Request. Duke Energy's Response i s on ly intended to supp ly in format ion and documents that are not protected from disclosure pursuant to attorney-client privilege , the work product doctrine, the critical self-evaluat ion privilege or any other applicab l e privi l ege or protection afforded by law
. When requested data could not be collec ted and reviewed within the timeframe imposed by EPA, Duke Energy will provide estimates of when such data will be produced.Mr. Ron Jordon Ma r ch 28, 2014 Page 2

T h e Supple mental In forma ti o n Request see ks disclosure of cer tain contidentia l or propri e tary informati on or trade sec r ets and/o r confide nti al bus iness o r comme r c ial in formation (co ll ective ly "Co nfid ential Business In formation" or "C BI "). The i nformation a nd document s that Duke Energy designates as .. CB I " sat is fy all the requ is ite co nditions governing CBI cla im s set forth in EP A's applicable regulations. I nc luded withi n Duke Energy's designation of C BI material are the following types of data: Fuel contracts, costs and ton s; fuel additives a nd other data which co u ld reveal o pera ti o nal prac ti ces, o ut age sc hedules or costs to Duke En e rgy's compe ti to r s. A ll CBI d es ignated data is marked accordin g l y and is prov ided to EPA o n a separate CD. If EPA d oes not ag ree w ith, or has questi o ns about, the proprietary of any CBI designation for certain document s or in format ion, E PA s h ould immediately contact Julie 

### L. Ezell , Duke Energy Lega l Department , 1000 Ea st Mai n Street , Plainfield, Indi a n a 46 168. Te lephone: 317-838

- 1100. Email: J u li e.ezell @duke

c n e r gy.com . I f EPA has any que s ti on spec ifi c to the data submitted, plea se co ntact Nathan Craig, Duke Energy, 526 South Church St. , Charlotte, NC 28202. Telephone: 704-382-9622. Email: nat ha n . c raig @ duke-e n eryg.com .



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**NathanC a~**  Senior Environmental Speciali s t Enclos ure Cc: J ulie Ezell R ichard Baker John Ve lte Jennif e r Ste nger B randon Del is Bill Ke n nedy J oe P otts Pat Coyle Derek Henderson