UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTAFEDERALCENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 

# MAY O 3 

# 2012
UNITED PARCEL SERVICE EMAIL RECEIPT REQUESTED
G. Dwain Waters GulfPower Company Lansing Smith Generating Plant -Environmental Affairs One Energy Place Pensacola, Florida 32520-0328
Dear 

### Mr. Waters: The purpose of this letter is to request informationto allow for the development of a federal implementation plan PIP) to address regional haze requirementsrelated to best available retrofit technology (BART) and reasonable progress (RP) regarding electrical generating units (EGUs) in Florida. Section 114(a)of the Clean Air Act (CAA or Act), 42 U.S.C $7414(a), authorizesthe Administratorofthe U.S. Environmental ProtectionAgency to require any person who owns or operates an emission source, whom the Administrator believes may have informationnecessary for the purposes of section 114(a), or who is subjectto any requirement ofthe CAA, to provide such information as the Administrator may reasonably require for the purpose of carrying out any provision of the Act. This authority has been duly delegated to the Director of the Air, Pesticides, and Toxics Management Division, Region 4. Specifically,the EPA is requiring Gulf Power Company to submit certain information about units 1 and 2 at the Lansing Smith GeneratingPlant that is necessaryto allow for the development of a FIP to satisfy BART and RP requirementsin support of the regional haze requirements for the State of Florida. As a result of a finding of failure to submit determinationthat the EPA made on January 9,2009, for Florida's regional haze state implementation plan (SIP) revision, the EPA was required to implement a FIP for Floridato satisfythe regional haze requirements (including those related to BART and RP) or approve a SIP revision addressing these requirementsby January 15,2011. On March 19,2010, as amended August 3 1,201 0, the Florida Department of Environmental Protection (FDEP) submitted a revision to Florida's SIP to addressregional haze in Class I areas as required by the EPA's regional haze regulations located at 40 CFR Part 5 1, Subpart P, also known as the Regional Haze Rule (RHR). This submittal identified the above EGUs owned or operatedby your company as being subject to BART or RP requirements.
In its submittal, the Staterelied on the Clean Air Interstate Rule (CAIR) to meet the BART and RP requirements for sulfurdioxide (SO2) and nitrogen oxides (NOx) for EGUs. However, on August 8, 201 1, the EPA published the Cross State Air Pollution Rule (CSAPR) which replaced CAIR and only coversNOx emissions in Florida. As a result of the replacement of CAIR with CSAPR, the State can no longer rely on CARto meet the BART and RP requirements for NOx and SO2.On December 30,2011,

Internet Address (URL) http://www.epa.gov RecycledlRecyclable .Printed with Vegetable On Based Inks on Recyded Paper (Mlnimum 30% Postconsumer)the EPA proposed its determinationthat CSAPR will satisfy BART requirements for SO2and NOx for EGUs in each CSAPR subject state where those pollutants are covered by CSAPR. For these reasons, FDEP has initiated an effort to reassess BART and RP requirements for SOzand particulate matter for some of the affected facilities. As mentioned above, the EPA is currently obligated to implement a FIP for Florida to meet the regional haze requirements. Where the Statehas provided the EPA with a SIP revision that sufficiently addresses the requirements, the EPA may have the opportunityto approve Florida's SIP in lieu ofimplementing a FIP. 

### In this particular case, the EPA has a SIP revision from Florida which meets some ofthe regional haze requirementsbut does not sufficientlymeet other requirements. FDEP identified Lansing Smith Generating Plant's EGUs as among those for which insufficient information exists for the State to prepare the necessary BART and RP analyses.
The CAA and RHR identify the factors that the EPA must considerin evaluatingBART and RP for individual sources. The BART analysis will be used to identify the best system of continuous emissions control technology taking into account the available retrofit control options, the costs of compliance, the energy and non-air quality impacts of compliance, any pollution control equipment in use at the source, the remaininguseful life ofthe source, and the degree ofimprovement in visibility which may reasonablybe anticipated to result fiom the use of the technology. At a minimum, the 

### RP analysis must considerthe costs of compliance,time necessary for compliance, the energy and non-air qualityimpacts of compliance, and the remaining usefbl life ofthe source. Enclosure C summarizes the analyhc approach delineated in Appendix Y of40 CFR Part 51 for evaluating BART. Therefore, pursuant to section 114(a), GulfPower Company is directed to provide the information identified in EnclosureA for the Lansing Smith Generating Plant within thirty (30) days of receipt of this letter. The EPA, for good cause shown, may extend the deadline for respondingto the request. The responses must be delivered to the EPA or postmarked no later than the above deadline. Send one complete copy of your response, including supportingdocumentation, to the following address: Lynorae Benjamin Chief, RegulatoryDevelopment Section U.S. EPA, Region 4 Atlanta Federal Center 61 Forsyth Street, S.W. Atlanta, Georgia 30303
You are entitled to assert a claim ofbusiness confidentiality covering all or part of any required information, except emission data, in the manner described at 40 CFR $2.203(b). Information subject to a claim ofbusiness confidentiality will be made availableto the public only in accordance with the procedures set forth at 40 CFR Part 2, SubpartB. Unless a confidentialityclaim is asserted at the time that the required information is provided, the EPA may make this information availableto the public without further notice to you. Notwithstanding the above, the informationyou provide may be used by the EPA in administrative, civil, and criminalproceedings.
Gulf Power Company must submit all requested information for the Lansing Smith Generating Plant under an authorized signature.An individual with sufficientknowledge and authoritymust certify on behalf of Gulf Power Company that all informationthat the Company submits in response to this request is true, correct, accurate, and complete, as follows:I certifythat I have examined and am familiar with the informationin the enclosed documents, including all attachments. Based on my inquiry ofthose individuals with primary responsibility for obtaining the information, I certify that the statements and information are, to the best of my knowledge and belief, true and complete.
Failure to provide the requested informationis a violation of section 114 of the CAA and could result in an enforcement action for the recovery of civil penalties not to exceed $37,500per day, per violation, for injunctive relief, or both. Section 113,42U.S.C. $7413, ofthe CAA gives the EPA the authority to seek criminalpenalties from any person who knowingly makes any false statement, representation, or certification in any report required under the CAA.
This required submittal of informationis not subjectto the provisions ofthe Paperwork Reduction Act of 1980,44 U.S.C. Chapter 35.
If you have any questions, you may consult with the EPA prior to the due date for your response. Questions shouldbe directed to Lynorae Benjamin at (404) 562-9040 or by email at 

### beniamin.lvnorae@,epa.nov. Thank you for your cooperationin this matter. Sincerely,

Beverly H. Banister u Director Air, Pesticides, and Toxics

Management Division

Enclosures

cc: Jeff Littlejohn, FDEP Brian Accardo, FDEP Chad Stevens (w/enclosures), FDEPEnclosure A Provide the following information for the Gulf Power Company 

## - Lansing Smith GeneratingPlant using the instructions and definitions supplied in EnclosureB. Unless otherwise directed, provide the requested information for the time period fiom January 2002 to the date of this request: 1. For each oil or coal-fired generating unit identified submit: a. the emission unit identificationnumber; b. the date or year commercial operationbegan; c. the Contract Data Sheet for each boiler; d. all data contained on the original nameplates for each boiler, each turbine and each generator (a legible photograph of each nameplate would suffice if available); e. all data contained on the current nameplates for each boiler, each turbine and each generator if the nameplates are not original to the equipment or if any information on the nameplateshasbeen changed from the original information (a legible photograph of each nameplatewould suffice if available); f. the original design and current maximum generating capacity (Megawatts gross and Megawatts net); g. the original design and currentmaximum heat input capacity (million British thermal units per hour ); h. the original design and currentmaximum steam flow output capacity (pounds of steam per hour); i. the original design and currentmaximum exhaust gas output (actual cubic feetper minute, standard cubic feetper minute and dry standard cubic feetper minute); j. the current operating status of each unit and the applicable date or year for any retired or inactiveunit; k. scheduled or planned boiler retirement dates; 1. current fuel(s)being fired; m. type of particulate emissions control and year installed; n. type of sulfur dioxide emissions control and year installed; and o. any anticipated emission controls and estimated dates of installation.
For each currently active oil or coal-fired generatingunit identified, provide the following on a monthly and annual basis. If the unit is capable of firing multiple fuels, provide the information requested by questions c. 

### -f. for each type of fuel used. To the extent available, please provide in computer readable format, such as a Microsoft Excel spreadsheet or other generally accessible computer readable format: a. total gross and net generation (Megawatt-hours); b. averageheat 

### rate (British thermal units per hour or kilowattsper hour); c. fuel usage (i.e., tons, gallons, etc.); d. averageheat content (i.e., British Thermal units per pound, British thermal units per gallon, etc.); e. averagefuel sulfur content; f. average fuel percent ash; g. total hours under load; and h. the peak hourly generation (Megawatts gross) actually achieved during each month.Provide all raw (instantaneous) data collected fiom January 2002 to present fiom continuous emissions monitoring devices for each identified oil or coal-fired unit, including, but not limited to, opacity, sulfur dioxide, carbon dioxide, and oxygen monitoring data. Please provide all data associated with this request in computer readable format, such as a Microsoft Access database or other generally accessible computer readable format. Provide all calculated averages of emissions data collected January 2002 to present fiom continuous emissions monitoring devices for each identified oil or coal-fired unit, including,but not limited to, averages of opacity, sulfur dioxide (SO2),carbon dioxide, and oxygen emissions data calculated for the purposes of demonstrating compliance with an emission standard andfor reporting. Provide copies ofthe summaryresults of all stack tests (including those tests that 

### were completed with three or more runs and those tests that were incomplete) for particulate matter (including PM, PMloand PM2.5),S@, and sulfuric acid mist (S03M2S04) for all identified oil or coal-fired generatingunits. Provide copies of all prevention of significant deterioration (PSD) and nonattainmentnew source review (NNSR) permits received and permit applications submitted sinceJanuary 2002. Provide copies of all documents, including, but not limited to, reports, correspondence, memoranda, and phone discussion summaries related to best available retrofit technology (BART), reasonable progress (RP), PSD, NNSR, and New Source Performance Standards for any projects assessed for the identified units. Provide copies of all reported generating capability and oil and coal usage and quality for each identified unit, reported to any federal (e.g., United States Department of Energy), state, or local governmentalbody. Provide copies of all studies, evaluations, assessments, and reports related to evaluatingBART or RP, including electronic copies of all air modeling files. Provide copies of all documents, for any ofthe identified generating units that contain any of the following information related to available control technologies: cost and cost effectiveness, energy or other non-air qualityimpacts, and modeled visibility impacts. These control technologies include new control equipment, upgrades to existing controls, changes in fuel sulfur content, or other emission control strategies for particulate matter (includingPM, PMloand PM2.5), S@, and SOdH2So4. Provide all engineering analyses, studies,reports, and other documents related to the considerationof andlorplanned installation of air pollution controls, includingbut not limited to, projected installationtimeframes, capital expenditures, operation and maintenance cost estimates, cost-effectiveness analyses, expected removal efficiencies, and outlet emission rates.
Provide all documents that discuss the application of current and potential future regulatory requirements that may apply to each identified unit, includingbut not limited to, BART, Clean Air Mercury Rule, Clean Air Interstate Rule, Cross State Air Pollution Rule, and StateImplementationPlan and how the company plans to comply with such requirements, including but not limited to, projected emission control installations and expected dates for the installation of control equipment for each unit.
13. Provide currentprojected retirement dates for all units. Provide copies of all documents discussingplanned, proposed, or projected retirement dates for all units.
14. Provide the information specified in EnclosureD which is needed for the EPA to conduct a modeling analysis to evaluate visibility impacts.
15. Provide the name and address ofthe person who should receive official correspondenceon behalf of the company concerningthis matter.Enclosure B Use the following instructions and definitionswhen providing the informationrequested in EnclosureA. INSTRUCTIONS Provide a separate response to each question and subpart of each question set forth in Enclosure A.
Precede each answer with the number ofthe question to which it corresponds and at the end of each answer identifythe person(s) that provided informationthat was used or considered in responding to that question, as well as each person that was consulted in the preparation ofthat response. Indicate on each documentproduced in response to each question, or in some other reasonable manner, the number of the questionto which it corresponds.
When a response is provided in the form of a number, specify the units ofmeasure of the number in a precise manner. Where documents or informationnecessary for a response are neither in your possession nor availableto you, indicate in your response why such documents or informationis not available or in your possession and identify any source that either possesses or is likely to possess such information. Whenever possible, provide narratives responses or scanned documentsin electronic, word searchable (PDF) format and all data associated with this request in computer readable format, such as a Microsoft Access database or other generally accessible computer readable format.

DEFINITIONS
All terms used in this informationrequest have their ordinary meaning unless such terms are defined in the CAA, 42 U.S.C. &j 7401 

## a.seq.,40 C.F.R. Part 52 (which incorporates the Federally-approved State ImplementationPlan), or other CAA implementing regulations. You should apply the applicable Federally-approved state provisions when appropriate. Definitional clarificationis specified below.
1. The term "capital expenditure," means a monetary expenditureon depreciableequipment, including any costs to design, engineer, transport, and install said equipment.
2. The terms "document" and "documents" shall mean any object that records, stores, or presents information, and includes writings, memoranda, records, or informationof any kind, formal or informal, whether wholly or partially handwritten or typed, whether in computer format, memory, or storage device, or in hardcopy, including any form or format ofthese. If in computer format or memory, each such document shall be provided in translation to a form useable and readableby the EPA, with all necessary documentation and support. All documents in hard copy should also include attachmentsto or enclosures with any document.3. The term "present" shall mean the date this request was received.


### 4. The terms "relate to" (or any form thereof) shall mean constituting, reflecting, representing, supporting, contradicting, referring to, stating, describing, recording, noting, embodying, containing, mentioning, studying, analyzing, discussing, evaluating or relevant to.
5. The term "currently active," as it applies to an oil or coal-fired generating unit, shall mean any unit that has been permanently retired and reported as such to the 

### US. Department of Energy.
6. 'You" and "Your" means GulfPower Company, includingbut not limited to its predecessors, successors, subsidiaries, parent companies, affiliates, 

### d/b/a, divisions, branches, distributors, offices, franchises, facilities, committees, trusts, partnerships, andjoint ventures in which it has any interest; all entities for which it is acting as an agent or contractor; and its past or present officers, directors, trustees, managers, employees, agents, consultants, contractors, attorneys, representatives, and any other persons acting on its behalf.Enclosure C Outline of Guidelines for Best Available Retrofit Technology (BART) Determinationsunder the Regional Haze Rule
1. Identify all available retrofit control technologies and options. a. Develop a comprehensive list of all commercially-available retrofit technologies including technology transfer of controlsthat have been applied to similar sources and gas streams. b. Consider control options that provide improvements to existing controls rather than limitingthe control options only to those measures that involve a completereplacement of control devices. 2. Eliminate technically-infeasible control technologies considering that a. A technically-infeasible control is one that is not commercially available, or b. A technology may or may not be applicableto a particular emissionunit.
3. Evaluate the emission performance (control effectiveness) for each technically-feasible control technology for SulfurDioxide (SOz)and Particulate Matter. a. Analysis should include evaluationofupgrading any existing controls.
4. Conduct an Impact Analysis identifying and discussing: a. The cost of compliance with control options including: i. Estimated capital and annual costs, and



### . . 11. Average and incremental cost effectiveness (for detailed explanation on costs, see EPA Air Pollution Control Cost Manual at 

### http://www.epa.gov/ttn/catc/dirl/c-allchs.pdf) b. The remaining useful life of the facility c. Energy Impacts d. Non-air quality environmental impacts, including the identification and quantification ofthe solid, liquid, and gaseous dischargesfiom the control device or devices under review.
5. Evaluate visibility improvements. a. Prepare and submit a source-specific modeling protocol for review and approval prior to performing visibility impact modeling. The Visibility Improvement State and Tribal Association of the Southeast (VISTAS) BART Modeling protocol1provides guidance on the procedures that should be used. The site-specific protocol should explain the data sources, model configuration, and rationale for any changes fiom the VISTAS BART modeling protocol. The following changes fiom the VISTAS BART Modeling Protocol should be made. i. The current regulatory version ofthe CALPUFF~ modeling system as specified
on EPA's SCRAM website3 shouldbe used. 

## 'http://www.vistas-sesarm.org/BARTMSTASBARTModelingProtocol~Da222005.pdf

Note that EPA's reference to CAI;PUFF encompasses the entire CALPUFF modeling system, which includes the CALMET, CALPUFF, and CALPOST models and other pre and post processors. The diierent versions of CALPUFF have corresponding versions of CALMET, CALPOST, etc. which may not be compatible with previous versions (e.g., the output f?om a newer version of CALMET may not be compatible with an older version of CALPUFF). The different versions of the 1ii. The Federal Land Manager-derived meteorological input data set for 2001-2003 available fiom Florida shouldbe used, 

### in lieu ofthe original VISTAS dataset. iii. The maximum actual 24-hour average emissionrates for SO2,sulfuric acid and 

### PMloshouldbe derived 

### from the most recent three years (2009-201 1) of operation for each unit. Use the CALPUFF model, accordingto the approved modeling protocol to determine the visibility impairment in each Class I area within 300 kilometer of your facility for all visibility-impairing pollutants emittedby your facility based on current emission rates. 

### Run CALPUFF with post-control emission rates for each technically-feasible control technology. Determine the net visibility improvement 

### in the impacted Class I areas for each technically feasible control technology.
6. Develop BART Recommendation. a. Identify BART for each electrical generating units by evaluatingthe control effectiveness, cost, remaining useful life ofthe unit, energy impacts, non-air quality environmental impacts, and visibility improvements for each technically-feasible control technology. b. Prepare 

### an explanation ofhow these factorswere considered (or weighted) in recommendingBART. c. Determine the recommended emission limits and associated monitoringreporting and recordkeeping requirements for each BART-eligible unit at your facilityfor SO2and particulate matter.

CALPUFF modeling system are availablefrom the model developeron the following Web site: httv://www.src.com/verio/download/download. htm.Enclosure D Summaryof Visibility Impact Modeling Information
For all emissions 

### units subjectto either best available retrofit technology or reasonableprogress, provide the following information (all units are metric):
1. Location ofthe source emissions units (universal transverse mercator (UTM) Coordinates) a. The source coordinates must be expressed

### in the coordinate systemused to define the CALMET and CALPUFF modeling domains.' For the regional screening simulations, a Larnbert Conformal Conic (LCC) coordinate system will be used. The required parameters to define an LCC coordinate include two matching parallels, 1atitudeAongitudeofthe projection origin, coordinatedatum, and false Easting and Northing (ifused) ofthe projection origin.
2. Source locationmap(s) showing location with respect to: a. Urban areas b. Topographic features (terrain, lakes, river valleys, etc.) c. National Weather Service meteorological observations (surface and upper air) d. On-siteAoca1meteorological observations (surface and upper air) e. StateAocaVon-site air quality monitoring locations f. Plant layout on a topographic map covering a 1kilometer (km) radius of the source with information sufficientto determine Good Engineering Practice (GEP) stack heights
3. Information on urbdrural characteristics: Land use within 3 km of source classified accordingto Auer (1978): Correlation of land use and cover with meteorological anomalies.J Appl. Meteor., 17: 636-643. Population i. total ii. density Based on current guidance determinationofwhether the area should be addressed using urban or rural modeling methodology
4. Emission inventory and operatingldesignparameters: a. Maximum actual 24-hr average emission rates in grams per second (gls)(sulfurdioxide, sulfuric acid, and PMlo). b. Maximum design load short-term emission rate (gls) c. Associated emissionslstackcharacteristicsas a function of load for maximum, average, and nominal operating conditions if stackheight is less than GEP or located in complex terrain. i. height of stack meters (m) and grade level above mean sea level

Note that EPAYs referenceto CALPUFF encompassesthe entire CALPUFF modeling system, which includes the CALMET, CUUFF,and CALPOST models and otherpre and post processors. The differentversions of CALPUFF have corresponding versions of CALMET, CALPOST, etc. which may not be compatible with previous versions (e.g.,the output &oma newer version ofCALMET may not be compatible with an older version of CALPUFF). The different versions ofthe CALPUFF modeling systemare available fiomthe model developeron the followingWeb site: http://www.src.com/verio/download/download.htm.ii. stack exit diameter (m) iii. stack exit velocity (meters per second) iv. stack exit temperature (OKelvin) d. Additional building dimension information (building width, length, height and corner locations) is needed for short stacks that are less than GEP height. This informationis used in providing effective structure dimensions for building downwash calculations.The requirement to conduct building downwash modeling may be waived if the transport distance is greater than 50 

### km. e. Associated parameters i. boiler size (megawatts, poundshr. steam, fuel consumption, etc.) ii. boiler parameters (percent excess air,boiler type, type of firing, etc.) iii. operatingconditions (pollutant content in fuel, hours of operation, capacity factor, percent load for winter, summer, etc. iv. pollutant control equipment parameters (design efficiency, operation record, e.g., can it be bypassed?, etc.)
f. Anticipated growth changes

### Enclosure 

### E

CONFIDENTIAL BUSI[NESS INFORMATION (CBI) ASSERTION AND SUBSTANTIATION REQUIREMENTS
You may assert a business confidentiality claim covering all or part of the informationyou provide in response to this informationrequest for any business information entitled to confidential treatment under section 114(c)ofthe Clean Air Act (theAct), 42 U.S.C. $7414, and 40 CFR Part 2, subpartB. Under Section 114(c)of the Act, you are entitledto confidentialtreatment of informationthat would divulge methods or processes entitled to protection 

### as trade secrets. Under 40 CFR Part 2, subpart B, business confidentiality means the concept of trade secrecy and otherrelated legal concepts which give (or may give) a business the right to preserve the confidentialityofbusiness information and to limit its use or disclosureby others in order that the business may obtain or retain business advantagesit derives fiom its rights in the information.

### See 40 CFR $2.201(e).
The criteria the EPA will use in determining whether material you claim as business confidential is entitled to confidential treatment are set forth at 40 CFR 52.208 and 2.301. Theseregulationsprovide, amongother things, that you must satisfactorilyshow that: (1) the informationis within the scopeof business confidentialityas defined at 40 CFR §2.201(e), (2) that you have taken reasonable measures to protect the confidentialityofthe information and that you intend to continueto do so, (3) the informationis not and has not been reasonably obtainableby legitimate means without your consent, and (4) the disclosure of the information is likely to cause substantial

### harm to your business' competitive edge. 

### See 40 CFR 52.208 (a)-(d). Emission data, as defined at 40 CFR $2.301(a)(2), is expressly not entitled to confidentialtreatment under 40 CFR Part 2, subpartB. 

### See 42 U.S.C. 57414(c); 40 CFR 

## 5 2.301(e).
Informationcovered by a claim ofbusiness confidentialitywill be disclosedby the EPA onlyto the extent, and by means ofthe procedures, set forth in Section 114(c) ofthe Act and 40 CFR Part 2, subpart B. The EPA will construe your failure to furnish a business confidentialityclaim with your response to this informationrequest as a waiver of that claim, and the information may be made availableto the public without furthernotice to you. To assert a business confidentialityclaim, you must place on (or attach to) all informationyou desireto assert as business confidential either a cover sheet, stamped or typed legend, or other suitable form of notice employing language such 

### as trade secret, proprietary, or company confidential at the time you submit your response to this information request. Allegedly confidential portions of otherwisenonconfidential documents should be clearly identified, and may be submitted separatelyto facilitate identification and handling by the EPA. You should indicate if you desire confidentialtreatment only until a certain date or until the occurrence of a certain event. 

### In addition, the EPA is providing you notice that if you assert a claim ofbusiness confidentiality for informationyou provide in response to this informationrequest, the EPA will determine whether such information is entitled to confidential treatment, pursuant to 40 CFR Part 2, subpart B. Accordingly, after the EPA's receipt of your business confidentialityclaim, you will receive a letter inviting your comments on the following questions:1. What specific portions of the information are alleged to be entitled to confidential treatment? Specifyby page, paragraph, and sentence when identifyrngthe information subject to your claim.
2. For what period oftime do you request that the informationbe maintained as confidential,

### e.p;.,until a certain date, until the occurrence of a specified event, or permanently? If the occurrence of a specific event will eliminate the need for confidentiality, specifythat event. Additionally, explain why the information shouldbe protected for the time period you've specified.
3. What measures have you taken to protect the information claimed 

### as confidential fkom undesired disclosure? Have you disclosed the information to anyone other than a governmental body or someonewho isbound by an agreement not to disclose the information Mer?If so, why should the information stillbe considered confidential?
4. Is the information contained in any publicly available material such as the Internet, publicly availabledatabases,promotional publications, annual reports, or articles? Is there any means by which a member ofthe public could obtain access to the information? Is the information of a kind that you would customarily not release to the public?
5. Has any governmental body made a determination as to the confidentialityof the information? If so, please attach a copy of the determination.
6. For each category of information claimed as confidential, explain with specificity whether disclosure of the informationis likely to result in substantialharm to your competitive position. Explain the specific nature ofthose harmful effects, why they shouldbe viewed as substantial, and the causal relationship between disclosureand such harmful effects. How could your competitors make use of this information to your detriment?
7. Is there any other explanation you deem relevant to the EPA's determinationof your business confidentiality claim that is not covered in the preceding questions? If so, you may provide such additional explanation.
See 40 CFR §2.204(e)(4). When you receive such a letter, you must provide the EPA with a written response within the number of days set forth in the letter. The EPA will construeyour failure to Msh timely comments 

### as a waiver of your confidentiality claim, consistent with 40 CFR 52.204(e)(l).