From: "Alicea, Jezebele" <Alicea.Jezebele@epa.gov>

To: Ling Paul <Paul.Ling@kcpl.com>

CC: "Covington, James" <Covington.James@epa.gov>, "Jordan, Ronald" <Jordan.Ronald@epa.gov>

Date: 7/24/2013 11:45 AM

Subject: RE: Urgent: Request for Release of Information From Docket No. EPA-HQ-OW-2009-0819

Greetings Mr. Ling!

EPA received your request for "all information related to Kansas City Power & Light Company facilities outlined below, including information 

that EPA has derived from information obtained from these facilities and from all other sources, and including facility-specific or facility-derived 

information in input files to" certain documents found on the docket for the Steam Electric ELG rulemaking.

· Kansas City Power & Light Company - Hawthorn Generating Station, Iatan Generating Station, Montrose Generating Station, La 

Cygne Generating Station

· Greater Missouri Operations Company - Lake Road Generating Station, Sibley Generating Station

EPA has made available substantial data and other information relating to the proposed rule in the docket for the steam electric power generating 

effluent guidelines rulemaking, including data relating to the specific facility(ies) you identified, data about other plants where that data is not 

claimed as confidential business information or could lead to the disclosure of confidential business information, equations used to estimate 

several key outputs such as costs, and a description of the various methodologies used by EPA (e.g., costing methodologies, pollutant loadings 

methodologies, etc.). In addition to this publicly available data, in response to your request, EPA is planning to forward under separate 

correspondence additional data that provides plant-specific compliance costs and pollutant removals that EPA estimated would be attributable to 

the proposed rule, as well as plant-specific input values that were used in EPA's cost models, pollutant loadings/removal models, and 

environmental assessment models. EPA is planning to provide a description of how each plant can use available data to make relevant 

calculations, such as how to calculate pollutant loadings. EPA believes these data, in addition to the publicly available data already provided in 

the docket, provide you with sufficient information to understand any effects the proposed rule may have on your facilities and to comment 

effectively on the proposed rule, and this data represents the extent of information that EPA can make available to you without disclosing, 

directly or indirectly, information claimed as confidential business information by other sources.

To ensure that confidential business information is only released to an authorized official, EPA requires that you submit your request on company 

letterhead using the certification statement below. The certifying official must be a responsible corporate official or his/her authorized 

representative.

Certification Statement

"I certify under penalty of law that I am a responsible corporate official or his/her authorized representative of [fill in name of corporate entity] 

and am authorized to request confidential business information on behalf of my company. I certify that [fill in name of corporate entity] is the 

majority owner or the operator for each facility (and for each unit at each facility) for which we are requesting confidential business information. 

I am aware that there may be significant penalties for submitting false information including the possibility of fines and imprisonment, pursuant

to 18 U.S.C. § 1001. "

In addition, you must provide the name (if not the certifying official) and mailing address (no P.O. boxes) for receipt of the requested 

information. Mailing addresses must be accessible to a commercial courier service (e.g., Federal Express).

Have a blessed day!

Sincerely,

[MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]]

Jezebele Alicea-Virella

Environmental Engineer

Phone No: 202-566-1755

Fax No: 202-566-1053

EPA-Office of Water/OST/EAD

Mail Code: 4303T

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

[MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]]

From: Ling Paul [mailto:Paul.Ling@kcpl.com]

Sent: Wednesday, July 10, 2013 5:56 PM

To: Alicea, Jezebele; Covington, James

Subject: Urgent: Request for Release of Information From Docket No. EPA-HQ-OW-2009-0819

VIA ELECTRONIC MAIL

Ms. Jezebele Alicea-Virella

USEPA Headquarters

Mr. James Covington

USEPA Headquarters
Urgent: Request for Release of Information

From Docket No. EPA-HQ-OW-2009-0819

***PROMPT RESPONSE REQUESTED***

Dear Ms. Alicea-Virella and Mr. Covington:

Our facilities provided information that is being used to inform EPA's development of the proposed revision of the effluent limitations guidelines 

and standards for the steam electric power generating point source (ELG Rule). The facilities listed below either responded to earlier ELG Rule 

questionnaires to the industry or provided information to you through other means, such as site visits or separate information requests. The 

specific facilities in question are as follows:

Kansas City Power & Light Company:

· Hawthorn Generating Station - NPDES Permit No. MO - 0004855

· Iatan Generating Station - NPDES Permit No. MO - 0082996

· Montrose Generating Station - NPDES Permit No. MO - 0101117

· La Cygne Generating Station - NPDES Permit No. KS - 0080071

Greater Missouri Operations Company:

· Lake Road Generating Station - NPDES Permit No. MO - 0004898

· Sibley Generating Station - NPDES Permit No. MO - 0004871

We have identified certain record documents which we believe contain information reported by, or derived from data or information reported by, 

one or more of our facilities. EPA has redacted all or portions of these documents as "confidential business information" (CBI).

We are requesting that you provide to us all information related to the facilities listed above (including information that EPA has derived from 

information obtained from our facilities and from all other sources, and including facility-specific or facility-derived information in input files to 

the listed documents) contained within the following documents:

EPA-HQ-OW-2009-0819 Doc. ID No. (DCN No.)

Short Description

1959 (DCN SE01825A53)

FGD Input Table Current Systems

1959 (DCN SE01825A54)

FGD Input Table Planned Systems

1959 (DCN SE01825A55)

FGD High Flow Analysis

1959 (DCN SE01825A73)

Bottom Ash MDS Conveyance O&M Costs

1959 (DCN SE01825A74)

Bottom Ash Intermediate Storage O&M Costs

1959 (DCN SE01825A75)

Bottom Ash Wet Sluicing O&M Costs

1959 (DCN SE01825A76)

Bottom Ash Remote MDS Capital Costs

1959 (DCN SE01825A77)

Bottom Ash Wet Sluicing O&M Costs

1959 (DCN SE01825A78)

Bottom Ash Remote MDS Capital Costs
1977 (SE02900)

CBI Steam Electric Pollutant Loading Model for FGD Wastewater

1984 (SE02899)

CBI Steam Electric Pollutant Loadings Model for Ash Transport Water

1986 (SE01756)

CBI Future Profile FGD Loads

2104 (SE02897)

CBI Steam Electric Cost Model (FGD and Ash Transport Water)

2105 (SE02898)

CBI Steam Electric Cost Model (FGD and Leachate)

2121 (SE03804)

CBI Data Dictionary for the FGD and Ash Cost Model

2157 (SE02988)

CBI Loads Calculation Database for Options 1, 2, 3, 4, and 5

2159 (SE03508)

CBI Loads Calculation Database Future Profile - IPM Only

2191 (SE03879)

CBI Bottom Ash Management Determination Calculations

2195 (SE03507)

Loads Calculation Database - Questionnaire and IPM

2197 (SE03552)

CBI EA Report Calculations Database

2201 (SE03895)

CBI Loads Calculation Database for Options 3a, 3b and 4a

2210 (SE02129)

CBI Memorandum to the Steam Electric Rulemaking Record: New Source Performance Standards Costing Memorandum and Attachment

2252, 2252.1 (SE01957, SE1957A1)

CBI Incremental Costs and Pollutant Removals for Proposed ELGs Report and Attachment

2256 (SE01957)

CBI Incremental Costs and Pollutant Removals

Please include all information from these documents that relates to our facilities. For example, our facilities supplied information about existing 

control technologies. Through this request, we are requesting not only the control technologies information supplied by our facilities, but also 

control technologies information about our facilities derived from other sources, as well as all EPA-developed information relating to our control 

technologies, including EPA's assessments of future technology choices for our facilities based on the various rule options.

For each document, as appropriate, please also include: (1) a legend which explains each column heading and each abbreviation used throughout 

the entire document; and (2) a list of all formulas applied in the document and a legend for any abbreviations used in the formulas. The legend 

and formula information is key to understanding these documents.

We make this request without waiving any of our CBI designations. Because you are providing the information only to us, there is no breach of 
confidentiality and no waiver of CBI protections. Furthermore, we are not requesting CBI information, or CBI-derived information, from other 

companies that may have furnished data or information appearing in the listed documents. We are requesting only information related to our 

own facilities.

We have done our best to be selective in asking for facility-specific information. The information we are seeking, however, is critical to our 

review of, and preparation of comments on, the proposed ELG Rule. Because of the brief comment period, we ask that you expedite this 

request.

If you have any questions about this request, please call or email me. I look forward to your prompt response. Thank you very much for your 

help.

Sincerely,

Paul M. Ling - PE (KS & MO)

Director of Compliance

Kansas City Power & Light Company

PO Box 418679

Kansas City, MO 64141-9679

E-mail: paul.ling@kcpl.com<mailto:paul.ling@kcpl.com>

Telephone No.: 816-556-2899

Cell Phone No.: 816-810-2326

Fax No.: 816-556-2058