November 14 , 201 2 Abt Associates | Economic and Financial Data Sanitation Plan | pg 1

Date November 14 , 201 2

To James Covington ( EPA/OST/EAD )

From Isabelle Morin and Rob Chew
Subject Economic and Financial Data Sanitation Plan: Steam Electric Effluent Guidelines

Rulemaking

This memo randum describes the proposed methodology for removing Confidential Business Information (CBI) data from Part I (Economic and Financial Data) of the Q uestionnaire for the Steam Electric Power Generating Effluent Guidelines . The objective of this process is to provide a version of the questionnaire

response s that is informative and useful for public comment without releasing proprietary information

. This memorandu m details Abt Associates‟ approach to sanitizing the data, pending the approval of EPA‟s Engineering and Analysis Division (EAD).

Abt Associates will produce a sanitized version of the Part I Q uestionnaire responses in the form of an MS AccessTM database [ Steam Electric Economic/Financial Questionnaire Database ]. This database will be based on the final version of the record used for the Regulatory Impact Analysis for Proposed Effluent
Limitations Guidelines and Standards for the Steam Electric Power Gener ating Point Source Category.
This version will have CBI and CBI

- deducible 1 responses re dacted and will be included in the public
docket.

Abt Associates will develop the public version of the Steam Electric Economic/Financial Questionnaire
Database using the following steps:

Removing data with CBI claims
 Convert survey responses to a text format. This allows responses of all data types ( Number, „Yes/No‟, and Text ) to be processed consistently

.  Develop, execute, and verify update queries to replace CBI data elements with the word “CBI”. This replacement step applies to every part of a multipart question that was tagged as CBI by the survey respondent

.
Removing CBI

- deducibl

e data
 To prevent the discovery of CBI data through financial statement anal ysis, we will i dentify survey responses in which the balance sheet, income statement, or cash flow statement of the Immediate
Parent firm is CBI.

o I n cases where CBI wa s claimed for at least one financial statement component, we will perform an update query to replace all financial statement data elements with the word
“CBI”. This replacement step applies to every part of a multipart question that is tagged as
CBI.

1 CBI

- deducible data is information that can be combined with non

- CBI data to determine (or back calculate) CBI information. 

# Memorandum
Environment and ResourcesNovember 14 , 201 2 Abt Associates | Economic and Financial Data Sanitation Plan | pg 2

 In cases where a parent firm claims ownership of multiple steam electr ic facilities, we will ensure that parent firm CBI designations are consistent across survey responses. This will prevent parent firm data from being designated as CBI in one survey response and n ot in other s

.

- For example, suppose the company “ Big Firm ” o wns two facilities, both of which respond ed to the Steam Electric Questionnaire. At one facility, the survey respondent marks “ Big Firm‟s ” Total R evenue as CBI whereas at the other facility, “Big Firm‟s ” Total Revenue is deemed to be non

- confidential . To be conservative in our disclosure of economic and financial data, we would treat “Big Firm‟s” Total Revenue as CBI in both cases.

- We will develop , execute , and verify queries to identify where parent firm data is inconsistent across survey responses and replace inconsistent data elements with the word “CBI”. This replacement step applies to every part of a multipart question that is tagged as CBI.

- This procedure will be performed for both Immediate Parent a nd Ultimate Parent firm information.

 Occasionally , the ultimate parent firm is the same as the immediate parent firm. In these situations

,

we will identify cases where the respondent designate d CBI differently in the ultimate parent firm and immediate par ent firm sections.

- We will develop, execute, and verify update queries to replace ultimate or immediate parent data elements that differ between sections with the word “CBI”. This replacement step applies to every part of a multipart question that is tagg ed as CBI.

 To ensure the robustness of the survey responses, redundancies were built int o Part I of the Questionnaire for certain key fields with related data elements (e.g., total revenue, revenue from electricity generation)

. If in the survey entry in a key field is designated as CBI, we will maintain the CBI designation for each instance in which the key value is reported.

- We will develop, execute, and verify update queries to replace key value data elements that are CBI with the word “CBI”.

- All key fields relate to the Primary Immediate Parent firm . They include :

 “Total Revenue („000$)”

 “Total Electricity Uses/Sources (MWh)”

 “Revenue from Electricity Generation („000$)”
 For some survey responses that ask for numerical values, estimates of the values can be calculated from other information in the survey. In these cases where the numerical value is CBI and the value can be deduced from other information, we will redact the data that is necessary for the calculation.

- We will develop, exec ute, and verify update queries to replace data elements that are necessary for the calculation of CBI with the word “CBI”.

- The numerical values that could be deduced are:

 “Number of Days in Operation” for a Steam Electric Generating Unit , could be
deduced from the following data fields:

 “Total Duration of Planned/Scheduled Routine Maintenance Outages (hours/year)”November 14 , 201 2 Abt Associates | Economic and Financial Data Sanitation Plan | pg 3  “Total Duration of Outages Planned/Scheduled to Address Major Upgrades (hours/year)”

 “Duration of Forced/Unscheduled Outages for this Unit (hour s/year)”

 “Fuel Costs ($)” for a Steam Electric Generating Unit , could be deduced from the following data fields:

 “Quantity of Fuel Burned (Units)”

 “Average Cost of Fuel Per Unit of Fuel Burned ($/unit)”