VIA ELECTRONIC MAIL: RETURN RECEIPT REQUESTED, to 

jordan.ronald@epa.gov and covington.james@epa.gov 

Mr. Ronald Jordan 

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 Mr. Jordan 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: 

Operating Company and Facility Name Facility NPDES Number 

Alabama Power Company 

Barry 

Gadsden 

E C Gaston 

Gorgas 

Greene County 

James H Miller Jr 

Georgia Power Company 

Bowen 

Harlee Branch 

Hammond 

Edwin I Hatch 

AL0002879 

AL0002887 

AL0003140 

AL0002909 

AL0002917 

AL0027146 

GA0001449 

GA0026051 

GA0001457 

GA0004120 
2 

Kraft 

Jack McDonough 

McIntosh 

McManus 

Mitchell 

Scherer 

Vogtle 

Wansley 

Yates 

Gulf Power Company 

Crist 

Scholz 

Lansing Smith 

Mississippi Power Company 

Victor J Daniel Jr 

Jack Watson 

Southern Power Company 

Curtis H Stanton Energy Center 

Rowan 

GA0003816 

GA0001431 

GA0003883 

GA0003794 

GA0001465 

GA0035564 

GA0026786 

GA0026778 

GA0001473 

FL0002275 

FL0002283 

FL0002267 

MS0024511 

MS0002925 

N/A 

NCG500582 

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: 
3 

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 
4 

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 there are less than 45 days left in the 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, 

Donna B. Hill 

Donna B. Hill 

Program Manager 

Southern Company Services, Inc. 

600 North 18th Street / Bin 14N-8195 

Birmingham, AL 35203 

205-257-5234 office 

205-587-4846 cell 

dbhill@southernco.com

Cc: Chris M. Hobson cmhobson@southernco.com 

 Ms. Jezebele Alicea-Virella alicea.jezebele@epa.gov