To: Maryt Smith/DC/USEPA/US@EPA

From: "Laity, James A." <James_A._Laity@omb.eop.gov>

Date: 05/07/2010 07:21PM

cc: Ronald Jordan/DC/USEPA/US@EPA

Subject: Comments on Steam Electric ICR

Summary of agreed upon changes:

All “look back” provisions for capital costs and treatment upgrades will be since Jan 1, 

2000.

OK - ALREADY BEING IMPLEMENTED. NOTE THAT BID PROPOSALS WILL 

STILL GO BACK TO 1995.

All facilities will have 90 days to complete survey, except that must do section G, which 

will have 120 days for Sec G and 90 days for everything else. Facilities will still have 

option to request extensions as per current instructions.

OK - WILL MAKE CHANGE IN INSTRUCTIONS.

After looking again at the certifications statement, I think it is OK.

OK - NO CHANGES NEEDED.

Addtl Comments (I only reviewed general instructions and parts A and I in detail, you get 

a “pass” on the others):

p i, 2nd para, drop ref to criminal fines.

OK - WILL MAKE CHANGE.

P ii, Electronic Version..., 3rd para, why do they have to submit hard copy and disk.

Suggest allowing disk only.

OK - WILL CHANGE TO SAY SEND DISK ONLY (SHOULD WE STILL 

ACKNOWLEDGE THEY ARE ALLOWED TO SEND IN A HARD COPY IF THEY 

WOULD LIKE?)

P iv, 1st para under bullets, “...in table of contents for each part, after which all header 

fields...”
OK - WILL MAKE EDIT.

P v, Can you provide a toll-free number? Can you provide a phone number for Jezebele 

so they can call to discuss potential extension requests (I understand that this does not 

substitute for a written request, and you can make that point in instructions, or she can if 

they call).

ASSUMING EAD IS OK WITH THIS, ERG WILL ARRANGE FOR A TOLL-FREE 

NUMBER AS WELL AS A LOCAL NUMBER (ALREADY HAVE INFO FROM 

ABT). WILL MAKE OTHER EDITS AS DISCUSSED VIA EMAIL WITH EAD AND 

ABT. SHALL WE ALSO INCLUDE JEZE'S OFFICE NUMBER?

P vi, 2nd para, you should NOT provide CBI box for any question not allowed to be 

claimed CBI. Make sure this is the case and drop this confusing reference in the 

instructions.

WE WILL NEED TO DISCUSS WHICH QUESTIONS WE FEEL CANNOT BE 

MARKED AS CBI. WILL THIS NEED TO GO THROUGH OMB AGAIN? WE'LL 

NEED TO CHECK BUT I'M NOT SURE THERE IS ANY PLACE WHERE FINAL 

EFFLUENT DATA IS REQUESTED IN THE STEAM ICR (EVEN THE EFFLUENT 

FROM THE FGD TREATMENT SYSTEM MAY NOT BE FINAL EFFLUENT) -

HOWEVER, THAT LANGUAGE HAS BEEN STANDARD IN ICRS FOR AS LONG 

AS I CAN REMEMBER. SO, LET US KNOW HOW YOU WANT THIS 

ADDRESSED.

P vi, 3rd para, “If you claim any questionnaire response or other data as CBI, other than 

by checking the box, you must specify... “ (checking the box is all that’s required, this 

para is for people who choose to claim CBI with a cover letter or some other format)

WE CAN MAKE EDIT TO ADD "OTHER THAN BY CHECKING THE BOX".

ALTHOUGH THIS LANGUAGE WAS TO ADDRESS THAT ONLY SOME OF THE 

DATA IN A QUESTION MAY BE CONSIDERED CBI.

General Questions (this was asked of me by my mgt and I didn’t know the answer): Do 

compliance/enforcement authorities at the agency have access to these questionnaire 

responses? Does it matter if it’s claimed CBI?

EPA ITEM

P A-4, Q A1-6, I assume you mean that if the answer is YES, they should stop, not if the 

answer if NO.

ALREADY IDENTIFIED/CHANGED

P A-6, Q A1-12, you ask for steam and other forms of heat, but then you ask for 

percentage breakdown of steam (underlined). Do you mean steam only, not other forms 
of heat? If so, what is the point of mentioning other forms of hear above and how would 

they even indicate this in the question? Clarify.

WE WANT THE PERCENT OF STEAM ONLY, BUT WANTED THEM TO 

INDICATE HOW OTHER FORMS OF HEAT MAY BE USED. I DON'T KNOW 

THAT WE REALLY NEED THAT DESIGNATION SO I WOULD BE FINE TO 

REWORD THE QUESTION AS STEAM ONLY.

P A-10, Q A2-5, why do you need gpd, gpy, and dpy? Any two of these determines the 

other. How about just gpd and dpy? For the other column, you do need all three 

numbers.

HOW ABOUT WE RETERM THE FIRST COLUMN AS GPD OR GPY (AND DPY)?

WE WERE TRYING TO GIVE THEM AN OPTION OF ANNUAL VS DAILY. WE 

DEFINITELY WANT DPY IN EITHER CASE.

P A-22, Q A5-2, is this map just to show the footprint of the property, or the buildings 

and other features of the plant within this footprint? Clarify.

NOT SURE WHAT COMMENT IS LOOKING FOR - MORE WORDING IN THE 

ACTUAL QUESTION, OR ASKING EPA WHY THIS INFORMATION IS NEEDED?

P A-28, Q A6-2, I assume you mean this to include units that COMMENCED operating 

after Jan 1,2010, and not to have them relist plants already included in Q A6-1. If you do 

mean to list the same unit twice, why? Most of the info in the two tables is the same.

YES, THE WORDING IN THE TABLE TITLE IS CORRECT (FIRST OPERATED 

AFTER JAN 1 2010), AND WE CAN ADD THAT TO THE QUESTION 

INSTRUCTIONS. OR REWORD BOTH AS "COMMENDED OPERATING."

P A-31, Q A8-1, you ask for BTUs generated, but there is no space to provide this info, 

only the amt of fuel burned. (I see that you have total BTUs generated in the lower right 

corner, do you meant that fossil/nuclear is one “general fuel type” and you don’t expect 

further breakdown. If so, clarify in wording of question above.

I DON'T THINK THIS IS CONFUSING AND NO ONE IN THE INDUSTRY 

COMMENTED ON IT. DO YOU THINK ANY CHANGE IS NEEDED? THERE IS A 

YELLOW RESPONSE BOX IN EACH COLUMN FOR BTUS.

P A-33, Q A9-1, “In Table A-12, provide info for Nox control systems that the plant has 

used after January 1, 2009, is currently constructing/installing...” (Clarification for 

consistency with earlier instructions)

OK - WILL MAKE EDIT
P A-35, Q A9-6, “...Please describe how the recycled process wastewater is reused.”

(you have not established that it is “treated”) Note, same issue applies to Q A9-11.

AGREE - WILL MAKE EDIT TO ALL AFFECTED QUESTIONS.

P A-40, Q A11-1, “In Table A-15, provide info for CC systems operated after Jan 1, 2009 

on fossil-fueled EGUs...” (Clarification for consistency with earlier instructions) Note 

that same issue applies to Q A12-1

OK - WILL MAKE EDIT

P A-51, Q A13-9, It is not clear whether you want a total amt of water generated over X 

days, or the amt per day.

Note, same issue applies to Qs A13-11 and A13-12.

IT'S HOWEVER THE PLANT CAN READILY PROVIDE THE INFORMATION. IS 

ANY CHANGE NEEDED HERE?

Part I Instructions, Refers to “separate glossary of selected economic and financial terms” 

but I didn’t see this.

P I-2, 2nd para of instructions, delete “...when answering the rest of the questions in this 

section.” (This is already clarified in the first part of the sentence, makes it more 

confusing)

P I-2, below Table I-2, add equations that were used to generate ownership share of 

steam capacity for each company, this will help make the calculation clearer (eg, for 

ABC LLC, (0.7 x 0.35) + (0.5 x 0.2) = 0.63)

P I-5, Table I-7, might be better throughout to refer to sources of “electricity,” unless 

“energy” is proper industry term here. Note in Q I2-11, you transition from using 

“energy” to using “electricity” to describe the same thing. Is there a reason for this?

P I-12, Add statement to instructions that if they estimate plant level data using some 

method other than the default, they should describe the method in the comments section, 
or you even want to provide a specific question up front for them to describe how they 

estimated it. This seems like pretty critical info for you to know how to use or not use the 

estimates.

P I-17, Col labeled “Gross and Net Electricity Generated” has only one space. Split into 

separate columns.

P I-21, Is Total Costs col meant to be sum of other two? If not, clarify possible cost 

categories and which are included/excluded from “fuel costs” and “variable O&M costs.”

--- jim