# = AMERICAN'' E£EC1RIC POWER

November26, 2014

Mr. Robert K. Wood, Director Engineering and Analysis Division Mail Code 4303T U.S. Environmental ProtectionAgency William Jefferson Clinton Building 1200 Pennsylvania Avenue, N. W. Washington, DC 20460 American Electric Power 1RiverSide Plaza Columbus, OH 43215-2373 AEP.com

Re: Information RequestPursuant to Section 308 of the Clean WaterAct Pilot Testing ConductedatJohn E. AmosPlantandOtherAEPPlants DearMr. Wood: On October 4, 2014, a letter was hand-delivered to Dr. Timothy Lohnerby Ronald Jordan ofU.S. EPA, seeking certain information related to pilot testing recently conducted at the John E. Amos Plant in Winfield, West Virginia, and similar testing conducted at other plants within the American Electric Power (AEP) system. The requested information was required to be submitted by November 21, 2014, but a timely request for extension was submitted, and the response deadline was extended to December 5, 2014. Attached hereto are narrative responses to the specific items identified in the request, and an indication that certain of the information requested is confidential business information, entitled to protection under 40 CFR Part 2. Information that is "CONFIDENTIAL BUSINESS INFORMATION" has been placed on a separate CD, and is identified by a stamp or other marking directly on the information submitted herewith. We understand that confidential information may be shared with contractors working with U.S. EPA on the development ofthe Effluent Limitation Guidelines for the Stearn Electric Generating Sector, as setforth inEnclosure 4 to your letter, and that U.S. EPA has included provisions in the contracts with those vendors all provisions necessary to implement the confidentiality provisions of40 CFR Part 2, specifically, 40 CFR §§ 2.301(h)(2), 2.302(h)(2) and 2.305(h)(2). Should further disclosure of our confidential information be necessary, we understand that it is U.S. EPA's obligation to provide us with notice ofany transfer ofconfidential information. We also understand that U.S. EPA will notifyAEP ifarequest is made for release ofthe information designated as confidential, that U.S. EPA may request further substantiation ofour claims ofbusiness confidentiality, and that we will be notified of any determination that a request for confidential treatment has been denied.The data included on the CD that is marked "CONFIDENTIAL BUSINESS INFORMATION" is primarily information obtained during the pilot testing. The pilot testing was conducted pursuant to a supplemental agreement with the Electric Power Research Institute (EPRI), and is valuable research and development data that could provide AEP and its affiliates with economic and commercial advantages in determining how best to comply with the effluent limitations currently under review at U.S. EPA. AEP has expended substantial resources to participate in these research activities, and the results of that research should not be made publicly available to AEP's competitors without charge, because doing so will rob AEP ofits investment inthat research. AEP's contract with EPRI also designates this information as CONFIDENTIAL INFORMATION of EPRI and its funders, gives AEP limited rights to use the data and information developed as part ofthis supplemental project only for its own internal purposes, and requires AEP to label the information as "confidential" prior to its disclosure to any third party or governmental entity, and disclose the information only ifit will be subject to a written agreement, confidentiality order, or non-disclosure agreement. AEP has discussed with EPRI this request, and the protection afforded pursuant to 40 CFR Part 2, and obtained EPRI's concurrence to disclose the information subject to a claim for confidential treatment under 40 CFRPart 2. None ofthe data for which AEP is requesting confidential treatment is "effluent data" as that term is defined in40 CFR §2.302(a)(2)(i), because all ofthe datarelates to wastewaters that were specially developed for purposes ofthe pilot testing, and were returned to the systems atthe John E. Amos Plant for further treatment prior to discharge. This information is being voluntarily submittedbyAEPto further the agency's understanding oftechnologiesthathave not yet progressed to the point ofcommercial availability. While AEP understands that the agency can consider certain research-related information to be "effluent data" if necessary to demonstrate the feasibility, practicability, or attainability (or lack thereof) of an existing or proposed standard or limitation, pursuant to 40 CFR § 2.302(a)(2)(ii)(A), and may disclose such information publicly, AEP submits that 'the preliminary nature of the requested data, and the limited nature ofthe pilot testing performed to date, is insufficient to allow U.S. EPA to make such a determinationbased onthis data alone. Should you have any questions concerning the narrative responses of the information provided with these responses, please contact me at (614) 716-1255, or by e-mail at twlohner@aep.com. Very trulyyours,

Timothy W. Lohner, Ph.D. ConsultingEnvironmental SpecialistAttachment: Responses to Request for Information Enclosures: CD "CONFIDENTIAL BUSINESS INFORMATION" CD "NON-CONFIDENTIALDATA"

cc: Ron Jordan- U.S. EPA 

### ....Phillip Flanders- U.S. EPA

John M. McManus- VP, AEP Environmental Services Janet J. Henry- AEP Deputy General CounselRESPONSES TO REQUEST FORINFORMATION UNDERSECTION 308 OFTHE CLEANWATERACT REGARDING PILOTTESTING CONDUCTEDAT THEJOHN E. AMOS PLANT SINCEJANUARY 1,2010 For each pilot-scale test of FGD wastewater treatment technologies conducted at the John E. Amos Plant since January 1, 2010, please provide the following information: 1. Please identifywhen thepilot-scale testing was conducted. Pilot scale testing of a group offour potential FGD wastewater treatment technologies was conducted at the John E. Amos Plant during the period from February 26, 2014 through October 13, 2014. Test periods for the different technologies overlapped, but did not extend for this entire period for any ofthe technologies. The technology provider, test start date, and test end date are provided in the chartbelow.**Technolo~** Provider Test StartDate TestEndDate Liberty Hydro, Inc. 3/20/2014 7/30/2014 MAR Systems 2/26/2014 7/6/2014 Nucon/Mersorb 3/10/2014 7/22/2014 Evoqua 7/10/2014 10/13/2014

2. Please identifyanddescribe the objectives of thepilottest. The pilot test was performed as part ofa self-directed research and development project in collaboration with the Electric Power Research Institute (EPRI) and other electric utilities. The primary objective of the pilot-scale testing was to further evaluate the selected technologies, and provide information to assist in assessments of the performance and cost-effectiveness ofthe selected technologies in removing trace metals from the FGDwastewater stream. 3. Pleaseprovide a description of the wastewater usedin thepilottesting (e.g., describe any treatment ofthe FGD wastewater prior to it being transferred to the technologies evaluatedaspartof thepilottesting). Wastewater used in the pilot testing was drawn from two locations within the physical/chemical treatment system at the John E. Amos Plant. About 50% of the wastewater was drawn from the primary clarifier, and about 50% ofthe wastewater was drawn from the secondary clarifier. These streams were blended, filtered, and spiked with various constituents ofconcern (i.e. arsenic and mercury) prior to being introduced 1to the technologies being evaluated. Following treatment and sampling, all processed wastewaterwas returned to the AEP physical/chemicaltreatment system. 4. Please describe any changes made to the pretreatment configuration/operations during thepilot testing andwhen those changes occurred. For example, describe any additional pretreatmentsteps thatwere addedprior to the wastewater being transferredto thepilottest technologies. Include a detailed description ofthe pretreatment technology (or changes to the technology) including chemicals and dosage rate, and the date the changes were made. For any changes made to the pretreatment system, provide an explanation as to why the changes were made. No additions or substitutions were made to the upstream physical/chemical treatment systems operated by AEP during the testing period, other than normal adjustments to ensure that the FGD wastewater entering the pond complex at the John E. Amos Plant would meetthe applicable effluent limitations priorto discharge. After the wastewater exited the primary and secondary clarifiers in AEP's physical/chemical treatment system, all further pretreatment operations were controlled by EPRI and its contractors. AEP does not have detailed information regarding specific pretreatment configurations or changes that occurred during thepilottesting. 5. Please provide a description ofall the wastewater treatment technologies evaluated as part of thepilottesting. Please also note any changes made to the treatment technologies of additionalpretreatment added, including any vendors, to the systems during thepilot testing, such as to optimizeperformance of the technology. For any changes made to the treatment technologies, provide an explanation as to why the changes were made and identify the dates the changes were made. A general description ofthe technologies evaluated is provided in the chartbelow. Vendor Technology Name Materials Used Level of Development Liberty Hydro ZVI Blue Zero-valent iron Pilot-scale Nucon Mesorb Sulfur-impregnated Pilot-scale activated carbon MAR Systems Sorbster SE-1 Activated alumina Pilot-scale Evoqua Tailored carbon Activated carbon Pilot-scale Evoqua GFH Granular ferric Pilot-scale hydroxide

AEP does not have access to detailed descriptions ofany ofthe technologies evaluated. EPRI, the vendors, and EPRI contractors, retained actual control ofthe pilot-testing.

26. Please identifY the amount of wastewater treated through each of the treatment technologies (including anypretreatmentsystem(s)) andnote any changes throughout the pilot test duration. For any changes in the wastewaterflow rate tested, please explain why there was an increase/decrease in theflow rate. Enclosed is a CD marked "CONFIDENTIAL BUSINESS INFORMATION" containing summary data, including flow rates, for each ofthe evaluated technologies (Amos Pilot Study Operating Data Q6 CBI.xlsx). After the wastewater exited the primary and secondary clarifiers in AEP's physical/chemical treatment system, all further pretreatment operations and pilot testing was controlled by EPRI and its contractors. AEP does not have detailed information regarding specific changes that occurred during the pilottesting. 7. Please identifYany waste streams or dilution streams that are/were commingledwith the FGD wastewaterprior to treatment. IdentifY thepercent contribution of the other waste streams/dilution streams comparedto the FGD wastewater that was/is treatedin thepilot test. No waste streams or dilution streams are commingled with the FGD wastewater prior to its treatment inthe AEP physical/chemical treatment system at the JohnE. Amos Plant. 8. Pleaseprovide a simplifiedprocessflow diagram ofthe entire pilot test corifiguration that identifies the generation of the FGD wastewater, anypretreatment systems, andall technologies evaluated. Please note that this simplified diagram should identifY the operation of thepilot test before andafter any changes were made, andthe date changes were made should be noted on the diagram. See Enclosure 1for an example ofa simplifiedprocessflow diagram. A simplified process diagram ofthe AEP physical/chemical FGD wastewater treatment system is set forth below.

3Organosulfide, GE MR 2405 Return from Pilot TestArea

Primary Sludge Pump

Filter Press Waterto Transfer Pump F·lt p wasteWater**~** owSump/FGD**~** 1 er resses

Absorbers

- J[!**~**- 2nd Stage Filter

--· Filter Press Feed Waste Water Cake Pump Collection

Sump Secondary Secondary Polymer, GE Clarffier AE 1703

Secondary

Sludge Pump

1st Stage Filter Press Feed

Pump Amos Waste Water Treatment System 

# ..... To PilotTestArea

Enclosed is a CD marked "CONFIDENTIAL BUSINESS INFORMATION" that contains a simplifiedprocess diagram ofthe additional pretreatment processes and the four pilot-scale FGD wastewater treatment technologies that were evaluated during the pilot testing (Pilot Test Simplified Process Diagram CBI.doc). 9. Pleaseprovide a detailedprocessflow diagramfor each technology evaluatedaspart of the pilot testing including any vendor installed pretreatment steps starting with the wastewater supplied by AEP. The diagram should show all ofthe specific sampling locations and chemical addition pointsfor that technology. Please note that each diagram should include specific sampling location names so the analytical data can be matchedspecifically to each technology evaluated. See Enclosure 1for an example of a simplified process flow diagram. Please see the diagram supplied in response to Request No. 8 (Pilot Test Simplified Process Diagram CBI.doc) on the enclosed CD marked "CONFIDENTIAL BUSINESS INFORMATION." Sampling locations are marked on that diagram to allow analytical datato be matched withthe specifictechnologies being evaluated. 10. EPA requests that AEP provide all arsenic, mercury, selenium, nitrate/nitrite, and ammonia concentration datafor thefollowing waste streamsfor the entire time period

4that the pilot test was conducted (see Enclosure 2 andAttachment 1 ("Analytical Data Table" workbook)for details onprovidinganalytical data):



### a. FGDpurge stream (e.g., prior to any treatment or dilution) Enclosed is a CD marked "NON-CONFIDENTIAL DATA" that contains available analytical data for the FGD wastewater entering AEP's physical/chemical wastewater treatment system during the period from 2/26/2014 through 10113/2014 (SE05159Al_Analytical DataTable_PurgeData.xlsx). b. Influent to pilot testing (e.g., after allpretreatment, but before treatment in the technologies evaluatedin thepilottest); and Enclosed is a CD marked "CONFIDENTIAL BUSINESS INFORMATION" that contains analytical data for the wastewater that was introduced to each of the technologies for which pilot testing was conducted, after all pretreatment was completed (Amos Vendor Lab Data Ques lOb & lOc CBI.xlsx; SE05159Al_Analytical Data Table_Pilot Data_ CBI.xlsx).

c. Treated wastewaterfrom each technology evaluated (Note: 

### ifany technologies are operated as treatment trains (i.e. one technology is downstream ofanother technology) then the datafor each stage in the treatmentshouldbeprovided). Enclosed is a CD marked "CONFIDENTIAL BUSINESS INFORMATION"that contains analytical data for the treated wastewater that was sampled from each ofthe technologies for which pilot testing was conducted (Amos Vendor Lab Data Ques 1Ob & lOc CBI.xlsx; SE05159Al_Analytical DataTable_Pilot Data_CBI.xlsx).

11. Additionally, EPA requires certain supplemental information to further evaluate the quality of the data. Pleaseprovide the data listedin Enclosure 2. Please see response to RequestNo. 10 onthe CDmarked "CONFIDENTIAL BUSINESS INFORMATION." AEP is also in the process of obtaining the associated AEP lab reports for analyses that were performed by the AEP John E. Dolan Laboratory. This informationwill be provided by December 5, 2014. 12. Pleaseprovide the type andsource of coal (i.e. mine name andlocation) usedat theplant each day starting one month prior to the beginning ofthe pilot test and continuing through the entirepilot test duration. In addition, pleaseprovide the sulfur andchlorine content of the coal usedat theplant each day of thisperiod, 

### if available. For days where coal blending occurred, please note the percentage ofeach type ofcoal used. See Attachment 2 (Supplemental Data workbook, tab titled "Coal Data")for theformat of the data requestedbyEPA. 5

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Enclosed is a CD marked "CONFIDENTIAL BUISNESS INFORMATION" that contains information on coal shipments received at the John Amos Plant during the period beginning 30 days priorto the commencement ofthe pilot testing and ending on or around 10/13/2014, including sulfur content ofthe coal received. Chlorine content for individual shipments is not available during this period (AEP Amos Coal Spec Narrative CBI.doc; SE005159A2_Supplemental Coal Data_Amos_l0082014 CBI.xlsx). 13. Please provide the following informationfor each day within the range ofsampling results that are being provided, 

### ifavailable (See Attachment 2, Supplemental Data workbook):

a. Chlorine concentration, pH, total suspended solids ("TSS"), and average daily oxidation-reductionpotential ("ORP ") values within each FGD scrubber system (tab titled "FGD System Information"); b. Chloride concentration, pH, TSS, andaverage daily ORP valuesfor the influent to the FGD wastewater treatment system (prior to any treatment/chemical addition) (tab entitled "FGD WWTInfluent"); and c. Electric generation output (MW-hr)for each generating unit serviced by a FGD system (tab entitled "Electricity Generation"). Enclosed is a CD marked "NON-CONFIDENTIAL DATA" that contains the available requested information (SE005159A2_Supplemental Data _Amos_10082014.xlsx. 14. Additionally, EPA requests that you identifY all other pilot tests conducted between January 1, 2010 and the present that evaluated the treatment ofFGD wastewater at Amos Station or any other AEPpower plants. For each ofthe additionalpilot tests identified, youmustprovide thefollowing information: Where was the test conducted; When was the test conducted; What technologies were evaluated(company andtechnology); and What were the objectives of the test? No additional pilot tests of any FGD wastewater treatment technologies have been conducted by AEP at any generating stations during the specifiedperiod.

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