E£EC1RIC 

AMERICAN'' = 

POWER 

November 26, 2014 

Mr. Robert K. Wood, Director 

Engineering and Analysis Division 

Mail Code 4303T 

U.S. Environmental Protection Agency 

William Jefferson Clinton Building 

1200 Pennsylvania Avenue, N. W. 

Washington, DC 20460 

American Electric Power 

1 RiverSide Plaza 

Columbus, OH 43215-2373 

AEP.com 

Re: Information Request Pursuant to Section 308 of the Clean Water Act 

Pilot Testing Conducted at John E. Amos Plant and Other AEP Plants 

Dear Mr. Wood: 

On October 4, 2014, a letter was hand-delivered to Dr. Timothy Lohner by Ronald Jordan 

of U.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 of the 

Effluent Limitation Guidelines for the Stearn Electric Generating Sector, as set forth in Enclosure 

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 of 40 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 of any transfer of confidential information. We also understand that U.S. EPA 

will notify AEP if a request is made for release of the information designated as confidential, that 

U.S. EPA may request further substantiation of our claims of business 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 of its 

investment in that 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 of this 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 if it 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 of the data for which AEP is requesting confidential treatment is "effluent data" as 

that term is defined in 40 CFR §2.302(a)(2)(i), because all of the data relates to wastewaters that 

were specially developed for purposes of the pilot testing, and were returned to the systems at the 

John E. Amos Plant for further treatment prior to discharge. This information is being 

voluntarily submitted byAEP to further the agency's understanding oftechnologies that have not 

yet progressed to the point of commercial 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 of the pilot testing performed to date, is insufficient to allow U.S. EPA to make 

such a determination based on this 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 truly yours, 

Timothy W. Lohner, Ph.D. 

Consulting Environmental Specialist 
Attachment: Responses to Request for Information 

Enclosures: CD "CONFIDENTIAL BUSINESS INFORMATION" 

CD "NON-CONFIDENTIAL DATA" 

cc: Ron Jordan- U.S. EPA 

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

John M. McManus- VP, AEP Environmental Services 

Janet J. Henry- AEP Deputy General Counsel 
RESPONSES TO REQUEST FOR INFORMATION 

UNDER SECTION 308 OF THE CLEAN WATER ACT 

REGARDING 

PILOT TESTING CONDUCTED AT THE JOHN E. AMOS PLANT 

SINCE JANUARY 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 identify when the pilot-scale testing was conducted. 

Pilot scale testing of a group of four 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 of the technologies. The technology provider, 

test start date, and test end date are provided in the chart below. 

Technolo~ Provider Test Start Date Test End Date 

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 identify and describe the objectives of the pilot test. 

The pilot test was performed as part of a 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 of the selected technologies in removing trace metals 

from the FGD wastewater stream. 

3. Please provide a description of the wastewater used in the pilot testing (e.g., describe any 

treatment of the FGD wastewater prior to it being transferred to the technologies 

evaluated as part of the pilot testing). 

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% of the wastewater was 

drawn from the secondary clarifier. These streams were blended, filtered, and spiked 

with various constituents of concern (i.e. arsenic and mercury) prior to being introduced 

1 
to the technologies being evaluated. Following treatment and sampling, all processed 

wastewater was returned to the AEP physical/chemical treatment system. 

4. Please describe any changes made to the pretreatment configuration/operations during 

the pilot testing and when those changes occurred. For example, describe any additional 

pretreatment steps that were added prior to the wastewater being transferred to the pilottest technologies. Include a detailed description of the 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 meet the applicable effluent limitations prior to 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 the pilot testing. 

5. Please provide a description of all the wastewater treatment technologies evaluated as 

part of the pilot testing. Please also note any changes made to the treatment technologies 

of additional pretreatment added, including any vendors, to the systems during the pilot 

testing, such as to optimize performance 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 of the technologies evaluated is provided in the chart below. 

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 of any of the technologies evaluated. 

EPRI, the vendors, and EPRI contractors, retained actual control of the pilot-testing. 

2 
6. Please identifY the amount of wastewater treated through each of the treatment 

technologies (including any pretreatment system(s)) and note any changes throughout the 

pilot test duration. For any changes in the wastewater flow rate tested, please explain 

why there was an increase/decrease in the flow rate. 

Enclosed is a CD marked "CONFIDENTIAL BUSINESS INFORMATION" containing 

summary data, including flow rates, for each of the 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 pilot testing. 

7. Please identifY any waste streams or dilution streams that are/were commingled with the 

FGD wastewater prior to treatment. IdentifY the percent contribution of the other waste 

streams/dilution streams compared to the FGD wastewater that was/is treated in the pilot 

test. 

No waste streams or dilution streams are commingled with the FGD wastewater prior to 

its treatment in the AEP physical/chemical treatment system at the John E. Amos Plant. 

8. Please provide a simplified process flow diagram ofthe entire pilot test corifiguration 

that identifies the generation of the FGD wastewater, any pretreatment systems, and all 

technologies evaluated. Please note that this simplified diagram should identifY the 

operation of the pilot test before and after any changes were made, and the date changes 

were made should be noted on the diagram. See Enclosure 1 for an example of a 

simplified process flow diagram. 

A simplified process diagram of the AEP physical/chemical FGD wastewater treatment 

system is set forth below. 

3 
Organosulfide, 

GE MR 2405 

Return from Pilot 

Test Area 

Primary 

Sludge 

Pump 

Filter Press Water to Transfer Pump F·lt p ow Sump /FGD ~ 

wasteWater ~ 

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 Pilot Test Area 

Enclosed is a CD marked "CONFIDENTIAL BUSINESS INFORMATION" that 

contains a simplified process diagram of the 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. Please provide a detailed process flow diagram for each technology evaluated as part of 

the pilot testing including any vendor installed pretreatment steps starting with the 

wastewater supplied by AEP. The diagram should show all of the specific sampling 

locations and chemical addition points for that technology. Please note that each 

diagram should include specific sampling location names so the analytical data can be 

matched specifically to each technology evaluated. See Enclosure 1 for 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 

data to be matched with the specific technologies being evaluated. 

10. EPA requests that AEP provide all arsenic, mercury, selenium, nitrate/nitrite, and 

ammonia concentration data for the following waste streams for the entire time period 

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that the pilot test was conducted (see Enclosure 2 and Attachment 1 ("Analytical Data 

Table" workbook) for details on providing analytical data): 

a. FGD purge 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 Data Table_Purge Data.xlsx). 

b. Influent to pilot testing (e.g., after all pretreatment, but before treatment in the 

technologies evaluated in the pilot test); 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 wastewater from each technology evaluated (Note: if any technologies 

are operated as treatment trains (i.e. one technology is downstream of another 

technology) then the data for each stage in the treatment should be provided). 

Enclosed is a CD marked "CONFIDENTIAL BUSINESS INFORMATION" that 

contains analytical data for the treated wastewater that was sampled from each of the 

technologies for which pilot testing was conducted (Amos Vendor Lab Data Ques 1 Ob & 

lOc CBI.xlsx; SE05159Al_Analytical Data Table_Pilot Data_CBI.xlsx). 

11. Additionally, EPA requires certain supplemental information to further evaluate the 

quality of the data. Please provide the data listed in Enclosure 2. 

Please see response to Request No. 10 on the CD marked "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 

information will be provided by December 5, 2014. 

12. Please provide the type and source of coal (i.e. mine name and location) used at the plant 

each day starting one month prior to the beginning of the pilot test and continuing 

through the entire pilot test duration. In addition, please provide the sulfur and chlorine 

content of the coal used at the plant each day of this period, if available. For days where 

coal blending occurred, please note the percentage of each type of coal used. See 

Attachment 2 (Supplemental Data workbook, tab titled "Coal Data") for the format of 

the data requested by EPA. 

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r--.·· 

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 prior to the commencement of the pilot testing and ending on or 

around 10/13/2014, including sulfur content of the 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 information for each day within the range of sampling 

results that are being provided, if available (See Attachment 2, Supplemental Data 

workbook): 

a. Chlorine concentration, pH, total suspended solids ("TSS"), and average daily 

oxidation-reduction potential ("ORP ") values within each FGD scrubber system 

(tab titled "FGD System Information"); 

b. Chloride concentration, pH, TSS, and average daily ORP values for the influent 

to the FGD wastewater treatment system (prior to any treatment/chemical 

addition) (tab entitled "FGD WWT Influent"); 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 _1 00820 14.xlsx. 

14. Additionally, EPA requests that you identifY all other pilot tests conducted between 

January 1, 2010 and the present that evaluated the treatment of FGD wastewater at 

Amos Station or any other AEP power plants. For each of the additional pilot tests 

identified, you must provide the following information: 

Where was the test conducted; 

When was the test conducted; 

What technologies were evaluated (company and technology); 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 specified period. 

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