Ron Jordan 

Engineering and Analysis Division (4303T) 

Office of Water 

U.S. Environmental Protection Agency 

1200 Pennsylvania A venue, NW 

Washington, DC 20460 

Re: Follow up to Comments on Proposed Steam Electric Effluent Guidelines 

AEP Mountaineer Plant (EPA Plant Survey ID- 04543; FGD-1) 

Contains "Confidential Business Information" 

Dear Mr. Jordan: 

In response to the EPA data request of February 6, 2014, American Electric Power (AEP) is 

providing flue gas desulfurization (FGD) waste water characterization and treatment 

performance data for the AEP Mountaineer Plant. This includes the following information: 

1. Metal and inorganic concentration data for the FGD and leachate treatment system during 

the period January 2012 through December 2013 from the following sample points 

(attachment: AEP- Mountaineer Analytical Data Table): 

o FGD wastewater influent to the chemical precipitation treatment system; 

o FGD wastewater effluent from the chemical precipitation treatment system (prior 

to commingling with leachate); 

o Leachate waste stream prior to commingling with FGD wastewater and upstream 

of the biological treatment system; 

o Combined FGD and leachate wastewater upstream of the biological treatment 

system; and 

o Combined FGD and leachate wastewater effluent from the biological treatment 

system. 

2. AEP began operating the biological treatment system on November I 0, 2011. 

3. The organosulfide additive, Metclear MR2405 from GE Betz, was primarily used in the 

FGD chemical precipitation wastewater treatment system for the specified time period 
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6. Available information on the chloride concentration, pH, and average daily ORP values 

for the following sampling locations, are provided: 

o Within the FGD scrubber system; 

o For the influent to the FGD chemical precipitation wastewater treatment system; 

and 

o For the influent to the FGD/leachate biological wastewater treatment system. 

7. Electric generation output (MW-hr) for the generating unit is also provided (attachment: 

AEP-SE04298A 1_ Data Request Spreadsheet_ Mountaineer). 

Please note that it was not possible to provide selected information for the following categories: 

1. Daily coal source information - This information is not collected on a daily basis. Coal is 

moved from rail cars or barges to the coal pile or directly into the boiler, subsequently, 

specific information on exactly when and what coal went to the boiler is not available. 

Coal chlorine content information is only available on a contract basis or by request. 

Coal sulfur content information that is available for the requested time period has been 

provided (attachment: AEP-SE04298Al_Data Request Spreadsheet_Mountaineer). 

2. FGD scrubber system CFGD -1) - There are gaps in the average daily chloride 

concentration record due to weekends, holidays and outages, when the requested 

information was not collected. Average daily ORP information was not recorded until 

monitoring instruments were installed during October 2012. 

3. FGD wastewater treatment system- The average daily influent chloride concentration 

and ORP data were not recorded. Average daily pH information has been provided. 

4. FGD biological wastewater treatment system- Gaps in the daily chloride concentration 

record are due to weekends, holidays and outages, when the requested information is not 

collected. 

AEP is also providing the requested supplemental information, including: 

• A list of the chemicals and dosages added to the treatment system, including the location 

of injection points (see attached flow diagram); 

• A process flow diagram of the sampled system (attached); and 

• Laboratory reports associated with the sampling data (will be delivered on a CD). 
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in accordance with the requirements of 40 CFR Part 2. AEP considers the coal specification and 

sulfur data, all organosulfide and treatment chemical vendors, and the flow diagram, with all 

chemical injection locations and treatment dosages to be confidential business information 

(CBI). 

If you have any questions regarding the data submittal, please contact me at 614-716-1255 or at 

twlohner@aep.com. 

Sincerely, 

Timothy W. Lohner, Ph.D. 

Environmental Services 

Enclosure: Laboratory Reports on CD 

Attachments: Completed AEP Mountaineer Analytical Data Table (w/e-version only) 

AEP Mountaineer Coal Specifications 

Completed AEP-SE04298Al_Data Request Spreadsheet_Mountaineer (w/eversion only) 

MSDS - Metclear MR2405 

MSDS - Metclear MR2416 

Mountaineer FGD wastewater treatment flow diagrams