July 25, 2013 

OHIO VALLEY ELECTRIC CORPORATION 

INDIANA-KENTUCKY ELECTRIC CORPORATION 

3932 U. S. Route 23 

P. 0. Box468 

Piketon, Ohio 45661 

740-289-7200 

WRITER'S DIRECT DIAL NO: 

(7 40)289-7299 

VIA ELECTRONIC MAIL: RETURN RECEIPT REQUESTED, to 

alicea.jezebele@epa.gov and covington.james@epa.gov 

Ms. Jezebele Alicea-Virella 

U.S. EPA Headquarters 

Mr. James Covington 

U.S. EPA Headquarters 

Urgent: Request for Release of Information 

From Docket No. EPA-HQ-OW-2009-0819 

***PROMPT RESPONSE REQUESTED*** 

Dear Ms. Alicea-Virella and Mr. Covington: 

The Ohio Valley Electric Corporation (OVEC) and its wholly owned subsidiary, IndianaKentucky Electric Corporation (IKEC) 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). OVEC's 

Kyger Creek Station and IKEC's Clifty Creek Station, (facility descriptions listed below), 

responded to earlier ELG Rule questionnaires to the industry and may have provided 

information to you through other means, such as site visits or separate information 

requests. The specific facilities in question are as follows: 

1. Ohio Valley Electric Corporation, Kyger Creek Station, NPDES Permit No. 

OIB00005*0D- issued by the Ohio Environmental Protection Agency; and 

2. Indiana-Kentucky Electric Corporation, Clifty Creek Station, NPDES Permit No. 

IN0001759- issued by the Indiana Department of Environmental Management. 

We have identified certain record documents which we believe contain information 

reported by, or derived from data or information reported by, Kyger Creek and Clifty 

Creek Stations. EPA has redacted all or portions of these documents as "confidential 

business information" (CBI). 
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We are requesting that you provide to us all information related to the Kyger Creek and 

Clifty Creek Stations listed above (including information that EPA has derived from 

information obtained from our facilities and from all other sources, and including facilityspecific or facility-derived information in input files to the listed documents) contained 

within the following documents: 

EPA-HQ-OW-2009-

0819 Doc.ID No. (DCN Short Description 

No.) 

1959 (DCN FGD Input Table Current Systems 

SE01825A53) 

1959 (DCN FGD Input Table Planned Systems 

SE01825A54) 

1959 (DCN FGD High Flow Analysis 

SE01825A55) 

1959 (DCN Bottom Ash MDS Conveyance O&M Costs 

SE01825A73) 

1959 (DCN Bottom Ash Intermediate Storage O&M Costs 

SE01825A74) 

1959 (DCN Bottom Ash Wet Sluicing O&M Costs 

SE01825A75) 

1959 (DCN Bottom Ash Remote MDS Capital Costs 

SE01825A76) 

1959 (DCN Bottom Ash Wet Sluicing O&M Costs 

SE01825A77) 

1959 (DCN Bottom Ash Remote MDS Capital Costs 

SE01825A78) 

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, CBI Incremental Costs and Pollutant Removals for Proposed 

SE1957A1) ELGs Report and Attachment 

2256 (SE01957) CBI Incremental Costs and Pollutant Removals 
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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 will be essential to 

understand 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 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 the comment period deadline is 

September 20, 2013, we ask that you expedite this request. 

I certify under penalty of law that I am a responsible corporate official or his/her 

authorized representative of OVEC-IKEC and am authorized to request confidential 

business information on behalf of my company. I certify that OVEC-IKEC is the majority 

owner or the operator for each facility (and for each unit at each facility) for which we 

are requesting confidential business information. I am aware that there may be 

significant penalties for submitting false information including the possibility of fines and 

imprisonment, pursuant to 18 U.S. C.§ 1001. 

Finally, in addition to (or even in lieu of a hard copy) I also ask that you submit the 

requested information to my attention electronically at the email address provided 

below: 

OVEC-IKEC's certifying official: 

Name: J. Michael Brown 

Title: Environmental, Safety & Health Director 

Mailing Address: 3932 U.S. Rt. 23, Piketon, OH 45661 

E-mail Address: mbrown@ovec.com 
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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. 

Since~#~ 

iichael Brown 

Environmental, Safety & Health Director 

Ohio Valley Electric Corporation 

Indiana-Kentucky Electric Corporation 

PO Box 468, 3932 U.S. Rt. 23 

Piketon, Ohio 45661 

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