### July25, 2013 OHIOVALLEY 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: (740)289-7299



### VIA ELECTRONIC MAIL: RETURN RECEIPT REQUESTED, to alicea.jezebele@epa.gov and covington.james@epa.gov

Ms. JezebeleAlicea-Virella U.S. EPA Headquarters

Mr. James Covington U.S. EPA Headquarters

Urgent: Requestfor 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 ofthe proposed revision ofthe effluent limitations guidelines and standards forthe steam electric powergenerating point source (ELG Rule). OVEC's Kyger Creek Station and IKEC's Clifty Creek Station, (facility descriptions listed below), responded to earlier ELG Rule questionnairesto the industry and may have provided information to you through other means, such as site visits orseparate information requests. The specific facilities in question are as follows:

1. OhioValley Electric Corporation, Kyger Creek Station, NPDES Permit No. OIB00005*0D- issued bythe Ohio Environmental Protection Agency; and

2. Indiana-Kentucky Electric Corporation, Clifty Creek Station, NPDES Permit No. IN0001759- issued bythe Indiana Department of Environmental Management.

We have identified certain record documentswhich we believe contain information reported by, orderived from data or information reported by, Kyger Creekand Clifty Creek Stations. EPA has redacted all or portions ofthese documents as "confidential business information" (CBI).

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We are requesting thatyou 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 ourfacilities and from all othersources, and including facilityspecific orfacility-derived information in inputfiles to the listed documents) contained within the following documents:

EPA-HQ-OW-2009- 0819 Doc.ID No. (DCN Short Description No.) 1959 (DCN FGD InputTable Current Systems SE01825A53) 1959 (DCN FGD InputTable Planned Systems SE01825A54) 1959 (DCN FGD High FlowAnalysis 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 forAsh TransportWater 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 Dictionaryforthe FGD and Ash Cost Model 2157 (SE02988) CBI Loads Calculation Database forOptions 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-3-

Please include all information from these documents that relates to ourfacilities. For example, ourfacilities supplied information about existing control technologies. Through this request, we are requesting not only the control technologies information supplied by ourfacilities, but also control technologies information aboutourfacilities derived from othersources, as well as all EPA-developed information relating to our control technologies, including EPA's assessments offuture technology choices for our facilities based on the various rule options.

Foreach document, as appropriate, please also include: (1) a legend which explains each column heading and each abbreviation used throughoutthe entire document; and (2) a list ofall formulas applied in the document and a legend forany abbreviations used in the formulas. The legend and formula information will be essential to understand these documents.

We makethis requestwithoutwaiving anyofour CBI designations. Becauseyou are providing the information only to us, there is no breach ofconfidentiality and no waiver ofCBI protections. Furthermore, we are not requesting CBI information, or CBI-derived information, from othercompanies 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 forfacility-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 September20, 2013, we askthatyou expedite this request.

I certify under penalty of lawthat I am a responsible corporate official or his/her authorized representative ofOVEC-IKEC and am authorized to request confidential business information on behalfofmycompany. I certifythat OVEC-IKEC is the majority
owner orthe operatorfor each facility (and for each unit ateach facility) forwhich we
are requesting confidential business information. I am awarethatthere may be significant penalties for submitting false information including the possibility offines and imprisonment, pursuantto 18 U.S.C.§ 1001.
Finally, in addition to (or even in lieu ofa hard copy) I also askthatyou submitthe requested information to myattention electronically atthe 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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Ifyou have any questions aboutthis request, please call oremail me. I lookforward to your prompt response. Thankyou very much foryour help.

# Since~#~

iichaelBrown

Environmental, Safety & Health Director Ohio Valley Electric Corporation Indiana-Kentucky Electric Corporation PO Box468, 3932 U.S. Rt. 23 Piketon, Ohio 45661

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