August 8, 2013

Ms. Jezebele Alicea- Virella

Environmental Engineer

EPA-Office ofWater/OST/EAD

Mail Code: 4303T

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Urgent: Request for Release ofInformation

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

***PROMPT RESPONSE REOUESTED***

Dear Ms. Alicea- Virella:

Our facilities 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). The facilities listed below either responded to earlier

ELG Rule questionnaires to the industry or provided information to you through other means,

such as site visits or separate information requests. The specific facilities in question are as

follows:

Kansas City Power & Light Company:

• Hawthorn Generating Station - NPDES Permit No. MO - 0004855

• latan Generating Station - NPDES Permit No. MO - 0082996

• Montrose Generating Station - NPDES Permit No. MO - 0101117

• La Cygne Generating Station - NPDES Permit No. KS - 0080071

KCP&L Greater Missouri Operations Company:

• Lake Road Generating Station - NPDES Permit No. MO - 0004898

• Sibley Generating Station - NPDES Permit No. MO - 0004871

KCP&L P.O. Box 41B679 Kansas City. MO 64141-9679 1-88B-471-5275 toll-free www.kcpl.com
We have identified certain record documents which we believe contain information reported by,

or derived from data or information reported by, one or more of our facilities. EPA has redacted

all or portions of these documents as "confidential business information" (CBI).

We are requesting that you provide to us all information related to the facilities listed above

(including information that EPA has derived from information obtained from our facilities and

from all other sources, and including facility-specific 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

SEO1825A53)

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

SEO1825A74)

1959 (DCN Bottom Ash Wet Sluicing O&M Costs

SED1825A75)

1959 (DCN Bottom Ash Remote MDS Capital Costs

SEOI 825A 76)

1959 (DCN Bottom Ash Wet Sluicing O&M Costs

SEOI825A77)

1959 (DCN Bottom Ash Remote MDS Capital Costs

SEO1825A 78)

1977 (SE02900) CBI Steam Electric Pollutant Loading Model for FGD

Wastewater

1984 (SE02899) cm Steam Electric Pollutant Loadings Model for Ash

Transport Water

1986 (SEO1756) cm 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) cm 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) cm 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) cm EA Report Calculations Database

2201 (SE03895) CBI Loads Calculation Database for Options 3a, 3b and 4a

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EPA-HQ-OW-2009-

0819 Doc. ID No. (DCN Short Description

No.)

1959 (DCN FGD Input Table Current Systems

SEO1825A53)

1959 (DCN FGD Input Table Planned Systems

SEO1825A54)

1959 (DCN FGD High Flow Analysis

SEO1825A55)

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

SEOI825A77)

1959 (DCN Bottom Ash Remote MDS Capital Costs

SEO1825A 78)

2210 (SE02129) CBI Memorandum to the Steam Electric Rulemaking Record:

New Source Performance Standards Costing Memorandum

and Attachment

2252,2252.1 (SEOI957, CBI Incremental Costs and Pollutant Removals for Proposed

SEI957AI) ELGs Report and Attachment

2256 (SEOI957) CBI Incremental Costs and Pollutant Removals

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: (I) 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 is key to understanding 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 ofCBI

protections. Furthermore, we are not requesting CBI information, or CBl-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.

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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.

Certification Statement

"I certifY under penalty of law that Iam a responsible corporate official or his/her authorized

representative of Kansas City Power and Light Company and KCP&L Greater Missouri

Operations Company and am authorized to request confidential business information on behalf

of my companies. IcertifY that Kansas City Power and Light Company and KCP&L Greater

Missouri Operations Company are the majority owners 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 submittingfalse information including the

possibility offines and imprisonment, pursuant to 18 Us.c. f 1001. "

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.

Si7~1o'

Paul M. Ling

Director of Compliance

Kansas City Power & Light Company

1200 Main

Kansas City, MO 64105-2154

E-mail: paul.ling@kcpl.com

Telephone No.: 816-556-2899

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