a: 

AMERICAN 

ELECFRIC 

POWER 

July 26, 2013 

Mr. Ron Jordan 

Mr. James Covington 

Ms. Jezebele Alicea-Virella 

US EPA-Office of Water/OST/EAD 

Mail Code: 4303T 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 

USEPA Headquarters 

Urgent: Request for Release of Information 

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

***PROMPT RESPONSE REQUESTED*** 

Dear Mr. Ron Jordan, Mr. Covington and Ms. Alicea-Virella: 

American Electric Power 

1 Roverside Plaza 

Columbus.OH 43215·2373 

AEP.com 

American Electric Power (AEP) 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: 

Plant O~erating Com~an~ EPA ID Number NPDES Permit Numberls 

John E Amos Appalachian Power Company 09161 WV0001074, WV0116254, 

WV0077046 

Big Sandy Kentucky Power Company 06118 KY0000221 

Cardinal Cardinal Operating Company 03265 OIB00009*QD 

Clinch River Appalachian Power Company 07727 VA0001015 

Conesville Columbus Southern Power Company 01402 01600013*10, OIN00101 *GO 

Flint Creek Southwestern Electric Power 03978 AR0037842 

Company 

General James M Ohio Power Company 04706 OIBOOOOG• JD 

Gavin 
Glen Lyn Appalachian Power Company 04711 VA0000370 

Kammer Ohio Power Company 02149 WV0005291 

Kanawha River Appalachian Power Company 08405 WV0001066 

Lieberman Southwestern Electric Power 06627 LA0002917 

., Company 

Mitchell Ohio Power Company 01236 WV0005304 

Mountaineer Appalachian Power Company 04543 WV0048500,WV0077038 

Muskingum River Ohio Power Company 09325 OIB00003*0D 

Northeastern 1 & 2 Public Service Company of Oklahoma 06933 OK0034380 

and 3 & 4 

Oklaunion Public Service Company of Oklahoma 00376 TX0087815 

Picway Columbus Southern Power Company 05802 41BOOOOO*GD 

Pirkey Southwestern Electric Power 06635 TX0087726 

Company 

Riverside Public Service Company of Oklahoma 03274 OK0002429 

Rockport Indiana Michigan Power Company 01671 IN0051845 

Philip Sporn Appalachian Power Company 05283 WV0001058 

Tanners Creek Indiana Michigan Power Company 05872 IN0002160 

Welsh Southwestern Electric Power 06739 TX0063215 

Company 

Wilkes Southwestern Electric Power 07535 TX0062006 

Company 

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-o819 Doc. ID No. 

{DCN No.) 

1959 (DCN SE01825A53) 

1959 (DCN SE01825A54) 

1959 (DCN SE01825A55) 

1959 (DCN SE01825A73) 

1959 (DCN SE01825A74) 

1959 (DCN SE01825A75) 

1959 (DCN SE01825A76) 

1959 (DCN SE01825A77) 

1959 (DCN SE01825A78) 

1977(SE02900) 

Short Description 

FGD Input Table Current Systems 

FGD Input Table Planned Systems 

FGD High Flow Analysis 

Bottom Ash MDS Conveyance O&M Costs 

Bottom Ash Intermediate Storage O&M Costs 

Bottom Ash Wet Sluicing O&M Costs 

Bottom Ash Remote MDS Capital Costs 

Bottom Ash Wet Sluicing O&M Costs 

Bottom Ash Remote MDS Capital Costs 

CBI Steam Electric Pollutant Loading Model for FGD Wastewater 
1984 {SE02899) 

1986(SE01756) 

2104(SE02897) 

2105 (SE02898) 

2121{SE03804) 

2157(SE02988) 

2159{SE03508) 

2191{SE03879) 

2195 {SE03507) 

2197{SE03552) 

2201{SE03895) 

2210 {SE02129) 

2252,2252.l{SE01957,SE1957Al) 

2256 (SE01957) 

CBI Steam Electric Pollutant loadings Model for Ash Transport Water 

CBI Future Profile FGD loads 

CBI Steam Electric Cost Model {FGD and Ash Transport Water) 

CBI Steam Electric Cost Model (FGD and leachate) 

CBI Data Dictionary for the FGD and Ash Cost Model 

CBI loads Calculation Database for Options 1, 2, 3, 4, and 5 

CBiloads Calculation Database Future Profile -I PM Only 

CBI Bottom Ash Management Determination Calculations 

loads Calculation Database- Questionnaire and IPM 

CBI EA Report Calculations Database 

CBI loads Calculation Database for Options 3a, 3b and 4a 

CBI Memorandum to the Steam Electric Rulemaking Record: New Source 

Performance Standards Costing Memorandum and Attachment 

CBI Incremental Costs and Pollutant Removals for Proposed ElGs Report 

and Attachment 

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: (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 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 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 there are less than 60 days left in the comment period, 

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 American Electric Power and am authorized to request confidential business 

information on behalf of my company. I certify that American Electric Power 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. , 

Please forward the requested information to Tim Lohner at the address below. It would also be 

appreciated if the requested information could be sent electronically to twlohner@aep.com. 

American Electric Power 

Environmental Services 

I Riverside Plaza 

Columbus, OH 43215 

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. 

Sincerely, 

John M. McManus 

Vice President - Environmental Services 

American Electric Power 

cc: T.W. Lohner