# 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 Penn sylvania Avenue, N .W. Washin gton , D.C. 20460 USEPA Headquarters



### Urgent: Request for Release ofInformation From Docket No. EPA-HQ-OW-2009-0819 ***PROMPT RESPONSE REQUESTED***

Dear Mr. Ron Jordan, Mr. Covington and Ms. Alicea-Virella: American E lectr ic 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 ofthe proposed revision ofthe effluent limitation s guidelines and standards for the steam electri c power generating point source (ELG Rule). T he 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 K entucky Power Company 06118 KY0000221 Cardinal Cardinal Operating Company 03265 OIB00009*QD Cl inch 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 Oh io Power Company 04706 OIBOOOOG•JD GavinGlen Lyn Appalachian Power Company 04711 VA0000370 Kammer Ohio Power Company 02149 WV0005291 Kanawha River Appalachian Power Company 08405 WV0001066 Lieberman Southwestern El ect ric Power 06627 LA0002917 

# ., Company Mitchell Ohio Power Company 01236 WV0005304 Mountaineer Appalach i an Power Company 04543 WV0048500,WV0077038 Muskingum River Oh i o Power Compa ny 09325 OIB00003*0D No rtheastern 1 & 2 Public Service Company of Oklahoma 06933 OK0034380 and 3 & 4 Oklaunion P ublic Service Company of Okl ahoma 00376 TX0087815 Picway Columbus Southern Power Company 05802 41BOOOOO*GD Pirkey Southwestern Electric Power 06635 TX0087726 Company Rivers ide P ublic Service Company of Okl ahoma 03274 OK0002429 Roc k port I ndiana Michigan Power Company 01671 IN0051845 Philip Sporn Appalachian Power Company 05283 WV0001058 Tanners Creek I ndiana Michigan Power Company 05872 IN0002160 Welsh Southwestern El ectric Power 06739 TX0063215 Company Wilkes Southwestern Electric Power 07535 TX0062006 Company
We have identified certa in record documents which we believe contain information reported by, or derived from data or information reported by, one or more ofour facilities

. EPA has redacted all or portions ofthese documents as "confidential business information" (CBI).
We are requesting that you provide to us all information related to the facil ities listed above (including information that EPA has derived from information obtained from our facilities and from all other sources, and including facility-sp ecific or facility-derived information in input fil es 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 Descript ion FGD I nput Tab le Current Systems FGD Input Tab le Pl anned Systems FGD High F l ow Ana lysis Bottom Ash MDS Conveyance O&M Costs Bottom Ash I ntermediate Storage O&M Costs Bottom Ash Wet Sluicing O&M Costs Bottom Ash Remote MDS Capita l Costs Bottom Ash Wet Sluici ng O&M Costs Bottom Ash Remote MDS Capita l Costs CBI Steam Electric Pollutant Load i ng Mode l for FGD Wastewater1984 {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 Futu re 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 Futu re Profile -I PM Only CBI Bottom Ash Management Determination Calculations loads Calculation Database- Questionnaire and I PM CBI EA Report Calculations Database CBI loads Calculat ion Database for Options 3a, 3b and 4a CBI Memorandum to the Steam Electric Rulemaking Record : New Source Performance Standards Costing Memorandum and Attachment CBI Increme ntal Costs and Pollutant Removals for Pro posed ElGs Report and Attachment CBI Incre mental Costs and Pollutant Removals
Please include all information from these documents that relates to our facilities. For example, our facilities suppli ed 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 f rom 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 co lumn 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 oflaw that I am a responsible corporate official or his/her authorized representative of America n Electric Power and am authorized to request confidential business informa tion 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 penaltiesfor submitting false information including the possibility offines 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. Th ank you very much for your help . Sincerely,

John M. McManus Vice President

- Environmental Services American Electr ic Power

cc: T.W. Lohner