From: "Alicea, Jezebele" <Alicea.Jezebele@epa.gov> 

To: "twlohner@aep.com" <twlohner@aep.com> 

CC: "Jordan, Ronald" <Jordan.Ronald@epa.gov>, "Covington, James" <Covington.James@epa.gov> 

Date: 7/24/2013 11:42 AM 

Subject: RE: Urgent: AEP Request for Release of ELG CBI Information 

Greetings Mr. Lohner! 

EPA received your request for "all information related to American Electric Power (AEP) facilities outlined below, including information that 

EPA has derived from information obtained from these facilities and from all other sources, and including facility-specific or facility-derived 

information in input files to" certain documents found on the docket for the Steam Electric ELG rulemaking. 

· Appalachian Power Company- John E Amos, Clinch River, Glen Lyn, Kanawha River, Mountaineer, Philip Sporn 

· Cardinal Operating Company - Cardinal 

· Columbus Southern Power Company - Picway, Conesville 

· Indiana Michigan Power Company - Rockport, Tanners Creek 

· Kentucky Power Company - Big Sandy 

· Ohio Power Company - General James M Gavin, Kammer, Mitchell, Muskingum River 

· Public Service Company of Oklahoma - Northeastern 1&2 and 3&4, Oklaunion, Riverside 

· Southwestern Electric Power Company - Flint Creek, Lieberman, Pirkey, Welsh, Wilkes 

EPA has made available substantial data and other information relating to the proposed rule in the docket for the steam electric power generating 

effluent guidelines rulemaking, including data relating to the specific facility(ies) you identified, data about other plants where that data is not 

claimed as confidential business information or could lead to the disclosure of confidential business information, equations used to estimate 

several key outputs such as costs, and a description of the various methodologies used by EPA (e.g., costing methodologies, pollutant loadings 

methodologies, etc.). In addition to this publicly available data, in response to your request, EPA is planning to forward under separate 

correspondence additional data that provides plant-specific compliance costs and pollutant removals that EPA estimated would be attributable to 

the proposed rule, as well as plant-specific input values that were used in EPA's cost models, pollutant loadings/removal models, and 

environmental assessment models. EPA is planning to provide a description of how each plant can use available data to make relevant 

calculations, such as how to calculate pollutant loadings. EPA believes these data, in addition to the publicly available data already provided in 

the docket, provide you with sufficient information to understand any effects the proposed rule may have on your facilities and to comment 

effectively on the proposed rule, and this data represents the extent of information that EPA can make available to you without disclosing, 

directly or indirectly, information claimed as confidential business information by other sources. 

To ensure that confidential business information is only released to an authorized official, EPA requires that you submit your request on company 

letterhead using the certification statement below. The certifying official must be a responsible corporate official or his/her authorized 

representative. 

Certification Statement 

"I certify under penalty of law that I am a responsible corporate official or his/her authorized representative of [fill in name of corporate entity] 

and am authorized to request confidential business information on behalf of my company. I certify that [fill in name of corporate entity] 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. " 

In addition, you must provide the name (if not the certifying official) and mailing address (no P.O. boxes) for receipt of the requested 

information. Mailing addresses must be accessible to a commercial courier service (e.g., Federal Express). 

Have a blessed day! 

Sincerely, 

[MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]] 

Jezebele Alicea-Virella 

Environmental Engineer 
Phone No: 202-566-1755 

Fax No: 202-566-1053 

EPA-Office of Water/OST/EAD 

Mail Code: 4303T 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460 

[MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]][MC900437627[1]] 

From: twlohner@aep.com<mailto:twlohner@aep.com> [mailto:twlohner@aep.com] 

Sent: Wednesday, June 26, 2013 11:08 AM 

To: Jordan, Ronald; Covington, James 

Cc: Alicea, Jezebele 

Subject: Urgent: AEP Request for Release of ELG CBI Information 

VIA ELECTRONIC MAIL: RETURN RECEIPT REQUESTED, to 

 jordan.ronald@epa.gov<mailto:jordan.ronald@epa.gov>, covington.james@epa.gov<mailto:covington.james@epa.gov> 

alicea.jezebele@epa.gov<mailto:alicea.jezebele@epa.gov> 

Mr. Ron Jordan 

USEPA Headquarters 

Mr. James Covington 

USEPA Headquarters 

Ms. Jezebele Alicea-Virella 

USEPA Headquarters 

Urgent: Request for Release of Information 

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

***PROMPT RESPONSE REQUESTED*** 

Dear Mr. Ron Jordan and Mr. Covington: 

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: 

 List of AEP Facilities 

Plant 

Operating Company 

EPA ID Number 

NPDES Permit Number/s 

John E Amos 

Appalachian Power Company 

09161 

WV0001074, WV0116254, WV0077046 

Big Sandy 

Kentucky Power Company 

06118 

KY0000221 

Cardinal 

Cardinal Operating Company 

03265 

0IB00009*QD 
Clinch River 

Appalachian Power Company 

07727 

VA0001015 

Conesville 

Columbus Southern Power Company 

01402 

0IB00013*ID, 0IN00101*GD 

Flint Creek 

Southwestern Electric Power Company 

03978 

AR0037842 

General James M Gavin 

Ohio Power Company 

04706 

0IB00006*JD 

Glen Lyn 

Appalachian Power Company 

04711 

VA0000370 

Kammer 

Ohio Power Company 

02149 

WV0005291 

Kanawha River 

Appalachian Power Company 

08405 

WV0001066 

Lieberman 

Southwestern Electric Power Company 

06627 

LA0002917 

Mitchell 

Ohio Power Company 

01236 
WV0005304 

Mountaineer 

Appalachian Power Company 

04543 

WV0048500, WV0077038 

Muskingum River 

Ohio Power Company 

09325 

0IB00003*OD 

Northeastern 1 & 2 and 

3 & 4 

Public Service Company of Oklahoma 

06933 

OK0034380 

Oklaunion 

Public Service Company of Oklahoma 

00376 

TX0087815 

Picway 

Columbus Southern Power Company 

05802 

4IB00000*GD 

Pirkey 

Southwestern Electric Power Company 

06635 

TX0087726 

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 Company 

06739 

TX0063215 

Wilkes 

Southwestern Electric Power Company 

07535 

TX0062006 

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 No.) 

Short Description 

1959 (DCN SE01825A53) 

FGD Input Table Current Systems 

1959 (DCN SE01825A54) 

FGD Input Table Planned Systems 

1959 (DCN SE01825A55) 

FGD High Flow Analysis 

1959 (DCN SE01825A73) 

Bottom Ash MDS Conveyance O&M Costs 

1959 (DCN SE01825A74) 

Bottom Ash Intermediate Storage O&M Costs 

1959 (DCN SE01825A75) 

Bottom Ash Wet Sluicing O&M Costs 

1959 (DCN SE01825A76) 

Bottom Ash Remote MDS Capital Costs 
1959 (DCN SE01825A77) 

Bottom Ash Wet Sluicing O&M Costs 

1959 (DCN SE01825A78) 

Bottom Ash Remote MDS Capital Costs 

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, SE1957A1) 

CBI Incremental Costs and Pollutant Removals for Proposed ELGs Report and Attachment 

2256 (SE01957) 

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 50 days left in the comment period, we ask that 

you expedite this request. 

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. 

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