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 Amer ican Electric Power (AEP) facilities outlined below, including in formation that

EPA has derived from informati on obtained from these facilities and from all ot her 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 Ri ver, 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 Ja mes M Gavin, Kammer, Mitchell, Muskingum River

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

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

EPA has made available substantial data a nd other information relating to the proposed rule in the docket for the steam electri c power generating
effluent guidelines rulemaking, including data relating to the specific facility(ies) you identifie d, data about other plants w here that data is not

claimed as confidential business information or could lead to the disclosure of conf idential business information, equations us ed to estimate
several key outputs such as costs, and a description of the various methodologies used by EPA (e.g., costing methodologies, pol lutant loadings
methodologies, etc.). In addition to this publicly available data, in response to y our request, EPA is planning to forward und er separate correspondence additional data that provides plant-specific complia nce costs and pollutant removals that EPA estimated would be attributable to
the proposed rule, as well as plant-specific input values that we re used in EPA's cost models, pollutant loadings/removal model s, and
environmental assessment models. EPA is pl anning to provide a description of how each plant can use available data to make rele vant calculations, such as how to calculate pollu tant loadings. EPA believes these data, in addition to the publicly available data already provided in
the docket, provide you with sufficient in formation to understand any effects the pr oposed rule may have on your facilities and to comment effectively on the proposed rule, and this data represents the ex tent of information that EPA ca n make available to you without disclosing,
directly or indirectly, information claimed as confidential business information by other sources.

To ensure that conf idential business information is only re leased 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/he r 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 nam e of corporate entity]
and am authorized to request confidential business information on behalf of my compan y. I certify that [f ill in name of corpor ate 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 submitti ng false information including the possibility of fines and impr isonment, pursuant

to 18 U.S.C. § 1001. "

In addition, you must provide the name (i f not the certifying official) and mailing a ddress (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 EngineerPhone 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@ep a.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 inform ation that is being used to inform EPA' s development of the proposed revision of t he effluent
limitations guidelines and standards for the steam electric pow er generating point source (ELG Rule). The facilities listed be low either
responded to earlier ELG Rule questionnaires to the industry or pr ovided information to you through other means, such as site v isits 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*QDClinch 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

01236WV0005304

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 SpornAppalachian 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 cont ain information reported by, or de rived from data or informati on reported by,

one or more of our facilities. EPA has red acted all or portions of these documents as "confidential business information" (CB I).

We are requesting that you provide to us all information relate d to the facilities listed above (including information that EPA has derived from

information obtained from our facilities a nd from all other sources, and including f acility-specific or f acility-derived inform ation 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 Costs1959 (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 fo r Options 1, 2, 3, 4, and 5

2159 (SE03508)

CBI Loads Calculation Database Future Profile - IPM Only

2191 (SE03879)

CBI Bottom Ash Management De termination 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 S ource Performance Standards Cos ting Memorandum and Attachment

2252, 2252.1 (SE01957, SE1957A1)

CBI Incremental Costs and Pollutant Remova ls for Proposed ELGs Report and Attachment

2256 (SE01957)

CBI Incremental Costs and Pollutant RemovalsPlease include all information from these documents that relate s to our facilities. For exam ple, our facilities supplied infor mation about existing
control technologies. Through this request, we are requesting not only the control t echnologies information supplied by our fa cilities, but also
control technologies information about our facilities derived from other sources, as we ll as all EPA-developed information rela ting to our control
technologies, including EPA's assessments of future technolog y choices for our facilities based on the various rule options.

For each document, as appropriate, please also include: (1) a le gend which explains each column heading and each abbreviation used throughout

the entire document; and (2) a list of all fo rmulas applied in the document and a lege nd for any abbreviations used in the form ulas. 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 reques ting CBI information, or CBI-derived informati on, from other
companies that may have furnished data or information appearing in the listed documen ts. We are requesting only information re lated to our

own facilities.

We have done our best to be se lective in asking for facility-specific informati on. 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 peri od, we ask that
you expedite this request.

If you have any questions about this reque st, please call or email me. I look forward to your prompt response. Thank you very much for your
help.

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