Chris M. Hobson 

Chief Environmental Officer 

SVP Research and Environmental Affairs 

600 North 18th Street, 14N-8195 

Birmingham, Alabama 35203 

cmhobson@ southernco.com 

205.257.2812 

Mr. Ronald Jordan 

USEP A Headquarters 

Mr. James Covington 

USEPA Headquarters 

July 23, 2013 

SOUTHERN A 

COMPANY 

Urgent: Request for Release of Information From Docket No. EPA-HQ-OW-2009-0819 

***PROMPT RESPONSE REQUESTED*** 

Dear Mr. Jordan and Mr. Covington: 

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: 

Operating Company and Facility Name Facility NPDES Number 

Alabama Power Company 

Barry AL0002879 

Gadsden AL0002887 

E C Gaston AL0003140 

Gorgas AL0002909 

Greene County AL0002917 

James H Miller Jr AL0027146 

Georgia Power Company 

Bowen GA0001449 

Harlee Branch GA0026051 

Hammond GA0001457 

Edwin I Hatch GA0004120 

Kraft GA0003816 

Jack McDonough GA0001431 
Ron Jordan 

James Covington 

July 23, 2013 

Page 2 

Mcintosh 

McManus 

Mitchell 

Scherer 

Vogtle 

Wansley 

Yates 

Gulf Power Company 

Crist 

Scholz 

Lansing Smith 

Mississippi Power Company 

Victor J Daniel Jr 

Jack Watson 

Southern Power Company 

Curtis H Stanton Energy Center 

Rowan 

Southern Nuclear Company 

Vogtle 

Edwin I Hatch 

GA0003883 

GA0003794 

GA0001465 

GA0035564 

GA0026786 

GA0026778 

GA0001473 

FL0002275 

FL0002283 

FL0002267 

MS0024511 

MS0002925 

N/A 

NCG500582 

GA0004120 

GA0026786 

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 Short Description Doc. ID No. (DCN No.) 

1959 (DCN SE01825A53) FGD Input Table Current Systems 

1959 (DCN SE01825A54) FGD Input Table Planned Systems 

1959 (DCN SE01825A55) FGD High Flow Analysis 
Ron Jordan 

James Covington 

July 23, 2013 

Page 3 

EPA-HQ-OW -2009-0819 

Doc. ID No. (DCN No.) 

1959 (DCN SE01825A73) 

1959 (DCN SE01825A74) 

1959 (DCN SE01825A75) 

1959 (DCN SE01825A76) 

1959 (DCN SE01825A77) 

1959 (DCN SE01825A78) 

1977 (SE02900) 

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, 2252.1 (SE01957, 

SE1957Al) 

2256 (SE01957) 

Short Description 

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 

CBI Steam Electric Pollutant Loadings Model for Ash Transport Water 

CBI Future Profile FGD Loads 

CBI Steam Electric Cost Model (FGD and Ash Tran~ort Water) 

CBI Steam Electric Cost Model (FGD and Leachate) 

CBI Data Dictionary for the FGD and Ash Cost Model 

CBI Loads Calculation Database for O_IJ_tions 1, 2, 3, 4, and 5 

CBI Loads Calculation Database Future Profile- IPM Only 

CBI Bottom Ash Management Determination Calculations 

Loads Calculation Database - Questionnaire and IPM 

CBI EA Report Calculations Database 

CBI Loads Calculation Database for O_Qtions 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. 
Ron Jordan 

James Covington 

July 23, 2013 

Page4 

Please send the facility-specific information that we have requested above in electronic form 

(CD) to: 

Donna B. Hill 

600 18th Street North 

Mail Bin 14N-8195 

Birmingham, AL 35203 

205-257-5234 

I certify under penalty of law that I am a responsible corporate official or his/her authorized 

representative of Southern Company and am authorized to request confidential business information 

on behalf of my company. I certify that Southern Company 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. 

Chris M. Hobson 

Chief Environmental Officer 

Senior Vice-President, Research & Environmental Affairs 

Cc: Donna Hill, dbhill @southemco.com 

Ms. Jezebele Alicea-Virella, alicea.jezebele@epa.gov