### 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 USEPA Headquarters Mr. James Covington USEPA Headquarters July 23, 2013 

# SOUTHERN 

# A COMPANY

Urgent: Request for Release ofInformation FromDocket No. EPA-HQ-OW-2009-0819 ***PROMPT RESPONSE REQUESTED*** DearMr. Jordan and Mr. Covington: Our facilities provided information that is being used to informEPA's development ofthe proposed revision ofthe effluent limitations guidelines and standards for the steamelectric powergenerating point source (ELG Rule). The facilities listed below eitherresponded to earlierELG Rule questionnaires to the industry orprovided 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 MillerJr AL0027146 Georgia Power Company Bowen GA0001449 Harlee Branch GA0026051

Hammond GA0001457 Edwin I Hatch GA0004120 Kraft GA0003816 JackMcDonough GA0001431Ron Jordan James Covington July 23, 2013 Page 2

Mcintosh McManus Mitchell Scherer Vogtle Wansley

Yates GulfPower 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 orinformation reported by, one ormore ofourfacilities. EPAhas redacted all or portions ofthese 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 EPAhas derived from information obtained from our facilities and from all other sources, and including facility-specific orfacility-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 InputTable Planned Systems 1959 (DCN SE01825A55) FGD High Flow AnalysisRon 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 BottomAsh MDS Conveyance O&M Costs BottomAsh Intermediate Storage O&M Costs BottomAsh Wet Sluicing O&M Costs BottomAsh Remote MDS Capital Costs BottomAsh Wet Sluicing O&M Costs BottomAsh Remote MDS Capital Costs CBI SteamElectric Pollutant Loading Model for FGD Wastewater CBI SteamElectric Pollutant Loadings Model for Ash Transport Water CBI Future Profile FGD Loads CBI SteamElectric Cost Model (FGD and Ash**Tran~ort** Water) CBI Steam Electric Cost Model (FGD and Leachate) CBI Data Dictionary for the FGD and Ash CostModel CBI Loads Calculation Database for O_IJ_tions 1, 2, 3, 4, and 

### 5 CBI Loads Calculation Database Future Profile- IPM Only CBI BottomAsh 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 SteamElectric 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 ourfacilities. Forexample, our facilities supplied information about existing control technologies. Through this request, we are requesting not only the control technologies information supplied by ourfacilities, but also control technologies information about ourfacilities derived from other sources, as well as all EPA-developed information relating to ourcontrol technologies, including EPA's assessments offuture technology choices for ourfacilities based on the various rule options. Foreach 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 ofall 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 ofour CBI designations. Because you are providing the information only to us, there is no breach ofconfidentiality and no waiver ofCBI protections. Furthermore, we are not requesting CBI information, or CBI-derived information, from other companies that may have furnished data orinformation appearing in the listed documents. We are requesting only information related to our own facilities. We have done ourbest to be selective in asking for facility-specific information. The information we are seeking, however, is critical to ourreview of, and preparation ofcomments 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 electronicform (CD) to: Donna B. Hill 600 18th Street North Mail Bin 14N-8195 Birmingham, AL35203 205-257-5234 

### Icertify underpenalty oflaw that Iam aresponsible corporate official orhis/herauthorized representative of Southern Company andam authorized to request confidential business information on behalf of

mycompany. Icertify that Southern Company is the majority owneror the operator for eachfacility (andfor each unitat eachfacility)for which we are requesting confidential business information. Iam aware that there may be significantpenaltiesfor submitting false information including thepossibility of fines and imprisonment,pursuant to 18 U.S. C.§ 

### 1001.

Chris M. Hobson ChiefEnvironmental Officer Senior Vice-President, Research 

### & Environmental Affairs

Cc: Donna Hill, dbhill @southemco.com Ms. Jezebele Alicea-Virella, alicea.jezebele@epa.gov