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

To: Castronovo.Alison <Alison.Castronovo@we

- energies.com>

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

Date: 7/24/2013 11:41 AM Subject: RE: Urgent: Request for Release of Information from Docket No. EPA

- HQ

- OW

- 2009

- 0819 for Wisconsin Electric Power Company facilities

Greetings Ms. Castronovo!

EPA received your request for "all information related to WeEnergies' 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 E lectric ELG rulemaking.

· Wisconsin Electric Power Company, Milwaukee County Power Plant

· Wisconsin Electric Power Company, Pleasant Prairie Power Plant

· Wisconsin Electric Power Company, Port Washington Generating Station

· Wisconsin Electric Power Company, Presque Isle Power Plant

· Wisconsin Electric Power Company, Oak Creek Power Plant

· Wisconsin Electric Power Company, Elm Road Generating Station/Oak Creek Expansion Project

· Wisconsin Electric Power Company, Valley Power Plant EPA has made available substantial data and other information relating to the proposed rule in the docket for the steam elect ric power generating effluent guidelines rulemaking, including data relating to the spec ific 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 cost s, 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 u nder separate

corres pondence 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/remo val models, and environmental assessment models. EPA is planning to provide a description of how each plant can use available data to make re levant calculations, such as how to calculate pollutant loadings. EPA believes these data, in addition to the publ icly available data already provided in the docket, provide you with sufficient information to understand any effects the proposed rule may have on your facilities a nd to comment effectively on the proposed rule, and this data represents the extent of info rmation 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 n ame of corporate entity] and am authorized to request confidential business information on behalf of my company. I certify that [f ill 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 confidentia l business information. I am aware that there may be significant penalties for submitting f alse 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 th e requested

information. Ma iling 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

Pho ne 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: Castronovo.Alison [mailto:Ali son.Castronovo@we

- energies.com] Sent: Monday, June 24, 2013 1:03 PMTo: Covington, James; Jordan, Ronald

Cc: Alicea, Jezebele Subject: Urgent: Request for Release of Information from Docket No. EPA

- HQ

- OW

- 2009

- 0819 for Wisconsin Electric Power Company facil ities

VIA ELECTRONIC MAIL: RETURN RECEIPT REQUESTED, to jordan.ronald@epa.gov<mailto:jordan.ronald@epa.gov> and covington.james@epa.gov<mailto:covington.james@epa.gov>, cc: alicea.jezebele@epa.gov<mailto:alicea.jezebele@epa.gov>

Mr. Ronald Jordan USEPA Headquarters

Mr. James Covington USEPA Headquarters

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 bei ng 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 questionnai res 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: Wisconsin Electric Power Company, Milwaukee County Power Plant, WPDES Permit No. WI

- 0044938

- 5 (General Permit to discharge noncontact cooling water or condensate and boiler water). Wisconsin Electric Power Company, Pleasant Prairie Power Plant, WPDES Permit No. WI

- 0043583

- 06

- 1. Wisconsin Electric Power Company, Port Washington Gene rating Station, WPDES Permit No. WI

- 0000922

- 07

- 0. Wisconsin Electric Power Company, Presque Isle Power Plant, NPDES Permit No. MI0006106. Wisconsin Electric Power Company, Oak Creek Power Plant (identified as South Oak Creek in the Steam Electric Questionn aire), WPDES

Permit No. WI

- 0000914

- 07

- 0. Wisconsin Electric Power Company, Elm Road Generating Station/Oak Creek Expansion Project, WPDES Permit No. WI

- 0000914

- 07

- 0. Wisconsin Electric Power Company, Valley Power Plant, WPDES Permit No. WI

- 0000931

- 05

- 0.

We have identified certain record documents which we believe contain information reported by, or derived from data or informatio n reported by, one or more of our facilities. EPA has redacted all or portions of these documents as "confidential business infor mation" (CBI). We are requesting that you provide to us all information related to the facilities listed above (including information that E PA has derived from information obtained from our facilities and from all other sources, and including facility

- spe cific 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)

Bott om 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 Wa ter)

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

2158 (DCN SE02990)

CBI Loads Preparation Database for Chesapeake Bay and Great Lakes Analysis

2159 (SE03508)

CBI Loads Calculation Database Future Profile

- IPM Only

2162 (DCN SE03571)

CBI Chesapeake Bay and Great Lakes Proximity Database

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 (S E02129)

CBI Memorandum to the Steam Electric Rulemaking Record: New Source Performance Standards Costing Memorandum and Attachment2252, 2252.1 (SE01957, SE1957A1)

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

225 6 (SE01957)

CBI Incremental Costs and Pollutant Removals

Please include all information from these documents that relates to our facilities. For example, our facilities supplied inf ormation about existing control technologies. Through this request, we are requesting not only the control technologies informatio n 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 abbreviatio n used throughout the entire document; and (2) a list of all formulas applie d 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 informa tion 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 list ed 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 c omments 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. Than k you very much for your help.

Sincerely,

Alison Castronovo Environmental Engineer We Energies
333 W. Everett Street, A231 Milwaukee, WI 53203 Office: (414) 221

- 4337

Email: alison.castronovo@we

- energies.com<mailto:alison.castronovo@we

- energies.com>