October 30, 2014 Tim Lohner UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WAS HINGTON , D

.C

. 20460

American Electric Power 1 Riverside Plaza Columbus, OH 43215 Dear Mr. Lohner: OFF ICE OF WA TER

The U .S. Environmental Protection Agency ("EPA"), under the authority ofthe Clean Water Act, as amended (the "Act"), 33 U.S.C. 1251 et seq., proposed revisions to the effluent limitations guidelines and standards (" ELGs") for the steam electric power generating point source category on June 7 , 2013. EPA received comments submitted by American Electric Power ("AEP") regarding the proposed ELGs on September 20,2013. Based on our review of AEP's comments, as well as those ofthe Utility Water Act Group ("UWAG"), which AEP expressly supports, we have concluded that additional information is needed to evaluate the comments with respect to flue gas desulfurization ("FGD") wastewater characterization and treatment. Therefore, pursuant to Section 308 ofthe Act, 33 U.S.C. 1318, EPA requests that you provide the Agency with any pilot-scale FGD wastewater treatment data collected from AEP's John E. Amos Plant since January 1, 2010. Additional details regarding how you should submit the data are provided in Enclosure 1. For each ofthe pilot tests identified, EPA is requesting the following information: 1. Please identify when the pilot testing was conducted. 2. Please identify and describe the objectives ofthe pilot test. 3. Please provide a description ofthe wastewater used in the pilot testing (e

.g., describe any treatment ofthe FGD wastewater prior to it being transferred to the technologies evaluated as part ofthe pilot testing)

. 4. Please describe any changes made to the pretreatment configuration/operations during the pilot testing and when these changes occurred. For example, describe any additional pretreatment steps that were added prior to the wastewater being

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.gov Recycled/Recyclable • Pri nted w ith Vegetable O il Bas ed I nks o n 100% Postco n sume r, Process C hlorine Free Recycl ed Papertransferred to the pilot-test technologies. Include a detailed description of the pretreatment technology (or changes to the technology ) including chemicals and dosage rates , and the date the changes were made . For any changes made to the pretreatment system, provide an explanation as to wh y the changes were made. 5. Please provide a description of all the wastewater treatment technologies evaluated as part of the pilot testing. Please also note any changes made to the treatment technologies or additional pretreatment added, including by any vendors, to the systems during the pilot testing, such as to optimize performance of the technology. For any changes made to the treatment technologies , p r ovide an explanation as to why the changes were made and identify the date the changes were made. 6. Please identify the amount of wastewater treated through each of the treatment technologies (including any pretreatment system(s)) and note any changes throughout the pilot test duration. For any changes in the wastewater flow rate treated, please explain why there was an increase / decrease in the flow rate. 7. Please identify any wastestreams or dilution streams that were / are comming l ed with the FGD wastewater prior to treatment. Identify the percent contribution of the other wastestreams / dilution streams compared to the FGD wastewater that was/is treated in the pilot test. 8. Please provide a simplified process flow diagram of the entire pilot test configuration that identifies the generation of the FGD wastewater , a ny pretreatment systems , and

all technologies evaluated. Please note that this simplified diagram should identify the operation of the pilot test before and after any changes were made and the date changes were made should be noted on the diagram. See Enclosure 1 for an example of a simplified process flow diagram. 9. Please provide a detailed process flow diagram for each wastewater treatment technology evaluated as part of the pilot testing including any vendor installed pretreatment steps starting with the wastewater supplied to the vendor by AEP. The diagram should show all the specific sampling l ocations and chemical addition points for that technology. Please note that each diagram sh o uld include specific sampling location names so the analytical data can be matched s pecifically to each technology evaluated. See Enclosure 1 for an example of a detailed process flow diagram. 10. E PA requests that AEP provide all arsenic , mercury , selenium, nitrate / nitrite, and ammonia concentration data for the following wastestreams for the entire time period that the pilot test was conducted (see Enclosure 2 and Attachment 1 ("Analytical DataTable" workbook) for details on providing the analytical data): a. FGD purge stream (e.g., prior to any treatment or dilution); b. Influent to pilot testing (e.g., after all pretreatment, but before treatment in the technologies evaluated in the pilot test); and c. T reated wastewater from each technology evaluated (Note: If any technologies are operated as treatment trains (i.e. , one technology is downstream of another technology) then the data for each stage in the treatment train should be provided).
11. Additionally, EPA requires certain supplemental information to further evaluate the quality ofthe data. Please provide the data listed ir). Enclosure 2. 12. Please provide the type and source ofcoal (i.e., mine name and location) used at the plant each day starting one month prior to the beginning ofthe pilot test and continuing through the entire pilot test duration. In addition, please provide the sulfur and chlorine content ofthe coal used at the plant for each day ofthis period, if available. For days where coal blending occurred, please note the percentage ofeach type ofcoal used. See Attachment 2 (Supplemental Data workbook, tab titled "Coal Data") for the format ofthe data requested by EPA.
13. Please provide the following information for each day within the rapge of sampling results that are being provided, if available (See Attachment 2, Supplemental Data workbook): a. Chloride concentration, pH, total suspended solids ("TSS") , and average daily oxidation-reduc tion potential ("ORP") values within each FGD scrubber system (tab titled "FGD System Information"); b. Chloride concentration, pH, TSS, and average daily ORP values for the influent to the FGD wastewater treatment system (prior to any treatment/chemical addition) (tab titled "FGD WWT Influent"); and c. Electric generat ion output (MW-hr) for each generating unit serviced by a FGD system (tab titled "Electricity Generation" ). Additionally, EPA requests that you identify all other pilot tests conducted between January 1 , 2010 and the present that evaluated the treatment ofFGD wastewater at Amos Station or any other AEP power plants. For each ofthe additional pilot test identified, you must provide the following information:

• Where was the test conducted; • When was the test conducted; • What technologies were evaluated (company and technology); and • What were the objectives ofthe test?The information and data responsive to the items above should be received by EPA !!Q later - than November 21,2014. EPA has determined that it requires such infonnation and data in order to assist with the development of its revised steam electric ELGs, and the Agency is under a consent decree to sign a decision taking final action on the rulemaking by September 30, 2015. The Agency also believes that all the information and data requested is readily available to AEP, and thus EPA's request is reasonable. You must provide t he information and data to EPA pursuant to the federal law cited above. Moreover, it is in your best interest to ensure that

any information on which EPA may base its regulations presents an accurate and representative picture of the industry. We appreciate your cooperation in providing all the information and data requested. Please be advised that legal action, resulting in penalties , could be taken against you should you fail to fully cooperate with this request. Enclosure 1 of this letter provides example process flow diagrams that should be provided in response to this request. Enclosure 2 of this letter provides details regarding how the analytical data and supplemental information should be provided to EPA. Enclosure 3 of this letter provides the statutory authority on which this request is based and explains your legal rights to protection of confidential business information. Enclosure 4 is a notice of EPA's intention to allow selected contractors access to all information, including confidential information that you submit. EPA will make your information available to EPA contractors to the extent they need such information to carry out any work required by their contracts. As noted in Enclosure 4, if you wish to comment on this action, any such comment must be received in writing by EPA within 10 days of your receipt of this notice. Please send these comments to the address listeq in Enclosure 4. If you have any questions or concerns , please contact Phillip Flanders via e-mail at flanders.phillip@epa.gov or by phone at 202-566-8323. We appreciate your help in providing the information described above in a timely manner. Sincerely, Robert K. Wood, Director Engineering & Analysis Division ( 4303T) EnclosuresEnclosure1Technology1_,.[Providecompanyandtechnology]SystemAddedon6/15/14Technology2SystemAddedon....Vendor......[Providecompany6/l/14Pretreatmentandtechnology]jPretreatmentPretreatmentStep2Step1[Providegeneral__...FGDSystem......[Providegeneraldescription(e.g.,Technology3description(e.g.,Chemical.....[ProvidecompanyPond))precipitation)andtechnology]Technology4......[Providecompanyandtechnology}Figure1.ExampleSimplifiedProcessFlow DiagramforPilotTestConfigurationTechnology

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### Enclosure 2 Guidelines for**~ubmitting** 

### Analytical Data for the Steam Electric Power Generating Effluent Guidelines Rulemaking

This document provides guidance regarding the submission of analytical da ta in response to the proposed Steam Electric ELGs , including the type of supplemental information that should be provided along with any analytical data, in order to ensure that EPA can use the data to inform its analyses for the final action. The data you submit should reflect typical operating conditions and be representative ofproperly operating treatment systems. Data you submit should be relevant to 

### flue gas desulfurization wastewater. Important Considera tions • The data provided should include both trea ted, partially treated, and untreated wastewater
. • Pollutant data should be collected using sufficiently sensitive, EPA-approved analytical methods in 40 CFR Part 136 appropriate for the pollutant concentrations present in the wastewater
. Data Submission Format and Criteria To facilitate EPA's analysis and use ofthe analytical data, the data should be submitted using the format provided in the Microsoft Excel Workbook titled " Analytical Data Table." The Analytical Data Table workbook provides the content, structure, and format for the analytical data submission. Included within the workbook are two separate spreadsheets. The spreadsheet titled "Data Table Structure" provides the table for entering the analytical data

. The spreadsheet titled "Example Data Table" includes three example entries to provide some context ofhow to populate each ofthe fields in the data table. Additionally, the sprea dsheet titled "Field Descriptions" describes each field included in the data table'. Provide the individual sample results associated with the sam p ling locations. Entries that average multiple results for a sampling point are oflimited u se. The following is the information that should be provided for each individual sampling result, as applicable (see the "Field Descriptions" spreadsheet for more details): • Plant Survey ID (from the Questionnaire for the Steam Electric Effluent Guidelines); • Plant Name; • Date Sample Collected; • Analyte (for metals, including whether it is total recoverable or dissolved) ; • CAS Number; • Analytical Method; • Type of Sample Collected (e.g., grab, 24-hour composite); • Type of Sample Analyzed (e.g., total recoverable, dissolved) • Units ; • Non-Detect Indicator; • Concentration;• J-Value Concentration; • Detection Limit; • Report in g Limit; • Dilution Factor; • Qualifiers; • Qualifier Description; • Wastestream represented by result; • F lo w rate ; and • Sample point description.

For EPA to eva lu ate whether the data provided are valid and of sufficient quality for use in the loadings analyses and/or limitations development , the fo llo wing supp l ementa l information

should accompany any submitted analytical data , as applicable: • Chemicals and dosages added to the treatment system, including location of injection points ( see Attachment 2 (Supp l emental Data workbook , tab titled " Chemical Dosages " ) ; • Laboratory report s associated with the sampling data; and • Identification of whether any data or supplemental information submitted to EPA is considered confidential business information.Enclosure 3

Legal Authority

This request for information is made under authority provided by Section 308 ofthe Federal Water Pollution Control Act, as amended, 33 U.S.C. 1318. Section 308 provides, in part, that, "Whenever required to carry out the objective ofthis Act, including but not limited to
... developing or assisting in the development of any effluent limitation, or other limitation, prohibition, or effluent standard, pretreatment standard, or standard ofperformance under this Act

. . . the Administrator shall require the owner or operator of any point source to (i) establish and maintain such records, (ii) make such reports, (iii) install, use, and maintain such monitoring equipment or methods

... , (iv) sample such effluents

... , and (v) provide such other information as [she] may reasonably require."

Confidentiality

A business ("you") may not withhold information from EPA on the grounds that it is confidential. You may, however, if you desire, assert a business confidentiality claim covering part or all ofthe information that you furnish to EPA EPA regulations concerning confidential business information are contained in 40 CFR Part 2, Subpart B. The manner of asserting such a claim is specified in 40 CFR 2.203(b ). Information covered by such a claim will be disclosed by EPA only to the extent, and by means ofthe procedures, set forth in Subpart B. Ifyou wish to claim as confidential any ofthe information covered by the enclosed request, you must do so at the time you submit the information to EPA Ifno such claim accompanies the information when EPA receives it, EPA may make the information available to the public without further notice to you. EPA will notify you in the event that a request is made for release ofinformation that you have claimed to be confidential or EPA otherwise decides to make a determination as to whether or not such information is entitled to confidential treatment. At that time, EPA will request that you substantiate any claim you have made that information is confidential. Therefore, we encourage you to consult 40 CFR Part 2, and to claim as confidential only those items that you truly believe satisfy the criteria for confidentiality. Note that effluent data are not eligible for confidential treatment (see 40 CFR 2.302).Enclosure 4 Notice of Intent to Transfer Confidential Information to Selected EPA Contractors EPA intends to grant access to any confidential information collec t ed as part of the steam electric effluent guidelines rulemaking to selected EPA contractors. In accordance with 40 CFR Sections 2.301(h)(2-3) , 2.302(h)(2

- 3), and 2.305(h)(2-3), EPA may

a ll ow those contractors identified below access to all data (including data claimed to be confidential) collected as part of this data request. Transfer of this information to these

contractors is necessary in order for the contractors to assist EPA in performing technical,

statistical, and environmental analyses to support the development of effluent limitations guidelines and standards for the Steam E lectric Power Generating industry. The contractors and subcontractors that will be providing support to EPA during the development of these regulations are listed below: EPA Office EPA Contract Receiving Contractor Name No. TypeofSupport Support Office of Water/ Eastern Research Group, Inc. EP-C-12-021 Engineer ing analysis Office ofScience & Technology / Engineering & Westat EP-C -1 0-023 Statistical analysis Analysis Division EPA has determined that it is necessary to transfer the information described above to the designated contractors and subcon tractors in order that they may carry out the work required by their contracts. The contracts contain all provisions necessary to implement the confidentiality regulations (see 40 CFR 2.301(h)(2), 2.302(h)(2), and 2.305(h)(2)). In accordance with these confidentiality regulations , you are entitled to provide comments to EPA regarding this notice of co ntempla ted disclosure. Any such comments must be recei ved by EPA in writing within 10 days of your receipt ofthis notice. Please send such comments to: Phillip F landers USEP A Hea dquarter s William Jefferson Clinton Bu ilding 1200 Pennsylvania Ave. , N.W. Mail Code: 4303T Washington, DC 20460 flanders.phillip @ epa.gov