October 30, 2014 

Tim Lohner 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

American Electric Power 

1 Riverside Plaza 

Columbus, OH 43215 

Dear Mr. Lohner: 

OFFICE OF 

WATER 

The U.S. Environmental Protection Agency ("EPA"), under the authority of the 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 of the 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 of the 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 of the 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 of the pilot test. 

3. Please provide a description of the wastewater used in the pilot testing (e.g., describe 

any treatment of the FGD wastewater prior to it being transferred to the technologies 

evaluated as part of the 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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transferred 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 why 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, provide 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 commingled 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, any 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 locations and chemical addition points 

for that technology. Please note that each diagram should include specific sampling 

location names so the analytical data can be matched specifically to each technology 

evaluated. See Enclosure 1 for an example of a detailed process flow diagram. 

10. EPA 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 Data 
Table" 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. Treated 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 of the data. Please provide the data listed ir). Enclosure 2. 

12. Please provide the type and source of coal (i.e., mine name and location) used at the 

plant each day starting one month prior to the beginning of the pilot test and 

continuing through the entire pilot test duration. In addition, please provide the sulfur 

and chlorine content of the coal used at the plant for each day of this period, if 

available. For days where coal blending occurred, please note the percentage of each 

type of coal used. See Attachment 2 (Supplemental Data workbook, tab titled "Coal 

Data") for the format of the 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-reduction 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 generation 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 of the 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 of the 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 the 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) 

Enclosures 
Enclosure 1 

Techno

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and tech

System Added on 

6/15/14 

Techno

System Added on .... Vendor ...... [Provide 

6/l /14 Pretreatment and tech

Pretreatment Pretreatment Step 2 Step 1 [Provide general __... FGD System ...... [Provide general description (e.g., 

Techno

description (e.g., Chemical 

..... [Provide 

Pond)) precipitation) 

and tech

Techno

...... [Provide 

and tech

Figure 1. Example Simplified Process Flow Diagram for Pilot Test Configuration 
Technology 2 Technology 2 

Equalized Influent Added 6115114 Pretreated Influent 

Technology 2 

Bioreactor 1 Effluent 

Technology 2 

Bloreactor 2 Effluent 

zation 

nk 

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Tank 

Polymer 

Settling Tank 

(Clarifier 

Simulation) 

Solids 

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---------------------------------1 

Nutrients 

Biological 

Reactor 1 

Nutrients 

Biological 

Reactor 2 

Figure 2. Example Detailed Process Flow Diagram for Pilot Test Technology 

Polishing 

Filter 

Technology 2 

Final Effluent 

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Effluent 
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 data 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 of properly operating treatment systems. 

Data you submit should be relevant to flue gas desulfurization wastewater. 

Important Considerations 

• The data provided should include both treated, 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 of the 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 of how to 

populate each of the fields in the data table. Additionally, the spreadsheet titled "Field 

Descriptions" describes each field included in the data table'. Provide the individual sample 

results associated with the sampling locations. Entries that average multiple results for a 

sampling point are of limited use. 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; 

• Reporting Limit; 

• Dilution Factor; 

• Qualifiers; 

• Qualifier Description; 

• Wastestream represented by result; 

• Flow rate; and 

• Sample point description. 

For EPA to evaluate whether the data provided are valid and of sufficient quality for use in the 

loadings analyses and/or limitations development, the following supplemental 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 (Supplemental Data workbook, tab titled "Chemical Dosages"); 

• Laboratory reports 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 of the 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 of this 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 of performance 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 of the 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 of the 

procedures, set forth in Subpart B. 

If you wish to claim as confidential any of the information covered by the enclosed request, you 

must do so at the time you submit the information to EPA If no 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 of information 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 collected 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 

allow 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 Electric 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 Engineering analysis Office of 

Science & 

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 subcontractors 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 contemplated disclosure. Any such comments must be received by 

EPA in writing within 10 days of your receipt ofthis notice. Please send such comments to: 

Phillip Flanders 

USEP A Headquarters 

William Jefferson Clinton Building 

1200 Pennsylvania Ave., N.W. 

Mail Code: 4303T 

Washington, DC 20460 

flanders.phillip@epa.gov