October 12, 2011

BY EMAIL

Lisa A. Biddle

United States Environmental Protection Agency

Office of Water (4100T)

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Re: 	Proposed National Pollutant Discharge Elimination System Rule for
Cooling Water Intake Structures at Existing Facilities and Phase I
Facilities, Docket ID No. EPA-HQ-OW-2008-0667

Ms. Biddle:

Enclosed please find the October 2004 - October 2005 actual impingement
data (raw) for species, with daily creel limits for recreational
fishermen, collected at Alabama Power Company’s (“Alabama Power”)
Electric Generating Plants.  You requested the data in a September 26,
2011 email to me and my colleagues in response to Alabama Power’s
August 18, 2011 comment letter to the above-referenced proposed rule. 
The data was collected every two weeks during 25 separate 24 hour
(daily) events at each facility’s intake structure for a period of one
year. 

Species	Barry Intake	Greene Co. Intake	Gorgas Intake	Gadsden	Gaston

	Unit 1-3	Unit 4-5	Unit 1-2	Unit 6-7	Unit 8-10	Unit 1-2	Unit 1-5

Paddlefish	7	54	0	0	1	0	0

Alligator Gar	1	1	0	0	0	0	0

White, Yellow, or Striped Basses	78	36	3	6	92	1	14

Black Basses	15	58	3	1	14	0	1

Bream	161	147	64	26	62	13	63

Crappie	653	1702	6	2	12	0	1



In its August 18 letter, Alabama Power requested that the Environmental
Protection Agency (“EPA”) establish a de minimis exception to its
annual (12 percent) and monthly (31 percent) impingement mortality
(“IM”) numeric standards to prevent facilities that have already
achieved reduced IM levels from being penalized over small quantities of
IM instances.  Alabama Power referenced state creel limits to illustrate
that, in some instances, regulated facilities are impinging certain
species of fish at a rate less than one recreational fisherman is
allowed to take from Alabama waters for a given year.  Alabama Power
made the comparison with annual estimates derived from the raw data
above.  Alabama Power maintains that this illustration is compelling and
supports the establishment of a de minimis exception to the percentage
IM standards.  However, Alabama Power is not advocating that any such de
minimis exception for recreational fish or other impingible organisms be
based on any state’s creel limits.  Should EPA determine that a de
minimis exception should be established—which it should—Alabama
Power would like the chance to provide additional comments or help the
agency develop that standard.

Thank you for requesting this additional information and for your
consideration of Alabama Power’s August 18, 2011 comments on the
above-referenced proposed rule.  Should you have any questions regarding
the enclosed data or another matter, please feel free to contact Charles
Stover (cmstover@southernco.com), Tim George (tgeorge@southernco.com),
or me.

Sincerely,

Mike Godfrey, Manager

Environmental Compliance

	(jgodfrey@southernco.com)

October 12, 2011						          		       Personal and Confidential

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600 North 18th Street							Personal and Confidential

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Birmingham, Alabama 35291

Tel 205.257.1000

