1. NOTICE OF FILING
      2. CERTIFICATE OF SERVICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MA
TIER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR
THE
CHICAGO AREA WATERWAY SYSTEM
AND LOWER DES PLAINES RIVER
PROPOSED AMENDMENTS TO 35 ILL.
ADM. CODE
301,302,303, and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking
- Water)
NOTICE OF FILING
TO:
John Therriault, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
Deborah J. Williams, Assistant Counsel
Stefanie
N. Diers, Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Splingfield,
IL 62794-9276
Malie Tipsord, Healing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
Persons included on the attached
SERVICE LIST
PLEASE TAKE NOTICE that I have today filed with the Office
of the Clerk of the
Pollution Control Board STEPAN COMPANY'S PRE-FILED QUESTIONS FOR MIDWEST
GENERATION WITNESS JULIA WOZNIAK, a copy
of which is herewith served upon you.
Electronic Filing - Received, Clerk's Office, August 25, 2008
Date: August 25, 2008
Thomas V. Skinner
Thomas W. Dimond
Kevin Desharnais
Jennifer
A.
Simon
Mayer Brown
LLP
71 South Wacker Drive
Chicago, Illinois 60606-4637
(312) 701-8407 (phone)
(312) 706-8117 (fax)
STEPAN
COMPANY
Electronic Filing - Received, Clerk's Office, August 25, 2008
CERTIFICATE OF SERVICE
I, the undersigned, certify that on this 25
th
day of August, 2008, I have served
electronically the attached STEPAN COMPANY'S PRE-FILED QUESTIONS FOR MIDWEST
GENERATION WITNESS JULIA WOZNIAK, and NOTICE OF FILING upon the following
person:
John Therriault, Clerk
Illinois Pollution Control Board
James
R.
Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
and
by U.S. Mail, first class postage prepaid, to the following persons:
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
The participants listed on the attached
SERVICE LIST
Deborah J. Williams, Assistant Counsel
Stefanie
N. Diers, Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
JenE{=--
Electronic Filing - Received, Clerk's Office, August 25, 2008
SERVICE
LIST
Frederick M. Feldman
Ronald M. Hill
Margaret T. Conway
Metropolitan Water Reclamation District
of Greater Chicago
III East Erie Street
Chicago, IL 60611
Bill Richardson, Chief Legal Counsel
Illinois Department
of Natural Resources
One Natural Resources Way
Springfield, IL 62702-1271
Keith Harley
Elizabeth Schenkier
Chicago Legal Clinic, Inc.
205 West Monroe, 4th Floor
Chicago, IL 60606
Katherine D. Hodge
Monica
T.
Rios
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
Springfield, IL 62705-5776
Dennis Duffield
Director
of Public Works
&
Utilities
City of Joliet
921
E. Washington St
Joliet, IL 60431
Claire Manning
Brown Hay
&
Stephens LLP
700 First Mercantile Bank Bldg
205
S. Fifth St
Springfield, IL 62705-2459
Frederick Keady
Vermillion Coal Company
1979 Jolms Drive
Glenview, IL 60025
Matthew Dunn, Chief
Environmental Bureau
Office
of the Attorney General
100 West Randolph, 12th Floor
Chicago, IL 60601
Ann Alexander
Natural Resources Defense Counsel
101 N. Wacker Dr., Ste. 609
Chicago, IL 60606
Susan M. Franzetti
Franzetti Law Firm P.C.
10 South Lasalle S1.
Suite 3600
Chicago, IL 60603
Albert Ettinger
Jessica Dexter
Environmental Law
&
Policy Center
35
E.
Wacker Dr., Suite 1300
Chicago, IL 60601
Richard Kissel
Roy Harsch
DrinkerBiddle
191 N. Wacker Dr., Suite 3700
Chicago, IL 60606-1698
Charles Wesselhoft
James Hanington
Ross
&
Hardies
150 N. Michigan Ave
Chicago, IL 60601-7567
Fred
L. Hubbard
P.O. Box 12
16 West Madison
Danville, IL 61834
Electronic Filing - Received, Clerk's Office, August 25, 2008
Georgia Vlahos
Naval Training Center
260lA Paul Jones St
Great Lakes, IL 60088-2845
W.e. Blanton
Blackwell Sanders LLP
4801 Main St, Suite 1000
Kansas City, MO 64112
JelTY Paulsen
Cindy Skukrud
McHenry County Defenders
132 Cass Street
Woodstock, IL 60098
Bernard Sawyer
Thomas Granto
Metropolitan Water Reclamation District
6001
W. Pershing Rd
Cicero, IL 60650-4112
Fredric Andes
Eri
ka Powers
Barnes
&
Thornburg
1 North Wacker
Dr
Suite 4400
Chicago, IL 60606
Bob Carter
Bloomington
Nonnal Water Reclamation
PO Box 3307
Bloomington, IL 61702-3307
Kenneth W. Liss
Andrews Environmental Engineering
3300 Ginger Creek Drive
Splingfield, IL 62711
Albert Ettinger
Jessica Dexter
Environmental Law
&
Policy Center
35 E. Wacker
Suite 1300
Chicago, IL 60601
Kay Anderson
American Bottoms
One American Bottoms Road
Sauget, IL 62201
Robert VanGyseghem
City of Geneva
1800 South St
Geneva, IL 60134-2203
Stacy Meyers-Glen
Openlands
Suite 1650
25 East Washington
Chicago, IL 60602
Lisa Frede
Chemical Industry Council of lllinois
2250
E.
Devon Ave
Suite 239
Des Plaines, IL 60018-4509
Jack Darin
Sierra Club
70
E.
Lake St
Suite 1500
Chicago, IL 60601-7447
Tom Muth
Fox Metro Water Reclamation District
682 State Route
31
Oswego, IL 60543
Vicky McKinley
Evanston Environmental Board
223 Grey Avenue
Evanston, IL 60202
Marc Miller
Jamie
S. Caston
Office of Lt. Governor Pat Quinn
Room 414 State House
Springfield, IL 62706
Electronic Filing - Received, Clerk's Office, August 25, 2008
James L. Daugherty
Thorn Creek Basin Sanitary District
700 West
End Avenue
Chicago Heights, IL 60411
Tracy Elzemeyer
Amelican Water Company
727 Craig Road
St. Louis,
MO 63141
Irwin Polls
Ecological Monitoring and Assessment
3206 Maple Leaf Drive
Glenview, IL 60025
Jeffrey C. Fort
Ariel J. Tesher
Sonnenschein Nath
&
Rosenthal LLP
7800 Sears Tower
233 S. Wacker Dlive
Chicago,
IL 60606-6404
Dr. Thomas
J. Murphy
2325 N. Clifton St
Chicago, IL 60614
Cathy Hudzik
City
of Chicago
Mayor's Office of Intergovernmental Affairs
121 North LaSalle Street, Room 406
Chicago,
IL 60602
Susan Hedman
Andrew Armstrong
Environmental Counsel
Environmental Bureau
Suite 1800
69 West Washington Street
Chicago, IL 60602
Sharon Neal
Commonwealth Edison
125 South Clark Street
Chicago, IL 60603
Margaret P. Howard
Hedinger Law Office
2601 South Fifth Street
Springfield, IL 62703
James Huff
Huff
&
Huff, Inc.
915 Harger Road, Suite 330
Oak Brook, IL 60523
Fredric P. Andes
Carolyn S. Hesse
David T. Ballard
Barnes
&
Thornburg LLP
1 N Wacker Dr, Suite 4400
Chicago, IL 60606
Beth Steinhorn
2021 Timberbrook
Springfield,
IL 62702
Traci Barkley
Prairie Rivers Networks
1902 Fox Drive, Suite 6
Champaign,
IL 61820
Brent Fewell
Kristy
A. N. Bulleit
HUNTON
&
WILLIAMS LLP
1900 K Street, N.W.
Washington,
DC 20006
Electronic Filing - Received, Clerk's Office, August 25, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN
THE MATIER OF:
WATER QUALITY STANDARDS AND
EFFLUENT LIMITATIONS FOR
THE
CHICAGO AREA WATERWAY SYSTEM
AND LOWER DES PLAINES RIVER
PROPOSED AMENDMENTS
TO 35 ILL.
ADM. CODE 301,302,303, and 304
)
)
)
)
)
)
)
)
R08-9
(Rulemaking - Water)
Pre-filed Questions for Midwest Generation Witness Julia Wozniak
1.
Explain what is meant by the term "derating" as referenced in your testimony concerning
how MWGen maintains compliance with the thermal water quality standards.
2.
For the recent past, provide additional information concerning the frequency with which
MWGen has employed "derating" to maintain compliance with the thermal water quality
standards, including to what extent these deratings have occurred during periods where
the ambient atmospheric temperature was above 90 degrees Farenheit and provide
estimates concerning the estimated number
of households that equate to the amount of
the derating taken by MWGen.
3.
Why hasn'tMWGen installed cooling towers at the other MWGen Plants, namely Fisk,
Crawford and Will County, in addition to the cooling towers installed at the Joliet Plant?
4.
Explain what is meant by the phrase the "design maximum temperature rise
in the
cooling water" in your description of the Joliet Facilities.
5.
In your description of the Joliet cooling towers, you state that "[t]hey are 'helpercooling
towers' which are not designed for long-term, continuous runs." Why weren't the
cooling towers designed for long-term, continuous runs?
6.
What do you mean when you state that the Joliet cooling towers "are capable
of cooling
approximately one-third of Units 7&8's total design discharge." Why can't the Joliet
cooling towers cool more than this portion
of the discharge?
7.
Why doesn'tMWGen have to use the cooling towers in the winter months?
8.
You state in your pre-filed testimony that: "Generally, the towers are used when the
circulating water discharge temperature exceeds 93°F for an extended period of time.
The towers do not work efficiently when the temperature
of the station condenser
discharge flow is less than 90°F or when the dew point temperature
(i.e.,
temperature to
Electronic Filing - Received, Clerk's Office, August 25, 2008
which the air must be cooled at constant pressure for it to become saturated) approaches
78-80
o
P." Please explain fmther what you mean by the these statements.
9.
You state in your pre-filed testimony that: "Based on my experience and first hand
observations through the UIW Studies, the Adjusted Standards provide
an adequate level
of protection for the aquatic community below I-55 and provide a more representative
normal, seasonal fluctuation than either the Secondary Contact
or the General Use
numeric standards." What is the experience and first-hand observations you are referring
to?
10.
You state
in your pre-filed testimony that: "Ambient stream temperature is largely
associated with the volume
of flow in the river. MWGen's compliance efforts are
therefore largely dictated by the upstream flow manipulations and perturbations in the
CAWS that
in tum affect the volume of flow to the Upper Dresden Pool." Please explain
the basis for your statement that the volume
of flow is largely associated with ambient
stream temperature and what you mean by your reference to "upstream flow
manipulations and perturbations in the CAWS", including how these actions affect the
volume
of flow to the Upper Dresden Pool.
11.
With regard to the thermodynamic model that MWGen runs to monitor compliance with
thermal water quality standards, how often is the model run during the summer months?
12.
With regard to Attachment 4, the water flow graphs, to your testimony, please explain in
greater detail what these graphs show and why they are representative
of the flows in the
Upper Dresden Pool? As to the flow graph showing flow changes in July 2008, have
such significant flow changes been seen at other times?
13.
With regard to your testimony that "[f]low conditions at any given time cannot be
predicted with great precision and flow does not follow any type
of normal trend,"
Explain why flow conditions "cannot be predicted with great precision" and why this is
relevant to the thermal water quality standards for the
CAWS and/or LDP? Also, please
explain what is mean by the statement that "flow does not follow any type
of normal
trend."
14.
With regard to the
LDP UAA stakeholder process, your testimony states that MWGen
provided extensive comments that General Use thermal standards were not justified
based on the lack
of adequate habitat to support an aquatic community that justified such
stringent thermal standards, was there discussion during the LDP UAA stakeholder
process concerning the habitat issue and
if so, what was the outcome of that or those
discussions?
15.
With regard to the draft
UAA Report on the LDP, you testify that MWGen's comments
regarding the draft report raised substantive issues that were ignored
as part of the revised
UAA report, what are the substantive issues that you are referring to?
Electronic Filing - Received, Clerk's Office, August 25, 2008
Date: August 25, 2008
Thomas
V. Skinner
Thomas W. Dimond
Kevin Desharnais
Jennifer
A.
Simon
Mayer Brown
LLP
71 South Wacker Dri ve
Chicago, Illinois 60606-4637
(312) 701-8407 (phone)
(312) 706-8117 (fax)
.STEPAN COMPANY
Electronic Filing - Received, Clerk's Office, August 25, 2008

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