BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
AMEREN ENERGY GENERATING
COMPANY,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
)
)
)
)
)
) PCB 09-38
) (Thennal Demonstration)
)
)
)
)
NOTICE OF FILING
TO:
John Therriault, Assistant Clerk
Illinois
Pollution Control Board
James
R. Thompson Center
Suite 11-500
100
West Randolph
Chicago, Illinois
60601
Joey Logan-Wilkey
Illinois Environmental
Protection Agency
Division
of Legal Counsel
1021 North Grand Avenue, East
P.O.Box 19276
Springfield, Illinois 62794-9276
Carol Webb, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O.Box 19274
Springfield, Illinois 62794-9274
Deborah Williams
Illinois Environmental
Protection Agency
Division
of Legal Counsel
1021 North Grand Avenue, East
P.O.Box 19276
Springfield, Illinois 62794-9276
PLEASE TAKE NOTICE that I have electronically filed with the Office of the Clerk of the
Pollution Control Board, AMEREN'S SUPPLEMENTAL RESPONSE TO INFORMATION
REQUESTED DURING PUBLIC HEARING,
copies of which are herewith served upon you.
Ameren Energy Generating Company
By:
y Antomolh
Dated: July 16, 2009
Amy Antoniolli
SCHIFF HARDIN LLP
233 South Wacker Drive
Suite 6600
Chicago, Illinois 60606
Tel: 312-258-5500
Email: aantoniolli@schiffhardin.com
Electronic Filing - Received, Clerk's Office, July 16, 2009
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
AMEREN ENERGY GENERATING
COMPANY,
)
)
)
)
)
)
Petitioner,
v.
PCB 09-38
ILLINOIS ENVIRONMENTAL PROTECTION )
AGENCY,
~
(Thennal Demonstration)
Respondent.
)
)
AMEREN'S SUPPLEMENTAL RESPONSE TO INFORMATION
REQUESTED DURING PUBLIC HEARING
NOW COMES AMEREN ENERGY GENERATING COMPANY ("Ameren" or "the
Petitioner"),
by and through its attorneys, SCHIFF HARDIN, LLP, and submits additional
infonnation.
On July 10, 2009, Ameren filed "Ameren's Supplemental Response to Infonnation
Requested During Public
Hearing" ("Response"). In Section D of the Response, Ameren stated:
The [Illinois Environmental Protection] Agency requested a signed copy
of the
provisional variance granted
by the Agency on October 24, 2007 (IEPA-08-14).
Hot and humid weather conditions and lack
of precipitation during September and
October
2007 led to Ameren's request for a provisional variance. By the time the
provisional variance was issued, these weather conditions no longer existed and
Ameren did not execute the variance or utilize the relief granted.
Subsequent to filing the Response on July 10,
2009, and upon further review of Ameren's
files, Ameren located a signed copy
of the "certificate of acceptance" for the Ameren Energy
Generating Company Coffeen Power Station Provisional Variance, IEPA 08-14. Ameren has
attached the signed certificate
of acceptance and a subsequent memorandum submitted to the
Illinois Environmental Protection Agency
("Agency") dated November 8, 2007.
Ameren revises Section D of the Response to note that Ameren did in fact execute the
provisional variance. As stated in the Response, however, and as indicated in the attached
Electronic Filing - Received, Clerk's Office, July 16, 2009
November 8, 2007 letter, Ameren did not utilize the relief granted due to load reductions taken
by Ameren
as well as the unforeseen return to typical late October weather conditions. Ameren
revises Section D
of the Response as follows:
The Agency requested a signed copy
of the provisional variance granted by the
Agency on October 24,
2007 (IEPA-08-14). Hot and humid weather conditions
and lack
of precipitation during September and October 2007 led to Ameren's
request for a provisional variance. Ameren executed the provisional variance on
October
26,2007. By the time the provisional variance was issued, however, the
unseasonal weather conditions
no longer existed and Ameren did not utilize the
relief granted.
Dated: July
16, 2009
Amy Antoniolli
SCHIFF HARDIN
LLP
233 South Wacker Drive
Suite
6600
Chicago, Illinois 60606
Tel: 312-258-5500
Email: aantoniolli@schiffuardin.com
Respectfully submitted,
Ameren Energy Generating Company
By:
4 y Antomolh
2
Electronic Filing - Received, Clerk's Office, July 16, 2009
AFFIDAVIT OF JAMES L. WILLIAMS, JR.
I, JAMES
L.
WILLIAMS, JR., having first been duly sworn, state as folJows:
1.
I am employed by Ameren Energy Generating Company ("Ameren"). I have
served as the Plant Manager at the Coffeen
Station from 2001 through June 2009. In that
capacity I was responsible for the safe operation
of Coffeen Station, and as such have knowledge
of the economic analysis Ameren performed on the proposed 175,000 gallon per minute
supplemental cooling tower, Ameren's
2007 provisional variance, as well as Ameren's plans to
conduct additional fish studies
of Coffeen Lake.
2.
I have read Sections
a,
D, and E of the preceding Ameren's Response to
Information Requested at Public Hearing.
3.
The statements
of facts contained therein are true and correct to the best of
my
knowledge and belief.
FURTHER, AFFIANT
SA YETH NOT.
~/u~1L
;ames
L.
Williams, Jr.
Subscribed
and
sworn to before me this
II#.
day of
li
'?
,2009.
NOTARY PUBLIC
Electronic Filing - Received, Clerk's Office, July 16, 2009
CERTIFICATE OF SERVICE
I, the undersigned, certify that on this 16
th
day of July, 2009, I have served electronically
the attached,
AMEREN'S SUPPLEMENTAL RESPONSE TO INFORMATION
REQUESTED DURING PUBLIC HEARING,
upon the following persons:
John Therriault, Assistant Clerk
Illinois Pollution Control Board
James
R. Thompson Center
Suite
11-500
100
West Randolph
Chicago, Illinois
60601
therriau;@ipcb.state.il.us
Joey Logan-Wilkey
Illinois Environmental Protection Agency
Division
of Legal Counsel
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
Joey.logan-wilkey@illinois.gov
July
16, 2009
Amy Antoniolli
SCHIFF HARDIN LLP
233 South Wacker Drive
Suite
6600
Chicago, Illinois 60606
312-258-5500
Carol Webb, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O.Box 19274
Springfield, Illinois 62794-9274
Webbc@ipcb.state.il.us
Deborah Williams
Illinois Environmental Protection Agency
Division
of Legal Counsel
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
Deborah.williams@illinois.gov
By:
y Antomolh
