Supplemental Info NOF and COS.pdf
Response to Information.pdf
1. PCB 09-38 Ameren's Response to Information Request.pdf

BEFORE THE

ILLINOIS POLLUTION CONTROL BOARD

AMEREN ENERGY GENERATING

COMPANY,

Petitioner,

ILLINOIS ENVIRONMENTAL PROTECTION

(Thermal Demonstration)

)

NOTICE OF FILING

TO:

John Therriault, Assistant Clerk

Illinois Pollution Control Board

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

WebbC@ipcb.state.il.us

PLEASE TAKE

NOTICE that I have electronically filed with the Office

of the Clerk of the

Pollution Control Board,

AMEREN'S RESPONSE TO INFORMATION REQUESTED

DURING PUBLIC HEARING, copies of which are herewith served upon you.

Ameren Energy Generating Company

Electronic Filing - Received, Clerk's Office, July 10, 2009

Dated: July 10, 2009

Amy Antoniolli

SCHIFF HARDIN LLP

233 South Wacker Drive

Suite

6600

Chicago, Illinois 60606

Tel: 312-258-5500

Email: aantoniolli@schitlhardin.com

CERTIFICATE OF SERVICE

I, the undersigned, certify that on this 10

day of July, 2009, I have served electronically

the attached,

AMEREN'S RESPONSE TO INFORMATION REQUESTED DURING

PUBLIC HEARING,

upon the following persons:

John Therriault, Assistant Clerk

Illinois Pollution Control Board

Chicago, Illinois 60601

therriauj@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

233 South Wacker Drive

Suite 6600

Chicago, Illinois 60606

312-258-5500

Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand A venue East

P.O.Box 19274

Springfield, Illinois 62794-9274

Webbc@ipcb.state.il.us

BEFORE THE

ILLINOIS POLLUTION CONTROL BOARD

AMEREN ENERGY GENERATING

COMPANY,

Petitioner,

ILLINOIS ENVIRONMENTAL PROTECTION

(Thermal Demonstration)

AMEREN’S 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

information. On June 23, 2009, the Illinois Pollution Control Board (“Board”) conducted a

hearing in this matter.

During the hearing, additional information was requested by either the

Board or the Illinois Environmental Protection Agency (“Agency”). The Hearing Officer set the

date by which to submit the additional information as July 10, 2009. In response to the

information requests and to complete the record, Ameren submits the following:

Flow Capacity of Ameren’s 48-cell Cooling Tower (Tr. at 69-70):

Ameren

currently utilizes supplemental cooling towers at the Coffeen Power Station with a flow capacity

of 200,000 gallons per minute (gpm). Pet. Exh. 15, pg. 9, Table 3-1. The permit application for

the construction of the cooling towers is attached as Exhibit A.

Economic Analysis of the Proposed 175,000 gpm Cooling Tower (Tr. at 72-

73):

As part of the capital planning and budget process, construction projects are screened and

ranked based upon an internal determination as to whether such projects are economically viable.

The transcript of the June 23, 2009 hearing will be cited to as “Tr. at __.”

Electronic Filing - Received, Clerk's Office, July 10, 2009

The company refers to this analysis as an “EVA” which stands for economic viability analysis.

To be viable, a capital project does not necessarily need to generate a “profit.” However, the

project must, at a minimum, be economically neutral over a reasonable cost-recovery period.

Projects necessary to fulfill environmental regulatory requirements such as the $600 million

dollars spent installing scrubbers and SCRs at Coffeen Power Station are exempt from this

requirement due to the mandatory nature of the project.

In the past ten years, Ameren has approved and implemented various capital projects

designed to reduce thermal loading on Coffeen Lake so that Coffeen Power Station could

continue to operate within the constraints of its specific thermal limits without resorting to de-

rates. These capital projects included the development of a 70-acre cooling basin as well as the

construction of a 48-cell cooling tower system. Despite these efforts, de-rates have been

necessary from time to time in the shoulder months of May and October. Ameren retained

Sargent & Lundy to propose and evaluate additional enhancements to the lake’s cooling systems.

Sargent & Lundy evaluated eight alternative capital projects designed to reduce further thermal

loading on the lake. Of these alternatives, the one providing the best economics was identified:

the installation of a 175,000 gpm cooling towers with a capital cost of $18 million dollars.

Ameren analyzed the economic viability of the 175,000 gpm cooling tower in

comparison to the alternative of continuing as-is by using derates to comply with the thermal

limits. That analysis, performed in 2006, estimated that it would take approximately 11.5 years

for the company to recover the costs of its investment in the new cooling tower. Because these

were extraordinary costs with a long payback period, the company concluded that these

investments, added to the initial investments made in the cooling basin and existing cooling

tower, were not justified especially inasmuch as the additional cooling capacity provided by the

175,000 gpm cooling tower would allow Coffeen Station an estimated 185,000 megawatt hours

(MWh) of additional annual generation. Ameren also asked Sargent & Lundy to model the

Electronic Filing - Received, Clerk's Office, July 10, 2009

performance of the existing cooling system under warmer-than-normal summer conditions, but

with the modified thermal limits being requested in this proceeding. Sargent & Lundy concluded

the proposed alternative May and October thermal limits would be able to accommodate the

same rate of generation as any of the other proposed additional cooling system modifications.

Based on these results, the company concluded that the substantial additional investment costs

necessary to meet the existing temperature limits outweighed the marginal benefits to be gained

by having a helper cooling tower at the ready, but that would realistically be deployed an average

of only 31 days per year during time periods when market prices and operating margins are low.

The Company concluded that the proposed project would be uneconomical, particularly when

compared to other capital projects that compete for finite capital dollars and promise greater

benefit per dollar spent.

In preparing for the hearing in this case, and recognizing that the United States is

experiencing economic conditions not seen since the Great Depression, Ameren updated its

analysis. In updating the analysis, two critical assumptions have changed: The future market

prices for power and the likelihood of additional costs in the form of a CO

tax or other

compliance cost. When such considerations are taken into account, the costs associated with the

capital investment in the 175,000 gpm cooling towers cannot be recovered before the equipment

itself needs to be replaced. The power generation industry in Illinois now operates in a

deregulated environment and as such capital expenditures are not subject to rate-based regulation

or recovery. Accordingly, capital expenditures must be supported by sales of power and

associated power prices that are the source of cash flow and earnings. Power prices began a

precipitous drop in July 2008 and have continued to be depressed during this prolonged

recession that has resulted in record job losses, bankruptcies and lay offs.

Set forth below is a table depicting futures prices for CinHub Real Time (RT) Around-

The-Clock (ATC) energy, calculated from peak and off-peak settlement prices reported by the

New York Mercantile Exchange (NYMEX), on a per megawatt-hour (MWh) basis. This data

demonstrates the material drop in power prices experienced in the past year, and expected by

market participants over the next few years:

Year

As of June 30,

2008

As of June

30, 2009

Change in

$/MWh

In addition, the original analysis of the economic viability of the 175,000 gpm cooling

tower did not consider the cost of compliance with carbon regulation. An energy cost adjustment

for pollution control equipment needed for compliance with carbon regulation beginning in 2014

was factored into the updated economic viability analysis. By changing these two critical

assumptions, the updated analysis demonstrates that despite the increased availability this

alternative would provide, the additional capacity revenues, given the decreasing energy margins

and high costs of compliance with future carbon regulation, Ameren would never recover the

total capital costs required to implement the 175,000 capacity cooling tower. As a result,

Ameren does not consider this technology an economically reasonable alternative.

Phosphorus Loading Calculations (Tr. at 226):

The calculations attached as

Exhibit B are the results Dr. Shortelle relied upon to support her estimate of the amount of

phosphorus that would be fluxed into the hypolimnion of Coffeen Lake during the months of

May and October. Tr. Exh. 3, Attach.2.

2007 Provisional Variance (Tr. at 109):

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. 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.

Coffeen Lake Studies (Tr. at 210-216):

Ameren and IDNR have reached an

agreement in principle, a draft memorandum of understanding (“Draft MOU”), to conduct

additional studies of Coffeen Lake and the fishery if the Board grants the requested relief.

See

the Draft MOU, attached as Exhibit C. Ameren believes that the draft MOU is ready for final

execution by IDNR. The Agency has advised Ameren that it has no objections to the agreement.

Assuming relief from the current thermal limits is granted, the MOU provides that

Ameren and IDNR will develop study plans to monitor the status of key fish populations in the

lake and document the long-term effects, if any, of the revised thermal limits for the months of

May and October on these populations. The studies will also investigate the ability of fish to

avoid exposure to stress by seeking preferred temperatures within the Lake’s environment and

will locate available thermal refuges during peak temperatures. The draft MOU sets forth the

conceptual framework for such studies. According to the MOU, the fish population study plan

design will be completed in collaboration with the IDNR and the field work will be done as a

joint effort between IDNR and Ameren field contractors.

The study will include the

representative important species (RIS) identified in this petition as well as new species that might

be introduced. Ameren is not asking that the studies also be made part of the request for relief

before the Board, but Ameren would agree to publish or otherwise make available the results of

the studies.

Electronic Filing - Received, Clerk's Office, July 10, 2009

The MOO does not alter IDNR authority or responsibility to investigate and assess fish

kills should they occur.

If investigation shows that a fish kill has resulted from the requested

relief, Ameren agrees to replenish

or replace the impacted resource pursuant to the terms and

conditions

of a Fish Stocking Plan to be developed in consultation with IDNR.

In addition to compliance with the thermal limitations, as well as and restocking and

replenishing fish PQPulations as provi

ded

in the draft MOO, in the event excessive fish mortality

occurs during the summer months, Ameren would also agree

to implement appropriate

mitigation measures. Ameren will set forth proposed mitigation measures in the post-hearing

233 South Wacker Drive

Email: aantoniolli@schiffuardin.com

Respectfully submitted,

Ameren Energy Generating Company

By:

my Antolllolll

Electronic Filing - Received, Clerk's Office, July 10, 2009

EXHIBIT A

~r.t.

iJiAmeren

eren Services

Envin",mental, Safety

Hellltlr

JI4.S54.4S11 (Phone)

JI4.554.4182 (Facsimile)

",jsmllliwood@ameren.com

November 1, 2001

Mr. Thomas G. McSwiggin, P.E.

Industrial Unit, Permit Section

I1Iinois Environmental Protection Agency

Division

of Water Pollution Control

1021 North Grand Avenue East

POBox 19276

Springfield IL 62794-9276

One Amcrt'll Plaza

1901 Chouteau Avenue

PO Box 66149

SI. LOllis. MO 63166.

6149

314.621.3222

RE:

Ameren Energy Generating Company - Coffeen Power Station

Supplemental Cooling Tower Construction Permit Application

Dear Mr. McSwiggin:

Enclosed are permit applications (WPC-PS-I, Schedule J, and Schedule

for the

construction

of supplemental cooling towers at the Coffeen Power Station. The

supplemental cooling towers will enable the Station to have greater flexibility and control

to maintain compliance with condenser cooling water temperature limitations.

The supplemental cooling towers will intercept the circulating discharge, prior to release

at Outfall

020, and divert the water through the cooling towers as necessary to support

plant operation. Water from the cooling towers will be released through a new outfall

directly into Coffeen Lake. With the creation

ofthe new outfall, we recognize our

obligation to modify the existing Station NPDES permit before any releases occur from

the cooling towers. The NPDES modification application will be submitted separately to

the Agency within the next week.

As the Station desires to have the cooling towers operational before April 15, 2002,

Ameren Energy would sincerely appreciate the Agency expediting the review and

approval

of this construction permit application so that construction can begin no later

than December 15, 2001.

Please contact me ifthere are any questions relating to the enclosed construction permit

/ /

Senior Environmental Engineer

Ameren Services As Affiliated Agent for Ameren Energy Generating Company

" subsidiary 01 Ameren CorporaflOn

Illinois Environmental Protection Agency

For IEPA Use:

Permit Section, Division

of Water Pollution Control

P. O. Box 19276

Springfield, Illinois

62794-9276

Application for Permit or Construction Approval

WPC-PS-l

1. Name and Location:

Arreren Energy Generating Corrpany - Coffeen Power Station

Name of project:

Supplemental cooling towers

BriefD •• crlptionofProject:

Installation of 12 Evapco AT 428-1248 induced draft cooling towers,

and construction of all auxiliary corrponents for operation and diSCharge to Coffeen Lake

Documents aeing Submitted: If the project involves any of the items listed below.

submit the

corresponding schedule. and check the appropriate

spaces.

Projoct

Private Sewer Connection/Extension .• . . . . . . . . .. AlB ____ _

Spray Irrigation .. .. .. .. . .. .. .. .. . .... H ____ _

Extension

Construct

Onty .................

C=====:

Sewage Treatment WorKs ............. .. ....... D

ExcessFlowTreatment ........... , . . . .. •• • .. .. E ____ _

un Station/Force Main ............... .. .. .... .. F ____ _

Septic

TanI<s .. . .. .. . . .. . . .. . • .. .. .... I

--,X---

Industriaf Treatment or Pretreatment .......

J _--;;;-__

=~=e~~~i~ .: :: ::::: : :::::: :. ~

==X===

Sludge Disposal "",,,,,,,,,,,,,,,,,,,,,,,,,, G _____ _

Trust Disclosure ....•................. T ____ _

Number of BooksIPages: _______ _

~~mems(P~~S~)

___________________________________ _

Land Trust: Is Ule project identified in item number 1 herein. for which a pennit is requested. to be constructed on land which is the subject of a

trust?

Yes__

No~

If yes, Schedule T (Trust Disclosure) must be completed and item number 7.1.1 must be signed by a beneficiary, trustee or trust officer.

5. This

an Application for

(Check Appropriate Una):

___ A.

Joint Construction and Operating Permit

_.:X~_B.

Authorization to Construction (See

___ D. Operate Onty Pemrit

Certifications and Approval:

Certificate by Design Engineer

(When required; refer to instruclion)

information contained in Ihis

application.

including the attached schedules

indicated

above, and that to

the

best of my knowledge and belief such information is true, complete and accurate. The plans and specifications (specifications other than Standard

Specifications

local

specifications

file with this Agency) as described above were prepared by me

____________________ --,Q<.>6 ..

2~-."04:I;4""4,,,Q,,,2

------~--~~~~~~-----------------

F~:,

___

_=~S~a~r~3~e~n~t~~&~L~u~n~d~y~!~L~L~C~----=---~----------------~--------~------~--~~~,,~"~"~'U"~,,~t

----------------

Address:

~5.:'.5-:-=E.:..a.:'.S.:'.t_M:..O=-n::.r=-07e=-S7t.:.r:...e=-e=-t=-=_=-___

...

Phone Number: 312-269-6137

S *\

ENGINEER

.: '

Certifications and Approvals for Permits:

/'4

Certificate by Applicant(s)

""'''//",.1/111111

IM/e hereby certify that I/we have read and thoroughly understand the conditions and requirements of this Application, and am/are authorized to

sign this application in accordance with

the

Rules and Regulatoos of the lUinois Poll

ution Control

Board.

I/We hereby agree to oonform with the

Standard Conditions and

with

any other Special Conditions made part of this Permit.

1 Name

of Applicant

fO< Permit

To Construct Ameren Energy Generating Coopany

Str...P1e Ameren

Zip Code 63103

Plaza, 1901 Chouteau Ave

Manager-EnviroMlental, Safety

Health Organization __________ _

7.1.2 Name of Applicant for Permit to Own and Operate

Ameren Energy Generating Coopany

State M:)

Zip

Cod. 63103

Stree~~~e~Amer~~en~~p~1~a~z~a~,~1~9~O~1:Ch~o~u~t~e:a:u~A~v~e~(MC:6~0~2~6ty

- Environmental, Safet & Health

7.2

Attested (Required When Applicant Is a Unit of Government)

Signature X. ___________________

Date,_-,=-=....,..=,.....-=....,..-=-TotIe-=:~=:_:_=_:_

(City

CIe<1<.

Vilage CIerl<, SanitaIy

the owner, must be signed

a principalexocutive officer of at least.

the

level of vice preSident, or a duty authorized representative.

7.4

Certificate By Intermediate Sewer Owner

___ 1

The

sewers to whict: this prc;act win be tributary tla'/o

a~~q:"'-lte

roSC!1'\t3

cap~.~ty

to transport the wastewater that wili;".;

c:,,;.Jo::-J

by this project without causing

violation

the Environmental Protection

Act or

Subtitle C, Chapter t,

___ 2

The Illinois Pollution

Control Board,

in PCB

dated _______ granted a variance from Subtitle C,

Chapter

to allow

construction

facitities that are the

subject

of this appication.

Name and location of sewer system to which this project will

tribulary:

______________________ _

Sewer System Owner, _________________________________________________________________ __

Street

State

Zip Code

SignatureX

_______________________________________ Dae'--__________________ T4e __________ __

7.4.1 Additional Certificate By Intennediate Sewer Owner

The

sewers to which this project wiN be tributary have adequate reserve capacity to transport the wastewater

that

wi ..

added

by this

project withOut

causing a violation of

the

Environmental Protection Act

01'

Subtitle C, Chapter I, or

___

,granted a variance from Subtitle C,

Chapter I to allow construction and operation of the facilities that are the subject of this appUcation.

Name and toeation of sewer system to which this

project

will be tributary:

SewerSy~emOwner

_______________________________________________________ __

__________________________

~----------~D~a~ta~--------~---------~~otIe~----------~

Certificate By Waste Treatment Works Owner

I hereby

certify

that (P1ease check one):

___

The waste b'eatment plant to

which

this proiect will

tributary has adequate reserve capacity to treat the wastewater that

wil

be added

by this project without causing a violation of the Environmental Protection Act or SubtiUe C, Chapter I. or

. granted a variance (rom Subtitle C,

Electronic Filing - Received, Clerk's Office, July 10, 2009

Chapter I to allow construction and operation of the facilities that are the subject of this application.

I also certify that the industrial waste discharges described in

the

appt;cation are capabfe of being treated by the treatment works.

Name and location of waste treatment

works

to which this project will be

fributary: _________________ _

TrealmenlWor1<s

Qwner. ________________________________ _

Street _____________________ ,City

Slale __ ZipCode, __ _

Signature X

Oale, ___________ Title, _____ _

This

IVJercy is

authorized 10 requirelhis information

information is required under thai Section. Failure 10 do so may prevent this form from being processed and could result in your application being

denied. This foon has been

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

DIVISION OF WATER POLLUTION CONTROL

PERMIT SECTION

Springfield, Illinois

J INDUSTRIAL TREATMENT WORKS CONSTRUCTION OR PRETREATMENT WORKS

Company-Coffeen Power Station - supplemental

Longitude _____________

Name of USGS Quadrangle Map

(7.5

minute) __

G"'o::;f:.f:.e"e"n:=.... _____________ _

NARRATIVE DESCRIPTION AND SCHEMATIC WASTE FLOW DIAGRAM: (see instructions)

Three existing supplemental cooling pond pumps will transport cooling water

induced draft cooling towers for additional supplemental cooling. The

period of cooling tower utilization will be dictated by plant operating conditions.

2.1

PRINCIPAL PRODUCTS:

electrical generation

2.2

PRINCIPALMWMATERIALS:

coal

3. DESCRIPTION OF TREATMENT FACILITIES:

3.1

Submita flow diagram through all treatment units showing size, volumes, detention times, organic loadings, surface settling

rate, weir overflow rate, and oIher pertinent design data. Include hydraulic profiles and description

of monitoring systems.

3.2

Waste Treatment Works is: Batch __ , Continuous __ , No. of Batches/day __ , No. ofShiftsiday __ _

3.3

Submit

plans and specifications for proposed construction.

3.4

Discharge is: Existing

, ; Will begin on

April

17« 2002.

4. DIRECT DISCHARGE IS TO: Receiving Stream

Municipal Sanitary Sewer _______ Municipal

storm or municipal combined sewer _____ _

If receiving stream or storm sewer are indicated complete the following:

Name of receiving stream

Coffeen Lake

: tributary to ______ . ____ _

tributary to

; tributary to

____________ _

Is the treatment works subject to flooding? If so, what is the maximum flood elevation of record (in reference to the treatment works

datum) and what prOVisions have been made to eliminate the flooding hazard?

......!NA~

____________ _

APPROXIMATE TIME SCHEDULE: Estimated construction schedule:

Start

of Construction 12/17/2001

; Date of Completion 6/01/2002

Operation Schedule

; Date Operation Begins 4(17/2002

100%

design load to be reached by year....::2:,::0:,::0:,:2=-__________________ _

DESIGN LOADINGS

7.1

Design population equivalent (one population equivalent is

100

galions of wastewater per day, containing

pounds of suspended solids;

BOD

; Suspended Solids ________ ; Flow __________

Design Average Flow Rate __________________________ MGD.

This

Agency is authorized to require trus information under IIWnoisRevised Statutes, 1979.

Chapter 111

112.

Section 1039, Oisdosure of this information is required under that Section.

Failure to

do so may prevent this form from

being

processed and coukj resuh in your

app~cation

being denied. This form has been approved by the Forms Management Center.

Electronic Filing - Received, Clerk's Office, July 10, 2009

7.3 Design Maximum Flow

Rate_----'2~8~8"_:_--------------------------

7.4 Design Minimum Flow Rate_..:

________________ --:-_________ _

7.5 Minimum 7-day,

100year low flow _______ _

cfs

________ MGD.

Minimum 7-day, 10-year flow obtained from ______________________ _

7.6

Dilution Ratio

__ ; ___ .

8. FLOW TO TREATMENT WORKS (if existingl:

8.1

Flow (last 12 months)

8.1 .1 AverageFlow _____ MGD

8.1.2 Maximum Flow

MGD

8.2 Equipment used in determining above flows ______________________ _

9. Has a preliminary engineering report for this project been submitted to this Agency for Approval?

Ves

No.JL. If so, when was it submitted and approved. Date Submitted __________ _

Certification

# ___________ _

Dated __ --:-_=====-___ _

. List Permits previously issued forthe facility: NPDES

operating pennit

ILOOOO108

MGD.

11. Describe provisions for operation during contingencies such as

' power failures. flooding, peak loads, equipment failure,

maintenance shut downs and other emergencies.

Condenser cooling water will be purrped to the

supplemental cooling towers. The towers gravity drain into Coffeen Lake via a

new

outfall. The cooling towers will not be operated continuously. but will

utilized on an as-needed basis to supplement the cooling of the condenser cooling

water discharge.

12. Complete and submit Schedule G if sludge disposal will be required by this facility. NA

. WASTE CHARACTERISTICS: Schedule N ",us' be s"b'!litt.d.

14. TREAJMENT

WORKS OPERATOR CERTIFICATION: List names and certification numbers of certified operators:

SCHEDJ.APP

Electronic Filing - Received, Clerk's Office, July 10, 2009

This Agency is authorized to require this infonnation under Illinois

Revised Statutes. 1979.

Chapter1111/2.

Section 1039. DisdosUfe

of this information

required under thai

section.

Failure to do so

may

prevent this form from being processed and could result in

IWNOIS ENVIRONMENTAL PROTECTION AGENCY

DIVISION OF WATER POLLUTION CONTROL

PERMIT SECTION

Springfield. illinois 62794-9276

Energy Generating Corrpany - Coffeen Power Station - SUpplemental 0001-

FLOW DATA

2.1

Average Flow (gpd)

Maximum Daily Flow (gpd)

Actual terrperature reduction fran cooling towers to be determined when

Thermal lirrdts established at edge of mixing zone remains at

Year

Temp. E

TempE.

2.4 Minimum 7oday. l().year flow: -,NA= ___ cfs _____ MGD.

rate at time of sampling_",NA"",, ___ cts _____ MGD.

3. CHEMICAL CONSTITUENT EXisting Permitted Conditions __ ; Existing condilions __ ; Proposed Permilled Conditions __ .

Type of sample:

__ grab (time of collection ->

;

__ composite (Number of samples per day -.l

(see instructions for analyses required)

Ammonia Nitrogen (as N)

Arsenic (total)

Barium

Boron

BOD,

Cadmium

Carbon Chloroform Extract

Electronic Filing - Received, Clerk's Office, July 10, 2009

Cyanide (readily released

Manganese

solubles or equivalent)

Organic Nitrogen (as N)

Selenium

Total Dissolved Solids

Zinc

Others

l'm'E: Not Applicable. Water is withdrawn from Coffeen Lake and passed through condensers in

the plant. Water terrperature is increased

the condensers and the water returned to Coffeen

Lake. The supplemental cooling towers will provide additional heat dissipation prior to water

discharging to lake. No chemical constituents are added to water other than heat.

Electronic Filing - Received, Clerk's Office, July 10, 2009

Ameren Energy Generating Company - Coffeen Power Station

Supplemental Cooling Tower Project

Plans and Drawings

•

Project Executive Summary

•

Drawing SK-05102000: Process Flow Diagram

•

Drawing S-863 : Lake Structures - General Arrangement

•

Drawing S-887: Cooling Tower Sections

Details

•

Drawing

SK-l: Coffeen Power Station Location

•

Drawing SK-2: Property Plat, Unit No. 1

2, Coffeen Power Station

•

Drawing SK-3: Lake Structures, General Arrangement

Ameren Energy Generating Company - Coffeen Power Station

Supplemental Cooling Tower Project Executive Summary

General Scope o(Work:

Civil, structural, mechanical and electrical engineering package.

Three of the existing vertical turbine pumps will be used to supply water to twelve new

cooling towers. Each

pump will be dedicated to four towers.

The existing piping will be modified and abandoned in place.

Civil work will

be performed to supply a clear and level area for placement ofthe cooling

towers (approximately 240

ft. long x 150 ft. wide).

New concrete and steel structures will be provided for support ofthe cooling towers.

Flumes will be provided to direct the tempered water toward the lake channel.

A final riprap cascade will

be provided to direct the tempered water to the lake channel.

Installation

of the cooling towers including rigging, assembly, piping and electrical work.

Induced Draft

4 cell / 4 fan arrangement (each tower)

460 volt! 60

hzJ

3 phase

High efficiency totally enclosed fan cooled motors

Heavy duty Power Band Drive System

Ll 0/75,000 hr. pillow block bearings with extended lube lines

G235 Galvanized steel construction

PVC fill, eliminators and water distribution systems

Large orifice distribution nozzles with ant-sludge ring

Beveled and grooved inlet and outlet connections

Motor davit with base

5 year motor and drive warranty

NEMA 4X custom electrical panels to include:

motor starters for each motor

65KAIC circuit breakers for each motor

main on-protecting electrical disconnect with

pad lockable handle

time delay between motor starts

hand-off-auto switches with indicator lights

control power transformer and terminals for remote control

Electrical Consumption:

Each tower has (4) 75 HP motors operating at 460 volts and 54.5 kW.

Each tower will consume 218

kW at full load, or 2,616 kW for all 12 towers at full load.

Civil and Structural Work:

All required excavating and backfill of the proposed cooling tower location is included

(approximately 240

ft. long x 150 ft. wide).

Concrete and steel structures will be furnished to support the cooling towers. A flume consisting

of concrete walls and riprap bottom will be provided to direct the tempered water, toward a riprap

cascade that will deliver the tempered water to the lake channel. Gravel and weed guard will

provided in between the cooling towers.

Mechanical Installation:

Included as part of this proposed project is the labor and material required to install and pipe the

proposed cooling towers. This will include:

rigging and setting

of the cooling towers

assembly

of the cooling towers

cutting

of the existing piping

piping and piping supports from the existing piping to the cooling towers

manual shut-off valves at each cooling tower cell

painting

of the new piping

Electrical Installation:

Labor and materials for the electrical installation is provided as follows:

Two new low voltage switchgear, unit substation transformers (2,000 KV A) and medium

voltage switches will

be furnished and installed.

Wiring in conduit to all terminations for cooling tower fans and associated motor control

centers.

Wiring in conduit back to electrical supply in existing pump house.

Control signal wiring to each motor control center.

Proper grounding rods will be provided.

Electronic Filing - Received, Clerk's Office, July 10, 2009

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APPliCATION

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Electronic Filing - Received, Clerk's Office, July 10, 2009

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COFFEEN POWER STATION

UNITS 1 AND 2

AIoIEREN SERvICES. INC

EXHIBIT B

Phosphorus Water Quality Analysis and Internal Loading

Calculations

Electronic Filing - Received, Clerk's Office, July 10, 2009

Seasonal Phosphorus Comparison

Seasonal phosphorus comparisons within Coffeen Lake were made after incorporating additional

phosphorus data used in the 2009 TMDL (Illinois EPA, 2009a) with the Illinois EPA 2007

TMDL dataset (Illinois EPA, 2007). Results were consistent with the 2007 TMDL.

Table A-1. Phosphorus Data Used for Seasonal Comparison Between 1989 and 2008

Station ID

Date Sampled

Characteristic Name

Concentration

(mg/L)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Station ID

Date Sampled

Characteristic Name

Concentration

(mg/L)

Characteristic Name

Concentration

(mg/L)

Data Sources: Illinois EPA (2007). Greenville Lake and Coffeen Lake TMDL. August 2007.

Illinois EPA (2009). Coffeen Lake and East Fork Shoal Creek TMDL Addendum. June 2009.

Table A-2. Regression Statistics for Seasonal Phosphorus Comparisons

Regression Statistics

Table A-3. ANOVA Summary Statistics for Seasonal Phosphorus Comparisons

Electronic Filing - Received, Clerk's Office, July 10, 2009

Comparison of Phosphorus and Chlorophyll-A by Station

Mean phosphorus and chlorophyll-a concentrations were found to be elevated at ROG-3 as

compared to ROG-1 and ROG-2. Chlorophyll-a concentrations at ROG-3 were approximately

68 and 24 percent greater than ROG-1 and ROG-2 respectively. Mean phosphorus

concentrations at ROG-3 measured approximately 28 and 64 percent greater than ROG-1 and

ROG-2 respectively.

Comparison of mean monthly chlorophyll-a concentrations between monitoring stations reveals

that ROG-3 maintains elevated chlorophyll-a concentrations during all summer months,

particularly when compared to ROG-1. During these months, chlorophyll-a concentrations at

ROG-3 were between 37-77 percent greater than ROG-1. Mean phosphorus concentrations were

also highest at ROG-3, which contained the greatest range of phosphorus concentrations (0.04-

2.52 mg/L) of all stations.

Table A-4. Phosphorus Data by Station and Month

Station

Date

Result (mg/l)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Station

Date

Result (mg/l)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Station

Date

Result (mg/l)

Data Source: Illinois EPA (2007)

Table A-5. Chlorophyll-A Data by Station and Month

Station

Electronic Filing - Received, Clerk's Office, July 10, 2009

Station

Electronic Filing - Received, Clerk's Office, July 10, 2009

Station

Data Source: Illinois EPA (2007)

Comparison of Suspend Solids by Station and Month

The majority of the Total Suspended Solids (TSS) values, a leading contributing factor to

turbidity, reported for Coffeen Lake provided in the 2007 TMDL (Illinois EPA, 2007) were

under 20 mg/L. Comparing between stations, ROG-3 was determined to have statistically higher

concentrations of TSS than ROG-1 and ROG-2.

Table A-6. Total Suspended Solids Data by Station and Month

Station

Date Sampled

Parameter

Value (mg/L)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Station

Date Sampled

Parameter

Value (mg/L)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Station

Date Sampled

Parameter

Value (mg/L)

Data Source: Illinois EPA (2007)

Table A-7. ANOVA Analysis of Total Suspended Solids by Station

Table A-8. ANOVA Analysis of Total Suspended Solids by Month

Electronic Filing - Received, Clerk's Office, July 10, 2009

Internal Loading Calculations

Estimates of average depth to anoxia and number of anoxic days per month were made using

water profile data from the Southern Illinois University at Carbondale (SIUC) annual monitoring

reports (SIUC, 2006 and SIUC, 2007).

Table A-9. Water Quality Profile Data by Year from SIUC Reports for Segment 1

Date

Bottom

Depth (m)

Depth <1.0

mg/L O2 (m)

Anoxic Depth (m)

Stratified

Depth to thermocline

(m)

Date

Bottom

Depth (m)

Depth <1.0

mg/L O2 (m)

Anoxic Depth (m)

Stratified

Depth to thermocline

(m)

Date

Bottom

Depth (m)

Depth <1.0

mg/L O2 (m)

Anoxic Depth (m)

Stratified

Depth to thermocline

(m)

Data Source: SIUC 2006 and 2007

Table A-10. Water Quality Profile Data by Year from SIUC Reports for Segment 2

Date

Bottom

Depth (m)

Depth <1.0

mg/L O2 (m)

Anoxic Depth (m)

Stratifie

Depth to thermocline

(m)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Date

Bottom

Depth (m)

Depth <1.0

mg/L O2 (m)

Anoxic Depth (m)

Stratifie

Depth to thermocline

(m)

Date

Bottom

Depth (m)

Depth <1.0

mg/L O2 (m)

Anoxic Depth (m)

Stratifie

Depth to thermocline

(m)

Data Source: SIUC 2006 and 2007

Table A-11. Water Quality Profile Data by Year from SIUC Reports for Segment 3

Date

Bottom Depth

(m)

Depth <1.0 mg/L

O2 (m)

Anoxic Depth (m)

Above Seds

Stratified

Depth to thermocline

(m)

Date

Bottom Depth

(m)

Depth <1.0 mg/L

O2 (m)

Anoxic Depth (m)

Above Seds

Stratified

Depth to thermocline

(m)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Date

Bottom Depth

(m)

Depth <1.0 mg/L

O2 (m)

Anoxic Depth (m)

Above Seds

Stratified

Depth to thermocline

(m)

Data Source: SIUC 2006 and 2007

Table A-12. Water Quality Profile Data by Year from SIUC Reports for Segment 4

Date

Bottom

Depth (m)

Depth <1.0 mg/L

O2 (m)

Anoxic Depth (m)

Stratified

Depth to thermocline

(m)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Date

Bottom

Depth (m)

Depth <1.0 mg/L

O2 (m)

Anoxic Depth (m)

Stratified

Depth to thermocline

(m)

Electronic Filing - Received, Clerk's Office, July 10, 2009

Date

Bottom

Depth (m)

Depth <1.0 mg/L

O2 (m)

Anoxic Depth (m)

Stratified

Depth to thermocline

(m)

Data Source: SIUC 2006 and 2007

Electronic Filing - Received, Clerk's Office, July 10, 2009

Table A-13. Summary of Average Depth to Anoxia for Segment 1 by Year

Segment 1

- Average depth to Anoxic conditions (<1mg/L O2) in Meters

JAN

FEB

MAR

APR

MAY JUN JUL

AUG

SEP

OCT

NOV

DEC

2001

2002

2003

2004

2005

2006

Monthly

Average

8.19

4.97

5.72

5.73

6.33

7.00

Note:

N = no anoxic conditions identified

NA = No data available

Table A-14. Summary of Average Depth to Anoxia for Segment 2 by Year

Segment 2

- Average depth to Anoxic conditions (<1mg/L O2) in Meters

JAN

FEB

MAR

APR

MAY

JUN

JUL

AUG

SEP

OCT

NOV

DEC

2001

2002

2003

2004

2005

2006

Monthly

Average

9.07

8.31

7.36

7.69

8.07

10.50

Note:

N = no anoxic conditions identified

NA = No data available

Table A-15. Summary of Average Depth to Anoxia for Segment 3 by Year

Segment 3

- Average depth to Anoxic conditions (<1mg/L O2) in Meters

JAN

FEB

MAR

APR

MAY JUN JUL

AUG

SEP

OCT

NOV

DEC

2001

7.50

6.50

2002

2003

2004

2005

2006

Monthly

Average

7.17

6.58

5.67

5.92

7.25

Note:

N = no anoxic conditions identified

NA = No data available

Electronic Filing - Received, Clerk's Office, July 10, 2009

Table A-16. Summary of Average Depth to Anoxia for Segment 4 by Year

Segment 4

- Average depth to Anoxic conditions (<1mg/L O2) in Meters

JAN

FEB

MAR

APR

MAY JUN JUL

AUG

SEP

OCT

NOV

DEC

2001

2002

2003

2004

2005

2006

Monthly

Average

8.19

4.97

5.72

5.73

6.33

7.00

Note:

N = no anoxic conditions identified

NA = No data available

Table A-17. Summary of Estimated Number of Anoxic Days for Segment 1 by Year

Segment 1

– Estimated Number of Anoxic Days

JAN

FEB

MAR

APR

MAY JUN JUL

AUG

SEP

OCT

NOV

DEC

2001

2002

2003

2004

2005

2006

Monthly

Average

Note:

N = no anoxic conditions identified

NA = No data available

Table A-18. Summary of Estimated Number of Anoxic Days for Segment 2 by Year

Segment 2

– Estimated Number of Anoxic Days

JAN

FEB

MAR

APR

MAY JUN JUL

AUG

SEP

OCT

NOV

DEC

2001

2002

2003

2004

2005

2006

Monthly

Average

Note:

N = no anoxic conditions identified

NA = No data available

Table A-19. Summary of Estimated Number of Anoxic Days for Segment 3 by Year

Segment 3

– Estimated Number of Anoxic Days

JAN

FEB

MAR

APR

MAY JUN JUL

AUG

SEP

OCT

NOV

DEC

2001

2002

2003

2004

2005

2006

Monthly

Average

Note:

N = no anoxic conditions identified

NA = No data available

Table A-20. Summary of Estimated Number of Anoxic Days for Segment 4 by Year

Segment 4

– Estimated Number of Anoxic Days

JAN

FEB

MAR

APR

MAY JUN JUL

AUG

SEP

OCT

NOV

DEC

2001

2002

2003

2004

2005

2006

Monthly

Average

Note:

N = no anoxic conditions identified

NA = No data available

GIS Calculation of Anoxic Substrate Area

Average monthly depths to anoxia (Tables A-8 through A-11) were used to set as the

area/volume planes in GIS. Because the lake was analyzed within four segments, separate

outputs were generated for each segment. The raw GIS output was in the form of a text (.txt) file

with square and cubic feet as the units. Once conversion of units was performed, data was

provided as a summary of the anoxic substrate surface area by month.

Table A-21. Summary of Lake Areas and Volumes Beneath the Water Surface

Water

Surface

Substrate

Surface

Volume

Depth

Mean

Depth

Max

Segment

Total

Table A-22. Summary of GIS Output of Anoxic Substrate Surface Area Under Existing

Conditions By Month (square meters)

MAY

JUN

JUL

AUG

SEP

OCT

Segment 1

252996 418480 382107 381670 297466 280984

Segment 2

726558 771795 834444 809588 786065 522929

Segment 3

Segment 4

133142 139594 142908 113172

Table A-23. GIS Output of Incremental Increase in Substrate Anoxia During May and

October (square meters)

MAY

MAY Proposed OCTOBER OCTOBER Proposed

Segment 1

Segment 2

EXHIBIT C

Electronic Filing - Received, Clerk's Office, July 10, 2009

MEMORANDUM OF UNDERSTANDING

This memorandum of understanding (“

Memorandum

”) is made as of the ___ day of ________,

2009 by and between Ameren Energy Generating Company, an Illinois corporation (“

Ameren

”),

and the State of Illinois, acting by and through the Department of Natural Resources (“

DNR

”).

WHEREAS, Ameren is the fee simple owner of certain real property located in

Montgomery County, Illinois depicted on Exhibit A attached hereto and made a part hereof (the

“

Property

”);

WHEREAS, Ameren operates the Coffeen Power Generating Station (the “

Coffeen

Station

”) on the Property, and the reservoir located thereon known as Coffeen Lake (the

“

Lake

”) was constructed for the purpose of providing cooling water for the Coffeen Station and

for other purposes relating to the operation of the Coffeen Station;

WHEREAS, Central Illinois Public Service Company, an Illinois corporation (“

CIPS

”),

as the prior Ameren of the Property, and DNR (formerly known as the Department of

Conservation) entered into that certain Lease Agreement dated July 2, 1986 (commonly referred

to as Lease Agreement No. 416A), as amended by that certain Amendment to Lease dated 1988,

that certain Amendment to Lease dated November 11, 1989, that certain Amendment to Lease

dated June 11, 1991, that certain Amendment #4 dated October 1, 1995, that certain Amendment

#5 dated August 20, 1996, and that certain Amendment #6 dated June 30, 1997 (collectively, the

“

Lease Agreement

”) relating to DNR’s right to use certain portions of the Property for the

purposes of conservation and public recreation;

WHEREAS, Ameren is the assignee of CIPS’ interest in the Lease Agreement;

WHEREAS, Owner’s primary obligation as an electric and power generating company is

to provide adequate and reliable service to its customers, and Ameren and DNR recognize that

use of the Lake and the adjoining recreational areas by DNR and the public must be restricted in

order that such use shall not conflict or interfere with the present and future operation and use of

the Coffeen Station; and

WHEREAS, Ameren is seeking regulatory relief from the Illinois Pollution Control

Board for certain thermal discharge standards applicable to its cooling water discharge to the

Lake in the months of May and October; and

WHEREAS, the parties desire to promote the continued use of the Lake for recreational

purposes and to identify fish species tolerant of thermal conditions within cooling lakes such as

the Lake; and

NOW, THEREFORE, in consideration of the foregoing premises and the mutual

covenants and agreements set forth in this Memorandum, the parties agree as follows:

Fish Population and Behavior Status Monitoring Studies.

Ameren shall monitor the

status of key fish populations in the Lake and document the long-term effects, if any, of the

revised thermal standards for the months of May and October on these populations. This study

will also investigate the ability of fish to avoid exposure to stress by seeking preferred

temperatures within the Lake’s environment and will locate available thermal refuges during

peak temperatures. IDNR annually monitors six fish species in the Lake and has created an

extensive long-term database. The proposed study will be designed to complement and utilize

IDNR data to the extent possible. A more detailed study design will be completed after review

of IDNR sampling methods and data, followed by a meeting with IDNR personnel to reach

agreement on sampling objectives and methodology. The study may be performed as a joint

study between IDNR and Ameren field contractors. The study plan design will be completed

within one year of execution of this Agreement MOU. Studies will be conducted under strict

quality assurance protocols including Standard Operating Procedures (SOP) to ensure reliable

data collection.

Fish Stocking Pilot Study

. In order to better evaluate suitable fish species for cooling

lakes in Illinois, Ameren will implement, in conjunction with IDNR, a three-year fish stocking

pilot study at the Lake. The stocking study will assess the viability of adding a new fish to the

lake. The fish population study will assess thermal impacts on the existing fish population and

the new species added as well. These studies includes Ameren’s agreement to dedicate up to

$20,000.00 per year for the three-year pilot towards stocking the Lake with suitable species, such

as the blue catfish, to help IDNR better assess the long term nature of maintaining a viable

fishing resource.

The foregoing studies shall include at least the following elements:

a. Collect annual data on the relative abundance, growth, condition, and size structure of

key fish populations such as largemouth bass, white crappie, bluegill, channel catfish, and

species stocked as a result of this agreement, e.g., blue catfish.

b. Compare results to data from previous years to detect long-term trends possibly related to

a changing thermal regime.

c. In vertical and horizontal planes, determine whether fish avoid certain areas and

congregate in others during near-peak water temperatures.

d. Record vertical profiles of water temperatures and dissolved oxygen in areas where fish

are aggregated and compare to other locations in the Lake.

e. In the event of excessive fish mortality, identify key species that are tolerant of thermal

conditions within the Lake.

The studies may incorporate the following methodologies

a. Fish Population Study

Study duration—three to five years

Sampling frequency—one survey per year during September or October

Electronic Filing - Received, Clerk's Office, July 10, 2009

3. Sampling stations—stratified design to include all lake zones with stations to be

determined after consultation with IDNR

4. Sampling gear—boat-mounted electrofisher

Sample processing—species identification, length and weight measurements, scale

samples for possible age analysis

b. Fish Behavior

Study duration—one year

Sampling frequency—one survey in mid- or late summer

Sampling stations—zig-zag transects across the lake along the axis of the lake, to

include major embayments (e.g., cemetery bay) and the northern arm above the intake

and railroad bridge

4. Sampling gear—scientific-grade hydroacoustics employing side-scan and down-

looking transducers; variable-mesh gill nets and/or boat-mounted electrofisher for

species/size composition; hand-held CTD (conductivity, temperature, and depth) and

DO meters

5. Sampling procedures—

Run simultaneous, synoptic thermal/DO 3-dimensional

mapping to characterize available habitat at the time of hydroacoustic sampling; run

additional profiles in areas of fish aggregations, as needed

Deliverables.

Ameren shall provide an

nnual summary data report and maintain an

electronic database.

Corrective Action – Fish Mortality.

During summer months, the Lake will be

monitored. In the event of an apparent fish kill, Ameren will investigate whether the fish kill

resulted from the increase in temperature and, specifically, Ameren’s electric generation

activities, resulted in the fish kill. If the fish kill resulted from the increase in thermal limits then

Ameren shall replenish or replace the impacted resource pursuant to the terms and conditions of

a Fish Stocking Plan to be developed in consultation with IDNR.

Ameren recognizes and agrees that IDNR participation in this study effort does not

prejudge or determine responsibility for fish kills in the Lake; IDNR will still be responsible for

investigation and assessment of such kills and for determining the agents and entities responsible

for fish kills. Further, IDNR participation does not commit IDNR to any position on planned or

future regulatory proceedings that might effect operations of the Ameren power plant or the

Lake.

With respect to the Petition to Modify Thermal Standard in Ameren Energy Generating

Company v. IEPA, PCB No. 2009-0038, currently pending before the Board, IDNR has

reviewed the technical support materials and consulted with Ameren’s fish experts, and has

agreed to the above described studies and actions to document and mitigate the effects, if any, of

the revised thermal standards on the lake fishery. Notwithstanding the foregoing, nothing in this

Agreement shall be construed to preclude or inhibit IDNR in any future legal proceeding.

Designated Contacts.

Notices, deliverables and other written communications made

under this Memorandum shall be sent to the persons listed herein, unless a Party designates in

writing another person as its contact:

For AMEREN

AMEREN ENERGY GENERATING COMPANY

Coffeen Power Station

134 CIPS Lane

Coffeen, IL 62739

ATTN: Plant Manager

For DNR:

Chief of Fisheries, Illinois Department of Natural Resources

One Natural Resources Way

Springfield, IL 62702-1271

IN WITNESS WHEREOF, the parties have executed this Agreement as of the date first above

written.

OWNER:

Attest:

Ameren Energy Generating Company

Department of Natural Resources, State of

Illinois

Electronic Filing - Received, Clerk's Office, July 10, 2009

AFFIDA VIT OF ANN 8. SHORTELLE. PH.D.

I, ANN 8. SHORT ELLE, PH .D., ha vin

I am a Chief Scientist with MACTEC Engineerin g and Consu lting, I

nc.

("MACT EC'), I have 24 years of professional experience in lim n

o l

ogy and lake and

eservoi r manageme nt, includi ng s

urFace wal

er quality monitoring and analysis.

In May 2009. Ameren Energy Gencnll ing Company ("'Amcren") engaged

MACTEC lO prepare a r

epo rt on the conditi

s of Coffee n L

ake wi th regar

d to phosphorus

d mercury. M ACTEC eva luated the conditi ons in Coffeen L

ake and th e potenti al fo r

impacts on phosphorus and mercury cycling

frolll

Amcrcn'

s proposed Illodifici.lli on to the

current si

te-specific thermal st

anda

rds. The r

eport is en titled "Evalu atio n of Ef

fects of

Revised Thermal Stand ards on Phosphorus and Mer

cury Cycling in Cof

feen Lake:'

I have read Secti

on C of the preceding Amcr

The statement s of facts contained therei n and the calculations cont ai

s Respon se to informat i

on Requested at Pu blic H

earing arc

InlC

and co rrecl l

O the best of my knowledge and belief.

FURTHER, A FFI ANT SA YETH NOT.

An n B. Shorlelle. Ph .D.

Subscribed and sworn t

NOTARY PUBUC.STAfE OF FI.ORlDA

Expires: MAR. 29, 2010

Bonded Thru Atlantic B

onding Co., Inc.