BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROCEDURES REQUIRED BY
)
R 07-020
P.A. 94-849 FOR REPORTING
)
(Rulemaking - Water)
RELEASES OF RADIONUCLIDES AT
)
NUCLEAR POWER PLANTS: NEW 35
)
ILL.ADM.CODE PART 1010
)
PRE-FILED TESTIMONY OF RICHARD P. COBB, P.G., OF THE ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
NOW COMES the Illinois Environmental Protection Agency, through one of its attorneys,
and hereby pre-files the enclosed testimony of Richard P. Cobb, P.G.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
/s/ Kyle Rominger
Kyle Rominger
Assistant Counsel
DATED: August 24, 2007
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Electronic Filing, Received, Clerk's Office, August 24, 2007
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROCEDURES REQUIRED BY
)
R 2007-020
P.A. 94-849 FOR REPORTING
)
(Rulemaking - Water)
RELEASES OF RADIONUCLIDES AT
)
NUCLEAR POWER PLANTS: NEW 35
)
ILL.ADM.CODE PART 1010
)
PRE-FILED TESTIMONY OF RICHARD P. COBB, P.G.,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
My name is Richard P. Cobb. I am a licensed professional geologist and the Deputy
Manager of the Division of Public Water Supplies of the Illinois Environmental Protection
Agency’s (“Illinois EPA’s”) Bureau of Water (“BOW”). My primary responsibilities include
managing the Groundwater and Source Water Protection, Field Operations, and the Administrative
Sections of the Division. Further, I assist with administering the public water supervision program
under the federal Safe Drinking Water Act (“SDWA”). Additionally, my responsibilities include
the integration of source water protection with traditional water supply engineering and treatment
practices, and assisting with linking Clean Water Act and SDWA programs. I also directly
manage the BOW’s Groundwater Section.
The groundwater section applies Geographic
Information System (“GIS”) programs, global positioning system technology, hydrogeologic
models (including, 3D geologic visualization, vadose zone, groundwater flow, particle tracking,
solute transport, and geochemical models), and geostatistical programs for groundwater protection
and remediation. I represent the BOW on Illinois EPA’s Contaminant Evaluation Group, Strategic
Management Planning Team, Environmental Justice Committee, Information Management
Steering Committee, and GIS Steering Committee. Since 1985 I have worked on the development
of legislation, rules, and regulations. I have also served as a primary Illinois EPA witness at
2
Illinois Pollution Control Board (“Board”) proceedings in the matters of groundwater quality
standards, technology control regulations, regulated recharge areas, clean-up regulations, and
water well setback zone exceptions. Furthermore, I have served as a primary Illinois EPA witness
in enforcement cases under these laws and regulations.
For further detail on my qualifications I have enclosed a copy of my Curriculum Vitae in
Attachment I. This testimony, the statement of reasons, and attachments included with this
testimony describe the basis for the proposed regulations.
PURPOSE OF THE REGULATIONS
The purpose of these regulations is to establish requirements for the owners and operators
of nuclear power generating facilities to fulfill their obligation under Section 13.6 of the Illinois
Environmental Protection Act (“Act”) (415 ILCS 5/13.6) for reporting releases of radionuclides to
soil, groundwater, or surface water to the Illinois EPA and the Illinois Emergency Management
Agency (“IEMA"). The purpose of this regulation is not to set standards for radionuclide releases,
but to merely establish requirements for reporting a release of radionuclides.
BACKGROUND
The genesis of these proposed regulations evolved from three tritium groundwater
contamination incidents that occurred at the following Exelon nuclear power generating facilities
located in Grundy, Will, and Ogle Counties: Dresden, Braidwood, and Byron, respectively.
Releases from the Braidwood facility garnered significant local and national attention. At
Braidwood, multiple releases of waste water mixed with tritium, released from leaking vacuum
breaker (“VB”) vaults along a blow down line to the Kankakee River, resulted in groundwater
contamination. In addition, other underground piping carrying tritium also leaked and resulted in
groundwater contamination at Braidwood. At Exelon’s Dresden station, numerous leaks of tritium
3
from underground piping resulted in groundwater contaminated with tritium. At Exelon’s Byron
Station leaky VB vaults along a blow down line resulted in groundwater contamination with
tritium. The tritium groundwater contamination at Byron was discovered after Public Act 94-
0849, which added Section 13.6 to the Act, was signed into law. A brief summary of tritium leaks
at each of these stations is included below.
Tritium is a radionuclide that is a byproduct of the production of electricity by nuclear
power plants. Tritium is also a naturally occurring radioactive form of hydrogen that is produced
in the atmosphere when cosmic rays collide with air molecules; as a result, naturally occurring
tritium is found in very small or trace amounts in groundwater throughout the world.
Exelon initiated a comprehensive Fleetwide Study in 2006 to determine whether
groundwater at and in the vicinity of all of its nuclear power generating facilities has been
adversely impacted by any releases of radionuclides. This study provided a comprehensive
analysis of the hydrogeologic conditions at each of its stations. Further, these studies delineated
tritium groundwater contamination at Exelon’s Zion generating station at Zion and its Quad Cities
generating station at Cordova.
Summaries of Braidwood, Dresden, and Byron Releases
Braidwood Station
- Attachment II details the multiple plumes that originated from
releases from underground piping and VB vaults at the Braidwood Station. Groundwater
contamination resulting from an approximate 3 million gallon release of tritiated waste water from
a blow down line VB3 at Exelon’s Braidwood facility, in 1998, resulted in one of the tritium
groundwater contamination plumes. Attachment III is a blow up of the plume that resulted from
this release. Further, Attachment III shows the contours of the tritium plume concentrations in the
groundwater relative to Exelon’s licensee controlled area, which is demarcated by the yellow line.
4
The area bounded by the red contour line has a tritium concentration greater than 20,000
picocuries per liter (“pCi/L”). Tritium contamination within the blue contour line, shown in
Attachment III, is at a concentration greater than 5,000 pCi/L. The concentration of tritium on the
north shore of the lake was 3,000 pCi/L, and a private drinking water system well north of the
pond had a concentration of 1,600 pCi/L. The concentration of tritium between the well and the
green contour line ranges from 1,600 to 200 pCi/L. Tritium contamination at the green contour
line is equal to 200 pCi/L. Two hundred pCi/L is the practical quantification limit (“PQL”) for
tritium. A PQL is the lowest concentration or level that can be reliably measured with 95 percent
confidence in the value (e.g., 200 vs. 201).
The plume illustrated in Attachment IV was continuing to move toward private drinking
water system wells down gradient. Exelon subsequently purchased the off-site property with the
well degraded by tritium contamination.
Tritium was found, using an enriched tritium testing method, in the Braidwood cooling
water pond at a concentration of 35 pCi/L. Thus, the true background concentration of tritium at
Braidwood is 35 pCi/L. However, enriched tritium tests are primarily only used in research
laboratories. Due to the technical feasibility and economical reasonableness issues associated with
using the enriched tritium laboratory method, Illinois EPA believes the use of the 200 pCi/L PQL
as a threshold for reporting releases is appropriate because it can be readily performed by Exelon,
IEMA’s Division of Nuclear Safety, and other commercial laboratories.
Dresden Station
- On October 15, 2004, the Illinois EPA first became aware of a release
of tritium from the Dresden Station from a
Crain’s Chicago Business
article. The article indicated
some piping at the plant had developed leaks, which allowed the discharge of tritiated water from
5
the Dresden Station. On October 25, 2005, IEMA indicated that there was a 9,000,000 pCi/L
release of tritium from a broken underground pipe.
The Dresden Station site sits on top of bedrock, and much of the piping for the Dresden
Station sits in excavated bedrock trenches. In 1994 Exelon had experienced a leak from the
underground piping at the Dresden Station. In response, they backfilled the area around the piping
with sand and installed a number of leak detection monitoring wells sunk to depths of ten to twenty
feet. The 2004 leak was discovered when concentrations of tritium in the range of 3,000,000 to
6,000,000 pCi/L were found in the leak detection monitoring wells installed after the 1994 release.
Exelon officials stated that the highest concentration of tritium found on site was 20,000,000
pCi/L.
Exelon investigations concluded that the tritium detected in monitoring wells and storm
sewers located near what is referred to as the “Unit 2/3 interlock building” originated from a
release in the condensate storage tank (“CST”) system through a pipe that passed under a liquid
nitrogen tank. The pipe was shut down on October 20, 2004, and a replacement section of pipe
around the tank was installed in November 2004. Tritium-impacted groundwater is currently
migrating both east and west. There are two active storm sewer systems at the Dresden Station,
with one originating immediately east of the liquid nitrogen tank, draining the southeastern and
northeastern perimeter of the turbine building and discharging to what is referred to as the “Unit 1
intake canal”. The second storm sewer originates immediately to the west of the liquid nitrogen
tank, drains the western perimeter of the turbine building, and drains to what is referred to as the
“Unit 2/3 discharge canal” through an outfall located in the west side of the canal. Tritium has
migrated into both storm sewer systems, although to a greater extent into the eastern system. The
source of the eastern system tritium appeared to be from the CST system.
6
It is estimated that the width of the plume of contamination at its source was approximately
20 feet. The depths of both the east and west-moving plumes near the source were estimated at
approximately 10 feet. The plume length in the eastern direction was estimated at 210 feet, with a
maximum plume width of 62 feet. The west flowing plume length was estimated at 255 feet, with
a maximum width of approximately 70 feet. A map of the tritium groundwater contamination
plume at the Dresden Station is provided in Attachment V. Tritium concentrations in this plume
map are delineated by concentration areas, as follows:
•
Red - represents the boundary of tritium concentrations greater than 5,000
pCi/L;
•
Light green – represents the boundary of tritium concentrations of 1,000 to
5,000 pCi/L; and
•
Dark green – represents the boundary of tritium concentrations between 200
to 1,000 pCi/L
Based on tritium concentrations in the CST system of 9,000,000 to 10,000,000 pCi/L, it was
estimated that approximately 121,000 gallons of tritiated water were released to groundwater and
approximately 148,000 gallons of tritiated water were released to the storm sewer system.
On February 14, 2006, IEMA notified the Illinois EPA of a new release of tritium found at
the Dresden Station. Exelon informed IEMA’s resident inspector on February 11, 2006, that it
believed an underground pipe was leaking near what is referred to as the “B CST.” The E-3
monitoring well near the area showed tritium concentrations at 5,000 pCi/L on January 3, 2006;
89,000 pCi/L on January 19, 2006; and 529,000 pCi/L on February 13, 2006. Exelon believed the
leak was in a portion of the 30+ year old piping that it did not replace when it made its November
2004 repairs. Exelon also indicated the valve used to isolate the pipe section was also leaking and
would need replacement.
7
Byron Station
- Internal inspections at Byron reported on Feb. 15, 2006, found standing
water inside five of six concrete VB vaults in the ground that are part of the blow down line, which
runs along a strip of company property to the Rock River. Tests showed the standing water in the
vaults contained tritium. After finding tritiated water in the vaults, Exelon arranged for
independent testing of drinking water wells at nine homes closest to the property line. None
showed detectable levels of tritium. Monitoring wells installed by Exelon showed elevated tritium.
One well showed a concentration of about 4,080 pCi/L, and the other about 459 pCi/L.
Attachment VI shows the location of the wells tested at the Byron Station and the associated
locations. No tritium has migrated outside of the licensee controlled area at the Byron Station.
EXPLANATION OF THE ILLINOIS EPA’S PROPOSAL
Section 1010.106 Definitions
This Section provides the definitions utilized in the proposed regulations. Many
definitions proposed in the regulations are codified in the Act or Board regulations (e.g., “Act”,
“Agency”, “Groundwater”, “Person”, etc.), or are consistent with other Board rules. The definition
of picocuries per liter is consistent with the definition in the Board’s primary drinking water
regulations at 35 Ill. Adm. Code 611.101.
SUBPART B: REPORTING
Section 1010.200 Evaluation of Releases
This Section provides the key thresholds for detecting and reporting releases under the
proposed regulation. The thresholds that trigger reporting were selected in order to identify
releases of tritium that may cause, threaten, or allow degradation of surface or groundwater
resources beyond the licensee control area boundary. Further, the thresholds were based on
8
practical experience in dealing with the Exelon sites, tritium’s laboratory PQL, groundwater fate
and transport modeling, and the Fleetwide Studies conducted by Exelon.
The reporting thresholds are based on tritium concentrations because our experience has
shown that the only radionuclide being found is tritium. Tritium is basically the same composition
as water (H
3
) and is highly mobile. Reverse osmosis treatment removes other radionuclide
contaminants in cooling water. However, there is no conventional or advanced treatment
technique (e.g., reverse osmosis) for removing tritium. This is the reason why blow down lines
were constructed at the Braidwood and Byron stations. The tritiated water is diluted with waste
water and is discharged to the Kankakee and Rock Rivers, respectively.
The proposed off-site reporting threshold is based on the PQL of 200 pCi/L for tritium.
Illinois EPA is recommending the PQL because it is used in the existing Board’s preventive notice
and response provisions of 35 Ill. Adm. Code 620.305 and 620.310. Moreover, as noted above, the
PQL is reasonably achieved in commercial, State, and private laboratories. Exelon is in agreement
with this threshold.
The on-site reporting threshold is based on the Exelon suggested level of 0.002 Ci of
tritium. Ci is a unit of measure that on-site Exelon staff is familiar with, and one that they can
easily use to relate the “occurrence” of a release in a rapid manner versus waiting on analytical
testing and detection to occur. Concentrations in pCi/L can also be easily calculated from Ci.
Thus, Ci was recommended due to its proactive and practical utility.
A groundwater fate and transport model (BIOSCREEN) was used to determine if a 0.002
Ci release on-site would be sufficiently conservative to predict if 200 PCi/L would be exceeded
beyond the licensee controlled area. Release scenarios were modeled for the Braidwood, Quad
Cities, and Zion Stations. Each Station was selected based on soil and groundwater characteristics
9
that give these Stations the highest potential for groundwater contamination. Further, each Station
contains adjacent surface water or groundwater resources proximate to its licensee controlled area.
Braidwood had the closest private drinking water system wells located north of the plume shown
in Attachment IV.
Groundwater Principles
- Water infiltrating the soil may evaporate, or be used by plants
and be transpired. The remainder migrates downward through pore spaces in soil or rock,
eventually reaching a zone where all pore spaces are saturated. The surface of this zone of
saturation is called the "water table". All water below the water table is considered groundwater
(415 ILCS 5/3.64 and 35 Ill. Adm. Code 620.105). The water table can be determined by
measuring the elevation of water surfaces in wells which penetrate the saturated zone. Under
natural conditions, the water table forms a surface which resembles the overlying land surface
topography, only in a more subdued and smoother configuration. The water table generally will be
at higher elevations beneath upland areas and at lower elevations in valley bottoms. The water
table may intersect the ground surface along perennial streams, springs, and lakes which are
natural areas of groundwater discharge. Groundwater moves in a fashion somewhat analogous to
surface water, only at much slower rates. While surface water moves downhill in response to
gravity, groundwater moves down gradient from areas of higher potential energy to areas of lower
potential energy. These areas of equal elevation are described as “hydraulic head”. Groundwater
flows from recharge zones, where infiltration occurs, to discharge zones, where groundwater
discharges into streams and lakes.
The direction of groundwater movement can be estimated from a map of the potentiometric
surface, i.e., a contour map of the elevations of water levels in observation wells. Generally,
groundwater flow will be perpendicular to the contours of the potentiometric surface. The rate of
groundwater movement is related to the permeability of the aquifer and the magnitude of the slope
of the potentiometric surface. In quantitative terms, "hydraulic conductivity" is used in place of
permeability and is a function of the size and shape of pore spaces, the degree of interconnection
of these spaces, and the type of fluid (e.g., water, oil, or brines) passing through the medium.
In general, contaminants are transported in the direction of groundwater flow. Transport in
this manner, that is, transport of dissolved constituents (solutes) at the same speed as the average
groundwater pore velocity, is called
advection
. Groundwater movement is governed by the
hydraulic principles described by Darcy's Law. This equation states that the flow rate of a liquid
through a porous medium is proportional to the head loss and inversely proportional to the length
of the flow path. The Darcian velocity assumes that flow occurs across the entire cross section of
the porous material without regard to solid or pore spaces. Actually, flow is limited to the pore
space only. Darcy’s Law can be rearranged to determine the average linear velocity or a velocity
representing the average
rate at which groundwater moves between two points, as follows:
V
x
= -
n dl
Kdh
e
Where:
V
x
= average linear velocity feet per day (ft/d)
K
=
hydraulic conductivity (ft/d)
n
e
= effective porosity (dimensionless)
dh
= delta or change in groundwater head elevation (ft)
dl
= delta or change in distance between wells (ft)
10
11
In natural porous materials, the pores possess different sizes, shapes, and orientations.
Similar to stream flow, a velocity distribution exists within the pore spaces such that the rate of
movement is greater in the center of the pore than at the edges. Thus, in saturated flow through
these materials, velocities vary widely across any single pore and between pores. As a result, a
miscible fluid (immiscible fluids do not have complete mutual solubility and co-exist as separate
phases) will spread gradually to occupy an ever increasing portion of the flow field when it is
introduced into a flow system. This mixing phenomenon is known as
dispersion
. In this sense,
dispersion is a mechanism of dilution. Dispersion acts to reduce the peak concentration of a "slug"
of material introduced into a flow field. However, dispersion also acts to reduce the travel time of
migration because some dissolved material will move ahead of what would actually have been
predicted by advective movement only.
As water soluble contaminants migrate hydraulically down gradient from their source and
are acted on by advection and dispersion, their peak concentrations tend to decline progressively.
This is due to dilution, retardation, and transformation (e.g., the half life of tritium is 12 years)
processes. Dilution occurs because dispersive and molecular diffusion processes cause the
contaminant to spread out and mix with uncontaminated groundwater. Retardation of a plume
front occurs due to reactions with soil or aquifer materials. There is no retardation expected with
tritium.
Contaminant masses either move as a slug from a “one time source” of contamination or
move as a contamination plume from a “continuous source” of contamination.
Modeling Approach
- First, a hypothetical source of tritium contamination was identified
for each site that is representative of systems at nuclear generating stations. The hypothetical
source was then used as the point of release for the model. Secondly, the model BIOSCREEN,
was then used to determine if a release of 0.002 Ci would leave the licensee controlled area, and
cause, threaten, or allow contamination of off-site resource groundwater at a concentration greater
than 200 pCi/L. BIOSCREEN is an analytical (versus numerical) solute transport model that
calculates solute migration under uniform groundwater flow conditions based on the Domenico
equation. Section 742.810 of the Board’s Tiered Approach to Correction Action Objectives
(“TACO”) regulations references the following R26 equation, detailed in Section742.Appendix C:
Cx
Csource
X
x
x
U
erf
Sw
yX
erf
Sd
zX
()
exp
=
••
−
+
•
•
••
•
••
⎛
⎝
⎜
⎞
⎠
⎟
⎛
⎝
⎜
⎞
⎠
⎟
⎡
⎣
⎢
⎢
⎤
⎦
⎥
⎥
⎡
⎣
⎢
⎢
⎤
⎦
⎥
⎥
⎡
⎣
⎢
⎢
⎤
⎦
⎥
2
⎥
11
4
α
42
λα
αα
R26 is the Domenico equation, which is the governing equation for BIOSCREEN. Figure 1 below
is a screen shot of the graphical user interface for BIOSCREEN.
12
Fi
gure 1. Screen shot of BIOSCREEN Model GUI
The scenarios modeled were “conservative” or “reasonable worst case” scenarios. There
were three basic objectives:
1)
Determine if a release of 0.002 Ci of tritium from a “representative” source
at a nuclear generating station would migrate off-site;
2)
Predict the migration of the tritium in groundwater with respect to the
licensee controlled area, and with respect to adjacent properties and water
bodies; and
3)
Use the modeling results to calculate leakage rates and associated
concentrations (e.g., 0.71 gallons per minute and 17,248 pCi/L) to determine
if they are realistic.
The models were completed using station-specific groundwater and soil characteristics.
The model was then adjusted to look at a time-specific source of contamination (e.g., a 30-day
13
14
release) versus a continuous source of contamination. Exelon has indicated that it is now
conducting monthly integrity tests of underground piping and blow down lines and has real-time
moisture sensors installed in VB vaults. Thus, it is anticipated that no leak would go undetected
more than 30 days. The model evaluated an equivalent “slug” of tritiated water released into the
aquifer over a 30-day period as shown in the conceptual models illustrated in Attachments VII,
VIII, and IX.
BIOSCREEN was used to assess systems at nuclear stations where releases could go
unnoticed in the subsurface. The modeling scenario assumed a release of tritiated water would
occur most commonly in buried pipes. Moreover, it was assumed that a conservative time between
leak start and discovery would be 30 days (e.g., monthly monitoring or maintenance schedule).
Further, the assumed release manifested itself in a buried pipe trench or backfill, as shown in
Attachment X.
The geologic cross section in Attachment XI illustrates the Class I groundwater at the
Braidwood Station. The uppermost aquifer is composed of coarse grained sand and gravel.
Attachment XII is a partial contour map of the potentiometric or water table elevation in the
subsurface materials at the Braidwood Station. Groundwater flows down gradient perpendicular to
these contours, or lines of equal elevation or head.
Table I below details the aquifer property data that was obtained or calculated for the
Braidwood Station and input into BIOSCREEN. Further, Table I also contains the resultant data
predicted by the model. In the model a mass of 0.002 Ci in 30,633 gallons of tritiated water, or a
concentration of 17,248 pCi/L, was released for a period of 30 days. For reference, the 3,000,000
gallon release from VB 3 in 1996 is estimated to have been at a concentration of 1,000,000 pCi/L.
In 2006, the source area of the release was measured at a concentration of 226,000 pCi/L.
BIOSCREEN predicts that the tritium plume will migrate 595 feet in 237 days, as roughly
shown in Attachment XV. Moreover, BIOSCREEN predicts that 17,248 pCi/L concentration of
tritium will be reduced down to concentration of 200 pCi/L at distance of 595 feet (“ft”) via
dispersion. As discussed previously, dispersion refers to spreading of a contaminant caused by the
fact that not all of the contaminant actually moves at the same linear velocity as the groundwater.
In this scenario, a release of this magnitude is predicted not to cause, threaten, or allow off-site
degradation of the groundwater at a concentration greater than or equal to 200 pCi/L.
Table I. Aquifer property data and modeling results
Attachments XIII, XIV, and XV provide a schematic picture of the slug of tritium moving
through the groundwater at Braidwood: 70 days after the end of the spill (plume front is at 350 ft
from source); 150 days after the end of the spill (plume front is at 500 ft from source); and 237
days after the end of the spill (plume front is at 595 ft from source). The tritium contaminant slug
is predicted by BIOSCREEN to be at a concentration of less than 200 pCi/L, before it crosses the
licensee controlled area boundary shown in Attachment XV.
15
Electronic Filing, Received, Clerk's Office, August 24, 2007
The information obtained from the Braidwood modeling scenario is very useful from a
pragmatic standpoint. First, we know how the Braidwood hydrogeologic susceptibility varies with
respect to the other Exelon facilities. Thus, we now have a hydrogeologic susceptibility reference
point. Secondly, if we have a release with an estimated mass of tritium from an underground
pipeline or waste water conveyance in a setting more or less susceptible than Braidwood, we know
what the potential fate and transport will be at distances more than or less than 595 feet. Further,
this distance is based on the known location of under ground piping. No piping is expected to be
closer to the boundaries of the licensee controlled areas at other Exelon facilities than what was
used in the modeling.
As a final step of the evaluation of the appropriateness of the proposed release reporting
thresholds, modeling was also performed for the Zion and Quad Cities facilities at various source
loading rates. Table II below provides the leakage rates used in each of these modeling runs.
Table II. Rate of leakage and concentrations used for additional modeling runs
16
Electronic Filing, Received, Clerk's Office, August 24, 2007
Table III below provides the results of the modeling scenarios with the maximum distances
needed to reach 200 pCi/L concentrations. These results do not predict that tritium will cause,
threaten, or allow tritium concentrations greater than 200 pCi/L beyond the licensee controlled
area.
Table III. Modeling results for Braidwood, Quad Cities, and Byron Station
The modeling results combined with knowledge about the Exelon stations (e.g.,
hydrogeologic susceptibility, layout, and design) show that 0.002 Ci is a conservative spill
reporting threshold for on-site releases of tritiated water. In addition, it is based on occurrence and
does not wait on detection. Furthermore, Exelon’s detection monitoring program (real time
sensors and groundwater monitoring wells) will serve as a backup for detecting tritium. Finally,
the reporting threshold will show if resource groundwater beyond the licensee controlled area
boundary is being caused, threatened, or allowed to exceed 200 pCi/L.
Section 1010.202 Reporting of Releases
This Part details the form and format of how a release must be reported to the Illinois EPA
and IEMA. Illinois EPA duty officers and first responders have an established communication
protocol with IEMA and the State Emergency Operations Center. This protocol uses cellular and
17
18
satellite technology via smart phones, and other wireless devices. Thus, this is the technological
basis for the proposed electronic method of reporting.
Section 1010.204 Follow-up Written Report
Illinois EPA believes it is essential to require a follow-up written report to the initial rapid
response report. It is our experience that more times than not information provided in the rapid
response mode needs to be clarified and supplemented. This report provides the ability to provide
follow-up. More importantly, today’s societal demands dictate that we provide this type of
information; it is expected to meet citizen’s information demands. Moreover, these requirements
will provide a practical bridge to the Right-to-Know (“RTK”) provisions of the Act (415 ILCS
5/25d), and the Board’s Community Relations Activities Performed in Conjunction with Illinois
EPA Notices of Threats from Contamination (35 Ill. Adm. Code 1600).
The reporting requirements do not establish assessment demands, but are merely intended
to capture reasonably available information. This information will be vital in addressing the
public’s RTK and concern about such releases. The elements that are proposed to be reported are
based in part on the Board’s RTK regulations.
CONCLUSION
This concludes my testimony. I will be happy to address any questions.
Attachment I.
CURRICULUM VITAE
RICHARD P. COBB, P.G.
Work Experience
Deputy Manager, Division of Public Water Supplies (DPWS)
,
Bureau of Water (BOW), Illinois
Environmental Protection Agency (EPA). (5/02- Present) My primary responsibilities include
managing the Groundwater and Source Water Protection, Field Operations, and the Administrative
Sections of the Division. Further, I assist with administering the public water supervision program
under the federal Safe Drinking Water Act (“SDWA”) and the Wellhead Protection Program
(“WHPP”) approved by the United States Environmental Protection Agency (‘U.S. EPA”).
Additionally, my responsibility includes the integration of source water protection with traditional
water supply engineering and treatment practices, and to further assist with linking Clean Water
Act and SDWA programs. I also directly manage the BOW’s Groundwater Section. The
Groundwater Section applies Geographic Information System (“GIS”) programs, global
positioning system (“GPS”) technology, hydrogeologic models (3D geologic visualization, vadose
zone, groundwater flow, groundwater particle tracking, solute transport, and geochemical models),
and geostatistical programs for groundwater protection and remediation projects.
The
Groundwater Section also continues to operate a statewide ambient groundwater monitoring
program for the assessment of groundwater protection and restoration programs. I also do
extensive coordination with federal, state and local stakeholders including the Governor appointed
Groundwater Advisory Council (“GAC”), the Interagency Coordinating Committee on
Groundwater (“ICCG”), four Priority Groundwater Protection Planning Committees, Illinois
Source Water Protection Technical and Citizens Advisory Committee, and with the Ground Water
Protection Council (“GWPC”), Association of State Drinking Water Administrators (“ASDWA”),
and the Association of State and Interstate Water Pollution Control Administrators (“ASWIPCA”)
to develop and implement groundwater protection policy, plans, and programs. I represent the
BOW on Illinois EPA’s: Contaminant Evaluation Group (“CEG”); Strategic Management
Planning Team; Environmental Justice Committee; Information Management Steering Committee;
and the GIS Steering Committee. Since starting with Illinois EPA in 1985, I have worked on the
development of legislation, rules and regulations. I have also served as a primary Illinois EPA
witness before Senate and House legislative committees, and at Illinois Pollution Control Board
(“Board”) proceedings in the matter of groundwater quality standards, technology control
regulations, cleanup regulations, regulated recharge areas, maximum setback zone, and water well
setback zone exceptions. Furthermore, I have served as primary Illinois EPA witness in
enforcement matters.
Manager, Groundwater Section
,
DPWS, BOW, Illinois EPA. (9/92-5/02) My primary
responsibilities included development and implementation of Illinois statewide groundwater
quality protection, USEPA approved WHPP, and source water protection program.
The
Groundwater Section worked with the United States Geological Survey (“USGS”) to refine Illinois
EPA’s ambient groundwater monitoring network using a random stratified probability based
design. The Groundwater Section continued to operate a statewide ambient groundwater
monitoring program for the assessment of groundwater protection and restoration programs based
on the new statistically-based design. I co-authored a
Guidance Document for Conducting
2
Groundwater Protection Needs Assessments
with the Illinois State Water and Illinois State
Geological Surveys. I also continued to conduct extensive coordination with federal, state and
local stakeholders including the Governor appointed GAC, the ICCG, four Priority Groundwater
Protection Planning Committees, Illinois Source Water Protection Technical and Citizens
Advisory Committee, and at the national level as Co-chair of the GWPC Ground Water Division to
develop and implement groundwater protection policy, plans, and programs. I also served
periodically as Acting Manager for the Division of Public Water Supplies. Additionally, the
Groundwater Section provided hydrogeologic technical assistance to the BOW Permit Section and
Mine Pollution Control Program to implement source water protection, groundwater monitoring
and aquifer evaluation and remediation programs. I continued to work on the development of
legislation, rules and regulations. I also served as a primary Illinois EPA witness at Board
proceedings in the matter of groundwater quality standards, technology control regulations,
regulated recharge areas and water well setback zone exceptions. Furthermore, I served as an
Agency witness in enforcement matters.
Acting Manager, Groundwater Section
,
DPWS, BOW, Illinois EPA. (7/91-9/92) My
responsibilities included continued development and implementation of Illinois statewide
groundwater quality protection, U.S. EPA approved WHPP, and ambient groundwater monitoring
program. The Groundwater Section developed the Illinois EPA’s WHPP pursuant to Section 1428
of the SDWA and was fully approved by U.S. EPA. Illinois EPA was the first state in U. S. EPA
Region V to obtain this approval. I performed extensive coordination with state and local
stakeholders including the Governor appointed GAC, the ICCG to develop and implement
groundwater protection, plans, policy, and programs.
Developed and implemented the
establishment of Illinois’ Priority Groundwater Protection Planning Committees. Developed and
implemented Pilot Groundwater Protection Needs Assessments. The Groundwater Section also
provided hydrogeologic technical assistance to the BOW Permit Section and Mine Pollution
Control Program staff to develop groundwater monitoring and aquifer evaluation, remediation
and/or groundwater management zone programs. I also served as a primary Agency witness at
Board proceedings in the matter of groundwater quality standards and technology control
regulations. Additionally, I served as an Agency total quality management (“TQM”) facilitator,
and TQM trainer.
Manager of the Hydrogeology Unit
,
Groundwater Section, DPWS, Illinois EPA (7/88-7/91)
Managed a staff of geologists and geological engineers that applied hydrogeologic and
groundwater modeling principals to statewide groundwater protection programs. Developed, and
integrated the application of GIS, GPS, geostatistical, optimization, vadose zone, solute transport,
groundwater flow and particle tracking computer hardware/software into groundwater protection
and remediation projects. Conducted extensive coordination with state and local stakeholders
including the Governor appointed GAC and ICCG to develop and implement groundwater
protection policy, plans, and programs. Developed and implemented a well site survey program to
inventory potential sources of contamination adjacent to community water supply wells.
Additionally, I worked on the development of rules to expand setback zones based on the lateral
area of influence of community water supply wells. Furthermore, I provided administrative
support to the Section manager in coordination, planning, and supervision of the groundwater
program. I also assisted with the development of grant applications and subsequent management
of approved projects. In addition, I assisted the section manager with regulatory and legislative
3
development in relation to the statewide groundwater quality protection program. I also served on
the Illinois EPA’s Cleanup Objectives Team (“COT”).
Environmental Protection Specialist I, II, and III, Groundwater Section
, DPWS, Illinois EPA.
(7/85-7/88) I was the lead worker and senior geologist in the development and implementation of
Illinois statewide groundwater quality protection program. I worked on the development of
Illinois EPA’s ambient groundwater monitoring network, and field sampling methods and
procedures with the USGS. I published the first state-wide scientific paper on volatile organic
compound occurrence in community water supply wells in Illinois. In addition, I assisted with the
development of
A Plan for Protecting Illinois Groundwater
, and the legislation that included the
Illinois Groundwater Protection Act
.
Consulting Well Site Geologist
,
Geological Exploration (GX) Consultants, Denver Colorado.
(3/81-12/83)
I worked as a consulting well site geologist in petroleum exploration and
development for major and independent oil companies. I was responsible for the geologic
oversight of test drilling for the determination and presence of petroleum hydrocarbons. Prepared
geologic correlations and performed analysis of geophysical logs, drilling logs and drill cuttings.
Supervised and analyzed geophysical logging. Made recommendations for conducting and
assisted with the analysis of drill stem tests and coring operations. In addition, I provided daily
telephone reports and final written geologic reports to clients.
Undergraduate Teaching Assistant
,
Geology Department, Illinois State University. (3/79-3/81) I
was responsible for teaching and assisting with lecture sessions, lab sessions, assignment
preparation and grading for Petrology, Stratigraphy and Geologic Field Technique courses.
Undergraduate Education
B.S Geology
, 1981, Illinois State University (“ISU”). Classes included field geology at South
Dakota School of Mines and Technology, and Marine Ecology Paleoecology at San Salvador Field
Station, Bahamas
Post Graduate Education
Hydrogeology and Engineering Geology
, 1984, ISU Graduate Hydrogeology Program
Geochemistry for Groundwater Systems
, 1986, USGS National Training Center
Hydrogeology of Waste Disposal Sites
, 1987, ISU Hydrogeology Program
Hydrogeology of Glacial Deposits in Illinois
, 1995, ISU Graduate Hydrogeology Program
MODFLOW, MODPATH and MT3D groundwater modeling
, 1992, USGS National Training
Center
24 Hour Occupational Health & Safety Training
, 1994
4
Computer Modeling of Groundwater Systems
, 1995, ISU Graduate Hydrogeology Program
Introduction to Quality Systems Requirements and Basic Statistics
, 2001, U.S. EPA
Source Water Contamination Prevention Measures
, 2001, U.S.EPA, Drinking Water Academy
Understanding Fate and Transport Processes and Models
, 2006, Risk Assessment and
Management Group, Inc.,
National Incident Management System (NIMS) an Introduction
IS-00700
, 2006, Emergency
Management Institute (EMI),
Introduction to the Incident Command System (ICS)
IS-00100
, 2006, EMI
ICS for Single Resources and Initial Action Incidents
IS-00200
, 2006, EMI,
License
Licensed Professional Geologist
196-000553, State of Illinois, expires 3/31/2009
Certification
Certified Professional Geologist
7455, Certified by the American Institute of Professional
Geologists 4/88
Certified Total Quality Management Facilitator
, 5/92, Organizational Dynamics Inc.,
Summary of Computer Skills
I am proficient with using the following computer programs ARC VIEW, Aqtesolv, SURFER,
WHPA, DREAM, AQUIFEM, MODFLOW, MODPATH, and MT3D. I can also use multiple
analytical solute transport models based on the Domenico equation.
Professional Representation
Illinois EPA liaison to the
GAC
and representative on the
ICCG
(1988 – present)
Illinois EPA representative,
Senate Working Committee on Geologic Mapping
.
Illinois EPA representative and subcommittee chairman,
State Certified Crop Advisory Board
,
and
Ethics and Regulatory Subcommittee
established in association with the American Society of
Agronomy/American Registry of Certified Professionals in Agronomy, Crops and Soils (1995 –
2001)
Member,
Illinois groundwater quality standards regulations technical work group
(1988 –
1991).
5
Illinois EPA representative,
ICCG State Pesticide Management Plan Subcommittee
for the
protection of groundwater.
Illinois EPA representative,
State task group involved with developing the siting criteria for a low
level radioactive waste site in Illinois.
Member,
Fresh Water Foundation's Groundwater Information System (GWIS)
project in the
great lakes basin.
Illinois EPA technical advisor,
four priority regional groundwater protection planning
committees
designated by the Director to advocate groundwater protection programs at the local
level (1991 – present)
Member,
Groundwater Subcommittee of the National Section 305(b) Report, of the Clean Water
Act Consistency Workgroup
.
Member,
Ground Water Protection Council’s Wellhead Protection Subcommittee
.
Co-Chair,
Groundwater Division of the GWPC
on (September 1997 to 2003)
Chairman of
Illinois’ Source Water Protection Technical and Citizens Advisory Committee
.
Member,
United States Environmental Protection Agency National Ground Water Report Work
Group
. One of 10 state representatives serving on a work group sponsored by U.S. EPA
headquarters charged with development of a national report to be submitted to the U.S. Congress
on the status and needs for groundwater protection programs across the country. (January 1999 to
July 2000)
Illinois EPA representative,
Northeastern Illinois Planning Commission Water Supply Task
Force
. The purpose of this task force is to assist the Commission in the development of a
Strategic Plan for Water Resource Management. (March 1999 to 2001)
Member,
GWPC/U.S. EPA Futures Forum Work Group
providing input on source water
protection for the next 25 years. (January 1999 to 2001)
Member,
GWPC/ASDWA work group providing input into the U.S. EPA Office of Ground and
Drinking Water Strategic Plan for Source Water Protection
. June 2000 to March 2005.
Co-Chair
,
U.S. EPA Headquarters/GWPC/ASDWA/ASWIPCA workgroup to develop the second
Ground Water Report to Congress
. March 2002 –present.
Chair,
ICCG Groundwater Contamination Response Subcommittee
responsible for developing a
new strategy for responding to groundwater contamination and the subsequent notification of
private well owners. March 2002 – April 2002.
6
Illinois EPA representative
,
ICCG Water Quantity Planning Subcommittee
working on
development of a surface and groundwater quantity- planning program for Illinois. June 2002 –
January 2003
Chair,
ICCG Right-to-Know (RTK) Subcommittee
Professional Affiliation
American Institute of Professional Geologists
Illinois Groundwater Association
Ground Water Protection Council
National Groundwater Association -Association of Groundwater Scientists and Engineers
Sigma Xi
– The Scientific Research Society
Honors
Sigma Xi
-4/81-
Elected to
Sigma Xi
The Scientific Research Society for undergraduate research
conducted and presented to the Illinois Academy of Science.
Director’s Commendation Award
- Participation in the development of the City of Pekin, Il.
Groundwater Protection Program and commitment to the protection of Illinois groundwater. 7/95
Certificate of Appreciation
- Outstanding contribution to the development of the Ground Water
Guidelines for the National Water Quality Inventory 1996 Report to Congress from the United
States Environmental Protection Agency Office of Ground Water and Drinking Water. 8/96
Groundwater Science Achievement Award
- Illinois Groundwater Association for outstanding
leadership and service in the application of groundwater science to groundwater protection in
Illinois and in the development of the wellhead protection program and pertinent land-use
regulations. 11/97
Certificate of Appreciation
- GWPC for distinguished service, remarkable dedication, valuable
wisdom and outstanding contribution as a GWPC member, division co-chair and special
committee member. 9/99
Drinking Water Hero Recognition
- United States Environmental Protection Agency
Administrator Carol Browner at the 25
th
Anniversary of the Federal Safe Drinking Water Act
Futures Forum in Washington D.C. 12/99.
Certificate of Recognition
- United States Environmental Protection Agency Region V
Administrator Fred Lyons for outstanding achievements in protecting Illinois’ groundwater
resources. 12/99
Exemplary Systems in Government (ESIG) Award
- Nomination by the Governor’s Office of
Technology from the Urban and Regional Information Systems Association (URISA) for the
7
Illinois EPA’s Source Water Assessment and Protection Internet Geographic Information System.
6/01
Publications
Cobb, R.P., 1980.
Petrography of the Houx Limestone in Missouri
. Transactions of the Illinois
Academy of Science Annual Conference, Illinois Wesleyan, Bloomington, IL.
A Plan for Protecting Illinois Groundwater
, 1986, Illinois Environmental Protection Agency,
January. 65 p.
Cobb, R.P., and Sinnott, C.L., 1987.
Organic Contaminants In Illinois Groundwater
.
Proceedings of the American Water Resources Association, Illinois Section, Annual Conference,
Champaign, IL, April 28-29, p. 33-43.
Clarke, R.P., and Cobb, R.P., 1988.
Winnebago County Groundwater Study
. Illinois
Environmental Protection Agency. 58 pp.
Groundwater in Illinois: A Threatened Resource, A Briefing Paper Regarding the Need for
Groundwater Protection Legislation
, April 1987, Governors Office and Illinois Environmental
Protection Agency, 34 pp.
Clarke, R.P., Cobb, R.P. and C.L. Sinnott, 1988.
A Primer Regarding Certain Provisions of the
Illinois Groundwater Protection Act
.
Illinois Environmental Protection Agency. 48 pp.
Cobb, R.P., etal, 1992.
Pilot Groundwater Protection Needs Assessment for the City of Pekin
.
Illinois Environmental Protection Agency. 111 pp.
Cobb, R.P., 1994.
Briefing Paper and Executive Summary on the Illinois Groundwater
Protection Act and Groundwater Protection Programs with Recommendations from the Illinois
Environmental Protection Agency Regarding the Siting of a Low Level Radioactive Waste Site
.
Presented to the Low Level Radioactive Waste Task Force on December 9, 1994 in Champaign-
Urbana.
Cobb, R.P., 1994.
Measuring Groundwater Protection Program Success
. In the proceedings of a
national conference on Protecting Ground Water: Promoting Understanding, Accepting
Responsibility, and Taking Action. Sponsored by the Terrene Institute and the United States
Environmental Protection Agency in Washington D.C., December 12-13, 1994.
Cobb, R.P., Wehrman, H.A., and R.C. Berg, 1994.
Groundwater Protection Needs Assessment
Guidance Document
. Illinois Environmental Protection Agency. +94 pp.
Cobb, R.P., and Dulka, W.A., 1995.
Illinois Prevention Efforts: The Illinois Groundwater
Protection Act Provides a Unified Prevention-Oriented Process to Protect Groundwater as a
Natural and Public Resource
, The AQUIFER, Journal of the Groundwater Foundation, Volume 9,
Number 4, March 1995. 3pp.
8
Cobb, R.P., 1995.
Integration of Source Water Protection into a Targeted Watershed Program
.
In the proceedings of the Ground Water Protection Council’S Annual Ground Water Protection
Forum in Kansas City Missouri.
Dulka, W.A., and R.P. Cobb, 1995.
Grassroots Group Forges Groundwater Protection Law
.
American Water Works Association, Opflow, Vol. 21 No. 3. 2pp.
Cobb, R.P., 1996.
A Three Dimensional Watershed Approach: Illinois Source Water Protection
Program
. In the proceedings of the Ground Water Protection Council’s Annual Ground Water
Protection Forum in Minneappolis Minnesota.
Cobb, R.P., and W.A. Dulka, 1996.
Discussion Document on the Development of a Regulated
Recharge Area for the Pleasant Valley Public Water District
. Illinois Environmental Protection
Agency. pp 28.
Cobb, R.P., 1996.
Illinois Source Water Protection Initiatives-Groundwater Perspective
. In the
proceedings of the American Water Works Association’s Annual Conference and Exposition in
Toronto Canada. pp 585- 594.
Cobb, R.P., and Dulka, W.A., 1996.
Illinois Community Examines Aquifer Protection Measures
.
American Water Works Association Journal. p10.
Cobb, R.P., etal. October 1999,
Ground Water Report to Congress
, United States Environmental
Protection Agency.
Cobb, R.P., December 2001.
Using An Internet Geographic Information System (GIS) to Provide
Public Access to Hydrologic Data
,
Association of Groundwater Scientists and Engineers, National
Groundwater Association, National Conference Proceedings, Nashville, Tennessee.
Cobb, R.P., September 2001
,
Regulated Recharge Area Proposal for the Pleasant Valley Public
Water District
,
Ground Water Protection Council Annual Forum Proceedings, Reno Nevada, 13
pp.
Wilson, S., Cobb, R.P., and K. Runkle, January 2002.
Arsenic in Illinois Groundwater
. Illinois
State Water Survey, Illinois Environmental Protection Agency, and Illinois Department of Public
Health. http://www.epa.state.il.us/water/groundwater/publications/arsenic/index.html
, 7 pp.
R.P., Cobb, August 2002,
Development of Water Quantity Planning and Protection in Illinois –
A New Direction
,
Proceedings of the Annual Ground Water Protection Council Technical Forum,
San Francisco, California, 10pp.
P.C. Mills, K.J. Halford, R.P. Cobb, and D.J. Yeskis, 2002.
Delineation of the Troy Bedrock
Valley and evaluation of ground-water flow by particle tracking, Belvidere, Illinois
, U.S.
Geological Survey Water-Resources Investigations Report 02-4062, 46 pp.
9
Illinois Environmental Protection Agency’s
Homeland Security Strategy
, March 2003, 20pp.
Illinois Environmental Protection Agency’
Strategic Plan
, Bureau of Water Section
, September
2003, pp.
Cobb, R.P., Fuller, C., Neibergall, K., and M. Carson, February 2004.
Community Water Supply
Well Shooting/Blasting near the Hillcrest Subdivision Lake County, Illinois Fact Sheet
. Illinois
Environmental Protection Agency. 4 pp.
Cobb, R.P., and J Konczyk, April 2007.
Increasing Volatile Organic Compound Detections in
Illinois Groundwater,
Groundwater Monitoring and Remediation Journal, [Under review]. 8 pp.
Attachment II. Tritium groundwater contamination plumes at Exelon Braidwood
10
Attachment III. Braidwood tritium groundwater contamination plume emanating from VB
3 (Exelon, February 7, 2006)
11
Attachment IV. Private drinking water system wells down gradient from VB 3 plume
12
Attachment V. Dresden Station tritium groundwater contamination plume
13
Attachment VI. Byron tritium contamination levels
14
Attachment VII. Hypothetical slug of tritium contaminated groundwater at time (t
0
)
15
Attachment VIII. Slug of tritium contaminated groundwater at time (t
1
)
16
Attachment IX. Slug of tritium contaminated groundwater at time (t
2
)
17
Attachment X. Conceptual model of a release of 0.002 Curies from an underground pipeline
leak
18
Attachment XI. Geologic cross section of Braidwood Exelon Station
19
Attachment XII. Partial potentiometric surface map of Braidwood station
20
Attachment XIII. Hypothetical plume release from an underground pipeline 70 days after
the end of the spill (plume front 350 ft from source)
21
Attachment XIV. 150 days after the end of the spill (plume front 500 ft from source)
22
Attachment XV. 237 days after the end of the spill (plume front 595 ft from source)
23
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROCEDURES REQUIRED BY
)
R 07-020
P.A. 94-849 FOR REPORTING
)
(Rulemaking - Water)
RELEASES OF RADIONUCLIDES AT
)
NUCLEAR POWER PLANTS: NEW 35
)
ILL.ADM.CODE PART 1010
)
NOTICE OF FILING
To:
Clerk
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
James R. Thompson Center
James R. Thompson Center
100 West Randolph Street, Suite 11-500
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
Matthew Dunn, Chief
Bill Richardson
Environmental Bureau
Office of Legal Counsel
Office of the Attorney General
Department of Natural Resources
100 W. Randolph, 12
th
Floor
One Natural Resources Way
Chicago, Illinois 60601
Springfield, IL 62702-1271
PLEASE TAKE NOTICE that today I filed with the Illinois Pollution Control Board the
Pre-Filed Testimony of Richard P. Cobb, P.G., of the Illinois Environmental Protection Agency, a
copy of which is herewith served upon you.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
/s/ Kyle Rominger
Kyle Rominger
Assistant Counsel
Dated: August 24, 2007
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
2
PROOF OF SERVICE
I, the undersigned, certify that I have served the enclosed Pre-Filed Testimony of Richard
P. Cobb, P.G., of the Illinois Environmental Protection Agency upon the following persons:
Clerk
Marie Tipsord, Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
James R. Thompson Center
James R. Thompson Center
100 West Randolph Street, Suite 11-500
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
(filed electronically)
Matthew Dunn, Chief
Bill Richardson
Environmental Bureau
Office of Legal Counsel
Office of the Attorney General
Department of Natural Resources
100 W. Randolph, 12
th
Floor
One Natural Resources Way
Chicago, Illinois 60601
Springfield, IL 62702-1271
by sending a true and correct copy of the document to the above addresses via first-class mail from
Springfield, Illinois, on the date below with sufficient postage affixed.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
/s/ Kyle Rominger
Kyle Rominger
Assistant Counsel
Dated: August 24, 2007
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
