)

(Rulemaking

—

Water)

)

)

NOTICE

OF

FILING

To:

John

Therriault,

Clerk

Illinois

Pollution

Control

Board

James

R.

Thompson

Center

100

West

Randolph

St.,

Suite

11-500

Chicago,

IL

60601

Deborah

J.

Williams,

Assistant

Counsel

Stefanie

N.

Diers,

Assistant

Counsel

Illinois

Environmental

Protection

Agency

1021

North

Grand

Avenue

East

P.O.Box

19276

Springfield,

IL

62794-9276

Marie

Tipsord,

Hearing

Officer

Illinois

Pollution

Control

Board

James

R.

Thompson

Center

100

WestRandolph

St,

Suite

11-500

Chicago,

Ii

60601

Persons

included

onthe

attached

SERVICE

LIST

PLEASE

TAKE

NOTICE

that

the

Environmental

Law

and

Policy

Center

of

the

Midwest

(“ELPC”)

and

the

Illinois

Chapter

of

the

Sierra

Club

today

have

electronically

filed

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

MARCELO

H.

GARCIA,

PhD;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

ADRIENNE

NEMURA;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

STEPHEN

F.

MCGOWAN;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

SUSAN

O’CONNELL;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

SCUDDER

D.

MACKEY;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

RICHARD

LANYON:

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

CHICAGO

AREA

WATERWAY

SYSTEM

AND

THE

LOWER

DES

PLAINES

RIVER:

PROPOSED

AMENDMENTS

TO

35

Ill.

Adm.

Code

Parts

301,

302,

303,

and

304

---

SIERRA

CLUBTO

SAMUEL

G.

DENNISON

REGARDING

BUBBLY

CREEK;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAWAND

POLICY

CENTER

AND

SIERRA

CLUB

TO

THOMAS

E.

KUNETZ,P.E.;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICYCENTER

AND

SIERRA

CLUB

TO

ROBERT

S.

ELVERT;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

PAUL

L.

FREEDMAN;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUBTO

JOHN

MASTRACCHIO

REGARDING

ECONOMIC

ASSESSMENT

FOR

DISINFECTION

FACILITIES;

PRE-FILEDQUESTIONS

OF

ENVIRONMENTAL

LAWAND

POLICYCENTER

AND

SIERRA

CLUB

TO

JOHN

MASTRACCHIOREGARDINGECONOMIC

ASSESSMENT

FOR

DISSOLVED

OXYGEN

ENHANCEMENT

FACILITES;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

DAVID

R.

ZENZ

REGARDING

EFFLUENTDISINFECTION

STUDIES;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUBTO

CARL

ADAMS

AND

ROBIN

GARIBAY;

PRE-FILEDQUESTIONS

OF

ENVIRONMENTAL

LAWAND

POLICY

CENTER

ANDSIERRA

CLUB

TO

ALAN

L.

JIRIK;

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

JAMES

E.

HUFF,

P.E.,

copies

of

which

are

herewith

served

upon

you.

Respectfully

Submitted,

Albert

Ettinger

Senior

Staff

Attorney

Environmental

Law

&

Policy

Center

35

E.

Wacker

Dr.

Suite

1300

Chicago,

Il

60601

DATED:

August

25,

2008

(312)

795-3707

---

)

AND

THE

LOWER

DES

PLAINES

RIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

Code

Parts

301,

302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

MARCELO

H.

GARCIA,

PhD

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Marcelo

H.

Garcia:

1.

On

page

2

of

your

testimony

you

refer

to

“density

currents.”

What

are

density

currents?

2.

How

do

density

currents

affect

aquatic

life

in

the

CAWS?

3.

When

are

the

studies

of

Bubbly

Creek

mentioned

on

page

14

of

your

testimony

to

be

completed?

4.

Has

the

MWRDGC,

URIC

or

anyone

else

to

your

knowledge

studied

fish

passage

through

the

CAWS?

5.

What

portions

of

the

CAWS

are

now

used

for

fish

passage

and

where

are

the

fish

going?

---

AND

THE

LOWER

DES

PLAINES

RIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

Code

Parts

301,

302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

ADRIENNE

NEM1JRA

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Adrienne

Nernura:

1.

Do

you

know

if

CSO

discharges

contain

the

same

level

of

human

pathogens

as

discharges

from

municipal

wastewater

treatment

plants

that

do

not

disinfect?

2.

On

page

7

of

your

testimony

you

mention

a

number

of

options

that

states

can

pursue

for

adopting

standards

that

are

identified

by

USEPA

includingsegmenting

the

water

body,

adopting“subclasses”

and

“high

flow

cutoffs.”

Do

you

suggest

that

the

CAWS

be

segmented

differently

for

consideration

in

the

UAA

and,

if

so,

how?

3.

What

sort

of

subclasses

might

you

have

in

mind?

4.

What

is

a

“high

flow

cutoff’

and

how

does

it

work?

5.

Do

you

believe

that

wet

weather

standards

should

be

adopted

that

would

allow

DOlevels

that

wouldpreclude

indigenous

aquatic

life

from

living

inareas

of

the

CAWS

during

wet

weather

events?

6.

Could

you

explain

what

you

mean

by

‘Range

for

Portionsof

2001

and

2002

that

were

Modeled’

in

Table

1

in

Attachment

4

of

your

testimony?

7.

Does

MWRD

haveactual

DO

measurements

taken

during

summer

2001

at

the

sites

which

you

have

modeled

that

could

be

shown

on

the

plots

in

Figures

2-9?

8.

In

Attachment

3

to

your

testimony

you

discuss

a

number

of

examples

of

“wet

weather

standards”

that

have

been

considered

for

other

water

bodies.

What

is

being

considered

in

Indiana

for

the

City

of

Indianapolis

and

elsewhere?

9.

What

has

been

done

in

Boston

and

other

cities

in

Massachusetts?

Has

Massachusetts

classified

the

Charles

River

in

a

manner

that

make

it

unnecessary

to

control

CSOs

or

disinfect

to

meet

the

standards

set

for

the

Charles?

10.

Please

explain

what

is

being

done

in

Maine.

11.

Has

ORSANCO

adopted

wet

weather

standards?

12.

Do

sewage

treatment

plants

discharging

to

the

Ohio

River

disinfect?

13.

Are

you

aware

of

the

efforts

being

made

to

control

CSOs

and

SSOs

by

the

City

of

Cincinnati

or

other

cities

that

discharge

into

the

Ohio

River?

14.

What

is

the

standardthat

was

adopted

for

the

SantaAna

River

in

California?

---

---

AND

THE

LOWER

DES

PLAINESRIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

Code

Parts

301.

302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

STEPHEN

F.

MCGOWAN

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Stephen

F.

McGowan:

1.

Have

you

worked

on

disinfection

issues

regarding

Milwaukee,

WI,

Detroit,

MI,

Norwalk,

CT.,

Columbia,

MD

or

any

otherplants?

2.

To

your

knowledge,

has

the

MWRDGC

ever

done

an

environmental

assessment

like

the

ones

you

did

regarding

DO

enhancement

and

disinfection

for

any

of

its

other

operations

or

proposed

operations?

3.

Was

such

an

assessment

donewith

regard

to

any

phase

or

portion

of

TARP?

4.

Have

you

or

to

your

knowledge

anyone

else

everattempted

to

calculate

any

favorable

environmental

effects

on

land,

air,

energy

use

or

other

portion

of

the

environment

that

might

result

from

disinfection

at

the

Calumet,North

Sideor

Stickney

plants?

5.

Have

you

or

to

your

knowledgeanyone

else

ever

attempted

to

calculate

any

favorable

environmental

effects

on

land,

air,

energy

use

or

other

portion

of

the

environment

that

might

result

from

enhanceddissolved

oxygen

levels

in

any

portion

of

the

CAWS

6.

Have

you

studied

the

effects

of

thework

necessary

to

the

meetexisting

dissolved

oxygen

requirements

applicable

to

the

CAWS?

7.

What

is

the

basis

for

your

assumption

that

MWRDGC

will

use

energy

originating

from

coal-fired

plants

(see

report

page

5-1)

to

produce

energyfor

disinfection

and

DO

enhancement?

8.

On

page

2-1

of

your

report

you

assume

that

disinfection

would

be

provided

from

March

through

November.

Why

did

you

decide

to

use

this

assumption?

---

AREA

WATERWAYS

SYSTEM

)

R08-09

AND

THE

LOWER

DES

PLALNES

RIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

Code

Parts

301.

302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

SUSAN

O’CONNELL

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Susan

O’Connell

regarding

CSO

discharges:

1.

Are

there

CSO

discharges

that

discharge

to

Lake

Michigan?

2.

Does

MWRDGC

maintain

data

sufficient

to

identify

the

particular

CSOs

that

have

discharged

by

date

of

discharge

for

some

or

all

of

the

CSO

or

dates

for

the

years

2005-

07?

If

so,

please

present

the

available

data

on

the

CSO

discharges

for

2005-07

at

the

hearing

---

AND

THE

LOWER

DES

PLAINES

RIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

CodeParts

301,302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICYCENTER

AND

SIERRA

CLUB

TO

SCUDDER

D.

MACKEY

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Scudder

D.

Mackey:

1.

In

various

parts

of

your

testimony

you

mention

temperature

effects

as

something

that

you

do

not

believethat

IEPA

adequately

studied.

What

portions

of

the

CAWS

need

further

study

with

regard

to

temperature

effects?

2.

What

are

the

significantthermal

dischargers

to

the

CAWS?

3.

Are

there

ways

to

categorize

subsections

of

the

CAWS

that

make

more

sense

to

you

than

the

categories

proposed

by

IEPA?

---

CHICAGO

AREA

WATERWAYS

SYSTEM

)

R08-09

AND

THE

LOWER

DES

PLAINES

RIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

Code

Parts

301,

302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

RICHARD

LANYON

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Richard

Lanyon:

1.

On

page

4

of

your

testimony

you

state

that

in

the

Calumet-Sag

Canal

“high

flows

can

impair

aquatic

life

uses

when

habitat

is

destroyed

and

aquatic

organisms

are

swept

downstream.”

How

does

this

occur?

2.

What

habitat

is

destroyed

by

such

high

flows?

3.

What

aquatic

organisms

are

swept

downstream?

4.

Where

are

they

swept?

5.

What

riparian

life

lives

on

the

CAWS

to

your

knowledge?

6.

Are

there

beavers,

otters

or

other

riparian

mammals

in

the

CAWS?

7.

What

birds

live

near

the

CAWS?

8.

Has

MWRDGC

ever

studied

the

effects

of

its

operations

on

riparian

mammals

or

birds?

9.

Can

the

different

reaches

and

segments

of

the

CAWS

be

said

tobe

homogenous

in

terms

of

its

recreational

uses

or

potential

for

aquatic

life?

10.

Your

testimony

discusses

barge

and

other

navigation

traffic

on

the

CAWS.

Has

the

MWRDGC

or

anyone

else

studied

this

barge

traffic

in

terms

of

what

segments

of

the

CAWS

are

traveled?

11.

Is

there

barge

traffic

above

Goose

Island

on

the

North

Branch

or

in

the

North

Shore

Channel?

12.

Has

anyone

to

your

knowledge

studied

what

the

level

of

barge

traffic

would

be

if

some

or

all

of

the

Midwest

Generation

units

at

Fisk,

Crawford

or

Will

County

are

shut

down?

13.

Has

MWRDGC

or

anyone

else

studied

the

recreational

boating

traffic

in

the

CAWS?

14.

Has

MWRDGC

or

anyone

else

to

your

knowledge

studied

the

value

of

the

recreational

boating

now

on

the

CAWS

or

any

segments

of

the

CAWS?

15.

MWRDGC

has

criticized

some

of

the

proposed

classifications

of

the

CAWS

that

have

been

proposed

by

IEPA,

but

is

there

another

classification

system

that

MWRDGC

would

propose

that

better

characterizes

the

CAWS

in

terms

of

potential

for

recreational

uses

or

aquatic

life

uses?

---

---

AREA

WATERWAYS

SYSTEM

)

R08-09

AND

THE

LOWER

DES

PLAINES

RIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

CodeParts

301,

302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

AND

SIERRA

CLUB

TO

CHARLES

S.

MELCIIING

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Charles

S.

Meiching:

I.

On

what

river

did

you

do

work

in

Belgium?

2.

How

generally

did

you

measure

the

duration

of

the

effect

of

a

CSO

event?

3.

What

counted

as

ending

the

effect

of

a

CSO

event?

4.

Are

CSOs

causing

violations

of

the

Illinois

ammonia

standard?

5.

Are

CSOs

causing

violations

of

the

DO

standards

currently

applicable

to

the

CAWS.

6.

Could

water

quality

in

the

North

Shore

Channel

or

Bubbly

Creek

be

improved

by

increasing

the

flow

in

these

water

bodies?

7.

Have

CSO

events

negatively

impacted

the

aquatic

community

in

any

parts

of

the

CAWS?

8.

On

page

24

of

your

report,

you

state

that

“long

storm

effects

can

negatively

affect

the

aquatic

community

and

these

long

term

effects

cannot

be

reduced

until

the

reservoirs

of

the

Tunnel

and

Reservoir

Plan

are

fully

on

line.”

Is

it

your

testimony

that

there

have

been

no

benefits

to

the

aquatic

community

from

the

partial

completion

of

TARP?

9.

Is

it

your

testimony

that

nothing

can

be

done

to

reduce

CSO

events

or

the

long-term

effects

of

CSO

events

other

than

to

complete

TARP?

10.

How

will

completion

of

TARP

benefit

aquatic

life?

11.

Are

there

parts

of

the

CAWS

that

could

meet

the

proposed

IEPA

DO

standards

almost

all

of

the

time?

12.

Would

you

classify

the

whole

CAWS

with

one

aquatic

life

use

or

are

there

segments

that

should

be

distinguished

as

to

different

uses?

13.

Did

the

1980s

Fish

&

Wildlife

Service

study

of

Habitat

Suitability

you

discuss

on

pages

13-14

of

your

testimony

deal

with

the

entire

CAWS?

14.

Is

it

your

testimony

that

there

are

no

early

life

stages

for

bass

or

channel

catfish

anywhere

in

the

CAWS?

15.

Can

substrate

be

improved

through

any

technique?

16.

Is

there

any

way

to

differentiate

the

effects

of

CSOs

from

those

of

poor

substrate

in

any

portion

of

the

CAWS?

---

---

CHICAGO

AREA

WATERWAYS

SYSTEM

)

R08-09

AND

THE

LOWER

DES

PLAINES

RIVER:

)

(Rulemaking

-

Water)

PROPOSED

AMENDMENTS

TO

35111.

Adm.

)

Code

Parts

301,

302,

303

and

304.

)

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICYCENTER

AND

SIERRA

CLUB

TO

JULIA

WOZNIAK

The

Environmental

Law

and

Policy

Center

of

the

Midwest

and

the

Illinois

Chapter

of

the

Sierra

Club

hereby

file

questions

to

Julia

Wozniak:

I.

Atpage

2

of

your

testimony

you

mention

that

the

MWG

stations

“use

large

volumes

of

surface

water.”

What

is

the

intake

of

each

of

the

Fisk,

Crawford,

Will

County

and

Joliet

Stations

relative

to

the

low

flow

of

the

water

body

from

which

the

water

is

taken?

2.

Is

the

intake

to

the

Joliet

plant

sometimes

larger

than

the

Des

Plaines

River

flow?

3.

Are

Joliet

Units

6,

7

and

8

sometimes

demarcated

with

a

different

numbering

system?

4.

What

are

Joliet

Units

9

and

29?

5.

Does

Midwest

Generation

keep

records

of

the

amount

of

power

production

at

each

of

its

units?

6.

Since

Midwest

Generation

began

operating

the

stations,

what

is

the

capacity

factor

of

the

unit

at

Fisk?

The

units

at

Crawford?

Will

County?

Joliet?

7.

Does

Midwest

Generation

have

plans

to

close

the

Fisk,

Crawford,

Will

County

or

Joliet

plants

or

any

of

the

units

at

those

plants?

8.

Should

we

assume

in

this

proceeding

that

any

capital

costs

for

putting

supplemental

cooling

equipment

on

those

plants

can

be

fully

amortized

over

the

life

of

the

plants?

9.

Does

MWG

claim

as

to

any

station

orunit

that

pollution

control

equipment

is

not

justifiable

because

the

plant

will

soon

close?

10.

Has

MWG

received

a

notice

of

violation

of

the

Clean

AirAct

that

relates

to

modifications

or

operation

of

any

units

of

the

Fisk,

Crawford,

Will

County

or

Joliet

Stations?

11.

Are

you

aware

of

any

power

plants

anywhere

that

have

been

retrofitted

to

add

cooling

capacity

other

than

the

cooling

towers

built

for

Joliet

Units

7

and

8?

12.

You

mention

on

page

5

that

the

allowed

mixing

zone

is

currently

26

acres.

Are

you

aware

of

any

study

that

has

determined

whether

the

heat

discharge

from

the

Joliet

station

contains

more

than

25%

of

the

cross-sectional

area

or

volume

of

flow

of

the

Des

Plaines

River?

---

in

1996?

15.

In

suggesting

that

the

1-55

rules

are

“more

stringent”

are

you

taking

into

account

the

general

use

limitation

prohibitingraising

temperatures

by

more

than

5

degrees

Fahrenheit?

16.

Has

MWG

or

Commonwealth

Edison

determined

what

the

temperature

of

the

Des

Plaines

River

at

the

1-55

bridge

would

be

if

the

Joliet

plant

were

not

operated?

17.

Has

MWG

or

Commonwealth

Edison

or

anyone

else

to

your

knowledgedetermined

whether

temperatures

at

the

1-55

bridge

are

more

than

5

degrees

Fahrenheit

higher

than

temperatures

in

the

Kankakee,

the

Upper

Des

Plaines,

theDu

Page

River

or

other

waters

in

the

area?

18.

Has

MWG

or

Commonwealth

Edison

or

anyone

else

to

your

knowledge

studied

how

temperature

affects

the

toxicity

of

the

pollutants

that

are

present

in

the

Upper

Dresden

Pool?

19.

Does

Midwest

Generation

intend

to

make

any

investments

in

any

of

the

plants

on

the

CAWS

or

the

Upper

Dresden

Pool

to

reduce

impingement

of

aquatic

life?

20.

Does

Midwest

Generation

have

any

data

on

the

effect

on

aquatic

life

ofimpingement

at

the

Joliet

station?

21.

Does

the

Joliet

plant

serve

to

discourage

fish

or

other

aquatic

life

from

movingfrom

the

Upper

Illinois

River

to

the

Great

Lakes

system?

22.

Does

heat

discharged

by

the

Joliet

plantattract

fish

to

come

up

from

below

the

1-55

Bridgeduring

the

winter?

23.

Has

Midwest

Generation

or

Commonwealth

Edison

measured

the

effect

of

heat

generated

bythe

Fisk,

Crawford,

Will

County

and

Joliet

plants

on

dissolved

oxygen

levels

at

the

I-

55

bridge?

24.

Has

any

study

been

done

on

the

effect

of

the

Fisk,

Crawford,

Will

County

or

Joliet

plants

on

DO

levels

at

the

1-55

Bridge

since

that

of

Dr.

John

F.

Kennedy

for

the

Joliet

heat

demonstration

proceeding

(PCB

87-93)?

25.

Does

Midwest

Generation

keep

data

on

intake

temperatures

at

the

Joliet

plant?

26.

Are

the

documents

attached

as

Exhibit

A

examples

of

documents

containing

intake

temperatures

at

the

Joliet

plant?

27.

Does

Midwest

Generation

keep

data

on

the

temperatures

at

the

1-55

Bridge?

28.

Does

MidwestGeneration

keep

data

on

DOlevels

at

the

1-55

Bridge?

29.

Do

you

know

if

there

are

unnatural

heat

inputs

to

the

Upper

Illinois

River

below

the

1-55

bridge?

30.

Has

Commonwealth

Edison

or

Exelon

violated

its

NPDES

permit

with

excessiveheat

discharges

from

the

Dresden

Nuclear

plant?

31.

Has

Midwest

Generation

investigated

the

amount

of

fish

habitat

in

tributaries

of

the

Upper

Dresden

Pool

or

other

watersconnected

to

the

Upper

Dresden

Pool

including

the

Du

Page

River,

Hickory

Creek,

Jackson

Creek,

and

the

Kankakee

River?

2

---

3

---

EXHIBIT

A

TO

PRE-FILED

QUESTIONS

OF

ENVIRONMENTAL

LAW

AND

POLICY

CENTER

FOR

JULIA

WOZNIAK

---

Mr.

Kenne

Rogers

Mana<

Compliance

Assurance

Section

Diyiion

of

Water

Pollution

Control

,Tlfinois

Environmental

Protection

Agency

/

1021

North

Grand

Avenue

East

Springfield,

Illinois

62794-9276

Re:

Dresden

Station

-

NPDES

Permit

No.

1L0002224

Noncompliance

Event

Report

and

Upset/Bypass

Demonstration

July

21-31,

1999

Dear

Mr.

Rogers:

By

letter

datedAugust

26,

1999,

Commonwealth

Edison

Company

(“CornEd

11)

sent

you

the

July1999

Discharge

Monitoring

Report

(DMR)

for

the

Dresden

Station.

The

DMR

identifies

exceedences

of

effluent

limits

governing

thermal

discharges

that

occurred

between

July

21

and

July

31,

1999.

The

DMR

also

notes

the

fact

that

for

a

period

of

time

on

July

23

and

July

24

the

plant

was

operated

in

the

Direct

Open

Cycle

Mode,

rather

than

the

Indirect

Open

Cycle

Mode

as

required

by

Special

Condition

2C.

Some

of

these

matters

were

the

subject

of

24-

hour

oral

notifications

to

IEPA.

IEPA

agreed

to

waive

the

requirement

that

CornEd

submit

a

follow-up

report

within

5

days

of

the

initial

notifications,

and

requested

instead

that

CornEd

submit

one

report

regarding

the

circumstances

that

gave

rise

to

the

exceedences,

and

actions

taken

by

the

Company

in

response

to

these

events.

This

letter

is

submitted

in

response

to

IEPA’s

request.

Background

The

Dresden

NPDES

Permit

allows

the

station

to

operate

its

cooling

pond

in

the

Indirect

Open

Cycle

mode

from

June

15th

through

September

30th.

When

the

Cooling

Pond

is

operating

in

the

Indirect

Open

Cycle

mode,

water

discharged

from

the

plant

circulates

through

the

cooling

pond

for

about

three

days

before

it

is

discharged

to

the

Illinois

River.

Therefore,

in

order

to

maintain

compliance

with

the

thermal

limits

imposed

by

its

permit

(90

F,

except

that

the

station

can

discharge

at

up

to

93

F

for

10%

of

the

hours

between

June

15

and

September

30),

Dresden

A

Unicorn

Company

---

instrumentation

data

and

three-dayforecasts

of

ambientair

temperature

and

humidity

parameters.

If

theprogram

predicts

that

effluent

temperatures

will

exceed

limits

set

by

thepermit

with

the

station

running

at

full

power,

the

program

specifies

the

extent

to

which

the

station

must

decrease

operations

(j.,

be

derated)

to

assure

that

compliance

is

maintained.

The

input

data

for

the

program

comes

from

on-line

instrumentation

and

three

days

of

weather

forecast

dataprovided

by

Murray

&

Truttel,

CertifiedConsulting

Meteorologists.

The

programcalculates

the

extent

of

cooling

that

will

occur

as

water

circulates

in

the

cooling

pond

based

on

predicted

ambient

air

and

wet

bulb

temperatures.Murray

&

Truttel

electronically

transmits

these

forecasts

to

Dresden’s

main

control

roomonce

per

day

and

sends

updated

weather

data

immediately

if

the

forecast

changes

significantly.

Murray

and

Truttel’s

forecasting

has

proven

to

be

reliable

and

accurate,

and

the

computer

program

has

been

used

to

successfully

maintain

the

coolingpond

effluent

temperatures

withinapplicable

limits

for

the

last

two

summers.

Toaugment

Dresden’s

ability

to

cool

water

before

it

is

dischargedfrom

the

cooling

pond,

cooling

towers

were

installed

in

the

spring

of

1999.

The

towers

are

capable

of

treating

about

22%

of

the

flow

coming

through

the

cooling

pond.

After

the

cooling

towers

were

installed,

tests

were

performed

to

veri1’

that

they

performed

as

designed.

The

cooling

capacity

of

the

towers

was

then

incorporated

into

the

computer

program

usedto

maintain

compliance

with

thermal

limits.

Because

the

cooling

towers

are

located

adjacent

to

the

canal

that

discharges

water

from

thecoolingpond

to

the

Illinois

River,

aspike

of

hot

water

in

the

cooling

pond

can

be

managed

by

adjusting

the

spillway

gates

so

that

thepercentage

of

water

treated

by

the

cooling

towers

increases,

thereby

lowering

the

effluent

temperature.

Modeling

shows

thatif

the

spiliway

-

gates

are

throttled

to

reduce

the

effluent

temperature

by

1/3

of

a

degree

F

(approximately

50

MWe),

for

a

period

of

9

hours,

the

cooling

pond

will

return

to

its

normal

level

11

hours

after

the

gates

are

reopened.

The

ability

to

manipulate

the

spiliway

gates

to

reduce

the

extent

to

which

Dresden

has

to

be

derated

was

part

of

the

cooling

pond

management

procedure

used

by

Dresden

personnel.

As

we

explain

in

detail

below,

the

exceedence

events

discussed

in

this

letter

resulted

from

unexpected

and

significant

discrepancies

in

forecasted

ambient

air

and

wet

bulb

temperatures

(with

the

exception

of

a

bypassincident

that

commenced

on

July

23rd).

In

each

case,

the

exceedences

occurred

despite

the

fact

that

Dresden

implemented

themeasures

(in

the

form

of

significant

deratings

and

spillway

manipulations)

that

the

compliance

program

and

procedures

called

for

to

avoid

exceedences.

However,

because

the

ambient

air

and

wet

bulb

temperatures

actually

experiencedwere

far

more

severe

than

wereforecasted

(and

input

into

the

---

very

first

exceedence

event,

CornEd

took

increasing

responsive

steps

in

an

effort

to

avoid

flrther

exceedences.

In

addition,

CornEd’s

monitoring

program

in

the

affected

area

revealed

no

significant

environmental

impacts

associated

with

the

exceedences.

Chronology

of

Events

7/21/99

On

Wednesday,

July

21,

1999,

Dresden’s

effluent

temperature

exceeded

93

F.

for

1.8

hours,

with

a

maximum

temperature

of

93.6

F.

At

approximately

1:00

p.m.

on

that

date,

when

the

cooling

pond

effluent

temperature

first

exceeded

92.5

F.,

station

operators

were

sent

to

manipulate

the

spiliway

gates

in

order

to

prevent

the

effluent

temperature

from

exceeding

93

F.

This

action

reduced

the

magnitude

and

duration

of

the

temperature

excursion.

This

exceedence

resulted

from

incorrectly

forecasted

three-day

ambient

air

and

wet

bulb

temperatures

that

were

input

into

Dresden’s

computer

program

on

Sunday,

July

18th.

As

it

turned

out,

the

Murray

&

Truttel

forecasted

ambient

air

temperature

data

were

11.3

-degree

days

lower

than

the

actual

temperatures

experienced

over

the

three-day

period

and

the

forecasted

wet

bulb

temperature

for

Wednesday

was

3

degrees

lower

than

the

actual

wet

bulb

temperature.’

As

a

result,

the

cooling

pond

and

cooling

towers

were

not

as

efficient

as

predicted.

In

response

to

this

event,

CornEd

investigated

the

reliability

of

the

Murray

&

Truttel

forecasts.

CornEd

evaluated

the

data

from

seven

different

weather-reporting

services,

and

found

that

all

of

the

weather

forecasting

services

significantly

under-predicted

the

ambient

air

temperatures

during

the

previous

3-day

period.

Therefore,

it

did

not

appear

necessary

or

reasonable

to

discontinue

relying

on

Murray

&

Truttel

forecasts.

7/22/99

On

Thursday,

July 22nd,

Dresden’s

effluent

temperature

exceeded

93

F.

for

8.3

hours,

with

a

maximum

temperature

of

95.6

F.

At

7:30

a.m.

on

that

date,

when

the

cooling

pond

effluent

temperature

first

exceeded

92.0

F.,

station

operators

manipulated

the

spillway

gates

in

order

to

prevent

the

effluent

temperature

from

exceeding

93

F.:

This

action

prevented

the

effluent

The

term

“degree-day”

is

based

on

calculating

the

difference

between

the

forecasted

and

actual

ambient

air

temperature

data

and

comparing

the

sum

of

the

forecasted

high

and

low

temperature

values

for

three

days

with

the

sum

of

the

actual

temperature

values

experienced

for

the

same

three

days.

---

exceed

93

F.

Again,

these

circumstances

were

due

to

thefact

that

the

ambient

air

and

wet

bulb

temperature

forecasts

on

July19th

substantially

underestimated

the

actual

ambient

air

and

wet

bulb

temperatures

experienced.

On

July

22nd,

the

second

day

that

the

effluent

limit

was

exceeded,

Dresden

decided

to

implement

further

corrective

action

by

adding

6

degree-days

tothe

weather

data

input

into

the

computer

program

to

provide

a

greater

margin

in

the

event

of

future

weather

forecast

errors.

7/23/9

9

7/24/99

Despite

the

corrective

actions

described

above,

on

July

23rd,

the

cooling

pond

effluent

temperature

exceeded

93

F

for

13.5

hours,

reaching

a

maximum

of

94.8

F.

This

exceedence

again

was

due

to

the

fact

that

temperature

forecastson

July

20th

substantially

underestimated

the

ambient

air

and

wet

bulb

temperatures.

In

addition,

onFriday,

July

23rd

at

approximately

10:00

p.m.,

a

lightning

strike

caused

a

loss

of

power

to

Dresden’s

lift

station.

Plant

personnel

took

immediate

actions,

by

adjusting

the

flow

regulating

stationgates

and

changing

the

cooling

pond

operatingmode

from

Indirect

Open

Cycle

to

Direct

Open

Cycle,

thereby

bypassing

the

cooling

pond

and

cooling

towers.

This

action

wasnecessary

toprevent

flooding

of

the

canal

and

the

surrounding

neighborhood.

Power

was

restored

to

the

Lift

Station

at

approximately6:00

a.m.

on

Saturday,

July

24th.

During

the

period

of

Direct

Open

Cycle

operation,

the

effluent

water

temperature

was

above

93

F

for

7.7

hours

and

reached

100.2

F.

OnSaturday,

July

24th,

after

the

plant

was

able

to

resume

using

the

cooling

pond

and

towers,

the

spillway

gates

were

successfully

used

to

keep

effluent

temperatures

below

93F.

This

left

the

coolingpond

at

its

high

level.

CornEd

provided

oral

notification

to

IEPA

at

approximately

9:30

a.m.

on

July

24th

of

this

incident

and

provided

•

.

.•

PA

a

tten

fo1lowupreport

in

the

aached

letter

of

July

28,

1999.

(Attachment

A)

s:.

•

7/25/99

•

On

Sunday,

July

25th,

at

12:00

noon,

the

Cooling

Pond

effluent

temperature

was

approaching

92.5

F.

Dresden

manipulated

the

spillway

gates

in

an

effort

to

prevent

any

exceedences.

However,at

4:10

p.m.

the

cooling

pond

effluent

temperature

exceeded

the

limit

for

the

remainder

of

the

day

(8

hours),reaching

a

maximum

of

94.8

F.

---

program

onThursday,

July

22nd.

However,

the

forecast

significantly

underestimated

the

wet

bulb

temperatures

experienced.

As

a

result,

the

cooling

towers

were

not

as

effective

as

anticipated.

On

July

25,

Dresden

implemented

additional

corrective

actions

by

changing

its

operating

procedure

to

discontinue

taking

credit

for

anticipated

cooling

benefits

derived

from

using

the

spillway

gates.

This

action

provided

extra

margin

for

preventing

effluent

temperature

excursions.

7/26/99

On

Monday,

July

26th,

the

extremely

high

humidity

(which

was

substantially

higher

than

forecasted)

caused

cooling

pond

effluent

temperatures

to

exceed

93

degrees

F

for

3.8

hours,

reaching

a

maximum

temperature

of

95.3

F.

In

response,

Dresden

implemented

additional

corrective

actions

by

adding

3

more

degree-days

(9

degree-days

total)

to

the

input

weather

data

of

the

computer

model.

7/27/99

On

Tuesday,

July

27th,

extremely

high

humidity

conditions

continued

causing

the

cooling

pond

effluent

temperatures

to

exceeded

93

F

for

11.2

hours,

reaching

a

maximum

of

94

7

F.

On

this

date,

Murray

&

Truttel

increased

their

predicted

wet

bulb

temperature

from

74

F

to

79

F.

As

a

result,

the

plant’s

operations

were

decreased

to

account

for

this

change.

7/28/99

On

Wednesday,

July

28th,

the

wet

bulb

temperature,

predicted

to

be

74

F,

exceeded

77

F.

As

a

result,

thecooling

pond

effluent

exceeded

93

F

for

15.2

hours

reaching

a

maximum

of

93.4

F.

7/29/99-7/30/99

The

ambient

air

and

humidity

conditions

experienced

on

Thursday

and

Friday,

July

30th

and

31st,

were

among

the

most

extreme

experienced

in

recent

years.

The

ambient

air

temperatures

predicted

to

be

93

and

94

degrees

F,

respectively,

actually

exceeded

96

and

100

degrees

F.

The

wet

bulb

temperatures

predicted

to

be

76

F

and

79

F,

exceeded

82

F.

(a

new

record

high).

These

unusually

extreme

and

significantly

under-predicted

temperature

and

humidity

conditions

caused

the

effluent

temperatures

to

exceed

93

F

for

all

24

hours

on

each

of

---

On

Friday,

July

30th,

Dresden

implemented

additional

corrective

actions

by

adding

an

additional

3

degree-days

(12

degree-days

total)

to

the

input

weather

data

of

the

computer

program.

7/31/99

As

the

ambient

air

temperatures

moderated

on

Saturday,

the

cooling

pondwater,

heated

by

the

ambient

air

conditions

over

the

last

two

days,

continued

to

be

discharged

from

the

cooling

pond

at

elevated

temperatures.

On

Saturday,

July

31st,

the

cooling

pond

effluent

temperatures

exceeded

93

F

for

6.8

hours

reaching

a

maximum

of

93.7

F.

Plant

Operations

The

exceedences

discussed

above

occurred

on

days

during

which

the

demand

for

electricity

on

CornEd’s

system

and

in

neighboring

states

was

extremely

high.

These

circumstances

raised

serious

concerns

regarding

whether

there

was

sufficient

power

available

on

the

CornEd

system

and

in

the

region

to

avoid

significant

outages.

Nevertheless,

it

should

be

emphasized

that

on

the

days

the

exceedences

occurred,

Dresden

was

derated

significantly,

to

operating

levels

that

were

predicted

to

allow

the

station

to

comply

with

thermal

limits.

During

this

period,

Dresden

was

derated

by

anywhere

from

30%

to

53%

of

full

power.

Corrective

Actions

CornEd

has

implemented

the

following

corrective

actions

designed

to

avoid

exceedences

in

the

future

that

are

similar

to

those

addressed

in

this

letter.

1.

CornEd

has

permanently

added

an

additional

12

degree-days

to

the

weather

data

input

of

its

compliance

program.

2.

Whenever

the

forecast

wet

bulb

temperature

is

above

76

F.,

CornEd

will

add

additional

degree-days

to

the

weather

data

input

of

the

compliance

program

to

account

for

potential

severe

humidity

conditions.

3.

The

compliance

procedures

no

longer

will

take

credit

for

spiliway

manipulations

to

determine

required

deratings.

4.

Two

weather

forecasts,

from

two

different

weather

services,

---

forecasts

will

be

used

as

the

input

data

for

the

program.

5.

CornEd

will

evaluate

the

need

for

additional

cooling

capacity,

such

as

additional

cooling

towers.

Environmental

Impacts

On

each

day

exceedences

occurred,

CornEd

monitored

the

cooling

pond,

discharge

canal

and

the

illinois

River

downstream

of

the

discharge.

No

fish

kills

or

other

noticeable

environmental

impacts

were

observed.

In

addition,

on

July

22

and

23,

and

again

on

July

30,

CornEd

and

its

environmental

consultants

conducted

extensive

fishsampling

activities

and

river

temperature

profiles

upstream

and

directly

downstream

of

the

Dresden

discharge.

Again

no

observable

impacts

were

noted.

*

*

*

*

Please

feel

free

to

contact

me

should

you

require

any

additional

information.

We

would

be

happy

to

meet

with

you

to

discuss

these

matters

in

further

detail.

Very

truly

yours,

Mary

O’l1oole

Manager

Environmental

Services

attachment

::ODMA\PCDOCS\CHJCAGO4\929181U

August

26,

1999

(5:01pm)

---

Bureau

of

Water,

Compliance

Assurance

Section

#19

Attention:

Dan

Ray

1021

North

Grand

Avenue

East

P.O.

Box

19276

Springfield,

Illinois

62794-9276

Subject:

Provisional

Variance

(PCB

00-18)

Follow-Up

Report

for

Dresden

Nuclear

Generating

Station,

NPDES

Permit

No.

1L0002224

Dear

Mr.

Ray:

In

accordance

with

Condition

No.

4

of

the

Board’s

Order

in

PCB

00-18,

dated

August

5,

1999,

a

weekly

summary

of

continuous

water

temperaturedata

records

for

the

following

locations

is

being

submitted

for

the

interval

coinciding

with

the

Provisional

Variance

period

(July

30th

through

September

13th,

1999):

Dresden

Station

Intake

Minimum

Average

Maximum

July

30-31

89.18

°F.

90.50

°F.

92.69

GF

August

1-7

81.95

°F.

85.61

°F.

89.25

°F.

August

8-14

77.97

°F.

80.81

°F.

83.20

°F.

August

15-21

76.15

°F.

79.53

°F.

81.67

°F.

August

22-28

76.30

°F.

78.64

°F.

82.73

°F.

August

29-September

4

77.76

°F.

80.93

oF.

85.92

°F.

September

5-11

76.09

°F.

80.90

°F.

84.90

°F.

September

12-13

75.54

F.

77.54

°F.

79.71

°F.

Dresden

Station

Discharge

Minimum

Average

Maximum

July

30-31

92.25

°F.

93.61

°F.

95.80

°F.

August

1-7

88.88

°F.

90.67

°F.

92.60

°F.

August

8-14

83.85

°F.

87.73

°F.

89.90

°F.

August

15-21

83.75

F.

87.21

°F.

89.45

°F.

August

22-28

86.50

°F.

88.35

°F.

90.60

°F.

August

29-September

4

85.17°F.

88.08

°F.

90.60

°F.

September

5-11

82.67

°F.

86.54

°F.

90.30

°F.

September

12-13

83.48

°F.

84.90

°F.

85.84

°F.

A

UruCorn

(onxtn’

---

July

30-31

90.28

°F.

91.59

°F.

93.47

°F.

August

1-7

85.47

°F.

88.31

°F.

90.50

°F.

August8-14

81.42°F.

84.74°F.

86.00°F.

August

15-21

80.36

°F.

83.84

°F.

85.44

°F.

August

22-28

79.89

°F.

83.23

°F.

86.02

°F.

August

29-September

4

82.12

°F.

84.82

°F.

88.24

°F.

September

5-11

80.41

°F.

84.74°F.

88.11

°F.

September

12-13

80.91

°F.

82.38

°F.

83.13

°F.

[The

above

data

summary

for

all

of

the

required

monitoring

locations

was

prepared

by

reviewing

either

circular

or

strip

chart

temperature

records,

or

computer

records

from

an

in-place

telemetry

monitoring

system

(depending

upon

location).

If

required,

complete

copies

of

the

actual

temperature

records

for

each

location

will

be

made

available

to

the

Agency

for

further

reviewl.

Inspections

of

the

Dresden

intake

and

discharge

were

also

made

during

the

Provisional

Variance

period,

in

accordance

with

requirements

of

the

Board

Order.

These

inspections

did

not

identify

any

unusual

or

unexpected

conditions

for

the

duration

of

the

variance

period.

There

were

two

extended

excursion

periods

associated

with

the

thermal

discharge

during

the

1999

Indirect

Open

Cycle

period

at

Dresden

Station.

These

have

been

summarized

in

prior

correspondence

to

the

Agency

dated

July

28th

and

August

26th,

1999.

A

total

of

400.2

allowable

excursion

hours

were

used

this

summer,

including

approximately

141

.2hours

permitted

under

Provisional

Variance

(PCB

00-18).

If

there

are

any

questions

concerning

the

above

information

and/or

accompanying

data,

please

contact

me

at

(630)

663-5409.

Sincerely,

JNla

P.

Wo

iak

Senior

Biologist

Endvar99.doc

cc:

Darin

LeCrone,

IEPA

Industrial

Permits

Section

Matthew

Wertman—IEPA

Maywood

Office

---

Mr.

Kenneth

Rogers

Manager,

Compliance

Assurance

Section

Division

of

Water

PollutionControl

Illinois

Environmental

Protection

Agency

1021

North

GrandAvenue

East

Springfield,

Illinois

62794-9276

Re:

Follow

up

Report

regarding

July

23

-

24

Noncompliance

Event

Dresden

Station

--

NPDES

Permit

No.

1L0002224

Dear

Mr

Rogers:

In

accordance

with

Standard

Condition

No.

12

and

40

CFR

122.141(m)

and

(n),

Commonwealth

Edison

Company(CornEd)

submitsthis

Follow

up

report

regarding

the

incident

which

occurred

July

23

and

24,1999

at

the

Dresden

Station

that

caused

the

plant

to

exceed

the

maximum

temperature

limit

contained

in

its

NPDES

permit.

CornEd

initially

notified

IEPA

regarding

this

incident

at

about

9:30

am

on

July

24,

by

contacting

IEPA

Duty

Officer,Jim

O’Brien,

and

subsequently

contacted

Dan

Ray,

IEPA

Compliance

Assurance

Section,

and

Mathew

Wertman,

TEPA

Maywood

Field

Office,

via

facsimile.

Dan

Ray

was

also

contacted

by

telephone

on

July

26

regarding

this

incident.

Late

Friday

evening,

July

23,

at

about

10:00

pm,

a

severe

storm

in

the

Dresden

area

resulted

in

a

lightening

strike

to

the

transmission

line

that

provides

the

source

of

powerfor

the

Dresden

Station

cooling

pond

lift

station.

As

a

result,

the

station

was

forced

to

switch

to

emergency

open

cycle

operation

(bypassing

the

cooling

pond),

to

prevent

flooding

and

forced

reactor

shutdown.

At

the

time

of

the

incident,

CornEd

was

experiencing

severe

demandfor

power

on

its

system.

There

were

no

feasible

alternatives

to

the

bypass.

Power

was

restored

to

the

lift

station

by

about

6:00

am

on

July

24,

at

which

time

the

station

resumed

operations

using

the

cooling

pond.

Water

temperatures

in

the

discharge

canal

(Outfall

002)

reached

100.7

F.

during

the

bypass

event.

Station

personnel

surveyed

the

discharge

area

and

did

not

observe

any

fish

kills

or

other

signs

of

adverse

environmental

impacts

attributable

to

this

relatively

short

elevated

temperature

event.

Prior

to

this

event,

the

station

experienced

another

incident

during

which

blowdown

temperatures

exceeded

the

permitted

93

F.

limit.

As

you

may

know,

the

Dresden

Station

relies

upon

a

computer

model

to

determine

the

power

levels

at

which

the

station

can

operate

and

maintain

compliance

with

thermal

discharge

limits.

The

model

uses

published

meteorological

forecasts

to

calculate

the

extent

of

cooling

which

will

occur

in

thecoolingpond

during

the

three

day

retention

A

Unicorn

Company

---

Very

truly

yours,

Environmental

Manager

Mary

Services

cc

D.

Ray

M.

Wertman

---

urgent

facsimile

To:

Dan

Ray--IEPA

Compliance

Assurance

Section

Company:

Fax

Number:

+1(217)557-1407

Business

Phone:

From:

Julia

Wozniak

Fax

Number

+1(630)

852-5766

Business

Phone:

(312)

394-4468

Home

Phone:

(630)

852-5766

Pages:

1

Datefflme:

7/24/99

9:50:30

AM

Subject:

24-Hour

Notification

of

Unanticipated

ByPass

Per

Pórmit

Standard

Condition

No.

12(e)(1),

I

am

reporting

that

Dresden

Station

temporarily

lost

thier

cooling

pond

lift

station

at

approx.

10pm

on

7/23--due

to

a

lightning

strike--and

were

forced

to

go

direct

open

cycle.

During

this

time,

the

effluent

temperature

reached

approx.

99.4

deg.

F.

The

system

was

restored

to

normal

operations

by

approx.

6am

on

7/24.

Station

was

already

derated

at

the

time

of

line

failure,

so

thermal

impact

was

mitigated

to

the

extent

possible.

Station

personnel

will

be

checking

for

any

adverse

environmental

impacts,

but

none

are

expected.

I

also

notified

the

IEPA

DutyOfficer,

Jim

0Brien,

at

approx.

9:20am

on

7/24.

I

will

call

you

on

this

on

Monday.

Written

follow-up

invoking

the

Upset

Defense,

will

also

be

sent..

Julia

Wozniak

ESD

CornEd

---

CERTIFIED

MAIL

Illinois

Environmental

Protection

Agency

Mr

Thomas

G.

McSwiggin,

P.

E

Manager,

Permits

Section

Bureau

of

Water

-f

1021

North

Grand

Avenue

East

P

0.

Box

19276

Springfield,

Illinois

62794-9276

Subject:

Annual

Temperature

Data

Submittal

for

Dresden

Nuclear

Generating

Station,

NPDES

Permit

No.

1L0002224

Dear

Mr.

McSwiggin:

In

accordance

with

Dresden’s

NPDES

permit

Special

Condition

No.

2,

Part

F,

Subsection

2,

a

monthly

summary

of

continuous

water

temperature

data

records

for

the

following

locations

is

being

submitted

for

the

period

coinciding

with

allowed

indirect

open

cycle

operation

(15

June-30

September,

1998):

(1)

Dresden

Island

Lock

and

Dam

(2)

Dresden

Station

Circulating

Water

Intake

(Kankakee

River)

(3)

Joliet

Station

#9

intake

(4)

Joliet

Station

#29

Intake

(5)

1-55

Bridge

Dresden

operating

data

for

the

June

through

September

period

is

also

being

included,

for

informational

There

purposes.

were

no

noncompliances

related

to

thermal

compliance

during

the

1998

Indirect

Open

Cycle

period

at

Dresden

Station.

A

total

of

418.8

allowable

excursion

hours

of

discharge

temperatures

between

90°F

and

93

°F

were

used

this

summer,

including

approximately

159.8

of

the

259

allotted

by

Provisional

Variance

(PCB

98-17),

Another

Provisional

Variance

was

obtained

(PCB

98-39)

in

order

to

provide

sufficient

extra

excursion

hours

to

last

the

remainder

of

the

summer

period,

but

due

to

an

abrupt

change

in

weather

conditions

in

early

September,

these

additional

hours

were

not

required

to

be

used.

i

1i(,’()flt

(

fl1IflV

---

either

circular

or

strip

chart

temperature

records,

or

computer

records

from

an

in-place

telemetry

monitoring

system

(depending

upon

location).

(If

required,

completecopies

of

the

actual

temperature

records

for

each

location

will

be

made

available

to

the

Agency

for

further

review).

If

there

are

any

questions

concerning

the

above

information

and/or

accompanying

data,

please

contact

me

at

(312)

394-4468.

Sincerely,

Senior

Biologist

Approved:

(

75

Endof98.doc

Attachments

cc:

Darin

LeCrone;

IEPA

Industrial

Permits

Section

Daniel

Ray,

IEPA

Compliance

Assurance

Section

Matthew

Wertman—IEPA

Maywood

Office

---

---

Dresden

Station

Intake

June

15-30

68.13

°F.

76.22

°F.

84.45

°F.

July

1-31

73.63

°F.

78.92

°F.

85.38

°F.

August

1-31

73.25

°F.

79.63

°F.

85.63

°F.

September

1-30

72.81

°F.

77.33

°F.

82.12

°F.

Dresden

Station

Discharge

June

15-30

84.04

°F.

87.36

°F.

92.09

°F.

July

1-31

86.88°F.

89.66°F.

92.87°F.

August

1-31

86.35

°F.

89.56°F.

92.03

°F.

September

1-30

83.44

°F.

87.02

°F.

91.31

°F.

Dresden

Lock

and

Dam

June

15-30

70.38

°F.

80.50

°F.

84.45

°F.

July

1-31

77.94°F.

84.24°F.

85.38°F.

August

1-31

78.15

°F.

85.04

°F.

85.63

°F.

September

1-30

78.56

°F.

83.38

°F.

82.12

°F.

Joliet

#9

Intake

June

-30

N/A’

77°F

88°F

July

1-31

N/A’

83°F

89°F

August

1-31

N/A’

82°F

90°F

September

1-30

N/A’

82

°F

84

°F

Joliet

#29

Intake

June

1-30

N/A’

79°F

90°F

July

1-31

N/A’

81

°F

101

°F

August

1-31

N/A’

79

°F

98

°F

September

1-30

N/A’

75

°F

98°F

1-55

Bridge

June

1-30

N/A’

81.3

°F

92°F

July

1-31

N/A’

87.0

°F

92°F

August

1-31

N/A’

85.9°F

92°F

September

1-30

N/A’

84.1

°F

89.8

°F

(‘Reports

from

which

data

was

taken

only

list

average

and

maximum

values)

9Santhrm.doc

10/21/98

---

9JOESR1O21

9JOESR1O31

29

Discharge

Temp

J29

Inlet

Temp

155

Water

Temp

DATE

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

1/1/2006

56.9

61.0

48.5

51.5

53.7

55.1

1/2/2006

58.8

63.8

48.9

50.7

54.6

55.0

1/3/2006

63.1

67.4

51.8

53.5

53.6

55.3

1/4/2006

61.6

65.0

50.5

52.4

54.4

56.2

1/5/2006

62.4

67.4

51.4

54.0

54.0

55.5

1/6/2006

59.6

61.6

48.3

50.3

75.9

54.8

1/7/2006

63.2

64.4

51.1

53.2

52.9

54.5

1/8/2006

58.1

63.8

50.3

52.9

53.3

56.2

1/9/2006

63.2

68.9

52.9

56.0

55.1

56.9

1/10/2006

59.6

63.3

51.6

54.0

54.0

55.5

1/1

1/2006

62.4

67.5

52.7

56.8

56.8

57.8

1/12/2006

63.5

67.8

54.1

566

55.2

56.8

111

3/2006

62.8

66.3

52.5

54.1

57.0

58.2

1/14/2006

61.9

67.1

51.7

54.2

54.3

56.7

1/15/2006

61.5

65.2

50.7

51.4

53.9

56.3

1/16/2006

59.0

64.3

49.7

51.5

53.8

55.8

1/17/2006

61.6

64.8

50.9

52.5

52.1

53.2

1/18/2006

63.8

71.6

52.6

59.2

51.2

53.3

1/19/2006

63.1

70.7

53.3

58.0

52.3

55.3

1/20/2006

60.9

64.3

54.0

57.3

57.1

59.2

1/21/2006

59.6

65.1

51.8

56.0

54.3

55.8

1/22/2006

54.4

59.0

47.9

50.6

53.6

55.3

1/23/2006

57.9

64.1

48.6

52.2

50.0

51.6

1/24/2006

56.9

61.0

48.6

49.7

49.7

52.1

1/25/2006

58.5

63.4

48.1

48.8

48.7

50.7

1/26/2006

:

590

63.4

48.9

49.8

51.1

53.4

1/27/2006

59

0

64

5

50

9

53

0

53

2

53

8

1/28/2006

59

2

61

0

52

4

54

1

54

2

55

4

1/29/2006

59.4

61.8

52.5

55.1

55.0

56.7

1/30/2006

56.7

59.4

49.6

51.3

52.3

53.4

1/31/2006

60.2

64.5

51.0

52.8

51.1

52.9

---

9JOESR1O11

9JOESR1O21

9JOESR1O31

29

Discharge

Temp

J29

Inlet

Temp

155

Water

Temp

DATE

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

12/1/2005

12/2/2005

12/3/2005

12/4/2005

12/5/2005

12/6/2005

12/7/2005

12/8/2005

12/9/2005

12/1

0/2005

12/11/2005

12/12/2005

12/13/2005

12/14/2005

12/15/2005

12/16/2005

12/17/2005

12/18/2005

12/19/2005

12/20/2005

12/21/2005

12/22/2005

12/23/2005

12/24/2005

12/25/2005

1.2(26/2005

12/27/2005

i212812005

1212912005

12/30/2005

12/31/2005

65.1

67.4

64.8

69.2

64.1

72.2

66.3

70.9

66.8

69.9

68.1

76.2

67.4

73.6

66.4

67.9

67.6

71.7

66.8

69.2

71.5

75.0

65.6

72.5

68.6

71.5

66.0

70.4

66.7

69.9

64.6

67.2

60.6

67.0

64.6

66.6

66.0

73.9

60.7

69.2

68.0

74.5

65.1

68.8

65.0

69.3

58.5

61.5

57.6

60.1

57.4

62.3

58A

63.2

61.6

65.4

62.9•

68.3

61.9

65.0

60.1

64.0

54.1

52.5

54.1

53.9

55.1

57.2

53.4

52.7

54.3

53.8

57.0

50.8

55.2

53.5

54.6

53.7

52.2

51.8

53.3

51.1

53.9

53.4

54.8

51.4

49.8

46.9.

.46.6:

.50.6

501

51.0

56.5

55.7

58.3

57.0

56.9

65.0

58.4

55.2

58.0

56.7

63.3

56.1

58.5

58.0

57.3

56.0

54.4

53.9

58.4

56.0

60.3

57.3

58.9

55.0

52.9

•

48.1

.45

•

.544

•

51.3

52.0

54.7

55.7

53.9

55.7

55.1

55.5

55.0

55.7

55.4

56.3

75.9

55.1

52.6

53.4

54.2

55.4

54.3

54.8

53.6

54.4

53.5

54.1

54.9

57.2

58.4

59.4

56.7

57.9

58.2

59.2

56.5

57.6

54.9

56.1

53.4

54.6

50.6

52.0

51.0

51.2

51.7

52.5

51.6

54.3

55.0

55.8

56.1

57.9

55.7

57.9

52.5

.

54.1

512

520

.52.7.

...

54.0

53.2

•

54.3

55.0

•

56.7

54.8

56.0

...•

..;•

..

---

9JOESR1O11

9JOESR1O21

9JOESR1O31

29

Discharge

Temp

J29

Inlet

Temp

155

Water

Temp

DATE

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

11/1/2005

75.6

79.3

65.2

66.5

67.1

68.4

1

1/2/2005

75.7

82.5

66.0

68.4

68.6

69.5

11/3/2005

75.6

80.8

67.8

71.8

67.6

68.4

1

1/4/2005

77.2

81.7

68.9

74.7

67.2

68.2

11/5/2005

72.8

75.1

66.1

68.1

69.3

72.2

11/6)2005

72.9

74.4

65.6

68.6

75.9

72.2

11/7/2005

69.1

70.2

61.7

63.3

67.2

67.6

1

1/8/2005

69.1

72.0

62.5

64.6

67.4

68.2

11/9/2005

71.0

73.3

64.4

66.1

65.2

67.6

11/10/2005

73.4

80.1

64.4

69.5

64.3

65.2

11/11/2005

76.7

79.8

62.1

64.5

64.6

65.7

11/12)2005

79.6

82.1

65.7

68.1

66.5

67.4

11/13/2005

74.9

80.7

63.4

67.5

65.6

66.6

11/14/2005

73.3

78.5

64.4

68.3

65.8

66.4

11/15/2005

72.6

75.4

60.5

63.8

64.5

65.3

11/16/2005

72.0

75.9

59.3

60.6

59.4

64.5

11/17/2005

71.3

75.3

57.4

60.0

56.2

57.6

11/18/2005

72.7

76.5

58.3

60.2

59.1

59.9

11/19/2005

74.2

78.9

61.4

65.5

60.1

60.5

11/20/2005

68.0

72.7

59.0

61.3

60.8

61.5

11/21/2005

73.8

79.5

61.2

64.5

62.2

63.0

11/22/2005

75.5

80.5

61.4

65.9

60.6

61.8

11/23/2005

69.6

75.4

57.7

60.9

61.8

62.7

11/24/2005

67.8

72.5

57.6

60.6

60.2

62.3

11125/2005

74.3

82.4

61.4

70.9

56.6

57.5

11/26/2005

71.4

82.2

58.8

72.0

56.0

57.1

.11/27/2005

66.8

75.6

58.1

62.5

.

61.9

.64.6

11/28/2005

69

1

73

4

59

1

61

8

63

4

3

:41/29/2005

66.0

8.0

53.9

58.3

59:3

:11/30/2005

62.0

67.4

51.2

53.9

55.6

56.3

---

9JOESR1O11

9JOESR1O21

9JOESR1O31

29

Discharge

Temp

J29

Inlet

Temp

155

Water

Temp

DATE

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

10/1/2005

10/2/2005

10)3/2005

10/4/2005

10/5/2005

10/6/2005

10/7/2005

10/8/2005

10/9/2005

10/10/2005

:10/11/2005

10/12/2005

10/13/2005

10/14/2005

10/15/2005

10/16/2005

10/17/2005

10/18/2005

10/19/2005

10/20/2005

10/21/2005

10/22/2005

10/23/2005

10/24/2005

10/25/2005

10/26/2005

10/27/2005

10/28/2005

10/29/2005

10/30/2005

10/31/2005

77.8

79.2

81.2

86.7

85.7

90.8

85.8

88.9

89.4

91.8

86.9

89.3

83.9

86.4

81.8

83.9

77.6

82.0

82.0

86.0

84.0

86.5

86.2

89.4

86.0

89.9

86.9

93.4

85.3

89.4

84.1

92.1

85.0

90.3

85.2

89.5

83.4

87.1

79.1

83.3

79.1

84.1

78.2

80.0

75.7

78.0

75.7

81.2

77.3

81.2

76.9

81.1

81.5

776

841

78.7

81.2

73.8

77.2

75.3

75.3

70.7

72.3

73.9

74.1

75.4

73.8

72.0

69.9

69.5

70.1

71.3

73.2

73.7

74.1

73.2

73.6

73.4

73.6

72.4

70.7

70.6

70.0

68.9

67.9

66.0

64.6

66.i

66.9

67.6

65.6

67.2

72.0

74.3

76.5

75.7

76.1

74.9

73.4

70.5

71.0

71.9

71.9

74.3

76.5

77.3

76.3

77.9

75.0

76.5

74.5

73.0

74.3

70.8

71.0

69.1

68.6

69.5

69.6

•

70.9

729

68.6

67.2

72.8

74.2

76.1

78.9

79.6

75.9

75.9

73.4

73.1

72.0

73.0

75.2

77.3

77.8

78.0

77.3

76.4

76.1

76.5

75.1

73.6

71.6

70.2

70.2

69.7

68.0

•

69.7

•708

69.7

69.3

73.4

75.2

76.9

82.3

80.4

79.8

78.1

74.5

73.6

72.7

74.8

76.1

78.7

78.7

78.7

78.8

77.2

77.1

77.3

76.4

74.5

72.4

70.8

71.0

71.4

69.9

72.6

70.9

71.5

70.1

69.3

---

9JOESR1O11

9JOESR1

021

9JOESR1

031

29

Discharge

Temp

J29

Inlet

Temp

155

Water

Temp

DATE

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

AVERAGE

MAXIMUM

9/1/2005

95.9

99.9

85.0

85.9

86.2

87.6

912/2005

91.0

96.9

83.0

84.0

61.0

86.5

9/3/2005

90.0

93.4

83.5

85.5

83.9

85.3

9/4/2005

89.7

92.1

83.2

84.3

84.4

86.0

9/5/2005

86.3

90.0

80.9

81.9

84.8

86.5

9/6/2005

85.8

91.8

81.2

83.5

75.9

84.8

9/7/2005

89.0

91.3

81.7

82.9

84.2

86.4

9/8/2005

92.9

98.7

81.7

82.8

85.4

87.2

9/9/2005

92.4

97.4

81.6

84.1

85.8

87.3

9/10/2005

93.0

98.4

82.8

85.3

85.6

87.3

9/1

1/2005

93.3

97.9

84.0

85.3

85.6

87.2

9/12/2005

94.4

97.8

84.1

84.7

85.6

86.6

9113/2005

94.2

97.1

84.5

85.6

85.3

86.3

9/1

4/2005

94.3

97.0

84.3

85.4

85.4

86.6

9/1

5/2005

92.6

96.2

82.9