ew Generation Project Water S
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    February
    11, 2005
    3 100 Stevenson
    Drive
    City
    Water Li
    Mr. Brian
    Fitzgerald
    New Generation
    Project
    Dear . Fitzgerald:
    f _.
    '"!)
    rd Amendment No. 2
    elated De
    :.
    unbar
    6, 20C1Q..
    support
    the addition of the
    new electric
    .-
    performed
    to ý<<idress wat(sul)ply,
    boron
    r.wmoval
    and lake water
    conservat
    A ttachments
    c
    c:
    Brian Basel
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    -JY$(erJ9bldy
    tndex and CedifNlan
    C
    ity Water Light & Power
    Springfield, Illinois
    New Generation Project
    INDEX
    AND CERTIFICA rION
    PAGE
    NUMBER
    PART 140.
    PART TITLE
    FO
    PAOFS
    PART 1.0
    Executive Summary
    2
    P ART 2.0
    Introduction
    2
    . ý . .ý-_-PART 3.0
    ,- Water Supply
    P
    ART 4.0
    Wastewater Treatment
    PART 5.0
    Options
    2
    3
    3
    PART 6.0
    Evaluation of Options
    23
    PART 7.0
    Conclusions and Recommendations
    3
    APPENDICES
    Water Balance Diagrams
    Typical Brine Concentrator/Spray
    Dryer Process Flow Diagram
    Typical HERO System Process Flow Diagram
    W ater Usage Projection
    for 2010-7050.
    Water Usage Charts
    Boron Treatment Options Cost Comparison
    Water Conservation Options Cost Comparison
    ICATION
    7
    2
    1
    1
    3
    1
    2
    Design Firm Registration Number: 184-001310
    -
    '"-CltkWeteiggd(APawaiý Spririyfeld,7gPriols
    --R!0=1.._..._-..
    Pr*c(34821. January 2005
    Kansas ft Mlasoud
    W8(erSWyCert
    Page RUM
    doo
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Table
    of Contents
    TABLE OF
    C ONTENTS
    1 .0 EXECUTIVE SUMMARY.........................,...
    2.0 INTRODUCTION..........,..........,...................
    3.0 WATER SUPPLY ..............
    ...........
    2-1
    ...,... 3-1
    ..................
    3-1
    4.0
    4.1 On-Site Wastewater Treatment Plant....
    ... 4-
    5.0
    I
    I .'!i' !' I,
    Pro'.-i.Juý_
    6.0 EVALUATION OF OPTIONS....
    6.1
    Wastewater Treatment Options...
    6.1.1 Plant Wastewater Discharges ................ ,......... .........
    .., 5-2
    ......
    6-1
    6.1.2 Ash Pond Discharges and Boron Removal Approach....
    6.1.3
    Boron Removal Options...
    6 .2 Water
    Supply
    and Conservation Options..................
    6 .2.1 Lake Sp
    6.2.2 W itr
    r
    C;onserva
    6.2.3 Wý<ler
    7 .0
    n .................
    6 .;3.1 Boron-Remo
    ..6-11
    ... ....... 6-20
    6.3.2 Water Conserva
    C ity Water Light & Power, Springfield, Illinois
    "TC)C-1
    Bums
    &
    Mcbc,rn,-.
    l
    P roject 34821, REV: 1, February 2005
    K&r, u iy Missouri
    CWLP Water Study Feb 2005. doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Table
    of Contents
    A PPENDICES
    Water Balance
    Diagrams
    O ption 1, Using Lake Wýjtc-a with No Water Conservation Options,
    Maximum Flow
    Option
    1, Using Lake Water with No Water Conservation Options,
    Annual Average Flow
    Option
    2, Using Cray Water, Annual Average Flow, Annual Average
    Flow
    Option
    3, Using Lake Water with Dry Fly Ash, Annual Average Flaw
    4 Option 4, Using Lake Water with Closed-loop Bottom Ash System,
    Annual Average Flaw
    Option
    5, Using Lake Water with Recycling Ash Pond Effluent, Annual
    Average
    Flow
    F inal Water Study Water Balance - All Selected Options
    Final
    Water
    Study
    Water
    Balance --All Selected Options (Maximum
    Load)
    PFD1 - Typical Brine Concentrator/Spray Dryer Process Flow Diagram
    (Sheet 1 and Sheet 2)
    PFD2
    -
    Typical HERO System Process Flow Diagram
    Table 1 - Water Usage Projection for 2010-2050
    C ity Water Light & Power, Springfield, Illinois
    TOC-2
    B urns & McDonnell Engineering Co.
    Project 3482?, REV. 1, February 2005
    Kansas City, Missouri
    CWLP Water Study Feb 2005.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Executive Summary
    1 .0 EXECUTIVE SUMMARY
    treatment system options
    tewater
    production rates.
    to study water conservation
    o
    t the Ntevenson Drive generating
    porate the results
    of
    the pr
    loped that
    sis of var
    t water source is treated
    economics may change which may
    i1:j''. e
    ý 'o ns to implement to aid in
    finalized.
    discharged from the plant. Because o
    ise the exiting city fihc. c
    plant
    has suffic
    new generation facilities'
    up w¬aý:r cteýzl, ýýid.
    Thus city water treatment plant treated
    water is the recommended water source.
    us boron mitigation studies indicated that the major source
    of boron
    exiti
    liquid blowdown from the Dallman 31, 3'2 and 33 FGU systems. Alternatives for
    treatment
    of this water stream were investigated during the
    water study. The preferred
    ndary option
    ystems from
    r Light &
    821,
    REV.
    1,
    E
    ®1
    r Study Feb
    B ums & McDonnell E-!7in,-nf
    -7
    Kansas City, (:ii:soud
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    wet to dry handling to
    ree of boron that i
    it
    reek, In
    p ond water for makeup to the
    new uni
    lowdown treatment
    equipment
    oundwater contamination and ash pond life expectancies
    ash
    from
    the ash ponds.
    The
    would need to be conducted to determine if this option is feasible. Additionally,
    a study
    should be conducted on the effect of the existing fly ash content of the ash ponds, as well
    l
    andfill
    leachate, on the ash pond and ground
    B esides the recommending boron removal and/or water conservation options, urgent R
    ded recycling the FGD vacuum pump seal water. This
    being
    made by
    eludes
    a zero
    discharge FGD
    followed by two
    Unii,, i o dry fly ash
    Ice-up be
    recotr
    Tit,-
    i
    I
    c,-, i j
    Awntr _ttors and
    In the c-,rent
    that
    the
    Ash Pond water quality is
    not suitable for
    direct
    discharge
    to Lake
    Sprirzi_ iiuld_ a wastewater treatment system could be added to allow recovery of the Ash
    Pond eftlucat as makeup to the new unit cooling tower for water conservation.
    B urns &
    Mchonneýi Ei7gine
    r,-nq
    C;o.
    h=r. -
    s
    ;'Y. Výscluri
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    2.0 INTRODUCTION
    &McD) to p
    new generation facilities at the Dallman Station. The study investigated the availabil
    and :Feasibility of water supply sources required for the planned
    new coal-fired unit (200
    followin
    wastewater treatment concerns;
    2004 report.
    r
    ,-:ý
    o
    ,'the
    r C f ý.
    Iti",Jtl'
    b
    Tn `1:
    ,(1'tiri the c ;J:t't)glfiiii", e'1-, ,1-thybent,ti I
    d y,
    Report L-008254, Sargent & Lundy, April 23,
    v,irious
    p1
    ý!I < ýý ?ýh water
    streams,
    u,1
    provided sevei A recommendations to CM'[,P to
    reduce boron concentrations in thei
    installed SCR
    equ
    Potentially feasible boron removal. options were identified and evaluated
    and three
    potentially viable options were selected. The net present value of each o
    calculated
    based on estimated installed equipment cost,
    and annual operation and
    Based on the net present value analysis, and other factors, a pre
    cted
    as the base-case option. This base-case opti
    t l on o
    r Light
    Project 34829, REV. 1,
    C WLP Water St udy
    Feb
    2(705.
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water
    Study
    Introduction
    Additional methods for conserving take water were reviewed. Three possible water
    tliods were selected
    for
    further study.
    These options, combined with two water supply options (Lake Springfield and the gray
    water), formed the five options studied to provide far the plant water supply and water
    . A. water balance was prepared for each of these live options, and water
    as calculated. `eater conservation options were then evaluated u
    these
    op
    lesions and Recommendations) of this
    report.
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Water Supply
    3 .0 WATER SUPPLY
    W ith the addition of a new unit at the Stevenson Drive plant site, the water source to
    this
    operation
    must be
    chosen.
    This section of
    the
    Water Study report discusses
    .'I Lake Springfield
    Lakeside
    and Dallman Units. It
    The
    consumptive loss of the lake water far condenser cooling.
    of the lake water far the existing units is
    a i-111 rn[W : .iur. a ''Cli.. L'lIII
    w
    ater.
    V
    L ite DC VV
    u-
    ump
    lant use without requir
    . S anitary Wastewater
    T
    reatment
    E
    ffluent
    (Gray
    Water)
    The use of gray water as make-up water to power plants is b: corning a mor, widely used
    method to conserve ri-esh
    water. Although
    this type
    of
    ý:Ii. <,.1
    ýn has
    w .,.I
    problems at some f 'shies, there are several successful cG ses of gray er reuse. The
    use of gray water
    Lt: ý UpWciat
    concerns in the operations and maintenance of power plant
    which is the fresh water supply
    snore valuable due to growth in demand,
    ling
    and corrosion within
    n ,-"is to be rc:,,,oved by bleu,- town.
    ad:";ti, r,:.,1 treatment
    if
    ant
    ýe r vice
    water arid
    ities exist to provide the lake water to
    r plant, Water from the city high
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Wafer Study
    Wafer
    Supply
    t is important to mi
    is
    located about 3 miles away
    ruction of a pipeline to bring the gray water to the site would be
    is would be costly and thus is a disadvantage
    compared to using the lake
    water as make-up water to the new
    unit. However, the use of gray water provides
    ianificant
    reduction of consumptive use of the lake water.
    nificant total organic content
    and solids content still remain that could cause problems
    with reusing gray water result from
    h igh potential
    for biological
    deposit or microbiologically
    content
    (d
    p roblems
    associated
    i
    Light E Power, Springfield, Illinois
    3 -2
    Burns ? McDonnell E
    ngin
    1 , REV. 1, February 2005
    Kansas
    City, Missouri
    s t of the suspended solids and organics in the incoming
    water are removed,
    b 2005.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Wastewater
    Treatment
    4.0 WASTEWATER TREATMENT
    T
    here
    are
    several types of
    wastewater
    streams
    generated
    from
    various plant systems.
    they
    fall in three
    consists
    of
    wastewater
    streams
    that can
    be
    . The
    third type
    will be
    a
    ess than the FGD blowdown and can continue to be treated
    nd currently the FGD system blowdown. This
    S ugar Creek. The boron content of the ash
    ily the FGD system blowdown. This
    of
    boron and
    cannot be discharged. This
    4.1 On-Site Wastewater Treatment Plant
    Dallman and Lakeside Units share a common on-site wastewater clarifier
    wastewater streams from the site, processes them
    afer to Lake Spr'- ;,field. Th_ ti f:,tment syst-,i-, k
    ponds using lake
    not
    rerno;-e any signifc
    .
    ',;mount of dissolved
    :-r-ttd t
    r (ý,
    arm , Sttch ^s th- FCT3
    n 1,1owdown, are n, ,t ,a[:
    water supply. The second
    6
    1r _S would
    cause.
    i
    s uspend,
    systems.
    The treatmer (pt , o t provi
    lake
    water or the mitigation of boron dischn)
    h plant service water drains, should be able
    to
    share the common wastewater
    clarifer treatment
    facility.
    However, modification
    of
    lant N
    streams e:_uld be discharge through the existing wastewater clarifier treatment facility.
    The disch<ti Ye from the wastewater clarifer plant is directed to Lake Springfield, which is
    the rev, ,,: ttcr -supply source to the plant. Thus the wastewater streams treated by
    the
    wastewater treatment plant are not considered consumptive losses froze lake water.
    4 . Ash Pond Discharge
    . {ail, float
    fication pond.
    At
    this
    stage,
    chemi,.i 1
    Its in settling; and separation of mos`
    ifed water overflows to Sugar Creek (via autfall #004).
    ischarge has periodically
    exceeded the discharge
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Wastewater Treatment
    occurred when the plant SCR system is in service (average concentrate
    Hanson's study report). The higlh,:st concentrations of
    boron
    are prom
    the
    blowdown streams (2010-400 ppm). However, ev
    levels have app
    ro«,ýftad
    the discharge
    s ource of boron contamination (40-50 ppm).
    d analysis, that eliminating the fly ash sluicing
    eters,
    t he
    baron
    discharge problem. Because the p'GD blowdown has much hi
    than any other wastewater streams contributing to the ash pon
    CWLP personnel have expressed concerns th
    ý,:
    'ally dur
    ,e boron are
    ru
    r<<oni,i Maya
    a.;1-1,-nciI in;rt a. dry
    system.sexper
    indicates that the fly ash
    sluicing water
    the largest
    treatment options for
    which boron, as
    likely and reliable o
    indiscriminately removed (separated) from the water.
    in
    dissolved
    solids,
    and may
    be
    reused as make-up water with
    mnf."Alp
    r.t :;icw,.ýter
    (e.g.,
    prcr=: t_,ss.
    of th i
    Common
    zero-discharge processes
    i
    f ed) must be further treated in a
    brine concerti It
    it bi,A
    to a sol
    i: ý n n ý r f- ,!turers have suL
    'roject 3 4¬321, REV. 1,
    C WLP Water Study Feb 2005.dcac
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Wastewater Treatment
    allizers may not be able to completely convert the wastewater to a
    solid waste.
    ever, if an RC} system is used, the proper treatment of the RQ waste brine
    crystallizer due to cost as well as the difference
    it
    the
    water
    chemistry
    after an RO
    system.
    in this report.
    The
    high for these systems. The disposal of the solids
    from the zero-discharge treatment equipment could be costly, too,
    s idered hazardous. This is not typical but high levels of
    a
    hazardous
    material
    classification
    which would cause the
    al expense to go up significantly. Potential constituents of concern
    and
    boron. Thus, zero-discharge options are normally not economical options far
    water conservation, but necessary means to meet discharge limits - in this case, the
    boron
    discharge limit.
    C tfy Wate7ight &
    Project 34821, REV. 9, FeLru-,
    i,,
    ý
    ,1
    cnginee
    C ity,
    C WLP Water Study Feb 2005.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    5.0
    OPTIONS
    for w ater c onservation a nd boron m itigation involved t he review of
    i
    dentified options. New options were also considered and evaluated if
    they were considered feasible.
    5 .1 Previous Study Options
    5.1.1 Water Conservat
    In the &L study; several potential water
    conservation op
    as follows:
    a sh handling systems
    (3)
    Dry
    (4) Sanitary wastewater
    trc-;ýtment effluent as additional water source
    (S) Recycle of ash pond e I
    i
    luent to Lake Springfield
    (6)
    FGD vacuum pump seal water and routing
    of
    FGD sump pit effluent
    (7)
    Ash handlin__
    water managem en t
    T
    (8) Pleat ex. l,
    ý,;
    me of FGD
    blo down from the
    of lake wat: r° because city water also origin -.tes
    ')tal
    ,r
    for the recovery o
    s currently being pursued
    by
    CAILR
    ns
    i .;r to lab
    requires a relatively small cap
    its, which will help re
    Iso small. Amore
    . br
    ption
    discussed
    b3
    ' < <
    gray water to
    "
    'b
    e
    -C,-;
    nd spray dryers). This op
    ply turning them
    lips,
    w ould be
    rr^ c inversion to using lake water as
    the
    coo
    water.
    led ash p f"
    lake water (clad
    e
    r
    pf-r
    water,
    it is more econorri'''?l
    1ý ý
    Uý7- treated
    ir; ;b.! crfpotable water, for lxý,ýt ý.:.c h +i -rý°s
    :
    cad
    some otl
    i,-,r 11:
    ;. r
    of pot
    However, many users offýc.ýý-'ýh
    ,,;J,
    r :;r
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Options
    currently connected
    to the same headers, such as
    safety
    showers, eye wa
    washroom facilities, which require true potable-quality water. The modifications
    5 .1.2 Boron Mitigation Options
    o r, crystallizer, spray dryer, etc.).
    if
    feasible, could be significantly less costly, but it is not recommended based
    on
    the lack
    of
    successful commercial operations of these types of systems for FGD blowdown treatment
    lications. In contrast, mechanical evaporation and/or R4
    systems
    are
    considered
    more proven technologies for this applic:tf
    i,:)n.
    Therefore,
    for selective
    boron removým1 pr-)cesse.;, erh.. cin?.ly the
    ion
    exchange
    res
    wid
    in
    anu
    ý 7-, ý turing),
    W ithout s ufficient iniora
    l
    r
    ed-,.) ý. f 'cuses on more,
    to
    s pray dryer,,- .ý uld be require
    re i x;,,.,
    ý1
    options concentrates c
    5 . Additional Options
    Besides the opt
    the true
    potable
    water users anti the outer potable water users may
    recommends that the following o
    ,posting a spray
    wet to dry h; f
    i
    t, i lit
    is report.
    o ption
    by activated carbon, ion exchange resin or chemical
    l fýý-;s
    for this
    i ;,
    j
    ided to CWLI', B&McD also
    l
    aloe-up to the new un
    and boron removal
    is using
    e concentrator bleed. Dry fly ash unloading (to
    off-
    quire water for dust control. If brine concentrator bleed
    t o mix
    d isposa
    could be used for
    th
    if
    doing
    so meets fly ash disposal quali
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Options
    One idea considered by B&McD was
    to
    r
    lowdown flow rate
    construction are compatible with the higher chloride concentrations. Lower FGD
    blowdown flow rates will make the brine concentrators/spray dryers smaller. Based on
    the scrubber design at the
    Dallman Units, the chloride concentration is maintained below
    10,000 ppm for corrosion prevention. Any reduction in the FGD blowdown rate to
    conserve water would result
    in an
    W hile smaller
    equipment means lower capital and O&M costs, the
    concentration in the scrubber and gypsum may cause the gypsum
    ich must meet certain quality specifications,
    its disposal will also
    ant operating expense. This
    option only slightly reduces the boron-
    oenetit is not signiticant, t)ut the prowern it orings coma oe
    C ity Water Light &
    Power, Springfield, fftin
    B urns & McDonnell Engineering
    Co.
    P roject 34821, REV. 1, February 2005
    Kansas City, Missouri
    CWL,P Water Study Feb 2005.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    D and 1.0 M
    6.1.1 Plant Wastewater Discharges
    A ccording to the S &L water balance
    w astewater discharge to the on-s
    6.0 EVALUATION OF OPTIONS
    cost and
    benefit
    evaluation was performed for the
    boron
    treatment
    4.22 MGD, respectively. The m
    orm water flow
    which
    will still c-gist after
    ired.
    After the Lakeside Units are retired in 2009, wý_rcwater
    ite wastewater clarificr treatment should decrease by appro:ý: i i, i <i i
    "the waste water clarif <<-r plant is about 7 MGD
    a
    ý1. -to
    t~'.,rLlý'
    al
    I'
    I.,
    f
    n'h.
    :
    pl
    i,; for'i.:.:t:rclii-
    1 1
    1.1!
    l
    1 !1i1 llll
    :
    110ý 1 ! h- 11 ý7 , 'IaaL'1ý 0.
    a ll Dalhrlan
    Uilit' 1 (il'ýs . tFlt: on ,ite wastewaicrý ýý[:irifier treatment
    p lant.
    e d to the existing wastewater c
    plant area
    st
    C 1 c.,n
    t
    and the new unit wastewater.
    e xisting wastewater treatment
    6 .1.2 Ash Pond Discharges and Boron Removal Approach
    n <,
    the Ranson study, as well as information
    from
    CWLP's staff, B&McD believes that
    refi loving the FGD blowdown stream(s) from
    the plant discharge to Sugar Creek may provide sufficient reduction of boron in the final
    wastewater discharge to meet the current 10 pl,m limit. Once removed from the Sugar
    the FGD blowdown stream
    r1 gust
    be
    treated to removal boron
    ihcations will be requi
    c,
    (i
    a w.{i.ste for off-site disposal.
    D ; t 1 h
    .
    _n
    l
    GD system blowdown
    u :
    104
    1-ýu}ýi.
    The
    r Light& Power, Spry
    , REV. 9, January
    Feb 2005.doc
    Burns
    & McDonnell Engineering Co.
    Kansas City, Missouri
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    wastewater from plant
    Outfall #004 would likely reduce boron concentration
    in Outfall #404 to below the
    current discharge limit. More importantly, if the FGD blowdown streams (including the
    new unit) are allowed to be discharged
    to the ash
    ponds
    in future, Outfall #004 would
    a lmost certainly exceed the boron discharge limit after the new unit is in servi
    combined FGD wastewater is about 201 ppm
    of the discharge to Sugar Creep is about 3.78 MGD w
    of 17.9 ppm during times when the SCR is in
    operation. Removing the FGD wastewater
    blowdown from the ash ponds is estimated to reduce the concentration
    of
    boron
    in the
    e lc down to about 10 ppm of boron, which is lower than the
    of 11 ppm, although the margin is not
    large.
    vc F,,
    I
    -n reported. Thu ;, not removing t
    I
    I t :,te ý-,
    ,
    potenti:-,t '1
    c
    I 'n- the
    The results
    ý," (I
    stt:;t11-3
    rý-iit
    Cb,, a'.11
    indicated that,
    h ponds,
    1n-a Dallman
    to Sugar Creek from the above 10 ppm to about 5
    ry handling alone would further reduce boron
    1 ppm
    additional reduction
    A lt o
    s h systems to dry
    c
    oncentrations) of various
    ion of the current
    of 0.15 MGD.
    The total flow
    ac-
    is
    root
    Miclenttocý'!ý.ply
    ing, the boron
    ischarge to Sugar Creels.
    nly,
    These were
    reviewed
    in more detail, and manufacturers that special
    h
    concentrati, w {-efdissolved
    R EV, 1, a' :rt!ý:.ry2008
    Kansas City; Missouri
    ight & Power; i ,,gf,,,d Illinois
    6-2
    r, car Mh.Oonnell Engineering Co.
    Feb 2005, doe
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    to remove boron. For example, materials of construction need to be
    corrosion
    resistant;
    ch as reverse osmosis (.RC7) will not have high recovery due to the
    limitation
    on osmotic pressure, and the high suspended solids content requires pre-
    treatment.
    T
    he Hanson study evaluated several options including selective boron removal, as well as
    general dissolved solids remove such as RC) and mechanical evaporation, However,
    B &McD's investigation
    change resin or a
    indicated
    that, due to
    the application of selective
    Id not be realistic (frequent
    ion
    or media change-out will be required). On
    the
    other
    hand, chemical
    ected to be effective, but in this case,
    concentra
    al methods, such as RC) and mechanical evaporation, are the only
    plication
    at
    CWLP. When
    iLccl -,,,-c,`cr normally becomes a
    I:igh-qur
    brine
    cancel'fr.'.1-,I
    small,
    r <<i I It 1ý
    I
    1l,
    "tý
    6.1.3.1
    Option
    1-1
    - Brine Concentrator Followed by Spray Dryer (Singli Train)
    , nc Cl:ariic:.4 tporators that separate and recovs
    r
    hater from the
    is high-quality, and may be reused in many
    power
    plant applications. The roar, [EiraLCd solution left behind is of much smaller
    volume, but still in a liquid (slurry) form. The most
    commonly
    used brine
    concentrators
    are called
    falling film seeded slurry brine concentrators, and most of these use a vapor
    compressor
    to provide self-sufficient supply of steam to heat up the wastewater slurry,
    The heated wastewater evaporate rnd generates steam that
    r slurry in. The slurry
    is recirculated in a vertica
    .:cl-l.tager), with the steam on the shell side. Due to the
    chlorides,
    the
    wetted materials are
    normally
    made from
    d the tubes from titanium. These types of brine
    ressor
    and the
    o usly bled from the system
    the system sea
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Options
    as 30:1 of
    the
    wastewater
    is achievable. However, to be conservative, in the water
    balances for this study, a 15:1 reduction was assumed. The water balances are attached
    ices of this report.
    The concentrated bleed would be taken to a spray dryer where it is
    completely dried
    to a
    solid
    form for disposal. The spray
    dryer is designed based on 20:1 wastewater volume
    reduction at maximum design flow rate. The above 15:1 reduction is for average
    itions which have
    flow rates much lower than the maximum design
    under the average operating conditions
    tle on the bottom of the drying; chamber, or are carried by the hot air to
    dowr; .t: i i lids-removal equipment, such as bag houses or
    cyclones.
    The rema
    n, these systems are then comp. cted by an "agglornerizer" to increase
    iiý - ,iids.
    This is important,*!'
    f 1
    *; posal cost of the solids is
    of total ,
    ý. ; I
    h Lire base (
    be treated by the spray dryer than its
    the power plant. No liquid
    once,
    such
    as
    that
    the incoming
    T
    he opt
    at trains of the br
    w unit
    a lso
    dryer units, each designed for
    50°% of the maximum capacity required.
    by two 50% spray dryer instead of one 10
    cost of this option
    will
    be
    higher due to the more pi
    ill serve all
    1 1,1-)st
    of the other TD) from th-
    ine concentrator of the dual un
    Power, Springfield, Illinois
    6-4
    Sums & McDonnell Engineering Co.
    >, January 2005
    Kansas City,
    Missouri
    dy Feb 2Q05.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of options
    r ay D ryer
    A
    n
    altern
    process to recov
    ical evaporation is to use a RO
    volume). However,
    water
    (to reduce
    dissolved constituents in the FGD
    blowdown streams, very high reco
    pressure
    and the pressure limitati
    system is impossible due to the osmoti
    ially available RO membranes,
    about 75% (the RO reject is about 25%
    most of the dissolved solids end up in the RO reject, this 25
    flow would also
    contain
    about 4 times the concentrations of dis
    solves
    this problem
    1,`.'i;
    ; alts
    1 ,'i
    A fter the liiý,.e/soda softener, water would contain relatively low hardness, but si
    conc(iJti ;,11 ý- J E is not affected
    by lime/soda softener as much as hardness. When
    lower solubility.
    could
    foul
    up the RO
    membranes. A hi
    by operating the RO system at elevated pH (l I or higher
    b oron stay in their soluble form and will not cause scaling probloms.
    s ilica and
    lime/soda
    softener, a HERO system (a patented high-pH RO,: y,-,tcm design) is use
    ERO is still an RO system, so its recovery is limited by tltC w.; ýzýutic pressure.
    Cil
    ,.
    I-ILRO. the size of the crvstalli
    ! i,
    rr
    y dryer afr -! the
    Cite cost of the HERO is generall
    ch
    less
    electricity.
    i
    ýYiii
    8. ;, REV,
    :udy Feb 2QQ5,doo
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of C?pti
    Compared to the brine concentrator/spray dryer design, the HERO
    disadvantages. From a simplicity
    point of
    view, the brine concentrator option is more
    favorable because it involves fewer components to operate. In contrast, the HERO
    f the lime/soda softener
    (chemical.
    feed, solids removal and disposal),
    p re-treatment of the HERO system, and the HERO itself. Typically, the pre-treatment
    includes a polishing ion exchange resin
    softener, such as a weak acid cation (WAC) resin
    i
    re concentrator unit. A typical process flow
    6.1.3.4 Option 3 -- Spray
    Dryer versus
    Fly Ash Mixing
    &J,
    _1
    information,
    projected
    avera
    °fa moisture content
    ing only
    3
    .,
    4
    for bleed for wet
    a verage operating conditions and plant load factors).
    Thus for this option to be used,
    Dallman Unit 33 trust be
    converted to dry fly ash system. This study assumed that
    Dallman Unit 33 would be converted to dry fly ash handling for this purpose.
    0
    S. This will require about 3 gpm
    fly
    ash system, there would be sufficient fly ash (in addition to the fly ash
    from the new unit) for the brine concentrator bleed to
    mix with. "Ibis will eliminate the
    need for dual trains
    of
    spray
    dyers. A single train of spray dryer is still recommended as
    nit
    33 is offline (not providing the required additional fly ash).
    anct
    a pt1 adjustment prior
    solids removal (for
    Lion
    of the
    igher
    compared to the spray dryer following the brine
    concentrator,
    ich
    is a trade-off with the
    cost
    savings on
    energy consu
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    the converted dry fly ash system is expected to be much less than
    that of the spray dryer.
    Thus the overall
    economics
    of
    this option may be more rat. o;-:J-,1e.
    ent. In this case
    this option becomes invalid, unless the customers consider
    w ith brine concentrator bleed, this could add significant expenses to
    the total (3&M cost
    of
    this
    option. Another concern with this option is that many potential customers for the
    fly ash fxom CWLP prefer pneumatically transferred fly ash, which does
    not need any
    tied fly ash.
    6.1.3.5 Other Option
    ,
    gr-selective
    (1)
    ic y: t:,ý ý+. tj
    sale, and must be taken
    c ost
    is higher than regular landfill because of the in
    ed in the Hanson study, were also reviewed,
    These opti
    f f,h
    i
    63. According
    f
    ,1)
    ,100 cu.ft.
    of resin would hi :
    Acid and caustic are normally to-.:for
    S-108, the total regeneration
    if the capacity of resin is at 2 ounces/f . If
    imately 550 cubic feet of S-108 will last about 4 hours
    wastewater. As an example, for total treatment flow
    rate of 1'74 gpm with 200
    The operating cost of the system depends on the concentrat
    ,,
    Jvutent in lieu of a brine concentrator, but some of tf,ý
    it lust be provided to treat the
    r-_.d to the brine concentrator/spray dryer
    option,
    11 ion exchange
    be
    C ity Water L rqjd
    P roject
    348- 1, REV. 1,
    CWLP Water Study Feb 2005. doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    to
    the
    spray
    dryer. The O&M. cost of the ion exchange resin systems is much cheaper than
    that of the brine concentrator. But the crystallizer O&M cost may be much higher
    than
    that of the spray dryer following the brine concentrator.
    FGD blowdown for the resin to achieve its typical performance for boron
    removal.
    Pilot testing would be recommended before this option could be more
    FGD blowdown. For examp
    applications. This type of resin may not perform well with the water chew
    applications are for lower concentrations of boron, and for
    water purifica
    FGD blowdown treatment application. Most of ion exchange boron removal
    The biggest concern of selecting this op
    converted
    to dry systems,
    s with
    l; r:
    , i
    ly considered.
    i :M n their
    n
    aii-,-,icon
    , :
    r1ie
    c u".
    (2) A tr;carbon for boron removal.
    This
    option
    v: ;
    discussed
    briefly
    by
    ( 3)
    °'s capabilities by B&McD has not provided any
    i11
    Engineers; but there was not sufficient inf,rrrn-i
    I, )i
    L
    to determine the
    b ility of activated carbon for boron removal. Re, earch into activated
    1 by activated carbon. Thus,
    thi
    i
    :',:(ýrn:.e
    lim
    it because the product failed to perform. Thus th
    agent indicated that the company that prcctýjc
    more applicable at higher boron
    conc:uýlirý IT
    o f the high solubility
    of
    ould remove a sufficient amount of boron from the
    be
    discharged with other wastewater in the ash
    C ity Water
    Light
    & Power,
    Springfield, Illinois
    5-8
    Bums & Mono
    nrneerlng Co.
    Project 34821, REV 1, January 20175
    K4, v _y, Missouri
    CWLP Water Study Feb 2005.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    6 .2 Water Supply and Conservation Options
    Two water supply sources were evaluated for use as make-cap water to bath the existing
    unit, Lake
    Springfield
    and the sanitary
    wastewater treatment plant
    Lake Springfield is the raw water source to the existing units and
    plant ýt, titer Plant) located on the plant site, and it
    fly second water source is the
    ater supply source as make-up
    i
    Springfield. The water is the treated, clarifier and filtered before being stored in
    large
    underground storage basins. The treated water is pump from the basins through a several
    fl. =,V
    cy and close proximity of the lake,
    be installed to extract water from the once-through
    through
    system operates at a low pressure.
    'pl'r--imately
    3-mile
    p
    forv.-arding pumps, won
    rce and
    cause
    severe operational problems in coolin
    s ystems, which take cooling tower blowdown as make-up water.
    ontent and high bio-activity could
    cause
    fouling and fouling-induced corrosi
    in plant equipment such as coo
    cont; l w iw:,rts in the
    trcatr<<,r,t, (-spec
    c hew
    ;..ýal
    treats
    ing station at
    the
    SWTP, an
    ility is recommen
    ?Isc 1_,jrfij-mentproblems,
    W ater Light& Power, Springfield, Illinois
    6-g
    igher than if lake water is used.
    t 34621, REV. fi, January 2005
    Kansas c f,,, Missouri
    later Study Feb 2005, doc
    Id
    s tora.,,:.- w uld be requir
    c
    flýcuive,
    some
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of
    Captions
    a nd some commercial and
    r esidential properties that are not owned by CWL,P. Obtaining casements across other
    properties
    could be time-consuming and costly. These costs are not included in the cost
    estimate for this option,
    more costly to use gray water than lake water, as make-up water to the
    ay Water as Make-up tea New Urea:
    Comparison Items --
    Lake Spririgý eld
    S WTP Gray Water ---- --
    Capital Cost
    _
    $150,0 00
    $ 3.7M'
    Pumps., pipeline, and tanks
    Pumping Cost
    $ 0 .0 013911,000-gal
    2
    40
    hp, continuous
    ($0 .0211,000- gat if
    e
    lectricity co t<
    hr)
    Pu..-i aýý 17
    $6
    l.
    ,
    It I
    - 0 t-}`,
    , hs (acid,
    -75 hp
    ,
    c,,.
    i.
    i.s
    (acid,
    c £,
    c y
    14
    iIif
    '
    ar°
    .
    l
    ired.
    N lýi:::1M!I!n Cycles of
    > 10
    <8
    t -
    n r _ i
    Co(`
    i I TI .'vý'r 1
    91
    I
    ,
    I I : "`, ird H igh-,iý. I-?; .fill maybe Low-Foul fill may be
    Con: i i ! ý'Aion
    used for lakrý water due to
    required for gray water.
    lower potential
    of fouling. Cost is about $400,000
    higher than the high-
    _
    effr_cienc_y_fiill..
    Additional Cooling Tower
    _
    NIA.
    -
    _
    More-frequent biocide
    Chemical Cost
    treatment and higher
    concentrations, or more
    expensive types, of scale
    and corrosion inhibitor
    treatment are expected.
    Possibly
    more chemical
    waste
    (in blowdown)
    due to
    lower cycles of
    concentration.
    __
    OtherC t'I.<.i`
    - Allinstallation and
    -Offsi cr'r,ý`!-Action of
    e quipment modifications pipeline, ;ind writing with
    are on-site.
    outside orb', i izations, could
    b e costly.
    ingfield, Illinois
    6-90
    Burns & McDonnell Engineering Co.
    Kansas City;
    Missouri
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Notes
    1. B&McD internal
    est
    tables).
    2 .
    3 .
    ided by CWLP letter 2/1112044.
    o st analysis
    ith using gray water
    iced that the use
    o f gray water
    will not
    be pursued at this time as part of this project.
    They may
    consider
    future use of gray water if it becomes less expensive than other make-up supply sources.
    6 ,2.2
    Water C onservation O
    ptions
    limited
    and potentially
    very costly. . S&L provided some recoiniriendations in their study for conserving lake
    water,
    mostly by modifying the plant s= ;f°rns, but also by reviewing and improvi
    ional procedures and water rn )
    A i
    aher
    of
    i
    Thi
    1-1 ý
    s u-PL. i
    solid-,
    water to remove ash fines,
    rem(,, c, but it prori las signi
    ition,
    t he
    five options
    ort. The water balances are
    2 010-2025.
    it load factors for
    o
    r-can
    lower flows in Sugar Creek which is
    currently
    where the ash sluiicin-
    d isch, a .Ied from the clarification pond. In some small streams reduced flow in cý;o ý ýi ix
    drou dhf times of a year could be of concern to plants or animals living in or around
    the
    streziiný
    Try
    this study, we have assumed that
    the effect on the hydrology and the ecology
    o f Sugaý-1
    " i .iot significant as a result of the water conservation options di
    below.
    L ight & Power, Springfield, Illinois
    REV.
    1, January
    2005
    udyFeb 2005,doc
    6-T1
    B urns & McDonnell Engineering Co.
    Kansas City, Missouri
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    6.2.2.1 Option 1 (Base
    Case)
    - Use Lake Water for Make-up with
    Pre-treatment
    acted from
    the
    existing
    Dallman Units' cooling water
    e-treatment system on site. This option has no reduction on take
    w ill have the minimum cost among
    in this report, due to some impurities in
    handling
    systern
    make-up water.
    ids, it requires pre-treatment before it could be used as a
    some
    of the problems caused
    condenser tubes
    which has been known to cause corros
    alloys,
    higher-grade
    stainless
    steel
    is an alternative to pre-treatment of the make-up water.
    This alternative could save some money on capita-t cost, as well as operating and
    of
    the make-up water. However, it i, a
    r ,-ative approach to remove the problc i a
    r , ,r,-i
    the source rather than deal try
    :
    r ; ,
    i
    di it
    not save any
    lake eater, but requires the least amount o
    6.2.2.2 Option 2 - Use Gray Water for Make-up with Pre-treatment. Use Lake
    Water
    as Backup
    In
    this
    option, gray water from
    the city's San
    pre-treated and transferred to CWLP's plant site for make-up to the new unit,
    the cooling tuwers. S&L recommended
    using
    gray
    water as ash sluicing water. In
    uld be used as make-up water to the FGD
    for the new unit. Water used for service
    water and
    D ue to reliability issues associated with a 3 mile
    pil',either
    a large storage tank or a
    backup water source would be required. Because
    lc l c, water is available and less costly
    than a
    large storage
    tank,
    it
    i
    recommended th; ý `. ( e water be used as an ý: azergency
    backup for cooling tov,-"r r,i:,'::e-up in case gray w ii,.r supply is interruftc-`.
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Wafer Study
    Evaluation of Options
    A s discussed earlier, gray water is mare expensiv
    a f ltration.
    chlorination is also incl
    ich is clarification
    in
    a
    clarifier
    to remove suspended solids and some organic matters. Other treatment
    technologies,
    such as microfiltration or ultrafiltration,
    may be used in this application, but
    the
    clarifier
    equipment and O&M costs are expected to be less expens
    for cooling tower make-up, F'GD
    or ash sluicing
    water (for the Dallman
    sluicing water, it would eventually be discharged to Sugar
    line and pumps must be i
    to the Dallman
    Station. Gray water contains
    o blems such as fouling and corrosion, and thus pre.-
    this
    study,
    the pre-treatment
    method is assumed to be the
    ical growth in the transfer pipeline from
    the SW
    ischarges its treated
    effluent,
    thus
    the
    impact on the
    be an
    is ,.
    i,c.
    However, the 1
    in the ash pr
    ,;rd
    , -ill
    vr .,
    ,, ,tc_i.
    itneeds ý
    3rminedif Výi,
    is
    ; r
    P..
    Yvater on site couto c:_<<
    o r dem
    ) ý_ CIr,ýin::1
    as good as the take water in terms of water qua
    p owc 1. Plant maybe
    limited. The use of gray water is not recommen
    ý i i 1: ý t.+;11'5,
    b le.
    l .`
    ?a, 1(} cycles of cone c
    a was
    assumed
    in the cooling towers
    when
    Ice
    water is the make-up v; ater, but for this option only cycles is
    recommended. This
    results in higher quantities of blowdown. Cooling tower blowdown
    the FGD system as part of the total make-up water, but suffici
    ided for the F GD m ist eliminator because c ooling t ower b 1
    acceptable for this app
    C ity Water Light & Rower, Springfield, Illinois
    8-93
    Burns & McDvnr fncýiru ng co,
    Project 34829,
    REV.
    1,
    January 2005
    K r
    %r- ; r9
    CWLP Wafer Study Feb 2005.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    t
    t o the bri
    water is still of similar quality to that
    in
    Caption 1.
    T
    his
    design
    increases
    the quantity
    of wastewater to be treated by the brine concentrator
    and the spray dryer, which in turn increases the operating and maintenance cost of the
    plant.
    However,
    increasing the
    maximum design
    capacity
    (currently
    at 200 gpm) of the
    brine concentrator
    is not necessary because of this additional wastewater.
    This
    is because
    the average wastewater flow rate (15 l. gpm) for this option is below the maximum design
    I thkt it also re
    for the short
    time durations.
    However, the
    chance
    for all un
    extended time
    un at higher load
    ling tower bl-:o="dov.,n
    6.2.2.3 Option 3 - Dry Fly Ash Systems for All Existing D llman Units
    between
    ammonia r ad
    boron
    in fly ash wi
    Unit
    33 generates the most fly h due to its IBC ftirnace (as opposed to cyclones
    for Units
    31/32),
    and its projected lc:.ýd i_LJCT is much higher than Units 31/32. In addition, Unit
    33
    could utilize a shared silo v iih the new
    unit, which will be installed
    regardless
    of the
    fly ash transfer method of Unit 33. Converting only Unit 33 to dry fly ash is the most
    is pre-determined
    based on
    the system
    ler
    converting
    all Dallman Units
    to
    dry fly ash and converting only Uni
    concern with not converting Units 31/32 to dry systems is that there is still a potential
    if all fly ash is not removed.
    ing any fly ash to the pond is that during times when the SCR is in
    ipped from the SCR could be adsorbed by the fly ash, and then
    Therefore,
    3 is also an option to in iti
    discharge limit of
    c ost analysis included
    later in this report,
    e detail. The comparison between
    t int
    Cr
    i n,, a po:
    t he bor,_-n
    ,ii wlic
    the ash ponds,
    r
    (lie ash ponds could be analyzed as follov ;
    load factors, more cooling tourer blowdown to the FGD
    means
    less fresh
    . This makes the
    combined
    water quality worse than that of Option 1.
    McDonnell
    Kansas
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Lions
    The total existing fly ash water to the ash ponds, according
    to
    the
    S&L water
    balance, is about 1.13 1VIGD based on the average water balance for the
    concentrations
    of Dallman Units' fly ash slui
    Dallman Units. According to the Hanson study report,
    the avera.
    ppm, and
    41.1 ppm, re
    ed on the S&L and
    is in operation.
    uming an average of the three boron concentr
    about
    6 ppm, which is
    well below
    the discharge limit
    of I I ppm.
    pond would reduce the boron concentratio
    about 46 ppm, removin
    o nly the Dallman FGD blowdown wastewater be
    w unit is in service, the FGD wastewater
    from
    the
    new
    unit
    f boron), combined with that from
    ould potentially cause
    vio
    %ithout fly ash slu
    ash wi
    :, not so
    ?bined with a zero-di: :h_
    I:i}rnace
    design. Thus converting Unit 33 to dry fly ash
    eliminates
    t is current being sent to the ash ponds. It is also possible to share
    t
    he
    ash
    silo of
    the
    new unit
    with
    Unit 33 which makes converting Unit 33 to
    dry
    fly ash
    more economical. However, a concern with not converting Units 31/32 to dry systems is
    o n Closed-Loop Bottom Ash System (with mechanical
    istina ®allman Uni
    involves conve
    chanical dew
    bins, settlers or thi(';_ rrs). The supernate from th,._
    ciý: ,,Aý_iing
    equipment is rech
    as ash sluicing water in!' :ad of using the lake water. Th,:: system has unrecoverable
    Illinois
    6-95
    Burns & McDonnell E
    t 31/32
    Kansas C
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Wafer Study
    Evaluation
    of
    Options
    as chlorides and sulfates could also cause corrosion
    at elevated concentrations. Thus a
    blowdown would be required from the system, similar to
    the operati
    tower.
    Besides blowdown,
    water is also lost froth hopper seal water over
    blowdown from this closed-loop bottom ash system could typ
    ommon system.
    bins, where most
    of the
    a ter. The supernate overflows to the
    L ion.
    The final
    clarified
    water is collected in
    option. Both S&L and Hanson stated
    that the
    r emoval of bottom ash water
    from the ash pond discharge could cause the boron
    C urrent
    U,:
    ý: 33 bottom ash is a ;
    sý_
    ['--<ttuly. Due to the lack ,
    th
    remai
    : irrent
    available
    pond
    stoat
    According to CWLP a hi
    in Springfield potentially
    would be able
    to
    use about 50% of the ash
    t his does not happen, CWLP may also dredge the pond and dispose of
    the ash in a landfill. Thus it is assumed for this
    study that the
    ponds
    will have sufficient
    service life in future.
    6.2.2.5 Option 5
    ..
    Recycle of Ash Water Clarification Pond Effluent a Make-up to
    the New Unit
    lake water for the operations of the
    Dallman Units.
    1 icill : ý r c
    pt
    when
    the
    new uni
    gent t- i1 i> l~ GD systems as make-
    _.;r.__(,
    Lni_rator. Normally the
    to the new unit,
    li .1 quantity c -ake water is sa.v
    unit, rd
    ljhtr.
    .gyp 101
    - ;;321,;73'.
    -:
    1, ý_: ruary X 005
    r ter Study Fed 2005. doe
    This is because the
    bottom
    ash
    sluicin : water with
    ilution water to other w< t,
    blowdown.
    rind is thus a consumptive
    loss of
    aloe-up water
    of
    the
    new
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evacuation of Options
    Compared to gray water, ash sluicing water
    (using
    lake water)
    is
    However, pre-treatment would still be recommended due to the potentially
    ntly discontinued, and the plant becomes a
    and suspended solids, as well as some metals
    content, in
    the recycled ash water. Most of
    the
    recovered water from the clarification pond is from the Dallman unit's ash sluicing
    water.
    Thus Options 3 and 4 above, which
    will
    reduce ash sluicing water to the ash
    ponds,
    will in turn reduce the quantity of ash water that is available for recovery from the
    clarification pond. If neither of Options 3 & 4 are selected for actual implementation (all
    Dallman Units will still sluice
    both
    their fly ash and bottom ash to the ash ponds), the
    larification pond effluent water available for recovery
    ,ible way to achieve this is to ree
    on the water balance. The average
    total raw water requirement
    is
    about
    3 MG
    The pre-treatment of the lake water and the recovered ash water is very
    id be reused for other applications at the
    plant,
    then
    S uspended solids and certain metals are the primary concern. Thus, there only needs to
    bt one pre-treatment system that is shared between the lake water quad the recovered ash
    -ýn
    . In Of, 1,i
    .
    1, a clari er system was assumed as the pre-
    eýi.dlm}rrýtv,-ýu1d
    be
    able
    to
    pre
    tr
    he
    Dallman
    Units
    only when
    nt equipment. This
    1. Thus the pre-
    ii-
    means of tempor,
    Creek
    is i
    age while the Dallman Units
    are
    still
    in
    service.
    1. The
    make-up
    to the new unit. The lerz _ c1; f ti
    i ý_ý
    V,ud
    to
    be a base
    . In this mode of operation, for short periods the ash p,-, .d water quality could
    become worse due to the closed-loop content
    of the ti
    . Thus some lake water must still be consumed.
    a n e is possible, it aii
    ash
    ay
    still cause boron.
    ystems.
    As discuss
    pringfield, liiinois
    uary 2005
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    ash pond may not resolve the boron discha
    ion
    because the discharge of boron to Sugar Creep
    is
    permanently
    to dry systems, the boron level would
    be further reduced. This is assuming that there
    [ , :,i j
    c-n-,
    nrr t,_,i -
    Yin.ation. Accordingto
    e several vround water
    still be
    discharge
    to Sugar Creels from the ash ponds. If all ash pond effluent is recycled,
    then the
    cost of converting
    to dry
    fly
    ash systems
    e liminated.
    I n this option; and other water
    conservation o
    flow in
    Sugar Creels will have no adverse
    luent) for
    Existinq Daliman units
    supernate
    o f 6
    s hould be further
    investirated
    shou
    -Loop Ash Water
    Systems
    (Recirculatinc Ash Water Clarification
    n
    4 ab._, re. However, the cost
    llman Units
    According
    to S&L,, only L)allman Unit 33 is suitable for
    conversion to dry botto
    sting equipment and space limitations. However,
    the cost-benefit ratio of this
    be unfavorable (bottom ash is only a small por
    of
    this type
    6.2.2.8 Water Mnnageanient Options
    gn
    ( eject 54829,
    a list- Y'arious options
    to reduce lake
    rocedures
    of certain systems and equ
    C
    WLP
    Water
    Study Feb 2005,
    ý in.-to
    i s ili;ts Pwmp
    c ,tiiý-;ýiýcý1t
    to-18
    Sums
    &
    McDonnell
    Engineer,
    K ansas City, M issou
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    (1)
    recycle of
    collected
    and pump
    o w
    for
    being dis
    (in future). This
    ificant amount of water (only
    about 0.06 MGD based on the
    ater. In this op
    Units).
    wastewater discharged to the brine concentrator
    will
    snake
    the
    much smaller, and thus less costly to install and operate. The equ
    mmendations
    on
    nds. S&L agreed that
    a
    ly flowing to the ash
    ion
    node far
    11
    i
    nd the scope
    of
    thi:, rL i ý-rt. However, eliminating continuous sluice water flow to the ash ponds has
    implemeated to both conserve water and reduce power usage in ash slid
    shout
    significant capital expenditure. Factors such as system water
    (3) Use Lake Water fur Heat Exchangers. Currently many plant process equipment
    lading building HVAC) are cooled by potable water
    years.
    to lake water. However, some potable water users (users that require
    I
    c,: ý'
    b
    :
    %,* r)
    are
    connected
    to
    the
    same headers as the heat
    exchangers.
    The separatic u (f f I I «- , e
    potable water users from the rest of the system could be costly. Additionally, tube
    6_19
    B urn: & McDonnell Engi
    Kansas City,
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    s ystem
    was
    used. Also, the
    Ill inch, unless an
    o cal pre-chlorination a nd possible de-c hlorination ( required
    to meet
    6 .2.3 Water Usage
    average water balance flow r
    ch
    year
    from 2010 to 2025 were
    coons
    for each unit
    r total water usa
    the
    five water conservation
    rptions
    discussed in the section above. The table
    titled
    "Table 1 - Lake Water Us<<:rc l')r Each Water Conservation Option (2010-2025)"
    ,ti
    tched table in the appendices). The result ofthe
    in Section 7.
    Lake
    water usage for makeup water obtained
    on
    1, because
    the water
    stays the same independent 0- the options.
    r
    ,
    hake-ul -w,
    r
    ýýc
    because no lake
    moval equipment options, the installed equipment cost was either
    project
    was
    the net prr,, nt value of the various options was
    calculated
    for
    2010 - 2025
    The most
    v iable., op!
    L ight & Flower Springfield, Illinois
    R EV. t, January 2005
    <, ".i um ;
    -i1-
    ngineering C
    K insas City; Missouri
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water
    E valuation or" Options
    n d water or surface
    water (ash is impounded at Turris, but the impoundment
    ost economical
    s . Thus the
    B&McD estimates were used in this cost
    calculations of the boron removal options and
    the water
    the tables (Table 2 and Table 3) in the
    6.3.1 Boron-Removal
    Options Summary
    Among the options studied, O
    a nd reliability. This option
    s pray dryers. Compared to Opti
    concentrator/spray
    dryer), but O
    tlic redundant equipment design,
    r v
    nit
    (a total
    olid.
    waste gea, -r ..;:_ ' from
    0% brine concentrators followed
    by t, :o
    ' -1 is less costly ( 100' `
    li
    in option t, option, t' , ti i,..
    1-2 is the preferred
    vý:it: . ;;t certain
    options
    may be ditterent,
    or
    i - c(
    ,nmercial landfills, where
    the solids waste may
    J
    r?sive.
    may not be acceptable as a construction
    mater
    by I3&McD. S&L's
    report
    n I i trough the lowest
    cost option
    based on the net press j ýý
    _i
    I,ýd to finalize the
    df Il or back to Tunis Mine, there could also be concerns of leaching
    au, t-dringfie(d,
    1G`inots
    J anuei y 2005
    ?> 705.doc
    dfor O&M costs to implement
    6-21
    Burns & McD gar:
    1-,r,-5;1
    Ue 11111ch more
    tsa,w
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Evaluation of Options
    ions. Unless the demand for lake water becomes such that the City
    ificant
    capital on another source of fresh water, it is not
    i
    I
    i lie Dallrit,-Ia
    Units
    to dry
    fly systems is t1 -e,luction of aýh
    The e
    provided
    estimated
    i
    nfo
    1 iy
    l'Lýý
    C i{ýi
    iscussed water conservation options
    on existing systems
    cost
    of each option, both in terms of total net present value
    "Water Conservation Options"
    attached in the appendic(
    lake
    water without any water conservation options is the
    realized lake
    water
    cost
    of $0.79/1,000 gallons). and also
    ý.ý. 1:
    r'h b ; ýrc F
    .
    it
    fill
    ý-
    water,
    is
    presented
    based on the annualized
    11
    D
    .'1n1nii
    Ur;<i,
    anufacturer-
    ons was also
    d
    ` ill un.`'.
    conversion to dry fly ash, the conv
    reduced
    lake
    a r::i
    '
    t o most 01 0 1
    y additional space on the existing
    lannin2 for the new unit.
    p resent
    values
    of
    each
    option
    were also converted to
    ivalent lake water cost (ratio of the annualized total cost to
    lake water
    saved)
    was calculated for each
    option.
    Option 1
    has the lowest
    equ
    water cost at $0.79/1,000 gallons. The lowest equivalent lake water cost among the other
    options
    is Option 2 (gray water) at $1.39/1,000 gallons. Although the water cost for
    Option l. is less expensive than the potable water cost established
    by CWLP for the filter
    plant water ($1.5511,000 gallons); the treatment ir<<Allods r ,a similar. Therefore, the actual
    cost
    to produce the water using a new clari
    plant should 1 sirnilar. Because
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    water treatment capacity
    new unit's makeup demand, additional capital
    expenditure for
    d maintenance expense.
    ater treatment plant would also add
    The costs of the S&L propo
    calculated in the table. These op
    ings. It is recommended that a separate study be conducted
    after
    a final
    to optimize
    the operation of this system.
    ifying operatin
    i i _-r:, instead
    of
    pots
    demand, (
    01ý-
    mater
    and loc-:' iiýýrinat
    ,f,-f:
    tj`
    e
    i
    rlnafiej,i
    ry 2(3( --
    F eb 2005,doc
    6-23
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Study
    Conclusions and Recommendations
    7 .0 CONCLUSIONS AND RECOMMENDATIONS
    Boron lVlitigation at Ash Pond Discharge
    h andling water usage and water
    conservation
    by Hanson
    Engineers,
    C WI,P,
    and
    Sargent & Lundy were reviewed and
    analyzed. The study results indicated that the most significant source for baron
    was FGD
    wastewater, but fly ash also contributed a significant amount of boron to the plant
    discharge.
    Bottom ash boron contribution was determined to be limi
    two above. Therefore, the most effective option to resolve the boron d
    at the ash water ponds is to prevent the FGD wastewater from being discharged to
    the
    ponds.
    irte
    SO°%
    spray dryers, is the
    preferred
    boron mitigation option.
    this treatment option by itself would only reduce boron concentration in
    the
    discharge
    to Sugar Creek to less than the disch lr.ý:1 limit by a small margin, and the
    ,re base
    ý;,
    avý.iý'_
    l?,i
    c i,
    . ý,j
    ,;",ýf ,:!.ins
    of < `i(a;i
    ,.
    dnurnlaer
    of s,u
    cL,i.,r
    tl.;
    =
    f1(*,,:;
    option
    by it,--elf
    i-
    net suiocient to mitigate
    )6lems, then
    in the second phase, conversion of the fly ash to dry
    sion of only Unit 33 to dry fly ash is preferred
    design,
    provided that fly
    ds. In addition, Unit
    this modification more
    Lion pond could be recycled back to the plant at all times,
    is not necessary for the purpose of more certain boron
    actually
    a
    more
    economical solution
    than
    converting
    to dry fly
    s that this option might involve closed-loop
    ash
    of time
    when the new unit is in an outage. This
    possi
    grc,ttnd water quality, to become worse during these frees. Also, c,
    ý;ý ,
    <<ing to send fl4
    ash
    try
    the ash ponds may also be
    a
    concern for boron contamination "1 gi'ound water.
    these issues
    can be resolved, this option is not considered a vial: le option.
    ,
    ight & Power, Springfield, Illinois
    7-1
    Burns & McDonnell Lili?7 ,,,y L:o,
    2
    1,
    REV,
    1, January 2005
    Kansas city, Missouri
    Study Feb 2005.doc
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water
    Study
    Conclusions and Recommendations
    of economical to implement
    any
    lake water conserva
    ors, such as tine additional boron-removal
    1
    or recycling
    of clarification pond
    s in lake water conservation.
    This study has
    assumed
    that the water conservation options, which would
    result in reduced Su
    flow, will have no impact
    on
    the ecology in or around the creek.
    The ash ponds are believed to be
    approaching their useful life. However, currently
    there
    fficient information to determine if this is the case (CNVLP
    stated that there is a
    that the ash could
    be
    dredged
    and used
    for a highway project). Additionally,
    isposing of the dredged ash off
    site is always an option.
    Therefore the current recommendation to
    CVvLP is to keep at least the bottom ash
    its unchanged until an important
    factor has changed in future,
    toLI ccA of t1., diG ., `,`later conservation
    op ti
    4
    .o .r
    ;;.ii
    I
    wt
    t',
    III
    S
    ;,Ilir
    I
    'I
    i,1
    _
    ater
    A erafe
    t J:
    r
    :,',,^,
    ( A Tt'
    ;
    T
    ?i
    ;e
    x
    ". i I' i,
    r'
    4.on t
    k
    -
    fs
    Lake
    1`.
    I'
    3 D
    5 .53 MG0
    1 .,(
    ii'
    rv
    ($0.79;
    t,001=i-gal)
    , .
    L` A,. re-Ft.)
    ,
    1.-.,
    r
    r ,
    i :
    421,315,459
    1.47 MGD
    `, iI,
    J f ::-:L_- iýla
    ($1.39/1,000-gal)
    (26,'-,28 Acre-Ft.)
    0 , Itlon 3, Dry
    Fly -$19,463,737
    27,697 MG
    4.74 MGD
    Ash
    ($6.50/1,000-gal)
    (
    84,998 Acre-Ft.)
    Option 4, Closed- -$20,179,721
    24,178
    MG
    4.14 MGD
    L oop Bottom Ash
    ($3.83/1,000-gal)
    (74,199
    Acre-Ft.)
    O ption 5, Recycling
    -$10,705,1.14
    21,334 MG
    3.65
    MGD
    Clarification Pond ($1.50/1,000-gal)
    (65,473
    Acre-Ft.)
    ýororrical option.
    Again, this conclusion
    is based on the
    .,rý.1,
    (11.39/Million Gallons). Unle " this cost of lake,
    nc_ ý:A to expand or construct ono [ I L (J° I i : ý,i
    water
    lake,
    or
    stiff the cost for any
    of
    thu
    w4o,,)
    --nsý_:rvation
    options.
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    and
    Recommendations
    filter plant effluent, CWLP has indicated the existing filter
    plant has excess capacity and
    can
    produce
    water mare
    economically than a new water treatment plant designed to serve
    just the makeup requirements for the new plant.
    provided from
    the CWLP Filtration Plant be used as the pr
    ter. A final water balance is provided in the appendices of this rep
    following recommended moth
    1
    concentrators and spray dryers.
    that
    the Ash Pond water qual
    stem crould be added to allow recov,ýiT
    ur"it
    cn, ý l i n e tower. if the
    value of ww
    r conservation
    ýn` ý"A associated added or,
    i;and
    ringfield, Illinois
    ='
    Burn
    2005
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    APPENDICES
    f or/Spray Dryer F
    Flow Diagram
    0
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    1.443
    1 1ý.
    !,4M
    PRELIMINARY
    --------------
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    -a W?w
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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    PAC to Sugar Cit0 (R.yded to ukej
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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

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    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    PFD1- Example Brine Concentrator Flow Diagram - For Reference
    Only (Sheet 112)
    W IRIATE P UMP
    7D SPRAY ORM
    MFR
    7 D MIST
    EWKAT0R RASH
    F® TMK
    F ® PUMP
    N EAT DMANOEN (2)
    m nK w
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    ...
    SEED PUMP
    01S161A7E
    TANK
    ANi1FOAM
    ANTFOAY
    PUMP (2)
    SUPPLY
    7 0 SPRAY DRWR
    FFfD TANT
    SEED
    TANK
    STEAL
    (STARr
    C AUS710 SUPPLY
    A .II)
    0
    C
    s
    A
    1
    4
    R ESOURCES CONSERVATION
    COMPANY
    2
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    PFD1- Example Spray
    Dryer FLow Diagram - For Reference
    Only (Sheet 2/2)
    r x~W
    0
    4-PD-626
    D
    C
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    ý MMýwOw.ýýMM"
    s M 19
    P ROCESS FLOW DIAGRAM
    EVAPORATOR
    SYSTEM
    BURNS Ac MCDONNELL
    CITY OF SPRINGFIELD
    CUSTOM Cgmm
    NO.
    04-3733
    RESOURCES
    CONSERVATION
    COMPANY
    2
    B
    A
    1
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    PFD2 -
    Typical HERO Process Flow Diagram
    DIST / SLUR
    RY TO
    THERMAL
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    MaArstvm Conditions at 100°9 Lead
    Calo.LakeN
    r:
    Const -
    Opt-son
    SASE CASE- LAKE WATER, BRINE C -ENTRATORISPRAYDRYER
    Caic. La e" 03<..
    Unit Load Factor
    2018
    2019
    2020
    2021
    2022
    2023
    2024
    2025
    Total
    MGI
    r
    &9031
    r
    h1Gt r MGI
    ' MG r M,G r MGI r
    ti7 r
    MG
    866
    867
    1
    867
    OF ,:0:: 2 - GRAY WATER, BRINE CONCENTRATORISPRAY
    DRYE
    Ca!e. Lake Water Usage
    t1 Load F
    - LConsum
    tire, MGD j. 1 Cal,
    i
    2018
    2019_.._. 2020
    2021
    2022
    2023
    MGI
    203
    203
    203... 204
    204
    I 204
    2c74
    3.253
    334
    339
    341
    344
    346
    349
    351
    5.326
    537
    542
    545
    547
    550
    552_...._._. 555
    8,579
    O PTION 3-LA:*_<;ATER,DRY FLY ASH, BRINE COPN"=':.T=-.TO- SPRAYDRYER
    CaTc. Lake Water Usa2e
    L .:"-' ;td Factor
    2010 2011
    2012
    2013
    20
    __20
    .
    2017
    -
    "
    2019
    2020
    2021
    2022
    2023
    2024
    2025
    0
    Ao6
    1,741
    OPTION 4- CLOSED-LOOP BOTTOM ASH, BRINE CONCFNTRATORISPRAY DRYER
    Cale. Lake
    Water
    Usage
    Unit Lead Factor
    2010
    0 sti
    D
    0 1 901 1 90
    e69 1...._u69--F-S6 9
    869
    13 867
    891
    898
    904
    910
    13,8'!0
    1,760
    1,767 1 1,773
    1.779.
    27.897
    Total
    2017
    2018
    2019
    2020
    2021
    2022
    2023
    2024
    2025
    Total
    ýMGfyr
    IAGNr (..MGtyr MGiyr MGlvr
    MGtvr MGtvr tdG'vr t9Gtur
    tdf
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Figure
    1 - Total Water Usage
    by Option (2010-2015)
    L
    N
    R
    O
    N
    G
    O
    C
    C
    O
    I
    4,000-
    3,600-
    3 ,000-
    2,500-
    2 ,000-
    1 ,600-
    1 ,000-
    500-
    2008 2010 201.2
    2014 2016 2018 2020
    2022 2024 2026
    0
    -'*-Option 1 - Max. Load
    (Option 1- Avg.
    Load
    w;r-Option 2 - Avg. Load
    Option
    3
    - Avg. Load
    Option 4 -
    Avg. Load
    (Option 5 - Avg. Load
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Figure 2 - Water Usage By
    Option and Unit
    0 New Unit
    " Dallman
    31132133]
    O ption 1
    Option 1
    Option 2
    Option 3
    Option 4
    Option
    s
    Max. Load Avg. Load Avg. Load
    Avg. Load
    Avg.
    Load Avg. Load
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Figure
    3
    - Water Usage By Option and
    Unit (Combined)
    ti
    m
    O
    VE
    10.00
    9.00
    8.00
    7.00
    6.00
    5.00
    4.00
    3.00
    2 .00
    1 .00
    0.00
    M
    Dallman
    31/32/33
    ® New
    Unit
    O ption 1
    Option
    1
    Option 2
    Option
    3
    Option 4
    Option s
    Max. Load
    Avg.
    Load
    Avg. Load
    Avg. Load
    Avg.
    Load
    Avg. Load
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Cky
    Water ht & Power
    She water Conservation Stud
    T able 2 - Boron Removal
    Option
    s
    Based on 2010-2025 averse load
    factors
    option 1.1
    -6F- -1-2
    Option
    2
    Same
    As Opoon 1-2 crew
    orly one
    Spray Dryar Is Used (as backup).
    Dual-Train (50%) &1na Cancwtmtcrs
    1x100% LktleModa Sooner, followed by Normally
    BC waste Is Mead wall New
    Single Tmia Bdne Concentrator
    followed by Du*Tr&M (50%)
    Spray
    2x50% HERO faHowed by
    Unit and
    Delimit Unit 33 (Modified for this
    D escription
    i followed Sktglo Train S Dryer
    Drors
    1 x100%C
    d
    o ption on
    Ash
    Equipment
    Installed Cost
    6
    56,155,000
    $8
    W-120.000
    59 356000
    Emensive c ellitfuctlon and
    Extdmtive eonsbuM011
    and
    more exlensne construction and
    EMewtve cansbuctlon
    artd Ceilglllpted
    Comet
    and
    flab
    of O&M
    rafts
    complicated
    ations
    cam fed rations Quart Option 1
    operations, tut
    aim than Option 1
    Ekckid
    Consultation.
    KW
    2.37
    1181
    1,027
    600
    1.027
    Eiectdctgr Cost,
    2
    $208,8 0
    79,
    $87,51
    6178,887
    Natural sea Cordumplim MMSTUthf
    2.3
    3.996
    3.998
    0
    0
    N atural CasCosL
    Styr
    2
    $210,930
    $219630
    50
    so
    Chemicals C
    ChenticaisCasl,
    8
    550.000
    550
    $471.760
    $50,000
    SWrPMak Flow MGD
    0
    0
    0
    0
    3WfP Mak Cost, r
    2
    50
    $O
    SO
    SO
    SWfP Return Flow, MOD
    0
    0
    0
    0
    SWTPReturn Cast.
    2
    30
    S
    O
    S o
    $0
    Fiber Plant Flow Reduction, M
    1
    0
    0
    --
    00
    Mar
    Water Cost Se s,
    2
    $0
    --
    fig
    so
    $0
    Lake Water Wk Flow Reductlon MGD
    1
    0.18
    0.18
    0.16
    0.18
    Lake Water
    Cost SeviO
    s. &yr
    2
    Sol
    591
    $91
    Sot
    Number of Additional
    aters
    2
    2
    2
    2
    G boroost,
    2
    S16f1000
    $180.000
    5160,000
    5160.000
    Hazardous Sam Waste GenoraBOn Rate non
    0
    0
    0
    0
    tiuardeas Solid Waste
    al Cost
    2
    $0
    60
    50
    60
    Non" z SoBd yWSte Genenuon Rate, ton
    4
    6,729
    20
    13,441
    44,326
    Non-Ham Sand waste
    I Cost,
    2
    $144,714
    S148714
    5349,476
    $354,625
    Assume waste Ill sent back to a
    Assume
    waste Is son back to a
    Assume waste is seal bit to
    a
    Waste Die at Deaufpti0n
    easanefdal l
    andfill
    c om
    l landfill
    dommerdai
    unaM
    Assume waste is sent bark
    to cowl nine
    Annualized Ma ntoMnce Cost SNr
    a
    $50.000
    550,00(1
    $50000
    $70.000
    ToUI Anmtal renal Cost
    5825622
    $796.539
    $1 118,649
    6814,421
    Total NPV terms of total
    expenses
    5
    14,723,835)
    WE)
    (517.731,181
    577 009,40
    Differential In N1W Com red l0 9ase Case
    $1171111.2a
    61,220 630
    (S1
    296,84
    Total NPVIMGD of Less water Saved
    581,797,973
    ($91.725,336
    (598,5001
    (594,941.15
    R easons for Relectiop M 'on
    Z oo
    tes"
    1. Gke Water and Filter Plant Make-u Ftow
    Reduction is based on design flow rates and ecta eve
    2010-2426
    toad
    tactc ra,
    2. Cost items per CWLP
    unless othsnwise not operation is assumed 365
    days
    a of a nd th-in ae factor
    she".
    a
    based an the due<asa water balance
    -Eieddd
    - GkeWatertt.380dGPOtablewaterffanFilterPlantS1.55n00
    Gray Water SH0
    al
    Wastewater Discharge to sewer18.974M-800-
    t.
    - NaturalGas.SNMMBTUassumed
    -Gbwcost,SW,00 (assumed
    - Waste ds
    to coal m Bilk Non-H azardous waste
    to to
    S28Aon
    A
    _ _
    owed hazardous waste disposal to landfill, 596non.
    3. inferential consum ion between the new a toms and the exist
    stems.
    4. Ash oration U Weed on CWLP "Ash Handitn Water St u ,
    L1U2004 and
    assume
    16X moisture eomeM in MW p
    ed ash. A
    Sawme t6X moisture to a9 balled soilds waste.
    5. cost ana sis M baked an 16 ears
    Ice, S% doceunl rate for cant worth calculation, and 2%
    avers kdiad Assume So plant salvage vane.
    6. Vendor (nforaat'
    9AMCD
    esdaatas
    err
    assum
    7. Duakrain BC 50X is assumed to
    use 15%
    Iris
    e1
    than sin 84raIrk SC 100 6n the average due to lower emrlen
    of turned dawn operations of dro latter.
    Equipment
    Cost
    Dascri tions"
    All options: maxkrmm ta Cal ca r$ is assumed to 200
    A
    O
    0
    ions
    ions:
    1-1
    Dual
    1-2
    and
    forwardln
    3: acne concemrator
    m anal pWg
    and e
    at each of m
    e
    e t hree FOO
    .
    costs
    bktwdown
    were from IonksIRCC.
    n
    R
    Unit
    C
    31132
    stated
    Unit
    1
    33
    for ads
    Me row uldt)
    lion
    to
    the
    send
    mete
    water
    ale
    to
    errs
    the
    more
    boron
    UeatmanL
    ' than
    540
    non
    each,
    systems thus use 30% for
    WAStilcdon C ost
    .
    !=-
    2: dual- a self-cleanto sum ales 0,000 are used to
    berso90s.
    BlowdMM MUMS 15 asswned to Cinch a to the
    seal
    water
    em orthe vacuum Idler
    feed
    = 2.
    ktdudes one limelsoda softener, dual media Idlers, dual YWC non elsilan resin sartamr
    one ess0er ana idusmten and dual
    HERO wkh a0 su=ary eq ant.
    FWalial at FGD blawdown 5
    Ill nit pereasa - tin ioywa -
    are
    al
    Option
    3:
    Assume Unit 33 fly ash is converted to Dry on for the
    ase of n11ne concentrator
    wastewater
    . f of Una 33 d ash tom is based m 8872nD
    eatimatu.
    I
    C ost Comparison
    t
    2 11tV2op5
    Electronic Filing - Received, Clerk's Office, November 21, 2008
    * * * * * PC #1 * * * * *

    Water Light A Power
    a
    -
    te Water Conservation Stud
    Table 3 - Water Conservation O tions 2 010-2025
    Operating
    Conditions
    O tio 1
    2
    L ake
    Water Co
    -6
    mervalWa-CFdons
    pn
    en
    n31
    Option 3.2
    en4
    'on5
    11sa
    Otey W er (pre4r0etad u 81e
    '
    OPNon waft Closed-Loop Bolton Option
    t Reu6s of Clad
    Pdp
    Use
    Lake
    Water a Make-up
    to
    New SWi P} es Pdmmy Msk"P to New Option t whh Dry Fly Ash on A8 Cfelm 1
    with
    Dry
    Fly Ash en OnBman Ash on AO Oatlmen lkiq w8h
    E04ent as Makes-up Watano the New Unit
    OesUttption
    i
    UniLw8ltOnsRePmiroaktreM
    IMRýwiMLakeWNSaaaectup
    Dadrtranthdts
    lhdl33oNy
    MarJtaNeaiDewa(oky
    COO6tgTowem
    E "
    nt
    Installed Cost
    6
    $4500,000
    $9,572.625
    Pat 9m h
    iffi lt t
    51015
    56,700.000
    511,600,500
    ate
    56,071625
    en y t e most d cu o
    mm wd (olbake pipdne) and
    More dUIdl to co nWm (more
    More 614cu8 to caminKY (me
    More d TmN h cdmnact
    (rnon
    ReladvaN easy to coruinicl and
    operate (No separate treatment
    specs) and operate (mate
    process space) attd opaata (mm praeas Wee) and operate (mere process
    Cortsbuctadf and
    Si
    0r06M
    o
    plsetM
    uwnem
    uipmsot
    Relafely ea
    to consWd and operate
    Ele
    Com on
    El l
    S/ f
    --
    3
    2
    339865
    4 7W,T15
    1 2881
    137,673
    S2t,Be2
    817
    ecu
    s
    y
    36
    595
    540251
    52,6331
    $10,434
    $12,346
    '
    Coapulaa.
    PONMKI
    hypodaod4
    Cowlant,
    Polymer,
    hypoddode. Cwt Pdymar.
    hypomkx8e,
    tpWnL pullner, hypocMoma.
    Bularit
    polymer,
    CoVulard. Polymer,
    bypodt09 add
    Chemirak Consu an
    add, c anaf
    acid etus0l.
    add,
    eaustk
    add. Ca00fe
    end, maul.
    ,
    ,
    ratlstie
    $
    so
    Return
    Return
    C=4 W
    $
    so
    Plant
    Water cost
    $
    Water
    $
    R
    $$
    "an waste
    ate,
    S8
    S9
    SD
    Disposal
    $
    SC A46
    Assume
    waste from the
    gray
    water Assume waste is riot back to coal Assume wane
    is
    seat beck to cad Assume waste is seat back
    W coal
    Waste Disposal Desod
    .
    WA,
    a
    is
    seat to ash
    PwW
    treatment Is seo to landfill
    rains
    tram.
    mitre
    NIA, sled e (s sent to ash PWA
    Annualized
    Maintenance C
    520.000
    $40.000
    $38667
    558.667
    566,667
    535,000
    M aintenance De
    m
    G enets m NMduna
    General
    mahaanano
    General muntenence
    General
    malmmance
    General nbmkeunce
    Gvteral rmintenanee
    Total
    tin Cost
    T t l NPV i t
    f t t
    l
    5
    5426,808
    80
    St
    1 ,186
    391
    567 787
    682£;542
    5446401
    oa
    n erms o o a expenses]
    ($ ,930, 90)
    (S21.351,45
    18 4W 73
    (515.800.74
    17721)
    10.705 tt4
    Annualized Total Option Cost,
    E
    60,3481
    .051 048
    (51,875,181
    1.572,280)
    (St
    944,18
    5(.031,355
    uivalentLake Water Cost,$17,6BOgat
    50.78
    St.30
    58,50
    -
    5622
    53.83
    57 58
    Total NPVfMGD of Lake Water 5aWd
    R
    f R
    i
    i
    f
    WA
    53 980
    (3 24.M 7,542)
    (523,583,203
    ( 614, 517.7&51
    .
    ($5ý694ý _2 09)
    easons or eject on, o ( on
    Notes:
    1. Lake Water and Fliter Plant ll
    Row Reduction is baud on des
    n
    flow
    rata
    and
    red even a 20162025 load he tets. S&L
    ad Wad tatters for
    Daemon units are 73% 31132 and 76.8% 1133 .
    2. Cost items
    CWLP unless atrervdse noted o oration is assumed 24
    hear
    a do tines 365
    days
    a ear, and
    water and of
    based en above load lactars
    -Ekttrfe' S20(MW-h
    Lake
    Water 1.3911116 Po4blewater$omFiIlerWmr$1.mr a r3ra
    WaterSH,00
    Waslsww
    etosewer;0.87Y100
    al.
    -Labe,COSt 58000 leeward
    -Waste da eel to coat mine ;then. Non-haurdaus waste d
    al to
    landfill,
    A roved haxar
    oars
    waste
    d
    t o fend $0 ton.
    -AssurteSWTPwill ch
    S6.1N
    of firmy water tocovertreatmentcost notMdndedinotkvcutamns.
    3 Differential ele ' consmn ' between the new systems and the existing
    shdca um s Na attire vetoes re
    sat net ..wings b tba new s stem s. Option
    2
    tdresadekioWbrineeeoeeetrator
    c' seeaterbafance
    Ash dG MraNon Is based on CV" -Z" Hand n Water Stud xrt 2 and assume 1514
    maictur oontent W Mat disposed Belt. acne Contxntralarl y
    rwasta Is not cud
    calcinatio n.
    5, Cost ena sfs is based ee 15 is 2616202 service N( 5% discount rah fer
    rots
    calculat and
    3% avers lolls
    Assume So ant salve a
    vatua.
    4Se
    ent6Wnd Re
    A dl 2aa4,BigWesftmtm orassum one,
    7. Option 5 assumes that Win water
    abrtent is
    ahead ledtrded as a d of the new unit coo and it is shared with the raaovmed ash water.
    The ant of recovered water (s
    aft" subtradin emoktouinashponds.
    E
    ui
    am Cost Descd Noes:
    Option 1: Lake Water Pre4reabnent " Assume a denier si zed for 3000
    kGowed 2x788
    fRen
    ate used wish atelf
    stWr as
    cat
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