ML13162A352

Applicant'S Environmental Report Operating License Renewal Stage Braidwood Station, Units 1 and 2. Cover Through Appendix B

ML13162A352
Person / Time
Site:	Braidwood
Issue date:	05/31/2013
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
References
Download: ML13162A352 (350)

Text

Appendix B NPDES Permit Braidwood Station Environmental Report This Appendix contains a copy of Braidwood Station's Illinois National Pollutant Discharge Elimination System (NPDES) Permit IL0048321, which authorizes the discharge of wastewater to the Kankakee River and stipulates the conditions of the permit. Also attached are (1) the cover letter dated February 29, 2000 transmitting an application to the Illinois Environmental Protection Agency for renewal of the Braidwood Station NPDES permit, (2) correspondence to the Illinois Environmental Protection Agency dated July 10, 2002 and March 24, 2004 concerning an increase in the circulating water blowdown flow and (3) the application to the Illinois Environmental Protection Agency dated March 28, 2009 for a permit to install a river diffuser at Outfall 001.

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Braidwood Station Environmental Report Appendix B - NPDES Permit Byron and Braidwood Stations, Units 1 and 2 Page B-iii License Renewal Application Table of Contents Letter Page Braidwood Station Illinois Pollutant Discharge Elimination System Permit IL0048321 ............. B-1 Cover letter to the Illinois Environmental Protection Agency transmitting the application for renewal of the NPDES permit dated February 29, 2000 ........................... B-15 Correspondence to the Illinois Environmental Protection Agency dated July 10, 2002 and March 24, 2004 concerning an increase in the Circulating Water Blowdown Flow

.... B-20 Application to the Illinois Environmental Protection Agency dated October 28, 2009 requesting a permit to install a river diffuser at NPDES Permit IL0048321 Outfall 001 ............................... B-24

This Page Intentionally Left Blank State of Illinois ENVIXONMENTAL PROTECTION AGENCY M A. Gade, Director 217782-06 10 1021 North Grand Ave. East, Springfield, IL 62794-9276 August 28, 1997 Commonwealth Edison Company Post Office Box 767,35 FNW Chicago, Illinois 60690-0767 Re: Commonwealth Edison Company NPDES Permit No. iLC048321 Modification of NPDES Permit (After Public Notice)

Gentlemen: The Illinois Environmental Protection Agency has reviewed the request for modification of the above-referenced NPDES Permit and issued a public notice based on that request. The final decision of the Agency is to modify the Permit as follows: The monitoring frequency for oil and grease is being reduced from Ifweek to Ifmonth for Outfalls 001(a) and 001(c). Additional monitoring requirements are being added to Outfall 001, concerning the usage of bromine based biocides. The elimination of fecal coliform monitoring at Outfall 001(b) due to the facility being granted a year- round disinfection exemption in July, 1995. Enclosed is a copy of the modified Permit. You have the right to appeal this modification to the Illinois Pollution Control Board within a 35 day period following the modification date shown on the first page of the permit. Should you have any question or comments regarding the above, please contact Darin LeCrone of my staff. WrnfY/ Thomas G. McSwiggin.

P.E." V' Manager. Permit Section Division of Water Pollution Control

Attachment:

Modified Permit cc: Records Compliance Assurance Section Facility NIPC USEPA ~b EIVED ENVIRONMENTAL SERVICES DEPT. 1Y SEP 0 4 1997 PM ?I fi ?I~PIFI?I

! I?I 01 41 48 Q' NPDES Permit No. ILOW8321 Expiration Date: September 1,2000 Illinois Environmental Protection Agency Division of Water Pollution Control 1021 North Grand Avenue East Post Office Box 19276 Springfield, lllinois 62794-9276 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM Modlfied (NPDES) Permit Name and Address of Permittee:

Commonwealth Edison Company Post Office Box 767,35 FNW Chicago, lllinois 60690-0767 Discharge Number and Name: No. 001 Cooling Pond Blowdown Line No. 001(a) Wastewater Treatment Plant Effluent No. OOl(b) Sewage Treatment Plant Effluent No. 001(c) Radwaste Treatment System Effluent No. OOl(d) Demineralizer Regenerant Wastes No. 001 (e) Intake Screen Backwash No. 002 North Site Stormwater Runoff Basin No. 003 South Site Stormwater Runoff Basin No. 004 Switchyard Area Runoff Issue Date: August 24, 1995 Effective Date: September

1. 1995 Modification Date: August 28, 1997 Faali Name and Address: Commonwealth Edison Company Braidwood Nudear Power Station Rural Route #I, Box 84 Braceville, lllinois 60407 (Wd1 County) Receiving Waters: Kankakee River Mazon River In compliance with the provisions of the lllinois Environmental Protection Act, Subtitle C. Rules and Regulations of the lllinois Pollution Control Board, and the FWPCA the above-named permittee is hereby authorized to discharge at the above location to the above-named receiving stream in accordance with the standard conditions and attachments herein. Permittee is not authorized to discharge afIer the above expiration date. In order to receive authorization to discharge beyond the expiration date, the permittee shall submit the proper application as required by the lllinois Environmental Protection Agency (IEPA) not later than 180 days prior to the expiration date.

Oz/@& omas G. c wiggin, P.E. Manager. Permit Section v Division of Water Pollution Control Page 2 Modification Date: August 28. 1997 NPDES Permit No. lL0048321 Effluent Limitations and Monitoring LOAD LIMITS CONCENTRATION lbsldav LIMITS.man 30 DAY DAILY 30DAY DAILY SAMPLE SAMPLE PARAMETER AVG. MAX. AVG.

MAX. FREQUENCY TYPE 1. From the effective date of this permit until September 1.2000, the effluent of the following discharge(s) shall be monitored and limited at all times as follows:

Outfall(s):

001 Cooling Pond Blowdown Line' This discharge consists of: 1. Condenser cooling water

2. House service water 3. Essential service water 4. Demineralizer regenerant waste

5. Wastewater treatment plant effluent

6. Radwaste treatment system effluent 7. House service water strainer backwash 8. Essential service water strainer backwash 9. Sewage treatment plant effluent

10. Water treatment system filter backwashes

11. River intake screen backwash 12. Cooling pond intake screen backwash Flow PH See Special Condition No. 1 Temperature See Special Condition No. 3 Total Residual Chlorinen Total Residual Oxidant" Approximate Flow 11.31 MGD 1.3 MGD 1.3 MGD 0.028 MGD 0.079 MGD 0.032 MGD 0.03 MGD 0.017 MGD 0.017 MGD 0.03 MGD 0.1 12 MGD 0.4 MGD Daily Daily llMonth Continuous Grab Continuous Grabn Grab" 'See Special Condition No. 12 -See Special Condition No. 4 Page 3 Modification Date: August 28, 1997 NPDES Permil No. 1~0048321 Effluent Limitations and Monitoring LOAD LIMITS CONCENTRATION lbsldav I IMlTS mail 30 DAY DAILY 30 DAY DAILY SAMPLE SAMPLE PARAMETER AVG. MAX. AVG.

MAX. FREQUENCY TYPE 1. From the effective date of this permit until September 1,2000, the effluent of the following discharge(s) shall be monitored and limited at all times as follows: Outfall(s):

OOl(a) Wastewater Treatment Plant Effluent This discharge consists of:

Approximate flow 1. Turbine building fire and oil sump' 0.079 MGD

a. ~urbine building floor drain tank' i. Turbine building floor drain sumps ii. Essential service water drain sumps iii. Condensate pit sumps b. Turbine building equipment drain tank' c. Units 1 and 2 tendon tunnel sumps d. Auxiliary boiler blowdown e. Units 1 and 2 diesel fuel storage tank sumps f. Oil-water separator No.

1 effluent g. Secondary-Side Drain Water 2. Water treatment area floor and equipment drain sumps 3. Water treatment lime-softening darator blowdown 4. Wastewater treatment system sand filter backwash 5. Condensate polisher regenerant wastes (Altemate Route) 6. Demineralizer Regenerant Waste Drains (Altemate Route) Flow Total Suspended Solids lntermittent lntermittent 0.002 MGD Intermittent lntermittent Daily 24 Hour Total 15.0 30.0 1NVeek 24 Hour Composite Oil and Grease 15.0 20.0 llMonth Grab These wastestreams may be directed to the Radwaste Treatment System depending on the results of the process rad~ation monitors.

Page 4 NPDES Permit No. 1L0048321 Effluent Limitations and Monitoring Modification Date: August 28. 1997 LOAD LIMITS CONCENTRATlON lbsldav LIMITS man 30 DAY DAILY 30 DAY DAILY SAMPLE SAMPLE PARAMETER AVG. MAX. AVG.

MAX. FREQUENCY TYPE 1. From the effective date of this permit until September 1.2000, the effluent of the following discharge@)

shall be monitored and limited at all times as follows: Outfall(s):

001 (b) Sewage Treatment Plant Emuent" Approximate Flow 0.017 MGD (DMF 0.078 MGD) Flow PH See Special Condiiion No. 1 Total Suspended Solids 19.5 39.0 30.0 60.0 BOD, 19.5 39.0 30.0 60.0 Daily Continuous 1NVeek Grab 1Mleek 24 Hour Composite 1NVeek 24 Hour Composite Outfall(s):

001 (c) Radwaste Treatment System Effluent This discharge consists of: Approximate Flow: 0.032 MGD 1. Steam generator condensate blowdown 2. cooling jacket blowdown 3. Auxiliary building and turbine building floor drains Laundry waste treatment system drains Chemical and volume control system drains Boron recyde system blowdown Radwaste demineralizer regenerant wastes and filter backwash Reactor building floor and equipment drains Turbine building floor drain tank (Alternate Route) Turbine building fire and oil sump (Alternate Route) Turbine building equipment drain tank (Alternate Route) Evaporator wastewater Intermittent lntermittent lntermittent 0.001 MGD lntermittent lntermittent 0.002 MGD lntermittent lntermittent lntermittent lntermittent lntermittent Flow Daily Continuous Total Suspended Solids 15.0 30.0 lMIeek Discharge Tank Composite Oil and Grease 15.0 20.0 1lMonth Grab "Outfall No. OOl(b) Sewage Treatment Plant Effluent will normally be discharged to the Kankakee River via the cooling pond blowdown line. The existing outfall to the Mazon River will be maintained as an emergency backup. The permittee shall give notice to the Agency of any emergency dlscharge to the Mazon River. Applicable effluent limitations shall apply.

Page 5 Modification Date:

AuguW 28, 1997 NPDES Permit No. !LO048321 Effluent Limitations and Monitoring LOAD LIMITS CONCENTRATION lbsldav LIMITS man 30 DAY DAILY 30 DAY DAILY SAMPLE SAMPLE PARAMETER AVG. MAX. AVG. MAX. FREQUENCY TYPE 1. From the effective date of this permit unffl September 1,2000, the effluent of the following discharge(s) shall be monitored and limited at all times as follows: Outfall(s):

OOl(d) Demineralizer Regenerant Wastes This discharge consists of

1. Make-up demineralber regenerant waste" 2. Condensate polisher regenerate waste" 3. Regenerant chemical area drains

4. Portable Demineralizer Regenerant Wastes Flow Approximate Flow 0.028 MGD Total Suspended Solids 15.0 30.0 "This wastestream may be alternately routed to the wastewater treatment system. Outfall(s):

Wl(e) River Intake Screen Backwash Daily Continuous 1Mleek 8 Hour Composite There shall be no discharge of collected debris.

Page 6 Modification Date: August 28.1997 NPDES Permit No. lL0048321 Effluent Limitations and Monitoring LOAD LIMITS CONCENTRATION

_Ibs/dav - 30 DAY DAILY 30 DAY DAILY SAMPLE SAMPLE PARAMETER AVG. MAX. AVG. MAX. FREQUENCY TYPE

1. From the effective date of this permit until September 1.2000, the effluent of the following discharge(s) shall be monitored and limited at all times as follows: Outfall(s): 002 North Site Stormwater Runoff Basin This discharge consists of: Approximate Flow: 1. Parking lot runoff 2. Transformer area runoff 3. North station area runoff 4. Turbine building, auxiliary building and waste treatment building roof drains lntermittent Intenittent lntermittent lntermittent lntermittent See Special Condition No. 8 Outfall(s):

003 South Site Stormwater Runoff Basin Approximate Flow lntermittent See Speaal Condition No. 8 Ouffill(s):

004 Switchyard Area Runoff Approximate Flow lntermittent See Special Condition No. 8 Page 7 NPDES Permit No. lL0048321 Modification Date: August 28. 1997 -1. The pH shall be in the range 6.0 to 9.0. SPECIAL CONDITION

2. Samples taken in compliance with the efRuent monitoring requirements shall be taken at a point representative of the discharge, but prior to entry into the receiving stream. SPFClAl CONDITION Q. Discharge of wastewater from this facility must not alone or in combination with other sources cause the receiving stream to violate the following thermal limitations at the edge of the mixing zone which is defined by Section 302.21 1, Illinois Administration Code, Title 35, Chapter 1, Subtitle C, as amended: A Maximum temperature rise above natural temperature must not exceed 5OF (2.B0C). 0. Water temperature at representative lacations in the main river shall not exceed the maximum limits in the following table during more than one (1) percent of the hours in the 12-month period ending with any month. Moreover, at no time shall the water temperature at such locations exceed the maximum limits in the following table by more than 3'F (1.7%). (Main river temperatures are temperatures of those portions of the river essentially similar to and following the same thermal regime as the temperatures of the main flow of the river.) SPEClAl CONDITION

4. Chlorine or bromine may not be discharged from each unit's main cooling condensers for more than two hours per day. The reported mean concentration and maximum concentration of Total Residual Chlorine/Total Residual Oxidant (TRC/TRO) shall be based on a minimum of three grab samples taken at approximately five minute intervals at Outfall 001. The time samples were collected. the time and duration of oxidant dosing period plus the monthly average and daily maximum amount of oxidant applied shall be reported on the Discharge Monitoring Reports. The reported average concentration of TRCfrRO is the average of all values measured for a sampling event and the reported maximum concentration is the highest value measured for a single grab sample. Discharge Monitoring Reports shall indicate whether bromine and/or chlorine compounds were used during the month. A discharge limit, as measured at the blowdown to the Kankakee River, of 0.05 mgil (instantaneous maximum) shall be achieved for total residual oxidant (total residual chlorinenotal residual halogen) when bromine biocides are used for condenser biofouling control. SPEClAl CONDITION

& There shall be no discharge of polychlorinated biphenyl compounds.

SPFClAL CONDITION

& There shall be no discharge of wmplexed metal bearing wastestreams or associated rinses from chemical metal cleaning unless this permit has been modified to indude the new discharge.

A. Intake impacts will be reduced by limiting pumping from the river during the peak enirainment period. For a four-week period (last three weeks in May and first week in June), pumping will be allowed only during the day (between one hour after sunrise and one hour before sunset). In addition, during the four-week period, pumping will be minimized during the day. Pumping will occur when needed to fill the freshwater holding pond and to maintain efficient operation of the cooling pond. In an extreme emergency, and upon immediate notification of the Agency, pumping could occur at night.

Such pumping would cease as soon as the emergency was over. Records of all pumping during the four-week period will be maintained.

Such records will include dates, number of pumps operating and start and end times.

Page 8 Mod'ication Date: August 28.1997 NPDES Permit No.

110048321 Wal Cm . . SPECIAL CONDITION

8. STORM WATER POI LUTlON PREVENTlON PLAN (SWPPP1 A. A storm water pollution prevention plan shall be developed by the permittee for the storm water associated with industrial activity at this facility.

The plan shall identify potential sources of pollution which may be expected to affect the quality of storm water discharges associated with the industrial activity at the faality. In addition, the plan shall desaibe and ensure the implementation of practices which are to be used to reduce the pollutants in storm water discharges associated with industrial activity at the facility and to assure compliance with the terms and conditions of this permit. B. The plan shall be completed within 180 days of the effective date of this permit. Plans shall provide for compliance with the terms of the plan within 365 days of the effective date of this permit. The owner or operator of the facility shall make a copy of the plan available to the Agency at any reasonable time upon request. [Note: If the plan has already been developed and implemented, it shall be maintained in accordance with all requirements of this special condition.]

C. The permittee may be notiiied by the Agency at any time that the plan does not meet the requirements of this condition.

After such notification, the permittee shall make changes to the plan and shall submit a written dification that the requested changes have been made. Unless otherwise provided, the permittee shall have 30 days after such notification to make the changes. D. The discharger shall amend the plan whenever there is a change in construction, operation, or maintenance which may affect the discharge of significant quantities of pollutants to the waters of the State or if a facility inspection required by paragraph G of this condition indicates that an amendment is needed. The plan should also be amended if the discharger is in violation of any conditions of this permit, or has not achieved the general objective of controlling pollutants in storm water discharges.

Amendments to the plan shall be made within the shortest reasonable period of time, and shall be provided to the Agency for review upon request.

E. The plan shall provide a description of potential sources which may be expected to add significant quantities of pollutants to storm water discharges, or which may result in non-storm water discharges from storm water outfalls at the facility.

The plan shall include, at a minimum, the following items: 1 A topographic map extending onequarter mile beyond the properly boundaries of the facility, showing: the facility, surface water bodies, wells (induding injection wells), seepage pits, infiltration ponds, and the discharge points where the facility's storm water discharges to a municipal storm drain system or other water body. The requirements of this paragraph may be included on the site map if appropriate.

2. A site map showing: i. The storm water conveyance and discharge structures; ii. An outline of the storm water drainage areas for each storm water discharge point; iii. Paved areas and buildings; iv. Areas used for outdoor manufacturing, storage, or disposal of significant materials, induding activities that generate significant quantities of dust or particulates.

v. Location of existing storm water structural control measures (dikes, coverings. detention facilities, etc.): vi. Surface water locations andlor municipal storm drain locations vii. Areas of existing and potential soil erosion; vlii. Vehlde sewice areas; ix. Material loading, unloading, and access areas.

Page 9 Medication Date: August 28.1997 NPDES Permit No. lL0048321

3. A narrative description of the following:

i. The nature of the industrial activities conducted at the site, inc1uding.a description of significant materials that are treated. stored or disposed of in a manner to allow exposure to storm water; ii. Materials, equipment, and vehicle management practices employed to minimize contact of significant materials with storm water discharges; iii. Existing structural and non-structural control measures to reduce pollutants in storm water discharges; iv. Industrial storm water discharge treatment facilities:

v. Methods of onsite storage and disposal of significant materials;

4. A list of the types of pollutants that have a reasonable potential to be present in storm water discharges in significant quantities.

5. An estimate of the size of the facili in acres or square feet, and the percent of the faalii that has impervious areas such as pavement or buildings.

6. A summary of existing sampling data desaibing pollutants in storm water discharges.

F. The plan shall describe the storm water management conbpls which will be implemented by the facility.

The appropriate controls shall reflect identified existing and potential sources of pollutants at the facility.

The desaiption of the storm water management controls shall include: 1. Storm Water Pollution Prevention Penonnel - Identification by job titles of the individuals who are responsible for developing, implementing, and revising the plan.

2. Preventive Maintenance - Procedures for inspection and maintenance of storm water conveyance system devices such as oilhvater separators, catch basins, etc., and inspection and testing of plant equipment and systems that could fail and result in discharges of pollutants to storm water. 3. Good Housekeeping - Good housekeeping requires the maintenance of clean, orderly facility areas that discharge storm water. Material handling areas shall be inspected and cleaned to reduce the potential for pollutants to enter the storm water conveyance system.

4. Spill Prevention and Response - Identification of areas where significant materials can spill into or otherwise enter the storm water conveyance systems and their accompanying drainage points.

Specific material handling procedures, storage requirements, spill clean up equipment and procedures should be identified.

as appropriate. Internal notification procedures for spills of significant materials should be established.

5. Storm Water Management Practices - Storm water management practices are practices other than those which control the source of pollutants. They include measures such as installing oil and grit separators, diverting storm water into retention basins, etc. Based on assessment of the potential of various sources to contribute pollutants, measures to remove pollutants from storm water discharge shall be implemented.

In developing the plan, the following management practices shall be considered:

i. Containment - Storage within berms or other secondary containment devices to prevent leaks and spills from entering storm water ~noff; ii. Oil & Grease Separation - Oilhater separators, booms, skimmers or other methods to minimize oil contaminated storm water discharges; iii. Debris & Sediment Control - Screens, booms, sediment ponds or other methods to reduce debris and sediment in storm water discharges; Page 10 Modification Date: August 28.1997 NPDES Permit No. 110048321 S~eaal ~ndmnfi . . iv. Waste Chemical Disposal -Waste chemicals such as antifreeze, degreasers and used oils shall be recycled or disposed of in an approved manner and in a way which prevents them from entering storm water discharges.

v. Storm Water Diversion - Storm water diversion away from materials manufacturing, storage and other areas of potential storm water contamination; vi. Cwered Storage or Manufacturing Areas - Covered fueling operations, materials manufacturing and storage areas to prevent contact with storm water. 6. Sediment and Erosion Prevention -The plan shall identify areas which due to topography, activities, or other factors, have a high potential for significant soil erosion and describe measures to limit erosi~n. 7. Employee Training - Employee training programs.shall inform personnel at all levels of responsibility of the components and goals of the storm water pollution control plan. Training should address topics such as spill response, good housekeeping and material management practices. The plan shall identify periodic dates for such training.

8, Inspection Procedures - Qualified plant personnel shall be identified to inspect designated equipment and plant areas. A tracking or follow-up procedure shall be used to ensure appropriate respanse has been taken in response to an inspection. Inspections and maintenance activities shall be documented and recorded.

G. The permittee shall conduct an annual fadlii inspection to verify that all elements of the plan, including the site map. potential pollutant sources, and structural and non-structural controls to reduce pollutants in industrial storm water discharges are accurate.

Observations that require a response and the appropriate response to the observation shall be retained as part of the plan. Records documenting significant obsewations made during the site inspection shall be submitted to the Agency in accordance with the reporting requirements of this permit. H. This plan should briefly describe the appropriate elements of other program requirements, induding Spill Prevention Control and Countermeasures (SPCC) plans required under Section 31 1 of the CWA and the regulations promulgated thereunder, and Best Management Programs under 40 CFR 125.100. I. The plan is considered a report that shall be available to the public under Section 308@) of the CWA. The permmee may daim portions of the plan as confidential business information, induding any portion describing faality security measures.

J. The plan shall indude the signature and tile ofthe penon responsible for preparation of the plan and indude the date of initial preparation and each amendment thereto.

K. The faalii shall submit an annual inspection report to the Illinois Environmental Protection Agency. The report shall include results of the annual faality inspedion which is required by Part G of the Storm Water Pollution Prevention Plan of this permit. The report shall also include documentation of any event (spill, treatment unit malfunction, etc.) which would require an inspection, results of the inspection, and any subsequent corrective maintenance activity. The report shall be completed and signed by the authorized facility employee(s) who conducted the inspection(s).

L. The first report shall contain information gathered during the one year time period beginning with the effective date of coverage under this permit and shall be submitted no later than 60 days after this one year period has expired. Each subsequent report shall contain the previous year's information and shall be submitted no later than one year after the previous year's report was due. M. Annual inspection reports shall be mailed to the following address:

Page 11 NPDES Permit No. lL00.48321 SrJecial cJmdmDs . . Modification Date: August 28. 1997 Illinois Environmental Protection Agency Division of Water Pollution Control Compliance Assurance Section Annual Inspection Report 1021 North Grand Avenue East P.O. Box 19276 Springfield, Illinois 62794-9276 N. If the facility performs inspections more frequently than required by this permit, the results shall be included as additional information in the annual report.

SpFCI-. Discharge of station cooling pond water to adjacent impoundments owned by the permittee, to replace water which is withdrawn from these impoundments for station operations during periods of low flows in the Kankakee River when the station must decouple its operations frbm the river, is hereby dermitted for these emergency periods. No monitoring is required for this permitted activity.

The IEPA shall be promptly notified during such operations.

SPFCIAI -ON 1Q. The permittee shall record monitoring results on Discharge Monitoring Report Forms using one such form for each discharge each month. The completed Discharge Monitoring Report forms shall be submitted to IEPA no later than the 28th of the following month, unless otherwise specified by the the permitting authority.

Discharge Monitoring Reports shall be mailed to the IEPA at the following address: Illinois Environmental Protection Agency Division of Water Pollution Control 1021 North Grand Avenue East Springfield, Illinois 62706 Attention: Compliance Assurance Section SpFClAI CONDITION

11. The 'upset' defense provisions of Tile 40, Section 122.41(n) of the Federal Regulations are hereby incorporated into this permit by reference.

WCIAI CONQITION I2 An emergency cooling pond overflow exists tributary to an unnamed drainage ditch which is tributary to the Mazon River. Discharges from this overRow shall be subject to the bypass provisions of 40 CFR 122.41(m).

--ITION 13, The permittee shall submit a completed Form 2F as soon as conditions allow, for Outfall 002 and Outfall 003. Based on the new information the Agency may choose to modify the permit afler public notice and opportunity for hearing. SPEClACCONDITlON

14. For Discharge No. 001(b), any use of chbrine to control slime growths, odors or as an operational control, etc. shall not exceed the limit of 0.05 rngn (daily maximum) total residual chlorine in the effluent.

Sampling is required on a daily grab basis during the chlorination process. Reporting shall be submitted on the (DMR's) on a monthly basis. -I CONDm~. Flow shall be reported as a daily maximum and a monthly average. and shall be reported in Million Gallons per Day.

Page 12 AWm w d r~a d k SYY Ya LM bYIY -rrmh .P- POl- -PI- m UI# m Y -1. *LC .I YL YL.C - -..I. or r- #In rr uwr .r..r Page 13 01 CIJ.wnm lor a# WMelmma duck rwre -.gnu 01 nu- rW ale n rrolr - yk* "11-r~ bl m - ~h wml 011 lkCImmW*k~~W~?Cmr(l.t~-~~*Ir

-. m-. 0 CroC- r* mr, r rr ah- rmc-I - .-rrl *@ b. rrnM I.I k pmd .kl om- rrrrnV .-* 1. nnr* ml r- I* II.C- .kl. - *-o.r hnnk(h.kr&m-..wSlncmmr-- ,h .m--rm hm md-* Irrn mrk c r~.Lllr I C U February 29,2000 CERTIFIED MAIL Mr. Thomas G. McSwiggin, P. E. Manager, Permit Section Water Pollution Control, Permit Section #15 Illinois Environmental Protection Agency 1 02 1 North Grand Avenue East P.O. Box 19276 Springfield, Illinois 62794-9276

Subject:

Renewal of NPDES Permit No. IL0048321 Braidwood Nuclear Generating Station

Dear Mr. McSwiggin:

Commonwealth Edison Company hereby submits two copies of Consolidated Permit Application Forms 1 and 2C for the renewal of the subject permit.

As confirmed by your letter dated July 24, 1997, the only Form 2C, Part V-A pollutants reported are those required by the station's existing NPDES permit, and no analytical data is presented for outfalls 001(e) - Intake Screen Backwash, 002 -North Site Stormwater Runoff Basin, 003 - South Site Stormwater Runoff Basin, and 004 - Switchyard Area Runoff. Additionally, pollutants categorized as GC/MS Fraction Compounds in Part V-C are not reported for any outfalls, as per your letter received on February 4, 1998. Pollutant levels for all permit-required parameters were derived fiom station data reported fiom June 1998 through May 1999. In most cases, only one analysis was conducted for all other pollutant data. All color analyses were performed as "true" (i.e., the samples were centrihged prior to analysis).

Mass load values were calculated using long term averase flows. Form 2C, Part IIB requires descriptions of wastewater treatment processes.

In addition to this requirement, we are listing the water treatment additives that have the potential of being discharged by way of various outfalls.

Material Safety Data Sheets (MSDS) have been enclosed where available.

Outfall OO1-r~C-o-oling-Pond Blowdown, receives no treatment as wastewater, however, the circulating water and service water systems are treated for scale inhibition, silt dispersion, corrosion inhibition and biofouling control as follows:

Mr. Thomas G. McSwiggin, P. E. February 29,2000 Page 2 of 3 DeposiTrol BL5400, a liquid acidic scale inhibitor consisting of 60% 1- Hydroxyethylidene-1, 1-DiPhosphonic Acid (HEDP), is applied to the cooling systems at a concentration of approximately 10 to 65 parts per billion (ppb) as product to minimize the risk of calcium carbonate scale formation. Either DeposiTrol PY5203, a 50% active blend of polyacrylic acid (PAA), or Dianodic DN2300, a 30% active blend of the polyacrylic acid based copolymer HPS-I, is applied to the service water systems to aid in silt dispersion.

FloGard POT6102, a polyphosphate corrosion inhibitor containing 35% sodium hexametaphosphate, is applied to the service water systems to inhibit corrosion.

Lastly, the circulating water and service water systems are treated with sodium hypochlorite and sodium bromide for biofouling control.

Outfall 001(a) - Wastewater Treatment Plant Emuent, may be treated with cationic and anionic polymers to aid coagulation~flocculation.

There also exists a slight possibility that a small amount of nitrite may be discharged fiom outfall 001(a) when the station's closed cycle bearing cooling water system is drained for service. This system is treated with 400 mg/L nitrite, but occurrences of release are expected to be very rare.

In the past, the system's 5000 gallon holding tank has discharged, at most, once per year. Due to the fkct that this system discharges into outfall 001(c) and that nitrites degrade rapidly under aerobic conditions, we believe that the environmental impact of such a discharge is minimal. OutfalI OOl(b) - Sewage Treatment Plant Effluent, may be treated with sodium bicarbonate for pH adjustment and carbonate addition during the treatment process. Outfall 001 (d) - Demineralizer Regenerant Wastes, consists of excess sulfiric acid, excess caustic, and rinse water used to regenerate the ion exchange the ion exchange resin beds that supply ultra-pure water required by the generating process. Additionally, please note that the station utilizes a portable demineralizer system to supplement demineralized water make-up. This portable system utilizes reverse osmosis (RO), electrodialysis reversal (EDR), and ultra-filtration (UF) technologies. Reject from the EDR and UF systems are recycled. Reject from the RO unit combines with regenerant wastes from the demineralizer system and is discharged via outfall 001(d). In addition to the chemicals listed above, secondary-side steam water (non-radioactive) containing hydrazine is discharged to the Kankakee River via Outfall 001 during unit outages. These outages typically result in the semi-annual discharge of about 200,000 gallons of a 100 mgll hydrazine solution. This solution is discharged to the cooling pond at approximately 55 GPM via the station's wastewater treatment plant - Outfall 001 a, result ins in a maximum possible hydrazine concentration of 2.7 ug/l in the cooling pond blowdown (Outfall 001). PIease note that this concentration is overly conservative as no dilution from other sources is considered; hydrazine readily undergoes a degradation reaction to ammonia in the presence of oxygen; and this discharge must travel the entire length of the cooling pond prior to reaching the blowdown point (approximately 4.5 days travel time).

Also, the station has the ability to utilize Nalco Elimin-Ox, a carbohydrazide-based product, in place of hydrazine to lay up the steam generators during unit outages.

Mr. Thomas G. McSwiggin, P. E. February 29,2000 Page 3 of 3 Lastly, no chemical treatment is applied to outfall 001(e) - Intake Screen Backwash.

Agency guidance relative to previous NPDES permit applications for CornEd nuclear generating stations indicated a need to provide additional detail on the contributing wastestreams for each outfall. As such, we request that the new permit be amended to reflect that the following systems discharge via outfall 001 (a) - Wastewater Treatment Plant Effluent:

Under 1. Turbine building fire and oil sump; please add: h. Miscellaneous non-contaminated auxiliary building drains Should you have any questions, or require additional information, please call Kevin K. Hersey at (630) 663-3094.

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IL 60407-9619 Tel. 815-458-2801 CERTIFIED MAIL July 10, 2002 Bw1020067 Mr. Darin LeCrone Industrial Unit, Permit Section Illinois Environmental Protection Agency Water Pollution Control, Permit Section

1. 15 1021 North Grand Avenue East P.O. Box 10276 Springfield, Illinois 62794-9276

Dear Mr. LeCrone:

The purpose of this letter is to outline a proposal to increase Cooling Pond Blowdown flow, NPDES Outfall 001, to approximately 30,000 gallons per minute (gpm) from the present blowdown flow of approximately 15,000gpm at the Exelon Braidwood Nuclear Generating Station. The Cooling Pond Blowdown flow has been limited in the past due to inherent design deficiencies related to low circulating water system pressure. The low circulating water system pressure prevents the blowdown flow from reaching designed flowrates assumed in the original plant design.

Installation of a booster pump(s) will allow the station to achieve a higher rate of blowdown resulting in better pond chemistry and lower pH for the Cooling Pond Blowdown, NPDES Outfall 001. Calculations show that the BTU input to the Kankakee River, as a result of this increase, will remain within the NPDES Permit discharge limits.

We believe that no NPDES permit modification is necessary for the increase in flow in the Cooling Pond Blowdown to the Kankakee River. No Illinois water quality standard will be exceeded and no adverse environmental consequence will result from this increase.

We are requesting Agency review and approval to implement design changes to achieve the desired blowdown flowrate.

Should you have any questions or require further information to process this request. please contact Brent Schramer.

Chemistry Manager at (815) 417-3200.

Respectfully, CERTIFIED MAIL March 24,2004 BW040032 Mr. A1 Keller Manager, Industrial Unit, Permit Section Illinois Environmental Protection Agency Division of Water Pollution Control 1021 North Grand Avenue East P.O. Box 19276 Springfield, Illinois 62794-9276

Subject:

Braidwood Station (NPDES Permit No. 110048321)

Circulating Water Blowdown Flow Increase

Dear Mr. Keller:

On July 10,2002, in a letter sent to Darin LeCrone, we informed the Illinois Environmental Protection Agency (IEPA) of Braidwood Nuclear Generating Station's need to increase the blowdown flow rate from the Braidwood cooling pond to the Kankakee River. The purpose of the letter was to notii IEPA that the planned change in operations would increase the blowdown flow rate above the original design rate for the cooling pond. In the letter to Mr. LeCrone, we also informed the Agency that the planned flow rate increase would not cause any exceedences of discharge limits specified in the NPDES Permit, nor would it cause or contribute to any violations of water quality standards in the Kankakee River. The Braidwood Station has yet to implement the planned flow rate increase.

As we explain below, as each day passes the need to increase the flow rate becomes more imperative, both for operational and environmental reasons. This letter also explains that there are no regulatory or legal impediments to allowing the plant to increase the flow rate as planned, without any further delay. Background The Braidwood Station cooling pond is a closed cycle cooling system. To make up for evaporative losses from the cooling pond and maintain suitable water chemistry in the pond, it is necessary to provide make-up water to the pond from the Kankakee River and to discharge (i.e. blow down) water from the pond back to the Kankakee River. The design blowdown flow rate for the cooling pond (to maintain optimal water chemistry) is about 21,000 gallons per minute (gprn). The Station's NPDES permit does not establish a maximum blowdown rate from the pond. Rather, the permit lists approximate flow rates for various internal waste streams that contribute to the blowdown discharge.

From about the time the Station came on line in 1987 until September 2003, the Station had not been able to achieve the 21,000 gpm design blow down flow rate on a consistent basis. AS a result, the wncentration~

of constituents in the cooling pond and pH levels in the pond have increased over time, above the levels that were expected based on design blowdown flow rates. As the concentrations of chemical constituents in the cooling water used by the Station have increased, the plant's operating efficiency has decreased correspondingly, due principally to scaling that occurs on piping systems that reduces the heat exchange capabilities of the systems. is important to note that, even though the concentrations of constituents in the cooling pond and blowdown water have increased beyond those that were expected based on assumed design blowdown flow rates, the concentrations remain at or below the numeric water quality standards for those constituents.

Thus, blowdown discharges to the Kankakee River, after allowance for mixing, are well within the applicable water quality standards for the River. everth he less, unless and until the blowdown flow rate is increased, constituent concentrations in the cooling pond will continue to increase, as will the concentrations of constituents that are discharged to the Kankakee River. The discussion below, Cooling pond Chemistry, contains specifics regarding constituent concentrations in the cooling pond. Circulating Water Blowdown Booster Pump Installation TO address the concerns related to the increased concentrations of chemical constituents and high pH levels, the Station installed booster pumps that would allow the Station to discharge at a fate between 25,000 to 30,000 gpm to the Kankakee River. The Station plans to operate the pumps at higher flow rates to lower the concentrations of constituents in the pond to optimal levels. These concentrations in the water discharged from the cooling pond to the Kankakee River will remain within the applicable water quality standards.

The mass loading of constituents discharged from the pond will not exceed any mass load limits included in the NPDES Permit at the higher flow rates. Environmental Considerations Further delaying the Station's plans to discharge at the higher average flow rate would be environmentally counterproductive.

As previously stated, the concentrations of constituents in the cooling pond will continue to increase as long as the Station continues to operate as it presently does. Constituent concentrations in the blowdown will begin decreasing almost immediately after the Station begins discharging at higher flow rates. In addition, as pH levels in the cooling pond decrease (following the blowdown flow rate increase) the Station will ultimately be able to reduce the amount of sulfuric acid it is required to add to the pond to control PH, thereby reducing associated environmental concems.

Use of other treatment chemicals will also be reduced over time. There are no environmental benefits achieved as a result of delay.

Regulatory Considerations Given that the N PDES Permit does not prescribe a maximum blowdown flow rate, and in view of the fact that the Station is not proposing to discharge water from the pond at concentrations that would cause exceedences of water quality standards or exceed the load limits set forth in the Permit, there is no need to modify the NPDES Permit before the Station begins discharging at the higher flow rate. Antidegradation review requirements are triggered by "any proposed increase in pollutant loading that necessitates a new, renewed or modified NPDES Permit ... ". The increased discharge flow rate does not require that the permit be modified; thus, an antidegradation review related to the planned blowdown flow rate increase is not rWuired. Cooling Pond Chemistry As you requested, attached is a Table that sets forth the current values of constituent concentrations in the cooling pond and the calculated stabilized values that will be achieved following operations at the higher blowdown rate. As previously stated, the concentration of constituents in the cooling pond are currently sufficiently low so as not to present any risk that either water quality standards applicable to the Kankakee River or that the load limits set forth in the Station's NPDES Permit will be exceeded as a result of increasing the average blowdown flow rate. Due to the significant operational and environmental factors described above, and consistent with the above regulatory considerations, Exelon is prepared to implement the increased blowdown flow rate as soon as possible.

Please contact Joe Tidmore at (815) 417-2299 if you would like any additional information or if you have any Comment regarding the above. Respectfully, Keith J: Polson Plant Manager Braidwood Generating Station Attachment Mostardi Platt 1520 Kensington Road, Suite 204 Oak Brook. Illinois 60523-2139 Phone 630-993-2100 Fa 630-993-9017 www.mostardiplattenv.com October 28,2009 Mr. Darin LeCrone P.E. Acting Unit Manager, Permits Section Illinois Environmental Protection Agency I 02 1 North Grand Avenue East Springfield, IL. 62794 RE: Exelon Nuclear Braidwood Generating Station, NPDES Permit No. IL0048321 USACE Project LRC-2008-340

Dear Mr. LeCrone:

As a foliow-up to our meeting on August 13,2009, MOSTARDI PLATT ENVIRONMENTAL (MPE) has prepared the attached application for a construction permit to instaIl a river diffuser at Outfall 001. Two (2) copies are being submitted--one original and one duplicate copy. The design details are based on information previously provided to the US Army Corps of Engineers (USACE). An electronic copy of that application is included as Appendix E to the attached application.

The information attached to this letter includes a completed IEPA Application for Permit or Construction Approval, form WPC-PS-1, with all necessary certifications and approvals provided.

As discussed with your department, no application fees are associated with the planned changes to the existing NPDES permitted outfall since the source is already subject to operating fees. The USACE had issued a project number for the Exelon River Diffiser project during the original meetings that took place in 2008 (LRC-2008-340).

In 2009, when the application was submitted, another project number was inadvertently issued (LRC-2009-269).

To eliminate confusion, the USACE has deleted the 2009 project number and is now using LRC-2008-340.

Illinois Environmental Protection Agency .. October 28,2009 Page 2 Sllould you have any questions or require Mer information, please contact me at 630-993- 2127. Respect filly submitted:

MOSTARDI PLATT ENVIRONMENTAL Joseph J. Macak III Principal Consultant

~nclosur&:

1 original, 1 copy cc: Ms. Kate Bliss, U.S. Army Corps of Engineers Mr. Joseph Macak III, Mostardi Platt Environmental Mr. Raymond Hall, Exelon Nuclear Mr. Dominic Jmburgia, Exelon Nuclear Mr. Bryan Risley, Exelon Nuclear

Mostardi Platt APPLICATION FOR A CONSTRUCTION PERMIT FOR THE INSTALLATION OF A RlVER DIFFUSER AT OUTFALL 001 Prepared For EXELONNUCLEAR For The Braidwood Generating Station 35100 South Route 53 Braceviiie, Illinois 60407 IEPA NPDES Permit No. IL0048321 September 1,2009 Q Copyright 2009 All rights reserved in Mostardi Plat? Environmentai 1520 Kensington Road, Suite 204 Oak Brook, Illinois 60523-2139 Phone 630-993-21 00 F% 630-993-901 7 www.rnostardiplanenv.com MPE PROJECT M0825 1 3 TABLE OF CONTENTS Section Page INTRODUCTION

.................................................................................................................................................................

1 . . .................................................................

...............................................................

1.0 Proposed River Diffuser Project : 1 . , 2.0 Project Team ...............................................................................................................................................................

2 2.1 Braidwood Station Plant Manager .............................................................................................................................

2 ............................................................................................................................

3.2 Braidwood Station Project Manager 3 ............................................................................................................................................

2.3 Environmental Consultant 3 ...................................................................................................................................................

3.0 Outfa11 001 Locations 4 APPENDICES Appendix A - IEPA Application for Permit or Construction Approval WPC-PS-I (Application Form) Appendix B - IEPA NPDES Permit Modification Request (as submitted in US Army Corps of Engineers Application) Appendix C - Outfall Location Calculation Appendix D - Engineering Drawings (as submitted in US Army Corps of Engineers Application)

Appendix E - "Application for an Individual Permit for a River Diffiser" (as submitted May 8,2009 to US Army Corps of Engineers Application)

Mostardi PIatt a1 ~6- y- APPLICATION FOR A CONSTRUCTION PERMIT FOR THE INSTALLATION OF A RIVER DIFFUSER AT OUTFALL 001 . , Prepared For EXELON NUCLEAR For The Braidwood Generating Stntion 35100 South Route 53 Braceville, Illinois 60407 IEPA NPDES Permit No. IL0048321 September 1,2009 1520 Kensington Road. Suite 204 Oak Brook, Illinois 60523-2139 Phone 630-993-21 00 Fax 630-993-901 7 www.mostardiplattenv.com INTRODUCTION The Braidwood Generating Station (Braidwood) is a nominal 2,362 MW base load generating facility located in Will County, IIlinois, approximately 20 miles south of Joliet, Illinois (see Figure 1). The facility, which serves northeastern Illinois, consists of two Westinghouse pressurized water reactors.

Unit 1 began operation on July 2, 1987, and Unit 2 began operation on May 5, 1988. Commercial operation began in May and October, 1988,'respectively.

The license expiration date is October 17,2026 for Unit I, and December 18,2027 for Unit 2. Braidwood is owned by Exelon Corporation, and operated by one of its business units-Exelon Nuclear. Braidwood is built on a 4,457-acre site, and its 2,537 acre cooling pond was formed from scarred farming land and an old strip mine. Figure 2 is an aerial photograph of the Braidwood site, showing the actual site, the cooling pond, and the Kankakee River intake and discharge locations.

1.0 PROPOSED RIVER DIFFUSER PROJECT By this submittal the facility is requesting that a construction permit be issued for the installation of a river difiser to be located at Exelon's Effluent Outfall 001. The difiser will be designed as specified in the "Application for an Individual Permit for a River Diffiser" submitted to the US Army Corps of Engineers (USACE) on May 8,2009. This Illinois Environmental Protection Agency (IEPA) permit application is provided to address the details associated with the proposed installation of a river difhser in the Kankakee River. This project will provide significant environmental benefits over the existing river outfaII. It is also proposed that the existing outfall will remain in service only as a back-up to the diffuser.

MPE Pmjcct No. M0825 13 1 Exelon Nuclear Elmidwood Storion This application includes the WPC-PS-1 form, all of the appropriate certifications as required by the IEPA WPC-PS-I form, copies of design documents as provided to the USACE, and an electronic copy of the may 8,2009 USACE application.

Figure 1. Braidwood Station Location Map. 2.0 PROJECT TEAM 2.1 BRAIDWOOD STATION PLANT MANAGER The authorized site representative is: Mr. Lawrence Coyle Plant Manager Braidwood Station - Exelon Nuclear 35 100 S. Route 53 Braceville, IL 60407 Phone: (8 1 5) 4 1 7-3700 Email: Lawrence.covle(~exeloncorp.com MPE Project No. M082513 2 Exelon Nuclear Braidwood Station 2.2 BRAIDWOOD STATION PROJECT MANAGER The Braidwood Station project manager for the proposed river diffuser is: Mr. Bryan Risley Project Manager Braidwood Station - Exelon Nuclear 35 100 S. Route 53 Braceville, IL 60407 Phone: (8 15) 4 17-4009 Ernail: brvan.rislev~ii),exeloncorp.com 2.3 ENVIRONMENTAL CONSULTANT The environmental permitting consultant lead professional in charge of this application is: Mr. Joseph J. Macak I11 Principal Consultant Mostardi Platt Environmental 1520 Kensington Road - Suite 204 Oak Brook, IL 60523 Phone: (630) 993-2127 Email: jmacak(llmostardiplattenv.com Figure 2. Braidwood Station Aerial Photograph (April 2005). MPE Project No. M0825 13 3 Exelon Nuclear Braidwood Station 3.0 OUTFALL 001 LOCATIONS The distance from the planned location of the river diffuser outfall compared to the existing 001 outfall is within 0 degrees, 0 minutes, and 15 seconds in distance.

Appendix C provides a calculation of this proposed changed.

The locations of the two (2) outfalls are provided in the following table. MPE Project No. M0825 13 4 Exelon Nuclear Braidwood Station Appendix A IEPA Application for Permit or Construction Approval WPC-PS-1 Illinois Environmental Protection Agency Permit Section, Division of Water Pollution Control P.O. Box 19276 Springfield, Illinois 62794-9276 For IEPA Use: r Application for Permit or Construction Approval WPC-PS-1 1. Owner Name: Braidwood Nuclear Power Station Name of Project: Installation of Braidwood Station Proposed River Diffuser Township:

Wilmington County: Will 2. Brief Description of Project: Install a new 7-port diffuser system at Outfall 001. Diffuser discharge would be below surface in the Kankakee River. The river diffuser would be fitted with Tideflex diffuser values; prevent backflow, intrusion of sediment or aquatic life, and enhance the hydraulic performance of the diffuser.

No changes to existing Outfall 001 - back-up. 3. Documents Being Submitted:

If the Project involves any of the items listed below, submit the corresponding schedule, and check the appropriate boxes.

Schedule Private Sewer ConnectionIExtension Spray Irrigation Sewer Extension Construct Only

'IB C 1 Septic Tanks Sewage Treatment Works D Industrial TreatmentIPretreatment Excess Flow Treatment E Waste Characteristics Lift StationIForce Main F Erosion Control Fast Track Service Connection FTP Trust Disclosure Sludge Disposal GO Schedule I Ha J CI NO PO TO Plans: Title "Application for an Individual Permit for a River Diffuser", dated May 8, 2009. Binder provided to IEPA, several hunderds of pages, with appendices.

No. of Pages: NA Specifications:

Title Appendix C - River Diffuser Modeling Study - HydroQual Report Appendix D - Engineering Drawings No. of ~ooksl~a~es: N A Other Documents: (Please Specify) 3.1 Illinois Historic Preservation Agency approval letter:

Yes ONO 4. Land Trust: Is the project identified in item number 1 herein, for which a permit is requested, to be constructed on land which is the subject of a trust? Yes No If yes, Schedule T (Trust Disclosure) must be completed and item number 7.1 .I must be signed by a beneficiary, trustee or trust officer.

5. This is an Application for (Check Appropriate Line):

A. Joint Construction and Operating Permit B. Authorization to Construct (See Instructions) NPDES Permit No. ILOO 48321 C. Construct Only Permit (Does Not Include Operations)

D. Operate Only Permit (Does Not Include Construction)

8. Certifications and Approvak 6.1 Certiffcate by Design Engineer (When required: refer to instntdhjns)

I hereby certify that I am familiar with the.inforrnation contained in this application, including the attached schedules indicated above, and that to the best of my knowledge and belief such information is true, complete and accurate.

The plans and specifications (speciffcatlons other than Standard Specifications or local specifications on file with this Agency) as described above were prepared by me or under my direction.

-. Engineer N~S Dinesh C. Patel - Certification letter attached dated 10lI12009 Registration Number: see (3Tmm- Firm: Sargent & Lundy, UC ~dd- 55 East Monroe Street I I City: Chicago State IL zip: 60603 Phone No: (312) 269-2033 SlgnatureX

"" see attached certification letter

~~t~: ---------------

7. Certifications and AppmaIs for Permits: 7.1 Certificate by Applicant(s)

IMle hereby certffy that Mwe have read and thoroughly understand the conditions and requirements of this Application, and amlare authorired to sign this applica~on in accordance with the Rules and Regulations of the Illinois PoUdon Control Board. We hereby agree to conform with the Standard Conditions and with any other Special Conditions made part of Ulis Permit. 7.1.1 Name of Applfcant for Permit to Construct:

Braidwood Generating Station Address: 351 00 Swttr Route 53 City: Braceville State: IL Zip Code: 60407 Signature X Date: Printed Name: Lawrema M. Coy19 Phone No: (815) 417-3700 Title: Plant Manager Organization:

Exefon Generation Company 7.1 2 Name of Applicant for Permit to Own and Operate: Braidwood Generating Station Address: 35100 South Route 53 Ci Braceville State: IL ap Code: 60407 Date: rnk.;/p Phone No: (815) 41 7-3700 Title: Plant Manager w 7.2 Attested (Required When Applicant is a Unit of Government)

Signature X Date: Title: NA (City Clerk, Village Clerk, Sanitary District Clerk, Etc.) 7.3 Applications from non-governmental applicants which are not signed by the owner, must be signed by a principal executive officer of at least the level of vice president, or a duly authorized representative.

7.4 Certificate By Intermediate Sewer Owner I hereby certify that (Please check one):

1. The sewers to which this project will be tributary have adequate reserve capacity to transport the wastewater that will be added by this project without causing a violation of the environmental Protection Act or Subtitle C. Chapter I, or 2. The Illinois Pollution Control Board, in PCB dated granted a variance from Subtitle C, Chapter I to allow construction of facilities that are the subject of this application.

Name and location of sewer system to which this project will be tributary:

Sewer System Owner: Address: City: State: Zip Code: Signature X Date: Printed Name: Phone No: Title: 7.4.1 Additional Certificate By Intermediate Sewer Owner I hereby certify that (Please check one): 1. The sewers to which this project will be tributary have adequate reserve capacity to transport the wastewater that will be added by this project without causing a violation of the environmental Protection Act or Subtitle C. Chapter I, or 2. The Illinois Pollution control Board, in PCB dated granted a variance from Subtitle C, Chapter I to allow construction facilities that are the subject of this application.

a 3. Not applicable Name and location of sewer system to which this project will be tributary: N A Sewer System Owner: Address: City: State: Zip Code:

Signature X Date:

Printed Name: Phone No: Title: 7.5 Certificate By Waste Treatment Works Owner I hereby certify that (Please check one):

1. The waste treatment plant to which this project will be tributary has adequate reserve capacity to treat the wastewater that will be added by this project without causing a violation of the Environmental Protection Act or Subtitle C, Chapter I, or [72. The Illinois Pollution Control Board, in PCB dated granted a variance from Subtitle C, Chapter I to allow construction and operation of the facilities that are the subject of this application.

03. Not applicable I also certify that, if applicable, the industrial waste discharges described in the application are capable of being treated by the treatment works. Name of Waste Treatment Works: NA Waste Treatment Works Owner: Address: City: State: Zip Code: Signature X Date: Printed Name: Phone No: Title: Please return completed form to the following address: Illinois Environmental Protection Agency Permit Section, Division of Water Pollution Control P.O. Box 19276 Springfield, lllinois 62794-9276 This Agency is authorized to require this information under lllinois Revised Statues, 1979, Chapter 11 1 %, Section 1039. Disclosure of this information is required under that Section. Failure to do so may prevent this form from being processed and could result in your application being denied.

This form has been approved by the Forms Management Center.

IL 532-0010 WPC 150 Sargent & Lundy lLC October 7,2009 Project No. 1 1329-1 24 S&L Ltr. No. 2009-BRW-194 Exelon Nuclear Braidwood Station - Units 1 and 2 Design Engineer Certification Regarding Application for Construction Permit from Illinois Environmental Project Agency (IEPA) for the Braidwood River Diffuser Installation Mr. B. Risley Exelon Nuclear Braidwood Station 35100 S. Route 53 Bracevilfe, Illinois 60407-961 9

Dear Mr. Risley:

At your request In support of the construction permit application to the IEPA for "installation of a River Diffuser at Outfali 001" being prepared by Mostardi Platt Environmental, we are providing this letter to certify that Sargent & Lundy LLC (S&L) is the consulting engineer contracted by Exelon to prepare the design documentation required to implement the river diffuser installation.

Sargent & Lundy prepared a conceptual deslgn of the river diffuser installation for Exelon, which included Detail A, Detail 1, Sections B-B, C-C, 0-D, E-E, H-H and J-J shown on sketches in Appendbc D of the permit application.

Sargent & Lundy is currently preparing the detail design documentation which will be used for installation of the river diffuser described in the permit application. S&L will complete the detail design documentation by December 31,2009. I hereby certify that I am familiar with the conceptual design documentation described above contained in Appendix D of the construction permit application. The detailed design documentation is being prepared under my direction.

Firm Sargent & Lundy LLC Address 55 E. Monroe Street City, Station, Zip Code Chicago, Illinois 60603 Telephone No. 31 2-269-2625 55 East MMlme Slreet '* Chicago, it 60603-5780 USA 312-26!b2000 Mr. 8. Risley Exelon Nuclear October 7,2009 Project No. I 13281 24 S&L Ltr. No. 2009-BRW-194 If you need any additional assistance in preparation of the construction permit application, please contact me or Mr. M. J. Krueger at 630-821-7365. Yours very truly, D. C. Patel Senior Manager DCP:MJK:iwm Original:

J. Macak - Mostardi Platt Copies: 6. Risley - Exelon T. J. Behringer M. J. Krueger SNL~C\DATA~UW~WROG\~~~~Q-~~~W.O~M~BRW~

94.00C Appendix B IEPA NPDES Permit Modification Request (Dated May 8,2009)

,.elon Cenerat~on Company. LLC ~vww.exeloncorp.com Eraidwood Station 35100 South Route 53. Suite Sq Braceville, lL 60407-gG1g Nuclear May 8,2009 Bw090044 Illinois Environmental Protection Agency Division of Water Pollution Control Permit Section

1. 15 1021 Grand Ave. PO Box 19276 Springfield, 11 62794-9276

Subject:

Braidwood Nuclear Power Station, NPDES Permit No. IL 0048321 The purpose of this correspondence is to notify the Illinois Environmental Protection Agency (IEPA) of a planned upgrade to Outfall No. 001 Cooling Pond Blowdown Line. Braidwood Nuclear Power Station (Braidwood) is currently undergoing permitting through the U.S. Army Corps of Engineers (USACE) to obtain an Individual Permit for the installation of a multi-port river diffuser in the Kankakee River. The IEPA will be receiving a complete apy of that application when it is filed. Modeling of the river diffuser using CORMIX demonstrates that there are environmental benefits to use of the diffuser over the existing above ground outfall. An excerpt copy of the modeling report performed by HyrdoQual can be found in Appendix A. The multi-port river diffuser will be installed parallel to the existing Outfall No. 001, and monitoring and sampling will be performed upstream of the tie-in to the blowdown line. Figure 1 illustrates the new river diffuser, and Figure 2 shows the changes to the NPDES water flow diagram. Braidwood is not requesting any change to the discharge limitations in the current NPDES Permit No. IL 0048321. However, we request written authorization to utilize the proposed multi-port river diiser as the main outfall location, while retaining the ability to use the existing outfall as a backup to the river diffuser. The river diffuser permit application will be filed with USACE in May, 2009, and the system should be operational by December, 2010. Until that time, the current above ground outfall (see Figures 3 and 4) will remain in operation. Both the river diffuser and the above ground outfall will continue to be called Outfall No. 001 in the permit. Should you have any questions, please contact Raymond Hall at (815) 417-3203.

JLM& Lawrence M. Coyle h Plant Manager Braidwood Generating Statio u Figure 1. Braidwood Station Proposed River Diffuser, NPDES Outfall No. 001.

Figure 3. Existing Braidwood Station River Outfall Pipes. Figure 4. Existing Braidwood Station River Outfall Canal, View from River.

Appendix A HydroQual Modeling Study Thermal Impact and Mixing Zone Analysis May 4,2009

~nvlro~ment~l Engineers

& Scientists PRIVILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Bryan L. Risley Project Manager Braidwood Station Exelon Nuclear Rural Route #I, Box 84 Braceville, IL 60407 Re: Thermal Impact and Mixing Zone Analysis

Dear Brian:

The following letter summarizes our efforts in regards to assessing the thermal impacts and developing a mixing zone for the Exelon Braidwood facility discharge (existing and proposed) to the Kankakee River. Currently, the Exelon Braidwood Nuclear Station discharges heated blowdown water to the Kankakee River through a surface, side bank discharge canal.

The facilities heated cooling water is first discharged to a cooling lake near the facility that allows opportunity for atmospheric cooling before being reused for cooling water. The blowdown water from the cooling lake that is discharged to the Kankakee River is needed to maintain proper constituent levels in the cooling lake. ~akeu~ intake water to balance the blowdown water is-withdrawn from the Kankakee River about 0.1 miles upstream from the discharge canal. The following sections present the study objective, relevant regulations, background information, procedure and analysis.

Objective The goal of this study was to gather, compile and analyze river and effluent data for use in assessing the thermal impact of the Braidwood discharge in the Kankakee River and to determine the size of a thermal mixing zone that is required to be in compliances with ILEPA regulations under critical river and discharge conditions on a monthly basis. Mixing Zone and Temperature Regulations Section 302.102 of Title 35, subtitle C, chapter I, part 302, subpart A, states the regulations pertaining to the allowed mixing, mixing zones and zones of initial dilution (ZIDs). The full citation is contained in Attachment

1. Section 302.100 of the same subpart defines the mixing zone as "a HYDROQUAL, INC. 1200 ~LWARTHUR BLVD., JMAHWAH, NEVVJERSEY 07430 T: 201-529-5151 F: 201-529-5728 W1XIW.H\T)ROQLfi.COhl Bryan L. Risley May 4,2009 PRIVILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 2 portion of the waters of the State identified as a region within which mixing is allowed pursuant to Section 302.102(d)" and the ZID as "a portion of a mixing zone, identified pursuant to Section 302.102(e) of this Part, within which acute toxicity standards need not be met". Some of the mixing zone limitations and requirements are as follows: 1. Mixing is not allowed in waters which include a tributary stream;

2. Mixing is not allowed in waters adjacent to bathing beaches, bank fishing areas, boat ramps, dockages or other public access areas; 3. Mixing is not allowed in waters containing mussel beds, endangered species habitat, fish spawning areas, areas of important aquatic life habitat, or any other natural features vital to the well being of aquatic life in such a manner that the maintenance of aquatic life in the body of water as a whole would be adversely affected;

4. Mixing is not allowed in waters which contain intake structures;

5. &fixing must allow for a zone of passage; 6. The area and volume in which mixing occurs must not contain more than 25% of the cross- sectional area of volume of flow; 7. No mixing is allowed where the water quality standards for the constituent in question is already violated; and

8. The area and volume in which mixing occurs must be as small as is practicable under the limitations prescribed and in no circumstance may the mixing encompass a surface area larger than 26 acres. Section 302.211 of Title 35, subtitle C, chapter I, part 302, subpart A states the water quality standards for temperature.

The full citation is contained in Attachment

2. These temperature criteria apply to all months of the year and limit the amount of heat rise above background river temperatures and also the maximum temperature levels in the river. The applicable temperature regulations for the Braidwood facility discharge are as follows: 1. Normal daily and seasonal temperature fluctuations which existed before the addition of heat shall be maintained;

2. The maximum temperature rise above natural temperatures shall not exceed 2.8OC (S°F); and 3. The water temperature at representative locations in the main river shall not exceed the maximum limits (see below) during more than 1 percent of the hours in the 12-month period ending with any month. Moreover, at no time shall the water temperature at such locations exceed maximum limits

@eIow) by more than 1.7OC (3OF); a. Maximum limits between December-March:

16OC (60'9; and b. Maximum limits between April-November:

32OC (90°F). The maximum temperature rise and maximum temperature limits will be assessed at the edge of the thermal mixing zone developed for this analysis.

Habitat Survey (Unionids - Mussels) In order to comply with the regulations, both habitat surveys and thermal dilution modeling of the Kankakee River were conducted near the Braidwood nuclear station discharge canal. The area near the proposed diffuser location was surveyed by HDR Engineering Inc.

in 2008 (HDR, 2008') to determine the state-listed species of fish and fresh-water mussels in the Kankakee River near the HYDROQUAL, INC. 1200 ~IACARTHUR BLVD., MAHWAH, NEW JERSEY 07430 201-529-5151 F: 201-529-5728

\WW.HYDROQUAL.COM Bryan L. Risley hlay 4,2009 PRIVILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 3 discharge canal. This study was followed by another detailed survey by Ecological Specialists, Inc. (ESI, 2008~) to study the mussels within the potential impact area of the proposed diffuser location.

Figure 1 presents the resnlts of the ESI survey, which showed diverse but low-density mussel populations within the near-field region of the proposed discharge location (transects 2 and 3, about 50 meters downstream).

The maximum number of live mussels in transects 2 and 3, within 50 meters from the proposed diffuser, was 5 with an average number of about 1. The following paragraph from the ESI 2008 Unionid Study summarizes the findings. "illthough the survey area harbors a relatively species-rich unionid community, unionid density is relatively low and no recruitment was observed.

The low abundance of unionids may be due to the general lack of suitable substrate.

By and large, substrate throughout the site appeared stable but did not contain much area with finer particles (i.e., sand and gravel) into which the unionids can burrow. Also of note, no juven.de unionids were observed suggesting little or no recruitment occurring within the survey area. Therefore, it is likely a denser, stable, and reproducing unionid community upstream, probably in a riffle habitat, seeds the study area. However, Illinois listed unionid species were present, and therefore impacts to unionids by construction and operation of the diffuser within the area should be minimized." Thermal Dilution Modeling Previously, near-field and far-field dilution analyses were performed (HydroQual, 20073 in order to determine discharge alternatives that improve mixing and dilution of the Braidwood facility discharge in the Kankakee River. Based on this study, the following three discharge scenarios in addition to the existing shoreline discharge were chosen for further thermal impact analysis: Submerged 3-port diffuser; Submerged 5-port diffuser; and Submerged 7-port diffuser.

The above scenarios were designed as submerged, multi-port diffusers placed perpendicular to the main river flow in the deeper eastern side of the river. Table 1 presents the diffuser design details. Table 1. Diffuser Design Details # of Ports The USEPA supported CORMIX (Version 4.2GT) initial dilution model (Jirka et al, 1996") was used to calculate the near-field mixing and dilution of the Braidwood facility discharge to the river. The 7 HYDROQUAI,, INC. 1200 AL~CAR~CR BLVD., MAHW.AH, NEW J~~S~k'07430 T: 201-529-5151 F: 201-529-5728 w%w.H\DRCX)ChL.c.o>f Port Dia. (in) Note: Main discharge line to the river diffuser is a 30-inch diameter pipe.

a - Based on dtscharge flow rate of 19,000 gpm 12 Port Velocity (m/s)a 2.3 Port Spacing (m) Diffiser Length (m) 3.3 - 20 Bryan L. Risley May 4,2009 PFUVILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 4 CORMIX initial dilution model can analyze mixing and dilution associated with discharges from surface or submerged diffusers due to both jet and buoyancy momentum in addition to ambient mixing. The CORMIX initial dilution model package contains three different CORMIX programs to analyze submerged single- and multi-port diffusers (CORMIXI and CORMIX2, respectively) and surface discharges (CORMIX3).

Since the CORMIX model can only represent an idealized cross- section of the river, the resulting calculations are typically only valid in the near-field.

The near-field is generally limited to the area where the river cross-section is similar or roughly within 100-500 meters downstream from the discharge.

Based on the previous analysis and information gathered, various CORMIX inputs such as the Manning's

'n' of 0.03, river geometry and outfall characterisctics were developed. Information from the USGS stations in the river also provided limited information on depth, width and velocity variation as a function of flow. This variation was built into the modeling analyses. Figure 2 presents river depth transects in the river along with the model grid. The cross-sections near the discharge were used to develop river geometry information for the near-field analyses.

In addition to the above, CORMIX requires the river flow, discharge flow rate, ambient temperature, discharge temperature, and discharge temperature rise above ambient to be specified.

The thermal analysis was performed on a monthly basis in order to incorporate the seasonal variability in river flow and ambient and discharge temperatures.

In order to be conservative, low river flow, maximum discharge temperatures, and minimum river (intake) temperatures were used. In order to estimate the ambient and discharge temperature, upstream river flow and temperature, effluent discharge flow and temperature from all months of the year were analyzed. This data is compiled in an EXCEL file that is included as Attachment

3. Model'Input Development Daily effluent flow, intake and discharge temperature from 2005-2008 were obtained from Exelon when available.

The data are presented in Figure 3 with the discharge flow in the top panel, intake temperature (green line) in the middle panel and the discharge temperature (blue line) in the bottom panel. The intake and discharge temperatures were limited to the months of April to September in 2005, 2006 and 2008, so additional data was analyzed to develop the model discharge inputs.

Historical river temperature data (1966-2001) from the upstream USGS station at Momence (#05520500) were used to define the intake temperatures during the missing months. For this analysis, the historical minimum monthly river temperature for the months when river intake temperatures were unavailable from Exelon was used.

The minimum monthly temperatures are shown by the black circles in the middle panel of Figure 3. This figure also presents the intake temperature at the cooling lake (red solid line) in the bottom panel along with the blowdown temperature in the discharge canal to the Kankakee River. Discharge (blowdown) temperature at the river discharge was unavailable for October through March and, therefore, additional data were analyzed to develop the model inputs. Intake temperature at the cooling lake (red line) was used since it was very similar to the discharge temperature (blue line) when the data overlapped. Based on these data, the minimum monthly intake and maximum monthly discharge temperatures were developed for model inputs. Although this may not represent actual conditions because of the similarity between the cooling lake and river temperature dynamics, it was analyzed to represent a worst case condition for the thermal assessment. The bottom panel in Figure 3 also presents the temperature rise (grey line) in 2006 and 2008. Figure 3 also highlights that the discharge temperature HYDROQUAL, INC. 1200 hL4WTHLX BLVD., hh1iWA4H, NEW JERSEY 07430 T: 201-529-5151 F: 201-529-5728 WWV.H\'DROQUALCOM Bvan L. Risley May 4,2009 PRlVILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 5 follows the natural river temperature (intake data), which suggests that no abnormal temperature changes will occur and that natural seasonal temperature fluctuations will be maintained.

For this analysis, a discharge flow rate of 19,000 gpm was used that represents a long term operating condition.

In order to be consistent with the permitted discharge flow and pump operating conditions, discharge flow rates of 12,500, 25,000 and 30,000 gpm were also analyzed for the thermal mixing zone assessment for the controlling month as discussed below.

River flow data was obtained for the last 42 years (1966-2008) for the USGS station at Wilrnington

(#05527500) and used to develop monthly upstream low river flow conditions.

EPA recommends using the hydrologically based 7410 design low-flow for water quality standards and toxic wasteload allocation studies relating to chronic effects on aquatic life. The 7410 low-flow is defined as "the lowest 7-day average flow that occurs on average once every 10 years". Figure 4 presents the monthly minimum 7-day moving average flow for each of the 42 years as a probability distribution with the red vertical line representing the 10~ percentile and the associated flow equal to the 7410. The resulting monthly 7410 low-flow is tabulated in each panel with September having the lowest flow and April the highest. These monthly 7410 low-flows were used for the thermal analysis and also to estimate the river geometry (depth and width). Table 2 summarizes the monthly river model inputs for flow, width, depth and velocity.

Table 2. Monthly Model River Inputs Velocity (m/s) January February Average Depth (m)

March April Width (m) Month 1,011 1,159 -- May June River Flow (cfs) 2,166 2,535 July August 109 11 1 2,176 '1,333 -- September October December 1 976 1 108 1 1.55 1 0.17 122 125 783 650 HYDROQUhL, INC. 12M) ~\.Z~(;AKTHL'R BLvD., MAHWAH, NEW JERSEY 07454 T: 201-529-5151 I? 201-529-5728 WWW.HI'DROQCAL.COM 1.55 1.57 122 113 641 702 November 0.17 0.19 1.70 1.74 104 101 I I I I 1.54 --- - 921 107 0.30 0.33 1.70 1.60 101 103 0.16 0.30 0.21 1.51 1.49 0.14 0.12 1.49 1.50 0.12 0.13 Bryan L. Risley May 4,2009 PRIVILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 6 Compliance with Temperature Criteria Using the above river and discharge information, the CORMIX model was applied for the 3-, 5- and 7-port diffuser alternatives in addition to the existing discharge canal. For the 3 diffuser alternatives, the single port program (CORMIXI) was used because the area of interest for the thermal analysis is not properly represented using the multi-port CORMIX2 program since the CORMIX2 analysis assumes that the plumes from the ports have completely merged.

This is not the case in the near- field region applicable for the thermal analysis.

The port diameters analyzed with the model for the 3-, 5- and 7-port diffusers were 18, 14 and 12 inches, respectively, with a port height of 0.5 meters. In addition to the proposed diffuser scenarios, the existing discharge scenario was modeled using the CORMIX3 surface discharge program. The discharge was modeled as a flush, side-bank release from the left bank, entering the river perpendicular to the bank with a bottom slope of 2'. The width of the discharge channel was assumed to be 5.44 meters wide and 1 meter deep (HydroQual, 20073. All CORMIX model output is presented in Attachment

4. The maximum temperature rise above natural temperatures is 5°F per ILEPA regulations.

The required effluent dilution to meet this criterion is the discharge temperature rise divided by maximum allowable temperature rise of 5°F. Using the CORMIX model calculated effluent dilutions, the distances to achieve the maximum allowable temperature rise for all months was determined and are presented in Table 3. This table also summarizes the river 7410 low-flow, river intake and discharge temperatures, discharge temperature rise and required effluent dilution.

In general, all the multi-port dffusers reduced the distance to achieve the required effluent dilution needed to meet the maximum temperature rise above natural river temperatures as compared to the existing discharge.

The maximum required effluent dilution (8.3:l) occurs in March and, therefore, the &stance to meet the maximum temperature rise in the river was the greatest.

In March, the 3-, 5- and 7-port diffusers decreased the required distance from 257 meters for the existing discharge to 25.1, 21.6 and 19.6 meters, respectively.

The maximum reduction in distance occurred in September, from about 12,000 meters for the existing discharge to between 15.5 and 20.3 meters for the proposed diffuser configurations.

The maximum distances to achieve the required effluent dilution to meet the maximum temperature rise for the existing discharge, 3-, 5-, and 7-port diffusers was 12,006,25.1,21.6 and 19.6 meters, respectively. Table 3 also presents the model results for discharge flow rates of 12,500 gprn (1 pump operation), 25,000 gprn (2 pump operation), and 30,000 gprn (NPDES permitted flow rate) for the controlling month of March. In general: the 12,500 gprn flow rate decreases the required distance to meet the temperature rise criteria; the 25,000 gprn flow rate increases the distance slightly for the 3- and 7- port diffusers, and decreases the distance for the 5-port diffuser; and the 30,000 gpm flow rate increases the distance slightly for the 3-port diffuser, and decreases the distance for the 5- and 7-port diffusers.

At the 30,000 gprn flow rates, the required distances to meet the temperature rise criteria are 25.9 meters for 3-port diffuser, 20.1 meters for the 5-port diffuser, and 17.3 meters for the 7- port diffuser.

The second component to the temperature criteria are the maximum allowable temperatures at a representative location in the river (edge of the thermal mixing zone).

In order to complete this assessment, the discharge temperature was first compared to the maximum temperature limits (Table 4). For the months of January, February, April, May, October and November, the discharge temperature was less than the maximum temperature limits and, therefore, dilution of the effluent in HYDROQUX, INC. 1200 MAXACAR~ZR BLVD., XIAHWAH, NEW JERSEY 07430 T: 201-529-5151 F: 201-529-5728 VCWW.HYDROQC.~L.COM Bryan L. Rislep hlay 4,2009 PRWILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 7 the river is not needed. In the remaining months, the allowable temperature rise was determined from the maximum alowable temperature and the intake or river temperature.

This allowable temperature rise was compared to the effluent temperature rise and a required effluent dilution calculated that will meet the maximum allowable temperature rise and, therefore, the maximum temperature limits.

The maximum required effluent dilution is 1.5 in March with a minimum dilution of 1.1 in June, September and December.

For all of the 6 months, the effluent dilution required to meet the maximum temperature limits is less than that needed to meet the maximum temperature rise criterion and, therefore, the latter controls the required distance to achieve the temperature criteria.

Therefore, the maximum allowable temperature criteria will be met for all months at distance closer than that required to meet the maximum temperature rise criteria.

Compliance with Mixing Zone Regulations The CORMIX plume calculations for the proposed 7-port diffuser also showed that the resulting thermal plumes, at the distance where the temperature criteria were achieved, were confined in an area less than 25% of the cross-sectional area of the Kankakee River. Using the cross-sectional area from measured transects near the outfall, the lateral mixing area of the proposed diffuser (20 meter diffuser length plus the additional spreading of the plume and plume thickness), the monthly cross- sectional areas of the effluent plume are presented in Table 5. M of the monthly plume cross- sectional areas are less than the required 25% cross-sectional area limitation and will allow for an adequate zone of passage for aquatic life. In addition, the surface area of the thermal mixing zone is much less than the required 26 acres and is 875 m%ased on a 25 meter downstream and 35 meter wide (maximum plume width) proposed thermal mixing zone, or about 0.22 acres. For the existing side canal discharge, the maximum surface area required to meet the temperature criteria is greater than 26 acres, which occurs in September at 19,000 gpm. Table 5. River and Plume Monthly Cross-Sectional Areas HYDROQUAI,, INC. 12W MACARTHVR BLVD., X~AH\V.AH, NEWJERSEY 07430 T: 201-529-5151 F: 201-529-5728

\kw.w.H~'DRC~QC~~I*Co~f Plurne/River CSA (Yo) Month River CSA (m2) Plume CSA (m2)

Bryan L. Rsley May 4,2009 PRIVILEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 8 rls presented in Figure 1 and summarized in the ESI Study report (ESI, 20083, the mussel population density is extremely sparse in the mixing zone region (less than 25 meters downstream from the diffuser).

Therefore, based on the mussel information gathered by HDR and ESI, during the post-construction operating period the proposed diffuser discharges should not interfere with endangered species habitat, fish spawning areas or areas of important aquatic life habitat. There are also no bathing beaches, bank fishing areas, boat ramps or dockages or any other public access areas within 25 meters of the proposed discharge.

There is an intake structure for the Wilmington water supply below the Wilmington dam, which is about 5 miles downstream from the proposed discharge location.

The nearest tributaries to the proposed discharge are: Horse Creek, 0.25 miles upstream; and three unnamed tributaries 1, 1.2 and 1.6 miles downstream, respectively. These tributaries are all outside of the proposed thermal mixing zone area (25 meters downstream from the proposed discharge).

Based on the river temperature data available from the upstream USGS station at Momence, historical monthly river temperatures are always less than the maximum allowed river temperatures of 63OF (December to March) and 93OF (April to November).

Finally, the normal daily and seasonal temperature fluctuations in the river are not expected to be altered as a result of the proposed thermal discharge to the Kankakee River. The discharged blowdown water originates from the Braidwood cooling lake and, therefore, already exhibits normal daily and seasonal temperature fluctuations that are similar to those observed in the Kankakee River. Summary In summary, the proposed diffuser alternatives all achieve the applicable temperature criteria within a short distance (less than 25 meters from the discharge and also comply with the applicable mixing zone regulations).

The proposed dffuser alternatives all represent a significant improvement in dilution and environmental benefit as compared to the existing side canal discharge to the river. Therefore, a thermal mixing zone of 25 meters downstream by 35 meters wide is recommended for the 7-port diffuser under preliminary design by Exelon. The 7-port diffuser analyzed is 20 meters in length with a port diameter of 12 inches. If there are any questions or if you would like to discuss this effort further, please do not hesitate to call. Very truly yours, HYDROQUAL, INC. Andrew J. Thurnan, P.E. cc: Biswamp Guha, HydroQual HYDROQUAL, INC. 12(X) I&~AC~\RTHL'R BLVD., 1%4HWAH, NEW JERSEY 07430 T: 201-329-51 51 F: 201-529-5728 ViWW.HYDROQCA*COM Bryan L. Risley &lay 4,2009 PRMLEDGED AND CONFIDENTIAL CLIENT WORK PRODUCT Page 9

References:

' HDR Engneering, Inc. 2008. Investigations to Determine Presence of State-Listed Species of Fish and Freshwater Mussels in the Kankakee River Near the Braidwood Nuclear Station Warmwater Discharge Channel. Prepared for Exelon Nuclear. 21pp. 2 Ecological Specialists, Inc., 2008, Draft Report: Characterization of Unionid Communities near the Braidwood Nuclear station Kankakee River Discharge Location, (ESI Project No.08-023) HydroQual, Inc. Letter Report, 2007a., Letter report to Ms. Sharon Neal on August 2,2007 regarding discharge alternative study (EXCO.OO1)

' Jirka, G.H., R.L. Doneker and S.W. Hinton, 1996. User's Manual for CORhIIX: A Hydrodynamic Mixing Zone hlodel and Decision Support System for Pollutant Discharges into Surface Waters.

DeFrees Hydraulic Laboratory, School of CiviI and Environmental Engineering, Comell University, Ithaca, NY. HYDROQUAL, INC. 1200 XI~\C~~KTHLR BLIJD., MHWAH, NRV JERSEY 07430 30: 201-529-51 31 F: 201-529-5728 NW\V.H\'DRO(ZL'.IL.COlI Table 3. Distance to Achieve 59 Temperature Rise (Discharge of 19,000 gpm) Maximum Minimum Temperature Dilution Distance to Achieve Required Dilution (m16 Month Month'y 7Q10 Temperature Temperature River Flow (cfs) (OF)' t low down' (OF)' lntake3 Rise OF)^ FIequired5 Existing 3-port 5-port 7-port (CORMIX3) (CORMIXl) (CORMIXI) (CORMIXI)

January 1,011 59.9 30.2 29.7 5.9 347 18.0 14.0 12.0 I February I March 2,166 74.4 32.9 41.5 8.3 257 25.1 21.6 19.6 1 I April 2,535 73.7 52.9 20.8 4.2 85 12.3 9.5 8.2 1 I June I August 650 95.8 71.5 24.3 4.9 6,264 19.7 16.4 14.4 I I September 64 1 92.2 60.5 31.6 6.3 12,007 20.3 17.4 15.5 1 I October 702 82.5 46.4 36.1 7.2 6,275 21.9 19.1 17.3 1 I November 92 1 70.3 32.9 37.4 7.5 396 22.7 21.3 18.9 1 I December 976 62.3 32.0 30.3 6.1 361 18.4 14.3 12.3 1 Distance to Achieve 54: Temperature Rise (Discharge of 12,500 gpm, 25,000 gpm and 30,000 gpm) I March (1 2,500 2,1 66 gpm Effluent)

I March (25,000 2,1 66 gpm Effluent)

March (30,000 2,166 80.7 32.9 41.5 8.3 339 25.9 20.1 17.3 gpm Effluent)

Notes: 1. Monthly maximum of daily average temperatures

2. Blowdown temperatures at the river discharge canal were unavailable for October-March and assumed to equal the cooling lake intake temperatures during this period. Blowdown temperatures from April-September are the monthly maximum of daily average temperature

3. River temperatures at the intake were unavailable for October-March and assumed to be equal to the historical (1966-2001) minimum monthly temperatures from the USGS station (05520500), Kankakee River at Momonce, which is upstream of the discharge location 4. Temperature Rise

= Blowdown Temperature - Intake Temperature

5. Dilution required

= (Temperature rise) I (Maximum temperature rise above natural temperatures as per Illinois Pollution Control Board (IPCB), Environmental Regulations for the State of Illinois, Title 35 of the Illinois Administrative Code, Subtitle C, Chapter I, Part 302, Subpart B, Section 302.21 1) 6. Results from CORMlX simulations Table 4. Dilution Required to Meet Maximum Temperature (Discharge of 19,000 gpm) I Allowable I Maximum Minimum Maximum Monthly Temperature Allowable Dilution Month 7010 River Temperature Temperature (OF)' Temperature at the Edge Rise (OQ5 Temperature Flow (cfs) (OF)' lntake3 of Mixing Rise M OF)^ ~equired' Blowdown*

zone4 I February 1,159 59.4 32.0 60 27.4 -- -- I I April 2,535 73.7 52.9 90 20.8 -- -- I June 1,333 92.9 63.2 90 29.6 26.8 1 .I July 783 95.3 72.1 90 23.2 17.9 1.3 August 650 95.8 71.5 90 24.3 18.5 1.3 September 641 92.2 60.5 90 31.6 29.5 1.1 October 702 82.5 46.4 90 36.1 -- -- November 92 1 70.3 32.9 90 37.4 -- -- December 976 62.3 32.0 60 30.3 28.0 1.1 Notes: 1. Monthly maximum or minimum of daily average temperatures

2. Blowdown temperatures at the river discharge canal were unavailable for October-March and assumed to equal the cooling lake intake temperatures during this period.

Blowdown temperatures from April-September are the monthly maximum of daily average temp

3. River temperatures at the intake were unavailable for October-March and assumed to be equal to the historical (1 966-2001) minimum monthly temperatures from the USGS station (05520500), Kankakee River at Momonce, which is upstream of the discharge locat 4. As per Illinois Pollution Control Board (IPCB), Environmental Regulations for the State of Illinois, Title 35 of the Illinois Administrative Code, Subtitle C, Chapter I, Part 302, Subpart B, Section 302.21 1 5. Temperature Rise

= Blowdown Temperature - Intake Temperature

6. Allowable temperature rise = Maximum allowable temperature as per regulations - Intake temperature

7. Dilution required

= (Temperature rise) / (Allowable temperature rise)

E 0 .- C m 0 OrL -00 sg QN l a (0 '5; = .= .I! -0 g g 6 2 st= v -2 73- c 2 m 0 cue .= !5 15 .- - .- m - c I 0 - s Q) p :5 (0 .h C I0 E r=

• 0 cnz .E - 3 a(2 E 'P m cu "'z en 3 5g - 'Po 10 0 s 0 E 12 $ D- .- = 2 .,O Q) e c s L cua > .h 'Z lr . g, 7z o m 3% ps Priviledged and Confidential Client Work Product Wilrnington Lakewood Shores Figure 2. ECOM Far-Field Model Grid and River Depths 130 IIIIIIIIII 120 - Intake and Upstream USG!~ Station Temperature 111111111,, 11111111,,I -mmmn iLh 110- 100- E 90 80 a 00 0. g ;: l .. l 40- l l l l l l l l l 30m1.1.1 I I I I I I 1.1. 01.,.1 1 I I I ' I 1.10 .#.,.I I I I 1 I I 1.1. JFMAMJJASONDJFMAMJJASONDJFMAMJJASOND Minimum (1966-2001) upstream 0101.1 1 I I I 1 I I. 10 I JFMAMJJASOND Figure 3. Exelon Braidwood Nuclear Facility, Kankakee River Discharge, Upstream River Temperature, River lntake and Blowdown Temperatures 130 200 11111111111 111,111111, 1111IIIIII and Blowdown Temperatures - - WIOUUQC wn - Intake - 180 - - Blowdc WP temp, at Kankakee River - 160 A/kAP ~f.'@ -"\, --* IIIIlilllll IIIIIIIIII

\rl I*0 110 100 90 80- 70 60 50 40 30 JFMAMJJASONDJFMAMJJASONDJFMAMJJASONDJFMAMJJASOND 2005 2006 2007 2008 IIIIIIIIII - Intake from Cooling Lake - - - - I~~IIIIIIII Priviledged and Confidential Client Work Product January February 1000 1 OOOOO June 10000 1000 100, 10 1 0.1 1 10 50 90 9999.9 October 100000 10000 1000 100 - 10 1 March IOOOOO l l Ill1 l .rnIII 7010 = 2166 g November l , 1 r 1 l l .lllIlI 0.1 1 10 50 90 99 99.9 December 1000 Percent less than or equal to Percent less than or equal to Percent less than or equal to Percent less than or equal to Figure 4. Monthly Minimum 7-Day Average Flow (1966-2008), USGS station 05527500, Kankakee River near Wilmington, IL Attachment I Section 302.102 of Title 35, Subtitle C, Chapter I, Part 302, Subpart A

Section 302.102 Allowed Mixing, Mixing Zones and ZIDs a) .Whenever a water quality standard is more restrictive than its corresponding effluent standard, or where there is no corresponding effluent standard specified at 35 111. Adm. Code 304, an opportunity shall be allowed for compliance with 35 Ill. Adm. Code 304.105 by mixture of an effluent with its receiving waters, provided the discharger has made every effort to comply with the requirements of 35 111. Adm. Code 304.102. b) The portion, volume and area of any receiving waters within which mixing is allowed pursuant to subsection (a) shall be limited by the following:

1) Mixing must be confined in an area or volume of the receiving water no larger than the area or volume which would result after incorporation of outfall design measures to attain optimal mixing efficiency of effluent and receiving waters. Such measures may include, but are not limited to, use of diffusers and engineered location and configuration of discharge points. 2) Mixing is not allowed in waters which include a tributary stream entrance if such mixing occludes the tributary mouth or otherwise restricts the movement of aquatic life into or out of the tributary.

3) Mixing is not allowed in water adjacent to bathing beaches, bank fishing areas, boat ramps or dockages or any other public access area. 4) Mixing is not allowed in waters containing mussel beds, endangered species habitat, fish spawning areas, areas of important aquatic life habitat, or any other natural features vital to the well being of aquatic life in such a manner that the maintenance of aquatic life in the body of water as a whole would be adversely affected.

5) Mixing is not allowed in waters which contain intake structures of public or food processing water supplies, points of withdrawal of water for irrigation, or watering areas accessed by wild or domestic animals.

6) Mixing must allow for a zone of passage for aquatic life in which water quality standards are met.

7) The area and volume in which mixing occurs, alone or in combination with other areas and volumes of mixing, must not intersect any area of any body of water in such a manner that the maintenance of aquatic life in the body of water as a whole would be adversely affected.

8) The area and volume in which mixing occurs, alone or in combination with other areas and volumes of mixing must not contain more than 25% of the cross-sectional area or volume of flow of a stream except for those streams where the dilution ratio is less than 3: 1. Mixing is not allowed in receiving waters which have a zero minimum seven day low flow which occurs once in ten years. 9) No mixing is allowed where the water quality standard for the constituent in question is already violated in the receiving water. 10) No body of water may be used totally for mixing of single outfall or combination of outfalls.

11) Single sources of effluents which have more than one outfall shall be limited to a total area and volume of mixing no larger than that allowable if a single outfall were used. 12) The area and volume in which mixing occurs must be as small as is practicable under the limitations prescribed in this subsection, and in no circumstances may the mixing encompass a surface area larger than 26 acres. c) All water quality standards of this Part must be met at every point outside of the area and volume of the receiving water within which mixing is allowed. The acute toxicity standards of Sections 302.208 and 302.210 must be met within the area and volume within which mixing is allowed, except as provided in subsection (e).

d) Pursuant to the procedures of Section 39 of the Act and 35 Ill. Adm. Code 309, a person may apply to the Agency to include as a condition in an NPDES permit formal definition of the area and volume of the waters of the State within which mixing is allowed for the NPDES discharge in question. Such formally defined area and volume of allowed mixing shall constitute a "mixing zone" for the purposes of 35 Ill. Adm. Code: Subtitle C. Upon proof by the applicant that a proposed mixing zone conforms with the requirements of Section 39 of the Act, this Section and any additional limitations as may be imposed by the Clean Water Act (CWA) (33 U.S.C 125 1 et seq.), the Act or Board regulations, the Agency shall, pursuant to Section 39(b) of the Act, include within the NPDES permit a condition defining the mixing zone.

e) Pursuant to the procedures of Section 39 of the Act and 35 Ill. Adm. Code 309, a person may apply to the Agency to include as a condition in an NPDES permit a ZID as a component portion of a mixing zone. Such ZID shall, at a minimum, be limited to waters within which effluent dispersion is immediate and rapid. For the purposes of this subsection, "immediate" dispersion means an effluent's merging with receiving waters without delay in time after its discharge and within close proximity of the end of the discharge pipe, so as to minimize the length of exposure time of aquatic life to undiluted effluent, and "rapid" dispersion means an effluent's merging with receiving waters so as to minimize the length of exposure time of aquatic life to undiluted effluent.

Upon proof by the applicant that a proposed ZID conforms with the requirements of Section 39 of the Act and this Section, the Agency shall, pursuant to Section 39(b) of the Act, include within the NPDES permit a condition defining the ZID.

f) Pursuant to Section 39 of the Act and 35 Ill. Adm. Code 309.103, an applicant for an NPDES permit shall submit data to allow the Agency to determine that the nature of any mixing zone or mixing zone in combination with a ZID conforms with the requirements of Section 39 of the Act and of this Section.

A permittee may appeal Agency determinations concerning a mixing zone or ZID pursuant to the procedures of Section 40 of the Act and 35 Ill. Adm.

Code 309.18 1. g) Where a mixing zone is defined in an NPDES permit, the waters within that mixing zone, for the duration of that NPDES permit, shall constitute the sole waters within which mixing is allowed for the permitted discharge. It shall not be a defense in any action brought pursuant to 35 111. Adm. Code 304.105 that the area and volume of waters within which mixing may be allowed pursuant to subsection (b) is less restrictive than the area or volume or waters encompassed in the mixing zone. h) Where a mixing zone is explicitly denied in a NPDES permit, no waters may be used for mixing by the discharge to which the NPDES permit applies, all other provisions of this Section notwithstanding.

i) Where an NPDES permit is silent on the matter of a mixing zone, or where no NPDES permit is in effect, the burden of proof shall be on the discharger to demonstrate compliance with this Section in any action brought pursuant to 35 Ill. Adrn. Code 304.105. (Source: Amended at 14 Ill. Reg. 2899, effective February 13, 1990)

Attachment I1 Section 302.211 of Title 35, Subtitle C, Chapter I, Part 302, Subpart A a) Temperature has STORET number (F") 000 1 1 and (CO) 000 10. b) There shall be no abnormal temperature changes that may adversely affect aquatic life unless caused by natural conditions.

c) The normal daily and seasonal temperature fluctuations which existed before the addition of heat due to other than natural causes shall be maintained.

d) The maximum temperature rise above natural temperatures shall not exceed 2.8' C (5" F). e) In addition, the water temperature at representative locations in the main river shall not exceed the maximum limits in the following table during more than one percent of the hours in the 12-month period ending with any month. Moreover, at no time shall the water temperature at such locations exceed the maximum limits in the following table by more than 1.7" C (3' F). JAN. 16 60 JUL. 3 2 90 FEB. 16 60 AUG. 3 2 90 MAR. 16 60 SEPT. 3 2 90 APR. 32 90 OCT. 32 90 MAY 3 2 90 NOV. 32 90 JUNE 32 90 DEC. 16 60 f) The owner or operator of a source of heated effluent which discharges 150 megawatts (0.5 billion British thermal units per hour) or more shall demonstrate in a hearing before this Pollution Control Board (Board) not less than 5 nor more than 6 years after the effective date of these regulations or, in the case of new sources, after the commencement of operation, that discharges from that source have not caused and cannot be reasonably expected to cause significant ecological damage to the receiving waters. If such proof is not made to the satisfaction of the Board appropriate corrective measures shall be ordered to be taken within a reasonable time as determined by the Board. g) Permits for heated effluent discharges, whether issued by the Board or the fllinois Environmental Protection Agency (Agency), shall be subject to revision in the event that reasonable future development creates a need for reallocation of the assimilative capacity of the receiving stream as defined in the regulation above.

h) The owner or operator of a source of heated effluent shall maintain such records and conduct such studies of the effluents from such sources and of their effects as may be required by the Agency or in any permit granted under the Illinois Environmental Protection Act (Act).

i) Appropriate corrective measures will be required if, upon complaint filed in accordance with Board rules, it is found at any time that any heated effluent causes significant ecological damage to the receiving stream.

j) All effluents to an artificial cooling lake must comply with the applicable provisions of the thermal water quality standards as set forth in this Section and 35 Ill. Adm. Code 303, except when all of the following requirements are met: 1) All discharges from the artificial cooling lake to other waters of the State comply with the applicable provisions of subsections (b) through (e). 2) The heated effluent discharged to the artificial cooling lake complies with a11 other applicable provisions of this Chapter, except subsections (b) through (e). 3) At an adjudicative hearing the discharger shall satisfactorily demonstrate to the Board that the artificial cooling lake receiving the heated effluent will be environmentally acceptable, and within the intent of the Act, including, but not limited to: A) provision of conditions capable of supporting shellfish, fish and wildlife, and recreational uses consistent with good management practices, and B) control of the thermal component of the discharger's effluent by a technologically feasible and economically reasonable method. 4) The required showing in subsection (j)(3) may take the form of an acceptable final environmental impact statement or pertinent provisions of environmental assessments used in the preparation of the final environmental impact statement, or may take the form of showing pursuant to Section 3 16(a) of the Clean Water Act (CWA) (33 U.S.C. 125 1 et seq.), which addresses the requirements of subsection (3)(3). 5) If an adequate showing as provided in subsection (j)(3) is found, the Board shall promulgate specific thermal standards to be applied to the discharge to that artificial cooling Lake.

Appendix C Outfall Location Calculation Exelon River Diffuser Project Appendix C Net Change - Location of Outfalls Geographic System Reference Latitude:

41' 15' Longitude:

88' 8' Existing Outfall (seconds only) 6.450 5.490 Calculated distance is based on the square root of the sum of the squares. Proposed Outfall (seconds only) 8.700 0.350 Latitude and longitude based on observations taken from Google Earth. 31.48 Difference (seconds only) 2.250 (5.140) 5.611 Square of the Difference (seconds only) 5.063 26.42 Calculated Distance (sec)

Appendix D Engineering Drawings (As Submitted May 8,2009)

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BEDOIW WlERIN (IWT I57 OR $07 HXREGATE)

SECTION E-E SECTION J-J Note: Dimensions may change slightly based on final enginesrlng darign. Updated drawtngs will be provided to USACE when available.

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Appendix E Electronic Copy of "Application for an Individual Permit for a River Diffuser" (as submitted May 8,2009 to US Army Corps of Engineers)

-- 1520 Kensington Road, Oak Brook, IL 60523 630-993-2100 EXELON NUCLEAR Brnidwood Generating Station PLICATION FOR AN INDIVIDUAL PERMI FOR A RIVER DIFFUSER