Notes from Site Visit at Consumers Energy’s Karn/Weadock Generating Complex on September 22, 2009

EPA conducted a site visit at Consumers Energy’s Karn/Weadock Generating Complex (Karn/Weadock) located in Essexville, MI on Tuesday, September 22, 2009 to learn about the operations at the plant. Table 1, located at the end of this memorandum, identifies the site visit participants. The presentation that the Karn/Wea dock personnel gave duri ng the site visit is provided in Attachment 1 of this memorandum.

This memorandum describes the informati on collected during the site visit.

Plant Overview

 The Karn/Weadock Generating Complex includes the D.E. Karn and J.C. Weadock power plants. Karn/Weadock has been in produc tion since the 1940’s. The site covers approximately 2,400 acres, which includes outlying property the plant has acquired located at 2742 Weadock Highway Essexville, MI. The comple x is located at the mouth of the Saginaw River, which discharges to the Saginaw Bay and ultimately combines with Lake Heron. Karn/Weadock pumps service water from the Saginaw River and disc harges pre-treated NPDES permit authorized effluent to Sagi naw Bay via Outfall 001. A discharge flow diagram for Karn/Weadock is provided in Attachment 2 of this memorandum.

 Karn/Weadock employs 381 personnel includi ng supplemental company and contracted employees. Roughly, Karn/Weadock employs 250 personnel to operate the units.

 Karn/Weadock has 12 electric generating units on site. Six of these twelve are retired Weadock units, while six are still in operation. Th e units still in operation are coal-fired units, Karn Units 1 and 2 and Weadock Units 7 and 8, and oil/natural gas-fire d units, Karn Units 3 and 4. Karn/Weadock stated that retired Wea dock Units 1-6 are “standard”, once- through steam electric generating units that were extr emely inefficient when operated. They were retired in the early 1980’s. The table below c ontains some general information for each operating electric generating unit.Page 2

Unit Boiler Description Installation Date Net Rated Capacity Power (MBTU per hour) Fuel Blend Particulate Control NOx Control

Karn Unit 1 Dry Bottom;Tangentialfired 1959 255 MW Baseload 2,500 75 % PRB 25 % Eastern bituminous 2 cold-side electrostatic precipitators (ESPs) in series; Sulfur trioxide system available to enhance efficiency SCR installed in 2004; Year round operation of SCR began in 2009

Karn Unit 2 Dry Bottom; Wall-fired 1961 260 MW Baseload 2,540 75 % PRB 25 % Eastern bituminous 2 cold-side ESPs in series; Sulfur trioxide system available to enhance efficiency SCR installed in 2003; Year round operation of SCR began in 2009; Low-NOx burners installed in 1998

Karn Unit 3 Natural gasand fuel oilfired (dual fuel) 1975 630 MW Peaking 7,290 # 6 fuel oil and natural
gas None Low-NO X burners

Karn Unit 4 Natural gasand fuel oilfired (dual fuel) 1977 630 MW Peaking 8,030 # 6 fuel oil, and natural
gas None Low-NO X burners

Weadock

Unit 7 Dry Bottom;Tangentialfired 1955 155 MW Baseload 1,610 80 % PRB 20 % Eastern bituminous Cold-side ESP; Sulfur trioxide system available to enhance efficiency Low-NO X burners (Operational May 2010)

Weadock

Unit 8 Dry Bottom;Tangentialfired 1958 155 MW Baseload 1,610 80 % PRB 20 % Eastern bituminous Cold-side ESP; Sulfur trioxide system available to enhance efficiency Low-NO X burners (Operational March 2010)

Note: Units 7 and 8 now have low NO x burners, but they were not in place and operational at the time of the site visit in September 2009.

 Karn/Weadock stated that there is no significan t difference in operation between the type of boilers (tangential versus wall) for Karn Units 1 and 2. There is no significant difference in the amount or split of ash (bottom versus fl y ash) or the efficiency of the boilers. Karn/Weadock installed a wall-fired boiler for Ka rn Unit 2 mostly due to market competition at the time.

 Karn Unit 1 was down for maintenance during the si te visit. Karn/Weadock stated that Karn has 30 to 60 days of outage planned for clea ning and maintenance throughout the year.Page 3

 Karn Units 1 and 2 and Weadock Units 7 and 8 use fuel oil for startup and supplemental cofiring for flame stabilization and mill outages.

 In 2008, Karn Units 1 and 2 and Weadock Units 7 and 8 burned a total of 1,947,422 tons of coal to produce 3,873,186 net MWh.

 Karn Units 3 and 4 have identical, front-fired boilers units with 30 burners (3 decks of 10). Each burner on each boiler must burn the same amount of BTU for balancing. The boilers are started with natural gas, and then typically burn a blend of natural gas and oil. Each burner is capable of burning both natural gas and oil at the same time, but Karn/Weadock does not do that. In years past, Karn/Weadock would typically burn a bout 40 percent natural gas and 60 percent oil in the boile rs, but the plant has recently been burning more natural gas in these boilers because it has been so in expensive. The plant is limited to burning 60 percent natural gas due to boile r reactions. The radiant flame affects the way the water walls absorb heat. Karn/Weadock cont rols sulfur dioxide emissions w ith a “ratio burn” of natural gas to oil. The burning of the medium sulfur o il, which contains more than 1 percent sulfur, is balanced with burning of natural gas to m eet the plant’s permitted sulfur dioxide limit.

 Karn Units 1 and 2 and Weadock Units 7 and 8 each have a sulfur trioxi de injection system to enhance the performance of the ESPs. Ka rn/Weadock has found that the these sulfur trioxide injection systems have not been necessary and they have not been used recently due to the year round operation of the SCRs. Heat tracing and thermal insulation systems were installed to allow SCR system operation through the winter.

 Once through cooling is used for Karn Un its 1 and 2 and Weadock Units 7 and 8.

 Karn Units 3 and 4 use closed loop, mechanical draft cooling towers.

Ash Generation, Handling, and Wastewater Treatment

Ash Generation

 Karn Units 3 and 4 are oil/natural gas-fired unit s. They produce very little ash. Soot blowers exist on each unit; however, are presently never us ed because no precipitators are installed on these units. Without precipitato rs, operating the soot blower s would cause ash to exit the stack with the flue gas and air pollution contro l limits would be exceeded. The soot blowers on these units were last operated in the 1970’s.

Bottom Ash Handling

 Karn/Weadock operates a wet bottom ash handl ing system on Karn Units 1 and 2 and Weadock Units 7 and 8. About ten percent of a ll ash produced at the plant is bottom ash. Mill rejects are collected dry and then handled we t with the bottom ash. The Weadock bottom ash sluice is directed to the Weadock bottom as h pond through a series of channels, discharged via Outfall 001H, and ultimately discharged to Saginaw Bay via Outfall 001A. An aerial view of the Weadock property, with labeled pon ds, channels, and outfalls, is provided in Attachment 3 of this memorandum.Page 4

 Karn/Weadock dredges the bottom ash pond a couple of times a year and uses the bottom ash for roadbed. The roads are constructed of about two feet of bottom ash, a geotech fabric, and about two feet of stone. Karn/Weadock also has plans to use bottom ash as landfill cover material.

 Karn Units 1 and 2 have a similar wet bottom ash handling system. The Karn bottom ash sluice is directed to the Karn bottom ash pond, discharged via Outfall 001B, and ultimately discharged to Saginaw Bay via Outfall 001A. An aerial view of the Karn property, with labeled ponds, channels, and outfalls, is prov ided in Attachment 4 of this memorandum.

 Karn/Weadock estimates that there is about six to eight years of capac ity left for the bottom ash pond. The facility will continue to develop mo re options for bottom ash sluice closer to that time.

 Plant personnel stated that if the bottom ash were sent to a dewatering bin, the plant would need to consider the cost for treatment of the recovered water, though reuse of the water is a possibility. The dewatered ash may need to be hauled.

Fly Ash Handling Overview

 Karn/Weadock operates a dry fly ash handling system on Karn Units 1 and 2 and Weadock Units 7 and 8. These systems are identical in operati on, but the Weadock system is smaller. There are fewer hoppers overall for the Weadoc k units. In both the Karn and Weadock systems, ash collected from the precipitators, air heaters, and economizers is handled dry. For the Karn units, the air heater and economizer ash is collected in separate sets of hoppers, whereas for the Weadock units, the air heater an d economizer ash is collected together in the same hoppers.

 The dry fly ash handling system (on Karn Units 1 and 2 and Weadock Units 7 and 8) is a conversion from the previously operated wet fly ash handling system. This conversion took place from 2006 to 2009, with initial operation of the dry fly ash handling system occurring in 2008. The dry fly ash handling system wa s designed by United Conveyor (UCC) in 2006. The dry fly ash flow diagram is provided in Attachment 1 of this memorandum.

 Some of the fly ash sluicing equipment is sti ll in place at Karn/Weadock, mainly due to the cost of removal. Karn/Weadock has no plans to use the sluicing equipment again. Plant personnel stated that there is no need because there is ample capacity and redundancy in current dry fly ash handling system (and fly ash can be diverted from the Karn to Weadock systems or vice versa). Additiona lly, plant personnel st ated that it might not be possible to use the sluicing system as is: valves and other equipment would need to be removed/replaced.

 Karn/Weadock discussed why they switched from the hydroveyors, which were used with the wet sluicing system, to mechanical exhauste rs to pull the fly ash by vacuum out of the hoppers. The mechanical exhausters are more re liable, and in general, the plant wants to reduce water use as much as possible. Add itionally, the hydroveyor sy stem would not have been able to pull enough vacuum to transfer th e dry fly ash from the hoppers to the transfer station/tank.Page 5

 New equipment additions for the dry fly ash systems include piping (some piping from the wet fly ash handling systems is still in use fo r the dry fly ash handling systems), valves, the exhaust systems, the transfer st ation/tanks, and the loading silo.

 Headwaters Resources (Headwaters) markets th e dry fly ash produced at the Karn/Weadock facility. The amount of fly ash sold depends on the availability of projects in the Michigan area. Lafarge Company purchases about 200 tons of the Karn/Weadock fly ash per day to manufacture cement.

 Long term, the facility is looking to sell abou t 50,000 tons of ash per year. Karn/Weadock produces about 160,000 tons of fly ash per year.

 The mixture of coal that Karn/Weadock uses to operate their units produces a valuable ash product. It is not Class C ash, but there is stil l a market for it. Karn/Weadock stated that the Campbell power plant burns a 100 percent west ern coal, which produces a more valuable Class C ash with a lower loss on ignition (L OI). Karn/Weadock stated that the major difference between the types/classe s of ash is the final color.

Detailed Dry Fly Ash Handling System Operation

 The fly ash is collected dry from the bottom of the precipitator and economizer hoppers and pulled by vacuum (generated by mechanical exha usters) to the transf er tank. The Karn and Weadock dry fly ash systems each have one tran sfer tank. The precipitator and economizer hoppers are emptied based on time intervals or leve ls of ash. The Karn transfer tank has the capacity to hold about two to three days worth of fly ash (from Karn Units 1 and 2 combined), but the transfer ta nk is typically operated at about 20 percent of its capacity. Karn/Weadock estimated that the distance from the Karn Unit 2 hoppers to the transfer tank is about 400 to 600 feet (and about an additi onal 200 feet from the Karn Unit 1 hoppers).

 Located on the side of each transfer tank is an emergency loading dock and pin mixer (pug mill) that can be used to unload ash from the tr ansfer tank in case there is a system failure or the loading silo requires maintenance. The pin mi xer conditions (i.e., adds moisture to) ash in preparation for loading, typically to about 15 to 20 percent moisture. The emergency pin mixer can condition ash at a rate of 50 tons per hour.

 Dry fly ash that enters the transfer tank (f rom the precipitator and economizer hoppers) is transferred into filter/separators. The filter/separators contain bag filters and separate the fly ash from the transfer air, which is exhausted. Th e fly ash is then transferred into air-locked transfer hoppers. As the ash is dropped into the hoppers, fugitive dus t is pulled through the filter/separators and captured by bin vent filters on top of the transfer tank, ensuring that no dust exits through the stack. Operators routinely check monitors that indicate if there any breaks in the filters.

 As the top of transfer hopper closes, separating the ash from the vacuum pressure, the bottom of the hopper opens, introducing th e ash to a positive air pressu re system. The ash is blown by compressed air to the 2,700 ton storage silo, wh ich is 2,300 ft away from the Karn transfer tank and over 4,000 ft away from the Weadock transfer tank. NUVA pressure feeders are used to introduce the ash to the positive pressure system. Relief valves were installed on the transfer hopper to ensure that they don’t contract as the chan ge in air pressure occurs.Page 6

 From the storage silo, dry fly ash is either lo aded pneumatically into trucks for sale or moisture conditioned, loaded into trucks and landfilled. Currently, Karn/Weadock unloads ash, either for landfill or sale, five days pe r week during daylight hours only. It is cost prohibitive for Karn/Weadock to install lights on the roads to the silo at this time.

 Dry fly ash for sale is transfe rred to the trucks pneumatically, under negative pressure, with a double annular spout. A vacuum is pulled throug h the outer annulus of the spout, creating a tight seal with the truck. Ash is delivered through the inner annulus of the spout into the truck. The vacuum captures any fugitive dust a nd pulls it back into the silo. Karn/Weadock stated that with this system, the ash flows easily into the trucks, “like a liquid”. Trucks are each loaded with approximately 50 tons of dry fly ash. Plant personnel stated that the moisture content of the dry fly ash stored in th e silo is very low. Any significant amount of moisture would cause sedimentation in the silo.

 Bagfilters are located at the top of the silo. There is a transmitter analog gauge to monitor the quality of the bags. Visual ch ecks are also performed and logg ed periodically by operators. The conveying piping is also visu ally checked for any leaks.

 Dry fly ash that is not sold is moisture-conditione d in pin mixers and then loaded into one of two trucks. The pin mixers at the storage silo are much larger than the emergency pin mixer near the transfer tank. Th e pin mixers at the storage silo moisture-condition the ash to about 17 to 18 percent. The inside of the pin mixer c ontains large bars (till bars) made out of nylon anti-stick material that mix the ash with the wa ter, which is sprayed into the mixer. The pin mixers are also operated under vacuum to control fugitive dust.

 One truck holds 42 tons of ash that has been conditioned to a moisture content of about 17 to 18 percent (about 37 tons of dry fly ash and 5 to 6 tons of water). A 6,500-gallon service water truck regularly drives around the perime ter of the silo area wetting the ground to control fugitive dust.

 The trucks that load the moisture-conditio ned ash place it in the landfill/ash pond area. A bulldozer spreads the ash and compacts it to the desired density. The bulldozer operator uses a compaction hammer to test the density of the surrounding area once every 104 truckloads or 4 ft of ash displaced. Lab tests are done to determine the exact density and moisture content of the ash placed. In or der to obtain an accurate read ing for the elevation, surveying would have to done.

 After trucks have loaded moisture-conditioned ash, some water is released to the silo area through a drain hose. Sumps around the area drain to a collection ditch and small sediment pond where sediment and ash are dredged and stacked.

Dry Fly Ash Handling Conversion Timeline and Costs

 Butch Braun, the System Engineer for th e dry fly ash handling system, presented Karn/Weadock’s conversion plan and the related costs during the site vi sit. The presentation given by Mr. Braun is provided in Attachment 5 of this memorandum.Page 7

 The scope of the project was to convert the wet fly ash handling systems on Karn Units 1 and 2 and Weadock Units 7 and 8 to dry fly ash ha ndling systems that pneumatically convey fly ash from the precipitator, economizer, and air heater hoppers to the storage silo for landfill and/or sale.

 The project was started in 2005 w ith the development of a dry fly ash handling study, which updated a previous study performed in 2002. The foundations for the new dry fly ash handling system were laid in 2006. The year 2007 focused on the engineering and mechanical/electrical designs . Activities in 2008 included th e construction, start-up, and testing of the final design. Karn/Weadock is closing out the project during the year 2009.

 UC Services developed the overall system design and provided the major equipment (compressors, blowers, tanks, piping, etc) as well as the redundant equipment used throughout the system. UCC designed a nd provided the ash storage silo.

 Karn installed isolation valves during a for ced outage for Karn Unit 1 in 2006. Karn Unit 2 was installed during a planned outage in 2007. Weadock Units 7 a nd 8 isolation valves were installed during a forced outage in 2006. With thes e isolation valves, the facility was able to isolate the wet system from the new dry system and perform tie in work while the generating units were still in operation.

 The total budget for the conversion was $50 million. This is nearly double the cost estimated in the 2005 plan.

 When asked about specific costs, Mr. Braun used the conversion for Karn Units 1 and 2 as an example. Mr. Braun estimated that the Karn installation was about $19 million (and the Weadock installation was about $24 million and the silo was about $7 million). He provided the following rough, breakout for the Karn materi als/installation cost (Note: the attached “Project Construction Cost Breakdown” presen tation includes anothe r version of this breakout):

 UC Services major equipment: $4 million;

 Buildings: $2 million;

 Piping to the silo: $2 million;

 Electrical: $2 million;

 Mechanical installation: $3 million; and

 Cement foundation for silo: $1.5 million

 The conversion for Weadock was more expensiv e than Karn due to challenges the facility encountered with spacing and location. The Weadock system re quired more piping to reach the transfer tank and storage silo. Some system equipment (e.g., compressors and filter/separators) also had to be split between two buildings for spacing issues. Additionally, the compressor pumps needed to be placed on the roof to save space, which resulted in the added construction of a platform for support.

 Challenges that Karn/Weadock encountered du ring the conversion included equipment and underground work interferences, manpower availa bility, weather, and the availability of the contractor to install the sil o. Karn/Weadock was able to us e regular scheduled outages to complete the conversion over the four-year period.Page 8

 Karn/Weadock stated that the silo star ted operating on December 9, 2008 and started landfilling ash on December 18, 2008. Both dry fly ash handling systems were in full operation on February 21, 2009.

 Karn/Weadock stated that the annual O&M co st, including labor, for the silo is around $225,000. This includes the O&M costs for two pic kup trucks, the bulldozer, and the service water truck. Typically, three to four operators and one ash ha ndling supervisor are dedicated on a full time basis (40 hpw/365 dpy).

 Karn/Weadock stated that there has been only a minimal increase in O&M costs for the dry system from the wet system thus far. Karn/Weadock estimated that start up time for the dry system is about one hour, compared to the 20 minutes for the wet system. The difference in start up time could be partly related to learning how to operate the new dry system. Karn/Weadock stated that maintenance costs have been low so far, but predicted that they will rise due to the complexity of th e new system (e.g., additional valves).

 The design of the Karn/Weadock dry fly ash ha ndling system is similar to the Campbell power plant system. Karn/Weadock looked to the Campbell system design for lessons learned during the conversion. The one major difference between the two systems is that theCampbell system has two loading silos: one for dry fly ash sale and one for moistureconditioned landfilling.

 Karn/Weadock discussed that they would like to modify the ash loading area for separate loading areas for dry fly ash sale and mois ture-conditioned landfilli ng. With two separate loading areas, moisture-conditioned ash and dry as h could be loaded at the same time. This would eliminate the timely pr ocess necessary to switch fr om the moisture-conditioned loading equipment and the dry spout between tr uck loads. Two loading bays versus two loading silos were also discussed.

Karn/Weadock Ash Ponds and Landfills

 Karn/Weadock operates a network of ash ponds. Th is network includes a series of ponds and channels that was created (and most useful when) fly ash was sluiced. The network of channels was created to increas e retention capacity. The earliest ponds that were constructed on the plant property were filled prior to 1969.

 The Karn ash field (landfill) is about 170 acr es and the Weadock ash field is 292 acres. There are no leachate collection systems for these landfills.

 The Karn fly ash ponds/landfill are currently full. A ll Karn ash that is not being sold is being used to fill in the Weadock ash ponds or landf ill. In Michigan, ash impoundments must be closed as landfills are with a cover. Karn/W eadock plans to use dredged bottom ash for this cover material.

 Karn/Weadock built a slurry wall al ong the entire pond system as pa rt of the plan for vertical expansion of the ash pond/landfill area.Page 9

 As the Karn fly ash ponds were running out of capacity, Karn/Weadock could no longer meet their TSS limits on the ash pond discharge. Because of this and Karn/Weadock’s overall goal to use and discharge less water (partly due to trends of tighter regulations on discharges), Karn/Weadock converted to a dry fly ash handling system.

 Karn/Weadock mentioned that they are consid ering building a new electric generating unit with cooling towers on top of the old Karn ponds.

 Karn/Weadock recently conducted a potential fail ure mode analysis of their ponds with the company, AECOM, and report(s) of the anal ysis are being drafted. Prior to that, Karn/Weadock conducted inspections of their ponds; these were not formal geotechnical inspections, but what Karn/Weadock described as general inspections.

 Karn/Weadock has conducted groundwater m onitoring around the as h pond/landfill area since 1982, with a particular focus on boron and ar senic. Typically, the leachate in the area contains about 2 ppb of boron, but closer to 100 ppb is measured during groundwater testing.

Metal Cleaning Wastes

 The plant determines when boiler cleaning (or wa shing) is necessary for Karn Units 3 and 4 based on gallons of oil burned. When cleaning is required, the boiler is shutdown and cleaned using water wash. The water used is plant serv ice water (Saginaw river water). There are no chemicals added to the boiler water wash. Used boiler water wash is transferred to the Karn ash ponds.

 Karn Units 3 and 4 boilers are usually cleaned twice a year. Karn has to balance cleaning the boilers with the efficiency of the units. Time and money are lost when the boiler is shut down for cleaning; however, when the boiler is not clean, the ash that has coated the reheater, superheater, and economizer tubes/surfaces de creases the efficiency of the boiler. Karn/Weadock stated that when the Karn Un its 3 and 4 boilers are not clean, they are typically about 10 percent less efficient than when clean.

 Unlike Karn Units 3 and 4, the coal-fired units on site produce so much ash that soot blower operation is necessary to mainta in efficiency. The coal ash th at collects on the water wall and steam tubes affects the heat absorption rate. The soot blowers, which consist of rotating lances that eject compressed air, run frequently while the unit is operating to remove the ash off the wall and tubes. Air pollution control is no t an issue, as would be with Karn Units 3 and 4, because the coal-fired units are equipped with ESPs. Water lances are also used while the unit is operating, but less frequently, to clean the water wall/tube s of the coal-fired boilers. Water from this operation immediately evaporates.

 Karn/Weadock stated that the Karn Units 1 and 2 boilers are chemically cleaned every seven years. Thermal evaporation of the metal clean ing waste is preferred by the plant, but the waste can be treate d for discharge.

 Karn/Weadock operates two chemical treatment ponds systems on site, one for Karn and one for Weadock. The metal cleaning wastes are tr eated, transferred to the respective ash ponds, and ultimately discharged via Outfall 001A in compliance with the terms and conditions of the NPDES permit.Page 10

 Plant personnel stated that tr eatment depends on the type of waste entering the chemical treatment site. Typically the process focuses on se ttling out iron and copper so that limits are met prior to transfer to the ash ponds. Th e Karn and Weadock Unit boiler cleaning waste steam consists of boiler metal cleaning waste (typical metals , minute amount of EDTA, iron, and copper) plus initial rinse water. Cleanin gs are typically performed on each boiler once every 5-7 years. Karn Unit 1 has been trea ted once since 2000 using the Karn Chemical Treatment Facility (CTF). The Unit 1 boiler cleaning waste stream was around 90,000 gallons. Unit 2 was last treated using the Ka rn CTF in 2004. The Unit 2 boiler cleaning waste stream was approximately 140,000 gallons. The CTF waste stream was treated to NPDES standards before mixing it with other wast e streams in the ash pond. Weadock Unit 7 has been treated twice since 2000, last treated in 2007 using the same process in the Weadock CTF. The Unit 7 boiler cleaning waste stre am was 70,000 gallons. Weadock Unit 8 has only been treated once since 2000 us ing the same CTF process. The Unit 8 boiler cleaning waste stream was 70,000 gallons.Table 1. Site Visit AttendeesNameOrganization (Representing)TelephoneE-mailRick Hall CECO KW Environmental(989) 891-3464 rghall@cmsenergy.comGary Dawson CECO LWM Corp (517)788-2432 gadawson@cmsenergy.comJR Register CECO LWM CorpNot provided Not providedJenny Crawford CECO LWM Corp (517)788-1469 jacrawford@cmsenergy.comDave MarshallCECO, Site Ash Handling SupervisorNot provided Not providedDave WalterCECO, Karn 1&2 Production LeadNot provided Not providedButch BraunCECO KW Dry Fly Ash SystemEngineerNot provided Not providedJim LalondeCECO, Karn 1&2 ProductionEngineerNot provided Not providedRoberto Falco CECO, Results Supervisor Not provided Not providedDennis Dobbs CECO, Site BusinessManager Not provided Not providedLarry Dewitt CECO, Site ProductionManager Not provided Not providedDonna Hill UWAG/Southern Co.(205) 257-5234 dbhill@southernco.comRon Jordan EPA/Office of Water(202) 566-1003 jordan.ronald@epa.govJezebele AliceaVirellaEPA/Office of Water (202) 566-1755 alicea.jezebele@epa.govSarah Holman ERG (Contractor to EPA) (703) 633-1661 sarah.holman@erg.comElizabeth Sabol ERG (Contractor to EPA)(703) 633-1659 elizabeth.sabol@erg.com