1 Site Visit Report

Crawford Generating Station

3501 South Pulaski Road Chicago, IL 60623 August 4, 2009

1.0 Background and Objectives

The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requi rements that reflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manufacturing facilities. As part of this process, EPA staff is visiting electric generato rs and manufacturers to better understand the cooling water intake structure (CWIS) technologies in use at facilities, including the sitespecific characteristics of each facility and how these affect the selection and performance of CWIS technologies. EPA is also visiting f acilities to better understand cooling water use and specific is sues or technologies that can affect 316(b) compliance. Crawford Generating Station (Crawford) was selected for a

site visit due to its urban location.

2.0 Facility Description

Crawford is located on a 70 acre site in Chicago and owned by Midwest Generation (Midwest). The facility w ithdraws cooling water from the Chicago Sanitary and Ship Canal 1 and began operations in 1923. The facility’s NPDES permit (IL0002186) expired on April 30, 2005, but has been administratively extended. Crawford employs approximately 110 workers.

3.0 Electricity Generation and Transmission

Crawford has 2 coal-fired generating units (Units 7 and 8) 2 with a total generating capacity of 581 MW. 3 The facility operates as a baseload generating station, 4

1 The canal was created to connect Lake Michigan with the Mississippi Rive r system, allowing for expanded shipping routes. Facility representatives noted that the canal receives all of the effluent from the area’s wastewater treatment plants and other similar effluent discharges; as such, the waterbody has not been designated as supporting contact recreation, has less stringent water quality standards than other state waters, and generally provides poor habitat. All of Chicago’s urban power plants were also sited on the canal, as it provides a constant depth and water flow du e to the system of locks and dams. The Army Corps of Engineers and Chicago Metropolitan Water Reclamation Department (MWRD) control the water levels within the canals; facility representatives noted that wa ter levels can fluctuate by several feet on a daily

basis.

2 Units 1 through 6 are currently retired. Unit 7 began operations in 1958 and Unit 8 in 1961. Units 7 and 8 use pulverized low sulfur Powder River Basin coal but are also capable of burning natural gas; however, fuel costs limit the use of gas to emergency situations. Coal is delivered by barge; the facility can no longer

receive coal via rail.

3 Unit 7 and Unit 8 have a generating capacity of 234 MW and 347 MW, respectively.

4 Crawford’s gross capacity rate for 2009 was 49.4% for Unit 7 and 56.7% for Unit 8.2 providing both electricity and voltage suppor t to the Chicago area. The facility has one scheduled outage per year for each unit; typically one unit is taken down in the spring and the other in the fall. Maintenance outages vary from 10-50 days, depending on the extent of activities required.

4.0 Cooling Water System and Intake Structure

Crawford employs a once-through cooling water system (CWS); it operates six single-speed circulating pump s (two for Unit 7 and four for Unit 8). The facility usually operates all of its pumps when generating, but may cycle off some pumps in the winter or during periods when the unit(s) are not operating. The design intake flow (DIF) is 593 million gallons per day (mgd) (including service water) and facility representatives estimated that the average actual intake flow (AIF) is approximately 500 mgd.

Crawford’s CWIS is on the shoreline at the end of a 400 foot canal off the Chicago Sanitary and Ship Canal. It is the original CWIS that began operations in 1923, but was expanded in 1927 to accommoda te the now-retired Units 5 and 6. The CWIS consists of a weir wall along th e bottom of the canal (to screen debris and sediment), an angled trash rack, and 11 coarse mesh (3/8”) vertical traveling screens; four are eight feet wide and seven are six f eet wide. The screens are washed (four per wash cycle) once per shif t and debris and fish are deposited in a perforated basket for dewatering and ev entually disposed of in a landfill. 5 Once per year, a diver is used to manually clean debris at th e trash racks; this cleaning takes approximately 3 weeks. The design th rough-screen velocity is 2.26 feet per second (fps).

An additional four intake bays are located in the screenhouse, but are not open to the source water; these pumps (2 screen wash and 2 fire suppression) withdraw from the common sump behi nd the traveling screens.

The facility’s NPDES permit does not contain any 316(b) requirements.

The facility discharges in to a second 400 foot long canal just upstream of the intake canal. A barge is positioned at the discharge canal to promote thermal mixing in the Chicago Sanitary and Ship Canal.

5.0 Impingement and Entrainment Information

In 2004-2005, Crawford conducted impingement and entrainment sampling in preparation for complying with the 2004 Phase II rule. Weekly impingement samples (not impingement mortality) were collected for a 24-hour period. A total of 7778 organisms were collected, consis ting of 41 species (27 of which are native species); eight species comprise d 94% of the biomass collected. The

5 Per state law, the facility is prevented from returning anything back to the waterbody.3 projected total annual impingement at the average actual intake flow was 53,000 organisms per year and 60,500 organi sms at the design intake flow.

Entrainment samples were collected during the spawning season (May through August). Weekly, the facil ity collected four six-hour samples and pumped them through a screen; 2227 organisms were collec ted, most of which were cypranids and clupeids. On an annualized basis (u sing the actual intake flow), Crawford’s annual entrainment was estimated to be 47.3 million eggs and larvae.

Facility representatives stat ed that they had not fina lized plans on how Crawford would have complied with the now-suspended 2004 Phase II rule.

6.0 Cooling Tower Feasibility

In 2008, Midwest conducted a f easibility study for converting several of its plants to closed-cycle cooling. The study (c onducted by Sargent & Lundy) concluded that there is sufficient space to install towe rs at Crawford, but that the cost would be approximately $145 million 6 (order of magnitude cost estimate). (See Attachments D, E, and F.) Facility repres entatives stated that financing and other considerations would likely render installation of coo ling towers at this site impractical.

7.0 Debris Handling

Crawford screens a very large volume of trash from the canal; approximately 60 tons of trash is removed each year. Facil ity representatives noted that Crawford is not permitted to return its screen wash water to the canal. Loading from other types of debris does not appear to be a major operational concern.

Facility representatives noted that typi cally, city workers collect trash by boat following storm events; converting to cl osed-cycle cooling would lead to a significant increase in the volume of tras h in the Chicago Sanitary and Ship

Canal.

Facility representatives noted that, in recent years, the CWIS has experienced significant clogging from nylon fibers in the source water; they continue to work with local officials to locate the source (suspected to be a large combined sewer overflow (CSO) discharge located di rectly upstream of the station).

6 The study assumed that mechanical draft towers w ith plume abatement and dr ift eliminators would be installed and that existing structures on the site would need to be relocated. The study did not consider permitting or other technical feasibility concerns (e.g., conflicts with existing piping); it was an order-ofmagnitude capital cost estimate only.4 8.0 Repowering/Future Uses

Facility representatives stat ed that there are no plans to expand the facility; they also noted that natural gas capacity in the area precludes repowering.

9.0 Cooling Ponds

There are no cooling ponds at the site.

10.0 Ownership

Crawford is owned by Midwest Generation, an investor-owned company and subsidiary of Edison International.

11.0 316(a)

The facility’s NPDES permit does not c ontain any 316(a) limits. The Chicago Sanitary and Ship Canal is a man-ma de waterway designed to convey POTW effluent and is manipulated to achieve flood control for the City of Chicago, as well as accommodate heavy commercial ba rge traffic. As such, it has less stringent water quality sta ndards for most pollutants, including temperature. Crawford has been consistently able to comply with the existing thermal limits such that no 316(a) variance has been required.

12.0 Ash Handling

Fly ash is sent to an offsite landfill, due to the use of activated carbon injection (ACI) for mercury control on both units. The ACI systems have been in service since July 1, 2008; pr ior to the start-up of thes e units, fly ash was sold for

beneficial reuse.

13.0 Air Emissions Controls

Crawford uses electrostatic precipitators for particulate control, overfired air for NOx reduction, and activated carbon to remove mercury.

14.0 Additional Information

Facility representatives also presented information on debris collection at the Joliet Station, located furt her downstream on the Lower Des Plaines River; that facility collects 30 tons of trash per year.

Facility representatives stated that many facilities owned by Midwest employ once-through cooling. Facility represen tatives stated that they had conducted impingement and cooling towe r feasibility studies at se veral of Midwest’s nearby facilities, including Joliet, Will County, and Fisk. The estimates were as follows:5 Joliet (Unit 6) $88 million to $109 million, Joliet (Units 7&8) $232 million to $296 million, and Will County $187 million to $233 million. Facility representatives provided detailed info rmation on Fisk Generating Station and EPA has prepared a separate re port outlining that information.

There has not been any determination ma de at this time for any of Midwest Generation’s 316(b)-affected facilities as to whether closed-cycle cooling systems are technically feasible, as the order-of-ma gnitude cost estimates did not consider permitting or other technical feasibility concerns (e.g., conflicts with existing piping, infrastructure, overhead power lines, proximity to airports, major highways, residential areas, etc.); it was an order-of-ma gnitude cost estimate only.

The facility installed a h eat treatment system for zebra mussel controls; an adjustable gate was added to the discharg e point and a concrete pipe was installed

to allow heated effluent to be recirculated to the intake canal. To date, the facility has not used the system.

The facility has positioned a river barge across the intake canal in an attempt to exclude floating debris and prevent recirculation of heated effluent.

Facility representatives stat ed that the city has a signi ficant problem with CSOs. Approximately 30-60 CSOs occur each year from over 300 separate discharges throughout the Chicago Area Waterway, sendi ng untreated sewage into the canal; this often depletes the entire supply of dissolved oxygen fr om the waterbody, further degrading the lo ng-term habitat quality.

Facility representatives expressed disappoi ntment that restoration is no longer a compliance alternative; Midwest has prev iously participated in restoration projects and would prefer to take that approach again. Facility representatives noted that state resource ag encies are often very supportiv e of restoration projects. As an example, Midwest has worked w ith the Illinois Department of Natural Resources (DNR) at one of their cooli ng ponds at a now-closed power plant in Illinois to develop a healthy and popul ar recreational fi shery. Facility representatives also noted that installi ng closed-cycle cooling, especially at facilities located on a man-made, artificial ly controlled waterways such as the Chicago Sanitary and Ship Canal, could pr ove to be a lost opportunity to further

protect or restore existing fisheries in other le ss urbanized/impacted waterways and help state agencies in maintainin g their resources; instead, closed-cycle cooling may actually benefit invasive sp ecies, by reducing the culling of those species via impingement and entrainment.

Invasive species have come to the fore front of public attention in the months following the site visit, beginning with Rotenone treatment of 6 miles of the Chicago Sanitary and Ship Canal in ea rly December 2009 in or der to attempt to eradicate Asian Carp from the waterway before they enter Lake Michigan. The State of Michigan has sued the State of I llinois, the US Army Corps of Engineers,6 and the Metropolitan Water Reclamation District of Greater Chicago (who controls the ship canal), demanding that all pathways to Lake Michigan be closed—an action that would significantly impact all Chicago Sanitary and Ship Canal users. A comprehensive Asian Ca rp Control Strategy has been developed by the US Army Corps of Engineers, US EPA, USFWS, IDNR, and other Federal and State natural resource agencies, larg ely targeting the Ch icago Sanitary and Ship Canal as the last line of defense against Asian Carp invasion of the Great Lakes. As such, they are looking to im plement a series of additional barriers, deterrents, and eradication efforts on this waterway—all of which will impact the existing indigenous aquatic community more than any power plant’s impingement

or entrainment effects.

Consideration of additional impingement and entrainment controls on this waterway, in light of recent and conti nuing Asian Carp defense planning seems counter to these efforts, which have state, federal and international support.

Attachments

Attachment A List of Attendees

Attachment B Aerial Photos

Attachment C PowerPoint Presentation (August 4, 2009) Attachment D Engineering Diagrams fo r Cooling Tower Locations at Crawford Attachment E Summary of costs from Sa rgent & Lundy cooling tower feasibility study Attachment F Executive Summary of Fi nal Draft Impingement Mortality and

Entrainment Characterization St udy, Crawford Station December

20077 Attachment A--Lis t of Attendees

Paul Shriner, EPA Jan Matuszko, EPA Sean Ramach, EPA Region V John Sunda, SAIC Kelly Meadows, Tetra Tech Julia Wozniak, Midwest Generation Bill Constantelos, Midwest Generation Luke Ford, Midwest Generation Dan Dammer, Midwest Generation Brenda Brock, Midwest Generation

# Copyrighted page/s removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder.

Please contact the EPA Docket Center, Public Reading Room to view this document.

Address: 1301 Constitution Ave, NW

Room 3334 Washington, DC 20004

Telephone: 202-566-1744

Fax: 202-566-9744
Email: docket-customerservice@epa.gov9 Attachment C—PowerPoint Presentation (August 4, 2009)

Please see the attached materials.

Attachment D—Engineering Diagrams for Cooling Tower Locations at Crawford

Please see the attached materials.

Attachment E—Summary of costs from Sa rgent & Lundy cooling tower feasibility study

Table ES-1 (from draft Sargen t and Lundy April 2008 report) Cost Summary of All Wet/Dry, Wet/Dry Convertible, and Wet Non-Convertible Towers, and Wet/Dry O&M Costs

Unit Station

Total

Gross

MW Capital Cost Wet/Dry Towers ($) Capital

Cost Wet

Convertible to Wet/Dry ($) Capital

Cost

Wet Only ($) Annual

O&M

Cost – Wet/Dry ($) Wet/Dry Capital cost ($) per kW

Fisk 19 348 $119,952,645 n/a* n/a* $1,926,728 $345

Crawford

7&8 585 $144,652,125 n/a* n/a* $3,579,632 $247

*Note that wet only towers would not be able to be permitted at these facilities, due to their close proximity to residential ar eas and major highways/roads/airports.

Attachment F—Executive Summary of Fi nal Draft Impingement Mortality and

Entrainment Characterization Stud y, Crawford Station December 2007

Please see the attached materials.