ML101060515

"Draft Supplement" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.

Comment (2) of Ginger L. Melton, on Behalf of Dominion Energy Kewaunee, on Draft Supplement 40 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants

ML101060515
Person / Time
Site:	Kewaunee
Issue date:	04/13/2010
From:	Melton G Dominion Energy Kewaunee, Dominion Resources Services
To:	Rulemaking, Directives, and Editing Branch
References
10-116, 72FR6065 00002, FOIA/PA-2010-0209
Download: ML101060515 (23)

Text

I Y Mendiola, Doris

Subject:

FW: 10-116 App for Renewed Oper. License Comments on Draft Supp. 40 To the Generic Env. Impact Statement KPS Attachments:

001_SerialNo.10-116.pdf From: Ginger L Melton [1]

Sent: Tuesday, April 13, 2010 3:42 PM To: Tam, Peter; Daily, John

Subject:

10-116 App for Renewed Oper. License Comments on Draft Supp. 40 To the Generic Env. Impact Statement KPS Please note my email address has changed to." giner.Lmelton@dom.com As a result of the VSP and vacant slots, supervisors are requested to forward to the correct individuals in their organization.

Ginger L. Melton Administrative Assistant III Dominion Resources Services Nuclear Licensing 5000 Dominion Blvd Glen Allen, VA 23060 (804) 273-4391 c#

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.4 Do minion April 12, 2010 United States Nuclear Regulatory Commission Serial No.:

10-116 Attention: Document Control Desk LR/MWH RO Washington, DC 20555-0001 Docket No.:

50-305 License No.:

DPR-43 DOMINION ENERGY KEWAUNEE, INC. (DEK)

KEWAUNEE POWER STATION APPLICATION FOR RENEWED OPERATING LICENSE COMMENTS ON DRAFT SUPPLEMENT 40 TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT By letter dated January 29, 2010, the Nuclear Regulatory Commission (NRC) issued Draft Plant-Specific Supplement 40 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants (GElS)," regarding the license renewal application (LRA) for Kewaunee Power Station. Enclosed with the letter was a copy of the Federal Register notice announcing the availability of the GElS and the opportunity to submit comments.

Dominion Energy Kewaunee, Inc. (DEK) has reviewed Supplement 40 to the draft GElS and considers the conclusions to be an accurate and factual representation of the environmental conditions associated with plant operation during the license renewal period.

The attachment to this letter provides DEK comments and clarifications concerning the content of the draft GELS, Supplement 40.

Should you have any questions regarding this submittal, please contact Mr. Paul C.

Aitken at (804) 273-2818.

Very truly yours, Leslie N. Hartz Vice President - Nuclear Support Services

Serial No.10-116 Docket No.: 50-305 Comments on Draft GELS Supplement 40 Page 2 of 3

Attachment:

1. Dominion Energy Kewaunee Comments on Draft Supplement 40 to the Generic Environmental Impact Statement for License Renewal

Enclosures:

A. Hazardous Materials Certification of Registration for Registration Year(s) 2009-2010 (Reg. No. 061709 551 056R). Issued to DEK 6/18/2009.

Expiration date 6/30/2010 B. Tennessee Radioactive Waste-License-for-Delivery Number T-WI003-L10.

Expiration date 12/31/2010 C. Generator Site Access Permit Number 0704004220 for DE'K.

Expiration date 6/28/2010 D. Kewaunee Well Usage Estimation Spreadsheet

References:

1. Letter from Bo M. Pham (NRC) to D. A Heacock (DEK), "Notice of Availability of the Draft Plant-Specific Supplement 40 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (GELS) Regarding Kewaunee Power Station (TAC No. MD9409)," dated January 29, 2010. [ADAMS Accession No. ML093280799]

Commitments made in this letter: None.

Serial No.10-116 Docket No.: 50-305 Comments on Draft GELS Supplement 40 Page 3 of 3 cc:

Chief, Rulemaking and Directives Branch U.S. Nuclear Regulatory Commission Division of Administrative Services Office of Administration, Mailstop TWB 5B01 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Regional Administrator, Region III 2443 Warrenville Road Suite 210 Lisle, IL 60532-4532 Mr. P. S. Tam, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, Mail Stop 08-H4A 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Daniel Doyle Environmental Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11F1 Washington, DC 20555-0001 Mr. John Daily License Renewal Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-11F1 Washington, DC 20555-0001 NRC Senior Resident Inspector Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 David Hardtke Chairman - Town of Carlton E2334 Lakeshore Road Kewaunee, WI 54216

Serial No.: 10-116 ATTACHMENT 1 DOMINION ENERGY KEWAUNEE COMMENTS ON DRAFT SUPPLEMENT 40 TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT FOR LICENSE RENEWAL KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 1 of 8 Executive Summary Page xx DEK Comment:

In the first row of the table, the Human Health impact of KPS License Renewal is specified as 'SMALL TO MODERATE'.

This is inconsistent with the conclusions elsewhere in the document where the NRC has concluded that the human health impact from continued operation of KPS during the license renewal term would be 'SMALL'.

Section 1.9 Status of Compliance Page 1-9, Table 1-2, Row 3 DEK Comment:

DEK has received a renewed certificate of registration for shipment of hazardous materials (Reg. No. 061709 551 056R), provided in Enclosure A. The expiration date of the renewed certificate of registration is 6/30/2010.

Section 1.9 Status of Compliance Page 1-10, Table 1-2, Row 3 DEK Comment:

DEK did not renew Permit number 0044-48-08 since KPS no longer ships radioactive waste to South Carolina.

Section 1.9 Status of Compliance Page 1-10, Table 1-2, Row 4 DEK Comment:

DEK has received a renewed license to ship radioactive material to Tennessee (License number T-WI003-L10), provided in Enclosure B. The expiration date of the renewed license is 12/31/2010.

Section 1.9 Status of Compliance Page 1-10, Table 1-2, Row 5 DEK Comment:

DEK has received a renewed Generator Site Access Permit for Utah (Permit No.

0704004220), provided in Enclosure C. The expiration date of the permit is 6/28/2010.

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 2 of 8 Section 2.1.1 Reactor and Containment Systems Page 2-5, Line 11 DEK Comment:

DEK believes "1722" should be changed to "1772." Per the Kewaunee Power Station Facility Operating License (License DPR-43) paragraph 2.C.(1), "Maximum Power Level," DEK is authorized to operate the facility at a steady-state power level not in excess of 1772 megawatts (thermal).

Section 2.1.1 Reactor and Containment Systems Page 2-5, Lines 14 to 15 DEK Comment:

DEK recommends changing "two reactor coolant pumps" to "onei reactor coolant pump."

Each of the Kewaunee reactor coolant loops contains one steam generator and one reactor coolant pump. The Kewaunee USAR Section 4.2 provides a description of the reactor coolant system and design.

Section 2.1.5 Power Transmission Systems Page 2-12, Lines 6 to 8 DEK Comment:

The 50-foot buffer indicated in the statement, "Additionally, there is a 50-foot (15-m) minimum buffer between the ROWs and any waterways and wetlands; however, buffers can vary up to 200 feet (61 m), based on agreements with the landowners or the State,"

implies that a restriction on vegetation management is in place. However, within 50 feet of waterways and wetlands, selective hand-cutting is an acceptable means of vegetation management.

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 3 of 8 Sections 2.1.6 and 2.1.7 Page 2-14, Line 27, and Page 2-15, Line 20 DEK Comment:

Two different numbers (approximately 400,000 gpm and 401,200 gpm, respectively) are provided for circulating water flow with two pumps running. While both numbers are correct (401,200 gpm is the rated design flow), DEK suggests replacing both sentences containing these values with the following:

"The flow rate through the circulating water system is approximately 400,000 gpm when both circulating water pumps are running."

Section 2.1.7.1 Groundwater Use Page 2-15, Line 11 DEK Comment:

The two on-site groundwater wells are used for the station's potable water supply. DEK suggests adding these on-site groundwater wells to the list of ground water uses in Line 11.

Section 2.1.7.2 Surface Water Use Page 2-15, Line 27 DEK Comment:

DEK suggests inserting "in the intake forebay" after the words "the water level" to clarify that the water level at the intake forebay is approximately 571 feet when two of the plant's circulating water pumps are in service.

Section 2.2.3.1 Kewaunee Power Station Water Supply Wells Page 2-19, Lines 29 to 30, and Page 2-20, Table 2-1.

DEK Comment:

The statement, "The KPS wells typically do not withdraw ground water during the summer months" is incorrect. The KPS wells withdraw ground water during all months.

The values in Table 2-1, Potable Water Usage (Gallons) at Kewaunee Power Station, between August 2008 and February 2009 are the result of equipment problems. New flow totalizers were installed in March of 2009. Details of monthly and average daily water use from March to December 2009 are provided in the Well Usage Estimation Spreadsheet in Enclosure D.

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 4 of 8 Section 2.2.4 Surface Water Resources Page 2-21, Line 17 to Page 2-22, Line I DEK Comment:

DEK believes the term "two to three times per quarter" should be changed to "two to three times during the duration of the permit." This proposed change is consistent with the Wisconsin Pollutant Discharge Elimination System (WPDES) Permit No. 0001571-07-0, Sections 3.2.1.6 and 3.2.3.3 which provides the requirements for Whole Effluent Toxicity (WET) testing at KPS, including required testing frequencies.

Section 2.2.5 Aquatic Resources Page 2-25, Line 34 DEK Comment:

DEK believes that the year "1983" should be changed to "1893."

Section 2.2.5 Aquatic Resources Page 2-26, Lines 31 and 32 DEK Comment:

Regarding the following sentence: "Native fish that consume smelt may have a decreased ability to successfully reproduce because smelt are rich in thiaminase, an enzyme that destroys thiamin, which is necessary for embr.o development."

DEK believes that "smelt" in these sentences should be changed to "alewives."

Section 2.2.6 Terrestrial Resources Page 2-30, Line 1 DEK Comment:

This line begins with the phrase, "DEK actively manages the Joe Krofta Memorial Forrest..."

DEK suggests deleting the word "actively" because use of this term is subject to wide interpretation.

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 5 of 8 Section 4.5.2 Entrainment Page 4-4, Line 19 DEK Comment:

The year of the Second Circuit Court of Appeals decision in Riverkeeper vs. EPA was 2007, not 2009 as indicated in the Draft GELS. Therefore, DEK believes the year "2009" should be changed to "2007," which is the correct date of the court decision.

Section 4.5.3 Impingement Page 4-10, Line 27 DEK Comment:

Regarding the sentence: "A total of 31 species of fish were collected in entrainment samples during the study year (See Table 4-8)." DEK believes "entrainment" should be changed to "impingement." The subject of this section of the GEIS is impingement and Table 4-8 is a list of impinged fish species.

Section 4.5.3 Impingement Page 4-15, Line 19 DEK Comment:

Regarding the sentence: "However, the staff concludes that none of mitigation measures considered would eliminate adverse entrainment impacts..." DEK believes that "entrainment" should be changed to "impingement." The subject of this section of the GElS is impingement.

Section 4.9.6 Historic and Archaeological Resources Page 4-33, Line 15 DEK Comment:

DEK believes Line 15 should be changed to read "DEK has established a Cultural Resources Protection Plan..."

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 6 of 8 Section 4.9.6 Historic and Archaeological Resources Page 4-33, Lines 32 to 33 DEK Comment:

DEK recommends changing this sentence to read "In addition, KPS forwarded its Cultural Resources Protection Plan to the WHS for review and comment. To date, no comments have been received." Letter Serial No. MISC-2009-0057, dated September 30, 2009, forwarded the Kewaunee Power Station Cultural Resources Protection Plan to the Wisconsin Historical Society.

Section 4.11.4 Cumulative Impacts on Socioeconomics Page 4-46, Lines 35 to 37 DEK Comment:

This sentence should be changed to read "DEK has also established a 'Cultural Resources Protection Plan' to improve the protection of archaeological resources at KPS."

Section 5.2.5 Cost Benefit Comparison Page 5-6, Line 15 DEK Comment:

DEK recommends changing the term "a-train 'closed' cooling water pump" to "a-train

'component' cooling water pump."

Section 5.2.5 Cost Benefit Comparison Page 5-6, Line 31 DEK Comment:

DEK believes the term "a diesel building" should be changed to "an EDG room."

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 7 of 8 Section 5.2.5 Cost Benefit Comparison Page 5-6, Line 33 DEK Comment:

DEK recommends changing "Open doors for alternate (diesel generator (DG) room cooling)" to "Open doors for alternate DG room cooling."

Sections 8.1, 8.2, 8.3, 8.4 and 8.5 Tables 8-1, 8-2, 8-3, 8-4 and 8-5 DEK Comment:

In the sixth row of each table, the socioeconomic impact of continued KPS operation is characterized as 'SMALL TO MODERATE'. This appears to be inconsistent with the conclusions elsewhere in the document where the staff analyses of environmental impacts of alternatives to license renewal conclude that the socioeconomic impact of continued KPS operation would be 'SMALL'. (For example see line 32 on page xvii and Table 4-17 on page 4-48).

Section F.3.2. Review of Dominion Energy Kewaunee, Inc.'s Process Page F-18, Line 23 DEK Comment:

DEK recommends changing "the 'central' cooling water (CCW)" to "the 'component' cooling water (CCW)."

Section F.3.2. Review of Dominion Energy Kewaunee, Inc.'s Process Page F-18, Line 43 DEK Comment:

DEK recommends changing "motor 'drive' auxiliary feedwater" to "motor 'driven' auxiliary feedwater."

Serial No.: 10-116 Docket No.: 50-305 Comments on Draft GElS Supplement 40 Page 8 of 8 Section F.6.2. Review of Dominion Energy Kewaunee, Inc.'s Cost-Benefit Evaluation Page F-37, Line3l DEK Comment:

DEK recommends changing "(DEK Electric Kewaunee, 2009b)" to "(Dominion Energy Kewaunee, 2009b)."

Serial No.: 10-116 ENCLOSURE A Hazardous Materials Certification of Registration for Registration year(s) 2009-2010 (Reg. No. 061709 551 056R)

Issued to DEK 6/1812009 Expiration Date 6/30/2010 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION O

HAZARDOUS MATERIALS CERTIFICATE OF REGISTRATION FOR REGISTRATION YEAR(S) 2009-2010 Registrant:

DOMINION ENERGY KEWAUNEE INC Attn: THEODORE L. MALONEY N490 HIGHWAY 42 KEWAUNEE, WI 54216 This certifies that the registrant is registered with Ihe U.S. Department of Transportation as required by 49 CFR Part 107, Subpart G.

This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alttr or falsify this document.

Reg. No: 061709 551 056R Issued: 6/18/2009 Expires: 6/30/2010 Record Keeping Requirements for the Registration Program The following must be maintained at the principal place of business for a period of three years from the date of issuance of this Certificate of Registration:

(1) A copy of the registration statement filed with PHMSA; and (2) This Certificate of Registration Each person subject to the registration requirement must furnish that person's Certificate of Registration (or a copy) and all other records and information pertaining to the information contained in the registration statement to an authorized representative or special agent of the U. S. Department of Transportation upon request.

Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement must keep a copy of the current Certificate of Registration or another document bearing the registration number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers and semi-trailers not included) used to transport hazardous materials subject tW the registration requirement. The Certificate of Registration or document bearing the registration number must be made available, upon request, to enforcement personnel.

For information, contact the Hazardous Materials Registration Manager, PHH-62, Pipeline and Hazardous Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey Avenue, SE,, Washington, DC 20590, telephone ('202) 366-4109.

Serial No.: 10-116 ENCLOSURE B Tennessee Radioactive Waste-License-for-Delivery Number T-WI003-LI0 Expiration Date 12/3112010 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

State of Tennessee DEPARTMENT OF ENVIRONMENT AND CONSERVATION Division of Radiological Health 3rd Floo~r, L & C Annex 401 Church Street Nashville., TN 37243-1532 December 17, 2009 Dominion Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Attention: Don Allison, Supervisor-Radioactive Material Control RE: Radioactive Waste License-for-Delivery Mr. Allison:

Attached to this letter is your Tennessee Radioactive Waste-License-for-Delivery Num-ber T-WI003-L10 issued with an expiration date of December 31, 2010.

If we may be of further assistance, please feel free to contact me at (615) 532-0405.

Sincerely,,

Michael Singleton Health Physicist Division of Radiological Health Attachments:

State of Tennessee Department of Environment and Conservation 3rd Floor, L & C Annex 401 Church Street Nashville, TN 37243-1532 LICENSEE:

Dominion Kewaunee Nuclear Power Station Delivery License Number: T-WI003-LIO N490 Highway 42 Kewaunee, WI 54216 Date of Expiration:

December 3!.2010 Gentlemen:

Pursuant to Tennessee Department of Environment and Conservation Regulat ons, and in reliance on statements and representations made by the licensee in application dated November 23, 2009, and Certificate of Nuclear Energy Liability Insurance dated October 15, 2009, a license is hereby issued authorizing the licensee to ship radioactive material described beflow to a licensed disposal/processing facility within Tennessee. This license is subject to all applicable rules and regulations of the Tennessee Department of Environment and Conservation and orders of the Division of Radiological Health, now or hereafter in effect.

The license authorizes shipment of any radioactive material (except special nuclear material sufficient to form a critical mass) in any chemical and/or physical form and in a quantity not to exceed the possession limit of the licensed recipient.

The licensee is authorized to ship radioactive material from the facility located at:

Kewaunee Power Station N490 Highway 42 Kewaunee, WI.54216 into or within Tennessee to a disposal/processing facility that is licensed by Tennessee to receive such material.

The licensee shall comply with all applicable provisions of the regulations and conditions of the recipient facility's license.

Effective date of this license: January 1. 2010 For the Commissioner Tennessee Department of Environment and Conservation Date: December 17.2009 Byy:

MRichael Singleton Health. Physicist Division of Radiological Health

Serial No.: 10-116 ENCLOSURE C Generator Site.Access Permit Number 0704004220 for DEK Expiration Date 6/2812010 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

JON M. HUNTSMAN Governor GARY HERBERT L~eutenant Governor State of Utah

• DEPARTMENT OF ENVIRONMENTAL QUALITY Division of Radiation Control A.nn*da Smith Acting Executive Director Dane L Finerfrock Division Director 2

June 25, 2009 Mr. Don Allison Dominion Energy Kewaunee Inc.

N490 Highway 42 Kewaunee, WI 54216

Subject:

Generator Site Access Permit Number 0704004220 The Generator Site Access Permit for Dominion Energy Kewaunee Inc. is complete and

" approved. The expiration date is 6/28/2010.

If you have any questions, please call Edith Barker of my staff at (801) 536-0077.

.UTAH RADIATION CONTROL BOARD Dane L. Finerfrock, Executive Secretary Enclosure cc:

Allan Erichsen, EnergySolutions Jule Fausto, DRC TransportAtion Specialist Jeff 'Ginsburg, EnergySolutions 168 North 1950 Wet F0 Box 144850, Sall lake City, UT 84114-4850 telephone (801) 5364250 - facstmle (801) 533.4097

• www.dq.utah.gov Printed an 100% recycled paper

UTAH DEPARTMENT OF ENVIRONMENTAL QUAlITY DIVISION OF RADIATION CONTROL GENERATOR SITE ACCESS PERMIT ACCESSING A LAND DISPOSAL FAC.IITY wITHIN UTAH UNDER THE PERMIT REQUIREMENTS IN R313-;6-3 R313-26 of the Utah Radiation Control Rules establishes the terms for a Generator Site Access Permit Program which authorizes waste generators, waste processors and waste collectors to deliver radioactive wastes to a land disposal facility located within the state.

Name: Dominion Energy Kewaunee Inc.

Permit Number: 0704004220 Address: N490 Highway 42 IExpiration date,: 6/28/10 Kewaunee, WI, 54216 Password: 04qm34Sm Your password Is required to renew your pernit onfine.

Store this hi oreation In a secure location.

Conditions;

1.

The waste generator, waste processor and waste collector shall comply with the provisions of R3 13-26 and the requirements as set forth in R313-19-100.

2.

The permit number shall accompany all waste generator, waste processor and wa tecollertor shipments to the land dspos. facilities within the state of Utakh

3.

Generator SiteAccess pormittees shall be subject to the provisions of Rule R313-14 for violations of.

federal'regulations, state rules or requirements in the current land disposal facility opprating license regarding radioactive waste.packaging, transportation, labeling, notification, clasi*ification, marking, manifesting or description.

UTAH RADIATION CONTROL BOARD 4/27/07 DatAt ivo te f

Registration Date Activation Date r

mfd ecutive Secretary For secu reasons, your permit will not be adhte undl after a 72-4ouir w.itingperiod.

Please note. There will be an adjustment to the expiration date for on-line reneials. Pfqe allow 30 days for,xpiration adjusflnenl notification.

'Serial No.: 10-116 ENCLOSURE D Kewaunee Well Usage Estimation Spreadsheet KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Kewaunee Power Station 2009 Potable Water Usage Numbers Kewaunee Well Usage Estimation Spreadsheet End of Month Reading Well Well Month I

A 18 MonthlyUsage Monthly Usage Well IA I

Well IB (gpd)

Average Reading usage Date Total Usage (gals) per day (gph)

Average usage ner hr (gpm)

Average usage nl~r rai ner hr er min New totalizers installed on both pumps in March 2009. "A" totalizer installed on 3/2/09 and "B" installed 3/3/09.

Mar-09 Mar-09 Apr-09 May-09 Jun-09 Jul-09 Aug-09 Sep-09 Oct-09 Nov-09 Dec-09 60,484 23 3/3/09 14:20 Startup documentation.

1,688,654 23 1,688,654 23 3/31109 15:15 1,688,677 28.0 60,228 2509 41.8 2,313,528 1,135,989

.... 624,874 1,135,966 4/30109 14:15 1,760,840 30.0 58,776 2449 40.8 3,145,926 1,984,293 832,398 848,304 5/29/09 10:00 1,680,702 28.8 58,311 2430 40.5 5,083,026 1,984,293 1,937,100 0

6/30/09 8:00 1,937,100 31.9 60,692 2529 42.1 6,282,736 2,378,540 1,199,710 394,247 7/30/09 6:00 1,593,957 29.9 53,280 2220 37.0 7,249,895 3,210,934 1

967,159 832,394 8131/09 8:40 1,799,553 32.1 56,041 2335 38.9 8,181,820 3,963,829 931,925 752,895 9/30/09 8:40 1,684,820 30.0 56,161 2340 39.0 9,657,370 3,964,527 1,475,550 698 10/30/09 10:50 1,476,248 30.1 49,061 2044 34.1 9,962,159 5,097,970 304,789 1,133,443 11/30/09 11:00 1,438,232 31.0 46,384 1933 32.2 10,539,450 5,976,990 577,291 879,020 12130/09 8:35 1,456,311 29.9 48,707 2029 33.8 1 10;539,450 1

5,976,990 I

2009 Average gallon per da 5

Avg gpm f738.

3/29/2010