BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND

Transcription

1 BEFORE THE PUBLIC SERVICE COMMISSION OF MARYLAND IN THE MATTER OF THE APPLICATION ) OF CONSTELLATION POWER SOURCE ) GENERATION, INC. FOR A CERTIFICATE OF ) PUBLIC CONVENIENCE AND NECESSITY ) CASE NO. 0 AUTHORIZING THE MODIFICATION OF THE ) BRANDON SHORES GENERATING STATION ) IN ANNE ARUNDEL COUNTY, MARYLAND ) DIRECT TESTIMONY OF DORI J. COSTA On Behalf of: CONSTELLATION POWER SOURCE GENERATION, INC. Dated: October, 00

2 DIRECT TESTIMONY OF DORI J. COSTA 0 0 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. A. My name is Dori J. Costa, and my business address is Constellation Generation Group, LLC ( CGG ), 00 Brandon Shores Road, Baltimore, Maryland. CGG is an affiliate of Constellation Power Source Generation, Inc. ( CPSG ). Q. PLEASE DESCRIBE YOUR POSITION WITH CGG. A. For the past six years I have provided environmental, technical, regulatory, compliance and management support services to CPSG and other CGG affiliates. Q. PLEASE DESCRIBE YOUR EDUCATION AND YOUR BUSINESS EXPERIENCE. A. I graduated from Rutgers University in with a bachelor s degree in Chemical Engineering. I am currently pursuing a Masters in Management and Business Administration. In the six years I have worked for CGG, I have supported the business development and strategy organization, permitting new power plants, performing environmental due diligence for the acquisition of existing power plants, and providing environmental compliance support for existing assets. From until 000, I worked within the chemical industry providing environmental, health, and safety support both in management and technical roles. I also provided technology and best management practices transfer, as well as environmental management system development, at several chemical plants located domestically and internationally.

3 0 Q. PLEASE STATE THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING. A. The purpose of my testimony is to provide support for CPSG s application for a Certificate of Public Convenience and Necessity ( CPCN ) to retrofit Brandon Shores Generating Station ( Brandon Shores or the Plant ) existing Units and with air quality control systems ( AQCS ) comprised of flue gas desulfurization ( FGD ) systems, mercury ( mercury or Hg ) and acid mist controls, as well as other associated enhancements (collectively referred to as the Project ) as filed with the Maryland Public Service Commission ( Commission ) on August, 00. I will provide an overview of the existing plant and the proposed modifications. In addition, I will review the impacts associated with the construction and operation of the proposed project. Environmental impacts were analyzed by Golder Associates, Inc. and are found in the Environmental Analysis portion of the application filed on August, 00. Q. WHO ELSE IS TESTIFYING? A. Mr. Ken Kosky of Golder Associates, Inc. will testify regarding the air, visibility, and noise impacts resulting from this Project. As well, Jim Burkman of CGG will testify regarding surface water, wetlands, terrestrial and aquatic impacts. 0 Q. COULD YOU PLEASE PROVIDE AN OVERVIEW OF THE EXISTING BRANDON SHORES GENERATING STATION? A. Brandon Shores currently consists of two coal-fired generating units with a combined nominal generating capacity of approximately,0 megawatts

4 0 ( MW ). Built in an industrially zoned area of Anne Arundel County, Brandon Shores Unit began operation in, followed by Unit in. Brandon Shores is co-located on a -acre site with the H.A. Wagner Generating Station ( Wagner ). The site also includes an office, maintenance shops and warehouse complex known as the Fort Smallwood Road Complex ( FSRC ). Wagner consists of four units with a combined nominal generating capacity of,00 MW. Coal is delivered to the Brandon Shores site primarily by barge and stored in areas adjacent to Units and. In order to achieve environmental compliance, the Plant currently utilizes low-sulfur compliance coal, a hot-side electrostatic precipitator ( ESP ) and a selective catalytic reduction ( SCR ) system on each unit. Compliance coal has a sulfur content of about 0. percent by weight to comply with the current sulfur dioxide ( SO ) emissions limit of. pounds of SO per million British thermal units ( lbs/mmbtu ) allowed under federal regulations and the Plant s Title V permit. ESPs reduce the PM emissions to less than about 0.0 lb/mmbtu on average. SCR systems, when operating, reduce the nitrogen oxides ( NO x ) emissions to less than about 0. lb/mmbtu on average. Currently, Brandon Shores SCR systems are used to limit NO x emissions only during the ozone season - May to September. 0 Q. PLEASE PROVIDE AN OVERVIEW OF THE PROPOSED MODIFICATIONS. A. The Project will consist of the following components: Installation of a wet FGD system and associated facilities ( FGD system ) for each unit.

5 0 0 Installation of a fabric filter baghouse ( fabric filter ) on each unit. Installation of sorbent injection equipment for removal of mercury and sulfuric acid mist ( SAM ) for each unit. Installation of a single dual-flue 00-foot stack that will serve both units. Installation of enhancements on the steam turbine to improve efficiency of the steam cycle and any necessary enhancements to the transmission interconnection facilities at Brandon Shores. Upgrading the existing steam boilers to enhance performance. The upgrades may increase the maximum heat input of the units. Installation of material handling equipment for limestone, other AQCS reagents and gypsum. Reconfiguration of the existing coal yard to accommodate use of other coals and blending of coal. Installation of water and wastewater treatment facilities. Installation of materials handling systems for water and wastewater treatment solids and fabric filter solids. Q. WHY IS THIS MODIFICATION BEING PERFORMED? A. This Project is necessary for the Plant to remain operational and in compliance with Maryland s Healthy Air Act s ( HAA ) new emissions reductions requirements applied beginning in 00 in tandem with the federal Clean Air

6 Interstate Rule as well as the Clean Air Mercury Rule. The Project will substantially decrease the emissions of the primary air pollutants emitted from the Plant, including sulfur dioxide ( SO ), particulate matter ( PM ) and particulate matter with an aerodynamic diameter of 0 microns or less ( PM 0 ), mercury ( Hg ), and other air emissions. Mr. Kosky discusses the air related environmental attributes of the project in his testimony. 0 0 Q. ARE THERE ANY ENVIRONMENTAL CONSIDERATIONS ASSOCIATED WITH THIS PROJECT? A. Yes. This is a pollution control project and the project will result in significant reductions of air emissions. An Environmental Analysis, prepared by Golder Associates was submitted with the CPCN application filed August, 00. Q. PLEASE DESCRIBE THE POWER BLOCK ENHANCEMENTS? A. Project operation will require a significant amount of auxiliary electrical energy to operate equipment such as pumps, fans, conveyors, miscellaneous motors, controls, etc. At full load operations, the Project parasitic power demand is expected to approach approximately MW (total both units). The increase in auxiliary power use will directly impact the Plant s net output to the grid. In order to minimize the loss of net output as much as possible, the Project will include enhancements to existing equipment that will cost-effectively increase electrical generation. Power block enhancements will include an upgrade of the high pressure steam turbine steam path components to increase turbine efficiency. The results of this upgrade will improve heat rate and increase generator output at current steam

7 flow. The increased turbine efficiency will result in a reduced high-pressure steam turbine exhaust temperature. In order to compensate for the lower temperature, additional enhancements to the boilers will be needed, which include upgrades to the economizers, superheaters, upgrades to related process equipment, as well as requiring an increase in fuel derived heat input to the boilers. 0 Collectively, the power block enhancements are estimated to allow Brandon Shores to generate an additional 0 MW, which will offset the approximately MW of auxiliary load for the Project and provide a potential net gain of about MW of additional power (total both boilers). Enhancements are planned to take effect during or after the initial startup of the AQCS equipment. The additional output resulting from the power block enhancements may require enhancements to the electrical interconnection facilities between the plant and the on-site Baltimore Gas and Electric ( BGE ) switchyard. 0 Q. HOW WILL THIS PROJECT AFFECT THE RELIABILITY OF THE PLANT AND THE POWER IT GENERATES? A. Brandon Shores is currently the largest coal-fired electric generating plant in Maryland, with generation units second in capacity only to the state s nuclear units. According to the Power Plant Research Program ( PPRP ), Maryland s total generating capacity within the state is nearly,00 MW, and coal-fired generation currently provides almost 0 percent of the power. Providing more than 0 percent of the state s total generation capacity, Brandon Shores is a critical resource to the reliable supply of power to the State and the region. Maryland is part of the region served by PJM Interconnection, L.L.C. ( PJM ).

8 PJM serves about million people across all or part of states and the District of Columbia. Within the PJM region, there is approximately, MW of generation capacity serving a peak load of about, MW (as of Aug., 00). PJM projects a. percent annual growth rate in summer peak load in the Mid-Atlantic region. 0 The equipment sought for this Project will be obtained from manufacturers and suppliers with reputable histories of quality products and service. FGD is a proven, reliable pollution control technology. Redundant components will be incorporated into the Project where appropriate, based on good engineering practices. However, as with any mechanical system, there exists an opportunity for equipment failure or malfunction, especially during initial operation. The AQCS adds a considerable amount of new equipment to the Plant, and its integration adds complexity to the controls, thus increasing the potential for malfunctions and component failures over the current configuration. Initial operations may also have reliability risks, but a carefully designed and executed commissioning process for the Project will minimize such risks. 0 Q. HOW WILL MATERIALS BE HANDLED AT THE PLANT? A. The material handling systems for the Project will include: modifications to coal handling equipment and additions of equipment and systems for limestone receiving, handling and storage; gypsum handling, storage and barge loading; fabric filter solid waste handling; receipt and storage of other reagents; and handling of water and wastewater treatment sludges.

9 Modifications to Coal Storage and Handling Enhancements will be made to the existing Brandon Shores solid fuel (e.g., coal) storage and handling system to allow for the blending of solid fuels to achieve the most optimal fuel characteristics including fuel sulfur content. enhancements will be made to the existing conveying system and coal yard. These 0 Solid fuels will be unloaded by barge using the existing system. The new overland conveying system will be located around the southern portion of the existing longterm storage pile. A radial stacking conveyor for stockpiling fuel will be added at the end of this system. The pile arrangement will allow coal to be fed directly on to the existing underground reclaim belt or to be pushed to a new underground reclaim tunnel and conveyor. The new reclaim tunnel conveyor will send the fuel to a new transfer tower, which will allow the blended fuel to be directed to new conveyors that will be connected to either of the two existing conveyors. Additionally, a new single hopper reclaim tunnel and conveyor will be added near an existing transfer tower in order to convey coal from the existing fixed stacker pile area onto an existing conveyor via a new transfer tower. 0 Limestone Receiving, Handling and Storage Up to 0,000 tons of limestone will be delivered to the site annually. Limestone will be used to react with SO in the AQCS system, removing it from the gaseous stream by forming solid gypsum particles. The limestone will be primarily delivered to the facility in up to,000-ton barges, similar in size to those currently

10 used at the site, and will be unloaded by the existing Wagner Barge Unloader. It is expected that up to seven barges a week of limestone will be unloaded at the facility when operating at design conditions. Barge operations are expected to occur primarily during daylight hours. Lighting is provided for nighttime operations, when necessary. 0 The existing Wagner Barge Unloader, located at the east edge of the site along the Patapsco River and historically used to offload barged coal for the nearby Wagner Station, will be reconditioned and modified to serve as a limestone barge unloader, though it will retain its coal unloading capability as back up. To prevent overloading, the unloader buckets will be modified to account for the density difference between coal and limestone. The barge unloader and conveyor system will be sized to unload a barge in approximately - hours. There will be no redundant unloading equipment, since there will be adequate limestone available in the limestone storage area to allow for equipment repairs without causing a forced outage of the FGD system. 0 The conveyor system deposits limestone onto the active storage pile. The nominal capacity of the storage pile will be about days total at full plant load, including about days live storage and about days long-term storage (approximately,000 tons in all). Long-term storage should be adequate for a disruption in barge deliveries or conveyor malfunctions and allow truck deliveries to be arranged for a delay beyond on-site supply. 0

11 A front-end loader will be used to move limestone within the storage area to a low-profile reclaimer, transferring limestone via a new conveyor to two limestone day-silos located in the FGD system area. Each silo will have a capacity for at least a hours supply of limestone. In addition, an emergency bucket elevator that can be fed from a front-end loader in the event of conveyor outage will be installed at the limestone silos. Additional facilities will be installed to allow for limestone receiving and handling via truck or rail as alternative modes of transportation. Impacts from truck traffic are discussed in the traffic study submitted with the application. 0 0 Gypsum Handling, Storage, and Offloading System Synthetic gypsum will be created from the chemical reaction of wet limestone solution and gaseous SO inside the FGD system. The gypsum handling system will convey the commercial grade gypsum product from the FGD system to the gypsum storage area and then to a new barge loader on the Patapsco River. A conveyor system common to both units will move the gypsum from the outlet of the vacuum filters in the FGD area to the gypsum storage pile. The gypsum conveyor is non-redundant. In case of a conveyor outage, gypsum is diverted from the vacuum filters through emergency gates and chutes to a holding area outside the dewatering building from which it will then be transferred by frontend loaders into trucks for transport to the gypsum storage pile. The nominal capacity of the gypsum storage is about days (approximately,000 tons). The active gypsum pile will be stored a concrete slab base while the

12 inactive pile will sit on a compacted fill base. Both will be in an enclosure to protect the gypsum product from rainfall. There is sufficient storage area adjacent to the live storage pile to accommodate approximately ten days of inactive storage, if needed. Should the gypsum be out of commercial use specification, should the conveyor to the barge loader malfunction, or should the barges be unavailable, the inactive storage area will be utilized for a temporary stockpile until the problem is alleviated. Should a longer-term problem occur, the gypsum can be loaded onto trucks by a front end loader and transported offsite for reuse and/or disposal. 0 Gypsum will be reclaimed from the pile and conveyed to the barge loader that will be located in the river to the east of the existing Wagner barge unloader. Gypsum product will be removed from the site in up to,000-ton barges (depending upon what the gypsum purchaser provides). It is expected that up to barges per week of commercial grade gypsum could be loaded for transport depending on plant load, sulfur content of fired coal, and barge size. Loading of a barge will take only a few hours, depending upon the size of the barge. Up to,00,000 tons of gypsum may be removed from the facility annually. 0 To deliver the gypsum to the barges, several new components will be constructed in the Patapsco River in the immediate vicinity of the existing coal unloading pier and coal conveyors. A new gypsum conveyor will be constructed from the storage area to the barge loader, part of which will be over water. This conveyor will be supported on a

13 series of pile bents and concrete caps, similar to the supports for existing coal conveyors in the immediate vicinity. Approximately 0 pile-supported platforms will be placed within the approximately 00 ft over-water portion of the span between the towers. 0 The gypsum is conveyed from the storage pile to a new barge loader, where it is emptied into the waiting barge via a telescoping loadout chute. A new barge loader, or gypsum offload tower, will be constructed in the Patapsco River on a load cell placed adjacent to the existing coal unloading pier. The load cell is cofferdam of interlocking steel sheet piling that is driven into the dense silty fine sand of the riverbed, then filled with structural backfill and capped with reinforced concrete. The barge is moved under the loadout chute, using a winch and sheaves system or barge positioner, so that the entire barge can be filled with gypsum. Its position is limited laterally at the pier by cleats and fenders. Several new small load cells will be added to support the positioners, fenders and cleats for barge handling. Marine positioning dolphins will be strategically located along the existing pier. Their function will be to draw and secure an empty barge to the loading zone, and through a series of sheaves and winches, advance the receiving barge across the discharge chute, in order to completely fill the barge. 0 Certain activities related to this construction will require tidal wetland permitting which may also seek authorization to dredge a limited amount of sediments to allow access for barge-mounted pile drivers to construct the new components.

14 No dredging is required for limestone or gypsum barge access. The existing channel is maintained at - ft mean low water ( mlw ). Additional facilities will be installed to allow for the delivery of gypsum via truck or rail as alternative modes of transportation. 0 Other Reagents Receiving and Storage Lime, for use in the wastewater treatment system, sorbent, for mercury control, and sorbent for SAM control will all be delivered to the site by bulk-carrier truck. Each will be pneumatically transported to its own storage silo. The silos will be equipped with dust collection to capture reagent dust expelled with the transport air. Solid Waste Handling and Storage In the event solid by-products are unsold or beneficially reused, they will require disposal as solid wastes. Solid wastes may include fabric filter solids and sludge cake solids from the water and wastewater treatment systems. Fabric Filter Waste Handling and Storage The fabric filter waste (containing fly ash and spent sorbents) is conveyed pneumatically from the fabric filter collection hoppers to a dedicated silo. The transport air is exhausted through a dust collector mounted on the silo. 0 The waste is removed from this silo by gravity through pug mills, where water is mixed with the material to reduce dusting, into trucks for offsite disposal, beneficial reuse, or as a marketable commodity. This dustless unloader is

15 common practice in the industry and is the same type of unloading system currently in use at the plant to unload fly ash from the ash silo serving the ESP. The trucks will have covers for dust control during transport. 0 Sludge Waste Handling and Storage The dewatered sludge, in the form of approximately 0 percent solids cake, exits the filter presses in the wastewater treatment building and is directed by chutes into a lined roll-off container (probably 0 cubic yards in size) located within the building and below the filter presses. Each roll-off can accept approximately 0 tons of wet sludge, at which point it is removed and replaced with an empty container. The full containers will be sampled, have a fully watertight cover installed, and then be moved to a temporary storage area in the yard. Samples will be analyzed to demonstrate that the material is non-hazardous. Following receipt of sample analysis results, the container will be removed from the site by a waste management contractor and transported to a licensed disposal facility or to beneficial re-use vendor, emptied and returned to the parking area. 0 Q. DESCRIBE THE WATER SUPPLY, WATER AND WASTEWATER TREATEMENT SYSTEMS. A. Water Supply To provide adequate make-up water for the AQCS system, the Project will use effluent from the neighboring municipal sewage treatment plant. The Anne Arundel County Cox Creek Water Reclamation Plant, a publicly owned treatment

16 works ( POTW ), shares the southern boundary of the CPSG property and has a right-of-way across the property to pipe its discharge into the Patapsco River. The Project will consumptively use water, because: 0 The hot flue gas evaporates a considerable amount of water from the limestone slurry. This water is exhausted to the atmosphere via the stack. A stream of water is continuously removed to maintain the necessary slurry quality in the FGD system. Water is chemically bound in the gypsum product. Water leaves the Project as free moisture in both the gypsum product and water/wastewater treatment sludge. The Project will need up to approximately. million gallons per day (mgd) on an average basis. The POTW s effluent varies hourly, daily and seasonally, but daily average flow has always exceeded the Project s needs by a large margin. Although the source of the water is reliable from a water quality and availability perspective, CPSG is considering adding backup make-up water supply in the event of POTW supply interruption. An alternative is to access supply from existing sources on-site. 0 A lift station will be installed near the POTW to pump the effluent water to new water treatment facilities on the Project Site, where it will be further treated to a quality suitable for use in the FGD equipment and the plant service water system.

17 CPSG will ensure that flow measurement of the POTW s discharge to the river is maintained. 0 Water Treatment The water treatment system will treat the POTW effluent by clarification, filtration and chlorination before transfer to the makeup water storage tanks from which it will be transferred as required for use as FGD makeup and plant service water. Its water quality after treatment will be sufficient for all types of service, including FGD make-up, cooling, flushing, seal and service water. The suspended solids concentration of plant makeup water, after treatment, will be less than approximately mg/l. Effluent water is chlorinated then fed into a clarifier where coagulant and polymer are injected into the raw water feed to flocculate and settle suspended solids. Clear water exits the clarifier over the discharge weir and is processed through multimedia filters before being transferred to the make-up water storage tank. From this point the water is distributed to FGD makeup and various process operations. Sludge from the clarifier is pumped to the FGD wastewater treatment system sludge thickener, where it is mixed with the FGD wastewater sludge prior to being dewatered and shipped offsite for disposal. 0 The multimedia filters are backwashed periodically with filtered water to maintain performance. The backwash water from the filters is recycled to the clarifier.

18 Liquid sodium hypochlorite is injected upstream of the clarifiers to provide a residual chlorine level throughout the water treatment system, in the piping and in the FGD make-up water storage tank. This will ensure that sufficient treatment of the water supply has occurred prior to use within the AQCS system. WASTEWATER TREATMENT In order to maintain appropriate quality of the limestone slurry recirculating within the FGD system, a quantity of water, referred to as the chloride purge stream (CPS) is continuously removed and directed to wastewater treatment. The Project will include a wastewater treatment system for the FGD CPS. In 0 addition, a system will be provided for thickening and dewatering of sludges from both the water and wastewater treatment system. 0 CPS Treatment The system will use a two-stage process designed to produce a plant effluent that will meet water quality standards. It is comprised of physical/chemical treatment for removal of suspended solids and heavy metals by chemical precipitation, followed by biological processes to remove nitrogen. The treated effluent will flow by gravity to the existing retention pond, from which it is discharged to the Patapsco River along with other plant wastewaters. The Plant s National Pollution Discharge Elimination System ( NPDES ) permit will be modified to include this wastewater stream prior to commencement of operations. An equalization tank is installed upstream of the CPS treatment system to handle operating fluctuations in CPS flow.

19 Physical/Chemical Treatment Suspended solids and metals removal is a two stage process, removing suspended solids and metals as the insoluble hydroxide salt in the first stage and as the insoluble sulfide salt in the second stage. The clarified wastewater is treated with acid to reduce the ph to a concentration suitable both for the downstream biological treatment system and for discharge. 0 Biological Treatment Biological treatment provides nitrogen removal in a two stage process. In the first stage, nitrate is converted to nitrogen gas in an anaerobic environment. In the second stage, the wastewater is treated in an aerobic biological reactor for removal of residual organics and oxidation of ammonia to nitrate. 0 Q. HOW WILL STORMWATER RUNOFF BE ADDRESSED? A. As required by the NPDES permit, Brandon Shores currently employs best management practices ( BMPs ), as defined in its Storm Water Pollution Prevention Plan ( SWPPP ), to mitigate the discharge of pollutants at the facility by stormwater. The new industrial areas associated with the Project will be designed with both engineering and administrative controls and recorded into the SWPPP. Stormwater in the limestone and gypsum material storage areas will be directed to an on-site industrial wastewater treatment plant to remove the solids and adjust the ph prior to discharge. Other smaller areas within the AQCS area that have potential for solids contamination of stormwater will be similarly collected and directed to treatment. The remaining areas of the Project use inlet

20 protection and diversion to minimize pollutant transport from industrial activities into the stormwater system. Other tasks or area-driven BMPs are currently incorporated into the stormwater management for Brandon Shores and are detailed in the SWPPP. The SWPPP will be amended to incorporate features of the Project, as appropriate. 0 The operation of the limestone/gypsum barge loading and material handling system will not significantly increase the amount or type of pollutants transported to the Patapsco River by stormwater. This discharge is already addressed in the pending application for the Plant s NPDES permit for industrial discharges and authorized in the existing NPDES permit, and would not require further modification. These new areas will be noted in annual revisions to the SWPPP, which will address administrative or structural controls around the coal handling system, as necessary. Any collateral changes to the existing NPDES or draft NPDES permit will be addressed in an application to modify the permit. The County rules require a sediment and erosion control (grading) permit for this Project. An application has been submitted to obtain a County grading permit, which also address Chesapeake Bay Critical Area (CBCA) issues. A Notice of Intent ( NOI ) to use a general permit for discharge of stormwater from construction activity will also be submitted. 0 Q. HOW MUCH SOLID MATERIALS WILL BE GENERATED BY THE PROJECT? 0

21 0 0 A. The following is a summary list of solid materials and by-products types and estimated volumes generated by the Project:. Synthetic Gypsum: Up to about,00,000 tons/year. Off-spec Synthetic Gypsum: Up to about,000 tons/year. Water/Wastewater Sludges: Up to about,000 tons/year (at 0% solids). Fabric Filter Solids: Up to about,000 tons/year Final volumes are subject to change based on selection of the AQCS vendor and final design. Q. WHAT BY-PRODUCTS MAY BE USED BENEFICIALLY? A. Potentially all wastes generated by the Project may be used as marketable byproducts. However, initially the Project intends on marketing the synthetic gypsum. Potential buyers of this material are able to use gypsum to manufacture wallboard. CPSG intends to explore other marketable uses of other Project-generated solid materials. Q. HOW WILL SOLID WASTES BE DISPOSED? A. By-products that cannot be beneficially used will be disposed of in landfills as solid wastes. CPSG is currently active in securing contracts to ensure that these solid wastes are disposed of properly. All characterization testing, storage, handling, transportation, and disposal will be in accordance to local, state, and federal regulations. Q. WHAT CONCLUSIONS CAN BE DRAWN FROM THIS TESTIMONY?

22 A. CPSG submits that it will meet all of the applicable requirements under federal, state and local law to modify Brandon Shores. We respectfully request that the Commission grant approval of our application. Q. DOES THIS CONCLUDE YOUR TESTIMONY? A. Yes.