ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
July 22, 2005 RECEIVE[)
Exelon Generation Company, L.L.C .
)
Quad Cities Nuclear Power Station
)
JUL 2
1
2005
STATE OF ILLINOIS
Pollution Control Board
Petitioner,
)
v .
)
IEPA -
44-
(Provisional Variance-Water)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent
.
)
Re :
Provisional Variance From Special Condition 6B
of NPDES Permit IL0005037
The Agency has completed its technical review of the attached provisional variance
request submitted by Exelon Generation Company, L .L.C. Quad Cities Nuclear Power
Station (Exelon's Quad Cities Station) on July 21, 2005 (Attachment A). Based on the
review, the Agency GRANTS a provisional variance subject to specific conditions set
forth below for a period of 45 days or until the additional 100 provisional variance
excursion hours are utilized, whichever occurs first
.
Exelon's Quad Cities Station is seeking a provisional variance from Special Condition 6B
of its NPDES Permit IL0005037 (Attachment B), which limits the number of excursion
hours and the maximum temperatures
.
Exelon's Quad Cities Station is a nuclear-fueled steam electric generating facility located
on the Mississippi River at River Mile 506.8 near Cordova, Illinois
.
It operates its
cooling water system in open cycle mode. Cooling water is taken from the Mississippi
River, passes through the plant system and is then discharged by diffusers into the
Mississippi River. Maximum design flow of this system is 2,253 efs
.
Exelon's Quad Cities Station seeks a variance from Special Condition 6B of NPDES
Permit IL0005037. This condition establishes the thermal discharge ranges for Exelon's
Quad Cities Station
.
Additionally, it allows Exelon's Quad Cities Station excursion
hours from these limits. Excursion hours are periods of time in which the temperature at
the edge of the mixing zone may be 3°F warmer than the temperature limit in the permit
.
Exelon's Quad Cities Station may only utilize 1% (87 .6) of the hours in a 12-month
period ending with any month as excursion hours. The permit also requires that water
temperature in the Mississippi River at the edge of the mixing zone shall at no time
exceed by 3°F the maximum limits of 86°F in July and August and 85°F in September
.
Normally, Exelon's Quad Cities Station can operate within these limits because the
ambient temperature in the Mississippi River at the intake points (or above the plant)
remain below the non-excursion hour temperature limit
.
Ordinarily, the Mississippi
River has significant river
flows
.
These significant river
flows
act to enable Exelon's
Quad Cities Station to meet its permit conditions even when ambient temperatures
approach non-excursion hour temperature limit . However, at this time the Mississippi
River is at extremely low
flow
condition. This low
flow
condition coupled with high
ambient river temperatures is the basis of the need for this provisional variance .
Inlet river temperatures have been ranging around 83°F to 86°F. The long range weather
forecasts predict the current drought and temperature conditions the continue for several
more weeks. This could cause the ambient river temperature to exceed non-excursion
hour temperature limits for significant periods of time
.
Current predictions indicate
Exelon's Quad Cities Station will use all of its permitted excursion hours around July 23,
2005. Petitioner claims the only alternative available for the station, other than relief
pursuant to this provisional variance request, is to shut down the station . Derating the
facility will not resolve this situation due to the high ambient temperatures . In addition,
power demand is extremely high due to the current weather conditions
.
The Agency has reviewed the requested provisional variance and has concluded the
following
:
1 . The environmental impact from the requested relief will be closely monitored and
the Agency will be immediately notified of any significant impact along with
actions taken to remedy the problem
;
2. No other reasonable alternatives appear available ;
3. No public water supplies will be affected ;
4. No federal regulations will preclude the granting of this request ; and
5. Exelon's Quad Cities Station will face an arbitrary and unreasonable hardship if
the request is not granted .
2
The Agency hereby GRANTS the Exelon's Quad Cities Station a provisional variance
from Special Condition 6B of NPDES Permit IL0005037 as follows :
(1) Exelon's Quad Cities Station is granted 100 provisional
variance excursion hours ;
(2) The provisional variance will begin on the date that Exelon's Quad Cities
Station either (1) exhausts the 87 .6 permitted excursion hours or
(2) on the date that Exelon's Quad Cities Station first exceeds the
current permitted excursion hour temperature limits (July 89°, August 89°, and
September 88°). The provisional variance will end on the date that the 100
provisional variance excursion hours are used, but in no case later than 45 days
following the start of the provisional variance period .
(3) Exelon's Quad Cities Station, during the 100 provisional
variance excursion hours, may exceed the maximum temperature limit stated in
Special Condition 6B in NPDES permit IL0005037 by no more than 5°F (July
91°, August 91°and September 90°)
.
This provisional variance includes the following conditions :
A. During the variance period, when excursion hours are being used,
Exelon's Quad Cities Station must continuously monitor intake, discharge
and receiving water temperatures and to visually inspect intake and
discharge areas at least three times daily to assess any mortalities to fish
and other aquatic life ;
B. Exelon's Quad Cities Station shall document environmental conditions
during the term of the provisional variance, including the activities
described in A above of this Section, and submit the documentation to the
Agency and the Department of Natural Resources within 30 days after the
provisional variance expires ;
C. Exelon's Quad Cities Station shall immediately implement biological
activities to characterize how fish and other aquatic life respond to the
thermal conditions resulting from the provisional variance ; to document
these activities ; and to submit the documentation to the Agency and the
Department of Natural Resources within 60 days after completing the
monitoring survey, as described below
.
Specifically, Exelon's Quad
Cities Station must prepare a study plan within three days of the beginning
date of this provisional variance to address the issue of increased
excursion hours (increase in thermal stress) on Unionid Mussels in the
Mississippi River in the vicinity of the discharge . The plan must include a
survey of the mussel beds identified in a recent report
: Draft Report :
Unionid Mussel Biothermal Assessment for the Quad Cities Nuclear
3
Station, Mississippi River Miles 503 .0 to 506.9 (Attachment C) .
The
survey must address the apparent health of the mussels within the mussel
beds given the current high river temperatures. Dives to ascertain ongoing
effects on the mussel beds must begin as soon as possible given current
dry and hot weather conditions and no later than Monday, July 25, 2005
.
Conditions pertinent to the mussel populations to be recorded during the
surveys will be much the same as conducted for the baseline study
referenced above
.
These must include but are not limited to mussel
species occurrence and density, age, zebra mussel infestation and apparent
condition,
i .e ., any outward signs of heat stress such as morbidity, reflex
time, position in the substrate, etc . Plant discharge temperatures, upstream
river temperatures, incidence of excursion hours and other pertinent
information must be provided to build an understanding of the conditions
to which the mussels have recently been exposed. Surveys must continue
until excursion hours are no longer being utilized, or in other words, until
the weather conditions causing the need for more excursion hours have
moderated. The final report for this study must address the changes noted
in mussel populations from the previous study. Verbal reports are due to
the Agency at regular intervals during the surveys. These reports must
include any information on mussel die-off. If mussel die-off downstream
from the discharge is found and is attributable to the thermal effects of the
effluent, as compared to the condition of upstream populations, a
monetary settlement will be required as calculated by the formula the
Illinois Department of Natural Resources uses for mussel die-off
settlements ;
D. Exelon's Quad Cities Station shall immediately notify the Agency and the
Department of Natural Resources of any unusual conditions, including
mortalities to fish or other aquatic life ; to immediately take action to
address the problem; to investigate and document the cause and
seriousness of the unusual conditions while providing updates to the
Agency and the Department of Natural Resources as changes occur until
normal conditions return; to notify the Agency and the Department of
Natural Resources when normal conditions return; and to submit the
documentation to the Agency and the Department of Natural Resources
within 30 days after normal conditions return ;
E. Exelon's Quad Cities Station shall develop and implement a response and
recovery plan to address any adverse environmental impact due to thermal
conditions resulting from the provisional variance, including loss and
damage to aquatic life ;
F. Exelon's Quad Cities Station must conduct a feasibility study for
incorporation of supplemental cooling capabilities (cooling towers at the
plant or other potential technologies) to avoid reliance on thermal
provisional variances in the future
.
The study must consider both
4
technical and economic feasibility .
Exelon's Quad Cities Station must
consider, but is not limited to studying the following aspects of this issue
:
the type and placement of cooling towers ; the efficiency of the towers, i .e .
how many towers would be necessary to cool the effluent a certain
amount; the cost of the towers relative to the profitability of the plant
during extreme summer weather conditions and the time frame for
obtaining and installing towers. A final report on tower feasibility along
with Exelon's Quad Cities Station conclusions for implementing a
portable cooling tower program, are due to the Agency within six months
of the beginning date of this provisional variance
;
G. Exelon's Quad Cities Station shall notify Roger Callaway of the Agency
by telephone at 217/782-9720 when the need for the 100 requested
excursion hours begin and again if the excursion hours are totally utilized
.
Written confirmation of each notice shall be sent within five days to the
following address :
Illinois Environmental Protection Agency
Bureau of Water - Water Pollution Control
Attention: Roger Callaway
1021 North Grand Avenue East, MC #19
Springfield, Illinois
62794-9276
H. Exelon's Quad Cities Station shall sign a certificate of acceptance of this
provisional variance and forward that certificate to Roger Callaway at the
address indicated above within one day of the date of this order
.
The
certification should take the following form
:
I(We) , hereby accept and agree to be bound by all
terms and conditions of the provisional variance granted by the
Agency in dated
Petitioner
Authorized Agent
Title
Date
5
Exelon's Quad Cities Station shall continue to monitor and maintain compliance with all
other parameters and conditions specified in its NPDES Permit No . 1L0005037 .
The Illinois EPA grants this provisional variance in accordance with its authority
contained in Sections 35(b), 36
(c), and 37(b) of the Illinois Environmental Protection
Act (415 ILCS 5/35(b), 36(c), and 37(b) (2004) . The decision to grant this provisional
variance is not intended to address compliance with any other applicable laws or
regulations
.
GRANTED
:
William D. Ingersoll
DATE: July 22, 2005
Acting Chief Legal Counsel
6
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ExelonGrnrr
:.IionCcmpany.LLC
www.exeloncotp.eom
Quad Cities Nuclear A,wrr Station
??71U 106`=Aveiwe North
CCTdova II
(0142-1)740
PM-05-008
July 21, 2005
Mr. Mike Garretson
Manager, Compliance Assurance Section
Division of Water Pollution Control
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794
Subject :
Quad Cities Nuclear Power Station
NPDES Permit No. IL0005037
Provisional Variance Request - Emergency Application
Dear Mr. Garretson :
Exelon Generation Company, L .L.C. ("Exelon") hereby requests that the Illinois
Environmental Protection Agency ("IEPA" or "Agency") grant a provisional variance for
Quad Cities Nuclear Power Station ("Quad Cities," "Station" or "Facility"), pursuant to
Section 35(b) of the Environmental Protection Act ("Act") 415 ILCS 5135. Exelon
submits this Emergency Application for a provisional variance consistent with IEPA
procedures at 35 III. Adm. Code 180.204. Quad Cities is located on the Mississippi
River in Rock Island County. The Station discharges wastewater pursuant to NPDES
Permit No. 1L0005037, which IEPA issued on December 17, 2001, ("NPDES Permit")
.
The Station submitted its NPDES Permit renewal application to the Agency on
November 18, 2004
.
Station Description
Quad Cities Station is a nuclear-fueled steam electric generating facility located near
Cordova, Illinois, on the Mississippi River at River Mile 506 .8. The two boiling water
reactors have a combined maximum generating capacity of 1824 megawatts electric .
Circulating water used to cool and condense the steam from the generating process Is
withdrawn from and discharged to the Mississippi River .
Quad Cities operates a condenser cooling water system in open cycle mode . In this
mode, cooling water is drawn from the Mississippi River into an intake canal, passes
through the plant systems, and is discharged via diffusers into the Mississippi River
ATTACHMENT A
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(Outfalls 001 and 002). The maximum design flow is 2253 cfs or 1,011,000 gpm . Open
cycle operation with the diffusers was initially permitted by the IEPA on December 22,
1983 .
Relief Requested
A provisional variance is being requested from the restrictions in Special Condition 6B
of the NPDES Permit, which limit the number of excursion hours to 1% (87 .6 hours) of
the hours in a 12-month period ending with any month and, which provide that water
temperatures in the Mississippi River shall at no time exceed by more than 3 °F the
maximum limits of 86 °F in July, 86 °F in August and 85 °F in September
.
Specifically, Exelon requests that a provisional variance be Issued to Quad Cities
Station, which ;
(1)
grants relief from the 87 .6 hour limitation for an additional 100 hours ;
and (2) which increases the maximum limits for July and August from 86 ° F to 88°F and
for September from B5°F to 87°F during the provisional variance period . During
excursion hour periods these maximum standards can be exceeded by no more than 3 °
F. The provisional variance period will begin on the date that the 87 .6 permitted
excursion hours are exhausted or on the date that the Station first exceeds the current
excursion hour limit
(i.e., 89° in July and August or 88 °F in September), which is
predicted to occur on or about July 23, 2005, based on current weather conditions and
ambient river temperature conditions . The provisional variance period will end on the
date that the additional 100 hours are used, but in no case later than 45 days following
the start of the provisional variance period,
Necessity for Request
Special Condition 6B of NPDES Permit limits the temperature at the edge of the mixing
zone to the maximum monthly temperature standards set forth at 35 III . Admin. Code
303.341 (86 °F in July and August and 85
°F in September), except when the Station is
using excursion hours, during which time the temperatures at the edge of the mixing
zone may be 3°F warmer than these limits. As a rule, the Quad Cities Station has been
able to operate well within both the 87.6 excursion hour limit and the 3°F allowance due
to the fact that the ambient temperatures of the River (measured upstream of the
discharge) generally remain below the non-excursion hour limit . Even when the
ambient river temperatures begin to approach the non-excursion hour limits, the
significant river flows, which are generally characteristic of the Mississippi River, are
sufficient to allow the Station to avoid using a significant percentage of its excursion
hour allowance . It is only during periods when the ambient river temperatures are very
close to or exceed the non-excursion hour limits or during periods of extreme low flows
that the Station is forced to use a significant number of its excursion hour allowance
.
When the ambient river temperatures exceed the non-excursion hour limits, the Station
has no option other than to use excursion hours, and once its allotment of excursion
hours is depleted, the Station must cease operating to maintain compliance with the
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NPDES Permit. Partial deratings or adding cooling facilities (such as cooling towers)
will not cause the Station to achieve compliance with the 87 .6 excursion hour limit that
already is exceeded even beforey heat is added as a result of Station operations
Similarly, as ambient river temperatures begin to approach the temperatures allowed
during excursion hour periods (i .e . 89°F In July and August and 88°F in September) the
plant's ability to try to assure that river temperatures do not exceed these excursion
hour temperatures through deratings becomes increasingly limited, and, ultimately,
shutdown would become the only option . However, the instances in which ambient
temperatures have reached these extreme temperatures have been very infrequent and
short-lived .
During the drought years 1987 through 1989, Quad Cities Station used 45 .2 hours in
1987, 108.3 hours in 1988 (allowed by Provisional Variance No. PCB-88-129), and 23 .2
hours in 1989. From 1990 through 2000, high ambient river temperatures and low river
flows resulted in Quad Cities Station using a total of 24 .5 excursion hours. Between
1990 and 2000, maximum ambient river temperatures at the Quad Cities Station intake
exceeded 86 °F on five occasions (July 14, 15, 16, 1995, when Mississippi River flow
was 45,000 cfs and July 30, 31, 1999, when Mississippi River flow was 94,000 cfs)
.
In 2001, daily maximum ambient temperatures in the Mississippi River at the Quad
Cities Station intake gradually increased from 76 .9 °F on July 3rd to a high of 87,8 °F on
August 8th. For eight days, maximum ambient river temperatures at the Quad Cities
Station intake exceeded 86 °F. During that time, the Station used 57 .5 hours of the
87.6 allowed. As in prior years, use of the excursion hours during 2001 was related to
the ambient upstream river temperatures approaching and exceeding 86 °F, River
flows were higher than normal during 2001, thereby reducing the number of excursion
hours used .
As you are aware, Illinois is enduring its driest summer in 134 years on record, which
began in March 2005. Ambient river temperatures recorded for July 2005 have been
much warmer than normal. The daily maximum ambient temperatures in the Mississippi
River at the Quad Cities Station intake have gradually increased from 75.2°F on July 5th
to levels at or above the discharge limits . Specifically, on July 16
th
and 18`h , 2005, the
maximum ambient river temperature at the Quad Cities intake reached 86 °F. On July
17'h maximum ambient river temperatures at the intake exceeded 86 °F. These
abnormal ambient river temperatures result from the combined effect of air temperature,
dew point, wind speed and cloud cover . In addition, Mississippi River flow is presently at
a dramatically low level of 39,000 cfs with a prediction to drop to 25,000 cfs by Sunday,
July 24, 2005. Normal River flow for this time of year is 68,000 cfs. As a consequence
of these unusually hot and humid weather conditions and drastically low flows, the
capacity of the Mississippi River to dissipate heat has been drastically reduced beyond
Its normal capabilities .
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As a result of these extreme conditions, on Saturday, July 16, 2005, Quad Cities Station
used 5 excursion hours, on Sunday, July 17th, the Station used 16 excursion hours, and
on Monday July 18"', Quad Cities used 7.5 excursion hours, totaling 28.5 excursion
hours to date .
Based on long range weather forecasts, it is very likely that the unusual drought and
temperature conditions experienced this summer will continue for several weeks,
causing the ambient river temperatures to exceed the non-excursion hour limits for
significant periods of time, and, at times, to approach the excursion hour limits. Under
these circumstances, it is expected that the Station may use up all of its permitted
excursion hours or contribute to River temperatures exceeding excursion hours limits on
or about July 23, 2005. Unless relief is granted by way of this provisional variance
request, it is likely that the Station will be forced to shut down for correspondingly
significant durations .
In cooperation with IEPA's request that Exelon explore long- term thermal relief options,
Exelon retained :
(1)
expert biologists to conduct a Fisheries Biothermal Assessment,
which defines fish responses to thermal impacts; and (2) a renowned expert on fresh
water mussels to perform a Unionid Mussel Biothermal Assessment, which evaluates
possible impacts to mussels from plant operations under existing and proposed thermal
conditions. Exelon has shared drafts of these studies and its draft long- term regulatory
relief proposal with federal and State regulators, including IEPA, USEPA, USFWS, Iowa
DNR, and Illinois DNR, with whom related discussions are currently underway. The
next scheduled meeting with these agencies is scheduled for early August . The goal of
Exelon's long- term regulatory relief proposal is to substantially mitigate the need for the
emergency type relief requested herein . However, current and forecasted extreme
weather, drought conditions and lowering river flows compel this urgent request for
relief .
Assessment of Environmental Impacts
Because Quad Cities Station is not proposing to increase cooling water flows or
increase the temperature of cooling water discharges, there will be no increase in
impingement or entrainment as a result of the Issuance of the requested Provisional
Variance. Additionally, because the ambient river temperature increase has been
gradual, resident fish species have either acclimated to the higher temperature or have
found thermal refuge . Therefore, resident fish species will not be subject to any heat
shock as a result of Increasing the allotment of excursion hours for Quad Cities Station
.
The biological studies undertaken as part of Exelon's above-mentioned investigation of
long-term, permanent relief options considered the effects on species of fish and
shellfish that could result from increasing the number of excursion hours available to the
plant. While these studies currently are under review, they fully support the conclusion
that granting the requested Provisional Variance will not cause significant or
unacceptable adverse effects to these species . Species of fish that are likely to be
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impacted from being exposed to temperatures in the excursion zone will already have
taken refuge from the higher than normal ambient river temperatures . Therefore, no
fish mortality should result from operations authorized by the Provisional Variance
.
Shellfish do not have similar thermal avoidance capabilities . However, the recently
conducted biological studies show that the mussel (unionid) species in beds that are
closest to the plant's discharge are generally more temperature tolerant, and are
capable of surviving relatively short-term elevated thermal exposures . Species thought
to be less thermally-tolerant Inhabit beds located further downstream, in the Cordova
Bed, located about f mile downstream from the plant. However, because the
considerable distance between the plant to the Cordova and the flow characteristics of
the River (that cause much of the plant's thermal discharge to avoid the Cordova Bed)
the Provisional Variance should not cause any appreciable harm to mussel species
downstream of the plant
.
Alternatives to Requested Relief
Quad Cities Station generally uses excursion hours during periods of extreme heat and
low-river flows. Due in part to the mixing capacity provided by the Mississippi River,
and the tact that ambient river temperatures rarely exceed the non-excursion hour
NPDES Permit limits, only a relatively small percentage of the permitted excursion
hours typically are used to cover any one of these periods. Additional hours are kept in
reserve to deal with future periods of extreme weather or other contingencies
.
However, this year, the unusually dry, hot and humid weather conditions have caused
the ambient river temperatures to approach and exceed the non-excursion hour
discharge temperature limits more often and for longer periods of time than normally
occurs. As a result, Quad Cities Station was required to use a substantial number of
the permitted excursion hours and has too few in reserve to deal with projected weather
conditions during the rest of July, August and September . Currently, Quad Cities is
expected to run out of permitted excursion hours on or about July 23, 2005 . In addition,
ambient River temperatures may begin to approach the current excursion hour limit for
July
(i.e . 89°F) in the next few days
.
Unless a provisional variance is issued, when the Station runs out of permitted
excursion hours, it will have to shut down during all times that the ambient river
temperatures are at or above the non-excursion hour limit, or when ambient
temperatures approach the excursion hour limits. Based on river temperatures
recorded so far this summer and long range weather projections for the balance of the
season, it is likely that there will be a number of extended periods during which ambient
river temperatures will be at or above the non-excursion hour limits, and infrequent
periods when the temperatures approach even the excursion hour limits
.
As previously explained, neither the option of derating the units nor of obtaining
additional temporary cooling capacity will allow the Station to maintain compliance with
the limitation of 87.6 excursion hours if the ambient river temperatures exceed the
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applicable temperature limits. The only option would be for the Station to shut down
once the ambient River temperatures are at or exceed 86° F in July and August, or 85°F
in September. Similarly, without relief from the excursion hour limits, plant shut down
would be required if the ambient temperatures approach these limits .
Without the power that Quad Cities Station could generate as a result of the requested
provisional variance, there is increased risk that the energy needs of Exelon's
customers may not be met during the next few weeks, when there is the greatest
demand for electricity resulting from extreme heat conditions. In addition, depending on
the operating status of other generating stations in the area, Quad Cities Station
continued operation may be essential for voltage support for the Commonwealth Edison
Company and Mid American Transmission systems .
Mitigat(ve Actions to be
Taken During the Variance Period
During the period when the Station uses any additional excursion hours authorized by
the requested provisional variance, Quad Cities Station will do the following: (1)
continuously monitor the intake and discharge temperatures and assess water
temperatures at the edge of the mixing zone specified in the NPDES Permit ; (2) on a
daily basis, inspect the intake and discharge areas to assess any mortalities to aquatic
life, and report the results of these monitoring activities to the Agency within 30 days of
the expiration of the provisional variance (or such other time as agreed upon by the
Agency); and (3) notify the Agency of any significant adverse environmental conditions
observed that might be caused by operations authorized by the provisional variance
.
including mortalities to fish or other aquatic life, investigate the cause of such
conditions, provide the Agency updates regarding the situation, including when normal
conditions return, and submit a report to the Agency regarding these matters within 30
days of the expiration of the provisional variance period (or such other time as agreed
upon by the Agency) .
Summary
Exelon seeks relief from Special Condition 68 of Quad Cities NPDES permit as
described above, For the reasons described above, Exelon believes that not granting
this provisional variance to Quad Cities Station will impose an arbitrary and
unreasonable hardship, A negative decision will almost certainly result in a loss of
generating capacity in Northern Illinois during periods of great electrical demand and
could impact voltage support for the Commonwealth Edison Company and Mid
American Transmission systems . There are presently no provisional variance orders in
effect for Quad Cities Station
.
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It you should have any questions regarding these matters, please feel free to contact
Vicki Neels at (309)
227-3200
or Mark Stuhlman at (309)
227- 2765
from Quad Cities or
John Petro, Senior Environmental Analyst, Exelon Generation at (630)
657-3209
.
Very Truly Yours,
William R. Gldeon
Plant Manager
Quad Cities Station
CC; Marcia Wilhite, IEPA
Roger Calloway, IEPA
Blaine Kinsley, IEPA
Connie Tonsor, IEPA
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