ILLINOIS POLLUTION CONTROL BOARD

July

9,

1981

IN THE MATTER OF:

410(c) PETITION FOR DRESDEN

)

PCB 79—134

NUCLEAR GENERATING STATION

MS. SUSAN

D.

PROCTOR OF ISHAM, LINCOLN AND BEALE APPEARED ON

BEHALF OF

PETITIONER.

MS. MARY

V. REHMAN APPEARED ON BEHALF OF RESPONDENT.

OPINION AND ORDER OF THE BOARD

(by J.D.

Dumelle):

This case

is before the Board pursuant to Rule 410(c)

of

Chapter

3:

Water Pollution.

In its petition of June 29,

1979

and its amended petition of December 30,

1980 Commonwealth Edison

requests that the Board allow the following thermal standard to

apply to Edison’s Dresden nuclear power plant:

During the period June 15 through September 30, the temperature

of the plant discharges shall not exceed 32.2°C (90°F)

more than 10

of the time in the period and never will

exceed 33.9°C (93°F).

Such operation would result

in periodic violations of

Rule 203(i)(3) and

(4)

of Chapter

3 which allows an excursion

above 32.2° (90°F) as measured at the boundary of a 26—acre

mixing zone for 1

of the hours

in any

12 month period.

The

proposed amendment does not include a mixing zone, but allows

the 32.2°C (90°F) standard to be exceeded approximate 3

of

the hours during any 12 month period.

Hearing was held on May

5,

1981.

Several witnesses testifiel

on behalf of Edison, but no witnesses testified on behalf of

the Illinois Environmental Protection Agency

(Agency) nor

was any evidence introduced.

No members of the public were

present.

On May 26,

1981 the Agency filed a recommendation that

the proposed alternate thermal standard be allowed for one year

subject to certain conditions.

These conditions would require

various studies to be performed such that the Agency could

better determine whether a permanent alternate standard is

warranted.

The Agency also stated that the U.S. Environmental

Protection Agency (USEPA), which must also accept any alternative

standard pursuant to Section 316(a)

of the Clean Water Act

(CWA) would not object to the Agency’s recommended procedure.

On June

5,

1981 Edison responded to the Agency’s recommenda-

tion by strongly maintaining that the proposed standard should

be made permanent rather than temporary.

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—2—

Dresden Station is a nuclear powered

stearri electric

generating

facility that utilizes three boiling water reactors.

Condenser cooling water

for all three

tiriits

is withdrawn from

the

Kankakee and Des Plaines Rivers and ultimately discharged

to the

Illinois River, which is formed by the confluence of

the

Kankakee

and Des Plaines Rivers.

Unit

1, which has

a generating capacity of 207 megawatts

electric power

(MWe) began chemical cleaning decontamination on

October 31,

1978 and is anticipated to be restarted no

~oones-

than June of 1986.

Units

2 and 3 each have a net generating

capacity of 794 MWe and began operating on August 11,

1970

and

October 30,

1971,

respectively.

Each uses a heat dissipation

system consisting of

a cooling pond,

spray modules and cooling

canals.

The cooling systems can be used for three modes of

operation:

direct open cycle, indirect open cycle and closed

cycle

(see pp.

16—20 of “316(a)—410(c) Demonstration for the

Dresden Nuclear Generating Station,” hereinafter “Demonstration

Document”).

Until September 3,

1971, Unit

2 was operated in an indirect

open cycle mode for cooling purposes.

Before Unit

3 began

commercial operation it was periodically operated in that mode

until the cooling pond was opened on September

3,

1971.

Under

such operation water withdrawn from the Kankakee and Des

Plairies

Rivers is circulated through the condensers and discharged

directly

to the Illinois River

(Dent.

Doc.

pp.

18—19).

From September

3,

1971 until October of

1974,

Units

2 and 3 were operated in an indirect open cycle mode which

routes the water through a two mile

long spray canal containing

floating spray modules and into a 1,275 acre cooling pond which

retains the water

for 2.8 days prior

to discharge to the Illi~oi3

River

(Dent. Doc. pp.

18—19).

After October of 1974,

both units were primarily operated

in a closed cycle mode.

In this mode condenser water is recircu-

lated after passage through the spray canals and cooling pond,

with a small portion blowndown to the Illinois River

(Dent.

Doc.

pp.

18—19).

Under the proposed standard Dresden Station would be operated

in the indirect open cycle mode from June 15 through September 30

and under current NPDES permit conditions during the remainder

of the year.

As such it would violate 42CFR423..13(l)

and

(m) which requires an essentially closed—cycle cooling system

by July

1,

1981.

However, under Section 316 of the CWA a

point source is entitled to an alternate standard if “shellfish,

fish,

and wildlife” are sufficiently protected.

A similar

showing can be made for exemption from Rule 410(c) of Chapter

3.

Edison believes that testimony and the Demonstration

Document support a finding that the alternate stanard would

result in overall environmental benefits.

Consultants

to the

study testified that:

43—4

---

1.

Indirect open cycle operation benefits water quality

in the Illinois River by reducing B0D5 most of the

time, reducing ammonia levels,

adding dissolved oxygen

and by reducing coliform bacteria and~toxic,heavy

metals

(Drs. Ewing and l3rill at p.

1.);

2.

All of the possible operation modes would have a

negligibly small

impact on phytoplar~.kton,periphyton

and zooplankton populations

(Verduin at pp.

1,2,6,

9—11);

3.

Species composition of macroinvertebrates will remain

essentially unchanged though there may be some slight

increase in tubificids and possibly chironids

(Lauer

at pp.

1—2);

4.

The expected thermal

impact on fish

would

be considerably

reduced under indirect open cycle

versus the direct

closed

cycle mode of operation.

No thermal mortality

should result and behavioral

avoidance of thermally

sensitive species should lead those

fish to the

environmentally acceptable waters

of the nearby

Kankakee River.

E’inally, the thermal plume is expectet3

to spread over the surface during summer low—flow

periods such that cool, bottom waters should prevail

(Dr. Gammon at pp.

6-8),

and

5,

The indirect open cycle mode would be beneficial th

the fish community of the cooling

pond,

might make

it acceptable as a fish nursery and thereby benefit

the fish communities of the kankakee,

bee Plajnee

and Illinois Rivers.

Against this testimony

is the Agency~sopinion that more

studies are necessary~

No counter testimony was presented nor

was any reason given

for

disputing the accuracy of the testir~ony,

except that the lack of prior appreciable harm was based on infor-

mation from September

of

1971

until October of i~74during which

times Units

2

and

3 were operated in the indirect open cycle mode,

However,

the testimony indicates that the conclusions reached

were

based not only on data

from that

time period,

but

also

en data

developed and analyzed between

1974

and

the date of the completion

of the Demonstration Document.

The

Board

finds that the evidence submitted indicates that

the environmental impact of the proposed alternate standard on the

Illinois River is at worst minimal and

may,

in fact,

he beneficial.

Therefore, the Board grants ~dison~srequest for the alternate

standard.

Testimony at

hearing

~waslargely presented in document form

as exhibits.

These will be referred to by the name of

the

authors and page numbers.

43—5

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—4—

However, the Board

further finds that an updated

study

of

the actual

impact

of

such operation

is preferable to studies

which are

up to ten years old

or projections based on modeling

of

a flow situation

as complex as that

affected by the Dresden

Station,

Therefore,

and

since Edison

has agreed,

the Board

will follow the recommendation of the Agency

to the extent

of requiring that Edison conduct monitoring studies during

the summer of 1981.

This opinion constitutes the

Board’s findings

of fact

and conclusions

c~

law in this matter.

ORDER

Pursuant to

Ru:Le 410(c)

of Chapter

3:

Water Pollution,

it

is

hereby ordered that

hhe Dresden Nuclear Generating

Station shall

he operated in accordance with the following limitation

in lieu of

Rules 203(i)(3) and ~4) of Chapter

3;

During the period June 15 through September

30,

the

temperature of the plant

discharges

shall not exceed 32.2°C(90°W)

more than 10

of the time in the period and never will

exceed

33.9°C(93°F)

It is further ordered that:

1~

At all times other than those indicated above

the Dresden Station shall be operated in accordance with

Rule 203(i)(3) and

(4)

of Chapter

3:

Water Pollution.

2. Commonwealth Edison shall conduct monitoring

studies

in conformity with Edi~on’~two documents

submitted to the Agency on May

23,

1980 entitled

“Proposed Hydrothermal Study Plan for 9ummer

19~0”and

“Proposed 1980 Environmental Program~~

as modified by

Agency suggestions as set forth in its ~ecommendatthn

submitted on May

26,

1981.

3,

The Illinois Environmental Protection ~gency

shall modify Commonwealth EdiSon’s

~4PDES

permit for

the Dresden Station

in a manner Consistent with this

Opinion and Order

IT

IS SO ORDLRED~

Mr. Anderson abstained.

I, Christen

L,

Moffett, Clerk of the

tilitmis Pollution

Control Board, hert~ycertify

tl)at the above Opinion and

Order wer~

adopted

on

the

J~

day ot

~

1981 by

a vote

ol’

~

/

/

Illinois Pollution

C~ntrol

floard

43—6