ILLINOIS POLLUTION CONTROL BOARD
April
25,
1972
In the matter of
JOINT APPLICATION OF
)
#71-20
COMMONWEALTH EDISON CO.
AND
)
IOWA-ILLINOIS
GAS
& ELECTRIC
CO.
)
(QUAD CITIES PERMIT)
)
(PETITION FOR MODIFICATION OF
PERMIT)
OPINION
AND
SUPPLEMENTAL ORDER OF THE BOARD
(BY MR. LAWTON):
On November
15,
1971,
a permit to operate
a new nuclear genera-
ting station consisting of two 809—mw Boiling-Water Reactors at
the Quad-Cities
plant near Cordova, Illinois,
on the Mississippi
River was issued to Applicants.
Section 5 of the permit provides
as follows:
“5.
Heated Water Discharges
(a)
With the discharge improvements described
in the
Supplement
to Appendix C of the Application
as Amended, Units
1
and/or
2 may be operated until April
1,
1972, at
a total output
not
to exceed 809 mw, without regard to the heat limitations
of
regulations
SWB-l2 as amended by #R70-l6 or of successor
regulations, provided that:
(i)
until operation of the diffuser is achieved,
effluents shall not exceed ambient river
temperatures by more than 12°F;and
(ii) within thirty days after receipt of this
permit,
the permittees
shall submit
a state-
ment regarding the feasibility and cost of
installing spray modules to reduce the heat
discharged
in the interim before completipn
of the diffuser.
The Board upon receipt of
such statement will take such further action
as appears appropriate.
(b)
On and after April
1,
1972,
Units
1 and
2 shall be
operated only in full compliance with
all provisions
of SWB-l2
as amended by #R70-16
or of successor regulations, with regard
to heated discharges.~
#R70-16
(Mississippi River Thermal Standards)
now embodied
in our
comprehensive water regulation
in addition to specifying monthly
4
—
405
temperature maximums prohibits an increase of water temperature
above ambient
in
excess of 5°F.outside of the mixing zone.
On March
1,
1972,
a petition for modification of paragraph
5
was filed with the Board seeking
a variance from the Mississippi
River Thermal Standards for
a period between approximately April
20,
1972 until August 15,1972,
at which
time the installation of the
diffuser discharge contemplated by paragraph
5 above will have
been completed.
Hearing was held on the petition.
The delay in the diffuser discharge installation
is
a consequence
of the refusal until recently, on the part of the State of Iowa to
allow construction of the diffuser discharge.
Originally,
it
was
contemplated that testing of the Quad-Cities units would be made during
the winter months when the ecological impact would be minimal.
How-
ever,
the pendency of an injunction proceeding
(now resolved)
in the
U.
S.
District Court for
the District of Columbia prevented such
testing from taking place.
Petitioners propose a program
of testing
and use
of the reactors ~to assure proper operation and to meet summer
peak load demands prior to the installation of the diffuser discharge.
We grant the modification,as
proposed, in the form set forth
in
our
order,
for the
reasons more fully discussed in this Opinion.
We
find
that while permitting departure from the Mississippi River Temperature
Standards will have some adverse effect on the biota, such damage
is
neither severe nor irreversible.
We further find that failure to
permit
such departure from the Mississippi River Temperature Stan-
dards will impose restrictions
on power generation having detrimental
consequences
to the entire community far in excess of
the limited
environmental damage consequential
to the variation permitted.
Applicants request authority
to continue
the testing of units
which began on April
1,
1972 when the AEC issued a 20
license for
each
unit,
at
a station capacity level not in excess
of 809-MW.
Petitioner anticipates
that the AEC percentage allowance will be
increased.
It is anticipated that 55 days will be needed for testing each
unit in order to bring it up to full capacity although the testing
of each will be carried on simultaneously and be coordinated so that
the maximum output at no time of testing will exceed a total of 609-
MW.
Testing of Unit No.
2 might
take less than the anticipated
55
days
(R.26l7).
Applicants have Contended that testing in order
to
demonstrate
full power capabilities of both units
is necessary to
insure maximum station reliability and availability during system
load emergencies or a forced outage of one unit.
Subsequent
to the
completion of the testing operation,
Applicants contemplate that each
unit will operate nornally at
200 mw capacity until the diffuser discharge
4
—
406
is in operation.
One or both units will be brought up to
500 mw
in the event weather forecast and early estimate of emergency help
available from other companies indicate that the Quad-Cities capa-
city will be needed.
Operation above 500 mw for either or both
units,
resulting in a total station output in excess of 1,000 mw
will not occur until after Commonwealth Edison has interrupted
service to those of
its customers whose service agreements allow
such interruption,
and in no event,
shall total station output
exceed 1,000 mw
for more than eight hours in any day.
Quad-Cities power capacity is needed to assure the meeting of
summer peak electrical loads resulting from the projection of
the
probable power demands and anticipated outages.
Total owned and
purchasedcapacity of Commonwealth Edison is 14,286 megawatts
(Com-
monwealth Edison Exhibit 100).
The predicted peak load is 12,600
megawatts while the projection of outages varies from 2,100 mw
to 3,900 mw.
A figure of 2,600 mw is assumed for purposes of this
proceeding.
This anticipated reduction in power-generating capacity
is
a consequence of
low sulphur coal limitation, non-turbine tempera-
ture limitations,
fast start peaking units, miscellaneous limitations
and forces outages of entire units.
With
a total capacity of 14,286
raw,
a peak
load of
12,600 mw and
a projected outage of 2,600
mw,
Commonwealth Edison would need
a total of 914
raw from Quad-Cities
to meet
the peak.
It
is anticipated that this would occur on approx-
imately seventeen occasions, being the average number of weekdays
on which 90° F.
is exceeded in Chicago
(R.2583)
From the foregoing,
it would appear that an amount
in excess
of
300
raw and on occasion in excess
of 900
it~
would be
required by Edison from Quad-Cities Station during the hot summer period
of 1972.
The evidence
also supports
the position that the load de-
mands and capacities of
Iowa—Illinois,
Iowa Pool
and MAIN are
such
that the Quad-Cities
capacity will be necessary
to insure adequate
power availability from these sources
for emergency situations,
particularly during the summer months
in order to meet peak demands
(R. 2590—2607)
The consequence of the increased power generation prior to the
installation of
the diffuser discharge must be considered in terms
of
the increase in temperature at the various levels of power generation
and its anticipated affect on the biota.
Frank
A.
Palmer,
Superintendant of the Quad-Cities Station testi-
fied
that
with
the
power
generation
indicated,
the
water
temperature
at
the
plant
discharge
point
for
the
two
units
is
estimated
as
follows
(H. 2618)
4
—
407
Two units
at 200 NW:
8 degrees
One unit at 200
and the second at
500 MW:
12 degrees
Both units
at 500 MW:
16 degrees
One unit at 500
and one at 809
raw:
19.5 degrees
Both units
at 809
raw:
23 degrees
Evidence
in the record indicates that the river flow at the end of
April will be
170,000
cfs,
declining
to as l~was 26,000
cfs
in
August.
The shape and direction of the plume from the side jet dis-
charge suggests
that the flow will be along the Illinois shore and
that one—half of the water having discharge temperature will encompass
the small islands on the Illinois side downstream from the plant
(R.2643),
The report on bioiogiôal effects
submitted at the hearing
indicates
a
possibility
of
slight changes
in spawning time and
maturation
rates
for
fish
spawning
at
that
location
but
little
likeli-
hood
of
a change in total fish population or
a change in the population
dynamics.
Lethal
temperature
effects
are
not
likely
to
occur
during
the
testing
period
because
the
water
temperature
during
that
time would range from
55°
in
April
to
80°
in
late
June.
Some
concern
was expressed over
the biological
effects
during
the
period
of
July
and
August prior to the bperation of the diffuser discharge.
During
this period some young of the year of walleye Sauger pike, white
crappie and black crappie,
may
be killed if
the
ambient
temperature
is greater than 91°F.
The net result would be
a shift in the species
composition of the community favoring the more temperature tolerant
types
(carp, carpsucker,
large-mouthed bass, bluegill and drum)
over
those
less tolerant
(northern pike,
crappie, sauger and walleye)
How-
ever,
the environmental report states that after the use of the side-
jet discharge
is discontinued
in August,
1972,
any displaced species
will repopulate
the affected area within
a relatively brief period.
Nor will temperature decrease following decrease in power generation ap-
pear to have any substantial adverse effect.
While elevated temperatures
may disrupt behavorial habits associated with spawning,
reduce the
rate
of fertilization,
increase egg mortality,
increase
the rate of
development to a point that hatching occurs at an unfavorable
time
and lower the viability of the larvae, even
a limitation on production
in this region during the test period will have little or no effect
on the
fish population dynamics within Pool 14
R.
2648)
Further,
the island area where the thermal impact would be riost
pronounced accounts for less than 10
of
the habitat in Pool 14 below
the Quad—Cities station and any changes that may occur
in the biota
will be of little significance
in the total ecology of
this pooi.
Any damage
to the benthic communities
is
likewise expected to be
minimal.
In summary,
it is the conclusion of
the witness testifying on
an
ecological
impact
that
the
anticipated
affects
of
the
interim
operation
of
the
side-jet
discharge on
the total ecology of Pool 14
appear to be minimal during the testing period when an increase of
11.5°F. will not be exceeded.
If the units are operated so that an
4
—
408
increase is above 11.5°F., some environmental impact
is
likely.
Assuming maximum operation of the station will cause increase to
23°above ambient,
immature fish unable
to move
from the area would be
killed and benthic populations would be affected.
Likewise,
depletion
of dissolved oxygen would have an adverse effect.
Notwithstanding the foregoing consequences of such temperature
increase,
it is believed that the repopulation will occur and that
recovery of
the fishery would result within a period of two to three
years
(R.2656),
In
order
to
minimize
such
environmental
impact,
Applicants
pro-
pose
to
keep
plant
operation
at
or
below
400
mw,
increasing
it
beyond
~±is
point
only
to
the
extent
load
demands
require
such
increase.
An
eight
hour
limit
on
capacities
above
a
total
of
1,000
MW
generation
is
also
provided
and
service
to
interruptible
customers
would
be
interrupted
when
total
output.
exceeds
1,000
megawatts.
We
grant
the
modification
as
proposed
because
in
our
view
the
impact
on
the
community
likely
to
result
from
the
suspension
of
electrical power during peak demands as
a consequence of outages and
other emergency situations is far greater than any likely damage
to
the ecology resulting from temperature increases of the river prior
to installation of the diffuser discharge which damage, while substan-
tial, would be reversible.
Our original permit, which is modified by this
Order,
was granted
pursuant to Section VI(a)
of the Environmental Protection Act and re-
lated essentially to radioactive emissions.
Because of the affirni~ance
by the Supreme Court of the United States of the 8th Circuit Court’s
decision in Minnesota v. Northern States Power Company,
447 Fed.
2d
1143
(1971), holding that regulation of radioactive emissions from powei
plants is preempted by the Federal Government,
jurisdictional doubts
have been raised concerning our permit authority generally.
However,
what Applicants seek by
the present proceeding is,
in substance,
a
variance from the limitations of #R70-l6 limiting thermal emissions in-
to the Mississippi
River.
Our jurisdiction
to promulgate and vary
regulations of this nature
is
in no way affected by the Northern States
Power Company decision,
irrespective of what our permit authority may
be as
a consequence of the case.
Applicants have correctly pursued
their remedy before
us.
We treat petitioner’s request
as avariance
petition and grant
it on that basis.
This opinion constitutes
the findings
of fact and conclusions
of
~aw of the Board.
4
—
409
SUPPLEMENTAL ORDER
Paragraph
5(b) of
the permit dated November 16, 1971
is deleted
and in lieu thereof,
the following paragraph
is added allowing a
variance from the Mississippi River Temperature Standards,
#R70-l6:
5.
(b)
On and after the date of this
order, Units
1 and
2 shall be operated in full compliance with all provisions
of SWB-l2 as amended by 4~R70—l6and or successor regulations
with regard to heated discharges, except that until the
diffuser discharge
is installed and operating, but no
later than August 15,
1972, Units
1 and
2 may be operated:
(1)
For the purpose of testing either Unit up to its
rated capacity of 809 MW,
effluent temperatures during
this period shall not exceed ambient river temperatures
by more than 12 degrees
F.;
(2)
For the purpose of meeting customer demands
for
electrical power,
in accordance with
the following operating
steps:
(a)
At
a
total
output
not
to
exceed
400
MW;
or
(b)
On any day when the applicants’
daily
load
forecasts
(including
bona
fide
requests
for
emergency
~wer
from
other
companies)
exceeds
the total estimated capacity available to them
from any source
(not including the last 182 MW of
capacity from Powerton Units
1 through 4),
at a
total output sufficient
to meet the~dai1y load
and in no event more than a total output of 1,000
MW,
or
(c)
On any day when the applicants’
load
forecasts
(including bona
fide requests
fur emergency
power
from other companies)
exceed the
total estimated
capacity
available
to
them
from
any
source
(not
including
the
last
182
MW
of
capacity
from
Powerton
Units
1
through
4)
by
an
amount
sufficient
to
require
more than
1,000
MW
total
output
from
Units
I
and
2,
at
any
level
of
output
required
to
meet
the
load,
provided
that
total
station
output
shall
not
be
raised
over
1,000
MW
until
after
Commonwealth
Edison
has
interrupted
service
to
those
of
its
customers
whose
service
agreements
allow
for
such
interruptions.
In
no
event
shall
total
station
output
exceed
1,000
MW
for
more
than
eight
hours
fr
any
day.
(d)
The
biological
effects
of
operatIon
at
more
than
400
NW
without
the
diffuser
tlischarge
~‘all
be
monitored
by
the
applicants,
and
the
results
of
such
monitoring
program shall be reported to the Environmental Protection
Agency not later than December
1,
1972.
I,
Chris-tan Moffett, Clerk of the
Illinois Pollutio~ontrol Board,
certify
that
the
above
Opinion
was
adopted on the ~
‘day of April,
1972,
by
a
vote
of
_____
to
/
4— 411