ILLINOIS POLLUTION CONTROL BOARD
September 21, 1978
CITY OF SPRINGFIELD,
)
Petitioner,
v.
)
P~B
78—23
PCB 78—52
CONSOLIDATED
ENVIRONMENTAL PROTECTION
)
AGENCY,
)
Respondent.
MR.
ROBERT
H.
WHEELER,
OF
ISHAN,
LINCOLN
AND
BEALE,
APPEARED
ON
BEHALF
OF
PETITIONER;
MR.
REED
NEUMAN,
OF
THE
OFFICE
OF
THE
ILLINOIS
ATTORNEY
GENERAL,
APPEARED
ON
BEHALF
OF
RESPONDENT.
OPINION
AND
ORDER
OF
THE
BOARD
(by
Mr.
Goodman):
The
City
of
Springfield
(City)
submitted
a
Petition
for
Specific Thermal Standard pursuant to Rule 203(i) (10) of the
Board’s Water Pollution Regulations
(Chapter
3)
on
February
2,
1978.
The Petition was docketed PCB 77—23.
On February
24,
1978,
the City submitted a Rule 203(i) (5)
Petition, which
was docketed PCB 78-52.
The Board consolidated the two pro-
ceedings on March
2,
1978.
A consolidated hearing was held on
June
12, 1978,
in Springfield.
No citizen witnesses appeared.
The subject of these proceedings is the thermal discharges
from the City’s Lakeside and Daliman electric generating facili-
ties to Lake Springfield,
a man—made, 4,234 acre cooling lake
with 57 miles of shoreline.
These facilities include Lakeside
I,
a
35 megawatt
(MW) facility scheduled for retirement in 1981,
Lakeside II,
a 106 MW facility which is to be placed on cold
stand-by when Lakeside
I is retired, and Dailman,
a plant with
two existing boilers each with approximately
80 MW capacity and
a third 180 MW
unit
scheduled to begin service in July of this
year.
All of these generating facilities are cooled using lake
water on a once-through cooling cycle.
There are separate
intake
and discharge facilities for the Lakeside plants and the Dailman
plant.
31—463
—2—
Rule 203(i) (5)
requires the owner of a source of thermal
effluent to demonstrate to the Board that discharges from that
sOurce have not caused and cannot be reasonably expected to cause
significant ecological damage to the receiving waters.
Rule
203(i) (10)
allows a source to obtain a thermal standard for dis-
charges to a cooling lake different than the thermal water quality
standards of Rule 203(i)
if the source demonstrates that the
cooling lake will be environmentally acceptable and within the
intent of the Act.
The City proposes that the following tempera-
ture limitation, based on historic and projected operating con-
ditions, be applied to its thermal discharges:
The thermal discharge to Lake Springfield
from the Lakeside plant shall not exceed
99°more than 5
of the hours in the
12—month period ending with any month and
the discharge from the Dalirnan plant shall
not exceed 99°more than 8
of the hours
in
the 12-month period ending with any month
and at no time shall any discharge exceed
109°.
As part of its showing pursuant to both Rules
203(i) (5)
and 203
Ci) (10),
the City has submitted a thermal standard study of Lake
Springfield dated August,
1977,
by Betz Environmental Engineers,
Inc.
In addition, the City presented several witnesses at hearing.
The
Environmental
Protection
Agency
(Agency)
at hearing and in its
brief supported the City’s position.
The City’s Exhibit
2
indicates that the temperatures
in
the
discharges from seven separate condensers at Lakeside measure
as
high as 108°Fand that condenser discharge temperatures from the
2 Dallman condensers measure as high as 113° (R.26).
Condenser
discharge temperatures at Lakeside have exceeded 100°as much as
7.6
of the year for one boiler, and at Dalirnan individual con-
denser discharges have exceeded 100°as much as 6.2
of the year.
Temperatures exceeding 90°occurred in Lakeside condenser dis-
charges 14.9
of 1976 and 24
of 1977,
and in Daliman condenser
discharges
20.2
of 1976 and 23.6
of 1977.
Based upon these
actual measured temperatures,
the City alleges its proposed
standard is representative of recent operating conditions at
Lake Springfield.
The City furthermore indicates that the
addition of Dallman Unit
3 is not expected to cause higher
temperatures than those experienced, although it may increase
the 5°mixing zone
(R.29,
58—59)
The record contains much information about the effect dis-
charges at these temperatures have upon Lake Springfield.
Mr.
Charley Narbut, District Fish Biologist in Sangamon County for
31—464
—3—
the Department of Conservation, appeared at the hearing and
entered into the record a letter containing the results of
electro—fishing surveys of Lake Springfield conducted by the
Department in 1963,
1972, 1975 and 1977
(R.9).
The surveys
evaluated five species of sport fishes:
largemouth bass,
bluegill, channel catfish,
flathead catfish, and white
crappie.
The conclusion of the surveys was that the fish pop-
ulations had remained stable throughout the years.
The channel
catfish and flathead catfish populations are considered to be
among the top in the state.
Mr. Marbut concluded that this
fishery is growing and expanding and is expected to provide
excellent fishing
(R. 14—15).
Dr. William Walker presented the results of the thermal
study of Lake Springfield done by
Betz
Environmental
Engineers.
A study of the thermal plume indicated that both the Lakeside
and Dailman
heated
effluents
remain
near
the
upper
five
feet
of
the lake water so that even though the 5°mixing zone may be
exceeded occasionally,
a safe zone of passage for fish is always
maintained beneath the plume.
Measurement indicated this zone
of passage contains sufficient dissolved oxygen levels to allow
fish to avoid undesirable temperature conditions.
Dr. Walker
also testified about surveys of existing aquatic populations on
the lake conducted under his direction.
The populations sampled
were algae,
zooplankton, benthic macroinvertebrates and fish.
In addition, Dr. Walker compared data from Lake Springfield to that
for
5 other Illinois lakes.
He concluded
that
the
overall
aqua-
tic
ecosystem
and
water
quality
of Lake Springfield is in healthy
condition for an aging lake and is without a general adverse
environmental effect.
He testified that there
is no evidence
of significant ecological damage due to the thermal discharges.
In addition,
Dr. Walker testified that because Dailman Unit
3
is designed to maintain a temperature change no higher than
previously experienced in the North Basin of the lake, no detri-
mental effect is expected from the addition of the Dallman
3
discharge.
Finally, his analysis of seven important fish species
(including a stomach analysis) revealed that adequate spawning
habitat is present,
that fish were avoiding high temperatures
and seeking the safe “zone of passage” beneath the warmer thermal
plume, and that there was
a wide and sufficient food source for
fish in Lake Springfield
(R.69—74).
Mr. Paul Bonarisinga, with the City, testified about alter-
natives to establishing a specific thermal standard.
These
include cooling towers,
a spray canal,
an extended discharge
pipe,
or a modified discharge channel
(R.32).
Although all of
these alternatives would allow the City to meet current mixing
zone requirements, only cooling towers or a spray canal would
31—465
—4—
result in compliance with maximum discharge temperatures.
How-
ever, both the cooling tower and spray canal, which would cost
approximately $13,500,000 and $10,000,000, respectively, would
create
dangerous
fogging
and
wet
conditions
on
the
interstate
highway next to the plant and would create an acid mist when
combined
with
emissions
from
the
plant.
Rule 203(i) (10) (cc) specifically provides that at hearing
the discharger must demonstrate with respect to the lake:
(1)
..
.
conditions capable of supporting
shellfish,
fish,
and
wildlife,
and
recre-
ational uses consistent with good manage-
ment practices, and
(2)
control
of
the
thermal
component
of
the
discharger’s
effluent
by
a
technologically
feasible and economically reasonable method.
The
Board
finds
that
the
City
has
met
its
burden
of
Droof.
In
addition,
the
Board
finds
that
the
City
has
met
its
Rule
203(i)
(5)
burden of proving that discharges from Lakeside and from Dallman
1 and
2 have not caused and cannot be reasonably expected to cause
significant ecological damage to Lake Springfield.
The Board notes,
however, that the City will be required to comply with Rule 203(i)
(5) with respect to Dallman Unit
3,
a new source, within five to
six years after commencement of operations.
This Opinion constitutes the findings of fact and conclusions
of law of the Board in this matter.
ORDER
It
is
the
Order
of
the
Pollution
Control
Board
that:
1)
The thermal discharge to Lake Springfield from
the Lakeside plant shall not exceed 99°more than
5
of the hours in the 12-month period ending with
any month and the discharge from the Dailman plant
shall not exceed 99°more than
8
of the hours
in
the 12-month period ending with any month and at
no time shall any discharge exceed 109°.
31—466
—5—
2)
The City of Springfield has complied with Rule
203(i) (5)
of Chapter
3 in that it has proven that
the thermal discharge from its Lakeside Plants
I
and II and from its Dailman Units
1 and 2 has not
caused and cannot be reasonably expected to cause
significant ecological damage to the receiving
waters.
I, Christan L.
Moffett, Clerk of the Illinois Pollution
Control Board, hereby ~rtify
the above Opinion and Order
were adopted on the
~
day of
~
,
1978 by
a
J
rr~L
Christan
L.
floffè
,
Clerk
Illinois Pollutio
ontrol Board
31—467