ILLINOIS POLLUTION CONTROL BOARD
    April 3, 1980
    CENTRAL ILLINOIS PUBLIC SERVICE COMPANY,
    (ilutsonville Power Station)
    Petitioner,
    v,
    )
    PCB 80—16
    ENVIRONMENTAL PROTECTION AGENCY,
    )
    Respondent.
    OPINION AND ORDER OF THE BOARD (by Dr. Satchell):
    This matter comes before the Board upon a variance petition
    filed January 21, 1980 by Central Illinois Public Service Company
    (CIPS). The petition requests for the Hutsonville power station
    a variance from the effluent standards for copper (total)
    ,
    iron
    (total) and iron (dissolved) which are found in Rule 408(a) of
    Chapter 3: Water Pollution. On March 3, 1980 the Environmental
    Protection Agency (Agency) recommended that the variance be
    granted with conditions. The hearing was waived and the Board
    has received no public comment.
    The Hutsonville power station is a 210 megawatt fossil—
    fueled electric generation plant which is situated two miles north
    of Hutsonville, Crawford County. On October 23, 1979 the Agency
    issued for the facility renewed NPDES Permit IL 0004120. This
    authorizes discharges from an ash pond to the Wabash River and
    discharge of boiler chemical and air heater cleaning solutions to
    the ash pond. The previous permit designated the ash pond dis-
    charge to the Wabash River as the point of discharge for these
    solutions. The new permit reauires application of the Rule 408(a)
    effluent standards at the point of discharge to the ash pond. On
    November 21, 1979 CIPS filed a petition for review of these permit
    conditions which is pending before the Board (PCB 79-247).
    During ordinary operation deposits build up inside boiler
    tubes. At Hutsonville these deposits are mostly iron and copper
    compounds which derive from corrosion of metal in the system. CIPS
    cleans boilers 5 and 6 at Hutsonville about once in three years.
    Cleaning is to take place during scheduled outages which for Boiler
    S is from February 3 through March 22, 1980 and for Boiler 6 is
    from April 27 through June 21, 1980. Delay in cleaning could re-
    sult in damage to the boiler. Rescheduling of cleanings is dif-
    ficult since CIPS must schedule generator outages with sufficient
    lead time to schedule other maintenance and so as to maintain
    adequate generating capacity in its system.

    —2—
    CIPS proposes to clean the boiler tubes by filling each with
    about 16,000 gallons (61,000 1) of a solution of ammoniated
    ethylenediaminetetraacetic acid (EDTA). This is a chelating agent
    which complexes metals rendering them water soluble in conditions
    under which they would otherwise be insoluble. After use the
    cleaning solution will contain about 700 pounds (320 kg) of iron
    and 200 to 300 pounds (90 to 140 kg) of cooper. This will be far
    in excess of the concentrations allowed by Rule 408(a). The
    boilers will be rinsed three times with water, resulting in another
    48,000 gallons (180,000 1) of water per boiler which will contain
    less iron and copper but will probably still exceed the concen-
    tration limits of Rule 408(a) (Pet. 3). The Agency estimates that
    a total of 2000 pounds (900 kg) of iron and 200 pounds (90 kg) of
    copper will be removed per boiler (Rec. 2).
    This is the first time the EDTA solution has been used at
    Hutsonville (Rec. 2). The ash pond provides treatment as well as
    dilution for the iron and copper in the effluent since the metals
    precipitate as hydroxides under basic conditions present in the
    ash pond. However, the Agency believes the EDTA chelated metals
    will be much more resistant to precipitation than the metals con-
    tained in other cleaning solutions. A detention time of 60 to
    120 days may be required. This may be greater than that provided
    by the ash oond (Rec. 3).
    CIPS retained a consulting engineering firm to investigate
    alternative methods of disposal. Three basic engineering alter-
    natives were proposed: incineration, chemical treatment and. off—
    site disposal. The first two could not be developed in time for
    the scheduled 1980 cleanings (Pet. 4). CIPS proposes to haul the
    spent EDTA cleaning waste to an Agency approved disposal facility.
    The EDTA will be pumped back into the tank trucks which deliver it.
    However, it would be impracticable to haul the 48,000 gallons of
    rinse water off site for disposal. It is doubtful if enough tank
    trucks are available to do this at the present time. Construction
    of a holding tank could not be done prior to the cleanings. The
    i3oard therefore finds that it would impose an arbitrary and un-
    reasonable hardship on CIPS to require immediate pretreatment of
    the rinse solutions.
    Air heater cleaning involves much l~irgervolumes of water
    than boiler cleaning (Pet. 7). Disposal of the contaminated water
    poses problems similar to the boiler rinse. The Agency has con-
    ceded, for purposes of this variance only, that the ash ponds are

    —3—
    adequate to precipitate the iron and copper from the air heater
    wash solutions. Since very little of this will be discharged to
    the Wabash River, the Board will grant a variance for the air
    heater cleaning solution wastes also. Since CIPS has not indicated
    a different cleaning schedule for air heaters, this variance will
    expire upon completion of the boiler cleaning.
    This Opinion constitutes the Boardts findings of fact and
    conclusions of law in this matter.
    ORDER
    Central Illinois Public Service Company is granted for its
    Hutsonville power plant a variance from the effluent standards
    for copper (total), iron (total) and iron (dissolved) of Rule
    408(a) of Chapter 3: Water Pollution, subject to the following
    conditions:
    1. This variance will expire on July 22, 1980.
    2. This variance will apply only to boiler cleaning rinse
    water and air heater wash discharges into the ash pond.
    3.~ Petitioner shall not discharge EDTA boiler chemical
    cleaning solution into the ash pond.
    4. Petitioner shall conduct a study to determine treatment
    capabilities of the ash pond. The study shall include
    as a minimum data on pH of the ash pond, the constituents
    in the metal cleaning waste rinses, the concentration of
    the constituents and the volume of the metal cleaning
    waste rinses discharged to the ash pond. A summary of
    results shall be sent to the Agency by August 30, 1980.
    5. The Agency, pursuant to Rule 914 of Chapter 3: Water
    Pollution, shall modify the NPDES Permit IL 0004120
    consistent with the conditions set forth in this Order.
    6. Within forty—five days of the date of this Order, Peti-
    tioner shall execute and forward to the Illinois En-
    vironmental Protection Agency, Variance Section, 2200
    Churchill Road, Springfield, Illinois 62706, a Certifi-
    cate of Acceptance and Agreement to he bound to all
    terms and conditions of this variance. This forty-five
    ‘hiy
    pen
    od shal 1 be liel (1 in abeyance for any period this
    na
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    —4—
    CERTIFICATION
    I, (We),
    ______________________,
    having read
    and fully understanding the Order in PCB 80-16,
    hereby accept that Order and agree to be bound by
    all of its terms and conditions.
    IT IS SO ORDERED.
    SIGNED
    TITLE
    DATE
    I, Christan L. Moffett, Clerk of the Illinois Pollution
    Control Board, he~~ycertify the above Opinion and Order were
    adop~don the ~
    day of
    ______________,
    1980 by a vote
    Christan L. Mof
    ,
    Clerk
    Illinois Polluti Control Board

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