ILLINOIS POLLUTION CONTROL BOARD

March 14,

1986

COMMONWEALTH EDISON COMPANY,

(Joliet Generating Station

)

Units

7

& 8),

Petitioner,

v.

)

PCB 86—39

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Respondent.

OPINION AND ORDER OF THE BOARD

(by W.J. Nega):

This provisional variance request comes before the Board

upon

a March 14,

1986 Recommendation of the Illinois

Environmental Protection Agency (Agency).

The Agency recommends

that

a 30—day provisional variance be granted

to the Petitioner

from 35

Ill.

Adm.

Code 304.124

as

it pertains

to total suspended

solids

(TSS)

and

from 35

Ill. Adm. Code 304.102(a)

as

it relates

to emergency discharges from the coal pile area runoff basin

for

Units

7 and

8 at Commonwealth Edison Company’s Joliet Generating

Station.

(Rec.

1).

Commonwealth Edison Company owns and operates

a coal—fired

electrical generating station known as the Joliet Generating

Station which

is located

on the Des Plaines River

at Route

6 and

Larkin Avenue

in Joliet,

Illinois.

The Petitioner’s coal pile

area runoff basin

is served by an emergency discharge point

system.

Flows

into the coal pile area runoff basin are

from

eight primary sources which include:

(1) Unit

7

and

8 coal pile

runoff;

(2) Unit

7 and 8 drive house

floor drains;

(3) Unit

7

roof drains;

(4) Unit

7

and

8 turbine room floor drains;

(5)

the

coal cracker sumps

(both east and west);

(6)

the crusher building

sump;

(7) the demineralized water tank area runoff, and

(8) the

equipment storage building floor

and roof drains.

Intermittent

flows result, with the volume of water

being largely dependent on

the amount of rainfall during

a given time period.

(Rec.

1).

At the present time,

the coal pile area runoff treatment

system consists of two 500 gallon per minute

(gpm) pumps.

These

two pumps transfer the effluent from the coal pile area runoff

basin

to oil coalescers

for further treatment.

The water

is

subsequently discharged

to the Des Plaines River.

During heavy

rainfall, the volume

of water entering the coal pile area runoff

basin rapidly increases.

On such occasions,

the filters

in the

oil coalescers become clogged because of the high amounts of

solids

in the incoming water.

This clogging of the oil coalescer

---

—2—

filters decreases the

flow rate through the filters at

the

precise time when maximum flow rate is most needed.

Accordingly,

the coal pile area runoff basin overflows through the emergency

overflow line

to the Des Plaines River during periods of very

heavy rainfall.

(Rec.

1).

The Petitioner

installed

a 1,000 gallon per minute pump

to

transfer water from the runoff basin

to the ash pond for

treatment as an

interim solution

to these troublesome emergency

discharges.

However, experience has shown that

a more permanent

solution

to this problem

is needed.

Therefore,

Commonwealth Edison Company

is requesting

a 30—

day provisional variance

to allow sufficient time to install

two

4,000 gallon per minute submersible pumps on

a concrete platform

in the coal pile area runoff basin.

These

two 4,000

gprn pumps

will discharge through

a new 16 inch line to the Petitioner’s ash

pond, thereby hopefully solving

the company’s emergency discharge

problem.

(Rec.

1—2).

The Petitioner

anticipates

that approximately half of

the

coal pile area runoff basin will need

to be dewatered and cleared

of sludge

in order

to install the necessary submersible pumps

and

concrete platform.

Although the Petitioner

intends

to process as

much water

as possible through the normal treatment process

(or

transfer

such water

to the ash pond for subsequent processing)

during

the term of the requested provisional variance,

the

company has asserted that the possibility of an emergency

discharge still exists and necessitates

the requested relief.

(Rec.

2).

In regard

to

the possibility of such emergency discharges,

the Agency has indicated that

it believes that the Petitioner

will

take appropriate precautions to prevent,

or

at least

minimize, any emergency discharges during the proposed variance

period.

(Rec.

2).

However, the Agency has determined

that the

Petitioner’s provisional variance request “fulfills Standard

Condition 12(b)

(Anticipated Non—compliance)

of Petitioner’s

N~PDESpermit”

and “as such,

it

is the Agency’s opinion that

Petitioner may use

this outfall

in the case of an emergency

only.”

(Rec.

2).

Thus, the Agency has concluded

that “relief

from 35

Ill. Adm. Code 309.102(a)

is unnecessary”

in

the present

case.

The Board

finds the Agency’s reasoning persuasive

in

reference to

the aforementioned matter and will therefore follow

the Agency’s recommendation not

to grant relief from Section

309.102(a)

The Agency believes that the environmental

impact of

the

proposed provisional variance will be minimal

“due to the

precautions Petitioner will

be taking during

the variance”

and

notes that there are no

federal regulations which would preclude

the granting

of the

requested relief from 35

Ill. Adm.

304.124

as

---

—3—

it pertains

to total suspended solids.

(Rec.

2).

The Agency has concluded that compliance with the provisions

of

35 Ill.

Adm. Code 304.124

as

it relates

to total

suspended

solids would

impose an arbitrary or unreasonable hardship upon

the Petitioner and emphasizes that “the end result of the

provisional variance will

be the solution

to

a longstanding

problem”.

(Rec.

2).

Accordingly, the Agency has recommended

that the Board grant the Petitioner

a provisional variance

from

35

Ill. Adm. Code 304.124

as

it pertains

to total

suspended

solids,

subject

to specified conditions.

Pursuant to Section 35(b)

of the Illinois Environmental

Protection Act,

the Board hereby grants the provisional variance

as recommended.

This Opinion constitutes

the Board’s findings of fact and

conclusions of law

in this matter.

ORDER

Commonwealth Edison Company

(Joliet Generating Station Units

7

&

8)

is hereby granted

a provisional variance from 35

Ill. Adm.

Code

304.124

as

it pertains

to

total suspended solids, subject

to

the following conditions:

1.

This provisional variance shall commence on March 17,

1986,

and shall continue for

30 days

or until installation of the two

4,000 gpm submersible pumps, concrete platform, and

16 inch line

to the ash pond

is completed, whichever comes

first.

2.

The Petitioner shall,

as

indicated, take all measures

necessary

to prevent or minimize any emergency discharges from

this system during

the variance period.

3.

Any emergency discharges from this system shall

be limited

to

50 mg/l TSS.

4.

The Petitioner shall notify Mr. Dan Ray of the Agency’s

Compliance Assurance Section via telephone at

217/782—9720 when

the work described above commences and when

it

is completed.

Each such notification shall be confirmed

in writing within

5

days

to:

Illinois Environmental Protection Agency

Division of Water Pollution Control

Compliance Assurance Section

2200 Churchill Road

Springfield, Illinois 62706

Attention:

Dan Ray

5.

During

the

term of this provisional variance, the Petitioner

---

—4—

shall

sample each emergency discharge which occurs from this

system and analyze

it

for TSS.

The results of this analysis

along with information as

to length of time the discharge

occurred and volume discharged shall

be submitted to

Mr. Dan Ray

at the address given

above

in Item #4

for each emergency

discharge that occurs from this system.

6.

During

the provisional variance period, the Petitioner

shall

submit

to the Agency

a request

to modify its NPDES Permit

#1L0064254

to include

the emergency overflow line from the coal

pile area runoff basin serving Units

7

&

8.

7.

The Petitioner shall

complete the work described

as

expeditiously as possible.

8.

The Petitioner shall

apply for

a construction permit

for

this

project.

9.

Within 10 days of the date of this Board’s Order,

the

Petitioner

shall execute

a Certificate of Acceptance and

Agreement which

shall

be sent

to Mr. James

Frost of the Agency at

the following address:

Mr. James Frost

Illinois Environmental Protection Agency

Division of Water Pollution Control

2200 Churchill Road

Springfield, Illinois 62706

This certification shall have

the following form:

CERTIFICATION

I,

(We),

,

having

read

the Order of the Illinois Pollution Control Board

in PCB 86—39,

dated

March 14,

1986,

understand and accept

the said Order,

realizing that such acceptance renders all terms and conditions

thereto binding and enforceable.

Petitioner

By:

Authorized Agent

Title

Date

---

—5—

10.

The Petitioner’s request

for

relief from 35 Ill.

Adm. Code

309.102(a)

is hereby denied

as unnecessary.

IT

IS SO ORDERED.

I,

Dorothy M.

Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify that the above Opinion and Order was

adopted on

the

~

day of

______________,

1986 by

a vote

of

‘7—c’

Dorothy M.

unn, Clerk

Illinois Pollution Control Board