ILLINOIS POLLUTION CONTROL BOARD
October 24,
1985
COMMONWEALTH EDISON COMPANY,
)
)
Petitioner,
)
v.
PCB 85-162
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
OPINION AND ORDER OF THE BOARD
(by W.
J.
Nega);
This
provisional variance request comes before
the
Board
upon an October
23, 1985 Recommendation of the Illinois
Environmental Protection Agency (Agency)
The Agency recommends
that
a 30-day provisional variance be granted
to Commonwealth
Edison Company from 35 Iii. Adm. Code 304.124
as it pertains
to
total suspended solids
(TSS)
and oil while necessary repairs are
being made to the Miscellaneous Wastewater Treatment Facility
(MWWTP)
at the Petitioner~sZion Generating Station.
(Rec.
4).
The Petitioner has requested interim effluent limitations of
75
milligrams
per liter
(mg/i) TSS and
75 mg/i oil during
the time
period
that repairs and maintenance operations are performed.
Commonwealth Edison Company owns and operates the Zion
Generating Station which is
a nuclear-fueled steam electric
generating
station
located
on
Lake
Michigan
in
Zion,
Illinois,
Station
wastewaters
going
to
its
Miscellaneous Wastewater
Treatment
Facility
consist of
(1)
the fire sump discharge,
and
(2)
station
roof
drainage.
The
fire
sump
discharge
includes
demineralizer
filter
backwash,
turbine
building
floor and
equipment
drains,
foundation
seepage,
auxiliary
boiler
blowdown,
demineralized
regenerate
wastes,
and
secondary
system
monitoring
drains.
(Rec.
1-2).
Treatment
is customarily provided by a flow
equalization basin, flocculator/clarifiers, and filters.
These
flows average 0.21 million gallons per day
(MCD)
and effluent
is
discharged
into
Lake Michigan.
(Rec,
2).
The
Petitioner
is currently required by its NPDES Permit
~ILOO02763 to meet effluent limitations of
15
mg/i TSS on
a
30
day average with
a 30 mg/I daily maximum and
15 mg/i oil with a
20 mg/i daily maximum for its discharge.
(Rec.
2).
No recent
effluent
data
was
initially
readily
available
because
the
Petitioner
was
not
required
to
sample
this
discharge
for
TSS
and
oil.
However, in telephone conversations
on
October
18,
1985
with
Commonwealth Edison employee Mary Ellen DiPonzio, the Agency
managed
to gather information on the effluent in question.
(Rec.
2).
Samples were
collected
at the fire
sump between October
1.
1985
and
October 17,
1985 which have yielded
the following
results:
$38~i99
-2-
9.66
ND
8.43
ND
7.16
ND
15.90
ND
50.50
144.6
36.30
77.7
24.00
2.47
31.10
0.72
53.10
4.53
23.50
0.84
17.85
11.5
17.44
7.7
15.10
ND
15.50
No Sample
12.30
2.29
12.40
2.3
11.90
1.21
(Rec. 2).
As previously indicated,
the Petitioner’s NPDES Permit has
not historically required sampling for TSS and oil at outfall
OOla.
However, NPDES Permit #11L0002763 has been ratssued and
will become effective on October 30,
1985.
In this reissued
NPDES Permit, the miscellaneous waste discharge has been
segregated from the condenser cooling water discharge of Outfall
001
and sampling for total suspended solids and oil will now be
mandated.
(Rec
2).
During the
time
period that the Miscellaneous Wast~water
Treatment Facility is being repaired, the Petitioner intends to
reroute wastewaters from the station fire sump to the Uhit
1
oil/water separator.
This oil/water separator, which is
currently designed as outfall OOle in the reissued NPDE$ Permit,
is ordinarily used for treating parking lot runoff and, as
presently configured, does not permit effluent sampling.
However, Commonwealth Edison believes that this oil/water
separator can reduce the oil content of the discharge by as much
as 802.
Although a temporary sampling device might possibly be
installed during the bypass of the MWWTP, the Petitioner believes
that such a sampling device would not yield representative
samples of discharges from the Unit 1 oil/water separator because
of the location of the discharge pipe in the separator and
because of possible back flow from Lake Michigan.
(Rec.
3).
Apparently, these cracks were first noticed by the Petitioner
almost two years ago in their initial stages and have now become
severe enough to require immediate repair.
(Rca. 3).
Commonwealth
Edison
intends
to
remove
oily
sludges
from
the
ND
a
no
data
available
—3
bottom of
its
equalization
basin
which
have accumulated ovcr e
period of
tine
to a depth of between three to five feet.
However, no immediate plan to dispose of these sludges has been
presented by the Petitio~er.
(Rec.
3).
lie Petitioner beJieves that there are no other practical
alternatiies to the
~
a
tment
plan
previously
delineated.
The
ftocs spparertly ‘‘anro
be ~reatedar the rad waste system
because
ti ey
are
too
largc.
and
because
the
oil
could
foul
the
filters
in
that
‘ys
em.’
(Rec.
3).
Commonwealth
Edison
Company
has asse.’ed that t’~only other alternative to its proposel plan
would be to close
ettin 7
r Generating Station at an
estimate
co’t of
$1 Ou
00
per
day.
(Rec.
3).
The
Agency ag e~s~‘itt
c Petitioner that the proposed method of
treatmer
is
the
orly
plan
wFs’h
will
give optional treatment
during
t. e
I
c
the
MW
‘P
out
of
service
without
causing
undue
economtc
iardship
‘r
c.nvirormei.al
problems.
(Rec.
3).
Becat.se
tin.
fib,
~
a
.1.
id
with
the
Unit
1
condenser
cooling
ater
Jina.i,
b
t
ltOO
YGD)
and
since
oil
booms
wilt
be
used
tIrot.ghout.
It
ri.
s
plant
to
contain
any
extraneous oil wtich may escape, the Agency believes that the
envirornental
impact
of
the
discharge
from
the
Unit
I
oil/water
separator
will
be
minimal
dditionally,
based
on
the
necessity
of
Lhe
cpair5
to
retrn
tat
Pe’aioner’s
plant
to
proper
operating
conditio
,
the
ma aimization
of
down
time,
and
upon
the
treatment
to
be
provided
in
the
interim
period while maintenance
and
repa
r
work
are
being
completed
the Agency believes that a
orovisLonal
variance
is
approoriate
in
the
instant case.
The
Agercy
has
‘he-
f
r
c
rcluded that compliance with
applt’abte
s
andards wo Id inpose an arbitrary or unreasonable
hardstip
upon
CoTnon
eaits
Mason
Company.
(Rec.
3-4).
Accord
igi
he
tgency
has
recommended that the Board grant the
Petitt)..°r
a
pros ~sors
variance
frnm
35
Ill.
Ad’n.
Code
304.12k
as
it
pe
tains
to
ttal auspended solids and oil, subject to
certain specified conditions.
PursLont to Se tici
35(b) of the Illinois Environmental
Protec
io
k
t
tIe
Board
hereby grants the provisional variance
as
re,on
-
de
his Opi
io.
onstitutes the Board’s findings of fact and
-onc
asi n
C
law
r Ui s
matter.
3
r
r
y grarted a pr~‘sioral
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f
i
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—5—
Illinois Environmental Protection Agency
Division of Water Pollution Control
Compliance Assurance Section
2200 Churchill Road
Springfield,
Illinois
62706
Attention:
Mr.
Roger
Cruse
11.
Within
10 days of the date of the Board’s Order,
the
Petitioner
shall execute a Certification of Acceptance
and
Agreement which
shall be sent to Nr~James Frost of
the Agency at
the following address:
il~:.
James Frost
TTlinois
Environmental
Protection Agency
Division
of
Water
Pollution
Control
Compliance Assurance Section
2200 Churchill Road
Springfield,
Illinois 62706
This certification shall have
the following
form:
I,
(We),
,
having read
the Order of the Illinois Pollution Control Board
in
PCB 86-162,
dated October 24,
1985, understand and accept the said Order,
realizing that such acceptance renders all terms and conditions
thereto binding and enforceable.
Petitioner
~3r:
Authorized Agent
Title
Date
IT IS SO ORDERED.
I, Dorothy
M. Gunn,
Clerk of the Illinois
Pollution Control
Boai:d,
hereby certify that the above Opinion and Order
was
adopted on the
______________
day of ~
,
1985
by vote
of
70
/~
~
Illinois
Pollution
Control
Board
86-203