ILLINOIS POLLUTION CONTROL BOARD
November
21,
1985
COMMONWEALTH
EDISON COMPANY,
Petitioner,
PCB
85—162
and
PCB 85—194
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
OPINION AND ORDER
OF
THE
BOARD
(by
N,
J~ Nega);
PCB 85—194
is
a provisional variance extension
request which
comes before
the
Board upon a November
21, 1985
Recommendation of
the Illinois Environmental Protection Agency (Agency)~ The
Agency recommends that
a 10—day provisional variance
extension
for the time period from November
30,
1985 until December
9,
1985
be granted
to
Commonwealth Edison Company from 35 I1l~Adm~
Code
304~124as
it pertai~nsto total suspended solids
(TSS)
and oil
while necessary repairs are being made
to
the
Miscellaneous
Wastewater Treatment Facility (MWWTP) at the Petitioner~s
Zion
Generating Station.~
(Rec. 1)~ The Board previouslygranted
the
Petitioner
a
30—day
provisional variance
in PCB 85—162 on
Dctober
24, 1985,
(See:
Opinion and Order of October
24, 1985
and Order
of
November
21, 1985
in PCB 85—162, Commonwealth Edison
Coj~panj
v.
IEPA),
In PCB
85~162,the Petiti~irreque~E&~Tnterim
~fluent
limitations of 75 milligrams
per liter
(ing/1) TSS
and
75
mg/i oil during the
time period that repairs and maintenance
operations
are performed~
PCB 85—162:
Modification
On October
29, 1985, Commonwealth Edison Company filed
a
Petition
to Modify Board Order which requested that the
Board
modify
its Order
of October
24, 1985,
so that the period
ofthe
30—day provisional variance commences on October
31, 1985,
rather
than on October
24,
1985,
to coincide with
the start
of
repairs
on
the Petitioner~sMiscellaneous Wastewater Treatment
Facility.
Although the Agency filed
no formal written response
to
the
Petitioner~smotion,
the Agency attorney handling this
case
orally represented
to the Board
that the Agency h~:s“no
objection”
to the requested modification,
Additionally,
the
Agency~sprovisional variance extension recommendation~to
extend,
for
10
days,
the provisional variance previously granted
in PCB
85—162,
implicitly demonstrates that the Agency approves
of
the
petitioner~sproposed modification of
the October 24,
1985
Order
in PCB 85—162.
—2—
PCB_85—194:
Extension
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,
Illiinois,
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
monit~oring
drains.
Treatment
is customarily provided by
a
flow equalization
basin,
flocculator/clarifiers,
and filters,
These
flows
average
0.21 million
gallons per day
(MGD) and effluent
is discharged
into Lake Michigan.
The
Petitioner
is currently required by
its NPDES Permit
#1L0002763
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~
The Petitioner~S
NPDES Permit has not historically
required
sampling for TSS
and oil at outfall
OOla.
However,
NPDES Permit
#lIL0002763 has been
reissued
and became 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 are now mandated.
During
the time period
that the Miscellaneous Wastewater
Treatment Facility
is being
repaired, the Petitioner
is
rerouting
wastewaters from the
station fire sump to the Unit
1
oil/water
separator.
This
oil/water separator, which
is currently
designated
as
outfall OOle
in the reissued NPDES Permit,
is
ordinarily used
for treating parking
lot runoff
and,
as
presently
configured, does
not permit effluent
samplings
However,
Commonwealth
Edison believes that this oil/water
separator can
reduce
the oil content
of the discharge by as much
as
80.
Commonwealth Edison
intends
to remove oily sludges from the
bottom of
its
equalization basin which have accumulated
over a
period
of time to a
depth of between three
to five feet.
Because
the
flows are mixed with the Unit
1 condenser
cooling water discharge
(about 1200 MCD) and
since oil
booms will
be used throughout
the Petitioner~splant
to contain any
extraneous oil
which may escape,
the Agency believes that the
environmental impact
of the discharge
from the Unit
I oil/water
separator will be
minimal,
During
an inspection
of
the Petitioner~swastewater
treatment equipment,
a
cracked shaft was discovered,
Prior
to
the commencement
of
its
other repairs,
the Petitioner was unaware
that this shaft
needed replacements
Expeditious replacement of
66~436
—3—
this
shaft
is necessary to assure
the proper operation
of
Commonwealth Edison’s MW~QTPO
(Rec.
1).
Based
on the necessity
of
the cracked
shaft repairs
to
return the Petitioner~sfacility
to
proper operating condition,
the short
time period of
the proposed
extension,
the
minimization
of down time,
and upon the treatment to he provided
in
the
interim period while maintenance
and repair work
are
being
completed,
the Agency believes that a
provisional
variance
extension is appropriate in the present
case.
The Agency
has
therefore
concluded
that
compliance with
the
total
suspended
solids
standards would
impose
an
arbitrary or
unreasonable
hardship
upon
Commonwealth
Ed:Lson
Company.
Accordingly,
the
Agency
has
recommended
that:
the
Board
grant
the
Petitioner
a
provisional
variance
extension
from
35
Ill,
Adm.
Code
304.124
as
it
pertains to
total
suspended
solids
and
oil,
subject
to
certain specified conditions.
On
the
other
hand,
in
another portion
of
the Recommendation,
the
Agency argues
that
under federal law the Board
is
precluded
from
granting the
requested variance from the oil effluent limitations and has not
recommended
that such relief
be granted.
The Board
has
denied
that relief
on
the basis
of this argument,
and has corrected the
Recommmendation’s
internal
inconsistency
by
deleting
the
grant
of
variance
from
oil
see
paragraph
B(l)
below
Pursuant
to
Section 35(b)
of
the
Illinois
Environmental
Protection Act,
the Board hereby grants the
provisional
variance
extension as r~cominended.
This Opinion constitutes
the Board~s
findings
of fact and
conclusions of law
in this matter.
ORDER
A.
Paragraph
1
of
the
October
24,
1985
Order
in
PCB
85—162
is
modified
to
read
as
follows:
1.
This
provisional
variance
shall
commence
on
October
31,
1985
and
shall
continue
for
a
period
of
30
days,
or upon the
completion
of
repairs
to
the
Miscellaneous
Wastewater
Treatment
Facility,
whichever
occurs
first..
B.
Commonwealth
Edison
Company
is
hereby
granted
an
extension
of
its
provisional
variance
from
35
Ill
Adm.
Code
304.124
as
it
pertains
to
total
suspended
solids
while
necessary
repair
and
maintenance
work
is
being
done
at
the
Miscellaneous
Wastewater Treatment Facility at
its
Zion
Generating
Station,
subject
to the following
conditions:
1.
This extension
of
its provisional variance shall
commence on November 30, 1985 and shall
terminate
upon the
completion of
repairs
to the Miscellaneous Nastewater Treatment
Facility,
or
on
December
9,
1985,
whichever
occurs
first.
86-437
—4—
2.
The Petitioner
shall take all
steps possible
to minimize
regenerative
wastewater,
as
outlined
in
its initial
petition for
provisional
variance.
3.
The Petitioner shall install oil
booms,
or similar oil
collection
devices,
throughout
the
station
to
minimize oil
from
entering
the
wastewater
system.
4.
The
process
flows
shall
be routed through the
Unit
I
Oil/Water
Separator
for
treatment
prior
to
discharge.
5.
The
Petitioner
shall
sample
the contents
of
the
tire
sump
and
at
a
poiot
as
represenative
as
possible of
the
discharge
of
the
oil/water
separator.
Grab
samples shall
be collected
daily
and
analyzed
for
total
suspended
solids
and
oil.
6.
The
Petitioner’s
effluent
shall
be limited,
during
the
term
of
this
provisional
variance,
as
follows’:
Daily
Maximum
~
Total
Suspended
Solids
100
mg/I
30.0
mg/l
7.
The
Petitioner’s
effluent
shall
meet
all
other
effluent
limitations
as
outlined
in
its
NPDES
Permit #1L0002763.
8.
The
Petitioner’s
request
for
relief
from
oil
effluent
limitations
is
hereby
denied
as
beyond
the Board’s authority.
9.
The
Petitioner
shall
dispose
of
its
sludges from the
Miscellaneous
Wastewater
Treatment
Facility
in
accordance with
the
appropriate
State
regulations
and
shall
obtain
the
proper
permits for
its disposal.
10.
The Petitioner
shall notify,
by
telephone,
the Agency’s
Maywood Regional Office when repairs
to
the
Miscellaneous
~astewater Treatment Facility are completed.
This
notification
shall
be made within 24 hours of
the
completion
of
the
repairs
and written notification
of the
completion
shall
be
sent
to:
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 Mr.
James Frost
of
the Agency
at
the following address:
Mr. James
Frost
Illinois
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 Boarã
in PCB 85—194,
dated November
21,
1985,
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
IT
IS SO ORDERED.
I,
Dorothy M.
Gunn,
Clerk of
the Illinois Pollution
Control
Board,
hereby
certify
that the above Opi
ion and Order
was
adopted on
the
_____________
day of
~
1985
by
a
vote
m
Dorothy
M. G~
Clerk
Illinois Pollution Control
Board