ILLINOIS

POLLUTION CONTROL BOARD

June

14,

1984

ILLINOIS

POWER

COMPANY,

Petitioner,

V.

)

PCB 84—75

ILLINOIS ENVIRONMENTAL

)

PROTECTION

AGENCY,

)

Respondent.

OPINION

AND

ORDER

OF

THE

BOARD

(by W,

3.

Nega):

This provisional

variance request comes before the

Board

upon

a June

14,

1984

Recommendation of the Illinois

Environmental

Protection Agency (Agency).

The Agency recommends that

the Board

grant Illinois Power

Company

(IPC) a 45—day provisional variance,

beginning on June 18,

1984 and lasting until August

2,

1984,

from

the effluent limitations,

monitoring requirements, and special

conditions in its currently

expired NPDES Permit No, 1L0036919*

and from 35

Ill. Adm~

Code 304.124(a)

and 35

Ill.

Adm. Code

3O4.141(a)~

(Rec~4).

The requested provisional variance

would

enable the Clinton

Power Station to:

(1)

bypass

the existing

station flushwater

treatment facilities

so that preoperational

flushwaters

from the

outside ring header of the station fire

protection and safe shutdown

service water systems can be

dis-

charged directly to Clinton

Lake and

(2) to allow it to exceed

the total suspended solids

(TSS)

and total iron effluent standards

for these discharges,

(Rec.

1),

IPC is

in the process

of constructing a nuclear—powered

electrical generating facility

at its Clinton Power Station in

DeWitt County,

Illinois which

will include

a boiling—water reactor

and steam turbine generator,

varied

electrical transmission

facilities, normal operating and

emergency shutdown

heat dissipa-

tion systems, primary water

consumption

systems, a station fire

*phe

Petitioner~s

NPDES Permit No, 1L0036919 e,~iredon

July 31, 1980w

Although

IPC submitted an application

for its

renewal on January 29,

1980,

the NPDES Permit has not yet been

reissueth

On April

ii,

1984, the Agency issued

a

pre—public—notice

draft reissued NPDES

Permit for the Clinton Power Station,

The

Petitioner has requested

that an additional

special condition be

incorporated

in the final

NPDES

Permit which would

authorize

direct discharge to Clinton

Lake such as requested in this

provi—

sional variance~

(Pet.

1

& 2),

58-363

---

protection system, and a safe

shutdown service water system.

Construction of this station,

which has been designed to generate

933 net megawatts of electricity,

was

begun in October of 1975

and

is expected to be completed around October of

1986,

The

initial

fuel loading has been scheduled for January

of 1986 and

the initial commercial

operation is anticipated

to

begin in

November of 1986.

(Pet,

3—4;

see:

Figure

1),

The fire protection

system

(which

supplies fire

suppression

water throughout the

station) and the safe shutdown service water

system

(which supplies

water to cool safety—related equipment

such as diesel—generator

coolers,

residual

heat

removal heat

exchangers, and other

equipment necessary

for a

safe shutdown of

the reactor)

are designed

to he operated and available as precau-

tionary operational

systems to prevent the potential loss of

life,

personal injury,

and property damage associated with accident

or

emergency situations.

(Pet,

4;

see:

Figures

1,

2,

&

3).

IPC has preliminarily

scheduled the

flushing

of the

ring

header portion of the

station~sfire protection system for

June

18—19, 1984 and anticipates

that about 2.8

million

gallons

of

water will be discharged

during this time

period,

This

flushing

operation will

flush

the service water pumphouse piping,

the

10-inch supply line;

and

the 14—inch loop

line

with water being

discharged from all

29

of the hydrants on the loop header,

(Pet,

8;

Rec.

2),

Similarly,

the

flushing of the division no,

3

subsystem of

the safe shudown service water

system

is tentatively scheduled

for July 1—4,

1984 and is

expected to discharge about

2 million

gallons of water during

this short time

period.

Flushing opera-

tions will involve the flushing piping associated with the ECCS

heat exchangers

1A,

1B,

and 1C as well as with the switch

heat

removal condensing piping and diesel—generator

1C,

(Pet.

8;

Rec,

There appears to be no reasonable alternative to the method

suggested by IPC, since the

flushing water

which will be discharged

is all very far removed from the flushwater treatment system.

To

be able to convey this flushwater to the treatment system,

IPC

would need to either lay ~thousands of feet of hose~which would

improperly block station roadways,

or make

costly modifications

to the piping systems which are

presently

ready

for startup.

If

large quantities of hose were

laid,

safety

hazards from ruptured

or broken hoses might be prevalent,

Similarly,

if costly modifica-

tions to existing piping

systems were made,

these changes might

be contrary to the design and installation specifications of the

Nuclear Regulatory

Commission.

(Rec.

2).

The flushwater treatment

system,

which has a batch treatment

capacity of

2 million gallons and normally receives

flows

of

about 350,000 gallons per

week,

consists of a storage chamber and

58-364

---

a

treatment

pond

followed

by a

filter,

(Rec,

2—3),

Twelve

days

are

usually

needed

to

treat

and discharge

each

hatch.

IPC

has

stated

that,

if

the

treatment

system

was

expanded

to

accommodate

the

additional

fiushwaters

resulting

from

a

temporary

flushing,

it

would

result

in

the

unnecessary

expenditure

of

funds

(since

the

resultant

additional

capacity

would

be

needed

infrequently)

and

would

necessitate costly delays in the construction of the

generating

station

without any concomitant benefits,

(Rec,

3).

The

Petitioner

has

indicated

that

both

of the

pre—operational

flushes

are

necessary

and

are

critical

path

milestones

on

the

startup

schedule

for

the

Clinton

Power

Station,

IPC has asserted

that

each

day

of

delay

in

the

completion

of

a

~critical

path

item~

is considered

equivalent

to

a

day

of

delay

in

fuel

loading

and

is estimated

to

cost

about

$1,000,000.

(Rec,

3).

Because

IPC

personnel

est.

imate

that

it

would

take

30

days

to

construct

special

facilities

to

convey

and

provide

the requisite treatment

for

the

pre~o~erational

flushwaters,

the

expense

involved

in

such

an

alternative

include

construction costs

plus the substantial

equivalent

of

$30,000,000

due to the

completion

delay.

(Rec,

3).

Data

obtained

from

previous

flushes

indicates

that

TSS

and

total

iron

concentrations

have been well

within

allowable

limits

when

flows

have

been

greater than

1

million gallons.

(Pet.

10;

see:

Table

1;

Rec,

3).

Moreover, because precleaned

pipes will

be

used

in

the

systems

to

be

flushed,

minimal

suspended

solids

and

iron

levels

are

expected

to be present

in

the flushwater.

(Rec.

3)~

Although

the

actual flushing of the two

systems

is

anticipated

to

occur

on

only

six

days,

IPC

has

requested

a

longer

time

period

to allow for adjustment,

if necessary,

of

the

planned

schedule

for the pipe flushing activities,

(Rec,

4).

While the presently

expired NPDES Permit does not

include

a provision to authorize

the discharge of the ring header

and safe

shutdown service water

system,

future flushing activities of a similar nature are expected

to be authorized in the proposed NPDES Permit which is presently

under public notice,

(Rec.

3—4),

IPC has requested this provi-

sional variance in order to maintain its construction schedule

and

control

its costs while discharging the necessary flushwaters.

The

Agency believes that the denial of

the

provisional

variance

would

impose an arbitrary or unreasonable hardship

on

the

Petitioner,

Thus,

the Agency recommends that

the

Board

grant

Illinois

Power

Company

a

45—day provisional variance from Sections

304,124(a)

and 304,141(a) to

begin on June

18,

1984,

subject to

certain

conditions,

Pursuant to Section 35(h) of the Illinois Environmental

Protection Act, the Board hereby grants the provisional variance

as

recommended,

However,

in so granting this provisional variance,

the Board

—4—

wishes to

alert

the parties

to portions of

the Petition

and

attachment that appear to

suggest that future flushing activities

may violate Board effluent

standards

and that these activities

are to be authorized in

a proposed NPDES permit renewal

(see

Pet.

unnumbered p.

3,

lines 2—5;

p.

4,

lines 4—6; Attach,

p.

3, para.

3

and 4),

It

is,

of course,

unacceptable

to include, without a

Board variance,

a

permit condition that

allows Board effluent

standards to be exceeded,

Also, regarding the ~infrequently”

needed

additional capacity

(Pet,

p,

3,

lines

2-5),

the Board

wishes to alert the parties to the limits on the frequency with

which

provisional variances may be granted

in

Sec.

34(c)

of the

Act.

This Opinion constitutes

the Boardes findings of fact and

conclusions of law

ORDER

Illinois Power

Company is hereby

granted

a 45—day provisional

variance,

beginning

on

June

18, 1984 and

lasting until August

2,

1984,

from

the

effluent

limitations, monitoring requirements,

and

special

conditions

in

its NPDES Permit No,

1L0036919

and

from

35

Ill.

Adm,

Code

304,124(a)

and 35

Ill,

Adin,

Code

304,141(a)

to

enable

the

Clinton

Power Station to

(1)

bypass

the existing

station

flushwater

treatment facilities

so

that pre—operational

flushwaters from the

outside ring header

of

the

station

fire

protection and safe

shutdown service

water systems can be dis-

charged directly

to

Clinton Lake and

(2)

to allow it to exceed

the total suspended

solids and total

iron

effluent

standards

for

these discharges,

subject to

the following conditions:

1.

The

Petitioner shall notify Roger Cruse of

the

Agency~s

Compliance

Assurance

Section by

telephone

at

217/782—9720

when each flushing

event begins

and ends.

2,

The Petitioner

shall

monitor

these

discharges

by

taking

a

24—hour

composite

sample each day

that

discharge

occurs,

These samples shall

be

analyzed

for

pH,

total

suspended

solids and total

iron,

3.

The

Petitioner

shall

monitor

the

lake water used for

these

flushes

prior

to

its

use

by

24

hour

composite

samples.

The waters of

Clinton Lake shall

be analyzed for total

suspended solids, total iron and pH.

4,

The

results

of the above

referenced analyses, along

with

flow data

and dates and

times

of

each

discharge,

shall

be

sent

to

Roger Cruse within

10

days

after

the

last

day

of

each

flushing

event,

The

appropriate

documents

shall

be

sent to

the

following

address:

58-366

---

—5—

Illinois Environmental Protection Agency

Division of Water Pollution Control

Compliance

Assurance

Section

2200

Churchill

Road

Springfield,

Illinois

62706

5.

The

Petitioner shall perform the flushes

so

as

to

minimize

any

impact

upon

Clinton

Lake.

6.

Within

10

days

of

the

date

of

the

Board~s Order,

Illinois

Power

Company

shall

execute

a

Certificate

of

Acceptance

and

Apreement.

which

shall

be

sent

to:

Illinois

Environmental

Protection

Agency,

Division

of Water Pollution Control,

Compliance

Assurance

Section,

2200

Churchill

Road,

Spring-

field,

illinois

62706,

This

certification

shall have the

following

form:

CERTIFICATION

I,

(We),

_______________________________having read

the

Order of the

Illinois

Pollution Control

Board in PCB 84~75

dated

June 14,

1984,

understand and accept the said Order, real-

izing

that such

acceptance

renders all terms

and conditions

thereto binding and

enforceable,

Petitioner

By:

Authorized Agent

Date

IT

IS

SO

ORDERED,

I,

Dorothy

M.

Gunn,

Clerk of the

Illinois Pollution Control

Board,

hereby

certif

that the above

Opinion

and

Order was adopted

on

the

~day

~

1984 by a

vote of

____

~

Clerk

Illinois Pollution Control Board

58-367