ILLINOIS POLLUTION CONTROL BOARD
November 16,
1978
CENTRAL ILLINOIS PUBLIC SERVICE
COMPANY
(MEREDOSIA POWER STATION),
Petitioner,
v.
)
PCB 78—101
ENVIRONMENTAL
PROTECTION
AGENCY,
Respondent.
MR.
THOMAS
COCHRAN,
ATTORNEY
AT
LAW,
APPEARED
ON
BEHALF
OF
THE
PETITIONER.
MR. STEPHEN
GROSSMARK,
ASSISTANT ATTORNEY GENERAL,
APPEARED
ON
BEHALF OF THE RESPONDENT.
OPINION
AND
ORDER OF THE BOARD
(by Dr. Satchel?):
This matter comes before the Board for a determination,
as
required by Rule 203(i) (5)
of Chapter
3:
Water Pollution Reg-
ulations, that thermal discharges from Central Illinois Public
Service Company’s Meredosia Power Station have not caused and
cannot reasonably be expected to cause significant ecological
damage to receiving waters.
A hearing was held on July
19,
1978.
The Environmental Protection Agency
(Agency) has not filed a
recommendation
in this matter.
However,
at the hearing
a memo
representing the Agency’s view point was introduced and entered
as
an exhibit
(Resp.
Ex.
1).
Petitioner’s basic presentation
is the Thermal Study done by
R.
W. Beck and Associates pursuant
to Procedural Rule 602.
Some additional testimony was given at
the hearing.
The Meredosia generating station is located on the Illinois
River at mile 70.7 near the town of Meredosia,
Illinois.
This
station has
four units, one of which uses cooling towers.
The
total generating capacity of the three units using once—through
condenser cooling
is 388 MW
(gross).
The Thermal Study was done
with an error in total maximum generating capacity.
The figure
used was 366 MW.
R.
W.
Beck and Associates have submitted a
letter explaining that the revised data were reviewed by their
biological consultant and the determination was made that the
small increase in thermal discharge associated with the difference
between 388 MW and 366 MW would not change the conclusions of the
report
(Pet.
Ex.
1A).
32—101
—2—
The heat rejection at maximum generation
of 388 MW is
2.083 x
l0~Btu/hour
(Ex.
lA).
The temperature rise across the condensers
varies with plant generation
(and resultant heat rejection)
and
the number of circulating water pumps
in operation.
The condenser
temperature rise
for maximum generation and maximum circulating
water
flow
(606.2
cfs)
is 15.3 F
(Ex.
IA).
Procedural
Rule 602(c)
requires that Petitioner’s thermal
demonstration include actual and theoretical plume studies.
Petitioner’s study indicates these were included
(Ex.
1,
p.
3-1).
However,
Respondent’s Exhibit
1,
the Agency’s only comment on the
study, concludes that only one actual plume study took place and
that more actual plume studies should be done to verify the
“typical” and “worst case” modelling results.
At the hearing
Kenneth Robinson,
a Senior Environmental Engineer with R.
W. Beck
and Associates, testified that
WAPORA,
Inc. had done forty-three
thermal plume surveys from November,
1971 through February 1975
(R.
15-17).
The dates of these studies were inadvertently left
off of Table 3—1 of Exhibit
1 and were submitted as Petitioner’s
Exhibit
2
(R.
19).
These thermal studies were used by R.
W. Beck
to calibrate the correct computer modelling for site specific
analysis to predict the expected thermal discharge conditions
under typical and worst case conditions
(R.
18).
WAPORA also
conducted biological studies during that time period which on
evaluation demonstrated no significant ecological damage has
occurred as
a result of the discharge from the Meredosia station
(R. 19,
20).
The Thermal Study concluded that the predominant discharge
behavior configuration for the Meredosia plant is a shoreline—
attached plume.
Typical conditions for the winter,
spring and
summer seasons produce only minimal changes
in temperature
(Ex.
1,
4-4).
During these seasons, under typical conditions,
the areas within the 3 F and 5 F isotherms are less than one
acre
(Ex,
1,
4—4).
During the lower flow of the typical fall
condition, the areas within the 3 F and 5 F isotherms are eight
acres and one acre, respectively
(Ex.
1,
4—4).
However,
the
ambient river temperature during the typical fall season
is
relatively low
(60.8 F).
During the worst-case condition in the
fall season,
the areas within the 3 F and
5 F isotherms are larger,
reflecting lower river flow;
however, the ambient river temperature
is lower
(Ex.
1,
4—4).
Because of the low temperatures, the study
concludes that it
is highly unlikely that the waters within the 5 F
isotherm will be avoided by
fish;
although the cross-sectional area
of the river within the 5 F isotherm is thirty-four percent of the
total cross—sectional area of the river,
it will
not have any
32—102
—3—
measurable effects on fish movements
(Ex.
1,
4-4)
.
Under extreme—
worst case conditions, the condenser cooling water would comprise
about seventeen percent of the total river flow
(Ex.
1,
4—5)
Under worst case and extreme-worst case conditions the temperature
would rise into the 90’s
(Ex.
1,
4—4,
4—5).
The Board notes that
should these circumstances arise,
a
violation of Rule 203(i) (4)
of Chapter 3 would occur and Petitioner would be required
to take
corrective
action.
The study further concludes that field studies of the river
ecology for
the
period 1971—1975 indicate increases
in river
temperatures due to thermal discharge have caused only relatively
minor and inconsistent changes
in the aquatic community
(Ex.
1,
4-7).
Future thermal discharges under typical conditions are
unlikely
to cause consistently measurable changes
in the aquatic
community
(Ex.
1,
4—7).
Worst case conditions are likely to cause
minor changes
in the aquatic community
(Ex.
1,
4—7).
With extreme-
worst case conditions,
it is probably that losses of sensitive
biota will occur within the 5 F isotherm; however,
the probability
that these conditions will occur is very low
(Ex.
1,
4-7).
These
various changes will be generally localized and are unlikely to
result in significant ecological damage to the river
(Ex.
1,
4—7).
The thermal discharges are unlikely to have any adverse effects on
other animal life or adverse
secondary impacts on human recreational
activities
or any influence on commercial fishing in the river
(Ex.
1,
4—7,
4—8).
The Board finds that Petitioner’s Thermal Demonstration contains
the information required by Procedural Rule
602.
As noted at the
hearing the Meredosia station has an eighteen year history of full
operation with no apparent adverse ecological impact
(R.
26).
The
Board finds that the thermal discharges
from the Meredosia Power
Station have not caused and cannot be reasonably expected to cause
significant ecological damage to the receiving waters.
Petitioner
has satisfied the requirements
of Rule 203(1) (5)
of Chapter
3.
This Opinion constitutes the Board’s finding of fact and
conclusions of law in this matter.
ORDER
It is the Order of the Pollution Control Board that Central
Illinois Public Service Company has complied with Rule 203(i) (5)
of Chapter
3:
Water Pollution Regulations by demonstrating that
its thermal discharges from its Meredosia Power Station have not
caused and cannot be reasonably expected to cause significant
ecological damage to receiving waters.
32—103
—4—
I, Christan
L.
Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify the above Order and Opinion were
adopted on the
_____________
day of
?)ri~~44.’—~.u...
,
1978 by a
vote of
~
Illinois
Pollution
Board
32—104