ILLINOIS POLLUTION CONTROL BOARD

November

15,

1971

In the matter of

JOINT APPLICATION OF

)

#

71-20

COMMONWEALTH EDISON CO. AND

IOWA—ILLINOIS GAS

& ELECTRIC CO.

(QUAD CITIES PERMIT)

O~inionof

the Board

(by Mr.

Currie):

Like in 70-21, Application of Commomwealth

Edison Co.

(Dresden

~3), decided March

3 and April

28,

1971, this is

an application under

Title \‘I-A of

the Environmental Protection Act for

a permit to

onerate

a new nuclear generating

station,

this one consisting

of two 809-mw boiling—water reactors at the Quad—Cities plant

near Cordova on the Mississippi River

in northwestern

Illinois.

We grant the permit on terms similar to those imposed in the

Dresden case, with differences

indicated below.

We note

that

there

are environmental considerations on both

sides in this case.

Petitioner Iowa-Illinois operates

an

old, smoky coal—fired power plant

in Moline that cannot be retired until Quad-Cities

is

in operation.

Every day’s delay

in bringing Quad-Cities

on line means another day

of dirty air

in Moline.

Sec Iowa-Illinois Gas

& Electric Co.

v,

EPA,

6

71-65

(Sept.

16,

1971).

The

statutory

framework,

the

operation

of

a

reactor,

the

environmental problems

and

their

means

of

control,

the

federal

radiation standards,

their derivation,

and their relation to

state law,

are all explained

in detail in our March

3 Dresden

opinion

and will not be repeated here.

The utilities raise once

again

the argument that federal

law deprives

us

of authority

to set standards for radioactive reactor discharges; we adhere

to

the

contrary

position

for

reasons

given

in

the

first

Dresden

opinion,

and

to the other lurisdicational and statutory interoretatio~

conclusions

there

reached.

As

held

in

Dresden,

our authority

in

this proceeding extends

to

all

environmental aspects of

the Quad—Cities

station,

the most

critical

of which

are gaseous

and liquid radioactive wastes,

protection

against

radiation

resulting

from

accident,

and

thermal

discharges

to

the

river.

We

also

must

examine

provisions

for

disposal

of~ .~olid radioactive

wastes,

for

ordinary

chemical

waste

and

sewage,

and

for

control

of

any

conventional

air

pollutants

that may be generated

by such sources

as boilers.

If construction

had not yet begun, we should be concerned with plant siting as

well.

But construction

is

all but complete.

Pursuant

bo permission

granted July

22

(see transcript of Board meeting of that date)

fuel loading

has

been completed

in

Unit

#1,

testing

at

significant

cower loads

is ready to begin, and full commercial service

is expecte~

in the

near future.

Unit

~2

is

to

be

loaded

in

November,

with

a

similar

testing schedule contemplating

full operation not long after

the

first

of

the

year

We shall discuss the several points of

environmental concern separately.

3—95

---

~.

i.Lnlts Is desI~nedto emit no more than 100,000 microcuries per

second ~.uCI/sec)

of gross activity,

and

with fair fuel performance

.s exzected to emit no more than 25,000 uCi/sec as a long—term

ave’ase

R. ~45l,5811,

593;

Environmental Feasibility Report,

r.

21), with monthly averages possibly ranging as much as

1~

1/2 times as high. (R. 454).

Emissions from other

sources are

far

smaller; the principal one is the turbine

~iandseals, which

are

expected to emit only 625 uCi/sec

(R.

1177).

Original

AEC

emission limits were designed in individual cases

so as to assure that the annual radiation dose to a hypothetical

person spending all his time in the open air at the plant boundary

(“fencepost”) wouldnot exceed 500 millirem (mr).

In the case

of Quad—Cities this standard could be

met

if emissions (except

for the

small

ventilation stack emissions) were limited to

350,000 uCi/sec when both units

are

operating at full power

and 250,000 when one is

(R.

11714).

Anticipating much better

performance than this, Edison

and

Iowa—Illinois have proposed

annual

emission limits of 110,000 uCi/sec and of 80,000, for

both units or for one, respectively, which would produce a

fencepost dose of 157 mr per year CR.

26, 474).

As the companies

point out, the actual dose to persons living or passing through

the vicinity will be significantly lower, since most people

live inside houses that provide some shielding, most do not

live at the property line, and most spend part of the time

away from the site.

Natural background radiation in the area

is said to yield an annual dose of 100 to 140 millirems

CR.

146; Environmental Feasibility Report,

p. 22).

Moreover,

at instantaneous emission levels Just under half the annual

average limits proposed (52,500 and 37,500 uCi/sec for both

units and for one), the companies pledge to

make

operational

changes if possible to reduce emissions at once and to look

toward early fuel replacement if necessary, since several

months may be required to rectify the sItuation without

unduly interfering with power production

(H.

26, 50—52).

Beyond this, however, as at Dresden, the utilities have

begun the design and are committed to the construction of

additional control facilities, consisting of a devibe for

reconbinin hydrogen with oxygen and e4ght charcoal beds to

afford a substantially longer delay before discharge ~sothat

short—lived isotopes

may

decay to insignificance.

These facilities

will cost $3,500,000

for

each of the two generating units

CR.

365—72); they will be completed within thirty months

after design was started, or about December 1973 CR.

28, 54);

they will reduce design level off—gas emissions fi’om each

unit

from 100,000 uCi/sec to less than 2500 (a factor of 40)

CR.

469,

473),

and

the annual fencepost off—gas dose from both

units operating at full power to 2.’I millirems, with an

3—Is

---

additional

0.08

mr/yr

O.8~J from the gland

seals, which

cannot

be routed throughthe charcoal system

(R.

365~-72,

478).

Utilizing

the

expected

annual

average

emissions

rather

than

the design figures,

the additional facilities would reduce

single—unit

emissions

to 625 and emissions from both units

operating together to

1250, •which when added to the gland seal

emissions of 625

each

unit?

would yield an approximate

site

emission of only

2500 uC.i/sec

and

a total fencepost dose

clearly

less

than

5 millirems per year.

The utilities contend that exposure to 170 millirems

per year is quite

safe, as

the ABC standards themselves incorporate

substantial margins

of safety below dose levels at which adverse

sQnatic

or genetic effects have been found

(R.

324),

There

is

of course

a school of thought

that the effects of radiation

are

in linear proportion to

the dose and that there

is no

threshold

(see the March

3 Dresden opinion fbr discussion).

Because of this possibility,

and in order to be especially

safe in dealing with such

a dangerous phenomenon as radioactivity,

we adopted in the Dresden case, and reaffirm here, the policy

of requiring use of the best practicable technology

for controlling

radioactive

emissions,

even though

a lesser degree of control

might suffice to avoid doses

set

to give breathing space below

levels

at which harm has

so far been discovered.

Accordingly

in Dresden

w~

adopted

limits

whose

effect

was

to require

the addition óf

a

r~combiner

and

eight

charcoal

beds,

and

we

do the

~

here,

as

the

companies

have agreed to do~

They

have agreed that

a fencepost dose of

5 millirems, which will be achieved by

this system,

is

a desirable

and achievable

goal

(B.

324,

474),

The ABC has recently required,

as

a numerical translation of the requirement of best practicable

control,

that the

dose to persons living near the

site

(which

should be

less than that at

the fencepost)

be limited to

5

mr/yr

(ABC Release

#778,

June

7,

1971)..

The companies propose

an interim emission

limit of 110,000

uCi/sec for all sources when both units operate and

80,000 when

one operates.

The recombiner

and charcoal beds will reduce

total site emissions by

a factor of

30.

Therefore, in light of

the reasons given above,

we shall reduce the proposed limits by

a factor of

30,

allowing

a small leeway

in rounding

off, to

4000 and

3000 uCi/sec, respectively,

as annual averages.

These

standards, based on poorer than expected fuel performance, will

allow some room for less than optimal operation,

since the

resultant doses are quite small.

We do not, however,

agree

with the companies that we should give such leeway (10,000

uCi/sec)

as to ignore the problem of excessive

fuel leakage;

the policy of best practicable treatment requires both good fuel

and good

controls.

We do

agree that there

is

no need

for monthly

averages, since at these

low levels only long—term exposures

are relevant and

since monthly values fluctuate enough that meeting

a strict monthly standard might impose

a significant hardship

(B.

454).

3

—

97

---

Very

~

~h~rt —ter..

e’t.

r

‘1

on-’

‘?

enurue

‘iuat

be

~.

r’~vented;

we

thlntc

tn!s

‘trobet

cm

be

,..Je?aatnt;

handled

by

the

AEC’s

accIdent

prov..aiono

and

t::

ra’ut~n~

the

coni aries

as

ajreed,

to

take

action

ehen

high emission levels (57,500 or

37,500

uCi/sec)

are

exceeded

on

an

lnjtantaneous

basis.

‘Ac

are

ur~edb.

thn

.~ttorr~e;

~enera

to

require

still

:urther

control

c

:tenc

ror~

.‘i:eouz

e:.itatan3.

Ct.

is

atCd

that.

“eon

.3ystems,

for

esnr

c.,

can

-

roiide

even

creator

de~reea

of

cont~ol than

can

ch2c.jas,

at

low...r

cot,

and

can

in

adcCtion

r~.’~ovt“rot.

the

affluent.

:aa

lon.;—flved

vadlo1.’flojns

01’

XCflOfl

and

kr;pt.n,

t.ch

are

not

r.xauc1’d

by

trw

..

.te

rianne’I

for

~uad—C1t..es

(~.

6S0—3).

ae

ec’: ‘miss

rest ona

t.nat

~uc’i

syatetto

iave mt

crt

teen

,~i’~m

Cu.

ez’ci’aLl

rs.~’:o..

for

fwtfltles

as

lar-•e

a.~:‘iad—C.

t:ea

and

that

It.

a~ ,e

.

‘n.e

unoe..’

:

:‘t.

e

to

concentrate

ai,d

~tnre

tha

:rtalL

uantl I.

I e~

gy’

Ion.’—

I

.‘ed

inotopec

‘rouLced

tnan

t-’

‘ii:

srse

ther,

.

-‘al

dilutea,

to

the

2tiorphere

(‘.

402—c)’.).

W.~ ri”:ed

riot

deude

tr,e

trick;

~

is

oL~ corn-norcial

t~ia11ab11tty,

fl.~.

.e

~çj~rjic~

the rharrcni

..“,;tr.1 sUl reduce

etlsa,on.

to

a

zer:’

t.ucier.t

ic

gc~J

hidec’a

tn.’ofar

~.s .:~‘o.s~

tcti’flty

,:,

concerrvt’i.

The

ro~

a.

..

c..f

tn’s

lcn;—lLJeo

l.~tone,

• on’zer,

Is

one

at

to

:‘

~

~:e

..‘

‘:.

to

ex!re~’os-

e

addltcna

caution

.

t

L’utra

u

jflt~~)•

~..

rtofl

S.,,

cn’ch

t:.I.

r

e’ Ittod

:oz~’c z~ndt2KCJ

a

cent.tr’

.o

‘Jaca:

to

Lnaicrilticiiace

(t.

o~a’J—’,t).

O:~e ~

trttiictc’i

4.’.’C.,

unlus,~

3OntrOl

‘riea:t’1fl21’

i’.’

In.:t.tutod,

‘i

gorldcide

buI1Qu’

ci’

‘ndloactiqe

kr::~tonwIll

ocor’

Mnt

tap

annual

do’s

to

r...io

Lo

‘•

“st’:.;;ae~efro’.

th::

JOuP’!C

w)J1

nau;h

.7

~.i’Jire:..,

°:

the

.

.~‘.

OX

1n1

17—fl

:.!

LJ.”o:

a~

2’:

to

3J

•.e.•p.

t:aereactcr

(It.

‘

.,f

—5i,

64—6a).

C.J?fs

t.

tb”.

i

ro.”ctt’d

1w

‘1;

are

rather

1045 ‘t

.n’

~tra’

cure-.

v

~n e. lei”i-

nr

p4ier’:i’

.a’~I’O1t

;oea,

aria

certi.n~

the.r~ L

no

c’tn’:e

Cr’

‘1r-2’J~n.e f”t•.

‘.

1.’.

not

toe

soon

t

.~t’rt, nc.wev ~r,

tL

—s

..

‘3?

~,ot

tnt ~n’i

t

c

a

I

I’r:

the

I

n :—1 I ‘r’d

raa’

tt

•

an

Pot

L’t

to

•‘c

‘.t.

anotac:.

ao’:

-

:t ~

.:

~,

~

...j!•j..

c”.la:lor.:

..t

~

iut~’

.

a.

I

a’

t.~,

to !ni!

nI”

•..p,4,

irs

t—5-

:~

n

t;

‘.

t

~

d

‘

‘:1’.’

—c’

s’”:

~.

~.i

I

‘.ccu’

~tat..

to

‘

(U

at’’

¶

in

r’n

a

cti”.’r,t

it..on

‘

•

•_•

A.

-*0

f’.

I’

•

~_O

—

rain

•

.-

~‘)

~,t.

P

.i..

-

‘-

1j~’

~~y•..at’e

t’

K’

‘

r

~

‘.r

Jt.-!:

Inn

—‘:~

;_

•

-.--

-

‘•:.

Ua~—’’Y’-

:r,

‘.

‘s.,~I

.1...

..~‘.!,..-

‘

‘‘_it’~’;

I

•~,

‘

‘f~

‘IJ(n,

:z’.’.

..an•

~

.

:~--

~

-

Cs.

~

:

~

:

~-

,

~t

•

•).‘t’i

‘1

ti’.

‘I.

•

‘

£

•

o~.ct’v..~t

~‘

.L4:~

c.’.•

_Uj)

.t~tI

~

—.•

-

.4

I

•

,

t’

t’LC

t

~

t”t?

t’.

•

.

-t”:.

.t.

•‘1’itnOt

t-,

._I

‘:

•:.“i,

~‘

T.’.

-

:•

ri

ic.’’’t

•_

t,3’...

‘‘0.

:0.:

chaerr,l

n’~

(

.

-

I.

—

~‘,

.

.

,

:-

lit

•

Lart’.~~

aL’~nL’t.

~•

a

‘-•

-

..

•

....n~to

tilt)

3:fll’c,t’

t’Iit”)

.5’.

.4

,

I

.‘.

;av

...

‘u..~

-‘.

‘1.’

to

4I~’

‘~)tit

‘at

,~“

‘‘~~~-

•

‘i

-

4~nc

.t

‘2

•

•

-

I’Y.’

3.’

4

•~

•

£

•

‘

•

:rui’—

::

1.,,~.

sq

:.,c’

•1’

—

—

‘

‘ii’

•,j

~

a.

.‘

---

Construction of the recombiner and charcoal beds at Quad—

Cities will not be complete until December 1973, and the :plant

is ready for operation this year.

It

is badly needed both to

provide more adequate reserve capacity to guard against interruptions

of electric service

that would impose significant hardships.

on innocent customers

(see the detailed discussion in the April

Dresden opinion)

and to relieve the load on older fossil-fuel

plants

that contribute significantly to air pollution.

Most

significantly,

the operation of Quad-Cities will make possible

the greatly reduced use of coal at an inadequately controlled

station in Moline

(see Iowa—Illinois Gas

& Electric Co.

v.

EPA,

#

71-165,

Sept.

16,

1971).

At the same time the emissions from

Quad-Cities during the interim before completion of the additional

control facilities will be low enough to afford

a substantial safety

margin below dose

levels at which adverse effects have been

detected.

While we have required that those levels be greatly

reduced for additional safety in the future because they reasonably

can be, we hold as

in the Dresden case that

the plant should be

allowed to operate in the meantime subject to interim limits,

namely, that not more than the proposed 110,000 uCi/sec be emitted

from both units,

or 80,000 from either alone.1

2.

Liquid Radioactive Wastes.

The planned discha9e

of

gross activity to the Mississippi River from various sources

of liquid waste at Quad-Cities is

26 curies per year plus

30

curies of tritium

(R.

384).

The utilities intend to dilute

these radioactive wastes with cooling water to a concentration

of

1 x 10-8 uCi/cc

(excluding tritium)

in the discharge canal.

In the river further dilution will reduce concentrations to

7 x 10-10 uCi/cc, affording

a safety factor of 2300 below the

drinking-water standard of

1 x

10-7 uCi/cc

(which is based

on

a 500 mr/yr dose to

a hypothetical person drinking river

water exclusively),

so that the dose to one drinking solely

from the river would be 0.2 millirems per year.

Dilution would

also leave

a large margin below the drinking-water tritium

standard of

3 x 10—3 uCi/cc

(R.

481-83).

On the basis

of these

facts the companies contend that the expected doses are

so

insignificant that no further treatment

is worthwhile.

Confronted with

a similar situation

in the Dresden case,

we pointed out that dilution is not

an adequate substitute for

treatment because it is better to keep harmful materials out

of the environment than

to dilute

them.

This is especially

true of materials,

such

as certain radioisotopes, that retain

their dangerous properties

for long

times after discharge and

that can be biologically concentrated by organisms

as they

move up the food chain.

A utility witness acknowledged that

cesium,

for example, concentrates

in fish by

a factor of 100 or

1000

CR.

333-34)~ A ~1~ais~f

Fcr

the Attorney General testified

1.

These tigures were substantially confirmed by additional testimony

in

the

Dresden

case,

#70-21

(Oct.

19,

1971), which predicted annuaL

emissions in the neighborhood

of 67,500 uCi/sec from one unit.

—

99

---

that strontium 90

is concentrated

20,000

to 30,000

times

(R.

2168),

It may therefore be

that the

most

limiting aspect of liquid waste

discharges

is not drinking water but aquatic life.

It is true

that the total quantity of activity to be discharged to

the

water

is quite small as compared with that to be discharged to the

air

(26 curies per year as compared

with

several thousand microcuries

per second, even after maximum control).

But

the discharge

is

tc

a much more limited receptacle,

the river,

not to the enormous

atmospheric reservoir;

and, in light of the policy of keeping

as

much radiation out of the environment as we reasonably

can, we

think it important

to consider possibilities

for reducing liquid

radioactive discharges still further.

In response to our concern over this

issue,

the utilities

have with accustomed thoroughness described for us two alternative

systems that would provide dramatic additional reductions in

radioactive discharges to the river.

Neither system will remove

tritium from water,

for the evidence

is

that

cannot

be

done.

But

the “maximum recycle”

plan,

by

the

addition

of extra

ion—

exchange

demineralizers

in

the

floor

drain

system, would reduce

non-tritium activity to

2

x

10-5

uCi/cc

before

mixing,

reduce

the

total

non-tritium

discharge

from

26

Cl/yr

to

1,2,

and

reduce

the

non—tritium

dose

to

a

hypothetical

river

drinker

from

0.

2

to 0.009 millirems per rear.

This system would

cost

$5,000,000

and require

24 months

to construct

(R.

372-77, 483)~

Or,

with the

“maximum treatment” plan, utilizing further concentration,

distillation,

and

ion exchange, the companies think

it

probable

they

could

meet

the effluent standards

without

any

dilttion

(except

for

tritium)

With

this

alternative,

non-tritium

re-

leases

would

be

only

0.0004

Cl/yr

and

the

dose

to

a

river

drinker

0~000003millirems per year.

The

estimated

cost

of

this

alternative would be $9~000~O00and the time

for construction

36 months

CR.

377—83, 483~

We

think the “maximum recycle”

system i~a desirable addition

to the Quad-Cities

slant,

in that

for

a

price

that

is only

2

1/2

of

total

plant

cost

it

will

reduce

radioactive

discharges

from

26

Cl/yr

to

1,2,

The

companies

have

agreed

to

the

installation

of

a

similar

system

at

Dresden

(#70—21,

hearings,

Oct.

19,

1971,

Ex.

1).

Although

the

need

for

such

a

system

is

greater

there

in

order

to

avoid

radiation

buildup

in

the

largely

closed

cooling

system

planned

to

meet

the

thermal

standards

for

the

Illinois

River,

we

agree

with

the

Attorney

General

s

witness

D~

Devolpi

that

this

additional

caution

is

worth

the

money

in

dealing

with

something

so

dangerous

as

radiation

(R.

630)

.

On

the

other

hand,

we

shall

not

be

dogmatic

in

insisting

on

a

complete

absence

of

dilation

irrespective

of

the

costs

and benefits

of

so

doing.

The important policy

is

that

dilution

not

be

emsloyed

in

lieu

of

reasonably practicable treatment; when all reasonable means

of

treatment

have

been asplied,

and

the

costs

of

further

treat-

ment are excessive, dilution should not he forbi~len.

In

the

Dresden

case

we

announced

the general policy against unnecessary

dilution.

In the light of additional evidence received since

that:

decision, we think the further reductions below the already small

discharges

from

the

proposed

“maximum

recycle”

system

that

would

he

afforded

by

the

“maximum

treatment”

system

would

not:

at

the

present

time

be

worth

the

$4,000,000

extra

cost.

3—

100

---

Thus we shall order Edison and Iowa—Illinois

to reduce

gross

activity

discharges,

exclusive

of

tritium,

to

1.2

Ci/yr

and to

2 x i05

Ci/cc before mixing, by December

1,

1973, and in

the meantime to meet the gross activity limit of

1 x l0~7uCi/cc

after

dilution,

at the point of discharge to

the

river.

Asin

the

case

of

gaseous discharges,

there is

no

serious

risk

from

the

discharges

during

the

interim,

and

to

require

the

stricter

standard

to

be

met

at once

would

keep

the

plant

closed

for

two

years,

im-

posing an unjustified hardship.

3.

Heat.

Two thirds of the

heat

generated

in

a nuclear

power plant cannot be translated into electricity;

it

is

a waste

product that presents

its own disposal problems.

The companies’

original plan was simply to discharge

the heated cooling water

(which at low flow will comprise

1/4

to 1/5 of the river’s entire

flow and which will be 23°warmer than the river)

into the main

river channel

(R.

698—99,

715,

731,

768).

In the

sunimer of 1970,

however,

a study demonstrated that this scheme would violate the

then existing water quality standard

(SWB-12)

(R,

768), which

limited stream temperatures to~90°F.

and to 5°above natural

temperatures outside

a mixing zone extending 600

feet

in any direction

from the point

of discharge.

So the companies proposed to install

a diffuser,

a pipe extending most of the way across the river,

discharging heated water at various points in order to maximize

rapid mixing with the cooler river water

CR.

722)

.

It was their

contention that with

such an arrangement the standard could be

met

(R.

824).

But the old standard, we concluded

in

a recent rule-making

proceeding

(#R 70-16, Mississippi River Thermal Standards, adopted

Nov.

15,

1971), was inadequate to protect

the river against

a substantial

risk of ecological alteration,

since it would allow

the whole river to be raised by 5°nearly all the time.

For this

reason we adopted

a new standard that imposes monthly maximum

temperatures, based upon federal recommendations derived from

prevailing temperatures and

the requirements

of the biota at various

seasons, that must be met during all but

a

few days each year

at the edge

of the 600—foot mixing zone.

The companies’

evidence,

not substantially contradicted,

is that they can meet

the new

standard too with their diffuser alone, avoiding the expenditure of

$40,000,000 or more

for cooling towers or spray ponds.

We find

it: probable

on this record that

they can and therefore will not

require the installation

of alternative cooling devices at this

time.

We do require that the companies condubt

a detailed study

of the effects of discharges and that additional measures be taken

if significant harm

is shown to occur.

A more difficult issue is what

to prescribe while the diffuser

is being built,

As in the Dresden case,

we find it somewhat sur-

prising that the companies did not discover until

1970 that the

long—existing standards would require even so much as

a diffuser

pipe, with

the unhappy result

that even the diffuser will not be

3

—

101

---

available before February,

1972

(R.

9).

Indeed,

later dalays re—

~ulting

from permit proceedings before the federal government and

the Iowa water pollution agency have so

far prevented construction

of the diffuser and put

its operation off until

later in the

Spring.

However,

as noted above,

the plant

is badly needed,

and

right away,

if innocent consumers

(and the air-breathing public)

are not

to suffer.

The harm to the

river

in the meantime,

if we

impose certain conditions

to keep

it within bounds,

is

a risk

rather than

a certainty; while we would not allow it over

the

long term,

the great probability is that any harm that does occur

will be undone naturally by repopulation from unaffected areas

after adequate cooling is provided.

So we will allow Unit #1

to be operated, with the discharge

improvements promised by the companies,

as soon

as it

is ready.

With only one unit in operation,

the increase in temperature

through the plant will be only 13° (R.

30), and river dilution

will be adequate to 9sure

that

the whole stream not be raised by

5°even

at low water.

Moreover,

we shall require the companies to report on the

feasibility

of installing spray modules

in the discharge canal,

as at Dresden,

to reduce the heat discharged

to the

river.

Unit

#2

may be tested during this period,

as the utilities request,

in order to assure its availability

for the peak demands of

summer

1972

(R.

31)

,

but,

to avoid

a full heat load on the river

without even rapid mixing, which might do considerable damage,

the total station output shall not exceed 809 mw--that of either

unit alone——until

the diffuser pipe is

in operation

to assure that

large areas are not raised more than 5°.

4.

Nuclear Accident.

The Attorney General raised the

question of the adequacy of safeguards against the possible escape

of radioactive materials

in the event of an accident.

In light of

recent controversy over the adequacy

of certain systems

for cooling

reactor cores

in the event of

a coolant loss, we scheduled

an

additional two days of hearings, after

the record had been

closed,

to pursue the question.

On the basis

of the record we

cannot.

find such

a significant danger of failure of

the emergency cool Inc

system as to lead us to dalay further

the operation of this

needed

facility.

21

The companies say

the area raised by more than 5°will be on1~~

20 acres

(R.

791)

3—

102

---

A highly qualified witness from General Electric,

manufacturer of the reactors, testified in great detail as

to the integrity

of normal controls making the need for

emergency cooling highly improbable;

to the quadruple

emergency systems provided, each independently capable

of quelling any foreseeable problem;

and to the extensive

testing that had been

and would be performed to determine

and to maintain the adequacy of the systems.

He assured

the Board that the problems encountered

in recently

publicized tests were specific to an entirely different

type of emergency

system that had never been used or planned

for boiling water reactors

(R.

2336-2426).

Dr. Alexander

DeVolpi of Argonne National Laboratory suggested that

a

1970 incident at Dresden raised questions

as to the adequacy

of BWR emergency cooling systems, but he was unable to

demonstrate that

the incident was

one in which

an emergency

cooling system would be expected to operate.

Dr. Henry

Kendall of MIT emphasized the desirability of further

testing of these systems but agreed that the problems

recently encountered with cooling systems had no application

to the BWR’s

and had

no suggestions

for improving the Quad-

Cities system.

Neither he nor Dr.

DeVolpi asked that the

permit be delayed or withheld;

the latter expressly said

that “inherent safety features make water reactors ex-

tremely safe”

and that the “probability

of failure

necessitating emergency core cooling is very small”

(R.

2428—2542)

While

we shall maintain

a continuing concern for

this

and

all

other

matters

related

to

possible

radiation

hazards,

and while we

~hall provide that the permit may be modified

or revoked if this

is proved necessary by new information,

we

do

not

perceive

a

justification

today

for

withholding

the

permit.

5.

Other

Issues,

Because of the advanced stage of

construction,

siting

considerations

are

of

little

consequence

in this proceeding;

suffice it that we see no reason to require

that

this

plant

be

dismantled

and rebuilt somewhere else.

Solid

radioactive

wastes

will

be

contained

and

shipped

to

an

established

burial

site

(Environmental

Feasibility

Report,

p.

36),

and

we

have

no

evidence

to

indicate

any

undue

dangers

in

the

plans

for

this

operation,

either

at Quad-Cities,

in transit,

or

at the ultimate disposal site.

The appropriate disposal of

such dangerous

wastes,

however,

is

an

important subject with

which we expect to have more to do in the near

future.

The

Attorney General raises the question of nuclear accidents, but

we

think the evidence insufficient

to show

the need for

additional precautions on this score beyond those already

3

—

103

---

provided.

The gaseous radiation controls agreed

to by

the

utilities will add significantly

to accident protection

(R.

641—42),

The sewage treatment system and the gas-fired boilers

are designed to comply with all relevant regulations,

and

there is no indication that any nonradioactIve solid wastes

generated at the

site will be improperly dispos~dof.

No

chemical water contaminant problems

appear;

the use of sodium

hypochiorite

for condenser cleaning will add some chlorine

to the river, and chlorine

and its compounds can be toxic

to

fish; but the undisputed testimony

is that the small amount

of chlorine added will be rendered innocuous within two minutes

by

the chlorine demand in the river

CR.

285-87).

The Attorney General moved on November

11 that we

further delay decision in this case pending

study of the

transcript of

a recent

Iowa hearing with respect to the

effects of the proposed diffuser.

We denied this motion

4-1, Mr.

Dumelle dissenting,

on the ground that ample

opportunity had already been afforded for

the presentation of

evidence and that there was nO justification for

the extra-

ordinary course of reopening and further delay.

In conclusion, we should like to commend the applicants

for

a thorough and lucid presentation of the relevant facts,

and to thank

the Attorney General

for his participation,

which provided the adversary proceeding that

is

so necessary

to adequate resolution of the issues by the Board.

Mr.

Dumelle dissents

for reasons to be stated ih

a separate

opinion.

This opinion constitutes

the Board’s findings of fact

and conclusions of

law,

3—

104

---

ORDER

After due notice and hearing,

and

for the reasons given in the

Board’s

opinion,

a

permit

is

hereby

issued

to

Commonwealth

Edison

Co.

and

Iowa-Illinois

Gas

& Electric

Co.

to operate Units

#*l

and

2 at the Qtiad-Cities Nuclear Power Station near Cordova,

Illinois,

subject to the following conditions:

General

Conditions

1.

This permit shall not release the permittees from any

liability or obligation

imposed by Illinois statutes or local ordinances

and shall remain in force subject to all conditions

and limitations

now or hereafter imposed by law.

The permit shall be permissive

only and shall not be construed

as estopping or limiting any

claims against the permittees for damage or injury to person or

property resulting

from any acts, operations,

or omissions of

the permittees, their

agents, bontractors or assigns,

nor

as estopping

or limiting any

legal claim of the state against the permittees,

their agents, contractors

or assigns,

for damage to state property,

or for ~ny violation of subsequent regulations or conditions of

this permit.

2.

This permit is subject to modification

or revocation,

and

may be suspended at any

time for failure

to comply with the terms

stated herein

or

wjth

the

provisions of any other applicable

present or future regulations or standards of the IPCB or its

predecessors

or successors,

and

is issued with

the understanding

that

it does not estop the Board from subsequent establishment

of further requirements

for treatment or control at any

time.

The Board upon notice and opportunity to be heard may reopen

this proceeding at any time

for the purpose of such revocation

or modification

in order to prevent or reduce possible pollution

of the environment,

3,

The permittees

or their assigns shall defend, indemnify and hold

harmless

the State of Illinois,

its officers, agents and employees,

officially or personally,

against any

and all actions, claims or

demands whatsoever which may arise from or on account of the

issuance of this permit,

or the construction or maintenance of

any facilities hereunder.

~al

Conditions Relatin

to Radioactive Dischar es

(I,

Policy of

the Board)

it is the policy of the IPCB that all radioactive pollution

of the environment

shall he held to the lowest level that

is

attainable within the limitations imposed by technological feasibility

and economic reasonableness.

In no case

shall members of the public

be exposed to radiation beyond the limits recommended by the

International Commission on Radiological Protection,

nor shall

radioactive emissions ever exceed the limits imposed by the TTnited

States Atomic Energy Commission.

In addition, the actual levels

---

of

radiation

exposure

of

members

of

the

public

shall

be

kept

as

far below those limits

as possible, consistent with technological

feasibility

and reasonableness

of cost.

2.

Radioactive Discharges Generally)

In

keeping

with

the

above

policy

of

the

IPCB,

all

practical

measures

for treatment, control and containment of

radioactive

wastes from Quad—Cities

Units

1

&

2 nuclear generating plant of the

Commonwealth Edison Company shall be employed for the purpose of pre-

venting the release of radioactivity to the environment,

Such

measures

shall

include

at

least,

but

not

be

limited

to;

all measures

for the treatment,

control and~containment of

liquid and gaseous

radioactive

effluents

that

are

indicated

in

the

Final

Safety

Analysis

Report

of

the Quad-Cities Units

1

&

2

nuclear

generating

plant.

3.

Liquid

Radioactive

Discharges

(a)

The

annual

average

gross

beta-gamma

radioactivity

of

liquid

effluents

released

to

the

Mississippi

River

shall

not

exceed l07

uCi/mI

(100 pCi/l).

(b)

Total activity discharged

to the Mississippi River

in any year, exclusive of tritium,

shall not exceed

26

curies.

(c)

Tritium discharged to the Mississippi River in any year

shall not exceed

30

curies.

(d)

On and after December

1,

1973, total activity discharged

to

the Mississippi River in any year, exclusive of tritium,

shall

not exceed 1.2

curies,

and qross activity exclusive of tritium

shall be reduced to

2

x l0~ Cl/cc before dilution.

4.

Gaseous Radioactive Discharges

(a)

Gross beta—gamma radioactivity of gaseous emissions

released to the

atmosphere

from

either

Unit

1

or

Unit

2

shall

not

exceed

an annual average of 80,000 microcuries

per

second,

and emissions from both units operating at the same

time shall

not exceed an annual average of 110,000,

(b)

If gaseous radioactive

emissions

at

any

time

exceed

37,500

uCi/sec

from

either

Unit

I

or

Unit

2,

or

exceed

57,500

uCi/sec

from

both

units

operating

at

the

same

time,

the permittees

shall initiate operating

procedures,

to

the

extent

permitted

by

power demand,

to reduce such release.

(c)

On

and

after

September

1, l973,gaseous radioactive emissions

from

either

Unit

1 or Unit

2 shall not exceed an annual average

of 3000 uCi/sec,

nor shall emissions from both units operating

at

the

same

time exceed an annual average of 4000 uCi/sec.

3

—

106

---

5.

Heated Water Discharges

(a)

With the discharge improvements described in the

Supplement

to Appendix

C of the Application

as Amended, Units

1

and/or

2 may be operated until April

1,

1972,

at

a total output

not to exceed 809 mw~without regard

to the heat limitations of

regulations SWB-l2 as amended by #R 70-16 or of successor

regulations, provided that:

Ci)

until operation of the diffuser

is achieved,

effluents shall not exceed ambient river

temperatures by more

than 12°F; and

(ii)

within thirty days after receipt of this

permit,

the permittees shall submit

a state-

ment regarding the feasibility and cost of

installing spray modules to reduce the heat

discharged

in the interim before completion

of

the diffuser.

The Board upon receipt of

such statement will take such further action

as appears appropriate.

(b)

On and after April

1,

1972,

Units

1 and

2 shall be

operated only

in full compliance with all provisions

of SWB—l2

as amended by

#R 70-16

or of successor regulations, with regard

to heated discharges.

6.

Reporting and Monitoring

(a)

Liquid discharges.

Prior

to any release of radio-

activity

in liquid effluents, each batch will be counted

for

gross beta activity,

excluding

tritium.

Records

of the radio-

active concentration and volume of each batch of effluent shall

be maintained as well as records of the amount of circulating

water available for mixing.

At least once per month

a gamma

scan of typical batches

of effluent shall be performed

to deter-

mine the gamma energy peaks of these batches.

Isotopic analyses

of representative batches

of effluent,

including determination

of

tritium,

shall

be performed and recorded at least once per

quarter.

If

the monthly gamma scan reveals energy peaks other

than

those

determined

by

the

previous

isotopic

analyses

and if

the difference

is significant,

a new set of isotopic analyses

will

be

performed

and

recorded.

(b)

Airborne activity.

Radioactive gases released from

the reactor building stack and plant chimneys shall be continuously

monitored.

To accomplish

this,

at least one reactor building

stack monitoring

system and plant chimney monitoring system shall

be operable

at all times.

Daily samples

of the air ejector

effluent will be

taken,

Within one month after initial

3

—

107

---

commercial operation

of the unit,

an

isotopic

analysis

will

be

made.

From this analysis

a ratio of long lived to short lived

activity will be computed.

If

a ratio based

on any daily sample

indicates

a change greater than

20 per

cent from the previous

isotopic analysis,

a new isotopic analysis will be performed

and

recorded,

In

any

event,

a

new

isotopic

analysis

will

be

performed at

least quarterly.

Gaseous releases of tritium shall

be calculated monthly from measured data,

Records from the

continuous monitors,

the daily samples

and the isotopic examinations

shall be maintained,

(c).

All effluent and environmental monitoring erogram

results shall be reported monthly by the Permittees

to the

Environmental Protection Agency

(EPA).

All monitoring program

results shall

also be available for inspection by the

Environmental Protection Agency

at the slant site at any time,

7.’

Emergency

Situations

The Permrttees shall cooperate

to

the

full extent necessary

with

the EPA and w.ith

the Ill~nozsDe~artment of Public Health

for par oses

of develojpment by those agencies

of an adequate

and effective esergency protection plan designed

to immediately

control and minimize the effects

of any accidental release

of

unexectedl

large quantities of radioactivity

from the Quad--

Cities nuclear generating plant.

In carticular,

the’ permittees

shall immediately notify both

the

EPA and the Illinois Department

of Publac Heaath or any uncontrolled release of unexpectedly

large quantities of radioactivity

to the offsite air and/or

water environment due to operational failure of any

of

the sower

plant systems,

and shall report monthly to the Board and EPA any

aCt1Va~

tion of the emergency core cooling system, whether

spurious or real,

exclusive

of today.

,

18.

Time

of Permltl

This permit shall expire

on November

15,

1973.

If the

permittees wish

to continua operation

of Quad--C.ities Units

1

and

2 beyond that date

they shall file with the

IPCB

an aoplication

for

a renewal permit on or before August

15.

1973.

Said

application shall contain comolote

information and data:

(a)

concerning the radioactive emissions,

osseous and

liquid,

ap to that date,

(b)

concerning the status of the construothan and installat:

of the radioactive control facilities

resurred

by

this oermrt,

and

Cc)

concerning thermal discharges

and their effects

on

t.he

Mississip~haRiver.

Said application shall

also include such

other information and data

as required by the Board

to oval~~~ate

the impact on the environment of

Quad-Cities. Units

1

and

2.

—

108

---

9.

Compliance with Existing Laws

The permittees

shall conform to all existing and future

laws and regulations in other aspects of the operation

of Quad-

Cities Units

1 and

2,

including among other things the operation

of boilers,

the operation

of sewage treatment facilities,

and the

disposal of solid waste, and

shall procure from the Environmental

Protection Agency such permits as may be required

for various

aspects of that operation.

I,

Christan

Moffett,

Acting

Clerk

of

the

Pollution

Control

Board,

certify

that

the

Board

issued

the

above

Permit

this

/~Y

~day

____

1971.

3— 109