ILLINOIS POLLUTION CONTROL BOARD

November 23, 1971

In the Matter of:

Application of Commonwealth  

)

PCB 70-21

Edison Company for a Permit

for Dresden 

Unit 

3, Dresden  

)

Nuclear Power Station     

)

Opinion of theBoard (by Mr. Kissel):

On March 3, 1971, this Board issued a permit to Commonwealth

Edison Company (“Edison”) to allow it to operate Dresden Unit 3

a nuclear power generating station near Morris, Illinois. The

Board~sprevious opinions detail the facts and reasons behind the

issuance of the permit and the conditions contained therein, and

those reasons and facts will not be repeated here, except as rele-

vant to this ~articular part of the permit proceeding. The permit

required that Edison submit certain reports concerning the installa-

tion of control equipment for gaseous radioactive emissions, liquid

radioactive discharges and heated water discharges as detailed in

the following paragraphs of the permit:

“3(b) The permittee shall within thirty (30) days after the

issuance of this permit submit to 

the

IPCB a written program with

a time schedule for controlling the liquid radioactive discharges

to the amounts set forth in paragraph 3(a) of this permit from

Dresden

Unit III without the use of dilution water.

“4(b) Within thirty (30) months from the date of issuance of

this permit, permittee shall construct and install facilities on

Dresden Unit 

to

reduce

gaseous radioactive emissions permitted

by paragraph 4(a) of this per~rtit by a factor of fifty (50). Within

thirty (30) 

days

after the date of the issuance 

this permit,

permaittee shall submit 

written program to the IPCB for designing,

constructing and installing 

the

control facilities required by 

this

paragraph~ Said written program shall include a detailed descrip-

tion 

of the proposed facilities, the

times when the design, purchase,

installation

and construction 

of the

facilities shall 

completed

and any other information as would be needed

the IPCB to

properly

evaluate

the

amount of

time needed by 

the permittee and its con—

tractors1 if any,

to complete 

said facilities.

—

125

“5(b) Permittee in the operation 

of Dresden Unit 

3 shall

comply with the thermal discharge 

requirements of SWB-8 as 

inter-

preted in the opinion of~eBoard, In 

order to assure such 

com-

pliance, permittee shall submit the following information to the

Board within thirty (30) days from this date:

1.  Engineering information and costs on the kinds

of additional facilities, if any, required to meet the standard

covering heated discharges allowing for a mixing zone of 600 feet,

2.  The time required to construct the additional

facilities referred to in paragraph l~.

3,  If additional time is required, the reasons why,

in accordance with the variance provisions of the Environmental

Protection Act and of the Board1s Procedural Rules, operation of

Dresden Unit 3 should be permitted during said construction,”

Edison filed the “thir~yday” report on April 13, 1971. It not

only contained the many alternate programs called for by the con-

ditions of the permit, but also contained a request by Edison to

reform certain of the other conditions of the permit, that is,

those dealing with the permitted gaseous emissions before control

equipment is installed and the use of an emission reduction (in-

stead of a dose reduction) factor as a measure of the effective-

ness of the ‘radioactive gaseous emission control equipment. After

receiving the detailed Edison report, the Board requested that the

Institute for Environmental Quality (the “Institute”) employ the

services of experts who could review the report and offer expert

comments on the various alternatives proposed by Edison, The Insti-

tute did hire three persons well qualified to review the report 

Dr. Hermen Cember of Northwestern University, Dr. James Leonard of

the University of Cincinnati and Dr. Henry Bremer, President of

Datagraphics, Inc. The Institute’s experts did, in fact, file

written reports which contained a detailed examination of the Edi-

son alternatives, When Edison received the reports, it requested

a hearing be held so that the various alternatives could be aired

in a public forum. A hearing was held on October 19 and 20, in

Chicago, Illinois,

There are three basic areas in which the Board must make deci-

sions as a result of the most recent hearings in this case: I) The

gaseous emission control equipment which must be installed by Edison;

2) the liquid radioactive control equipment to 

installed by Edi-

son; and 3) the futhet controls, if 

any,

to be installed in order

to reduce the thermal input into the Illinois River. Each of these

areas will be considered separately, although there is a relation-

ship between some of the issues.

3— 126

Gaseous Radioactive Controls

Before reaching the actual control equipment discussion, it

is necessary to discuss the interim radioactive emission limits

imposed as a condition in the original permit issued to Edison,

The permit provided in paragraph 4(a) as follows:

“The release rates of gross beta-gamma radio-

activity of gaseous effluent released to the environs

from DresdenUnit 3 shall not exceed a monthly average

release rate of twenty-five thousand (25,000) micro-

curies per second and on no occasion shall the emis-

sions exceed one hundred thousand (100,000) microcuries

per second.”

This part of the permit was taken almost directly from the testimony

of an Edison witness who testified, in essence, that an annual

average emission rate at the Dresden 3 unit of 25,000 microcuries

per second at the Dresden plant would be “average to good” fuel per-

formance, An instantaneous emission of more than 100,000 micro—

ounce per second would indicate “fair to poor” fuel performance.

While the witness himself did not feel that an instantaneous emission

rate should be adopted, the Board felt that this was a point at

which emissions should be limited because we did not wish to encour-

age Edison to continue to allow “poor” fuel performance. Since the

original Dresden 3 hearings, there has been much testimony by

General Electric and Edison personnel about paragraph 4(a) of the

Dresden 3 Permit, In a hearing on the application for a permit to

operate two identical boiling water reactor power generating units

at Quad Cities, the same witness who had previously substantiated

the emission levels in paragraph 4(a) of the Dresden 3 Permit, testi-

fied that what he meant to say at the Dresden hearing was that the

emission level Of 25,000 microcunies per second was an average to

be sustained “over the years” and was not meant to be an annual aver-

age, His testimony in the Dresden 3 hearing, however, was contrary.

(See, Transcript of Original Hearing, December 9, 1970, page 480).

Be that as it may, we are convinced, based upon new testimony in the

Quad Cities hearing and the most recent hearings on the hardware to

be installed at Dresden, that a new emission level should be set

for the gaseous radioactive emissions prior to the installation of

control equipment. The Quad Cities testimony demonstrated that a

realistic emission level would be 80,000 microcunies per ~econd as

an annual average for the operation of one unit essentially identical

to Dresden 3, and this was adopted as the interim emission level in

the recently issued permit for the Quad Cities plant. See Permit

and Opinion of the Board, In the Matter of the Joint Application of

Commonwealth Edison Company’and Iowa-illinois Gas & Electric company

(Quad

Cities Permit), PCB 71-20, deôided November 15, 1971, In the

Quad Cities case the single unit emission level of 80,000 inicrocuries

per second would produce a fencepost dose of about 157 millirem per

year. The testimony in the Dresden 3 hearing demonstrated that

the 80,000 inicrocurie emission from one unit would result in a fence-

post dose of about 44 millirem per year. Of course, the fencepost

dose is normally reduced by a factor of three because no one lives

at the fencepost twenty-four hours a day, 365 days a year. With 

this

factor reduction, the actual 

emission 

rate and dose to the public

is still very low even at the emission level of 80,000 microcuries

per year, considering the fact that background radiation provides a

yearly dose to the public of about 100 millirem.

The most recent hearing on the Dresden 3 hardware produced testi-

mony that the expected annual average emission rate at Dresden 3,

assuming the unit operated at full power for the entire year, is

90,000 microcuries per year. The 

number 

was obtained by looking at

the actual performance ‘~of the two large Dresden units, 2 and 3, at

less than full power levels, and applying a computed factor increase

of the emissions for operation at full power. According to Mr. Stiede,

the 90,000 microcurie emission level could be sustained on a monthly

basis, and as far as a yearly average is concerned, the unit can be

expected to be operated about 75 of the time; therefore, an annual

average of 67,500 microcuries per second could be maintained, We think

that this level of emission is very close to the one proposed in the

Quad Cities application hearing and in order to assure greater leeway,

we adopt the Quad Cities standard for Dresden.  We, therefore, be-

lieve that based upon the new testimony of the actual performance of

the units at Dresden, paragraph 4(a) of the permit should be amended

as follows:

“Gross beta—gamma radioactivity of gaseous emissions

released to the atmosphere from Dresden Unit 3 shall not

exceed an annual average of 80,000 microcuries per second,”

The

rates of emission at this level will not cause a significant in-

crease of the dose to the population around the plant.

With the establishment of a new interim emission rate for

Dresden 3, we do believe that the action level suggested by Edison

at the Quad Cities hearing should also be adopted for Dresden 

3

for the same reasons as outlined in the Quad Cities opinion. We

therefore will require that if the gaseous radioactive emissions

from Dresden 3 exceed 37,500 microcuries per second at any time,

Edison shall initiate operating procedures, to the extent permitted

without interrupting electric service, to reduce such release.

3— 128

In the original permit Edison was required to construct gas-

eous emission control facilities within thirty (30) months from the

date the permit was issued, which facilities would reduce the “gaseous

radioactive emissions 

. . .

by a factor of fifty (50).” Paragraph 4(b)

of the Dresden 3 Permit. The intent of that paragraph was to require

that Edison construct, install and operate the catalytic recombiner

and eight charcoal beds to treat the air ejector effluent. This,

according to Edison, would result in an emission reduction by a fac-

tor of 40 and a dose reduction by a factor of 80. Edison has already

begun its program to install this equipment, and, in fact, the comple-

tion date will be earlier than originally anticipated 

—-

the present

completion date now hoped for by Edison is April 1, 1973, and we

will hold them to that date. We will also modify the language of

paragraph 4(b) to be consistent with the rate at which gaseous radio-

activity will be emitted from the air ejector system and the gland

seal system. Since Edison has testified that the recombiner and eight

charcoal beds will result in an emission reduction factor of 40, and

since the record shows that as an annual average Edison can achieve

an airejector emission rate of80,000 microcuries per second, we will

require that after the installation and operation of 

the

control

equipment 

which will be no later than April 1, 1973 

Edison shall

not emit more than 2000 microcuries per second gross beta—gamma

activity from the air ejector off gas system. In addition, the gland

seal system will result in emissions of about 1000 microcuries per

second on an annual average, so that paragraph 4(b) will be modified

to read as follows:

“By April 1, 1973, Edison shall have completed

the installation of a catalytic recoinbiner and eight

charcoal bed system, as outlined in the record of this

proceeding, to treat the air ejector effluent, On and

after that date, gaseous radioactive emissions from

Dresden Unit 3 shall not exceed an annual average of

3000 microcuries per second. The latter emission limit

shall include emissions from the 

gland seal.”

Liquid Radioactive Controls

The Permit originally issued to Edison for the operation of

Dresden 3 provided that the liquid radioactive emissions from the

Dresden 3 facility should not exceed l0~ microcuries per liter,

Further, paragraph 3(b) provided as follows:

“The permittee shall within thirty (30) days after

the issuance of this permit submit to the IPCB a written

program with a time schedule for controlling the liquid

radioactive discharges up to the amounts set forth in

paragraph 3(a) of this permit from Dresden Unit III with-

out the use of dilution water.”

—

129

In its “thirty-day” report Edison detailed for alternative systems

which it indicated would meet the Board’s requirements under the

above quoted condition of 

the permit.

Alternate 1 is entitled, “Liquid Waste Dilution Station with

Closed Cycle Lake”, This system involves a closed—cycle lake operation

with sprays for Units 2 and 3 and the installation 

of a dilution sta-

tion for Unit 

1

condenser cooling water discharge. There would be no

need for major modifications to the presently radwaste 

system. At a

dilution station on the north side of the Dresden Unit

2-3

intake canal,

250,000

gallons per minute (gpm) 

would 

be piped to the Unit I dis-

charge canal where it would mix with the existing 190,000 gpm of cool-

ing water from Unit I. In addition, the 50,000 gpm of blowdown water

from the lake would 

be piped to 

the Unit 1 discharge canal and mixed

with the cooling

water before discharge into the river, Units 2 and

3

discharge line would be rerouted to the Unit 1 canal and discharged

into the canal to provide distribution of the waste across the canal,

The waste would be mixed with the cooling water as it passed down the

canal 

and

would be released along with the Unit 1 liquid waste to the

river at an activity level of 100 picocuries per liter, for the com-

bined releases from all units, The 50,000 gpm blowdown will benefit

management of the lake by limiting the buildup of impurities in the

lake, The installed cost of the dilution station, and mlated costs,

will be $2,898,000 and the operating costs will be $130,000, These

costs would be in addition to the cost of $12,500,000 which is common

to all alternates proposed by Edison, The time for completion of

this alternate would be twenty-six months.

Alternate 2 is entitled, “300,000 GPM Continuous Discharge of

Cooling Lake Water for Dilution of Liquid Waste”. Under this system

the liquid radwaste would not be changed from its present design.

The water use system of the plant would be changed to require that

only 300,000 gpm of water from the facility would be discharged to

the river. This would require that the plant reuse either 700,000 gpm

for six-pump operation and 420,000 gpm for four-pump operation. The

discharge flow would travel through the existing Units 2 and 3 dis-

charge canal to the river and would be discharged through a diffuser

pipe. Under certain circumstances Dresden Unit 1 will have to be

reduced in operation in order to meet the present SWBL8 standards.

The cost to install this system would be $1,903,000 with operating

costs of $40,000,

Alternate 3 is entitled, “Maximum Recycle Liquid Waste System

with Closed Cycle Lake”, This system would result in compliance of

the radioactive standatd of 100 picocuries per liter with a minimum

blowdown of 50,000 gpm which blowdown is only 

necessary

to assure

proper 

operation

of

the lake. The present waste collection system

3

—

130

would not be changed, but additions would be made. The floor drain

subsystem would be modified to permit recycling of most of the

effluent, This would be accomplished by the addition of two deep

bed demineralizers after the floor drain filter. These demineral-

izers would provide ion exchange treatment. The water so treated

could be returned to the condensate storage tank for recycling. A

small amount of the recycled water, however, will not meet the con-

densate purity standards and would have to be discharged to the

canal, A floor drain surge tank would be added to serve as a con~

tingency collector. Also as part of this proposed Alternate, 

the

existing concentrators in the chemical waste subsystem would be

utilized to remove dissolved impurities for solidification. The

concentrator distillates would go to the collector subsystem for

further 

treatrnent 

and recycling, and the waste salts will be drummed

solid wastes, This system would reduce the radioactivity from

1.2 microcuries per second to approximately .009 microcuries 

per

second, and this estimate is 

based upon fuel performance which would

be approximately 0.1 microcuries per second. Thus, this alternate

would allow for meeting the proposed effluent standard with the

50,000 gpm blowdown, which is necessary for the proper operation of

the

cooling lake. According to Edison’s estimate, the total exposure

from Dresden Units 2 and 

to a person using river 

water as drinking

water for his entire liquid intake is 0.0038 millirem per year. This

alternate would also use the diffuser pipe for the Unit 1 discharge.

The installation cost of this equipment will be $2,946,000 with

operating cost of

$165,000 per year. This system could be completed

within 21 months.

Alternate 4 is entitled, “Maximum Treatment Liquid Waste

System with Closed Cycle Lake”, 

The

waste collector system will re-

main as is presently 

designed except 

that there will 

be a contingency

collection system. There will be two 

parallel demineralizers in-

stalled and a line from the floor drain sample tanks 

to

the Contin-

gency subsystem. 

All

floor drain wastes complete recycling, but

there will 

be a small 

amount not able to be recycled. This small

amount will be routed to the contingency 

subsystem. 

In the chemical

waste 

subsystem 

the chemical wastes will be concentrated, a~dnot

discharged. In the decontamination subsystem, the wastes will be

connected to the solid waste system, mixed with cement and drummed,

The

contingency subsystem

is completely new and will allow 

the dis-

charge of 100 

picocuries per liter without the use of dilution.

This system will include a floor drain surge tank, two 2&-gpm con-

centrators, two 500-gallon distillate tanks, two demineralizers with

10

ft.3

of ion exchange resin each and two 30,000-gallon sample tanks.

There will be a large contingency collector tank of approximately

200,000 gallons. As has been previously stated, the discharge of

radioactive liquid wastes would be met before mixing with the blow-

down water. 

Unit

1, in this alternate as well, would have its

discharge routed through

a diffuser pipe. The installation cost

of this alEernate 

would be $4,498,000 and the operating cost would

be $300,000,

3— 131

In providing to the Board the four Alternates for treatment

of liquid radioactive wastes and heated water discharges, Edison.

has complied fully with the condition of the permit requiring these

submissions. The first opinion of the Board in the Dresden 

3

case

did make the point that dilution should not be used as an alterna-

tive to the treatment of liquid radioactive wastes. We feel that

although dilution water is still used, Alternate 3, the “Maximum

Recycle” alternative, is the perfect blend of applying present

technology with economic reasonableness for keeping the level of

liquid radioactive discharges at a “safe” one, 

Alternate 

4 does

comply with the “no dilution” concept, but we believ~that 

the addi-

tional capital costs for 

Alternate 4 (over $2 millio~) is simply

not worth the minimal reduction gained by using 

Alternate 4 

over

Alternate 3. We will,therefore, order the installation of Alternate

3, as described in the record, and in addition will 

require that the

decontamination solutions be sent to 

solid waste disposal by putting

the wastes into cement and drumming it for disposal. This recommen-

dation was made by one of the Institute’s consultants and seems a

reasonable one,

Edison also raises the point that tritium should be handled

differently in the permit and we agree. We, therefore, modify the

permit and substitute the following paragraphs for paragraphs 3(a)

and 3(b):

“(a) Radioactivity in liquid effluents shall be

controlled so that the annual average gross

beta-gamma

radioactivity, excluding tritiuiu,discharged to ~the

Illinois River shall not exceed 1x107 microcuries per

cubic centimeter (100 picocuries per liter) and annual

average tritium activity discharged to the Illinois

River shall not exceed 3xl04 microcuries per cubic

centimeter,

“(b) Edison shall immediately begin to install

the system described in the April 13 report as the

maximum recycle system (Alternate 3), a system which

would require that the decontamination solutions be

drummed 

and disposed of as a solid waste, 

Installa-

tion of the system as required herein shall be com-

pleted by September 1, 1973, and thereafter the emis-

sion limits of paragraph 4(a), herein, shall apply to

the blowdown of the cooling lake,”

—

132

Heated Water Controls

Under the Dresden permit Edison was required to submit to

the Board a plan for bringing the heated water discharges from the

Dresden 3 plant into compliance with the standards of SWB-8. Since

the issuance of the permit Edison has put the cooling lake into

operation and has installed 98 spray modules in the canals at the

Dresden facility. Even with those installations Edison has admitted

that its heated water discharges will not meet the SWB-8 standards

all the time. As stated by Mr. Ellis of Edison, the discharge from

Dresden will meet the 93°F, temperature at all times, but will not

meet the 5°F,after the 600’ mixing zone in the winter months under

certain conditions. However, when Alternate 3 is completed by

September 1, 1973, and the cooling lake is being operated closed

cycle, and the discharge is passed through a diffuser, these condi-

tions will be met.

It is obvious that using Alternate 3, which is basically the

closed cycle operation of 

the

cooling lake, Edison has met the

Board’s request that it find a method to meet the standards in SWB-8.

From the uncontradicted evidence, all discharges, even that of

Dresden 1, will meet 

the standards of SWB-8, when the closed 

cycle

system is installed in September of 1973. This is indeed an example

of compliance with the wishes of the Board.

Edison askes that it be granted a variance to fully operate

the Dresden units, even though during certain times 

in the winter

it will not meet 

the 5°F.limitation at 

the end of the 600’ 

mixing

zone. To be granted a 

variance 

Edison must prove, as we have said,

that compliance with the Rules, SWB-8 in this instance, would

impose an arbitrary or unreasonable hardship, We believe that Edi-

son has proved that such a hardship exists here. The harm to the

River will be minimal because the violations of the temperature stand-

ards will occur only in the wintertime, when the system is best able

to take the additional heat. To require a cutback in the operation

of the units could mean that electric power will not be available

when the system demands it, For the little amount of damage., if any,

that will occur as a result of the slight breach of the Rules, we

do not feel that it is worth controlling that discharge by 

requir-

ing

that the production of power be cut back. 

The cost would be too

high, and therefore, we grant the variance from the 5°limitation 

of

SWB-8 

durinq the winter months until November 23, 1972. Edison can,

if

it desires, file a petition to extend that variance until September

1, 1973, so 

long as the petition is filed not later than ninety (90)

days before November 23, 1972. It is our intent at this time to

allow the variance until the cooling lake is in operation, but the

Act does not allow variances longer than one year.

3

—

133

One other point concerning heated water discharges must be

dealt with. On September 24, 1971, Edison directed a letter to the

Board, in the nature of 

a petition for variance, asking for a var-

iance

covering heat discharges to the Illinois River because the

cooling lake may not have operated by October 1, 1971, the date

originally set by the Board, Since the testimony by Mr. Ellis 

is

that the cooling lake is operating,the question of the variance

requested in the letter of September 24, 1971 

is

now moot and

therefore will be denied as such.

Emergency Core Cooling

The

subject of the emergency core cooling systems in Dresden

Unit 3 were not 

really dealt with in any of the hearings specific-

ally related to that Unit. However, the Board has had hearings

related to that

matter in the Quad 

Cities application. Since each

Quad Cities unit 

is

almost a “carbon copy” of the Dresden Unit 3,

the testimony gained on the subject of core cooling in 

the Quad

Cities case is certainly applicable here. In the Quad Cities

opinion, we concluded the following after

reviewing the testimony

on the subject of core cooling:

“While we shall maintain a continuing concern

for this and all other matters related to possible

radiation hazards, and while we shall 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.”

In essence, then, we feel that the core cooling problem may be a

real one and needs close supervision. It is for this reason that

the Dresden Unit 3 permit is herein modified to require reporting

of any activation, whether spurious or real, of the emergency core

cooling system. This information, when provided and analyzed, will

provide the basis, perhaps, for decisions in the area of emergency

core

cooling.

While we 

do not feel the evidence warrants any more action

than reporting of activation of 

the

emergency core cooling systems,

we do know from 

the evidence 

in

the

Quad Cities record that 

the

Dresden Unit 3 should not be operated 

if

~ny of the emergency core

cooling systems are unable to operate. This will be a condition of the

permit, for to do otherwise would create a radiation risk which the

public should not be forced to accept.

This opinion constitutes the findings of fact and conclusions

of law of the Board.

3—134

ORDER

Based upon the testimony and exhibits in the record, the

Board hereby orders the following:

1.  The Permit issued by 

the

Board to Edison on March 3,

1971 for the operation of Dresden Unit 3 is hereby amended as

follows:

(a) Paragraphs 4(a) 

and

4(b) of the original permit

are hereby replaced by the following paragraphs:

“4(a)

Gross beta-gamma radioactivity of

gaseous emissions released to the atmosphere

from Dresden Unit 

3 shall not exceed an 

annual

average of 80,000 microcuries per second,

“4(b) If gaseous radioactive emissions

at any time exceed 37,500 microcuries per

second from Dresden Unit 3, Edison shall ini-

tiate operating procedures, to the extent

permitted wit~outinterrupting electric ser-

‘~ice, to reduce such release,

“4(c) By April 1, 1973, Edison shall

have completed the installation of a catalytic

recom.biner and eight (8) charcoal bed system,

as outlined in the record of this proceeding,

to treat the air ejector effluent, On and

after that date gaseous radioactive emissions

from Dresden Unit 3 shall not exceed an annual

average of 3000 microcuries per second. The

latter emission limit shall include emissions

from the gland seal,”

(b) Paragraphs 3(a) and 3(b) of the original permit

are hereby replaced by the following paragraphs:

“3(a) Radioactivity in liquid effluents

shall be controlled so that the annual average

gross beta-gamma radioactivity, excluding tn-

tium, discharged to the Illinois-River shall

not exceed lxlO7 microcuries per cubic centi-

meter (100 picocuries per liter) and annual

average tritium activity discharged to the

Illinois River shall not exceed 3xl0’~4micro-

cunies per cubic centimeter.

3

—

135

“3(b)

Edison shall immediately begin to

install the 

system described in

the

April

13

report as the “maximum recycle” system (Alter-

nate 3) plus a system which would require the

decontamination solutions be drummed and 

dis-

posed

of as a solid waste. Installation of the

system as required herein shall be completed by

September 1, 1973, and thereafter the emission

limits of paragraph 4(a), herein, shall apply

to the blowdown of the cooling lake.”

(c)  Paragraph 7 of the Original permit is hereby

replaced by the followinc; paragraphs:

“7(a) Permittee shall cooperate to the

full extent necessary with the Environmental

Protection Agency and the Illinois Department

of Public Health for purposes of development

by those agencies of an adequate and effective

emergency protection plan designed to imme-

diately control and minimize the effects of

any accidental release of unexpectedly large

quantities of radioactivity from the Dresden

Unit 3 nuclear generating plant. In particular,

Edison shall immediately notify both the Environ-

mental Protection Agency and the Illinois Depart-

ment of Public Health of 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 power plant systems, and shall report

monthly to the Board and the Environmental

Protection Agency any activation of the emer-

gency core cooling system, whether spurious

or real, exclusive of testing.

“7(b)

Edison shall not operate Dresden

Unit 3 if any of the emergency core cooling

systems are unable to operate.”

2.  Edison is hereby granted a variance from the 5°F. limi-

tation of SWB—8 during the winter months under the following condi-

tions:

(a) The variance shall end on November 23, 1972; and

3— 136

(b)  If Edison seeks to extend the variance beyond

that date to September of 1973 when it is contemplated

that the cooling lake will be operated closed cycle, Edi-

son shall file a petition for variance with the Board

not later than ninety (90) days prior to November 23, 1972.

I,

Christan Moffett, Acting Clerk of the Pollution Control

Board, certify that the Board adopted the above Opinion and Order

this 

..~

day of November, 1971.

Christan Moffet

/29

Acting Clerk

3—1