ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
October 31, 2005
R A.` C
Rt
I V E D
CLERKS OFFICE
Dresden Nuclear Generation Station
)
NOV - 2 2005
STATE OF
ILLINOIS
Pollution Control Board
Petitioner,
)
v
.
)
IEPA - 06-09
(Provisional Variance-Water)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent
.
)
Re :
Provisional Variance From Special Conditions 4A, 4D, and 4G
of NPDES Permit IL0002224
Dear Mr. Wozniak
:
The Illinois Environmental Protection Agency (Agency) has completed its technical review of
the attached provisional variance request (Attachment A) submitted by Dresden Nuclear
Generation Station (Dresden Station) on October 14, 2005 . Dresden Station is requesting this
provisional variance so that it can install a redundant lift station main breaker and replace all six
of the lift pump breakers. These improvements will significantly improve the reliability of the
cooling pond lift station .
Based on its review, the Agency GRANTS a provisional variance
subject to the specific conditions set forth below
.
Background
Dresden Station is a nuclear-fueled steam electric generating facility located at the confluence of
the Des Plaines and Kankakee Rivers near Morris, Illinois, at River Mile 272
.3. The two boiling
reactors have a maximum generating capacity of 1824 megawatts electric .
Circulating water
used to cool and condense the steam from the generating process is discharged to a 1275 acre
cooling pond .
Dresden Station normally operates in a closed cycle mode from October 1 through June 14
(about 8 % months) . In the closed cycle mode, approximately 1,000,000 gallons per minute
(gpm) of cooling water is drawn into the station's cribhouse intake structure, passes through the
station's heat exchangers, and discharges to a hot canal that routes the water approximately two
miles to the lift station
.
The lift station lifts the 1,000,000 gpm of the cooling water
approximately 20 feet from the hot canal to the aboveground cooling pond . The cooling water
routes around the cooling pond and spills over a spillway into the cold canal, which routes the
cooling water approximately two miles back to the station . The flow regulating gates direct the
majority of the cooling water back to the cribhouse intake structure through a return canal
.
These gates divert approximately 5 percent or 50,000 gpm of the cooling water flow (limited to
72 million gallons per day (MGD)) to the Illinois River via Outfall 002. The Kankakee River
provides makeup flow through a '/a-mile intake canal . The volume of makeup flow is equal to
the blowdown flow and water lost to evaporation .
From June 15`h to September 30th (about 3 % months), Dresden is allowed to operate in an in-
direct open cycle mode. In this mode, approximately 1,000,000 gpm of cooling water is drawn
into the station's cribhouse intake structure from the Kankakee River via the intake canal . This
cooling water passes through Dresden's heat exchangers and discharges to the hot canal that
routes the water approximately two miles to the lift station . The lift station lifts the cooling
water approximately 20 feet from the hot canal to the aboveground cooling pond . The cooling
water routes around the cooling pond and spills over the spillway into the cold canal, which
routes the cooling water approximately two miles back to the station . The flow regulating gates
divert all the cooling water flow (approximately 1,000,000 gpm) to the Illinois River via Outfall
002. The Illinois Pollution Control Board approved this operational scheme and the related
alternate thermal standards on July 9, 1981
.
The lift station is equipped with six lift pumps, each with a 167,000-gpm capacity. The pumps
provide motive force that allows the cooling water to flow around the cooling pond, over the
spillway, through the cold canal to the flow regulating gates
.
Relief Requested
Dresden Station seeks a variance from Special Conditions 4A, 4D,and 4G of NPDES Permit
IL0002224 (Attachment B). Special Condition 4A requires that the maximum temperature rise
above natural temperature must not exceed 5° at the edge of the mixing zone, in accordance with
Section 302.211(d) of Subtitle C (35 Ill. Adm. Code Sec. 302.211(d)) when operating in close
cycle mode. Special Condition 4D requires that Dresden operate in the closed cycle mode during
the period October 1 to June 14. Special Condition 4G allows Dresden to bypass the cooling
pond only when both generating units are out of service . A variance from these conditions will
allow Dresden Station to operate in direct open cycle mode
(i.e ., bypass the cooling pond) .
Dresden Station requests that the provisional variance begin on Tuesday, November 1, 2005, and
potentially extend into Sunday, November 20, 2005, during which time Dresden Station can
operate in direct open cycle mode for 180 hours . During this period, Dresden Station will install
new 4KV switchgear with a backup Main Feed Breaker (MFB)
.
Once the installation is
complete, the lift station will have redundant powerlines, redundant transformers, and redundant
MFBs, which will enable the lift station to withstand any single component failure . In addition,
Dresden Station will also replace the six lift pump breakers with new breakers
.
To minimize the thermal discharge from the plant, the provisional variance period coincides with
a scheduled refueling outage in November when the station requires one-half of the normal
2
cooling requirements. In addition, here will be a period of several days when both units are out
of service, further minimizing the thermal output during the this period
.
Agency Determiniations
The Agency has reviewed the requested provisional variance and has concluded the following
:
1 . No significant environmental impact will occur as a result of this provisional variance
.
Dresden Station will closely monitor the environmental impact from the requested relief
and will immediately notify the Agency of any significant impact along with actions
taken to remedy the problem ;
2. No reasonable alternatives appear available ;
3. No public water supplies will be affected ;
4. No federal regulations will preclude the granting of this request; and
5. Dresden Station will face an arbitrary and unreasonable hardship if the request is not
granted
.
Conditions
The Agency hereby GRANTS the Dresden Station a provisional variance from Special
Conditions 4A, 4D, and 4G of NPDES Permit IL0002224, subject to the following conditions
:
A. The provisional variance shall begin on Tuesday, November 1, 2005, and
potentially extend into Sunday, November 20, 2005, during which time Dresden
Station can operate in direct open cycle mode for 180 hours
;
B. Dresden Station shall comply with the General Use thermal discharge standards
outlined in its NPDES permit's Special Condition 4B during the variance period ;
C. Dresden Station shall continuously monitor intake, discharge and Dresden Lock
and Dam temperatures to so it can document environmental conditions during the
variance period. Dresden Station shall also conduct visual inspections on a daily
basis in the vicinity of the intake and the discharge, so it can document the effects
of the increased thermal output to the river .
Dresden Station shall notify the
Agency if it identifies any unusual or unexpected environmental impact
;
D. Dresden Station shall conduct additional biological monitoring of the resident fish
community, which shall consist of fish sampling during and after the variance
period .
Dresden Station shall conduct two surveys at eight locations using
electrofishing, and two surveys at seven locations using seining . Dresden Station
3
shall also monitor the physical conditions by compiling temperature and oxygen
profiles in all appropriate survey locations ;
E. Dresden Station shall conduct additional biological monitoring of the benthos
community, which shall consist of macro invertebrate sampling just prior to and
just after the variance period
.
These two surveys shall be performed at six
locations using a Ponar grab sampler
;
F. Dresden Station shall notify Roger Callaway of the Agency by telephone at
217/782-9720 when the need to operate in direct open mode begins and again
when the 180 hours are utilized . Written confirmation of each notice shall be sent
within five days to the following address
:
Illinois Environmental Protection Agency
Bureau of Water - Water Pollution Control
Attention: Roger Callaway
1021 North Grand Avenue East, MC #19
Springfield, Illinois 62794-9276
G. Dresden Station shall sign a certificate of acceptance of this provisional variance
and forward that certificate to Roger Callaway at the address indicated above
within one day of the date of this order
.
The certification should take the
following form
:
I (We) , hereby accept and agree to be bound by all terms
and conditions of the provisional variance granted by the Agency in
dated
Petitioner
Authorized Agent
Title
Date
Dresden Station shall continue to monitor and maintain compliance with all other parameters and
conditions specified in its NPDES Permit No . IL0002224 .
4
Conclusion
The Agency grants this provisional variance in accordance with its authority contained in
Sections 35(b), 36 (c), and 37(b) of the Illinois Environmental Protection Act (415 ILCS 5/35(b),
36(c), and 37(b) (2004) .
The decision to grant this provisional variance is not intended to
address compliance with any other applicable laws or regulations
.
Robert A. Messina
Chief Legal Counsel
cc
:
Marcia Willhite
Roger Callaway
Vera Herst
5
ExelonCeneratIorCOmDany,LLC
evww.exeloncecp.cem
Dresden Nuclear Power Ration
65u0 Noesden Road
M 0rris,IL60A50-97b .
~'
OCT 1 4 2005
DBWLtr 05-022
a F,
VIA AIRBORNE EXPRESS
Mr. Mike Garretson
Manager, Compliance Assurance Section #19
Illinois Environmental Protection Agency
Bureau of Water
1021 North Grand Avenue East
P. 0. Box 19276
Springfield, Illinois 62794-9276
Subject :
Dresden Nuclear Generation Station
NPDES Permit No. IL0002224
Provisional Variance
- Request for Installing Redundant Lift Station Main Breaker
Dear Mr. Garretson :
The purpose of this request is to allow Dresden Station to operate in the Direct Open Cycle mode for a
maximum of 180 hours during a twenty-day period in order to install a redundant Lift Station Main Breaker
and replace all six Lift Pump Breakers, significantly improving the reliability of the cooling pond Lift Station
.
Exelon Generation Company, LLC . ("Exelon") hereby requests that a provisional variance be granted for
its Dresden Generating Station ("Dresden" or "station") as provided for by Title IX, Section 35, Subsection
(b) of the Illinois Environmental Protection Act ("Act") .
BACKGROUND
Dresden is a nuclear-fueled steam electric generating facility located at the confluence of the Des Plaines
and Kankakee Rivers near Morris, Illinois, at River Mile 272 .3. The two boiling water reactors have a
maximum generating capacity of 1824 megawatts electric. Circulating water used to cool and condense
the steam from the generating process is discharged to a 1275 acre cooling pond
.
The Station normally operates in a Closed Cycle mode from October 1st through June 14th of each year
(about 8-1/2 months) . In this mode, approximately 1,000,000 gallons per minute (gpm) of cooling water is
drawn into the station's Cribhouse intake structure, passes through the station's heat exchangers, and
discharges to a hot canal that routes the water approximately two miles to the Lift Station . The Lift Station
lifts the 1,000,000 gpm of the cooling water approximately 20 feet from the hot canal to the aboveground
cooling pond. The cooling water routes around the cooling pond and spills over a Spillway into the cold
canal. The cold canal routes the cooling water approximately two miles back to the station . The Flow
Regulating Gates direct the majority of the cooling water back to the Cribhouse intake structure through a
return canal. The Flow Regulating Gates divert approximately 5 percent or 50,000 gpm of the cooling
water flow (limited to 72 million gallons per day (MGD)), to the Illinois River via Outfall 002. The Kankakee
River provides makeup flow through a
1/4-mile intake canal. The volume of makeup flow is equal to the
blowdown flow and water lost to evaporation
.
Attachment A
Exel n
Nuclear
Dresden is allowed to operate in an In-Direct Open Cycle mode from June 15th to September 30th of
each year (about 3-1/2 months). In the Indirect Open Cycle mode, approximately 1,000,000 gpm of
cooling water is drawn into the station's Cribhouse intake structure from the Kankakee River via the intake
canal. This cooling water passes through the station's heat exchangers and discharges to the hot canal
that routes the water approximately 2 miles to the Lift Station . The Lift Station lifts the cooling water
approximately 20 feet from the hot canal to the aboveground cooling pond. The cooling water routes
around the cooling pond and spills over the Spillway into the cold canal . The cold canal routes the cooling
water approximately two miles back to the station. The Flow Regulating Gates divert all the cooling water
flow (approximately 1,000,000 gpm) to the Illinois River via Outfall 002 . The Illinois Pollution Control
Board ("IPCB") approved this operational scheme and the related alternate thermal standards on July 9,
1981, (IPCB #79-134)
.
The Lift Station is equipped with six lift pumps, each with a 167,000-gpm capacity . The lift pumps provide
motive force that allows the cooling water to flow around the cooling pond, over the Spillway, through the
cold canal to the Flow Regulating Gates
.
I
.
RELIEF REQUESTED
A provisional variance is being requested from Special Condition Nos . 4A, 4D and 4G in NPDES Permit
No. IL0002224
.
•
Special Condition 4A requires that the maximum temperature rise above natural
temperature must not exceed 5° F at the edge of the mixing zone, in accordance with
Section 302.211(d) when operating in closed cycle mode .
•
Special Condition 4D requires that Dresden operate in the Closed Cycle mode during the
period October 1st to June 14th .
•
Special Condition 4G allows the station to bypass the cooling pond only when both
generating units are out of service.
Based on historical Illinois River flow data we reasonably anticipate that the temperature rise in the Illinois
River will remain within the 5 F temperature limit of Special Condition 4A during the Provisional Variance
period. In response to your specific request we have determined a worst-case scenario that would occur
with extremely low Illinois River flows . Assuming Illinois River flow dropped to 1,000,000 gpm ; a Plant
discharge temperature rise of 14 F, and, a Discharge Canal flow of 1,000,000 gpm, the maximum
temperature rise in the Illinois River may reach as high as 7 F . However, we do not anticipate the Illinois
River flows to drop below 2,000,000 gpm during the provisional variance period
.
Specifically, Exelon requests that Dresden be allowed take the Lift Station out of service and operate in
the Direct Open Cycle mode (i .e . bypass the cooling pond) for 180 hours during a twenty-day period . The
period would begin on Tuesday, November 1st, and potentially extend into Sunday November 20, 2005
.
During this period, Dresden will install new 4KV switchgear with a backup Main Feed Breaker (MFB)
.
Once this installation is complete the Lift Station will have redundant power lines, redundant transformers
and redundant MFBs, enabling the Lift Station power supply system to withstand any single component
failure. Dresden will also replace all six aging Lift Station Pump breakers with new breakers. These
actions will significantly increase the reliability of the Lift Station
.
This work is scheduled to coincide with a refueling outage on one of the Station's two generating units in
order to minimize the thermal discharge from the plant during the provisional variance period
. There will
be a period of several days when both units are out of service further minimizing the thermal output during
the provisional variance period .
OCT 1 4 2005
O
II .
NECESSITY FOR REQUEST
The requested provisional variance will enable Dresden to install new 4KV switchgear with a redundant Lift
Station MFB. With the installation of a redundant Lift Station MFB, the Lift Station will continue to operate
even with a loss of a power supply, or the loss of a main transformer or the loss of the MFB. Prior to
these upgrades a loss of any of these power supply components would force the bypass of the cooling
pond in violation of NPDES Permit Special Condition 4G, and, cause the effluent temperature to exceed
93 degrees F in violation of NPDES Permit Special Condition 4B . To reduce the potential for this type of
event, Dresden is implementing the final hardware piece needed to make the power supply single failure
proof .
This hardware upgrade can only be accomplished while the Lift Station is out of service . With the Lift
Station out of service, Dresden's effluent cooling water must bypass the cooling pond and be sent directly
to the Illinois River (Direct Open Cycle operation) . After careful analysis, the Station determined that all
tasks associated with the hardware upgrade could be completed and fully tested within the fifteen day time
frame .
This provisional variance is intended to coincide with a scheduled refueling outage in November when the
station only requires one-half of the normal cooling requirements . In addition, there will be an over-lapping
dual unit outage. Performing the provisional variance during the period requested should have a
negligible impact on the aquatic community of the Illinois River
.
Ill . ASSESSMENT OF ADVERSE ENVIRONMENTAL IMPACTS
The thermal impact of the proposed Open Cycle operation with respect to the near-field aquatic
community is expected to be minimal . Over the last four years, the ambient water temperature in the
Illinois River (receiving stream) averaged 52 degrees F between November 1 s' and November 20`h .
It is
anticipated that the ambient temperature of the Illinois River will be about the same during this provisional
variance period .
The flow rate in the Illinois River during the fall is typically higher than during the summer months
.
During the fall, cooler ambient air temperatures and lower humidity will dissipate heat from the cooling
water discharged from the plant to the atmosphere more rapidly than during typical summer conditions
.
With one of the Dresden Units in a refueling outage, the discharge flow will be about one-half the normal
discharge flow rate. The combination of higher Illinois River flow, lower station effluent flow, and cooler
ambient conditions will result in the facility maintaining compliance with the thermal limits specified in
Special Condition 4B of the NPDES Permit
.
The Station normally discharges a blowdown flow of warmer cooling pond water to the Illinois River during
the closed cycle operating mode (72-MGD maximum). Thus, fish inhabiting the discharge canal will be
acclimated to temperatures above ambient river temperature and should be sufficiently reactive to avoid
areas that are out of their desired temperature range
.
In all the previous years of fisheries monitoring near Dresden, the resident fish community was dominated
by species that are not highly sensitive to moderate temperature changes . In addition, the number of fish
species and individuals has steadily improved since the station began operating in the In-Direct Open
Cycle mode, despite the increased thermal input. Fish spawning activities generally occur in the spring
.
Despite Dresden's significant discharge volume, the thermal plume has been characterized as buoyant in
all previous studies submitted to the IEPA. Therefore, benthic organisms are not likely to be adversely
affected by the short-term relief requested . The overall impact of the Station's thermal plume on the
Illinois River is expected to be minimal
.
3
OCT 1 4 2005
As mentioned above, this upgrade is scheduled to occur during an outage of one of the two units . In
addition, the second unit will be out of service for a few days of the provisional variance period . This
scheduling will decrease the thermal output of the plant and, consequently, decrease thermal impacts
during this period
Dresden obtained a 21-day provisional variance during the fall of 1999 to perform an upgrade to the Lift
Station power supply (Line 1207) . This upgrade was also performed when one of the two units was in a
refueling outage. Monitoring included river temperatures, flows and visual observations . Dresden also
received a 10-day provisional variance on October 8, 2002 to allow completion of Dresden Lift Station
preventative maintenance pursuant to IPCB 03-40 . During both periods, no adverse environmental
impacts were noted
.
Station management is committed to remaining in compliance with the applicable General Use
temperature standards (as required by permit Special Condition 48), throughout the course of the Lift
Station maintenance work. All of the factors listed above should effectively minimize the impact of this
period of Open Cycle operation upon the surrounding aquatic environment
.
IV . ALTERNATIVES TO REQUESTED RELIEF
Exelon considered various alternatives to seeking regulatory relief in planning the installation of a backup
Main Feed Breaker to Dresden Station's cooling lake lift station and in planning the replacement of all six
Lift Pump breakers . The challenge that we faced in planning out this activity was to figure out a way to
safely and reliably use as much of the existing cooling system as possible while simultaneously performing
the needed system modifications. Since installation of a backup Main Feed Breaker involved power to all
six lift station pumps, the planning scenarios quickly focused on three options : (1) Shutdown all plant
operations to eliminate the thermal discharge (2) construct auxiliary cooling facilities and (3) install
temporary lift station pumps while the lift station is out-of-service . Each of these alternatives are evaluated
in more detail below :
(1)
Shut Down All Plant Operations to Eliminate the Thermal Discharge
A full fifteen-day shutdown of both units at this time could significantly affect the company's ability
to maintain power on the grid. Further, it would be difficult to schedule the resources needed to
perform simultaneously, the maintenance required during shutdown of both units and support the
needed Lift Station work . To do so would result in significant time and materials, as well as undue
stress on existing equipment, while the overall benefit to the environment would be expected to be
minimal . In addition, a 15 day shut down of this base-loaded nuclear plant could potentially
jeopardize power availability in our service territory, as this is the normal time period when many
of the cycling fossil units are brought down for routine maintenance outages
.
(2)
Construct Auxiliary Cooling System
This option would involve the utilization of existing Cooling Towers . These Cooling Towers would
be used to reduce the temperature of the cooling water discharged from the plant instead of the
cooling pond . The cooling water discharged from the Cooling Towers would have to be re-routed
to the cold canal. This would require the installation and operation of a diesel-generator capable
of lifting the cooling water at the rate of 500,000 gpm . Temporary pumps and piping would be
required to transport the 500,000 gpm from the Hot Canal to the Cold Canal . The Cold Canal
would then route the cooling water back to the plant .
(3)
Install Temporary Lift Pumps While the Lift Station is Out-Of-Service
OCT 1 4 2005
This would involve the installation and operation of a diesel-generator capable of lifting cooling
water 23 from the Hot Canal into the cooling pond at the rate of 500,000 gpm . Temporary pumps
and piping would be required to transport the cooling water into the cooling pond where it would
route by gravity to the Cold Canal . The cold Canal would route the cooling water back to the
plant. This temporary installation would required a considerable amount of space and would
interfere with the Lift Station switchgear replacement and reserve feed raceway installation
.
Whenever installing large, complex temporary systems there is always a concern with safety and
reliability. There can be unexpected power interruptions and/or equipment failures that have the
potential of complicating the ongoing work . Renting temporary pumps of this size would require
the building of a temporary structure to house them . The discharges from these pumps would
have to place across and over the top of the lake dike that could impact the dike integrity in the
event of a hose rupture. The failure of a single temporary transfer pipe could be catastrophic
.
V .
MITIGATIVE ACTIONS TOBETAKEN DURING THE VARIANCE PERIOD
Station management is committed to complying with the General Use thermal discharge standards
outlined in permit Special Condition 4B during the requested provisional variance period
.
To document environmental conditions during the open cycle period, intake, discharge and Dresden Lock
and Dam temperatures will be continuously monitored . A summary of this data will be submitted to the
Agency after the variance period ends. Additionally, visual inspections will be conducted on a daily basis
in the vicinity of the intake and the discharge, to document the effects of the increased intake flow, as well
as increased thermal output to the river. If any unusual or unexpected environmental impacts are
identified, Dresden will notify the IEPA immediately.
VI
. ADDITIONAL ENVIRONMENTAL MONITORING
Dresden intends to perform additional environmental monitoring in association with the provisional
variance . Dresden will have per-variance environmental data collected in August/September as part of
our on-going long-term Upper-Illinois Waterway Study. Additional monitoring will be conducted during and
after the provisional variance period
.
The additional biological monitoring of the fisheries will consist of fish sampling during and after the
variance period . There will be two surveys performed at 8 locations using electrofishing and two surveys
performed at 7 locations using seining . Monitoring of the physical conditions will consist of temperature
and oxygen profiles in all appropriate survey locations
.
The additional biological monitoring of the benthos community will consist of macro invertebrate sampling
just prior to and just after the variance period . Unlike the fisheries sample, where we can use the last fish
collection of the long-term monitoring study as the pre-variance sample, the benthos samples collected in
August would not be adequately representative of the early November benthic community . These two
surveys will be performed at 6 locations using a Ponar grab sampler
.
VII . SUMMARY
A provisional variance for relief from Special Conditions 4A, 4D and 4G is requested for a 180 hours
during a twenty day period from November 1st through November 20th . It is Exelon's position that not
granting this provisional variance to Dresden Station would impose an arbitrary and unreasonable
hardship. A negative decision could result in the Station being forced into an emergency Open Cycle
situation during a period when performing the required repairs may not be feasible
.
a
A (?~"
T'th T?
~!'
OCT 14 2005
There is no other provisional variance relief in effect at this time for Dresden Station
.
The last provisional variance for Dresden Station was granted on October 8, 2002 for the period of 10
days to allow completion of Dresden Lift Station preventative maintenance pursuant to IPCB 03-40
.
Should you require any further information in order to expedite the processing of this request or have any
questions, please contact Ed Rowley of my staff at 815-416-3287
.
Sincerely
David B. Wozniak
Dresden Station Plant
CC :
J. Roberson
J. Petro
G. Papanic
B. Rybak
J. Schmitz
S . Neal
P. Melberg
File
r
OCT 1 4 2005
217/732-0610
October
6,
2000
Commonwealth Edison Company
Environmental Services Department
Post Office Box
767
Chicago, Illinois
60690
Re :
Commonwealth Edison Company
Dresden Power Station
NPDES Permit No. 1L0002224
Final Permit
Gentlemen :
Attached is the final NPDES Permit for your discharge. The Permit as issued covers discharge limitations,
monitoring, and reporting requirements. The failure of you to meet any portion of the Permit could result in
civil and/or criminal penalties. The Illinois Environmental Protection Agency is ready and willing to assist
you in interpreting any of the conditions of the Permit as they relate specifically to your discharge
.
The Permit as issued is effective as of the date indicated on the first page of the Permit. You have the right
to appeal any condition of the Permit to the Illinois Pollution Control Board within a 35 day period following
the issuance date
.
To assist you in meeting the self-monitoring and reporting requirements of your reissued NPDES permit, a
supply of preprinted Discharge Monitoring Report (DMR) forms for your facility is being prepared. These
forms will be sent to you prior to the initiation of DMR reporting under the reissued permit . Additional
information and instructions will accompany the preprinted DMRs upon their arrival
.
Should you have questions concerning the Permit, please contact Darin LeCrone at the telephone number
indicated above
.
Thomas G. McSwiggin, P .E .
Manager, Permit Section
Division of Water Pollution Control
TGM:SFN:DEL:99122901 .grm
Attachment: Final Permit
cc :
Records
ance
ce:Sectrorr.
'a
Maywood Region
Facility
Attachment B
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021
NORTH GRAND AVENUE EAST, P.O .
Box 19276 .
SPRINGFIELD, ILLINOIS
b2794-9276
THOMAS V. SKINNER, DIRECTOR
PRINTED ON RECYCLED PAPER
Expiration Date :
October 31
,
2005
Name and Address of Permittee :
Commonwealth Edison Company
Environmental Services Department
Post Office Box 767
Chicago, Illinois 60690
Discharge Number and Name :
001 Unit I House Service Water
A01 Unit 1 Intake Screen Backwash
002 Cooling Pond Blowdown
A02 Unit 2/3 Intake Screen Backwash
B02 Wastewater Treatment System Effluent
C02 Red waste Treatment System Effluent
D02 Demineralizer Regenerate Waste
E02 NW Material Access
Runoff
003 Sewage Treatment Plant
Effluent
004
Cooling Pond Discharge
.
005 South East Area Runoff
006 North East Area Runoff
NPDES Permit No . IL0002224
Illinois Environmental Protection Agency
Division of Water Pollution Control
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
Reissued (NPDES) Permit
Issue Date
:
October 6, 2000
Effective Date
:
November 1, 2000
Facility Name and Address
:
Commonwealth Edison Company
Dresden Power Station
6500 North Dresden Road
Morris, Illinois 60450
Receiving Waters
:
Illinois River
Illinois River
Illinois River
Illinois River
Illinois River
Illinois River
Illinois River
Illinois River
Kankakee River
Kankakee River
Kankakee River
Kankakee River
In compliance with the provisions of the Illinois Environmental Protection Act . Title 35 of III. Adm. Code, Subtitle C and/or Subtitle D, Chapter
1, and the Clean Water Act (CWA), the above-named permittee is hereby authorized to discharge at the above location to the above-named
receiving stream in accordance with the standard conditions and attachments herein
.
Permittee is not authorized to discharge after the above expiration date . In order to receive authorization to discharge beyond the expiration
date . the permittee shall submit the proper application as required by the Illinois Environmental Protection Agency (IEPA) not later than
180 days prior to the expiration date .
homas G. McSwiggin, 15 E .
~/
Manager, Permit Section
Division of Water Pollution Control
TGM:OEL:99122901 .grm
Page 2
NPDES Permit No . IL0002224
Effluent Limitations and Monitorinq
LOAD LIMITS lbs/day
CONCENTRATION
DAF (DMF) LIMITS mo/I
30 DAY
DAILY
30 DAY
DAILY
SAMPLE
SAMPLE
PARAMETER
AVERAGE
MAXIMUM
AVERAGE
MAXIMUM
FREQUENCY
TYPE
1 . From the effective date of this permit until the expiration date, the effluent of the following discharge(s) shall be monitored and limited
at all times as follows :
Flow (MGD)
Daily
Continuous
*See Special Condition 11
.
"See Special Condition 18
.
Outfall : A01 - Intake Screen Backwash
There shall be no discharge of collected debris
Outfall(s) : 001
- Unit 1 House Service Water**
This discharge consists of:
Approximate Flow
1
.
Equipment Cooling Water
4.3 MGD
2 .
Unit 1 Area Stormwater Runoff
Intermittent
3 .
a .
b .
East Area Roof Runoff
Unit 1 Yard Area Runoff
Intermittent
Unit 1 Intake Screen Backwash
4 .
North East Area Runoff*
Page 3
LOAD LIMITS lbs/day
DAF (DMF)
30 DAY
DAILY
PARAMETER
AVERAGE
MAXIMUM
NPDES Permit No. IL0002224
Effluent Limitations and Monitorinq
CONCENTRATION
LIMITS mg/I
30 DAY
AVERAGE
DAILY
SAMPLE
SAMPLE
MAXIMUM
FREQUENCY
TYPE
1 . From the effective date of this permit until the expiration date, the effluent of the following discharge(s) shall be monitored and limited
'Cooling pond blowdown flow during closed cycle : 72 MGD: during indirect open cycle operation : 1548 MGD
'-See Special Condition 13
.
"`See Special Condition 18
.
at all times as follows
:
Outfall(s): 002 - Cooling Pond Blowdown
This discharge consists of
:
Approximate Flow
1
.
Unit 2/3 Condenser Cooling Water
2 .
Demineralizer Regenerant Waste
0.034 MGD
3 .
Rad waste Treatment System Effluent
Intermittent
4 .
Wastewater Treatment System Effluent
0.021 MGD
5 .
Unit 2/3 House Service Water
86.4 MGD
6 .
Unit 2/3 House Service Water Strainer Backwasn
0.001 MGD
7 .
Unit 2/3 Intake Screen Backwash
Intermittent
8 .
Unit 2 Auxiliary Boiler Area Oil/Water Separator
Intermittent
9 .
138 KV Switchyard Oil/Water Separator
intermittent
10 .
345 KV Switchyard OiI/Water Separator—
intermittent
Flow (MGD)
pH
Temperature
Total Residual Chlorine/
Total Residual Oxidant**
See Special Condition 1
See Special Condition 2
See Special Condition
4
0/2/0.05"
Daily
1/Week
Daily
2/Month
Continuous
Grab
Continuous
Grab**
Page
4
LOAD LIMITS lbs/day
DAF (DMF)
30 DAY
DAILY
PARAMETER
AVERAGE
MAXIMUM
'See Special Condition 14
.
NPDES Permit No. IL0002224
Effluent Limitations and Monitoring
CONCENTRATION
LIMITS mq/I
30 DAY
DAILY
SAMPLE
SAMPLE
AVERAGE
MAXIMUM
FREQUENCY
TYPE
1 . From the effective date of this permit until the expiration date, the effluent of the following discharge(s) shall be monitored and
limited at all times as follows :
Outfall(s): A01 - Unit 2/3 Intake Screen Backwash
There shall be no discharge of collected debris
Outfall(s)
: B02 - Wastewater Treatment System Effluent'
This discharge consists of:
Approximate Flow : 0.021 MGD
1
.
Unit 1 Oil/Water Separator Effluent
IntermiCent
2 .
a
.
b
.
c .
Unit 1 HPCI Building Floor Drains
Unit 1 Main Power and Auxiliary Power
Transformer Area Runoff
Decontamination Area Runoff
ntemattent
Unit 2/3 Oil/Water Separator Effluent
3 .
a
.
b
.
d
.
West Area Roof Runoff
Station Floor Drains (Turbine building,
Turbine Lube Oil Storage Area, Diesel
Generator Room, Air Compressor Room)
Unit 2/3 Area Yard Runoff
Unit 2/3 Main Power and Auxiliary Power
Transformer Area Runoff
Crib House Floor Drains
I nterr:'.ent
Flow (MGD)
Total Suspended Solids
15
30
Daily
1/Week
Continuous
24-Hour
Composite
Oil and Grease
10
2C
2/Month
Grab
Page
5
LOAD LIMITS lbs/day
OAF (DMF)
30 DAY
DAILY
PARAMETER
AVERAGE
MAXIMUM
1 . From the effective date of this permit until the expiration date, the effluent of the following discharges) shall be monitored and
Outfall(sy 002 - Demineralizer Regenerant Waste and Filter Backwash
Flow (MGD)
Total Suspended Solids
Outfall(s): E02
- NW Material Access Runoff'
'See Special Condition 18
.
NPDES Permit No . IL0002224
Effluent Limitations and Monitoring
CONCENTRATION
LIMITS mg/I
30 DAY
DAILY
SAMPLE
SAMPLE
AVERAGE
MAXIMUM
TREQUENCY
TYPE
.Approximate Flow: 0.034 MGD
Daily
Continuous
8-Hour
15
30
?!Month
Composite
limited at all times as follows
:
Outfall(s) : C02
- Rad Waste Treatment System Effluent
This discharge consists of :
Approximate Flow
1
.
Equipment Drains in the Drywall, Reactor
0.001 MGD
Building, Rad waste and Turbine Building
2
.
Unit 2/3 Decontamination System Drains
Intermittent
3
Floor Drains
0.001 MGD
4 .
_aboratory and Sample Drains
intermittent
5 .
Unit 1 Heating Boiler Slowdown
Intermittent
6 .
Unit 2/3 Auxiliary Boiler Blowdown
Intermittent
7 .
Laundry Wastewater
Intermittent
8 .
Condenser Polisher Sonic Cleaning Waste
intermittent
Flow (MGD)
Total Suspended Solids
15
30
Daily
1/Week
Continuous
Discharge Tank
Composite
Oil and Grease
15
20
t/Week
Grab
Page 6
'Load Limits were computed based on a Design Average Flow of 0 .031 MGD (Design Maximum Flow of 0 .075 MGD). Load limits
based on Design Maximum Flow (in parenthesis) shall apply only when flow exceeds Design Average
Flow
.
**See Special Condition 17
Outfall(s) : 004-Cooling Pond Discharge'
Flow (MGD)
Temperature
Total Residual Chlorine/
Total Residual Oxidant**
'See Special Condition 10
.
"See Special Condition 13 .
Outfall(s): 005 South East Area Runoff*
006 North East Area Runoff**
-See Special Condition 18
.
"See Special Conditions 11 and 18 .
NPDES Permit No. IL0002224
Effluent Limitations and Monitorinq
LOAD LIMITS lbs/day
CONCENTRATION
OAF (DMF) LIMITS mq/l
30 DAY
DAILY
30 DAY
DAILY
SAMPLE
SAMPLE
PARAMETER
AVERAGE
MAXIMUM
AVERAGE
MAXIMUM
FREQUENCY
TYPE
1 . From the effective date of this permit until the expiration date, the effluent of the following
discharge(s) shall be monitored and
limited at alt times as follows
:
Outfall(s): 003 - Sewage Treatment Plant
Daily When
Discharging
Estimate
Once Per
0 .2/0.05"
Discharge Event
Grab
Approximate Flow : 0.03 MGD
Flow (MGD)
See Special Condition 1
Daily
Continuous
pH
See Special Condition 2
1/Week
Grab
BOD E
30
60
1/Week
24-Hour
Composite
7 .76 (18 .77)'
15.51 (37.53)`
Total Suspended Solids
7.76 (18 .77)'
15 .51 (37.53)'
30
60
1/Week
24-Hour
Composite
Fecal Coliform**
400/100 mL
1/Week
Grab
Total Residual Chlorine**
0.75
'/leek
Grab
Page 7
NPDES Permit No . IL0002224
Special Conditions
SS jCIAL CONDITION 1
. Flow shall be reported as a monthly average and a daily maximum on the DMR form,
SPECIAL CONDITION 2
.
The pH shall be in the range 6 .0 to 9.0. The monthly minimum and monthly maximum values shall be reported
on the DMR form
.
SPECIAL CONDITION 3
.
Samples taken in compliance with the effluent monitoring requirements shall be taken at a point representative
of the discharge, but prior to entry into the receiving stream
.
SPECIAL CONDITION 4,
Discharge of wastewater from this facility must not alone or in combination with other sources cause the receiving
stream to violate the following thermal limitations at the edge of the mixing zone which is defined by Section 302
.211 . Illinois Administration
Code, Title 35, Chapter 1, Subtitle C, as amended
:
A. Maximum temperature rise above natural temperature must not exceed 5°F (2 .8°C)
.
B. Water temperature at representative locations in the main river shall not exceed the maximum limits in the following table during more
than one (1) percent of the hours in the 12-month period ending with any month . Moreover, at no time shall the water temperature at
such locations exceed the maximum limits in the following table by more than 3°F (1
.7°C). (Main river temperatures are temperatures
of those portions of the river essentially similar to and following the same thermal regime as the temperatures of the main flow of the
river .)
Jan
.
Feb.
Mar.
April
May
June
July
Auo
.
Sept .
Oct .
Nov
.
Dec.
'F
60
60
60
90
90
90
90
90
90
90
90
60
1C
16
16
16
32
32
32
32
32
32
32
32
16
C. The permittee may discharge cooling pond blowdown using an indirect open cycle cooling mode from June 15 through September
30 in accordance with the following limitaticn in lieu of 35 III . Adm. Code 302.211(d) and 302.211(e) as written above in Special
Condition 4A and 4B respectively : During the period June 15 through September 30, the temperature of the plant discharges shall
not exceed 32.2°C (90°F) more than 10% of the time in the period and never will exceed 33 .9 °C (93°F)
.
D .
The Dresden Station shall be operated closed cycle during the period October 1 to June 15 . The station may be operated in
accordance with the Unit 2/3 Variable Blowdown Plan (governed by the original July 6 . 1977 Thermal Compliance Plan calculations)
from June 1 to June 15, as deemed necessary by station management
.
E .
Compliance with the thermal limitations shall be determined by maintaining a continuous temperature and flow record for cooling pono
blowdown to the Illinois River. If the variable blowdown plan will be used from June 1 to June 15, data acquisition and records for the
parameters necessary to implement the plan shall be maintained
.
F .
Additional water temperature monitoring shall be continued as follows
:
1
.
A continuous water temperature record of water temperature at the Dresden Island Lock and Dam . and the Dresden Station intake
shall be maintained during the period of June 15 through September 30 .
2
Water temperature recorded at these locations shall be tabulated and submitted to this Agency, Industrial Unit, Division of Water
Pollution Control by December 31, each year
.
,
3
.
Per
ee s failure to submit the temperature monitoring data from these locations due to equipment malfunction shall not be
deemed a permit violation provided the permittee employs reasonable efforts to repair the malfunction . If the malfunction lasts
more than 24 hours; a manual measurement shall be made at least once per day
.
G
.
The station may bypass the cooling pond, that is operate open cycle, only during periods when both generating units have been taken
out of service .
SPECIAL CONDITION 5
. There shall be no discharge of polychlorinated biphenyl compounds
.
SPECIAL CONDITION 6
. The "Upset" defense provisions listed under 40 CFR 122 .41(N) are hereby incorporated by reference .
Page 8
NPDES Permit No. IL0002224
Special Conditions
SPECIAL CONDITION 7
. Commonwealth Edison Company has complied with 35 III . Adm . Code 302.211 (f) and Section 316(a) of the Clean
Water Act in demonstrating that the thermal discharge from its Dresden Nuclear Power Station has not caused and cannot be reasonably
expected to cause significant ecological damage to receiving waters as approved by the Illinois Pollution Control Board in PCB Order 73-
359 dated January 17, 1974 and PCB Order 79-134 dated July 9, 1981 . Pursuant to 35 III. Adm. Code 302.211(g), no additional monitoring
or modification is now being required for reissuance of this NPDES Permit
.
SPECIAL CONDITION 8
. Pursuant to Section 316(b) of the Clean Water Act, a determination for the Dresden Nuclear Power Station has
not been made . Data submitted by Commonwealth Edison Company pursuant to Section 316(b) of the CWA for the Dresden Nuclear
Power Station has been reviewed by the Illinois Environmental Protection Agency and the review determination is : That where as additional
intake monitoring is not being required at this time, further monitoring is not precluded if determined necessary at the time of any
modification or reissuance of NPDES Permit No. 1L0002224 .
SPECIAL CONDITION 9
. The permittee shall record monitoring results on Discharge Monitoring Report forms using one such form for
each discharge each month. The completed Discharge Monitoring Report form shall be submitted monthly to IEPAA no later than the 15th
of the following month, unless otherwise specified by the Agency, to the following address :
Illinois Environmental Protection Agency
Bureau of Water
Compliance Assurance Section
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
SPECIAL CONDITION 10
. The permittee shall minimize make-up water requirements to the cooling pond system during cooling pond water
diversion to the Kankakee River in order to minimize fish impingement losses . This should be accomplished by eliminating to the extent
feasible normal closed cycle blowdown flows of 50,000 gpm to the Illinois River except during a discharge from the rad waste treatment
system and/or other water conservation measures . Such measures and operations taken by the station to minimize make-up water
requirements during diversion shall be documented and reported with monthly discharge monitoring reports
.
a,
Operating requirements
1
.
The siphon will be operated for only two runs during the winter, each run lasting no more than 14 days
.
2 .
Thermal monitoring at established transects and narrative observations will be recorded during operations in accordance with the
siphon Operations Plan dated November, 1993 and a report of findings made available to this Agency in late spring
.
3
.
The maximum amount of heat that will be placed in the Kankakee River shall be -0 .5 billion BTUs per hour .
4 .
A fish barrier net must be in place around the siphon inlet before the s!ohon is operated . and must remain intact throughout the
run .
SPECIAL CONDITION 11
. The North East Area Runoff discharges to the Unit 1 intake canal. When the Unit 1 service water system is
in use, the discharge will be drawn into the intake and eventually discharged a! outfall 001 . During those times when the Unit 1 service
water system is out of service, this discharge will remain in the intake canal and eventually flow into the Kankakee River
.
SPECIAL CONDITION 12 .
This permit may be modified to include appropriate final limitations, requirements, or conditions, which are
consistent with applicable laws, regulations, or judicial orders . The Agency will public notice the permit modification
.
SPECIAL CONDITION 13. The cooling pond blowdown shall be monitored twice per month for Total Residual Chlorine or Total Residual
Oxidant concentration by grab sample, recording the date and time of sampling, the times and duration of the daily chlorine or bromine
dosing periods plus the amount of each chemical applied per day. For purposes of reporting and determining compliance, the highest
single instantaneous TRC/TRO concentration measured on any day will be regarded as the daily maximum concentration . and the monthly
average shall be the average of all daily discharges
.
Total Residual Chlorine may not be discharged from each unit's main cooling condensers for more than two hours in any one day, and is
subject to a limit of 0.2 mg/L .
The use of bromine based biocides for micro invertebrate control, and regardless of duration, is subject to the discharge limit of 0 .05 mg/L
TRO (Total Residual Oxidant) measured as an instantaneous maximum
.
Page 9
NPDES Permit No. IL0002224
Special Conditions
SPECIAL CONDITION 14
.
The Agency has determined that the effluent limitations in this permit constitute BAT/BCT for storm water which
is treated in the existing treatment facilities for purposes of this permit reissuance, and no pollution prevention plan will be required for such
storm water. In addition to the chemical specific monitoring required elsewhere in this permit . the permittee shall conduct an annual
inspection of the facility site to identify areas contributing to a storm water discharge associated with industrial ac vity, and determine
whether any facility modifications have occurred which result in previously-treated storm water discharges no longer receiving treatment
.
If any such discharges are identified the permittee shall request a modification of this permit within 30 days after the inspection
. Records
of the annual inspection shall be retained by the permittee for the term of this permit and be made available to the Agency on request
.
SPECIAL CONDITION 15 .
The responsibility for outfall 004
- Cooling Pond Discharge will be transferred to the Will County Emergency
Management Agency upon issuance of a separate NPDES permit for operation of the Dresden Station siphon Ice Melt system . Upon
issuance of a permit to Will County EMA, Commonwealth Edison shall submit a request to terminate the monitoring and reporting
requirements associated with outfall 004, in writing to the Agency
.
SPECIAL CONDITION 16
. There shall be no discharge of complexed metal bearing wastestreams and associated rinses from chemical
metal cleaning unless this permit has been modified to include the new discharge
.
SPECIAL CONDITION 17
. (Outfall 003) The daily maximum fecal coliform count shall not exceed 400 per 100 mL . Fecal Coliform limits
for Curtail 003 are effective May through October . Sampling of Fecal Coliform concentrations are only required during this time period
.
The Total Residual Chlorine limit of 0 .75 mg/L is applicable at ail times. If the permittee is chlorinating for any purpose during the months
of November through April, sampling is required on a daily grab basis. Sampling frequency for the months of May through October shall
oe as indicated on page 6 of this permit .
SPECIAL CONDITION 18 .
STORM WATER POLLUTION PREVENTION PLAN (SWPPP)
A .
A storm water pollution prevention plan shall be developed by the permittee for the storm water associated with industrial activity at
this facility. The plan shall identify potential sources of pollution which may be expected to affect the auaiity of storm water discharges
associated with the industrial activity at the facility . In addition, the plan shall describe and ensure the implementation of practices
which are to be used to reduce the pollutants in storm water discharges associated with industrial activity at the facility and to assure
compliance with the terms and conditions of this permit .
B
.
The plan shall be completed within 180 days of the effective date of this permit. Plans shall provide for compliance with the terms of
the plan within 365 days of the effective date of this permit. The owner or operator of the facility shall make a copy of the plan available
to the Agency at any reasonable time upon request. [Note: If the plan has already been developed and implemented it shall be
maintained in accordance with all requirements of this special condition .]
C .
The permittee may be notified by the Agency at any time that the plan does not meet the requirements or this condition. After such
notification, the permittee shall make changes to the plan and shall submit a written certification that the requested changes have been
made. Unless otherwise provided, the permittee shall have 30 days after such notification to make the changes
.
0 .
The discharger shall amend the plan whenever there is a change in construction, operation, or maintenance wnich may affect the
discharge of significant quantities of pollutants to the waters of the State or if a facility inspection required by paragraph G of this
condition indicates that an amendment is needed . The plan should also be amended if the discharger is in violation of any conditions
of this permit, or has not achieved the general objective of controlling pollutants in storm water discharges . Amendments to the plan
shall be made within the shortest reasonable period of time, and shall be provided to the Agency for review ucon request
.
_ .
The plan shall provide a description of potential sources which may be expected to add significant ouantities of pollutants to storm
water discharges, or which may result in non-storm water discharges from storm water outfalls at the facility
. The plan shall include,
at a minimum, the following items
:
A topographic map extending one-quarter mile beyond the property boundaries of the facility, showing : the facility, surface water
bodies, wells (including injection wells), seepage pits, infiltration ponds, and the discharge points where the facility's storm water
discharges to a municipal storm drain system or other water body . The requirements of this paragraph may be included on the
site map if appropriate .
-age
1 0
NPDES Permit No. IL0002224
Special Conditions
2
.
A site map showing :
The storm water conveyance and discharge structures
;
An outline of the storm water drainage areas for each storm water discharge point
:
Paved areas and buildings
:
Areas used for outdoor manufacturing, storage, or disposal of significant materials, including activities that generate
significant quantities of dust or particulates
.
Location of existing storm water structural control measures (dikes, coverings, detention facilities, etc .)
:
Surface water locations and/or municipal storm drain locations
vii .
Areas of existing and potential soil erosion
:
viii
.
Vehicle service areas
:
Material loading, unloading, and access areas
.
3
.
A narrative description of the following
:
The nature of the industrial activities conducted at the site. including a description of significant materials that are treated,
stored or disposed of in a manner to allow exposure to storm water
;
Materials, equipment, and vehicle management practices employed to minimize contact of significant materials with storm water
discharges :
iii .
Existing structural and non-structural control measures to reduce pollutants in storm water discharges
:
iv .
Industrial storm water discharge treatment facilities
:
Methods of onsite storage and disposal of significant materials
:
4
.
A list of the types of pollutants that have a reasonable potential to be present in storm water discharges in significant quantities
.
5
.
An estimate of the size of the facility in acres or square feet . and the percent of the facility that has impervious areas such as
pavement or buildings
.
6
.
A summary of existing sampling data describing pollutants in storm water discharges
.
F . The plan shall describe the storm water management controls which will be implemented by the facility . The appropriate controls shall
reflect identified existing and potential sources of pollutants at the facility . The description of the storm water management controls
shall include
:
1
.
Storm Water Pollution Prevention Personnel
- Identification by job titles of the individuals who are responsible for developing,
implementing, and revising the plan .
2 .
Preventive Maintenance
- Procedures for inspection and maintenance of storm water conveyance system devices such as
oillwater separators, catch basins, etc . . and inspection and testing of plant equipment and systems that could fail and result in
discharges of pollutants to storm water.
3-
Good Housekeeping - Good housekeeping requires the maintenance of clean, orderly facility areas that discharge storm water
.
Material handling areas shall be inspected and cleaned to reduce the potential for pollutants to enter the storm water conveyance
system .
4
.
Spill Prevention and Response
- Identification of areas where significant materials can spill into or otherwise enter the storm water
conveyance systems and their accompanying drainage points. Specific material handling procedures, storage requirements, spill
clean up equipment and procedures should be identified, as appropriate. Internal notification procedures for spills of significant
materials should be established .
Page
1
1
NPDES Permit No . IL0002224
Special Conditions
5 .
Storm Water Management Practices - Storm water management practices are practices other than those which control the source
of pollutants. They include measures such as installing oil and grit separators, diverting storm water into retention basins, etc
.
Based on assessment of the potential of various sources to contribute pollutants, measures to remove coilutants from storm water
discharge shall be implemented. In developing the plan, the following management practices snail be considered
:
Containment - Storage within berms or other secondary containment devices to prevent leaks and spills from entering storm
water runoff;
Oil & Grease Separation
- Oil/water separators, booms, skimmers or other methods to minimize oil contaminated storm
water discharges
;
Debris & Sediment Control
- Screens, booms, sediment ponds or other methods to reduce debris and sediment in storm
water discharges
;
IV,
Waste Chemical Disposal
- Waste chemicals such as antifreeze, degreasers and used oils shall be recycled or disposed
of in an approved manner and in a way which prevents them from entering storm water discharges
.
v .
Storm Water Diversion
- Storm water diversion away from materials manufacturing . storage and other areas of potential
storm water contamination
:
vi .
Covered Storage or Manufacturing Areas - Covered fueling operations, materials manufacturing and storage areas to
prevent contact with storm water
.
6 .
Sediment and Erosion Prevention - The plan shall identify areas which due to topography, activities . or ether factors, have a high
potential for significant soil erosion and describe measures to limit erosion
.
i. Employee Training - Employee training programs shall inform personnel at all levels of responsibility of the components and goals
of the storm water pollution control plan . Training should address topics such as spill responsee good hcusekeeping and material
management practices. The plan shall identify periodic dates for such training
.
Inspection Procedures - Qualified plant personnel shall be identified to inspect designated equipment and plant areas . A tracking
or follow-up procedure shall be used to ensure appropriate response has been taken in response to an inspection
. Inspections
and maintenance activities shall be documented and recorded
.
The permittee shall conduct an annual facility inspection to verify that all elements of the plan . inctudine the site map, potential pollutant
sources . and structural and non-structural controls to reduce pollutants in industrial storm water discnarges are accurate . Observations
that require a response and the appropriate response to the observation shall be retained as part of the cian . Records documenting
significant observations made during the site inspection shall be submitted to the Agency in accorcance with the reporting
requirements of this permit .
H .
This plan should briefly describe the appropriate elements of other program requirements, including Soul Prevention Control and
Countermeasures (SPCC) plans required under Section 311 of the CWA and the regulations promulgated thereunder, and Best
Management Programs under 40 CFR 125 .100 .
The plan is considered a report that shall be available to the public under Section 308(b) of the CWA . The permittee may claim
portions of the plan as confidential business information, including any portion describing facility security measures
.
The plan shall include the signature and title of the person responsible for .preparation of the plan ano mctude the date of initial
preparation and each amendment thereto
.
Construction Authorization
K .
Authonzation is hereby granted to construct treatment works and related equipment that may be required by the Storm Water Pollution
Prevention developed pursuant to this permit.
This Authorization is issued subject to the following condition(s) .
1
.
If any statement or representation is found to be incorrect, this authorization may be revoked and the permittee there upon waives all
rights thereunder.
Page
1 2
NPDES Permit No . IL0002224
Special Conditions
2 .
The issuance of this authorization (a) does not release the permittee from any liability for damage to persons or property caused by
or resulting from the installation, maintenance or operation of the proposed facilities; (b) does not take into consideration the structural
stability of any units or part of this project : and (c) does not release the permittee from compliance with other applicable statutes of
the State of Illinois, or other applicable local law . regulations or ordinances .
3
.
Plans and specifications of all treatment equipment being included as part of the stormwater management practice shall be included
in the SWPPP
.
4
.
Construction activities which result from treatment equipment installation, including cleaning, grading and excavation activities which
result in the disturbance of five acres or more of land area, are not covered by this authorization . The permittee shall contact the IEPA
regarding the required permit(s)
.
REPORTING
L
.
The facility shall submit an annual inspection report to the Illinois Environmental Protection Agency . The report shall include results
of the annual facility inspection which is required by Part G of the Storm Water Pollution Prevention Plan of this permit . The report
shall also include documentation of any event (spill, treatment unit malfunction . etc.) Which would require an inspection, results of the
inspection, and any subsequent corrective mantenance activity . The report shall be completed and signed by the authorized facility
employee(s) who conducted the inspection(s)
.
M
.
The first report shall contain information gathered during the one year time period beginning with the effective date of coverage under
this permit and shall be submitted no later than 60 days after this one year period has expired . Each subsequent report shall contain
the previous years information and shall be submitted no later than one year after the previous years report was due
.
N
.
Annual inspection reports shall be mailed to the following address :
Illinois Environmental Protection Agency
Bureau of Water
Compliance Assurance Section
Annual Inspection Report
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
O
.
If the facility performs inspections more frequently than required by this permit, the results shall be included as additional information
in the annual report .
age 13
.
.. .acnm+n.n
Standard Conditions
Definitions
Act means me Illinois Environmental Protection Act, 415 ILCS 5 as Amended
.
Agency means Me Illinois Environmental Protection Agency.
Board means the Illinois Pollution Control Board.
Clean Water Act (formerly referred to as lone Federal
Water
Pollution Control Act) means
Pub. L 92-500, as amended. 33 U.S.C. 1251 et seg.
NPDES (National Pollutant Discharge Elirwat n System) means the national program for
issuing, modifying, revoking and rsssng, term. leg, monaasg and enforcing permits, and
imposing and enforcing permart rent requirements, under Sections 307, 402, 315 and 405
of me Clean Water Act
USEPA means Me United States Environmental Protect/on Agency
.
Daily Discharge means she diWarge
c
a po&tant measured during a calendar bay or any
74-hour period that reasonably represents the calendar day for purposes of sampling. For
pollutants with limitations expressed
n
units of mass, the 'daily discharge' Is calculated as
the total mass of the pollutant discharged over me day . Far pollutants with Ilmnations
expressed n other units d measurements, the 'daily discharge' is calculated as Me average
measurement of me pollutant over me day .
Maximum Dolly Discharge Llmltstion (daily minimum) means me highest allowable daily
discharge .
Average Monthly Discharge Limitation (30 day average) means the highest allowable,
average of daily discharges over a calendar month, calculated as Me sum of all daily
discharges measured during a calendar month drvated
by the
number of
daily
discharges
measured during that month.
Average Weekly Discharge Limitation (7 day average) means the higher allowable
average of daily discharges over a calendar week
. calculated as the sum of all daily
discharges measured during a calendar week divided by Me number of daily dsaurges
measured during that week
Best Management Practices (BMPs) means schedules of acuinties, pronibitiwss
a
practices,
maintenance procedures, and Other
managrmrit
Ml- to prevent or reduce the pollution
of waters of Me Slate, BMPs also horde treatment reouvennms, operating procedures, and
practices to control plant see runoff, spillage w leaks, sludge w waste disposal, or drainage
from raw Material storage.
Aliquot means a sample of specified volume used to make up a total composite sample.
Grab Sample means en Individual sample of at lean 100 mlllilfters collected ate randomly-
selected lime over a period not exceeding 15 minutes.
24 Hour Composite Sample means a combination of at lean 8 sample aliquots of n least
100 milliliters. collected at parodic intervals during rte operating hours of a facility over a 24-
hour Penod.
8 Hour Composite Sample means a canbnabm of n lean 3 Sample aliquots of
at least 100
rvlldners. collected at periodic intervals during the operating hours of a facility over an B-hour
period
.
Flow Prooortonal Composite Sample means a combination of sample aliquots of at least
100 milliliters collected at periodic intervals such Mat either me time Inlervat between each
"uouot or the volume of each aliquot Is propomonal to either the stream flow at me time of
sampling or the total stream flow
, since me collection of Me previous aliquot,
(1) Duty to comply. The penmnee must comply with all conditions of this Owning . Any
permit noncompliance constitutes a violations of the Act and is grounds for enforcement
action, permit termination, revocation and reusuance. modification, or for denial of a
permit renewal application. The pennon, shall comply with effluent standards or
prohibitions established under Section 307(a) of Me Clean Water Act for toxic
pollutants within Me time provided
n
the regulations that establish these standards or
prohibitions, even it Me permit has not yet been modified to incorporate the
requirement
.
(2) Duty to reapply. If the pernattee wishes to ,thnue an actrwity regulated by this permit
war
the expiration date of this permit, me pennmee must
apply for
and totem a new
perms If me pennlttee submits a proper appnaldn as required by the Agency no later
Iran 180 days prior to Me expiration date, this permit shall continue
m
full force and
effect until the final Agency decision on me application has been made .
(2) Need to halt or reduce activIty not a defense. It shall not be a defense for a
permmee
n
an enforcement action Mat
it wad have been necessary to half or reduce
me permitted actwey
n
order d manan osnpwnce with the conditions of this parmtt .
(4)
Duty to mitigate. The pemiatee shall take alrreasmable reps to minimize or prevent
any discharge n violation of this penmt Wtm has a reasonable likelihood of adversely
affecting human health
Or
Me environment
(5) Properopenllon and maintenance . The permmee shag
n
all times properly operate
and maintain all facilities and systems
n
treatment and control (and related
appurtenances) which are Installed or used by Me pernmee to achieve compliance
with conditions of this permit . Proper operation and maintenance Includes effective
Performance, adequate funding. adequate Operator sating and training, and adequate
labdntory and
process
controls, including appropriate Quality assurance procedures .
This provision requires me operation of backupi
or
auxiliary facilities. or sanaar
systems only wnm necessary to achieve mnpiunce with the conditions of Me permit
.
(B)
(9)
"'it aoopns .
,nis permit .Tay ere mwlned, revoked and reissues . or
{err
!or cause by me Agency pursuant to 40 CFR 122 .62. The filing of a ecues
parent" Is' a permit medication, revocation and recsusnte, or temaauc
notification of planned changes or anticipated noncompliance, does not n
persnd conodion,
7)
Property rights. This permit does not convey any property rights of any sort .
exclusive privilege .
Duty to provide Information. The pennmee shall furnish to the Agency v
reasonable drive. any rifonnaban which the Agency may request to det
ermine w
cause exists for modifying, revoking and reissuing, or teminating this pens,
detrma,e o:anplianoe war one Posting. The perrrsttee shag also hsrush to the A
upon request, copies
a
records
required to be kept by this permit,
Inspection and
entry .
The permittee shall allow an
authorized
represe
. .utrve
Agency, upon the presentation of osadenuals and omar doaasgnts as may be n
by
aw,
to :
(a) Enter upon me permlttee's premises where a regulated
facility or act
b®ted or conducted, w svthere records must be kept under Me conditions
permit ;
(b) Have access to and opy, n reasonable tines any records Vat must t
under the conditions of this permit
(c) Inspect at reasonable times any faciliies, equipment (Including Mongol.,
control equipment), practices, or operations regulated or required and
pennlC and
(d) Sample or monitor
at reasonable Ilmes, for me purpose
of assuring
compliance. Or as omrwise authorized by Me Ad, any substances w carat
at any khnuon .
(10)
Monitoring and records .
(a) Samples and measurements taken for the purpose of monitoring sit
representative of me monitored activity
.
(b) The permmee shag retain records of all monitoring Information, nciuo
calibration and nantenano records, and ad original imp than re^_rdr
continuous monitoring instrumentation . copies of all reports many C
prmit, and records of all data used to complete Me application for Ma pen
a period of at lean 3 years from Me date of this permit. measurement, re :
application. This pence may be
extended
by request of the Agency a:
an,
(c) Records of monitoring information shall include :
(1) The date, exact place, and time of sampling or measurements:
(2) The individual(s) who performed Me sampling or measurements
:
(3) The date(s) analyses were performed
;
(4) The individual(s) who performed the analyses ;
(5) The analytical techniques or methods used; and
(6) The results of such analyses .
(d) Monitoring mum be conducted according to test procedures approved unc
CFR Par 136, unless other test procedures have been speed in this p
'Where no lest procedure under 40 CFR Part 136 has been ace ;rove :
permmee must submit to me Agency a test
method
for approval.
T.`.e den
snail calibrate and oertorm maintenance procedures on all monrcnne
analytical Instrumentation at Intervals to ensure accuracy of measuremen'
(11)
Signatory requirement All applications, reports or information Subm^,ed
Agency Shall be signed and certified
.
(a) Application . All permit applications shall be signed as follows
:
(1) For a corporation: by a principal executive officer
of
at leas: t.e le
vice president or a person or position having overall resporslollr
environmental matters for the corporation
;
(2) For a partnership or sole proprietorship : by a general partner <
proprietor, respectively: or
(3) For a municipality, State, Federal, or other public agency: by en
principal executive center or ranking elected official
.
(b) Reports. All reports required by permits, or other Information requested t
Agency shall be signed by a person deathbed
n
paragraph (a) w ey a
authorized representative of mat person. A parson Is a duly authc
represenutfve only a :
(1) The aumanzation d made in writing by a person described
n
paragrap
and
(2) The authorization soeci6es either an individual ore position respell
the overall operation of Me tacitly. from Much, the discharge orginatess
as a plant manager, superintendent or person of equivalent responn
and
(3) The written authorization is submitted to the Agency
.
Z)
Changes of AuL^,ennuen
.
if an a0.
•
.
c _sunn under
Iol
is no longer azJ
because a
:r:'enent :norvidual a adscah has esoahs,u,
;., for !no -.-a
77eratlon of the facility_ a new au,ncr-ton satisfying the re: too o -,
-east be cur nanac to me
>CMOI
av-~ 7 :pg~thrw.r any re>n .^,i .
aoolicnons td be sync air ar. ad_ c-__o ;errec^_n:J;ive .
'.eport'n ; redulrements
.
;a) Planned changes. The pernmee snot ;Ive notice to the Agency a
s
Sinn- as
possible of any planrec physical aeentucns Or aodnions to the perrnted !27:
.n,.
(b) Anuo!patad noncompllanu . -,he ,e flee shall give advance notice
.o
.
.
gene/ of any planned changes o Ce pernlteed tacitly or atrvay whir ray
resist
m
noncompliance with pemN, nomoe^le .^.3 .
(C) Camollanr. sehedulea. Resorts
of
reliance a noncomptance w t^,, oc any
progress moor's m, nlenm and fatal re :u.nments con:alnec ^. any corm:ante
acnedaro of mix permit snail be outdo
:S:
no oar than la can ICpcw,c ; ea_,
schedule date.
Monitoring npcrrs, lAcnnonng resins shall be reoonec r, the nee-
.acs
specified ei.sewnem n this perms.
(t) Monitoring results must be revered on a Discharge Monmon, ; Report
(-
.MR) .
(2) K the pertnS ee rrnnitors any pollutant more frequently man required by the
permit, using test proadures act red under 40 CFIP 1A or as specked
in the prat the resues of eas rrortsarg wax be neudec n the caicr aeon
and resonating of me data tuomftec A the
CMR
( 22)
CalculaC7ns for all limitations w^ .:c, require averaging o. measure-t,
sraa utlce en arhme
do
mean un:ess 7therwtse spec-fed by rte Agency
l: n
the permit.
Twenty-four hour reporting . Te Vermr
..ee snail report any noncomol :ance
Amen may endanger hea= or the environment. Any
intonation
sit
to
:.=irked crafty with. 24 hours front „e ore, ore per- met oe'_-les aware a„
-- e
~msldnC,e. A wren suornisslon snail also be omvided w-
..^,in 5 says
: _c
tore me permmee oe roes aware :
'.C
c.'msances. The'wTen sunnnnsssn
snail Contain a Cas.Tptibn of the ncn nnotanse and do causei the petty:: o,
nmcvnplunm, n=dng exact dates and came; and I the nonrro:lance has -.01
been correctedt the antlcoaled tine L ; exbecec to bor-irus no
I,-,
to,
orowned to reduct elmratee and pc.c:m-ones :e of _re naibnb',a
The lclkkeng snail be included as r!:mr than wnict must be m :.;nec w
hours .
(
:1
Any unasc.-aed bypass wnc. ez
: icy e!^uent Iim,-Oatc.r
or ^.c Oar n
(2) Violation a' a maxincurn dairy tSCa;e I',^,natlcn for a-
•'
of
the bba_:a-:s
holed by lore Agency
in tie pe.-..: tb ce repcnec wrtnin
:
•
- .
.::6
One Agency may waive Lhe written recd, on a case-oy-tae pass
e
the ^_ si
-_con has been receives wrnin 2'- tic_; .
,'I
Ochar noddpmottance. Te be--tree srta:l reoa a: '.-stances
: I
r_r_smmmnce rot moaned under caag-sons (d) . 0-is), at tit_ _„_
m&nnor^,g mans are wcinme^ . Tire rep^_.^s malt or,, :am tne':nformat'An
LSet:
n aaragraon (12),e) .
g,
Z
tner Information. When the penmntee 7ebmes aware that' tadec to s
.,
am retevant fats
I7
a penne epolicalcn . on Supmted nC_V-et mist^,aeon
r,C aItil,bllcn Or on any repcn e roe A
ir^ocy, c small p b
u :, .,,n s ic-n
aacs or Information
.
Transfer of permits. A perms may be an:nabcalty Canstereo to a new oenr-ee
al
he current pe.^,nee notified the Aggsmy at tees 30 days n advance of :^,e
=posed transte .' date :
(b) The notice Induces a whoon agreement between the Slidin g a rd new perrrthees
containing a specific date for transfer of permit responsioiiry . Coverage and
1aoiiny between rte current and new bee=nint s'. and
!:)
The Agency does not notify !Me a Y,mg pemtctee and L^e proposed n
e
w
bermmee of Its sment io modify or revoke anal reissue the pe".d If Iris notice is
not received, the transfer
Ia
effeCNe on the date specified in line agreement .
r.;. .'nanufaounng, commercial . mining, and siwicunuml d ;schargers must notify tote
Agency as soon as they know or nave reason to betlevC
(a) That any aefvlty has occurred or willo~wnidr would result In the discharge of
any toxic pollutant Identified under SeCon 307 of the Clean Water Act wntc, is
not limned vn the oenna, K that discharge will exceed the highest of the tollo'wng
notification levels :
(I) One hundred micrograms per Inc. (100 ug .9) :
(2) Two hundred mieograms per Inc. (200 ug
•i
)
for acolen and acylonltrpel
five hundred micrograms per liter 1500 uge) for 2,a-dInitroonenol and for 2-
methy-4
6
dmNppnenoll end one n :ltigram per titer (1 mg!) for antimony
.
(2) Five (5) times the maavnum cpncensalnn value reported for mat pollutant
in the NPCES permit a000Ubon'n or
(A) The level estaohsned by the Agency in this Serino
(25)
S: °'/ ;IJ7P ceoun IX 110nO :a be inn
:C use 9r manufacture as
:: heal oroduod Or Cvcro0'00 a,
to ccllc'anl *nice was tict r,=cr,a'-~
.'tp005 oc'n: .^, 0z; =tan .
- :-h 0,,o T.eut-lent're:ns ='' h
•
m
u
s
t
•r
ace nos'_ate
b_l ._
v
- ;afty of One !oll0'.vm;
'al Any new Inlrvcuolon of p :l:_cams into that POT'SW from an I,ndirec disco'
I.=
would be suolet m Serums 301 or 335 of the Clean Water Ac
.1 n w
d:reCly cisorar ;In^y .hone pollcams's and
(b) Any sub. ant Canoe n one mime or c,arater of pollutants being In . odu
.
Imo that POT'N by a Sour-- pollutants Into he PCTW a
: the issuance, of ins ise llt-
(c) For purposes of this pareg :acn, adequate notice shall InCUde Information c-
the quality and
cuant'ty
of effluent ltoauced Into the POTW. and
Iii; c
an:IeoatCO m, s o
this = a,,;, on the quantify or -.air, Of ii
discharged from rte POPW .
is hereby inx,:craled by reference as a condmod 01 tilt permit .
(19) Tne pernntae stall not make any false Statement. representation IX cenYyton
:^. a
abolioation, rebmm report, plan or other document Submitted to the Agere: ar
S
A, or requires! tp be main :a:nee unber this permit
.
-e ;aeon Water A 1rovioes nat any person who violates a permt sons-
maletne.nlung Sec;os 201 . 2_
•
.
305. 307, 3C8. 318, Cr 4C5 of the Clean '"later
-
Is sublet to a cvii oe^.a .^.y no: to exxeo 510.000 per day of such vlola :Icn
-
:rson, wrl0 wiii'ully or negfgenlm violates oernie conditions Imolementmg Sets
201 . 202, 2:A. 307,
by
303 o: one Cean Water AV.. is subiec to a fire of not less I-
no more Iran 525 CC, per day of violation . or Oy imprisonment for not m
.
than one year, or
Doo,,-
21) '-.e Clean Water Act provides :-,at rucy person who falsifies. tampers with
.._
giy r boars - ._ ate aov ra, .,crlng oe
•n
ce 0, method re:ucee t-
under per.: snail uaon = .^victim. be ounisnec by a fine of .-: r'^
SIC 3(p per vialmim, or
coy
vm,cnscnment for not more Can 6 months per ec:a::cr
by xth
.
_ .e C'tean Water AC
:,
..noes
that any person who knowingly makes
any 'a
Statement, reoresenta:ICnT
noes
or :2 .^.f.I7daon
in
any record or other C00cn.en: Sub.m ..'
_r -ecuirec :o be maintained under this permit snail, including mcnncnng reconc
mode's of mrmoodnce c -rca,..~^.71x:2 snaa. uocnc
onviClon . be pu'nis.hed ov a'
o, not more than SoC ocr vicacn. or by vnprlsonment for not .more than 6 mo-.'
per violation, or by bate
.
(23) Collected st_Sening, slum as . siud;et. and ather solids shall be d :sacse^_ of ins.
a trainer as to prevent em ry of those wastes (or runoff from rte wastes ; Into waio
of the State. Rte Sober autn0.caton for such disposal snail be Obtained fro-'
Agency and is incorpo.mted as pan hereof by reference.
(24) in case of conflict between these standard conditions and any other
:_
Inb:ueeo r, Inns perms, !one Other CcnOoionl5) shah govern
.
(25) The permittee snail ccmoiy wilnl in addition to the requirements of the perm
:
.
.
asphcaole provisions 0135111. ACT. Code, Subtitle C, Subtitle 0. SuoWe 6. arc
aoplicaple orders
at the
Board
.
The previsions of this benro are sevetells , and if any provision of this permit, or
:
acpllclion
o
f any provision of MIS permit
Is held invalid, the remaining provisions
this permit shall continue in lull form and effect
.
;Rev
. :-t3A8)
(16)
f
the
oennf
is
Issues
to
a cubI c/ owned or pubhdy regulated treatment works
(17)
perrti shall require any ndust^al user of such treatment works to comply
.
federal requraments blnreming
:
(s)
;b)
ic)
Usr charges pnuant m Soc:on 204(b) of the Clean Water Ac . and apply
regulations appearng
:n
40
CFR 25 ;
Toxc cclutant of um standams a'ld pretreatment Standards pursuant to Se=
307 of me Clean Water Act and
L^spec
. mmcsrg arc e.nt / pursuant to Section 308 of the Clean Water =
M
an applicable stancart or limfflabbn a promulgated under Session 201
(let
(0), 30a(b)(2), w 307(al(2) and hat effluent standard or limitation is more st
•n
g'
:'an any effluent tn'siaton in the Y_ .^.nit. Or controls a pollutant not Iimrec in
pe.'ms. Ine pe.mi Seal: be yomctiv modlfed or revoked, and reissued to cons=
Par
effluent sahoard or,mitation
.
- .v a0
.hdnoaCOn to Cnstuc sued to the Oermmee pursuant to 35111 . A,.m. __
