ML20140F389

Advises That Validity of Allegation Re Discharge of Raw Sanitary Waste to Clinton Lake Could Not Be Determined.Util Authorized to Discharge Untreated Pipe Flush Waters Into Lake After Hydrostatically Testing Pipe Sys

ML20140F389
Person / Time
Site:	Clinton
Issue date:	03/13/1986
From:	Rogers K ILLINOIS, STATE OF
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8604010033
Download: ML20140F389 (8)

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pmB Illinois Environmental Protection Agency 2200 Churchill Road, Springfield, IL 62706 217/782-9720 FTIIC1ITY RO:f ring Illinois Power Company ,m si " I_f , w Clinton Station +

M NPDES Permit No. IL0036919 [/ I ~'-

Verbal Complaint of Sanitary Discharge

- March 13, 1986

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-v A rutJg Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Comission

. Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

Your letter of February 4,1986, was referred to this office for additional foliow-up. Roger Cruse of my staff spoke once again with Frank Jablonski on February 21, 1986, concerning the allegation that Illinois Power had been discharging raw sanitary waste to the Clinton Lake.

Given the information supplied to us we were not able to determine if the person referring this matter had a valid complaint. We do advise you that Illinois Power has a current variance (copy attached) issued by the Illinois Pollution Control Board to discharge untreated pipe flush waters back to the lake after hydrostatically testing specffic pipe systems on the station.

In the future, if your staff could transfer calls of this nature directly to Ken Baumann, our regional manager, at 217/333-8361, it would help our assessment of the situation.

Sincerely, Kenneth R. Rogers, Manager Compliance Assurance Section Division of Water Pollution Control KRR:RC:sf/441 f,32 cc: Compliance Assurance Section Records Unit-Ken Baumann, FOS - Region 4 e6o wiooaa 86oana-MAR 171986 6 PDR ADOCK 05000461

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s ILLINOES POLLUTION CONTROL BOARD

{y October 12, 1984 ILLINOIS POWER _ COMPANY, )

(CLINTON POWER STATION) , )

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Petitioner, )

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v. ) PCB 84-135

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ILLINOIS ENVIRONMENTAL )

PROTECTION AGENCY, )

)

Respondent. )

OPINION AND ORDER OF THE BOARD (by B. Forcade ) :

On Augu st 29, 1984, the Illinois Power Company ("IPC") filed a request for variance from certain Board regulations that af fect water discharges from their Clinton Power Station to Clinton Lake. IPC requests variance from ef fluent limitations for total suspended solids (TSS) . ?nd total iron (" Iron"), in order to conduct pre-operational flushing of process piping systems at the nuclear-fueled electric generating station prior to loading the station with nuclear fuel . Specifically, IPC requests variance

~gpg from the TSS and iron effluent limitations of 35 Ill. Adm. Code 304.124, and from the requirements of 35 Ill. Adm. Code 309.102 which prohibits the discharge of contaminants except in compliance with the Environmental Protection Act, Board regulations and conditions of an NPDES permit. IPC requests variance until the date when nuclear fuel is loaded at the station or until .

September 1, 19 89, whichever is sooner. At the time of filing this petition, IPC also filed a motion for prompt consideration stating that delays in pre-operational requirements could force delays in fuel loading; each day of delay will cost in excess of one million dollars (Pet., 13).

On October 1, 1984, the Illinois Environmental Protection Agency (" Agency") filed a recommendation that variance be granted, with certain conditions, from 304.124 (TSS and iron) until December 31, 1986, or until nuclear fuel loading whichever is sooner. On October 5, 1984, IPC filed a response to Agency recommendation that accepted all conditions (including the -19 86 date), but pointed out that the Agency had not taken a position on IPC 's request f rom 309.102. IPC believes that procedurally a variance from that Section is also required even though the substance of the request is the TSS and iron limitations of 304.124. IPC's October 5, 1984, filing also renewed the motion for prompt consideration. No objections were received by the Board and no hearing was held. In view of the Board 's disposition of this matter within four days of the last filing, the motion f4 for prompt consideration is moot.

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' IPC is a public utility, headquartered in Decatur, Illinois.

It has a service territory of approximately 15,000 square miles and employs approximItely 4,000 people. IPC provides electric f' service to approximately 530,000 customers and gas service to approximately 382,000 customers.

The station, which presently is under construction, is a nuclear-fueled electrical generating station designed to generate 933 net megawatts of electricity.

It is located near Clinton, Illinois, on Clinton Lake.

effluents are discharged from the station to Clinton LakeVarious pursuant to the conditions of a NPDES permit. The station is scheduled to begin fuel loading in January, 1986, and to begin commercial operation in Novermber, 1986, at which time it will employ approximately 900 people. To meet these scheduled dates for commencement of fuel loading and of commercial operation,

• approximately 6,600 per sonnel currently are employed on site, and three shif ts a day are working on the construction (Pet., 1 1-3).

i One important aspect of the construction being done at the station is the flushing of certain process piping. systems upon their completion in order to test their integrity for operational

'u se .

Several of these flushes have been conducted in the past and were of such nature that the waters used in flushing could be routed through the station's sedimentation ponds for treatment, prior to discharge to waters of the State. These flushes were covered by the terms of a new-expired NPDES Permit No. IL0036919, which was issued on October 21, 1977, by the United States Environmental Protection Agency to IPC. Prior to the expiration of this permit, on July 31, 1980, IPC filed with IEPA an appli- pag cation for renewal, with the consequence, because of the provisions of Section 12(f) of the Environmental Protection Act, Ill. Rev. Stat. 1983, ch. 111Y, 5 1012 (f ), and 40 C.F.R. S 122. 6 (d ) (1983), that the permit was continued in effect and will be taken in effect on the until such permit time as final ad mini str ative action is application. Certain other pre-operational pipe flushes, which have been identified as critical path milestones in the start-up schedule for the station, cannot be handled in the same manner as those prior flushes (Pet., 1 4-6).

To deal with the flushes, IPC requested a provisional variance from the Agency. The Agency recommended to the Board that a provisional variance be granted with conditions and on June 14, 1984, the Board granted the provisional variance in PCB 84-75. One additional purpose of this provisional variance flushing was to acquire data on the quality of effluent discharged into Clinton Lake to determine if Board regulations for TSS and iron would be exceeded . The outside ring header subsystem of the fire protection system was flushed on June 19, 1984, and June 20, 1984. This subsystem consists of a 14-inch primary , ring header, a 12-inch secondary ring header, and numerous smaller lines that service the many buildings at the station. These ring headers were. flushed by pumping untreated water from Clinton Lake through the lines. Grab samples of the flushwater discharges were gathered during both days of this f lu shing . These were manu ally composited , and composite /"'

pollutant concentrations were determined. The

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3 results show that on the first day of flushing, June 19, 1984, the flush waters exceeWed the Board 's ef fluent limitations of 15 f- mg/l for TSS and 2.0 mg/l for total iron. The composite of al l grab samples indicated a level of 140 mg/l of TSS and 32 mg/l of total iron. However, on the second day of flushing, June 20, 1984, the flush waters were well within ef fluent . limitations:

the composite of all grab samples indicated a level of 9.2 mg/l of TSS and 0.98 mg/l of total iron (Pet., 1 10, 11).

Flushing of the Division III subsystem of the safe shu td own service water system began on July 19, 1984, and was to have been continued on -July 20 and July 24-26, 1984. This subsystem consists of piping associated with diesel generator IC and switch

. gear heat removal condensing piping. The flush could not be completed, however, because on July 24, 1984, the pump being used failed, necessitating the suspension of the flush. Flushing of the subsystem re sumed on Augu st 1 and was continued through August 2, 1984. However, flushing could not be completed in accordance with the operational protocol. Data was collected concerning the quality of the flush waters that were discharged on July .19-2 0 and Augu st 1-2, 1984. The data indicated that on Ju ly 19 , 1984, the first day of flushing, the Board 's ef fluent limitations for TSS and iron were exceeded as 45 mg/l of TSS and

5. 2 mg/l of iron were discharged . However, on the remaining three days of the flush, ef fluent limitations were met with one exception: on July 20, 1984, flush waters with concentrations of 24 mg/l TSS and 1.0 mg/l of total iron were discharged; on

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Augu st 1, 1984, flush waters with concentrations of 12 mg/l TSS lPi and 0.66 mg/l of total iron were discharged; and on August 2, 1984, flush waters with concentrations of 13 mg/l TSS and 0.67 mg/l of total iron were discharged. For the flushing operations conducted to date there has been substantial variation in ef fluent quality, making accurate prediction of future flushing

. concentrations impossible.

Despite the flushing which has already occurred, IPC'will need to conduct more flushing to demonstrate the integrity of the piping systems to the Nuclear Regulatory Commission bef ore fuel-loading will be allowed. Since these flushings will occur before fu el-lo ad ing , no question of accidental radiological contamination is bef ore the Board. The addition al subsystems which IPC requests to flush are the following:

The segment of the fire protection system which is contained in the diesel generator building; The segment of the fire protection system which is contained in .the containment and auxiliary control building; The segment of the fire p,rotection system which is contained in the control building; b

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.g same shutdown service water sy stem; Divisions I and IJ of the I'

The station's chilled water sy stem, which is contained throughout the power block; and The component cooling water sy stem, which is contained in the control building.

In each case, the volune of ~ flush water is quite large, typically one-half million to fif ty million gallons. The se volumes are too large to be conveyed through the existing floor drain system to IPC's sedimentation ponds for treatment before discharge. Since many of the flush discharge points are f ar from

- the pond s, thousands of feet of hose would have to be laid, blocking roadways and presenting a danger of rupture. Moreover, the total volume of flows would exceel the treatment capacity of the present system. The cost and delays for creating temporary addtional capacity would be sub stantial (Pet., 1 39-41).

IPC and the Agency anticipate there will be minimal, if any, adverse environmental impact resulting from the proposed flushing operations. First, the flushing water will be withdrawn from Clinton Lake which has historically had a high level of TSS: 13 mg/l to 68 mg/l from 1978 through 19 83. T hu s, the amount of TL; in the effluent from prior testing does not reflect the amount or TSS added to Clinton Lake, although exact calculation of the amount added would be impossible. Also, the TSS added would be predominantly inorganic in nature (rust). Second, any elevated (*'

levels of iron would be predominantly in the form of ferric oxide or rust which is relatively insoluble in water and would be expected to settle to the botton of Clinton Lake. The small amount of ferrous oxide, which is soluble in water, should be rapidly oxidized to ferric oxide in the alkaline aerobicThird, condition-the of Clinton Lake and would again settle to the bottom.

elevated levels of TSS and iron from prior flushing occurred primarily during the initial stages or "first flush". Since IPC has agreed to convey the maximum feasible amount of first flush to the existing treatment system through all existing (and reasonable available temporary) piping systems, the total amoun t of pollutants added , as well as any shock load ing , should be greatly reduced. Last, the discharges will not be a continuous event, bu t a series of discrete events which appear to result in less than seventy million gallons in total (Pet., 1 22-25, Exhibit A, Rec., 1 22).

The Board finds that the station cannot become operational until the flushing is completed, the existing treatment system cannot handle the total flu shing volume s, and that construction of additional su f f icient temporary treatment capacity would impose an arbitrary or unreasonable hardship when balanced r

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against the minimal adverse environmental impact which might The Board will impose, as conditions of this variance, fi. occur.

the termination date, first flush treatment requirements and monitoring requirements to which IPC and the Agency have agreed.

The Board has re' viewed IPC's request for variance from Section 309.102. That section prohibits discharges of contaminants or pollutants to the waters of the state except in compliance with the Act, Board regulations and provisions and conditions of NPDES permits. 'In a normal variance situation where the permittee seeks to discharge at levels above those contained in the applicable NPDES permit, no variance from this section would be required ; the Agency would be expected to modify the NPDES permit conditions in accordance with the Board Order. Therefore, to the extent that IPC requests relief from this section for currently permitted outf alls that. relief is denied as unnecessary. However, to the extent IPC requests to discharge from outf alls that do not presently have an NPDES permit, relief from Section 309.102 would be required.

IPC and the Agency have both included copies of the draf t NPDES permit which may be issued to IPC in the future. That draft permit specifically lists and imposes conditions on all outfalls of concern i,n this proceeding. However, neither party has included a copy of the currently applicable NPDES permit so that the Board can determine if this proceeding concerns new outf alls. Con sequ en tly , the Board will grant a variance from 309.102 only to the extent of currently unpermitted discharges.

. This Opinion constitutes the Board's findings of f act and conclusions of law on tnis matter.

ORDER Illinois Power Company, Clinton Power Station, is hereby granted a variance from 35 Ill. Ad m. - Cod e 304.124 (Total Suspended Solids and Total Iron only) and 309.102, subject to the following conditions:

1. The variance from Section 304.124, Total Suspended ~ Solid s and Total Iron only, shall apply only to the following flushing operations and outf alls:

Flush Discharge Event Point A. Portions of the (1) to intake fire protection structure

+ sy stem located in from inside (i) diesel - he ader s generator building , (2) to storm drains (ii) containment from hose stations fI and auxiliary fuel bu ild ing s, and (iii) control building

, ~6-B. Divisions I and II of 007 safe shut down service (I' water system C. Station chil' led water Intake structure sy stem D. Component cooling Intake structure water system E. Integrated flush 002(b) of Station systems F. Reactor ~ core Storm drains isolation cooling sy stem G. Division III of 007 safe shu tdown service water system H. Operation 'of safe 007 shutdown service water system

2. The variance from Section 309.102 shall apply only to those /"N discharge points listed above that presently have no NPDES

. permit.

3. This variance shall expire when nuclear fr. I loading begins at the station or December 31, 19 86, whicheve is earlier.

4. IPC shall treat the maximum feasible portion of "first flush" flows for the fire protection sy stem, the chilled water system and the component cooling water system at the station utilizing existing treatment f acilities, as well as existing and reasonably avail able tempor ary pumps and piping.

5. IPC shall monitor the discharges covered by this variance by taking 24-hour composite samples each day that discharge occurs. Tho se samples shall be analyzed for pH, oil and grease, total iron and total su spended sol id s .

6. IPC shall monitor the lake water used for these flushes prior to its use by 24-hour composite s ample s . In such monitoring, the waters of Clinton Lake shall be analyzed f or pH, oil and grease ,

+ total iron and total su spended solid s.

7. The re sults of the above-ref erenced analyse s, along with flow data and dates and times of each discharge, shall be sent to Roger Cruse within ten (10) days af ter the last day of each f.%

flushing event. At the same time , progress toward s completing remaining flushes shall be reported. The appropriate documents shall be sent to the following address:

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Illinois Environmental Protection Agency Division of Water Pollution Control

, Compliasce Assurance Section 2200 Churchill Road Springfield, Illinois 62706 Attention: Roger Cruse

8. Within forty-five ( 4 5 ) day s of tod ay 's Board Order , IPC shall execute and forward to the Illinois Environmental Protection Agency, Division of Water Pollution Control, Compliance Assarance Section, 2200 Churchill Road, Springfield, Illinois 62706 (Attention: Carol Morrison), a Certificate of Acceptance and Agreement to be bound by all terms and conditions of this variance. This fortyfive (45) day period shall be held in abeyance for any period this matter is beina appe aled . The.

form of the certificate shall be as follows:

CERTIFICATE

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I, (We), , having read the order of the Illinois Pollution Control Board in PCB 84-135, dated October 12, 19 84, understand and accept said order, realizing that such acceptance renders all terms and conditions thereto binding and enforceable.

Petitioner Title Date By :

Authorized Agency IT IS SO ORDERED.

I, Dorothy M. Gunn, ~ Clerk of the Il1inois Pollution Control that the above opinion and Order was Board, hereby adepted on the certify

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% _ day of g g _ , 1984 by a vote of 4, - O y

Dorothy M. nn, Clerk Illinois Po lution Control Board 4/