SVP-10-062, National Pollutant Discharge Elimination System (NPDES) Permit No. IL0005037

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National Pollutant Discharge Elimination System (NPDES) Permit No. IL0005037
ML102650041
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 09/16/2010
From: William Gideon
Exelon Nuclear, Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
SVP-10-062, IL0005037
Download: ML102650041 (17)
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Text

ExeIkn Exelon Generation Company, LLC Quad Cities Nuclear Power Station www.exeloncorp.com Nuclear 22710 206" Avenue North Cordova, IL61242-9740 SVP-10-062 September 16, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

National Pollutant Discharge Elimination System (NPDES)

Permit No. IL0005037 Pursuant to Technical Specifications, Appendix B, Section 2.2, "Reporting Related to the NPDES Permits and State Certifications," enclosed is the current NPDES permit for Quad Cities Nuclear Power Station. The permit was recently reissued and effective on September 1, 2010.

Should you have any questions concerning this letter, please contact Mr. Wally J. Beck at (309) 227-2800.

William R. Gideon Site Vice President Quad Cities Nuclear Power Station

Enclosure:

NPDES Permit No. IL0005037 cc: Regional Administrator- NRC Region III NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Q'ool

Enclosure NPDES Permit No. IL0005037

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 1021 North Grand Avenue East, P.O. Box 192.76,*Springfield, Illinois 62794-9276 * (217) 782-2829 James R. Thompson Center, 100 West Randolph, Suite 11-300, Chicago, IL 60601 * (312) 814-6026 PAT QUINN, GOVERNOR DOUGLAS P. ScoTT, DIRECTOR

.217/782-0610 August 26, 2010 Exelon Generation Company, LLC Quad Cities Generation Station 22710 206th Avenue North Cordova, Illinois 61242 Re: Exelon Generation Company, LLC Quad Cities Generating Station NPDES Permit No. IL0005037 Final Permit Gentlemen:

Attached is the final NPDES Permit for your discharge. The Permit as issued covers discharge limitations, monitoring, and reporting requirements. Failure 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 Agency received a letter dated November 22, 2008 from Student Allied for a Greener Earth (SAGE) regarding the draft NPDES .permit. Based on the information provided the following change was made to the permit. Mass limits were added to internal outfall B01.

The Agency also added zinc monitoring to Outfall 001/002 due to an additive change made by the facility.

The Agency has begun a program allowing the submittal of electronic Discharge Monitoring Reports (eDMRs) instead of paper Discharge Monitoring Reports (DMRs). If you are interested in eDMRs, more information can be found on the Agency website, http://epa.state.il.us/water/edmr/index.html.

If your facility is not registered in the eDMR program, a supply of preprinted paper DMR Forms for your facility 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.

The attached Permit is effective as of the date indicated on the first page of the Permit. Until the effective date of any re-issued Permit, the limitations and conditions of the previously-issued Permit remain in full effect. 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.

Rockford &4302 N. Main St., Rockford, IL 61103 * (815) 9837-7760 Des Plaines - 9511 W. Harrison St., Des Plaines, IL 60016 - (847) 294-4000 Elgin e 595 S. Staie, Elgin, IL60123 . (847) 608-3131 Peoria . 5415 N. University St., Peoria, IL61614 - (309) 693-5463 Bureau of Land - Peoria . 7620 N. University St,, Peoria, IL 61614 * (309) 693-5462 Champaign - 2125 S. First St., Champaign, IL 61820 . (217) 278-5800 Collinsville -,2009 Mall Street, Collinsville, IL62234. (6118) 346-5120 Marion - 2309 W. Main SI., Suite 116, Marion, IL62959 0 (618) 993-7200

'rin610don R.cryC'l 1c Cr1-'

Should you have questions concerning the Permit, please contact Leslie R. Lowry at the telephone number indicated above.

Sincerely, Alan Keller, P.E.

Manager, Permit Section Division of Water Pollution Control SAK:LRL:05110101.bah

Attachment:

Final Permit cc: Records Compliance Assurance Section Rockford Region Iowa Department of Natural Resources

NPDES Permit No. IL0005037 Illinois Environmental Protection Agency Iowa Department of Natural Resources Division of Water Pollution Control NPDES Section 1021 North Grand Avenue East Henry A. Wallace Building Post Office Box 19276 900 East Grand Avenue Springfield, Illinois 62794-9276 Des Moines, Iowa 50319 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM Reissued (NPDES) Permit Expiration Date: August 31, 2015 Issue Date: August 26, 2010 Effective Date: September 1, 2010 Name and Address of Permittee: Facility Name and Address:

Exelon Generation Company, LLC Quad Cities Generating Station 4300 Winfield Road 22710 206th Avenue North Warrenville, Illinois 60555 Cordova, Illinois 61242 (Rock Island County)

Discharge Number and Name: Receiving Waters:

001/002 Open Cycle Diffusers Mississippi River B01 Wastewater Treatment System C01 Sanitary Waste Treatment Plant A02 Radwaste Treatment System Blowdown In compliance with the provisions of the Illinois Environmental Protection Act, Title 35 of Ill. Adm. Code, Subtitle C and/or Subtitle D, Chapter 1, the Iowa Code Section 455B.174 and rule 567-64.3 of the Iowa Administrative Code, 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.

Alan Keller, P.E. Steven Williams Manager, Permit Section Iowa Department of Natural Resources Division of Water Pollution Control NPDES Section Environmental Services Division SAK:LRL:05110101.bah

Page 2 NPDES Permit No. IL0005037 Effluent Limitations and Monitoring

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:

LOAD LIMITS lbs/day CONCENTRATION DAF (DMFI LIMITS mg/I 30 DAY DAILY 30 DAY DAILY SAMPLE SAMPLE PARAMETER AVERAGE MAXIMUM AVERAGE MAXIMUM. FREQUENCY TYPE Ouffall 001/002 - Open Cycle Diffusers*

(Total Average Flow = 1017.2 MGD)

The discharge consists of: Approximate Flow (MGD)

Main Condenser Cooling Water 972.4 House Service Water 44 Radwaste Treatment System Blowdown (Outfall A02) 0.055 Wastewater Treatment Plant (Ouffall B01) 0.051 Sanitary Waste Treatment Plant (Outfall C01) 0.004 House Service Water Strainer Backwash 0.126 Intake Screen Backwash 0.508 Units 1 and 2 Oil/Water Separators (stormwater) Intermittent Fish Culture Facilities Intermittent Crib House Floor Drain Sump** 0.05 Flow (MGD) See Special Condition 1. Daily 24-Hour Total pH See Special Condition 2. 1/Month Grab Total Residual Chlorine / 0.05 1/Month Grab Total Residual Oxidant***

Temperature"* See Special Condition 7. Daily Continuous Zinc (Total)***** -Monitor Only 1/Quarter Grab

  • - Outfall 0011002 consists two open cycle diffusers which are side by side and discharge equally into the Mississippi River. See Special Condition 5.
    • -This sub-waste stream is an alternative routing from Outfall B01. See Special Condition 17.

- See Special Condition 4.

- Daily grab samples for Temperature are allowed when the Continuous Temperature Recorder is inoperable.

- Quarterly sampling for zinc shall only be done when using the zinc-phosphate corrosion inhibitor.

NPDES Permit No. IL0005037 Effluent Limitations and Monitorine

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:

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 Ouffall B01 - Wastewater Treatment System*

(DMF =.0.155 MGD)

  • The discharge consists of:** Approximate Flow (MGD)

Crib House Floor Drain 0.050 Aux. Boiler Blowdown Seasonal Roof and Floor Drains Intermittent Portable Demineralizer Rinse Water Intermittent Flow (MGD) See Special Condition 1. 2/Month 24-Hour Total Total Suspended Solids 19 39 15 30 2/Month 8-Hour Composite Oil and Grease 19 26 15 20 I/Month Grab

  • - Wastewater treatment system effluent is routed through an oil/water separator prior to discharge.

- The listed contributory waste stream all pass through an oil/water separator (Units / oil/water separator) prior to entering the wastewater treatment plant. The crib house floor drain sump water may be discharged directly to Outfalls 001/002 as an alternative route. See Special Condition 17.

Ouffall COI - Sanitary Waste Treatment Plant (DMF = 0.06 MGD)

Flow (MGD) See Special Condition 1. 2/Month 24ýHour Total pH See Special Condition 2. 2/Month Grab BOD 5 15 30 30 60 2/Month 24-Hour Composite Fecal Coliform See Special Condition 13. 2/Month Grab Total Suspended Solids 15 30 30 60 2/Month 24-Hour Composite

Page 4 NPDES Permit No. IL0005037 Effluent Limitations and Monitoring

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:

LOAD LIMITS Ibs/day CONCENTRATION DAF (DMF) LIMITS mq/l 30 DAY DAILY 30 DAY DAILY SAMPLE SAMPLE PARAMETER AVERAGE MAXIMUM AVERAGE MAXIMUM FREQUENCY TYPE Outfall A02 - Radwaste Treatment System Blowdown*

(Average Flow = 0.055 MGD)

The discharge consists of:

Laundry Wastewater

,Floor Drains Equipment Drains Reactor Water Filter Backwash from Reactor Cleanup Filter Backwash from Condensate Demineralizers Laboratory Wastewater Groundwater Flow (MGD) See Special Condition 1. Daily 24-Hour Total Total Suspended Solids 15 30 I/Month Grab Oil and Grease 15 20 I/Month Grab Boron See Special Condition 16. Monitor Only 1/Discharge Event" Grab

  • - The Permittee shall comply with the Nuclear Regulatory Commission, Title 10, regulations for discharge and monitoring of radioactive wastewater discharges. Wastewater is generally batch treated and recycled, therefore the daily average discharge rate from Outfall A02 does not reflect influent flow rates.
    • - When discharging sodium pentaborate.

Page 5 NPDES Permit No. IL0005037 Special Conditions SPECIAL CONDITION 1. Flow shall be measured in units of Million Gallons per Day (MGD) and reported as a monthly average and a daily maximum on the monthly Discharge Monitoring Report.

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. All samples for Total Residual Chlorine shall be analyzed by an applicable method contained in 40 CFR 136, equivalent in accuracy to low-level amperometric titration or other methods found In Standard Methods for-Examination of Water and Wastewater, current edition. Any analytical variability of the method used shall be considered when determining the accuracy and precision of the results.

SPECIAL CONDITION 5. Compliance with discharge limitations for Ouffall 001 shall be determined by representative sampling of Outfall 002. Due to the configuration of the discharge bay, which is immediately upstream of the two open cycle diffusers, the effluent from the discharge bay flows into the two open cycle diffuser pipes which equally release the discharge into the Mississippi River.

SPECIAL CONDITION 6. Nothing in this permit affects or abrogates the responsibilities or commitments of the Permittee herein as set forth in the agreement entered into by the Permittee in the consolidated cases of Izaak Walton League of America, et. al. v. Schlesinger, No. 2208-71 and People of the State of Illinois, et. al. v. United States Atomic Energy Commission, No. 2208-71 (U.S. District Court, District of Columbia).

SPECIAL CONDITION 7. 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:

A. Maximum temperature rise above natural temperature must not exceed 5OF.

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. cMjoreover, at no time shall the water temperature at such locations exceed the maximum limits In the following table by more than 3 F. (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. A*r. Jy June July Aug Seot. Oct. Nov. Dec.

OF 45 45 57 68 78 85 86 86 85 75 65 52 C. The area of diffusion of an effluent In the receiving water is a mixing zone, and that mixing zone shall not extend:

I) over more than 25 percent of the cross sectional area or volume of flow in the Mississippi River; ii) more than 26 acres of the Mississippi River The following data shall be collected and recorded:

1. Weekly determination of the river flow rate (daily when the river flows fall below 23,000 cfs).
2. Daily determination of the ambient river temperature (at or upstream of station intakes).
3. Daily recording of station discharge rate.
4. Daily continuous recording of the temperature of the station discharge.
5. Daily determination of station load.

Page 6 NPDES Permit No. IL0005037 Special Conditions

6. As deemed necessary according to the above data, daily determination of the cross-sectional average temperature at the 500 foot downstream cross-section in the river.

Compliance with the thermal limitations of Special Condition 7 shall be demonstrated as follows:

1. When river flow is 21,000 cfs or greater and the ambient river temperature is 50 F or more lower than the monthly limiting temperatures, the temperature monitoring curve' establishes that the permittee is in compliance for all power generation levels;
2. When the river flow is less than 21,000 cfs and/or the ambient river temperature is within 50 F of the monthly limiting temperatures, the permittee shall demonstrate compliance using either:
a. Plant load, river flow, ambient river temperature, and the temperature monitoring curve, or
b. Field measurement' of the river cross-sectional average temperature taken 500 feet downstream of the diffusers.

In the event that compliance monitoring shows that the permittee has exceeded the monthly limiting temperature, the number of hours of such exceedance shall be reported on the permittee's Discharge Monitoring Report.

1 The temperature monitoring curve identified as figure 2 in the December 2000 "Revised Temperature Monitoring Curve for Quad Cities Nuclear Generating Station".

2 When conditions such as ice formation render the Mississippi River inaccessible to marine activity, the Permittee may demonstrate compliance with the thermal limitations of Special Condition 7 by using the most recent field measurement data collected at a river flow equal to or less than the flow for which field measurement data cannot be collected. The most recent field measurement data shall be normalized to the power production level for the day when the river was inaccessible.

SPECIAL CONDITION 8. There shall be no discharge of polychlorinated biphenyl compounds from any discharge.

SPECIAL CONDITION 9. There shall be no discharge of complexed metai bearing wastestreams and associated rinses from chemical metal cleaning, unless this permit has been modified to include 'the new discharge.

SPECIAL CONDITION 10. Demonstration for the Quad Cities Nuclear Power Station in accordance with Section 316(a) and 316(b) of the Clean Water Act was approved by IEPA by letter dated July 28,1981 and by the Iowa Department of Environmental Quality (IDEQ) by letter dated May 18, 1981. Based on these conclusions the following actions by the permittee are required:

A. The permittee shall monitor fish impingement once per week, year round. Each year's data shall be tabulated and compared to historical fish impingement data for the same period with the results submitted to IEPA Compliance Assurance Section and Iowa Department of Natural Resources by July 28, each year.

Iowa Department of Natural Resources Attn. Fisheries Management Biologist Bellevue Research Station 24143 Highway 52 Bellevue, Iowa 52031 B. The permittee shall monitor water temperatures as described in Special Condition,7.

SPECIAL CONDITION 11. A permittee who wishes to establish the affirmative defense of upset as defined in 40 CFR 122.41(n) shall demonstrate, through properly signed, contemporaneous operating logs, or other relevant evidence that: An upset occurred and that the permittee can identify the cause(s) of the upset; the permitted facility was at the time being properly*operated; the permittee submitted notice of the upset as required in standard condition 12 of this permit; and the permittee complied with any remedial measures required in standard condition 4 of this permit.

Page 7 NPDES Permit No. IL0005037 Special Conditions SPECIAL CONDITION 12. Discharge is allowed from the Unit I oil/water separator and the Unit 2 oil/water separator in accordance with the Spill Prevention Control and Countermeasure Plan (SPCC). If an applicable effluent standard or water quality related effluent limitation is promulgated under Section 301 and 302 of the Clean Water Act (CWA) and that effluent or water quality standard or limitation is more stringent than any effluent or water quality limitations in this permit, or controls a pollutant not limited in this NPDES Permit, the Agencies shall revise or modify the permit in accordance with the promulgated standard and shall notify the permittee.

SPECIAL CONDITION 13. The daily maximum fecal coliform count shall not exceed 400 per 100 ml.

SPECIAL CONDITION 14. The Permittee shall record monitoring results on Discharge Monitoring Report (DMR) Forms using one such form for each outfall each month.

In the event that an ouffall does not discharge during a monthly reporting period, the DMR Form shall be submitted with no discharge indicated.

The Permittee may choose to submit electronic DMRs (eDMRs) instead of mailing paper DMRs to the IEPA. More information, including registration information for the eDMR program, can be obtained on the IEPA website, http://www.epa.state.il.us/water/edmr/index.html.

The completed Discharge Monitoring Report forms shall be submitted to IEPA no later than the 28th day of the following month, unless otherwise specified by-the permitting authority.

Permittees not using eDMRs shall mail Discharge Monitoring Reports with an original signature to the IEPA at the following address:

Illinois Environmental Protection Agency Division of Water Pollution Control 1021 North Grand Avenue East Post Office Box 19276 Springfield, Illinois 62794-9276 Attention: Compliance Assurance Section, Mail Code # 19 SPECIAL CONDITION 15. 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 activity, 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 16. The permittee shall monitor for boron during periods when Sodium Pentaborate is discharged as a result of tank testing and connection drainage from components in the radwaste treatment system. The effluent boron concentration in the subject discharge shall not cause the receiving stream to exceed the water quality standards in Section 302 of 35 II1.Adm. Code, Chapter 1, Subtitle C. This permit may be modified to include effluent limitations or requirements which are consistent with applicable laws, regulations, or judicial orders. The Agency will public notice the permit modification.

SPECIAL CONDITION 17. Crib House Floor Drain Sump shall only be routed to the Outfall 001/002 Open Cycle Diffusers during periods when increased pump seal cooling water leakage is significant enough so as to overload the wastewater treatment plant. Alternate routing of this discharge shall not take place in lieu of proper maintenance and operation of the circulating pumps.

SPECIAL CONDITION 18. This permit authorizes the use of water treatment additives that were requested as part of this renewal. The use of any new additives, or change in those previously approved by the Agencies, or if the permittee increases the feed rate or quantity of the additives used beyond what has been approved by the Agencies, the permittee shall request a modification of this permit in accordance with the Standard Condition - Attachment H.

The permittee shall submit to the Agencies on a yearly basis a report summarizing their efforts with water treatment suppliers to find a suitable altemative to phosphorus based additives.

Page 8 NPDES Permit No. IL0005037 Soecial Conditions SPECIAL CONDITION 19. In order for theAgency to evaluate the potential impacts of cooling water intake structure operations pursuant to 40 CFR 125.90(b), the permittee shall prepare and submit information to the Agency outlining current intake structure conditions at this facility, including a detailed description of the current intake structure operation and design, description of any operational or structural modifications from original design parameters, source waterbody flow information, or other information as necessary. The information submitted should be in accordance with the previously submitted information collection proposal received by the Agency on May 10, 2005.

The information shall also include a summary of historical 316(b) related intake impingement and I or entrainment studies, if any, as well as current impingement mortality and / or entrainment characterization data; and shall be submitted to the Agency within six (6) months of the permit's effective date.

Upon the receipt and review of this information, the permit may be modified to require the submittal of additional information based on a Best Professional Judgement review by the Agency. This permit may also be revised or modified in accordance with any laws, regulationsi or judicial orders pursuant to Section 316(b) of the Clean Water Act.

Page 9.

Attachment H (6) Permit actions. This permit may be modified,.revoked and reissued, or terminated for cause by the Agency pursuant to 40 CFR 122.62. The filing of a request by the Standard Conditions - permittee for a permit modification, revocation and reissuance, or termination, or a notification of planned changes or anticipated noncompliance, does not stay any Definitions permit condition.

Act means the Illinois Environmental Protection Act, 415 ILCS 5 as Amended. (7) Property rights. This permitdoes not convey any property rights of any sort, or any exclusive privilege.

Agency means the Illinois Environmental Protection Agency.

(8) Duty to provide Information. The permittee shall furnish to the Agency within a Board means the Illinois Pollution Control Board. reasonable time, any infomiation which the Agency may request to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to Clean Water Act (formerly referred to as the Federal Water Pollution Control Act) means determine compliance with-the permit. The permittee shall also furnish to the Agency.

Pub. L92-500, .as amended. 33 U.S.C. 1251 at seq. upon request, copies of records required to be kept by this permit.

NPDES (National Pollutant Discharge Elimination System) means the national program for (9) Inspection and entry. The permittee shall allow an authorized representative of the issuing, modiyingrevoklngand reissuing, terminating, monitoring and enforcing permits, and Agency, upon the presentation of credentials and other documents as may be required imposing and-enforcing. pretreatment requirements, under Sections 307, 402, 318 and 405 by law, to:

of the Clean Water Act.

(a). Enter upon the permiltee's premises where a regulated facility or activity is USEPA means thb United States Environmental Protection Agency. located or conducted, or where records must be kept under the conditions of this permit; Daily Discharge means the discharge of a pollutant measured during a calendar day or any 24-hour penod~that reasonably represents the calendar day for purposes of sampling. For (b) Have access to and copy, at reasonable times, any records that must be kept pollutants withimitations expressed in units of mass, the 'daily discharge" is calculated as under the conditions of this permit; the total mass of'.the:pollutant discharged over the day. For pollutants with limitations expressedinother units of measurements, the 'dally discharge" Is calculated as the average (c) Inspect at reasonable times any facilities, equipment (including monitoring and measurement',of the-pollutant over-the day. control equipment), practices, or operations regulated or required under this permit; and Maximumbally Discharge-LImitation (daily maximum) means the highest allowable daily discharge. (d) Sample or monitor at reasonable times, for the purpose of assuring permit compliance, or as otherwise authorized by the Act, any substances or parameters Average Monthly Discharge Umltation (30 day average) means the highest. allowable at any location.

average of daily dlischarges over a calendar month, calculated as the sum of all daily discharges ia6sureak uring a calendar month divided by the number of daily discharges (10) Monitoring and records.

measured .. u*ng'that month..

(a) Samples and measurements taken for the purpose of monitoring shall be Average Weekly Discharge Limitation (7 day average) means the highest allowable representative of the monitored activity. -

average of.dally.;discharges over a calendar week, calculated as the sum of all daily discharges meassiredduring .a calendar week divided by the number of daily discharges (b) The permittee shall retain records of all monitoring information, including all measured- durig that week. calibration and maintenance records, and all original strip chart recordings for continuous monitoring instrumentation, copies of all reports required by this Best Management Practices (BMPs) means schedules of activities, prohibtions of practices, permit, and records of at data used to complete the application for this permit, for maintnar.cppr*cedures, and other management practices to prevent or reduce the pollution a period of at least 3 years from the date of this permit, measurement, report or of water&of.lhýeState. BMPs alsoinclude treatment requirements, operating procedures, and application. This period may be extended by request of the Agency at any time.

practices to6cotrole plant.ste runoff, spillage or leaks, sludge or waste disposal, or drainage from raw rmatedal storage. (c) Records of monitoring Information shall include:

Aliquot means a sample of specified volume used to make up a total composite sample. (1) The date, exact place, and time of sampling or measurements; Grab Sampl~emea.n an Individual sample of at least 100 milliliters collected at a randomly- (2) The Individual(s) who performed the sampling or measurements; selected timever* aperlod'not exceeding 15 minutes.

(3) The date(s) analyses were performed; 24 Hour Composits Sample means a combination of at least 8 sample aliquots of at least 100 mlt * *l deat periodi intervals-during the operating hours of a facility over a 24- (4) The individual(s) who performed the analyses; hour, perd.

(5) The nalytical. techniques. or methods used;.and 8 Hour Cornposlit Sample means a combination of at least 3 sample allqucts of at least 100 mililitere c6.1illed-atpeo-dic intervalsduring the operating hours of a facility over an 8-hour (8) The results of such analyses.

(d) Monitoring must be conducted according to test procedures approved under 40

- Flow.lPr*p*onal ComposIte Sample means a combinationof sample aliquots of at least CFR Part 136, unless other test procedures have been specified in-this permit.

10Omliiltar~c~lete~atperiodic. Intervals such that either the time Interval between-each Where no test procedure under 40 CFR Part 136 has been approved, the aliquot cortl6eVume of eachallquot is.proportIonal to either the-stream flow St the time of permlitee must submit to the Agency a.seet method for approval. Thewpermittee sam pling ootalstpam f'.ow since.the -collection.of theprevious aliquot. shall calibrate and perform maintenance procedures on all monitoring and analytical instrumentation at intervals to ensure accuracy of measurements.

(1) Du*tyjo comply, Theiermltte must comply with all conditions of this permit. Any (11) Signatory requirement All applications, reports or Information submitted to the pae 0norll0p8 tltes-avlolation of.the Act and:is grounds for enforcement cto e 0n*e*i*ioar* on' and raissuance, modification, or-for denial of a Agency. shall be signed and certified.

permu .vqppwalagplaptpon/T.'ieh-permnltee shall comply with effluent standards or pro6hbItios establihed ..under Sectlon 307(a) of- the.Clean Water Act for toxic (a) Application. All permit applications shall be signed as follows:

poll *"1hietime provided inthe regulations that establish these standards or proo to@nsI :even;*f:.[he v .permit:-has not yet been- modified to. Incorporate the (1) For e corporation: by a principal executive officer of at least the level of requirenent. - vice president or a person or position having overall responsibility for environmental matters for the corporation; (2) Duty !*t~eapply. Ifthe permiftee wishes to continue an actity regulated by this permit afterie xpiration dateof this-permit, the permittee must apply for and obtain a new (2) For a partnership or sole proprietorship: by a general partner or the permot. the. permitteewsubmits a proper application as required by theAgency no later proprietor, respectively; or thani-*80<.ays priorlto the expiration date,.this permit shall continue In full force and effetii.1:finýpýncyn. decision on the application has been made. (3) For a municipality, State, Federal, or other public agency: by either a principal executive officer or ranking elected official.

(3) Needjo'poalt or reduce activity not a defense. it shall not be a defense for a perm tleeian enforcement action that Itwould have been necessary to haft or reduce (b) Reports. All reports required by permits, orother Information requested by the the p4i* qtýtin orderoamaintaln compliance with the conditions of this permit. Agency shall be signed by a person described In paragraph (a) or by a duly authorized representative of that person. A person is a duly authorized (4) Dutytt**.mtlgate. The :prmittee shall take all reasonable steps to minimize or prevent representative only if:

anyd1scrgex-ri ,violation of this permit which has a reasonable likelihood of adversely affec)pg~umant~eatlvothei environment., (1) The authorization Is made in writing by a person described in paragraph (a);

and (5) Prope-operation and maintenance. The parmlttee shall-at all times propertyoperate and 'aianain all-facilitles and systems of treatment and control (and related (2) The authorization specifies either an individual or a position responsible lor apputea4nces) which are Installed or used by the permiltae to achieve compliance the overall operation of the facility, from which the discharge originates, such as a plant manager, superintendent or person of equivalent responsibility; with cOnditions of thispermit.: Proper operation and maintenance includes effective and ped ae, adequate funding, adequate operator staffing and training, and adequate laboratory-and process controls, including appropriate quality assurance procedures.

This-..provision requires: the operation of back-up, or auxiliary facilities, or similar (3) The written authorization is submitted to the Agency.

systems only when necessary to achievecompliance with-the conditions of the-permit.

-Page 10.

(c), Changes of Authorization. If an authorization Under (b) Is no longer accurate (4) The level established by the Agency In this permit.

. because a different Individual or postion' has responsibility for the overall operation of the facility, a new authorization satisfying the requirements of (b) (b) That they have begun or expect to begin to use or manufacture as an intermediate must be submitted to the Agency prior to or together with any reports, information, or final product or byproduct any toxic pollutant which was not reported in the or applications to be signed by an authorized representative. NPDES permit application.

(12) Reporting requirements. (15) All Publicly Owned Treatment Works (POTWs) must provide adequate notice to the Agency of the following:

(a) Planned changes. The permittee shall give notice to the Agency as soon as possible of any planned physical alterations or additions to the permitted facility. (a) Any new introduction of pollutants into that POTW from an indirect discharge which would be subject to Sections 301 or 306.of the Clean Water Act if itwere (b) Anticipated noncompliance. The permittee shall give advance notice to the directly discharging those pollutants; and Agency of any planned changes in the permitted facility or activity which may result in noncompliance with permit requirements. (b) Any substantial change in the volume or character of pollutants being introduced into that POTW by a source introducing pollutants into the POTW at the time of (c) Compliance schedules. Reports of compliance or noncompliance with, or any issuance of the permit.

progress reports on, interim and final requirements contained in any compliance schedule of this permit shall be submitted no later than 14 days following each (c) For purposes of this paragraph, adequate notice shall include information on (i) schedule date. the quality and quantity of effluent Introduced into the POTW, and (ii) any anticipated impact of the change on the quantity or quality of effluent to he.

(d) Monitoring reports. Monitoring results shall be reported at the intervals discharged from the POTW.

specified elsewhere in this permit.

(16) If the permit is Issued to a publicly owned or publicly regulated treatment works, the (1) Monitoring results must be reported on a Discharge Monitoring Report permittee shall require any industrial user of such treatment works to comply with (DMR). federal requirements concerning:

(2) If the permittee monitors any pollutant more frequently than required by the (a) User charges pursuant to Section 204(b) of the Clean Water Act, and applicable pefmit, using test procedures approved under 40 CFR 136 or as specified regulations appearing in 40 CFR 35; in the permit, the results of this monitoring shall be included in the calculation and reporting of the data submitted In the DMR. (b) Toxic pollutant effluent standards and pretreatment standards pursuant to Section 307 of the Clean Water Act; and (3) Calculations for all limitations which require averaging of measurements shall utillze.anadrthmeticmean unless otherwise specified bythe Agency In (c) Inspection, monitoring and entry pursuant to Section 308 of the Clean Water Act.

the permit.

(17) Ifan appllcab!e standard or limitation.is promulgated under Section 301(b)(2)(C) and (e) Twenty-four hour reporting. The permittee shall report any noncompliance (D), 304(b)(2), or 307(a)(2) and that effluent standard or limitation is more stringent which mlay endanger health or the environment. Any information shall be than any effluent limitation in the permit, or controls a pollutant not limited in the provided orally within 24hours from the time the permittee becomes aware of the permit, the permit shall be promptly modified or revoked, and reissued to conform to circumstances. A written submisslon shall also be provided within 5 days of the that effluent standard or limitation.

time:the permittee becomes aware of the circumstances. The written submission shall:contain a description of the noncompliance and its cause; the period of (18) Any authorization to construct issued to.the permittee pursuant to 35 III.Adm. Code noncomptiance,'including exact dates and time; and if the noncompliance has not 309.154 is hereby incorporated by reference as a condition of this permit.

been corrected, theeanticipated time it Is expected to continue; and steps taken or planned toreduce, eliminate, and prevent reoccurrence of the noncompliance. (19) The permittee shall not make any false statement, representation or certification in any Thefollowilngshall be:included as information which must be reported within 24 application, record, report, plan or other document submitted to the Agency or the hours: USEPA, or required to be maintained under this permit.

(1) Any unanticipated bypass which exceeds any effluent limiiation in the (20) The Clean Water Act provides 'that any person who violates a permit condition permit: implementing Sections 301, 302, 306, 307, 308, 318, or 405 of the Clean Water Act is subject to a civil penalty not to exceed $10,000 per day of such violation. Any (2). Violation of a maximum daily discharge limitation for any of the pollutants person who willfully or negligently violates permit conditions implementing Sections

'listed by theAgency In the.permit to be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. 301, 302, 306, 307, or 308 of the Clean Water Act is subject to a fine of not less than

$2,500 nor more then $25,000 per day of violation, or by imprisonment for not more The Agency may waive the written report on a case-by-case basis If the oral than one year, or both.

rep.rt.has:been'received:within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(21) The Clean Water Act provides that any person. who falsifies, tampers with, or (1) Other noncompliance, The permittee shall report all Instances of knowingly renders Inaccurate any monitoring device or method required to be noncompliance~not-reported-underparegraphs-(-12)(c)ý-(d)i or-(e); at the time maintained.underpermit shall, upon conviction, be.punished by a fine fritIrmore than.

monitoring reportsare submitted. The reports shall contain the Information listed $10,000 per violation, or by Imprisonment for not more than 6 months per violation, or

  • niparagraph. (12)(e).

by both.

(g) :iherinformation. tWheethe perrlttee becomes aware that it failed to submit (22) The Clean Water Act provides that any person who knowingly makes any false anyrelevantfactsin a permit application, or submitted incorrect Information In a statement, representation or certification in any record or other document submitted permitapplication, or in any r.eport.tothe Agency, it shall promptly submit such or required to be maintained under this permit shall, including monitoring reportsor facts:or.information. reports of compliance or non-compliance shall, upon conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for not more than 6 months (13) Trar.n.sf,.of permlts. A permitmay beautomatically transferred to a new permittee per violation, or by both.

(23) Collected screening, slurries, sludges, and other solids shall be disposed of In such (a) :The current permittee notifies the Agency at least 30 days in advance of the a manner as to prevent entry of those wastes (or runoff from the wastes) into waters prpl;.osedl transfer fate::' of the State. The proper authorization for such disposal shall be obtained from the Agency and is incorporated as part hereof by reference.

(b)..,Thnotice Includes a written agreement between the existing and new permittees containing a.specific date for transfer of permit responsibility, coverage and (24) In case of conflict between these standard conditions and any other condition(s) liabi!ltybetween thei curen and new permittees; and included in this permit, the other condition(s) shall govern.

(c) The Agency does not notify the existing permittee and the proposed new (25) The permIttee shall comply with, in addition to the requirements of the permit, all pe.mittee of its intent to modify or revokeand reissue the permit. If this notice Is applicable provisions of 35 Ill. Adm. Code, Subtitle C, Subtitle D, Subtitle E, and all not*ecelved, the transfer is effective on the date specified In the agreement. applicable orders of the Board.

(14) All manufacturing; commercial, mining, and slivicultural dischargers must notify the (26) The provisions of this permit are severable, and If any provision of this permit, or the Agency.*aS :soon:as they Ioiow or'have reason to believe: application of anyprovision of this permit is held Invalid, the remaining provisions of this permit shall continue in full force and effect.

(a) Tlhat any activity has occurred orwill occur which would result In the discharge of any!;toxic pollutant Identified under Section 307 of the Clean Water Act which is not~limited in the permit, if that discharge will exceed the highest of the following (Rev. 3-13-98) notification levels:

(1) 'One hundred micrograms per liter (100 ug/I);

(2). Two hundred micrograms per liter (200 ug/1) for acrolein and acrylonitrile; five hundred micrograms per liter (500 ugh) for 2,4-dinltrophenol and for 2-methyl-4,6 dlnitrophenol; and one milligram per liter(1 mg/I) for antimony.

(3) Five (5) times the maximum concentration value reported for that pollutant in the NPDES permit application; or

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276 a (217) 782-2829 James R. Thompson Center, 100 West Randolph, Suite 11-300, Chicago, IL 60601 * (312) 814-6026 PAT QUINN, GOVERNOR DOUGLAS P. SCOTT, DIRECTOR 217/782-0610 August 26, 2010 Tih-Fen Ting (SAGE)

University of Illinois at Springfield PAC 308 One University Plaza Springfield, Illinois 612703-5407 Re: Exelon Generation Company, LLC Quad Cities Generating Station NPDES Permit No. IL0005037 Comments Received During 30-Day Public Notice

Dear Mr. Ting:

The Agency has received your letter dated November 22, 2008, in which you offered comments on the public notice draft NPDES permit for Quad Cities Generating Station. The Agency considered your comments as well as comments received by the applicant before making the decision to issue the permit. Enclosed is a copy of the permit as issued. The Agency offers the following responses to comments received from Students Allied for a Greener Earth.

1. The 35 IAC 302.209 standard is based on a geometric mean of the analyzed samples and 10 percent of the samples can be over the 400 per 100 mL limit. The 35 IAC 304.121 standard is generally more restrictive. However, due'to the high amount of dilution the sanitary wastewater received when mixing with the condenser cooling water along with additional dilution in the Mississippi River the water quality limit in 35 IAC 302.209 will be met.
2. Pursuant to 40 CFR 125.5(c)(3), the Agency considers the 0.05 mg/I limit for Total Residual Chlorine (TRC) to meet the Best Available Technology (BAT) standard.
3. The provisions of 40 CFR 125.3(d)(3)(I) through (vi) are unnecessary given that the universal technology for chlorine removal is inexpensive and very effective. There are no other options or considerations when a treatment method effectively achieves the desired result. Dechlorination is' rather unique in this regard. Where chlorine must be removed from effluents, chemical dechlorination is the technology that must be applied. In other words, there is no "development" of a BAT limit as outlined in the cited federal regulation; facilities that must remove chlorine must use the best available technology of adding the dechlorination -chemical to the final effluent. While the dechlorination chemical removes virtually all chlorine, the limit is dependent on the analytical methods available to the permittee. Chlorine is highly volatile and effluent measurement must be made within minutes of sample collection. Because of the limitations ofthe USEPA approved analytical methods for chlorine, which are essentially field methods, IEPA must use the detection level of these methods as t6e permit limit.

Rockford

  • 4302 N. Main St., Rockford, IL61103 - (8135)987-7760 Des Plaines
  • 9511 W. Harrison St., Des Plaines, IL 60016 * (847) 294-4000 Elgin
  • 595 S. State, Elgin, IL 60123 * (847) 608-3131 Peoria
  • 5415 N. University St., Peoria, IL61614 * (309) 693-5463 Bureau of Land - Peoria o 7620 N. University St., Peoria, IL61614 * (309) 693-5462 Champaign* 2125 S. First St., Champaign, IL 61820 * (217) 278-5800 Collinsville ,2009 Mall Street, Collinsville, I1 62234 a (618) 346-5120 Marion e 2309 W. Main St., Suite 116, Marion, IL 62959 a (618) 993-7200
4. Sometimes water quality standards are adopted at levels that are below the available laboratory detection level. In the case of chlorine, laboratory methods available to discharges can only accurately measure chlorine concentrations down to about 0.05 mg/l. In these instances, chlorine being the most common disinfectant, IEPA may set the permit limit at the detection level and require that the permittee report that no chlorine was measurable at that level. The permittee understands that to assume compliance with this value, dechlorination must be provided. The dosing of the dechlorination chemical is administered to remove all chlorine present, not just down to 0.05 rmg/l.

If IEPA were to put limits in permits at the water quality standard, i.e., 0.011 mg/l, and then note that the permittee must monitor and show "no detection" to avoid noncompliance, false detections would occur because of the nature of analytical devices. Laboratory methods involving colorimetry or amperometry (the two most common methods used to measure chlorine) may show color or amperometric change on samples below the stated detection levels of those methods. These color or amperometric changes may or may not be due to the presence of chlorine. Sometimes they are due to interferences from other substances that may be masked at high (above detection limit) levels for chlorine. In other cases, human error (seeing a color change or ampere deflection when there was really none) can lead to a "measurement" where no chlorine concentration, existed. These measurements are not valid because they go beyond the range and abilities of the method. These attempts at pushing the limits of the chlorine methods beyond stated boundaries will lead to recording of chlorine results that are inaccurate and invalid. Until methods are developed and approved for use by USEPA (as USEPA has approved the methods that have detection limits of 0.05 mg/I now in use),

that have lower detection limits equal to or lower than the water quality standard, IEPA will regulate chlorine (and other substances with this problem) at the recognized detection limit. We know of no federal or state regulation that dictates how a permit limit is to be established when the minimum detection limit is above the water quality based permit limit, i.e., the water quality standard. There is federal guidance on this subject, however, it located on page 111 and 112 of USEPA's Technical Supporting Document for Water Quality-Based Toxic Control, EPA/505/2-90-001. The guidance gives states flexibility when dealing with parameters like chlorine, where, for the reason specified above, regulation with permit limits set at-the water quality standards would be impractical. On page 112, under the heading "Detection Level Limits," this document states: "The permitting authority may choose to specify another level at which compliance determination are made. When the permitting authority so chooses, the authority must be assured that the level is quantifiable, defensible, and close as possible to the permit level." The regulation of chlorine in this permit fits this guidance. Until an accurate, field enabled analytical procedure with a lower detection limit is available, chlorine will be limited in permits at the 0.05 mg/l level.

5. A waste load allocation is only required when "an NPDES Permit applied any more stringent effluent limitation." Id. In this case, no "more stringent effluent limitation" is applied, and therefore no waste load allocation is required by Section 309.142.
6. In reviewing stormwater discharges the Agency can make one of two decisions, either effluent limits apply to the discharge or best management practices through a Stormwater Pollution Prevention Plan (SWPPP) will be required. In discharges, such as the discharge at outfall 001, where stormwater passes through an oil/water separator prior to mixing with a large volume wastestream, condenser cooling water, before discharging to the Mississippi River, the Agency made the determination that limits apply to the stormwater discharged. The effluent limits included in the permit constitute as BAT and therefore a SWPPP is not required.
7. See response above in comment 6.
8. Mass limits were added to internal outfall BO I. For outfall 001 mass limits are not required due to the large volume of condenser cooling water and stormwater, both of which are variable in flow and in their nature. To express limitations in terms of mass at this outfall is impracticable and unnecessary. At internal outfall A02 given that the system is a batch method of operation and relative high variability of the percent of water that is recycled back to the plant for use, it is impractable and unnecessary to express limitations in terms of mass at this outfall.

9... Boron monitoring is only required when the permittee discharges Sodium Pentaborate as a result of tank testing and connection drainage from components in the radwaste treatment system. The effluent boron concentration in the discharge shall not cause the receiving stream to exceed the water quality standards in 35 LAC 302, therefore no limits are necessary and boron monitoring is sufficient to ensure compliance with the standard.

10. The effluent pH concentration in the discharge shall not cause the receiving stream to exceed the water quality standard in 35 IAC 302, therefore pH limits of 6.0 - 9.0 are sufficient to ensure compliance with the standard.

11 ' Radiological admissions and/or discharges from licensed facilities are regulated by the Nuclear Regulatory Commission and the Illinois Emergency Management Agency. This facility is a licensed facility therefore the pollutants in 35 IAC 302.207 do not apply.

The Agency thanks you for your interest and participation in the public notice process. If you have any questions concerning this letter, please contact Leslie Lowry at 217/782-0610 or the address listed above.

Sincerely, AlanKellerP.E.

Manager, Permit Section Division ofWater Pollution Control SAK:LRL:05037sage.wpd cc: Exelon Generation Company, LLC - Quad Cities Peoria Region Records Faci I i ty

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