U-601255, Forwards Listed Documents Per Section 3.2 of Environ Protection Plan in Response to Provisional Variance Request Submitted to NRC Via

Forwards Listed Documents Per Section 3.2 of Environ Protection Plan in Response to Provisional Variance Request Submitted to NRC Via

ML20151Z565
Person / Time
Site:	Clinton
Issue date:	08/18/1988
From:	Holtzscher D ILLINOIS POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
U-601255, NUDOCS 8808300015
Download: ML20151Z565 (13)

Text

a-

, U- 601255

• _ f.

.L30-88 (08 -18 )-LP 1A.120 ILLINDIS POWER COMPANY CLINTON PoAER STATION, P.o. BOX 678. CUNTON, ILUNOIS 61727 Auguat 18,.1988 Docket No. 50-461 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Clinton Power Station Environmental Protection Plan

Dear Sir:

In accordance with Section 3.2 of the Environmental Protection Plan (EPP) for the Clinton Power Station (C?S), attached are the following documents which are in response to Illinois Powe'r's (IP) provisional variance request (submitted to the Nuclear Regulatory Commission via a letter dated July 26, 1988):

a) The Illinois Environmental Protection Agency recommendation b) The opinion and order of the Illinois Pollution Control Board c) IP's submission of Certificate of Acceptance and Agreement Please contact me if you have any questions on this submittal.

Sincerely yours, 3.;r /L D. L. Holtzscher Acting Manager - Licensing and Safety DW/bjc Attachments cc: NRC Clinton Licensing Project Manager NRC Resident Office Regional Administrator, Region III, USNRC l Illinois Department of Nuclear Safety -, -l

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I BEFORE THE ILLIN0IS POLLUTION CONTROL BOARD .

ILLIN0IS POWER COMPANY

)

CLINTON POWER STATION,

)

Petitioner,

)

v. ) PCB 88-ILLIN0IS ENVIRONMENTAL PROTECTION AGENCY,

)

Respondent.

N0TICE T0: Dorothy Gunn, Clerk Jene L. Robinson Pollution Control Board Manager Environmental Affairs State of Illinois Center Illinois Power Company 100 W. Randolph, Suite 11-500 500 South 27th Street Chicago, IL 60601 Decatur, IL 62525-1805

(

l PLEASE TAKE NOTICE that I have today filed with the Office of l the Clerk of the Pollution Control Board the PROVISIONAL VARIANCE-AGENCY REC 0fmENDATION j

l of the Illinois Environmental Protection Agency, a copy of which is i herewith served upon you.

ENVIRONMENTAL PROTECTION AGENCY I 0F THE STATE OF ILLIN0IS BY: Y.,0 .

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_ Stepfien C. Ewart b Attorney Enforcement Programs p g i

Ava o2 g

0 ATE: August 1, 1988 E' $ag -

i Agency Fil #:

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• 2200 Churchill Road #4 i P.O. Box 19276 Springfield, IL 62794-9276 2-

_ _ 217/782-5544 . _ _ _ _ _ _ _ _

BEFORE THE: ILLINOIS POLLUTION CONTROL BOARD

(

ILLIN0IS POWER COMPANY )

CLINTON POWER STATION, .

)'

Petitioner- )

)

v.. ) PCB 88-

)

ILLIN0IS ENVIRONMENTAL ) .

PROTECTION AGENCY )

Respondent )

AGENCY RECOMMENDATION The Illinois Environmental Protection Agency (Agency) recomends that a variance from 35 11. Adm. Code 302.211 and Part 303 be granted subject to the conditions set forth in paragraph 11 below. - ACTION MUST BE TAKEN WITHIN 2 DAYS OF NOTIFICATION OF THIS RECOMMENDATION FROM THE AGENCY.

1. On July 25, 1988, the Agency received a request for a provisional variance from the Illinois Power Company, Clinton Power Station (Petitioner).

Petitioner is requesting a variance to allow them to "temporarily suspend, for j a period of 45 days, the effluent temperature limitations currently applied at the end of the discharge flume for discharges to Clinton Lake at Illinois Power Company's Clinton Power Station", (page 1, Petitioner Variance-Request).

Petitioner is also requesting that their 108.3 F maximum limitation sampling point be moved from the end of the discharge fiume to the edge of a 26 acre l mixing zone.

NOTE: Petitioner requested a 23 acre (800' radius) mixing zone in the  ;

main body of the lake, however, there is 3 acres of water in an inlet below the discharge fiume before the main body of water. Total mixing area requested from the Petitioner is therefore 3 acres in the inlet and 23 acres in the main i body (26 acres).

2. Petitioner owns and operates a nuclear-fuelea electrical generating

( -station located.in Clinton, Illinois. The station is designed to generate 933 net megawatts of electricity. "The circulating cooling water syste.7 is designed to deliver water from Clinton Lake to the main condenser in sufficient quantities to condense the turbine exhaust system, the turbine bypass steam, and other turbine cycle fl.ows. The components of the system that affect or monitor fiume discharge temperatures include the screenhouse, condenser, discharge' flume, and fiume monitoring building", (Exhibit H, Petitioner Standard Variance Request).

The screenhouse consists of six bar grills, six traveling screens, and three circulating cooling single stage vertical column centrifugel pumps. Each circulating cooling water pump has a design capacity of approximately 446 cfs (288 MGD). Total cooling water flow of the three pumps is 1338 cfs (864 MGD).

The discharge fiume conveys circulating cooling water and service water from the station to Clinton Lake. The fiume discharges into the Salt Creek leg of Clinton Lake. The Lake then acts as a heat sink, dissipating the heat.

3. PCB 81-82 issued May 21, 1981 which has been incorporated into Petitioner's NPDES permit states that the daily average discharge temperature of discharges to Clinton Lake from the Power Station "shall not exceed 99'F during more thm 12 percent of the hours in twelve-month periods ending with any month and shall at no time exceed 108.3 F", (Special Condition #4, NPDES permit). The 99'F limitations for no more than 12 percent of the hours in a twelve month period provides Petitioner 44 days to exceed the 99'F limit.

Sampling must be performed at the end of the discharge fiume.

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4. Petitioner has indicated that on July 18, 1988 one of the circulating cooling water pumps failed resulting in reduction of approximately 446 cfs (288 MDG) of circulating cooling water flow and that this circulating water pump will remain out of service until August 6, 1988.

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5. . Petitioner has stated that "during the period of two circulating i-water pump operation, average daily fiume discharge temperatures have an,d will continue to exceed 99'F", (page 7 Provisional Variance Request). Petitioner believes that because of the loss of this pump their limit of not to exceed 99'F as an average discharge temperature will be reduced from 44 days to 11 days by August 4, 1988 Petitioner has stated that this reduction would limit operation of the power station through September even with the additional days they will recover during August and September. The Agency agrees with this statement.

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6. Petitioner has stated that "depending upon the cooling that may occur in the discharge flume, discharge fiume temperatures should approach the 108.3 F  !

. limitation of the Board under normal three circulating water pump operation as intake water temperatures approach 84 F", (page 8 Provisional Variance Request).

Petitioner has based this statement on the assumption that the cooling process raises the cooling water 24 F from the intake temperature while actual plant data I

has shown this not to be the case (see chart below; data obtained from Petitioner's  !

Attachment 1).

1 CLINTON POWER STATION i

Ave. Max. Cooling Daily Ave. Daily Water Daily Power Flume Temp. I Levels Intake Discharge Difference Date (P/o) Temo. (

• F) (*F) (*F)

July 1, 1988 100 75 96 21 July 2 100 75 96 21 July 3 98 76 96 20

, July 4 100 77 98 21 July 5 100 78 100 22 July 6 100 81 102 21 July 7 100 81 103 22 July 8 100 81 102 21 July 9 100 83 103 20 July 10 98 83 102 19 July 11 100 82 102 20 July 16 95 84 103 19 Average 99 79.6 100.3 20.6

As can be seen from the chart above, the. cooling process of the plant during

[ the above period of time raised the temperture of the intake water on an average of 20.6*F when all three cooling pumps were running and when power levels were running 95% or higher. Using the actual operation data presented above and assuming a 22*F- raise in temperature (highest water temperature raise on these dates) the water. intake temperature would need to reach 86*F before the Petitioner's maximum fiume discharge will reach 108.3*F not 84*F as the Petitioner suggest.

7. If the Petitioner's request was granted to move the sampling location for the 108.3*F effluent temperature limitation from the end of the discharge flume to the edge of a 26 acre mixing zone it would result in granting the Petitioner a much higher effluent temperature than their current NPDES permit allows when measured at the end of the discharge fiume. The Agency believes that this is outside the-i scope of a provisional variance and should be addressed in the standard variance l

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petition currently before the Board from the Petitioner.  :

8. Petitioner has stated that in order to meet the daily average fiume discharge of 99*F for no more than 12% of the hcurs in a twelve-month period I they may need to derate as much as 55 percent at full circulating cooling water flow. The Petitioner has indicated that this amount of derating would impose an arbitrary and unreasonable hardship. Tne Agency is supporting this hardship based l on the 99*F average discharge limitation only.

9. There are no public water supplies which would be adversely affected by granting this provisional variance.

10. There are no federal laws which would preclude the granting of this variance.

11. The Agency recommends that Illinois Power Company, Clinton Power Station be granted a provisional variance from 35 11. Adm. Code 302.211 and Part 303 subject to the following conditions:

I

a.

This variance shall commence on the date of the Board Order and ' continue

( for 45 days.

b. During the variance the 99*F average. daily temperature limitation on the fiume discharge be inscended such that if Petitioner's effluent exceeds the 99*F, during the provisional variance period, these days shall not be counted toward the 44-day limitation imposed by the Board's 81-82 Order.

c. The 108.3*F maximum daily average thermal limit shall still be applied at the end of the discharge fiume.

d. The monitoring program proposed by the Petitioner in Attachment 4 of their provisional variance petition be inacted,

e. The Petitioner shall also monitor water temperature (same frequency as condition d above) at the edge of the 3 acre inlet just before this inlet water mixes with the main body of the lake.

f. Within 10 days of the date of the PCB Order, Petitioner shall execute and submit a Certificate of Acceptance and Agreement'shall be sent to Mark T. Books at f

the address indicated below:  !

Illinois Environmental Protection Agency 2200 Churchill Road ,

P.O. Box 19276 '

Springfield, Illinois 62794-9276 I Attn: Mark T. Books ILLIN0IS ENVIRONMENTAL PROTECTION AGENCY BY: ( p 8/ e > M, Delbert D. Haschemeyer Deputy Director Date: I-/- 7#f MTB:bab

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STATE OF ILLIN0IS ) .  ;

)  !

COUNTY OF SANGAMON )

i PROOF OF SERVICE I, the undersigned, on oath state that I have served the attached ,

PROVISIdNAL VARIANCE - AGENCY RECOMMENDATION upon the person to whom it is directed, by placing a copy in an envelope addressed to:

Dorothy Gunn, Clerk Jene L. Robinson Pollution Control Board Manager Environmental Affairs State of Illinois Center Illinois Power Company 100 W. Randolph, Suite 11-500 500 South 27th Street i Chicago, IL 60601 Decatur, IL 62525-1805 (AIRBORNE EXPRESS) (CERTIFIED MAIL) .

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and mailing it from Springfield, Illinois on Aucust 1 ,

192, with sufficient postage affixed as indicated above.

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SUBSCRIBED AND SWORN TO BEFORE ME this /M day of bw/ , 1988. l f

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4 BARBARA K. McGE ll

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• NoTAmy PUauC STATE OF fLUN0f8 * '

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ILLINOIS POLLUTION' CONTROL BOARD I August 4, 1988 ILLINOIS POWER COMP ANY )

CLINTON POWER STATION, )

)

Petitioner, )

)

v. ) PCB 88-118

) I ILLINOIS ENVIRONMENTAL ) )

. PROTECTION AGENCY, .)

)

Respondent. )

l OPINION AND ORDER OF THE BOARD (by J.D. Dumelle): 1 This matter comes before the Board upon receipt of the August 2, 1988, provisional variance recommendation by  !

Respondent, Illinois Environmental Protection Agency (IEPA). l l

Petitioner, Illinois Power Co., Clinton Power Station '

requests a provisional variance from the provisions of 35 Ill.

Adm. Code 302.211 and Part 303 for a period of 45 0 days.

Petitioner is also requesting that their 108.3 0 maximum limitation sampling point be moved from the end of the discharge flu. s to the edge of a 26 acre mixing zone.

Petitioner owns and operates a nuclear-fuelded electrical generating station located in Clinton, Illinois. The station in designed to generate 933 not megawatts of clectricity. The circulating cooling water system is designed to deliver water f rom Clinton Lake to the main condenser in sufficient quantities to condense the turbine exhaust system, the turbine bypass stream, and other turbine cycle ficws. Petitioner's current NPDES permit states that of discharges to Clinton Lake the daily "shallaverage discharge not exceed temperature 99 F during more than 12 percent of the hours in a twelve-month period ending with any month and shall at no time exceed 108.3?F.

Petitioner has indicated that on July 18, 1988 one of the circulating cooling pumps f ailed resulting in reduction of approximately 446 cfs (288 MGD] of circulating cooling water .

flow. This pump will remain out of service until August 6, '

1988. While the pump is not in operction the average daily fiume discharge temperatures will exceed 99 F. 0 The Agency's recommendation states tha t the request to move '

the sampling location to the edge of the 26 acre mixing zone is outside the scope of a request for provisional variance and l

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6. auld be adoressed in a standard variance petition. The Board i ogrees.

The Agency's recommendation also states that it concurs with Petitioner ethat denial of the remainder of the requested provisional variance would impose an arbitrary and unreasonable hardship. The Agency recommends that the provisional variance be granted t/. abject to certain conditions. The Board concurs.

The Board does hereby grant the Illinois Power Company, Clinton Power Station a provisional variance f rom 35 Ill. Adm.

Code 302.211 and Part 303 subject to the following conditions:

a. This variance shall commence on the date of the Board Order and continue for 45 days.  !

b. During the variance the 99 0 F average daily temperature )

limitation on the flume discharge be suspended such that if Petitioner's effluent exceeds the 99 F, during the provisional variance period, these days shall not be counted toward the 44-day limitation.

c. The 108.3 ? maximum daily average thermal limit shall still be applied at the end of the discharge fiume.

d. The monitoring program proposed by the Petitioner in )

Attachment 4 of their provisional variance petition be enacted.

e. The Petitioner shall also monitor water temperature (same f requency as conditior, d above) at the edge of the 3 acre inlet just before this inlet water mixes with the main body of the lake.

f. Within 10 days of the date of the Board's Order, Petitior <r shall execute a Certificate of Acceptance and Agreement which shall be sen* to Mark T. Books at the addrest indicate 3 indicated below:

Illinois Environmental Protection Agency 2200 Churchill road P.O. Box 19276 Springfield, IL 62974-9276 ATTN: Mark T. Books This variance shall be void if Petitioner fails to execute and forward the certificate within the ten day period. The ten day period shall be held in abuyance during any period that this matter is being appealed.

The form of said Certification shall be as follows:

v.. .. .

CERTIFICATION I, (We), Illinois Power Company, Clinton Power Station, having read the Order of the Illinois Pollution Control Board, in PCB 88-118, dated August 4, 1988, understand and accept the said Order, realizing that such acceptance renders all terms and conditions thereto binding and enforceable. .

Petitioner By: Autnorized Agent Title Date IT IS SO ORDERED.

I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control ^

the above Order was adopted on Board, the her #ebv_

4 certify day ofthat du- -# , 1988 by a vote of 9-0 . V

' A p. ,

Dorothy M.fyunn, Clerk Illinois Nilution Control Board

, , 0-600564 LO4-88(08-11)-L 8F.120 ILLINDIS POWER COMPANY 500 SOUTH 27TH STREFT, oECATUR, ILLINolS 62525 1805 -

August 11, 1988 Illinois Environmental Protection Agency Division of Water Pollution Control 2200 Churchill Road P. O. Box 19276 Springf: eld, IL 62974-9276 Attention: Mr. Mark T. Books Environmental Protection Specialist Compliance Assurance Section

Dear Mr. Books,

Clinton Power Station Illinois Pollution Control Board Order 88-128 Submission of Certificate of Acceptanca and Agreement In accordance with the referenced order, enclosed pleased find a signed and executed Certificate of Acceptance and Agreement acknowledging our understanding of and agreement with the order and its conditions.

MM W

' Thomas L. Davis, P.E.

Supervisor - Environmental Engineering TLD19:cis 6

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< s Before the ILLINOIS POLLUTION CONTROL 30ARD ILLINOIS POWER COMPANY )

(Clinton Power Station), )

)

Petitioner, )

) PCB 88-118

v. )

)

ILLINOIS ENVIRONMENTAL )

PROTECTION AOENCY, )

)

_ Rsspondent. ..) . . _ --- -. - - - - - - -- - - - - -

CERTIFICATE OF ACCEPTANCE AND AGREEMENT Manager, Environmental Affairs Dept.

The undersigned, Jene L. Robinson hereby states that he is the of Illinois Power Company ("IPC") and duly authorized to execute this Certificate on i:s behalf.

He further states that he has read and understands the Order of the Pollution Control Board entered on August 4,1988 in the above-captioned case and that IPC accepts and absces to comply with each of the conditions of that Order during its term.

Dated: August 9,1988 Illinois Power Company

( Q .$f w Y W L By: Manager, Environmental Affairs Dept.

Title y

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