-------
416
J-, C-. Geyer
We believe that the work being carried out for
EEI by Johns Hopkins represents a significant addition to
the body of knowledge concerning the effects of thermal
discharges. EEI has committed over $1 million to this
work, and this amount has been multiplied by expenditures
of individual companies involved in cooperative efforts
at field sites. We have asked Dr. John Geyer and Dr. Loren
Jensen to describe the work which has been done under
EEI sponsorship and to make any additional comments which.,
based on their professional experience, they may feel are
appropriate.
I would like to introduce Dr. Geyer at this
time who will make a few comments and then in turn
introduce Dr. Jensen.
STATEMENT OP DR. JOHN GEYER, DIRECTOR,
PHYSICAL STUDIES, THE JOHNS HOPKINS
UNIVERSITY, BALTIMORE, MARYLAND
DR. GEYER: Thank you, Jack.
Mr. Stein, conferees, and ladies and gentlemen,
it is a pleasure to be asked to participate in this
discussion of thermal effects. We have prepared a statement
that Dr. Jensen will read for you. I would like to say at
-------
417
J. C. Geyer
the outset, the principle that guided us in developing the
cooling water studies for the Edison Electric Institute
was that we would have to get out in the field to find
out what goes on, that you can't study the environment in
the laboratory very satisfactorily. And so, both in our
physical and biological studies, we have taken the laboratory
out into the field, even to the extent of having microscopes
in rowboats so that we could look at what was going on
in the water in terms of biological behavior of the critters
right at the time they are taken out of the water.
Now, we have prepared a number of reports of
which I have three of the latest ones here, that are
available from the Edison Electric Institute. Our
biological studies have been going forward for a couple of
years so it will be another month or two before the first
reports on our field biology begin to appear, and they
will come out station by station as we work up the data
for the three places which the staff are studying, and
three others in which we are cooperating with the staffs
of the industries in biological studies.
The last report is "Surface Heat at Power Plant
Cooling Lakes." This analyzes three or four of the eleven
sites where we are working.
"Effects of Elevating Temperature Upon Aquatic
-------
J. C. Geyer
Invertebrates." That follows up an earlier one on
effective temperatures on fish.
"Field Sites and Survey Methods." A report
which describes the places that we are making these
studies and the manner in which the studies are made,
and the data processed.
Now, the details will be expanded a little bit
by Dr. Loren Jensen who is in charge of the biological
aspects of these studies, and, of course, the biology is
the whole story really. We are interested in temperatures
only insofar as they may affect the ecology of the
environment.
MR. STEIN: Thank you, Dr. Geyer. You know,
I am glad to see that you have reduced Johns Hopkins to
human proportions, and you have microscopes in rowboats.
When you used to have a man there who could walk water
like Dr. Abel Wolman* — he used to put rowboats in
microscopes.'
*Wolman, Abel
Professor Emeritus
Sanitary Engineering, Johns Hopkins University
Baltimore, Maryland
-------
419
L. D. Jensen
STATEMENT OF DR. LOREN D. JENSEN,
DIRECTOR, BIOLOGICAL STUDIES, THE
JOHNS HOPKINS UNIVERSITY, BALTIMORE,
MARYLAND
DR. JENSEN: Mr. Stein, conferees. The Johns
Hopkins University has conducted field research activities
relative to the discharge of heated effluents into surface
waters for the Edison Electric Institute specifically in
this field since 1965. Initial phases of this program
were directed towards physical aspects of heat dissipation
from surface waters.
The objectives of the physical program of the
Cooling Water Discharge Project include:
1) Evaluation of the roles of advection, dilution
by mixing, and surface cooling in the overall dissipation
of heat in the environment, by analyzing field data from
operating thermal discharges on a nationwide basis.
2) Development of computer modeling techniques
for simulating the flow behavior of receiving waters and
for predicting temperatures near proposed thermal discharges.
3) Development of operations research
techniques for optimizing the selection of locations for
-------
420
L. D. Jensen
proposed thermal discharges subject to receiving water
temperature constraints.
Although the above three objectives appear to form
a sequence in which output from preceding work becomes
input for the following objective, for various reasons it
has been considered desirable to proceed towards all three
objectives concurrently. Progress since 1965 on this work
may be summarized as follows:
1) Establishment of field survey instrumentation
and data collection systems at eleven sites of existing
thermal discharges was published in Report No. 3, available
as Dr. Geyer has previously mentioned, entitled "Field
Sites and Survey Methods" in June 1968. Physical and
meteorological data have been collected since 1966 from
these eleven sites, which are located at various latitudes
in the United States.
In most cases, these data were recorded
continuously through use of recording instruments located
within and adjacent to surface waters used for cooling
purposes. Synoptic data gathered from a large number of
stations, supplements data from continuously recording
instruments.
2) Results of analyses of rates of surface
cooling at three of the eleven field sites were published
-------
421
L. D. Jensen
in Report No. 5, as Dr. Geyer also mentioned just a moment
ago, entitled "Surface Heat Exchange at Power Plant
Cooling Lakes," in December 1969. This report describes
the methods and results of analyses of surface heat
exchange using 3 years of field data from three recirculated
cooling lake sites in south-central United States. The
procedure for preparing the data for analyses by computer
is summarized and followed by a comprehensive description
of the methods used for evaluating rates of surface heat
dissipation in terms of the surface heat exchange
coefficient, K, and the equilibrium temperature, E.
The results of these evaluations indicate:
1) That the capacity of a cooling lake to
dissipate heat to its atmosphere during periods of low
wind speed is, contrary to the findings of some previous
investigations, quite appreciable, and
2) That the equilibrium temperature may be
estimated reasonably accurately simply by adding to the
dewpoint temperature the quotient obtained by dividing the
gross solar radiation by the exchange coefficient.
This work has considerable significance for the
design and performance analysis of power plant cooling
lakes. Further, the exchange coefficient is currently being
used to evaluate hydraulic diffusion rates near thermal
-------
422
L. D. Jensen
discharges into other types of receiving waters such as
lakes, rivers, and estuaries.
3) Development of a preliminary integer
programming model for optimal location of thermal power
plants is currently in publication as Report No. 6, soon to
be released, entitled "An Optimal Location Model for
Thermal Plants with Temperature Constraints."
4) Development of a new technique for digital
simulation of thermal discharges in three dimensions is
now well advanced and is currently being applied to the
evaluation of rates of turbulent diffusion (using the
collected field data) at river sites. Future reports will
cover application of this computer modeling technique to
thermal discharges into lakes, estuaries and ocean sites,
after field calibration has been completed.
As far as thermal regulation of Lake Michigan is
concerned, the results of the physical program of this
project to date permit the following observations:
1) If the surface area of Lake Michigan is
assumed to be 22,000 mi.2 and the prevailing surface
cooling coefficient (Report No. 5) is assumed to be
32 MW/mi. °F., then a mean surface temperature increase of
1°F. would cause the dissipation of heat to the atmosphere
at an increased rate of 700,000 MW (i.e. 32 x 22 x 10^).
-------
423
L. D. Jensen
At current system thermal efficiencies (35$), this corresponds
to a theoretical electrical generating capacity of about
2 x 10° MW (which is equal to about one-third of the
current world rate of fuel energy combustion by man). This
figure is immense, by man's standards, not so much because
the surface cooling capacity of water is high per unit area,
but because in this case the available lake surface area is
extremely large.
2) Because of the rapid decay of excess
temperatures that occurs near thermal discharges into open
waters, the theoretical heat assimilative capacity
estimated above could not be achieved in practice without
some regions near the discharges exhibiting higher-than-
average excess temperatures, and other more distant regions
exhibiting lower-than-average temperatures. Thus, the
question of realistic temperature regulations for such a
water body must take into account:
a) The rates of decline of excess temperatures
near individual thermal discharges due to the combined
effects of advection, mixing, and surface cooling,
b) The integrated time-temperature exposures of
biological organisms entrained in the condenser flow
both before and after discharge,
c) The ecological consequences of the biological
-------
424
L. D. Jensen
responses to these temperature histories, and
d) The seasonal variations in the above factors.
Work on the physical aspects of these factors is
proceeding in conjunction with the project's biological
program.
Biological data collection was initated in 1968
at three utilities in the mid-Atlantic area. These
studies represent collaborative investigations with individ-
ual utilities (Duke Power Company, Delmarva Power
Company, and Virginia Electric Power Company), State
resource agencies, local university scientists, and The
Johns Hopkins staff of biological and engineering
specialists. Field data have been collected over the past
2 years on a year-round basis with hydrological and
meteorological data being recorded on a continuous basis.
In 1969, three additional sites were added to
the project (Allen S. King site of Northern States Power
Company, Wabash River Station of Public Service Indiana,
and the Pittsburgh Station of Pacific Gas and Electric
Company). These new sites represent previously existing
environmental research projects in which the Hopkins project
staff are assisting in the data collection and analysis
with the respective research staffs of each site.
The biological investigations have had two
-------
425
L. D. Jensen
principal objectives. A first objective has been the
study of populations of aquatic organisms (fishes, plankton,
and benthic invertebrates) residing in the mixing zones
for thermal discharges. These populations are being
compared with those in similar areas that are not thermally
influenced (i.e., upstream or distant stations). Changes
in species diversity and population size fluctuations are
under detailed surveillance with the objective of under-
standing the temporal and spatial distribution of
significant aquatic organisms in relation to real thermal
outfalls.
A second objective has been to study the effects
of entrainment of microscopic organisms in waters used for
cooling at these same stations. This work involves
detailed comparisons of micro-biota before and after passage
through cooling systems.
Results of the biological aspects of this
research have been interesting. The populations of
aquatic organisms located in thermally influenced zones
of the three sites (an estuary, a tidal river, and a lake)
have very little variance with those of comparable
habitats lacking influence from artificial thermal sources.
During warmer summer periods in the mid-Atlantic (July
through September) fish population densities in discharge
-------
if'26
L. D. Jensen
canal areas are reduced apparently due to avoidance behavior
in response to higher discharge temperatures (95 to 110°P.).
Comparisons of planktonic populations reveal that
during summer periods some species of microcrustaceans are
affected by the higher summer discharge temperatures in
ways which we are currently attempting to clarify. In
contrast, during cooler months (November through May)
intake discharge comparisons do not reveal statistically
different results.
Chlorination schedules and levels are being used
to study their effects on microscopic animal life
during such passages through the cooling systems.
Phytoplankton studies involving rates of photosynthesis
before and after passage through cooling systems are also
under review. Tentative data suggest that, during
summer periods, some reduction in the photosynthetic rates
in discharge waters may occur. Winter and spring
photosynthetic rates in discharge waters are higher than
intake waters, suggesting an increase in productivity
during cooler periods. Comparable rates in downstream
mixing and cooling areas do not show large variance from
control areas upstream from intake areas.
These data are under continual analysis and
review with appropriate changes in collection techniques,
-------
427
L. D, Jensen
observation and culture techniques, etc., being made as
warranted. Similar entrainment studies are either under
way or planned for the three secondary sites to augment
existing data programs.
In summary, our studies have not revealed
conspicuous biological changes in populations of aquatic
organisms residing in waters influenced by power plant
discharges. It is becoming obvious that our observation
techniques and data analysis will require careful super-
vision to locate and describe less obvious and subtle
biological changes, if and when they occur.
MR. STEIN: Thank you, Dr. Jensen.
Are there any comments or questions?
MR. GURRIE: Yes, Mr. Chairman.
MR. STEIN: Yes, Mr. Currie.
MR. GURRIE: Are you trying to say, Dr. Jensen,
that even within the mixing zones there will be no
significant change in the biota?
MR0 JENSEN: The questions we are asking relative
to that is: What are the temporal and expansion changes of
significant species, that is, species known to be important
in the local biology wi ,ain the mixing zonesv And we can
see effects on the discharge side of the condensers, as
I mentioned here, during the warmer summer periods.
-------
L. D. Jensen
Our research is currently attempting to verify
whether these effects are serious to the local biology
involved immediately adjacent to the power plant or
whether they are mitigated by reproductive potential on
the part of the species involved.
MR. CURRIE: Well, I would like to call your
attention to some testimony that was presented before our
Board by Dr» Edward Raney on behalf of the Commonwealth
Edison Company last week, in which he said that most
organisms including fish eggs will be denied some living
space in the vicinity of outfalls, and it may be fair
to characterize the type of several Edison biological
discharges by saying that Lake Michigan is a big lake,
and although small areas of it may be very seriously
affected by heated discharges, we can spare some of the
lake.
Are you trying to say that we don't even have
to give up small areas?
MR. JENSEN: I am trying to say that we have
not observed biological deserts, as we have had implied
from numerous published articles that deal with thermal
pollution. We are saying that the effects that we are
observing are not year-round when we observe them. They
are not a hundred percent effective among the populations
-------
429
L. D. Jensen
we observe them in and we are trying to clarify whether
such facts as reproductive potential of the seemingly
nonaffected organisms are involved.
In other words, we are trying to culture collec-
tions of animals that we know have been in condenser
systems to know whether their biological potential is
affected in subtle ways other than just plain death,
What other people have said regarding the exist-
ence of biological deserts downstream from thermal dis-
charges I couldn't address myself to other than to say
we have not observed uniform and year-round high death
rates.
MR. CURRIE: Well, thank you. I think that
helps to clarify what your conclusion is.
I wonder if you will be giving us at any time
some of the reports and the facts on which your conclusions
are based. I notice that there are no facts in your
current statement,
DR. JENSEN: Our work is planned through the
calendar year 1972.
MR. CURRIE: But you have conclusions in this
report already; there must have been facts.
DR. JENSEN: We have some preliminary conclusions
based on facts that have been included for the first two
-------
430
L, D. Jensen
years of the study at the sites concerned.
MR. CURRIE: Will you make those a part of the
record?
DR. JENSEN: As Dr. Geyer suggested, there are
interim reports that are currently under development now,
the first to be released in a few weeks.
MR. CURRIE: But you are making conclusions
without giving us the facts on which you base them.
DR. JENSEN: Well, the data that were used for
drawing these conclusions for this presentation today are
in these interim reports which will be available for
distribution on a nationwide basis as soon as they are
out of the printer's hand,
MR. STEIN: Are there any other questions?
Your reports won't be completed until 1972?
DR. JENSEN: Our field collection of data is
planned through the end of 1971 and our reports are
anticipated to be resolved — our final reports — during
the calendar year 1972.
MR. STEIN: When did you think in 1972?
DR. JENSEN: Presumably late in the spring or
early in the summer period.
MR. STEIN: You suggest wo wait until then
before we come to a conclusion?
-------
431
L. D. Jensen
DR. JENSEN: No, sir, I do not.
MR. STEIN: In other words, we have to move now.
DR. JENSEN: That is correct.
MR0 STEIN: Let me go back. You talk about an
estuary near the mid-Atlantic States. What estuary did
you work with?
DR. JENSEN: The lower Chesapeake Bay.
MR0 STEIN: What kind of estuary are you working
with?
DR. JENSEN: This is the James River below
Richmond.
MR. STEIN: And what lake?
DR. JENSEN: This is Lake Morgan, above
Charlotte, North Carolina, of about a million—acre—feet-
volume capacity.
MR0 STEIN: How much acre feet is Lake Michigan?
DR. JENSEN: I can't tell you exactly.
MR0 STEIN: All right. In other words, we get
the lower Chesapeake Bay salt water operation, the James
River, which is at least brackish, and a lake which is a
fraction of Lake Michigan, and you want us to utilize
these findings to make judgments on Lake Michigan?
DR0 JENSEN: No, sir. I am only saying that
in relation to observed biological effects downstream from
-------
432
L. D. Jensen
thermal discharges, one has to be very careful in projecting
laboratory results into ecological projections.
MR. STEIN: Well, we recognize this. But you
cited these; I didn't cite these. You cited an estuary, a
tiny river, and a little lake, as compared to Lake Michigan
on the mid-Atlantic. It IG a reference point to what we
are doing on Lake Michigan.
Now, if we are going to take due care to extrapo-
late laboratory results to field studies, what kind of
comparison do you think we could do to take a salt water
or brackish water and a relatively small lake compared to
Lake Michigan?
DR. JENSEN: It seems to me that the research
objectives, the methods of formulating the studies by
going out into thermal discharges and actually making
some measurements can be translated from one area of the
country to another.
MR. STEIN: Would you care to make —
DR0 JENSEN: Of course, the local biology is
going to vary and I am not suggesting that you can trans-
late from the Chesapeake Bay or from North Carolina to
Lake Michigan. I am suggesting that you can go out and
look into thermal discharges.
MR. STEIN: In other words, you say your study
-------
433
L. D. Jensen
does not reveal conspicuously logical changes in populations
of aquatic organisms residing in water influenced by power
plant discharges.
Now, some of these power plants intend to raise
their water maybe by 10, 12, 14, 1$ degrees. Since this
cannot be demonstrated, are you suggesting that we let
them go ahead?
DR. JENSEN: No, I am suggesting that you go out
looking at some existing thermal discharges in the Great
Lakes, those in Lake Michigan — if you can possibly do
so — before you come to a final conclusion.
MR. STEIN: Well, how long do you think this
would take?
DR. JENSEN: It would seem to me that that would
have already been done by now.
MR. STEIN: But you don't think we have done it?
DR. JENSEN: Well, I have not heard it mentioned
today.
MR. STEIN: Well, do you think you have done it?
DR. JENSEN: Excuse me?
MR. STEIN: Do you think you have done it?
DR. JENSEN: No, I am not suggesting we have
done it.
MR, STEIN: In other words, you are not suggesting
-------
434
L. D. Jensen
that any material you have presented here applies to Lake
Mi chigan.
DR. JENSEN: I am saying that in the Lake
Michigan area there ought to be data that is applicable
to Lake Michigan.
MRo STEIN: But nothing that you have given us
here applies to it.
DR. JENSEN: That is correct. My conclusions
are all based on the mid-Atlantic States.
MR. STEIN: Thank you.
Any other questions? Are there any questions
from the audience?
Thank you very much.
DR. McWHINNIE: I am Mary Alice McWhinnie from
DePaul University, Chicago, Illinois, engaged in a study
on Lake Michigan known as the DePaul EPRO Program* I
have worked in Antarctica now for 3 years. I return
within 3 weeks. My objective is the study of temperature
on living systems.
I think that there are basic elements of science
with which we are dealing, most particularly a unit in
living systems. It is imperative to recognize that
whether the organism is adaptive to aquamarine or a
freshwater environment, that it follows the same basic
-------
435
L. D. Jensen
biological laws.
I am delighted to report that organisms that die
at plus 2 degrees centigrade show exactly the same
temperature responses as do those that have a broad thermal
latitude or broad thermal tolerance.
The point I am trying to make is that I think
in the good interest of science it should be recognized
that whether the organisms are in a river, a small lake,
a large lake, or the marine environment, that they will
follow the same laws of response to temperature.
In deference to the question of Mr. Stein, I
would also like to emphasize that I do think it is critical
that the hydrography of the region be learned with respect
to the exposure field of the biotic system, not the
response of the biotic system.
Thank you.
MR. STEIN: Can you respond to that?
Are there any other comments or questions?
Thank you very much, Dr. Jensen.
Mr. Petersen.
MR. PfiTERSEN: Mr. Donald H0 Brandt, Director
of Air and Water Quality Control for Consumers Power
Company, will be spokesman for Consumers Power Company,,
Mr. Brandt.
-------
436
0. K. Petersen
The two doctors who were just on the stand
giving statements are the two doctors who will be leaving.
MR, STEIN: From now on we will withhold other
than panel comments any audience comments until all of
the power industry is completed, and they will be here to
answer questions, is that correct?
MR. PETERSEN: That is my understanding, Mr.
Chairman. If someone should be called away, the industry
will notify the Chair so that an opportunity will be given
for questioning.
MR. STEIN: Right.
Thank you.
MR. PETERSEN: Thank you, Mr. Chairman.
-------
437
D. H. Brandt
STATEMENT OP DONALD H. BRANDT,
DIRECTOR OP AIR AND WATER QUALITY
CONTROL, CONSUMERS POWER COMPANY,
JACKSON, MICHIGAN
MR. BRANDT: Mr. Chairman, gentlemen, ladies and
gentlemen in the audience, my name is Donald H. Brandt. I
am Director of Air and Water Quality Control for Consumers
Power Company.
Consumers Power Company is a Michigan utility
providing electric and natural gas service to 1,886
communities in a 30,800 square-mile area covering 6? of the
68 counties in the lower peninsula of Michigan.
MR. STEIN: Are you going to put in this whole
report or are you going to summarize it? You can put it
in in its entirety now.
MR. BRANDT: We would like it in its entirety placed
in the record.
MR. STEIN: This will be placed in the record
as if read.
(The report above referred to follows in its
entirety.)
-------
438
Consumers
Power
Company
LAKE MICHIGAN ENFORCEMENT
CONFERENCE WORKSHOP
September 28 • October 2,1970
Chicago, Illinois
-------
439
STATEMENT BY
CONSUMERS POWER COMPANY
To Be Given at
A Workshop Ancillary to the
Third Session of the
Federal-State Enforcement Conference
on Pollution of Lake Michigan
and Its Tributaries
September 28 to October 2, 1970
Sherman House
Chicago, Illinois
Presented by:
Mr. D. H. Brandt
Director of Air & Water Quality Control
Dr. J. Z. Reynolds
Environmental Surveillance Coordinator
-------
CONTESTS
I. INTRODUCTION
II. LAKE MICHIGAN THERMAL DISCHARGES AND TEMPERATURE REGULATIONS
A. SUMMARY OF EXPERIENCE WITH THERMAL DISCHARGES
(l) Known Effects of Thermal Discharges in Lake Michigan
(2) Relative Significance of Thermal Discharges in
Lake Michigan
B. STANDARDS FOR LIMITING THERMAL DISCHARGES
(l) Recommendations of National Technical Advisory Committee
(2) Various Proposals and Recommendations Related to Temper-
ature Standards
(3) Water Use Parameters and Restrictions on Uses
III. COMPANY ENVIRONMENTAL PROGRAMS
A. COMPANY SURVEYS ON THE GREAT LAKES
B. J. H. CAMPBELL PLANT BIOLOGICAL AND TEMPERATURE SURVEYS
C. PALISADES PLANT COMPREHENSIVE SURVEYS
IV. STATUS OF THERMAL DISCHARGE CONSIDERATIONS
A. POPULAR VIEW VERSUS TECHNICAL EVIDENCE
B. RATIONALE FOR CONTROLLING THERMAL DISCHARGES
(1) Probable Versus "Possible" Effects
(2) Priorities for Environmental Improvement
(3) Alternative Considerations and Economic Significance
(a) Impact of 1 F or No Heat Discharge Recommendation
(b) Palisades Plant Alternatives
V. CONCLUSIONS
-------
441
I. INTRODUCTION
My name is Donald H. Brandt. I am Director of Air and
Water Quality Control for Consumers Power Company.
Consumers Power Company is a Michigan utility providing
electric and natural gas service to 1,886 communities in a 30,800 square
mile area covering 67 of the 68 counties in the lower peninsula of
Michigan.
In order to meet the service requirements of over 1,000,000
electric customers the Company has constructed, owns, maintains and
operates an integrated electric generation, transmission and distribu-
tion system.
Presently, Consumers Power Company has several thermal
electric generating installations in the Lake Michigan Basin which are
part of this integrated network system. These are the B. C. Cobb Plant
on Muskegon Lake, the James H. Campbell Plant on Lake Michigan near
Holland and the Big Rock Point Nuclear Plant near Charlevoix. On
tributaries to Lake Michigan the Company operates the B. E. Morrow Plant
near Kalamazoo and three smaller plants in Kalamazoo, Battle Creek, and
Grand Rapids. Electric production at the last three (3) plants is
scheduled to be discontinued in the near future as a part of the Company's
program for air quality control.
Additionally, construction has been completed on the Palisades
Nuclear Plant directly on Lake Michigan, 35 miles west of Kalamazoo and it
is awaiting* an AEC operating license. Also, construction is underway on
the Ludingtom Pumped Storage hydroelectric plant, 4 miles south of
1-1
-------
Ludington, which will cycle lake waters to generate power to meet peak
system demands.
Before proceeding with my specific comments, I want to
identify, for the record, my Company's concern for the environment.
For more than 50 years, Consumers Power Company or its predecessor
companies, have demonstrated their concern with protecting Michigan's
environment. This includes careful management of more than 700 miles
of river lands. land that was denuded by the lumber interests now has
been replanted and made available to the general public. Our efforts
also include application of the more effective technologies available
to protect and improve the quality of air and water, such as the addi-
tion of electrostatic precipitators, conversion to gas and oil, and
sponsoring research and numerous environmental studies to guide us in
making decisions on these important matters.
As a public utility company, Consumers Power Company has an
obligation to its customers to provide adequate, reliable and economical
energy to meet their ever increasing energy requirements. At the same
time, it has an obligation to-protect the environment and, whenever
possible, also makes life better for the people of Michigan by develop-
ing picnic areas, campsites and other recreational facilities. We are
confident we can meet all of our obligations through the continued exer-
cise of sound business judgment, consultation and guidance by technically
qualified people, the application of appropriate control technology and
acting in a forthright manner on environmental issues. Our responsibility
to meet these obligations does not permit us the comfort, in today's
1-2
-------
social atmosphere, of refraining from comment on these vital issues,
just because the comments may be misunderstood, by some people, as
opposition to pollution abatement.
We have examined the Federal Water Pollution Control Act,
as amended, the Michigan water pollution control statute, consulted with
counsel and we have examined the February 19, 1968 opinion from the
Michigan Attorney's General's office dealing with these matters.
In view of these examinations it seems appropriate to draw
the Conferee's attention to the philosophy of the Federal Act and some
of its provisions.
1. First, Section l(b) of the Federal Act provides in
part:
"it is hereby declared to be the policy of Congress to
recognize, preserve, and protect the primary responsibilities
and rights of the States in preventing and controlling water
pollution..."
A number of Federal officials often appear to forget or
ignore this basic policy of primacy of the state regulation in their
temperature standard setting efforts.
2. The setting of standards, according to Section 10(c)
(3) requires that:
"In establishing such standards the Secretary, the
Hearing Board, or the appropriate State authority shall take
into consideration their use and value for public water sup-
plies, propagation of fish and wildlife, recreational pur-
poses, and agricultural, industrial and other legitimate
uses."
Too many Federal officials and others have ignored this
requirement to take into consideration all legitimate uses of
1-3
-------
interstate waters. Instead, they consider exclusively the propaga-
tion of fish and wildlife. The Act obviously requires a balancing of
interests and forbids the all too prevalent approach of considering
other uses of the waters only to the extent that such uses will not
limit or interfere in any way with propagation of fish and wildlife.
3. The legislative history of the Federal Act shows that
Congress rejected the principal of effluent standards. This rejection
resulted in a statute which did not confer upon the Secretary of the
Interior the power to promulgate or enforce effluent standards. Never-
theless, at the last meeting of this conference a "policy" announce-
ment of two Assistant Secretaries of the Interior was made which sought
to have effluent standards imposed on Lake Michigan. Such standards
would not be enforceable and standards to be meaningful must be enforceable.
4. Section 10(g) of the Federal Act provides that before
any enforcement action can be undertaken there must be pollution which
is endangering the health or welfare of persons. As the Michigan
Attorney General's office has pointed out, "the danger must be real and
immediate." Too many of the proposals regarding thermal discharge limi-
tations deal not with real and immediate danger to the health or welfare
of persons but a possible danger to some aquatic life. These proposals
are predicated on extremely long-range predictions regarding the use of
Lake Michigan Waters by electric utilities.
5. Sections 10(c) (5) and I0(h) of the Federal Act both
contain provisions concerning court action on pollution. Where standards
are involved the Court will make a complete review of the standards per-
taining to the alleged violation, and the Court must give due consideration
to the practicability and to the physical and economic feasibility of
-------
complying with standards or otherwise securing abatement of proved
pollution. In the words of the Michigan Attorney General's Office:
"...the government must prove that it is physically
and economically feasible to abate the particular pollution
complained of, that it is in the public interest to so abate
the pollution and that it is equitable to do so. In view of
these considerations, the Court must find not only that the
pollution exists as defined in the statute, but that it is
economically feasible, physically possible, and equitable to
order its abatement. ...it certainly would be an anomoly
to require states to adopt standards for water quality or to
take measures in the abatement of pollution if such standards
of water quality are not enforceable in a suit brought by the
US Government. It would seem that it was the Congressional
intent to require the states to adopt standards of water
quality, which if not adhered to would be enforceable in a
suit brought by the US."
Consumers Power Company has on numerous occasions endeavored
to make clear its concern for the environment. Our management has
publicly stated that if a plant is found to be harmful to the environ-
mentj the Company will act promptly to correct the situation. Further-
more, this commitment is included in the Orders of Determination issued
by the Michigan Water Resources Commission for all recently authorized
electric generating facilities. The Company also believes that unneces-
sary equipment should not be required or built simply because of unsub-
stantiated anxiety that adverse conditions might exist. To install such
equipment without first establishing the need for it would consitute an
unnecessary burden on the financial resources of our economy without
achieving a meaningful contribution to environmental quality.
I agree with Representative Craig Hosmer, Republican from
California, when he said:
1-5
-------
446
"Environmental protection does not necessarily mean
sending the world back to whence it came to be refurbished
in its original pristine condition, nor does it involve turn-
ing off air conditioners, abolishing the automobile and un-
inventing the wheel. Rather the solution lies in achieving
a satisfactory accommodation between the demands of the en-
vironment and of social benefits of technology."
This Enforcement Conference, prior to its May J, 1970 meet-
ing, was reported to have made progress by reaching an agreement between
/4
the Conferees on April Jff, 1970 on a uniform procedure for the establish-
ment of monthly maximum temperatures. The so-called one degree "policy"
statement made at the opening of the May 7 conference and the "White
Paper", belatedly issued for this conference, are not in our opinion,
of sufficient value to warrant much attention on the part of the
Conferees. The "one degree" statement clearly goes beyond reason as
well as the intent of Congress. The "White Paper", drafted over a four
month period, fails to take into account the technical data gained through
years of experience with existing thermal electric generating plants (on
the Great Lakes). Scientific studies, and actual observations of existing
heated discharges in Lake Michigan, conducted by the staff of the Michigan
Water Resources Commission and other qualified groups, have documented on
numerous occasions that these plants have been operating many years without
demonstrable adverse effects to the aquatic environment. These and other
studies being made on the basis of data obtained from actual field ob-
servations warrant careful attention of the Conferees. FWQA. is now pro-
posing to subject all electric generating plants to temperature standards
predicated on theories misapplied because of inadequate recognition of
natural ecological factors.
1-6
-------
447
Site studies made at existing plants (along the Great
Lakes) should be evaluated before subjecting them to temperature stan-
dards which may require millions of dollars of capital expenditure
because past studies and present surveillance programs offer no evidence
that these waters require greater protection.
Gentlemen, we ask that you continue on your way to reaching
conclusions supported by the law rather than emotion, and fact rather
than fancy. We are confident you will reach conclusions which will
adequately protect all of the legitimate uses of this natural resource
for future generations.
Other individuals who Consumers Power Company has asked to
present information to this workshop are Dr. John Z. Reynolds and rep-
resentatives of the firm of Sargent & Lundy Engineers.
They will present Consumers Power Company's experience with
thermal discharges into the Great Lakes, the results of studies and en-
vironmental surveillance programs and how they relate to the issue of
regulating such discharges, and our assessment of the procedures by which
such water use should be restricted.
1-7
-------
II. LAKE MICHIGAN THERMAL DISCHARGES AND TEMPERATURE REGULATIONS
A. SUMMARY OF EXPERIENCE WITH THERMAL DISCHARGES
(l) Known Effects of Thermal Discharges in Lake Michigan
In recognition of a need for data collected from systematic
surveillance, and for an expanded research effort on thermal discharges,
electric utilities around Lake Michigan have launched an unprecedented
effort to determine the effects of these discharges. Some of the studies
of Consumers Power Company will be described in detail later. It would
be appropriate at this point, however, to summarize the results of the
various studies to date, and how they relate to the issue of establishing
a basis for setting meaningful temperature standards, or otherwise limiting
thermal discharges.
Thermal discharges into the Lake Michigan Basin have existed at
numerous locations for many years. Most of these have been studied to
determine their physical behavior under various conditions and some have
been otudlod to determine thcii ph.yalc;al l)eliavTo"r under various- eottttitronf
and some have been studied to detect any related biological effects.
It has been observed in all cases that discharges that are warmer
than the ambient waters are buoyant and tend to spread into relatively
thin layers on the surface. Mixing of the thermal discharge with the
adjacent waters causes some entrainment into the plume. The relative
amount of entrainment is primarily a function of the velocity conditions
and the density differences at the interface. Theoretically, the least
amount of mixing would occur when the temperature differentials are
greatest and when the relative velocities are smallest.
II-l
-------
449
With any degree of entrainment, the resulting mixed fluid
will still he less dense than the amhient waters, and cause the com-
bined volume to be buoyant. The commonly observed plume therefore tends
to float on the surface of the lake until the excess heat has been dissi-
pated to the atmosphere.
The "White Paper" purports to make a case that a large propor-
tion of the heat from a thermal discharge is effectively mixed with the
lake to accumulate and result in unacceptably high temperatures. We
would like to cite just a few examples of the misleading way technical
reports were abstracted in the paper to document the case.
It was quoted that Hoops et al (1968) "concluded, on the basis
of work at a Lake Monona (Wisconsin) power plant, that surface heat losses
were about 5 percent of the heat discharged by the power plant; the re-
maining 95 percent was dissipated by dilution with lake water." It was
not stated, however, that this result was based on analysis of a dis-
charge, contained by a baffle, from two days of field data on January 25
and 26, 1967, during a period of significant atmospheric warming. It
might also be noted that these.researchers concluded from the results of
22 field surveys during the remainder of the year that "power production
increases of less than 100$ will have a negligible effect on ... lake
temperatures."
Work by Palmer (1969) was cited as supporting the notion that
excess heat diffuses into the lake, as opposed to any significant atmos-
pheric losses occurring. Our review of the paper failed to identify any
point that would support this view. His studies of a cooling water dis-
charge into Lake Ontario showed "that the warmer water stays near the
II-2
-------
450
surface and the shore. The subsurface cooling water had acquired lake
temperature by ^,000 feet while the surface cooling water (was) still
h F warmer than the lake water at U,000 feet." Model studies were cited
that assumed no atmospheric heat transfer, to simplify, in a conservative
way, the mathematical predictions.
Similarily, work by Sundaram et al (1969) was cited where they
"concluded that the heated discharge of the proposed Bell Nuclear Sta-
tion on Cayuga Lake (New York) would increase the average surface tem-
perature of this 66. U square mile lake about 0..7 F." The Sundaram report,
however, went on to note that "for a given amount of heat that is dis-
charged into the lake, the far-field effects will be greater if the dis-
charge temperatures were close to the ambient lake surface temperatures
than if the discharge temperatures were significantly higher than the
ambient lake surface temperatures, since in the latter case a greater
fraction of the total heat can be lost to the atmosphere directly than
in the former case."
Benedict's (1970) shoreline discharge: model of ,he Campbell
Plant and Prichard-Carpenter Consultants (1969 and 1970) computations
for Toledo Edison were cited in the "White Paper" as further support that
the "assumption of little or no waste heat loss to the atmosphere is rea-
sonable , at least during a great deal of the annual temperature cycle."
In both cases the assumption that surface heat loss was limited was
arbitrarily made to simplify the model. No evidence is given or even
implied by the original authors that this was a. realistic assumption.
H-3
-------
It's not realistic, or even honest, to use such model studies
to support such a viewpoint, when much field data, from actual installa-
tions, are available that can be used for this purpose.
No evidence has been presented of which we are aware that the
physical presence of a thermal plume on Lake Michigan has interferred
with or otherwise caused injury to any beneficial use of the waters. In
fact, the areas of heated discharge are often observed to appeal to
swimmers, since the lake waters are normally too cold for comfortable
water contact activities.
Researchers evaluating the results of biological studies that
have been conducted in the vicinities of thermal discharges in Lake
Michigan have similarly concluded that no adverse effects have occurred
as a result of this use of the waters. Electric utilities, consultants,
universities and governmental agencies have been unable to document sig-
nificant biological effects outside of the localized influences on fish
that prefer or avoid the region of increased temperature. Fishing in the
vicinities of thermal discharges has been observed to be favored for the
greater portion of the year, even for some of the so-called cold water,
heat sensitive species.
Consumers Power Company has maintained parking areas in the
vicinities of some of the plant discharges to facilitate access for
fishermen and others. We have received requests from the Fish Division
tfci
and the Bureau of Water Management of^Michigan Department of Natural
Resources to provide more facilities to accommodate the public because
of the "recreation potential in year-round fishing" in these areas.
II-U
-------
452
The only reference in the "White Paper" purporting actual evi-
dence of harmful effects of a thermal discharge into Lake Michigan con-
cerns an alleged fish kill at the Consumers Power Company Campbell Plant
on August 29, 1968. While it was indicated that a drop in temperature;
due to natural upwelling may have been a major factor resulting in the;
conditions observed, the paper does not give any indication of the scope
of the adverse condition noted.
The observations were made by John Robinson, Aquatic Biologist,
employed by the Michigan Water Resources Commission. He stated that the
water temperature at the point of discharge was 6^.U F and that the tem-
perature dropped in a short distance to 59 F and then gradually declined
to the ambient of 50 F in one-half mile. This is the lowest temperature
recorded at the plant for any day in August since the plant has been in
operation, and occurred only a few days after a water intake temperature
of T6°F had been observed.
Mr. Robinson noted there were live catfish and carp near the
discharge and schools of alewives in the area. Some dead alewives were
observed, but no estimates were made of the numbers involved. The only
other dead fish reported were a catfish and/or carp approximately every
150 feet along one mile of shoreline. This amounts to a total of about
35 fish. Apparently no sport fish were involved. Mr. Robinson concluded
that the fish affected were apparently indigenous to the long cooling
water discharge canal and that the very unusual combination of natural
temperature fluctuations was partly responsible for their condition. It
has been reported that this phenomenon of rapid natural temperature var-
iations has caused fish to be in distress at other locations, around the
Great Lakes.,
II-5
-------
453
At the recommendation of the conferees of the Lake Michigan
Enforcement Conference in 19°"8, an interagency Committee on Nuclear
Power Plant Waste Disposal was formed which reported to the conferees
in November 1968. They stated:
"The effects of localized temperature increases on the
aquatic life in Lake Michigan are impossible to predict from
the limited information available. Only a few observations
have been made to date of the effects of existing thermal
discharges on Lake Michigan biota. However, laboratory in-
vestigations and observations elsewhere suggest that increase
in temperature can result in damage to the aquatic environment."
The Committee recommended, with regard to thermal discharges,
that:
"Coordinated study of the thermal effects on water
quality and aquatic life of one or more fossil fuel plants
now discharging cooling water to Lake Michigan, and of
various methods of cooling water dispersion be undertaken
by FWPCA."
and
"FWPCA coordinate a comprehensive study of the effects
on water quality and aquatic life of thermal wastes from a
large nuclear power plant on Lake Michigan, with attention
to various methods of cooling water dispersion."
It is apparent that the Federal Water Quality Administration
(formerly FWPCA) has not carried out either recommendation of the Com-
mittee inasmuch as no notice has been made of such comprehensive studies
by FWQA. Fortunately, even before the Committee's report, the electric
utilities around Lake Michigan were concerned about the early detection
of any possible adverse effects that thermal discharges might cause.
These companies instituted comprehensive studies on their own or in coop-
eration with the appropriate state agencies. The scope and methodology of
these studies are such that it can be assured that, if harmful effects are
caused, they will be detected.
II-6
-------
(2) Relative Significance of Thermal Discharges
in Lake Michigan
The previously mentioned report of the Committee on Nuclear
Power Plant Waste Disposal to the Conferees of the Lake Michigan En-
forcement Conference included the following comment on thermal discharges
into Lake Michigan:
"In spite of the known adverse effects which tempera-
ture change can have on aquatic life, it is not certain that
they will occur in the unique environment of Lake Michigan.
Much of the shoreline is seldom inhabited "by aquatic animals
because the bottom materials consist of shifting sand. There
are rocky shoals that support game fish population. Whether
or not local increases in temperatures will accelerate the
eutrophication of Lake Michigan is uncertain at present. It
is tempting to speculate on this but only intensive longterm
studies will reveal the facts. Local increases in algal
growth very probably will develop if sufficient nutrients are
available, since biological activity is greater in warmer
than in cooler water. The magnitude of these increases must
be known before there can be evaluation of the potential
problem."
Then, after discussing the relative merits of low or high
velocity, and offshore or onshore discharges, the Committee reported that:
"A recommendation that one or the other (type of dis-
charge) be routinely required for all power plants would
have to be supported by firm information on damages to water
quality and uses that would result from failure to require
such devices. Available information on potential damages
does not provide a basis for such a position at this time.
Such information can be obtained through studies by aquatic
biologists of areas in Lake Michigan where large fossil
fuel plants presently discharge large quantities of cooling
water."
To our knowledge the biological data that have been compiled
since the Committee's report have failed to substantiate any significant
biological effects.
It is also interesting to note that in the same report, after
computing the total heat input into Lake Michigan from existing and
II-T
-------
proposed power plants, the Committee concluded that "there is minimum
need for immediate concern over the effect of temperature on the lake
as a whole." They went on to say that the probable long-range effects
deserve consideration. We agree there may be some future point at which
the effects of substantial additional thermal discharges might cause
significant effects for the lake as a whole. We demonstrate our con-
currence with their observation that the possible local effects are of
more practical and immediate concern in that our ecological investiga-
tions are largely oriented to detect such influences of thermal
discharges.
B. STANDARDS FOR LIMITING THERMAL DISCHARGES
(l) Recommendations of National Technical
Advisory Committee
"On February 21, 1967, the Secretary of the Interior
established the first National Technical Advisory Committee
on Water Quality Criteria to the Federal Water Pollution
Control Administration. The Committee's principal function
was to collect into one volume a basic foundation of water
quality criteria."
As described in the introduction to the Report of the National
Technical Advisory Committee on Water Quality Criteria dated April 1968:
"The Committee was concerned abouve several issues
relating to water quality standards for the control and
abatement of water pollution. Foremost among these is the
lack of adequate knowledge concerning many of the quality
characteristics upon which criteria and, hence, standards
should be based. The unknowns still outweigh the knowns.
Complicating factors in setting standards are varying
natural conditions affecting water quality, such as climate,
geography, and geology of a specific location. The Com-
mittee does not want to be dogmatic in recommending these
criteria. They are meant as guidelines only, to be used
in conjunction with a thorough knowledge of local condi-
tions. Further, it is anticipated that future research
will provide considerable basis for refinements in the
recommendations."
II-8
-------
456
"The Committee recognizes that the protection of
water quality for legitimate uses requires far more than
scientific information. There is an urgent need for data
collected from systematic surveillance of waters and
waste sources and for an expanded research effort."
While the Committee observed that for lakes the situation is
complex and cannot be specified in simple terms, their recommendation
for both warm and cold water lakes was that the temperature of the
epilimnion should not be raised more than 3 F by the addition of heat
of artificial origin. They further qualified that position in the case
of warm waters saying that "in those areas where important organisms are
most likely to be adversely affected, (the temperature) should not be
raised more than 3 F above that which existed before the addition of heat
of artificial origin." The committee members clearly implied that they
felt temperatures in excess of 3 F within a mixing zone were of no special
significance unless, of course, it could be demonstrated that harmful
effects would occur.
It should be pointed out that while the Committee made no
specific reference to mixing zones with regard to freshwater organisms,
in discussing criteria for marine and estuarine organisms it was stated
that the suggested temperatures were to apply outside of mixing zones,
which would be related to required zones of passage. The situation re-
garding heated discharges into very large lakes, such as Lake Michigan,
would be comparable to ocean discharges in this respect.
The Committee could be critized, however, for not making a
distinction between mixing zones involving temperature and those that
would involve contaminating substances. They stated, in effect, that
dilution flows should be very large to limit the area of mixing. While
II-9
-------
this would be generally true for contaminating substances which would
remain in the water body, discharge of heated waters involving buoyancy
effects and dissipation of heat to the atmosphere complicates the task
of defining mixing and zones of passage. The significance of the con-
figuration of the mixing zone or its dimensions can only be based on
individual site considerations and the nature of the aquatic life or
other beneficial uses to be protected.
(2) Various Proposals and Recommendations Related
to Temperature Standards
STATE ACTION - In accordance with the Federal Water Pollution
Control Act, as amended by the Water Quality Act of 19^5, the Governor
of the State of Michigan wrote to the Secretary of Health, Education and
Welfare on December 17, 1965, that it was the intent of the State to
adopt criteria applicable to interstate waters under the authority of
Act 2^5, Public Acts of 1929> as amended. The Michigan Statute declares
to be unlawful, the discharge of any substance:
"which is or may become injurious to public health,
commercial, industrial, agricultural, recreational or
other uses which are being or may be made of such waters;
or which is or may become- injurious to the value or utility
of riparian lands; or which is or may become injurious to
livestock, wild animals, birds, fish, aquatic life or plants
or the growth or propagation thereof be prevented or in-
juriously affected; or whereby the value of fish and game
is or may be destroyed or impaired."
Section 5 of the Act declares in part:
"The Commission (Michigan Water Resources Commission)
shall establish such pollution standards for lakes, rivers,
streams and other waters of the state in relation to the
public use to which they are or may be put, as it shall
deem necessary."
11-10
-------
458
In June 19&7; water temperature standards for the Great Lakes
were adopted by the Michigan Water Resources Commission (MWRC) and sub-
mitted by the State to the Federal Government for approval. It reads
as follows:
"For the Great Lakes and connecting waters no heat load
in sufficient quantity to create conditions which are or may
become injurious to the public health, safety or welfare; or
which are or may become injurious to domestic, commercial,
industrial, agricultural, recreational or other uses which
are being or may be made of such waters; or which are or may
become injurious to the value or utility of riparian lands;
or which are or may become injurious to livestock, wild
animals, birds, fish or aquatic life or the growth or
propagation thereof."
FEDERAL ACTION - Even though the temperature standards adopted
by the MWRC in 19&7 appeared to contain all the necessary restrictions
defined in the Federal Water Pollution Control Act, and met the con-
stitutional requirement that beneficial uses unrelated to any injury
could not be prohibited, the Secretary of the Interior did not approve;
them.
Then, on October 23, 1969, H. W. Poston, Regional Director of
the Federal Water Pollution Control Administration (FWPCA), U. S. Depart-
ment of the Interior, sent to R. W. Purdy, Executive Secretary of the
MWRC, a proposed Lake Michigan Temperature Standard, stating "This
standard is the result of a comprehensive review of temperature and
aquatic life data for Lake Michigan conducted by the National Water
Quality Laboratory in Duluth."
The recommendations for monthly maximum surface temperature
o
in F were:
Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
50 50 50 50 55 70 85 85 85 85 70 55
11-11
-------
No recommendations were made regarding the definition of
mixing zones and the only comments on discharge areas were related to
the possibility of fish kills and the blockage of tributaries supporting
anadromous fish.
STATE ACTION - On February 17, 1970, Carlos Fetterolf, Super-
visor of the Water Quality Appraisal Section, MWRC, reported to the
Commission that his staff had explored the reasons for disapproval of
the Michigan temperature standards by the Federal Government. He then
submitted new standards for consideration. The principal changes for
the Great Lakes involved substitution of a 5 F temperature rise limita-
tion and the setting of monthly maximum temperature values outside of
mixing zones to be defined by the MWRC. Lake Michigan was divided into
northern and southern sectors at Pentwater, Michigan. No increase would
be allowed greater than 5 F nor any temperature above 80 or 85 F for the
northern and southern sectors, respectively.
He reaffirmed the MWRC staff position that mixing zones should
be established based on individual site conditions and stated further
that Dr. Mount of the FWPCA Duluth Laboratory had questioned the advis-
ability of subjecting mixing zones to formula identification. Apparently
some FWPCA representatives had informally suggested that formulas would
be appropriate.
The MWRC scheduled a public hearing for March 19, 1970, to
review the staff recommendations. In the meantime, however, the staff
felt that approval from FWPCA could be expedited by complying with their
further request for numerical monthly temperature maximums for the Great
Lakes, and by adding some general considerations as to philosophy of
regulation.
11-12
-------
460
The proposed monthly temperature limitations for the southern
sector of Lake Michigan, for instance, in F were:
Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
50 50 60 65 75 85 85 85 85 70 60 50
The maximum temperature limit for the northern sector would
be 80°F.
FEDERAL ACTION - Representatives of FWPCA testified at the public
hearing on March 19, 1970, at which time they presented an edited copy of
the proposed State regulations. They suggested striking any reference
that mixing zones be related to the value of aquatic life and physical
characteristics of the receiving water body, and all qualifying statements
as to the extent of adverse effects. It was suggested that mixing zones
be defined by formula but should not exceed one mile in radius.
They further suggested that the Great Lakes be separated into
loosely defined open waters and inshore waters. For Lake Michigan the
recommended temperature limits for open waters in F were;
Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
U2 37 37 kh 53 65 71 7^ 72 65 5^ 50
It was pointed out at the hearing by Mr. Purdy of MWRC that
these suggested limits are exceeded, due to natural causes, on a regular
basis.
Consumers Power Company has collected a considerable amount of
temperature data from two power plants on Lake Michigan that are somewhat
representative of lake temperatures. One, the Big Rock Point Plant, has
an intake that is located 1^50 feet from shore at a depth of approximately
25 feet and would be subject somewhat to stratification influences. The
11-13
-------
461
range of maximum daily average temperatures for each month for a six year
period of record are shown on Exhibit II-A, as are the temperature limi-
tations proposed in March 1970. It should be noted that for seven of the
twelve months during this short period of record the natural intake tem-
peratures equaled or exceeded the limitations proposed by PWPCA for open
waters in Lake Michigan.
The J. H. Campbell Plant intake is located on Pigeon Lake into
which Lake Michigan water flows. From a temperature standpoint the intake
is indicative of "inshore" conditions, though some recirculation from the
discharge occurs periodically. The range of maximum daily average tem-
peratures for each month for a six year period of record is shown on
Exhibit 11-1$, with the proposed temperature limitations for open and
inshore waters. For several months the maximum daily average temperature
exceeded the proposed FWPCA limitations for every year of record. In
three months the proposed limit was exceeded by over 10 F, which would be
difficult to account for by considering the maximum effect of recirculated
discharge from the plant.
FWPCA representatives further recommended that a 3 F tempera-
ture rise outside the mixing zone be the limitation for Lake Michigan.
Their testimony supported the MWRC staff proposal that the water
resources be protected for the "optimum use by fish, wildlife and other
aquatic life," without mention of other beneficial uses. They further
recommended that "at no place in a mixing zone shall the 96-hour median
tolerance limit (96 hr. TL ) to aquatic life be exceeded." The recom-
mendation did not define what aquatic life was to be protected. No ex-
planation or justification for such a restrictive limitation was given.
-------
462
EXHIBIT II-A
BIG ROCK POINT
INTAKE TEMPERATURE
RANGE OF MAXIMUM DAILY AVERAGE
TEMPERATURE FOR EACH MONTH
OF RECORD ( 1964-1969)
FWPCA
RECOMMENDATIONS
(INSHORE WATERS)
-1 - —r
WRC STAFF
RECOMMENDATIONS
FWPCA
RECOMMENDATIONS
(OPEN WATERS)
-------
EXHIBIT II-B
463
J. H. CAMPBELL PLANT
INTAKE TEMPERATURE
RANGE OF MAXIMUM DAILY AVERAGE
TEMPERATURE FOR EACH MONTH
OF RECORD ( 1964-1969)
I
O£
LJJ
O.
FWPCA
RECOMMENDATIONS
(INSHORE WATE~RS5
WRC STAFF
RECOMMENDATIONS
FWPCA
RECOMMENDATIONS
(OPEN WATERS)
-------
464
On April 10, 1970, F. T. Mayo of the FWPCA regional office sub-
mitted additional recommendations. The suggested monthly maximum tempera-
ture limits for Lake Michigan inshore waters In F were:
Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
42 37 37 44 53 65 72 77 75 65 54 50
It was further recommended that mixing zones should not include
waters within 600 feet of shore.
STATE ACTION - After the March 1970 hearing, the MWRC released
the results of a study consisting of approximately 24,000 temperature
readings from eight Lake Michigan water intakes in Michigan which are
unaffected by heated discharges and over 300 shoreline temperatures from
20 swimming beach stations. This study was initiated after consultation
with Federal Water Quality Administration (FWQA) representatives.
At a meeting in Ann Arbor, Michigan, on April 16, 1970, it was
,^JL|pk,t-t,?3id£v<-iu%.
agreed by the Lake Michigan Enforcement Conferee* that the States and
F¥QA would tabulate existing temperature data for Lake Michigan. The
90th percentile value to be determined from this data would then serve
to establish monthly maximum temperature limitations. This information
would be the basis for discussions at the Executive Session of the Lake
Michigan Enforcement Conference scheduled to be held in Chicago on
May 1, 1970.
FEDERAL ACTION - The meeting in Chicago on May 7, 1970, although
scheduled as an executive session, actually became a public hearing. The
following statement issued by Carl L. Klein and Leslie Glasgow, Assistant
Secretaries of the Interior, was read before the Lake Michigan Enforce-
ment Conference:
11-15
-------
465
"The minimum possible waste heat shall be added to the
waters of Lake Michigan. In no event will heat discharges
be permitted to exceed a 1°F rise over ambient (existing
temperature) at the point of discharge. This will preclude
the need for mixing zones."
This declaration effectively negated the substantial efforts
of the State conferees and the staff of FWQA, during the previous months,
to resolve differences in concepts and to secure a reasonable basis for
temperature standards.
STATE ACTION - The MWRC requested FWQA to provide written
clarification of the policy statement issued by Carl L. Klein and Leslie
Glasgow, and scientific documentation which would show the need for such
a strict policy.
On September l8, 1970, the MWRC expressed its support of a re-
vised set of temperature standards, as recommended by the staff. Their
proposed maximum monthly temperature standards for the open waters of the
southern sector of Lake Michigan in F are as follows:
Jan Feb Mar Apr May June July Aug Sept Oct Nov 'Dec.
35 35 39 ^9 57 67 7^ 76 73 6U 5^ ^3
Similarly, the proposed standards for the inshore waters of
o
this sector in F are:
Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
38 38 42 51*- 63 78 82 82 80 70 60 U8
The maximum temperature limit proposed for the inshore waters of
the northern sector of Lake Michigan is 76°F.
The proposed temperature standards for inshore waters are based
on the 90th percentile, adjusted for 3°F increase at the edge of the
mixing zone.
II-16
-------
466
This recitation of exchanges between the Department of the
Interior and the MWRC has been primarily for the purpose of illustrating
the confusion that prevails concerning the adoption of temperature
standards. The sincere and honest efforts of many who have worked to
develop reasonable temperature standards, based on the technical evi-
dence, have been repeatedly destroyed by inconsistent and confused pro-
nouncements and recommendations by others.
(3) Water Use Parameters and Restrictions on Uses
It is the philosophy of the Federal Water Pollution Control Act
to assure that all waters will be equally protected for all legitimate
uses. Propagation of fish and wildlife is one of those legitimate uses.
Utilization by industry is another one. This is particularly true for
those rivers and lakes where either or both of these uses are already
established. Industry must not be allowed to pollute a body of water and
destroy the fish and wildlife that exist. Similarly, propagation of fish
and wildlife must not be .such as to destroy or pose intolerable burdens
upon the industries that utilize the waters. Vfe believe it is possible
to set standards that will satisfy both requirements.
In view of this, we objected to several statements and sugges-
tions made by the representatives of FWPCA at the March 19, 1970, MWRC
hearing regarding thermal discharges, effects, and regulations.
Their basic rationale, as stated by Dr. Donald Mount of the
National Water Quality Laboratory, Duluth, Minnesota, that "when pro-
tecting aquatic life we normally protect the waters for all beneficial
uses," and their suggestion that the 96-hour median temperature tolerance
11-17
-------
1*67
limit to aquatic life not be exceeded at any point, is meaningless unless
related to specific aquatic life to be protected.
Dr. Mount's statement, that "fishes are repelled by temperatures
that are unacceptably high during the summer months and, therefore, these
pose no particular problem except that the habitat available is reduced
in area," is clearly inconsistent with the PWPCA position taken at the
same meeting that at no point should temperatures exceed values that have
been shown to cause detrimental effects in confined laboratory conditions.
Likewise, a rigid definition of lake mixing zones based solely
on a rate of discharge, as they suggested, does not recognize either the
potential effects of thermal discharges on aquatic life or a beneficial
use concept. Dr. Mount's brief statement that "every mixing zone should
be defined geographically," oversimplifies the ecological complexity of
the waters involved, as does the FWPCA recommendation that uniform tem-
perature limits should be imposed on each of the Great Lakes.
Dr. Mount was concerned that fish residing in warmwater effluents
during the winter be protected in case the plant must be shut down. The
fish that are most likely to inhabit.thls relatively small area would not
find the normally cold lake temperatures suitable. As such, these warm-
water areas provide for greater diversity of fish habitat for the lake as
a whole, and, although these fish might be temporarily adversely affected
by plant shutdown, the natural populations should not be significantly
affected.
Similarly, the importance of maintaining the "normal daily
fluctuations" for the Great Lakes has been overstated in the various
proposed standards, in view of the great natural temperature fluctuations
II-18
-------
468
that occur from day to day. This situation is described in the "White
Paper" and is well documented in the records of the staff of the MWRC
and others.
While the FWPCA concept in March 1970, of differentiating
between inshore waters and open waters is ecologically sound, the
definition set forth by FWPCA was not complete enough to allow for
confident prediction of these limits, either spatially or tempora^
They stated simply that "inshore waters are those waters which are
affected by tributary stream plumes (other than connecting channels),
near shore thermal bars, natural shore erosion, or bottom sediment
resuspended by wave action. Waters not defined as inshore waters would
be considered as open waters."
The "White Paper" now defines the inshore zone as "that volume
of water which lies between the shoreline and the 100-foot depth contour,"
and includes what is called a "beach water zone, a sub-area that extends
from the shoreline out to the 30-foot depth contour." This vacillation
in establishing basic definitions does not facilitate efforts to set
standards.
Whether for inshore or open waters, any temperature regula-
tions should reflect naturally occurring conditions, and allow for
variations consistent with those known to occur without any thermal
discharges.
It was pointed out at the March 1970 hearing that a 58 F
limitation, as proposed by FWPCA for migratory routes of salmonid species
during migration, was unrealistic considering the fact that healthy mi-
grations occur in 70 F water. Similarly, lake water temperatures should
11-19
-------
not be arbitrarily restrictive, in view of the fact that extreme tempera-
ture excursions have occurred in the past by natural and artificial means,
with no apparent damage to the aquatic ecology.
Dr. Mount made the statement, when questioned about the natural
conditions exceeding his recommendations, "that if the temperature is
unacceptable, it is unacceptable whether it has been caused by the sun
or man." This should cause us to pause and consider the nature of the
situation. Because if the artificial aquatic habitat mankind has nurtured,
in the lakes particularly, is truly unsuited to this climate, the concept
of beneficial use of these waters by all citizens should receive prompt
15
and thorough revieww According to the law, other beneficial uses should
vt
not be placed in jeopardy because an especially delicate fishery has
been developed, as Dr. Mount suggests.
Consumers Power Company is convinced that this is not the situa-
tion, and based on years of experience with thermal discharges on the Great
Lakes, is certain that even greater heat loads can be added to the lakes
without harming the aquatic ecology as it exists today or otherwise inter-
fering with other reasonable beneficial uses.
11-20
-------
470
III. COMPANY ENVIRONMENTAL PROGRAMS
A. COMPANY SURVEYS ON THE GREAT LAKES
As mentioned earlier, concern for preserving the environment
has historically "been the corporate policy of Consumers Power Company.
This concern for preserving water quality in Michigan can best be demon-
strated by describing our water quality surveillance programs conducted
in the past several years at all our major generating stations.
The Company has engaged the services of university and private
consultants in all facets of the aquatic sciences, cooperated with efforts
of state agencies, and has added technically qualified staff in this field.
As a result of this combined effort, over 80 temperature surveys and 20
biological surveys have been conducted to date in the cooling water dis-
charges of the Company's seven major electrical generating sites. Exhibit
III-A summarizes these studies. It should be noted the list of surveys
shown in Exhibit III-A includes only surveys related to thermal effects
and does not include numerous radiological and other surveys that have
been conducted relative to water quality.
III-l
-------
471
EXHIBIT III-A
WATER QUALITY SURVEILLANCE STUDIES
AT CONSUMERS POWER COMPANY
MAJOR STEAM GENERATING PLANTS, 1967 - 1970
PLANT NAME
TEMPERATURE
SURVEY
INFRARED
IMAGERY SURVEY
BIOLOGICAL
SURVEY
A. BY CONSUMERS POWER COMPANY
1. J. R. Whiting
2. D. E. Karn - J. C. Weadock
3. Big Rock Point
4. B. C. Cobb
5. J. H. Campbell
6. Palisades
7. B. E. Morrow
Sub Total
B. COOPERATIVE STUDIES WITH OTHER
UTILITIES, STATE AGENCIES AND
UNIVERSITIES
1. J. R. Whiting
2. D. E. Karn - J. C. Weadock
3. Big Rock Point
4. B. C. Cobb
5. J. H. Campbell
6. Pal i sades
7. B. E. Morrow
Sub Total
Total
6
8
1
8
8
13
13
57
1
0
4
t
1
1
0
m
71
i
i
2
1
2
0
1
8
1
0
0
0
1
1
0
3
II
0
1
0
0
2
1 1
0
11
0
0
1
0
3
3
1
8
22
-------
472
B. C. COBB PLANT - MUSKEGON LAKE - Beginning in 196?, a series
of temperature surveys have been conducted at the 531 MWe B. C. Cobb Plant
on Muskegon Lake. Most have been made during fish migratory seasons to
determine the plant's influence on the zone of passage in Cedar Creek
(North Branch Muskegon River). These studies have demonstrated that a
zone of passage was maintained in Cedar Creek from the point of condenser
water discharge to Muskegon Lake. As an example, the thermal plume ob-
served on July IT, 19TO, is shown on Exhibits III-B, C and D for the sur-
face, 2 ft depth and bottom, respectively. Other temperature surveys have
been conducted on Muskegon Lake and include an infrared aerial survey in
1970.
BIG ROCK POINT PLANT - LAKE MICHIGAN - Since I960, Consumers
Power Company, in cooperation with various state agencies, has conducted a
routine radiological monitoring program of the biota in the vicinity of
the 71 MWe Big Rock Point Plant on Lake Michigan near Charlevoix. In addi-
tion, temperature surveys have been conducted., including two infrared
flights. The surface plume observed on June 18, 1968, is shown on Ex-
hibit III-E, as an example.
KARN-WEADOCK PLANTS - SAGINAW BAY - A comprehensive biological
survey has been conducted at the 1226 MWe Karn-Weadock facility on Saginaw
Bay, which includes bottom fauna, plankton and macrophytes. In conjunc-
tion with the study, the results of which will be available later this
year, extensive fish surveys were conducted in the discharge vicinity. In
addition, numerous thermal plume measurements were made, including an in-
frared aerial survey in 1970. The thermal plume observed on August 7, 1970,
III-2
-------
473
EXHIBIT III-B
o
(SI
o
xO
+- +
*-> -M
C fi
JO
g
JO
s
o
CT-
4-
,£3
s
-------
EXHTBIT III-C
CQ
O O
(M
c
0)
c
4)
J3 ,£)
e a
-------
EXHIBIT III-
O O
rt O
c c
D
-------
o o
-H CO
G
0)
a
H
£
J
0,
04
<
w
_!
POINT NUC
X
u
0
Pi
0
S
CO
0)
h
CO 5 ^
vo rt h S1
O *-" O ^
— 1 1) (\J
d. LO O uj
oo" g •£ 7 "rt
^H v c in u
« H -3 co w
§ s 1 i
- JS < -5
^ ^
T3
>^
O
O
3
C/3
O
I—)
£
U
i-(
2
w
tf
<
_i
-------
477
is shown on Exhibits III-F, G and H for the surface, 2 ft and 5 ft depths,
respectively.
J. R. WHITING PLANT - LAKE ERIE - Since 1966 , several thermal
plume surveys have been conducted at the 3^2 MWe J. R. Whiting Plant on
Lake Erie, including two infrared aerial surveys this year. The thermal
plume observed on June IT, 1970 is shown on Exhibits III-I and J for the
surface and 5 ft depth, respectively.
It is not practical to include in this report the full details
of the above studies. However, some graphic illustrations from a few of
the thermal surveys have been shown because they document various plume
characteristics for different plant locations, loads and meteorological
conditions.
B. J. H. CAMPBELL PLANT BIOLOGICAL AND TEMPERATURE SURVEYS
Ten temperature and two biological surveys have been conducted
at the Company's J. H. Campbell Plant site on Lake Michigan near Holland.
The following information includes some of the results of these surveys.
TEMPERATURE SURVEYS - The condenser cooling water for the J. H.
Campbell Plant is drawn through Pigeon Lake and discharged into Lake
1 -^-,0?^
Michigan at a maximum rate of about ^yQQOjOOQ gpm, with an average tem-
perature rise of about 1T°F. The Campbell Plant has two units and is
capable of producing 6^7 MWe.
On July 10, 19TO, a surface water temperature survey of the
J. H. Campbell Plant condenser cooling water discharge, as shown on Exhibit
III-K, was made when the plant intake temperature was 66°F and the dis-
charge temperature was 82°F. The plant was discharging approximately
III-3
-------
478
EXHIBIT III-F
CO
H
PH
O
Q
<
w
g
?°
+i m
rt r-
s. I*
r^ "
S r<"
a; H
H ^
. c
" Q)
-------
479
EXHIBIT III-G
a.
rt
O O
oo in
C
(U
CO
1
t—I
O
O O
a> rg
C
(U
fi
0)
I I e
-------
430
EXHIBIT I1I-H
o
o
Q
w
^
(U
Q
(M
o
r-
o
^ co H
« £ S
3 a £
OB 2 S
5 rt -O
a
CQ
O
-------
\
EXHIBIT III-I
-------
482
I
EXHIBIT III-J
O O
-H 00
O
un
O
00
O
O
c
1)
c
0)
C
01
43
s e
43 43
e s
43
g
HI
£
C/3
o
r-
o-
O
« ^
r o
b ^
^
H g -
«.;;_.
H -9 ^
o
o
(M
O
o
un
-------
183
EXHIBIT III-K
H
j
4
&
5
<
u
*
K
X
4) t*
> O
fH ^JO
rt) J-l
^ 0)
41 a,
g-s
C 1)
a; H
hi
0)
^ -^
0) a)
4-> 1
rt "-I
5 -S
^ S
a,
S
LT)
c
^
O
00
2:
<;
^a
£
U
w
J
c
0)
fi
(U
-------
300,000 gpm. Due to unfavorable lake conditions (rough water), tempera-
ture profiles were not made. A 15 mph north wind caused the main portion
of the plume to travel south for approximately one mile before it dissi-
pated. The unusual plume configuration, shown on this exhibit, resulted
from a change in wind direction during the preceeding 10 hour period. At
points 6,000 ft north and south of the discharge the temperature was 66°F
from the shore lakeward. The maximum offshore extent of the plume was
approximately 1,000 ft.
On August 26, 19TO another surface water temperature survey was
conducted as shown on Exhibit III-L. The plant was operating only with
Unit #1 and was producing 2^7 MWe. The discharge was approximately
120,000 gpm, with intake and discharge temperatures of 7U°F and 85°F,
respectively. During the survey the wind was from the S-SW at about 10
mph and the plume was traveling northward alongshore in a relatively
narrow ban. The maximum offshore extent of the plume was about 800 ft at
the point of discharge. The plume at 6,000 ft to the north was within
1°F of the ambient lake temperature. There was no measurable increase
above ambient temperature, 6,500 ft to the north.
Another surface water temperature survey was conducted, as
shown on Exhibit III-M, on September 9> 1970. An additional objective
of this survey was to gather ground-truth data for an infrared imagery
flight made on that day. The plant load was 568 MWe and the discharge
was approximately 300,000 gpm. The intake temperature was 72°F and the
discharge temperature was 89°F. The wind was from the S-SW at speeds
III-U
-------
&
J
J
w
«
&
S
<
u
3 fa
-------
\
486
EXHIBIT III-M
-------
48?
up to 5 mph. It was evident during this survey that the plume was shift-
ing to the north. The northern boundary of the plume moved 500 ft further
north in approximately 1-1/2 hours. Near the point of discharge, where
the surface temperature was about 88°F, the temperature at 3 ft depth was
7^°F. Where the surface temperature was observed to be 79°F, "the ambient
temperature of 72°F was found at 2 ft depth.
1968 BIOLOGICAL SURVEY - To assist Consumers Power Company in
evaluating the impact of heated water discharges on the biota of south-
eastern Lake Michigan, T. W. Beak Consultants Limited were retained to
carry out a biological survey in the vicinity of the J. H. Campbell Plant.
The survey work was carried out on August 30, 1968. Field work was ac-
complished by T. W. Beak Consultants Limited and a crew from the Michigan
Department of Conservation, assisted by Consumers' technical staff.
Eight sampling stations were selected; seven in the vicinity
of the cooling water discharge point and one, a control, three miles
south of .the plant. Station locations are shown in Exhibit III-W. Dis-
tances and directions were measured by means of an electronic range
finder and compass headings. At each station, six bottom samples were
taken by means of a Ponar dredge. This is a clam-shell type device which
cuts out about one-half sq ft of the bottom to a depth of 2 to 6 inches,
depending on texture. Samples were washed in a 30-mesh screen, to remove
sand and mud, and preserved for shipment to the laboratory. There, the
benthic macroinvertebrate organisms were hand sorted, classified to major
taxonomic groups and counted.
Ill-5
-------
488
EXHIBIT III-N
H
5^
j
;j
""I
OH
j
j
w
CQ
P.
2
<
U
33
t-5
CO
sO
r— 1
•i
O
CO
CO
bC
3
^
co
C
O
v>
nl
CO
00
_c
'a.
H
oj
CO
u
5
'a
-H
O
o
o
o
1 — 1
cu"
so
_e
u
co
Q
•5
0
o
r~
-------
489
Plankton samples were collected at each station by means of an
electric pump with a calibrated intake hose which could be lowered to the
desired depth. To obtain a sample, about kQ liters of water from a 5 ft
depth were strained through a Wisconsin plankton net aboard the boat. One
additional sample from a 10 ft depth was taken at Station 8, where the
water was deeper. The concentrated plankton samples were preserved and
sent to the laboratory for analysis.
The lake bottom in the study area consists mainly of fine,
loose sand, mixed with some gravel at the inshore stations. There were
no stable deposits of silt or organic debris.
The prevailing movement of heated water away from the discharge
point is northward along the coast, following the general counterclockwise
circulation pattern in the southern basin of Lake Michigan. The biolog-
ical results from the control station, 3 miles south, indicate the makeup
and density of the benthic community outside the warmwater plume.
In order to compare the density and diversity of organisms, the
number of general taxonomic groups found and their average numbers per
square foot at each station were calculated. The principal observation
which can be made concerning these data is that there is very little
difference between the animal communities in the plume and control areas.
The dominant animal forms in both areas were midge larvae (Chironomidae)
and scuds (Amphipoda). The density of organisms at all inshore stations
(kOO ft offshore) was quite similar.
Stations 8 and 9, which were the furthest offshore, yielded
numbers of midge larvae and scuds approaching those found at the "1/2 mile"
III-6
-------
stations near South Haven, Michigan in May. This suggests that distance
from shore is an important factor in explaining the observed animal
distribution. Station 7, which was slightly closer to shore, yielded
results similar to those at the kOO ft line. The extreme scarcity of
aquatic segmented worms, which are detritus feeders, probably reflects
the absence of significant sources of organic wastes in the area. The
bottom fauna were found to be sparse and restricted in variety. Two
main factors appear to be responsible for this; the sand bottom, which
is not highly productive even when not mechanically disturbed and the
shallow depth which results in bottom sediment disturbance by waves.
On the basis of the study results, the biological consultants
concluded that there appeared to be no gross thermal damage to the benthic
fauna of the main plume area at the Campbell site.
1970 BIOLOGICAL SURVEY - To further document the effects of
condenser water discharges into Lake Michigan, another biological survey
was conducted in 1970 at the J. H. Campbell Plant. The 1968 biological
sampling stations and five additional offshore stations were sampled on
August 26, 1970 for benthic organisms. Three Ponar dredge samples were
collected at each of the thirteen stations on Exhibit III-O. The samples
are being analyzed as they were in 1968 and the results will be available
later this year.
The temperature and biological studies which have been conducted
at the J. H. Campbell Plant have shown; (l) the ecology of Lake Michigan
in the condenser water discharge area has not been significantly affected,
(2) wind velocity and direction influence the maximum extent and pattern
III-7
-------
EXHIBIT
H
Z
• rH
s
CO
CD
M
Q
r|
to
£
o
o
o
o
1— (
CO
in
D
' '
s
rO
CU
rH
O
J^
in
VH
VH
O
o
o
•*
to"
CU
f— 1
n
«<-4
"HH
O
o
o
o
r—H
w
Z
-------
492
of the thermal plume, (3) temperature profile data have shown that outside
the immediate area of the discharge the plume is confined primarily to the
surface waters.
C. PALISADES PLANT COMPREHENSIVE SURVEYS
The Palisades Nuclear Plant, located on the eastern shoreline
of Lake Michigan, five miles south of South Haven, Michigan, is designed
for initial operation at 2200 MWt and 710 MWe. The ultimate capacity is
expected to be approximately 2600 MWt, corresponding to 845 MWe. Con-
denser cooling water is withdrawn through a crib intake 20 to 25 feet
below the lake surface, about 3300 feet from shore, at a rate of 390,000
gpm, and is discharged through a simple diverging pile structure at the
shoreline as shown on Exhibit III-P.
Concern about the environmental effects of the plant prompted
Consumers Power Company to engage the serviceis of University of Michigan
biologists to develop a study plan to detect any effects of the heated
discharge on the aquatic biota of Lake Michigan. The biological collec-
tion and analysis are being done by T. W. Beak Consultants, Limited, in
cooperation with the Michigan Department of Natural Resources.
Temperature and biological surveys conducted at the J. H.
Campbell Plant in 1968, as described earlier, indicated no significant
ecological effects from that heated discharge. The Palisades Plant, how-
ever, is larger, and a more cautious approach of thoroughly studying its
discharge effects was initiated to ensure that if subtle ecological
changes take place they will be detected.
Ill-8
-------
EXHIBIT III-P
PALISADES NUCLEAR PLANT
493
-------
The biological studies at Palisades are sufficiently comprehensive
in scope to detect, either directly or indirectly, virtually any signifi-
cant effect on the local aquatic ecosystem attributable to the thermal
discharge. These studies are concentrated on the benthos, plankton,
periphyton, fish, and, of course, temperature.
The benthos are considered to be the most delicate indicators
of ecological change since they are relatively sessile and cannot escape
environmental stress conditions. Plankton and periphyton are also good
indicators of change, being relatively low in the food chain and only
passively moved, and provide direct indications of nuisance conditions;
should their populations increase drastically. Limited fish sampling is
conducted since, aside from being highly mobile, fish are relatively slow
in reacting to environmental changes providing toxic conditions are not a
factor.
SURVEY PROCEDURES AND RESULTS - The survey area near the plant
is shown on Exhibit III-Q and the basic fan-shaped sampling grid is
identified. Sampling stations were established on 1/U-, 1/2-, 1-, 2-
and 5~mile radii on nine radial lines. In addition, there are two control
stations located near each of the cities of South Haven and Benton Harbor,
about 7 miles north and 16 miles south of the plant site, respectively.
The surveys began in 1968 with samples scheduled to be gathered in early
May, late June, August and October. The initial survey is planned to
extend for five years. The sampling stations are not marked in the field,
but are accurately located by means of an electronic range finder.
III-9
-------
495
EXHIBIT III-Q
PALISADES PLANT
LAKE MICHIGAN ECOLOGICAL SURVEY STATIONS
102 72
For more
seeChart
96
66
SOUTH HAVE^I
57
PALISADES
T
LEGEND
• TEMPERATURE SAMPLE
o BENTHOS SAMPLE.
• PLANKTON SAMPLE
* PERIPHVTON SAMPLE
Lake Michigan Beach
KM.C IN MILM
-------
496
Indicated on Exhibit III-Q is the initial basic plan for collec-
tion of "benthos, plankton and periphyton at the various locations. The
basic sampling grid, not counting control stations, contains 21 stations
for benthos, 10 for plankton and 3 for periphyton. Some minor modifica-
tions since the survey began included the addition of several more inshore
benthic stations in exchange for two benthic stations at five miles, and
the addition of several plankton and periphyton stations. Adverse weather
conditions have precluded the collection of a few samples, but without
loss to the integrity of the coverage.
"EEHTHOS - All benthos samples are collected by means of a Ponar
dredge, as shown in Exhibit III-R^
The bottom deposits of the study area consist of mixed gravel and coarse
sand inshore, grading outward to medium, then fine sand, and then to fine
sand mixed with silt at approximately two miles offshore. At five miles
offshore, fine sand is overlain in irregular patches by organic detritus.
In 1968, six replicate samples of benthos were collected at
each station, the macroinvertebrate organisms screened out and preserved
for shipment to the laboratory. The samples were analyzed for all benthic
macroinvertebrate and identified to family in all cases and to genus
wherever possible. In addition, one sample from each station from each
survey was analyzed and the organisms identified to species, or as close
to species as taxonomy permitted. The replicate samples were sufficiently
uniform in 1968 that the procedure in 1969 was modified to collect only
three replicates.
111-10
-------
EXHIBIT III-R
PALISADES PLANT
BENTHIC SAMPLING
497
-------
498
Analysis of benthic data to assess environmental conditions
and changes in the aquatic ecosystem can proceed along several different
lines. For example, indicator organisms can be selected for detailed
study, and the relative numbers compared before and after plant operation,
and in proximity to the plant discharge. Such an organism representative
of clean water conditions, and widely prevalent in Lake Michigan, might
"be the Crustacea, amphipoda (commonly called aquatic scuds), consisting
of the dominant species Pontoporeia affinis. An example of the relative
distribution of this organism is shown in Exhibit III-S for the August;
1968 sampling period.
Another approach would be to examine an organism that is known
to be relatively pollution tolerant or to compare relative numbers of
tolerant and intolerant species. The dominant representative of tolerant
organisms would be the oligochaeta (made up of numerous species known as
aquatic earthworms, tubificids or sludgeworms). The relative distribution
of these organisms observed in August of 1968 is shown in Exhibit III-T as
an example.
The relative populations of other benthic organisms will also be
studied and correlated, not only within the project area, but also in re-
lation to similar data being gathered at other locations around the lake.
Species diversity of the entire benthic community is another tool
for assessing the influence of environmental factors and is readily adaptable
to statistical analysis. A crude illustration of the variation of species
number with depth for August 1968 is shown in Exhibit III-U. The scarcity
of benthic organisms in the sandy, wave-swept shallows should be noted,
III-ll
-------
EXHIBIT III-S
PALISADES PLANT
LAKE MICHIGAN ECOLOGICAL SURVEY STATIONS
AMPHIPODA - AUGUST 1968
NO OF ORGANISMS PER FT.Z
PALISADES
PLANT
SCALE IN MILES
-------
EXHIBIT III-T
PALISADES PLANT
LAKE MICHIGAN ECOLOGICAL SURVEY STATIONS
500
OLIGOCHAETA - AUGUST 1968
NO. OF ORGANISMS PER FT.2
PALISADES
PLANT
0 __l 2
SCALE IN MILES
-------
501
H
S
I—I
ffi
X
w
O
u
I
H
Z
UJ
DQ
UJ
O
CO
_l
Q_
GO
CO
O>
CO
CD
O
CO CO
2 Z
CO CO
cc.cc.oc.
< 11
-------
502
along with the apparent evidence that the southern control stations are
relatively sparse and unrepresentative of the project area in this respect.
PLAHKTON - Plankton samples are obtained by passing ^0 liters
of water through a Wisconsin plankton net as shown in Exhibit III-V. At
each station, samples are collected at depths of 5, 10 and 15 feet. G?he
preserved samples are received at the laboratory where they are centrifuged
and the volume of plankton concentrate measured.
Relative changes in plankton concentrations, both within the
project area and as related to the control sta/tions, will indicate whether
the thermal discharge is having a substantial impact on these organisms.
Stimulation of algae growth, such as the filamentous green algae Cladophora,
to nuisance proportions would be so detected. Subtle changes in relative
numbers of the various types of plankton can only be verified through
microscopic examination. When the plant is in. operation, samples will be
collected for such detailed analysis in the immediate vicinities of the
intake and discharge.
Typical results of the plankton concentrate analysis are shown
in Exhibits III-W and X. Exhibit III-W shows the seasonal succession of
plankton concentrations at the 5 ft level one, two and five miles from
shore. Exhibit III-X similarly shows concentrations at 5> 10 and 15 feet
deep at the one-mile station. This data clearly shows the general cyclic
nature of the phytoplankton production. This fluctuation is typical of
Lake Michigan in which diatom populations dominate and bloom in early
spring and late fall.
Ill-12
-------
EXHIBIT III-V
PALISADES PLANT
PLANKTON SAMPLING
503
-------
EXHIBIT III-W
PALISADES PLANT
PLANKTON SAMPLING
1968
504
<
o
o:
o
MONTH
-------
505
EXHIBIT III-X
PALISADES PLANT
PLANKTON SAMPLING
1968
i
CO
2
CO
z
<
-------
506
FERIPHYTON - Periphyton organisms are collected on artificial
substrate, constructed of Plexiglas plates, which are suspended from
metal supports imbedded in concrete "blocks. The samplers are placed in
15 feet of water and after suitable exposure, at least four weeks, they
are retrieved. The preserved plates are sent to the laboratory where
the periphyton scrapings from the plates are extracted with acetone and
the amount of chlorophyll determined spectrophotometrically.
The periphyton sampling program was beset with considerable
difficulties in both 1968 and 1969' Intermittent storms hampered the
retrieval of the collection plates. In addition, public destruction
resulted in the loss of all but a few marker buoys. The addition of
several more unmarked samples to be recovered by divers has been insti-
tuted to compensate for these problems.
Chlorophyll analysis for the one-month exposure in May-June
1968 yielded concentrations ranging from 0.0 to 0.0056 micrograms per
square centimeter. Sufficient data are not available for confident
representation of seasonal fluctuations or other natural variations.
Information gathered on periphyton during plant operation will be ana-
lyzed primarily to detect correlation between growth and proximity tc
the plant outfall.
FISH - The Michigan Department of Natural Resources has provided
the vessel used in the biological sampling program and their personnel
have been in charge of all fish sampling and analysis. Their sampling
schedule calls for gill nets of various mesh sizes to be set for two 24-
hour periods four times a year at depths of 20 feet, 40 feet and 55 feet.
111-13
-------
507
All fish captured are measured and counted, and many are scale sampled,
sexed, and weighed.
In addition to the gill nettings, a bag seine was used on five
occasions in 1969 to sample fish populations along 1200 feet of shoreline
north of the plant. Data on offshore populations are also available for
two dates in 1969 from the trawling efforts of the Bureau of Commercial
Fisheries, United States Fish and Wildlife Service.
The results of the various fish studies to date indicate that
at least 22 species of fish live in the area, of which perch and alewives
are most abundant. While both yearling and adult salmonids have been
captured, their numbers have been very small and all have been planted
fish, as identified by their markings.
TEMPERATURE - Lake temperatures have been measured periodically
at various depths and locations since before the biological sampling pro-
gram began. The objective oif the preoperational temperature surveys has
been to define the general natural variations that occur. For this pur-
pose, a series of measurements has been made approximately every month,
weather permitting.
A representative series of temperature profiles for 1968 is
shown in Exhibit III-Y for a location one mile from shore. It can be
seen that a relatively shallow thermocline developed in the spring and
early summer, but typically the thermocline in Lake Michigan will reach
depths exceeding 100 feet by early fall.
The thermal structure of Lake Michigan is a highly variable
phenomenon and can change significantly in a relatively short period of
III-
-------
508
UJ
J
2
00
§
UJ
3 b
H 2
a
ffi
X
W
UJ
u.
e
(O
UJ
O
2
-------
509
time as veil as from year to year. The great influence of the shoreline
is typified in Exhibit III-Z for April 10, 1968, at vhich time the temper-
ature variation from shore to five miles out exceeded 13°F. Such wide-
spread natural temperature excursions have certainly had a major influence
in the establishment of aquatic life populations as they exist today.
Artificial thermal discharges to the lake, as from power plants, can and
should "be evaluated in the context of these natural variations.
When the Palisades Plant is in operation, the thermal discharge
will be mapped periodically to define the extent and magnitude of its
influence under various meteorological and natural lake conditions.
Studies of lakeshore currents have indicated that the buoyant thermal
plume will flow northward about 33$ of the time, southward 23$ of the
time and drift almost directly offshore about 38$ of the time. The re-
maining 6$ of the year the plume is expected to more or less remain as
a stationary water mass nearshore.
Data on the spatial and temporal influence of the thermal
discharge will, when correlated with the biological data, make possible
an accurate assessment of the impact of plant operations on the aquatic
ecology of Lake Michigan.
111-15
-------
510
EXHIBIT III-Z
PALISADES PLANT
LAKE MICHIGAN ECOLOGICAL SURVEY STATIONS
SURFACE TEMPERATURE- °F (4/10/68)
PALISADES
PLANT
-------
511
IV. STATUS OF THERMAL DISCHARGE CONSIDERATIONS
A. POPULAR VIEW VERSUS TECHNICAL EVIDENCE
Passage of the Water Quality Act of 1965? to amend the Federal
Water Pollution Control Act, set into motion a widespread review of water
quality criteria to be used in the standard setting process. For many con-
taminants and water quality parameters the determination of the necessary
restrictions to protect aquatic life or other beneficial uses was rather
simple. Agreement on standards for such things as dissolved oxygen and
certain toxic substances was secured rather early because of the demon-
strated need to control waste discharges to minimize almost certain harmful
effects. Recognized pollution conditions caused by such discharges had
clearly been shown.
The situation with regard to temperature was not so well defined.
It was known that if heated waters were discharged into a relatively small
body of water the local aquatic ecology would be changed. But such things
as fish kills or other adverse effects associated with such discharges
were relatively rare, and research to determine potential damage was con-
sidered frivolous, under the circumstances. Utilities around the country,
however, recognizing the accelerated rate at which thermal discharges
would be made from power plants, initiated studies to attempt to detect
adverse effects. In the case of the Great Lakes, short-term studies have
failed to show harmful effects and the long-term studies, by their nature,
have not provided much definitive information to date.
The US Department of the Interior, because they were charged by
Congress to approve Water Quality Standards has felt obliged to require
numerical limits to restrict thermal discharges into the Great Lakes.
IV-1
-------
512
However, until technically supportable evidence concerning harmful
effects of such a discharge has been presented, there is no rational
or legal basis for such a dogmatic viewpoint. The popular view of the
possible consequences of thermal discharges promoted by FWQA is not
consistent with existing factual information and does not enjoy any
broad recognition by the scientific community.,
B. RATIONALE FOR CONTROLLING THERMAL DISCHARGES
(l) Probable Versus "Possible" Effects
Considerable effort has been expended, by both scientists and
laymen, in theorizing on the possible adverse effects of thermal discharges,
A considerable amount of this activity has been stimulated by governmental
pressure and the misguided urgings to set specific numerical temperature
standards. But a clear distinction must be made between what can be con-
sidered "possible effects" and what is truly probable, based on existing
evidence and scientifically valid projections.
It is postulated, for instance, that there will be long-term
deleterious biological effects caused by the thermal discharges from
power plants. Lake Michigan, as has been shown, is in no immediate danger
of being significantly warmed by heated discharges. The seasonal succes-
sion of the lower aquatic life forms is so dramatic'due to natural causes
that the relatively minor circulation through power plants could not be
a significant factor in their overall populations. And the fish manage-
ment program by the Federal Government and the bordering states is evi-
dence in itself that we are not tampering with natural ecological
phenomena as far as fish are concerned. There is, therefore, no reasonable
IV-2
-------
513
basis for asserting that the existing level of thermal discharges could
have long-term effects.
The "White Paper" discusses at length the possible effects of
heated water on fish, as if they were confined to these waters and would
not naturally avoid temperatures not to their liking. The paper describes
very well the significant historical succession of fish species, the con-
siderable management efforts that have been instituted to change the
natural balance of species, and the variability of habitat and its impor-
tance in the succession of life stages. But on the basis of the evidence
presented, it certainly does not follow that any significant thermal
discharge, at any place, at any time, would jeopardize the existence or
otherwise interfere with the population of any species of fish in Lake
Michigan.
Another misleading implication made in the "White Paper" is that
if thermal discharges are eliminated, the accelerated rate of eutrophica-
tion of Lake Michigan will be checked, even though nutrient build-up may
continue unabated. Such an assertion fails to recognize the relative
causes of the existing rate of eutrophication, the insignificant warming
of the lake caused by existing thermal discharges, the natural heat inputs
to the lake, or the historical temperature conditions of the lake.
The predictions that thermal discharges will cause significant
undesirable shifts in predominance of planktonic forms of aquatic life,
such as algae and Type E botulinum, as so dramatically identified in the
White Paper, does not take into consideration that thermal plumes are
transitory, self-renewing water masses and the generation times of the
IV-3
-------
514
organisms contained therein would not allow for growths that could be
construed as proliferation.
(2) Priorities for Environmental Improvement
As we all know, thermal discharges are only one result of man's
activities that can have apparent or possible adverse effects on the en-
vironment. The principles of ecology would demand that priorities be
established as to the potentially harmful effects of all forces impinging
on man and his environment, so that manpower, economic and other resources
can be apportioned accordingly to deal with the problems.
This philosophy is obviously lacking in the procedures and pro-
nouncements of the Department of the Interior regarding environmental
problems in the Great Lakes area. The recommendation of standards that
would commit vast resources, to prevent imagined damage or to allay base-
less fears predicated on unreasonably extrapolated data, is not in the
best interests of the people or the natural environment. There are real,
presently existing environmental problems that deserve a higher measure
of our attention than that presently being allotted thermal discharges.
The easiest targets of criticism and control should not be the criteria
for selecting the priority for dealing with environmental effects.
(3) Alternative Considerations and Economic Significance
(a) Impact of 1 F or No Heat Discharge Recommendation
Consumers Power Company has reviewed the problems involved with
reducing the temperature of the discharge of cooling water to 1 F over
the ambient temperature of the receiving body of water for each of our
plants on the Great Lakes.
Tf-k
-------
515
To do this would, in each case, require us to install closed
loop cooling systems with evaporative cooling devices such as powered
draft cooling, natural draft cooling, spray ponds or possibly a combina-
tion of these.
Each of these systems has its own particular disadvantage,
but common to all of the systems would be:
1. A loss of unit capacity of k-6% due to increased turbine
back pressure. This would have to be made up with new capacity costing
about $175AW.
2. A decrease in unit cycle efficiency of 2-3$ during the
summer period. This would increase the fuel requirements proportion-
ately.
3- An increase in capital expenditures for cooling systems
and associated changes.
U. A decrease in the net plant capability for pumping energy
which would have to be made up with new plant capacity costing about
$175/kW.
5- Increased maintenance cost required to maintain spray
nozzles, tower fill, pumps and electrical equipment, etc.
6. Increased operating costs for water treatment of the
water in the closed loop.
7- An increase in water evaporated and discharged to the
atmosphere.
8. Possible problems with blowdown due to the concentration
of solids because of the evaporation of water by the cooling towers.
IV-5
-------
516
9. Possible problems with drift and fallout of condensed
water that cannot be fully assessed until a HOdel study of each plant
area is made.
10. Increased problems with insulators and other electrical
equipment because of the increased humidity in the immediate plant area.
11. Problems with icing, particularly when a single unit is
operated or when the plant is operated as a peaking plant.
To approach compliance with such a restrictive standard for
the plants on Lake Michigan would cost millions of dollars per year. It
is frequently stated that because this represents only a few percent of
operating revenues, it is an insignificant expenditure for environmental
controls. Many millions of dollars spent for any purpose cannot be con-
sidered insignificant. This represents a considerable amount of society's
financial resources and should not be diverted from more deserving uses
because of unsubstantiated fears of "thermal pollution." Considering
the known adverse environmental effects of artifical cooling facilities,
expenditures for these devices based on arbitrary restrictions, assumed
to protect the lake, cannot be supported under the guise of improving
environmental quality.
(b) Palisades Plant Alternatives
The Company has conducted preliminary feasibility studies for
the Palisades plant with Bechtel Corp, on three alternative systems to
modify the possible effects of the thermal discharge on the adjacent
inshore area. These alternatives and a discussion of each are listed
below.
IV-6
-------
517
Alternate I - Cooling Towers - A closed cycle cooling tower
system has been considered which would for the most part isolate the
plant from the lake. This would require three structures about 75' x
400' which would be placed to the south of the existing plant. This
system would utilize forced air circulation towers rather than the
natural draft towers due to performance and site location considerations.
The approximate engineering-procurement-construction schedule
for this alternate is twenty (20) months.
Alternate II - Dilution of Discharge Flow - This system would
provide additional dilution water to the discharge structure to reduce
the outlet temperature to 10 P higher than the plant inlet flow. Modi-
fications include additional (l) inlet line(s) parallel to the existing
inlet line, (2) intake structure(s), (3) pumps, and (k) discharge struc-
ture(s) to accommodate the approximate tripling in quantity of discharge
flow.
The approximate lead time for this alternate is twenty-eight
(28) months.
Alternate III - Extended Discharge Piping - This system would
provide for the addition of a pump structure, pumps and discharge pipe.
The condenser discharge would flow to an enclosed discharge structure,
from where it would be pumped to offshore points of discharge selected
to minimize warm water effects along the lakeshore. A disadvantage of
this scheme would be the dissipation of more heat into the lake water
and less to the atmosphere from the surface cooling effect.
The approximate lead time for this alternate is twenty-eight
(28) months.
IV-T
-------
518
An additional alternative which would be immediately available
to reduce temperature rise, if required, would be the curtailment of plant
power output. Since the circulating water temperature rise across the
condenser is an approximate linear function with respect to power, reduction
of plant power output would reduce the temperature rise accordingly. This
measure could be taken at any time adverse effects are indicated and, of
course, could be continued until some permanent solution such as the
alternates listed above was implemented. A major disadvantage of this
method would be the sacrifice of installed electrical capability during
any periods when a power curtailment would be in effect.
All of the various alternatives would effectively reduce the
capability of the plant and tend to reduce the reliability of the elec-
trical system. Energy not available from nuclear plants must necessarily
be supplied by older fossil-fueled generating stations that inherently
have a greater impact on air quality. The adverse environmental effects
of reducing the availability and reliability of electrical energy should
certainly be weighed in any decisions made to ostensively improve environ-
mental quality.
IV-8
-------
519
V. CONCLUSIONS
We would restate, in concluding, that the Federal position
regarding thermal discharges into Lake Michigan is not warranted by
the known facts concerning such discharges, or the potential effects
of these discharges in the foreseeable future. Further, the vacilla-
tion in the Federal position has interfered with rational standard
setting. Moreover, Consumers Power Company is profoundly disturbed by
the misleading information which has been released on this subject and
by the escalation of groundless fears in the minds of the public. The
result of these needless anxieties is even more serious coming, as it
does, at a time of rapid growth in electrical requirements and increas-
ing energy shortages.
The Company is deeply involved in environmental studies to
detect effects of thermal discharges into the Great Lakes, and is pub-
licly committed to make corrections should damage occur. We would urge
the conferees to carefully consider our statement and proceed with the
business of developing a reasonable position concerning regulation of
thermal discharges.
V-l
-------
520
D. H. Brandt
In order to meet the service requirements
of over 1 million electric customers the company has
constructed, owns, maintains and operates an integrated
electric generation, transmission and distribution system.
Presently, Consumers Power Company has several
thermal electric generating installations in the Lake
Michigan basin which are part of this integrated network
system. These are the B. C. Cobb Plant on Muskegon Lake,
the James H. Campbell Plant on Lake Michigan near Holland,
and the Big Rock Point Nuclear Plant near Charlevoix. On
tributaries to Lake Michigan the company operates the
B. E. Morrow Plant near Kalamazoo and three smaller plants
in Kalamazoo, Battle Creek, and Grand Rapids. Electric
production at the last three plants is scheduled to be
discontinued in the near future as a part of the company's
program for air quality control.
Additionally, construction has been completed
on the Palisades nuclear plant directly on Lake Michigan,
35 miles west of Kalamazoo and it is awaiting an AEC
operating license. Also, construction is under way on the
Ludington pumped storage hydroelectric plant, 4 miles south
of Ludington, which will cycle lake waters to generate power
to meet peak system demands.
Before proceeding with my specific comments, I
-------
521
D. H. Brandt
want to identify, for the record, my company's concern for
the environment. For more than 50 years Consumers Power
Company or its predecessor companies, have demonstrated
their concern with protecting Michigan's environment. This
includes careful management of more than 700 miles of river
lands. Land that was denuded by the lumber interests now
has been replanted and made available to the general public.
Our efforts also include application of the more effective
technologies available to protect and improve the quality
of air and water, such as the addition of electrostatic
precipitators, conversion to gas and oil, and sponsoring
research and numerous environmental studies to guide us in
making decisions on these important matters.
As a public utility company, Consumers Power
Company has an obligation to its customers to provide
adequate, reliable, and economical energy to meet
their ever increasing energy requirements. At the same
time, it has an obligation to protect the environment and,
whenever possible, also makes life better for the people
of Michigan by developing picnic areas, campsites and other
recreational facilities. We are confident we can meet all
of our obligations through the continued exercise of sound
business judgment, consultation and guidance by technically
qualified people, the application of appropriate control
-------
522
D. H. Brandt
technology and acting in a forthright manner on
environmental issues. Our responsibility to meet these
obligations does not permit us the comfort, in today's
social atmosphere, of refraining from comment on these
vital issues, just because the comments may be misunder-
stood by some people as opposition to pollution abatement,
We have examined the Federal Water Pollution
Control Act, as amended, the Michigan water pollution
control statute, consulted with counsel and we have
examined the February 19, 1968, opinion from the Michigan
Attorneys General's office dealing with these matters.
In view of these examinations it seems
appropriate to draw the conferees' attention to the
philosophy of the Federal Act and some of its provisions.
1) First, section l(b) of the Federal Act
provides in part:
"It is hereby declared to be the policy of
Congress to recognize, preserve, and protect the primary
responsibilities and rights of the States in preventing
and controlling water pollution ..."
MR. STEIN: It might save a little time, when
you get down to 1 and 2 and you talk about the Federal
officials, whether you can be specific in your general
-------
523
D. H. Brandt
allegations that follow.
MR. BRANDT: Yes, sir.
A number of Federal officials often appear to
forget or ignore this basic policy of primacy of the
&
State regulation in- their temperature-standard-setting
efforts.
2) The setting of standards, according to
section 10(c)(3) requires that:
"In establishing such standards the Secretary,
the hearing board, or the appropriate State authority shall
take into consideration their use and value for public
water supplies, propagation of fish and wildlife,
recreational purposes, and agricultural, industrial and
other legitimate uses."
Too many Federal officials and others have
ignored this requirement to take into consideration all
legitimate uses of interstate waters. Instead, they consider
exclusively the propagation of fish and wildlife. The Act
obviously requires a balancing of interests and forbids
the all-too-prevalent approach of considering other uses
of the waters only to the extent that such uses will not
limit or interfere in any way with propagation of fish
and wildlife.
3) The legislative history of the Federal Act
-------
524
D. H. Brandt
shows that Congress rejected the principle of effluent
standards. This rejection resulted in a statute which
did not —
MR. STEIN: I take it, Mr. Brandt, that you
did not want to accept the opportunity of being specific,
and we will get to those general statements as they come
up.
Thank you. Go on.
MR. BRANDT: Mr. Chairman, they will be in the
body of the report; the specifics will be in there, sir.
MR. STEIN: All right, go on.
MR. BRANDT: This rejection resulted in a statute
which did not confer upon the Secretary of the Interior the
power to promulgate or enforce effluent standards.
Nevertheless, at the last meeting of this conference a
"policy" announcement of two Assistant Secretaries of the
Interior was made which sought to have effluent standards
imposed on Lake Michigan. Such standards would not be
enforceable and standards to be meaningful must be
enforceable.
4) Section 10(g) of the Federal Act provides
that before any enforcement action can be undertaken there
must be pollution which is endangering the health or
welfare of persons. As the Michigan Attorney General's
-------
525
D. H. Brandt
office has pointed out, "The danger must be real and
immediate." Too many of the proposals regarding thermal
discharge limitations deal not with real and immediate
danger to the health or welfare of persons, but a possible
danger to some aquatic life. These proposals are
predicated on extremely long-range predictions regarding the
use of Lake Michigan waters by electric utilities.
5) Sections 10(c)(5) and 10(h) of the Federal
Act both contain provisions concerning court action on
pollution. Where standards are involved the court will
make a complete review of the standards pertaining to the
alleged violation, and the court must give due consideration
to the practicability and to the physical and economic
feasibility of complying with standards or otherwise securing
abatement of proved pollution. In the words of the
Michigan Attorney General's office:
" ... the government must prove that it is
physically and economically feasible to abate the
particular pollution complained of, that it is in the
public interest to so abate the pollution and that it
is equitable to do so. In view of these considerations,
the court must find not only that the pollution exists as
defined in the statute, but that it is economically feasible,
physically possible, and equitable to order its abatement.
-------
526
D. H. Brandt
... it certainly would be an anomaly to require States
to adopt standards for water quality or to take measures
in the abatement of pollution if such standards of water
quality are not enforceable in a suit brought by the U.S.
Government. It would seem that it was the Congressional
intent to require the states to adopt standards of water
quality, which if not adhered to would be enforceable in a
suit brought by the U.S."
Consumers Power Company has on numerous
occasions endeavored to make clear its concern for the
environment. Our management has publicly stated that if a
plant ±s found to be harmful to the environment the company
will act promptly to correct the situation. Furthermore,
this commitment is included in the Orders of Determination
issued by the Michigan Water Resources Commission for all
recently authorized electric generating facilities. The
company also believes that unnecessary equipment should
not be required or built simply because of unsubstantiated
anxiety that adverse conditions might exist. To install
such equipment without first establishing the need for it
would constitute an unnecessary burden on the financial
resources of our economy without achieving a meaningful
contribution to environmental quality.
I agree with Representative Craig Hosmer,
-------
527
D. H. Brandt
Republican from California, when he said:
"Environmental protection does not necessarily
mean sending the world back to whence it came to be
refurbished in its original pristine condition, nor does
it involve turning off air conditioners, abolishing
the automobile and uninventing the wheel. Rather the
solution lies in achieving a satisfactory accommodation
between the demands of the environment and of social
benefits of technology."
This Enforcement Conference, prior to its
May 7, 1970, meeting, was reported to have made progress
by reaching an agreement between the conferees on April 16,
1970, on a uniform procedure for the establishment of
monthly maximum temperatures. The so-called 1-degree
policy statement made at the opening of the May 7 conference
and the "white paper" belatedly issued for this conference,
are not in our opinion, of sufficient value to warrant
much attention on the part of the conferees.
The 1-degree statement clearly goes beyond reason
as well as the intent of Congress. The "white paper,"
drafted over a 4-month period, fails to take into account
the technical data gained through years of experience with
existing thermal electric generating plants on the Great
Lakes. Scientific studies and actual observations of
-------
52:8
D. H. Brandt
existing heated discharges in Lake Michigan, conducted by
the staff of the Michigan Water Resources Commission and
other qualified groups, have documented on numerous
occasions that these plants have been operating many
years without demonstrable adverse effects to the aquatic
environment. These and other studies being made on the
basis of data obtained from actual field observations warrant
careful attention of the conferees. PWQA is now proposing;
to subject all electric generating plants to temperature
standards predicated on theories misapplied because of
inadequate recognition of natural ecological factors.
Site studies made at existing plants along the
Great Lakes should be evaluated before subjecting them to
temperature standards which may require millions of
dollars of capital expenditure because past studies and
present surveillance programs offer no evidence that these
waters require greater protection.
Gentlemen, we ask that you continue on your way
to reaching conclusions supported by the law rather than
emotion, and fact rather than fancy. We are confident
you will reach conclusions which will adequately protect
all of the legitimate uses of this natural resource for
future generations.
Other individuals who Consumers Power Company has
-------
529
J. Z. Reynolds
asked to present information to this workshop are Dr.
John Z. Reynolds and two representatives of the firm of
Sargent and Lundy Engineers, Mr. A. P. Aschoff and Mr.
Robert W. Patterson.
At this time I would like to call on Dr.
Reynolds.
STATEMENT OP JOHN Z. REYNOLDS,
ENVIRONMENTAL SURVEILLANCE COORDINATOR,
CONSUMERS POWER COMPANY, JACKSON, MICHIGAN
DR. REYNOLDS: Mr. Chairman, conferees, ladies
and gentlemen, my name is John Z. Reynolds. I am the
Environmental Surveillance Coordinator for Consumers Power
Company.
In recognition of a need for data collected from
systematic surveillance, and for an expanded research effort
on thermal discharges, electric utilities around Lake
Michigan have launched an unprecedented effort to determine
the effects of these discharges. Some of the studies of
Consumers Power Company will be described in detail later.
It would be appropriate at this point, however, to summarize
the results of the various studies to date and how they relate
to the issue of establishing a basis for setting
-------
530
J. Z. Reynolds
meaningful temperature standards, or otherwise limiting
thermal discharges.
Thermal discharges into the Lake Michigan basin
have existed at numerous locations for many years. Most
of these have been studied to determine their physical
behavior under various conditions and some have been
studied to detect any related biological effects.
It has been observed in all cases that discharges
that are warmer than the ambient waters are buoyant and tend
to spread into relatively thin layers on the surface. Mixing
of the thermal discharge with the adjacent waters causes
some entrainment into the plume. The relative amount of
entrainment is primarily a function of the velocity
conditions and the density differences at the interface.
Theoretically, the least amount of mixing would occur
when the temperature differentials are greatest and when
the relative velocities are smallest.
With any degree of entrainment, the resulting
mixed fluid will still be less dense than the ambient
waters, and cause the combined volume to be buoyant. The
commonly observed plume therefore tends to float on the
surface of the lake until the excess heat has been
dissipated to the atmosphere.
The "white paper" purports to make a case that
-------
531
J. Z. Reynolds
a large proportion of the heat from a thermal discharge
is effectively mixed with the lake to accumulate and result
in unacceptably high temperatures. We would like to cite
just a few examples of the misleading way technical
reports were abstracted in the paper to document the case.
It was quoted that Hope et al (1968) "concluded,
on the basis of work at a Lake Monona (Wisconsin) power
plant, that surface heat losses were about 5 percent of the
heat discharged by the power plant; the remaining 95 percent
was dissipated by dilution with lake water." It was not
stated, however, that this result was based on analysis
of a discharge, contained by a baffle, from 2 days of
field data on January 25 and 26, 1967, during a period of
significant atmospheric warming. It might also be noted
that these researchers concluded from the results of 22
field surveys during the remainder of the year that "power
production increases of less than 100 percent will have a
negligible effect on ... lake temperatures."
Work by Palmer (1969) was cited as supporting the
notion that excess heat diffuses into the lake, as
opposed to any significant atmospheric losses occurring.
Our review of the paper failed to identify any point that
would support this view. His studies of a cooling water
discharge into Lake Ontario showed "that the warmer water
-------
53;?
J. Z. Reynolds
stays near the surface and the shore. The subsurface cooling
water had acquired lake temperature by 4,000 feet while the;
surface cooling water (was) still 4 degrees F. warmer
than the lake water at 4,000 feet." Model studies were
cited that assumed no atmospheric heat transfer, to simplify,
in a conservative way, the mathematical predictions.
Similarly, work by Sundaram et al., (1969) was
cited where they "concluded that the heated discharge of
the proposed Bell Nuclear Station on Cayuga Lake (New York)
would increase the average surface temperature of this
66.4-square-mile lake about .7 degrees F." The Sundaram
report, however, went on to note that, "for a given amount
of heat that is discharged into the lake, the far-field
effects will be greater if the discharge temperatures were
close to the ambient lake surface temperatures than if
the discharge temperatures were significantly higher than
the ambient lake surface temperatures, since in the latter
case a greater fraction of the total heat can be lost to the
atmosphere directly than in the former case."
Benedict's (1970) shoreline discharge model of the
Campbell plant and Pritchard-Carpenter Consultants (1969
and 1970) computations for Toledo Edison were cited in the
"white paper" as further support that the "assumption of
little or no waste heat loss to the atmosphere is
-------
533
J. Z. Reynolds
reasonable, at least during a great deal of the annual
temperature cycle." In both cases the assumption that
surface heat loss was limited was arbitrarily made to
simplify the model. No evidence is given or even implied
by the original authors that this was a realistic
assumption.
It is not realistic, or even honest, to use
such model studies to support such a viewpoint, when much
field data, from actual installations, are available that
can be used for this purpose.
No evidence has been presented of which we are
aware that the physical presence of a thermal plume on
Lake Michigan has interferred with or otherwise caused
injury to any beneficial use of the waters. In fact, the
areas of heated discharge are often observed to appeal to
swimmers, since the lake waters are normally too cold for
comfortable water contact activities.
Researchers evaluating the results of biological
studies that have been conducted in the vicinities of
thermal discharges in Lake Michigan have similarly
concluded that no adverse effects have occurred as a
result of this use of the waters. Electric utilities,
consultants, universities and governmental agencies have
been unable to document significant biological effects
-------
534
J. Z. Reynolds
outside of the localized influences on fish that prefer
or avoid the region of increased temperature. Fishing
in the vicinities of thermal discharges has been observed
to be favored for the greater portion of the year, even for
some of the so-called cold water, heat sensitive species.
Consumers Power Company has maintained parking
areas in the vicinities of some of the plant discharges to
facilitate access for fishermen and others. We have
received requests from the Pish Division and the Bureau of
Water Management of the Michigan Department of Natural
Resources to provide more facilities to accommodate the
public because of the "recreation potential in year-round
fishing" in these areas.
The only reference in the "white paper" purporting
actual evidence of harmful effects of a thermal
discharge into Lake Michigan concerns an alleged fish kill
at the Consumers Power Company Campbell Plant on August
29, 1968. While it was indicated that a drop in temperature
due to natural upwelling may have been a major factor
resulting in the conditions observed, the paper does not
give any indication of the scope of the adverse condition
noted.
The observations were made by John Robinson,
Aquatic Biologist, employed by the Michigan Water Resources
-------
535
J . Z. Reynolds
Commission. He stated that the water temperature at the
point of discharge was 64.4 degrees P. and that the
temperature dropped in a short distance to 59 degrees F.
and then gradually declined to the ambient of 50 degrees P.
in one-half mile. This is the lowest temperature
recorded at the plant for any day in August since the plant
has been in operation, and occurred only a few days after
a water intake temperature of 76 degrees F. had been
observed.
Mr. Robinson noted that there were live catfish
and carp near the discharge and schools of alewives in the
area. Some dead alewives were observed, but no estimates
were made of the numbers involved. The only other dead
fish reported were a catfish and/or carp approximately
every 150 feet along 1 mile of shoreline. This amounts to
a total of about 35 fish. Apparently no sport fish were
involved. Mr. Robinson concluded that the fish affected
were apparently indigenous to the long cooling water
discharge canal and that the very unusual combination of
natural temperature fluctuations was partly responsible for
their condition. It has been reported that this phenomenon
of rapid natural temperature variations has caused fish to
be in distress at other locations, around the Great Lakes.
At the recommendation of the conferees of the
-------
536
J. Z. Reynolds
Lake Michigan Enforcement Conference in 1968, an interagency
Committee on Nuclear Power Plant Waste Disposal was formed
which reported to the conferees in November 1968. They
stated:
"The effects of localized temperature increases
on the aquatic life in Lake Michigan- are impossible to
predict from the limited information available. Only a
few observations have been made to date of the effects
of existing thermal discharges on Lake Michigan biota.
However, laboratory investigations and observations else-
where suggest that increase in temperature can result in
damage to the aquatic environment."
The committee recommended with regard to thermal
discharges that:
"Coordinated study of the thermal effects on water
quality and aquatic life of one or more fossil fuel plants
now discharging cooling water to Lake Michigan, and of various
methods of cooling water dispersion be undertaken by
FWPCA," and "FWPCA coordinate a comprehensive study of the
effects on water quality and aquatic life of thermal wastes
from a large nuclear power plant on Lake Michigan, with
attention to various methods of cooling water dispersion."
It is apparent that the Federal Water Quality
Administration has not carried out either recommendation of
-------
537
J. Z. Reynolds
the committee inasmuch as no notice has been made of such
comprehensive studies by FWQA. Fortunately, even before
the committee's report, the electric utilities around Lake
Michigan were concerned about the early detection of any
possible adverse effects that thermal discharges might
cause. These companies instituted comprehensive studies on
their own or in cooperation with the appropriate State
agencies. The scope and methodology of these studies are
such that it can be assured that, if harmful effects are
caused, they will be detected.
The previously mentioned report of the Committee
on Nuclear Power Plant Waste Disposal to the conferees of
the Lake Michigan Enforcement Conference included the
following comment on thermal discharges into Lake Michigan;
"In spite of the known adverse effects which
temperature change can have on aquatic life, it is not
certain that they will occur in the unique environment of
Lake Michigan. Much of the shoreline is seldom inhabited by
aquatic animals because the bottom materials consist of
shifting sand. There are rocky shoals that support game
fish population. Whether or not local increases In
temperatures will accelerate the eutrophication of Lake
Michigan is uncertain at present. It is tempting to
speculate on this, but only intensive long-term studies
-------
538
J. Z. Reynolds
will reveal the facts. Local increases in algal growth
very probably will develop if sufficient nutrients are
available, since biological activity is greater in
warmer than in cooler water. The magnitude of these
increases must be known before there can be evaluation of
the potential problem."
Then, after discussing the relative merits of low
or high velocity, and offshore or onshore discharges, the
committee reported that:
"A recommendation that one or the other (type of
discharge) be routinely required for all power plants would
have to be supported by firm information on damages to
water quality and uses that would result from failure to
require such devices. Available information on potential
damages does not provide a basis for such a position at
this time. Such information can be obtained through
studies by aquatic biologists of areas in Lake Michigan
where large fossil fuel plants presently discharge large
quantities of cooling water."
To our knowledge the biological data that have been
compiled since the committee's report have failed to
substantiate any significant biological effects.
It is also interesting to note that in the same
report after computing the total heat input into Lake Michigan
-------
539
D. H. Brandt
from existing and proposed power plants, the committee
concluded that "there is a minimum need for immediate
concern over the effect of temperatures on the lake as a
whole." They went on to say that the probable long-range
effects deserve consideration. We agree there may be
some future point at which the effects of substantial
additional thermal discharges might cause significant
effects for the lake as a whole. We demonstrate our
concurrence with their observation that the possible local
effects are of more practical and immediate concern in that
our ecological investigations are largely oriented to
detect such influences of thermal discharges.
Mr. Chairman, Mr. Brandt will continue with this
report.
MR. BRANDT: Mr. Chairman, at this point we would
like to take a few moments to review with the conferees
the sequence of events experienced in the State of Michigan
in setting temperature standards for Lake Michigan and for
the other waters of Michigan.
We start off with — it was a recommendation of
the National Technical Advisory Committee that I would like
to refer to first in the so-called "green book," quote,
"On February 27, 1967, the Secretary of the Interior
established the first National Technical Advisory Committee
-------
D. H. Brandt
on Water Quality Criteria to the Federal Water Pollution
Control Administration. The committee's principal function
was to collect into one volume a basic: foundation of water
quality criteria."
As described in the introduction to the report
of the National Technical Advisory Committee on Water Quality
Criteria dated April 1968:
"The committee was concerned about several issues
relating to water quality standards for the control and
abatement of water pollution. Foremost among these is the
lack of adequate knowledge concerning many of the quality
characteristics upon which criteria arid, hence, standards
should be based. The unknowns still outweigh the knowns.
Complicating factors in setting standards are varying
natural conditions affecting water quality, such as climate,
geography, and geology of a specific location. The
committee does not want to be dogmatic in recommending these
criteria. They are meant as guidelines only, to be used in
conjunction with a thorough knowledge of local conditions,,
Further, it is anticipated that future research will
provide considerable basis for refinements in the
recommendations."
"The committee recognizes that the protection of
water quality for legitimate uses requires far more than
-------
D. H. Brandt
scientific information. There is an urgent need for data
collected from systematic surveillance of waters and
waste sources and for an expanded research effort."
While the committee observed that for lakes the
situation is complex and cannot be specified in simple
terms, their recommendation for both warm and cold water
lakes was that the temperature of the e^ilimnion should
not be raised more than 3 degrees P. by the addition of heat
of artificial origin. They further qualified that position
in the case of warm waters saying that, "In those areas
where important organisms are most likely to be adversely
affected (the temperature) should not be raised more than
3 degrees P. above that which existed before the addition
of heat of artificial origin." The committee members
clearly implied that they felt temperatures in excess of
3 degrees P. within a mixing zone were of no special
significance unless, of course, it could be demonstrated
that harmful effects would occur.
It should be pointed out that while the committee
made no specific reference to mixing zones with regard to
freshwater organisms, in discussing criteria for marine
and estuarine organisms it was stated that the suggested
temperatures were to apply outside of mixing zones, which
would be related to required zones of passage. The situation
-------
542
D. H. Brandt
regarding heated discharges into very large lakes, such
as Lake Michigan, would be comparable to ocean discharges
in this respect.
The committee could be criticized, however,
for not making a distinction between mixing zones involving
temperature and those that would involve contaminating
substances. They stated, in effect, that dilution flows
should be very large to limit the area of mixing. While
this would be generally true for contaminating substances
which would remain in the water body, discharge of heated
waters involving buoyancy effects and dissipation of heat
to the atmosphere complicates the task of defining
mixing and zones of passage. The significance of the
configuration of the mixing zone or its dimensions can
only be based on Individual site considerations and the
nature of the aquatic life or other beneficial uses to be
protected.
Now, in the past 3 years there has been an ongoing
effort to obtain approval of the Michigan water temperature
standards. We would like to take a moment to touch
on a few significant exchanges in that regard.
Initally in the State of Michigan, in accordance
with the Federal Water Pollution Control Act, as amended
by the Water Quality Act of 1965, the Governor of the State
-------
543
D. H. Brandt
of Michigan wrote to the Secretary of Health, Education,
and Welfare on December 17, 1965, that it was the intent of
the State to adopt criteria applicable to interstate waters
under the authority of Act 245, Public Acts of 1929, as
amended. The Michigan statute declares to be unlawful
the discharge of any substance "which is or may become
injurious to public health, commercial, industrial,
agricultural, recreational or other uses which are being
or may be made of such waters; or which is or may become
injurious to the value or utility of riparian lands; or
which is or may become injurious to livestock, wild animals,
birds, fish, aquatic life or plants or the growth or
propagation thereof be prevented or injuriously affected;
or whereby the value of fish and game is or may be destroyed
or impaired."
Section 5 of the Act declares in part:
"The Commission (Michigan Water Resources
Commission) shall establish such pollution standards for
lakes, rivers, streams and other waters of the state in
relation to the public use to which they are or may be put,
as it shall deem necessary."
In June 1967, water temperature standards for the
Great Lakes were adopted by the Michigan Water Resources
Commission and submitted by the State to the Federal
-------
D. H. Brandt
Government for approval. It reads as follows:
"For the Great Lakes and connecting waters no
heat load In sufficient quantity to create conditions which
are or may become injurious to the public health, safety,
or welfare; or which are or may become injurious to domestic,
commercial, industrial, agricultural, recreational or other
uses which are being or may be made of such waters; or
which are or may become injurious to the value or utility of
riparian lands; or which are or may become injurious to
livestock, wild animals, birds, fish or aquatic life or the
growth or propagation thereof."
The Federal action following that: Even though
the temperature standards adopted by the Michigan Water
Resources Commission in 1967 appeared to contain all the
necessary restrictions defined in the Federal Water Pollution
Control Act, and met the constitutional requirement that
beneficial uses unrelated to any injury could not be
prohibited, the Secretary of the Interior did not approve
them.
Then, on October 23, 1969, H. W. Boston, Regional
Director of the Federal Water Pollution Control
Administration, U. S. Department of the Interior, sent to
R. W. Purdy, Executive Secretary of the Michigan Water
Resources Commission, a proposed Lake Michigan temperature
-------
D. H. Brandt
Standard, stating, "This standard is the result of a
comprehensive review of temperature and aquatic life data
for Lake Michigan conducted by the National Water Quality
Laboratory in Duluth."
... Slide ...
The recommendations for monthly maximum surface
temperature in degrees P. were: January, 50; February, 50;
March, 50; April, 50; May, 55; June, 70; July, 85; Augusts,
85; September, 85; October, 85; November, 70; December, 55.
No recommendations were made regarding the
definition of mixing zones and the only comments on discharge
areas were related to the possibility of fish kills and
the blockage of tributaries supporting anadromous fish.
State action: On February 17, 1970, Carlos
Fetterolf, Supervisor of the Water Quality Appraisal
Section, Michigan Water Resources Commission, reported to
the Commission that his staff had explored the reasons
for disapproval of the Michigan temperature standards by
the Federal Government. He then submitted new standards
for consideration.
The principal changes for the Great Lakes involved
substitution of a 5 degree F. temperature rise limitation
and the setting of monthly maximum temperature values otit-
side of mixing zones to be defined by the Michigan Water
-------
546
D. H. Brandt
Resources Commission. Lake Michigan was divided into
northern and southern sectors at Pentwater, Michigan. No
increase would be allowed greater than 5 degrees F. nor
any temperature above 80 or 85 degrees F. for the
northern and southern sectors, respectively.
He reaffirmed the MWRC staff position that mixing
zones should be established based on individual site
conditions and stated further that Dr. Mount of the FWPCA
Duluth Laboratory had questioned the advisability of
subjecting mixing zones to formula identification.
Apparently some FWPCA representatives had informally
suggested that formulas would be appropriate.
The MWRC scheduled a public hearing for March 19..
1970, to review the staff recommendations. In the meantime,
however, the staff felt that approval from FWPC,. could
be expedited by complying with their further request for
numerical monthly temperature maximums for the Great
Lakes, and by adding some general considerations as to
philosophy of regulation.
The proposed monthly temperature limitations for
the southern sector of Lake Michigan, for instance, in
degrees F. were: —
... Slide ...
MR. STEIN: Let's have the lights on, please.
-------
547
D. H. Brandt
MR. MAYO: What page are you leading to,
Mr. Brandt?
MR. BRANDT: This would be 11-13, sir, at the top
of the page.
January, 50; February, 50; March, 60; April, 65;
May, 75; June, 85; July, 85; August, 85; September, 85;
October, 70; November, 60; December, 50.
The maximum temperature limit for the northern
sector would be 80 degrees F.
Federal action: Representatives of FWPCA
testified at the public hearing on March 19, 1970, at which
time they presented an edited copy of the proposed State
regulations. They suggested striking any reference that
mixing zones be related to the value of aquatic life and
physical characteristics of the receiving water body, and
all qualifying statements as to the extent of adverse
effects. It was suggested that mixing zones be defined by
formula but should not exceed 1 mile in radius.
They further suggested that the Great Lakes be
separated into lossely defined open waters and inshore
waters. For Lake Michigan the recommended temperature
limits for open waters in degrees F. were:
... Slide ...
January, 42; February, 37; March, 37; April, 44;
-------
548
D. H. Brandt
May, 53; June, 65; July, 71; August, 74; September, 72;
October, 65; November, 54; December, 50.
It was pointed out at the hearing by Mr. Purdy of
MWRC that these suggested limits are exceeded, due to
natural causes, on a regular basis.
Consumers Power Company has collected a
considerable amount of temperature data from two power
plants on Lake Michigan that are somewhat representative of
lake temperatures. One, the Big Rock Point plant, has
an intake that is located 1,450 feet from shore at a depth of
approximately 25 feet and would be subject somewhat to
stratification influences. The range of maximum daily
average temperatures for each month for a 6-year period
of record are shown on Exhibit II-A (See P.462), as are
the temperature limitations proposed in March 1970. It
should be noted that for 7 of the 12 months during this
short period of record, the natural intake temperatures
equaled or exceeded the limitations proposed by PWPCA for
open waters in Lake Michigan.
The J. H. Campbell plant intake is located on
Pigeon Lake into which Lake Michigan water flows. Prom a
temperature standpoint the intake is indicative of "inshore"
conditions, though some recirculation from the discharge
occurs periodically. The range of maximum daily average
-------
549
D. H. Brandt
temperatures for each month for a 6-year period of record
is shown on Exhibit II-B (See P. 463), with the proposed
temperature limitations for open and inshore waters.
For several months the maximum daily average temperature
exceeded the proposed FWPCA limitations for every year of
record. In 3 months the proposed limit was exceeded by
over 10 degrees F. which would be difficult to account for
by considering the maximum effect of recirculated
discharge from the plant.
FWPCA representatives further recommended that a
3 degree F. temperature rise outside the mixing zone be
the limitation for Lake Michigan.
Their testimony supported the MWRC staff proposal
that the water resources be protected for the "optimum
use by fish, wildlife and other aquatic life," without
mention of other beneficial uses. They further
recommended that "at no place in a mixing zone shall the
96-hour median tolerance limit (96 hr. TL ) to aquatic
m
life be exceeded." The recommendation did not define
what aquatic life was to be protected. No explanation or
justification for such a restrictive limitation, was
given.
Qn April 10, 1970, F. T. Mayo of the FWPCA
regional office submitted additional recommendations. The
-------
550
D. H. Brandt
suggested monthly maximum temperature limits for La,ke
Michigan inshore waters in degrees P. were: January, 42;
February, 37; March, 37; April 44; May, 53; June, 65; July,
72; August, 77; September, 75; October, 65; November, 54;
December, 50.
It was further recommended that mixing zones
should not include waters within 600 feet of shore.
State action: After the March 1970, hearing,
the MWRC released the results of a study consisting of
approximately 24,000 temperature readings from eight Lake
Michigan water intakes in Michigan which are unaffected by
heated discharges and over 300 shoreline temperatures from
twenty swimming beach stations. This study was initiated
after consultation with Federal Water Quality
Administration representatives.
At a meeting in Ann Arbor, Michigan, on April 16,
1970, it was agreed by the Lake Michigan Enforcement
conferee representatives that the States and FWQA would
tabulate existing temperature data for Lake Michigan. The
90th percentile value to be determined fron. this data would
then serve to establish monthly maximum temperature
limitations. This information would be the basis for
discussions at the Executive Session of the Lake Michigan
Enforcement Conference scheduled to be held in Chicago on
-------
551
D. H. Brandt
May 7, 1970.
Federal action: The meeting in Chicago on May
7, 1970, although scheduled as an executive session, actually
became a public hearing. The following statement issued by
Carl L. Klein and Leslie Glasgow, Assistant Secretaries of
the Interior, was read before the Lake Michigan Enforcement
Conference:
"The minimum possible waste heat shall be
added to the waters of Lake Michigan. In no event will
heat discharges be permitted to exceed a 1 degree P. rise
over ambient (existing temperature) at the point of
discharge. This will preclude the need for mixing zones."
This declaration effectively negated the
substantial efforts of the State conferees and the
staff of FWQA, during the previous months, to resolve
differences in concepts and to secure a reasonable basis for
temperature standards.
State action: The MWRC requested FWQA to provide
written clarification of the policy statement issued by
Carl L. Klein and Leslie Glasgow, and scientific documentation
which would show the need for such a strict policy.
On September 18, 1970, the MWRC expressed its
support of a revised set of temperature standards, as
recommended by the staff. Their proposed maximum monthly
-------
51)2
D. H. Brandt
temperature standards for the open waters of the
southern sector of Lake Michigan in degrees P. are as
follows: January, 35; February, 35; March, 39; April, 49;;
May, 57; June, 67; July, 74; August, 76; September, 73;
October, 64; November, 54; December, 43.
Similarly, the proposed standards for the inshore
waters of this sector in degrees P. are: January, 38;
February, 38; March, 42; April, 54; May, 63; June, 78; Jul.y,
82; August, 82; September, 80; October, 70; November, 60;
December, 48.
The maximum temperature limit proposed for the
inshore waters of the northern sector of Lake Michigan is
76 degrees P.
The proposed temperature standards for inshore
waters are based on the 90th percentile, adjusted for 3
degrees P. increase at the edge of the mixing zone.
This recitation of exchanges between the Department
of the Interior and the MWRC has been primarily for the
purpose of illustrating the confusion that prevails
concerning the adoption of temperature standards. The
sincere and honest efforts of many who have worked
to develop reasonable temperature standards, based on
technical evidence, .have been repeatedly destroyed by
inconsistent and confused pronouncements and recommendations
-------
553
D. H. Brandt
by others.
It is the philosophy of the Federal Water
Pollution Control Act to assure that all waters will be
equally protected for all legitimate uses. Propagation
of fish and wildlife is one of those legitimate uses.
Utilization by industry is another one. This is
particularly true for those rivers and lakes where
either or both of these uses are already established.
Industry must not be allowed to pollute a body of water and
destroy the fish and wildlife that exist. Similarly,
propagation of fish and wildlife must not be such as to
destroy or pose intolerable burdens upon the industries
that utilize the waters. We believe it is possible to set
standards that will satisfy both requirements.
In view of this, we objected to several
statements and suggestions made by the representatives of
FWPCA at the March 19, 1970, MWRC hearing regarding
thermal discharges, effects, and regulations.
Their basic rationale, as stated by Dr. Donald
Mount of the National Water Quality Laboratory, Duluth,
Minnesota, that "when protecting aquatic life we normally
protect the waters for all beneficial uses," and their
suggestion that the 96-hour median temperature tolerance
limit to aquatic life not be exceeded at any point is
-------
D. H. Brandt
meaningless unless related to specific aquatic life to be
protected.
Dr. Mount's statement that "fishes are repelled
by temperatures that are unacceptably high during the
summer months and, therefore, these pose no particular
problem except that the habitat available is reduced in
area," is clearly inconsistent with the PWPCA position
taken at the same meeting that at no point should
temperatures exceed values that have been shown to cause
detrimental effects in confined laboratory conditions.
Likewise, a rigid definition of lake mixing
zones based solely on a rate of discharge, as they
suggested, does not recognize either the potential effects
of thermal discharges on aquatic life or a beneficial-use
concept. Dr. Mount's brief statement; that "every mixing
zone should be defined geographically," oversimplifies
the ecological complexity of the waters involved, as does
the FWPCA recommendation that uniform temperature limits
should be imposed on each of the Great Lakes.
Dr. Mount was concerned that fish residing in
warm-water effluents during the winter be protected in case
the plant must be shut down. The fish that are most likejly
to inhabit this relatively small area would not find
the normally cold lake temperatures suitable. As such, these
-------
555
D. H. Brandt
warm-water areas provide for greater diversity of fish
habitat for the lake as a whole, and, although these fish
might be temporarily adversely affected by plant shutdown,
the natural populations should not be significantly
affected.
Similarly, the importance of maintaining the
"normal daily fluctuations" for the Great Lakes has been
overstated in the various proposed standards, in view of
the great natural temperature fluctuations that occur from
day to day. This situation is described in the "white
paper" and it well documented in the records of the staff
of the MWRC and others.
While the FWPCA concept in March 1970, of
differentiating between inshore waters and open waters
is ecologically sound, the definition set forth by FWPCA
was not complete enough to allow for confident prediction
of these limits, either spatially or temporally. They
stated simply that, "Inshore waters are those waters which
are affected by tributary stream plumes (other than connecting
channels), near shore thermal bars, natural shore erosion,
or bottom sediment resuspended by wave action. Waters not
defined as inshore waters would be considered as open waters."
The "white paper" now defines the inshore zone
-------
556
D. H. Brandt
as, "That volume of water which lies between the shoreline
and the 100-foot depth contour," and includes what is called
a "beach water zone, a sub-area that extends from the
shoreline out to the 30-foot depth contour." This vacillation
in establishing basic definitions does not facilitate efforts
to set standards.
Whether for inshore or open waters, any
temperature regulations should reflect naturally-occurring
conditions, and allow for variations consistent with
those known to occur without any thermal discharges.
It was pointed out at the March 1970, hearing that
a 58-degree P. limitation, as proposed by FWPCA for migratory
routes of salmonid species during migration, was
unrealistic considering the fact that healthy migrations
occur in 70-degree P. water. Similarly, lake water
temperatures should not be arbitrarily restrictive, in vlev
of the fact that extreme temperature excursions have
occurred in the past by natural and artificial means,
with no apparent damage to the aquatic ecology.
Dr. Mount made the statement, when questioned
about the natural conditions exceeding his recommendations,
"That if the temperature is unacceptable, it is
unacceptable whether it has been caused by the sun or man."
This should cause us to pause and consider the nature of
-------
557
J* Z% Reynolds
the situation. Because if the artificial aquatic habitat
mankind has nurtured, in the lakes particularly, is truly
unsuited to this climate, the concept of beneficial use
of these waters by all citizens should receive prompt
and thorough review if, according to law, other beneficial
uses should not be placed in Jeopardy because an especially
delicate fishery has been developed, as Dr. Mount suggests.
Consumers Power Company is convinced that
this is not the situation, and based on years of
experience with thermal discharges on the Great Lakes, is
certain that even greater heat loads can be added to the
lakes without harming the aquatic ecology as it exists
today or otherwise interfering with other reasonable
beneficial uses.
Dr. Reynolds will now speak about the environmental
programs that the company has conducted and is conducting
at the present time.
DR. REYNOLDS: As mentioned earlier, concern for
preserving the —
MR. STEIN: Dr. Reynolds, how long will this
paper continue, for another hour? How long do you expect
to have?
DR. REYNOLDS: Don, do you have the time on
this?
-------
558
J. Z. Reynolds
MR. STEIN: That we have left on the paper.
DR. REYNOLDS: How much time do you estimate we
have left?
MR. PETERSEN: Forty-five minutes on this part
of the presentation and another 45 minutes after that.
MR. STEIN: Let's recess for 10 minutes.
(Short recess.)
MR. STEIN: Let's reconvene.
Would you continue?
DR. REYNOLDS: Mr. Chairman, before I proceed,
on section II, page 20, I would like to correct a typographi-
cal error for the record.
The second paragraph, the last sentence where it
starts out, "According to the —" there should have been
an, "If, according to the law."
MR. STEIN: Where is that?
Would you give us the citation again, please?
Let's have the page.
DR. REYNOLDS: Page 20, section II.
MR. STEIN: Where do you want the "if"?
DR. REYNOLDS: In the second paragraph the last
sentence where it starts out, "According to the law."
MR. STEIN: Where do you want the "if"?
DR. REYNOLDS: Start out the sentence, "If
-------
559
J. Z. Reynolds
according to the law, other beneficial uses should not
be placed in jeopardy because an especially delicate fishery
has been developed, as Dr. Mount suggests."
MR. STEIN: I know I went to these effete
English schools, but that isn't a sentence the way you
changed it.
DR. REYNOLDS: I am sorry, that shouldn't be a
new sentence, that should be a comma.
MR. STEIN: How do you want that now?
DR. REYNOLDS: A comma where the period went
before that sentence, insert "if" and make that a small "a"
and go ahead.
O.K.?
MR. STEIN: O.K. Let's go on.
DR. REYNOLDS: As mentioned earlier, concern for
preserving the environment has historically been the
corporate policy of Consumers Power Company. This concern
for preserving water quality in Michigan can best be
demonstrated by describing our water quality surveillance
programs conducted in the past several years at all our
major generating stations.
The company has engaged the services of
university and private consultants in all facets of the
aquatic sciences, cooperated with efforts of State agencies,
-------
560
J. Z. Reynolds
and has added technically-qualified staff in this field.
As a result of this combined effort, over 80 temperature
surveys and 20 biological surveys have been conducted to
date in the cooling water discharges of the company's
seven major electrical generating sites. Exhibit III-A
summarizes these studies. (See P. 471) It should be noted
the list of surveys shown in Exhibit III-A includes only
surveys related to thermal effects and does not include
numerous radiological and other surveys that have been
conducted relative to water quality.
Beginning in 1967, a series of temperature
surveys have been conducted at the 531 MWe B. C. Cobb
plant on Muskegon Lake. Most have been made during
fish migratory seasons to determine the plant's influence
on the zone of passage in Cedar Creek (North branch
Muskegon River). These studies have demonstrated that a
zone of passage was maintained in Cedar Creek from the point
of condenser water discharge to Muskegon Lake. As an
example, the thermal plume observed on July 17, 1970, is shown
on Exhibits III-B, C, and D (See p.. 473, W, *»75) for the
surface, 2-foot depth and bottom, respectively. Other
temperature surveys have been conducted on Muskegon Lake
and include an infrared aerial survey in 1970.
Since I960, Consumers Power Company, in cooperation
-------
561
J. Z. Reynolds
with various State agencies, has conducted a routine
radiological monitoring program of the biota in the vicinity
of the 71 MWe Big Rock Point plant on Lake Michigan near
Charlevoix. In addition, temperature surveys have been
conducted, including two infrared flights. The surface
plume observed on June 18, 1968, is shown on Exhibit
III-E, as an example. (See P. 476)
A comprehensive biological survey has been
conducted at the 1226 MWe Karn-Weadock facility on Saginaw
Bay, which includes bottom fauna, plankton and macrophytes.
In conjunction with the study, the results of which will
be available later this year, extensive fish surveys were
conducted in the discharge vicinity. In addition, numerous
thermal plume measurements were made, including an infrared
aerial survey in 1970. The thermal plume observed on
August 7, 1970, is shown on Exhibits III-F, G, and H (See
p. 478, 479, and 480) for the surface, 2-foot and 5-foot
depths, respectively.
Since 1966, several thermal plume surveys have
been conducted at the 342 MWe J. R. Whiting plant on Lake
Erie, including two infrared aerial surveys this year.
The thermal plume observed on June 17, 1970, is shown on
Exhibits III-I and J (See p. 481, 482) for the surface
and 5-foot depth, respectively.
-------
562
J. Z. Reynolds
It is not practical to include in this report the
full details of the above studies. However, some graphic
illustrations from a few of the thermal surveys have
been shown because they document various plume characteristics
for different plant locations, loads and meteorological
conditions.
Ten temperature and two biological surveys
have been conducted at the company's J. H. Campbell plant
site on Lake Michigan near Holland. The following
information includes some of the results of these surveys.
Temperature surveys: The condenser cooling
water for the J. H. Campbell plant is drawn through
Pigeon Lake and discharged into Lake Michigan at a maximum
rate of about 300,000 g.p.m., with an average temperature
rise of about 17 degrees P. The Campbell plant has two
units and is capable of producing 64? MWe.
On July 10, 1970, a surface water temperature
survey of the J. H. Campbell plant condenser cooling water
discharge, as shown on Exhibit III-K (See P.483), was
made when the plant intake temperature was 66 degrees P. and
the discharge temperature was 82 degrees F. The plant was
discharging approximately 300,000 g.p.m. Due to
unfavorable lake conditions (rough water), temperature
profiles were not made. A 15 m.p.h. north wind caused the
-------
563
J. Z. Reynolds
main portion of the plume to travel south for approximately
1 mile before it dissipated. The unusual plume
configuration, shown on this exhibit, resulted from a change
in wind direction during the preceding 10-hour period.
At points 6,000 feet north and south of the discharge the
temperature was 66 degrees P. from the shore lakeward. The
maximum offshore extent of the plume was approximately
1,000 feet.
On August 26, 1970, another surface water
temperature survey was conducted as shown on Exhibit
III-L. (See P. 485) The plant was operating only with
Unit No. 1 and was producing 247 MWe. The discharge was
approximately 120,000 g.p.m. with intake and discharge
temperatures of 74 degrees F. and 85 degrees P., respect-
ively. During the survey the wind was from the S-SW at
about 10 m.p.h. and the plume was traveling northward
alongshore in a relatively narrow ban. The maximum
offshore extent of the plume was about 800 feet at the
point of discharge. The plume at 6,000 feet to the north
was within 1 degree F of the ambient lake temperature.
There was no measurable increase above ambient
temperature, 6,500 feet to the north.
Another surface water temperature survey was
conducted, as shown on Exhibit III-M (See P. 486), on
September 9, 1970. An additional objective of this
-------
564
J. Z. Reynolds
survey was to gather ground-truth data for an infrared
imagery flight made on that day. The plant load was 568
Me and the discharge was approximately 300,000 g.p.m. The
intake temperature was 72 degrees P. and the discharge
temperature was 89 degrees P. The wind was from the S-SW
at speeds up to 5 m.p.h. It was evident during this
survey that the plume was shifting to the north. The
northern boundary of the plume moved 500 feet further
north in approximately 1 1/2 hours. Near the point of
discharge, where the surface temperature was about 88
degrees P., the temperature at 3-ft. depth was 7^ degrees
P. Where the surface temperature was observed to be
79 degrees P., the ambient temperature of 72 degrees P.
was found at 2-ft. depth.
1968 biological survey: To assist Consumers
Power Company in evaluating the impact of heated water
discharges on the biota of southeastern Lake Michigan,
T. W. Beak Consultants Limited were retained to
carry out a biological survey in the vicinity of the J.
H. Campbell plant. The survey work was carried out on
August 30, 1968. Field work was accomplished by T. W.
Beak Consultants Limited and a crew from the Michigan
Department of Conservation, assisted by Consumers'
technical staff.
-------
565
J. Z. Reynolds
Eight sampling stations were selected; seven in
the vicinity of the cooling water discharge point and
one, a control, 3 Biles south of the plant. Station
locations are shown in Exhibit III-N. (See P.488)
Distances and directions were measured by means of an
electronic range finder and compass headings. At each
station, six bottom samples were taken by means of a Ponar
dredge. This is a clam-shell type device which cuts
about 1/2 sq. ft. of the bottom to a depth of 2 to 6 inches,
depending on texture. Samples were washed in a 30-mesh
screen, to remove sand and mud, and preserved for shipment
to the laboratory. There the benthic macroinvertebrate
organisms were hand-sorted, classified to major taxonomic
groups and counted.
Plankton samples were collected at each station
by means of an electric pump with a calibrated intake
hose which could be lowered to the desired depth. To obtain
a sample, about 40 liters of water from a 5-ft. depth were
strained through a Wisconsin plankton net aboard the boat.
One additional sample from a 10-ft. depth was taken at
station .8, where the water was deeper. The concentrated
plankton samples were preserved and sent to the laboratory
for analysis.
The lake bottom in the study area consists mainly
-------
566
J. Z. Reynolds
of fine, loose sand, mixed with some gravel at the inshore
stations. There were no stable deposits of silt or organic
debris.
The prevailing movement of heated water away
from the discharge point is northward along the coast, fol-
lowing the general counterclockwise circulation pattern in
the southern basin of Lake Michigan. The biological
results from the control station, 3 miles south, indicate
the makeup and density of the benthic community outside
the warm-water plume.
In order to compare the density and diversity
of organisms, the number of general taxonomic groups found
and their average numbers per square foot at each station
were calculated. The principal observation which can be
made concerning these data is that there is very little
difference between the animal communities in the plume
and control areas. The dominant animal forms in both areas
were midge larvae (Chironomidae) and scuds (Amphipoda).
The density of organisms at all inshore stations
(400 ft. offshore) was quite similar.
Stations 8 and 9 which were the furthest offshore
yielded numbers of midge larvae and scuds approaching those
found at the 1/2-mi. stations near South Haven, Michigan,
in May. This suggests that distance from shore is an
-------
567
J. Z. Reynolds
important factor in explaining the observed animal
distribution. Station 1, which was slightly closer to
shore, yielded results similar to those at the 400-ft. line,
The extreme scarcity of aquatic segmented worms, which are
detritus feeders, probably reflects the absence of
significant sources of organic wastes in the area. The
bottom fauna were found to be sparse and restricted in
variety. Two main factors appear to be responsible for
this—the sand bottom, which is not highly productive
even when not mechanically disturbed , and the shallow
depth which results in bottom sediment disturbance by
waves.
On the basis of the study results, the
biological consultants concluded that there appeared to be
no gross thermal damage to the benthic fauna of the main
plume area at the Campbell site.
1970 biological survey: To further document the
effects of condenser water discharges into Lake Michigan,
another biological survey was conducted in 1970 at the
J. H. Campbell plant. The 1968 biological sampling
stations and five additional offshore stations were sampled
on August 26, 1970, for benthic organisms. Three Ponar
dredge samples were collected at each of the thirteen
stations on Exhibit III-O. (See P. ^91) The samples are
-------
568
being analyzed as they were in 1968, and the Results will
be available later this year.
The temperature and biological studies which have
been conducted at the J. H. Campbell plant have shown:
1) The ecology of Lake Michigan in the
condenser water discharge area has not been significantly
affected.
2) Wind velocity and direction influence the
maximum extent and pattern of the thermal plume.
3) Temperature profile data have shown that
outside the immediate area of the discharge the plume is
confined primarily to the surface waters.
The Palisades nuclear plant, located on the
eastern shoreline of Lake Michigan, 5 miles south of South
Haven, Michigan, is designed for initial operation at
2^00 MWt and 710 MWe. The ultimate capacity is expected
to be approximately 2,600 MWt, corresponding to 845 MWe.
Condenser cooling water is withdrawn through a crib intake
20 to 25 feet below the lake surface, about 3,300 feet
from shore, at a rate of 390,000 g.p.m., and is discharged
through a simple diverging pile structure at the shoreline
as shown on Exhibit III-P. (See P. 493).
Concern about the environmental effects of the
plant prompted Consumers Power Company to engage the ser-
vices of University of Michigan biologists to develop a
-------
569
J. Z. Reynolds
study plan to detect any effects of the heated discharge
on the aquatic biota of Lake Michigan. The biological
collection and analysis are being done by T. W. Beak
Consultants, Limited, in cooperation with the Michigan
Department of Natural Resources.
Temperature and biological surveys conducted
at the J. H. Campbell plant in 1968, as described earlier,
indicated no significant ecological effects from that heated
discharge. The Palisades plant, however, is larger, and
a more cautious approach of thoroughly studying its discharge
effects was initiated to insure that if subtle ecological
changes take place they will be detected.
The biological studies at Palisades are
sufficiently comprehensive in scope to detect, either
directly or indirectly, virtually any significant effect on
the local aquatic ecosystem attributable to the thermal
discharge. These studies are concentrated on the benthos,
plankton, periphyton, fish, and, of course, temperature.
The benthos are considered to be the most
delicate indicators of ecological change since they are
relatively sessile and cannot escape environmental stress
conditions. Plankton and periphyton are also good
indicators of change, being relatively low in the food chain
and only passively moved, and provide direct indications or
-------
570
J. Z. Reynolds
nuisance conditions should their populations increase
drastically. Limited fish sampling is conducted since,
aside from being highly mobile, fish are relatively slow
in reacting to environmental changes providing toxic
conditions are not a factor.
The survey area near the pliant is shown
on Exhibit III-Q (See P. 495) and the basic fan-shaped
sampling grid is identified. Sampling stations were
established on 1/4-, 1/2-, 1-, 2-> and 5-mi. radii on nine
radial lines. In addition, there are two control stations
located near each of the cities of South Haven and Benton
Harbor, about 7 miles north and 16 miles south of the plant
site, respectively. The surveys began in 1968 with samples
scheduled to be gathered in early May, late June, August
and October. The initial survey is planned to extend for
5 years. The sampling stations are not marked in the field,
but are accurately located by means of an electronic
range finder.
Indicated on Exhibit III-Q is the initial basic
plan for collection of benthos, plankton and periphyton
at the various locations. The basic sampling grid, not
counting control stations, contains 21 stations for benthos,
10 for plankton, and 3 for periphyton. Some minor
modifications since the survey began included the addition
-------
571
J. Z. Reynolds
of several more inshore benthic stations in exchange for
two benthic stations at 5 miles, and the addition of
several plankton and periphyton stations. Adverse
weather conditions have precluded the collection of a
few samples, but without loss to the integrity of the
coverage.
All benthos samples are collected by means of a
Ponar dredge, as shown in Exhibit III-R. (See P. 497)
The bottom deposits of the study area consist of mixed
gravel and coarse sand inshore, grading outward to medium,
then fine sand, and then to fine sand mixed with silt at
approximately 2 miles offshore. At 5 miles offshore, fine
sand is overlain in irregular patches by organic
detritus.
In 196S, six replicate samples of benthos were
collected at each station, the macroinvertebrate organisms
screened out and preserved for shipment to the laboratory,,
The samples were analyzed for all benthic macroinvertebrate
and identified to family in all cases and to genus wherever
possible. In addition, one sample from each station from
each survey was analyzed and the organisms identified to
species, or as close to species as taxonomy permitted. The
replicate samples were sufficiently uniform in 196$ that
the procedure in 19&9 was modified to collect only three
-------
572
J. Z. Reynolds
replicates.
Analysis of benthic data to assess environmental
conditions and changes in the aquatic ecosystem can proceed
along several different lines. For example, indicator
organisms can be selected for detailed study, and the
relative numbers compared before and after plant operation,
and in proximity to the plant discharge. Such an
organism representative of clean water conditions, and
widely prevalent in Lake Michigan, might be the Crustacea.,
amphipoda (commonly called aquatic scuds), consisting
of the dominant species Pontoporeia affinis. An example
of the relative distribution of this organism is shown in
Exhibit III-S (See P. 499) for the August 1968, sampling
period.
Another approach would be to examine an organism
that is known to be relatively pollution-tolerant or to
compare relative numbers of tolerant and intolerant
species. The dominant representative of tolerant
organisms would be the oligochaeta (made up of numerous
species known as aquatic earthworms, tubificids or sludge-
worms). The relative distribution of these organisms
observed in August of 1968 is shown in Exhibit III-T as
an example. (See P. 500)
The relative populations of other benthic
-------
573
J. Z. Reynolds
organisms will also be studied and correlated, not only
within the project area, but also in relation to similar
data being gathered at other locations around the lake.
Species diversity of the entire benthic
community is another tool for assessing the influence of
environmental factors and is readily adaptable to
statistical analysis. A crude illustration of the
variation of species number with depth for August 1968,
is shown in Exhibit III-U. (See P. 501) The scarcity of
benthic organisms in the sandy, wave-swept shallows should
be noted, along with the apparent evidence that the
southern control stations are relatively sparse and
unrepresentative of the project area in this respect.
Plankton samples are obtained by passing 40
liters of water through a Wisconsin plankton net as shown
in Exhibit III-V. (See P. 503) At each station, samples
are collected at depths of 5, 10, and 15 feet. The
preserved samples are received at the laboratory where
they are centri fuged and the volume of plankton concentrate
measured.
Relative changes in plankton concentrations, both
within the project area and as related to the control
stations, will indicate whether the thermal discharge is
having a substantial impact on these organisms. Stimulation
-------
574
J. Z. Reynolds
of algal growth, such as the filamentous green algae • '
Cladophora, to nuisance proportions would be so detected.
Subtle changes in relative numbers of the various types of
plankton can only be verified through microscopic
examination. When the plant is in operation, samples will
be collected for such detailed analysis in the immediate
vicinities of the intake and discharge.
Typical results of the plankton concentrate
analysis are shown in Exhibits III-W and -X. (See Pp.
504 and 505) Exhibit III-W shows the seasonal succession
of plankton concentrations at the 5-ft. level 1, 2,
and 5 miles from shore. Exhibit III-X similarly shows
concentrations at 5, 10, and 15 feet deep at the 1-mi.
station. This data clearly shows the general cyclic nature
of the phytoplankton production. This fluctuation is
typical of Lake Michigan in which diatom populations dominate
and bloom in early spring and late fall.
Periphyton organisms are collected on artificial
substrate, constructed of Plexiglas plates, which are
suspended from metal supports imbedded in concrete blocks.
The samplers are placed in 15 feet of water and after
suitable exposure, at least 4 weeks, they are retrieved.
The preserved plates are sent to the laboratory where the
periphyton scrapings from the plates are extracted with
acetone and the amount of chlorophyll determined
-------
575
J. Z. Reynolds
spectrophotometrically.
The periphyton sampling program was beset with
considerable difficulties in both 1968 and 1969. Inter-
mittent storms hampered the retrieval of the collection
plates. In addition, public destruction resulted in the
loss of all but a few marker buoys. The addition of several
more unmarked samples to be recovered by divers has been
instituted to compensate for these problems.
Chlorophyll analysis for the 1-month exposure
in May-June 1968, yielded concentrations ranging from
0.0 to 0.0056 micrograms per square centimeter. Sufficient
data are not available for confident representation of
seasonal fluctuations or other natural variations.
Information gathered on periphyton during plant operation
will be analyzed primarily to detect correlation between
growth and proximity to the plant outfall.
The Michigan Department of Natural Resources
has provided the vessel used in the biological sampling
program and their personnel have been in charge of all
fish sampling and analysis. Their sampling schedule
calls for gill nets of various mesh sizes to be set for
two 24-hour periods four times a year at depths of 20 feet,
40 feet and 55 feet. All fish captured are measured and
counted, and many are scale sampled, sexed, and weighed.
-------
576
J. Z. Reynolds
In addition to the gill nettings, a bag seine
was used on five occasions in 1969 to sample fish
populations along 1,200 feet of shoreline north of the
plant. Data on offshore populations are also available
for two dates in 1969 from the trawling efforts of the
Bureau of Commercial Fisheries, United States Pish and
Wildlife Service.
The results of the various fish studies to
date indicate that at least 22 species of fish live in the
area, of which perch and alewives are most abundant. While
both yearling and adult salmonids have been captured,
their numbers have been very small and all have been planted
fish, as identified by their markings.
Lake temperatures have been measured
periodically at various depths and locations since before
the biological sampling program began. The objective of
the preoperational temperature surveys has been to define
the general natural variations that occur. For this purpose,
a series of measurements has been made approximately
every month, weather permitting.
A representative series of temperature profiles
for 1968 is shown in Exhibit III-Y (See P. 508) for a
location 1 mile from shore. It can be seen that a relatively
shallow thermocline developed in the spring and early
-------
577
J, Z. Reynolds
summer, but typically the thermocline in Lake Michigan will
reach depths exceeding 100 feet by early fall.
The thermal structure of Lake Michigan is a
highly variable phenomenon and can change significantly
in a relatively short period of time as well as from year
to year. The great influence of the shoreline is typified
in Exhibit III-Z (See P. 510) for April 10, 1968, at
which time the temperature variation from shore to five
miles out exceeded 13 degrees F. Such widespread natural
temperature excursions have certainly had a major
influence in the establishment of aquatic life populations
as they exist today. Artificial thermal discharges to the
lake, as from powerplants , can and should be evaluated
in the context of these natural variations.
When the Palisades plant is in operation, the
thermal discharge will be mapped periodically to define
the extent and magnitude of its influence under various
meterorological and natural lake conditions. Studies of
lakeshore currents have indicated that the buoyant thermal
plume will flow northward about 33 percent of the time,
southward 23 percent of the time and drift almost directly
offshore about 3$ percent of the time. The remaining
6 percent of the year the plume is expected to more or
less remain as a stationary water mass near shore.
Data on the spatial and temporal influence of
-------
578
J. Z. Reynolds
the thermal discharge will, when correlated with the
biological data, make possible an accurate assessment of
the impact of plant operations on the aquatic ecology of
Lake Michigan.
Passage of the Water Quality Act of 1965, to
amend the Federal Water Pollution Control Act, set into
motion a widespread review of water quality criteria
to be used in the standard-setting process. For many
contaminants and water quality parameters the determination
of the necessary restrictions to protect aquatic life or
other beneficial uses was rather simple. Agreement on
standards for such things as dissolved oxygen and certain
toxic substances was secured rather early because of
the demonstrated need to control waste discharges to
minimize almost certain harmful effects. Recognized
pollution conditions caused by such discharges had
clearly been shown.
The situation with regard to temperature was not
so well defined. It was known that if heated waters were
discharged into a relatively small body of water the local
aquatic ecology would be changed. But such things as
fish kills or other adverse effects associated with such
discharges were relatively rare, and research to determine
potential damage was considered frivolous, under the
-------
579
J. Z. Reynolds
circumstances. Utilities around the country, however,
recognizing the accelerated rate at which thermal discharges
would be made from powerplants, initiated studies to
attempt to detect adverse effects. In the case of the
Great Lakes, short-term studies have failed to show
harmful effects and the long-term studies, by their nature,
have not provided much definitive information to date.
The U. S. Department of the Interior, because they
were charged by Congress to approve water quality standards
has felt obliged to require numerical limits to restrict
thermal discharges into the Great Lakes. However, until
technically supportable evidence concerning harmful effects
of such a discharge has oeen presented, there is no
rational or legal basis for such a dogmatic viewpoint.
The popular view of the possible consequences of thermal
discharges promoted by PWQA is not consistent with existing
factual information and does not enjoy any broad
recognition by the scientific community.
Considerable effort has been expended, by both
scientists and laymen, in theorizing on the possible
adverse effects of thermal discharges. A considerable amount
of this activity has been stimulated by governmental
pressure and the misguided urgings to set specific numerical
temperature standards. But a clear distinction must be made
-------
580
J. Z. Reynolds
between what can be considered "possible effects" and
what is truly probable, based on existing evidence and
scientifically valid projections.
It is postulated, for instance, that there will
be long-term deleterious biological effects caused by the
thermal discharges from powerplants . LaKe Michigan, as
has been shown, is in no immediate danger of being
significantly warmed by heated discharges. The seasonal
succession of the lower aquatic life forms is so dramatic
due to natural causes that the relatively minor circulation
through powerplants could not be a significant factor in
their overall populations. And the fish management program
by the Federal Government and the bordering States is
evidence in itself that we are not tampering with natural
ecological phenomena as far as fish are concerned. There
is, therefore, no reasonable basis for asserting that
the existing level of thermal discharges could have
long-term effects.
The "white paper" discusses at length the
possible effects of heated water on fish, as if they were
confined to these waters and would not naturally avoid
temperatures not to their liking. The paper describes
very well the significant historical succession of fish
species, the considerable management efforts that have been
-------
581
J. Z. Reynolds
instituted to change the natural balance of species,
and the variability of habitat and its importance in the
succession of life stages. But on the basis of the
evidence presented, it certainly does not follow that any
significant thermal discharge, at any place, at any time,
would jeopardize the existence or otherwise interfere with
the population of any species of fish in Lake Michigan.
Another misleading implication in the "white
paper" is that if thermal discharges are eliminated, the
accelerated rate of eutrophication of Lake Michigan will
be checked, even though nutrient buildup may continue
unabated. Such an assertion fails to recognize the relative
causes of the existing rate of eutrophication, the
insignificant warming of the lake caused by existing thermal
discharges, the natural heat inputs to the lake, or the
historical temperature conditions of the lake.
The predictions that thermal discharges will
cause significant undesirable shifts in predominance of
planktonic forms of aquatic life, such as algae and
Type E botulinum, as so dramatically identified in the
"white paper," does not take into consideration that thermal
plumes are transitory, self-renewing water masses and the
generation times of the organisms contained therein would no"c
allow for growths that could be construed as proliferation.
-------
582
J. Z. Reynolds
As we all know, thermal discharges are only
one result of man's activities that can have apparent or
possible adverse effects on the environment. The principles
of ecology would demand that priorities be established
as to the potentially harmful effects of all forces
impinging on man and his environment, so that manpower,
economic and other resources can be apportioned
accordingly to deal with the problems.
This philosophy is obviously lacking in the
procedures and pronouncements of the Department of the
Interior regarding environmental problems in the Great
Lakes area. The recommendation of standards that would
commit vast resources to prevent imagined damage or to
allay baseless fears predicated on unreasonably
extrapolated data, is not in the best interests of the
people or the natural environment. There are real,
presently-existing environmental problems that deserve a
higher measure of our attention than that presently
being allotted thermal discharges. The easiest targets of
criticism and control should not be the criteria for
selecting the priority for dealing with environmental
effects.
Impact of the 1 degree F. or no heat discharge
recommendation: Consumers Power Company has reviewed the
-------
583
J. Z. Reynolds
problems involved with reducing the temperature of the
discharge of cooling water to 1 degree F. over the ambient
temperature of the receiving body of water for each of our
plants on the Great Lakes.
To do this would, in each case, require us to
install closed loop cooling systems with evaporative cooling
devices such as powered draft cooling, natural draft
cooling, spray ponds or possibly a combination of these.
Each of these systems has its own particular
disadvantage, but common to all of the systems would be:
1) A loss of unit capacity of 4 to 6 percent due
to increased turbine back pressure. This would have to be
made up with new capacity costing about $175/kw.
2) A decrease in unit cycle efficiency of
2 to 3 percent during the summer period. This would
increase the fuel requirements proportionately.
3) An increase in capital expenditures for
cooling systems and associated changes.
4) A decrease in the net plant capability for
pumping energy which would have to be made up with new
plant capacity costing about $175/kw.
5) Increased maintenance cost required to maintain
spray nozzles, tower fill, pumps and electrical equipment,
etc.
-------
584
J. Z. Reynolds
6) Increased operating costs for water treatment
of the water in the closed loop.
7) An increase in water evaporated and discharged
to the atmosphere.
8) Possible problems with blowdown due to the
concentration of solids because of the evaporation of water
by the cooling towers.
9) Possible problems with drift and fallout
of condensed water that cannot be fully assessed until
a study of each plant area is made.
10) Increased problems with insulators and
other electrical equipment because of the increased
humidity in the immediate plant area.
11) Problems with icing, particularly when a
single unit is operated or when the plant is operated as
a peaking plant.
To approach compliance with such a restrictive
standard for the plants on Lake Michigan would cost millions
of dollars per year. It is frequently stated that because
this represents only a few percent of operating revenues,
it is an insignificant expenditure for environmental
controls. Many millions of dollars spent for any purpose
cannot be considered insignificant. This represents a
considerable amount of society's financial resources and
-------
585
J. Z. Reynolds
should not be diverted from more deserving uses because of
unsubstantiated fears of "thermal pollution." Considering
the known adverse environmental effects of artificial
cooling facilities, expenditures for these devices based
on arbitrary restrictions, assumed to protect the lake,
cannot be supported under the guise of improving
environmental quality.
The company has conducted preliminary
feasibility studies for the Palisades plant with Bechtel
Corporation on three alternative systems to modify the
possible effects of the thermal discharge on the adjacent
inshore area. These alternatives and a discussion of
each are listed below.
Alternate I - Cooling Towers. A closed cycle
cooling tower system has been considered which would
for the most part isolate the plant from the lake. This
would require three structures about 75 ft. x 400 ft.
which would be placed to the south of the existing plant.
This system would utilize forced air circulation towers
rather than the natural draft towers due to performance
and site location considerations.
The approximate engineering-procurement-
construction schedule for this alternate is 20 months.
Alternate II - Dilution of Discharge Flow. This
-------
586
J. Z. Reynolds
system would provide additional dilution water to the
discharge structure to reduce the outlet temperature to
10 degree* F. higher than the plant inlet flow.
Modifications include additional (1) inlet line(s)
parallel to the existing inlet line, (2) intake
structured), (3) pumps, and (4) discharge structure(s)
to accommodate,the approximate tripling in quantity of
discharge flow.
The approximate leadtime for this alternate is
28 months.
Alternate III - Extended Discharge Piping. This
system would provide for the addition of a pump structure,
pumps and discharge pipe. The condenser discharge would
flow to an enclosed discharge structure, from where it
would be pumped to offshore points of discharge selected to
minimize warm-water effects along the lakeshore. A
disadvantage of this scheme would be the dissipation of
more heat into the lake water and less to the atmosphere
from the surface cooling effect.
The approximate leadtime for this alternate is
28 months.
An additional alternative which would be
Immediately available to reduce temperature rise, if
required, would be the curtailment of plant power output,
-------
587
J. Z. Reynolds
Since the circulating water temperature rise across the
condenser is an approximate linear function with respect
to power, reduction of plant power output would reduce the
temperature rise accordingly. This measure could be
taken at any time adverse effects are indicated and,
of course, could be continued until some permanent solution
such as the alternates listed above was implemented. A
major disadvantage of this method would be the sacrifice
of installed electrical capability during any periods
when a power curtailment would be in effect.
All of the various alternatives would effectively
reduce the capability of the plant and tend to reduce the
reliability of the electrical system. Energy not
available from nuclear plants must necessarily be supplied
by older fossil fueled generating stations that inherently
have a greater impact on air quality. The adverse
environmental effects of reducing the availability and
reliability of electrical energy should certainly be
weighed in any decisions made to ostensibly improve
environmental quality.
We would restate, in concluding, that the Federal
position regarding thermal discharges into Lake Michigan is
not warranted by the known facts concerning such discharges
or the potential effects of these discharges in the
-------
588
J. Z. Reynolds
foreseeable future. Further, the vacillation in the
Federal position has interfered,with rational standard-
setting. Moreover, Consumers Power Company is profoundly
disturbed by the misleading information which has been
released on this subject and by the escalation of
groundless fears in the minds of the public. The result
of these needless anxieties is even more serious coming,
as it does, at a time of rapid growth in electrical
requirements and increasing energy shortages.
The company is deeply involved in environmental
studies to detect effects of thermal discharges into the
Great Lakes, and is publicly committed to make corrections
should damage occur. We would urge the conferees to
carefully consider our statement and proceed with the
business of developing a reasonable position concerning
regulation of thermal discharges.
-------
589
D. H. Brandt
MR. STEIN: Thank you, Dr. Reynolds.
I think this is the last statement we are going
to have, and we just have comments and questions from the
conferees.
I followed your statement, Mr. Brandt, very
carefully, and unless I can't believe my ears — but let
me state what I think your conclusion states. It is that
you don't believe you are doing any damage, that you don't
believe you want to change your operation, and if damage
occurs, you will take that into consideration,
I take it this makes you among the only major
industries and municipalities discharging to Lake Michigan
— after we have had this tremendous program of cleanup
— to think that what they are doing is all right, and
you don't have to do anything else until you demonstrate
damage. This is how I understand the main thrust of
your paper. Do I understand that correctly?
MR. BRANDT: I think there is a fundamental
difference between thermal discharges and other contami-
nants that you might be referring to in other industries.
The basic scientific evidence would indicate
that effects of thermal discharges, if such damaging
effects might occur, are certainly not irreversible.
MR. STEIN: In other words, I am correct that we
-------
590
D. H. Brandt
have the steel companies, the oil companies, the cities,
the plating plants — all of the plants committed to a
program of correction of pollution of Lake Michigan in an
abatement program, but you don't think you need anything
at the present time.
I think we are in agreement on what you said, 1
just want to make sure, because it boggles the imagination.
If that is what you say, I guess we can proceed from there.
MR. BRANDT: I think our statement is clear that
should pollution exist from our operations we are going
to correct them.
MR. STEIN: But you don't believe it exists.
Isn't that what you said?
MR. BRANDT: Essentially, sir.
MR. STEIN: That is right. All right. Have
any of the conferees anything?
Mr. Currie.
MR. CURRIE: Yes, Mr. Chairman. I would like,
at this point, first to repeat the suggestion that I made
in my letter to Secretary Hickel of September 17, that
expert witnesses be required to submit their statements
in writing in advance so that the public and the conferees
would have an opportunity to read them beforehand.
In past conference sessions and in this session,
-------
591
D. H0 Brandt
voluminous and detailed reports have been presented with
no time for the conferees or the public to thoroughly
review them.
Comments and questions would be much more mean-
ingful if advance copies are required. It is rather
difficult, to evaluate and comment on the factual or tech-
nical material without time to read it in advance. Happily,
however, the statement we have just heard is neither factual
nor technical and, therefore, relatively simple to deal
with.
Now, as I understand it, we are being urged here
to look at the facts and not be swayed by emotion, and as
far as I can tell, the facts that are relevant are a one-
day's study of a middle-sized fossil-fueled plant conducted
on August 30, 196S, which purports to show that there was
no gross thermal damage to the benthic fauna in the main
thermal plume.
Now, I take it we are not concerned only with
gross thermal damage, and I take it we are not concerned
only with damage to benthic organisms, and in view of the
— in connection with the adequacy of such a survey, I
would like to quote from a statement made to our Board
last week by Dr. Wesley Pipes, who says, "Our current
estimate of the numbers of samples required to demonstrate
-------
592
D. H. Brandt
the subtle effects on the statistically significant basis
is between 500 and 1,000 samples collected over a 1-year
period."
MR. BRANDT: Mr. Currie.
MR. CURRIE: Yes.
MR. BRANDT: I would like you to recognize that
the sample biological survey referred to was conducted in
196# before there was really any public discussion, so to
speak, about thermal pollution.
MR. CURRIE: Well, do you have any facts to give
us?
MR0 BRANDT: And our Palisades survey, coming
at a point in time when this question has been raised,
is designed to detect or to measure all of these parameters
you have indicated, and I would certainly have as many
samples as I am sure that Dr. Pipes said we should have.
MR. CURRIE: Do you have any existing studies
that can help us?
MR. BRANDT: No other studies, no.
There are other studies available. The Michigan
Water Resources Commission has conducted independent
surveys. I am sure they will make them available to the
conferees.
MR. CURRIE: I have no further questions.
-------
593
D. H. Brandt
MR. STEIN: Are there any other comments or
questions?
MR. PURDY: I have just one comment, Mr. Stein,
with respect to the statement made on page 11-15 under the
State action, the second paragraph, relating to a meeting
in Ann Arbor on April 16, and I don't believe that this
was attended by the conferees themselves. It would be
representatives of the conferees who met in Ann Arbor on
this date.
MR. STEIN: All right. Thank you.
Are there any other comments or questions?
Mr. Frangos.
MR. FRANGOS: Yes, Mr. Chairman.
On page IV-5> there is included a listing of
the disadvantages for installing a closed cooling system,
and I am wondering if people from Consumers Power might
indicate any cost estimates that they may have, if they
added all of the detrimental problems that they have
listed here, how those figures would compare with the
figures presented by the Interior people this raorningo
MR. BRANDT: We don't have that here now. We
can look into that for you and perhaps provide it later.
MR. STEIN: May I ask one question on this, so
we keep the record straight?
-------
D. H. Brandt
I noted on page IV-5 you listed eleven reasons
why the closed cooling system wasn't feasible. Of those
eleven, eight of them related to the operation of the
power plant and only three of them related to what might
happen to the environment, and of these three, I think
all of them have been covered by Mr, Tichenor in his
paper where he said there wouldn't be any problem. But
I think it is of interest to note that the vast majority
of the reasons why the system cannot be closed were not
because of relationship of damage to the environment but
to the operation, or possible additional costs to a power
plant.
Mr. Frangos.
MR. FRANGOS: One other question. Following this
discussion on page IV-6 and IV-7 of the discussion are some
alternative investigations that are being made by the
company, and I am wondering if you could perhaps make it
a little bit more clear what the motivation of the company
is in pursuing these studies at the Palisades plant.
In other words, if indeed you may not have any
problems, why are you making these inquiries?
MR. BRANDT: There has been some public comment
and some intervention in our Atomic Energy Commission
hearings for an operating license that would lead us to
-------
595
D. H. Brandt
believe that this information would be desirable.
MR. FRANCOS: Thank you.
MR. PURDY: I have a comment with respect to that,
Mr. Chairman.
MR. STEIN: Yes, go ahead.
MR. PURDY: These studies are being made at the
request of the Michigan Water Resources Commission to
demonstrate the compliance with the order of the Commission
that these injuries cannot occur. It is part of our plant
approval for their operations.
MR. STEIN: Are there any other comments or ques-
tions?
If not, let me go through 1-2 — this was right
at the beginning of your statement. You had a very
optimistic observation.
You say, "We are confident we can meet all our
obligations through the continued exercise of sound business
judgment, consultation and guidance by technically qualified
people f the application of appropriate control technology
and acting in a forthright manner on environmental issues."
Do you mean to say that you think that the rest
of your statement supports that, I take it?
MR. BRANDT: Yes, sir, I do.
MR. STEIN: Now, you said, and I call this to
-------
596
D. H. Brandt
your attention, at the beginning, "A number of Federal
officials often appear to forget or ignore this basic
policy of primacy of the State regulation in their temper-
ature standard-setting efforts," page 1-3•
I have listened to your presentation and read
with candor your paper. You said it would be apparent.
I didn't see it. What do you mean that we don't recognize
the primary responsibilities and rights of the States?
MR. BRANDT: I believe, sir, I can best answer
that by recalling the 3-year experience that the State has
had in struggling to try to find acceptable standards.
MR. STEIN: What State are you talking about, sir?
MR. BRANDT: Michigan.
MR. STEIN: How many States border Lake Michigan?
MR. BRANDT: There are four States.
MR. STEIN: Would you suggest that we can have
a standard that is going to be equitable to Michigan and
the other three States without getting uniformity of all
four and the Federal Government?
MR. BRANDT: I can appreciate, sir, the need for
a uniform approach in procedure, and this is why we were,
in our company, very pleased to see at a Michigan Public
Service Commission meeting, that there was identity at the
April 16 meeting where the — and Mr. Purdy corrected the
-------
597
D. H. Brandt
fact that it was representatives of the conferees that had
agreed. But it seemed to us that this was a very positive
step in the right direction.
I do not believe, and I believe this body has
indicated, that the numbers — maximum monthly numbers,
and so on, would not be identical for the various areas of
the lake. However, the approach to it would have to be
uniform, and we certainly appreciate this.
MR. STEIN: And I think that is why we are here,
sir, with all these States, and we would hope that we can
have uniformity of opinion, and agreement, and that is how
we have handled all of the other problems.
I think the record indicates — just look at those .at
this table here — rather than ignoring the primary rights
and responsibilities of the States, the fact that we are here
shows that we recognize those, and I just don't see your
point on our ignoring them.
Why are we here with all these States? We have
other methods of setting water quality requirements, but
we are sitting here with four States with us, and we are
striving to get uniformity of judgment.
Now, in the face of this, and in the face of
the conferences that we have had in Lake Michigan, and our
achievement in every instance of uniformity with the four
-------
598
D. H, Brandt
Lake Michigan States, how can you say that we have a
record of ignoring the principle of law which asks us to
recognize the primary rights and responsibilities of the
States?
MR. BRANDT: I draw that conclusion from having,
in the past 23 years, attended a large majority of the
Michigan Water Resources Commission meetings, and seeing
the staff present recommendations for either precise values
or philosophies to be used in the standard-setting process
that were predicated on their expert capability,, agreed to
by the Commission on the recommendation of staff, to be
overruled or further delayed in finalizing because of the
points that I brought up, sir, in the vacillation in basis
for recommendation.
MR. STEIN: I don't see any vacillation here,
because we don't have any, but you cart go on and continue
this. I think the record on that speaks for itself. If
you don't want to say anything, let me make the next point.
You say, "Too many Federal officials and others
have ignored this requirement to take into consideration
all legitimate uses of interstate waters. Instead, they
consider exclusively the propagation of fish and wildlife.."
Now, the trouble is, I think, here — and I almost
hate to push this issue because we have a large delegation
-------
599
D. H. Brandt
from-our Fish and Wildlife Service here and they wish this
^
were true. But if you think — I want to know in what
instances we have considered exclusively in all our causes
— and these are standards of enforcement action — the
propagation of fish and wildlife and have not considered
all legitimate water uses.
MR. BRANDT: I believe, sir, that the recommenda-
tions of the FWQA Regional Office to the State of Michigan
in their March 19 public hearing will bear that out by
some of the language and definitions. I do not have a
copy of it with me at the moment.
MR. STEIN: Maybe you would make that allegation
to the next conference of the Audobon Society or the Izaak
Walton League that we consider exclusively the propagation
of fish and wildlife,and I would like to see the reception
we get.
To my mind, nothing is so far from the fact.
We get criticized constantly by the conservation organiza-
tions that we are taking into consideration the other water
uses other than fish and wildlife, and how anyone can —
this is the first time I have ever heard the allegation
that the Federal people exclusively consider the considera-
tion of fish and wildlife, and I guess there are many
conservationists in the audience. This is a remarkable way
-------
600
D. H. Brandt
of looking at things, I think.
Now, again, I think — let me go to the next
point. You talked to our Act and you say — and I have
the greatest respect for — I guess Mr. Kelly is your
Attorney-General yet, isn't he?
MR. PURDY:, Yes.
MR. STEIN: You talk about the Federal Act and
then you point out, as the Michigan Attorney-General's
office has pointed out, and then you go to another section
of the Federal Act and talk about the Michigan Attorney-
General's office and his opinion.
Again, I have the highest regard for Mr» Kelly.
I have worked with him through the years. I consider him
an old friend and colleague. But I think he would be the
first to agree that the people who interpreted the Federal
Act are the Federal people, and I would agree that the
people who interpret the Michigan Act is Mr. Kelly .
I am not looking for reciprocity in this regard, but I
wonder what Michigan would think if in interpreting their
Act you quoted our Solicitor's opinion on what the Michigan
Act meant.
This may be the way of doing business, but I
don't quite —
Let me ask you another question. What do you mean
-------
601
D. H. Brandt
when you get on page II-4, that "thermal plume ... has
interfered with or otherwise caused injury to any beneficial
use of the waters"? What do you mean by "beneficial use"?
MR. BRANDT: What area are you quoting from?
MR. STEIN: You repeated it several times, but
page II-4» paragraph 2.
DR. REYNDOLDS: What was the question, sir?
MR. STEIN: What do you mean by "beneficial use"?
DR. REYNOLDS: This was in reference to the fish
activities at the discharge point.
MR. STEIN: No, I want to understand what you
mean by "beneficial use."
DR. REYNOLDS: Fishing is a beneficial use of
water. This is what we are referring to.
MR. STEIN: Do you mean by "beneficial use," the
word "fishing"?
DR. REYNOLDS: Yes.
MR. STEIN: And the last point, I am not sure I
agree with: "In fact, the areas of heated discharge are
often observed to appeal to swimmers, since the lake waters
are normally too cold for comfortable water contact
activities.".
When we were on the Raritan Bay, we found that
appealed to the swimmers, too, but they were swimming in
-------
602
D. H. Brandt
the discharge of the Perth Amboy sewer. It was nice and
warm.
DR. REYNOLDS: I don't think the comparison was
quite appropriate.
MR. STEIN: There are other water uses other than
swimming.
MR. MACKIE: This morning we were presented with
a table which listed the increases in costs of electrical
productions for a number of alternatives over the once-
through design. I am wondering if sometime perhaps tomorrow
the power industry could be prepared to comment on these
increases in cost, or shall we at the conference consider
these to be reasonable in this case?
I am referring here to Table 2 of the presenta-
tion of the Department of Interior report on "Feasibility
of Alternative Means of Cooling for Thermal Power Plants
Near Lake Michigan."
The point is: Shall the conferees consider
that the power interests agree with the figures in Table 2?
MR. BRANDT: We will have two more witnesses
appearing on behalf of Consumers Power Company — the
gentlemen I mentioned in my opening remarks from Sargent
and Lundy. We will make sure that some comments on that
point will be included, sir.
-------
603
D. H. Brandt
MR. MACKIE: Thank you.
MR. STEIN: Let me go on.
Running a careful operation here, let me refer
to 11-12, next to the last paragraph, last sentence, talk-
ing about Dr. Mount's suggestion.
Again, this reminds me something of Freud's
definition of paternity. The presumption is based on
supposition, for anyone that is really as careful as this.
You say — and let me read this — "Apparently some FWPCA
representatives had informally suggested t h at formulas
would be appropriate."
MR. BRANDT: les, sir. Again, the basis for that
statement is that there had not, to my knowledge, been a
formal presentation to the Michigan Water Resources Commis-
sion with that statement or that position set forth, sir0
MR. STEIN: No, I am not talking about that.
I am talking about all of the provisos and qualifications.
"Apparently some ... informally ..." — one of the radio
stations in Washington has a little song that goes to the
tune, I guess, of "Home on the Range," about what goes on
in Washington, and they say, "And seldom is heard an
unqualified word0"
Now, on page II-l? it says, "The sincere and
honest efforts of many who have worked to develop reasonable
-------
604
D. H. Brandt
temperature standards, based on the technical evidence,
have been repeatedly destroyed by inconsistent and confused
pronouncements and recommendations by others."
Do you consider yourselves included among those
who have made sincere and honest efforts to have worked
to develop reasonable temperature standards for Lake Michigan?
MR. BRANDT: Yes, sir, I do.
MR. STEIN: Then, let me refer you to page IV-3
where you say, "It certainly does not follow that any
significant thermal discharge, at any place, at any time,,
would jeopardize the existence or otherwise interfere with
the population of any species of fish in Lake Michigan."
DR. REYNOLDS: I don't see any inconsistency, sir.
MR. STEIN: I guess not.
All right, now. You say, "'that if the temperature
is unacceptable, it is unacceptable whether it has been
caused by the sun or man.'"
I want to make this clear for the record.
In dealing with thermal discharges, we know that from
the beginning of time there have probably been fish kills
from heat due to natural causes. This probably has
occurred ever since there were fish and a world, and it
will continue in the future. But that doesn't mean that
-------
605
D. H. Brandt
since we are going to have natural fish kills caused by
heat that we are not going to try and prevent manmade
fish kills caused by heat.
•
MR. BRANDT: Mr. Chairman, if I may.
MR. STEIN: Yes.
MR. BRANDT: That particular quotation was
extracted from the testimony of Dr. Mount.
MR. STEIN: Yes.
MR. BRANDT: And it was associated with the fact
that the recommendation of specific maximum temperature for
certain water bodies was found by the Commission staff in
their comments, I believe, that it exceeded the natural
condition and also this — if my memory is correct — was
a reference to the Muskegon River, and the statement by
Dr. Mount was a suggestion of something in the order of
5$ degrees, I believe, as a maximum, in order to facilitate
the fish run.
MR. STEIN: Well, I am familiar with the views of
Dr. Mount, but Dr. Mount is very interested in controlling
natural sources of discharges to the lake.
Now, are you people familiar with what is gen-
erally called the "green book"? What do they call that,
the National Technical Advisory Commission?
MR. BRANDT: Advisory Committee Report, yes, sir.
-------
606
D. H. Brandt
MR, STEIN: And are you familiar with the temp-
erature requirements in there?
MR. BRANDT: Yes, sir,
MR, STEIN: And the numbers?
MR. BRANDT: Yes, sir,
MR, STEIN: Well, then, this is my last question,
You say, "The popular view of the possible consequences of
thermal discharges promoted by FWQA is not consistent
with existing factual information" -- which may be your
conclusion — "and does not enjoy any broad recognition
by the scientific community,"
As far as I know, that "green book" has the
broadest recognition and most of the scientific community
involved in the aquatic biology field has signed off on
it, I don't know what you are talking about,
MR. BRANDT: Sir, the criticism was not of the
"green book."
MR. STEIN: Well, this is a flat statement.
You said that what we have put forth is not by
the scientific community.
Now, the "green book" — let's get down to this
— for lakes says "not more than" — I repeat — and I
had it marked here on this stuff where it said "not more
than" — and you thought that was ambiguous and meant to
-------
607
D. H. Brandt
be over« "Not more than" is not any more ambiguous to me
than is "less than," But that is in your statement some-
where.
But the "green book" talks about lakes and talks
about a maximum rise in that "green book" of not more than
3 degrees. Do I take it that your industry is ready to
abide by that — of not more than three?
MR. BRANDT: The recommendation that was pre-
sented by the Michigan staff to the Water Resources Com-
mission this last monthly Commission meeting recommended
3 degrees as the maximum at the edge of the mixing zone.
MR. STEIN: I didn't ask you that question.
Do I take it that you are in favor of the not
more than 3 degrees and subscribe to the "green book"?
MR. BRANDT: I subscribe to the concept that is
identified in the Michigan standards, at this point in
time,which I further believe are in accordance with tne
philosophies of the "green book," sir.
MR. STEIN: Then, what we are talking about —
and we really have a very small scope and if we can continue
this and maybe you can talk to the rest of the industry, I
think we have made an agreement. If we are talking of a
rise between 1 and 3 degrees — not talking about raising
the temperature 1$ or 20 degrees — we are a lot closer
-------
608
D. H. Brandt
together than we thought. If that is what you mean, I
think we can recess here on a very optimistic note*
MR. BRANDT: Sir, I qualified my statement as
being in support of the philosophy applied in the present
proposed Michigan temperature standards.
MR. STEIN: Not the "green book."
MR. BRANDT: I believe they are compatible.
MR. STEIN: As I understand the "green book," r&
is not more than 3 degrees. If I am wrong, I wish someone
would correct me.
MR. BRANDT: That is what the Michigan standard
says then.
MR. STEIN: If that is what they say, then we
are really talking about a difference of a proposal, say,
of 6 months ago of 1 degree or no significant rise, which
may mean zero to 1 or something like that, and a maximum
of 3.
Now, if that is the scope in our difference
possibly or some of the technical difference with the
industries, I think we should be able to resolve that.
MR. BRANDT: Sir, I would call your attention
to the FWQA Regional Office comments at the March 19
hearing of the Michigan Public Service Commission.
It was after considerable discussion with the
-------
609
D. H. Brandt
Commission members of Michigan and Mr. Danielle that just
about the same statement was made — that, apparently, if
the discussions were carried on consistently in that level,
there perhaps was not too much difference in view, at that
point in time, between the State of Michigan staff and the
PVTQA Regional Office.
But I call your attention, sir, within 30 days,
there was the announcement of the 1-degree limit as an
effluent standard.
MR, STEIN: I think our purpose here is to try
to come to an agreement among ourselves with the parties
here. Now, if we are talking in terms of a rise in
temperature of between zero and 3 degrees, I think we have
really narrowed the issue.
Now, if the industry will agree that that is the
issue and the States will agree that that is the issue,
I think we can move on hopefully very rapidly. But
there is a difference between a rise of zero degrees
up to and not more than 3 degrees and a rise from
zero up to 18 or 20. I think we have a fundamental
problem there. If we can narrow down what we are
talking about, and I am asking, to try to get this
en the track, I don't r>oc that nroblcn omtc az acute
if one considers the scope of what we are talking about
here will range somewhere up to 3 degrees rise.
-------
610
D. H. Brandt
MR. BRANDT: I believe, sir, the difficulty we
are having here in communicating is the fact that you have
indicated earlier today the approach that you are applying
that number at the outlet point. The philosophy to us, as
we had tried to illustrate in our presentation, is that if
you include a mixing zone in a site-by-site evaluation,
then I think we could certainly find some common ground.
MR. STEIN: I don't know whether I had difficulty
in communicating, because I have communicated this idea
to many, many people and they had no difficulty under-
standing it. But I don't think you quite understand what
I said. I think the record will bear this out.
What I am talking about is establishing a
theoretical mixing zone. What I said — and I think the
record will bear this out — if we place a degree
limitation on temperature at that pipe, that will be for
the purpose of regulatory control. This will oblige us
to deal with the effect that that has on a theoretical
mixing zone, as I see it.
Now, I do think that the industry will be much
better off — this is my view, and as far as I can see,
when I have discussed this, I see no one in the industry
who really disagrees with it — you will be much better
off if you will just be responsible for the temperature of
-------
611
D. H. Brandt
the water as it comes out of your pipe than 5 miles away
or 200 yards away or 300 yards away on a current that is
going in and out.
I am not saying, nor did I say that that 3
degrees will necessarily apply to the temperature coming out
of your pipe. I hope I am communicating that very clearly.
We are talking about a regulatory system of control, and
I think we have to think this through very carefully.
And the other is the impact on a theoretical mixing zone.
MR. BRANDT: I appreciate the problem that is
somewhat associated.
I have heard you recite it and I have no quarrel
with that as an enforcement standpoint problem.
However, we feel that the studies going forth,
the data and evaluation of the operations of existing
plants have not to this point indicated any need for going
to the cooling tower concept on the basis of evidence of
data.
MR. STEIN: Well, I think the issue is drawn.
Maybe we don't see this philosophically. I think your
point is that, for plants in existence, you would be
-------
612
D. H. Brandt
opposed to any plant that you know on Lake Michigan now
requiring a cooling facility or doing more than they
are doing at the present time.
I think I have stated that fairly, haven't I?
I don't know. You may not want to answer that. But I
think the issue is that for any plant in existence, as far
as I understand your proposal, you would be against putting
in any cooling device. You think they are all all right
doing what they are doing.
MR. BRANDT: 1 would not take the position that
I would be against doing it in toto. We would look at the
result of that effluent. If there is no basis, no harmful
effect, and it does not interfere with other uses of that
water body, I feel that the resource should be utilized
as long as it is not damaged.
MR. STEIN: All right. I think we are in
agreement there. And whose job is it to show that it
isn't being damaged--the people who use it or us?
MR. BRANDT: To show that it is not being damaged,
sir, I believe that for over 2 hours we have identified
the efforts that we are making. It will take time to
produce the number of samples that you referred to. We
would certainly suggest that the Palisades plant be per-
mitted to go into service so that the 3 years of
-------
613
D. H. Brandt
pre-operational testing to provide a base for comparison
will be a meaningful effort, and that it can be carefully
observed by ourselves and the regulatory agencies in its
operation.
MR, STEIN: Well, let me make this very clear,
And I think we really have to think about this, I think
you have heard what Mr. Currie said about your report —
your proposal that we allow you to put heated water into
the lake from the Palisades plant — it is not going to
raise the water 3 degrees at least at the pipej it will
raise the water about 1$ degrees — do a 3-year study and
see if it is causing any damage and afterward, then, if
we see that it is causing any damage we do something about
it.
The theory that we have now — at least the
purport of the legislation that we have to administer now
— and I think the States do too — is not only do we have to
correct pollution but we have to prevent it before it
occurs.
How are we going to carry out our obligation
with that kind of an approach?
MR. BRANDT: Sir, I think the 3 years is mis-
placed. I defined the pre-operational effort as the effort
going on for 3 years. It is my opinion that we would
-------
614
D. H. Brandt
conduct a very comprehensive surveillance program, and if
within the first 3 months or 3 days, 3 samples — whatever
it takes — for the people qualified to evaluate it, if
there is harmful effect, we have said we would modify the
facility. We also identified that reduction level of power
generation from that station is one of the alternatives
that could control the effluent from that plant until such
time as another alternative could be developed,
MR, STEIN: Sir, I read your material in here
where you had the distinguished firm of Bechtel as con-
sultants, and dealing with the leadti.me that they say
you are going to need to correct these things, you are
going to condemn that lake, if you think it is bad, to a
couple of years of damage before it is corrected, right
by your own report. Is that what you are proposing?
MR. BRANDT: Mr. Chairman, that is why I men-
tioned that the fourth alternative identified there was
the reduction of load as a solution, so that we don't
encounter the condition that you are speaking of,
MR. STEIN: Sir, again — and we have gone
through this in many, many places, and the people are out
here and we are out here — when you are talking about the
reduction of load, once we let you build the plant, you are
going to leave us only the Hopkins choice
-------
615
D. H. Brandt
of either having a brownout or pollution ox" the lake.
We are going to recess very shortly, but I
really hope you will rethink that position before you ask
the regulatory agencies to get into that kind of spot where
we are going to be faced a year from now — or as we are
faced with some plants down in south Florida right now —
with the alternative of giving the people brownouts and
not enough electricity, or causing many, many acres of
Biscayne Bay to become a biological desert for several
years.
Now, I would hope that you v/ould not place a
choice on us in Lake Michigan, and I would hope that the
conferees would think long and hard before they put them-
selves in that position. I don't think that the shutting
down of power and the cutting back of power in this age of
power demands and power shortages is a realistic one.
MR. BRANDT: Mr. Chairman, we are not suggesting
damaging this resource. We have not in any indication caid
so. We are saying that the experience to date on the
existing plant has not indicated any harmful effect from
the presence of their discharge. We, therefore, feel that
there is evidence — and the other speakers that will
follow us I am sure will point this out in more detail.
MR. STEIN: Are there any other comments or
-------
616
D. H. Brandt
questions?
Again, I am not sure that we are very far apart,,
But I hope the industry, and I hope our people will try
to rethink this, and let's try to see if we can get some
method of accommodation whereby we can solve this.
Because the way this is operating, I think it would be
unfortunate to have a confrontation on this. I don't
think we are very far apart.
Let us recess. We have the same room
tomorrow, don't we? We are going to start at 9:00 a.m.
tomorrow instead of 9:30.
We stand recessed. Tomorrow we meet in Louis
XVI Suite on the first floor.
(The conference adjourned at 5:45 p.m.)
ft U. S. GOVERNMENT PRINTING OFFICE : 1971 O - 422-409 (Vol. 1)
-------