ILLINOIS
THIRD SESSION
RECONVENED IN
WORKSHOP SESSIONS
September 28, 29, 3O,
October 1,2, 197O.
Chicago, Illinois
Vol. 3,
Pollution of Lake Michigan
and Its Tributary Basin
U.S. DEPARTMENT OF THE INTERIOR . . . FEDERAL WATER QUALITY ADMINISTRATION
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WORKSHOP SESSION FOR THE THIRD SESSION OF
THE CONFERENCE IN THE MATTER OF POLLUTION
OF LAKE MICHIGAN AND ITS TRIBUTARY BASIN
IN THE STATES OF WISCONSIN, ILLINOIS,
INDIANA, AND MICHIGAN VOLUME III
Bal Tabarin Room
Sherman House
Chicago, Illinois
September 30, 1970
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11
CONTENTS
Page
Joseph A. Pelletier 96?
Robert M. Kopper 9^7
Fabian C. Polcyn 997
David H. Williams, Jr. 1015
John C. Ayers 1042
0. D. Butler 1093
Wesley 0. Pipes 1130
Evan W. James llol
Sol Burstein 11S6
Yates M. Barber 1225
John G. Carr 1230
Peter J. Colby 1261
Thomas A. Edsall 1283
Richard Callaway 1330
John T. Graikoski (Read by Kenneth Roberts.) 135$
Charles Powers 1367
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Ill
Workshop Session for the Third Session of the
Conference in the Matter of Pollution of Lake Michigan and
Its Tributary Basin, in the States of Wisconsin, Illinois,
Indiana, and Michigan, held in the Bal Tabarin Room of the
Sherman House, Chicago, Illinois, on Wednesday, September 30,
1970, at 9:00 a.m.
PRESIDING:
MURRAY STEIN, Assistant Commissioner
for Enforcement and Standards Compliance,
Federal Water Quality Administration, U.S.
Department of the Interior, Washington, D.C.
CONFEREES:
BLUCHER A. POOLE, Technical Secretary, Stream
Pollution Control Board, Indiana State Board
of Health, Indianapolis, Indiana.
PERRY E. MILLER, Assistant Director, Stream
Pollution Control Board, Indiana State Board
of Health, Indianapolis, Indiana.
RALPH W. PURDY, Executive Secretary, Michigan
Water Resources Commission, Landing, Michigan.
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iv
CONFEREES (Continued):
FRANCIS T. MAYO, Regional Director, Federal
Water Quality Administration, U.S. Department
of Interior, Chicago, Illinois.
ALTERNATE CONFEREES;
CARL T. BLOMGREN, Environmental Control
Engineer, Illinois Environmental Protection
Association, Springfield, Illinois.
RICHARD S. NELLE, State Sanitary Engineer,
Illinois Environmental Protection Association,
Springfield, Illinois.
DAVID P. CURRIE, Chairman, Illinois
Pollution Control Board, Chicago, Illinois.
CARLOS FETTEROLF, Supervisor, Water Quality
Standards Appraisal, Michigan Water Resources
Commission, Lansing, Michigan.
DONALD J. MACKIE, Assistant Secretary,
Division of Environmental Protection,
Wisconsin Department of Natural Resources,
Madison, Wisconsin.
ROBERT P. HARTLEY, Director, Office of
Enforcement and Cooperative Programs, Federal
Water Quality Administration, U.S. Department
of Interior, Chicago, Illinois.
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PARTICIPANTS:
Joseph A. Pelletier, Vice President, Northern
Indiana Public Service Company, Hammond, Indiana,
Michael Sheldrick, McGraw-Hill publications.
Byron 0, Lee, Jr., Assistant to the President,
Commonwealth Edison Company, Chicago, Illinois.
G. Fred Lee, Professor of Water Chemistry,
University of Wisconsin, Madison, Wisconsin.
A. Joseph Dowd, Assistant General Counsel,
American Electric Power Service Corporation, Two Broadway,
New York, New York.
Robert M. Kopper, Executive Vice President,
Indiana and Michigan Electric Company, Fort Wayne, Indiana.
Fabian C. Polcyn, Research Engineer, University
of Michigan, Ann Arbor, Michigan,
David H. Williams, Jr., Assistant Vice President
and Chief Mechanical Engineer, American Electric Power
Service Corporation, New York, New York.
Jacob Dumelle, Member, Illinois Pollution
Control Board, Chicago, Illinois.
John C. Ayers, Professor of Oceanography,
University of Michigan, Ann Arbor, Michigan.
Bruce A. Tichenor, Chief, Hydrographic Branch,
National Thermal Pollution Research Program, Pacific
Northwest Water Laboratory, FWQA, U.S. Department of the
Interior, Corvnllir,, Orepron.
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PARTICIPANTS (Continued):
VI
Yates M. Barber, Jr., Staff Assistant to the
Assistant Director of Research, Bureau of Sport Fisheries
and Wildlife, U.S. Department of the Interior, Annandale,
Virginia.
0. D, Butler, Assistant Vice President,
Commonwealth Edison Company, Chicago, Illinois.
Wesley 0. Pipes, Professor of Civil Engineering,
Northwestern University, Evanston, Illinois.
Evan W. James, Vice President, Power Generation
and Engineering, Wisconsin Public Service Corporation,
Green Bay, Wisconsin.
Sol Burstein, Senior Vice President, Wisconsin
Electric Power Company, Milwaukee, Wisconsin.
0. K. Petersen, Senior Attorney, Consumers
Power Company, 212 W. Michigan Avenue, Jackson, Michigan.
John F. Carr, Chief, Environmental Research
Program, Fish and Wildlife Service, U.S. Department of
the Interior, Ann Arbor, Michigan.
Charles A. Bane, Attorney, of the firm of Isham,
Lincoln and Beale, One First National Plaza, Chicago,
Illinois.
Mary Alice McWhinnie, Professor, DeP'aul
University, Chicago, Illinois.
Steven E. Keane, Attorney, V/isconsin Public
Service Corporation, Milwaukee, Wisconsin.
Jack L. Hipke, Environmental Chemist, Wisconsin
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Vll
PARTICIPANTS (Continued):
Power and Light Company, Madison, Wisconsin.
Kenneth R. Roberts, Resource Management Officer,
Bureau of Commercial Fisheries, U.S. Department of the
Interior, Arlington, Virginia.
John R. Brough, Director, Air and Water Control,
Inland Steel Company, East Chicago, Indiana.
Peter J. Colby, Aquatic Biologist, Fish and
Wildlife Service, U.S. Department of the Interior, Ann
Arbor, Michigan.
Kenneth Lehner, Superintendent, of Chemical
Services, Wisconsin Electric Power Company, Milwaukee,
Wisconsin.
Thomas A. Edsall, Fishery Biologist, Bureau of
Commercial Fisheries, U.S. Department of the Interior,
Ann Arbor, Michigan.
Daniel Feldman, Attorney, of the firm of Isham,
Lincoln and Beale, One First National Plaza, Chicago,
Illinois.
Charles Powers, National Eutrophication Laboratory,
FWQA, U.S. Department of the Interior, Corvallis, Oregon.
Richard Callaway, Chief, Physical Oceanography
Branch, National Coastal Pollution Research Program,
Corvallis Laboratory, FWQA, U.S. Department of the Interior,
Corvallis, Oregon.
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Vlll
PARTICIPANTS (Continued):
John T. Graikoski, Microbiologist, Bureau of
Commercial Fisheries, U.S. Department of the Interior,
Ann Arbor, Michigan. (Read by Kenneth R. Roberts.)
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965
Murray Stein
PROCEEDINGS
MR. STEIN: Let's reconvene.
Let me outline some procedural problems we
have here. One, because we are running a little longer
than we expected, we are going to have to make some
adjustments in agenda in relation to the Commonwealth
Edison Corporation.
Will Mr. Petersen please come up?
This is the next point I wanted to talk about.
As you know, the acoustics in this room are fiendish,
particularly for the reporter.
Mrs. Hall has put herself in the spot where she
thinks she can hear best, which is over here on my left.
This is going to place an obligation on the people in
the panel on my right, and I would ask those to speak
very, very clearly, and identify yourself by name because
she can't really see you there.
Now, again, we also have a religious situation,
where some people have to get out of here by sundown. If
any of these people have a problem.of that kind and have
to get on, to get out, I wish they would let Mrs. Piere
know, and we will make arrangements so that will be done.
With that, may we have Mr. Petersen?
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966
0. K. Petersen
MR. PETERSEN: Due to the passage of time and
Interruptions, Mr. Bane of Commonwealth Edison has
consented to let two other companies make their
presentations before Commonwealth Edison continues with
its presentation.
In both cases, it would be advisable to allow
the questioning from the panel and from the floor while
the witnesses are here.
MR. STEIN: I think if this is agreeable to all
because of the complications we had, and the audience
looks as if it expected it, it has gotten a little smaller -
I think it might be helpful if we Just followed that
procedure with all of the witnesses from here on out. I
think it will move faster.
Is that agreeable? In addition to the panel we
will have public participation.
All right.
MR. PETERSEN: Mr. Joseph A. Pelletier, Vice
President in charge of Engineering and Electric Operations
for Northern Indiana Public Service Company, NIPSCO, will
give the statement for that company.
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967
J. A. Pelletler
STATEMENT OP JOSEPH A. PELLETIER,
VICE PRESIDENT, NORTHERN INDIANA
PUBLIC SERVICE COMPANY, HAMMOND
INDIANA
MR. PELLETIER: Mr. Chairman, conferee*, ladies
and gentlemen, my name is Joseph A. Pelletier. I am employed
by Northern Indiana Public Service Company as its Vice
President in charge of Engineering and Electric Operations.
I thank you for the opportunity to appear before this
third session of the Federal Conference on Lake Michigan
and its Tributary Basin. In my statement I will refer
to Northern Indiana Public Service Company as "NIPSCO."
NIPSCO is a combination utility engaged in
supplying electrical energy and natural gas to the public
in thirty counties in the northern part of Indiana.
NIPSCO's principal office is located at 5265 Hohrnan Avenue,
Hammond, Indiana 46320. NIPSCO serves an area of 12,000
square miles, which has an estimated population of 2
million. The company serves approximately 311,000 electric
customers and 421,000 gas customers. NIPSCO presently
has three generating plants located on Lake Michigan.
These plants are the Mitchell Generating Station,
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968
J. A. Pelletier
located at the western edge of Gary, Indiana; the Bailly
Generating Station, located in Porter County, Indiana; and
the Michigan City Station, located at Michigan City,
LaPorte County, Indiana.
Additional electrical generating units are
committed for the Michigan City Generating Station and
the Bailly Generating Station.
NIPSCO's experience has been that the electrical
demand in its territory has approximately doubled every 10
years. Geographically speaking, 70 to 75 percent of the
company's electrical demand has come from LaPorte, Porter
and Lake County areas, which are the counties in which our
present generating plants are located. NIPSCO understands
the environmental and ecological problems facing the
country and is keenly interested in their solution, and
has committed large sums of money in existing and pro-
posed facilities to provide improved environmental controls.
Additionally, the company has participated in
studies of Lake Michigan in an effort to determine the
validity or lack of validity of charges concerning, the
effect upon the lake of cooling water discharges by
generating plants.
NIPSCO has operated generating plants on Lake
Michigan for approximately 40 years and during the course
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969
J. A. Pelletler
of this operation it has been observed:
1) The extent of cooling water discharges into
the lake has been very local. Observations recorded by
photographs taken of the lake in wintertime show that
shore ice is undisturbed except in the immediate area of
the discharge plume.
2) Pish apparently find the temperature of the
discharge to their liking, as there has been a
concentration of fishermen at the discharge plume on many
occasions during the 4o-year history of NIPSCO's operation
on the lake.
3) Since 1967, NIPSCO has been conducting water
quality tests at Mitchell Generating Station, Gary,
Indiana, and Bailly Generating Station in Porter County,
Indiana, at the request of the Indiana Stream Pollution
Board. These tests have shown no change in the water
quality from warming.
4) During the *»0 years of NIPSCO's operation
on Lake Michigan no adverse results have been observed due
to our cooling water discharges into the lake.
The company has also reviewed and studied
infrared slides taken of our facilities from the air by
Willow Run Laboratories of the University of Michigan.
We are informed that these slides will be made available
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970
J. A. Pelletier
to the conferees by Willow Run Laboratories at this
conference.
The conclusion that we reach from these slides
is that the effect of the discharge plume is very local,
consistent with the observations as to shore ice heretofore
mentioned and temperature profile studies. The temperature
of ftie shore water is relatively uniform along the
shore outside of the immediate area of the discharge plume.
The company's facilities have been examined as
part of a study of Lake Michigan conducted by Dr. John
C. Ayers of the University of Michigan. The results and
conclusions of Dr. Ayers' study have presented or will be
presented to the conferees at this workshop.
In substance, it is our company's position
that the thermal effect of electrical generating stations
upon the 14.3 million acres of Lake Michigan is
insignificant. Much of the year the lake is unusable
for bathers because of the extremely cold temperature
of the lake. Electrical generating plants cannot change
this natural condition found in the lake. Further, we
have closely followed scientific studies of cooling water
discharges on the lake and we have not seen any evidence
in those studies of adverse effects due to generation
plants.
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971
J. A. Pelletier
On the other hand, the lake contributes sub-
stantially as a natural resource to the production of
power in the States of Illinois, Wisconsin, Michigan, and
Indiana. The citizens of these States have an interest
in the supply of adequate, reliable and economical power.
This interest is also part of the public interest in
its larger context and must be considered along with the
environmental interests. Standards should not be
established which threaten the adequacy and reliability
or unnecessarily increase the cost of electricity to
the consumers of Illinois, Wisconsin, Michigan and
Indiana.
It is in the nature of the electrical industry
that commitments for construction and actual construction
must precede the demand for energy. Commitments and
construction starts have been made by the industry to meet
the demands of the next decade. A good deal of this
construction necessary to supply electricity in the next
10 years is being obstructed and delayed by arguments
based upon what it is anticipated the lake thermal additions
may be by the year 2000. The construction necessary to
meet the requirements in the next 10 years should not be
delayed by these arguments. Research, studies and
monitoring programs now under way and proposed can reliably
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972
J. A. Pelletier
establish criteria, if necessary for future regulation,
long before the year 2000. A standstill at this point in
time based upon concern for a greatly increased number of
plants by the year 2000 will severely affect the residents
of the Midwest in the 1970»s.
In 1967, the State of Indiana adopted thermal
standards for Lake Michigan. These standards were
submitted to the United States Department of Interior and
were approved by that Department. NIPSCO operates within
the standards as adopted by the State of Indiana and as
approved by the Department of Interior. Subsequently, we
are Informed, the Department of Interior notified the State
of Indiana that the standards so adopted should be
reconsidered. We are unaware of the basis upon which
such a decision was made. Likewise, we are unaware of any
scientific studies or data in existence that would warrant
the change in the position of the Department of Interior.
We are further informed that the Department of
Interior proposes that no heat discharges will be
permitted in excess of 1 degree P. rise over ambient at the
point of discharge and that there will be no mixing zones.
We are unaware of any studies that have been made which
would support this standard. The two papers recently
released by the Department of Interior on the previously-
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973
J. A. Pelletier
announced-1-degree proposal do not contain any significant
Information which would warrant a change from the
presently-adopted standards of the conferee States. The
effect of the Department of Interior policy would be to
prohibit the operation of NIPSCO's three existing generating
plants and the construction of any new plants necessary
to meet the electrical demands of our area.
We earnestly suggest that Lake Michigan is a
valuable natural resource that is important to the
producers and consumers of electrical energy as well as
others here represented and that the thermal effect of
generating plants is local and Insignificant. We
further urge the conferees to conclude that the existing
Indiana standards are adequate and presently need no
revision, and that the Department of Interior proposal is
unnecessarily restrictive and detrimental to the electrical
power needs of the area.
Thank you.
MR. STEIN: Thank you. Are there any comments
or questions?
MR. MAYO: I have a question. In essentially the
last sentence on your page 3, you say the effect of the
Department of Interior policy would be to prohibit the
operation of NIPSCO's three existing generating plants.
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974
J. A. Pelletier
What brought you to that conclusion?
MR. PELLETIER: In looking at the arrangement
that would be required for attempting to meet the
1-degree arrangement, it would be necessary to make
complete revisions with respect to the plant facilities,
not knowing what the timetables could be with reference
to Installation of these devices to provide for cooling
other than the once-through cooling. We would have
difficulty and probably not be able to utilize depending
on what the timetable would be using this facility.
If a sufficient timetable were given, its
revisions could be made and it would not be
necessary to rule out the plant operation.
MR. MAYO: I think perhaps you are generally
familiar with the procedures in this matter involving
water quality standards. Where once the standard is
set precisely and its non-conforming discharges identified,
some reasonable period of time is given in which to take
the remedial action. So, I think it is inappropriate
for you to state flat out that the adoption of the
recommended Department of Interior position would in fact
prohibit the operations of the existing plants. I really
think that statement is erroneous.
MR. PELLETIER: Mr. Mayo, in dealing with all of
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975
J. A. Pelletier
environmental areas I think a number of companies
especially the steel companies run into problems of not
being able to make some of the schedules. We are faced
with this in the utility industry, based on some of the
deadlines given with respect to air quality and so on.
Based on the equipment that may be available,
being able to take a unit out of service and so on and
then comes a Court action with respect to a timetable
there is a question of whether you shut the plant down or
continue.
MR. MAYO: Well, I think if we look at the
history of the enforcement conference, in fact on the steel
industry in Lake Michigan, I think we will find without
any question that there has not been any threat of
shutdown. There hasn't been any significant impact on
production and yet the steel companies have moved ahead
with some reasonable speed in meeting the requirements of
the conference. So I would hope that as far as
the electric generating industry is concerned and the
public generally, that there would be an appreciation
of the fact that we would seek the same solution, to
the extent that current waste heat discharges might later
be determined to be in nonconformance with a standard
adopted by the conferees and by the States.
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976
J. A. Pelletier
MR. STEIN: Thank you. Are there any other
comments or questions?
Mr. Pelletier, in the interest of communication,
let me try something again because I know if you say
something over and over again, even though it may in
fact be somewhat larger than the truth, you tend to believe
it. It impedes working out a solution to the problem.
One, we have pointed out the Interior Department
does not have a policy yet on temperature in the Great
Lakes or in Lake Michigan. That is why we are here today.
The Department of the Interior has not made a
proposal. As we always have at these enforcement
conferences, we have a report by an investigatory staff
within the Department of the Interior who have come up
with certain conclusions and recommendations for
consideration by the conferees. I just ask that we consider
these. At the beginning, I said we are trying and I
hope we can work out with the power industry a position
and adopt a policy of the Department of the Interior,
as well as the other States, that will be fully compatible
with the requirements for operation of the power industry.
We do this all the time with other industries.
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977
J. A. Pelletler
As I said many, many times before, anyone can
clean up pollution by shutting down a plant whatever
It Is or putting a padlock on the city hall. That Is
no challenge. The challenge Is to keep you going, to
keep you competitive, and having you serve the needs of
the people and yet to protect the environment. And I
think If we start with that, we are going to be In a lot
better position to work out an agreement. I ask you
again to consider the record that we have not adopted a
policy nor has the Department of Interior put forward a
position yet.
MR. PELLETIER: It was my understanding that
this was the position of the Department of Interior, that
the 1-degree position or proposal I know that It isn't
the rule or the law, and that we have to go through the
normal procedure, but I think the general understanding of
the public and what you see in the papers, and so on, is
that this is a proposal or a movement of the Department of
the Interior.
MR. STEIN: I understand that. That is why I
said this again. I know I said this at the beginning of
the conference, and whatever your impression is by the
way, I have read the newspaper reports. I think they are
accurate. They have reflected this when we reported it to
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978
J. A. Pelletier
the papers. They have reported this. But I know that
may have been a Judgment, as reflected In several papers
presented here, but I think this is an important enough
point, and I think I am speaking officially for the
Department because we have been over this point or these
points or these what we consider misunderstandings
many, many times.
The Secretary of the Interior has indicated that
he makes the policy for the Department, and he hasn't
spoken on this yet* I don't think he is going to make
his judgment on this until he gets the recommendations of
the conferees sitting here. So we have no policy. We
have made no proposal from the Department because we never
do at one of these conferences. If we made this proposal
we wouldn't need this conference here.
We have an investigatory group. The conferees
are going to come up with recommendations, and I will take
those recommendations back and have them sent to the
Secretary of Interior for his judgment. This is the
procedure we are in now, and I think if we can have a
clear understanding of that, please do.
Again, I wish you could realize that some of the
questions and comments that we are raising here are to
bring points into sharp focus because we have no judgment
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979
0. K. Petersen
or prejudgment of this matter.
MR. MAYO: Mr. Chairman, you mentioned cleaning up
pollution by padlocking city hall. We don't have anyone on
our list yet on Lake Michigan. Have we missed something?
MR. STEIN: We had several on our list.
Do we have any others?
Thank you very much.
MR. PELLETIER: Thank you, sir.
MR. PETERSEN: With your indulgence, we would like
to make another change. Commonwealth Edison Company has
three speakers who we would like to offer for public ques-
tioning, and at this time Consumers Power Company would
like to offer D. H. Brandt and Dr. Reynolds for questioning
hopefully to catch up as much as possible before the presen-
tations.
MR, STEIN: Are there any questions from the aud-
ience of either Mr. Pelletier or the others, at the present
time?
If not, would you continue?
MR. PETERSEN: The two witnesses that Consumers
Power Company has to offer for questions are D. H. Brandt
and J. Z. Reynolds.
MR. STEIN: I see no request for questioning, so
let's continue with the presentation.
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930
B. 0. Lee, Jr.
MR, BANE: Thank you very much,
MR. STEIN: Right.
(Discussion off the record,)
MR. SHELDRICK: My name is Michael Sheldrick.
I am with McGraw-Hill Publications. I have a total of four
questions. I will try to make them as brief as possible.
MR. STEIN: Let's ask one at a time.
MR. SHELDRICK: One at a time?
MR. STEIN: Yes.
MR. SHELDRICK: First of all, it appears to me
that the biological and ecological studies that were pre-
sented here by various witnesses for Commonwealth Edison
all appeared first about April of 196S. We also heard
that the site was purchased some 15 years ago, and with
my knowledge of the way nuclear plants are built, the
company began at least 5 or 6 years ago, had made a
decision on the nature of the plant and what it would look
like. Why did the biological studies only begin in 196#,
and if they didn't before, could you describe all of the
ecological and biological studies that have been conducted
both at Zion and in general for Lake Michigan?
MR. STEIN: Would you identify yourself?
MR. BANE: Byron Lee, who previously testified,
will respond to this question.
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9&L
3. 0. Lee, Jr.
MR. LEE: Well, you are perfectly correct in that
we have owned the site for 15 years. It has been our choice
not to build at that site for this period of time primarily
because we felt that this was not a good site for a fossil-
fuel which in our terms means coal fired plant.
Because of its location we felt that this was a plant that
was best suited for nuclear power. As a consequence, the
decision to build the nuclear powerplant was not made
until it really nuclear power had proved itself to be
the right direction to go.
This decision was made about 196? to build and
design units and, as you pointed out, the studies started
shortly thereafter. We think that this is a fairly
reasonable time schedule to take with the operation of the
plants not starting until 1972 and 1973.
There was another part of the question, and I
am afraid
MR. SHELDRICK: Yes. I was just wondering
I can't pinpoint it exactly, but I think you did say that
a number of other places have been studied over a consid-
erable length of time, particularly Waukegan. Could you
describe the kind of ecological studies you have been
doing for whatever period you have been doing them?
MR. LEE: Well, basically, the other studies
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932
B. 0. Lee, Jr.
that we have been doing are, of course, at Waukegan. There
have been others. The study at Waukegan the first study
we have talked about is 1963. We have looked at the
basic outflow, and the effects of the outflow in general
terms at Waukegan. I would say the other location where
we have run studies of some depth have been at our Dresden
nuclear power station, and these date back, of course, to
the start of that plant in the late 1950's<>
MR. SHELDRICK: This second one is pretty much
directed at scientists, although if you care to answer,
that would be fine, too.
You have hinted and other people have that
if there is evidence of damage to the lake, even though
you submit at the same time that there won't be damage, you
will then take remedial action.
I would like to ask the scientists if they really
think there is enough data to draw a baseline from which
we can later determine if there is any deterioration of
the water quality in the lake as a result of the dischargesv
and if not what kind of data should be gotten, in what sort
of period 1 year, 2 years, 5 years, etc.«?
MR. LEE: Well, I would answer in general I think
that the study plan that we have submitted, I believe,
to the conferees, indicates the scope of the studies that
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G. F. Lee
we intend to run. It goes into great detail on the
information to be gathered, and the duration, of course
these studies will continue through this year and we will
keep updating them, depending on the results of what we
find, and they will continue through the start of the plant
and then will continue after the plant is in service for
a long enough time to verify what we are saying.
Now, I don't know if Dr. Lee would like maybe
to add anything to that or not.
DR. G. FRED LEE: Yes, I would support what has
been said here with regard to these studies. I think that
we have on the books now a reasonably good plan to determine,
I think, any significant changes in the characteristics of
the area. We could determine the baselines now and
the changes that may occur after the plant goes into
operation.
MR. SHELDRICK: All right. I have talked to many
people in the course of my activities. One of the things
I have found, among other scientists some of whom work for
FfeTQA they seem to say that the research results of
Commonwealth Edison and perhaps other people are private
research results* I am not I haven't finished with my
question yet. If indeed these are studies that you are fund-
ing will- you make them available to the qualified scientific
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934
3. 0. Lee, Jr.
researchers and the general public, and at what point
as the results come in, and when? I would like to know
what is your general position on releasing research that
you fund.
MR. BYRON 0. LEE: Well, I think we have stated
several times that the results of these reports will be
available to the various governmental agencies and other
people. We have tried to cooperate with all organizations*
In my statement I indicated that the Argonne
National Laboratory is really acting as a coordinator on
the studies being conducted at Waukegan and Zion between
Argonne, the Metropolitan Sanitary District and EPRO and
ourselves, and anybody else who would care to go into this
study plan.
MR. SHELDRICK: One final one: Would you be
willing to put up a performance bond at Zion which you
would forfeit in the event that there is deterioration of
water quality, say, 5 years, 10 years, or whatever period,
as sort of an act of good faith on your part?
MR. BYRON 0. LEE: I defer to the legal counsel
here.
MR. BANE: I think that is a legal question*
I haven't heard anything, and I don't know of anything
that impugns the good faith of Commonwealth Edison* We are
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A. J. Dowd
always financially responsible so I don't see any need for
a bond*
MR, STEIN: By the way, are you and Dr. Lee
brothers ?
MR. BIRON 0. LEE: No, sir.
MR. STEIN: Related?
MR. BYRON 0. LEE: Never met before until several
months ago.
MR. STEIN: I was wondering because you look a
little bit alike.
MR. BYRON 0. LEE: No.
MR. STEIN: Thank you.
MR. PETERSEN: A. Joseph Dowd, the counsel for
Indiana and Michigan Electric Company, will be in charge
of their presentation.
MR. DOWD: Mr. Chairman and conferees, ladies
and gentlemen. My name is A. Joseph Dowd. I am Assistant
General Counsel, American Electric Power Service Corpora-
tion, acting as counsel for Indiana-Michigan Electric
Company at this conference.
Indiana-Michigan Electric Company's presentation
this morning consists of four statements: The first by
Mr. Robert M0 Kopper, Executive Vice-President and Chief
Operating Officer of Indiana-Michigan. The second by Mr.
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936
A. J. Dowd
Fabian C. Polcyn, Research Engineer of Willow Run Labora-
tories, The third by Mr* D. H. Williams, Assistant Vice-
President and Chief Mechanical Engineer of the American
Electric Power Service Corporation. And the fourth by Dr.
John C. Ayers of the University of Michigan.
I should note that the professional qualifications
of our three technical expert witnesses, Mr. Polcyn, Mr.
Williams and Dr. Ayers, are attached to their prepared
statements, and we request that they be incorporated in
the record.
Now, it is also my understanding that all ques-
tions of these witnesses will be asked by the conferees
and by the members of the public at the conclusion of
their respective statements, is that correct?
MR. STEIN: That is correct.
I think we will move faster that way.
MR. DOWD: Fine.
Mr. Kopper.
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937
R. M. Kopper
STATEMENT OF ROBERT M. KOPPER, EXECUTIVE
VICE-PRESIDENT, INDIANA AND MICHIGAN
ELECTRIC COMPANY, FORT WAYNE, INDIANA
MR. KOPPER: Mr. Chairman, members of the con-
ference, ladies and gentlemen. I am Robert M. Kopper,
Executive Vice-President of the Indiana and Michigan
Electric Company, and its chief operating officer. I
appreciate this opportunity to present my company's
position with respect to the effect of warm water dis-
charges into Lake Michigan.
The Indiana and Michigan Electric Company, which
is a part of the American Electric Power System, supplies
electric energy to more than l££ communities in the States
of Indiana and Michigan. Over 1,600,000 people in our
service area are depending upon us for an adequate and
reliable electric power supply.
Demands for electric power have been increasing
over the Nation at a rate requiring the doubling of electric
generating capacity every 10 years. The territory in
which we operate in southwestern Michigan and northern
Indiana is growing at an even faster rate which requires
the doubling of electric generating capacity every 3-
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R, M» Kopper
years. As a public utility, we have an obligation under
the law to see to it that the necessary generation, trans-
mission and distribution facilities are available in order
to meet in a reliable manner this increasing demand for
electric energy. A substantial part of the increased
demand for electric power will be for municipal and indus-
trial purposes to eliminate discharges to air as well as
water that cause pollution.
It was this growing demand for electric power in
southwestern Michigan and northern Indiana that dictated
the need to build a large powerplant in the area ~ a
nuclear plant since our service area is some distance
from the coalfields of West Virginia, Kentucky, and Ohio.
In March of 1969» we received a permit from the
Atomic Energy Commission to construct the Donald C. Cook
Nuclear Plant on the southeastern shore of Lake Michigan
at Bridgman, Michigan. The Cook Plant, which is presently
under construction, will consist of two 1,100 megawatt
units and will have a capital cost of approximately $400
million, over $100 million of which has already been
expended. The plant will utilize the once-through method
of condenser cooling. At full load, this will involve
the circulation of about 1.5 million gallons of lake water
per minute. The company, after public hearing, received
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9^9
R. M. Kopper
the necessary authorization from the Michigan Water
Resources Commission to make this use of the lake water
subject to the condition that if any injury to the lake
should result from the discharge of this cooling water,
the company will take whatever corrective action may be
necessary to eliminate such injury. The cooling water
will be returned to the lake by means of a submerged outlet
located approximately 1,200 feet offshore. At maximum
plant loading, the temperature of the cooling water across
the condensers will be 21 degrees Fahrenheit warmer than
at the intake pipe. Also after public hearing, the company
received the necessary approval of the Corps of Engineers
for the construction of this cooling water system, and
such construction is presently under way.
Our decision to utilize the once-through cooling
method was arrived at on the basis of extensive and
detailed studies showing that warm-water discharges will
have no adverse effect upon the lake's ecology. To carry
out these studies, we obtained the services of the Great
Lakes Research Division of the University of Michigan,
and of Dr. John C. Ayers, who will be presenting a state-
ment later today. Frankly, when we initially contacted
Dr. Ayers, he advised us of his apprehension over the warm
water effects of the existing and proposed powerplants on
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990
R. M. Kopper
the lake and indicated that he was considerably disturbed.
We agreed to have the Great Lakes Research Division make
the studies with the full understanding that their findings
would be accepted on the basis of their own independent
evaluations. Dr. Ayers' conclusions, which he will present
to you later, as well as those of our own technical people,
are to the effect that warm water discharges into Lake
Michigan from the Cook Plant will not result in any harm
to the lake. One of the basic concepts that Dr. Ayers has
brought into focus is that the warmer water will float on
the surface and be exposed to the air and that the heat
will rapidly dissipate into the air. Lake Michigan will
reject the heat in this manner and the temperature of the
lake beyond and below the thin layer of the plume will not
be influenced by the warm-water discharge of this plant.
It is important to understand that his studies are not
limited to laboratory findings, but involve actual field
studies, including studies of powerplants that have
discharged warm water into Lake Michigan for a number of
years. His studies included the impact on benthic
organisms and other living organisms as well as algae.
Another area of environmental considerations
regarding the Cook Plant, which I believe is of relevance
to this conference workshop, is aesthetics. Because our
-------
R. M, Kopper
plant is located in the dune area along Lake Michigan, we
have given especially careful consideration to the planning
of our plant, its design, appearance and location, so that
when completed, there will be a harmonious blending with
the natural environment, even to the extent of using exterior
surface materials that will "weather," that is, oxidize, to
a compatible shade. We have adopted an entirely new
concept with respect to reactor containment, with the resull
that the total height of the containment structure can
reduced. This will permit the construction of a
plant which will be hidden from the adjacent land
the dunes and native trees. In fact, the plant
visible only from the lake.
With respect to Interior's anonymously
"white papers" which were issued on
attempt to retroactively justify its propos<
temperature rise limitation, we must note tj
contributions from the FWQA to these report!
to the report on Physical and Ecologd
National Water Quality Laboratoj
which is under the direction ol
is making a major effort to,
mter discharges upon
from participation ij
-------
992
Ro M. Kopper
Much of the basic argument in the report on
'logical effects is based upon conditions projected for
.e year 2000 with no consideration of the present or of
rany time short of the year 20000 It misleads the reader
into equating "now" with the year 2000.
The basic arguments given in this report do not
Lude any evaluation of existing warm-water discharges,
of which are substantial. This report provides no
^tion of any proven, appreciable damage from the
;tscharges. The published discussion does not
^resent discharges should be eliminated if
i; nor does it address itself to why dis-
Slants presently under construction will be
sting discharges do no harm; also it does
5charges of the near future will be
$rs only what might occur in the year
ipeaker in our presentation, Mr,
the monumental engineering
comply with the
pmmendations that have
w that the erection
ts the tic
concept of
be
-------
991
R. M, Kopper
plant is located in the dune area along Lake Michigan, we
have given especially careful consideration to the planning
of our plant, its design, appearance and location, so that
when completed, there will be a harmonious blending with
the natural environment, even to the extent of using exterior
surface materials that will "weather," that is, oxidize, to
a compatible shade. We have adopted an entirely new
concept with respect to reactor containment, with the result
that the total height of the containment structure can be
reduced. This will permit the construction of a low profile
plant which will be hidden from the adjacent land area by
the dunes and native trees. In fact, the plant will be
visible only from the lake.
With respect to Interior's anonymously authored
"white papers" which were issued on September IB in an
attempt to retroactively justify its proposed 1-degree
temperature rise limitation, we must note the paucity of
contributions from the FWQA to these reports, particularly
to the report on Physical and Ecological Effects. FWQA's
National Water Quality Laboratory near Duluth, Minnesota,
which is under the direction of Dr. Donald Mount and which
is making a major effort to determine the effects of warm- r.
water discharges upon aqua/tic life, was conspicuously absent
from participation in this report.
-------
992
Ro M. Kopper
Much of the basic argument in the report on
ecological effects is based upon conditions projected for
tte year 2000 with no consideration of the present or of
my time short of the year 20000 It misleads the reader
into equating "now" with the year 2000,
The basic arguments given in this report do not
ip.-i.ude any evaluation of existing warm-water discharges,
some of which are substantial. This report provides no
documentation of any proven, appreciable damage from the
existing discharges. The published discussion does not
suggest why present discharges should be eliminated if
they do no harm; nor does it address itself to why dis-
charges from plants presently under construction will be
harmful if existing discharges do no harm; also it does
not tell us why discharges of the near future will be
harmful. It considers only what might occur in the year
2000.
The next speaker in our presentation, Mr.
David Williams, will discuss the monumental engineering
changes that would be necessary "t-o comply with the
thermal discharge policies or recommendations that have
been issued by Interior. He will show that the erection
of cooling towers would destroy the aesthetic concept of
our plant and that the other alternates would be equally
-------
993
R. M. Kopper
offensive. He will show that these alternatives are tech-
nically unsuited for this plant at this site and at this
stage of construction.
Dr. John C. Ayers will follow Mr, Williams. Dr.
Ayers will summarize his studies and report on evidence
regarding the effect on the lake of warm-water plumes of
generating plants, and that the dimensions of these warm-
water plumes are very limited.
After Dr. Ayers, the next speaker will be Mr,
Fabian Polcyn, Research Engineer of the Willow Run
Laboratories of the University of Michigan. Mr, Polcyn
will show you some actual displays of aerial mapping of
natural and industrial discharges into Lake Michigan of
warm water. His photographs are evidence of the actual
areas of the lake that are occupied by these warm water
plumes.
In concluding my own remarks, I would simply
ask that we not lose sight of the fact that the use of
limited areas of Lake Michigan for industrial cooling pur-
poses is a legitimate use of the lake and, under the law,
is on a par with other legitimate uses. Thermal standards,
therefore, should not prefer one such use to the virtual
exclusion of other uses. Nor should thermal standards
have as their goal the optimization of one such use with
-------
994
R. M. Kopper
the result that other legitimate uses of the lake can be
accommodated only to the extent that they permit such
optimization. Valid thermal standards must be realistic
and they must give recognition to all legitimate water
uses.
I also commit my company to support continued,
meaningful studies by qualified personnel in a cooperative
program with the appropriate State and Federal agencies.
The increased knowledge from such studies will p;ive
assurance to the public that no injury will befall Lake
Michigan.
MR. STEIN: Thank you.
Are there any comments or questions?
Let me make one factual statement here, because
this is something with which, at least in some other
capacity I have had something to do. On the allegation
of Dr. Mount's and others not participating in the
report, this report was prepared by the Fish and
Wildlife Service, and they were familiar with Dr. Mount's
views. As a matter of fact, I had them sent over there,
as well as Dr. Tarzwell's and our other experts. So
they did participate in this report.
Mow, I have heard this several times. You talk
about anonymously authored "white papers." This is one
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995
R. M. Kopper
of the issues on which I guess we may have a difference
within the Federal organization. I say I am certainly
sympathetic with you because my position has always been
to list the names of the people who prepared these
documents.
The issue here is not to preserve anonymity.
One of these reports comes from the organization with
which I am intimately concerned, i.e., the second one.
That has an institutional preparation.
One report says, "Prepared by National Thermal
Pollution Research Program, Pacific Northwest Water
Laboratory and Great Lakes Regional Office," and the
other does the same kind of thing. It says, "Prepared
by Great Lakes Fishery Laboratory, Bureau of Commercial
Fisheries, Ann Arbor, Michigan, in Cooperation with the
Bureau of Sport Fisheries and Wildlife, Federal Water
Quality Administration."
Now, we did this: The people who prepared
these reports and who are responsible for them are here.
They have appeared before you and they have answered
questions. I do not think that this is a question of
anonymity. However, I can sympathize with vour
raising the charge, not having them signed. I would
hope to commend this sort of thing to our organization
-------
996
R. M. Kopper
again. But the people are here and their names are here
and they are available as the people responsible for writing
these reports.
Looking at it from the Government point of view,
I thimc, Mr. Kopper, rather than anonymity and I say
this as the point of view that we espouse within the
Government some people think that it is better to
have an institutional representation of these things as
opposed to an individual representation. I would like
to say that I think it is a matter of style rather than
having anyone hide behind a closet of anonymity.
Are there any other comments or questions?
Are there any comments or questions from the public?
If not, thank you very much, sir.
MR. KOPPER: Yes, sir.
MR. DOWD: Mr. Chairman, because of the
scheduling problem, we would like to present Mr. Fabian
Polcyn. Mr. Kopper had indicated that the next speaker
would be Mr. Williams. We would like Mr. Polcyn to
move up to second position.
-------
997
P. C. Polcyn
STATEMENT OP FABIAN C. POLCYN,
RESEARCH ENGINEER, THE UNIVERSITY
OP MICHIGAN, ANN ARBOR, MICHIGAN
MR. POLCYN: Mr. Chairman, conferees, ladies and
gentlemen. My name is Pabian Polcyn, Research Engineer
with The University of Michigan, Willow Run Laboratories.
I would like to present the results of some multispectral
surveys in Lake Michigan.
(Mr. Polcyn1s qualifications and publications
follow on Pp. 998-999)
During the last 2 years, overflights of Lake
Michigan by The University of Michigan, Willow Run
Laboratories have been made under sponsorship of both
Federal agencies and utility contracts. More recently,
two flights were made under contract with Indiana and
Michigan Electric Company as part of their continuing
study of the ecological factors related to thermal
effluents.
We present today results of these surveys
specifically those which mapped the extent of the heated
effluents along the eastern shore of Lake Michigan from
Michigan City, Indiana to Muskegon, Michigan.
-------
BIOGRAPHICAL SUMMARY
for
Fabian C. Polcyn
Mr. Polcyn is a research engineer with the Willow Run Laboratory at
The University of Michigan1s Institute of Science and Technology. He
holds a BSE (Physics) 1954 and a MS (Physics) 1958 from The University of
Michigan and has been employed with the Institute since 1959. He is
presently head of the Interpretation and Information Group of the Infrafed
and Optics Laboratory, a unit of WRL. The laboratory received an award
in 1969 from the American Society of Photogrammetry for development of the
Multispectral Optical-Mechanical Scanner.
Mr. Polcyn has a wide range of experience in remote sensing
instrumentation and technique developments as well as applications as
exemplified by the list of publications attached.
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999
PUBLICATIONS
"Infrared", Co-author, International Science and Technology, April 1963.
"infrared Scanner Observations of Volcanic Activity", Co-author,
Proc. IRIS, Vol. 8, No. 3, August 1963.
"MORL Multispectral Experiment Definition", Co-author, The University
of Michigan 1ST, Report 6688-1-F, August 1964.
"Comparative Multispectral Sensing", Co-author, The University of
Michigan, 1ST, Report 2900-484-S, March 1964.
"Multispectral Data Collection Program", Co-author, Proceedings of the
Third Symposium on Remote Sensing of Environment, February 1965.
"Infrared Surveys of Hax^aiian Volcanoes", Co-author, Science, Vol. 146,
No. 3645, p. 733, 6 November 1964.
"investigations of Multispectral Image Interpretation", Co-author,
Proceedings of the Third Symposium on Remote Sensing of Environment,
February 1965.
"Investigation of Spectrum Matching Sensing in Agriculture", Semi-annual
Report, 2 Vol., September 1967.
"Investigation of Spectrum Matching Sensing in Agriculture", Final
Report, Vol. 1, November 1967.
"Remote Sensing Techniques for the Detection of Doubtful Shoals", Co-
author, Ninth Meeting of. Ad Hoc Spacecraft Oceanography Advisory
Group, January 1968.
"How Multispectral Sensing Helps the Ecologist", Co-author, Remote
Sensing in Ecology, First AIBS Interdisciplinary Meeting on
Environmental Biology, June 1968.
"Analysis of Lake Michigan Data", Preliminary Science Report, Co-author,
Report 8973-13-L, November 1968.
"Remote Sensing Techniques for Location and Measurement of Shallow
Water Features," Co-author, Report No. 8973-10-F, January 1969.
"Effects of Atmospheric Path on Airborne Multispectral Sensors"
Co-author, Report 1674-5-T, January 1969.
"Applications of Multispectral Remote Sensing Techniques in Water
Pollution Control", Co-author, 157th National Meeting of the
American Chemical Society, April, 1969.
"Taking a New Look at the Lakes", LIMNOS, Vol. 2, No. 2, p. 12,
Summer 1969.
"Water Depth Determinations Using Remote Sensing Techniques", Co-author,
Proceedings of the Sixth International Symposium on Remote Sensing
of Environment, October 1969.
"Potential Applications of Remote Sensing to Oceanography and Hydrology",
Co-author, presented at the Remote Sensing Principles and Applications
To Earth Resources Survey Seminar, Paris, France, November 1969.
"Multispectral Remote Sensing Study of Industrial Discharges," Co-author,
presented at the 25th Annual Purdue Industrial Waste Conference,
Purdue University, May 1970.
"Analysis of Multispectral Data of the Santa Barbara Oil Slick", Co-author,
Final Report 3340-4-F (in publication).
"The Measurement of Water Depth by Remote Sensing Techniques", Co-author,
Final Report 8973-26-F, (in publication).
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1000
P. C. Polcyn
The sensor system used in most of these flights
collects light in the ultraviolet, visible, and the
thermal infrared wave lengths, simultaneously. Thus, the
color of the water and any temperature patterns can be
mapped to learn their mixing patterns and to measure
their area of influence. The infrared radiation observed
by this airborne method comes from only the surface of the
water, and since the warmest waters are usually least
dense, the surface patterns are a reliable measure of
the maximum spatial extent of a given temperature Interval.
Thermal contours were made by electronically isolating a
signal for each degree of temperature, beginning with ambient
lake temperature and ending with the warmest temperature
present in the thermal plumes. Each degree of temperature
was assigned a color, and a display of the temperature
mixing pattern was formed.
Three types of results will be presented today
in a series of slides. These include the discharges
around existing plumes, the temperatures at sites not yet
in operation, and naturally-occurring temperature patterns
many of which are greater than 1 degree of temperature.
Now, we will supply negatives for these slides at a later
date.
If we could now look at the series.
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1001
P. C. Polcyn
MR. STEIN: I should mention that we do not
reproduce color, so when these appear in the report
everything will be in black and white.
MR. POLCYN: I am sorry to hear that.
MR. STEIN: Let me go off the record just
for a second here.
(Discussion off the record.)
MR. STEIN: Back on the record.
MR. POLCYN: Thank you.
... Slide ...
The first slide is showing a map of Lake
Michigan.
Two flights were flown, one on 11 August 1969,
and the other on 7 May of this year. Fossil powerplants
at Michigan City and Port Sheldon, two proposed nuclear
plant sites, one at Bridgeman (Cook Plant) and one at
Palisades as well as the St. Joseph River outfall were
mapped.
... Slide ...
Color Aerial Photograph of Harbor at Michigan
City, Indiana, 11 August 1969
The area shown is 1-1/2 mi. x 3/iJ ml. The
distance across the harbor is 2,000 ft. The harbor,
river, marina, and plant site can be readily seen. Sediment
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1002
P. C. Polcyn
in the harbor water can be detected due to the light
yellow hue. Lack of any pronounced current due to the wind
is evident by the uniform pattern of distribution across
the harbor.
... Slide ...
Color Code for Temperatures, 11 August 19&5
The temperature range for each color is shown
in the table. In general, as color shifts from blue to
red, the temperatures increase.
... Slide ...
Color Coded Thermal Contour of Harbor at
Michigan City, Indiana, 11 August 1969
The image here is 2-1/4 mi. x 3/4 mi. Temperature
pattern can be seen by observing distribution of each
color. A 4.4 degree P. difference was measured between
the lake temperature (dark blue) and warmest part of
discharge plume (sepia). The reason this Delta T is smaller
than the 11 degrees P. across the condensers is that the
intake pipe is below the river's surface where the water
was measured to be almost 4 degrees P. colder; also, there
is some cooling as the water flows down the discharge
canal. The size of the warmest portion is only of the
dimensions of the width of the river channel,
approximately 270 ft. Cooling of the warm plume takes
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1003
P. C. Polcyn
place continuously so that relatively small areas are influ-
enced by waters even 2 degrees P. above ambient lake
temperatures. For this day, the warmer waters were
confined inside the harbor barrier and no recycling of
the heated water was present.
«,. Slide ...
Color Aerial Photograph of Harbor at Michigan
City, Indiana, 7 May 1970
Distribution of sediment in harbor is different
in comparison with Slide 2 taken on 11 August 1969. Edge
of current (movement of suspended sediment) can be seen at
the upper right Just above harbor breakwater.
MR. STEIN: Let me interrupt. Maybe counsel
wants to consider this, but since this depends so much
on color, I would suggest you consider putting these in
as an exhibit, so we have these on file in Washington and
in the regional office . If anyone has to go to this,
we can produce slides, I know it is going to lose a lot
of its impact if it gets to black and white. Would that
be agreeable?
MR. DOWD: We would prefer to do it that
way, because colors are so Integral to this presentation.
MR. STEIN: That is the essence of the
presentation.
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1004
P. C. Polcyn
MR. DOWD: Exactly, we will do that.
MR. STEIN: Right.
MR. FETTEROLF: Mr. Polcyn, would it be
possible to have Mr. Ayers point with the pointer and to
point out some of these areas you are speaking about?
MR. POLCYN:. I think that is possible, or Mr.
Stewart is nearer by the screen. He could perhaps point
them out.
MR. FETTEROLF: Is there a pointer available?
Let's hope Mr. Stewart has a long arm.
MR. MAYO: While we are waiting for Mr. Stewart
to come up, at the time the photographs were taken were
on-the-site ambient temperatures taken?
MR. POLCYN: At each site personnel from the
plant there were plant personnel taking ground
measurements, surface measurements.
Now, there is evidence of current flowing
eastward due to wind from WSW (at 13 knots). Muddy water
was due to several days of rain which caused Trail Creek
to be very turbid. The plant was taking this water,
pumping it through the condensers, and discharging it
into the harbor.
... Slide ,,.
Color Code Table for Temperatures, 7 May 1970
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1005
P. C» Polcyn
... Slide ...
Color Coded Thermal Contour of Harbor at
Michigan City, Indiana, 7 May 1970
Temperature range and distribution is seen to be
different in comparison to 11 August 1969, data. The
area shown in this slide is 2-1/2 mi. x 1-1/2 mi. Strong
winds (from west) affect surface waters most readily
and thus warm waters are pushed eastward against breakwater.
Warmest water (Magenta) at outfall is 10 degrees P. warmer
than lake rater temperature (dark blue). Water at tempera-
ture 3.4 degrees P. above lake temperatures can be seen
flowing past breakwater similar in distribution to sediment
pattern of Slide 5.
Due to the springtime heating of land faster
than water, temperatures about 6 degrees P. (orange
color) warmer than lake temperatures (dark blue) can be
seen all along shoreline. This naturally-occurring heating
of shore waters should be noted for its greater importance
in contributing to lake temperature rise because of
the wider area of influence along the entire shoreline
compared to the localized area of plant discharges.
... Slide ...
Water Masses at Harbor at Michigan City,
Indiana, August 11, 1969
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1006
P. C. Polcyn
Shown here is the result of multispectral
processing of the visible data to obtain different water
masses in an area 3 mi. x. 1 mi. path. The tan, sepia,
violet, and cyan areas show varying kinds of deeper lake
water. This apparent turbidity in the water was probably
due to the two previous days of strong winds from the NW.
The dark blue area in the harbor shows the distribution of
river water. The marina shows up strongly as a contributor
to this particular kind of water in the harbor.
... Slide ...
Water Masses in Harbor at Michigan City,
Indiana, 7 May 1970
The water mass distribution as seen on this
day is quite different from that observed on 11 August
1969.
In the 4 mi. x 1-1/4 mi. area shown, dark blue
shows the deeper lake water, the pastel blue shows the
pattern of nearshore waters heavily laden with sediment.
The medium blue inside the harbor corresponds to
sediment pattern seen in Slide 5 and the dark green shows
river water entering harbor.
A small patch of river water (dark green color)
can also be seen at the discharge point of the plant
effluent. This suggests the relatively small influence the
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1007
P. C. Polcyn
cycling of river water by the plant for cooling purposes
has on the harbor area. Under strong winds (13 knots, WSW)
the near-shore currents appear to dominate the harbor
waters.
... Slide ...
Discharge Plumes at Campbell Plant, Port Sheldon,
Michigan, as Function of Wind
Plumes Shown were taken at three different times
under widely separated wind conditions. The top plume
was obtained on 7 May 1968, when a SE wind of 14 knots was
blowing. The strong wind blows the plume to the north and
NW. Most of the warm water has been cooled by the time
it reaches the right-hand edge of the picture (about 1/2 mi.)
The middle plume was obtained on 26 September
1968. The wind for this day was out of the NW at 10-12
knots. The velocity of the discharge carries the warm
water straight out for a few hundred yards before the
wind blows it back towards shore. The distance from the
discharge point to the harbor breakwater is 3/4 mi.
The bottom plume shows the effect of both wind
and current. The wind for this day (11 August 1969) was
4 knots out of the SE but a strong 2-day wind out of the
NW had just ended 9-12 hours earlier. The relatively calm
wind is just beginning to effect the shallower water as
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1003
F. C. Polcyn
evident by the portion of the plume seen near shore to the
north of the discharge canal.
We see by this evidence that the warmer water
near the surface is most easily moved about by changes in
wind direction. We also see that no accumulation of
warmer water is found in any given place. In fact,
although a larger area may be covered because plumes can
be found north and south of the discharge channel, a given
receiving point will experience a variable contact with the
warmer discharge waters and hence will not be heated
continuously. In other words, wind direction changes
produce a spreading of the heat over a larger area and
thus increases the heat exchange to the surroundings.
... Slide ...
Color Aerial Photograph of Palisades Nuclear
Plant Site, Michigan, 11 August 1969
The construction at the site is clearly visible
on the lower right corner of the 1-1/2 mi. x. 1-1/8 mi.
area shown. The sediment which has been placed in
suspension by 2 days of NW winds can be seen near shore as
compared to the deep blue waters offshore. The very light
area in the water off the plant site is a sand bar built
up because of a sunken barge located there.
... Slide ...
-------
1009
F. C. Polcyn
Color Coded Thermal Cqntour_of Palisades Nuclear
Plant Site, Michigan, 11 August. 1969
It is apparent that very little temperature
pattern is present off the site which is as one would
expect since no thermal sources are near. A naturally-
occurring 1-degree variation is seen towards the middle
of the picture which is probably due to an upwelling
of colder water. The area shown is 3/4 mi. x 3 mi.
... Slide ...
Water Masses at Palisades Plant Si/be, Michigan,
11 August 1969
The imare represents an area 1 mi. x. 3-1/4 mi.
Although few temperature gradients were noticed (Slide
12) there is a mixture of different water masses inshore
while the deeper water shows little change. Tnis shows
the naturally-occurring change in water Quality due
to strong wiids before plant is placed in operation.
... Slide ...
Wat e r Mas s e s at^ Pa 1 is ad e s Nuc1ea r PI an t Site,
tfichigan, 7 May 1 }?0
Although the wind was stronger this day as
compared to 11 August and also heading in a different
direction, there was no previous history of poor weather
to stir the water and produce the changing water masses as
-------
1010
F. C. Polcyn
seen before on 11 August 1969. The sunken barge area can
be seen quite clearly in this picture.
... Slide ...
Thermal Imagery of Donald Cook Plant Site,
7 May 1970
Warmer land area appears brighter in the picture,
The Cook Plant Site is located to the left of the middle
of the slide.
... Slide ...
Water Masses off Donald Cook Nuclear Plant Site,
Bridgeman, Michigan, 11 August 1970
The area shown is 3 mi. x 1 mi. Again, the
turbulence caused by the preceding 2 days of strong
weather is shown by the water mass patterns. The Cook
plant site is along the shore near the left middle of the
slide. These particular patterns suggest that some
effluent from the St. Joseph River might have been swept
past the site by the storm.
... Slide ...
Color Code Table for St. Joseph River, 11 August
1969
... Slide ...
Color Coded Thermal Contour of Benton Harbor/
St. Joseph, Michigan, 11 August 1969
-------
1011
F. C. Polcyn
As can be seen for this time of year the tempera-
ture difference between the river water (blue-green) and
lake water (cyan) is 1.4 degrees P. The direction of the
river flow is due to a slight SW wind blowing at that
time. The dimensions of the image are 2-1/4 mi. x 3/4 mi,
... Slide ...
Water Masses at Benton Harbor/St. Joseph,
Michigan, 11 August 1969
The dark green area (3/4 sq. mi.) shows the
effluent from the river while the dark and pastel blues
show water masses in deep and shallow water. It is possible
that the river was turbid due to increased runoff from land
due to the storm and this is what is being emptied into
the lake. Area shown covers 3 mi. x 1-1/2 mi.
... Slide ...
Color Code Table for Temperature, 7 May 1970
... Slide ...
Color Coded Thermal Contour of Benton Harbor/
St. Joseph Harbor, Michigan, 7 May 1970
Compared to 11 August, a very dramatic, change
takes place in the river-lake relationship during the
spring. Because the land is warmer than the lake, the
river water has warmed up considerably while the lake
water, being a much larger body of water, still remains
-------
1012
P. C. Polcyn
quite cold. The difference in temperature between the
warmest part of the river (red) and the deep lake water
(dark blue) is 14.9 degrees P. The heating of the
shallower waters near shore is also evident by yellow and
orange strips near shore. Even these areas are more than
8 degrees P. warmer than the deeper offshore water.
... Slide ..,
Infrared Image of Thermal Bar in Lake Michigan
This strip of infrared imagery was taken with an
infrared scanner at 12,000 feet on 7 May 1968, along the
eastern shore of Lake Michigan between Port Sheldon and
Muskegon, Michigan, a distance of 30 miles. The darker
tones represent cooler temperatures than the lighter ones.
In the lower edge toward the right, the outfalls of the
Grand and Muskegon Rivers can be seen as bright plumes.
Temperatures measured across "thermal gradient" seen
offshore were about M degrees P. The large areas of
these thermal anomalies generated naturally by the warmer
temperatures of the land during the day in spring place
in better perspective the relative contribution of warm
waters discharged locally by power generating plants and
that produced by the natural environment along many miles
of shoreline.
In summary, we have shown pictorially the
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1013
F. C. Polcyn
relatively small area of influence due to heated discharges
from plants presently operating along Lake Michigan. We
have shown how the temperature contours distribute across
the plume and how they are influenced by the wind changes.
Finally, we have shown examples of naturally-occurring
temperature gradients in the lake, many of which lie between
4 degrees and 15 degrees F. higher than the background water
temperature and extend over areas much larger than what
is observed at power generating plant sites.
MR. FETTEROLF: Mr. Polcyn, A PT appears on that
slide that would take in a shoreline area which includes
the candle point.
MR. POLCYN: Yes, it is off to the very left
corner, if Mr. Stewart would try to point to it. It is
just barely seen. It is much smaller than the outfalls
from the Grand River and the St. Joseph River. We would
have to see this picture much closer to just see it.
MR. FETTEROLF: The large warm water masses
which are shown the're are not due to the influence of
river flows or heated discharges?
MR. POLCYN: As we saw from the colored bank
across the edge of the shoreline in the spring pictures
in these previous slides, one would have to conclude
that the effect of land heating and water seems to be
-------
1014
F. C. Polcyn
bigger this is shown here, the orange band across it
extends for every mile along the shoreline. In my judgment
it would be this mechanism which probably leads to heating,
although there is bound to be some minor influence by the
rivers and the plants, but it seems the major contribu-
tion would have to be by this extended heating source.
MR. STEIN: Are there any other comments or
questions from the conferees or any from the public?
If not, thank you very much, Mr. Polcyn, for a
very interesting presentation. Without objection, the
slides will be entered as exhibits and will be available
in Washington at Headquarters and at our Regional Office
and be available for inspection during normal business
hours. Of course we will make them available to anyone
who wants to evaluate the report. I think that is probably
the best way to handle this.
(The above-mentioned slides are on file
Headquarters, FWQA, Washington, D.C., and the Great
Lakes Regional Office, Chicago, Illinois.)
May we continue?
MR. DOWD; Our next speaker is Mr. David
Williams.
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1015
D. H. Williams
STATEMENT OP DAVID H. WILLIAMS, JR.,
ASSISTANT VICE PRESIDENT AND CHIEF
MECHANICAL ENGINEER, AMERICAN ELECTRIC
POWER SERVICE CORPORATION, NEW YORK,
NEW YORK
MR. WILLIAMS: Mr. Chairman, conferees, ladies
and gentlemen. I am David H. Williams, Jr., Assistant
Vice President and Chief Mechanical Engineer of the
American Electric Power Service Corporation.
(Mr. Williams' qualifications appear on P. 1016)
Mr. Chairman, it is my intent to use some
slides during my presentation and we will make a
duplicate set of the slides available to you, too.
MR. STEIN: Are these colored ones, too?
MR. WILLIAMS: Some of them are, yes, sir.
MR. STEIN: Let's see. Again, make your
judgment whether you want them reproduced in black and white
in the report or handled as exhibits, and you don't have to
do that right now. Maybe we can see what they look like.
MR. WILLIAMS: Fine.
The design of the Donald C. Cook nuclear plant
utilizes the cooling capacity of Lake Michigan as a
-------
1016
D. H. Williams, Jr.
D. H. Williams, Jr. is Assistant Vice President and Chief Mechanical
Engineer. In this position he is responsible for the mechanical
engineering activities of the American Electric Power System.
Mr. Williams received his B.S. and M.S. in Mechanical Engineering from
Virginia Polytechnic Institute in 1953 and 1954, respectively. In the
period 1954-1956, he was a lieutenant in the U.S. Army Corps of Engineers,
Company Commander in a construction battalion.
Mr. Williams joined the AEP Service Corporation in 1956 as an engineer
responsible for the startup of several new large turbine-generator
installations, including maintenance and operating procedures. In 1961,
he was appointed Head of the Turbine Section of the Mechanical Engineering
Division, with responsibility for all turbine activities in the AEP
System. In 1963, Mr. Williams was appointed Prelect Engineer, in charge
of design studies and coordination of design activities for the Cardinal
Plant which consists of two 600 Mw units. He was promoted to Assistant
Chief Mechanical Engineer in 1965 and to Chief Mechanical Engineer in
1967.
Mr. Williams was elected to his additional, present position of Assistant
Vice President in July 1968.
Mr. Williams is a member of The American Society of Mechanical Engineers
and Pi Tau Sigma.
-------
1017
D. H. Williams
natural resource to provide vital low cost electric energy
to the consumers in Indiana and Michigan Electric Company's
service area and on the AEP system. From the initial design
concept we have followed the philosophy of utilizing
the lake water for cooling without abuse or harmful effects
to the health, safety or welfare of the public. Also of
primary importance in the design has been the concept of
keeping the plant site as aesthetically pleasing as
possible.
The cooling water for the two-unit plant is
brought into the plant structure through three 16-foot
diameter pipes which extend some 2,280 feet out into the
lake. The water intake into each of these pipes is a
steel crib structure located on the bed of the lake
some 12 feet below the surface. Each of the three intake
structures is designed with a screen having eight inch
openings to avoid the possibility of drawing large objects
into the pipes. Where the pipes enter the plant structure,
the water then passes through rotating screens and is then
pumped by seven circulating water pumps through the unit
condensers and is discharged back to the lake through two
pipes. These discharge pipes extend approximately 1,200
feet out into the lake.
The concrete portion of the circulating water
-------
1018
D. H. Williams
pump house as well as the sinking of the intake and
discharge pipes into the lake is well under way, as is
shown in these slides. All the cooling circuits in the
plant have been designed and the equipment purchased.
In most cases this equipment is in the final stages of
production or has been shipped to the Job site.
To consider an alternate scheme for cooling at
this point in time would require a drastic redesign of
a number of major components which would have the immediate
effect of delaying the generating capacity of this vitally-
needed plant, reducing the efficiency and plant output and,
while not of primary concern here, but nevertheless an
important factor to our customers, is the fact that there
would be a significant increase in the cost of the plant.
It is our firm belief that the existing design will meet
the requirement of having no harmful effect. It is our
position, therefore, that an alternate cooling means would
have no beneficial effect on the lake or to the general
public.
In discussing alternate cooling methods in
powerplant design, I would like to point out that the
American Electric Power Company is probably the leader in
the utility industry in the development and application
of natural draft wet cooling towers. The first such tower
designed and installed in this country went into service
-------
1019
D. H. Williams
in 1963 on a 275-MW unit at our Big Sandy Plant in
eastern Kentucky. This was the first so-called hyperbolic
natural draft cooling tower built in this country. This
tower is some 320 feet high and has a base diameter of
245 feet. Since this first tower was built, we have
designed and built a natural draft tower for a 600-MW
unit which went in service in 1968. This was followed
by the construction of five 800-MW units located in three
different plants, each utilizing a single natural draft
cooling tower for condenser cooling. We are presently
in the process of designing and constructing a 1300-MW
fossil unit which will utilize a single natural draft
cooling tower with a diameter of 400 feet at the base and
a height of 495 feet. This tower has the capability of
cooling 600,000 gallons/min. of water by 20 degrees P.
This gives a heat rejection rate of 6 billion B.t.u.'s/hr.
The physical size of this tower is dramatic. It could
hold the playing field of White Sox Park. The Marina
Towers could fit with ease inside this tower.
It has been, and continues to be, our position
that design of each generating facility should be
approached on the basis of a thorough study of water
requirements, heat discharge and environmental effects.
In applying for the water-use permit from the State of
-------
1020
D. H. Williams
Michigan, the cooling tower concept was considered for
the Cook Nuclear Plant. However, after talcing all things
into consideration, it was felt that no sound environmental
purpose would be served by the construction of cooling
towers at this site quite the contrary, that the public
interest would be best served by utilizing the lake for
cooling. The point is and our record bears this out
that the AEP system does not hesitate to go to cooling
towers where they are needed.
We have given careful consideration to the recently
proposed 1 degree P. rise limitation for Lake Michigan.
The longer we looked into the problem the more overwhelming
and impractical the possible solutions became and we
arrived at the following general conclusions based on the
design of our plant.
There are two basic approaches to the problem
of designing for 1-degree P. rise. The first being to
maintain the present once-through cooling concept, but to
discharge the warm water back to the lake with a temperature
not to exceed 1 degree P. above the ambient lake
temperature. The second alternative is to design a
closed loop cooling system utilizing either a cooling pond,
wet cooling towers or so-called dry cooling towers. This
study parallels to a modest extent the recently received
-------
1021
D. H. Williams
document from the U. S. Department of the Interior, "The
Feasibility of Alternative Means of Cooling For Thermal
Powerplants Near Lake Michigan." The closed loop systems
would, however, require the use of Lake Michigan water,
but would avoid any significant flow of warmed discharges
directly to the lake.
Taking dilution as the first case, we start
with a designed circulating water flow requirement of
1,500,000 gal./min. This water provides cooling to the
main turbine condensers as well as to a number of plant
auxiliary systems including those within the reactor
building itself. With the present design, the discharge
temperature at maximum licensed output on both reactors
is some 21 degrees F. above the lake ambient temperature.
In order to bring this within the rise limit of
1 degree P., we calculated the dilution required to
reduce the discharge temperature by mixing prior to discharge
to the lake. This would necessitate a flow rate of about
20 gallons of unwarmed water for each gallon of warmed
water in order to achieve the 1-degree F. limit at the
point of discharge.
We would have to use the lake waters for dilution
and this would require a colossal pumping system which
would handle a flow of some 77,500 cubic feet per second.
-------
1022
D. H. Williams
This is equivalent to pumping the average flow of the entire
Ohio River at its mid-point. Pumps with high flow
capacity and low head or discharge pressure would be
needed. Commercially this type of pump is available
at capacities ranging from 150,000 to 500,000 g.p.m. If
we use a typical pump rated at 300,000 g.p.m, and 20-ft.
head, we would need 100 such pumps with a total installed
power requirement of approximately 180 MW. This would
represent a consumption of approximately 8 percent of the
total plant electrical output to the customer. The cost
of the pumps alone without motors or structure would
exceed $15 million.
It would require 40 pipes 16 feet in diameter
to bring this water into the dilution facility. This
facility would be extremely complex because of the absolute
necessity of mixing to achieve a uniform 1-degree P.
discharge limit. The total installed cost of such a facility
would be in the order of $230 million. As engineers and
designers, we feel that this dilution scheme would be a
totally impractical solution to meet the 1-degree P.
condition.
With respect to a closed cooling loop design,
one alternate would be the wet type hyperbolic or natural
draft cooling tower as previously mentioned. At a
-------
1023
D. H. Williams
minimum, we calculate that a three-tower structure would
be required to serve the two-unit plant. These towers
would each handle approximately 500,000 gallons per minute,
The dimensions of these towers would be 400 feet at base
diameter and 500 feet in height or the same physical size
as the tower previously mentioned.
Since the design of the plant is complete and
construction is quite far along, we would be forced to
maintain the same condenser flow rates and we, therefore,
would have to operate the two units at higher condenser
back-pressures. Based on a cooling tower performance
approach temperature of 18 degrees P., the summer cold
water temperature would average approximately 90 degrees
or some 14 degrees P. above the maximum expected lake
temperature. At these water temperatures, the expected
condenser back-pressure would increase from 2.9 inches of
mercury to *l.3 inches causing a load curtailment of
approximately *JO MW per unit or some 80 MW for the total
plant.
The natural draft cooling tower requires an
unrestricted air flow around its base. Three cooling
towers of the size Indicated would require a minimum of
30 acres of flat, cleared land. This would necessitate
the destruction of a sizeable portion of the sand dune
-------
1024
D. H. Williams
area. A second pumping system in addition to the
present designed condenser circulating water pump system
would be mandatory to transport the cooling water from the
condenser discharge to the cooling towers. The cooling
towers would have to be at a higher elevation than the
plant in order to gravity flow the cooled water back to the
circulating water pump suction, thus making the towers
even more conspicuous.
Since the reactor safeguard systems have been
completely designed for expected lake temperatures and
reviewed by the Atomic Energy Commission, an increase in
cooling tower temperature levels would require major
equipment modifications and resubmittal of the safeguard
design to the AEG.
Based on today's labor rates, a rough estimate
of the cooling tower costs would be $18 million. This
excludes excavation, pumps, structures and other piping
costs and overheads. Labor constitutes at least 40 percent
of the total cost of cooling towers. With a continuation
of current construction wage escalation, the cost of these
towers would exceed $20 million at the time of installation.
The pumping and transport systems through the cooling
towers and back to the plant is estimated to cost In excess
of $12 million.
-------
1025
D. H. Williams
Cooling towers also involve the problem of
handling wastewater discharge such as cooling water
blowdown to control dissolved solids. Based upon limits
adopted by some State agencies, it is assumed that the
dissolved solids concentrations would exceed the effluent
limits allowable for discharge directly back to the lake
and that this blowdown water would exceed the 1-degree F.
limit. Therefore, a large soak pond or land disposal
system would have to be installed in order to avoid
discharge of water directly to the lake.
Another closed system would be a large cooling
pond. To build such a pond would require the acquisition
of a suitable block of land for a lake having a
minimum size of 5»000 acres. We feel that this system
would constitute a totally unacceptable use of the land
resources of this area.
Dry cooling towers have been discussed as a
possible method of avoiding warm-water discharges. We
feel that for the Cook Plant they are totally out of the
question because of the limited experience with such
cooling facilities. With a dry cooling tower, the
cold water cooling temperatures are substantially
higher than ambient air temperature. During the summer
months this would create a condenser pressure of 8 inches
-------
1026
D. H. Williams
to 14 inches of mercury. Turbines which have been designed
and are being manufactured for the Donald C» Cook Plant
cannot operate much above 4 inches of absolute mercury
without overheating and causing distortion of the casings,
As far as the cost of any dry cooling system, there are
no reliable figures which would be applicable because the
largest such system in service in the world today is for
a unit of approximately 150 megawatts at Ibbenburen,
Germany, There must be more development on smaller con-
ventional plants before a dry cooling system can be applied
to nuclear plants of the size of the Cook Station,
If we are required to meet the 1 degree Fahrenheit
rise limitation, it would mean scrapping a major portion
of the equipment and design. This would result in a sub-
stantial delay of a year or more in the production of over
2 million kilowatts of electric power that is sorely needed
to meet the normal .requirements of the people in this part
of the country. More important is the fact that the present
design of the Cook Nuclear Plant, to the best of our
knowledge (and this knowledge is based on extensive tech-
nical research) will not be harmful to Lake Michigan.
Furthermore, it is our firm belief that the possible
alternatives would be extremely objectionable to the
public, and not in their best interests because of the
-------
1027
D. H. Williams
unnecessary waste of human and financial resources.
We would like to comment briefly on the document
from the Department of Interior issued on September 1#, 1970,
entitled "The Feasibility of Alternative Means of Cooling
for Thermal Power Plants Near Lake Michigan," We believe
it should be clearly understood that the economic evalua-
tion contained in this "white paper** applies to the con-
struction of wholly new plants on ideal new sites and that
the cost and efficiency figures in this report do not
apply to the backfitting of cooling equipment onto existing
installations or those under construction.
The feasibility of dry cooling towers has stirred
the interest of the general public since all the heat
would be discharged directly to the air without any effect
on the surrounding waters. It is well known that both
mechanical draft and natural draft evaporative cooling
towers have been built for large units. Dry towers have
been built, but the largest size in service today, as
stated before, is only 150 megawatts0 The turbines for
the dry tower installation must be designed to operate
with back pressures as high as 14 inch mercury on days
when the ambient temperature is high* In addition, there
would be other cooling design problems, such as lubricating
oil, and the reactor and nuclear steam supply components
-------
1028
D. H. Williams
which require a cooling temperature lower than that which
can be achieved with the dry type tower. By this we are
not saying that it is technically impossible to design a
nuclear plant with a dry type cooling tower for condenser
cooling. We are saying, however, that it is virtually
impossible to apply the dry tower to an existing plant or
one under construction. We feel that a great deal of work
needs to be done by the turbine manufacturers before units
of the 1,000 megawatt and higher size can be produced for
dry cooling tower application.
There is very little doubt that the electric
utility growth will continue to double every 10 years to
meet further load demands. If we continue to do things
exactly as we are doing them today without any change,
then it could be said that the potential heat release
input to Lake Michigan from power generating stations
may increase more than tenfold in the next 30 years or
by the year 2000. This country, let alone the utility
industry, cannot possibly afford to continue to generate
power exactly as we are today. If we go back 30 years
in time to 1940 and look at the means of generating power
that existed at that point in time, we would find that
the largest single generator size was approximately 50
to 60 megawatts with a design unit efficiency of 10,700
-------
1029
D. H. Williams
B.toU.'s per kilowatt hour. This is to be compared with
the most efficient plants being designed today units
in the size range of 1,000 to 1,300 megawatts with heat
rates of 8,300 B.t.u.fs per kilwatt hour. If we step
aside and look at the ingenuity that has gone into the
design, construction, and operation of the vast electrical
energy system which supports the economic growth and
strength of the country today, then surely we can meet
the demands of the future with respect to heat release
problems and cycle efficiencies.
In conclusion, the overall public interest
requires that there be a balanced consideration of
environmental effects against other considerations
affecting the public interest, including specifically
the public interest in assuring adequate electric power
to meet the needs of the next several years.
Any material interference with the operations
or the imposition of any substantial delay in the bringing
into being of plants in operation, under construction, or
now on the planning boards to meet loads in the next
several years will materially impair the ability to assure
adequate electric power for such years.
Accordingly, it is unsound and improper to
attempt to establish proposed solutions for plants in
-------
1030
D. H. Williams
existence, under construction, and on the planning boards
on the basis of assuming the consequences of an aggregate
of heat which might be discharged in the year 2000 on
the assumption that future plants will be built on the lake
without limitation.
The public interest requires the use of sound
judgment in balancing the effect on the environment of
warm water discharges against other alternatives which
frequently may have greater adverse effects on the
environment <>
In many areas along the shore of Lake Michigan,
the use of enormous cooling towers or large ponds would,
as a matter of aesthetics and optimum land-use, have a
much more detrimental effect on the environment than
the warm water discharge associated with the properly
designed heat discharge system.
-------
1031
D. H« Williams
MR. STEIN: Thank you, Mr. Williams. I don't
know about those slides. They are kind of marginal. I
expect at least the first few are not going to come out
with any justice to black and white.
MR. DOWD: We would propose to submit several
copies of those in color also as exhibits if this is
agreeable.
MR. STEIN: All right. I think that would be
better. Those pastels in the first just would come out
a blur, I am sure.
MR. DOWD: We will do that.
MR. STEIN: They will be received as part of the
record without objection. (See Pp. 1031-a through 1031-1)
Are there any comments?
MR. CURRIE: Yes, Mr. Chairman.
I take it, Mr. Williams, that your objections
regarding alternative cooling systems in the vicinity of
the Cook Plant are not based on the basis of disagreement
with the FWQA paper as to the technical and economic
feasibility of cooling towers, for example, under other
conditions, that is, in other geographical locations and
as to plants which are not already under construction, is
that right?
MR. WILLIAMS: If I understand you correctly, yes.
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IJJx-J.
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-------
1032
D. H. Williams
MR. CURRIE: You are referring, then, to the fact
that the site chosen is somewhat unfavorable in your view
for such devices as cooling towers?
MR. WILLIAMS: That is correct.
MR. CURRIE: Now, who chose the site? Did any
State or Federal agency choose that site?
MR. WILLIAMS: I would like to call on some of
my colleagues to help answer that.
MR. CURRIE: Well, I don't think I really expected
an answer.
MR. STEIN: I think when you ask a question
they should be given the privilege of answering if they
want to.
MR. KOPPER: I am Mr. Kopper. I think we have
to look the history over of who is responsible over the
years for selecting powerplant sites and building power-
plant systems. The utilities have been assigned this
responsibility, and I think we performed under this
responsibility all of these years of selecting the sites
in light of the total problem.
The total problem involves fuel supply, adequate
water for cooling, finding the access routes for trans-
mission lines to take the power from the plant and deliver
it to the load center. This is a total composite factor
-------
1033
D. H. Williams
here. There is also a very strong factor which we have
been under tremendous pressure on over the years, and that
is to develop economics in all facets of our business to
provide the public with low cost power.and, therefore, in
selecting a site, this is another important factor. So
I think you have to take all these factors into considera-
tion, and we have been given that responsibility under law
to build a system we accept a franchise and operate
under franchise to build a system and provide power to
the public in the area. Does that help the situation?
MR. CURRIE: I think the question really is: Why
was not the possibility that pollution control equipment
might be required also taken into account in selecting
this site and also in beginning construction of this
plant. I take it Mr. Williams' additional point is that
dry cooling towers would be particularly difficult here
because of the backfitting problem, because the plant
has been constructed so far in such a way as to make
backfitting very difficult.
I take it that decision the decision to ignore
the possibility that pollution control equipment might be
required, the decision to build it in such a way as to make
backfitting difficult was also not a decision dictated
by a State or Federal agency but rather was your own
-------
1034
D. H. Williams
decision.
MR, KOPPER: Yes, sir, it was our own decision,
but this decision was made on the basis that there would
be no pollution that would be harmful to the public and
to the lake by building the plant on this site.
MR. WILLIAMS: I would also like to comment
there, sir. I tried to give the impression that it would
be impossible to backfit with a dry tower on this
installation.
MR. STEIN: Are there any other comments or
questions?
By the way, I think you have given some valuable
information on this analysis. Again, I think we are
beginning to get a pattern, as I see it, of these
industries' position on this: 1) that the heat discharged
into Lake Michigan is creating no damage; 2) that the
heat that enters the water is primarily deflected into
the air and that if any damage results or all the heat
is not deflected, heat damage is temporary and not
cumulative; 3) that we shouldn't impose positions today
which may affect loads going into the lake in the year
2000; and 4) that whatever we do, the regulatory agencies
should not deal, as we have at other plants, with
existing plants, but exempt existing plants, those under
construction, and those on the planning boards; but
if they are going to come up with a future operation,
-------
1035
D. H. Williams
that should apply to only plants which are not even
on the planning boards yet. I get that as a theme through
all of the presentations.
I think this is a what I consider reason-
able summary so far of the things that I find from the
power companies.
Will you come up, Mr. Duraelle?
MR. DUMELLE: My name is Jacob Dumelle, a member
of the Illinois Pollution Control Board.
Mr. Williams, you mentioned that the American
Electric Power Company has seven very large cooling towers
built and one under design. I wonder if you would
comment on the experience of the company with fog and ice
conditions from these existing cooling towers, because
that is one of the arguments which has been raised against
them. I realize this varies by site possibly, but of
the sites where they are in operation, what has been the
experience?
MR. WILLIAMS: I would be glad to comment on
that, sir: In addition to the natural draft towers which
I showed on the slides, we also have the 6?5 megawatt
plant on the mechanical draft dry towers. Since the
installation of these towers, we have been conducting
primarily in the winter months surveys of exactly what
plume configurations exist from the discharge of these
-------
1036
D0 H. Williams
towers under various atmospheric conditions.
With respect to fog, as far as ground level fog
or icing conditions, we have had excellent experience in
that there have been no reported problems from these
towers. However, this is a substantial visible plume
which extends upwards of 4,000, 5,000 feet in the air
that can be seen from quite some distances on cold
winter days.
MR. DUMELLE: What about snow fallout or icing
conditions?
MR. WILLIAMS: We have tried to observe this very
closely, and we have had no adverse conditions.
MR. DUMELLE: How do you design these plants
and what do you do during periods of high humidity when
the wet bulb temperature is very close to the dry bulb
temperature? Do you reduce the plant output or just what?
MR. WILLIAMS: Mother nature does that for us.
The back pressure, of course, increases and the turbine
or the capability of the turbine generating power reduces
and we keep the same input to the turbine and the generator
produces accordingly as the back pressure goes up»
MR8 STEIN: Are there any other questions from
the audience?
If not, thank you very much,.
-------
1037
D. H. Williams
MR. CURRIE: Mr. Chairman, may I ask one more?
MR. STEIN: Yes.
MR. CURRIE: What do you do about blowdown in
your cooling towers?
MR. WILLIAMS: The plants we are designing today
and have in existence utilizing cooling towers, we have
designed what we call a wastewater scheme whereby we take
backup water into the cooling tower basin. We then with-
draw water from that basin to handle our bottom ash system
which automatically acts as a means of blowing down.
This water is then taken to a bottom ash pond where we
also pump any other plant's wastewaters.
We take the water from this pond back to the
plant and utilize it for our fly ash handling system, and
we take all of the combined wastes which would include
the cooling tower blowdown, mix them together, and put
them in our fly ash pond, which is a long-time settling
area. An effluent which takes a week's time for
the solids to drop out and is a combined mixture of
all these wastes may require treatment before it
evaporates to the atmosphere or overflows back to a local
river or stream.
MR. CURRIE: So that you combine this problem of
blowdown with the other water pollution problems created
-------
103S
D. H. Williams
by a fossil plant, which are not the same as those of
a nuclear plant, is that right?
What would you do if you had a nuclear plant
with blowdown?
MR, WILLIAMS; Again, with the State restrictions
on allowable effluent standards, as I stated in the paper,
in all probability we would try to devise some kind of
evaporative or soak pond or some type of
facility.
MR. STEIN: Are there any other comments or
questions?
Thank you very much.
MR. WILLIAMS: Yes, sir.
MR. PETERSEN: I have one question.
My name is 0. K. Petersen, and I would like to
know if you have made any studies of the comparable climate
conditions between .existing plants and the site of the
proposed Cook Plant and if you have, do you have any con-
clusions as to the difference in climate or likeness of
climate as the case may be between operations which might
affect the operations of the cooling tower at the Cook
Plant site.
MR. WILLIAMS: I will try to answer that in that
if you consider the Cook site and under the supposition
-------
1039
D. H. Williams
that we were required to come in with an alternate cooling
facility if we looked at all of the alternatives I
mentioned that land is totally out of the question in that
area as far as the cooling ponds. Dry towers are an impossi-
bility because of the turbine problems which I mentioned
with existing turbines that we have.
This leaves the alternative of mechanical draft
or natural draft cooling towers. Mechanical drafts would
definitely be ruled out based on our experience with the
number required. The interstate highway which was near a
powerplant with a low level of vapor discharge that you
get there from the mechanical towers, I feel, would defi-
nitely be a problem with relation to the highway.
With the natural draft tower, with the plume
discharge plus its heat 500 feet in the air this
is not a problem,
So far as meteorological studies, that would
have to be my response, as to the only practical approach
with regard to the cooling plant condition.
I don't know if I have answered what you really
were getting at.
MR. PETERSEN: Very well, except for one small
area, and that is: Would there be any conditions of
freezing within the cooling tower due to possible lower
-------
1040
D. H. Williams
temperatures and high winds coming in off the lake during
the winter?
MR. WILLIAMS: Never having operated a tower on
the lake and I know the wind blows quite hard I think
this would be a design problem.
We have been able to overcome this problem at
other installations where we have nowhere near the pro-
longed wind and the cold air. I think it would be a problem,
But I think it is technically possible to overcome it.
MR. STEIN: With that, let me just ask one
last question. I don't expect you to speak for all of
the industries, but maybe you can for the industry around
here. You do indicate that you have selected a site and
you have put something on the planning boards where if
something is asked or required, you may then consider
a device to protect the environment. You say that we
are not going to get the counter argument that the site
is such that the meteorological conditions are bad and
it can't be done, that it is near a road, that it is near
an airport or near a congested area because you are
picking these sites as we go along, or as your industry
develops.
Now, when can we expect or is there going to
come a time when the power industry picks the site and
-------
1041
D. H. Williams
can say it has taken these conditions into account just
in case people responsible for the environment might
ask, and therefore these are not going to be interposed
as objections anymore?
MR. WILLIAMS: I would rather not speak for the
industry, but I think generally the approach is that in
the selection of any site today and I think we have to
start talking from today these are definitely to be
taken into consideration as to what the future might
bring as far as requirements on this plant, where we can
do these things with the technical tools we have at that
time.
MR. STEIN: All right.
Are there any other comments or questions?
Thank you very much.
I think with all the things we have to do, there
is just one way to do it. We will go until just about
12:00 o'clock and then recess until 1:30 for lunch.
We will adhere to that schedule because a deviation,
again I think, might give certain problems for this
evening especially and would slow things up.
Would you continue, sir?
MR. DOWD: Our final speaker is Dr. John C.
Ayers of the University of Michigan,
-------
1042
J, C. Ayers
STATEMENT OF JOHN C. AYERS, PROFESSOR
OF OCEANOGRAPHY, UNIVERSITY OF MICHIGAN,
ANN ARBOR, MICHIGAN
DR. AYERS: Mr. Chairman, conferees, ladies and
gentlemen. I am John C. Ayers. I am a Professor of
Oceanography at the University of Michigan, I hold a
Bachelor's Degree in chemistry and Master's and Doctoral
degrees in zoology. I received 5 years of on-the-job train-
ing in oceanography at the Woods Hole Oceanographic Institu-
tion in Woods Hole, Massachusetts.
I have been engaged in research on the Great Lakes
since 1954. I am presently in my eleventh year of research
on Lake Michigan, and in my seventh year of research on
those types of inshore phenomena that apply to electrical
generating stations.
My inshore studies have included the warm-water
discharges from electrical generating stations and the
naturally-warmed discharges from rivers entering into Lake
Michigan.
I have personally investigated the plumes of warmed
discharge water from generating plants at Big Rock Point
near Charlevoix, Michigan; at Muskegon, Michigan; at Port
-------
1043
J. C, Ayers
Sheldon, Michigan; at Michigan City, Indiana; at Burns
Ditch, Indiana; at Waukegan, Illinois; and at Port
Washington, Wisconsin. I have studied the results of surveys
by others of generating plant discharges in Lakes Erie and
Huron as well as Lake Michigan. I have studied the results
of surveys by others of generating plant plumes on both the
east and west coasts and in other parts of the country.
I have personally studied the discharges of the
Milwaukee and Grand Rivers into Lake Michigan.
(Dr. Ayers' qualifications and publications appear
on Pp. 1044-1046.)
Let me get into the record at this point that I
am a conservationist, that I know the literature of labora-
tory tests which show heat to produce undesirable effects
on organisms or environmental parameters, and that I am
engaged in studies of releases of real waste heat into the
real environment because I fear the potential effects of
this heat as much as do the concerned conservationists who
appear in such numbers at every public hearing.
Because I am a conservationist, my work is
addressed to the very same questions that the conservationists
raise. In what I am about to say, I speak only to these
problems in connection with real heat rejection to the real
Great Lakes, I have not personally studied them in other
-------
3-044
JOHN C. AYERS Professor of Oceanography, Department of Meteorology and
Oceanography; Research Oceanographer, Great Lakes Research
Division, University of Michigan
Born: Marcellus, Michigan, October 4, 1912.
Education;
Kalanazoo College AB in Chemistry, 1934
Kansas State College MS in Zoology, 1936
Duke University PhD in Zoology. 1939
Positions Held:
Instructor in Biology, Univ. of South Carolina, 1939-41.
Adjunct Prof, of Biology, " " " 1941-43.
Instructor, Physics & theory of flight, U. S. Naval Flight Prep. School,
1943-44.
Research Associate, Woods Hole Oceanographic Institution, 1944-49.
Asst. Prof, of Oceanography, Cornell University, 1949-52; Assoc. Prof.
1952-56,
Assoc. Prof, of Zoology, Univ. of Michigan, 1956-58; Prof., 1958-63'.
Research Director, Great Lakes Research Institute, Univ. of Michigan,
1956-60.
Research Oceanographer, Great Lakes Research Division, Univ. of Michigan,
I960-.
Prof, of Oceanography, University of Michigan, 1963-.
Scientific Societies;
American Society of Limnology and Oceanography
Vice President 1962-63; President 1963-64.
Chairman, Comm. on Education & Recruitment 1961-.
Co-chairman, Program Committee, 1964-.
American Association for the Advancement of Science
Sigma Xi Honorary Society ' '
International Association for Great Lakes Research
Professional Activities;
Member of Corporation, Marine Biological Laboratory, Woods Hole, Massa-
chusetts, 1953-.
Official collaborator, Marsh Ecology Research, N. Y. State Dept. of Con-
servation. 1958.
General Chairman, Third Conference on Great Lakes Research. 1959.
. Consultant to Power Reactor Development Company, 1958-1961; Canadian-
American Committee on Great Lakes Water Pollution, 1959; Upper
Peninsula Office, Michigan Dept. of Health, 1959; Huron-Clinton
Metropolitan Park Commission, 1960; Consumers Power Co., 1961;
American Electric Power Service Corporation, 1966-; Oxford Paper Co.,
1967-68; Toledo Edison Co., 1968-; Great Lakes Basin Commission,
1968-.
Principal Publications;
Relationship of habitat to oxygen consumption by certain estuarine crabs.
Ecology, 19: 523-527, 1938.
-------
1045
Action of antifouling paints. VI. Effect of nontoxic pigments on the
performance of antifouling paints. (With B. H. Ketchum) Ind. &
Eng. Chemistry, 40, p. 2124, 1948.
The oceanography of New York Bight. (With B. H. Ketchum and A. C. Red-
field.) Pap. in Phys. Oceanog. & Meteor., 12(1) 46 pp., 1951.
The principal fouling organisms. Chapter in Marine Fouling and Its Pre-
vention. (With H. J. Turner.) pp. 118-164. U. S. Naval Institute,
Annapolis, Md., 1952.
A method for rendering wood resistant to marine borers. Bull. Mar. Sci.
Gulf & Caribbean, 3(4): 297-304, 1954.
Population dynamics of the marine clam, Mya arenaria. Limnol. Oceanogr.,
1:26-34, 1956.
Currents and water masses of Lake Huron. (With D. V. Anderson, D. C.
Chandler, and G. H. Lauff.) Pub. No. 1, Great Lakes Research
Institute, Univ. Michigan, 101 pp. 47 figs., 12 tables, 1956.'
A dynamic height method for the determination of currents in deep lakes.
Limnol. Oceanogr., 1:150-161, 1956.
*
Simplified computations for the dynamic height method of current deter-
mination in lakes. (With R. W. Bachmann) Limnol. Oceanogr., 2:155-157,
1957.
Currents and water masses of Lake Michigan. (With D. C. Chandler, G. H.
Lauff, C. F. Powers, and E..B. Henson.) Pub. No. 3, Great Lakes
Research Institute, Univ. Michigan, 169 pp., 52 figs., 16 tables,
1958.
Th'e hydrography of Barnstable Harbor, Massachusetts. Limnol. Oceanogr.,
4:448-462, 1959. :
Sources of hydrographic and meteorological data on the Great Lakes. (With
C. F. Powers and a. L. Jones.) U. S. Fish & Wildlife Serv. Spec.
Sci. Rept.Fisheries No. 314, 183 pp., 1959.
Water transport studies in the Straits of Mackinac region of Lake Huron.
(With C. F. Powers.) Limnol. Oceanogr., 5:81-85, 1960.
The bottom sediments of the Straits of Mackinac region. (With G. H.
Lauff, E. B. Henson, D. C. Chandler, and C. F. Powers.) Pub. No. 6
Great Lake<= Research Division, Univ. Michigan, 1961.
A portable photocell fluorometer for dilution measurements in natural
waters. (With V. E. Noble.) Limnol. Oceanogr., 6:457-461, 1961.
Great Lakes waters, their circulation, and physical and chemical charc-
teristics. P. 71-88 in "Great Lakes Basin," Pub. No. 7, American
Association for the Advancement of Science, Washington, D. C.
-------
1046
Hydrology of Lakes and Swamps. (With James H. Zumberge.) Section 23 (33 p.)
in Handbook of Applied Hydrology. Ven Te Chow, Ed. McGraw-Hill,
N. Y. 196A.
The climatology of Lake Michigan. Univ. Michigan, Great Lakes Research
Division Pub. No. 12, 1965. 73 p.
The people, the alpha and the omega. Kalamazoo College Review 24(2):
15-17, 1967.
Studies on the environment and eutrophication of Lake Michigan. (With
D. C. Chandler, Eds.) Univ. Michigan, Great Lakes Res. Div. Spec.
Rep. No. 30, 1967. 415 p.
Current patterns and lake slope. (With F. R. Bellaire.) Proc. 10th
Conf. on Great Lakes Res., p. 251-263, 1967.
-------
1047
J. C. Ayers
environments.
Since this conference bears upon the ultimate
establishment of standards for thermal inputs into Lake
Michigan, it is logical as background material to ascertain
something about the natural inputs of heat to which Lake
Michigan is accustomed and adapted.
These heat inputs are primarily 1) direct input
of heat from the sun of which there are several computations,
and 2) inputs of heat delivered to the lake by rivers which
have collected it in the shallow waters and large areas of
their watersheds. I speak here to the latter of these two
items
The Grand River, which opens to the lake at Grand
Haven, Michigan, is situated on the east side of Lake Mich-
igan to which the prevailing southwest winds push warmed
surface water from the lake. Heat input from the Grand
River, then, is an injection of heat into some of the warmer
waters of the lake.
The long-term mean outflow of the Grand River is
1,500,000 gallons per minute, comparable to the discharge
of a large nuclear generating station.
Let us see how the temperatures of the Grand
River discharge compare to those of the ambient lake water
in spring, summer, and fall.
-------
104$
J. C. Ayers
... Slide No. 1 (See P. 1049) ...
Even in March the river water entering the lake
is warmer than the lake. The temperature difference
increases steadily into July, but fall cooling has begun
by August and river temperatures soon fall below those of
the lake water.
From mid-March through July the Grand River waters
reaching the lake average 7 to 12 degrees F. warmer than
the lake. It is reasonable to expect that this has been the
case during all the years since the deforestation of its
watershed.
On the west side of the lake the prevailing south-
west winds blow off from the shore and surface water is
pushed out into the lake. The west-shore rivers consequently
discharge much of the time into cold upwelled subsurface
water. The temperature differences between river water and
lake water on that side should be even larger than at the
Grand River.
It is difficult to understand the need for a
plus 1 degree F. thermal standard for the inshore waters of
Lake Michigan when for generations these waters have
received from their tributaries natural inputs of 7 to 12
degrees or more of excess temperature during the critical
spring and summer seasons.
-------
1049
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-------
1050
Je C. Ayers
Consideration of thermal standards are inspired
by very proper concern over the possibility that waste
heat will hasten the eutrophic deterioration of Lake
Michigan's waters.. Among the several sources of waste heat
are electric generating stations. They are contributors of
heat, but they are not the only contributors of heat.
Investigations of waste heat and its effects could, then,
properly begin with the waste heat of generating stations.
Our investigations of waste heat rejection to the
lake cover seven different generating stations to date,
and some of them have been visited more than once.
The nature and behavior of the plumes of warm
discharge water from these plants are fundamental matters
in determining what, if any, effects their rejected heat
has on the aquatic ecology of the lake.
Electric generating stations are attracted to
the lake shore by the large volume of cooling water that
the lake provides. The cooling water they use is drawn
from the inshore water of the lake, and the warmed water
is released back into the inshore water.
The dominant condition of water current movement
in the inshore water is that of alongshore currents being
present and moving the warmed discharge water parallel to
the shore.
-------
1051
J. C. Ayers
To illustrate the behavior of a plume of warmed
discharge water in the usual condition of its moving with
the alongshore current, we have chosen the plume of the
Waukegan, Illinois, generating station of Commonwealth
Edison as we observed it on 30 June 1969. The current this
day was definitely northward under the residual influence
of strong south wind during the previous night,
... Slide No. 2 (See P. 1052) ...
This shows the layout of our sampling stations,
and the vertical distribution of excess temperature in a
section along the lengthwise axis of the plume. In both
the station layout and the section, a line labeled HA"
indicates the beginning of ambient lake temperature, which
in this case is 55.4 degrees F. Distances indicated in
the section are distances along the axial line indicated
by dashes in the station layout at the left. Distance along
the beach is shown on the beach at the left of the station
layout. Station 1 gives the vertical distribution of excess
temperature observed just outside the end of the plant's
discharge channel as far in as the survey boat could go.
The rest of the section shows the vertical distribution of
excess temperature along the plume axis.
Along the bottom, ambient temperature was reached
at 4»250 feet along the axis from Station 1. At the water
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-------
1053
J, C. Ayers
surface ambient temperature was attained at 10,500 feet from
Station 1. Rapid loss of excess temperature is shown along
the surface of the section, where more than 4 degrees F, of
the 6 degrees F, of excess temperature was lost in the
4,250 feet along the axis to Station 11.
The tendency of the warmest water to float on cooler
water begins in the isotherm of plus 5 degrees above ambient
immediately beyond Station 1 and becomes progressively more
evident from there outward along the section until warmed
water leaves the bottom at 4»250 feet,
This 4,250 feet, along which benthic organisms
would have been exposed to excess temperature is about 0,8
mile of the 164? miles of Lake Michigan's shoreline.
Furthermore, this distance lies mostly within a wave-swept
zone, characteristic of Lake Michigan, in which benthic
organisms are scarce because wave action produces shifting
bottom and winnows away the detrital organic food materials
of the benthos,
... Slide Ho. 3 (See P. 1054) ,..
This is the first of four slides showing cross-
sections of the plume. The orientation of this section is
shown at the left by a line from shore through stations 1,
14, and 4,
Station 14 was isothermal at ambient temperature,
-------
1054
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-------
1055
J. C» Ayers
55,4 degrees F. The isotherms of excess temperature between
Stations 14 and 1 are linear interpolations which may not
be correctly placed for the actual conditions of the day,
but which do accurately depict the limited lakeward extent
of excess temperature,
... Slide No. 4 (See P. 1056) ,,.
Mr, Chairman and conferees, there is a typograph-
ical error in the last line. This should be 3t500 feet
instead of 3,300.
This is the second transect of the plume at 4»250
feet of axial length or 3»500 feet along the beach.
Here a section from shore through Stations 11, 12,
and 6 shows the plume to be floating and to have a maximum
excess temperature of a little more than 2 degrees F. All
the temperatures above ambient are in the upper 12.5 feet
of water, beneath which lies lake water of ambient tempera-
ture.
The maximum content of excess temperature in this
section is inshore of Station 11, where somewhat over 2
degrees F, of excess temperature is in contact with the
shore in only the very inshore upper 3 feet of water depth,
... Slide No. 5 (See P. 1057) ...
This is a cross-section of excess temperature
through Stations 9f 8, and 7 at 7»250 feet along the plume
-------
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1053
J. C. Ayers
axis or 6,000 feet along the beach. Ambient temperature
is present on the surface at 1,250 feet off the beach and
is present in the cross-section at 3«5 feet of depth.
Above 3«5 feet of depth and against the shore the excess
temperature barely exceeds 1 degree F. and is present in
about one foot of depth.
In the Waukegan study just presented, the rapid
diminishing of excess temperature in the surface water of
the plume has been evident.
As a means of getting at a more representative
measure of the decline in excess temperature along the
axial length of generating plant plumes, a study of the
distributions of loss of excess temperature along the axes
of the best available plume surveys has been carried out*
In this study the initial amount of excess
temperature has been that temperature observed at the mouth
of the outfall structure where the survey boat could reach.
It is emphasized that these initial excess temperatures are
not plant Delta T's but that they are the excess tempera-
tures with which the plume in the open lake commences.
The computations consist of the initial excess temperature
(IET) minus excess temperature remaining (ETR) at distance
along the plume axis.
x 10° s fi excess temperature lost
-------
1059
J, C. Ayers
Length of the plume axis has been measured along
the path (curved if necessary) of the plume to that point
in contoured plots of surface temperature where 1 degree F.
of remaining excess temperature occurred farthest away from
the source*
In some cases a contour for the extent of initial
excess temperature can be obtained, in such cases the
percent of plume length has been computed for this zero
percent loss of excess temperature. At other residuals of
excess temperature, percent of excess temperature lost
has been plotted against percent of plume length where the
isotherm in question crossed the plume axis* All computa-
tions were stopped at 1 degree F. of remaining excess
temperature because in most cases it was unclear how others
had determined the beginning of ambient temperature*
Surveys of eight plant plumes of those available
were adjudged adequate for the purposes of this study.
The primary difficulty was lack of data on the initial
excess temperature as defined above. Plant Delta T's are
common, but actual temperatures at the beginnings of
plumes in the open lake are scarce.
From the available adequate surveys the following
plot of percent loss of excess surface temperature against
percent of axial plume length has been prepared.
-------
1060
J, C, Ayers
... Slide No. 6 (See P. 1061) ...
Five of the curves of loss of excess temperature
against distance down the plume lie in a compact central
band with two curves flatter and one much more curved.
Since the data include both large and small
plants and different wind conditions, it appears to be
possible to begin an approach to a generalized expression
for loss of excess temperature in a natural plume in the
Great Lakes. Further data and refinement of the
generalized curve will be required, of course.
From the present data, it appears that 25 percent
of the excess temperature is lost at about 13 percent of
the axial plume length. Fifty percent of the excess
temperature appears to be lost by 25 to 30 percent of the
axis length along the plume. At about 60 percent of the
plume length about 75 percent of the excess temperature has
been lost.
The above considerations of loss of excess
temperature in plumes of real waste heat in the real
environment of the Great Lakes indicate rapid loss of
excess temperature from the warmest parts of the plume
with less rapid loss from the cooler parts.
I am going to depart from my text here for a
moment.
-------
1061
3«niVa3dW31 SS3DX3 JO SSO1 lN3D«3d
-------
1062
J, C, Ayers
This rapid loss of the heat takes place much
more ~ in much less time than I had previously realized.
This spring down in the plume of the Bailly Plant at Burns
Ditch, we were drafting bags of outfall water down the axis
of the plume and sampling them when they reached ambient
temperatureo In several runs, these bags varied from 2&
to 35 minutes to reach ambient temperature,
I will return to the text.
The primary thrust toward the establishment of
thermal standards is the real fear among all of us that
waste heat can be an augmenter of natural eutrophication
processes. It is, however, proper to consider other
factors in the nature of plumes that may bear upon whether
waste heat in the real environment is apt to produce the
undesirable biological effects that have been so abundantly
demonstrated in laboratory tank experiments.
It is evident that the freedom of warmed discharge
water to float upon the cooler receiving water is a condi-
tion not achieved in laboratory tank experiments where
uniform temperature throughout the tank is a condition
strived for.
It is also evident that test organisms are
confined during laboratory tank experiments. This is
another condition that does not pertain in warm-water
-------
1063
J. C. Ayers
plumes in the natural environment.
In plumes in nature the unconfined organisms
are subject to daytime light and warming as well as night-
time cooling and darkness. Being unconfined, the organisms
are free to use such powers of swimming as they possess.
If they do not swim (the phytoplankton, for example) or
if they are weakly-swimming (the zooplankton, for example)
they drift with currents from place to place and from
depth to depth and may even be transferred by mixing from
water mass to water mass. None of these conditions are
duplicated in laboratory tank experiments.
In brief, laboratory tank experiments utilize
captive organisms under artificially controlled conditions,
all of which is very different from conditions pertaining
in nature.
The very circumstances that produce real warm-
water plumes are virtually impossible to duplicate in the
laboratory. In nature massive current capable of sweeping
organisms into a plant is followed by mechanical mauling
by pumps and then by abrupt addition of heat greater than
that to which the organism is acclimatized, and these are
in turn followed by release of the organisms into the open
lake under conditions of rapidly slowing current and
rapidly cooling water. Leaving out the possibility that
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J. C. Ayers
the organisms might be subjected to fatal chlorination
during their passage through the plant, the rapid sequence
of physical changes alone would leave the organisms in a
debilitated condition and little able to respond physio-
logically to the rapidly disappearing heat of the plume.
We genuinely believe that most of the present
fear of release of waste heat to the environment stems
from knowledge of the results of laboratory experiments
without any accompanying information as to how waste heat
behaves in nature, and I would comment here.
I suggest Friday, gentlemen, or maybe it will
be Saturday, when you have the concerned conservationists
before you, that you query the sources of their knowledge,
I think you will find it is undigested results of labora-
tory studies.
Our studies of plumes of real waste heat in the
real environment, and the similar studies of others whose
data we have reviewed, do not reveal in or near real waste
heat plumes the evil effects of heat that have been so
confidently predicted from laboratory results.
We believe, as do others who have studied the
problem in the field, that the physical behavior of warmed
discharge water along with the physical conditions inherent
in the production of a discharge plume act together in a
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J. C. Ayers
manner that prevents the development of the predicted
undesirable effects of heat. Our evidence indicates that
the following circumstances prevent the development of
the feared undesirable effects of heat:
1, Warmed water is less dense than cool water
and floats on the cool water, giving off its heat directly
or indirectly to the air, with little if any heat being
actually incorporated into the aquatic environment. This
is observed.
2. Plant intakes are usually in the same source
water as the outfalls* The mere addition of heat for a
short period of time cannot change the chemical charac-
teristics of the water. This is observed.
3. The abrupt addition of heat in passage
through a plant's condensers results in a temporary super-
saturation of the plume water with oxygen. The supersatur-
ation takes the form of microbubbles clinging to particulate
matter, and the microbubbles redissolve as the water cools.
It is observed that little or no decrease in dissolved
oxygen is measured after passage through a plant.
4* Phytoplankton and zooplankton carried through
a plant circulating water do indeed constitute a breeding
stock that might respond to being in warm water by increas-
ing their reproduction and producing noxious blooms. That
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J. C. Ayers
this breeding stock does not produce noxious blooms in the
plume is observed. The reasons that blooms are not pro-
duced appear to be:
a. Mechanical mauling by pumps produces breakage
and death of some of the plankters, particularly of
zooplankton,
b. Occasional dosages of the circulating water
with chlorine kill the breeding stocks of plankters passing
through the plant at the time of dosing,
c. The abrupt addition of heat during a short-
time passage through the condensers puts some of the
plankton into a state of thermal shock from which recovery
must be made before reproduction can be carried on,
d. Immediately after thermal shock is delivered
in the condensers, the breeding stock of plankters is
delivered into the discharge plume where water initially
warm cools rapidly. Even with a breeding stock of plankters
in good physiological condition, a regime of falling
temperature is not conducive to heat-stimulated excess
reproduction,
5, Changes in benthic populations near discharge
plumes are minor, if observed at all. In a few instances
benthos may have been washed out into deeper water by the
current of the discharge water, but in general in Lake
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J, C. Ayers
Michigan the discharge of cooling water is into a natural
wave-swept inshore zone where benthos is normally scarce
or absent. Once the plume of discharge water begins to
float, it is of course not in contact with the lake bottom
and benthos are not affected by it.
6. Much is written and said about the disruption
of fish physiology and behavior (and even the ability of
fish to live) in or near plumes of warm water discharged
from generating plants*
With few exceptions the things being written or
said are extensions of laboratory experiments into open
nature where they are applied to unconfined fish.
The observations of salmon behavior in the
Columbia River are a living refutation of the criers of
fish doom. In the Columbia River salmon have lived,
migrated, and spawned in and through the Atomic Energy
Commission's reservation where the Hanford reactors are
located.
The water discharges from the Hanford reactors
are much hotter than any plume that is extant in or con-
templated for the Great Lakes, yet salmon have existed
and increased their spawning at Hanford as dams have
reduced their original spawning territory.
The Pacific Gas and Electric Company is
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J, C, Ayers
cooperating with the California Department of Fish and Game
in studies of survival of small organisms that are
deliberately passed through generating plants. To date
they have reported that opossum shrimp, small king salmon,
and small striped bass have been passed through Delta T's
of 16 degrees F, and IB degrees F. with a high rate of
survival.
There is much speculation that local desirable
species of fish will be replaced in plant plumes by coarse
fish such as carp and suckers. It is true that local carp
and suckers are attracted to the present generating plant
plumes, but in so doing they leave available a wider
ecological space for other species.
It is also true that desirable salmon and trout
species are attracted to plumes of discharge water in
spring, fall, and winter. Local fishermen in the vicinity
of existing discharge plumes will testify to this.
In final summary, we have not yet been able to
find evidence of adverse effects of generating plant
cooling water upon Great Lakes aquatic ecology. The dire
consequences of waste heat, so confidently predicted by
persons who do not go into the field, are simply not being
found by ourselves or others who seek them in real plumes
in the real environment.
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J. C, Ayers
Mr. Chairman, I would like to make one more
comment. I recall your memory to the thermal water picture
which Mr. Polcyn showed and to the fact that you were
just barely able to see the discharge of the Grand River
in that massive display of swirling water in which there
was a lot of heat, most of it apparently contributed by
the sun.
I believe also that a part of the alarm over the
discharge of waste heat is failure to realize how tremendous
nature's applications of heat are in comparison to the size
of heat from a generating plant.
Now, the outflow of the Grand is 500,000 gallons
of water a minute, which is exactly the outflow expected
for the Donald C. Cook Plant, and at the time that picture
was taken, the Grand River was in the high teens warmer
than the lake, so that its Delta T is approaching that
of the future Cook Plant. Tet, in the picture, in compar-
ison to the heat added by nature, the plume from Grand
River was so insignificant it could be barely photographed.
MR. STEIN: Thank you.
Are there any comments or questions?
MR. PURDY: Dr. Ayers, you have discussed in
detail your observations with respect to the effects of
the pollution upon the ecology of the lake, but there is
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J. C. Ayers
one other point that has not been mentioned so far in this
conference, and that is the matter of the effect of the
thermal pollution upon the ice barrier along the western
shore of Lake Michigan, We do have severe erosion problems
along this shoreline, and the ice barrier during the
wintertime acts to protect this shoreline from erosion
damage. Now, do you anticipate that there will be major
destruction of this ice barrier and an acceleration of
the shore erosion problem as a result of the thermal
pollution?
DR<> AYERS: I do not anticipate this. Last
winter we flew the lake, photographing the discharges of
all of the generating plants. In nearly every case in
every case where we still found ice, there was heavy shore
ice still on the shores right up to the edges of the dis-
charge structure.
On the west shore, there was even ice in the
shore ice in the discharge channel of the Waukegan
generating station.
MR. STEIN: Any other comments or questions?
MR. CURRIE: Yes.
MR. STEIN: Mr. Currie.
MR. CURRIE: I take it in regard to that last
question, Dr. Ayers, you didn't investigate the effects on
ice at all temperatures at all times, but only at a selected
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J, C. Ayers
time when the temperature may have been low enough to over-
come any effect which the thermal plume might have had.
Is that correct?
DR. AYERS: No, We missed the coldest part of the
winter, and we had in some parts of the lake primarily
ice floes rather than solid ice.
Earlier photographs taken last winter at Waukegan
in subzero conditions showed a very small melt hole in front
of that plant and at Big Rock we could see the melt spot,
and it was just small. Traverse City, with the submerged
discharge plume, only a very small melt spot.
In all cases, where we still had ice, where the
spring hadn't sufficiently progressed to the point where we
lost the ice, we could see evidence of heavy buildup of
shore ice.
MR. CURRIE: So you are prepared to say that this
is essentially no problem?
DR« AIERS: I am convinced in my mind that there
is no problem.
MR. CURRIE: Now, in your paper, you make a number
of biological conclusions as to the effects of the heated
water on the fish and other life in the lake, and yet it
seems to me that the studies which you describe in here are
primarily -physical studies as to the dissipation of heat
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J. C. Ayers
itself.
Where are the biological studies on which your
biological conclusions are based?
DR. AYERS: A good part of them are my own, and I
have also drawn upon the biological studies reported by
others.
MR, CURRIE: Well, I think I for one would be
helped if I could see the studies as well as your conclusions.
DR. AYERS: We have one or two sets of my reports
available and others can be mailed to you later on.
MR. CURRIE: Now, I am interested in your analogy
of the Grand River. I take it you are not suggesting that
we ought to be willing to accept throughout the entire
inshore zone of the lake the kind of biological conditions
which are found around the mouth of the Grand River and as
evidence of the kinds of conditions found there. I would
refer you to a statement made by Dr. Bartsch at the first
session of this conference with regard to both algal and
sludgeworm populations.
DR. AYERS: I am aware of the conditions at the
mouth of the Grand River. I was making the analogy of size
of flow of a plant which would be drawing relatively clean
water and putting back the same water.
MR. CURRIE: Thank you.
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1073
J. C. Ayers
MR. STEIN: Are there any other questions?
MR. MAYO: Yes, I had a couple of questions, Mr.
Chairman.
I was interested in your comment concerning a
Hanford Plant on the Columbia River. It is my understanding
that at the present time the only nuclear generating plant
on the Columbia River has cooling towers for the specific
purpose of minimizing or eliminating the input into the
river from the tower.
DRe AYERS: I certainly didn't get that informa-
tion from Nakatani's paper.
DR. TICHENOR: May I clarify a point?
MR. STEIN: Dr. Ayers, did you have another
comment ?
DR0 AYERS: No.
DR. TICHENOR: My name is Bruce Tichenor. I am
from the Corvallis Laboratory of the FWQA.
I would like just to clarify the point that there
is a nuclear reactor at Hanford which in addition to pro-
ducing plutoniura also produces electric power. This
reactor was not designed for the production of power, but
they are using the waste heat from the reactor to produce
power. However, the first commercial nuclear powerplants
constructed by a utility the Portland General Electric
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1074
J. C. Ayers
Company is in the final planning stages at the Trojan
site, near Portland or on the Columbia River, and they do
plan to use cooling towers.
MR. STEIN: Well, in order to round this out,
I think the facts are that Washington and Oregon have
essentially adopted the no-temperature rise for power-
plants in both States in their water quality standards
now.
MR. MAYO: I get the impression, Dr. Ayers, that
you differ somewhat from Dr. Raney in terms of the
opportunity for either mortality or damage or mauling of
organisms as they pass through the condenser stage. I got
the impression, I think, from Dr. Raney yesterday that
there was a pretty rosy sort of a picture that things
slid through and came out without any significant damage.
I get the impression from your observations that there
could be a. rather substantial amount of damage.
DR. ATERS: I don't think it is a substantial
or significant damage, but we frequently find 20 percent
of the zooplankters are broken.
MR. STEIN: Well, I have just one real general
question here, Dr. Ayers. You heard the first paper that
alluded to this combination of factors that I talked about
I believe, yesterday at least two of them that is,
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1075
J. C. Ayers
when you get the water in, you have this bruising and
mauling, and occasional shots of chlorine, which I under-
stand doesn't do the organisms any good.
DR. AYERS: No.
MR. STEIN: Then, aside from the heat, you have
the combination of the heat and the question that
Mr. Purdy talked about of the velocity of the water,
whatever temperature it is, as well as the fact you
are taking in a lot of water and displacing it.
Now, as a conservationist, what would your
recommendation to this panel be? Do you think we should
go along with this once-through cooling method, which is
not to cool the water but to cool the condensers from the
plant and not beneficial to the water? As far as I am
concerned, I have heard no one here from the power
companies propose a water-cooling device just to cool
the water.
As a conservationist, do you propose that we
go along with this as a future approach to protect Lake
Michigan, then just wait and see if we have any trouble
later? Or should we do something to possibly restrict
it? I think your advice on this would be very useful.
DR. ATERS: As a conservationist, and after the
years that I have put in studying the matter, it seems to me
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1076
J. C. Ayers
a practical solution would be to let the present building
plans come through* We need not only the experience on this,
we need to actually find out if we can find any damage
there. All of the evidence that I can lay hands on today
and mine seems to match other people's is that we are not
finding the evil effects, and that very likely once-through
cooling even on a bigger scale, given judicious siting,
no overlap of spawning streams, and several other obvious
things, I believe that our present evidence indicates that
we could try these three, four, or five big plants, get
some real big plant knowledge and they have all agreed to
modify if we find anything,
MR. STEIN: Well, I am not sure they have the site.
This is the point I am getting at, and I would like to
explore this with you. If you do this now and we have
heard testimony that once anything is in the planning stage,
don't fool with it now, obviously, no industry, including
the power industry, can stop tomorrow. They are going to
plan} they are going to go forward with this operation. If
we adopt that, how far down the road are we committed if we
decide to make a modification . If we are confronted
with the notion that once they have selected the site
and I know you modified your statement with judicious site
selection - but once they have selected the site and they
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1077
J. C. Ayers
have started the plant, and then the notion is this can't
be changed, as we have heard, where does this leave us?
I am trying to work out with you an approach or get a
recommendation from you on how we are going to protect
the lake. I recognize your scientific concern. But as an
operating agency, we have to make the judgment* Hopefully
industry will agree with us on how we proceed. I am not
sure I think I understand you correctly from the
scientific point of view, you would like it if we could
freeze everything, and you could check this out in actual
conditions in the lake. Now, you can come up with a judg-
ment, but the world has to move. We can't freeze, so how
do we move? How would you suggest the conferees move from
here?
DR. ATERS: I would suggest the setting of an
interim set of standards such that the building plants could
live with for 5 to 10 years, and use for this the experience
and guidance of the State people who not only know the
problems locally, who have to do the enforcement, who know
what is practical for them. If these could be a compromise
interim thing, that would be the best I could suggest.
MR. STEIN: Thank you, sir.
Are there any other comments or questions?
MR. PDRDY: A comment, Mr, Stein, with respect to
your statement, and as a State in which two of the large
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J, C, Ayers
nuclear facilities are now being constructed, I don't believe
that we are ready to accept the fact that the existing
facilities cannot be modified should an injury result. If
the studies that are under way show an injury, we feel that
these necessary modifications must be made.
Now, I hope that I am interpreting the statements
of the industry correctly that if you had to shut the
facility down immediately and could not operate it until
the modifications had been made, that then this would cause
a serious interruption in the plant.
From the standpoint of the statement of American
Electric Power this morning, I do not interpret this that
they cannot build a wet cooling tower, that if a wet cooling
tower is built, there will be certain other undesirable
side effects from this, from the standpoint of aesthetics
in that particular area, but that it can be put in at a
cost and that, if necessary, it will be put in, and this
is the position that we take on this,
MR. STEIN: Well, I hope that that is a possible
position. Again, having been through some of these, Mr,
Purdy, when you talk about an alternative in this business,
shutting down the plant, I think you are going to find in
the face of it, it isn't a very realistic alternative,
in view of the power needs we have now.
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1079
J. C. Ayers
Now, I just put this out without saying that
anything is needed. But the question, again, that I
think has to be determined is are you going to have, say,
either a closed loop system, wet cooling towers, dry cooling
towers, lagoons, what-have-you, and presumably you are going
to have to consider that the site is available for these
contingencies, and you are going to have to be prepared to
go with that? You are not going to be blocked because
of congestion, highways, drift, meteorological conditions,
roads, or airports?
Now, the point is, I think, if we adopt what I
understand your suggestion to be that we are not pre-
cluded by the very physical and economical conditions and
the need for power in exercising options if you feel these
options are important.
MR. PURDY: That is correct, and in addition for
those plants that are now under construction, we are
requiring that the alternatives now be selected, so that
if they are necessary, there will be no lag in the design.
MR. STEIN: Yes, for some of the plants here
the companies may want to answer this later. In the
testimony we have heard concerning the existing Zion
plant, for example, we already have heard that the
company feels that none of these remedial facilities are
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1060
J. C. Ayers
feasible on the site they have selected. In other words,
the options already are stopped. Possibly your only alterna-
tive would be to shut the plant down, and the reason
those plants were built was the crying need for power,
and this would ruin the whole ball game if we did that.
Now, this is the situation, I think, and we
all have to work with it that the conferees confine
themselves to that. I can appreciate Dr. Raney's approaches
and doubts, but I know he approaches this with scientific
inquiry.
But if remedial facilities are called for we must
be able to put them in and not just block all our avenues.
DR. AYERS; If damage is proven, we will need
corrective measures.
MR. DUMELLE: I have two questions, Dr. Ayers.
On your June 30, 1969, study of Waukegan, you measured the
ambient temperature and gave it as 55.4 degrees Fahrenheit,
and I recall that earlier in the conference some of the
people testifying stated that it was very difficult to
measure the ambient temperature of the lake because of local
hotspots or coldspots, and I wondered if you could comment
on how precise a measure is that ambient temperature that
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1031
J, C. Ayers
you recorded, or any other enforcement type measurement.
DR. AYERS: The determination of ambient can
really drive you crazy. I have some surveys which I can
only partly use because I cannot determine ambient.
In my survey of Waukegan, I caught the area in a
very uniform condition, where at an intake south of the
breakwaters, the intake temperature was 55.4» and that
I took as ambient, and I found it all of the way around the
edges of the plume. I wanted to look at what was happening
to the added heat, so for this type of thing I took the
intake temperature«
MR. DUMELLE: What would be a range of precision,
within 3 degrees or within 1 degree, or within 5> on
determining ambient temperature?
DR. AYERS: In this case, I was able to get 1.
Usually I have to be satisfied with 2.
MR. DUMELLE: Two degrees?
DR. AYERS: Sometimes even 3.
MR. DUMELLE: Or 3. Thank you.
The second question is: I would be very much
interested in whether you fully agree or disagree or any-
thing in between with the Federal thesis of the inshore
waters acting in effect as a separate part of the lake,
and comprising only 4 percent of the volume, and I think
-------
1082
J, C. Ayers
that is a very important part of the Federal case.
DR0 AYERS: I am afraid that I don't agree very
much with their thesis* As I see the inshore bar and have
seen it for several years, Pritchard's computations of shear
mixing along the bar are evident. They were even evident
in the slide those great swirls on the outside. So, in
general, I can accept rather little of their conclusions0
MR. DUMELLE: For the interest of the conferees,
I have taken Dr. Pritchard's interchange figure, 1,430,000
c.f.s., as passing through this bar or barrier. If you
relate that to the 47«6 cubic miles contained in inshore
waters you get a turnover rate of 43 days. In other words,
every 43 days the inshore waters are changed.
Now, that to me is a significantly long period,
and would indicate, as I would see it, that this is acting
as a separate body of water. If you are only changing
2-1/2 percent of the water every day, reciprocal of 43
days, it seems to me you are dealing essentially with
the same bulk of water.
DR. AYERS: I think, in countercomment, that it
is equally important that our measurements of total
dissolved solids do not indicate drastic rises in Delta
T's during the time when the thermal water is present.
MR. STEIN: I think possibly, gentlemen, what we
-------
J. C, Ayers
have just heard here illustrates the problem that we have.
Of course, Dr. Pritchard has left, which possibly is
unfortunate. But as I understood him, he dealt with just
heat. He said there was no evidence of damage and as a
matter of fact in his opinion heat might be good for the
lake. That might lead to the conclusion we should
encourage discharges.
You have found no damage, in a sense, and you
have a latency attitude with an interim kind of proposal.
Mr. Dumelle evidently thinks there is pretty good
evidence of damage now, but I think you might adduce
from that that we might have some restrictions at the
present time.
Mow, I think, given the same body of evidence,
and, I am sure, very able scientific people have this spec-
trum of use again you have to recognize that the
panel, in dealing with the lake, is going to have to
exercise reasonable prudence and caution, because that
lake really is not a thing we can toy with as an experimental
body of water to find out what happens. We must be reason-
ably sure it is safe in dealing with it.
Mr. Barber.
MR. BARBSR: My name is Yates Barber. I am with
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1084
J» C. Ayers
the U. S. Bureau of Sport Fisheries and Wildlife, Washington,
D. C.
Mr. Chairman, I would like to question Dr. Ayers
on certain points that are in his paper. On pages 9,
10, and 11, you treat the matter that breakage of plankters
passing through a plant would reduce the breeding stock,
which might otherwise result in eutrophication due to in-
creased heat.
Is this generally correct, sir?
DR. AYERS: Yes.
MR. BARBER: Is this work of determining the
breakages ~ is this based on actual field experience and
research?
DR. AYERS: Yes, we have been doing this quite
awhile.
MR. BARBER: On Lake Michigan, sir?
DR. AYERS: Yes, sir.
MR. BARBER: Does this include the work done by,
I believe, a Mr. Krezoski, one of your students, I believe?
DR. AYERS: He was in on the beginning of our
technique, when we were having some trouble.
MR. STEIN: May I suggest that you both speak a
little louder. I know both of you can hear each other and
the secretary can hear you, but I am not sure about the
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J. C. Ayers
rest of the people.
MR. BARBER: Fine.
I note that you conclude, as a result of your work,
that about 20 percent of certain types of plankters might
suffer breakage. You have determined this?
DR. ATERS: They seem to be the large zooplankters.
MR. BARBER: Right, sir.
Now, I believe you also state there and let
me read this: "the rapid sequence of physical changes
alone would leave the organisms in a debilitated condition
and little able to respond physiologically to the
rapidly disappearing heat of the plume."
But, I take it that the other BO percent or all
of the other surviving organisms even though they came
through do tend to show damage from the experience, and
that presumably they would not as we contend show
an accelerated breeding rate because of the increased
temperature.
DR. AYERS: According to our observations and
some that Mihursky at Maryland has made, he has demon-
strated loss of fuller photo synthetic activity. We have
found some actual cell count in oceans.
I believe that my thesis is basically the reason
why we do not find noxious blooms of blue-greens or greens
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1036
J. C, Ayers
in the plume.
MR, BARBER: Now, I take it from another statement
here that is in your paper that you contend that if you could
inoculate this plume again with undamaged organisms that
their physiology, their reproduction might be controlled
by the fact that the heat was in declining phase. Is this
right, sir?
DR. AYERS: That is right.
MR, BARBER: How long would this effect last?
I mean what is the temperature range over which this would
prevail, and what time factors are involved?
DR, AYERS: I think the largest temperature range
that I have seen yet is 12 degrees of excess temperature,
as I define it, and while very few people have made float
measurements down the length of the plume, I think my
measurement of roughly a half hour to ambient at Bailly
is indicative of the speed with which these plumes die away.
MR. BARBER: But at what temperatures would this
effect of physiological restriction cease to function?
Would this cease at only, say, IB to 12 degrees, or would
it have effects from these temperatures on down?
DR. AYERS: You mean in the case of our re-
inoculating?
MR, BARBER: Yes, sir.
DR, AYERS: Oh, that would continue until
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J. C. Ayers
ambient was reached, and down to a degree or half a degree
effect; as long as it is declining, it would be not con-
ducive to excess reproduction,
MR. BARBER: I see.
Well, yesterday, Dr. Pritchard presented the
hypothesis, based on his model, that the best way to
handle heat would be to inject it at a very high velocity
so that it would entrain vast quantities of other lake water,
resulting in a small high-temperature zone, but a very,
very, very large zone of quite low temperature, so that
there would be a maximum surface exposure.
Now, in a case of this sort, would not the lake
organisms involved in this mixing process, be in effect
unaffected entrained organisms that did not go through
the plant system; and would this not actually involve
many times the volume of water actually sent through the
plant? Is this correct, sir?
DR. ATERS: Yes.
MR. BARBER: Right, sir.
DR. ATERS: But they would still receive a
dimension temperature relationship.
MR. BARBER: Right, and here the eutrophication
process that we fear would be induced.
Now, let me ask you this: If this volume of
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1083
J. C. Ayers
water that we have predicted might be as much as 4»4
percent of the inshore area and mind you this is only
what passes through the pumps, not what is entrained outside
of the plant and if the physiology of these organisms
would be affected, and if we assumed that we lost virtually
all of the organisms or their effective reproduction for
this A-.4 percent that goes through the pumps every day,
and knowing that many times this volume would be entrained
and subjected to a declining temperature down to the 1
degree that Dr. Pritchard indicated would involve at
least a possible 11-hour exposure, is it not true that
tampering in these ways with water in this volume and in
these shallow areas, that we might well be tampering with
the total productivity of this lake?
DR. AYERS: No, I don't believe it. I think you
deal with a very minute part of the population, and even
though I didn't make a point of it, the organisms which I
talked about as being in thermal shock are expected to
recover.
MR. BARBER: They are expected to recover?
DR. AIERS: Yes.
MR. BARBER: Thank you very much.
MR. STEIN: Thank you.
Are there any other people who wish to ask
questions or make a comment at this time?
-------
J. C. Ayers
If not, I would like to thank you very much, Dr.
Ayers. I think you made an excellent contribution to the
conference, and I would also like to thank American Electric
for inviting you or making you available.
DR. AYERS: Thank you.
MR. STEIN: Off the record.
(Discussion off the record.)
MR. STEIN: We will get back on the record.
I think, Mr. Bane, it is about 12:00 o'clock,
and I think we may recess for lunch now. Do you want to
say something first?
MR. BANE: No, that is perfectly all right.
We would like to resume after lunch with the Commonwealth
Edison case. I would just like to say with respect to Mr.
Dumelle's remarks about the 43-day turnover, which he
derives from Dr. Pritchard's calculation Dr. Pritchard,
of course, testified before the Illinois Pollution Control
Board and is going to be made available at the request of
the hearing officer at hearings on November 5 and 6 for
cross examination, 3o that I would suggest that before
Mr. Dumelle or anybody else reaches a final answer on
that 43-day matter, that he will wait and explore it at
his own board's hearings early in November.
MR. STEIN: I can understand your view. I just
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J. C. Ayers
wish Dr. Pritchard had been available to us here because
he did make some quite definite and extensive remarks, but
I guess that is just one of these things that we have to
go along with.
MR. BANE: Well, he was available yesterday, of
course.
MR. STEIN: Well, not at the end when we asked
for him.
In other words, if anyone is going to leave, we
should first give these people an opportunity to ask
questions after that person has finished his presentation.
We are doing that from now on. I think this was unfortunate
indeed, since there were several questions on a presentation
we assumed they would be available and they weren't here.
MR, PETERSEN: Mr. Chairman, I would just like
to suggest that when calculations are accepted from the
floor as to such matters as the turnover, that it would
be helpful to those of us who are here to have that person
later testify as to those matters, so we have a chance to
question him pertaining to such calculations and other
theories.
MR. STEIN: Is Mr. Dumelle here?
Do you want to speak for him, Mr. Currie? He
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J. C. Ayers
is never very bashful in my experience.
MR. CURRIE: I am sure Mr. Dumelle would be
willing to answer the question,
MR. STEIN: Thank you.
All right. We will stand recessed until 1:30.
(Noon recess.)
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1092
Murray Stein
AFTERNOON SESSION
MR. STEIN: Let's reconvene.
We are going to continue with the power company
presentations. I note several of the other State
representatives have some other people here that they feel
they might want to get on today.
I would like to do two things. I wonder, Mr.
Bane, if you can give me an estimate of how long you think
your presentation is going to be#
MR. BANE: We have a final two witnesses and
I would estimate without the time required for their
cross examination they would take about an hour.
MR. STEIN: About an hour?
MR. BANE: Yes, sir, yes.
MR. STEIN: I would again ask that I know
Michigan, Wisconsin I am not sure that the Attorney
General of Illinois wants to make a statement but I
think we should get that lined up as soon as possible to
put everyone on. The way it looks to me, we will get
everyone today who has to get on.
Mr. Bane, would you continue?
MR. BANE: Yes, sir, the first of our final
two witnesses, Mr. 0. D. Butler, Assistant Vice
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1093
0. D. Butler
President, will discuss alternative cooling possibilities
at Zion.
STATEMENT OP 0. D. BUTLER,
ASSISTANT VICE PRESIDENT,
COMMONWEALTH EDISON COMPANY,
CHICAGO, ILLINOIS
MR. BUTLER: Mr. Chairman, members of the
conference, ladies and gentlemen. My name is 0. D.
Butler, and I am Assistant Vice President of Commonwealth
Edison Company in the area of engineering.
Commonwealth Edison has devoted careful study
to its proposal to use Lake Michigan water to provide
cooling capacity at the company's generating stations
located at Zion. We are convinced that in proposing
to use Lake Michigan water we have selected the method
of cooling which is the most desirable among the methods
which we might reasonably employ at Zion.
Last Friday afternoon the Federal Water Quality
Administration released a report entitled "Feasibility of
Alternative Means of Cooling for Thermal Powerplants Near
Lake Michigan." This report is significant to the
deliberations of this conference and it seems appropriate,
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0. D, Butler
therefore, that we offer a preliminary evaluation of that
report in terras of our plans at Zion.
The report was prepared by scientific
organizations who exhibit competence in their field.
Although they are not experienced powerplant designers,
it is obvious that they have reviewed much of the published
literature and have conversed with a number of persons
in the field. Basically, the authors of the report have
gone to the manufacturers of cooling towers and spray-
pond equipment to find out whether their equipment would
be suitable for powerplant use in the Great Lakes area.
Not surprisingly, they have concluded that such equipment
is feasible when properly applied at properly-selected
locations.
We do not propose now to debate the detailed
basis of the many items of data and computations that the
report contains. However, because it is often tempting
to sweep aside the qualifying clauses and remember only
the broad conclusions, I think it is very Important that
some of the qualifying clauses to the conclusion of this
report be brought to your attention and kept firmly
in mind.
First, the report makes it clear that "no
attempt is made to optimize any particular plant or
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0. D. Butler
site." (PWQA Report, P. 1-1) The report recognizes
that these cooling devices do have the potential for
producing undesirable environmental effects but that these
potential problems can be avoided or alleviated through
proper site selection and engineering design an
approach which is very similar to Commonwealth Edison1*
approach to once-through cooling designs. The report
also points out that careful pre-site selection surveys
should eliminate sites which have a high potential for
fog or drift problems. The authors of the report suggest
that such problems should normally be prevented by siting
a cooling tower as far from highways and airports as
possible. They also recommend that the tower be located
so it is down wind from the point of interest during
periods of low temperature and high humidity. Again, our
studies of this problem confirm these observations
and recommendations.
These observations and recommendations are
highly significant in terms of our Zion site because the
site would not permit compliance with them. In fact,
considering the landscape of the State of Illinois along
the Lake Michigan shore from the Wisconsin border to the
Indiana border, I believe that there is not a single site
that would meet the qualifications, Just reviewed, which
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0. D. Butler
are a part of the basis for the conclusions of the report.
I think two significant facts, each of them
brought out in this report, should be kept in mind in
conjunction with the use of the report's conclusion.
First is the fact that the conclusion does not apply to
any particular plant or site. The second fact is that the
cost estimates and resultant conclusions of feasibility
are not based on back fit of an existing plant or of a
plant well advanced in construction. The report makes
this very clear. But as I have said, it is tempting to
remember only the conclusion.
I think it would be worthwhile to explain the
inapplicability of the cost estimates and site
requirements of the PWQA report to the Commonwealth Edison's
Zlon plant on Lake Michigan in the State of Illinois. The
Zion site has been a planned electric generating station
site since its purchase in 1955. Prominent signs on the
property have displayed this fact through most of those
intervening years. The Zion site location was particularly
advantageous because of its closeness to Chicago, the
principal load center in northern Illinois. Of further
importance was its location in relation to other
generating units. New generating units prior to Zion were
located in the western and southwestern area of the
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0. D. Butler
Commonwealth Edison system. Additional generation in the
northern area of the system would improve system
reliability because, as generation and load are balanced
by areas, the north-south bulk transmission becomes more
available to transmit power flow.
Detailed design of the Zion facilities was
begun on a full-scale basis in the fall of 1966, and major
equipment purchases were made in the spring of 196?. Site
work began in the fall of 1967, and construction has been
proceeding at a rapid pace since the spring of 1968.
To date more than 200,000 cubic yards of reinforced concrete
is in place. This represents more than 80 percent of the
structural work. More particularly, it means that the
dimensions of the condensing equipment have been fixed in
concrete and in fact the main condenser for the first unit
is well along in erection and welding. The second unit
is ready for shipment to the site. The design we adopted
for cooling was considered to be the best plan with
respect to impact on the environment. The design met and
still meets all thermal and other governing regulations,
and we still believe sincerely that it is the best design
for the site.
The authors of the PWQA report on the feasibility
of alternate means of cooling do not address themselves to
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0. D. Butler
the problems of adapting their alternate plans to a plant
In such a stage of construction. In fact, they assume
that the means of cooling will be decided before design
begins and that the size, configuration and location of
the equipment will be optimized, or nearly so, for the
cooling means selected. To illustrate the significance
of this assumption with respect to an assumption that
the alternate cooling means might be applied at Zion,
I would like to briefly mention ten significant
considerations not evaluated in the PWQA report:
1) Our studies show that the cost of applying
wet or dry cooling towers at the present stage of
construction of Zion station are in the order of five
to six times the cost estimates in the report.
Our preliminary engineering estimates indicate
that dry natural draft towers would cost more than
$200 million in capital cost, capacity loss and additional
fuel consumed due to poorer plant efficiency. Our
estimates use the plant cost in dollars per kilowatt as
the plant is now proposed to be constructed in the
evaluation of cost of lost capacity. Even for a new plant
where construction has not begun the estimated costs in
the report are below price estimates that have been made
to us by some of the same manufacturers whose data was
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0. D. Butler
quoted in the report. It appears that adequate
consideration by the authors many not have been given
to items that are not normally included in the tower
suppliers' package, such as structures, piping,
electrical services, controls, realistic labor rates,
escalation, poorer efficiency and top charges.
2) We are in a relatively high incidence
tornado area, where extremely high winds may Jeopardize
cooling tower structures.
3) The aesthetic degradation of a lakefront
plant by the addition of massive cooling towers of either
the wet or dry type was ignored in the report. Natural
draft towers are almost certain to be considered
undesirable additions to the aesthetics of the Lake
Michigan landscape. I assume the authors of the report
Ignored this consideration because their advice is to
eliminate plant sites from consideration where such a
problem in cooling tower application may exist.
4) The noise problem associated with the fans
in mechanical draft towers was also Ignored, again perhaps
for the same reason. This problem would be a very serious
one at Zion and other existing sites, due to the limited
size of the sites and the proximity of populous areas.
5) The Zlon site is approximately 3 miles from
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1100
0. D. Butler
the Waukegan Memorial airport. Our request to construct
a 400-foot high meteorological tower was reduced to M*»5*
feet by the Federal Aviation Administration. The PWQA
report assumes that tower heights will be on the order of
500 feet for a unit a little more than half the size
of the Zion unit. This difference will have a profound
effect upon cost, and more importantly, upon plume
behavior. Marshy land to westward of the north shore
towns already produces a bad fogging condition. Low
alt-itude vapor plumes from cooling towers may seriously
worsen this condition. We have had photographs reproduced
which show plume effects at the TVA's Paradise Station in
Kentucky and at the Keystone Station operated by the
Pennsylvania Electric Company in western Pennsylvania.
I believe those are filed with the report as Exhibit B.
We will file copies of those photographs with this
testimony. (See Pp. lllla-llllc)
Our consultant, Dr. G. E. McVehil of Sierra
Research Corporation, has performed some studies of the
plume behavior and meteorological effects of cooling towers
that reasonably could be built at the Zlon site. His
preliminary findings are attached as Exhibit A to
this testimony. (See Pp. 1106-1110)
Dr. McVehil's findings indicate that coolins:
# Should r«»d 245, not 445. (see p. 1112.)
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0. D. Butler
towers at Zion would create significant problems
due to fog, icing and increased cloud cover, which would
be undesirable in a metropolitan area. The report does
not seem to recognize the significance of the shore line
of a large body of water on the environmental effects
caused by the alternate cooling means. Chicagoans frequently
hear of the "lake effect." This phenomenon will have an
important bearing on the acceptability of cooling towers,
as is pointed out in Exhibit A.
6) The report recognizes the possibility that
removing water from Lake Michigan, not to be returned, may
constitute an undesirable diversion. For a plant located
in the State of Illinois this is an important
consideration.
7) In the case of very large dry towers, such
as would be required at Zion, knowledgeable people in the
industry have been concerned with their effect on the
meteorological conditions in the area. No towers even
approaching this magnitude have ever been undertaken, so
there is no experience to rely on. I think Dr. Robert
Jaske of Pacific Northwest Laboratories expressed these
concerns very well in a paper presented in August 1968,
to the ASCE Conference on Research Needs as follows:
"In the case of the dry, nonevaporative systems,
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1102
0. D. Butler
serious consideration must be accorded to the induced
circulation of the Immense air plumes which would rise
above the Installation. On relatively quiet days, it has
been estimated that such dry towers could induce
sufficient vertical circulation to produce cumulus clouds
of extensive magnitude over the release point. The
resulting opportunities for Involvement in weather are
not inconsiderable and remain as one of the significant
research areas for the future." Dr. McVehil has pointed
out that changes in precipitation and other weather
effects are found down wind of large cities. These are
believed to be manmade effects caused, at least in part,
by heat from the city. The implications of a possible
large number of dry cooling units some time in the
future deserve serious consideration.
8) Another consideration with regard to dry
towers not recognized in the report is that design and
cost data must be extrapolated from much smaller
Installations. Insofar as we have been able to determine,
the largest operating Heller cycle dry tower in the world
is of 150 MW size, 1/14 the size of Zion. If we were to
construct mechanical draft dry cooling towers, preliminary
investigations Indicate that we would need to construct
two such towers, each roughly more than a block wide,
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1103
0. D. Butler
nearly a half-mile long and taller than a five-story
building.
Additionally, dry type cooling tower
installations normally employ an entirely different
condenser cooling cycle philosophy, and the steam turbine
would be designed for back pressures impossible with the
standard design at Zion. To understand the differences
in the condenser cooling cycle, it is necessary to review
the equipment involved. The Zion cycle utilizes a tube
type surface condenser in which steam is condensed on the
outside surface of the tubes by circulating lake water
within the tubes. A dry cycle on the other hand, utilizes
a direct contact condenser in which steam is condensed
by intimate direct contact with cooled water returned
from the tower. Conventional turbine generators operate
with vacuums at their exhaust ends in the range of 1 to
3-1/2 in. Hg. Abs. The manufacturers' designs are for a
maximum of 5 to 5-1/2 in. Hg. The vacuum is directly
related to the cooling water temperature. With a dry
cooling tower system, optimum cycles operate at
considerably higher pressures because the dry tower
is simply unable to provide the condensing water at the
cool temperatures available with wet systems. In summary/,
neither the condensers nor the turbine-generators at Ziqtn
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1104
0. D. Butler
are compatible with dry cooling towers.
9) A specific cost omission which is admitted
in the report is land preparation and construction work
associated with cooling ponds. This is such a significant
cost factor that this part of the study is of limited
value. Insofar as a cooling pond at ZIon is concerned,
it is simply not a feasible alternative because adequate
land is not available.
10) At this stage of construction of our
Zion station, adoption of one of the alternate cooling
means treated in the report would seriously delay completion
of construction and operation of the plant. The Zion
units represent an integral part of our planning to meet
our system load requirements In the next several years.
In the simplest terms, a delay would mean that we will
not be able to provide the dependable power reserves which
we have provided until now and which our plans at Zion
are Intended to enable us to continue. Of course, a delay
would be expensive in terms of additional costs generated;
for example, by the necessity to continue to pay, interest
on an Investment which is not earning a return but a
delay would be expensive in broader terms as well, for in
a very real sense it would mean relinquishing the
certainty that we will be able to provide reliable electric
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1105
0. D. Butler
service as we have done In the past.
In conclusion, the report does not say that
cooling towers, wet or dry, are feasible at every site and
it does not say that it is feasible or practicable to
back fit a plant with these cooling means. Commonwealth
Edison has devoted careful studies to its proposal to
use Lake Michigan to provide cooling at the Zion site.
Our studies convince us that our use of Lake Michigan
with the plan for intake and discharge that has been
developed will not exert any adverse influence upon the
ecological balance of the lake. We are by no means
opposed to cooling tcwers or cooling ponds as a general
matter. But we believe that the cooling method we have
selected at Zion represents the best choice among the
methods which have been considered by us and by the report
of the Federal Water Quality Administration and is the
choice which is most desirable from the standpoint of its
impact upon the total environment.
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A
n
1106
PRELIMINARY REPORT
ENVIRONMENTAL EFFECT OF COOLING TOWERS AT
ZION NUCLEAR GENERATING STATION
Prepared For:
Commonwealth Edison Company
Chicago, Illinois
22 September 1970
Prepared By:
George E. Me Vehil
Sierra Research Corporation
Environmental Systems Group
Boulder, Colorado
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110?
I Introduction
Sierra Research Corporation is conducting an analysis of
possible environmental effects of alternative cooling techniques
proposed for the Zion nuclear generating station. This analysis
is primarily directed toward potential problems of fog and icing
in connection with evaporative cooling towers. The present brief
report presents preliminary conclusions of the study, which is
still in progress.
II Significant Meteorological Factors at Zion
The Lake Michigan area has several features that tend to
create unique problems for cooling tower operation. These are
all related in some way to the presence of the Lake.
The Lake serves as an additional source of water vapor for
the air, resulting in somewhat higher humidities than average for
the upper midlist. The effect is, of course, greatest near the
lake shore. A combination of factors conducive to cooling tower
fog occurs with on-shore winds in spring' and summer. Air carried
inland is both moist end cool, giving a stable situation with
weak mixing and little additional water required to produce
saturation. Indeed, natural fog at times occurs in these situations,
A further important effect, directly related to that just
described, is the existence of the "lake-breeze circulation."
This local atmospheric circulation, driven by the temperature
difference between land and lake, takes the form of lake air
blowing inland near the ground, rising at a distance 5-15
miles inland, and returning toward the lake at altitudes of
several thousand feet. The lake breeze occurs during the day
when the lend is warm, and reverses direction at night to become
a land breeze.
The potential hazard in the lake breeze, which occurs fre-
quently along Lake Michigan during the spring and summer, is that
since air velocities are low and the circulation essentially closed,
pollutajits tend to build up and become concentrated in a limited
volume of air. Olsson & Lyons'1) have described the buildup and
transport of air pollution over Chicago in the lake breeze. Cooling
tower plumes from large towers could form highly persistent haze
and cloud layers in such a circulation.
Ill Potential for Cooling Tower Fog
Preliminary results of our analysis indicate that cooling
towers would create significant problems at Zion due to fog,
icing, and increased cloud cover.
The rate of release of evaporated water to the atmosphere from
all cooling towers required to satisfy cooling requirements at the
Zion plant would average 18,000 gal/min. It should be pointed out
that, because of the large size of the plant, this quantity of water
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1108
- 2 -
is considerably greater than that released at most locations where
cooling towers are now utilized. The anticipated adverse effects
are a direct result of the large quantity of water and prevailing
meteorological conditions at the site.
Computations have been made of the concentrations of water
which would be added to the atmosphere downwind of the plant. For
mechanical draft towers, concentrations at ground level exceeding
one gram of water per cubic meter of sir will frequently occur.
These computed concentrations, when compared to natural water
content and saturation limits, indicate the following:
1) Fog will occur at the ground one mile downwind of
the towers on many occasions. These will primarily
occur during the early morning hours from fall through
spring.
2) Ten miles downwind of the plant, fog will occur on
some occasions with weak mixing and high humidity.
It is estimated that such occurrences will be
.experienced approximately i+OO hours per year.
In addition to this direct fogging situation for which the
evaluation was made, there would be an additional fog source when
mechanical tower fans have to be reversed in winter to prevent
freezing.
Since fog will occur a significant number of times, even at
a distance of 10 miles, and winds from the Lake occur at least 30^
of the time, fog plumes will at times interfere with highway traffic
and aircraft operations at Waukegan. Also, since much of the fogging
will occur at temperatures below freezing, icing on vehicles, power
lines, and structures is to be expected.
Natural draft cooling towers would provide less potential for
ground-level fog, because of the greater initial height attained by
the plumes. If toxvers are restricted to -25>0 ft. in height, signifi-
cant fogging is to be expected, though not as frequently as with
mechanical draft towers.
The greatest hazard to be expected from very tall natural draft
towers will be due to cloud layers and persistent plumes above ground
level. These towers do on occasion produce quite extensive plumes
in the free atmosphere above the ground. Such plumes have not usually
been considered troublesome. However, they can provide a hazard to
aircraft operations near airports. A single plume on rare occasions
is probably not significant, but the eventual existence of a large
number of cooling towers in one geographical area such as Southern
Lake Michigan could lead to troublesome amounts of tower-produced
cloud. A particular problem is anticipated at Zion because of the
presence of local lake breeze circulations along the lake shore
during spring pnd summer. This circulation will at times tend to
collect and concentrate released water in a layer overlying the
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1109
- 3 -
lake shore and extending inland, producing cloud and haze conditions
which could interfere with Waukegan Airport traffic.
IV Discussion
A recent report by the Federal Vfoter Quality Administration' '
refers to several surveys of existing power plants where cooling
towers are employed. According to the report, these surveys have
found few environmental problems with cooling towers. However,
the surveys primarily covered fairly isolated, natural draft cool-
ing towers. Experience with other types of cooling, very large
units, and stations in heavily populated areas, is very limited.
It is worth noting that even the natural draft units surveyed have
experienced occasional problems ranging from icing to fog and light
snowfall.
An independent survey, conducted by Power Engineering Magazine
does indicate a substantial number of environmental problems. Of
the l|7 utilities surveyed who used cooling towers or ponds, 39 re-
ported the existence of problems. There were 1? reports of ground
fog effects and 20 reports of icing problems. These numbers seem
particularly significant because the larger plants surveyed were
all in the southwest or arid plains states. Problems would be
expected to be more widespread and serious in other parts of the
country.
Potential for fog formation by cooling towers is discussed
in the FWQA report referred to previously. There, it is concluded
that "such effects do not seem to be a problem for the Lake Michigan
area." Our results differ with this conclusion for the specific
Zion site. We have utilized observed meteorological conditions for
the area, and proposed specifications for cooling tower equipment
that would be required at Zion. Under these conditions, our rather
extensive calculations result in significantly higher fog probabil-
ities than are obtained for the general case by FWQA.
Though our quantitative analysis has been limited to cooling
towers, some general statements can be made about other cooling
methods. Spray cooling canals would be expected to have a fog
potential greater than cooling towers, since the water is released
to the atmosphere at ground level. Ponds, because of their much
larger area, are less of a fog hazard. Hox^ever, even ponds are
known to produce heavy fog in areas close to the pond. We strongly
agree with the FWQA's recommendation that sites for all types of
evaporative cooling equipment be chosen on the basis of detailed
meteorological surveys, and should avoid close proximity to highways,
airports, and other fog-sensitive operations.
Dry cooling towers represent an environmental situation about
which least is known. Certainly the large quantities of heat re-
leased to the atmosphere will result in an increase in convection,
turbulence, and cumulus clouds. Whether these will produce any
significant meteorological consequences is beyond the current
state-of-the-art to predict. There is strong evidence that man-made
-------
1110
changes of precipitation and weather are found downwind of some
large cities. These are believed to be, at least in part, a conse-
quence of heat from the city. Thus, there is some reason to believe
that the very large quantities of heat released by dry cooling
towers for a plant the size of Zion could lead to detectable changes
in the average weather conditions downwind.
In summary, it appears that environmental problems, some well-
defined and others more vague, are associated with all proposed
cooling techniques. We strongly support the FWQA's recommendation
that careful site environmental studies precede the decision to use
any particular cooling method at a given plant. In the case of the
Zion station, our studies indicate that fog potential, in particular,
is relatively high. Because the site is located in a populated area
close to highways and airports, environmental effects of cooling
towers may be expected to produce significant problems.
References
1) Olsson, L.E., and W.A. Lyons: Air Pollution Dispersion in a
Lake Breeze Regime. Paper presented at the 62nd Annual Meeting
of the Air Pollution Control Association, June 22-26, 1969,
New York.
2) Feasibility of Alternative Means of Cooling for Thermal Power
Plants near Lake Michigan. National Thermal Pollution Research
Program, U.S. Dept. of Interior, FWQA, August, 1970.
3) Thermal Effects: A Report on Utility Action, Power Engineering,
April, 1970.
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1111-a
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1111-b
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1111-c
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1112
0, D. Butler
MR. STEIN: Thank you, Mr. Butler.
Any comments or questions?
MR. BANE: Mr. Chairman, I believe the witness
may have misread one figure. Could I get it clarified
before examination?
Mr. Butler, would you turn to page 6 of your
prepared statement down in the paragraph relating to your
fifth consideration where you indicate that your request
to construct the 400foot-high meteorological tower was
reduced to and you said orally 445 feet
MR. BUTLER: I am sorry; it should be 245.
MR. STEIN: That will stand corrected.
Your meaning was clear.
MR. BUTLER: I am sorry.
MR. STEIN: Before we get into the questions, I
have just a few of these general ones before we get into
the specifics.
As I understand what you said about the Zion
Plant improvements, it is that you can't really put in a
cooling device now.
MR. BUTLER: No, I didn't say that they were
improvements. I was really pointing out the inapplicability
of them as is pointed out in the PWQA report.
MR. STEIN: You see here this is where I am
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1113
0. D. Butler
trying to understand what you people are saying. lou say
if we continue to operate this and let's suppose for the
sake of argument I am not saying you are not correct
that there won't be any bad ecological effects, but your
previous witnesses have said if there proves to be damages
you will be glad to put in devices. But if the site is
so located and you have made such commitments in concrete
that you can't possibly do this, as things come up, then
what is the point in saying you will? Let's suppose
you have made a misjudgment. Let's suppose damages occmr.
What kind of cooling can you put in, since you have done
such a good job in indicating it can't be done?
MR. BUTLER: Well, Mr. Chairman, no place did I
intend to insinuate and I don't believe I said that
it is not possible. It is very hard for an engineer to
say that anything is not possible, and I didn't intend to
insinuate that it was not possible.
MR. STEIN: All right.
Then, I certainly agree that we are close
together.
How, there is one other thing that I run into
here all the time on which I really think I would like
some clarification. On your first page you said, "We
are convinced that in proposing to use Lake Michigan water
we have selected the method of cooling which is the most
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1114
0. D. Butler
desirable among the methods which we might reasonably
employ at Zion."
Then on page 2, in dealing with that, you say,
"... an approach which is very similar...*1 to a once-
through cooling system.
Now, the point is, that cooling you are talking
about is really condenser cooling, that is not water
cooling, is it?
You haven't put anything in Zion which is designed
to cool the water, and when you are talking in terms of a
method of cooling, and the once-through cooling design,
these all refer to cooling which you are going to use as
far as your steam and your condenser operation but it
doesn't refer to cooling your water before discharge, is
that correct?
MR, BUTLER: It is correct, that I was referring
to the cooling of the steam, and I believe that is also true
of the FWQA report.
MR. STEIN: All right.
I want that to be clear, when we talk about a
once-through cooling system that doesn't mean a system to
cool the water; that means to cool the steam when the water
gets out of it.
Any more questions or comments?
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1115
0, D. Butler
Mr, Currie.
MR. CURRIE: I have one question.
You mentioned the land shortage in regard to the
possibilities of cooling ponds at the Zion Plant. Perhaps
Mr. Bane is in a better position than you, Mr. Butler, to
answer that question. Is it not true that Commonwealth
Edison has the power of condemnation?
MR. BANE: Yes, we do have the power of condemna-
tion. We have complications at that particular site, Mr.
Chairman. There is a State park, as you know, not far to
the north, and indeed we made a contribution to that park
by exchanging one of our parcels for another parcel so
that it could be added onto the park there. It would take
braver men than we, I think, to attempt to interfere with
that park.
Whether or not we could go I think that
immediately as we go to the west -- Mr. Butler could
probably answer this better than I but I think that
as we go to the west we get into a highly built up area}
is that correct, Mr. Butler?
MR. BUTLER: Yes, we do, and the land price is very
high as we go to the west alsoc That is, in fact, the city
of Zion.
MR. BANE: But there is another paper as to which
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1116
0. D. Butler
I would very much like to hear the views of the Department
of Interior
MR, STEIN: Again, sir, you. may want to talk
about this, because I think the philosophic approach has
been one possibly which isn't going to settle this opera-
tion. You talk about material in the FWQA or the
official Wildlife report, and then you say **... these
observations are highly significant." Of course, you
say w...in terms of our Zion site...because the site
would not permit compliance with them."
Then you go on to say that you have more than
200,000 cubic yards of concrete in place. You have the
dimensions of the condensing equipment already set, etc*
It seems this raises the question of how far any company,
by setting a plant in motion or selecting a site or
building a plant, can limit the remedial options of
the people responsible for protecting the environment,
or whether and this is the same question because you
can answer them both or whether it is the responsibility
indeed of a Federal or State or local regulatory agency
to give you an alternative on how you are to protect the
environment. The point is if you have selected the site,
selected the process and built the plant, it seems to me that
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1117
0. D. Butler
the general rule of law on this, if there is a requirement
that the environment is to be protected, the company doing
that is responsible for coming up with the method,
MR0 BANE: Well, I think that our policy statement,
that was one of the first papers delivered by Commonwealth
Edison Company,very clearly said if there turned out to be
a need to modify or change the cooling method because of
environmental damage, it would be in the future determined
that we certainly stood ready to do so*
MR. STEIN: But all those have reasons
against them. Do you have any methods to correct this in
case you have to use it that we haven't heard of?
MR. BANE: Well, Mr. Chairman, it is very difficult
to speculate on how you would modify a cooling system before
you know what the problem with the cooling system is. I
think there are many modifications that can be made depend-
ing upon what the problem is. We don't see any problem at
the present time.
MR0 STEIN: Any other questions or comments?
By the way, Mr. Butler, I don't think we are
far apart. I really don't. And are there any comments
or questions from the people on the floor?
DR. TICHENOR: My name is Bruce Tichenor from
the Corvallis Lab of the FWQA.
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1118
0. D. Butler
One of the anonymous authors of the feasibility
study paper
MR. BUTLER: Pardon me. I can't quite hear you.
I have a little hearing problem.
DR. TICHENOR: Maybe I can stand over here. It
will be a little easier.
I just have some general questions and comments
related to your presentation.
I notice initially that many of these comments
are essentially the same as the presentation that was
delivered earlier by Mr. Patterson of Sargent and Lundy.
First of all, on the first page, you make a state-
ment that basically the authors of the report have gone to
the manufacturers of cooling towers and spray pond equipment
to find out whether their equipment would be suitable for
powerplant use in the Great Lakes area.
I am wondering if you really have made a careful
reading of the report, because I think in the report
itself we point out that the procedures used in estimating
and defining the costs were somewhat more sophisticated
than this in fact, quite a bit more sophisticated --
and I think Section 4 of the report and Section 5 of the
report indicated that, and I wonder if you have any comment
on what sort of procedures you think we really used to come
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1119
0. D. Butler
up with these cost estimates?
MR. BUTLER: Well, yes, I would be glad to comment
on that.
You do mention in the report that some of your
data comes from the Marley Company and some from the
Ceramic Cooling Tower Company and we, of course, have had
contact with those same firms.
Now, when you start to compare cost estimates
from two different organizations working independently of
each other, of course, it is very hard to compare the costs
because neither one knows exactly where the other started
and where the other ended, and neither one knows specific-
ally the criteria under which the design was specified and,
therefore, the price is affected by that design specification.
Now, I might just point out, as an example, that
experienced powerplant engineers are accustomed to optimiz-
ing the capital cost of a plant with the operating and
maintenance cost of a plant; where the suppliers of the
equipment generally, if you go to them for an estimate price,
they tend to give you the lowest estimating price unless you
in a very detailed manner specify what you want.
As an example of that, just let me quote an
example,, As a matter of minimizing investment and opera-
tion, one company may say I will put an operator on the site
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1120
0* D. Butler
and when it becomes necessary to shut the cooling towers
off and drain them, I will have one or two or three
operators there that can go around and twist all of the
necessary valves and shut it down and drain it and protect
it from freezing, and so forth.
It may, though, be more economical in the
overall picture to put in more operating valves in certain
locations which raise the capital cost but reduce the
operating and maintenance cost in sufficient amount to
justify the higher capital cost. That is why it is very
difficult to compare two cost estimates of doing this, and
I stated very frankly that I thought that your costs were
low in comparison to our experience of estimating similar
installations.
DR. TICHENOR: Yes. I appreciate your comments,
and I think that in some cases you are probably directing
most of these comments to capital cost,
I was more concerned with as you can tell by
our report the effect of cooling systems on the pro-
duction cost of electricity, and I have another statement
to make on that a little later.
I think you list a total of ten points which
are considerations not evaluated in the FWQA report,
MR. BUTLER: As they apply to Zion.
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1121
0. D. Butler
DR. TICHENOR: This is true. I think you appre-
ciate the fact that that report was not meant to include
backfitting as was pointed out so well by Mr. Williams of
the AEP.
MR. BUTLER: I certainly do. I didn't mean to be
redundant of Mr. Williams. I didn't know what he was
going to say, I think we came to similar conclusions on
that, and you made it quite clear in your own report. I
was not picking flaws with your report in that respect but
my point was that there are qualifications to your conclu-
sion and people tend to forget the qualifications.
DR. TICHENOR: This is absolutely true. Our
report did not consider backfitting. I do have some ques-
tions on these ten points even though some of them may not
be particularly applicable to our report.
First of all, you make the statement that the
costs of the plant wet or dry cooling towers at the present
stage of construction at the Zion station are in the order
af "ive to six times the cost estimates in the report.
Again, I don't think this is a fair comparison because our
cost estimates were not based upon backfitting,
MR. BUTLER: Tours were not backfitting and mine
is.
DR. TICHELOR: My question is: Are these five
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1122
0. D. Butler
to six times the cost capital costs, busbar costs,
consumer costs what are we talking here?
MR, BUTLER: This is capital cost^ with the loss
of capacity that may be involved valued not at the hundred
dollars a kilowatt that was used in your report but at $207
a kilowatt which is our estimated cost of the capacity at
our Zion station, and in addition the poorer efficiency or
the use of more fuel that would be required. The equivalent
investment of the loss due to the additional fuel consumed
is included in that,
DR, TICHEMOR: Right.
MR, STEIN: Do you mind if I go on with some-
thing not on here but just in the general report? As I
understand it, here is what happened. You have indicated
that they qualified the report not to include backfitting
and you said they said that was very clear, but you want
to emphasize it so it wouldn't be misunderstood,
MR, BUTLER: I wanted it emphasized so that you
gentlemen who are deliberating this problem would not
overlook it in your deliberations. That is correct,
MR. STEIN: And then you switched four, five or
six times relating to Zion, which is a backfitting report
that they reported. Now, what we are doing is writing out
the discharge and then using that as a main point of
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1123
0. D. Butler
difference.
All right. Would you go on?
DR. TICHENOR: I would just like to ask what
estimate do you think this five or six times the capital
cost would have on the busbar cost?
MR. BUTLER: I have not computed that. I would
be glad to do it or have it done and report, if you would
like. I have not made that computation.
DR. TICHENOR: This is for backfitting. Again,
lower down here there is a statement about: Even for a
new plant now, this is reflected in our report the
price estimates that have been made are higher and lower
than the ones that you people have.
I think that this question was raised yesterday
with respect to Mr. Patterson. I won't go into that.
I have been talking to Mr. Patterson, by the way, and
we are exchanging information. I have made available
our information to him and I understand that he is going
to come up with some numbers, so I won't go into that
any further.
Again, I would like to emphasize again which
has been emphasized by the consultant that dry towers
are brought in again. I couldn't agree with them more
-------
0. D. Butler
that dry towers are not a practical alternative to back-
fitting a plant with a tube condenser. I can't see
anyplace in our report where we even jame close to
inferring that that was a possibility,
I have a couple of questions related to Dr.
McVehil's study. You make the statement that his prelim-
inary findings are attached as Exhibit A, which I have
read, and these preliminary findings indicate that
cooling towers at Zion would create significant problems.
And if these are preliminary findings, how can we come
up with a conclusive statement?
MR, BUTLER: Well, the preliminary findings of
Dr. McVehil are based upon the 245-foot high tower. Now,
we hired this firm sometime ago to study this problem,
and they have not completed their stud^. Tou will
notice that in a place or two in his report he did come up
with some numbers of frequency with respect to certain
things, but they have not completed the report to the
extent that they can say on a certain expected frequency
this will happen or that will happen with respect to some
of them . We are asking them to carry right on with
the report and to complete their study on it0
How, certainly Dr, McVehil can be made available
for cross examination, I am not a meteorologist and I
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1125
0, D. Butler
certainly can't talk I can't convey to you all of the
reasons that he may have for his conclusions. But I think
the significant point here is that the low relatively
low wet cooling towers perform differently than the high
cooling towers like Mr. Williams showed this morning .
I think also that this what the meteorologists call
the induced air flow due to being on the shore of a very
large body of water seems to be from discussions with Dr.
McVehil -- seems to be quite an important consideration.
MR. MAYO: May I make an observation, Mr.
Chairman? I have the feeling that perhaps a liberty
may have been taken with Dr. McVehil's comments. If we
go to page 4, the very last sentence uses the terminology:
"Environmental effects of cooling towers may be expected
to produce significant problems."
Did you interpret this conclusion as being that
cooling towers at Zion would create significant problems?
MR. STEIN: Well, he didn't say "will," I
noticed that. They didn't say they "will" cause signi-
ficant problems. Okay, go on.
DR. TICHENOR: Your Point No. 6 is that the
report recognizes the possibility that removing water
from Lake Michigan not to be returned may constitute an
undesirable diversion.
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1126
0. D. Butler
I wonder if you considered whether or not the
increased evaporation due to a once-through cooling system
constitutes undesirable diversion,
MR. BUTLER: I think that is a legal question
and I am, of course, no authority on interpretation of
the merits of the decision. However, I only throw it
out as a consideration. I didn't try to give the answer
to it as you will notice.
DR. TICHENOR: Right. I think that in our
report we indicated that certainly these wet devices will
have higher evaporation rates than the once-through system
and the data are given. But I am like you, I am not going
to try to draw any conclusions on that.
On Point 9, you mentioned a specific cost
omission, which is admitted in the report, land prepara-
tion and construction work associated with cooling
ponds. This is true. Then you say this is such a sig-
nificant cost factor that this part of the study is of
limited value.
I am not too sure I agree with that, in that even
if our construction costs were significantly low, the
fact that we are looking at not only the effect on the
cost of electricity of the capital cost but also the
effect of operating the cooling system,such that we include
-------
1127
0, D, Butler
things as fuel differential cost,y would make me believe
that in the end the results that come out are meaningful.
For examplef if you make an error in construction
cost, all other things being equal, of a million dollars,
and using a fixed charge rate of about 14 percent, this
makes a difference in the busbar cost of about .02 mills
per kilowatt hour. So, in this case, if our cooling
pond costs capital costs were low or even significantly
low, $1 or $2 million, I think in the end when we talk
about our busbar cost increase, I think you would see at
least our conclusions are that it would not make a very
great difference in the production cost.
MR. BUTLER: Well, I disagree with you on that
completely. We have some experience in building cooling
ponds, as you may know. We have our Kincaid Lake with a
JSinemouift station. We are building a cooling pond near
Pekin, Illinois, for a new unit, and we are undertaking
to build about a A-» 500-acre lake at another site which
Mr. Currie is very familiar with. We find that the land
cost is a rather insignificant part of the cost because
we are talking about moving in the order of 20' million
yards of dirt to consummate this cooling pond.
Of course, the topography of the land is the
controlling factor whether the land or the construction
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1128
0. D. Butler
cost of the cooling pond is significant. In our cases, we
find that the land is a rather insignificant part of the
total cost of putting a cooling pond into service.
DR. TICHENOR: Yes. This was not my point. I
will agree that leaving out the cost of construction and
land preparation definitely makes our capital costs of
our cooling ponds low. My point was that unless, as you
suggest, the land costs are an insignificant portion, which
for $1,000 an acre that would be quite an expensive cooling
pond are an insignificant portion of the capital cost,
I would agree with you, but if we missed the cost of the
cooling pond by $1 or $2 million
MR. BUTLER: Let's say $20 million.
DR. TICHENOR: $20 million, then I would
agree.
I think we are talking here about a portion of
the cost of the total cooling pond land preparation cost,
and I think, in this respect, if we added $20 million to
the cost of our cooling pond for, again, our 1,000
megawatt base plant, I would agree with you. But if it
was $1 or $2 million, then I would think that we
MR. BUTLER: I would agree with you, if you can
build one after owning the land for $1 or $2 million,
that is not significant. In the topography that I have
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1129
0. D. Butler
been unfortunate enough to have to deal with, I don't think
you build any 4,000 or 5»000-acre cooling ponds for I mean
after you own the land -- for $1 million or $2 million,
I just don't think there is any such topography very
available. I haven't found any.
DR« TICHENOR: Okay. Cooling ponds in our report
I think ranged from about 1,400 to 1,900 acres, but I
don't think we are really disagreeing. I don't have any
further comments.
MR. STEIN: Thank you.
Are there any other comments or questions?
Thank you very much, Mr. Butler,,
MRo BANE: Commonwealth Edison's final witness is
a recall of Dr. Pipes who will discuss some proposed
thermal pollution standards.
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1130
W. 0. Pipes
STATEMENT OP WESLEY 0. PIPES,
PROFESSOR OP CIVIL ENGINEERING,
NORTHWESTERN UNIVERSITY, EVANSTON,
ILLINOIS
MR. PIPES: Mr. Chairman, members of the
conference, ladies and gentlemen.
During the last two-and-one-half years I have
had the opportunity to study, read, and think about the
effects of temperature on Lake Michigan water quality
and aquatic ecology. As a result I have reached
certain Judgments about temperature criteria for
protection of the lake and would like to present these
Judgments for your consideration. My studies of
temperature effects in Lake Michigan were the result of
a request from Commonwealth Edison Company that I advise
them on this subject. However, these Judgments are my
own personal opinion and do not represent a position of any
agency.
Purpose of Water Quality Criteria
I believe that the intent of water quality
criteria is to protect the value of water as a natural
resource. In this context it would be as much a squandering
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1131
W. 0. Pipes
of natural resources to adopt criteria which are so strict
as to prevent the beneficial use of Lake Michigan as it
would be to adopt criteria which are so lax as to allow
degradation of water quality and destruction of aquatic
life. I believe that it is possible to develop water
quality criteria which will allow all users of Lake
Michigan, the municipalities and industries, as well as
the fishermen, boaters, and swimmers, to make optimum
beneficial use of this resource without interfering with
each other.
In approaching the problem of temperature
criteria for Lake Michigan I have formulated a series of
questions. The answers to these questions provide a
scientific basis for deciding which of the proposed
criteria best meet the objective of maintaining the
value of the water as a natural resource. I will first
present these questions and the answers which I have
obtained and then comment on some specific items of the
proposed criteria.
Temperature Change
On the subject of temperature criteria for Lake
Michigan the first question to be answered is:
Should any temperature change from normal water
temperatures be permitted?
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1132
W. 0. Pipes
I believe that the available data and scientific
evidence clearly demonstrate that moderate temperature
changes over small areas of Lake Michigan have not caused
any degradation of water quality or any damage to aquatic
communities. I have studied one area of temperature
increase in Lake Michigan intensively myself and have
found evidence that no detrimental effects are occurring.
I have examined reports by scientists who studied other
areas of temperature increase in Lake Michigan and found
that no detrimental effects are described. I have
studied articles by other scientists who hypothesized that
certain detrimental effects might occur as a result of
temperature increases in certain areas of Lake Michigan
but have found these hypotheses to be based on speculative
calculations and translation of laboratory data to natural
environments.
There is no scientific evidence from studies of
Lake Michigan to support the need of a criterion of a 1-
degree temperature rise at the point of discharge to pro-
tect water quality and aquatic ecology of Lake Michigan.
Indeed, there is substantial ecological evidence to
support the concept that modest temperature increases over
small areas of Lake Michigan have no detrimental effects.
If I could elaborate for a moment, Mr. Chairman,
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1133
W. 0. Pipes
I would like to point out I said detrimental effects
there are ecological changes, and we are attempting to
measure the magnitude of these ecological changes. We
have fairly good limits, I think, on the magnitude of
the ecological changes. We don't know precisely what the
measurements will be.
I might also point out that the introduction
of coho salmon into Lake Michigan was a very large
ecological change a much larger ecological change than
we are talking about here. Whether or not this is a
detrimental effect on Lake Michigan is a matter which
is presently being debated among fisheries' biologists.
The types of temperature effects which may be
occurring in Lake Michigan due to present powerplant
discharges are subtle changes in the biological
populations which comprise the aquatic communities. If
they do occur in the lake, they should be measurable at
certain times of the year at temperature increases in the
range of 5 degrees to 10 degrees P. above the normal
water temperature. Obviously, if we can find no changes
at 5 degrees P. above normal water temperature, we can
feel quite comfortable in concluding that no change will
occur below that level. In the rest of this statement,
I am referring to the areas in the discharge plumes which
-------
W. 0. Pipes
are 5 degrees P. or greater above normal water
temperatures.
Mixing Zones
I believe that the available scientific
evidence and the calculations and conclusions based on
this evidence demonstrate that the heat from discharges
of condenser water from steam electric generating units
having a capacity between 1,000 and 1,100 MW is dissipated
in a relatively small area around the point of discharge
and that these discharges can be designed so that the
temperature will be reduced to within 5 degrees P. of
normal water temperature in less than 1 mile from the
point of discharge. These discharge plumes would
have no measurable temperature effect upon the water at
a distance of 3 miles from the point of discharge. The
judgments which I am making in this statement depend on the
conclusion that the types of thermal discharges proposed
for Lake Michigan will have no measurable effect on the
overall temperature of the lake. Given this position
the second question to be answered is:
How large should mixing zones be?
I am considering discharges which would have
no measurable effect on lake temperature at a distance of
3 miles from the point of discharge. Because of the
-------
1135
W. 0. Pipes
normal configuration of thermal plumes these discharges
would create mixing zones having areas less than 1
square mile if a temperature change of 5 degrees P. from
ambient water temperature is taken as the edge of the
mixing zone. In my judgment a limited number of mixing
zones of this size with moderate temperature increases
(5 degrees P. to 20 degrees P.) in the mixing zones
can be allowed without running a significant risk of
degradation of water quality or damage to aquatic
communities.
This Judgment is based on the following
facts:
1) In water depths less than 10 feet in
Lake Michigan the benthic organisms are very sparse. In
water depths greater than 10 feet the warmest part a
thermal discharge plume floats and there is little
temperature effect on the benthic community.
2) In discharge plumes with an area of less
than 1 square mile the time of exposure of planktonic
organisms to temperatures 5 degrees P. or gerater above
ambient is less than one-quarter of a day. The planktonic
organisms in the lake have generation times of 1 day and
longer. Thus, the plankton are exposed to increased
temperatures for periods much less than their generation
-------
1136
W. 0. Pipes
times.
3) Fish are normally expected to seek out their
preferred temperatures and will be present in the mixing
zone when the temperatures there are near these preferred
temperatures.
How Many Mixing Zones
The Judgments on mixing zones are made with
the knowledge that there are, and probably always will be,
some uncertainties about the effects of temperature change
on the aquatic communities. If a conservative
viewpoint is taken, these uncertainties become risks.
Given the concept that some risks are associated with
allowing mixing zones this large, the third question to be
answered is:
How many of these mixing zones should be accepted?
The surface area of Lake Michigan is 22,400
square miles. If we assume that it is acceptable to take
small risks with 1 percent of the lake surface, then 224
square miles of surface area could be utilized for mixing
zones. This area would allow a total of 224 nuclear
units of 1,000 to 1,100 MWe capacity if individual mixing
zones are limited to 1 square mile. This is far more
plants than are likely to be built on the lake.
Mr. Chairman, I want to emphasize the point that I am not
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1137
W. 0. Pipes
proposing to allow construction of anywhere near that
number of powerplants on Lake Michigan.
This judgment is made on the assumption that
the mixing zones which are permitted will be studied.
There should be continuing study of the aquatic ecology
of Lake Michigan and the effect of temperature changes
upon the aquatic communities in these mixing zones. There
should also be a reevaluation of the temperature standards
periodically as more information about temperature effects
becomes available. I believe that several years of study
will produce scientific evidence to support the judgment
that the temperature criteria we are considering at the
present time are conservative.
Here, Mr. Chairman, what I am saying, on the
basis of the scientific evidence we go in the direction
which the data points. You do not take a look at the
data you have and assume that the next batch of data
that you have will contradict the first batch of data
you have, and I believe that this is the scientific view
on this. I think after sitting through 5 days of
hearing or the last 6 days now I have realized that
this conference needed not only scientific input but
also input from other fields of endeavor. I am just
trying to express the scientific use of the data in this
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1138
W. 0. Pipes
context.
It has been speculated by some that the most
important period for temperature effects on Lake Michigan
organisms will be the months of March, April, and May.
There is evidence to Indicate that during these months
the thermal barrier in Lake Michigan inhibits the mixing
of shore waters **!/ch the open areas of the lake. If these
ideas are correct?-and I think it has been brought
out here very well that this particular point is a
matter of considerable debate in the scientific community
at the present timebut if these ideas are correct, then
we are dealing with an area to protect which is much
smaller than the 22,400 square miles of lake surface.
The Department of Interior "white paper" on
thermal effects (September 1970) concludes that the so-
called Inshore area must be separately considered because
it is the most biologically productive area. That
inshore area, defined as the area from the shore to a
depth of 100 feet, contains some 5,OMO square miles
Again, as you have heard, there is considerable question
in the scientific community of the adequacy of this
definition. That is, defining inshore zone as the
area in which the depth is less than 100 feet. So there is
still some debate, as a matter of fact some considerable
-------
1139
W. 0. Pipes
debate about that point.
The largest portion of that area lies within
Green Bay, and the inshore area, excluding Green Bay
for the moment, contains about 1,500 square miles.
Now, if we take an extremely conservative
position for the moment and assume that the inshore area
ought to be separately considered, mixing zones of the
size I am discussing do not now present a problem. There
are nine large units now under construction around the
lake. While I have not studied all of them, I am
reasonably sure that their mixing zones will occupy,
even if added together, less than 1 percent of the inshore
area, even excluding Green Bay,
As a result, I believe we have clearly not
yet reached the point at which an unreasonably large
number of mixing zones 1 square mile in size are planned
for the lake. That point presumably will be reached in
time, and I believe it reasonable for regulatory bodies
to consider fixing an interim limit on the total number
of large plant sites until such time as studies of the
present discharge plumes can be completed,
Temperature Rise
Having answered the questions of how large and
how many mixing zones, the next question which arises is;
What should be the temperature rise allowed
-------
1140
W. 0. Pipes
at the edge of the mixing zone?
In order to arrive at an answer to this question,
it must be stated again that we are dealing with practical
questions of locating a particular isotherm on the lake
surface. In my experience the uncertainty of locating
a particular isotherm is about 1 percent of the distance
from the shore. In other words, the uncertainty in
locating a temperature difference of 1 degree F. at a
distance of 1 mile from shore is about 1500 feet. At
smaller distances from the shore and for larger temperature
differences the uncertainties of measurement decrease
rapidly. I estimate that it should be possible to locate
a temperature difference of 3 degrees F. at a distance of
1 mile from shore within a range of "t.250 feet and a tempera-
ture difference of 5 degrees F. within a range of IllOO feet.
I believe that the temperature rise selected for
the edge of the mixing zone should be realistic in terms
of a reasonable degree of precision in measurement. The
measurements have to be made in terms of both measuring
changes in aquatic communities and in terms of locating
a particular point in the lake. A 5 degree F. temperature
change would be readily measurable and also marks point
below which biological changes are most unlikely. My
previous discussion of the size and number of mixing
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W. 0. Pipes
zones was based on a definition of a 5 degree F,
temperature change at the edge of the mixing zone. If
a different temperature change were used for defining
mixing zones the areas would have to be revised.
MR. STEIN: Dr. Pipes, may I interrupt there.
because I think this might help.
I know you probably wrote this before you
got here this week.
DR. PIPES: Right.
MR. STEIN: In view of what we heard about the
difference of opinion and the way people look at thermal
plumes and tongues of heat going in and out would give us
a difference of plus or minus 200 feet or plus or minus
100 feet. Are you really suggesting that this would be
appropriate thinking? I want to do this before you come
to your conclusions as consenting to this. Do you think
this is appropriate that we can administer this, companies
are going to be happy with the results, you are going
to be happy with the results and the regulatory agencies
are going to be happy with the results if we start
checking these plus or minus when they vary?
DR. PIPES: Well
MR. STEIN: Go on, because I didn't want you to
get locked into your contusions first. I know you put
this before I am trying to look at a way out of
-------
1142
W. 0. Pipes
this, but you go on. I Just meant to flag that.
I don't want to pursue that point.
DR. PIPES: Well, I am going to comment on this
in Just a minute as an interjection here. When I wrote
this I was thinking about problems of measurement.
MR. STEIN: That is right.
DR. PIPES: There is first the problem of
locating a particular isotherm on the surface of the lake.
And the second point is the question of deciding whether
this is a temperature change from the natural water
temperature of so much so many degrees.
Now, I think what I am trying to say here is
that in terms of measurement and the precision of the
instruments that we have available at the present time,
if you are talking about temperatures changes of the
order of magnitude of 5 degrees, then we can be fairly
certain to say that this is the plume, this is not the
plume. When you are looking at the temperature changes
in the order of magnitude of 1 degree then there is a
great degree of uncertainty whether you are in the plume
or measuring ambient temperature.
MR. STEIN: I think it is one area maybe we can
come to an agreement on with all concerned. I am not
arguing about this scientifically and I am not arguing
-------
1143
W. 0. Pipes
about using these as theoretical considerations to set up
a mixing zone. But what I am saying, sir, is that I
think this would be better for the industry as well as
the regulatory agency if we can agree on an area of
regulation.That is why I suggested the pipe. Even
though you go to higher temperature, you relate this
theoretically to what would happen in the mixing zone.
Because if we are going to do what I heard this week,
we will be here interminably on every alleged violation
or not-alleged violation.
DR. PIPES: I am not familiar with all of the
problems of enforcement. I do think that it is possible
to measure temperatures of well, temperature measure-
ments fairly accurately with a thermometer to a
hundredths of a degree and so forth, but locate a point
in the lake at which there is a measurable temperature
difference from ambient. So, I am concerned with
measurement here really more than enforcement.
MR. STEIN: Okay. All right.
DR. PIPES: Comments on proposed standards,
and I interject here at this point that these comments
were written in reference to a series of three proposals
the ones which are officially under consideration
by the State of Illinois, as I understand. I have seen
-------
1144
W. 0. Pipes
proposals from some of the other States, and I felt it
more appropriate to comment on the proposals which
are before the Illinois Pollution Control Board rather
than try to cover the whole thing.
Following the discussion of what I believe to
be the pertinent questions which must be answeredf. to
establish temperature criteria for Lake Michigan and how
I would answer them,.it is appropriate to comment on some
of the previous proposed temperature criteria.
The description of the mixing zone as having a
length of radius in feet given by 100/ Q
where Q is the discharge rate in cubic feet per second
is quite conservative in terms of our present experience
with previously existing discharge plumes. I really have
no knowledge of where this particular formulation came
from. I understand it is a formulation which Mr. Mayo
presented in the State of Michigan last April. I
would point out that this formulation does limit the mixing
zone to smaller areas than I was talking about earlier,
mainly because of the type of configuration you h are to
use for the discharge in order to meet this standard.
And, as I say, I believe it is quite conservative
in terms of our present experience with previously
existing discharge plumes and biological effects in these
-------
1145
W. 0. Pipes
plumes. It is, however, a standard which can be met
with a reasonable engineering design, except perhaps in
the case of a small discharge. I have really not looked
at any application of this when X is a very small
number and realize there is some mathematical problems
in calculating if you get a very low Q.
In other words, I am saying that this is a
I think in view of the biological information we have,
this is a very conservative estimate of the size of thy
mixing zone, and it would limit the actual mixing zones
in the lake that are smaller sizes than the ones I have
been talking about earlier.
An allowable temperature rise of 3 degrees P.
at the edge of the mixing zone is very conservative
and probably too restrictive. An allowable temperature
rise of 5 degrees F. at the edge of the mixing zone is
more realistic in terms of allowing measurement of any
of the postulated temperature effects on aquatic
communities if they do occur. The organisms in Lake
Michigan are subjected to normal temperature variations
which are a part of the natural environment to which they
have adapted. The formulation of temperature standards
in terms of allowable temperature rise above ambient is
more realistic for preserving the natural temperature
-------
1146
W. 0. Pipes
variations than setting maximum temperatures on a month-
by-month basis.
Again, I am not familiar with all of the
previous input in the area of writing proposed criteria.
I am assuming that the month-by-month maxima in the
various sets of tables which are going around is
basically an attempt to define what is ambient so we can
get away from the problems of measurement.
The monthly temperature maxima which were listed
in Mr. Klassen's letter of August 12 to Mr. Currie as a
part of proposal No. 2, as far as I have been able to
ascertain, have no relationship to the temperature
requirements of aquatic organisms. Indeed, for several
months of the year the normal water temperature in the
inshore area exceeds the proposed maximum a significant
fraction of the time.
I believe that the temperature standards for
Lake Michigan should not contain any reference to the
96-hour median tolerance limit for aquatic life. One
of the gentlemen from Michigan pointed out to me that
between August and September they had dropped this out
of their State proposal. However, I understand that it
is still a part of the proposal in Illinois and therefore,
we will comment on it.
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11*7
W. 0. Pipes
This criterion is inconsistent with other
concepts of the proposed standards because:
1) The reference is to a maximum temperature
which will persist for only a few seconds and in an area
having a radius of, at Zion, for example, of 100 feet.
Regarding such an area as critical would, as a matter of
logic, require you to prohibit the building of discharge
works into the lake because they occupy as much space.
2) Planktonic organisms are subjected to the
maximum temperatures in the mixing zone for periods of
time much less than 96 hours. You remember what Dr.
Pritchard shows in a matter of seconds, perhaps minutes.
3) The scouring action of the discharge will
prevent any benthos from occupying the area of maximum
temperature and so none will be exposed to these
temperatures.
4) Pish have the option of leaving areas in
which the temperature exceeds their tolerance limit and
evidence indicates that they do.
5) This, I suppose, is related to the
problem of enforcement. There are hundreds and perhaps
thousands of organisms in Lake Michigan for which the
96-hour median tolerance limit temperature is not known
and years of laboratory work will be required to find out
-------
1148
W. 0. Pipes
what this specification means.
Use of a 96-hour TLm, in effect reduces the
proposal to one governing the temperature at the point
of discharge, which is not consistent with the mixing
zone concept on which the remainder of the proposal is
based. The concept of a 96-hour TLro is useful for discussing
water masses which have a uniform temperature. It is not
directly applicable as a regulation governing discharges
which constantly decline in temperature.
Summary
To summarize, I believe that the appropriate
regulation at this time is one which limits the number
of plants located around the lake until the presently
planned studies are completed and evaluated, and limits
each plant to a reasonable mixing zone and a 5 degree P.
temperature rise at the edge of that mixing zone.
MR. STEIN: Any comments or questions?
I don't know, I can hardly contain myself.
MR. CURRIE: Dr. Pipes, you are concerned
that we should limit the size and number of mixing
zones, and I take it also the spacing of mixing zones
around the lake, so that we don't have a number of them
right together, is that right?
DR. PIPES: I might point out that all along
-------
1149
W. 0. Pipes
there have been a number of other considerations in, let's
say, the spacing and location of these mixing zones that
have been brought out. Dr» Robertson suggested yesterday
the mixing zones should be located so that there would be
no warming of the thermocline, and the hypolimnion, it has
been suggested, in these mixing zones be located so that
it not affect fish spawning grounds and such things.
Excuse me. I am not answering your question
directly. In answer to your direct question, I think the
spacing of the mixing zones should be limited so that the
possibility of interactions of the plumes is at a very low
temperature differential.
MR. CURRIE: Yes. Do you also have any thought
that we ought to limit the temperature inside a mixing
zone itself, or should we be content if someone wanted to
discharge water which would create mixing zones of a square
mile in which the temperature was 40 or 50 degrees above
ambient ?
DR0 PIPES: Well, I don't know of anybody that
was proposing to discharge water at this type of temperature
increase. There certainly are temperatures ~ temperature
increases which would definitely do damage to aquatic
communities in Lake Michigan. I would like to ask if you
really want me to say exactly at what point of temperature
-------
1150
W. 0. Pipes
rise you get damage to aquatic ecology. I don't have the
particular figure for this.
MR, CURRIE: But I take it that your acceptance
of the mixing zone concept is based on an expectation that
temperatures within the zones themselves will not be as
much as to cause gross pollutional effects. Therefore,
we should be concerned with the temperature inside the
zone itself so that it doesn't get completely out of hand,
DR, PIPES: One of my basic assumptions is that
we are avoiding detrimental pollutional effects, or I will
say ecological changes, that certainly are acceptable in
limited areas,
MR, CURRIE: So you are saying that there may be
some harm within the mixing zone itself,
I was about to ask you if you didn't think that
there was going to be any harm within the mixing zone,
why should we limit the size of the number of these zones?
And I think you have given me the answer. You are saying
not that there won *t be any harm within the mixing zones
but that the area involved is so small that we can afford
to give up that part of the lake,
DR, PIPES: No, I think in the statement if
I can find the particular place well, I can't point out
the page right now. What I am saying is there are certain
-------
1151
W. 0. Pipes
changes which very likely do occur in the mixing zones.
We do not yet have the data to say specifically what these
changes are. We do have the data to say they are of rather
small magnitude and I hope we can find the magnitude pre-
cisely within another year.
What I am saying is that if you take a conservative
position, then any change in the environment becomes a risk.
What I am saying is that it is this concept of risk associated
with the mixing zone and let's minimize the risk asso-
ciated with the mixing zones by limiting the number of mixing
zones until we have further information.
MR. CURRIE: Now, you are interestod in elimin-
ating the size of the zone. I remember Dr. McWhinnie
testifying last week before our Board as to the difficulty
of measuring.
I think this is the kind of point that Chairman
Stein was just raising, measuring the ambient temperature
and where the mixing zone really ends.
I wonder what your opinion would be as to the
relative advisability of doing it the way you suggest by
the limiting of an area for the mixing zone or rather by
determining on the basis of standard models, or something
like that, the approximate area of plume that would be
expected from a given volume and temperature of discharge,
-------
1152
W, 0. Pipes
and then making it an effluent limitation rather than a
mixing zone definition limiting, in fact, directly the
temperature and volume of the discharge, so as to accomplish
roughly your same goal. Wouldn't that be administratively
more feasible?
DR. PIPES: Well, as I understand, let's say, the
approach that he used here, is that this conference is
talking about water quality criteria. What would we like
to achieve in terms of protecting aquatic community and
enhancing the water quality in Lake Michigan? And this
is the intent of the statement is to discuss this area.
Last week, Dr. McWhinnie, I think, probably was
wiser than I was, when she refused to give any specific
recommendations on the stand. I realize in doing this I
am running certain risks, but certainly I am not an expert
in enforcement.
I would say, however, that the informational
studies made and the information and studies I have seen
that other people have made indicate that the area of
influence, the area of measurable temperature influence
from a discharge at a given volume, a given temperature
rise, can vary considerably depending upon the engineering
and the design of the discharge point, and my own experience
with standards is that very often we engineer into law a
-------
1153
W, 0. Pipes
particular type of discharge which prevents further engineer-
ing development. In other words, if you take today's present
models and say, "All right. This is what we can do at the
present time and, therefore, we will inscribe as a law you
do this," Then, this inhibits further engineering ingenuity,
further improvements in the state of the art, and I think
there are well some areas in our society for
instance, building codes, I think, have sort of inhibited
a good many possible improvements in building methods and
materials, and so my own philosophy in this is that as mucn
as possible the criteria should be performance criteria
and the engineers should be given the opportunity to use
their ingenuity to do as good a job as they can. Hope-
fully the job will get better as time goes on, as we learn
more about some of the problems,
MR. STEIN: Well, let me start with your last
point first,
I think possibly you don't know the antecedent of
some of the people on the Board but a lot of us came from
the old Public Health Service operation. As a matter of
fact, I hate to tell you how many years Perry Miller and
I were co-working on septic tanks. So you can see how
far we have gone. And I grew up on these building codes,
I worked on the hygiene codes, and if you want to look at
-------
1154
W. Oc Pipes
something, look at the building codes sometime and see the
restrictive area. I think that given that and given our
experience, we have more or less avoided that in the field
of water. We recognize the limitations and we don't fold
those in.
We have a couple of examples in where the drinking
water coliform standards were so highly regarded in New
York that the New York State Legislature enacted them
into law, and a couple of the New England States have had
the Legislature classify their efforts. Other than that,
I don't think we have much of that any more.
DR. PIPES: Mr. Stein * if I can interject, I
hope this is a very personal opinion I hope there will
be a continuing reevaluation of these standards as we go
along, and we won't get into some of the traps of legislat-
ing these things into permanent standards.
MR, STEIN: We have said that over and over again.
Among other jobs I have, I am in charge of the standards
setting program for the Federal Government. We have said
that over and over again about reevaluating it. This is
why some of the States may be a little irritated on the
reevaluating technique, but we recognize this is not going
in law.
-------
1155
W. 0. Pipes
We recognize always that when you are constructing
any of these plans, it is kind of .a moving target we are
putting before you. It is good one year, but it may not
be good 5 years from now.
Let me get back to the main point. I guess if you
are around this operation long enough, things begin repeating
themselves. But when we first went out, in dealing with the
pulp and paper industry in the Pacific Northwest, I can still
see in my mind's eye, Mr. Vinton Bacon, who I think was in
Chicago for a while and before that he was working for the
pulp and paper industry in the Pacific Northwest, between
the time he was in Chicago and the head of the California
agencyo
Mr, Vinton Bacon, in presenting an argument for
the pulp and paper industry with a big map of Puget Sound,
said, "Look at this big sound." And then he would draw a
little circle outside the outfall of every paper plant and
say, "This is the little area of risk you are taking with
the bay with Puget Sound." And this was the
argument, then. And you might want to read the history of
that as to what happened subsequently in that case.
But I don't think what you are saying is very
much different, and we have run into that before.
DR. PIPES: I think the big difference in this
-------
1156
W. 0. Pipes
case, Mr, Stein, is that the evidence we have does not show
pollutional effects of these thermal discharges in Lake
Michigan.
MR. STEIN: I think if you read Mr. Bacon's state-
ment at the time he said practically the same thing. "The
evidence we have" as a matter of fact, he showed his
charts of salmon and stuff no pollutional effect. That
is true<> I am not arguing the validity.
But here is what I want to get down to, sir<>
I want to get down to your conclusion, the summary. "I
believe that the appropriate regulation at this time is one
which limits the number of plants located around the lake
until the presently planned studies are completed and
evaluated, and limits each plant to a reasonable mixing
zone and a 5 degree Fahrenheit temperature rise at the edge
of that mixing zone»M
Now, if we have this 5-degree mixing zone, would
there be any plant that you know of under construction now
on the planning boards or proposed that would have to put
in any cooling devices or could just get by with this once-
through shot?
DR. PIPES: There are only two plants with which
I am really quite familiar: This is Waukegan Station which
has been operating for 40 years and Zion Station which is
-------
1157
W. 0. Pipes
under construction.
I have no personal knowledge of the mixing zones
or the discharge plumes from the other plants. Now,
this
MR. STEIN: I think the basic issue is whether
the regulatory agencies are going to require the plants
to put in cooling devices. After hearing some of the
other testimony and in talking about this 5-degree temper-
ature at the end of the mixing zone an allowable operation,
I would take it, unless I hear to the contrary^ that we
ought not require any special cooling devices.
Therefore, as Mr. Currie said, you don't have
to have too many of these, but we limit the number of
the plants.
Now, here is what you are proposing. It is
precisely that area over which the water pollution control
people and the ecological people have the least amount
of jurisdiction. We don't set the plant sites initially.
There are other agencies that do it. Traditionally we
have not gotten into land use but let anyone use something
for a land use if they can meet ecological considerations.
In other words, what you are suggesting to this
-------
W. 0. Pipes
board is that the limitation put on the plants to save the
lake be in the area of the restriction on land use. But
when we have a land use, we have a relatively broad operation
in the mixing zone in order that no cooling devices will be
required,
DR. PIPES: Well, my consideration on the mixing
zone what I said was again, going in the direction in
which the scientific evidence indicates and I also said
rather clearly that after the two days of hearing in Illinois
last Friday and Saturday and the three days of hearing now,
I realize that there are inputs other than scientific, but
I am just expressing the scientific input.
MR. STEIN: Are there any other comments or
questions?
If not
MR. PURDY: I have one question, Professor Pipes.
Your recommendation with respect to the mixing
zones with your recommendations with respect to the
mixing zones, do you believe that it would be possible to
have infrared flights made to determine whether or not the
mixing zones are not being exceeded in size?
DR. PIPES: Well, infrared flyovers are certainly
one way of measuring temperature. I have not studied the
question of how fine a measurement in other words, the
-------
1159
W. 0, Pipes
accuracy of locating a point by infrared flyover technique
at small temperature rises. I know that surface temperature
measurements can be made this way.
MR. STEIN: Are there any other comments or ques-
tions? Any from the audience?
If not, thank you very much, Professor Pipes.
Mr. Bane, does that conclude the
MR. BANE: Yes, that concludes the Commonwealth
Edison presentation. We wish to thank the conferees for
their patience in listening to us. I think Mr. Petersen
will now
DR. PIPES: Excuse me. There are some additional
copies of the study plan that we were talking about yesterday.
MR. STEIN: By the way, I wish to express my
appreciation to you, Mr. Bane, for interrupting your presen-
tation to accommodate others, and we appreciate the presen-
tation and the spirit in which it was made and thank you
very much for cooperating with us.
MR. BANE: Thank you.
Mr. Petersen, I think, will handle the program
from now on.
MR, STEIN: Yes.
MR. PETERSEN: In accordance with the previous
arrangement, Mr. Chairman, Witnesses Aschoff and Patterson
-------
1160
0, Ko Petersen
of Consumers Power Company of Sargent and Lundy for
Consumers Power Company are now made available for such
questions as may be asked.
MR. STEIN: Are there any other questions?
If not, does that conclude the power company
presentation?
MR. PETERSEN: No, there will be two more
presentations, I think, of a total of about 45 to 50
minutes total at most. Wisconsin Public Service Company
and Wisconsin Electric Power Company have not appeared and
as far as I know those will be the last of them.
MR. STEIN: Well, I think in view of the time,
let us -- would you come up here? and let us talk to
the States and let's take an in-place recess.
(Short recess.)
MR. STEIN: Let's reconvene, please.
Mr. Petersen, will you continue?
MR. PETERSEN: The next presentation will be by
Mr. Evan W. James, Vice President, Power Generation and
Engineering, for Wisconsin Public Service Corporation.
-------
1161
E. W. James
STATEMENT OP EVAN W. JAMES, VICE
PRESIDENT, POWER GENERATION AND
ENGINEERING, WISCONSIN PUBLIC
SERVICE CORPORATION, GREEN BAY,
WISCONSIN
MR. JAMES: Mr. Chairman, conferees, ladies
and gentlemen in attendance at this workshop. I am
Evan W. James, Vice President, Power Generation and
Engineering, with the Wisconsin Public Service Corporation.
I appreciate having the opportunity to state briefly our
position and a few thoughts. I will appreciate having
these remarks made part of the record.
MR. STEIN: Without objection, these remarks
will be entered into the record as if read.
(The .remarks above referred to follow in their
entirety.)
-------
SEK-10 1162
9-25-70
STATEMENT OF WISCONSIN PUBLIC SERVICE CORPORATION
PREPARED FOR WORKSHOP SESSION OF THE FEDERAL-STATE
ENFORCEMENT CONFERENCE ON POLLUTION OF LAKE MICHIGAN
SCHEDULED FOR THE WEEK OF SEPTEMBER 28, 1970
Wisconsin Public Service Corporation, whose
address is P.O. Box 700, Green Bay, Wisconsin 54305, is
a public utility organized under the laws of the State
of Wisconsin. It is engaged principally in the produc-
tion, transmission and distribution of electricity and
the purchase and distribution of natural gas. It also
operates a small urban bus system in the Green Bay area.
In the 12 months ended May 31, 1970, it received 63.7%
of its operating revenues from the sale of electricity,
35.970 from the sale of gas and 0.4% from its bus opera-
tion.
The Corporation's total investment in utility
plant at the end of 1969 was $311,627,418.
The Corporation serves approximately 210,000
electric customers and 116,000 gas customers in north-
eastern Wisconsin and an adjacent part of Upper Michigan.
The largest cities served are Green Bay, Sheboygan,
Oshkosh and Wausau, It furnishes electricity in all of
these cities except Sheboygan and (feas in all except Wausau.
The Corporation has a total capability of elec-
tric power available from generating units wholly or
-------
1163
jointly owned of 760,000 kilowatts. Of relevance in this
matter are the Pulliam fossil-fired steam plant at Green
Bay located at the confluence of the Fox River and Green
Bay wholly owned by the Corporation and the Edgewater
fossil-fired steam plant unit No. 4 at Sheboygan on the
shores of Lake Michigan owned jointly with Wisconsin Power
& Light Company, this Corporation having a 31.8% interest.
The maximum load on the Corporation's electric system ,for
the 12 months ended May 31, 1970, on a 1-hour integrated
basis was 622,000 kilowatts on February 16, 1970. A new
peak of 651,000 kilowatts was reached in early August 1970.
The Corporation is a party to a power pool agree-
ment with Wisconsin Power & Light Company and Madison Gas
& Electric Company under which these three utilities com-
menced sharing reserve generating capacity on January 1,
1970. Pursuant to this agreement the Corporation is build-
ing for the pool a nuclear generating plant near Kewaunee
on the west shore of Lake Michigan. This unit will have
a net generating capability of 527,000 kilowatts which
will be shared by the three pool members, this Corporation
having a 41.2% interest.
Pulliam Plant
The Pulliam plant originally designated as the
Bayside plant was placed in service in 1926, the first
-2-
-------
1164
installation consisting of two 10,000 kilowatt turbo-
generators. Coal was originally delivered by railroad,
but in 1928 a dock was constructed and since that time
fuel has been delivered by lake freighter.
A third generating unit was placed in opera-
tion in 1943. This added 30,000 kilowatts to the plant's
capability. In 1947 a fourth unit, also 30,000 kilo-
watts, was placed in operation. Construction of a fifth
unit of 50,000 kilowatt capacity was completed in 1949
and a sixth of 62,500 kilowatt capacity in 1951. In 1958
a seventh unit of 75,000 kilowatt capacity, and in 1964
an eighth unit of 125,000 kilowatt capacity were completed.
The capacity of Pulliam's eight units is listed
as 392,500 kilowatts. Construction of all the units was
made with the approval of the Public Service Commission
of Wisconsin and pertinent federal and state regulatory
bodies.
The Pulliam plant is located in an industrial
area in the northwest section of the City of Green Bay.
A residential area commences about 3/4 of a mile away
to the south. The site is low land.with the area immedi-
ately to the west of the plant until recent years being
swamp land. This land is being filled by normal processes
and by extensive transfer of river bottom silt.
With the plant being located at the mouth of
-3-
-------
1165
the Fox River as it enters Green Bay, the Bay being a
part of Lake Michigan, it has intakes on both the River
and Bay fronts. The circulating water conditions vary
considerably with wind and season. Water inlet tempera-
tures vary from 33°F to 83°F. The temperatures, however,
exceed 80°F only a small fraction of the time. For the
period July 1, 1969 to June 30, 1970 the inlet water
temperatures were as follows: They exceeded 70°F 15.62%
of the time; 75°F 7.40% of the time. During this period
there was no intake at a temperature in excess of 80°F.
Normal circulating water use is 480,000,000
gallons a day with a maximum temperature gradient + 16°F.
During the five summer months the high monthly average
AT is 11.4°F; during the seven colder months it is
13.7°F; the yearly average is 12.8°F. The discharge from
the plant is directed to the River side where mixing
occurs in the River stream.
A number of the comments which follow and which
are directly related to the Kewaunee Nuclear Energy Plant
have application to Pulliam also.
Kewaunee Nuclear Energy Plant
Under the terms of the power pool agreement
previously referred to, this Corporation became the
-4-
-------
1166
builder of the nuclear plant now in the course of con-
struction on the Lake Michigan shoreline approximately
8 miles south of the City of Kewaunee. An application
to construct this 527,000 kilowatt (net) nuclear plant
(the reactor is a Westinghouse pressurized water reactor)
was made to the Public Service Commission of Wisconsin
in March 1967 (Docket CA-4759 and 2 WP 2570), and to the
Atomic Energy Commission in August of 1967 (Docket 50-305)
Approval was received from the Public Service Commission
in October 1967 and from the Atomic Energy Commission in
August 1968. Ownership of the plant is being shared
41.2% by Wisconsin Public Service Corporation, 41.0% by
Wisconsin Power & Light Company, and 17.87o by Madison Gas
& Electric Company, The plant is planned for commence-
ment of operation in October 1972. Responsibility for
construction and operation of the plant rests with this
Corporation. It has thus developed contacts with other
interested governmental units such as the Corps of Engi-
neers and the Wisconsin Department of Natural Resources.
It has procured all permits and approvals necessary to
this stage of construction
Selection of the Kewaunee site was primarily
determined because of its proximity to the electrical
-5-
-------
1167
system of the Wisconsin pool, the availability of Lake
Michigan cooling water and the favorable topography of
the area,
The plant is being constructed in a sparsely
populated region devoted to agriculture and dairy farm-
ing. The City of Green Bay is 30 miles northwest, and
Milwaukee is about 90 miles southwest.
Temperatures taken at the intake to the City
of Green Bay water system which is located in Lake
Michigan north of the City of Kewaunee indicate that
the temperature of the Lake exceeds 50°F only 3270 of
the time, 55 °F 19%, and 59°F only 11%. The average
temperature range based on ten years' experience 1957-
1967 is from an average low of 34 °F to an average high
of 62°F. The maximum experienced during this period was
68°F and this occurred on only one occasion.
Although the latest technology available is
being incorporated into the Kewaunee plant, its thermal
efficiency, as is true of large nuclear stations gen-
erally, is only about flB* As a consequence, about
U £>?%
(IB of the heat generated in the plant has to be dis-
posed of in one form or another. A major portion of
this heat is removed through the electric power plant's
-6-
-------
1163
circulating water system which passes the water through
a steam surface condenser where the heat is absorbed.
The circulating water system of the Kewaunee plant draws
Lake Michigan water from an area approximately 1,750
feet from the shoreline at a depth of 15 feet. The
water flows through a submerged 10-foot diameter steel
pipe at a rate of 400,000 gallons per minute during
summertime operation, and 270,000 gallons per minute
during the winter. The water flows from the steel pipe
under the lake bed into an open forebay into the screen-
house structure. Equipment for cleaning the water and
the circulating water pumps are also located in the
screenhouse. The water is pumped into the turbine build-
ing where it is passed through the steam surface con-
denser and then returned to the Lake. The system relies
on the natural effect of a syphon for return of the water
to the Lake.
Based upon design data during the five summer
months, the maximum AT will be 19. ST. The average
AT for the summer months will be considerably less.
-7-
-------
1169
An extensive environmental study of the area sur-
rounding the Kewaunee plant has been carried on dating back
to almost four years prior to start-up in order to obtain
background information. The company will continue a program
of monitoring the surroundings for the life of the plant to
be certain plant operation has no adverse effects.
Without going into extensive detail we can give
a brief explanation of what the company's environmental
program is with respect to discharges at Kewaunee. The
company has four areas of environmental effort under way
which can be summarized as follows:
1. A meteorological study by company engineers
and by NUS Corporation of Rockville, Maryland, has been
and is in progress in which the winds in the area are con-
tinually monitored so their direction and variances can
be studied in detail.
2. A background information study of the lake
area adjacent to the site is under way. This study is
conducted by personnel of the University of Wisconsin -
Milwaukee under the provisions of a grant from the three
parties to the Wisconsin power pool. This study^ includes
obtaining pertinent data and information on the water,
lake bottom conditions, and plant and animal life in the
water and underwater areas.
-8-
-------
1170
3. A preoperational study of the site and shore
area is being conducted by Industrial Bio-Test Laboratories
of Nbrthbrook, Illinois. The purpose of this program is to
establish background measurements for land and shore areas
near the site. This study includes obtaining data and in-
formation on airborne particulates, well water, surface
waters, lake bottom organisms, bottom sediments, slime,
vegetation and soil. This work is being continued after
September 1, 1970 on an even broader basfis.
4. Kewaunee is also participating in a general
study of Lake Michigan as it may be affected by nuclear
plants through work being performed by the Research Depart-
ment of the University of Michigan. This study which covers
the lower two-thirds of Lake Michigan is being financed by
the six utilities (and their associates) who are or will
be building nuclear plants on the shores of Lake Michigan.
Sampling includes water and where possible bottom samples.
A portion of this effort has been completed and will be
reported on in the near future.
As respects Kewaunee both the intake and dis-
charge structures have been designed through the aid of
hydraulic models to achieve efficient flow of water so as
to have the least possible effect on both the shore and
the lake. Of interest in this connection is the fact
-9-
-------
1171
that environmental studies thus far made indicate that
apparently the lake bed and waters in the Kewaunee area
do not contain significant quantities of plant, fish or
animal life.
As already pointed out, environmental surveillance
programs will be continued after operation of Kewaunee
begins so that there will be continuing data available.
This will enable the utility and the regulatory bodies to
evaluate the impact of the plant's operation and thus, if
necessary be able to prescribe changes in plant or proce-
dures.
To conclude, there are two points to be emphasized:
1. Lake Michigan cooling water is a natural resource avail-
able for use to benefit the public in the generation of
reasonably-priced electric energy - there being, as we
believe, based on credible evidence, no adverse effects of
such use. Both Pulliam and Kewaunee plants have been
designed to use this resource, and any substantial limita-
tion on its use will interfere drastically with their
operation.
2. This corporation is following the regulations of the
State of Wisconsin respecting thermal emissions, which
regulations have been approved by the United States Depart-
ment of the Interior, and we are firmly convinced that
-10-
-------
1172
no modifications of such regulations are required on the
basis of information and data presently available.
-11-
-------
1173
E. W. James
MR. JAMES: Wisconsin Public Service
Corporation, whose address is P. 0. Box 700, Green Bay,
Wisconsin 5^305, is a public utility organized under the
laws of the State of Wisconsin. It is engaged
principally in the production, transmission and distribution
of electricity and the purchase and distribution of
natural gas. It also operates a small urban bus
system in the Green Bay area. In the 12 months
ended May 31, 1970, it received 63.7 percent of its
operating revenues from the sale of electricity, 35.9
percent from the sale of gas and 0.4 percent from its
bus operation.
The corporation's total investment in utility
plant at the end of 1969 was $311,627,^18.
The corporation serves approximately 210,000
electric customers and 116,000 gas customers In north-
eastern Wisconsin and an adjacent part of Upper Michigan.
The largest cities served are Green Bay, Sheboygan,
Oshkosh and Wausau. It furnishes electricity in all of
these cities except Sheboygan and gas in all except
Wausau.
The corporation has a total capability of
electric power available from generating units wholly or
jointly owned of 760,000 kilowatts. Of relevance in this
-------
1174
E. W. James
matter are the Pulliam fossil-fired steam plant at Green
Bay located at the confluence of the Pox River and
Green Bay wholly owned by the corporation and the Edgewater
fossil-fired steam plant unit No. 4 at Sheboygan on the
shores of Lake Michigan owned Jointly with Wisconsin Power
and Light Company, this corporation having a 31.8 percent
interest. The maximum load on the corporation's electric
system for the 12 months ended May 31, 1970, on a 1-hour
integrated basis was 622,000 kilowatts on February 16,
1970. A new peak of 651,000 kilowatts was reached in early
August 1970.
The corporation is a party to a power pool
agreement with Wisconsin Power and Light Company and
Madison Gas and Electric Company under which these three
utilities commenced sharing reserve generating capacity
on January 1, 1970. Pursuant to this agreement the
corporation is building for the pool a nuclear
generating plant near Kewaunee on the west shore of Lake
Michigan. This unit will have a net generating
capability of 527,000 kilowatts which will be shared by
the three pool members, this corporation having a 41.2
percent Interest.
Pulliam Plant
The Pulliam Plant originally designated as the
-------
1175
E. W. James
Bayside plant was placed in service in 1926, the first
installation consisting of two 10,000 kilowatt turbo-
generators. Coal was originally delivered by railroad,
but in 1928 a dock was constructed and since that time
fuel has been delivered by lake freighter.
A third generating unit was placed in operation
in 19*»3. This added 30,000 kilowatts to the plant's
capability. In 19*17, a fourth unit, also 30,000 kilowatts,
was placed in operation. Construction of a fifth unit of
50,000 kilowatt capacity was completed in 19^9, and a
sixth of 62,500 kilowatt capacity in 1951. In 1958, a
seventh unit of 75,000 kilowatt capacity, and in 1964, an
eighth unit of 125,000 kilowatt capacity were completed.
The capacity of Pulllam's eight units is
listed as 392,500 kilowatts. Construction of all the
units was made with the approval of the Public Service
Commission of Wisconsin and pertinent Federal and State
regulatory bodies.
The Pulllam plant is located in an Industrial
area in the northwest section of the city of Gree"n Bay.
A residential area commences about 3/4 of a mile away
to the south. The site is low land with the area
immediately to the west of the plant until recent years
being swamp land. This land is being filled by normal
-------
1176
E. W. James
processes and by extensive transfer of river bottom silt.
With the plant being located at the mouth of
the Fox River as it enters Green Bay, the Bay being a
part of Lake Michigan, it has intakes on both the
river and bay fronts. The circulating water conditions
vary considerably with wind and season. Water inlet
temperatures vary from 33 degrees P. to 83 degrees P.
The temperatures, however, exceed 80 degrees P. only
a small fraction of the time. For the period July 1,
1969, to June 30, 1970, the inlet water temperatures were
as follows: They exceeded 70 degrees F. 15.62 percent
of the time; 75 degrees F. 7.40 percent of the time.
During this period there was no intake at a temperature
in excess of 80 degrees F.
Normal circulating water use is 480 million gallons
a day with a maximum temperature gradient + 16 degrees F.
During the five summer months the high monthly average
Delta T is 11.4 degrees P.; during the seven colder months
it is 13.7 degrees P.; the yearly average is 12.8 degrees
F. The discharge from the plant is directed to the river
side where mixing occurs in the river stream.
A number of the comments which follow and which
are directly related to the Kewaunee nuclear energy plant
have application to Pulliam also.
-------
1177
E. W. James
Kewaunee Nuclear Energy Plant
Under the terms of the power pool agreement
previously referred to, this corporation became the
builder of the nuclear plant now In the course of
construction on the Lake Michigan shoreline approximately
8 miles south of the city of Kewaunee. An application
to construct this 527,000 kilowatt (net) nuclear plant
(the reactor is a Westlnghouse pressurized water
reactor) was made to the Public Service Commission of
Wisconsin in March 196? (Docket CA-4759 and 2 WP 2570),
and to the Atomic Energy Commission in August of 1967
(Docket 50-305). Approval was received from the Public
Service Commission in October 1967, and from the Atomic
Energy Commission in August 1968. Ownership of the
plant is being shared 41.2 percent by Wisconsin Public
Service Corporation, 41.0 percent by Wisconsin Power and
Light Company, and 17.8 percent by Madison Gas and
Electric Company. The plant is planned for commencement
of operation in October 1972.
Responsibility for construction and operation of
the plant rests with this corporation. It has thus
developed contacts with other interested governmental
units such as the Corps of Engineers and the Wisconsin
Department of Natural Resources. It has procured all
-------
117S
E. W. James
permits and approvals necessary to this stage of
construction.
Selection of the Kewaunee site was primarily
determined because of its proximity to the electrical
system of the Wisconsin pool, the availability of Lake
Michigan cooling water and the favorable topography of
the area.
The plant is being constructed in a sparsely
populated region devoted to agriculture and dairy
farming. The city of Green Bay is 30 miles northwest, and
Milwaukee is about 90 miles southwest.
Temperatures taken at the intake to the city
of the Green Bay water system which is located in Lake
Michigan north of the city of Kewaunee indicate that the
temperature of the lake exceeds 50 degrees P. only 32
percent of the time, 55 degrees P. 19 percent, and 59
degrees P. only 11 percent. The average temperature
range based on 10 years' experience 1957-1967 is from an
average low of 3^ degrees P. to an average high of 62
degrees P. The maximum experienced during this period
was 68 degrees P. and this occurred on only one
occasion.
Although the latest technology available is
being incorporated into the Kawaunee plant, its thermal
-------
1179
E. W. James
efficiency, as is true of large nuclear stations
generally, is only about 33.3^ percent. As a consequence,
about 66-67 percent of the heat generated in the plant
has to be disposed of in one form or another. A major
portion of this heat is removed through the electric
powerplant's circulating water system which passes the
water through a steam surface condenser where the heat
is absorbed. The circulating water system of the Kewaunee
plant draws Lake Michigan water from an area approximately
1,750 feet from the shoreline at a depth of 15 feet. The
water flows through a submerged 10-foot diameter steel
pipe at a rate of 400,000 gallons per minute during
summertime operation, and 270,000 gallons per minute
during the winter. The water flows from the steel pipe
under the lake bed into an open forebay into the screen-
house structure. Equipment for cleaning the water and
the circulating water pumps are also located in the
screenhouse. The water is pumped into the turbine building
where it is passed through the steam surface condenser
and then returned to the lake. The system relies on the
natural effect of a syphon for return of the water to the
lake.
Based upon design data during the five summer
months, the maximum Delta T will be 19.3 degrees P. The
-------
E. W. James
average Delta T for the summer months will be considerably
less.
An extensive environmental study of the area
surrounding the Kewaunee plant has been carried on dating
back to almost ^ years prior to start-up in order to
obtain background information. The company will continue
a program of monitoring the surroundings for the life
of the plant to be certain plant operation has no adverse
effects.
Without going into extensive detail we can give
a brief explanation of what the company's environmental
program is with respect to discharges at Kewaunee. The
company has four areas of environmental effort under way
which can be summarized as follows:
1) A meteorological study by company engineers
and by NUS Corporation of Rockville, Maryland, has been
and is in progress in which the winds in the area are
continually monitored so their direction and variances can
be studied in detail.
2) A background information study of the lake
area adjacent to the site is under way. This study is
conducted by personnel of the University of Wisconsin,
Milwaukee, under the provisions of a grant from the three
parties to the Wisconsin power pool. This study includes
-------
1131
E. W. James
obtaining pertinent data and Information on the water,
lake bottom conditions, and plant and animal life in the
water and underwater areas.
3) A preoperational study of the site and shore
area is being conducted by Industrial Bio-Test
Laboratories of Northbrook, Illinois. The purpose of this
program is to establish background measurements for land
and shore areas near the site. This study Includes
obtaining data and information on airborne particulates,
well water, surface waters, lake bottom organisms,
bottom sediments, slime, vegetation and soil. This work
is being continued after September 1, 1970, on an even
broader basis.
4) Kewaunee is also participating in a general
study of Lake Michigan as it may be affected by nuclear
plants through work being performed by the research
department of the University of Michigan. This study
which covers the lower two-thirds of Lake Michigan is being
financed by the six utilities (and their associates) who
are or will be building nuclear plants on the shores of
Lake Michigan. Sampling includes water and where possible
bottom samples. A portion of this effort has been completed
and will be reported on in the near future.
As respects Kewaunee both the intake and
-------
1132
E. W. James
discharge structures have been designed through the aid of
hydraulic models to achieve efficient flow of water so
as to have the least possible effect on both the shore
and the lake. Of interest in this connection is the
fact that environmental studies thus far made indicate
that apparently the lake bed and waters in the Kewaunee
area do not contain significant quantities of plant,
fish or animal life.
As already pointed out, environmental
surveillance programs will be continued after operation
of Kewaunee begins so that there will be continuing data
available. This will enable the utility and the
regulatory bodies to evaluate the impact of the plant's
operation and thus, if necessary, be able to prescribe
changes in plant or procedures.
In this connection, I should advise you that
our position on future planning for Lake Michigan is
directly opposed to certain suggestions made by some
speakers recently about withholding further development
on the lake for some more or less indeterminate time.
We are satisfied that the evidence now available
calls for no such drastic moves in the iace of the growing
demands for electric service, and the capital demands on our
economy. Surely reasonable regulatory rules can be
-------
1133
E. W. James
established and monitoring of the environment conditions
so that no damage from the thermal discharge can result.
This I might add, is the fact as respects the northern
part of the lake where our installations are and will be
constructed.
Evidence of any damage or potential damage
to the cold northern half of the lake is simply nonexistent.
Frankly, I have no information, no data which permits
me to go to the Board of Directors of the Wisconsin Public
Service Corporation or to the boards of our partners in
the Kewaunee project to request millions of dollars to
add cooling towers and to inform them that I am in turn
decreasing the capacity and the efficiency of the Pulliam
or the Kewaunee plants.
To conclude, there are two points to be
emphasized:
1) Lake Michigan cooling water is a natural
resource available for use to benefit the public in the
generation of reasonably-priced electric energy there
being, as we believe, based on credible evidence, no adverse
effects of such use. Both Pulliam and Kewaunee plants
have been designed to use this resource, and any
substantial limitation on its use will interfere
drastically with their operation.
-------
1134
E. W. James
2) This corporation is following the regulations
of the State of Wisconsin respecting thermal emissions,
which regulations have been approved by the United States
Department of the Interior, and we are firmly convinced
that no modifications of such regulations are required
on the basis of information and data presently available.
I thank you, Mr. Chairman.
MR. STEIN: Thank you, Mr. James, for a
very forthright statement.
I don't think there is any doubt of what your
position is and where you stand.
Would you identify yourself for purposes of
the reporter?
MR. McKERSIE: My name is Jerome McKersie.
Mr. James, on page 9 you mentioned the
preoperational study by Industrial Bio-Test Laboratories,
and it is our knowledge that this preoperational study
dealt strictly with radioactivity. Are you saying here
that the study will be background information on thermal
measurements and so forth now?
MR. JAMES: Yes, to the present point, Mr.
McKersie, it has largely been pointed to the
radiological* There are some areas of it which go into
the thermal and the thermal aspects of the study are part
-------
1185
£. W. James
of the broadening that I referred to. They have already
broadened their study in that particular area.
MR. STEIN: Are there any other comments or
questions from the panel?
Are there any from anyone in the audience?
If not, thank you very much.
MR. JAMES: Thank you, sir.
MR. PETERSEN: The next presentation will
be by Mr. Sol Burnstein correction, Burstein, Senior Vice
President, Wisconsin Electric Power Company.
-------
1186
S. Bursteln
STATEMENT OP SOL BURSTEIN, SENIOR
VICE PRESIDENT, WISCONSIN ELECTRIC
POWER COMPANY, MILWAUKEE, WISCONSIN
MR. BURSTEIN: Mr. Stein and members of the
conference, ladies and gentlemen.
My name is Sol Burstein. I am Senior Vice
President of Wisconsin Electric Power Company, headquartered
in Milwaukee, Wisconsin. For further information as to
the nature of the utilities I represent, the territory and
number of customers we serve and other aspects of our
operation, I refer you to my statement at the Third
Session of the Lake Michigan Conference held in Milwaukee
on March 31» 1970. Suffice it to say, that as the largest
utility in the State of Wisconsin, most of the two million
people we serve and all of our steam powerplants are
irretrievably tied to the west shore of Lake Michigan.
This conference has been called basically because
the industrial users of Lake Michigan waters vigorously
opposed the policy statement announced by the Department
of the Interior at the Executive Session of this
conference held on May 7, 1970. That statement as quoted
-------
1187
S. Burstein
to us is as follows:
"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
F. rise over ambient at the point of discharge. This will
preclude the need for mixing zones."
If this, indeed, remains the position 6f the
Department of the Interior today, we are still opposed
to its implementation as we were at the time of its
announcement. Nothing has occurred since then either in the
form of new data, new interpretations of existing facts
or breakthroughs in alternative systems that provide a
legitimate basis for reconsideration.
As we understand, these sessions are beyond
the normal context of the proceedings authorized by
statute. We believe they proceed from the May 7 Executive
Session and the requests at that time and since then
by nonstate participants for opportunity to be heard.
These sessions are being called "workshops," which
indicate an opportunity for information and discussion, and
we are pleased to participate on this basis.
It is recognized that events of this last week
have considerably changed the approach many of us
had taken in preparation for this discussion. Following
-------
1188
S. Burstein
the May 7 policy statement, many of us concerned with Lake
Michigan waters met with Assistant Secretary Klein and
others in the Deparment of the Interior in attempts to
develop an understanding of the basis of the Department
position. We were advised that the Department would
issue a so-called "white paper" and would schedule further
hearings at which opportunity for discussions would take
place. The hearings were postponed to this date and
the intervening silence from the Department of the
Interior on the issuance of the "white paper" prompted
us, and I believe others, to proceed on the basis that
no position paper by the Department would be available in
time for this meeting. Distribution of the two reports,
almost on the eve of these sessions, together with the
announcement of the resignation of Assistant Secretary
Klein, must be confusing to others, as it is to me.
MR. STEIN: I don't like to interrupt again,
and you have a lot of points here, but if you want to take
the opportunity to link the resignation of the Assistant
Secretary with these reports and you think there is some
kind of connection or something to it, I guess that is
your privilege.
MR. BURSTEIN: In this respect, sir, I can only
report what I have read.
-------
1189
S. Burstein
MR. STEIN: And you have read there is a
connection?
MR. BURSTEIN: No, sir.
MR. STEIN: Then what kind of a non sequitur
is this? I don't mind what is said objectively, but if
you are dealing on the basis of personalities, what does
that sentence mean? We have kept this discussion and
I think we have had fine cooperation from the
industry from personalities up to now. I can't
understand what the purpose is.
MR. BURSTEIN: I don't mean to engage in
personalities, sir. It was just that the reports were
issued and the newspaper announcement of Mr. Klein's
resignation, who was a proponent of the policy as far as
we know, occurred coincidentally.
I attach no other significance to that
coincidence.
MR. STEIN: Well, you have said they were
confusing.
MR. BURSTEIN: Yes, sir.
MR. STEIN: All right, go on.
MR. BURSTEIN: I have said we were opposed to
the implementation of the May 7 policy statement or guide-
line or whatever you may wish to call it. I think it is
-------
1190
S. Burstein
important to ask why. In these days of environment
politics and general utility criticism it would be
expedient and certainly considerably easier for us to
either agree with the policy statement, or at least
take no position at all. Assuming all of us in industry
could quickly pass on the increased construction and
operating costs to our customers, as some have charged,
what would we and our stockholders have to lose? In
fact, some have said we might be able to make more
profits on a larger rate base. So why do we appear in
opposition?
It is simply that adoption of this policy will
place undue economic burdens on the public and on other
natural resources and other aspects of our environment
without any measurable compensatory benefit. We would
be pouring hundreds of millions of dollars and millions
of tons of fuel, mineral and other resources into systems
that on the basis of present knowledge and, in our considered
analyses and judgments, would gain us practically no
yield.
We have, on past occasions, participated in the
Lake Michigan Conferences and have indicated what we
believe to be responsible and realistic positions. In
our March 31 appearance we made specific observations and
-------
1191
S. Burstein
recommendations concerning the objectives of the Four-State
Lake Michigan Conference, among which were the following:
1) An adequate and reliable power supply
is vital to this region and to the Nation, and electric
utilities must have the use of adequate sites for power-
plants needed to meet these requirements.
2) Problems associated with plant locations
concern Federal and State regulatory agencies having
responsibility in regard to electric power supply, and
also concern agencies having responsibility for
environmental quality. These are not necessarily mutually
conflicting concerns and, in the total public interest,
they must receive appropriate consideration and, if
necessary, compromise.
The Federal Water Pollution Control Act
requires that standards of water quality 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." In enforcing these standards, the
courts are required to give "due consideration to the
practicability and to the physical and economic
feasibility of complying with such standards."
Despite these clear-cut statutory provisions and
-------
1192
S. Bursteln
despite the testimony offered in previous sessions, the
Department of the Interior has chosen to pursue only
the single course which it believes will protect certain
species of fish in Lake Michigan. Is this the only
objective, and does this discharge the obligations of the
Federal Government in respect to Lake Michigan?
We have looked to the Department of the Interior
for leadership in helping to evaluate the present status
of Lake Michigan waters and to assist in defining
criteria for the future utilization of this vital resource,
The Department has to date responded with an arbitrary
position that has forced users of Lake Michigan waters
to be in opposition, sometimes even with each other
and leaving the general public dismayed and confused
in the midst of these conflicts.
We are currently building two 500,000 kilowatt
units known as the Point Beach Nuclear Plant, one of
which is complete and ready for operation. Its operation
is being delayed because of a petition for intervention
filed by interested citizens who are concerned with the
environmental effects of this facility, among which
are the thermal discharges from the plant. We believe
that a lack of a clear-cut, realistic and constructive
policy by the Department of the Interior is partially
responsible for this delay since the absence of such
-------
1193
S. Burstein
policy forces concerned individuals to seek resolution
of these matters in other licensing procedures. In
recent days, the shortage of electric power in»the eastern
part of the united States has received national attention
and is due entirely to the lack of adequate generating
capacity, a major cause of which has been similar
unclear and indefinite environmental criteria.
We regret not having sufficient time to give
deserving review to the contents of the two reports
distributed by the Federal Water Quality Administration
on September 18. We believe, and recommend to this
Conference, that some provision will have to be made for
future opportunity to present detailed discussion and
comment. Our quick inspection of these reports, however,
causes us to make the following comments:
1) We are pleased to note that the 1 degree
P. temperature rise limit and reference to mixing zones
have disappeared from the recommendations of the
Department, leaving the general criteria "for ecological
reasons that no significant discharge of waste heat into
Lake Michigan should be permitted." I, therefore, conclude
that the only item on which we need to agree is what
constitutes a significant discharge of waste heat.
2) The report specifies that currently (1968) a
-------
1194
S. Burstein
value of .05 B.t.u./sq. ft. per day of waste heat Is added
to Lake Michigan and that this would grow to .52 B.t.u./sq.
ft. per day in the year 2000, applied to the entire lake
surface. This represents 1/7,000 of the natural rate of
heat input today, and with the tenfold increase predicted
would be only 1/700 of the natural heat addition in the
year 2000. No case has or can be made for the effects of
these powerplant thermal discharges on Lake Michigan as
a whole. We note that the projections for present and
future waste heat additions are based on a 100-percent
capacity operation. We wish we could operate this way.
Our system capacity factor is currently about 65
percent and, with more air conditioning and not enough
electric heating, we expect it to drop in the next decade.
Thus, estimates of 1*31 billion B.t.u./hr.
calcualted for the year 2000 are more nearly like 250
billion B.t.u., and would then result in nearly half the
fractions referred to In subsequent arithmetic comparisons.
Using the report figures, industrial heat inputs to
Lake Michigan, as noted above, are essentially
insignificant.
3) The report attempts to define an inshore
zone and a beach zone for comparative temperature arithmetic
purposes only. We disagree with the opinion that says
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S. Burstein
heat additions, as presently proposed (which we interpret
to mean once-through cooling for steam powerplants) is
essentially a cumulative problem. We note that the report
has observed natural temperature changes at inshore sur-
face water at as much as * 18 degrees P. in less than
2k hours. Our records indicate even greater natural
temperature variations along shorelines over relatively
few hours. Changes in the wind direction, the report
states, induce those large changes in the temperature of
the entire inshore zone, further demonstrating the
insignificant contribution of powerplants.
I submit that shoreline turbidity and the
erosion of vast quantities of land along the Wisconsin
shore of Lake Michigan have several orders of magnitude
greater effect on the ecology of this region than any
temperature change.
4) We have not been able to substantiate
the theory that the principal amount of waste heat is
passed to the water mass and only a small portion is
dissipated directly from the plume to the atmosphere.
Our plume measurements and laboratory models, confirmed
by operating results, indicated otherwise, or, indeed, if
mixing is the mechanism in unrestricted waters, that
such mixing is so effective that no discernible
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S. Burstein
temperature change can be determined beyond the limited
mixing zone. It is not appropriate to utilize dye to
simulate complete heat transfer phenomena.
The report indicates Lake Michigan surface
waters reach 75 degrees F. or greater in summer, and
32 degrees F. to 35 degrees F. in winter, with substantial
ice formations on the surface of the lake, particularly
along shorelines in winter months. To use a layman's
approach, where does all the heat contained in all the
surface water of Lake Michigan go between August and
January?
There is only one place this heat can go, and
that is from water to air. The report admits to the fact
that once a body of water comes to equilibrium temperature
the equilibrium is maintained by heat exchange with the
air at the interface. We know that a 1,000-acre cooling
pond operating at 100 degrees F., discharges essentially
all of the heat input from the powerplant to the
atmosphere, as confirmed in the second document on
"Alternative Means of Cooling" by evidently another author.
To suggest for ecological reasons that a plume (or a
floating cooling pond in Lake Michigan) of the same area
at the same surface temperature would not discharge the
same quantity of heat via the same mechanism is untenable.
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S. Burstein
5) The theoretical model for a theoretical
plume is inconsistent with readily observed data.
Attached to these remarks are copies of infrared imagery
taken of thermal discharges at our Oak Creek Powerplant
and Port Washington Powerplant. (See Pp. 1198 and 1199)
No detectable temperature differences (1 degree
F.) are noted beyond about 1 mile; not 5 miles nor 20
miles, as theoretically calculated by some. The area of
the plume from the largest plant on Lake Michigan,
namely, the 1,670,000 k.w. thermal capacity at Oak Creek,
is of the order of 1/2 sq. mi., and not the 13 or 37*-
sq. mi. figures obtained by calculation. It seems
unfortunate that laboratory and mathematical models
should be utilized in trying to establish the mechanics
of plant circulating water flows when full-sized operating
facilities are available for direct observation and
measurement. If our
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1196
THERMAL PLUME
INFRARED IMAGERY
OAK CREEK POWER PLANT
-------
1199
THERMAL PLUME ,
INFRARED IMAGERY
PORT WASHINGTON
POWER PLANT
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S. Burstein
greatly reduced, the report continues, In the late
1940s and 1950s by lamprey predatlon. This is an immediate
and real threat to the fish life of the lake, on the basis
of which expenditures of the order of $500,000 annually
are considered appropriate. In the same context, the
Pish and Wildlife Service has the temerity to suggest that
the unknown and unsubstantiated danger to fish life in the
year 2000 now requires an expenditure by this company of
some $60 million for its existing powerplants, plus $6
million annually. A 1,000-acre cooling pond in central
Wisconsin for one 527,000 k.w. powerplant is costing our
sister utilities $5.7. By the year 2000 we would
be talking about hundreds of millions. These are
preposterous comparisons.
7) The report makes some references to fish
kills that have me confused. First, It Is stated that warm
water will kill fish. Then, it admits to the fact that
many fish are attracted to the waited water outfalls of
powerplants where angling success is Improved. The fish
become acclimated to these comfortable temperatures
only to be subjected to cold temperature shock and
mortality due to upwellings or shutting the plant down.
If this theory holds, might we not expect to have had
massive natural fish kills at least six times a year, since
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S. Bursteln
the entire inshore zones are subject to the rapid tempera-
ture changes recorded?
Prom June I960, through December 1968^ Miller
of Argonne reports eleven incidents of fish kills in the
United States which might have been caused by the release
of warmed water from steam electric generating plants.
The total number of fish kills from all causes during
the same period was 2,830. The eleven episodes identified
with powerplants involved the death of 81,000 fish out of
a total of more than 103 million killed from other pollution
incidents during the same period.
D. Merrimam of Yale found essentially no adverse
effects on shad in the Connecticut River. W. L. Templeton
of Battelle found thermal discharges on the Columbia had
no measurable effect on the important fish resources of
that body of water. Proceeding from essentially no
adverse effects to predictions of disaster by
extrapolation denotes a most serious fault either in the
data we select to use or the techniques of prediction. In
a matter which will have such long-range and significant
/
impact on the lives of the millions of people in this area
as will thermal criteria for Lake Michigan, this is not
an adequate standard of performance.
8) The second report dealing with alternative
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S. Burstein
means of cooling also requires considerably more time
for a more responsive comment. We note, however, that
the figures for plant construction, fixed charges and
operating and maintenance ratios are far below what we
are, in Wisconsin, able to do today and take no account
of what the industry and other branches of State and
Federal establishments estimate for the future. The
cost data for cooling towers and ponds are the lowest we
have seen published and far more optimistic than we have
been able to develop.
Even so, the report seems to deliberately avoid
the mention of the total dollars involved, but they are
in the hundreds of millions of dollars. There is no way
of minimizing these sums which, I repeat, will be borne
by the same, already over-burdened taxpayer and ratepayer.
Nowhere does the report define the additional
fuel requirements for these alternative cooling arrangements,
Increased fossil and nuclear fuel consumptions of from
5 percent to 20 percent are drains on irreplaceable natural
resources which should be of great concern to all of us.
Further, in the less efficient operation of other than
once-through cooling, there is, of course, a proportionately
greater heat rejection to the environment, precisely
opposite in net effect to what we are trying to accomplish.
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S. Burstein
Although the report mentions increased costs
of land, increased evaporative losses of water, and
additional chemical requirements, few references are noted
as to the total effects of these intrusions on our
environment, solutions to which will further escalate
both confrontation and costs.
In anticipation of these sessions, we have
discussed the nature of our responses with other
utilities in this area. We understand that Commonwealth
Edison Company is recommending that only plants
operating or committed at Lake Michigan sites should be
permitted once-through cooling, and that new additions
to the region's generating capability should be
installed only after successful demonstration of these
current plants confirm that they do not adversely
affect Lake Michigan and that the aggregate effect of all
present plants are similar on the lake as a whole.
We disagree with Commonwealth Edison in this
respect. We believe that the operation of current power-
plants already demonstrates that they do not adversely
affect the ecology of Lake Michigan and, as we said
before, even with the present pessimism of some observers,
no case is proposed that all future powerplants could by
their thermal discharges affect Lake Michigan as a whole.
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S. Burstein
In Wisconsin and in Michigan we have considerably longer
shorelines along Lake Michigan than Illinois and Indiana,
and there are imposed upon us some different problems,
as well as opportunities, than may be true for Illinois
and Indiana.
Further delay in the future constructions of
generating facilities in this area will aggravate an
already difficult situation into one of crisis.
We consider that the heat inputs from the power
industry into Lake Michigan are truly not significant in
comparison with natural heat addition now or in the
reasonably foreseeable future. Do not mistake our position
as one of unconcern or unawareness of the problems
confronting us. On the contrary, in addition to our
individual enjoyment of Lake Michigan, any significant
deterioration of inshore waters impairs our ability to
meet our basic corporate obligation to furnish adequate and
reliable electric service.
The U. S. Senate Appropriations Committee, which
will undoubtedly have some say in the dollars committed
to Federal programs regarding Lake Michigan, made the
following comment last month.
"If we are to succeed in a sustained effort
to fight pollution, the present hysteria must be replaced
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S. Burstein
with knowledge and understanding. The cost of the
program will be more staggering than any of the estimates
now available. We cannot expect the problem to be solved
immediately. Patience, understanding, and the placement
of priority on the most flagrant sources of pollution
should be our first consideration. The establishment of
unrealistic standards which are impracticable of
enforcement will adversely affect the program. Recently,
The Department of the Interior recommended that water
released into Lake Michigan, no matter from what source,
could not be more than 1 degree over existing temperatures
at the point of discharge. Certainly thermal pollution
must be controlled, but the Commission*is not aware of any
evidence that we need such a drastic restriction on the
temperature of water discharged into the lake."
We believe that no new standards are required
by the Federal authorities but that current State
criteria are adequate. We believe that this can be readily
confirmed by actual observations at operating steam-
electric generating plants on Lake Michigan. We believe
the effects of thermal discharges in localized, sensitive
areas can be accommodated by proper surface discharge,
the various parameters of which can be adjusted for new
facilities on a case-by-case basis for each site. Anything
* See page 2159 corrected to "Committee."
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1206
S, Burstein
more restrictive at this time and on the present evidence
is an extraordinary burden on the people of this region that
is not justified.
The position I have expressed in these remarks
and those presented by other electric utilities in the last
few days are offered in the best interests of the tens of
millions of people served by power companies in this area.
I believe the interests of these people and those of pre-
serving the quality of Lake Michigan are compatible. I
trust that the Department of the Interior or its successors
in these matters will recognize that a realistic pooling
of all legitimate interests in Lake Michigan can be
achieved without significant penalty to either fish or
people.
MR. STEIN: Thank you, Mr. Burstein.
I have one point here that I think has got us
a little puzzled with the U. S. Senate Appropriations
Committee quote. On the second page of the quote you are
saying, "'but the Commission1" what commission?
MR. BURSTEIN: I believe that was a report
referenced to the Atomic Energy Commission.
MR. STEIN: But this is "Commission," is it not,
not Appropriations Committee? Who do you attribute this to?
MR. BURSTEIN: I believe it was by the
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120?
S. Burstein
Appropriations Committee.
MR, STEIN: No, if they quoted it in reference to
a report from that commission, is it the committee's
comment ?
MR. BURSTEIN: I believe it was, but I would
appreciate an opportunity to clarify it for you.
MR. STEIN: All right. Are there any other
comments or questions?
MR. McKERSIE: One question, Mr0 Burstein. You
have said that you have studies or have done studies on
powerplants on Lake Michigan. Are these published studies
or just within your own company?
MR. BURSTEIN: The most recently published study
we have has to do with the 2 years of pre-operational en-
vironmental statistics for the Point Beach nuclear plant.
That report includes a number of factors among which are
the records of ambient water temperature at our intakes
and in various points along the shoreline at the Point
Beach site over periods of time.
For example, in these reports, we have noted the
f
very large natural temperature variations in a few hours.
As you may know also, every powerplant that I know of on
Lake Michigan records circulating water temperatures, as
an example, at least on an hourly basis, and have done
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120S
S. Burstein
so ever since they began operation. They are excellent
sources of existing temperature data.
MR. MdKERSIE: Since you mentioned that the Oak
Creek powerplant is the largest plant on Lake Michigan now
operating, have you done any type of monitoring on this
plant, any extensive work on this plant?
MR, BURSTEIN: We have the inlet temperature data.
We have discharge temperature data. We have examined the
bottom of the lake and that particular area by means of
visual physical inspection, utilizing divers. We have
included as part of these remarks one copy of the infrared
imagery, one of the photographs showing the Oak Creek
powerplant at one particular time a few years ago. We
do have some data.
MR. STEIN: Are there any other comments or
questions?
I guess I just have to do this for the record,
because there is some of this material, Mr. Burstein, that
I have been principally involved with, and I think this
deals with the jurisdictional question. So I think it is
important to clear this up if we are going to get together
with the industry and the others. You say "This conference
has been called basically because industrial users of
Lake Michigan waters vigorously opposed the policy
statement... ."
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1209
S. Burstein
This isn't why this conference was called. The
conference was called because after I made the announcement
and I was directed to make this announcement or this
recommendation the conferees representing the States,
right here, asked for this other meeting and this policy
paper. It was not from any opposition of industry. We
agreed to do that right after I made that statement.
Now, we didn't even have an opportunity to hear
any other comment, other than the States, when I made that
statement. We made the commitment to hold this kind of
meeting for the purpose of discussion. That is why it was
done. The reason I have a problem here is that you talk
about opposition when we are trying to resolve our problem
that we were forced to have a meeting because of
opposition. If this is the genesis, I think that stands
in the way of agreement. This wasn't the case at all.
Now, again, I thought I mentioned before
and I will say it again this was a recommendation.
The Secretary makes policy in the Department. We do not
have a policy statement. I hope you will recognize that,
and I think most of the testimony was directed toward that.
Then you talk about, "If this indeed remains the
position of the Interior Department today..)1 I told
you that is why we were here, to consider this recommendation
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1210
S. Burstein
in the light of all the evidence.
Mow, on the next page again you go on to say,
"... new interpretations of existing facts or break-
throughs in alternative systems that provide a legitimate
basis for reconsideration.** By whom? I guess the industry.
If you mean to imply that you have already made up your
mind, I don't know.
I hope we will try to work this out.
Then you say, " As we understand, these sessions
are beyond the normal context of the proceedings authorized
by statute." They are certainly not. If they were we
couldn't be here, and we couldn't spend public funds. They
have to be authorized by statute.
Now, I don't think this kind of thing is helping
us. Again, I guess I knew if I were here long enough what
I was afraid was going to happen would. I knew the
environmentalists would get mentioned. Read page 5* No
one has said this. I haven't nor anyone I know. We
recognize the difficulties of the power industry. I have
seen some people make statements that the power industry
wasn't planning and that is why we had these brownouts.
But we all see the problems you have here today, and it
is very easy to criticize someone from the outside, and
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1211
S. Burstein
I wouldn't make this against the power industry by any
manner of means.
But if you say, "In recent days, the shortage of
electric power in the eastern part of the United States has
received national attention and is due entirely to the lack
of adequate generating capacity, a major cause of which has
been similar unclear and indefinite environmental criteria "
I would submit environmental criteria have had little
impact one way or the other either way on eastern
power requirements.
Again, concerning your last point, may I say I
have something to do with getting out these "white papers."
Part of the kind of job I have is being a KP pusher in
getting material out of the Department. Despite the problems
we have had with this mercury crisis that we have been
dealing with, I have been, along with other people, trying
to push these reports out as rapidly as possible. The
Fish and Wildlife Service finally got it out. This
had nothing to do with any personality in the Department.
The entire operation was one of mechanically doing it.
Now, I will read the quote you gave by the ₯.3.
Senate Appropriations Committee.
"If we are to succeed in a sustained effort
to fight pollution, the present hysteria must be replaced
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1212
S. Burstein
with knowledge and understanding,"
I ask that we all proceed on that basis.
Do you have any comments or want to say anything
then?
MR. BURSTEIM: Tou have invited me, and I would
like to, sir.
MR. STEIN: Yes.
MR. BBRSTEIN: I, of course, am not privy to the
deliberations of the conference, but you may recall that
the May ?th was an executive session in which we and other
members of the public were not there to present testimony.
We did not know we would have an opportunity to present
testimony following the announcement which you read at
that particular session. It was in this context that we
went to see Mr. Klein, and my interview and my discussions
with him are what led me to make the statements I did in
this remark.
In regard to reconsideration, you are correct.
It is Wisconsin Electric Power and, I believe, the other
utilities who believe firmly that there are no adverse
effects from the thermal discharge of our plant. If we
thought there were, we would do something about them. But
we cannot see the expenditure of these very, very vast sums
-------
1213
S. Burstein
of money without having some substantiation for them*, and
to date, as we have indicated, in summary, in all of the
preparation for this conference, in all of the technical
witnesses and the work that we have had to do in a very
short time has been in response to that direction.
I would, of course, not presume to debate the
matter of the statute. I have, again, felt from what I
had heard in Washington that the enforcement executive
session was entirely different from the public hearing
types of meeting that preceded it,
I would submit, sir, that when it takes 7 years
for a Consolidated Edison Company of New York, as one
example, to get the license to build a hydroplant on the
scenic Hudson River, most of which come from citizens
concerned with environmental effects, whether they be
aesthetic or whether they be river flow or others, cer-
tainly one type of evidence that environmental criteria
not necessarily associated with Lake Michigan are
indeed a very major cause of generating capability delays.
₯R. STEIN: But you didn't say thato You said,
"unclear ana indefinite.*1 The idea is if the company didn't
like it and fought that for 7 years that is one thing.
But I didn't know that New York had an unclear and
indefinite requirement there.
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1214
S. Burstein
MR. BURSTEIN: I believe, sir as you know,
there are many agencies dealing with the environment and
evidently soon some of them will be consolidated. But in
the meantime, although we have had a Federal Power Commission
license for that facility, we have had changes in law, we
have had changes in administration, and we have had an
entire go-round with only one independent result as far as
power is concerned. The plant hasn't even begun construc-
tion. And finally I must echo and share your repetition
of the quotation, that the only way we are going to solve
this problem is by partnership and reason and considered
judgment, based on solutions to pollution by scientific
people and by engineering people. They are the ones who
are going to build the things; they are going to find the
facts; and they are going to implement them.
MR. STEIN: Sir, that executive session ~ very
often they are in public that executive session was in
public. The press watched it; the conferees watched it.
Let me assure you this - and the record will
show this after I made that announcement with the
request from the other States and I assured them at
that time we would have a meeting of thia sort this
presumably was quite sometime before you had your meeting
with Assistant Secretary Klein.
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121$
S. Burstein
In other words, as soon as this announcement was
made, and there were questions on the part of the States
and the conferees, we all came to an agreement that we
would have this meeting soon after the "white papers" were
prepared, and we went into that discussion almost
immediately and came to this conclusion very fast as I
recall it.
I think we have a complete record of that in
the verbatim transcript and you can read it and see.
MR. BURSTEIN: Our meeting with Secretary Klein
was on May 2$, sir.
MR. STEIN: After this meeting?
MR. BURSTEIN: Yes, sir.
MR. STEIN: Right. All right.
Are there any other comments? Any from the
floor? Yes, Mr. Dumelle.
MR. DUMELLE: Mr. Burstein, I wonder if on that
photograph in your paper you could quantify that plume
as to area and temperatures?
MR. BURSTEIN: The maximum temperature from the
Oak Creek powerplant on that day in question was just
under 10 degrees. The photograph, we believe, is
accurate, to show the demarcation at approximately the
1-degree temperature difference from our approximation
-------
1216
S. Burstein
of the area. It was not a precise parameter method. Some
are 0,43 square miles.
MR. DUMELLE: Thank you.
MR. STEIN: Are there any other comments or
questions.
If not, thank you very much, Mr. Burstein<,
MR. BURSTEIH: May I take one more moment of
your patient time, sir?
Mr. Purdy asked a question before which I don't
know whether it was totally answered. He asked what would
happen if we found some evidence of damage or potential
damage by the presence of the projected thermal discharges
from powerplants. Could we do anything about it?
I think the answer is, of course, yes, and I
would refer to the analogy of what most of us have done
in air pollution control. Where years ago a 90 percent or
an 85 percent deficient dust collecting system might have
been adequate, we have replaced these and in many cases
replaced them two, three, and four times, with more up-
to-date equipment. Nobody has been able in the past
successfully to eliminate S02 from gases and yet now we
are seeing the technical developments in areas that look
like, in the next few years, we may be able to have systems
and facilities to do it.
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1217
S. Burstein
I think we can build cooling towers on any exist-
ing plant. It is going to take a heck of a lot of money.
It is going to take a lot of resources of other kinds. It
is going to reduce the output, but if that is the kind of
a price that will have to be paid, once we know what it
is, then I think it can be done.
I would like to leave that thought in response
to Mr. Purdy's question.
MR. STEIM: Let me give you another suggestion.
I don't say this immediately, but in the future we can
think about this. I hope you weren't referring in your
thinking to cooling towers. This is just my thinking.
I get this from going around all over the country and answer-
ing my telephone and mail. As I pointed out, we are going
to have this problem not only of heat but we have to
deal with the hydrology of the intake water, the fate of
the fishes, the phytoplankton, the zooplankton that go
through and the hydrology of the receiving water of
where you put the material out.
Now, the heat may not necessarily be the key
factor on the last three. There may well be other key
factors.
I am not sure when you say to put cooling towers
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1218
S. Burstein
on any system whether the requirement might not be for
a pressure to come to an essentially closed system or
loop-type system.
As a matter of fact, the reason I bring that up
and think it is pertinent and I say this to the industry
I have just been dealing for several months with the
paper industry and the chlorine industry on this mercury
crisis. While these companies may have thought that
they had their effluent problems licked, along came some
bright young guys who found some very small amounts of
material in there that everyone certainly felt was
significant.
Now, I think this is the kind of thing with
which we are going to be faced. I don't think this is
industry alone, sir, but also regulatory agencies, because
we have to respond so people will get th« kind of environ-
ment and pollution control that we are developing. I
think the time has come and I am not speaking of this
is relationship necessarily to this conference when
we are really going to have to think in terms of an
essentially closed system including disposal of the
leadoff or blowdown if we are going to be home free. I
think we are coming to that in some industries, and we
are getting to that more and more.
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1219
S, Burstein
The difficulty is, I suspect, you may be at the
end of the spectrum of using a heck of a lot of water with
not enough material in it. I know I have been in this
business for 25 years. I tell the people here, too,
time after time^when we went out and looked^at a pollution
situation, when I found that there was cooling water, I
felt we were home free.
As a matter of fact, if you look at the list of
all of the companies we have proceeded against through
the years and you know we have been pretty active ~
you will find that until recently practically no power
companies have been on that list. So our companies dis-
charging heat has not been the problem until we found the
causal relationship between discharge and damage. But
I suspect as we are getting more refined and at least
have programs to deal with the gross pollutants which we
had before, there is going to be more and more emphasis
on aspects of discharges which we just didn't consider
before.
And I don't know that the industry has a dif-
ferent problem than we have. But I really do think,
gentlemen, we have to sit down and try to think this
through or work this through together and see where we go
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1220
S. Burstein
from here,because otherwise we are always going to be faced
with something such as is facing us now.
MR. BURSTEIN: I am encouraged and I agree with
you wholeheartedly, sir.
Let me say that the electric power industry has
no desire to discharge heat. It is ridiculous for us and
a small company like Wisconsin Electric to pay $50 million
for its annual fuel bill and then dump $35 million of it
into Lake Michigan. We know of no other way of doing it
at the moment. But in time if we are more successful in
selling steam heat, as we are trying to do in some central
areas, or in a year-round agriculture, fishery business*
or some of the other attempts to utilize this low level
material, this very, valuable resource, we will both
accomplish the same ends.
MR. STEIN: Are there any other comments or
questions?
MR0 MACKIE: Mr. Burstein, both you and Mr.
James and a number of other representatives of the
industry at this meeting have indicated that if adverse
environmental effects are identified after a plant has
been in operation for sometime that the industry stands
pretty much committed at the time. Actually from a
practical point of view and this was borne out in some
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1221
S« Burstein
of the testimony the other day it would appear that at
least in some cases the only real alternative would be to
reduce power production. So it would seem to me that
insofar as new plants are concerned that initial engineer-
ing plans should provide for some of these alternatives
right at the outset*
Now, would you comment on that?
MR. BURSTEIN: Yes, I wish it were as simple
as that, sir.
But, again, as you know, for example, the
exhaust end of the steam turbines are designed with a
particular size capacity, a certain quantity of steam at
a certain volume. If we design it to operate on a cooling
pond or a cooling lake or a cooling tower, be it dry or
wet, we will find that this will reject more heat in a
once-through system than some other design and will be
defeating the initial opportunity by adding considerably
more into the once-through system now in order to be able
to utilize it without a reduction in capacity later.
I think these are compromises we will have to
face and pay for. I don't think there is a universal
steam turbine or a universal system that can go anywhere
and serve any purpose. But if, for example, my infrared
photographs are pertinent, one of the solutions may be
-------
1222
S. Burstein
to put a dike around that portion of Lake Michigan, that
half square mile if that is the place it is and if
we are concerned about letting this effect get somewhere
else.
I might also comment on this overlapping plume
theory. As you know from Wisconsin, sir, the Kewaunee
plant is 4 and a half miles from the Point Beach plant,
and there has been some concern that these plumes are so
large that they overlap. For our own selfish purpose, we
don't want at Kewaunee or Point Beach to induce the hot
water from the other guy's plant. It would reduce our
efficiency, would make our temperature rises considerably
higher, and so we have already looked at this overlapping
plume idea if you want to call it just from a prac-
tical operating point of view and we find there is
sufficient more than ample under all the predictable
weather and wind conditions to avail that. We couldn't
tolerate a 40- or 50-degree temperature rise for the same
reason. I think the maximum is closer to 30, again, for
optimization of the turbine generator.
MR. MACKIE: I think perhaps you have added to
my concern rather than detracted from it.
MR. STEIN: You know, Mr. Mackie, the biggest
thing we have going for us now, I think, from practical
-------
1223
S. Burstein
effects in getting dispersion of heated water from the
powerplants is the fact that if they put it too close to
the water intake»,they are taking in their own hot water,
and they are decreasing their own efficiency. We have
had that complication.
MR. BURSTEIN: I think you are also familiar,
sir, that we have on rivers both discharges and intakes
within a couple hundred feet of each other. How do they
work?
MR. STEIN: You know better than I do.
MR. BURSTEIN: Surface cooling.
MR. STEIN: I know, but you are trying to avoid
it when you can.
Are there any other questions or comments?
If not, thank you very much, Mr. Burstein.
Mr. Petersen.
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1224
0. K. Petersen
MR. PETERSEN: Mr. Chairman and conferees, the
statement by Mr. Burstein on behalf of Wisconsin Electric
Power Company was the last electric utility presentation so
far as I know. I would remind you again that each company's
statement was independent of the others and my function,
except for being a representative of Consumers Power Company,
was to aid in coordinating the time and order of appearances
for the benefit of the conferees and those present to
appear.
And, lastly, we would appreciate having placed
on the record the name of the individual to contact to
obtain the data behind the "white paper."
MR. STEIN: Oh, it will be right up. That is why
I want you to wait.
At the conference, the conferees asked that the
people who prepared the "white paper" and the man in
point is Mr. Yates Barber, and we prevailed on him to stay,
and I suggest that the industry representative stay so he
can make his comment.
lates, will you come up and make any remarks
you wish to?
Now, there are two parts to that "white paper."
Let me make this clear. I don't want to confuse you with
the bureaucracy.
-------
1225
Y. M. Barber
On the Fish and Wildlife part you get in touch
with Mr. Tates Barber. On the other part, prepared
in Corvallis, Mr. Tichenor or Howard Zar can give you
this, and if you feel that you don't want to do this, of
course, you can get in touch with any one of our regional
offices and they will direct it to the party.
Mr. Barber.
MR. BARBER: Thank you, Mr. Chairman.
Mr. Chairman, honored conferees, ladies and
gentlemen. I am very happy to be back here today to make
this response to the papers that have been presented
by the electric power industry. We were asked to respond
to the paper by Dr. Pritchard and others.
MR. STEIN: Before you start, may I make one
announcement? I am sorry to break in. I think tomorrow
when we are going to have municipalities come here may be
a relatively light day, and the reason I want to make this
announcement is because some of you people may leave before
the end, so if there are any public people who want to make
a statement, it may be advisable for them to check in
tomorrow and we may be able to put them on.
Mr. Barber.
MR. BARBER: Thank you.
We have had, of course, but the one day to review
-------
1226
T. M. Barber
Dr. Pritchard's paper. Because we have wanted to be here
to hear the other papers, we have not been able to prepare
any written statement for distribution. I am very sorry
about this, but you understand the time limitations.
If we may, Mr. Chairman, we would like to direct
some comments at some of the papers that have been
presented by consultants to the power industry. This is
by no means an effort to cover everything point by point,
but there are some important points that we would like to
identify for you if we may.
To begin with, if I may, I would like to identify
the so-called "anonymous authors'" of the Fish and Wildlife
Service "white paper." This report was done by a large
number of individuals, and we are going to ask each one of
them to respond to certain points which are his specialty
a little bit later, in just a few minutes. Meanwhile, I
would like to ask these individuals to stand and be
identified.
We have, first, Mr. John Carr, who is Acting
Director of the Great Lake Fishery Laboratory, U. S.
Bureau of Commercial Fisheries at Ann Arbor, Michigan.
We have Dr. Peter Colby of the same staff.
Mr. Thomas Edsall of the Ann Arbor Laboratory.
Mr. Kenneth Roberts of the Bureau of
-------
122?
Y. M. Barber
Commercial Fisheries, formerly in the regional office at
Ann Arbor, and currently in the Washington office,
Then we had able assistance from two individuals
in the Federal Water Quality Administration* They are
Dr, Charles Powers from the National Eutrophication
Laboratory at Corvallis, Oregon, and Mr. Richard Callaway,
who is from the National Thermal Pollution Laboratory in
Corvallis.
I would like to review that there have been in
addition to these men perhaps a dozen others who have
assisted. Several of these are from the Ann Arbor
Laboratory, which has done the principal biological work.
The section dealing with thermal influence was done by
the Corvallis Laboratory.
During the course of the events, there were a
number of comments offered as to the qualifications and
the lack of field experience that might have been exhibited
by some of the authors of this paper. Just so that we do
fully understand the scientific qualifications and the
degree of experience and professionalism that we employ,
I would like to note that the seven professional staff
members from Ann Arbor who participated in authoring this
report have all combined an I think impressive
total of 107 years' experience in professional fishery
-------
1223
Y. M. Barber
work. Most of it is in the Great Lakes; much of it is
in Lake Michigan. In the last l£ years there have been
more than 6000 man days in the field in vessels in Lake
Michigan alone, a good deal of which was by these
particular individuals.
There were a few other people like myself, that
were engaged in preparing this report, and we combine a
total of about 50 years' experience in environmental and
ecological matters, including the evaluation of the effects
of water development projects on the environment, particularly
effects of powerplants along with dams, navigational projects
and other such developments.
Bow, before I start asking these men to give
you their comments, I would like to call your attention
to a few basic concepts that were involved in the
preparation of our basic biological report entitled
"Physical and Ecological Effects of Waste Heat on Lake
Michigan."
The reason I want to do this is because the
engineering fraternity frequently tends to deal in terms
of averages. This is perfectly valid. It is perfectly
good. We do, too. But, just as when a dam is designed you
must recognize the average and peak flows, in biology
you must .recognize the extremes. Therefore, in making
-------
1229
Y. M. Barber
our evaluation of the impact of waste heat in the lake,
we have paid particular attention to the extreme conditions
that are occasionally induced by climate or other reasons
from the waste heat discharges in areas of the lake.
I think there is a very important point that I want
to make here, I will put it simply» Our evaluation is
based on the fact that we do not feel you have to kill
a fish more than once to establish damage. Basically
what I mean by this is that impacts in a river or lake
which eliminate a population of fish, whether it be the
adults, the juveniles, the larvae, the eggs and spawn, or
simply causes the adult female to resorb her spawn products
because of a change in temperature, are damaging effects.
If such impacts are induced periodically in an area, it
may be sufficient to control the population of that
particular species.
I want to emphasize, of course, that in addition
to these immediate effects,that we are very much interested
in the long-term and indirect effects, which may not
appear for quite a long time yet to come.
Now, I would like to call upon Mr. John Carr to
offer his comments relative to the paper by Dr. Pritchard
and others.
Mr. Chairman, would you like to have these men
come up here?
-------
1230
J. F. Carr
MR. STEIN: Tes, I think that would be better.
MR. BARBER: Each of them will speak briefly,
and I would also like to ask them to state for you their
professional experience, training, and qualifications as
individuals.
MR. STEIN: Do you think it would be better, Mr.
Barber, if each of them spoke briefly and we would give
them a chance to ask them questions one at a time?
MR. BARBER: If we may, I think it might be better
if we completed this, since most of these will be brief,
then I would like to make a few summary remarks.
MR. STEIN: We will do this.
MR. BARBER: Yes. Now, let me say this: Dr.
Tichenor's comments relative to the feasibility report will
be made individually after I have completed our comments
on the biological report.
MR. STEIN: All right.
STATEMENT OF JOHN F. CARR, CHIEF, ENVIRONMENTAL
RESEARCH PROGRAM, FISH AND WILDLIFE
SERVICE, U. S. DEPARTMENT OF THE INTERIOR, ANN ARBOR, MICHIGAN
MR. CARR: I am John Carr, Chief, Environmental
Research Program of the Great Lakes Fishing Lab, Fish and
Wildlife Service. Today I am in the Bureau of Commercial
Fisheries, tomorrow I will be in the Bureau of
-------
1231
J, F. Carr
Sport Fisheries and Wildlife,
I hava a master's degree from Michigan State
University in fish and limnology. 1 have spent the last
10 years actively engaged in environmental study in all
of the Great Lakes.
Most of my remarks are going to be directed to
questions raised some of them I think most of them
by Mr. Currie, and I want to begin by rereading the
.-5-
introduccion to the "white paper."
"There is reason for concern about potential
serious ecological damage to Lake Michigan as a result of
discharge of industrial and municipal waste heat. At the
predicted rate of increase, the waste heat load rejected
to Lake Michigan by the year 2000 would be more than 10
times the present load. The source of most of the waste
heat will be the power industry. Required power capacity
has been doubling each decade and there is no sign that
this rate will diminish."
I donft think that has been disputed in the
three days of hearings.
"Everyone concerned with the problem agrees that
not enough is known about the ecological effects of massive
heated effluents and that a great deal of research is
needed on this problem. Unfortunately, the information is
-------
1232
J. F. Carr
needed now; since it is not available, however, interim
standards must be set for Lake Michigan on the basis of
existing knowledge.
"The purpose of the present report is to present
the available evidence that substantiates this concern.
The evidence reasonably demonstrates that heat addition,
as presently proposed, is an essentially cumulative
problem that would contribute to inshore eutrophication
and be intolerable from the fish and wildlife standpoint
by tfcr year 2000."
There has been some question about "cumulative.11
By this, we simply mean that as the years go on,
approaching the year 2000, there are more and more discharges
into the lake, more B-t.u.'s, more cubic feet, or what-have-
you. We didn't mean that the lake continually warms up.
1 think we make the statement that the lake always
returns to winter temperatures.
"Therefore, it is in the public interest to stop
this process now, rather than attempt the difficult task
of correcting or reversing it after it has occurred."
The power industry has emphasized over and over
that they can do things before they design, but it is
difficult after they are constructed.
"On the basis of the evidence presented herein,
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1233
J. F. Carr
this Department supports stringent standards for Lake
Michigan, and concludes that no significant amounts of
waste heat should be discharged into Lake Michigan."
And this was covered very well in the last paper,
One of the questions that has arisen is the
selection of the zones, the size of the zones and the
depth. The inshore zone, designated at zero to 100 feet,
was selected because this depth usually includes all
of the epilimnetic water and the thermocline when it
is present. It is an ecologically distinct zone. When
there is a thermocline present, it is usually 100 feet
or shallower. The beach water zone, zero to 30 feet, was
selected because there is usually complete vertical mixing
in this zone. It is rare to find a horizontal gradient
in this beach zone. From the biological standpoint,
these two zones are ecologically unique. That is why
they were selected.
The importance of the shallow water is: The
shallow waters are most important from an ecological point
of view. It is far more productive per unit area than
what is beyond the photic zone area, and we gave some
examples in the "white paper" why this is so. Every
ecology textbook also discusses it.
According to all reports presented thus far,
-------
1234
J. F. Carr
including Dr. Pritchard's, the thermal plume from all
currently proposed plants will be in this zone. The slides
from the Willow Run laboratory^that we saw this morning
illustrates this very well. Also I don't think it was
mentioned, but infrared imagery only shows the surface
temperature to a depth of a few molecules. We had some
arguments, discussions, about the volume of the inshore
zone. We are talking about 4 percent included in 100
feet contour and only four-tenths of a percent to a 30-
foot contour. We think this is a significant statistic,
and I hope to show why.
The surface of the zone inside the thermal
barrier or bar we realize is level. Dr. Pritchard
questioned us on our belief here. We do believe in water
seeking its own level. But mixing between the inshore
waters and the offshore waters is inhibited in the spring
due to this thermal barrier. We prefer to call it a
thermal barrier because the thermal bar has developed with a
specific definition in that 4-degree water or water
of maximum density must be present with water of less
density on both sides. Quite often in Lake Michigan this
is not necessarily true, but there is a horizontal
gradient^which would be a barrier to mixing. I think the
people talking today realize that this is so, but they
-------
1235
J. F. Carr
skirted it,
The interface between these 2 zones is readily
visible to the naked eye, because of the buildup of
suspended matters on the inshore side. The secchi disk
readings are three to four times greater on the lakeward
side of this thermal bar than on the inside of the bar.
The thermal bar is essentially a thermocline turned on
edge, and if Dr. Ayers or Dr. Pritchard could convince me
there is a great amount of mixing between the two zones,
then the people at Lake Erie could quit worrying about
oxygen pollution from the bottom waters of the central
basin. There is a barrier to mixing between these two zones.
Now, during the, period that the thermal barrier
is present, the effective volume as far^as the entire lake
is concerned*is reduced. I think Dr. Mortimer will present
more information on this tomorrow or the next day.
One other statistic that has not been brought
out: The 91,000 cubic feet per second predicted for the
year 2000 is one and a half times the outflow of Lake
Michigan based on the computations of Dr. Ayers. I think
it has already been explained why we used the date of the
year 2000. We thought we would go to the point where
damage could be shown and try to work backwards from that
point. In the year 2000, we are thoroughly convinced there
-------
1236
J. F. Carr
be a problem if projections hold true. The thermal
bar slide showed by the Willow Run Laboratory was a
very impressive slide, but very deceptive. The slide
showed that the thermal bar was a good ways offshore
it looked like several miles. Even the thermal bar is much
closer inshore and the Grand River would appear much larger
in proportion to this.
Another thing, most of the studies we have heard
about have not concerned fish. The only one I have heard
about and I may be wrong on this was a gill net had
to be set 4 times a year by the State of Michigan. Four
times a year would not even detect, I would say, a
decrease in the population of 50 percent each year; fish
are so variable.
Dr. Ayers' slideyshow considerable bottom
influence on the Waukegan plume. I understood from Dr.
Pritchard's report that this probably would not be true.
Also from Dr. Ayer's slides I saw almost no tendency
for this water to flow, and you can look at his paper.
Damage to fish is difficult to measure. It is so
difficult that it would probably take 1 or 2 vessels
fulltime with full crews to show a change each year of 10
percent or greater. What we have been dealing with in the
Great Lakes in the last few years is a slow decline, and
-------
1237
J. F. Carr
suddenly we have no fish at all. We have lost, I think,
3 species of fish completely in Lake Michigan in the
last 20 years.
I am disappointed that some of our colleagues
are accusing us of being armchair biologists because
there are several wives at Ann Arbor that wish to heck
we were.
In conclusion, I feel that the testimony of Dr.
Ayers, Pritchard, Raney, Robertson, and Dr. Lee all support
the thesis that damage can occur as a result of powerplants
on Lake Michigan, using once-through cooling, because
all of these people suggested ways of minimizing the
damage by such things as proper site selection, design of
intake, design of outfall, or manipulation of the operation.
Thank you.
MR. STEIN: Mr. Carr, I have talked to Mr. Barber,
and in listening to your statement because of a possible
crucial impact on the deliberations and the technical
nature of this, I think we are going to change the
procedure and ask for questions now, so we can keep it in
one place in the record, because I hadn't realized these
comments would be that extensive or that technical.
Are there any comments from the conferees?
Mr. Currie.
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123$
J. P. Carr
MR. CURRIE: Do you have any comments about
the dye test run by Dr. Pritchard to determine the extent
of blocking at the thermal barrier?
MR. CARR: Yes, and I think Dr. Lee's comment
and Dr. Ayers' comment on measuring total dissolved
solids this zone is large I think the measurement
techniques used as far as dilution is concerned, are such
that the buildup in total dissolved solids would not occur
to the point where one could measure it. Tou have to be
in an area where you have an input of total dissolved solids
and it has to be a river.
With the dye you are talking about at the
thermal bar there is a terrific downwelling of water, and
I think it is just simply diluted. He did not show that it
crossed the thermal bar. The very name to me indicates
lack of exchange, and how you could have temperature gradients
as great as you had, if you had complete mixing is beyond me.
MR. CURRIE: Do you have any views on Dr.
Pritchardfs notion about the limited residence time of
any particular molecule or organism in the thermal plume?
I take it that this is a very important part of the thesis
of the Commonwealth Edison Company.
MR. CARR: I don't feel that I could comment on
-------
1239
J. F. Carr
that. That is out of my area. I would have to rely on his
statement.
MR. CURRIE: Do you have any studies that show
an increase in the eutrojphication field studies
MR. CARR: Due to heated
MR. CURRIE: due to heated discharges of the
type, of the size that we are talking about on Lake
Michigan? We have had some limited preliminary studies
presented by utility companies that purport to show that
so far they have been unable to find any eutrophication or
indeed other kinds of biological damage. Do you have any
conflicting data?
MR. CARR: No, sir.
MR. CURRIE: What is the closest thing to relevant
data that you have? I take it there must be some studies
somewhere that someone has conducted that show some adverse
effects of heat on something, and that is the basis of
your recommendations.
MR. CARR: If you are talking about fish, yes,
but you were asking about eutrophication. I am not even
sure what the term means. It had several definitions here,
most of which I disagree with. Eutrophication can be a
very desirable thing. If you are talking about the growth
of algae, we do not have any studies. If the inshore zone
-------
1240
J. F. CARR
inside this thermal barrier is visible because of the increase
of the algae on the inside part the warmer part if
this is due to the increased heat in this area, then there
is a good case to show that you have a buildup of algae.
I am not saying it is.
MR. STEIN: Mr. Miller.
MR. MILLER: John, do you have any indication of
critical areas around Lake Michigan where one or two degrees
would be very critical? Can you identify these areas?
MR. CARR: A report at the Milwaukee hearing of
this committee that some recent study by Canadians have
found some rather discrete spawning areas in Lake Huron
in 3 to 5 feet of water and it was felt if this spawning
stock were wiped out it would not be replaced going
from that discovery to Lake Michigan, I suppose there
are also stocks in Lake Michigan that could be affected.
These have not been identified.
MR. STEIN: Mr. Purdy.
MR. PURDT: John, you have seemed in your
additional remarks here to focus upon the year 2000 as being
a time when you could with certainty predict the damage.
During the last several days we have heard a great deal of
testimony with respect to the problems of backfitting
-------
1241
J. F. Carr
existing powerplants, and that you can treat this
problem in a different fashion on powerplants yet to be
constructed. But yet in your report and you repeated
this, I believe, in the earlier remarks but anyhow in
the report it reaches a conclusion that no significant
neat input should be made to Lake Michigan. I am not
sure what "significant" is yet, but you mean a significant
addition over and above what we have now? Or do we have
to cut back what we have now?
MR. CARR: From a fishery standpoint, I think
some of the fellows that follow me will maybe answer this
a little more. I think any plant that pulls in water,
takes it through a turbine, heats it, dumps it out, causes
damage. Whether that is significant or not, I don't think
I am to be the judge of it. I don't know that I can answer
it any more than that, Ralph.
MR. STEIN: Are there any other comments or
questions from the panel? Are there any from the audience?
MR. FETTEROLF: John, did I understand you to
say that the increases in turbidity inside the thermal bar
may be plankton?
MR. CARR: Yes, I think they are plankton.
MR. FETTEROLF: And if they are plankton, you
would relate this to the temperature?
-------
1242
J. F. Carr
MR. CARR: No.
MR. FETTEROLF: All right. I misunderstood you
then.
MR. CARR: I said it could be a factor.
MR. STEIN: Mr. Bane.
MR. BANE: Mr. Carr, in connection with your
statement about the sensitive area in Lake Huron you said
that there were likely to be similar areas in Lake
Michigan, but that they had not been identified. Can they
be identified with proper environmental studies?
MR. CARR: I think so, yes.
MR, BANE: And could be identified before a
powerplant was sited in that area?
MR. CARR: I think so, yes.
MR. BANE: Thank you.
MR. STEIN: Are there any other comments or
questions from the audience?
Yes, come on up. I take it if anyone and I
say this generally wants to make a statement, try to get
close to the mike, and we will save time.
DR. McWHINNIE: I am Mary Alice McWhinnie. I am
glad to see you again. I couldn't place why I knew you
before.
MR. STEIN: Can you hear in the back?
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1243
J. F. Carr
... Cries of "No11 ...
DR. McWHINNIE: Somewhere in your report and
I cannot recall it verbatim it goes that because of a
thermal increment infirmity, young fishes will develop
faster before their food organisms are available. I assume
both populations are exposed to the same thermal increment
the young fishes, the fry, the just early post-embryonic
stages. Accordingly, so too will not the zooplankton
experience the same thermal increment? Why would it be that
the fishes are ready for feeding in advance of when the
zooplankton would not yet be available?
MR. CARR: There will be more comments later
on this. I would just say that we are dealing with eggs
on the bottom in the influence of the thermal plume. The
food organisms are not in the influence of the thermal
plume. When the eggs hatch out they become part of the
entire lake, not rooted to one spot.
DR. McWHINNIE: So this becomes, then, a matter of
the geometry of the plume relative to the two populations,
and do we not see that the thermal plume, when released
in shallow water, does involve most of the water column?
MR. CARR: The plankton may originate miles from
where the fishes are hatching. You heat up the egg area,
they hatch sooner, but you have not influenced the
-------
1244
J. F. Carr
plankton in the lake. The whole lake is not heated up,
only that area.
DR. McWHINNIE: This is true, but then you are
presenting this as a I will say theoretical
circumstance of a special difference without, if you will,
the true evidence for where those currents are going either
for the young fishes, which are also subject to currents,
as are the zooplankton or phytoplankton.
MR. CARR: Could you wait for .a little better
explanation from Dr. Colby with some data on this and the
effects of a few degrees on egg incubation?
DR. McWHINNIE: Yes, thank you.
MR. STEIN: Thank you.
Are there any further questions?
MR. CURRIE: I have ^ne more.
There was a suggestion, I think, in one of the
power company papers that an increase in heat could
affect the species distribution of algae but not the total
amount of algae. Would you agree with that?
MR. CARR: Yes. If there are just so many nutrients
available, and that is all that can be used, the heat can
speed up the process, but it can't produce more than you
have the building blocks for.
MR. CURRIE: Then suppose you have a large amount
-------
1245
J. F. Carr
of nutrients present, might then the addition of heat
increase the percentage of such available nutrients which
are in fact utilized by algae?
MR. CARR: Would you repeat that?
MR. CURRIE: If you have an adequate supply of
nutrients, a large supply of nutrients, might the addition
of heat increase the proportion of such available nutrients
which are used by algae and therefore increase the total
algae production?
MR. CARR: If heat is a limiting factor, nutrients,
by adding heat, you would get a greater productivity, yes.
MR. CURRIE: And are there situations in which
heat can be a limiting factor in the total algal production?
MR. CARR: Yes, but I am not being specific to
Lake Michigan. In general, yes.
MR. STEIN: Any other comments?
MR. FETTEROLF: When you said you would get
greater productivity, did you mean standing crop or
productivity?
MR. CARR: Which one, the latter supposition?
MR. FETTEROLF: The first one.
MR. CARR: The first one where a limited amount
MR. FETTEROLF: If you had an excess amount of
nutrients, the question was: Will, then, the addition of
-------
1246
J. F. Carr
heat increase the amount of algae and you, I believe, said
it would increase the productivity, and this might be
interpreted as the standing crop.
MR. CARR: No, if heat is the limiting factor
and there is adequate nutrient and you add heat, you would
increase productivity. I donft know about the standing
crop.
MR. PETERSEN: I regret that the scientists who
would be best able to ask questions pertaining to this
matter have left without awareness that this testimony
would be presented. Accordingly I hope you will follow
through with a mere lawyer trying to ascertain what is
happening here% 8ut I think if I understand you correctly
that you challenge the findings of those who have made
thermal plume studies that they float.
MR. CARR: No, we have heard testimony over the
past few days about how the thermal plume floats has very
little effect on the bottom. I was ready to believe this.
I was convinced until Dr. Ayers showed his slides. From
his slides, there is no evidence that the plume that he
studied has any tendency to float until it gets less than
2 degrees Delta T. If I am misinterpreting the slides
and the paper, then
MR. PETERSEN: Then, the only evidence upon which
-------
1247
J. F. Carr
you made that statement was your interpretation of those
slides which were prepared by Dr. Ayers.
MR. CARR: That is the only ones I referred to,
yes.
MR. PETERSEN: And have you identified any fish
eggs in the vicinity of any present or proposed thermal
plume from an electric power generating station in Lake
Michigan which might be affected?
MR. CARR: I don*t know that we have studied this.
We have not deliberately gone out to look at any thermal
plumes in the Great Lakes.
MR. PETERSEN: Do you have any challenge or
question pertaining to the testimony which you have heardf
at least as to the eastern shore of Lake Michigan, as to
there being a relatively barren area insofar as benthic
organisms are concerned due to the grinding of sand caused
by wave action?
MR. CARR: No, I agree with this.
MR. PETERSEN: Would it be correct to assume that
if benthic organisms could not survive such grinding
that fish eggs would be similarly affected?
MR. CARR: No, I don't think so.
MR. PETERSEN: Then, it would be appropriate to
believe that fish eggs could be deposited on this grinding
-------
1243
J. F. Carr
sand and they would survive and produce viable fish
populations in that area? I am just trying to get this
straight. I am not challenging you.
MR. CARR: Many of the fish in this inshore
zone, particularly perch, the eggs don't necessarily lay
on the bottom.
MR. PETERSEN: What do those fish eggs do, then,
please?
MR. CARR: They usually usually they are an
envelope, and they are usually wrapped around some
projection above the bottom, whether it is a plant or
something like this.
MR. PETERSEN: Well, in the case of a sand bottom
where we have no projections, other than the experimental
stations of various scientists checking the plume, we
wouldn't expect to find, then, perch eggs?
MR. CARR: Right.
MR. PETERSEN: Now, as to this thermal barrier or
bar I think you used both terms, and I am not well enough
acquainted with the terms to be able to precisely identify
which is the correct one, if one of them was more correct
than the other it is my understanding from reading a
couple of these papers, and some discussion, that this bar
forms in the spring and moves rather consistently outward
-------
1249
J. F. Carr
into the lake until eventually it disappears. Is that
essentially correct?
MR. CARR: Yes.
MR. PETERSEN: Is that a constant moving factor
and about what rate does it move? Could you give us any
idea of that?
MR. CARR: I think in perhaps Figure 1 we have
an average of about sometime around April 1 or April 15
to June 1, in the neighborhood of 45 days, when it is
first detected until it becomes a thermocline.
MR. PETERSEN: Have you or those others who
prepared the paper made a particular study of this
phenomenon? Have you followed it out day by day to
ascertain its movement and its behavior other than the
let me say just disk observations which you described
earlier?
MR. CARR: No. If you were fishing in Lake
Michigan in the springtime, particularly if you are going
coho fishing in April or May, you fish inside this bar, if
you want to catch a fish. If you fish outside, you won»t
catch coho; neither if you are fishing commercially for
alewife. We find that in this regard too we do locate the
position, but we do not measure its movement.
MR. PETERSEN: Well, have you any figures that
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1250
J. F. Carr
you could give us to aid us in determining what is going on
as to its relative position of movement and the relative
volume of water inside the plume day by day as it moves
outward? 1 take it from the fact that it moves outward
there has to be some passage of water one way or the other
between the two, otherwise it would act as a dike.
MR. CARR: Yes, water does seek its own level,
if that is what you mean. Its temperature, according to
the people of the University of Toronto who studied this in
Lake Ontario the position of the thermal bar in relative
relation to the shore is dependent on the offshore
temperatures of the mass of water lakeward. If you add
temperature particularly to the inshore area, you increase
the gradient across the thermal bar, but you do not
increase its distance from shore. That is determined by the
warming trends on the inside the lakeward side of the bar,
MR. PBTERSEN: Well, could you give us an idea of
how fast that moves outward?
MR. CARR: It begins some distance offshore, less
than five miles, sometime around the 15th of April, on
the average. By June 1st, it is no longer present.
MR. PETERSEN: How far up does this move?
MR. CARR: In the first part of June, I would say
it could be as much as 15 miles offshore.
-------
1251
J. F. Carr
MR. PETERSEN: The way you answered that led me
to believe it was what we might term as a guesstimate. Have
you any
MR. CARR: Yes, we have a report based on the
temperatures of 54 and 55 in Lake Michigan, in which we
have 55 crossings of the lake, three or four a month.
From these you could determine its position.
MR. PETERSEN: Did you do that?
MR. CARR: Yes.
MR. PETERSEN: During your studies?
MR. CARR: The two papers by Church referred to
in here - Dr. Mortimer, I think, will present the data
on Friday to show some of the effects here. He also
refers to Church.
Most of the information, most of the study on
thermal bar and thermal bar phenomena has been documented
on Lake Ontario because it is so much more pronounced on
that lake.
MR. PETERSEN: Once again, you will have to pardon
me as being a lawyer, not a scientist in this matter, but if
it is so much more pronounced on the other lake, would
that not be some indication that its behavior might be
different on the two lakes?
MR. CARR: It is very definitely different on
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1252
J. F. Carr
each of the lakes in which it is found on every lake on
which it is found, and probably varies with season and
every year it is different.
MR. PEfERSEN: And your real studies of this were
on Lake Ontario rather than Lake Michigan?
MR, CARR: No. I didn't say that. The studies
that we have I referred to was Church, the paper that
is in press, by Carr, Moffett, and Gannon, and some work
by Dr. Mortimer.
MR. PETERSEN: Very briefly, then, to try and
conclude this, you, as I understand it, challenged the
testimony of Dr. Pritchard as to mixing. Would that be
properly stated?
MR. CARR: Yes. It was unfortunate that we didn't
get a chance to question the witnesses. It is unfortunate
that some of the questions concerning our paper were not
asked at the time that the paper was presented. Dr.
Pritchard left me with the impression and I think he left
the audience with the impression that the thermal bar
is no barrier to mixing, that there is no restriction
between the movement of water from the inshore area to
the offshore area during the period in which the bar is
there. Is that your opinion of what he said?
MR. PETERSEN» I would just as soon ask the
-------
1253
J. F. Carr
questions if you don't mind.
MR. CARR: Well, I will speak for Myself. This
is the opinion he left with me. If that is what he is
saying, I am questioning I say that is not true.
MR. PETERSEN: There are various things, I
understand what you are challenging, then, is that it
does present some barrier, but it is not a complete lack of
barrier is what you are saying?
MR. CARR: No, it is not a complete lack of
barrier.
MR. PETERSEN: But I do get, then, from what you
hare just said that you would agree that there is mixing
across that barrier.
MR. CARR: Yes, there is mixing across the
barrier. There is mixing through the thermocline in Lake
Erie. Dr. Pritchard, I believe, said although I don't
think he meant it the way it came out that the thermal
barrier enhances mixing. It may enhance mixing inshore; it
may enhance mixing on both sides of it, but it does not
enhance mixing from the inside to the outside.
MR. PETERSEN: Now, to return to the question I
asked you: If there is some mixing across the thermal
barrier, have you quantified that in terms of mathematics,
or have you performed any studies as to the extent of such
-------
1254
J. F. Carr
mixing?
MR. CARR: No.
MR. PETERSEN: I think I have no further questions
at this time. Thank you.
MR. STEIN: Thank you.
Are there any come on up. While you are
coming up, I would like to make a couple of procedural
points clear if I may. One, that after the Federal report
as well as any other, I believe we offered full opportunity
for questioning We announced relatively early
yesterday that at the request, I believe, of Mr. Currie
that Mr. Barber and his group would provide this information
and, of course, these people are open to questioning by
whoever is here. I know we have the occupational problem
that lawyers also have to be around when sometimes other
people aren't here. Perhaps let me give a personal
aside. You see how difficult it is sometimes for me to get
a report out from some scientific people,particularly when
they are at a different agency than mine and all I have is
my persuasive powers to get them to do it.
MR. KEANE: My name is Steven Keane. That is
spelled K-e-a-n-e, and I am a scientist of the nature of
Mr. Bane and Mr. Petersen; namely, I am an attorney for
Wisconsin Public Service Corporation, for further
-------
1255
J. F. Carr
identification, and I would just like a little information.
Did you mention, I think, at the conclusion of
your original presentation that the fish species in Lake
Michigan that three of the species in Lake Michigan had
disappeared in the course of the past number of years?
Are we to understand from that that that bore any relation
to the thermal conditions in Lake Michigan?
MR. CARR: It bore no relation whatsoever, and I
was merely using it as an example of what has happened
in the Great Lakes, in which we lose species after species,
population after population, with no one to blame.
MR. KEAJJE: Fine. This was a good clarifying
question then.
One further question in that respect: You have
been here during the past several days when Drs. Raney,
Pritchard, and so forth, testified, and described the type
of examinations and surveys that they had made in connection
with thermal pollution from the various outfalls of
electrical generating stations. Have you yourself, sir,
to any degree, made that kind of a survey which could in
any way for us describe by picture or otherwise the nature
of plumes by which you disagree with their contentions as
to what they are, or by which you might indicate that you
believe that their conclusions that the harm to fish life
-------
1256
J. F. Carr
is insignificant could be challenged? Have you made any
such surveys?
MR. CARR: I have not personally made these
surveys, and I think what he said was mostly in agreement
with what they were saying.
MR. KEANE: Very good. Thank you.
MR. STEIN: Are there any other questions?
MR. HIPKE: My name is JackHipke from Wisconsin
Power and Light.
a
I just wanted to ask a question. Tou say you
cannot determine the mineral content in the two zones that
are separated by the thermal barrier due to dilution. You
also stated that there is a definite plankton concentration
on one side of the thermal barrier. Did you do any plankton
counts on the water on the two sides of this barrier?
MR. CARR: I did not.
MR. HIPKE: How about bacterial count, since this
is supposedly an area of concentration of all nutrients,
wouldn't this this would be some indication if there
was a passage of water from one barrier to the other?
MR. CARR: I think the statement was made that
any river discharge into this inshore zone during the time
the thermal bar was there would tend to keep most of the
nutrients inside this thermal bar and would prevent mixing.
-------
1257
J. F. Carr
The only data I can cite on that were some studies done
in 1965 in the vicinity of Ludington, in which phosphorus and
nitrogen was higher in this inshore zone than the offshore
zone, this was due to a river on the opposite side of the
lake. This was not true. You could not measure this.
MR. HIPKE: Well, it seemed like this would be a
very good indication, once and for all, if you could find
out if there was either a higher plankton count or a
bacterial count on one side of the barrier or not.
MR. CARR: The statistic I cited was about four
times better visibility on one side than on the other.
MR. HIPKE: You really didn't actually take a
plankton count so you can't really say it was the plankton
that caused it.
MR. CARR: I can definitely say it was plankton
causing it, yes. I didn't count them.
MR. HIPKE: And there was some things in the
"white paper" on Clostridium botulinura that bacteria are
supposed to increase with temperature in the area of the
plume. Since these are classified as anaerobic bacteria
would you like to comment if there would be a decrease in
bacteria in this zone or supposedly an increase?
MR. CARR: Do you have a statement from
Dr. Graikoski on this?
-------
1253
J. F. Carr
MR. BARBER: Yes, I do.
MR. STEIN: Why don't we wait you are going
to make a presentation, Mr. Roberts, arenft you?
MR. ROBERTS: I am now.
MR. CARR: Yes.
MR. STEIN: Can you wait on that question?
MR. HIPKE: Yes, I have one more question as
far as the dispersion of the plume. I don't know if this
is one of your questions or not, but from the 1 million
kilowatt nuclear plant how did you determine the dispersion
at 364-square-mile area back down to ambient?
MR. CARR: Would you save that question for Mr.
Roberts, please?
MR. HIPKE: Right, thank you.
MR. CURRIE: I have one more question, Mr.
Chairman.
It is prompted by a question that I believe was
asked by Mr. Fetterolf a moment ago, and he was asking
whether heat can be a limiting factor in the production of
algae. He attempted, I think, to distinguish between
productivity, on the one hand, and a standing crop, on the
other, and I would like a clarification as to what is meant
by that if I could have it.
MR. CARR: A standing crop is the amount of
-------
1259
J. F. Carr
organisms present at any one time. Productivity is the
rate at which they are renewed.
MR. CURRIE: Well, if there is no increase in the
standing crop but there is an increase in productivity,
have we made the problem of algae more serious?
MR. CARR: Well, it is usually the standing crop
that most people complain about, if you are talking
about that. If you are talking about the rainout of
plankton, perhaps the productivity would be the thing we
are concerned with. It is a high standing crop that people
see.
MR. BROUGH: My name is Jphn Brough. Did I
understand
MR. STEIN: Do you want to identify yourself
further, whom you represent?
MR. BROUGH: Well, I work for Inland Steel
Company.
Did I understand you to say that when you were
discussing eutrophication that eutrophication can be
beneficial? I thought I heard you say this. I was
interested to clarify it.
MR. CARR: Yes.
MR. BROUGH: Would you elaborate a little more
on this, because I got the impression from reading the
-------
1260
J. F. Carr
"white paper" that the increasing eutrophication was bad,
and I just would like to know about that.
MR. CARR: If you are a catfish farmer in
Arkansas, you try to have as eutrophic a pond as possible.
If you want to go swimming in a body of water, you want to
try to have as oligotrophic a pond as possible. So it
depends on your use of waters, whether it is desirable or
not.
MR. BROUGH: In the context that you were talking
about in the "white paper" is that eutrophication good or
bad?
MR. CARR: This is based on what the people appear
to prefer, and everything I have heard at every conference
they prefer clean water with no slimy algae on the beaches.
MR. BROUGH: I see. Thank you.
MR. CARR: Undesirable.
MR. STEIN: Mr. Brough, I knew where you worked,
I just wanted to see if you were still working there.
Any other comments or questions? If not, thank
you very much. I think the record on this is going to be
very valuable, and I think we are really getting pretty
precise on the issues.
MR. CARR: Excuse me, may I introduce the next
speaker?
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1261
P. J. Colby
MR, STEIN: Tes, go right ahead.
MR. CARR: Next will be Dr. Peter Colby*
DR. COLBY: I am Peter J. Colby, the project
leader in the Fish and Wildlife Service, studying the
biology and ecology of Great Lakes fish, and one of the
authors of Chapter IV of the "white paper." I received my
Ph.D. in 1966 at the University of Minnesota in fisheries
biology. Prior to receiving my Ph.D., I worked for five
years for General Foods Corporation in research and
development. I worked the past four years at the Great
Lakes Fishery Laboratory conducting both laboratory and
field studies.
During this hearing, there has been no evidence
in the form of studies or data presented here or publications
made available, which have demonstrated that fish life
will not be damaged by the intakes and the hot water
plumes during their critical life history stages. In
contrast, our studies at the Great Lakes Fishery Laboratory
and published literature cited in the"white paper" indicate
that massive damage will be caused by thermal discharge
predicted in the year 2000.
Another point I want to make: we have talked
about lab studies. All of our lab studies cited in the
-------
1262
P. J. Colby
"white paper" were practical studies directed to answering
questions raised, but unable to be answered by field
observations. Where confirmation has been attempted, the
results of these lab studies have been consistent with
results predicted from field observations. Studies of the
early life requirements of lake herring, for instance, have
yielded a predicted model for incubation times. When tested
against field observations this was found to actually
predict hatching time in nature when water temperatures
are known.
In other words, our time-rate studies in the
laboratory applied to a model have been verified by three
years of research in the field. So when I say that 3»6
degrees Fahrenneit is going to shorten the incubation period
by 29 days of lake herring in the lake, I feel reasonably
sure that is going to happen.
In reply to Dr. Raney's studies, he made a
statement yesterday that I just cannot believe. He said
coldwater fishes do not use the inshore waters at least
within the last 50 years. This is absolutely not true.
I cannot imagine what he was thinking. He made another
statement. He said that fish can swim away from an intake
velocity of one-half foot per second. He didn't specify
the size of the fish. This may be true for some fish. It
-------
1263
P. J. Colby
is not true for sac fry.
To my knowledge, also, I want to add there is no
intake design in use by powerplants which will prevent
entrainment or damage to larval fish. If there is, I want
to know about it.
And, in conclusion, it is in my opinion that
regardless of which plume model is used, as long as there is
an intake and a hot water discharge in the beach zone, there
will be local damage to fishes and fry utilizing the beach
zone. Intakes and hot water discharge covering significant
areas of Lake Michiganfs shoreline will destroy the lake
herring and whitefish stocks in these areas, and if these
species are presently depleted in these areas, this will
prevent them from returning to their original distribution
and abundance.
MR. STEIN: Does that conclude your statement?
DR. COLBY: That concludes my statement.
MR. STEIN: Thank you, Dr. Colby.
Are there any comments or questions?
MR. PURDY: Er. Colby, again, you have repeated
this matter of a discharge into the beach zone, and maybe
we wonder how this might be accomplished in some other
zone. Silt I don't think that is for you and I to worry
about, because unless we answer this question, I think
-------
1264
P. J. Colby
somebody will figure out how it can be done and then we
will have to answer it.
And that is: Do you predict the same sort of
problems if the discharge is made into the offshore waters
rather than into the inshore waters or the beach zone
waters?
DR. COLBY: I am not in a position to answer
that. I don't know.
MR. STEIN: Are there any other comments or
questions?
MR. CURR3E: Yes, one, Mr. Chairman.
You say, Dr. Colby, that there are studies that
show that fish will be hurt by the discharges contemplated
by the year 2000. Now, those studies are not presently in
the record, are they? I think it would be helpful if they
were.
DR. COLBY: Are you referring to the study of
why I am saying that incubation period will be shortened?
MR. CURRIE: Well, I think you made the clear
statement that although there was evidence of studies in
the record that would show no harm would result from power
discharges by the year 2000, you had studies that would show
the opposite.
DR. COLBY: Let me qualify this. My studies
-------
1265
P. J. Colby
show that if eggs are laying on the bottom and the
temperatures are raised 3.6 degrees, over the period of the
incubation period they will hatch 29 days early. This means
instead of hatching in April they will hatch in March.
Now, in March, this is a hostile environment. I haven't
conducted this study in Lake Michigan, and I am referring
because we don't have the data I am referring to
other studies a literature search of other studies
pertinent to these fish that were conducted throughout the
world. They are all cited in the paper, and the case was
put together that, for instance, if these fish hatch a-
month early, it is my opinion that the food availability
will not be there. Then I cite Einsele's paper showing
the effect of density and light intensity as far as its
effect on the survival of fish. I cited the German studies,
which show that when they hatched their fry early they
do not get survivial in lakes. For instance in Lake
Constance, they had to reduce the incubation temperatures
to get those fish to hatch in April so they could be available
at the right time, when the plankton was available for
survival.
How, all this is in here. It is all presented.
MR. CURRIE: But I think my point is the same one
I was trying to make to people from the power companies.
-------
1266
P. J. Colby
Both sides seemed to me to have said: Studies show that,
and then they proceed with their conclusion. But they give
us their conclusion, their summary of this study, their
assessment of its results, without giving us the study
itself, and I would be more comfortable if I could see the
study.
DR. COLBY: Well, you have got the information
right here, and if you want to go through and read those
literature citations and all of the bibliographies you may
draw the same conclusions as I. If you don't, I will debate
it with you. I didnft conduct these studies; they are in
the libraries. Read them. I think people should be more
scholarly about these problems. You sit in the position here
to make a decision. Why don't you read some of this?
MR. STEIN: You know, Dr. Colby, this works both
ways^. I really have to give a tremendous vote of thanks
to the power industry, because they talked about the
anonymity of your report, and I guess they spun you back
out into the real world to talk to us. What I have been
trying to do in the Government for 10 or 20 years and
certainly since we came into the Department of Interior
and haven't been that successful, is getting out individuals
like you here today. They have been able to achieve this,
and I think this is great. I would like you to meet each
-------
126?
P. J. Colby
other. I think we are having a wonderful conference here
because of this. This is a great thing, and I hope you go
back and tell Gottschalk, Glasgow and Edsall what an
exhilarating experience you have had. Maybe we can keep
doing this.
MR. CURRIE: It seems to me that when someone
comes before judges and other decision-makers and asks
them to accept the position that one has adopted, one has
some responsibility of presenting evidence to persuade the
judge to the validity 6f his position.
MR, STEIM: That may be. I don't want to get
into this. But the notion is what you are doing is
getting an opinion here an opinion evidenced from
an expert. We are not in a court of law; we are not
dealing with evidence.
Now, as I understand it, these studies were
done presumably by these other scholars. They were not
done by Dr. Colby. I don't know, if we were dealing
with strict rules of evidence in a court of law whether he
could get those in. What he might be able to do is qualify
himself as an expert and say, on the basis of his reading,
he was giving us his opinion. I don't know whether you
would be in accord with what we got here from this type
of expert witness.
-------
1268
P. J. Colby
We are getting these facts out, and this is something
on which the conferees are going to hare to make a judgment.
I think this again boils down to the question of where
you have evidence, perhaps referred to in literature,
which in the opinion of some expert is applicable to Lake
Michigan some experts might not think it applicable to
Lake Michigan that on the basis of that 1)whether
we permit something to go on in the lake and don't prevent
it and wait for damage to occur before we do anything, or
2)whether we have sufficient evidence or a sufficient
cause to make a judgment that we are going to place
certain restrictions on activities in anticipation that
if we don't, damage might occur. I think this is the
judgment we have to make after we hear all this information.
Are there any other comments or questions? Is
there anyone in the audience who wants to ask a question?
MR. BANE: Charles Bane, representing
Commonwealth Edison Company.
Did you hear Dr. Raney's testimony yesterday
about the circumstance I think it was on the Pacific
Coast in which there was evidence in fishes I think
it was the specie of salmon was able to pass through
without harm and to stay alive, pass through the condensing
water as it went over the turbines and was discharged? Did
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1269
P. J. Colby
you hear that testimony?
DR. COLBY: Yes, I heard that, right.
MR. BANE: Do you agree that it is possible that *
DR. COLBY: What size fish was that?
MR. BANE: What size?
DR. COLBY: Yes.
MR. BANE: I don't recall.
DR. COLBY: I think that would be important.
I don't think it was fry. He didn't specify what size it
was.
MR. BANE: Well, is it your testimony, with
respect to harm to fish, it was confined to fry fish?
DR. COLBY: Yes.
MR. BANE: You wouldn't deny, then, I take it,
that a fish of another size are capable of surviving, of
being passed over the condensers?
DR. COLBY: No, not if he said it.
MR. BANE: Have you made any studies to determine
whether fish, whether they are of the fry size or otherwise,
could survive being passed through the condensing water not
only over the turbines, but in a cooling tower operation?
DR. COLBY: No.
MR. BANE: Would you expect that fish could
survive a cooling tower operation?
-------
1270
P. J. Colby
DR. COLBY: Just as intuition, no.
MR. BANE: Your intuition is that they would not
survive?
DR. COLBY: Yes.
MR. BANE: Yes. Thank you.
MR. KEANE: Steven Keane from Wisconsin Public
Service Corporation. And I don't think I will be able to
find the answer to this one in the book.
As I understood your statement before, you were
taking some issue with what I understood at least Dr. Ayers
to have stated, that there were some differences in field
surveys and what happened in laboratories, and I think
the impression you are attempting to give us now, I take
it, is that what he develops in the laboratory is
sustained when you get out in the field. Am I understanding
you correctly?
DR. COLBY: Yes, this one study, I feel ~ it
will be published in a scientific journal and the community
can decide this for themselves.
MR. KEANE: But this is one study, and how confining
is it? What is it a study about?
DR. COLBY: It is a study about lake herring
and the effect of temperature on rate of development.
MR. KEANE: I see. Now, as I understood when
-------
1271
P. J. Colby
Dr. Ayers was talking, he was using as a demonstration the
fact that in a body such as Lake Michigan there is a great
variety of temperatures at any given time, that there are
currents, that there are winds blowing.
DR. COLBY: Right.
MR. KEANE: And that a fish will go into a
temperature that he wants, and this sort of thing. You
agree with him, do you not, that insofar as those are
applicable and I think they were applicable to Dr. Ayers1
statements that there may well be differences or
distinctions between what you find in the laboratory and
what you find in the field?
DR. COLBY: It depends on the study. I don't
know what he found in the laboratory what specifically he
found in the laboratory that didn't agree with the field.
MR. KEANE: Well, I cannot possibly repeat his
statement. Of course, you have this in writing, I am sure,
but be that as it may, have you ever made any survey or
study to find out whether there were differences in the field
from what you found in the laboratory?
DR. COLBY: On this study on the fry, where I
went out to the field and actually observed lake herring
on the spawning beds and the rate of development, he
predicted when the 20 phases of development would occur,
-------
1272
P. J. Colby
and they came within 2 percent.
MR. KEANE: Are you able to duplicate current,
for example, in your laboratory studies?
DR. COLBY: Duplicate current?
MR. KEANE: Yes.
DR. COLBY: I think we could.
MR. KEANE: Do you?
DR. COLBY: No.
MR. KEANE: Have you?
DR. COLBY: No.
MR. KEANE: Are you able to duplicate differences
in temperature in the same bed or in the same relative
area or in the same area in a near vicinity?
DR. COLBY: In other words, can we set up a
temperature gradient, do you mean?
MR. KEANE: Yes.
DR. COLBY: And vertical? We could.
MR. KEANE: Do you?
DR. COLBY: We haven't.
MR. KEANE: You haven't?
DR. COLBY: No, I haven't.
MR. KEANE: Have you set up temperature gradient
studies?
DR. COLBY: No, we haven't.
-------
1273
P. J. Colby
MR. KEAME: Well, then, don't you think from the
very factor of the absence of those gradients, as you
*
used the term, and which I presume is the correct one, that
your model, as you determine it in the laboratory, is
different from what would be experienced in the field?
DR. COLBY: Oh, we work at constant temperatures
in the laboratory, right. You don't get this in the field.
MR. KEANE: So that there is this difference
between lab studies and field studies?
DR. COLBY: But it is how you use these constant
temperatures that is important. This is why we went to the
field.
MR. KEANE: As I understand, you only went on
this conference to satisfy yourself in this very narrow
area for this hearing.
DR. COLBY: To satisfy myself that the constant
temperature, that rates of development differ from the
constant temperatures, and then you take these rates and
apply them to the temperature regimes in the field, and,
for instance, you take the time of exposure of a temperature
and multiply that time by the rate and you get a progress
to development. You do this for twenty stages, and as
you progress when you get to a 100 percent progress,
this developmental stage will occur. Then go back
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1274
P. J. Colby
and we have put this into a computer all these rates
and then when the computer looks back and goes back and
starts answering to developmental stage 2, 3» up to 20,
Then, we have gone to the field and we have taken temperature
regimes and applied these laboratory determined rates to
the field, and we get verification that they occur in
a natural temperature regime. We can predict when the
eggs will hatch in the lake that we are studying,
Now, with these rates, we have gone to computer
simulation, and we have added 1 and 2 degrees centigrade
above ambient 2 degrees centigrade, (3.6 degrees
Fahrenheit) and these results from these rates predict
that these eggs will hatch 29 days early.
MR, KEANE: I had no idea I was going to get that
much answer for that question.
DR, COLBY: That is what happens when you ask
an expert a question.
MR, KEANE: Well, I didn't understand it was
cross examination. As I explained to you, sir, we are
trying to get some more facts,
Now, this witness I call him a witness, being
a lawyer, but he is, I think up here today, and he has
been quite critical of the statement that Dr, Ayers, as
I understood was the one that made it, that there were
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1275
P. J. Colby
substantial differences between studying the life history
of these fishes and other organisms in the natural bodies
of water such as Lake Michigan and in the laboratory and,
as I understood this gentleman was taking issue, I was
simply trying to find out whether or not that was true.
DR. COLBY: There are also many studies that are
in good agreement, laboratory and field. I have one
in my briefcase if you want to look at it.
MR. KEANE: I am certain that Dr. Ayers'
statement was not that they are exclusively all wrong, but
you do not yet agree with him, then, to some extent, let
us say, that studies in laboratories do not necessarily
have to fall in line with what actually happens in open
waters. Is that correct?
DR. COLBY: Oh, this is a case of how good the
investigator is. If he sets up a poor experimental design
he cannot help that his lab studies don't agree with
the field or meet his predictions. Yes, that is true. It
depends on the individual.
MR. KEANE: Are you satisfied that all of your
laboratory studies simulate the field in their exactitude?
DR. COLBY: Yes.
MR. KEANE: You are satisfied?
DR. COLBY: I am satisfied.
-------
1276
P. J. Colby
MR. KEANE: Even though you do not have temperature
gradients and you do not show current differentials or the
effect of wind?
DR. COLBY: Yes. I think temperature is the
most important and these other factors are minimal.
MR. KEANE: But you don't have the temperature
gradient either because you just said that you didn't. Or
did I misunderstand you? I understood you to say you do not
simulate temperature gradients in the lab.
DR. COLBY: No, that is right.
MR. KEANE: That is all.
DR. COLBY: Right.
MR. STEIN: But let me ask you, Dr. Colby: Do
you consider not simulating these temperature gradients
in the laboratory to invalidate the laboratory correlation
with your field testing when you check them out?
DR. COLBY: I think this should be done.
MR. STEIN: When you verify your work in the field,
do you feel the absence of temperature gradients maintained
in the laboratory do not permit you to verify with the
system that you use of getting the material and running
it through the computer to check it out?
DR. COLBY: No, I don't think I have to have
the gradients in nature in the laboratory.
-------
1277
P. J. Colby
MR. STEIN: Right. Thank you.
MR. PURDY: On this matter of the eggs on the
spawning bed, in the one case you are studying a constant
temperature in the laboratory, and are the eggs subject to
a constant temperature in the lake
DR. COLBY: No.
MR. PURDY: -- over their spawning period?
DR. COLBY: No.
MR. PURDY: What sort of variation of
temperature might they go through?
DR. COLBY: They go from lake herring spawning,
4, dropping to 3» down to .05 degrees centigrade, and up
about 14 in the spring. They experience a curve like this
(indicating).
MR. PURDY: So your study that you are talking
about of where they would hatch that much earlier would be
if they were exposed throughout this spawning period to
the full 2 degrees or
DR. COLBY: Above that curve.
DR. PURDY: Above that curve?
DR. COLBY: Right.
MR. PURDY: So if they were not exposed to that
during that full spawning period, they would not hatch that
much earlier?
DR. COLBY: That is right.
-------
P. J. Colby
MR. LEHNER: Kenneth Lehner, Wisconsin Electric
Power.
Tou mentioned that the eggs hatched 29 days
prematurely.
DR. COLBY: That is right. That is right, early.
MR, STEIN: May I make a suggestion because you
have possibly experienced this before, that you wait
until the question is completely finished before you begin
talking. Mow, this works both ways. You notice the lawyers
will not interrupt you usually when you have an answer, and
try not to interrupt them, because otherwise we cannot
maintain the record.
DR. COLBY: Thank you. I am sorry.
MR. LEHNER: You mentioned a 29-day prematurity.
Could you tell me approximately how many eggs were involved?
Did they all hatch exactly 29 days prematurely and, if not,
what would be the statistical variation of the time of
hatch?
DR. COLBY: Early hatch was determined by computer
simulations. We can give you an idea of constant
temperatures the time to hatch from fertilization.
Some hatch were based on constant temperature results.
For instance, an increase of temperature from 68
degrees centigrade, by 2 degrees, in the laboratory at
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1279
P. J. Colby
constant temperatures would shorten the incubation period
by 30 days, and we have done this.
MR, LEHHER: For every egg would it shorten the
temperature?
DR. COLBY: Yes, it would do this for every egg,
however, the time interval is to 50 percent hatch. We
have the number, I believe it was around 14-0, 200 eggs
I can 't remember exactly right now and these would
incubate and hatch 50 percent of them would hatch within
these time intervals. So this is the time from fertiliza-
tion to 50 percent hatch, and it forms a normal distribution.
MR, LEHNER: In other words, the great majority
hatched at 29 days, but there were some that probably
hatched at 21, and some, say, at 40.
DR. COLBY: Right.
MR. LEHNER: What I am getting at is perhaps
would you agree that there might be some evolutionary
pressures put on the indigenous fish population? Supposing
that we did raise the temperature, would the species
evolve to accommodate their gestation time to the new
temperature?
DR, COLBY: Mot in as short a period of time as
we are talking about.
MR, LEHNER: To the year 2000, is that what you
-------
1230
P. J. Colby
mean?
DR. COLBY: Thirty-five years?
MR. LEHNER: Yes.
DR. COLBY: No, I don't believe so, but I am not
an evolutionist. That is my opinion. If there is an expert
in evolution and he can tell me the rate of evolution and
whether he actually thinks this can happen, I will yield
to his testimony.
MR. LEHNER: Thank you.
MR. STEIN: Are you suggesting we put out heated
water to create a brave new world?
MR. LEHNER: No, I think what I am suggesting
is the relatively rapid adaptation of natural organisms
to environmental changes.
MR. STEIN: Right.
MR. PETERSEN: 0. K. Petersen.
I think this is 1970, isn't it? Just 30 years
to the year 2000.
DR. COLBY: Right, oh, pardon me. Okay.
MR. PETERSEN: I trust that the rest of your
mathematics are done on the computer.
DR. COLBY: Thank you.
MR. PETERSEN: I had once again a little
difficulty, but I noticed that you said that if the eggs
-------
P. J. Colby
were exposed to 3.6 degrees centigrade, which I think is
about 6.5 degrees Fahrenheit
DR. COLBY: 3.6 degrees Fahrenheit would be 2
degrees centigrade.
MR. PETERSEN: I understood you to say
centigrade.
DR. COLBY: Maybe I made a mistake, but I am
correcting it if that is what I said.
MR. PETERSEN: Then, at 3-6 degrees, which
particular fish populations I believe you spoke of
whitefish several times were there some other ones?
DR. COLBY: No, this was lake herring.
MR. PETERSEN: I wasn't speaking about your study,
I was speaking about your application to Lake Michigan. I
think you mentioned a fear of damage to whitefish population.
I wondered if there were any other fish populations which
you had particularly in mind when you were making your
conclusions as far as Lake Michigan was concerned.
DR. COLBY: No, those two species.
MR. PETERSEN: Whitefish and lake herring?
DR. COLBY: Whitefish is a closely related
species.
MR. PETERSEN: I see. And where do whitefish
spawn normally? I don't know the answer to this question,
-------
1232
P. J. Colby
which is a little bad for a lawyer, but I find I am in a
bad spot.
DR. COLBY: From all of the studies that I have
read, they spawn in the shallow waters from inches out to
20 feet.
MR. PETERSEN: In Lake Michigan?
DR. COLBY: These are in the other Great Lakes,
and there is at present a study being documented by the
University of Wisconsin. They haven't found the spawning
area yet, but there is all reason to believe that if they
do in all of the other lakes they should in Lake Michigan,
too.
MR. PETERSEN: Do you have any reason to believe
that the whitefish or lake herring spawning area is in the
area of any present thermal plume from an electric
generating station or proposed one?
DR. COLBY: We don't know where these spawning
areas are. We do need an inshore ecology study to find
these spawning areas, so I cannot say.
MR. PETERSEN: I have mentioned to the previous
witness something about the testimony that the area for
some distance out to 20 or 30 feet of depth is a relatively
barren area, a relative desert, that there the benthic
organisms are gone, there aren't any algae or other materials
-------
P. J. Colby
present. Do we have any reason to believe that in this
particular area, subject to this wave action, that we
would find the whitefish?
DR. COLBY: Yes, these are from the studies
in South Bay mouth, they like these rocky barren exposed
areas.
MR. PETERSEN: These are not rocky, these are
shifting, grinding sand.
DR. COLBY: Studies in Europe show that they also
lay their eggs on coarse sand. Now, the question is: The
people in lands and forests believe that eggs that are
laid on these bottoms do drift and roll down the beach.
But we just donft know that much about whitefish eggs
exposed to these areas on sand areas.
MR. PETERSEN: Then, really as far as you are
concerned, you have no study which you have performed, and
you know of no study performed in Lake Michigan or even in
shifting aand similar to that on the eastern shore of Lake
Michigan, pertaining to either whitefish or, as I understand
it from you, the related species of the lake herring?
DR. COLBY: No, not the spawning grounds. The
nursery grounds are being studied where the fry are located.
MR. PETERSEN: Now, do you have any indication that
there is a nursery grounds in the vicinity of any of
-------
1234
P. J. Colby
the present or proposed thermal discharges from electric
power generating stations?
DR. COLBY: May I use the map?
MR. PETERSEN: You certainly may.
MR. STEIN: Go ahead. , ,:
v - -. <
DR. COLBY: The studies by Walter Hogman at the
University of Wisconsin are in this area (indicating).
MR. STEIN: That is not going to show in the
record.
DR. COLBY: Well, they are all along the inshore
areas he has found 90 percent of them within 10 feet
in the basin and along the shores of North Green Bay.
Now, do you have a plant in there proposed?
MR. PETERSEN: I represent Consumers Power
Company.
DR. COLBY: Oh, pardon me.
MR. STEIN: Well, I believe someone was in here
talking about something between Fox River and Green Bay. I
think the record is clear on that.
DR. COLBY: I would say that was in the area.
MR. PETERSEN: All right. You have indicated, as
I understand it, an area along Green Bay from approximately
the city of Green Bay to approximately the city of
Menominee, and you indicated, as I noticed your finger
-------
1285
P. J. Colby
pointing, the southeast shoreline of that bay. Now
DR. COLBY: Southeast, and also on the Michigan
shoreline of Green Bay, they found them there.
MR. PETERSEN: Michigan shoreline of Green Bay?
DR. COLBY: I mean the outer shoreline.
MR. PETERSEN: Thank you. I was having a little
difficulty with that.
DR. COLBY: The west coast of Lake Michigan.
MR. PETERSEN: Now, in these areas, are any of
these nurseries exposed to a thermal plume?
DR. COLBY: I don't know.
MR. PETERSEN: I see. And you, I noted, did
not discuss the eastern shore of Lake Michigan itself. I
take it that you haven't identified nor has anyone
else the spawning ground in that area.
DR. COLBY: No, we are in a great need for an
inshore ecology study.
MR. PETERSEN: Once you have the fry, have you
any reason to believe that they would be harmed by being
at the edge of a thermal plume where the temperature
difference is, let us say, 1 or 2 degrees above ambient
temperatures?
DR. COLBY: Not from temperature. If they are
going into supersaturated solution and they get if they
-------
1236
P. J. Colby
get into a supersaturated gas solution and they get gas
bubbles in the gastrointestinal tract, I believe this would
kill them, and I think it should be investigated.
MR. PETERSEN: Have you any reason to believe
that the oxygen supersaturation which is described as
coming just out of the condensers would continue to exist
at the edges of the plume?
DR. COLBY: I don't know.
MR. PETERSEN: Is there any belief on your part
that the fish would swim into the plume to a point where
they became uncomfortable?
DR. COLBY: I believe this could be a possibility.
MR. PETERSEN: A possibility?
DR. COLBY: Yes, but I don't know.
MR. PETERSEN: But not a probability, or do you
have any reason
DR. COLBY: I have no reason to say one way or
the other.
MR. PETERSEN: I see.
DR. COLBY: I think it should be studied. I was
hoping that this was some of the evidence that we would
get today.
MR. PETERSEN: I also would assume that your idea
of where the lake would be heated was based on someone
-------
P. J. Colby
else's study of the inshore area and thermal bar or
barrier, et cetera? I take it that the inshore area idea
or let me start again.
Do you agree with this inshore theory that has
been promulgated in this "white paper?"
DR. COLBY: Yes.
MR. PETERSEN: Now, is this theory based upon
your work or someone else's?
DR. COLBY: Someone else's.
MR. PETERSEN: And you did not take part in the
studies which produced that theory?
DR. COLBY: N*.
MR. PETERSEN: Now, let us assume that for a
small area let us say for the full area of the plume,
we will say, take a square mile, which seems to be vastly
more than would be involved in each of the plants involved
and we add, say, 30 square miles of the lake shore covered
by plume, and for this purpose, down to the bottom, which
doesn't appear in the testimony, what would be the overall
effect on fish population of being deprived of that amount
of breeding area, if it would be such a deprivation by
being raised, as we decided now, 3-6 degrees Fahrenheit?
DR. COLBY: It is my opinion that those fish
that use those areas for spawning would be deprived of
-------
128S
T. A. Edsall
these areas and you would lose these fish in this area.
MR. PETERSEN: You missed the question. What
would be the overall effect on the fish population of that
species in Lake Michigan?
DR. COLBY: I don't know.
MR. PETERSEN: I have no more questions at this time,
MR. STEIN: Thank you.
Are there any further questions for Dr. Colby?
Thank you very much, Dr. Colby. We certainly appreciate it,
Mr. Barber.
MR. BARBER: I would like to introduce now another
of our fishery biologists, Mr. Thomas Edsall, from the
Great Lakes Laboratory, who will make a statement.
MR. STEIN: And who comes after him?
MR. BARBER: Mr. Roberts will just read a brief
statement into the record, then Mr. Callaway excuse me
this other gentleman, Dr. Charlie Powers, and Mr,
Callaway, and then myself,
MR. STEIN: All right. Thank you. Just so we
have an idea.
STATEMENT OF THOMAS A. EDSALL, BIOLOGIST,
FISH AND WILDLIFE SERVICE, GREAT LAKES FISHERIES LABORATORY
ANN ARBOR, MICHIGAN
MR. EDSALL: Mr. Chairman, conferees, ladies and
gentlemen. My name is Thomas Edsall. I am a research
-------
12S9
T. A. Edsall
biologist with the Fish and Wildlife Service, Great
Lakes Fisheries Laboratory, Ann Arbor, Michigan. I am one
of the authors of Section IV of the Department of
Interior "white paper" dealing with the "Physical and
Ecological Effect of Waste Heat Discharge on Lake Michigan."
I have a Bachelor of Science degree in fisheries
from the University of Connecticut, and a Master of Science
degree in fisheries from the University of Michigan. My
graduate studies and post-graduate studies at the University
of Michigan have dealt with the physiological ecology of
fishes. I have been employed by the U. S. Fish and Wildlife
Service at Ann Arbor for approximately 14 years of which
a total of about 6 years was spent in field ecological
research on the Great Lakes. Three of these 6 years were
spent on Lake Michigan. The remainder of my term of
employment has been spent conducting lab studies on the
environmental requirements of Great Lakes fishes including
studies of the thermal requirements of these fishes.
I have recently published a couple of papers
on the temperature tolerance of Great Lakes fishes.
These are listed in the "white paper," and I have a thirtf-
paper which will appear in print this fall.
I have conducted or supervised a number of other
lab studies of the temperature requirements of Great Lakes
-------
1290
T. A. Edsall
fishes. These studies are now continuing or have been
completed and are in the process of being drafted into
manuscripts for report form.
I would like, at this time, to make two
statements concerning the Department of Interior Fish and
Wildlife "white paper." Firstly, there can be little
doubt^even among those of you who are of a different
persuasion than perhaps i am, that Section IV of .the "white"
paper" is as fully as possible a documented current and
complete presentatior of the facts describing the potential
effects on the ecology of Lake Michigan of using Lake
Michigan waters for cooling purposes. The lack of any
serious or effective attempts to refute statements
concerning fishes in Section IV of this document, I think,
attests to its validity.
Secondly, I would like to speak to the problem
of entrainment, induced mortality among Lake Michigan
aquatic organisms.
Dr. Raney, in his discussion, related to the
first filling of the swim bladder of whitefish larvae.
Incidentally, I believe this was a study done by Dr.
Tate of the University of Toronto, who stated and I think
this is almost a direct quote whitefish larvae that rise
to the surface in the hottest area of the plume would not
-------
1291
T. A. Edsall
survive.
Because the hottest area of the plume is at
least as hot as the temperature of entrained water at or
immediately downstream from the condensers, we must also
expect that all of the whitefish larvae passing through a
once-through cooling system would also be killed.
Furthermore, since information on the physiology and
ecology of whitefishes, including the Great Lakes whitefish
and the lake herring, show them to be similar in their
tolerances and requirements, we can also expect that the
lake herring would also be similarly affected when passing
through cooling systems or encountering the hottest portions
of thermal pollution.
Other species of fishes and aquatic organisms
may be similarly affected. Evidence for the loss of
entrained phytoplankton has been given by Morgan and Stress,
and this is a paper cited in the "white paper," and this
morning by Dr. Ayers at this hearing.
As stated in the whitefish paper (laughter)
I mean the "white paper" it is beginning to sound that
way, I am afraid as stated in the "white paper,"
whitefish and herring hatch in April through May and
spend about 90 days in the beach zone waters as larvae.
The thermal bar is present at this time or at least during
-------
1292
T. A. Edsall
the months of April and May and retards mixing of the
beach zone water with the waters farther offshore. Any
installation drawing cooling water from the beach zone
will draw in larval fishes and plankton in the beach zone
waters especially during the time that the thermal bar
exists, and according to projections in the "white paper,"
by the year 2000, the water drawn into these plants daily
will amount to about 1 percent of all the water in the beach
zone area of Lake Michigan proper. In the Chicago area
this amounts to about 4 percent daily of the beach zone
water. These are projections. Nearly all of the water in
the Lake Michigan beach zone area should pass through
cooling intakes once during the period of beach zone
residence of larval whitefishes. The whitefish here
means herring and lake whitefish. That is, 100 days or
during the period April through June. In the Chicago
that is a parenthetical statement in the Chicago area,
only 25 days would be required to pass all of the beach
zone water in that area through cooling systems.
According to sources cited above, Morgan and Stress,
Ayers, and Dr. Raney, all or nearly all of the organisms
in this intake water would be, in fact, killed. Complete
destruction of the class of herring or whitefish could be
accomplished during the first few months following hatching.
-------
1293
T. A. Edsall
Of course, it is probably not reasonable to assume that all
beach zone waters will pass through the cooling system only
once and, therefore, that all of the Lake Michigan beach
zone waters will be passed through cooling systems in 100
days, and that this same thing would be accomplished in
the Chicago area in 25 days. Longer times would
undoubtedly be required for these areas to be drawn through
the plants. If, however, we add to the mortality caused
by passers through the plant, the mortality that would be
caused due to entrainment in the discharge waters, I think,
we are going to find that the two types of mortality are
going to tend to complement each other,
Whitefishes that are entrained in discharge
waters and exposed to the hottest water in the plume
I seem to have lost my place here.
Basically what I am trying to say is that the
Pritchard model, which was Model No, IV, I believe, or
No, III, which has a high discharge velocity, would cause
a high degree of entrainment of lake water at the discharge
point, and that this would also tend to draw in fairly
large numbers of fish larvae that were present in that
area.
There is little doubt in my mind that if this
man-induced mortality is added to the mortality from
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1294
T. A. Edsall
natural causes, which are already acting to limit the
abundance of whitefishes, that the collapse of populations
of whitefishes in the Great Lakes could certainly be
expected by the year 2000 if not before.
Furthermore, any other fish species similarly
vulnerable to entrainment would also be expected to suffer
a similar fate.
That is all I have.
MR. STEIN: Let's just wait to see if the
panel
MR. PURDY: Doctor, in equating the problem,
do you equate the problem of drawing organisms through
the condenser has to be greater than the heat plume?
MR. EDSALL: I am sorry, I really don't think
I can answer that. 1 would say that on the basis of the
available evidence, that all organisms drawn through the
condensers the organisms that I specified would be
killed. Organisms drawn in by entrainment, according to
Dr. Raney, if they get to the hottest portion of the
plume, would also be killed. I don't know what volume of
water would actually be entrained for a given discharge
volume of water and I would have to know this before I
could answer your question.
MR, PURDY: Well, there are many schemes that
-------
1295
T. A. Edsall
can be utilized to meet the problem and for example,
if the heat discharge is exceptionally significant, then
the so-called closed system with very little blowdown
possibly has to be looked at. If the heat problem is not
so great, but it is the matter now of physically dragging
all of these organisms through the condensers, possibly
you can look at a cooling tower that has a significant
blowdown now to control corrosion products and the
buildup with solids in it. I am attempting now to
sort out what various schemes of controls could possibly
be used to meet the conditions that you are now describing,
MR. EDSALL: Well, as I said, I feel that any
organism that is drawn into the condenser tubes and
experiences a 20-degree Delta T, I guess that it is
typical. According to the expert witnesses that the power
companies have presented, the organism would die.
Similar effects would be expected in the discharge
effluent.
I expect that anything that passes through
cooling towers would also be killed. Am I answering
your question?
MR. PURDY: Tes. I realize that, but I don't
want to misconstrue your answer to me. You apparently
feel that some heat could be put into the lake. if we
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1296
T. A. Edsall
can control this other problem.
MR. EDSALL: I don't want you to misquote me.
I certainly didn't say that.
MR. PURDY: Am I wrong in this assumption,
then?
MR. EDSALL: Tour assumption is that some heat
could be put into the lake if we could control the problem
of mortality of entrained organisms?
MR. PURDY: That is correct.
MR. EDSALL: You would solve the problem related
to the entrained organisms if you kept heat out of the
lake, I suspect. The heat would have other effects which
have been described by Mr. Carr, anc? Dr. Colby, and will
be treated in more detail by Dr. Powers and others.
MR. PURDY: Okay.
MR. STEIN: Are there any other comments from
the panel?
Let me ask you, if I really understood what you
said. If we pursue the kind of pass-through devices for
all of the plants we heard about today on Lake Michigan
and let's assume that we have the same kind of system
throughout the Great Lakes and we set up relatively
uniform requirements then if we do that, we are going
to wipe out the whitefish in the lakes by 2000?
-------
1297
T. A. Edsall
MR. EDSALL: I say that might be a good guess.
MR. PURDT: I think this is fairly important, Mr.
Stein, because we are not talking now about a thermal
standard, we are talking about actually extracting them
out of the lake.
MR. STEIN: I understand that. That is why,
again, I made that little talk before. We are talking in
terms of closed systems, because if this is what we are
up against and I find this more and more in various
aspects of the problem as we go around the country I
certainly think the conferees and the industry have to be
thinking in terms if this is, in fact, the issue. I am
making no judgment on the validity of the statements and all
that, but I read the implications, Mr. Purdy, just as you
do. I have heard this pretty frequently today.
MR. PURDY: It seems to me that this is a separate
subject and should not be dealt with jointly with the thermal
standards.
MR. STEIN: Well, that may be true, but the
question here is perhaps when we started dealing with
this several months ago you thought you could separate
the thermal standard out. Now, I may be wrong, but as I
understand it, and I am not talking about feasibility or
-------
1293
T. A. Edsall
economics or practicality but i f you have a closed
system where they carefully screen and design intake and
a blowdown and you are careful what you do with the waters
you are disposing of, you can handle, at least on a
theoretical basis, both the intake problem and the entrain-
ment problem, the bruising problem, the mauling problem,
the adding of the chlorine, the discharge of the waste,
the hydraulic problem. It can all be handled theoretically,
at any rate, with a closed system, as well as the heat rise.
I think we have to recognize and I think we heard the
suggestion from Dr. Ayers maybe if we are thinking in
these terms, we have to give it careful consideration to
at least meet part of the problem with interim requirements,
until we can really get to the dimensions of it.
How, I don't know. As I say, the implications
of this seem to me to raise the same questions that you
raised in your question, Mr. Purdy. I think we are just
going to have to move toward meeting them.
Are there any other comments from the conferees?
If not, may we hear from the audience.
MR. EDSALL: I wanted to answer Mr. Purdy to
say that the subject of this entrainment damage was
introduced on Pages 74 and 75 of the "white paper" under the
heading Intake Damage.
-------
1299
T. A. Edsall
MR. STEIN: I think he said that he did include
a reference to this in his report.
Go ahead.
MR. FELDMAN: My name is Daniel Feldman. I am
from the firm of Isham, Lincoln and Beale, and I am here
on behalf of the Commonwealth Edison Company. Mr. Stein,
if I may ask one preliminary question. I have some questions
which relate to the statement of clarification which Mr.
Barber read on Monday, and I don't know who it is
appropriate to ask about this.
MR. STEIN; Well, I'll tell you, Mr. Barber is here,
and why doesn't he come up? If Mr. Edsall cannot
answer the question, Mr. Barber will respond. In the
interest of time, if this is all right with you, you
propound your questions, and we will try to find the man
to answer them.
MR. FELDMA.N: Well, I do have some questions also
which go directly to what this gentleman has just said.
I might start with those and then go to Mr. Barber.
MR. STEIN: In other words, you handle the
questions the way you wish.
MR. FELDMAN: Okay.
Lastly, Mr. Stein, do you mind if I sit down
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1300
T. A. Edsall
while I ask the questions?
MR. STEIN: Perfectly all right. Go ahead.
MR. FELDMAN: To be sure that I understand what
you were saying about the whitefish larvae , might I
restate what I thought I heard you say? You began
by quoting Dr. Raney's statement with respect to whitefish
larvae which go through the condenser or which are in
the hottest part of the plume, and then as your
exposition went on, you discussed those whitefish larvae
which may be entrained in the plume assuming a high velocity
discharge. Is that a fair resume of what you said?
MR. EDSALL: I think what I said was that in
discussing the process whereby whitefish larvae first fill
their swim bladder, they are required to rise to the
surface and gulp air. This is what Dr. Raney was talking
about. He said, then, that those that rose to the surface
and encountered the hottest part of the plume surely would
die.
Now, if they encountered the hottest part of the
pliuw, certainly the temperatures upstream toward the
condensers would be higher^ consequently anything coming
through the plant would experience higher temperatures
and in the plume would certainly be killed. Also organisms
that w«re entrained by the plume and did, in fact, reach
-------
1301
T. A. Edsall
the hottest part of the plume would also be killed.
MR. FELDMAN: Organisms, in this case, means
whitefish larvae, and when you say that, are you saying
that an organism if entrained by the momentum of the plume
that it may be carried to the point of discharge from the
place at which it was entrained?
MR. EDSALL: I visualize entrainment and I
am not a biological engineer or anything of this sort
but it would be a current moving very quickly in one
direction with a fairly sharp, sheer surface. But at
the surface, at the interface between the plume and the
surrounding water, some of the surrounding water would
be, because of the motion of the plume, drawn to the plume.
Does this ring any bells?
MR. FELDMAN: Let me put it the other way.
Assume a pipe is discharging into the lake. The pipe
leads from the powerplant to the lake. The velocity of
the water coming out of the pipe is approximately 7 feet
per second. Assume the Zion plant on the west side of the
lake, and the pipe is pointed toward the east side of the
lake. With water coming out of that pipe at 7 feet per
second, wouldn't you assume that the movement of water
is away from the pipe toward the eastern shore, and wouldn't
your assumption that organisms which are entrained will
-------
1302
T. A. Edsall
move back toward the end of the pipe isn't that
assumption clearly erroneous?
MR. EDSALL: I am speaking of Pritchard's
Models III and IV in which velocities were can someone
help me were 3 and 10 much higher, and it is my
impression that organisms that would encounter the edge
of this plume would be actually going into it.
MR. FELDMAN: Are you suggesting to me that in
Dr. Pritchard's Model IV Case IV an organism
entrained in the plume would tend to move in the direction
of the discharge pipe rather than out toward open water?
MR. EDSALL: No. With the direction of the
flow towards open water.
MR. FELDMAN: And in Case IV, doesn't the
temperature of the water decrease as it moves away from
the discharge pipe?
MR. EDSALL: That is correct.
MR. FELDMAN: So that an organism which was
entrained would be subject always to temperatures lower
than the temperature at which it entered the plume?
MR. EDSALL: That is correct.
MR. FELDMAN: And it would never reach the hottest
part of the plume, would it?
MR. EDSALL: Organisms entrained let's say
-------
1303
T. A. Edsall
at the point of discharge would be, then, at the
hottest part of the plume, is that correct?
MR. FELDMAN: But an organism entrained at any
point after the hottest part of the discharge would never
be exposed to the hottest part of the discharge, would it?
MR. EDSALL: That is correct, as I see it.
MR. FELDMAN: Do you recall the size of that
part of Dr. Pritchardfs Case IV which is in excess of
14 degrees above ambient?
MR. EDSALL: No, sir, I do not.
MR. FELDMAN: Would it refresh your recollection
if I suggested that it was 100 feet?
MR. EDSALL: If that is what it says, I will
accept that.
MR. FELDMAN: When you made the statement that
organisms entrained in the plume might be killed, what
were you assuming in the way of transit time within the
heated water, and what were you assuming in the way of
degrees above ambient temperature?
MR. EDSALL: I based that statement on Dr. Raney's
statement in which no times were given.
MR. FELDMAN: And if Dr. Raney's statement was
that 20 degrees above ambient might be fatal to fish, then
would you agree with me that a whitefish larva exposed
-------
1304
T. A. Edsall
at any point after the plume reaches 14 degrees would not
suffer mortality?
MR. EDSALL: No, sir, I wouldnft.
MR. FELDMAN: Does it seem to you that a
whitefish larva exposed to 14 degrees for 29 seconds
would suffer mortality?
MR. EDSALL: It depends on the type of mortality
that you are talking about.
MR. FELDMAN: I didn't know that there was more
than one. Could you explain that to me?
MR. EDSALL: Yes, sir.
There is another theory that says that exposure
of organisms in this case I am talking about fishes
to temperatures that are considerably below the temperatures
that will be immediately lethal to them will be reduced in
their ability to avoid predators. Okay?
MR. FELDMAN: And does that statement apply to
whitefish larvae?
MR. EDSALL: I think it would apply to
salmonids. The study was originally done by Dr. Charles
Coutant of Battelle Northwest Laboratory, in which he showed
th;*t young rainbow trout and chinook salmon exposed to
temperatures that were approximately 25 percent let me
state this correctly to heat doses that were only
-------
1305
T. A. Edsall
25 percent as large as those required to cause the organism
to lose equilibrium, would be statistically more
susceptible to predation, vby predators. The heat dose
that is required to cause the loss of equilibrium is
approximately 90 percent of that that is required to cause
direct mortality. The whitefish is a salmonid.
MR. FELDMAN: Excuse my confusion. I thought
we were discussing whitefish larvae, and I would not have
expected that a larva had the kind of agility which a fish
uses to escape predators. Is that wrong?
MR. EDSALL: I am sorry. Would you repeat that?
MR. FELDMAN: I would not have thought that the
larva stage of a fish had the ability to escape those
fish which are predators on it, does it?
MR. EDSALL: That is a good question. I think
I would have to answer yes.
MR. FELDMAN: And at what temperature level
above ambient do you believe whitefish larvae are subject
to the kind of impact which may impair their ability to
escape predators?
MR. EDSALL: Twenty-five percent of 90 percent
of whatever temperature Dr. Raney was talking about.
MR. FELDMAN: Okay, then, ultimately your
statements about whitefish larvae depend upon what Dr.
-------
1306
T. A. Edsall
Raney would say is the mortality or stunning figure for
them.
MR. EDSALL: Any comment I would have to make
right now certainly would depend upon his statement.
MR. FELDMAN: Okay.
In your discussion, you also assume, I think,
that 4.4 percent of the beach zone water would be going
through the condensers in the year 2000.
MR. EDSALL: That is correct.
MR. FELDMAN: Am I correct in assuming that
that statement of yours depends on the assumption that
there was no mixing across the thermal bar?
MR. EDSALL: I would think that the existence of
a thermal bar certainly would enhace the possibility of
this occurring.
MR. FELDMAN: No, what I am really asking is:
Didn't your percentage, 4.4 percent, depend on once
assuming that the beach zone is a wholly separate body of
water which does not mix with the rest of the lake?
MR. EDSALL: Basically I think that would be a
fair assumption.
MR. FELDMAN: And if the beach zone mixes with
the rest of the lake, then your 4.4 percent figure is
erroneous, is it not?
-------
1307
T. A. Edsall
MR. EDSALL: Only in the sense that the larvae
remain in the beach zone area. They are moving up and down
the beach with response to currents. They will, in fact,
remain in this area and will be susceptible to being
drawn into the intakes.
Now, if the water that they are in is water that
has drifted in from offshore, I don't really see how it
makes any difference.
MR. FELDMAN: Well, Mr. Edsall, you were
making a statement about the percentage of water -that
will circulate through the condensers, and the statement
was made that in the Chicago-Gary area all of the water
will go through the condensers every 25 days. Is that a
fair statement of what you said?
MR. EDSALL: That is correct.
MR. FELDMAN: Mr. Edsall, if the amount of
mixing between the beach zone and the rest of the lake
is a figure which is in excess of the amount of water being
taken through the powerplant condensers do you have
any assumption?
MR. EDSALL: Any water coming into the beach
zone from farther out in the lake is in excess of water
being taken into the condensers, is that what you said,
sir?
-------
1303
T. A. Edsall
MR. FELDMAN: Nope. Do you regard that your
statement that all of the water in the beach zone will go
through the condensers every 25 days as an accurate
statement?
MR. EDSALL: As I said a minute ago, it doesn't
really, in my estimation, make any difference whether or
not there is water moving in and out of the beach zone as
long as the larvae remain in the beach zone and are
susceptible to being drawn into the intakes. We use the
beach zone simply to describe a convenient volume ©f
water to demonstrate possible thermal effects.
MR. FELDMAN: Just for the record, the year 2000
estimate, which you were using, which yields 4*4 percent,
is based, is it not, on the assumption of 30 megawatts
excuse me 30,000 cubic feet per second of cooling water
in the Chicago-Gary sector?
MR. EDSALL: It was based on 91,000 cubic feet a
second in the entire beach zone, and I offhand don*t
recall what the volumes were in the Chicago-Gary, Indiana,
area, but I am sure it is in the report there.
MR. FELDMAN: Mr. Edsall, let me show you
Table 11 of the paper, and ask you to confirm to me, if
you can, that the volume for the Chicago-Gary area in the
-------
1309
K. R. Roberts
year 2000 is 30,000 cubic feet per second.
MR. EDSALL: That is correct.
MR. FELDMAN: And that figure in turn depended
on the capacity figures shown in Table 7, which show
30 megawatts of capacity in the year 2000 for that area.
MR. EDSALL: Yes, I believe it does. May I say
that I had no hand in calculating these figures. We
discussed some of these numbers. My input was strictly
to Section IV dealing with fish and wildlife interactions.
MR. FELDMAN: That may well make my next question
inappropriate, and I would only ask you to answer it by
telling me who I ought to direct it to.
The question is: That year 2000 figure was
based, was it not, on the Acres' report, except that the
surveys took the Acres1 figures and increased them by
30 percent.
MR. EDSALL: I would like to redirect that
question to someone who has more expertise in the area, if
I may.
MR. STEIN: Do you want to come up, Mr. Roberts?
May we go off the record?
(Discussion off the record.)
MR. STEIN: Let's go back on the record.
MR. ROBERTS: Okay, I didn't exactly catch
-------
1310
K. R. Roberts
which extremes were you were referring to. However,
Mr. Barber did point out why we did go to 100 percent
capacity operation in our estimation and projections.
MR. FELDMAN: I am sorry. I may well have missed
that part of the discussion and I wonder if you could repeat
it to me.
MR. ROBERTS: Well, Mr. Barber basically said
that since we are particularly interested in ecological
extremes and we are most interested with the times that
most of the waste heat is going into the water, and this
would be at a time of 100 percent or maximum operational
capacity.
MR. FELDMAN: Isn't the statement of operation
at 100 percent of capacity a statement that the
powerplants are going to talk about are going to
operate wide open, at nameplate capacity, 24 hours a day,
365 days a year? Isn't that what 100 percent of capacity
means?
MR. ROBERTS: Not to my understanding. My
estimation of description of 100 percent capacity would
be when the lights tend to become a little dim, which we
hear quite a lot about lately.
MR. FELDMAN: Mr. Stein, it is unfortunate, I
think if I could be a little more informal that
-------
1311
Y. M. Barber
Mr. Barber is probably the most appropriate witness.
MR. STEIN: Why don't you come up, Mr. Barber?
MR. BARBER: Sure.
The figure that we used there is computed
first first we tried to determine what the probable
existing capacity would be on the lake. We fully recognize
that no plant is going to run 100 percent of the time
all the time.
Now, the 91,000 c.f.s. is the figure, the volume of
discharge, which would be occurring when and if all of the
units were running at 100 percent. In other words, we
were searching for these extreme conditions that we
mentioned earlier. As, for example, when New York is in
brownout.
MR, FELDMAN: When the plants are running wide
open?
MR. BARBER: Yes, that is right.
MR. FELDMAN: When you come to discuss daily and
annual input of B.t.u.'s to the lakes, and their impact upon
the ecology, and in particular when you tend to talk about
what will happen over a spawning season in April, is it
fair to assume 100 percent capacity operation?
MR. BARBER: Let me say this: A 100 percent
operation can and might be demanded of any plant in any
-------
1312
Y. M. Barber
system. Is this not fair? I mean, under emergency
conditions. You have a plant that goes out> you are going
to make it up elsewhere in the system, is this right?
So that any plant theoretically could run at its maximum
for the period of time during an emergency outage. This
would be that period when you would be discharging
maximum waste heat. What we were looking for is that
maximum which affects the largest area most severely.
MR. FELDMAN: Mr. Barber, do I understand you
to be saying that April, May, and June have in any year
of record been maximum electrical load months in the Middle
West?
MR. BARBER: I doubt that they have, sir.
MR. FELDMAN: And, as a matter of fact
MR. BARBER: But they could be, if you had a
plant that went out, and they do go out. I remember four
or five going out in my area just last week.
MR. FELDMAN: But your paper assumes that 30
plants are operating that is plants in 4 states all
around the lake. Do you regard that as a rational
assumption?
MR. BARBER: With the power demand that you are
going to have in the year 2000, you are going to be running
it at 70 percent all of the time, according to the Acres Reoort,
-------
1313
Y. M. Barber
so this is only really less than a 50 percent increase
in your normal operation. I realize that 100 percent
operation all of the time would not be a fair allocation
of it, but I would say that your estimate of capacity
might be conservative.
MR. FELDMAN: Mr. Barber, while I am here, maybe
I can shift those questions to the clarifying statement
you issued on Monday. Do you have a copy of that in front
of you?
MR. BARBER: No, I don't, and I was going to ask
Mr. Roberts if he would bring me one.
While I am here, and while we are waiting for
that, I might, I think I might be able to clarify for
you this question of the 4.4 percent. This was an effort
on our part to illustrate the fact to anyone who read the
report that we weren't just talking about some little
dribbles of water. That at maximum we could be turning
over a very, very significant volume of lake water and
passing it through the system in that lower area there.
It would not be dependent upon the existence of the thermal
bar at all, and I think you have heard testimony here that
the thermal bar usually begins somewhat further out than
the beach water zone. We were trying to relate the volumes
of water subjected to heat input in that important biological
area.
-------
13U
Y. M. Barber
MR. FELDMAN: But its ecological significance
depends on your ability to consider a separate part of the
lake, doesn't it? Otherwise you are simply passing through
.014 percent of the whole lake, aren't you?
MR. BARBER: I think we have to consider that
surface water does, as a matter of fact, exist as a little
bit separate from, say, the water below the 200-foot
level and things of this sort. We consider the beach
water area ecologically significant. I might also point
out that when you start pumping those volumes of water with
those velocities, we don't have any idea yet what the
power problems might be with regard to these biological
matters.
MR. FELDMAN: Mr. Barber, if you can and I can be
in agreement that the water
MR. STEIN: May I say, let's try to please
don't both talk at once. We do want to have this rigid
question and answer,, and obviously if you both talk at once
we are not going to get it.
MR. FELDMAN: Mr. Barber, let me start all over.
I was asking you really whether it was a separate body of
water. I thought you referred to, sure it is different
from the water which lies below the 200-foot depth line.
And I was trying to agree with you, taking the 200-foot
-------
1315
Y. M. Barber
depth line is perhaps the location of the thermocline; I
think we can agree. I thought we would agree that if the
beach zone water and the water out in the open lake above
the thermocline were one body of water, we might regard
that as a distinct body for the purposes of the discussion
we are having.
MR. BARBER: I don't think it is in any way
reasonable to associate a heat input to a 4«4 percent
I beach water volume to the surface water of the
mid-lake, no. I used thermocline just simply as an
extreme. I don't know where the line would be drawn. I
think that Mr. Carr established quite clearly that at
certain times there is a thermal bar which tends to
positively separate the inshore water from the offshore
water for a period of about six weeks in the spring.
Therefore, in that case, I don't think we would be talking
about the same body of water for that period of tirae^, even
though there might be some minor interchanges.
MR. FELDMAN: Two things: This thermocline --
this thermal bar was not located at the same place as the
boundary of your beach zone, was it?
MR. BARBER: That is correct, it was not. This
would mean
MR. FELDMAN: And the accuracy of your statement
-------
1316
T. M. Barber
depends upon the amount of mixing which occurs across
the thermal bar, does it not?
MR. BARBER: I think our statement is, sir, that
it is a volume of water equal to 4.4 percent of the volume
of the beach zone. It might also be 4-4 percent of the
volume of New York Harbor. I don't know, you see.
MR. FELDMAN: Right. And what I am trying to get
to is: Haven't you defined the beach zone in a perfectly
arbitrary manner just by drawing a line.on a map, and that
is all?
MR. BARBER: No, sir. We think that there are
cases of biological significance within this 30-foot zone.
It might vary from place to place, it is true. We did
have to have something though, and if we talk about 32
feet here and 16 feet there and 100 feet beyond there
on a lake the size of Lake Michigan, it becomes totally
unmanageable as a subject.
MR. FELDMAN: But your ability to consider it
separately in the way you just did depends upon its
being separated in some way from the waters in the rest
of the lake just beyond the edge of your beach zone, does
it not?
MR. BARBER: I don't think so, sir, not in my
-estimation .
-------
1317
Y. M. Barber
MR. FELDMAN: Do you now have a copy of your
clarifying statement in front of you?
MR. BARBER: I do, sir.
MR. FELDMAN: The last paragraph of that paper,
Mr. Barber, refers it says, "This does not alter the
important conclusion of Subsection 2C ..." I have been
unable to locate Subsection 2C. Could you tell me where
it is?
MR. BARBER: Yes, sir, just one moment.
If you go over to Page 41, there is a study of
model plumes, No. 2, and below that there is an "A" and
on 42 there is a "B" and if you come on over, you arrive
at a "C" on Page 44- This is all under Section 2. That
extends over to Page 46.
MR. FELDMAN: Well, maybe the only way to get
at this is, then, to go through with you Pages 44 and 46,
and see what changes you have made in them.
Would you take a look at Page 46, please?
MR. BARBER: All right, sir. Let me say, at
this point, that this section of the report was written
by Mr. Callaway at the lab in Corvallis. We were the ones
who didn't do too well in the editing which required
revision and, if I may, I might refer a question to Mr.
Callaway if it is necessary in order to give you a clear
-------
13 IS
R. Callaway
answer.
MR. FELDMAN: Is he here?
MR. BARBER: Yes, sir. He is right back there.
MR. FELDMAN: It might save time if he were
with you.
MR. BARBER: He helped us clarify this thing.
MR. FELDMAN: Would you look with me, please,
at the first sentence on Page 46.
MR. BARBER: This is the one that begins, "However
..."
MR. FELDMAN: "However, from the earlier discussion
of heat dissipation, it appears that ..." and so on,
until it gets to the phrase: "that the assumption of
little or no waste heat loss to the atmosphere is reasonable,
at least during a great deal of the annual temperature cycle."
Now, do you regard that statement as still
accurate?
MR. CALLAWAY: No, that is not accurate. That
part isn't accurate. That is where a little bit got lost
in the translation between Gorvallis and Washington.
Let me go over what my intent was. My
understanding, at the outset of this "white paper," was
that there was a confusion between jet entrainment,
turbulent diffusion, and cooling to the atmosphere, and as
-------
1319
R. Callaway
it was explained to me, there are two factions. One said
none of the heat was lost to the atmosphere; the other
said all of the heat was lost to the atmosphere immediately,
I wrote the section to explain that if a
plume is going to maintain its shape as heat is entering
the lake at some place, then heat has to leave at some
place, and the place where it leaves in a jet is near
the water, when the excess temperature approaches the
ambient. And I went through, at great length, to clarify
it, and didn't apparently because in the editing it got
lost.
Now, I think what I have done
MR. FELDMAN: Mr. Callaway, I don't want to
interrupt, but I have a couple of more specific questions
about the accuracy of the sentence, and then maybe by the
time I finish them we will be in agreement with respect
to what Section 2C is intended to say.
Would you look at Page 45, Table 14? The
dilution table example on the left-hand side of the page,
as an example of what occurs in the real world, has been
retracted by you, has it not?
MR. CALLAWAY: Yes, sir. Well, again, these
two in the initial writeup that I gave were to show
what would happen for a substance that wouldn't decay at
-------
1320
R. Callaway
all, a conservative substance, and one that would decay,
to put a little bit put the problem on a better perspective
because there was a lot of confusion about the size of the
area. It was nowhere indicated, and I don't think it is
indicated in here that this is a real life situation,
because and only because the model is, as used by Dr.
Pritchard, unverified.
MR. FELDMAN: I am sorry. I didn't hear the end
of that, Mr. Callaway.
MR. CALLAWAY: The model which was used to go
through these manipulations by Dr. Pritchard for these
calculations is not verified. That is just a term to
indicate that there wasn't any real life data to go with
it.
MR. FELDMAN: Are you familiar with the fact that
other of Dr. Pritchard's calculations for discharge plume
have been verified by measuring the temperature after the
discharge?
MR. CALLAWAY: I have seen one example of that.
MR. STEIN: Was any of that verification put in
the record by Dr. Pritchard,put in the record here?
MR. CALLAWAY: Just in the paper he gave
yesterday.
MR. FELDMAN: When you say the one example, you
-------
1321
R. Callaway
are referring to the example in his paper of the Waukegan
plume?
MR. CALLAWAY: Yes.
MR. FELDMAN: And are you aware of any other
discharges of his that have been verified by actual
experience?
MR. CALLAWAY: I am sure they have, but that is
the only one I have seen.
MR. FELDMAN: Would you turn to the bottom of
Page 41 and the top of Page 42? In that discussion of
Mr. Benedict's plume, there is a statement on Page 42
that the study made no allowance for surface heat loss.
Do you find that statement?
MR. CALLAWAY: Page 42, right?
MR. FELDMAN: Right. Would you agree with me that
the error in that assumption makes the first the two
paragraphs I referred to at the bottom of 41 and the top of
42 irrelevant to the discussion of what happens to the
lake?
MR. CALLAWAY: I am not sure I follow you.
MR. FELDMAN: As I understand the discussion on
Page 42 at the top, the Benedict study made no allowance
for surface heat loss. It seems to me that you and I have
agreed that there should be an allowance for surface heat
-------
1322
R. Callaway
loss, and therefore that both of those paragraphs that
is the full discussion of the Benedict study are not
useful in a discussion of what happens in the lake.
MR. CALLAWAY: The purpose of this example, again,
was to give some perspective for laymen, or whatever you
want to call them, for dimensions of these plumes for
different situations.
MR. FELDMAN: Does the Benedict study represent
a plume that you would expect to find in real life on
any lake?
MR. CALLAWAY: No.
MR. FELDMAN: And so, then, on the bottom of
the second paragraph on Page 42, you say that the thermal
plume would extend a substantial distance and thus cover
an extensive area, you really werenft talking about the real
world, were you?
MR. CALLAWAY: Well, I don't believe those are
my words there.
MR. FELDMAN: Well, do you regard those words as
inaccurate?
MR. CALLAWAY: Inaccurate.
MR. FELDMAN: And under the clarification they
should be deleted from the report?
MR. CALLAWAY: I suppose so.
-------
1323
Y. M. Barber
MR. FELDMAN: Would you turn back to Page 46
with me? Five lines up from the paragraph which begins
that page is the phrase, "...the 'dilution only' assumption
of the other two examples is the more applicable."
Do you see that?
MR. CALLAWAY: Yes.
MR. FELDMAN: Do you agree with me that the
effect of the clarification is to withdraw that phrase?
MR. CALLAWAY: Yes, it has lost a little bit
in the translation.
MR. FELDMAN: Mr. Callaway, the clarification
statement which was read on Monday says in its last
paragraph that "...under some conditions large percentages
of the discharged waste heat are added to the water mass
of the lake." Could you tell me what those conditions are?
MR. CALLAWAY: Well, at the outfall, all of the
heat is going into the lake. Eventually the plume comes
to the equilibrium and there is a balance , and all of the
heat has left over a certain time interval.
MR. FELDMAN: So, your reference to the word
"conditions" was not a reference to where the discharge is
located, or what the bottom is like, or the amount of
water into which it discharges, or the velocity of the
water, or anything else. It was simply a reference to
-------
1324
T. M. Barber
the fact that for perhaps 100 feet or so all of the heat
is, in fact, in the water.
MR. CALLAWAY: Well, that is true, but I think
that if Mr. Barber wants to explain that paragraph that is
his privilege.
MR. FELDMAN: Mr. Barber, could you tell me what
you meant in that last paragraph when you said that H...
under some conditions large percentages ... are added to
the water mass of the lake"?
MR. BARBER: Yes, sir. This would mean that
under some conditions, the bulk of the heat in the water
leaving the pipe would go into the lake; it would not
get away into the air in the next few minutes.
MR. FELDMAN: You mean if I put it in the bottom
of the lake, it would stay in the lake until it got to the
surface? That is all you are saying?
MR. BARBER: Well, I think we were saying a little
more than that. You understand when we consider plumes
we have to consider more than these two hypothetical models.
We have to consider the real cases and, as I understand it
from Dr. Pritchard's examples, there are variations on
how much of the heat gets into the lake and how long it
stays there. His Case II and Case III I think illustrate
that on one type of discharge much more of the heat goes
-------
1325
I. M. Barber
into the lake and stays much longer than does in his
Case No. IV.
MR. FELDMAN: Maybe we can clarify this, Mr.
Barber, if you would turn to Page ##. Page 8& is the
page on which the Service begins its statement of
conclusions, is it not?
MR. BARBER: Yes, sir.
MR. FELDMAN: And your clarification statement
Monday does not refer to Page ## or any of the conclusions,
does it?
MR. BARBER: No, sir, it does not.
MR. FELDMAN: Would you read with me Conclusion
No. 2?
MR. BARBER: Yes, sir.
MR. FELDMAN: "At times very large percentages
(up to virtually 100 percent) of the waste heat discharged
to the lake are diffused into the beach water zone;..."
Could you tell me what that means, Mr. Barber?
MR. BARBER: Yes. That a very large part of
that heat goes into that beach zone water.
MR. FELDMAN: Does that say anything more than
that the discharge pipes are physically located in the
beach zone?
MR. BARBER: As I remember from drawingswe saw
-------
1326
T. M. Barber
of a plant I don't think their pipe is out there, but some
of the plume drawings that Mr. Fetterolf showed me back in
June certainly suggested that there was a lot of heat in
that water on ^he lake.
MR. FELDMAN: Excuse me, Mr. Barber, the beach
zone, as I understand it, is from the shoreline from the
dry land out to 30 feet.
MR. BARBER: Yes, sir.
MR. FELDMAN: Now, does the first phrase in
Conclusion 2 say more than that the end of the pipe
occurs someplace between dry land and the 30-foot depth?
MR. BARBER: I think it could be inferred to mean
more than that, sir.
MR. FELDMAN: And what more could it be inferred
to mean?
MR. BARBER: Well, that this heated plume of
water (if, for example, a jet discharge) was thoroughly
mixed with the receiving water, and if the heat was still
below the water surface rather than going into the air,
and if it was a longshore current that turned that plume
down the shore, then I think it could still be within the
30-foot contour.
MR. BARBER: But that is an interesting aside.
You have in all of the discussion in the "white paper"
-------
1327
Y. M. Barber
of discharge schemes assumed that the discharge was at the
shoreline and that the plume would tend to hug the shore,
have you not?
MR. BARBER: To a considerable extent, yes. This is
because most of the powerplant designs that we have
examined have involved either inshore or near shore
discharges.
MR. FELDMAN: But your other paper deals with
six alternative mechanisms. There is and we have
discussed in this section the seventh mechanism which is
putting the pipe farther out in the lake and giving this
a velocity, right?
MR. BARBER: You mean Dr. Pritchard's model?
MR. FELDMAN: Right. And that model isn't
discussed anyplace in the "white paper" or anything like
it.
MR. BARBER: No, sir.
MR. FELDMAN: When you modify Pages 41 through 46
of the "white paper" that is those pages we have just
been talking about by issuing the clarifying statement
on Monday, did you, at that time, consider whether you ought
to modify either Conclusion 2 or Conclusion 3 on Page
MR. BARBER: Two or 3? I don't believe that
I did. Did you?
-------
13 2S
Y. M. Barber
MR. ROBERTS: I considered it.
MR. BARBER: Yes.
MR. STEIN: Mr. Feldman?
MR. BARBER: Mr. Roberts said he did consider
it. I did not frankly, but if I had I doubt if I would
have modified it significantly if at all.
MR. FELDMAN: Well, take a look at the last
phrase in the third conclusion.
MR. BARBER: Yes, sir.
MR. FELDMAN: It reads, "...it is not difficult to
envision resultant physical warming of a large
proportion of the beach water zone and certain adjacent
waters."
Doesn't that statement, Mr. Barber, depend upon
the assumption in Pages 41 through 46 that the heat stays
in the water, and having withdrawn that assumption don't
you have to withdraw that phrase?
MR. BARBER: I don't think -- we don't on a
permanent basis. We have sought to withdraw any assumption
or any inference that the heat stays in the water
permanently.
Now, Mr. Callaway testified here on Monday
that there was something in the order of possibly a
10-day half life or heat in water. Dr. Pritchard didn't
-------
1329
Y. M. Barber
favor us with a time period, as I recall, but I have been
told and I can't verify this that he used a figure
of maybe 10 days offhand at the Illinois hearing. That
may not be accurate, but it is the same ballpark with
Mr. Callaway'? figure, and so we have nowhere sought to
imply total heat retention. As I said earlier, we needn't
kill a fish but once.
MR. FELDMAN: I understand what you are saying
about the length of time it would take a plume to die out if
you turned the powerplant off.
MR. BARBER: Right.
MR. FELDMAN: But my question to you is: Since
you now admit there is substantial surface cooling, do you
think that it is fair to conclude as you have on Page BB
that there will be substantial physical warming of a long
proportion of the beach water zone? Doesn't that conclusion,
Mr. Barber, really depend on the heat staying in the lake
forever or for a substantial length of time, rather than being
given off at the surface?
MR. BARBER: Obviously the longer it stays there
the more likely it is to affect something over a given
area;. But I don't see where there is any requirement for
a forever circumstance there, and we never intended any ,
-------
1330
R. Callaway
MR. FELDMAN: Maybe I can put it this way: Is
your position with respect to surface cooling that Pritchard's
Case IV is in error, and that the extent of isotherms on
a discharge like this is really much greater than he shows
in Case IV?
MR. BARBER: I think I might refer that question
to Mr. Callaway if I may.
MR. CALLAWAY: The Pritchard Case IV in the
paper he gave yesterday?
MR. FELDMAN: Yes.
MR. CALLAWAY: I don't think any of Pritchard's
cases that were given yesterday mean a thing unless you
have the mathematical model that goes with it.
MR, FELDMAN: I am sorry, I missed your
statement. You don't think that any of Pritchard's
cases are
MR. CALLAWAY: They don't mean a thing unless
you have the assumptions, the boundary conditions, the
mathematical model that went with it, the computer code,
the whole thing. Otherwise it is just anybody's guess.
MR. FELDMAN: If we supplied you with the
calculations on what Dr. Pritchard based his diagram of
Case IV would you then believe that it can be done?
MR. CALLAWAY: No, because there is no such
-------
1331
R. Callaway
outfall to begin with. How are you going to verify it?
MR. FELDMAN: You are saying that unless we
can verify in the field a mathematical model is not a useful
device, and we cannot say that it could really exist?
MR. CALLAWAY: It is witchcraft. If you don't
verify it, what good is it?
MR. FELDMAN: Okay. I thought you agreed with
me a little earlier that Dr. Pritchard had done calculations
MR. CALLAWAY: He has done them
MR. FELDMAN: which have been verified in the
field.
MR. CALLAWAY: He has shown one example of a
verification, and it is a lousy fit to begin with.
MR. FELDMAN: Mr. Callaway, let me try it another
way, because I don't think we are going to get very far this
way. Assume with me for a second that Dr. Pritchard's
Case IV is an accurate picture of what will happen with
the kind of discharge, the kind of velocity, he assumes in
his paper. Just make an assumption for a minute.
MR. CALLAWAY: You are asking for a lot.
MR. FELDMAN: Pardon?
MR. CALLAWAY: You are asking for a lot. I will
do it.
MR. FELDMAN: Okay. If we make that assumption,
-------
1332
R. Callaway
is the last phrase in Conclusion No. 3 still accurate?
MR. CALLAWAY: Pritchard's Conclusion No. 3?
I don't think it is particularly difficult to envision the
warming of a large portion of the beach and certain
adjacent waters. If you mean if his model works well, that
is something else again. But I don't think it does in this
kind of case. It doesn't make any sense. But if his
model works, we could have another model that works twice
as good ten times as much of the area so what is to
be gained by that?
MR. FELDMAN: If his model works, then, the
statement in Conclusion 3 that physical warming of a large
proportion of the beach water zone will occur is
inaccurate, is it not?
MR. CALLAWAY: If his model applies, right, sure.
MR. FELDMAN: Okay, then, therefore, would you
agree with me that Dr. Pritchard's the clarifying
statement issued Monday should have withdrawn that part
of Conclusion 3 as well as whatever else it purports to
withdraw?
MR. CALLAWAY: I don't think we had Dr.
Pritchard's Model IV at that time. How could we do that
since we didn't have it?
MR. FELDMAN: Isn't it only since you have
-------
1333
R. Callaway
initially learned about that that you think it is useful
to withdraw the third conclusion?
MR. CALLAWAY: I meant no such thing.
MR. FELDMAN: Let me go back just a little bit,
Mr. Callaway. Isn't the major difference between Dr.
Pritchard's analysis of cooling and the general analysis
of cooling which is in the "white paper" the fact that
the "white paper" assumed no surface loss, and that is
it?
MR. CALLAWAY: I don't think that say that
again.
MR. FELDMAN: Isn't the major difference between
Dr. Pritchard's analysis of the behavior of heat that is
put in the lake and the "white paper"'s analysis the
fact that the "white paper" simply assumed that there would
be no loss of heat fi*om the surface?
MR. CALLAWAY: I don't think the "white paper"
assumed that at all, that there be no loss. I don't see
where you get that.
MR. FELDMAN: Well, you assumed that the bulk
of the heat would stay in the lake, did you not?
MR. CALLAWAY: At the outfall, all of the heat
is going to go into the lake. The plume is going to come
to some sort of configuration by the loss to the atmosphere.
-------
1334
R. Callaway
That is what I said.
MR. FELDMAN: Okay. And withdrawing those parts
of Section 2C, which we have discussed for the last half
hour or so, you were withdrawing those parts that went
beyond that and implied that it is never lost to the
atmosphere, did you not?
MR. CALLAWAY: I didn't imply ~ I implied no
such thing.
MR. FELDMAN: The "white paper"
MR. CALLAWAY: Even if Dr. Benedict's model
assumes no heat loss to the atmosphere you can find
atmospheric conditions when that will occur. I don't say
it is going to occur forever, but there are times when
there is no surface heat exchange.
MR. FELDMAN: The rate of radiation from the
water may for very short periods of time drop to
substantially zero.
MR. CALLAWAY: That is right, and you might get
a very good agreement between Benedict's model and one
that accounts for cooling. There would be very little
difference.
MR. STEIN: Would you repeat that? Between
Benedict's model and
MR. CALLAWAY: Yes, between Benedict's model
-------
1335
R. Callaway
which, in this case, didn't account for surface cooling
and between the field study wherein you might have
surface cooling occurring there may be pretty good
agreement.
MR. FELDMAN: Do you ever expect to see a day
on which there is no longwave radiation from a body of
water back into the air?
MR. CALLAWAY: No, sir.
MR. FELDMAN: No?
MR. CALLAWAY: You are always going to have
back radiation.
MR. FELDMAN: And, therefore, when Dr. Benedict
assumed there would be no longwave radiation to the
air, was he making an assumption which would be virtually
impossible?
MR. CALLAWAY: I think you are putting some
assumptions on Dr. Benedict's paper that you had best
discuss with him.
MR. FELDMAN: Well, you said a few moments ago
that under some conditions for some short periods of time
a field study might be able to find a plume which behaves
the way Dr. Benedict's does. I am just probing that.
MR. CALLAWAY: That just shows you how much
use mathematical models are sometimes, right.
-------
1336
R. Callaway
MR. FELDMAN: Mr. Callaway, if there is always
longwave radiation from a body of water to the air, then
is it ever permissible to assume there will be no loss of
heat from the surface?
MR, GALLAWAT: Net loss, never.
MR. FELDMAN: When Benedict's study makes that
assumption, it is making an assumption which is physically
impossible, is it not?
MR. CALLAWAY: Tes, but I don't I lost track
again.
MR. FELDMAN: I asked whether it wasn't true that
Benedict's assumption of no loss of heat from the surface
wasn't a physical impossibility.
MR. CALLAWAT: Tes, but this I want to bring
out: You are making it sound and I don't want to be
responsible for it you are making it sound like Dr.
Benedict doesn't know what back radiation is and I
wouldn't want to have that in the record. I am not trying
to be obfuscatory towards you, but you are asking me some
difficult questions.
MR. FELDMAN: Mr. Barber, I have just one more
question.
MR. BARBER: Yes, sir.
MR. FELDMAN: Would you agree with me that
insofar as the physics of the "white paper" is concerned
-------
1337
T. M. Barber
and, therefore, the statements with respect to how much
heat you get, the two major premises of the "white paper"
are that heat which you put in the lake stays in the lake,
and that heat which you put in the area near the shore
stays in that area which is near the shore?
MR. BARBER: No, sir. I never interpreted anything
that I read in several drafts of this report to mean that
the heat stayed in the lake indefinitely. It doesn't
have to, to do damage. As far as heat staying in the
inshore zone, I feel sure that there are many, many times
when there are significant currents that will take the
shape of that shore. We see this in the wandering of
plumes, as pointed out by Dr. Benedict and others here,
so I don't mean to infer thatthe heat is necessarily all
going to stay in the shore zone. It is going to respond to
current, and the normal forces which create movement of
water, such as density, temperature, wind and seiches, and
so forth.
MR. FELDMAN: I am afraid when I ask a simple
question this creates five or seven more problems, and it
may be a little late to pursue them. I think while I
might disagree with Mr. Barber, I think I understand now
what his position is.
I am at the end, Mr. Stein.
-------
133$
R. Callaway
MR. STEIN: Thank you very much.
Mr. Bane, did you want to
MR. BANE: No, sir.
MR. STEIN: Do we have any other questions from
the audience?
I am afraid as late as it is we are going to have
to use this microphone. We have to give Mrs. Hall all of
the help she needs.
MR. FETTEROLF: Mr. Stein, may I ask where
Benedict's paper may be found? There is no citation on
that.
MR. STEIN: Is there a citation to Benedict's
paper?
MR. BARBER: Mr. Callaway did he leave?
MR. STEIN: Is there a citation to Benedict's
paper, or can you supply this to Mr. Fetterolf?
MR. CALLAWAY: Do I have a copy?
MR. STEIN: No, a citation.
MR. FETTEROLF: I only want to know where I can
get a hold of the paper. You do not give me any clues in
the bibliography.
MR. CALLAWAY: Vanderbilt University.
MR. FETTEROLF: Does Dr. Benedict's paper
compare actual plume measurements of the Campbell plume
-------
1339
R. Callaway
with his model?
MR. CALLAWAY: I am not sure at this stage. It
has been a long time since I have seen it.
MR. STEIN: Yes.
MR. FELDMAN: If you will forgive me, I have one
more question.
MR. STEIN: Oh, sure. When you said it was
your last question, I was making book.
MR. FELDMAN: That is why I stopped even though
I didn't get the answer I wanted, Mr. Stein.
You indicated the other day that the Department
would make available the data which underlies various portions
I just wondered who we ought to write to.
MR. STEIN: Oh, I mentioned this before and let
me make this clear to all. All of the data we have is
public, at least in this field. Don't start questioning
me on that. But you do know we have confidential data,
for other reasons, but nothing involved in this.
Now, the data is available in our various
offices. Your initial point of contact anyway is Mr.
Mayo here, who is the Regional Director. Your contact
will either be with the Fish and Wildlife Laboratory at
Ann Arbor or with Mr. Yates Barber. Who do they get in
touch with at Ann Arbor?
-------
1340
Y. M. Barber
MRo BARBER: Well, let's mail it to the Director
of the Laboratory there.
MR. STEIN: Either that or Mr. Yates Barber.
Now, in addition to that, Mr. Callaway is at
our Pacific Northwest Laboratory in Corvallis and they have
the data available. My suggestion to any of you is to
deal directly with them and try to get the data. If you
have any problem whatsoever call me, and I take collect
calls. But what I am saying is not that I don't want
the calls it is the long way around when you come to
Washington. So I recommend that you try getting it
directly from the source first, and we will cut out as much
red tape as we can.
MR. FELDMAN: Thank you.
MR0 STEIN: Mr. Petersen.
MR. PETERSEN: Mr. Chairman, I believe when we
digressed into numerous witnesses, we were questioning
Mr. Edsall, and he had not been released, so I would like
to take up with Mr. Edsall where things got off into
MR. STEIN: Did he come back?
MR. BARBER: He is right here.
MR. PETERSEN: I might observe that using Mr.
Callaway's analogy, that if Benedict's paper didn't compare
them with the Campbell plume this too must be witchcraft.
-------
1341
T. A. Edsall
I think you are prepared on the question which
I mentioned I was going to ask about this. I understand
from what you had to say that all organisms drawn through
condensers would be killed. Would you care to elaborate
or explain further on that?
MR. EDSALL: In the next sentence I said
something to the effect that the complete destruction of
a year class of whitefishes could thus be accomplished
during the first few months following hatching.
Basically, what I meant to say here was
whitefishes. The statement probably also applies in another
sense, too: plankton, including zooplankton and
phytoplankton.
If you consider the number of phytoplankters
passing through relative to the number of zooplank-
ters and relative to the number of whitefishes, and if you
assume that the majority of the phytoplankton plankters will be
killed, which I believe that Morgan and Stress show on their
paper, then we are still talking about a majority, nearly
all of the organisms, numerically speaking.
MR. PETERSEN: Is your microphone working, sir?
I found some difficulty in following and understanding what
you had to say. But, as I understand it, you are referring
to someone's paper and saying that that shows that all or
-------
1342
T, A. Edsall
nearly all of the plankton which may be drawn through a
condenser will be killed.
MR. EDSALL: Phytoplankton, yes, sir.
MR. PETERSEN: Were you here to listen to Dr.
Ayers' statement?
MR. EDSALL: No, sir, I heard about it secondhand.
MR. PETERSEN: It was the impression which I
received from that, that the smaller organisms were not
as grossly affected, but that of the larger organisms,
75 or 80 percent survived. Would you, on the basis of your
studies, care to express agreement or disagreement with
that?
MR. EDSALL: This paper isn't predicated on my
studies. It is simply based on statements made by expert
witnesses appearing for the Power Commission power
interests in this,
MS. STEIN: Let's fix that thing. You mean the
power interests?
MR. EDSALL: Yes, not Power Commission.
KR. STEIN: Off the record.
(Discussion off the record.)
MR. EDSALL: I had a point. Would you ask the
question, please? I am sorry. I was distracted.
MR. PETERSEN: I thought you had given your
-------
1343
T. A. Edsall
answer. I asked: Can you, or do you care to agree or
disagree with Dr. Ayers1 testimony? I understood you to
explain it not on the basis of your own experience and,
as I recall, you answered you didn't have any of your own
experience, but you referred to some paper which you said
gave data to the contrary of Dr. Ayers' statement. That
was given on behalf of the Federal Power Commission or the
power interests or something of that nature.
MR. EDSALL: No, the paper is by Morgan and
Stress and it is cited in the "white paper" in the
literature cited. As I said, I didn't hear Dr. Ayers'
paper, but from some of my fellow fish people I got a brief
summary. As I understood, its conclusion was that a major
portion of the zooplankters would be killed.
MR. PETERSEN: This being an informal affair
somewhat, I don't object to your going ahead and explaining
onwards and onwards, but I think the answer to my question
was that really you couldn't agree or disagree on the basis
of your own experience. Would that be a correct statement?
MR. EDSALL: Yes, I have no expertise in the
field of phytoplankton or zooplankton. The important point
that I was trying to make was that the destruction of the
year class of whitefishes could be accomplished.
MR. PETERSEN: When whitefish larvae once fill
-------
1344
T. A. Edsall
their swim bladders I think this is the correct term
are they no longer larvae or what is the stage when we say
they are no longer larvae?
MR. EDSALL: Well, generally, when these fish
hatch they are very small and transparent, and, in a
sense, they do not resemble in miniature size the adult
fish. Perhaps the best criterion for distinguishing
between a larva and a nonlarva is the fact that the
larva is transparent and nonlarva is not.
MR. PETERSEN: Are you aware of whitefish
breeding areas in the vicinity of any present or projected
thermal plumes from electric generating plants?
MR. EDSALL: I believe the paper says that
historically all of the shallow inshore waters of Lake
Michigan were whitefish spawning areas. Presently the
stocks are down. There is a table in the report that
shows they are down in abundance but that they are
increasing.
MR. PETERSEN: Are you aware, as I suggested --
would you answer the question, please?
MR. EDSALL: I was getting to it in a
roundabout way. Okay. My own experience is that there are
spawning areas in the vicinity of Saugatuck, Michigan.
My last full year on the research vessel,
-------
1345
T. A. Edsall
which was about 1963, was in that area, and whitefish
were taken there, as I recall, during the spawning season
when they were carrying eggs and apparently about to spawn.
Circumstantial but
MR. PETERSEN: I was going to ask, precisely where
in that area? What is the area in which they laid their
eggs as to location and depth of water from shore.
But I take it from what you have said you only have
evidence that there were pregnant heavily pregnant
whitefish taken in the area.
MR. STEIN: They are not live bearers, are they?
MR. EDSALL: That is right. They have
external fertilization, so they wouldn't be pregnant. The
females were full of eggs that were about to be spawned.
This would be within a mile of the mouth of the Kalamazoo
River at Saugatuck, Michigan. The Kalamazoo River is shown
on the map there pointing south of Grand Rapids.
MR. PETERSEN: Have you any reason to believe that
any of the existing or projected thermal plumes would
encompass that particular area one mile south of the
Kalamazoo River?
MR. EDSALL: I am not sure where the projected
installations would be in that area. Could you tell me
that, and also the length of the plume, perhaps?
-------
1346
T. A. Edsall
MR. PETERSEN: The Palisades projected plant
is near South Haven and the Cook plant is, as I understand
it, quite a distance to the south of that point, in any
event, neither of which are near the point which you
mentioned as to the Kalamazoo River.
MR. EDSALL: I would say in that event that
the likelihood of a plume reaching Saugatuk from South
Haven would probably be pretty remote. Most of our
information on spawning is based and spawning a_ea.
is based upon the literature which deals with Lake
Ontario and Lake Huron.
MR. PETERSEN: Are the areas in Lake Ontario and
Lake Huron identical to those on the eastern shore of Lake
Michigan?
MR. EDSALL: I would guess that they would
probably be similar, yes. They certainly would not be
identical.
MR. PETERSEN: That would be a guess?
MR. EDSALL: Right.
MR. PETERSEN: On what do you predicate your
assumptions of damage to organisms going through the
condensers? Is that mechanical damage or heat damage or
both?
MR. EDSALL: I would say that probably was
-------
1347
T. A. Edsall
two out of three. The third one would be damage caused
by sharp temperature rise, and the production of lethal
air emboli within the tissues of the larvae body
tissues.
MR. PETERSEN: Lethal once more for the
benefit of the unscientific lawyer.
MR. EDSALL: Nonscientifically, the bends."
MR. PETERSEN: Now, is your general theory of
damage , wh-itefish, aside from being pumped through a
plant,' predicated upon the theory of no mixing outside
of the beach zone?
MR. EDSALL: No, sir, I think I stated clearly
that it wasn't.
MR. PETERSEN: Perhaps you did. I didn't get
it.
Then, a general warming trend, which has been
predicted in this theory is not a part of your thesis, but
it is the but the general warming trend in a beach
zone which is predicted by that theory has nothing to do
with loss of whitefish insofar as you are concerned?
MR. EDSALL: I did not say that. What I was
speaking of was loss of whitefish caused by the whitefish
passing through cooling intakes and/or being entrained
at the outfall. Other losses may occur, and Dr. Colby is
-------
1343
T. A. Edsall
perhaps a little bit more qualified to talk about this
than I. But they involve loss or death of the eggs
caused by the eggs coming in contact with slightly heated
water during critical periods of their development.
MR. PETERSEN: As to the latter position, you
are not speaking as an expert, is that correct?
MR. EDSALL: About the eggs?
MR. PETERSEN: About the eggs and the heat.
MR. EDSALL: Only that I have read some of his
papers and I have, you know, watched him conduct his
experiments.
MR. PETERSEN: Then, as I understand it, the only
reference to the nonmixing beyond the thermal bar was the
limitation on how often the beach zone water might be
pumped through a plant or plants or what percentage of that
water might be pumped through a plant or plants. I am not
trying to catch you, I am just trying to understand you.
MR. EDSALL: I am not just sure exactly what
you said. Could you say it another way, perhaps?
MR. PETERSEN: In your consideration of the
possible damage to the whitefish population, the only way
in which you utilized the theory of nonmixing across
the thermal bar was to determine the chance of a given
whitefish larva or juvenile being picked up through a
-------
1349
T. A. Edsall
plant.
MR. EDSALL: I think I know what you mean.
Just let me restate something. Maybe it will make it a
little more clear. What I said was that all information
indicates that the larvae are abundant in the inshore
waters I am sorry not inshore but beach zone waters,
water shallower than 30 feet. By virtue of being in this
area, they would be highly susceptible to being pumped
through cooling systems. If there is exchange between
beach zone water and nonbeach zone water water farther
offshore as long as the larvae stay in the beach zone
it doesn't make any difference whether we get any exchange
or not.
MR. PETERSEN: Have you taken this idea made
allowances for differences in intakes?
MR. EDSALL: Physical differences?
MR. PETERSEN: For example, the beach zone, as
I think I understand it by arbitrary definition, is the
30-feet depth contour.
MR. EDSALL: By ecological definition, 30
feet, yes, sir.
MR. PETERSEN: What percent of the whitefish
did you expect to find, then, between 20 and 30 feet
in depth?
-------
1350
T. A. Edsall
MR. EDSALL: I think it would probably depend
upon meteorological conditions, and wave action, and this
sort of thing turbulence in this zone. I suspect that
if there were a lot of large waves crashing in on the
beach that the larvae would move out to the area of non-
extreme turbulence.
MR. PETERSEN: I am speaking of actually present
in waters deeper than 20 feet and being below 20 feet in
depth. Below meaning deeper than 20 feet.
MR. EDSALL: Below the surface?
MR. PETERSEN: More than 20 feet below the
surface yet within the beach zone.
MR. EDSALL: I suspect that as they grow and
approach the nonlarval stage that they would tend to move
towards these deeper waters.
MR. PETERSEN: The question which ~ now, taking
that into account, would it make any difference in your
thesis whether the intakes were at the shoreline or if it
were 20 feet or 30 feet in depth? Have you considered it
up to this point first?
MR. EDSALL: On any given day, I suspect that
it probably would make a difference.
MR. PETERSEN: Have you, prior to my asking the
question, considered this issue?
-------
1351
T. A. Edsall
MR. EDSALL: Do you mean depth
MR. PETERSEN: The depth of intakes in making
your assumptions for the "white paper."
MR. EDSALL: We more or less assumed that the
intakes would be shoreline intakes and I frankly haven't
tried to envision whether a shoreline intake would be
6 inches of water or 16 feet of water »
MR. PETERSEN: Were you aware of the 3 plants,
2 presently in operation and 1 proposed, of Consumer
Power Company on Lake Michigan's shoreline? Two of them
have relatively deep water intakes and only 1 has what might
be considered a shoreline intake.
MR. EDSALL: I am not really familiar with the
intake structure of the powerplant. I am vaguely familiar
with the intake structure of the Chicago municipal water
plant system. I believe they are located in about 30
feet of water.
MR. PETERSEN: No further questions at this
time. Thank you.
MR. STEIN: Thank you.
Are there any other questions here? If not,
Mr. Yates, will you proceed.
I am beginning to get nostalgia. You know
you haven't heard about a discussion like this for
-------
1352
Y. M. Barber
years. But about 20 years ago when we had this program,
and we were working on primary treatment, and before the
days we had computers, we also used to have scientific
discussions, on sewage outfalls, of whitefish.
Mr. Barber.
MR. BARBER: Our next witness, we would like to
ask Mr. Kenneth Roberts to read a brief statement.
Dr. Graikoski, our botulism expert, was here
on Monday, but at that time we had no questions, so we let
him go home. Today we received a telephone message from
him. This is the way we got this statement, so we will
do our best to respond if you have questions, but I am going
to ask Mr. Roberts to read it now.
MR. PETERSEN: If I may interject one moment,
Mr. Chairman, it is &:00 'o'clock and I have no objection
to going all night if it is the pleasure of the Board.
But I think it would be helpful to those of us who are
participating probably also to the reporter to take
a break.
MR. STEIN: Well, I have been checking with
the reporter. Would you rather go right through? If you
take a break you are going to revive. Do you want to go
through or not?
THE REPORTER; Let's take five minutes.
-------
1353
Y. M. Barber
MR. STEIN: We will have a five-minute recess.
(Short recess.)
MR. STEIN: Let's reconvene.
Mr. Barber.
MR. PETERSEN: Mr. Chairman, in all that switch
of witnesses, I lost two questions about evasive action
and distribution.
MR. STEIN: Do you want to ask them now?
MR. PETERSEN: Yes.
MR. STEIN: Address them to whom?
MR. PETERSEN: Whoever Dr. Barber thinks is
the right party.
MR. STEIN: Go right ahead.
MR. PETERSEN: One is: Just what evasive action
can a whitefish larva take, and what action can a juvenile
take? What is their swim speed, and on what do they base
their theories of distribution of whitefish in Lake Michigan
today?
MR. BARBER: Which of you two gentlemen back
there can respond to this one best, please?
Dr. Colby will respond. I suspect he may have
to ask for a repeat on the latter part of that
question.
MR. STEIN: Why don't you try answering it and
-------
1354
P. J. Colby
see how much you can cover. Go ahead, Dr.'Colby. Did
you hear the question?
DR. COLBY: No.
MR. STEIN: We will try one at a time.
MR. PETERSEN: What evasive action can a
whitefish larva take?
DR. COLBY: Whitefish larvae are semi-planktonic
in the sense that they do move with the current but they
can swim. For instance, they can swim, and they are not
totally dependent on the current. So they can swim away,
but they are drifting as they swim. Do you understand what
I mean?
MR. PETERSEN: Yes, I think I do.
DR. COLBY: Their swimming speed is 2 to 3
centimeters per second from the literature, if that will
help you.
MR. PETERSEN: Now, the same question for the
whitefish juvenile I think juvenile is the term you used.
DR. COLBY: Larvae?
MR. PETERSEN: No, after it is a larva, after
it climbs the swim ladder it is no longer a juvenile or
is no longer a larva, it is something else, is it not?
DR. COLBY: Well, this is a nebulous thing,
calling a fish from a larva to a juvenile. I am talking
-------
1355
P. J. Colby
about sac fry larvae. This is before they absorb the yolk
sac.
MR. PETERSEN: How long does that take?
DR. COLBY: That depends on the temperature
and you would have to give me a temperature. It varies
with temperature.
MR. PETERSEN: Well, let's say average in Lake
Michigan waters. I am sorry, I forgot, you haven't
done your research on Lake Michigan water.
Well, Lake Ontario waters, was it?
DR. COLBY: No, it doesn't make any difference
if it is Lake Michigan or Lake Ontario waters, it
depends on the water temperature when they hatch.
MR. PETERSEN: I am trying to get if I explain
this perhaps you can answer it better. I am trying to
get a feel for how long the whitefish larvae are in
relatively vulnerable position* I take it you are saying,
with the yolk sac attached, during this period of hatching,
which as I understand it goes from somewhere in April
through May, from the testimony I heard here today
DR. COLBY: Just a second, Tom, is it about
three weeks to a month before the yolk sac is absorbed in
the lake? I would have to check the record, but I would
say three weeks at least.
-------
1356
P. J. Colby
MR. PETERSEN: When is the predominant hatch
in Lake Michigan, do you know?
DR. COLBY: No, I don't.
MR. PETERSEN: About what time?
DR. COLBY: In April and May early May. The
University I would have to call on the University of
Wisconsin studies conducted by Walter Hogman, He has
studied fish in the northern Green Bay area.
MR. PETERSEN: He wasn't the one who made the
whitefish conclusions for the whitefish paper, was he?
MR. STEIN: That really is the "white paper,"
isn't it?
DR. COLBY: No, he isn't.
MR. PETERSEN: What is the sustained swim speed
and darting speed for the juveniles?
DR. COLBY: I don't know.
MR. PETERSEN: Upon what does your Department
or I should say the authors of the paper base their theories
of distribution of whitefish at present in Lake Michgian?
DR. COLBY: We base it on studies by Walter
Hogman, He is looking at them in Lake Michigan.
If there are whitefish in the Saugatuck area and
they are reproducing there, then there are larvae there,
-------
1357
P. J. Colby
but we have not made a survey of the spawning grounds on
the distribution of whitefish or cisco larva in Lake
Michigan, and I am making we are assuming we are
making an assumption here. It is our opinion, from
studies on Lake Ontario and Lake Huron, that they occupy
the same areas in Lake Michigan the same type of areas
as they do in the other Great Lakes, and that is what
I am basing it on.
MR. PETERSEN: Is this the same kind of
assumption that one of your colleagues called witchcraft a
little while ago, or is this on a different basis? I am
asking because I am not just sure when mathematical models
and when projections of data are in this regard.
DR. COLBY: No, I don't believe this is witch-
craft. This is my opinion.
MR. PETERSEN: No further questions. Thank you.
MR. STEIN: Are there
MR. FETTEROLF: Dr. Colby, it was mentioned by
Tom Edsall that larvae fish would die of air emboli.
Has this been observed as the cause of death?
DR. COLBY: Yes, from laboratory studies.
MR. FETTEROLF: But not in heated plumes or not
in plumes?
DR. COLBY: No, not to my knowledge.
-------
13 53
K. R. Roberts
MR. STEIN: Any further comments?
Let me ask you one question, Dr. Colby,
and this is meant to really clear things up. I am somewhat
familiar, against my will I must admit, with mathematical
models. But would you consider studies which have been
done in the field, say, in other Great Lakes, and then you
extrapolate those field results to conditions which you
must expect in Lake Michigan to be a mathematical model
approach to things?
MR. PETERSEN: Mr. Stein, may the record show a
very significant pause.
DR. COLBY: I don't believe I can answer that.
MR. STEIN: All right.
Are there any other questions or comments? If
not, thank you.
Mr. Barber;
MR. BARBER: At this time, we will ask Mr.
Roberts to read the statement on botulism.
STATEMENT OF KENNETH R. ROBERTS,
RESOURCE MANAGEMENT OFFICER, BUREAU OF COMMERCIAL
FISHERIES, ARLINGTON, VIRGINIA
MR. ROBERTS: My name is Kenneth R. Roberts.
I am presently Resource Management Officer with the Bureau
of Commercial Fisheries, Arlington, Virginia. I have a
Bachelor of Science degree in fishery biology from Michigan
-------
1359
K. R. Roberts
State University, my Master's degree is in fishery science
from Michigan State University and I have 10 years of
experience as a practicing fishery biologist.
It has been indicated that we would have a
statement from Dr. Graikoski, who is a microbiologist in
our Commercial Fisheries Laboratory, Ann Arbor. However,
in reviewing the information which I got from him by
telephone this morning, I find that there are a number of
typographical errors that make it such that I hesitate to
advance this as a statement on his part. I believe, for
the purposes here, if it would be desirable, I would be
glad to express his thoughts.
MR. STEIN: Why don't you go ahead and, with those
reservations, put this in later. Anything you might give
would be pertinent and add to the consideration of the
conferees. (Dr. Graikoski's statement follows.)
MR. ROBERTS: All right, sir.
The question that was originally broached, I think,
evolved around our mention on Page 74 of the "white paper"
about morality of water birds, and in this we referred
to multiplication of bacteria being encouraged by increasing
summer lake temperatures.
One organism which is of concern is Clostridium
botulinum type E, which is a bacteria, which is found in
fish-eating birds on Lake Michigan and have caused human
-------
1359a
ADDRESS ONLY THE DIRECTOR,
BUREAU OF SPORT FISHERIES
UNITED STATES
DEPARTMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
BUREAU OF SPORT FISHERIES AND WILDLIFE
WASHINGTON, D.C. 20240
JAN 1 8 1971
Mr. Murray Stein
Assistant Commissioner -
Enforcement and Standards Compliance
Environmental Protection Agency
Water Quality Office
Washington, D.C. 202U2
Dear Mr. Stein:
During the evening testimony of September 30, 1970 at
the Lake Michigan Pollution Enforcement Conference, the
topic of waste thermal effects on Clostridium botulinum
type E was discussed. The National Marine Fisheries
Service (the Bureau of Commercial Fisheries) specialist
on botulism, Dr. John T. Graikoski, had returned to
Ann Arbor and was unable to testify at that session.
Since then, Dr. Graikoski has prepared a brief statement,
and for the benefit and clarification of the record we
would like it included in the conference proceedings. A
copy of the statement is enclosed.
Sincerely yours,
'>, U.- C <
Paul E. Thompson v'
Acting Assistant Director
Research
Enclosure
-------
Dr. John T. Graikoski
Microbiologist, National Marine Fisheries Service
Ann Arbor/ Michigan
October 13, 1970
As a way of background, I have been studying botulism for the past 20 years,
most recently Clostridium botulinum type E in the Great Lakes.
As a consequence of the botulism incident of 1963, due to type E, which
focused the problem to the Great Lakes Region, our laboratory initiated a program
of botulism researchone objective being to assess the degree of contamination by
toxin producing anaerobes in the Great Lakes. In addition to these studies, attempts
were made to locate possible reservoirs of the organisms and preformed toxin in the
environment. Not only fish, but various other elements of the ecosystem were anal-
yzed for the presence of the organisms and toxin.
The results of these studies have shown that type E is quite prevalent in the
various samples examined; and, in many cases, the incidence was high. In addition,
the Incidence of the organisms was found to vary between the Great Lakes and even
in areas of the same lake. For example, the incidence is high in Green Bay and
around the mouth of certain rivers on Lake Michigan; whereas, in open lake waters
and in Traverse Bay the incidence is low. The overall incidence has not changed
significantly over the past several years we have studied the problem.
In part, the higher incidence of the organisms observed in certain areas can
be related to the water temperatures. In areas where there is a high incidence of the
-------
organism, the water temperature increases in late spring and remains at this elevated
temperature to early fall.
Growth and toxin formation by type E is a function of both temperature and
time, provided adequate substrates are available. Therefore, water areas at elevated
temperatures are conducive for the proliferation of the organisms. A detailed study
of one area on Saginaw Bay during the summer months demonstrated the increase in
incidence, as well as toxin appearance in fish as the summer progressed.
Clostridium botulinum type E is peculiar, in that it can grow at 4°C (39°F)
- although slowly. Therefore, in reference to type E growth, attention must be given
to the temperature range under consideration. At sub-optimal temperatures (4°-20°C),
a slight increase in temperature can cause significant growth^ whereas, in the optimal
range (20°-30°C), a slight change in the ambient temperature will not reflect signi-
ficant changes in growth.
Although consideration has been given to the incidence of C. botulinum type
E in Lake Michigan, the incidence of other pathogenic bacteria has not been studied
heretofore in these waters to any great extent.
-------
1360
K. R. Roberts
mortalities. Although this organism readily grows at low
temperatures it has optimum range of about 6B to #6 degrees
Fahrenheit. Since it becomes most common in areas of high
localized temperatures, any increase in temperature within
this range will stimulate both multiplication of the organism
and production of its toxin.
That is essentially our statement and text.
MR, STEIN: Are there any comments or questions?
Yes, come on up.
MR. HIPKE: My name is Jack Hipke, with Wisconsin
Power and Light.
As I understand, the Clostridium botulinum
bacteria is anaerobic which means without air, I am sure you
know, and, as such, being in plumes I would think that they
would be of less magnitude than they would in any other type
of circumstance. If they should be in this plume at the
time, and with slightly increased temperatures, I would
think that bacteria that are aerobic would take the place
of this anaerobic type bacteria, so I was just wondering
if you could comment as to the possibility of replacement
of the botulinum bacteria by other bacteria and possibly
elimination rather than growth.
MR. ROBERTS: Okay. First of all, I am not
qualified to respond to a question on the mechanism of
the botulinum proliferation in Lake Michigan, but I will
-------
1361
K. R. Roberts
forward to you what Dr. Graikoski did tell me this
morning.
Dr. Graikojski has been studying botulinum
for the past 20 years, and most recently he has been
focusing his attention on the botulinum type E. This
effort began as a result of the botulism incident of
1963 which was due to type E, and focused the problem
on the Great Lakes region.
MR. STEIN: What was that, smoked fish?
MR. ROBERTS: Yes.
MR. STEIN: Right. Go ahead.
MR. ROBERTS: At that time, this area of research
began. One objective was to determine the degree of
contamination by toxin-producing anaerobes in the Great
Lakes and in known possible reservoirs of the organisms
and resultantly formed toxin in the environment. Not
only whitefish but other various elements of the eco-
system were analyzed for the presence of the organisms.
The results of the studies have shown that type
E is quite prevalent in the various samcle? that have been
examined, and in some cases the incidence is quite high.
The incidence of the organism has been found to vary between
the Great Lakes and even in areas of the same lake. For
example, the incidence is high in Green Bay and at the
-------
1362
K. R. Roberts
mouth of certain rivers on Lake Michigan. In Traverse
Bay, the overall incidence has not changed significantly
over the past several years.
In part, the higher temperature of the organisms
observed in certain areas can be related to temperatures of
the water, and in areas where we have shown a high incidence
of the organism, the water temperature is high and usually
becomes so early in the summer. Growth and toxic formation
is a function of both time and temperature. Therefore,
warmed areas are conducive to the proliferation of the
organism. A detailed study of one area on Saginaw Bay
shows this to be the case. The results of that study can
be made available.
MR. STEIN: Are there any other comments or
questions?
MR. PETERSEN: Thank you for your prolonged
courtesy.
As I understand it, these comments are not yours
but of another individual not present, and they are the
results of your studies.
MR. ROBERTS: Yes.
MR. PETERSEN: Perhaps you can answer one or
two questions. I won't propose to ask you full details on
his studies other than to ask you: Do you know if studies
-------
1363
K. R. Roberts
were made in plume waters to ascertain the effect in plume
waters?
MR. ROBERTS: I do not know that. I don't
believe that they were.
MR. PETERSEN: Now, are these bacteria which
multiply in the water itself, or do they multiply in the
bodies of hosts, fish, or crustaceans, or something of
that nature?
MR. ROBERTS: I am not qualified to answer that.
MR. PETERSEN: Thank you very much.
MR. ROBERTS: What I am saying is: I am not really
qualified to discuss this mechanism with you.
MR. PETERSEN: What I am trying to ascertain
is if we are trying to find out what happened to certain
bacteria which happen, to be present in the water and passe
through the plume and are subject to the rapid warming and
reasonably rapid cooling, and possible, therefore,
deleterious effect on their reproductive mechanisms for a
short period of time, or if we are talking about a
mechanism which is free in a fish which itself is warmed
by placing itself in the plume.
MR. STEIN: Do you want to answer that?
MR. ROBERTS: I was going to say, from this
statement, we have said that the incidence in the surface
-------
1364
K. R. Roberts
waters is higher in some places than others, and we have
indicated the temperature is a governing factor a
limiting factor. When this was presented to Dr. Graikoski
it was with the assumption that significant areas of
inshore waters could be warmed artificially.
MR, PETERSEN: I haven't any answers now, and
I will have to say it was my understanding that fish take
their temperature from the surrounding environment of the
water and, therefore, it wasn't clear from your statement
as to what was meant. If you say it was in the water itself,
fine. I can't ask you further questions because you aren't
an expert in that particular field.
MR. ROBERTS: That is true.
MR, STEIN: As I understand the point that was
made, it was that there was general relationship of a
higher incidence of botulism in warmer waters than there
was in colder waters. Just given the same waters, and
presumably without drawing any relationship, anything that
was warmed significantly, which would warm a large area or
significant area of relatively shallower waters in Lake
Michigan, might be said to plot conditions which would
cause a faster growth of botulism. This is the way I
understand. Mow, I am not trying to argue about the
validity of the statement or answer any questions. This
-------
1365
K. R. Roberts
is the way that I understand the thrust of the comments
on this.
MR. PETERSEN: Thank you, and I was trying to
determine whether there was a difference between just
plain warmer water or the dynamics of a plume.
MR. STEIN: Correct.
MR. PETTEROLF: Mr. Stein, when I read the
paragraph on mortality of water birds, the part about the
Clostridium botulinum type E, I called a bacteriologist
associated with the Michigan Department of Natural
Resources at their Rose Lake Wildlife Station. I found
that he disagreed with the statement of Dr. Graikaski.
And I am not going to present any questions on this*. But I
think if the conferees are to attach an importance to this
statement, then they should hear from other bacteriologists.
such as Dr. Lee mentioned yesterday, or other specialists
in botulism that are available.
MR. STEIN: Any comments?
MR. PETERSEN: Mr. Chairman, a young lady has
come in -- I don't know who she is she is a
microbiologist and has had some experience in this field.
Perhaps I don't know whether you would want to hear from
her or not, but she
MR. STEIN: Not now. I have got some time after
-------
1366
Y. M. Barber
midnight, but it won't be here. We appreciate it.
Are there any other statements or comments or
questions? If not, thank you.
Mr. Barber.
MR. BARBER: Thank you, Mr. Chairman. We would
be glad to file a clarification on this question of Botulism
which has been raised. I am sorry we couldn't respond more
positively. We had the man here Monday, but unfortunately
he was not able to return today.
MR. STEIN: Well, we have had several of the
experts who haven't been subject to questioning. I think
in the informal proceeding we shouldn't discount the state-
ment just because the man was not here, because if we
extended that rule, there would be quite a few. Notably
Dr. Pritchard
MR. FETTEROLF: Tes, the reason for my questioning
the statement is that the time of migration of birds on
Lake Michigan loons and grebes this is in the fall
when the temperatures have started dropping, and it is this
time that the outbreaks of botulinum in water birds are
most pronounced on Lake Michigan.
MR. STEIN: Are there any other comments or
questions? If not, Mr. Barber, go ahead.
MR. BARBER: I would like, now, to introduce
Dr. Charles Powers of the National Eutrophication Laboratory,
-------
1367
C. Powers
Corvallis, Oregon, with the Federal Water Quality
Administration.
STATEMENT OF CHARLES POWERS, NATIONAL EUTROPHICATION
LABORATORY, FWQA, U. S. DEPARTMENT OF THE INTERIOR,
CORVALLIS, OREGON
DR. POWERS: Mr. Chairman, my name is Charles
Powers, and I am with the National Butrophication Research
Program of the Federal Water Quality Administration in
Corvallis, Oregon.
By way of background, I have a Bachelor's degree
in zoology from the University of North Carolina, and a
Ph.D. degree from Cornell University in the field of
limnology and oceanography. And prior to my association with
the National Eutrophication Research Program, a little over
two years ago I was with the University of Michigan, Great
Lakes Research Division, and in that respect had the
opportunity to carry out research on the Great Lakes.
What I have to say here is a brief statement, and
it is in the nature of what I would like to think might be
a clarification with respect to some of our thoughts in
the relationship of eutrophication to thermal pollution,
I think there is a little disagreement, maybe
confusion, or what-have-you, with respect to precisely what
we mean by eutrophication. I think it has gotten to be
a little bit of a household word and it means different
-------
1363
C. Powers
things to different people. I think in the strictest
sense, eutrophication refers to the increase in
concentration of dissolved nutrients within the water of a
lake. These would be such nutrients as nitrogen,
phosphorus, and other things which are essential to the
growth of algae and other plants. This in itself, then, is
eutrophication, and then the things such as increased algal
growth, which in an advanced case of eutrophication tends to
run into the more undesirable nuisance species of algae
this is one of the common symptoms of eutrophication, so
that there are many symptoms which this state of being
enriched with nutrients displays large concentrations
of algae, possibly depletion of oxygen in the deep waters
I am referring now to experience with small lakes, and so
forth.
In lakes in which nutrient concentrations are
low, the phytoplankton seems to be mostly composed of
diatoms, and as nutrient levels increase, as they wash into
the lake, from the watershed, or if they are put into sources
of domestic and other types of pollution so as nutrient
levels increase by whatever mechanisms they get in there,
you find that algal growth known as the green algae and
the blue-green algae tend to greatly increase in numbers
in the lake.
-------
1369
C. Powers
In lakes where nutrient levels are high,
such as in Lake Erie, for example, a condition is attained
in which the first algae to appear in the spring are mostly
diatoms, such as one finds in a lake where the nutrients
are low, and these are eventually as the season
progresses, these diatoms are replaced at least in terms
of the dominant kinds present they will be replaced by
the green algae. This doesn't mean to say that some
diatoms aren 't there, but there will be more greens
than anything else. And as the season progresses and we get
into the summer, those greens will in turn be succeeded by
the blue-greens which will become dominant. The blue-greens
are the biggest nuisancetype of algae. These are the ones
which tend to form mats, and they decay later in the season
and may give rise to noxious odors.
In lakes of low nutrient level, this progression,
this succession, I should say, of forms through the season
doesn't appear to occur, and in lakes of low nutrient levels
the diatoms are the dominant algae the year round.
Now, two researchers at the University of
Michigan, Dr. Schelske and Stoermer, have recently reported
at a meeting of the American Society of Limnology and
Oceanography that the plankton diatoms comprise less than
10 percent of the phytoplankton in samples from the southern
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C. Powers
part of Lake Michigan collected there in 1969. This is
unusual since in previous years they had found that the
dominant forms were diatoms. In 1969, they said less than
10 percent were diatoms. To quote them they stated in an
abstract of their paper they say: "'The evidence
compared with data from Lake Erie and Lake Superior suggests
that acclerated eutrophication in Lake Michigan is rapidly
approaching the point of a severe environmental change
in which the diatom flora will be reduced or replaced by
green and blue-green algae."
What data we have available and most of this,
I think, are probably the data which were collected by the
Public Health Service in the early to mid-60fs and a lot
of these data are reproduced in the "white paper" I
believe that is where those data came from/. But they
have available data to indicate that levels of nutrients,
and particularly phosphorus,are higher in the near shore
waters of Lake Michigan than in the open lakes. I will not
attempt to define here just what we mean by near shore and
open lake. I am not really referring to a 30-foot depth
or a 100-foot depth, but near shore in a rather loose
fashion.
As Dr. Lee pointed out yesterday and he is
quite right we are not sure at all of the extent of
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C. Powers
temperature effect in stimulating the appearance and growth
of blue-green algae. We do have this inferential evidence
that I cited a moment ago where, as the season progresses
in lakes which have high nutrient levels, we do find that
the blue-greens become dominant during the warmest part of
the year. We are not sure that it is strictly a
temperature effect, &ut many limnologists, and I would
mention, such as Dr. Ruth Patrick of the Philadelphia
Academy of Natural Science she has a good deal of
experience in the studies of temperature effects on algae
and I feel that she believes that the correlation between
the occurrence of blue-greens and the warm summer
temperatures is a demonstration of the cause-and-effect
relationship. We could point to some things she has said
which indicate she thinks this may be the case.
In addition, Dr. Stoermer has said in another
paper Lake Michigan is near what he calls a breaking point
where a change to a nuisance eutrophic form would be
indicated. It would seem, then, that with respect to the
warming up of the coastal waters of the lakes, one should
exercise extreme care in introducing or reinforcing
warm water or other environmental factors which might help
in effecting or bringing about such an unwanted change.
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C. Powers
The evidence which Dr. Ayers presented yesterday
and he also cited Joseph Mihursky indicated that
there is not any stimulation of algal growth through
algal cells being passed through the condensers, and if
anything there is a destruction of the diatoms and other
phytoplankton which mitigate against a stimulation of algal
growth. But I think we need not rely upon the algal cells
actually passing through the plant. But rather, then, I
think we should think in terms if there is a general
inshore warming, such as has been debated here this
afternoon, by effluents, then one might find a situation
which, in conjunction with increased concentrations of
nutrients occurring in the inshore waters, might result
in a stimulated growth of bluegreen algae. If the waters
were artificially warmed, the period during which the
bluegreens would dominate might be extended.
That is what I have to say about that. Thank
you.
I wanted also to point out that I have found two
references in which Mr. Petersen might be interested. Are
you here, sir?
You were discussing with Mr, Carr the thermal
bar, and I have here a publication. I will show you this.
There are two references in this publication dealing
with studies of the thermal bar in Lake Michigan. One,
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C. Powers
the physical aspect of it; and another, some studies of
the plankton. I think it was the phytoplankton and how
they occurred on the two sides of the bar. So if you are
interested in that
Also, Mr. Currie, did you ask Mr. Carr something
to the effect that was there an example of a study where
an entire lake had been J.sated, and if this had any
effect on the production It seemed to me you had a
question something like that, and I had a little thing
here that might help you.
MR. CURRIE: It wasn't about the entire lake,
it was a question of whether there were any studies of
comparable discharges to comparable waters comparable,
that is, to those that we are discussing on Lake Michigan
which would show adverse effects on algal populations.
DR. POWERS: Right, and I think the answer would
be no to that. I believe that is what Mr. Carr said
also. In here the only thing I have been able to find
was this Polish lake three Polish lakes actually
where they point out that the richest phytoplankton flora
occurred in the warm lake.and also they said productivity
rates of the algae were higher than this. But the
evidence given here is certainly not conclusive and I would
not cite this as conclusive evidence. What I have here is
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C. Powers
only a citation of a Polish work cited by an American author,
He gives nothing on nutrient levels, and so forth, and
",
so one would have to go to the original reference to really
decide whether anything conclusive was there, I think.
Thank you.
MR. STEIN: Thank you, Mr. Powers.
Are there any questions?
MR. PETERSEN: Making the assumptions for water
heating of inshore or beach waters which I don't think you
and I care to debate, Dr. Powers, as I understand your
testimony, the possibility of advanced eutrophication
as shown by proliferation of bluegreens depends largely on
the nutrients present and the area in which the bluejfreen
count was high or at least diatom count was so low was
around the Gary-Chicago area as opposed to, let us say,
the Muskegan area or the Grand Haven area of Lake Michigan.
DR. POWERS: Referring to the 1969 samples?
MR. PETERSEN: Yes.
DR. POWERS: I asked Dr. Stoermer about this and
he indicated that he had felt that rather generally over
the southern basin of the lake,. This was as specific as
he could be at the time, because he did not have the data,
But he said that formerly he had found them only in the
Gary-Chicago region. In 1969, he had found the blue-greens
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1375
C. Powers
I don't mean in bloom concentrations but in quantities
exceeding anything he had seen bef oret generally through
the southern basin which would be say up as far as
Muskegan, or something like this.
MR. PETERSEN: Do you have any data as to the
relative availability of nutrients in the various areas, or
is the availability uniform throughout in the southern basin?
DR. POWERS: I think probably the availability
would be greater in the eastern side of the southern basin
because- it is there that the four largest tributaries
of the southern basin enter the lake. This would be the
Muskegan River, the Grand River, the Kalamazoo River, and
the St. Joseph River. These are the four principal rivers,
and then as one proceeds past Gary and Chicago there are no
more rivers of any consequence entering the lake until you
get to Milwaukee. On this basis and the fact that the
Chicago sewage effluents are not put into the lake, but
are diverted to the Illinois River, I would think that the
eastern side of the southern basin might have a larger
influence than the rest of the basin.
MR. PETERSEN: Is this on the basis of
observation or just your general ideas of what probably
would be
DR. POWERS: I have seen data and I am sure
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1376
C. Powers
I could not quote any of it but I have seen data on
nutrient levels for those rivers mentioned and they do
run quite high in nitrogen, phosphorus, and other dissolved
materials.
MR. PETERSEN: What I am trying to get at in
part here is: Are you telling us, or I should say, are
you telling the conferees that plant siting, as to
eutrophication as shown by accumulations of blue-greens,
is an important thing?
DR. POWERS: I don't know that there has been
enough accumulation of blue-greens on that east side, for
instance, to merit a statement like that. I think I would
say that with respect to if we are talking about the
east side of the southern basin versus the west, for
instance, that this is the side of the lake on which one
would be more likely to get the blue-green flora if this
were heated to some degree, which the blue-greens found
favorable. It might prolong it might make earlier in the
year the time that they become abundant and it might
prolong their bloom, and I say bloom because I have already
stated I really agree with Dr. Lee, because we really
cannot prove this.
MR. PETERSEN: No further questions.
"MR. STEIN: Thank you very much, Dr. Powers.
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1377
C. Powers
I am sorry it was so late that we got to you that we didn't
have a larger captive audience so you could have given
them the primer lecture on eutrophication. Next time we
will try to do better.
MR, HIPKE: Just more or less in accumulation of
data in Lake Erie, for instance, the greatest accumulation
of bluegreen algae is located in the center where there
is no heat discharge from generating plants, and you stated
that the eutrophication process is primarily due to
nutrition. So I would say that if this was the case,
wouldn't you think that it was primarily due to nutrition
and also photosynthesis due to the sunlight? And so, if
this is the case in the shallow waters on the shore, wouldn't
you find the more concentrated the nutrients the higher
the accumulation of algae, rather than the heat that is
supplied to the area?
DR, POWERS: There is one thing you said you
say, "...the greatest concentration of bluegreen algae is
located in the center "of the lake, did you say?
MR. HIPKE: Lake Erie, right.
DR. POWERS: This I really wasn't aware of. This
may be true.
MR. HIPKE: I have seen some rather large concentra-
tions of these in the western basin, for instance, w&ich is -
DR. POWERS: By the center you mean the geographical
center of the whole lake?
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C. Powers
MR. HIPKE: Approximately, yes. There is
algal matter there. I can't remember exactly what the
size is, but it is definitely in the center of the lake
where we don't have any generating plants.
DR. POWERS: I would say there might have been
some, on one occasion, but I don't think it is necessarily
there all of the time. The last time I was down there
and that has been possibly four years there were no
mats there at all, but I saw mats in the western basin of
the lake. These mats also move around you know. They will
move by the wind and this is sometimes why they seem to
accumulate overnight, because we have had a bloom and then
there will be a movement of these things with the winds.
MR. HIPKE: Well, since you do find a large
accumulation during the summer months, and since the
sun time is that much greater, wouldn't you think that
it would probably be due to photosynthesis and not
nutrients? I think the heat factor there doesn 't really
play a part in it.
DR. POWERS: The nutrients of course, we
never seem to get this unless we get a lake in which the
nutrients are high phosphorus, 150 micrograms per liter
or more because photosynthesis is a process by which
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1379
R. Callaway
these things multiply themselves.
As I say, there does seem to be a temperature
effect. I said that I thought it was a difficult thing
to prove.
I had a point and I talked myself right out of
it. I am sorry.
MR. HIPKE: Thank you.
DR. POWERS: I am sorry, sir, thank you.
MR. BARBER: Thank you, Dr. Powers. We would
like to call next Mr. Richard Callaway. He advices me
that I have been putting him with the wrong laboratory, so
I am glad he called it to my attention. He is with the
National Coastal Pollution Research Program at the
Corvallis Laboratory of the Federal Water Quality Administration
MR. CALLAWAY: My name is Richard J. Callaway.
I am chief of the Physical Oceanography Branch, National'
Coastal Pollution Research Program.
I have a B.S. and M.S. in physical
oceanography from the University of Washington and from
Oregon State University, respectively. I have been an
oceanographer for the Fish and Wildlife Service, Public
Health Service, and Federal Water Quality Administration
since 1956. I am a member of the AAAS, American Geophysical
Union, American Society of Limnology and Oceanography,
\
\
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1330
R. Callaway
American Meteorological Society.
My present interests are in computer simulation
through numerical methods in estuarine and coastal waters.
My comments are restricted to Dr. PritchardTs
paper. I do not argue fundamentally with Dr. PiiitschardTs
explanation that the lake is merely a temporary storer
of heat; however, it should be borne in mind that
Dr. Pritchard's approach seems to be a highly simplified
model of the environment.
I know that Dr. Pratichard is well aware of this
difficulty because he is also consultant to us at the
Corvallis Laboratory of the National Coastal Pollution
Research Program on the state of the art of mathematical
modeling in estuaries and has devoted considerable portions
of his effort to this aspect.
One of the difficulties in dealing with the
output generated by someone else's mathematical models is
devining what the model actually consists of. It is not
sufficient to describe the model in words; the equations
and the boundary conditions and assumptions must be clearly
indicated. It would have been helpful if the accompanying
mathematics had been presented as an appendix. Without a
full treatment of the methods of solution, no real
evaluation of his tables and figures is possible. This is
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13S1
R. Callaway
referring to the paper yesterday. As one indication of
the completeness of his model some investigators have
recently found an hydraulic zone in addition to the three
discussed by Dr. Pritchard. This additional zone consists
of our internal hydraulic jump at the discontinuity layer
which can result in submergence of the outfall. This
report was developed by Drs. Koh and Fan of Tetra-Tech,
Pasadena, California, and is in the process of being
published.
In essence, Dr. PritchardTs report gives
considerable information on the input and output data but
virtually nothing on the black box in between. Personally
I am quite satisfied with simply looking at a TV show
without trying to figure out how the input signal is
transformed into the TV image. I don't think this should
be the case here with regard to Dr. Pritchard's output
which in this case is in terms of areas, etc.
It was also indicated by Dr. Raney that model
experiments were conducted by Pritchard at the C of E
Vickburg station. These results should also be made
available for this new design.
I have used many numerical models of estuaries
and river systems and have found that it is sometimes
quite easy to generate results that couldn't possibly
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1332
R. Callaway
occur in nature. This can be done either by making bad
assumptions or running a program with a bug in it or using
incorrect input data. In this regard it is also sometimes
quite easy to obtain a suitable comparison of model and
prototype results by gradually tuning the input coefficients
to fit the data. Such results are useful but not always
extrapolatable. So even though Dr. Pritchard maintains
on Page 13 that he has made "... use of the most recent
knowledge of momentary jet entrainment, etc. ..." it does
not follow that models or our knowledge of the physics
are all that well developed. I might add especially with
the jet entrainment situation.
In summary, it would have been useful if
additional runs had been made assuming shallower depths
of the mixed layer, by presenting the analytical or
numerical methods used in generating the isotherms and
residence times, and by supplying the computer code.
It may well be that Dr. Pritchard!s model is
the most advanced of the many models that have been
developed on this and related problems. Without an
indication of the fine points,however, the results
presented have to be taken simply on faith.
These additional questions should be asked:
1) What boundary conditions were used in the
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R. Callaway
model?
2) Is Case IV a verified model?
3) Is a steady-state approximation 'useful in
Lake Michigan?
4) Wouldn't a three-dimensional model be more
realistic so that the analysis should also be jcarried out
in the vertical?
5) If the depth of mixing is determined by
the Monin-Obukhov length why should the assumption of a
constant mixed layer depth be accepted here?
6) At the high ejection speed of the mo'del
couldn't rather unexpected circulation patterns arise,
including zones of erosion and deposition? Thus, the
simplified isotherm configuration given might not have any
resemblance to reality.
Additional questions will arise with the
availability of the mathematical and hydraulic model
results.
MR. STEIN: Thank you, Mr. Callaway. Any
comments or questions?
MR. CURRIE: I have one.
Your reservations as to Dr. Pritchard's results,
I take it, then, go not only to his isotherm but also to
his estimates of residence time, is that right?
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1334
Y. M. Barber
MR. CALLAWAY: Yes, sir.
MR. CURRIE: Thank you.
MR. STEIN: Are there any other comments or
questions?
Thank you very much.
Mr. Callaway, let me ask you something on this.
I believe the problem or possibly ~,he differences with
these mathematical models is similar to some of these
5-year projected plans. That is, in changing the
assumptions, where you move on them, you may or may not
get certain desired results, and we are in the hands of
the model maker. Now, you can shift these back and forth,
but we never know whether we are certain as to what
we are saying.
MR. CALLAWAY: I don't like to criticize models
because I build them, but I think they can be misused more
easily than well used. Did I answer the question?
MR. STEIN: Yes, that is what that model from
Bergdorf-Goodman told me.
Any questions? Thank you very much.
Mr. Barber?
MR. BARBER: Well, we are approaching the end,
I think, of our presentation.
I would like to make some summary comments
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1385
I. M. Barber
relative to the portion of the "white paper" dealing with
physical and ecological effects. After I have completed
my comments, I will turn the mike over to Dr. Bruce Tichenor,
who will comment on the cooling-feasibility report.
I would like to bring some attention now to some
of the aspects of Dr. Pritchard's paper, and I think they
are applicable to some of the other papers that have been
presented here the last 3 days. I think we have all been
wonderfully impressed with the quality of the scientists
that have been employed to represent the power industry.
I am quite certain of the thorough scientific qualifications
of many of them from their national reputations. They
also write very carefully, which is a pretty good indicator
as well.
What I am referring here to is that we take
Dr. Pritchard's paper and analyze it. I don't think
that he has really brought us very much evidence at all.
As Mr. Callaway has pointed out, he has an unverified
model, which he is promoting, the validity of which can
well be debated by other, as I call them, model mechanics.
If I may, I will just refer you to Page 26 of
Dr. Pritchard's paper. I think I can raise my questions
better that way than any other way. You will note there
under some final comments that he reports as did Dr. Raney
that he has investigated the circumstances associated with
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1336
I. M, Barber
all mass mortalities of aquatic organisms reported in the past
5 years as having been caused by thermal shock. He doesn't
tell us whether there are a hundred or one. He doesn't
tell us where they were. He does not describe any of
the circumstances involving them. He doesn't say what
was killed^ or who. and how the determination was made as
to what caused the death. I do not doubt that he has
investigated all of these things probably in a
scientific fashion, but I am compelled to believe that if
there was a great deal of evidence that he would have
offered us some of it.
He makes an assertion that these have been killed
by being caught in the intakes and trapped, I believe,
against screens. I am not reading this word for word. The
mike gets in the way of my reading. But I don't know how
he made this determination. He has no indication of
having autopsied any of these fish or other things.
Now, I am very glad that he did indicate this
death factor in the intakes, because the Fish and Wildlife
Service has been recognizing this problem for many, many
years and recommending to the various power companies
and others who build big water intakes that these be
modified and screened so as to provide protection to the
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13S7
T. M. Barber
organisms that are caught therein4
I think we might have to question what I
consider a rather glib assumption, that we will just
modify the intakes and take care of all of these problems.
Perhaps we will take care of adult fish, but I am not
aware of any existing technology that makes it possible
to screen out the very smallest larval fish, fish eggs,
and all of the plankton. All of these organisms make up
the balanced biota of a large body of water anywhere,
especially Lake Michigan.
I will call your attention to the fact that
Dr. Ayers did identify yesterday that there is significant
damage to plankton forms, which do go through these intakes.
Dr. Pritchard states that, "On the basis of my experience
and my calculations of heat exchange from the surface of
Lake Michigan, I find that the discharge of condenser cooling
water from the powerplants currently proposed for Lake
Michigan will have no measurable effect on the overall lake
temperature." He doesn't really elaborate on this. I
think he would have us believe that if the jet entrainment
method is used that there would be virtually no heat effect
on the lake.
However, insofar as I am aware of the five fairly
large to very large plants, now under construction or
proposed, the concept of the jet intake or exhaust excuse
-------
Y. M. Barber
me the jet discharge,in the sense proposed by Dr.
Pritchard, has not until now been brought to our attention.
This is true of all our studies of those plants which have
reached the construction license stage.
Dr. Pritchard goes on to say, "I do find that
even using the most conservative assumptions, the area
of the thermal plume from a 1000 MWE nuclear power station
having excess temperatures greater than 2 degrees Fahrenheit
would be less than 100 acres, and would have a maximum
linear dimension of less than 1500 yards."
I am not quite sure why we should just accept
this. It strikes me that he is saying," If you use Model
IV as I have proposed" and, of course, as you know, we
have questioned whether this is really valid "that
this is what you will get." But I don't understand what
he means by "the most conservative assumptions," since he
has three models in that table or four, in fact. He
does not refer to any, and it is only Model IV that he
proposes that the plume is down to 100 acres.
Now, ladies and gentlemen, I would like to
suggest that these points should be reviewed very carefully.
I am not implying that this is not a good paper, but I
am implying that we cannot agree with the conclusions.
-------
1339
Y. M. Barber
There is no significant data here which would really tend
to refute the case which we have made in the "white paper."
I believe that if you will look through all of
the other papers presented by the biological consultants
at this conference, you will find one thing that is fairly
common to them they are extremely short in reflecting
Lake Michigan field experience,although there are some
studies which have been performed and there is some
evidence presented.
I merely wish to caution care in reading and
reaching conclusions based upon those papers. In comoarison,
I would point out that our "white paper" has summarized
the bulk of the literature which we had on the lake and
does present a reasonably well-documented case for why
there will be damage to the ecology of Lake Michigan from
these heat discharges.
MR. STEIN: Thank you, Mr. Barber.
Any domments from conferees? Any from the
audience?
If not, thank you very much.
Mr. Tichenor, do I understand you want to say
\
something or not?
DR. TICHENOR: Not really. If there are some
questions that are to be asked, then, I will be glad to
answer them.
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1390
I. M. Barber
MR. STEIN: There are no questions.
By the way, I want to thank you all for staying
with us and the courtesy you have shown in staying with
this procedure so long. I do think this exchange has
been very useful, and we are going to have a reallj useful
document. At least we are framing the issues. A good
portion of the material was brought out late or as we went
on into the evening. I do want to thank the attorneys
who carried the ball for the power companies for asking
these questions and bringing all these points out.
So, at this point, I cannot help but observe
that we would have been much further ahead if, in addition
to questioning the Government witnesses this closely,
we had questioned that closely the witnesses put forth
by the power companies on their papers. We may have been
much closer together. I guess this is the way things go.
We will stand recessed until 9 o'clock tomorrow
in this same room.
(Whereupon, the conference recessed at 9:02
p.m.)
U. S. GOVERNMENT PRINTING OFFICE : 1971 O - 422-409 (Vol. 3)
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